Wild Park, Brighton - not so wild now

 

The autumn leaves fell like soft rainfall in Broadstone Wood after a night of hard frost. It was magical, and reminded me of the first time I had seen this phenomenon, in the White Mountain National Forest of New England in 2005. The frost seems to loosen the grip on leaves, sending them falling before their time. When I started writing about wildness 10 years ago, I thought it would be about more of these magical moments, and how I wanted others to have the opportunity to experience them. For the first year or so, it was my explorations of wilder locations, and how it was that they existed because of being outside of any intensive use. Looking back, though, I find a couple of surprising omissions. I didn’t write about the Great Smoky Mountains for some years, when walking there in 2001 had been a pivotal experience. Also, I never fully explained how I alighted on and chose self-willed land.

I first experienced the magic of wild land through the botanical richness of a chance week spent walking the Great Smoky Mountains National Park in North Carolina. It seemed like I could not go more than 50 paces on its trails without coming across another new woodland flower. I fell in love with the brightly coloured, showy spring-flowered trillium, and astonishingly recognise a morphological similarity with Herb Paris, a native woodland wildflower of Britain. I have to thank the Great Smoky Mountain National Park for turning me on to woodland again, but also providing me with the simple truth that wild nature is a better gardener than any human could ever be. It also confirmed that my instincts and unease about the British landscape were valid, that our use of land is so comprehensive that we have little or no example of what is truly natural, or what has been lost.

Having visited Shenandoah National Park in the Virginian Appalachians earlier this year, I can reflect now on the botanical connections I have seen between enclaves of wildness up and down the eastern states of America. I immediately recognised the whorled-leaved Indian cucumber-root in Shenandoah, even though I had only seen very end-of-season plants in the wilderness of the White Mountains. The trillium, lady slipper orchid, jack-in-the-pulpit, False Hellebore, Clinton’s lily, and the amazingly beautiful flowers of the tulip tree, were a shared joy between the Great Smoky Mountains and Shenandoah, and make me appreciate how lucky I had been that my first experience of wild nature in America had been home to over 1,500 flowering plant species growing within forests that cover 95% of its area. Thus Great Smoky Mountains National Park has some 100 species of native trees, more than in any other North American National Park, as well as one of the largest blocks of deciduous, temperate, old-growth forest remaining in North America.

An emphasis on its own intrinsic volition

None of these wild places are unused land. Their wildness comes from the decision at some point in their recent past to withdraw human land use. I had understood this better after I had read a remarkable collection of essays - Unmanaged Landscapes: Voices for Untamed Nature - in which various authors challenged the need for human interference in wild nature, and discussed how modern civilisation can live with unmanaged, self-regulating, self-regenerating land (1). While it was mostly based on the American experience, there was an essay that had some profound insights for the landscapes of the Scottish Highlands, and which I would later write about (2). I was also reading Wild Earth, the magazine of the Wildlands Project (now called the Wildlands Network) as well as various articles about wilderness published by the US Forest Service’s Rocky Mountain Research Station.

In the same way that the imprecision of the word wilderness plagued drafting wilderness legislation in America, I was having difficulties in using the word in the British context. Howard Zahniser, executive director of The Wilderness Society, had come up with a draft bill in the spring of 1956 that used the word “untrammeled” to define and characterise areas of wilderness. He had passed over using “undisturbed” as that could not be the case for the land that was being considered for wilderness designation, since it had all been subjected to human usage to some degree. Zahniser was adamant that “management” of the ecosystem in each wilderness area should occur almost entirely by restraint on human influences. He thus chose untrammelled as he wanted to convey the idea that the land would not be subjected to human controls and manipulations that hamper the free play of natural forces (3). Moreover, it would be the best word to express a forward-looking perspective about the future of land and ecosystems. Thus once designated, wilderness was to be allowed to express its own will - with the forces of Nature untrammelled into the future.

In anchoring a banner for my writings, I could not use the word wilderness, as it was an even more fraught term in Britain when we have lost, unlike America, much of our natural vegetation by a simplification of our ecology through farming, as well as our key mammalian species through extirpation. However, I came across terms like self-willed nature, and self-regulating land communities in the landmark article by Michael Soulé and Reed Noss on the importance of reinstatement of the large carnivores in a continental scale linked and connected landscape (4). I expect it must have been in articles by Dave Foreman of the Wildlands Project, and then Rewilding Institute, that I first saw the term self-willed land used, and recognised that it would be a better fit with the potential situation in Britain. I realised that it did not necessarily rely on every species being reinstated because it was a statement of outcome from the lack of human intervention, in the same way that untrammelled was for wilderness in America. It would be a few years afterward that I thought to track down where Foreman had got it from (5).

