ADDENDUM -Jun 2011
Because I make the effort, I get to see some of the wilder places, distinguished by their lack of evident human management, even to the extent of an absence of tree stumps or cut boughs and blessedly free of the litter of our detritus. They are “rare” in the real sense of the word, but I will never use “precious” to describe them, the other misused word of the conservation industry, because that word too has become devalued by its association with their irrational preferences, the choices of their dogma. Were they to have come with me recently and seen the few patches of May lily in what is regarded by some as the only native location of this woodland lily (Take three woodland wildflowers (1)) would they then describe it as rare and precious considering that inconceivably it is not one of their choices for priority in the UK Biodiversity Action Plan? Since this location is in broadleaved woodland at the edge of a Forestry Commission plantation, would that make any difference to their contemptuous lack of support for England’s Public Forest Estate?
On visiting Scar Close again recently, a colleague expressed the sheer dismay that others could not see the sense of what was happening there, the explosion of wild nature since grazing had been removed decades ago (Walking the wild places (2)). We had a comparison in front of us, the grazed limestone pavement of Southerscales, a “nature reserve” of the Yorkshire Wildlife Trust. What this colleague couldn’t understand, was how the Wildlife Trust could be so blind to the lessons of Scar Close, a place so magically more alive than Southerscales. Our only answer to that was the slavish adherence to dogma, a wilful ignorance in spite of evidence to the contrary.
Inaccessible ledges, gullies and screes
contrast is evident everywhere. A chance to see Spring gentian in bloom in
the Moor House – Upper Teesdale NNR created a dilemma in me, as the
hyperbole about this upland area is dreadful. Just to set the scene before
I pick out what good bits there are - this from the Natural England
House – Upper Teesdale NNR is also part of a larger Special Area of
Conservation (SAC) of the same name, and this is from the data form (4):
upland area, studied to death for its blanket bog, and which raises more
questions than answers in terms of how we artificially maintain
pseudo-Arctic alpine habitats by grazing. It ignores the history of our
uplands that only 2.5% could be considered to have been above a tree-line
in its original natural state (5):
contemporary commentators on the uplands, the hyperbole surrounding the
NNR ignores the evidence that peat formation in blanket bogs is underlain
by Mesolithic and Neolithic human remains, and that the onset of peat
development is particularly clustered around 5,000BP and thus associated
with the onset of human intervention (6):
Of much greater interest to me are the exposures of Whin Sill and gritstones across the NNR that form cliffs and screes in places, and where an acid flora has developed away from the effects of grazing. On the cliffs of the rocky slopes of Falcon Clints, a Whin Sill edge of quartz-dolerite below Whiddy Fell, I saw fern-rich communities, but also woodrush as well as juniper, birch and aspen. The SSSI notification for this area of the NNR says that bearberry and golden rod can also be found in these locations (7), and the monitoring report that covers it says that Falcon Clints should have dwarf birch (8), but frustratingly I did not see any. On the other side of the NNR, on Appleby Fells, tall herb vegetation is said to occur on the ungrazed crags and ledges as well as on some of the steeper, inaccessible screes (9).
As would be expected, blanket bogs, an Annex I habitat under the Habitats Directive, is one of the main habitats that is a primary reason for the selection as a SAC of the larger upland area that includes the NNR (10). The blanket bog takes up half of the area of the SAC and is regarded as “one of the best areas in the United Kingdom” (11). “Siliceous rocky slopes with chasmophytic vegetation” are also an Annex I habitat of the SAC (chasmophytic means growing in rock crevices) the site details for this habitat mentioning the Whin Sill outcrops and their vegetation communities at Falcon Clints. The SAC is also notified for “Hydrophilous tall herb fringe communities of plains and of the montane to alpine levels”, another Annex I habitat. The site details say that these tall herb communities occur on “wet ledges in base-rich rocks, which are inaccessible to grazing livestock” such as at High Cup Nick and Mickle Fell. Typical species include great wood-rush, wood crane’s-bill, water avens, lady’s-mantle, wild angelica and roseroot.
