Natural England’s Evidence to the Fursdon Review

Tony Whitehead, November 2024

In 2023, Natural England (NE) submitted evidence to the Independent Review of Protected Site Management on Dartmoor. This evidence was not made public by the Agency or the review panel and was obtained by an Environmental Information Request in 2024. 

Dartmoor Nature Alliance has today published this evidence. It provides a valuable and comprehensive description of the state of Dartmoor’s protected sites, the reasons they are in such poor condition, and the numerous issues NE has faced in carrying out its statutory duties to try to ensure the sites reach favourable condition. 

Protected Sites

Sites of Special Scientific Interest (SSSIs) are nature conservation designations that aim to protect areas of particular interest due to their unique flora, fauna or geological features. SSSIs often underpin Special Areas of Conservation (SAC) and Special Protection Areas (SPA), a European designation that marks them as internationally important. They represent some of the most valuable and vulnerable habitats in the UK. 

NE is legally responsible for designating, protecting, and managing SSSIs in England under the Wildlife and Countryside Act 1981 and subsequent legislation. NE must ensure the sites are maintained or enhanced through monitoring and sympathetic management, providing guidance to landowners, and issuing consent for any activities that might impact the site's special features. It has enforcement powers to prevent or address damage to SSSIs.

Similarly, landowners are legally required to prevent damage, seek consent for potentially harmful activities, comply with management agreements, allow monitoring access, and restore any damage to the site’s special features.

Dartmoor’s SSSIs are shown on this map. Each SSSI is declared based on “designated features” - the key habitats and species for which the site is nationally significant. On Dartmoor, this is mainly due to its blanket bogs, wet and dry heaths, and Atlantic oak woodlands. 

Each SSSI is divided into smaller units. The key focus of the review was the management of North, South, East Dartmoor, Dendles Wood, Tor Royal Bog, and Wistman’s Wood SSSIs, which in turn forms the Dartmoor SAC. This covers c25k ha (26%) of the National Park’s total area of 95k ha.

What “Favourable Condition” means for each SSSI is described in depth for each site. Here are the definitions of favourable condition for the designated features of North, South and East Dartmoor SSSIs.  Targets are given for both habitats and for species. For instance, on the heaths of North Dartmoor less than 50% of the previous year's growth of heather and bilberry should show signs of animal grazing (“browsing”) when surveyed (or less than 66% when it’s in a pioneer phase). If more than 50% does show signs of grazing, it’s classed as unfavourable. The key message from these documents is that “what good looks like” on Dartmoor is very well established. 

Site surveys are carried out by NE staff using tested methods based on the definitions of favourable condition. Pages 12-16 in this document give the years in which both site condition and overgrazing reports have been produced since 1993. Most have been assessed since 2013, and the majority within the last five years. This means we have a reliable view of protected site condition on Dartmoor. 

In short, the science is not in doubt. 

What the science tells us

The condition of Dartmoor’s SSSI units is given on this map and listed here. By area, only 6.62% of the SSSIs that form the SAC are in favourable condition. There’s a handy summary table here.  As the Fursdon review concluded, Dartmoor is “not in a good state”. 

NE summarise this exceptionally well here and are very clear on the reason why they are in a poor state:

The habitats and ecosystems on Dartmoor are in a significantly degraded condition.

This affects biodiversity and the ecosystem services they provide. These are ecosystem services that provide benefits to society beyond Dartmoor. 

The ecosystems have been in poor condition and declining for a long time but there is also evidence of more recent declines in some places. 

The main reasons for this are land management practices – draining, burning and overgrazing.

NE are also very clear in this document (p3) that additional external factors that are often stated to influence Dartmoor’s condition are not as important as the effect of land management practices: 

We are aware of the suggestion that external factors, such as climate change, air pollution and the impact of heather beetle have been significant causes of declining condition on the moorland SSSIs on Dartmoor. While we agree these factors have played a role, we consider that impacts of management are more important. 

So what is it about the land management practices that causes the damage?  In essence, this is twofold.

