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Tony Whitehead


“The fact that undergrazing is having a negative impact on the natural environment of various parts of the commons is supported by firsthand experience of council members, many of whom have worked the commons of Dartmoor a daily basis for much of their lives and continue to do so”

Report prepared by the Chairman of Dartmoor Commoners Council for a meeting on 4 December 2024 


I am in complete agreement with the chair of Dartmoor Commoners Council. 


Much of Dartmoor’s central Blanket Bogs, particularly on the Forest of Dartmoor Common (a huge area of the moor owned by the Duchy of Cornwall), are in very poor condition and have come to be dominated by Purple Moor Grass, aka “Molinia.”  


In Europe, blanket bogs are found primarily in the UK and Ireland, and Dartmoor is the southernmost location for this habitat. A blanket bog is a type of peatland that forms in cool, wet climates, covering large areas of land with waterlogged, acidic, and nutrient-poor soil. 

Natural England’s (NE) site designation details for North Dartmoor SSSI list one of the key pressures as “undergrazing”. In an extensive site check carried out by NE in 2019 the following is written in comments for the condition of the blanket bogs:


In most cases the driver of poor condition seems to be the expansion of Molinia in both mires and heaths and this may reflect a combination of insufficient grazing in the main growing season, but also probably the continuing effects of historical drainage and/or turbary, perhaps in combination with climate change and nitrogen deposition. 


This is very clear.  However, what’s important to understand is that Molinia is not actually the root cause of poor condition; it is a symptom that expresses poor condition. The fundamental cause of the blanket bogs not flourishing is the appalling condition of Dartmoor’s peatlands. 


This condition is largely due to historic peat cutting as well as historic overgrazing and associated management practices such as burning. This has caused extensive erosion and significantly altered the hydrology of the peat, lowering the water table, suiting the deep-rooted Molinia and allowing it to outcompete the mosses that do not thrive when the peat is degraded. Read more here about all this. 


The grass is then given a further boost both by nitrogen deposition - it basically rains fertilizer on the moor - and an element of climate change.


The Molinia, favoured by the eroded peat, has “swamped out” what should be the key features of a healthy blanket bog – sphagnum, heathers, cotton grass, sundew, and so on. Anyone who regularly walks up there can see this or experience it while stumbling through knee-deep Molinia tussocks! 


And “undergrazing”?  How does that fit in? 


Molinia is a bit of an odd grass in that it dies back entirely in winter and, therefore, is only palatable for livestock in the spring and summer months. Sheep largely avoid it (with, I’m told, the exception of a few specialist hardy breeds such as Hebridean sheep, of which there are very few on Dartmoor). 


Cattle and ponies, however, will graze it in the warmer months, with the additional benefit that their pulling and trampling of the sward can open up the ground between tussocks to allow other plants to flourish.  But they have to be encouraged to do this as Molinia is not top of their list of favourite grasses - if they are not encouraged, they tend to avoid it, and you end up with “undergrazing” in areas where the grass really gets hold.  


Two things are therefore necessary to restore the blanket bogs and get a handle on the Molina. The first is to rewet the peat; the second is to actively encourage cattle to graze it in Summer.  Problem, solution – great. Restoration works to rewet the peat have been taking place since 2009 and great work is being done. But what about the grazing? 


Cash for Cattle


In May 2012, the then-Defra Secretary of State, Caroline Spelman, proudly announced the launch of the Forest of Dartmoor Common Higher Level Stewardship (HLS) Agreement. As the Government press release said:


The Dartmoor agreement is one of the largest agri-environment agreements in Europe and is part of Natural England’s Environmental Stewardship Higher Level Scheme, which is funded by the EU and UK Government.  The annual payments will help to safeguard a viable future for the commoners on Dartmoor, as well as delivering habitat enhancement of blanket bog, upland heath and species rich grassland habitats.


It agreed to pay £13M over ten years to Dartmoor commoners with grazing rights on the Forest Common. In return, the taxpayer who was funding this would get healthy blanket bogs and so on.


Central to delivering “enhancement” was a plan for dealing with the Molina. In 2021 I asked to see the agreement and was sent the then latest version. It’s long, but you can read it here. The agreement is clear (p56) about the need to tackle the Molinia, not just because it’s affecting the condition of the blanket bog, but the knock-on effect it’s having of forcing stock elsewhere, particularly when it’s unpalatable. This leads to overgrazing of the outer commons.


