Swineholes Wood - 'Too many trees being cut down'


It seems fate that within days of writing about the discontent of people at the industrialised nature conservation going on in their backyard (see Take three woodland flowers) another example pops up, and to no surprise it fits with the common pattern.

This time it is in Staffordshire, where the felling of trees in Swineholes Wood has been going on for a number of years. The wood is a 61 acre nature reserve at Ipstones Edge that is managed by Staffordshire Wildlife Trust. The most recent tree felling, reported in The Sentinel, has angered Linda Malyon, an Ipstones parish councillor and a member of Staffordshire Moorlands District Council (1):
"They are going too far with the work. It's never too late to stop what's going on. When you look at what they have done, they have gone too far. The woodland is hundreds of years old and needs to be protected. There's been no consultation"

Other locals share this anger. Thus Alan Byatt who lives at nearby Ipstones fears that the wood is being devastated – “I have seen 20 men down there with chainsaws”. David Plant of nearby Winkhill has been walking the wood for more than 30 years, but he is really sad to see such a large area cleared recently. Sylvia, his wife, cancelled her membership of the Staffordshire Wildlife Trust in protest at the tree felling:
"It just seems a tragedy to cut down trees that have been growing for more than 100 years. Trees struggle to grow here anyway, so it seems a great pity to cut down the ones that have made it."

This emotional appeal is reinforced by the photograph accompanying the newspaper article that shows two of the felled trees, their girths of 90cm and more testifying to their age.

So why is this happening?

Swineholes Wood is part of a designated Site of Special Scientific Interest (SSSI) and the answer lies in the details of this designation (2). It was picked out to become a SSSI in 1968 because it had remnants of acidic dwarf shrub heath. The notification of the site admits to extensive cover of semi-natural broadleaved scrub and developing woodland on parts of Swineholes, along with the vestiges of a mixed plantation” (3). SSSIs are often parceled up into discrete units or areas, each of which identifies the features for which the overall site is notified. However, the woodland element described above is denied by the description of the unit that covers Swineholes Wood. This characterizes it as “Dwarf shrub heath – upland” (4) and in doing so locks it into a generic management approach that severely limits tree cover (5):
Continued habitat management is essential for maintaining the nature conservation interest and open nature of dry upland heaths by preventing the invasion of scrub and trees that would otherwise dominate these dwarf shrub communities.”

It has to be said that the unit description is partially truthful since it also covers a small commons that lies along the NW boundary of Swineholes Wood (6). However, the proportion that this commons makes up of the unit is no more than one third, and thus it seems perverse to apply a generic management approach to the unit that doesn’t implicitly recognise the woodland element. It is as if the management issues of the heathy commons are more important than the woodland. Moreover, the Wildlife Trust themselves belittle the woodland element of their reserve, pointing to a map from 1775 that showed the whole of Ipstone Edge as heathland, and also by implying that the woodland only became significant from the 1930’s onward after a small plantation area of pine and larch was introduced, and when the oak, birch and rowan “invaded” the heathland through natural regeneration (7).

Guidance on agreeing management plans

Is the wood an inconvenience to the conservation professionals, who seem almost to deny that it exists? Certainly local people think it is a wood, and even though the location has not been continuously wooded since 1600 (8) – which would give it the status of ancient woodland - it has obviously been there long enough to have been in the affections of a number of generations of local people. It is marked on the Ordnance Survey map as a wood (Explorer OL24), and it appears as a wood on the aerial photographs of any of the internet mapping sites (9). Thus when, without consultation with local people, a gang of workmen with chainsaws comes along and takes out a chunk of woodland, then it is not surprising that tensions arise.

In an attempt at a defence, the Staffordshire Wildlife Trust are reported in the newspaper article to have discussed their management program with Natural England and the Forestry Commission before proceeding. That’s alright then, but this is a staggering complacency on all their parts when you consider that guidance entitled A Common Purpose: A guide to agreeing management on common land has been around for over two years, and which seeks to reduce the potential for controversy. It sets out a process for planning management of locations like Swineholes Wood that takes proper account of the views of all interested parties (10):
“By developing an increased understanding of all stakeholders’ views, and agreeing the problems before proposing solutions, this approach seeks to promote the development of sound, effective management proposals based on co-operation”

As the National Trust was one of the sponsors of this guidance, you would have thought that they could have applied this approach in their program of conservation at Harting Down in W Sussex, and thus avoided the despair of local people when the Trust brought in commercial contractors to completely clear through trees and scrub on 20-30 acre blocks of this landscape (see Harting Down – obsession with conserving man made landscapes). Harting Down has all the usual ingredients: a substantial area of commons (6) that is covered by a SSSI designation (11) and which also has bands of woodland. While some of that woodland is identified in the various units of the SSSI, the units characterised as “Calcareous grassland – lowland” all overlap with the mapped woodland, putting the woodland and its trees at risk from the generic management approach to that type of grassland unit.