These tall herb communities remind me of the conversation I had with Keith Miller, an ecologist and accomplished climber, about the tall herb vegetation that is found in the inaccessible gullies and ledges around such places as the steep and rugged crags of Pillar above the Ennerdale Valley. At the time, we were dodging rain showers in the valley, while peering through binoculars to survey the small native trees in refuge on the inaccessible ledges below Pillar. The SSSI notification for Pillar and Ennerdale Fell SSSI explains that a lush herb-rich sward has become established in gullies and ledges away from the effects of the grazing sheep that over the centuries have left the surrounding Ennerdale Fell completely degraded. Typical species present in the gullies are great woodrush, water avens, roseroot, lady’s mantle, and golden rod (12). Keith sent me pictures from a gully at Tarn and Falcon Crag on the Helvellyn range in the Lake District that he had roped into and surveyed, and which show astonishing drifts of ferns, wood cranesbill, rose-root, hogweed, lady’s mantle, wild angelica, valerian, devil’s-bit scabious and hawkweed.
Both Pillar and the Helvellyn range are included in the Lake District High Fells SAC, and each receive a mention as locations in the site details under the Annex I habitats of Siliceous rocky slopes and Hydrophilous tall herb fringe communities (13). The habitat Siliceous rocky slopes with chasmophytic vegetation is regarded to be widespread in upland areas of the UK, its total area given as 39,850ha (14) although it covers only 38.8ha or 0.1% of the 38,796ha of the Moor House – Upper Teesdale SAC (11) and 540ha or 2% of the 26,999ha of the Lake District High Fells SAC (15). Hydrophilous tall herb fringe communities are however, regarded to be a very rare habitat, and while its total extent in the UK is said to be difficult to estimate, it is probably around 359ha (16). In the Moor House – Upper Teesdale SAC it is given as 0% (probably indicating that it is <0.1% (11) whereas it is 108ha or 0.4% of the Lake District High Fells SAC (15).
Coastal cliff shelf woodland
I will have to work out some low-anxiety routes to these gullies and ledges and summon up courage if I am to see the fabulous wonder of their wildflowers, but there are relatively inaccessible places that are easier for me to get to, and which have a wildness all of their own. I have written before of Hayburn Wyke, a wooded valley on the N. Yorkshire coast that drops down to the sea, and how the high canopy woodland turns into lower growing trees as it spills around and out along a shelf below the cliff edge (The most natural succession of woodland (17)). I went back recently to explore the woodland on that shelf at Little Cliff, and found a narrow trail leading into it. It took me into an unexpected and hidden world of wildness, its lush ground layer consisting of ferns, woodrush, and dog’s mercury, interspersed with astonishing drifts of wild garlic. This was overtopped by oak, ash, aspen and rowan that was a spindly tracery of wind shaped branches near the shelf edge, but stood taller away from it. The trail was compelling, and I kept expecting it to disappear as it seemed so unused (except for deer), but it continued until the shelf itself petered out and a wooded sheer cliff confronted me.
There is another undercliff woodland on a shelf at Beast Cliff, a couple of miles north of Hayburn Wyke towards Ravenscar. A footpath is shown going down to the woodland from Petard Point and traversing the shelf northward through the woodland and then out onto Common Cliff before coming back up the cliff. I chose to approach the wood the other way around, along Common Cliff, but it proved hard to find the downward path, which turned out to be only somewhat short of a vertical drop at the start. It was even harder to see where the path traversed the plateau before finally reaching the woodland. The woodland itself has a very wild quality, with a lush understorey of ferns and woodrush topped by ash and birch, with pools fringed by alder and willow. So wild was it that the path was hard to find and eventually I gave up trying to walk through it, and instead just admired from the outside how it beautifully clothed the shelf. While I saw roe deer on the plateau, they weren’t doing a very good job of keeping this path open. I will try again sometime to walk the woodland, but coming into it from the south at Petard Point.