Foreman wrote that he first heard it described during a talk by philosopher Jay Hansford Vest at the Third World Wilderness Conference in Scotland in 1983 (6). While I have always avoided getting into an etymological quagmire on the meaning of words through their Celtic origins, Vest first recounted wilderness historian Roderick Nash’s recognition of wilderness as “wild-deor-ness” meaning the place of wild beasts, but noted that Nash had failed to deal adequately with what "ness" meant. Turning to the Old Scandinavian languages as well, Vest identified ness (naes) primarily as “the ground” or as a headland, point, or promontory, a prominence of land or a prominent mass of land. This led Vest to believe that wilderness means “‘self-willed land’…with an emphasis on its own intrinsic volition”. He interpreted der as “of the”, not as deor (animal or deer):
“Hence, in wil-der-ness, there is a ‘will-of-the-land’; and in wildeor, there is ‘will of the animal’. A wild animal is a ‘self-willed animal’ - an undomesticated animal - similarly, wildland is ‘self-willed land’”

Vest averred that this wilfulness “is itself in opposition to the controlled and ordered environment which is characteristic of the notion of civilization. While control, order, domination and management are true of civilization and domestication, they are not essentials of primal culture”. I would agree, but I wouldn’t say that my original appreciation of a meaning for self-willed land is enhanced by Vest’s etymological derivation. It seemed self-explanatory anyway when I came across it, and my understanding and use has always been about that intrinsic volition.

The dignity of wild animals

If I was hypercritical in that first year or so, it was on behalf of wild animals, and the poor regard in which they are held. It is an inescapable fact that wild nature in Britain has to co-exist with the needs of human land use, and if that co-existence is threatening to us then we manage-out the threat in an often ruthless way, with no pause for contemplation of relative rights to life and freedom. What incensed me was a Government consultation on deer management that didn’t give dignity to the wild animals it was talking about. There were brief descriptions of the two native and four introduced species in Britain, and limited information on their population size and distribution, but there was no explanation of their natural behaviour or habitat, nor indications of geographical locations in Britain where their unhindered presence could be welcomed (7).

As I explained, the best hope of maintaining species is to give them the space to have an unfettered existence, free from our management and influence. I surprise myself now, but perhaps it was the influence of the Soulé and Noss article on continental scale conservation that encouraged me to say back then that it made sense to reintroduce large predators to those sanctuary areas so that the true dynamic of nature's balance is restored, taking away our need to have to choose what to slaughter. I suggested the lynx and the wolf, but that if we were really adventurous then it could also be the brown bear. The frequency with which this proposal for re-instatement of large carnivores is heard nowadays may suggest progress, but the fundamental issue remains the same, the re-dignifying of wild animals and gifting them the space to exhibit their natural behaviour. Having just re-read another of the early influences on me, the late Melissa Walker’s two-year solitary exploration of wilderness – Living on Wilderness Time: 200 days alone in America's wild places – I would echo her take on this while walking Zion National Park in Utah, known for its mountain lions (8):
“Sitting on a rock jutting out into the river, I was acutely aware of the chasm that separates modern humans from most other creatures. While we have the advantage of being able to enter their habitats, they cannot enter ours without risking their lives….. With the exception of domestic animals and those wild critters that have learnt we might provide them with food, I knew of no animals that could possibly be better off because of my presence”

Taking on another purpose

I did appraise the state of wildness one year in, and its progress as a value, describing it as being from an outsider’s perspective (9). I found that there was an aspect to wilderness in Britain that was alarming, and which I called the "anthropocentric conceptualisation" of wilderness. This conceptualisation was completely devoid of any biophysical reality because it resided in things like state of mind, cultural context, romanticism - the literary regard of the gatekeepers to what passes as nature writing in Britain, their literature having little imagining of landscapes prior to the coming of agriculture, or scenarios of future natural landscapes from re-naturing. One of its high priests was Robert Macfarlane, who famously wrote in a Guardian article that "it is clear that the British Isles in fact still seethe with wildness and wilderness" (10). Of course it had to, or he could not, in his books and articles, have basked in its reflective glory. Macfarlane gives his readers what they want, and it is perhaps less of a crime against logic than the habitual cosmetic syrup that is poured over our degraded uplands that astonishingly are portrayed by the degraders as beautiful nature, and which fools many only because we have nothing else to compare them with.

It was after the end of the second year that I started to pick up on dissatisfaction with the dogmatic orthodoxy of the conservation professionals in Britain, and how it was an industrialised process that led to destructive action. It came to me from two sources, the first was alighting on the uncompromising criticism from Stephen Rowe, a young man who had posted an independent study module from his degree studies along with other thoughts on his charmingly idiosyncratic website (11). His brushes with conservation organisations, and his exposition on Grazing and Diversity, had led him to have a pretty jaundiced view of the conservation industry. He asked (12):
“Have you ever gone out to your favourite woods to discover that it has been visited by countryside vandals? Not only has your favourite woods been vandalised, but it was done in the name of conservation, by the British Trust for Conservation Volunteers?”