The plan is then clear (also p56) about what needs to happen:


To help address this we first need to break up the dense Molinia thatch that prevents stock accessing the areas and protects the new growth from being grazed whilst it is palatable. We then need to graze the Molinia to prevent it reforming the thatch.

We propose to encourage cattle into the Molinia dominated areas using feed blocks/buckets, molasses, cobs or lumps of rock salt to trample the vegetation and create tracks.


And that to help further to get the stock in the right place:


Increased shepherding will take place to ensure livestock use the tracks created by this plan and graze/trample the Molinia around the tracks to break up the Molinia thatch and improve biodiversity.


It was also determined that “Cattle will be the only or main grazing species from 1 May to 31 October. They will comprise at least 50% of the livestock unit grazing days on the parcel.” (p50).  To support this, a special cattle grazing supplement (code HR1) was agreed. In 2021 and 2022, the commoners, via the Commons Association, were paid each year £390,360.25  for this cattle grazing supplement (p5 of the agreement).


This is precisely what is needed to help deal with the Molinia. Very detailed stocking calendars were drawn up for each management area within the Forest Common to guide this. I was sent these via another EIR request in February 2025 and you can read them here.


On the Forest Common, it was agreed that starting in May, there were to be 1672 cattle (including heifers), rising to 2226 in July and 2079 in August and falling back to 1372 in October before the animals were taken off. Properly shepherded, this should have been more than enough to start dealing with the Molina.


Where are all the cattle?


The Forest of Dartmoor Common site check of 2019, seven years into the agreement, gave no indication of any resulting improvement to the state of the habitats. The site check results were sent as part of an EIR request, and you can read them here, but the key finding was:


Cover of Purple Moor-grass (Molinia caerulea) was estimated in the area surrounding each quadrat. The average recorded cover across all habitats was 55%. This breaks down to Bogs 60%, Dry heath 35%, Wet heath 56%.


That’s a lot of Molinia still, especially on the bogs. The supposition being:


[The] figures are all consistent with insufficient grazing during the period when Molinia is more palatable and the consequent shading and build-up of thatch are likely to contribute to all of the more significant attribute failures…


Further:


Around half of all quadrats showed some evidence of grazing, though in many cases this was just a few nibbled stems, some dung or hoofprints of indeterminate age. Only eight quadrats had “many” livestock nearby, fourteen had “several”, twenty-six had “few” and at the remaining ninety-two stops no livestock were visible nearby.


This survey was carried out in August 2019.  Dartmoor is a very open landscape. There should have been 2079 cattle on the common.  And yet at 92 stops, picked at random, “no livestock were visible nearby”. 


Where the surveyors were seeing stock:


Early indications are that the majority of those areas where many or several livestock were noted were on lower ground in the north and east of the North Dartmoor units and in the northwest of the South Dartmoor units (i.e. sheltered areas closer to farms).


To summarise, while there were some cattle out on the common, there were very few on the Molinia where they needed to be. Hence, the “insufficient grazing.”


The NE area team picked up this issue with the Forest of Dartmoor Commoners Association in an email sent in September 2019 (also obtained through EIR Request, available here p22):

I have no further emails, so I don’t know the outcome of any meetings. However, five years later, this same issue is referenced in NE’s evidence to the Fursden Review in 2023 (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.


In essence, this is saying that there is a percentage allowance in the stocking calendar, and the cattle put on the moor have always been at the low end of that allowance. And this has contributed to the increase in Molinia. 


Further, and crucially:


… 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.


What is to be done?


There has been a lot of criticism that NE is “anti-grazing”. However, here, on the largest of the Dartmoor Commons, a very well-funded agreement has been in place for over a decade precisely to encourage grazing with the right numbers of cattle at the right time of year to deal with the Molinia. But it appears according to NE’s evidence, that some of the commoners' “agricultural considerations" have meant that the right cattle numbers may have never really been put in the right places. 


As we move forward, with the new Dartmoor Land Management Group now convened, it’s vital that we examine how much these “agricultural considerations” are a barrier to nature’s recovery on Dartmoor and what needs to be done to address this. 