The landscape of Common Cliff on the way to the woodland didn’t look right – it appeared more like it had been periodically grazed over the decades rather than being shaped by natural forces. It was a more open landscape, scattered with a cover of bracken, brambles and hawthorns and the occasional small scrubby woodland, although it is well-wooded along the steep, inaccessible upslope of the cliff. Without too much surprise, I find that the whole length of the cliff and undercliff area, from Old Point at Ravenscar down to Petard Point is a registered commons, even though in some places there is little or no shelf area where grazing could take place. It just seems another vestige of how every last bit of land has been exploited in the past. A recently installed gate at the start of the descent down to Common Cliff, plus new fencing going up in front of an old wall that divides off the woodland at Beast Cliff, suggests that it wont be long before the grazing of this area will be backed by a hefty chunk of Higher Level Stewardship funding. I see no logic in that, when the woodland is the unique feature of this shelf, and could eventually clothe along the whole of the plateau if grazing was kept off. It would provide one of the few reasonably undisturbed areas as a sanctuary for roe deer, instead of the usual compromise we inflict on them of having to share landscapes with livestock.
The woodland at Beast Cliff is recognised as nationally important in the notification of the SSSI that covers it, which has the description that the vertical hard cliffs support maritime crevice and ledge vegetation, whereas the more gently sloping parts are covered by scrub and woodland that due to the frequent land slippage, is constantly changing and being rejuvenated with young trees (18). The SSSI also covers Cliff Common, where it says the vegetation is more open and reflects alternating strata of rich and poor base-status, but it does not mention whether that open character is also as a result of grazing. Beast Cliff and all the maritime cliff along the coast to Maw Wyke, above Robin Hood’s Bay, is included in a SAC (19). The only habitat for which the SAC is notified is "Vegetated sea cliffs of the Atlantic and Baltic coasts", and Beast Cliff is described as one of the best examples of vegetated sea cliffs on the north-east coast of England. The description of this habitat notes a number of influences that are key determinants of the type of sea cliff vegetation, such as exposure to the sea and weather; the cliff structure and geomorphological processes (profile and stability); and the nature of the underlying rock or drift deposit, particularly whether it is basic or acidic (20). The one thing this description does not list as a factor in the vegetation cover of these cliffs is grazing.
It would seem to me that the variability in the factors that are listed, are enough to produce a variety of vegetated cliffs without the need for the overlaying of the effect of grazing. There are good examples of woodland along the vegetated cliffs of N. Yorkshire, such as that at Beast Cliff and Hayburn Wyke, and other examples can be seen at Cayton Bay, Cornelian Bay, and especially at Runswick Bay. These are part of the estimated 22,000ha of vegetated sea cliffs around the coast of the UK (21) which of course would not all be woodland, but then it may be, based on the evidence of Common Cliff, that not all of it would be a natural landscape either.
Rare and precious lowland heathland
You will invariably hear the words “rare” and “precious” used in describing lowland heathland. Precious can mean a number of things, but it is an odd word to use about a totally artificial, secondary habitat. Just how rare lowland heathland is can be assessed by comparing the 70,000ha or so that exist at the moment (22) with the one native location of May lily, or the 340ha of the tall herb communities. It is certainly less rare than the woodland of vegetated coastal cliffs, and it is almost double the area of Siliceous rocky slopes with chasmophytic vegetation. And yet do you ever hear anything about May lily or those primary habitats from the conservation industry? Perhaps not, as they owe nothing to human intervention.
juggernaut that is lowland heathland continues to throw up discontent.