Stephen reserved his greatest vituperation for the conservation professionals, the “grazierphiles” who he thinks were bringing about the “farmification” of all our land. Chief amongst these was the then English Nature. Stephen believed they were on a mission to convert and maintain the whole of our countryside as fenced-in and grazed farmland. One of his examples was Portsdown Hill, a place I know since it is not far from where I grew up (13). It’s a chalky slope above Portsmouth where grazing had ceased over 60 years ago. It has long been favoured by walkers and horse riders, who used to enjoy the open access of this public land. Not so now. The slope was designated a SSSI in 1978 and thus after grazing had ceased, the notification recognising the absence of grazing and the presence of hawthorn scrub (14). Come forward 25 years or so, and English Nature was forcing Portsmouth City Council to erect fences, clear scrub, and graze with cattle. As I search back now, I see that the essential bribe was eventually put in place one year later, in November 2006, when Portsmouth City Council signed an agreement for Higher Level Stewardship of £193,273 (AG00170539). I briefly corresponded with Stephen in 2005, who encouraged me to send any examples I may have had as he was intending to write a book, but he seemed to disappear.

The other source was being contacted by Neil Fitzmaurice, who told me how Sheffield Wildlife Trust was destroying the wild character of his local moor at Blacka. Neil put forward a persuasive case for the nonsense of this publicly owned moor being shrugged off by Sheffield City Council so that the local wildlife trust could build its income and its land empire. Working with Neil, this led to a first article written in cooperation with the local people that were challenging what was often the destruction of a beloved place by the conservation industry (15). Thus it was through the influence of Stephen and Neil that my writing took on another purpose, of documenting the discontent of local people at the slavish ideology that destroys much of our wilder nature. Working with local people, I have written over the years about this contested and discredited approach at locations that include St Catherines Hill, Ashdown Forest, Esher Commons, Chobham Common, Harting Down, Swineholes Wood, Nomansland Common, Loxley and Wadsley Commons, Penwith Moors, Norton Heath Common, River Avon, White Moss, Gib Torr, Scilly Isles, Kingwood Common, Tayside beavers, Hurn Forest, Hartlebury Common, Malvern Hills, Sutton Common, Padworth Common, Thursley Common, Bitchet Common, Cwmma Moors, Longmoor Common and Sound Common. I have only but admiration and great respect for all those people unprepared to allow this damaging dogma go unchallenged, and who have freely given of their experience and knowledge.

A glorious stretch of wild, almost rugged downland

Wild Park in Brighton can now be added to the list. I was contacted last August by someone from Wild Park Defenders (16) the group that had been formed to oppose the destruction of this “large and beautiful public park on the urban fringes of Brighton”. Despite widespread public opposition, Brighton and Hove City Council and a rubber-stamping "Friends" group, supported by Natural England, had apparently been vandalising the park on a “huge scale in the name of 'restoring' the area to chalk grassland with the introduction of sheep”. It didn’t take me long to find out what was going on from reports in the local press, and confirm the stultifying familiarity of another public place that was having the will of the conservation industry imposed on it.

The area in which the park is located was purchased by Brighton Council as part of the Moulsecoomb estate in February 1925 (17). Over 200 acres were leased as farm land, but the 90-acre park was formally opened by the mayor, Charles Teasdale, on 30 June 1925. Grazing was removed and, other than the playing fields in the valley bottom, the remaining areas of gently sloping chalkland were left as open downland. When the site was acquired by the council, it was described as “A glorious stretch of wild, almost rugged downland with deep valleys and furze clad heights” and it is perhaps this that led to the adoption of the name “Wild Park” (18). However, with the cessation of grazing, it could only have got wilder, as is shown by ariel photographs from the 1940s onward that illustrate natural regeneration of ash-oak woodland, and its gradual progression over the park so that there are now extensive woodland walks.

The contemporary conservation industry loathe this evidence of the advance of wild nature over the twentieth century, when it means that it has reclaimed the farmed landscapes that they so admire. Thus in the Management Plan produced by David Larkin, Countryside Ranger, that popped up in May 2012 (remember that date) it has this (18):
“Future management of Wild Park needs to reflect the importance of its historical sheep pasture as well as its more recent importance for recreation”

Moreover, it has a priceless sentence that appears to use the extinction of such as the woolly mammoth as a justification for conservation grazing with sheep, an absurd piece of nonsense that I know will have come from Sussex Wildlife Trust, and which has no basis in the scientific literature, nor are sheep in anyway native to Britain (18):
"Recognition of the need for management to maintain grasslands (in the absence of large wild herbivores which were hunted to extinction by man in prehistory) led first to small scale scrub clearance and mowing in the 1980’s followed by the reintroduction of managed grazing in the winter of 2008/2009”

The Management Plan also tells us that a large area of trees on the northern dipslope above the valley was cleared in the winter of 2009/2010, along with some areas of scrub – “All necessary approvals were obtained”. By 2011, a large grazing compartment had been created on this northern dipslope area by enclosing it with fencing. These are all the ingredients to drive a local population to despair when they were not involved in the decision-making that led to these works, and are not convinced of the need for them. Thus in 2008, Denise Friend thought the original trial proposals to graze sheep in the park was some sort of joke (19):
“There are many questions which must be answered before we consider putting vulnerable animals in a city park. How long are the sheep going to be kept there? Where are they going to be sited? Who is going to look after them? How will they interfere with the people using the park"

It did not have to have been this way, except for the shabby means by which the decision was made to carry out the destructive work at Wild Park. The Director of Environment of Brighton and Hove City Council took a report to an Environment Cabinet Member meeting in September 2009 in which he made recommendations about "Downland Management" in the various city parks, and in which grass mowing would be replaced by sheep grazing. However, this was more than just a replacement for grass mowing in Wild Park because, while sheep grazing had been trialled there on a limited area of chalk grassland, this report proposed a massive expansion from a three year program of land clearance coupled to permanent fencing and sheep grazing, with a "large area of scrub" cleared over the winter of 2009/2010, and further areas over the winters of 2010/2011 and 2011/2012 (20). That this was a large area proposed for clearance in the first winter of the proposals can be seen from the grazing plan for 2009/2010 given in an Appendix to the report (21).