Dartmoor’s priority is how it can deliver on nature and carbon. Money and support must be made available to those with the skills, imagination, understanding, and willingness to tackle this.  This can work and benefit everyone. But nature has to be put first, and if public money is going to be used, it must only be paid where it can evidenced to be focused on the delivery of outcomes for nature recovery. And agreements must only be signed if it is certain those signing can deliver the work.



 
 
 
Restored peat near Whte Horse Hill in summer; photo by the author
Restored peat near Whte Horse Hill in summer; photo by the author

Tony Whitehead describes the huge value of Dartmoor's peatlands. This article first appeared in West Country Voices in 2021 and has been updated.


According to the International Union for Conservation of Nature (IUCN), the remaining area of near-natural peatland (more than three million km²) globally contains more than 550 gigatonnes of carbon. This is 42 percent of all soil carbon and exceeds the carbon stored in all other vegetation types, including the world’s forests. However, the first global assessment of peatlands published in February 2025 found that only 17% of the world's peatlands are in protected areas.


On Dartmoor, as elsewhere, peat started to form shortly after the end of the last ice age 12,000 years ago. The rate of deposition altered with changing climates, with more being laid down in wetter times such as towards the end of the Bronze Age, but on average each year adds one millimetre to its depth. The deeper the peat, the greater its importance in storing carbon. Peat over 40cm deep covers around 15,800 ha of Dartmoor and it is estimated this stores 13.1 megatonnes of carbon.


For this reason alone, the peat in the National Park is probably its greatest single asset.


And this is just the carbon; peat is also of high value for its wildlife. The habitat most closely associated with deep, wet peat in the uplands is blanket bog. This is well known to all walkers on the high moor; it’s the wet, jelly-like land that makes wellies the favoured footwear at any time of year. Blanketing the ground, in the valley mires and on the gentle slopes amongst the grasses are the rich greens and reds of the sphagnum moss. In high summer the bogs come alive with the yellow blossoms of asphodel, the white cotton grasses and tiny carnivorous sundews. These places provide a home to specialist animals such as dunlin and snipe, both wading birds that enjoy the wet conditions. It’s a rare habitat globally.


However, sadly, peat is an asset that’s in a very poor condition. To understand why, it’s worth looking first at how blanket bogs form.


Blanket Bog Magic


Peat forms when plant matter is unable to decompose completely. This occurs in naturally cool, wet areas such as Dartmoor, where rainfall is particularly high. In such watery conditions the normal rates of plant decomposition are slowed because of lack of oxygen. Organic matter is laid down faster than it can decompose, and this is how the peat forms. One of the key constituents in the formation of the bogs are the sphagnum mosses that thrive in these wet conditions. The roughness and water-retaining ability of this mossy surface vegetation naturally slows the flow of water off the bog. Also, the high moor’s only water input is from overhead rain – which makes it very low in mineral nutrients (hence the need for the sundews to supplement their diets by ensnaring flies).


So the key thing with peat is that it needs to be constantly forming, and crucially, to achieve this, it needs to be wet. Anything that hinders its formation and its “wetness” is a problem. Historically two things have done this: firstly it’s been extracted as a resource, and secondly, it’s been ‘managed’ in a way that causes the peat to dry out and erode.


Deep peat damage


Peat has been dug, or ‘cut’, on Dartmoor for hundreds of years. It’s a handy fuel source, akin to coal. It was used domestically, and it fuelled the tin industry through its boom times, particularly in the Middle Ages. In a charter of 1201, King John confirmed the privilege of ‘digging tin and turves for smelting at all times’ to Dartmoor tinners. Peat was converted into charcoal by specialist workers known as carbonarrii. In the 19th and early 20th century, there was also experimentation in using peat to distil naphtha oils for use in gas production or for the manufacture of candles.


The peat was also cut to drain land for agricultural improvement, and in places it was cut to create the well-known Dartmoor ‘peat passes’: drier tracks through the blanket bog. The peat on the northern part of the moor was also ‘extracted’, in an explosive manner, by the military, via artillery, mortars and grenades.


The extent of historical peat cuttings is quite significant, as can be seen in the map below, where they are shown in purple. In short, the peat on Dartmoor has been much exploited.