Nick Day contacted me about felling on his local, publicly owned common in
Suffolk (and see 23, 24):
whether anyone had successfully disputed a similar assault on woodland. My
simple answer was no, but as with all these heathland schemes, I went
through the available information just so I could establish the familiar
pattern of a SSSI designation for lowland heathland in spite of the
location having a woodland cover of over 60% (see 25). The monitoring
report for Sutton Heath says the following (26):
standard conservation industry dogma, and has been refuted for me by
Imogen, a colleague who went to see for herself:
I explained to Nick about Common Standards Monitoring guidance for SSSI, how trees and shrubs were a negative indicator for lowland heathland and that to achieve favourable condition, there had to be less than 15% tree and shrub cover – thus putting at risk at least three-quarters of the current woodland on Sutton Heath. I showed that part of Sutton Heath is registered common land, so that the Council could argue that it is required on behalf on those with commons rights to keep that area free of trees so that it can be grazed, but I doubted whether any of those rights were being exercised. I looked up the felling licences, and agreed with Nick that it was bizarre that an area of mixed woodland had been targeted for felling, which would have perhaps greater interest and thus should not be felled. I explained that there were Woodland Grant Schemes in place on the common, which were probably funding the felling and other thinnings and clearings. I found that Suffolk Coastal District Council had recently entered into a 10-year Higher Level Stewardship agreement on the Heath, bringing in £133,889, some of which likely goes to Suffolk Wildlife Trust as “rent” for the use of their Hebridean sheep. I also explained that the Sutton & Hollesley Heaths SSSI is part of the Sandlings Special Protection Area (SPA) a designation under the EU Birds Directive for woodlark and nightjar, and that even if we may dream of changing the SSSI system, there is no provision in the Birds Directive to de-designate an SPA.
The public should be included in discussions about the management of publicly owned land. While all the odds would have been stacked against Nick in resisting the overall aim of restoration of heathland – because of the SSSI – there could have been negotiations about where the felling took place, what would be cleared, where the grazing took place, and the pace of transformation. Of course the conservation industry thinks it knows best, and it will have been advising the Council, probably in a cosy relationship with some council officers rather than with elected members. In the end, though, Councils just want to get the juggernaut of heathland conservation off their back. Nick tells me that he has had an overwhelming response to the coverage he has had so far, and various further actions are planned.
Within days of Nick contacting me, I got another enquiry about heathland restoration from an assistant editor of the BBC’s Midlands Today program asking me about the opposition to fencing and grazing of the publicly-owned Hartlebury Common near Stourport, and whether there was anything that could be done about it. This is a classic heathland madness story, which I first wrote about in 2009 (Heathland MADNESS - the juggernaut of nature conservation (27)). It took me only an hour or so to catch up on what had happened since (see 28). The proposal to enfence the commons needed consent from the Planning Inspectorate. Because of the level of objection received by January 2009 to the application, a Planning Inquiry was held in July 2009. The Inspector ruled in favour of the application in September 2009. In February 2010, Natural England agreed a Higher Level Stewardship (HLS) grant of £368,871 over 10 years to Worcestershire County Council. The Council put the fencing out to tender and would appear to have used about £60,000 of the HLS money to enfence the commons, the work starting last December, and completed by the time the Council also put the grazing of the commons out to tender in May, asking for 25 rare breed cattle to begin grazing in June. I am still aghast at how the fenced area includes inside the grazing area the wet woodland at the south of the common. It will be trashed by the cattle.