The report said that consultation and publicity for each grazing site would include ward councillors, community conservation groups, site users, local residents, and recruitment of “lookerers” to assist with checking sheep (20). That the report said that "Consultation is underway with existing conservation community groups" must have meant the malleable "Friends" group for Wild Park that few local people were aware of. However, Council officers had obviously also been in discussion with local Natural England staff, because the report said that NE had "supported" the council in making an application that had been submitted for "Higher Level Scheme (HLS) agricultural funding for ten years from 2010 to fund site improvements and facilitate grazing, such as scrub clearance, fences and accessible gates" At the time of the report, Natural England was funding the Farm Environment Plan that is a requirement of HLS applications, and which includes the choices of actions that the council were seeking funding for.

In what may seem a bizarre consequence of the reorganisation of local authority governance from 2000, the decision to approve the grazing report at that meeting was made by one person, the Cabinet Member for Environment (22). Even so, the decision to approve the grazing plans for each site was "subject to full consultation with ward councilors and residents", and that implementation of the plans was subject to successful completion of that consultation. I wonder what evidence the Director of Environment took as the successful completion of that consultation, because tree felling followed within only a few months?

Shrub and woodland has been massacred

There was alarm about the tree clearance over the winter of 2009/2010, with Sue Grimstone writing a letter to The Argus in April (23):
“I am concerned by the destruction of many trees during the past month in Wild Park. A notice says that the Friends Of Wild Park, in conjunction with Brighton and Hove Council are clearing shrubland to bring it back to how it looked in the 1940s. I have to ask: What was wrong with how it was looking? Was it right in the 1940s? There is nothing wrong with clearing a small area of shrubland but this is a bit more than that. Trees which were clearly more than shrub have been felled leaving nothing more than stumps. Why was it necessary to clear so much?”

Natalie Nortcliff wrote of her own concerns a few days later about the destruction of trees in Wild Park (24):
“I could literally cry as I walk around there these days. The shrub and woodland has been massacred, all for the sake of grazing sheep which could have been accommodated on the field above without the financial costs and the destruction of wildlife”

In early May 2010, campaigners spent the weekend tying ribbons to the oldest and biggest trees in the park to show the trees they were desperate to save. Campaigner Sue Grimstone said (25):
“The work to clear the park has only just started and the end plan is nothing but horrifying. Everyone that I have since spoken to in the area is unaware of the extent. There are now a growing group of very angry local people who intend to fight this. The council seem adamant this is right, something that we cannot believe, to clear so much which is so established for the sake of flowers and butterflies that do not exist yet”

Christine Simpson, councillor for the ward that covers Wild Park, was moved sufficiently by the concerns of local residents to make a request later in May 2010, for Brighton and Hove City Council to undertake a scrutiny review of the clearance work (26):
“In recent weeks I and many colleagues have received expressions of concern about the work that has been going on to encourage the reintroduction of chalk grassland in Wild Park. It is fair to say that there is a divergence of views on the scrub clearance, with some local residents and people who have a strong interest in nature conservation having expressed strong reservations about the appropriateness of the work taking place at all in a public park, and also the extent and manner of the work that has been done”

Amongst the concerns that had been expressed to her were the destruction of valuable flora and wildlife habitats, and the removal of mature and semi mature trees. Most damningly, it was alleged that the work had been carried out without the benefit of a management plan and proper surveys, and without adequate consultation taking place prior to the clearance work. The Director of Environment’s report to the subsequent Scrutiny Committee meeting in June 2010 showed, as is often the case, that consultation had only really occurred with the “Friends of Wild Park” group, that comments from the public were only received after the felling work had largely been completed, and that there had been a meeting with the “Friends” to review the project and consider future works in response to the comments received (26). As a concession on consultation (for being found out for the lack of it?) there was a commitment to consult during the summer on reducing the scale of further “scrub clearance”. The report always refers to scrub, and never trees, or at least only younger trees, in a deliberate approach to minimise the significance of the tree felling and the regulatory processes involved in obtaining a felling licence. This diminishment to “small trees” is also apparent in the first of two newsletters circulated to all houses within about 15 minutes walk from Wild Park (about 16,000 people) (18). This October 2010 newsletter was apparently compiled with the help of a focus group representing a variety of interests, and which invited people to a series of four workshops run by an independent facilitator – more of which later.