First, the poor condition of the blanket bogs and mires on Dartmoor is due to the degraded condition of the deep peat, which has been caused by historical drainage, digging, overgrazing, and deliberate burning (or “swaling” as it is known on Dartmoor, the use of fire to promote grass growth at the expense of species such as heather). The lowering of the water table resulting from these combined actions, plus a reduction in summer grazing by cattle, has favoured the growth of Purple Moor Grass (aka Molinia, its scientific name) on the bogs and mires, which has suppressed the peat-forming Sphagnum mosses. As NE state (p3 here)

The disruption of hydrological function in areas of blanket bog and valley mires combined with a reduction in early summer cattle grazing pressure has, we believe, favoured the expansion of Molinia. 

Second, the poor condition of the dry heaths around the peripheries of the moor is due to overgrazing, particularly by sheep in winter (who, with little else to eat, browse on the heather and bilberry shoots). This is well described throughout NE’s evidence, but there is a good summary here:

We have evidence from 30 years of agri-environment monitoring, 20 years of SSSI condition assessments and intensive overgrazing surveys from 1998 to 2010. These consistently show:

• Poor and unfavourable habitat condition. 

• Heavy grazing pressure on vegetation, particularly dwarf shrubs affecting vegetation structure, dwarf shrub structure and cover.

• Declining condition in many places. On some sites this has happened relatively recently. 

One particularly stark example of the ongoing effects of overgrazing is given in a 2023 report on the condition of South Dartmoor SSSI unit 61, Hen Tor and Willingwalls in the Upper Plym Valley.  This unit is in unfavourable declining condition. The survey revealed “significant grazing/browsing effect across habitats in the unit,” with:

The decline [...] greatest in dry heath samples in which cover was highest in 2013 at 29%, falling to 1.7% in 2023”.  

This isn’t a historical issue with overgrazing; this is contemporary. 

In short, the evidence shows clearly that the poor condition of Dartmoor’s SSSIs is due to: 

a) Degraded peat in poor hydrological condition plus lack of summer grazing by cattle on the central blanket bogs and valley mires, the symptom of which is extensive Molinia growth. 

b) Overgrazing on the peripheral dry heaths, particularly by sheep in winter. 

The Schemes

In the last few decades of the 20th C, Dartmoor farmers were subsidised per head of livestock to graze Dartmoor. These production subsidies, while supporting incomes, incentivised the keeping of large numbers of animals all year round on the Dartmoor Commons. This initiated significant overgazing and extensive damage to the protected sites (see above).

In response to this, the Dartmoor Environmentally Sensitive Area (ESA) was designated in 1994 and was operational from 1996. In NE’s words:  

This scheme, which had a very high uptake, offered incentives to encourage farmers to adopt agricultural practices that would safeguard and enhance areas of high landscape, wildlife or historic value. 

The Dartmoor ESA scheme ran from 1996 to 2005. As ESA agreements came to an end most local Commons Associations applied for the replacement Higher Level Stewardship (HLS) schemes. 

Local Dartmoor Commons Associations managed these different schemes in agreement first with English Nature, the precursor to Natural England, then later with the Rural Payments Agency, with advice from Natural England. Each association received public money in return for agreeing to manage stock numbers. This, in turn, was shared amongst those with commons’ rights, plus a percentage to landowners. 

These schemes (plus “cross-compliance” - what farmers were required to do to qualify for basic payments from the early 2000s) did help to control livestock numbers, but, as NE state:

There were significant reductions during 2000s because of cross-compliance and agri-environment agreements. These halted or reduced decline in many areas but did not result in recovery.

This is a crucial point. 

Under the schemes, the condition of protected sites has not (with a few exceptions) worsened significantly from an already poor baseline, but they have NOT recovered either. Millions of pounds of public money have been invested in schemes over the past thirty years. The 10-year Dartmoor Commons HLS agreements that started around 2010 alone cost the taxpayer £32M. But none of these have resulted in the restoration of nature. Ninety-three percent of the SSSIs in the Dartmoor SAC remain in unfavorable condition. 

Why has nature not been restored on Dartmoor’s protected sites?

In a nutshell two factors have prevented the restoration of nature on Dartmoor.  The first is the slow progress on peat restoration. One of the key ways in which you get a handle on the Molinia dominance on the blanket bogs and mires is to raise the water table.  The South West Peat Partnership has done some heroic work on this over the past ten years, for which they are to be commended, but not yet at the scale required. This is not a failure of agri-environment schemes as such; it’s more linked to available funding for what is expensive and challenging work. 