objection to the grazing that I documented previously appears to have died
away, precisely because it is now a done deal. However, the HLS is
probably also funding tree felling on the common, and it is this that has
been objected to recently by local people. Cliff Day, who lives next to
the common, is reported in the Kidderminster Shuttle to be objecting to
the extent of tree felling, pointing out that even mature oak and silver
birch trees were being felled in areas of the common (29). Mr. Day is
concerned that Worcestershire County Council is not being open about its
plans and that much more felling is to be expected, which would put at
risk the wildlife on the common, such as foxes, badgers, woodpeckers,
jays, tree creepers, nuthatches, blue tits and great tit:
objections have already met with indifference, as a spokesperson for
Worcestershire County Council is wittingly or not hiding behind the Common
Standards Monitoring guidance for lowland heath that says that there
should be less than 15% tree and shrub cover (29):
He went on
The unfolding events at Hartlebury Common provide exemplary evidence of the moral impoverishment that is attendant in the conservation industry on the back of HLS and the SSSI system, and with Natural England ultimately responsible. Since Natural England took over sole responsibility for HLS on its formation in 2006, it has used it for pursuing their agenda of conservation dogma, as well as meeting the Public Service Agreement (PSA) target on SSSIs of 95% in favourable or unfavourable recovering condition by 2010 (27). In this case, it has resulted in the re-imposition of a farming pressure on Hartlebury Common, when it has no registered grazing commoners, and has no value in the contemporary farming economy. Instead we are to have the cute rare breeds of cattle so beloved by the conservation industry as they are so less challenging than wild nature. The immorality comes from changing the monitoring status of a SSSI Unit as soon as an HLS is signed, and perhaps even before the ink is dry. Thus Natural England reported a change in status from unfavourable no change for the heath on the common in May 2007 to unfavourable recovering in February 2010 (30) and in the nick of time for the PSA target. That latter date coincides with the signing of the HLS agreement, but it is 16 months in advance of the grazing starting on the common, and certainly before any outcome of the grazing can be assessed. This is not a rare event, and the only thing precious about it is how the conservation industry feel so confident that they get to railroad public interest every time, and use public money to do it.
Mark Fisher 26 May 2011, 13 June 2011
I've been contacted by Steve McCarron, pointing me to his petition site objecting to the destruction of Hartlebury Common by Natural England and Worcestershire County Council - Hands Off Hartlebury Common (31). The petition has some telling insights into what is going on there, and shows up the fencing, grazing and tree felling to be a nonsense. Steve contacted Francis Flanagan of Natural England, asking why 90% of the trees were going to be felled on the common. He was given the usual stuff about SSSI designation, with Flanagan making the entirely dubious assertion, given the artificial nature of heathland, that SSSIs are “the country’s very best wildlife and geological sites, often standing out as the last remaining areas of natural habitat in our modern countryside”
Steve notes that there was significant woodland cover when the common was first designated in 1955, as well as in 1986 when it was re-designated, but that the woodland then was not an impediment to its designation. This is more evidence, like Sutton Heath above, of the influence of the introduction of Common Standards Monitoring guidance in the late 90s retrospectively imposing a draconian ideal for the vegetative cover of these “natural habitats” (see Swineholes Wood - 'Too many trees being cut down' (32).
goes on to say:
I often get
accused of being categorical, but this beats me hands down! Flanagan was
less categorical when Steve talked to him in person, and somewhat
I should point out that it was Flanagan who promptly changed the status of the heath on the common from unfavourable no change to unfavourable recovering in February 2010, at the same time that the HLS agreement was signed (see above). Since he probably negotiated the agreement as well, we can put this one man centre stage in the destruction going on at Hartlebury Common.
Natural England is intervening in an arrogant and brutalist fashion
causing the uprooting and cutting down of healthy trees.
He is supported in this by a comment left on the petition site by “Regular
Steve points to the fact that even after almost 100 years of non interference (there are no registered rights for grazing) the common is hardly completely wooded, confounding the irrational logic of the conservation industry. He says that unmanaged, this site is a flourishing habitat that does not need any interference under the UK Biodiversity Action Plan.
The tree felling is only one aspect of the nonsense going on at Hartlebury Common. Fencing and grazing has followed the decision by the Inspector at the Public Inquiry (see above). I believe, however, there is good reason to revisit that decision. The fencing and grazing nonsense at Kingwood Common went to Public Inquiry in April (see The grazing war comes to Kingwood Common (34). The application to fence was refused as the 1906 Act of the Conservators forbade inclosure (35) This was pointed out by the objectors at Kingwood, in the same way that Mr Powell of the Open Spaces Society did about the 1815 Inclosure Act at the Hartlebury Common Public Inquiry in 2009 (36). For the Public Inquiry at Kingwood, the Inspector took advice from DEFRA, who confirmed that fencing would be illegal under the 1906 Act. This was backed up by the advice of a barrister for the objectors that had looked at case law.