As is also always the case, the value of the grass habitat to be restored was highly exaggerated in the section of the report by David Larkin, while at the same time he trashed the tree regeneration in Wild Park by saying that the scrub and woodland has a much lower value for wildlife. The report hides behind the Convention on Biological Diversity, the UK Biodiversity Action Plan and the BAP for calcareous grassland therein, and Section 40 of the Natural Environment and Rural Communities Act 2006 as an obligation on the council to have regard to biodiversity in the exercise of its functions, none of which forces them to vandalise Wild Park. If the chalk grassland there was so special, why wasn't it designated a SSSI. As it is, there are 539sqkm of lowland calcareous grassland in England, and 79% of that is already designated as SSSI (27). While designation of Wild Park as a Local Nature Reserve in 1996 has no statutory basis for habitats, I wonder why it took the council 12 years to decide that they had to do something about what chalk grassland that is there?

The BAP priority habitat mapping for Wild Park shows a lot of deciduous woodland, very little chalk grassland, and then superimposes "Undetermined Grassland" over most of the woodland area. The council could have instead recognised the natural tree regeneration of over 80 years as a contribution to the BAP on deciduous woodland. They should also have recognised the natural value of scrub, along with that woodland, for wild nature because this is shown in a report commissioned by the Joint Nature Conservation Committee entitled The nature conservation value of scrub in Britain (28). Even the Scrub Management Handbook, a scrub trashers guide commissioned by English Nature, cautions against indiscriminately clearing scrub without surveying for species associated with scrub, because many scrub dependent species are now increasingly uncommon due to loss and fragmentation of their habitat (29). In light of this caution and the need to survey existing species, the council should have taken notice of the amateur mycologist who had alerted it to the presence of Solitary Amanita in Wild Park, an uncommon mycorhizal fungus that grows in mixed woodland on dry calcareous soils, the nearest official sighting being 25km away in woodland between Arundel and Patching (see E.4 in (30)). Then there is the loss of the many woodland and woodland edge birds that was also pointed out to the council, some of which like Nightingale, Whitethroats, Garden and Willow Warbler, and Yellowhammer are unlikely to find a home in the changed landscape. As this informant noted “All this loss just to gain a few butterflies?” (see E13 in (30)). I wonder why the ecological survey of Wild Park, belatedly carried out in 2011, is no longer available on the council's website?

The council’s failure to follow existing procedures

The essential dishonesty that characterises the persecution of Wild Park pivots around the report delivered at that scrutiny meeting, and the subsequent portrayals of the consultation process as having some meaning. There is an assertion in the report that the plans, presumably for the tree felling, were “assessed and approved in advance by Natural England under the Environmental Impact Assessment (Agriculture) Regulations 2006”. In the October 2010 newsletter, it is claimed that “All necessary approvals were obtained” (18). And yet before that newsletter was circulated, the council knew they were being investigated by the Forestry Commission for not having a felling licence, after a local resident had raised the issue with the FC a few weeks after the scrutiny meeting. The Review of Alleged Illegal Felling was published by the FC in November 2010 (31). Working months after the event, and with none of the felled material left on site, the FC had to calculate from stumps whether the council had complied with regulations on the diameter of trees and amount felled per quarter that would have been exempt from the requirement for a felling licence (Article 9 (32)). However, 229 oak trees above the legal minimum size had been felled, and with a total volume that was six times over the non-licensable limit.

The Review is very revealing in how the council regarded their obligation to comply with regulations arising from the Forestry Act. When looking through past correspondence, the FC found that the council had told it in May 2010 - and thus after the tree felling had taken place - that only scrub would be cleared from Wild Park, a representation of their activity that avoids regulatory scrutiny. Following completion of that scrub clearance, the council said they would then make an assessment of whether a Felling Licence Application would be needed for any further clearance. No complete application was ever received by the FC, just a blank application form. Thus the Recommendations in the Review were that action must be taken to avoid such incidents in the future and, because a warning letter would be inadequate due to the council’s failure to follow existing procedures, and which they were aware of, then a Restocking Notice should be issued to ensure the replacement of the licensable trees felled without a licence.

Deforestation, which this was, is regulated by Environmental Impact Assessment (EIA) before a felling licence can be issued. Since at that time, Wild Park was in an Area of Outstanding Natural Beauty (it is now in the South Downs National Park) then the area felled was above the threshold that would have required an EIA to justify the deforestation (33). The Review (and the report - see above) indicates that the screening process for an EIA had been completed by Natural England, which is very odd because their remit for EIA extends mostly to screening agricultural projects (which may include "clearing land")(34) and not to forestry. Moreover, a determination that an EIA is not required does not preclude the need for a felling licence, and felling trees is not the same as clearing land. In another twist, the council claimed that Wild Park can be considered an Open Space, and thus is exempt from felling regulations in the Forestry Act, which excludes the felling of “fruit trees or trees standing or growing on land comprised in an orchard, garden, churchyard or public open space”. The Open Spaces Act 1906 has the following definition (35):
“The expression ‘open space’ means any land, whether inclosed or not, on which there are no buildings or of which not more than one-twentieth part is covered with buildings, and the whole or the remainder of which is laid out as a garden or is used for purposes of recreation, or lies waste and unoccupied”