The second, however, is completely linked to the schemes, and it is simply that, despite agreements and supporting cash, the grazing regimes on Dartmoor have never been right to restore nature. NE evidence is frank about this (p53 here):

Typical HLS grazing calendars allow for ranges of numbers of cattle, sheep and ponies intended to provide commoners some flexibility in how they manage stock to meet scheme objectives. We often find that cattle numbers are maintained at the low end of these ranges with winter sheep at the high end, though decisions on stock numbers within the agreed maxima and minima appear to be driven by agricultural considerations rather than the requirement to deliver agreement outcomes.

The cattle numbers needed to graze the Molinia in summer have not been sufficient. NE gives this example (also p53 here): 

the Forest of Dartmoor agreement (11,000ha) [...] for the last 10 years has reported summer grazing levels at 70 to 80% of levels allowed within the agreement (from records collated by the agreement administrator). This combination of reduced cattle numbers and grazing cattle late in the summer has contributed to local undergrazing and an increase in Molinia.

Then, on the issue of sheep numbers, to quote from the same page: 

During the autumn, winter and early spring, Molinia provides little or no forage for sheep so any sheep on the commons in winter are forced to graze in other habitats. Hence there is a pattern of under grazing by cattle in some areas and overgrazing by sheep in others.

And the other areas that the sheep overgraze are the dry heaths, as NE says (p55 here): 

Sheep are selective grazers; in winter the growth of their preferred grass species slows / stops. When grass is not growing, any remaining grass rapidly loses its nutritional value and selective grazers like sheep turn their attention to other plants, especially heather and bilberry.

So why has this happened, given that agreements are in place and money is being paid?   Remember the evidence is clear on required grazing regimes; the key guide to this here (table one, page four).  

So what’s the problem on Dartmoor? 

NE summarises the factors that have contributed to the failure of agreements here.  I’ll run through these (in bold italics below) and provide extra background … all but one of these is cultural … 

With management dependent on co-operation between a number of commoners,

without appropriate governance, compliance with agreement requirements can rapidly break down.

As NE states here (p29): 

Dartmoor also has particular challenges that create resource demands, including a history of noncompliance, so some agreements have not been successful and in some cases, commons associations struggle to achieve internal consensus. These difficulties create extra demands on Natural England staff and take time to resolve.

In essence, according to the NE evidence, some commoners simply do not comply with the agreements.

The loss of trust and respect between NE and some commoners which impacts our

capacity to provide advice and support

One of the most depressing parts of NE’s voluminous evidence is this paragraph (p29) 

Successful agri-environment agreements are reliant on long standing professional relationships. It is true to say that there has been a breakdown in trust with some farmers on Dartmoor and our staff have also experienced some challenging behaviours from farmers. This has had the impact of constraining frank and open conversations. The reputation of the area within the sector has led to difficulties in recruiting and maintaining experienced staff. Confrontational behaviours between commoners and other farmers on Dartmoor does seem to stifle progress, as farmers try to adapt to a shifting context some more innovative and progressive voices are not confident to make themselves heard.

This is linked to the next issue …

The risk of a small number of voices dominating public debates. and stifling positive

Innovation

As NE describes further (p105 here) 

Barriers to active participation of all commoners may prevent more inclusive and broader based decision making. There needs to be space for a wide range of voices including those who do not currently take part in public debate: The dominance of the agenda by a minority is a barrier to change in itself. Improved facilitation and professional support to put commons associations on a more professional footing would improve governance and delivery of agreement commitments.

There is significant disagreement around the evidence base leading to misinterpretation and confusion on what management is needed and why.

In such a culture as described above, it is perhaps easy to see why there would be disagreement on the evidence base, especially if that evidence contradicts agricultural considerations rather than the requirement to deliver agreement outcomes. 

But the science is clear. As Professor Charles Tyler, a Fursdon Review Panel Member, said in a comment to ENDS report:  

“There is no issue with [Natural England’s] science,” he said. “The science is right,” 

Worryingly, in the same comment to ENDS, Professor Tyler said with regard to the Fursdon review that “quite a lot” of the science was “skipped over in panel discussions”.  