Natural England was another of the sponsors of the Common Purpose guidance, as it was also the commissioner of a study from 2005 entitled South East Commons and their Conservation Management (12). This study looked at amongst other things the controversy over tree clearance on commons:
“Clearance can very quickly and dramatically change the character of a landscape which people cherish. The fact that the wooded landscape has only developed in say the last 20 years is almost irrelevant to most people as they won’t necessarily remember what it was like beforehand”

The report highlighted that one of the main problems that local people have with the conservation management of SSSI commons was that stakeholders were rarely engaged in the development of management proposals from an early stage. Consequently, they can rightly feel that proposals are being imposed upon them and that their views are not valued, let alone considered. Thus the report recommended that the staff of Natural England should take note of this need for engagement.

Let down by Natural England

This report brings a hollow laugh from protestors to the management of Ashdown Forest in E Sussex, especially as it mentions the Forest as a priority in terms of a review of its management. The protestors feel that Natural England should have listened to that recommendation before they sanctioned the tree felling of the previous winter, and the illegal burn of the forest near Gills Lap, set by forest rangers during the beginning of the nesting season in March 2007. But by then they had already asked for and got an assurance in a letter from Natural England that committed the organisation to encouraging the adoption of the approach to agreeing management on common land, as given in the Common Purpose guidance (see above).

Anger is a word that so often crops up on these occasions, and so it did in a Daily Telegraph article from last May that reported that visitors to Ashdown Forest were reduced to tears by the sight of trees being toppled and the ground being churned up by bulldozers (13):
”Controversial measures to restore and maintain traditional heathland, including felling mature trees and fencing off areas so sheep can be grazed, has angered the legion of forest supporters”

Gillian Nassau of the Ashdown Forest Action Group (now sadly departed) was particularly concerned at the works carried out in the areas of Wren's Warren and New Road. She said:
"At Wren's Warren heavy machinery has crushed the land and created huge ruts. Any underground animal habitats must have been destroyed. Trees which included mature oaks were felled and vegetation stripped leaving a scene of desolation."

Yet again we have dissonance about the threats to woodland between local people and conservation professionals, created by the SSSI designation of an area of commons. The often avowed intent of the Board of Conservators of Ashdown Forest is to maintain a balance between heath and woodland with the proportions of 60% heath and 40% woodland. But wait a minute, the SSSI notification tells another story (14): of the 34 units of the Ashdown Forest SSSI, 76% by area (19 units) is heath; one unit (0.02%) is acid grassland; and the remaining 22% (14 units) is woodland. There is a third set of figures in the designation of Ashdown Forest as a Special Protection Area (SPA) from 1996 that gives 10% as wetland (bogs, marshes etc.); 50% as heath; and 40% as mixed woodland (15). A fourth set of figures is given in the designation of the Forest as a Special Area of Conservation (SAC) which has 45% as wet heath, 14% as dry heath and 40% as woodland (16). No wonder there is confusion amongst local people as to what is the landscape cover of the Forest.

The website of the High Weald AONB has a page extolling the virtues of Ashdown Forest. In a chilling reflection of the reality, and without any apparent sense of irony, it lists chainsaws clearing trees as one of the sounds you will hear on the Forest in winter (17). For a very few conservation professionals, this persecution of trees has become too much. Bob Bleakley works for the Environment and Heritage Service of Northern Ireland. In an email discussion group, Bob bemoaned the ill-experience of the hard of thinking officialdom that regulates nature conservation both here and at European level. He says it is especially true of the Natura 2000 sites like SPAs and SACs where everyone is terrified of the European authorities taking proceedings for infractions of the designations. Bob is beginning to question the whole concept of "holding the line" by costly intervention to prevent "seral succession" (the natural regeneration of woodland):
“We need to be much more careful in describing features when designating. Where a habitat is naturally in transition, we should describe it as such and be prepared to let it develop towards the climax condition rather then spending a fortune trying to prevent nature from progressing”