The Town and Country Planning Act 1990 has a similar definition of "land laid out as a public garden, or used for the purposes of public recreation, or land which is a disused burial ground” (36). However, the council can’t have it both ways, that Wild Park is used as an area of public recreation, when it was considered as agricultural land by Natural England in the screening process for EIA. Moreover, the inevitable Higher Level Stewardship (HLS) agreement (AG00299565) that was concluded between the council and Natural England would have required the council to have had a County Parish Holding (CPH) Number for Wild Park, or the application for HLS would not have gone ahead (37). CPH numbers are used to identify agricultural holdings where cattle, sheep, goats and pigs are kept (38). A CPH number is required by law to report livestock movements between locations, and is one means to help prevent the spread of livestock diseases. That there is a differential recognised between public recreational space and areas of agricultural activity on Wild Park is shown by the mapping for the HLS agreement, which excludes the area of playing fields in the valley - the area of public recreation that could qualify as Open Space - but includes the much larger areas of the dipslopes and where felling has taken place, thus categorising it as agricultural land. So why did the council think they could avoid applying for a felling licence when they knew that pursuit of the HLS funding would mean that large areas of Wild Park would be categorised as agricultural land and not Open Space? The pre-emption of the screening process for an EIA by Natural England strongly implies that the bootprints of their local officers were all over this illegal felling.

A disingenuous consultation process

Any consultation after the scrutiny meeting in June 2010 has to be seen in light of a petition of around 1,800 signatures that expressed opposition to both the works and the permanent fencing to create sheep paddocks in a public park. The necessity is then for the beleaguered conservation industry to contrive some bogus process that they can claim shows support for their proposals. In the timeline after the scrutiny meeting, the petition was received by the council before the October 2010 newsletter went out in which the facilitated workshops were advertised, but at least the newsletter acknowledged the issues of the petition, although it omitted the level of support that it had had (18). Thus the petition stated that the clearance work was destroying valuable habitat for wild birds and other flora and fauna, that barbed wire had no place in a public park, that sheep will curtail people’s freedom to use the park, and as such it should remain unfenced as open access space. The consequent workshops in late November, early December 2010 drew only 34 people, which was a poor return on the financial outlay of distributing the newsletter and paying for the facilitators, especially when several people attended more than one workshop (30). A further 18 emails that were received by the facilitators were appended in their report, some just saying they wanted to be kept in touch, others having cogent (and somewhat vehement) arguments for a cessation of the extent of harmful works.

I find it hard to draw any credible consensus from the data in the facilitators report, but the next newsletter, circulated in March 2011, suggests that as a result of the workshops and other comments received from residents, the draft principles and draft maps for the future management of Wild Park had been updated, and were set out in that newsletter (18). Since the original maps were not available, it’s hard to judge what updates there had been, but surely somebody should have realised that the area of unlicensed felling that was shown on the map given in the October 2010 newsletter had miraculously been repopulated with trees in the maps of the March 2011 newsletter. The latter newsletter also announced some public roadshows at which the draft plans would be displayed, as well as an online consultation that sought views on the five draft principles given in the newsletter, as well as some phased broad-brush actions.

The Management Plan, finally produced in May 2012, is claimed to have been “compiled following extensive local consultation where the overarching management principals received support from 69% or more of those who responded”. That statistic is derived from 51 responses to the online consultation, as well as 10 at the public roadshows, and 9 by e-mail (18). Let us remind ourselves that that consultation was not about the specific management actions in the Management Plan, but just about the overarching management principals. We can gauge the response to resumption of works proposed in this Management Plan by a report in the local press. James Parrot was shocked to see notices of the proposals when walking in the park in October 2012. He is reported to have said, in a letter to his local councillors (39):
“Your justification for this destruction and enclosure is the return of the park to ‘semi-natural grassland’ by removing large areas of ‘scrubland’. How can this woodland be described as scrubland? Since the end of the Second World War, Wild Park has gradually turned back to its natural habitat of first shrub and now woodland. Brighton and Hove Council should be proud that they have created an area of woodland ….These woodland areas provide much needed protection for small birds and mammals….. Brighton and Hove is not a large city. It is surrounded by grazing land and has very few natural woods. Why do they want to destroy this one?”

The measure of how disingenuous this consultation process has been is to recognise that the HLS funding agreement that covers Wild Park started on 1st April 2011, and thus within days of the of the March 2011 newsletter that announced the public roadshows and online consultation The agreement (AG00299565) covers Wild Park as well as number of areas around Brighton that the council presumably own, the council trousering £653,216 over the 10 years of the agreement. It would take a Freedom of Information request to find out the date that Natural England received the HLS application from the council, but we know from the grazing report approved by the Cabinet Member for Environment that the application was being worked up as far back as September 2009 (see above). It is thus highly likely that the council would have had a clear idea by the time of the October 2010 newsletter of what options and actions they sought under the HLS funding, as well as the Capital Budget they were seeking. They could not have modified that application in any significant way in response to consultation outcomes, because it was already drawn up and then submitted. They certainly knew that was the case, especially at the time of the March 2011 newsletter when the online consultation was announced, the results of which they trumpet so loudly. It would thus be an interesting exercise to compare the similarity between the HLS application and the subsequent Management Plan “compiled following extensive local consultation”.