I think it highly likely
that the fencing at Hartlebury Common is illegal, as the decision at
Kingwood casts serious doubt on the decision at Hartlebury. I think the
Inspector was negligent in failing to seek similar advice, and that it is
totally unsatisfactory for the Inspector to have said in the decision at
I have forwarded a copy of the relevant sections from the Inquiry decisions, as well as the legal advice from the barrister to the Open Spaces Society, and await their thoughts with interest.
9 June 2011
(1) Take three woodland wildflowers, Self-willed Land February 2008
(2) Walking the wild places, Self-willed Land September 2010
(3) Moor House – Upper Teesdale: What makes it special, natural England
(4) Moor House – Upper Teesdale SAC, Natura 2000 Data Form
(5) Convention on Biological Diversity: Thematic Report on Mountain Ecosystems, DEFRA 2003
(6) Moore, P.D (1975) Origin of blanket mires. Nature 256: 267-269
(7) Upper Teesdale SSSI, Natural England
(8) Upper Teesdale - Unit 75, SSSI unit information, Natural England
(9) Appleby Fells SSSI, Natural England
(10) Moor House – Upper Teesdale SAC, Site Details, JNCC
(11) Moor House – Upper Teesdale SAC, Natura 2000 Standard Data Form, JNCC
(12) Pillar and Ennerdale Fells SSSI
(13) Lake District High Fells SAC, Site Details, JNCC
(14) 8220 Siliceous rocky slopes with chasmophytic vegetation, UK Distribution, JNCC
(15) Lake District High Fells SAC, Natura 2000 Standard Data Form, JNCC
(16) 6430 Hydrophilous tall herb fringe communities, UK Distribution, JNCC
(17) The most natural succession of woodland, Self-willed land November 2009
(18) Robin Hood’s Bay: Maw Wyke to Beast Cliff SSSI, Natural England
(19) Beast Cliff – Whitby (Robin Hood`s Bay) SAC, Site details, JNCC
(20) 1230 Vegetated sea cliffs of the Atlantic and Baltic coasts, Habitat account -Marine, coastal and halophytic habitats, JNCC
(21) 1230 Vegetated sea cliffs of the Atlantic and Baltic coasts, UK Distribution, JNCC
(22) Lowland Heathland, UK Habitat Types, JNCC
(23) Sutton Heath tree felling questioned by locals, BBC News 5 May 2011
(24) Dog walkers brand tree felling 'a disgrace', BBC News 9 May 2011
(25) Notes on Sutton Heath, Self-willed Land May 2011
(26) Sutton And Hollesley Heaths - Unit 9, SSSI unit information, Natural England
(27) Heathland MADNESS - the juggernaut of nature conservation, Self-willed Land March 2009
(28) Notes on Hartlebury Common, Self-willed Land May 2011
(29) Residents' fears over tree felling, Kidderminster Shuttle 3 March 2011
(30) Hartlebury Common And Hillditch Coppice SSSI, Condition of SSSI units, Natural England
(31) Hands Off Hartlebury Common
(32) Swineholes Wood - 'Too many trees being cut down', Self-willed land 18 February 2008
(33) “Regular walker” Comment #27, Hands Off Hartlebury Common, 7 June 2011
(34) The grazing war comes to Kingwood Common, Self-willed land 26 April 2010
(35) Kingwood Common, Oxfordshire, Application Ref: COM165, Application Decision, Planning Inspectorate 27 May 2011
(36) Hartlebury Common, Worcestershire, Application Ref: COM54, Application Decision, Planning Inspectorate 17 September 2009