I couldn’t agree more, but there are inexorable pressures at work, with little sign of change. The main pressure is the obvious one of the notification of features of a SSSI fixing the components of the landscape in stasis because there is a legal obligation for the landowner to maintain those features. A more recent pressure derives from the Government’s Public Service Agreement (PSA) target that requires 95% of all SSSI to be brought into favourable condition by 2010 (18). The baseline figure from March 2003 for SSSIs overall was 56.9%. In the context of Swineholes, Ashdown and Harting, it is interesting to note that over half the common land in England is designated SSSI and, as of March 2006, 43% of those SSSIs commons were classified by English Nature as being in poor or declining condition (19). The situation with the SSSI commons in the SE, which includes Ashdown and Harting, was less dire (27% in unfavourable condition as of 2003 – see (12)), but English Nature were anxious enough of that PSA target that in 2005 they commissioned the study on the conservation management of SE Commons, as well as they sponsored the guidance in A Common Purpose (see earlier). In addition, English Nature must have been very pleased with the Commons Act 2006 because an express aim of the Act is to contribute to the reaching of the PSA target for SSSIs by encouraging “commons to be managed more sustainably” through the setting up of statutory Commons Councils (19).

While Ashdown Forest is a heathland SSSI commons, not all SSSIs commons are heathlands (i.e. Harting Down) and not all heathland SSSI’s are commons (i.e. Blacka Moor). However the sound of mature trees hitting the ground after being felled on SSSIs can be heard all over England as conservation professionals play a murderous game of catch-up as they fall into line with Natural England in maintaining the landscape in stasis and with the added pressure of trying to achieve the PSA target.

MacDonaldising the countryside

You may like to know that Natural England uses a Common Standards for Monitoring (CSM) approach for each characteristic feature of a SSSI that is notified, and that this contains guidance on the proportions of the various mandatory attributes (components) expected in the landscape when they come to inspect its condition (20). That is how the stasis is achieved. The implied strength of a CSM approach for monitoring condition is that it uses the same suite of quantifiable and measurable attributes for each interest feature across England, which in turn allows for “consistency”, reduces the cost of data exchange, facilitates data reporting, which of course all allows targets to be set (21). For such as lowland heath (22), this prescriptive CSM guidance will specify the limits to such as scrub and tree cover (<15%); the dwarf shrub diversity and cover; the gorse, bryophyte and lichen cover; the amount of bare earth (>1% but <10%); the presence of graminoids (grasses) etc. etc.

There is some discretionary scope in the guidance for local distinctiveness: thus for lowland heath it talks about the presence of rare or notable plant species or other features (such as pools) that make the heathland site distinctive or special in the sense that they do not appear in all heathlands. Another discretionary attribute as an indicator of local distinctiveness are associations between lowland heathland and other habitats or mosaics of which the transition to woodland is given as an example. However, it seems to be the experience in most locations that the conservation professionals are either ideologues or they are too timid or unimaginative in making the case for this as a smooth transition – or even a mosaic - when instead there is often an abrupt clearance line as over the felled trees go.

Does the use of a CSM approach thus mean that every heathland SSSI has to look the same everywhere in England, irrespective of any local conditions and considerations? This is the concern of Michael Jeeves, Head of Conservation at Leicester and Rutland Wildlife Trust, when free to express his own views on targets in nature conservation said (23):
“The targets used to measure the condition of SSSIs are surely arbitrary. Does every woodland have to have 20% open ground and less than 5% non-native trees, every calcareous grassland no more than 5% bare ground, and every heathland 25-90% cover of ericaceous shrubs? How do you accurately measure these things in practice?”

No wonder many people living near SSSIs are angry with the conservation industry because in the drive to manage, measure and report, they have MacDonalised nature conservation. Their process of maintaining land in a prescribed stasis is killing off all the wildness in nature. If you think this is immoderate rhetoric, then think through the implications of Natural England commissioning a study of non-designated lowland heathland in light of it being a priority habitat in the UKBAP, and thus to do with meeting another target! The study carried out field surveys of a sample selection across England to see how much of it would pass inspection based on the CSM approach (24). The study reports that the pass rate of the sample was 0% and thus none could be considered in a “favourable condition”. Even by relaxing various of the mandatory attributes in the CSM guidance, the pass rate could only be brought up to 5%.