In giving thanks to that early influence of Stephen Rowe, I bought his book a week ago. It was finally published in October last year, and with a title that shows that the fervour of his opposition against the actions of the conservation industry is undiminished – Conservation Controversy: A Factual Account of Conservationists Destroying the Environment (40). Imagine my surprise but delight that Stephen has Wild Park as one of his examples. It seems only fitting to give Stephen the last word. In a section of the book on Conservation and Manipulation, Stephen writes about how conservationists manipulate the facts about the environment to pursue their own personal agenda, how they promote traditional practices rather than pursuing good ecological science. After identifying the South Downs as a spiritual home of the conservationists, because of its grazed chalk land, a manufacturing of nature that they admire, he also describes it as the "conservation fraud centre" in Britain – “Conservation fraudsters have been conducting very effective frauds for some time now” because, he suggests, conservationists miss-inform about the ecology of the South Downs, a "lie by omission" in not giving a true historical account, and which suits their conservation farming projects. He then alights on Wild Park (40):
“Wild Park Brighton had to some extent escaped the ravages of the conservationists. However this could not last. The trees and wildlife had been spotted by psychotic conservationists. Looks nice doesn’t it. Yes a small remnant of semi-natural landscape that is surrounded by unnatural downland. So what did the ignorant moronic stupid councillors that run Brighton council do, they introduced the following: sheep destruction. Locals on the Moulscombe estate set up a petition to save Wild Park, however the morons who run Brighton council just laughed in their face: you can imagine the comments from the nasty councillors went like 'How dare they. We will make sure we ruin their Wild Park if it’s the last thing we do….Lets ruin their enjoyment anyway and turn it into the monoculture that the rest of the South Downs is”

Hyperbole though this may be from Stephen, and lacking censure of the council officers involved, it is a necessary redress to the overweening control of the conservation industry.

Mark Fisher 3 December 2013, 7 January 2014

(1) Willers, W.B., ed., 1999. Unmanaged Landscapes: Voices for Untamed Nature. Island Press ISBN 1-55963-694-7

(2) Fisher, M. (2005) A Walk in the Forest of Forgetfulness. Self-willed land April 2004

www.self-willed-land.org.uk/articles/forest_forget.htm

(3) Scott, D. (2001) “Untrammeled” “Wilderness Character” and the Challenges of Wilderness. Wild Earth. Wildlands Project. Winter 2000-2001

http://www.pewenvironment.org/uploadedFiles/PEG/Publications/Report/report_untrammeled_fall-winter-01-02.pdf

(4) Soulé, M & Noss, R. (1999) Rewilding and Biodiversity: Complementary Goals for Continental Conservation. Wild Earth. Wildlands Project. Fall 1999

http://www.michaelsoule.com/resource_files/167/167_resource_file1.pdf

(5) Foreman, D. (2000) The Real Wilderness Idea, Dave Foreman, USDA Forest Service Proceedings RMRS-P-15-VOL-1. 32-38

http://www.fs.fed.us/rm/pubs/rmrs_p015_1/rmrs_p015_1_032_038.pdf

(6) Vest, J.H. C. (1985) Will of the land: Wilderness among Primal Indo-Europeans. Environmental Review 9: 323-329

(7) Fisher, M. (2004) The Dignity of Wild Animals. Self-willed land February 2004

www.self-willed-land.org.uk/articles/wild_animals.htm

(8) Walker, M. (2002) Living on Wilderness Time. University of Virginia Press ISBN 0-8139-2109-0

(9) Fisher, M. (2005) Wildernesses of the Mind. Self-willed land January 2005

www.self-willed-land.org.uk/articles/wild_mind.htm

(10) Macfarlane, R. (2004) Where the wild things are. Guardian 30 October 2004

http://www.theguardian.com/books/2004/oct/30/featuresreviews.guardianreview35

(11) Stephen’s Green Page, Stephen Rowe

http://webspace.webring.com/people/es/stephenrowe/

(12) British Trust For conservation Volunteers, Stephen’s Green Page

http://webspace.webring.com/people/es/stephenrowe/BTCV.html

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http://webspace.webring.com/people/es/stephenrowe/tagcon.html

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http://www.sssi.naturalengland.org.uk/citation/citation_photo/1003165.pdf

(15) Fisher, M. (2005) Blacka Moor in peril from the conservation professionals. Self-willed land December 2005

www.self-willed-land.org.uk/articles/blacka_moor.htm

(16) Wild Park Defenders

https://www.facebook.com/pages/Wild-Park-Defenders/149387201890546

(17) Wild Park, My Brighton and Hove

http://www.mybrightonandhove.org.uk/page_id__8321_path__0p114p437p1556p.aspx

(18) Larkin, D. (2012) Wild Park Management Plan 2012-2022. Brighton & Hove Council May 2012

http://www.brighton-hove.gov.uk/sites/brighton-hove.gov.uk/files/downloads/countryside/Wild_Park_Management_Plan_2012-2022.pdf