There is no shortage of science on Dartmoor - in their evidence, NE submitted a spreadsheet listing 606 papers, books, and journals related to the review, which excluded their own surveys carried out over the past few decades. But awareness of the extent of work already carried out appears worryingly low. Dartmoor National Park Authority themselves in their response to the review re-emphasised Fursdon’s calls for “the need for evidence to support management decisions.”

Yes, of course, there could always be more science; in his comment to ENDS Professor Tyler added for instance that there could be “more detailed information on how the condition of SSSIs is changing over time”. 

However, despite this, and despite questioning and disagreement, there already exists more than enough science to support NE’s evidence to the review, and to guide what action needs to be taken. Indeed, and tellingly, when the commoners themselves monitored SSSI condition … 

Where there was self-monitoring of SSSI condition by agreement holders their assessments tended to support the conclusions of Natural England’s assessments of condition. However, this did not result in adjustment of management or other interventions to improve the delivery of agreement outcomes, particularly nature recovery including SSSI condition. (p105 here)

Many of these areas are unfenced and targeted changes in grazing regimes are

difficult to maintain.

This is the factor in NE’s list that is not cultural in nature, it is simply a fact. Livestock does not recognise boundaries, and thus, targets for grazing on one common may be compromised by animals wandering from another common. 

NE’s response to this (p54) in their evidence is interesting: 

Where the adjoining commons are unfenced, the possibility that stock stray from one common to another must be accounted for and on agreement land it is the agreement holder’s responsibility to meet the prescriptions. To do this they must be able to manage any stray stock. It is acknowledged that unfenced boundaries present problems; however, the HLS agreement payments reflect the range of management demands on the agreement holders.

And further:

In HLS there is an agreement holder who, on signing the agreements, confirms that they have land management control so that the agreement prescriptions can be met. Unless there is agreement from all parties with rights to graze on the commons, it is unlikely that an agreement will be practical, because it will be impossible for a prospective agreement holder to confirm that they have land management control. 

It’s worth remembering that these schemes are voluntary. No one is forcing the Commons Associations to enter into an agreement.  But if they do wish to do so, they must be able to deliver what is asked in return for the public money they are given. A basic starting point is that those signing the agreement have control of their common. 

NE helpfully offers a solution: 

One possible solution is to manage several Commons together, for example, the East Quarter Commons with 5/6 commons all with habitat in similar condition is successfully managed as one block with allowances for straying between commons boundaries. This is possible as the stocking level on each common land unit is similar and several commoners hold rights and graze adjacent commons. 

However, if commons associations even struggle to achieve internal consensus on one common, it is difficult to see how consensus would be reached on multiple commons. 

What needs to be done?

On nature restoration, NE is clear: 

Recovery requires:

• Peatland restoration particularly the restoration of more naturally functioning hydrology.

• Significant changes to grazing management including reductions in stock on some sites and at particular times of year.

Simple enough in concept, but this, of course, belies all sorts of issues many economic, many social, and many cultural. Fundamentally, we need to be sure that taxpayers' money paid to commoners to restore nature is doing the job that’s intended. 

Previous schemes have clearly failed. As NE said publicly in 2023: “Despite the protection these designations provided, and the huge investment of public money in agri-environment schemes, wildlife has declined.”  Any new schemes or extensions to previous schemes must now follow the evidence and start to deliver visible positive change. We are in a climate and ecological emergency; we need to start seeing that change now; we are running out of time. 

For this renewed ambition is required on a considerable scale, and other voices need to be heard in this place, along with new approaches and solutions to restoring nature. 

To leave the final words to the NE evidence: 

Natural England is keen to work in partnership to develop and implement much more ambitious and innovative approaches to restore the health of the natural environment of Dartmoor in ways which also ensure viable farm businesses in a new era of public funding. There needs to be an evolution of land management business models to enable lower input lower output systems to be profitable, including financing of the transition. We would like the Review to help all parties by finding constructive ways to explore, decide on and implement the changes necessary for a positive future for farmers, farming and the environment of Dartmoor and to make clear recommendations to Government on the support system to enable what, for many, will be transformative change, for the benefit of wider society and in line with Government’s statutory goals for nature and for climate.

On Dartmoor investment is needed in building a very strong partnership, supported by governance that enables innovation, where evidence is understood and accepted and where public outcomes are fully rewarded.