I am not surprised at the results of this study. As it is, the pass rate for UK SSSI heathland itself in 2006 was only 17% (25) and this is because heathland is rarely the natural state of the landscape, except in climatic extremes where there is a natural absence of trees (24). Our heathland is thus almost entirely an artifact of a human use that has invariably sucked the life out of the land without any thought of giving anything back. That traditional management through livestock grazing and other extractive activities has in many locations fallen into disuse, only to be replaced by the synthetic “farming” by conservation professionals. The “favourable condition” of lowland heathland thus reflects a management prowess in maintaining an artificial landscape to prescriptive targets, and is not any measure of the natural health or wellbeing of the landscape as is so often claimed.

The authors of the study recommend that Natural England consider a program for the designation of more lowland heathland sites as SSSIs. I take no joy from the thought that this will undoubtedly provide me with more opportunities to document the public’s dismay at the destructive activity of conservation professionals.

Mark Fisher 18 February 2008

(English Nature turned into Natural England in 2006)

This is the second in a series of three articles. It follows Take three woodland wildflowers, 4 Feb 2008 and is itself followed by High price for heath - Loxley and Wadsley Commons 8 March 2008

(1) Too many trees being cut down, Roger Houldcroft, The Sentinel 7 February 2008


(2) Swineholes Wood and Blackheath, SSSI information, Natural England


(3) Swineholes Wood and Blackheath, SSSI citation, Natural England


(4) Unit 1, Swineholes Wood and Blackheath SSSI, Natural England


(5) A statement of English Nature’s views about the management of Swineholes Wood & Black Heath SSSI, English Nature


(6) Commons can be located using the Open Access website www.openaccess.gov.uk

A map showing the commons next to Swineholes Wood can be downloaded from:


(7) Swineholes Wood, Staffordshire Wildlife Trust


(8) The ancient woodland status of all mapped woodland in England can be found using the mapping on the Woods and Trees Under Threat website www.woodsunderthreat.info

(9) The following link will take you to an ariel photograph of Swineholes Wood on Multimap


(10) A Common Purpose: A guide to agreeing management on common land, Short et al (2005) sponsored by English Nature, RDS Defra, Open Spaces Society, The Countryside Agency and the National Trust


(11) Harting Down, SSSI information, Natural England www.english-nature.org.uk/Special/sssi/sssi_details.cfm?sssi_id=1000415

(12) South East Commons and their Conservation Management, ENTEC (2005) for English Nature and the Countryside Agency


(13) Anger over management of Ashdown Forest, Paul Eccleston, Daily Telegraph 25 May 2007


(14) Ashdown Forest, SSSI information, Natural England


(15) Ashdown Forest SPA Data Form, JNCC  www.jncc.gov.uk/pdf/SPA/UK9012181.pdf

(16) Ashdown Forest SAC Data Form, JNCC  www.jncc.gov.uk/protectedsites/sacselection/n2kforms/UK0030080.pdf

(17) Ashdown Forest, Popular Places, High Weald AONB  www.highweald.org/text.asp?PageId=170

(18) England’s best wildlife and geological sites : The condition of Sites of Special Scientific Interest in England in 2003, English Nature 2003 (catalogue Code ST10.4)

(19) Why do we need a Commons Act? Commons Act 2006, DEFRA


(20) Key aspects of Common Standards Monitoring, JNCC  www.jncc.gov.uk/page-2219

(21) The need for common standards for site monitoring, A Statement on Common Standards Monitoring (1998) JNCC


(22) Common Standards Monitoring Guidance for Lowland Heathland (2004) JNCC


(23) Targets in nature conservation – sending the wrong signals? Michael Jeeves (2007) ECOS 28 (1) 7-10 www.banc.org.uk

(24) The condition of lowland heathland: results from a sample survey of non-SSSI stands in England (2007) Natural England Research Report NERR002


(25) Summary, Common Standards Monitoring for Designated Sites: First Six Year Report (2006) JNCC  www.jncc.gov.uk/pdf/CSM_06summary.pdf

(26) Heaths and moorlands, Charles Gimingham in Wild Flowers - Their habitats in Britain and Northern Europe, Geoffrey Halliday and Andrew Malloch, Eds. (1981) Collins ISBN 0-85654-618-6


www.self-willed-land.org.uk  mark.fisher@self-willed-land.org.uk