(19) Friend, D. (2008) Pity the sheep in Wild Park. Letters. The Argus 24th September 2008

http://www.theargus.co.uk/opinion/letters/3699130.Pity_the_sheep_in_Wild_Park/

(20y) Agenda Item 49: Cityparks Downland Management, Report of: Director of Environment to Environment Cabinet Member Meeting, Brighton & Hove City Council 24 September 2009

http://present.brighton-hove.gov.uk/Published/C00000286/M00001849/AI00010792/$Item49CityparksDownlandManagement280809.docA.ps.pdf

(21u) Appendix 1: Individual site grazing plans for 2009/2010, Agenda Item 49: Cityparks Downland Management, Report of: Director of Environment to Environment Cabinet Member Meeting, Brighton & Hove City Council 24 September 2009

http://present.brighton-hove.gov.uk/Published/C00000286/M00001849/AI00010792/$Item49Appendix1.pdfA.ps.pdf

(22) Record of Cabinet Member for Environment Decision No: CMM70 – 24/09/09, Brighton and Hove City Council

http://present.brighton-hove.gov.uk/Published/C00000286/M00001850/AI00011245/$Item60iAppendixBix.docA.ps.pdf

(23) Grimstone, S. (2010) Scars on our parkland. Letters. The Argus April 2010

http://www.theargus.co.uk/opinion/letters/8086831.Scars_on_our_parkland/

(24) Nortcliff, N.C. (2010) The state of Wild Park. Letters. The Argus 30th April 2010

http://www.theargus.co.uk/opinion/letters/8131844.The_state_of_Wild_Park/

(25) Campaigners battle to save Brighton trees, Emily Walker, The Argus 3 May 2010

http://www.theargus.co.uk/news/8132719.Campaigners_battle_to_save_Brighton_trees/

(26) Agenda Item 6: Chalk downland restoration in Wild Park Local Nature Reserve. Report of Director of Environment, Environment and Community Safety Overview and Scrutiny Committee, Brighton & Hove City Council 21 June 2010

http://present.brighton-hove.gov.uk/Published/C00000138/M00002365/AI00015571/$Item6WildParkscrubclearance.docA.ps.pdf

(27) Table 2 Coverage of habitats, Annex 1 Background and Supporting information. Sites of Special Scientific Interest (SSSI): a notification strategy for England. Natural England November 2008

http://www.naturalengland.org.uk/Images/Notification%20strategy%20for%20web_tcm6-15235.pdf

(28) Mortimer, S.R., Turner, A.J., Brown, V.K., Fuller, R.J., Good, J.E.G., Bell, S.A. Stevens, P.A., Norris, D., Bayfield, N. and Ward, L.K., (2000) The nature conservation value of scrub in Britain, August 2000, JNCC Report 308

http://jncc.defra.gov.uk/page-2445

(29) The Scrub Management Handbook: Guidance on the management of scrub on nature conservation sites (IN124), Forum for the Application of Conservation Techniques & English Nature 2003
http://publications.naturalengland.org.uk/publication/72031

(30) Wild Park Public Consultation Workshop Results. Nick Wates Associates for Brighton & Hove City Council. 12 January 2011

http://www.nickwates.co.uk/reports/r&ppdfs/WildPark.pdf

(31) Review of Alleged Illegal Felling – Wild Park. Forestry Commission Region: South East England 7 November 2011

https://www.facebook.com/photo.php?fbid=160603434102256&set=a.159459130883353.1073741830.149387201890546&type=1&theater

(32) Forestry Act 1967 CHAPTER 10

http://www.legislation.gov.uk/ukpga/1967/10

(33) Environmental Impact Assessment projects and thresholds, Forestry Commission

http://www.forestry.gov.uk/forestry/infd-6dfl55

(34) Environmental Impact Assessments, Farming

https://www.gov.uk/environmental-impact-assessments

(35) Open Spaces Act 1906 c. 25 (Regnal. 6_Edw_7)

http://www.legislation.gov.uk/ukpga/Edw7/6/25

(36) Town and Country Planning Act 1990 c. 8

http://www.legislation.gov.uk/ukpga/1990/8/contents

(37) How to get started in Higher Level Stewardship, Natural England

http://www.naturalengland.org.uk/ourwork/farming/funding/es/hls/howtogetstartedhls.aspx

(38) Customer Registration - Frequently Asked Questions. Rural Payments Agency

http://rpa.defra.gov.uk/rpa/index.nsf/contentdocs/018D4B9233648D1D48025765C004EF7EE

(39) Clearance of Wild Park 'scrub' under fire. Ben James, The Argus 16 Oct 2012

http://www.theargus.co.uk/news/9987719.Clearance_of_Wild_Park__scrub__under_fire/

(40) Rowe, S. (2012) Conservation Controversy: A Factual Account of Conservationists Destroying the Environment. Kindle Edition 24 Oct 2012

http://www.amazon.co.uk/Conservation-Controversy-Stephen-Rowe-ebook/dp/B009WL11GK

url:www.self-willed-land.org.uk/articles/wild_park.htm

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

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