Although the cutting of peat is perhaps the most obvious cause of damage, peat has also been mismanaged in other ways. Wherever peat is exposed – wherever there is bare peat – it will dry out and erode. The areas of bare peat (or ‘peat pans’ as they are known) on the northern part of Dartmoor are shown in black on the map below.


Bare peat is caused mainly by human activity. Peat can be exposed simply through overgrazing. From the 1970s through to the late 1990s, much of Dartmoor was heavily overgrazed, and even today, when livestock numbers are lower, there are still parts of the moor that are under pressure from too many grazing animals.


Related to grazing is the exposure of bare peat through fire, particularly regular and deliberate burning by farmers, known as ‘swaling’ on Dartmoor. Swaling is an ancient tradition, going back hundreds, if not thousands, of years. It is done to encourage the growth of grasses for livestock to eat. However, if it is done intensively and regularly, it is a disaster on deep peat. Not necessarily because it burns the peat itself (although that can happen), but because regular ‘burns’ change the surface vegetation, from peat-forming plants such as the mosses that blanket the ground, to an open mix of grasses and bare peat.


Carbon catastrophe


Once exposed, the direct forces of warm sunlight and cold nights on the peat’s surface causes it to dry and oxidise, emitting significant amounts of carbon (CO₂) into the atmosphere. To put this into a global perspective, according to the IUCN, “Damaged peatlands contribute about 10 per cent of greenhouse gas emissions from the land use sector. CO₂ emissions from drained peatlands are estimated at 1.3 gigatonnes of CO₂ annually. This is equivalent to 5.6 per cent of global anthropogenic CO₂ emissions.”


And in the UK context, according to the government’s November 2021 Net Zero Strategy, “In 2019, peatlands emitted 4 per cent of UK net greenhouse gas emissions.


Then also, through the action of rain, peat is lost into our rivers, washing off rapidly – without the rough surface vegetation to hold it back – and causing deep erosion gullies and ‘hags’ (mounds of uneroded peat between erosion sites). These gullies – particularly evident on the high moor – in turn lower the water-table locally, causing more drying and exposure in a vicious cycle that leads to the bogs becoming less and less able to function and hold water. You can see the extent of erosion gullies near Hangingstone Hill marked in yellow and red on this map:


This breakdown in the ability of the bogs to slow the flow of water leads inevitably to higher rates of flow in the rivers that lead off the high moor, increasing the risk of flooding. Additionally, it costs all water-users millions of pounds through water charges, to clean the water of the peat material.


It’s clear, in summary, that Dartmoor’s peatlands are in poor condition. But restored, they could be hugely important locally and nationally, in terms of storing carbon, benefits to biodiversity, and as a ‘nature-based solution’ for issues such as flooding and the provision of clean water. The UK’s Natural Capital team stated in 2019 that restoring just “55 per cent of peatlands to near natural condition is estimated to have a present value of approximately £45bn to £51bn.”


It’s impossible for the UK to achieve its net zero ambitions without extensive peatland restoration.


The solution


The theory is simple. The peatland needs to be ‘rewetted’. It needs to be brought back into a condition where the natural surface vegetation is restored and the bare peat covered. To do this, the water must be prevented from rapidly running off through the erosion gullies. And to achieve this, the gullies need to be blocked with dams. Just slow the flow. And that’s it!


The practicalities, though, are enormously challenging. The first challenge is that the work is being done in a very remote place, so the people and machinery that are building the dams need to find a way to get in. To avoid disturbance to wildlife during spring and summer when birds and other creatures are breeding, the work has to be done in autumn and winter – the toughest time of the year to be on the high moor. The machinery has to be of a special type that avoids putting huge pressure on the ground and potentially adding to the peat’s problems, and indeed the operators’. This means using ‘wide track’ machines that are remarkably light on the ground (pound for pound, they exert much less pressure per square inch than you or me).


The work also has to consider archaeology. Dartmoor is one of the finest bronze age landscapes in Europe, and for this reason, restoration efforts must involve qualified professional archaeologists to ensure nothing is damaged. But it’s also worth remembering that the peat itself is important archaeologically. The paleoenvironmental record contained in peat is very important, and this is lost as the peat degrades. The peat also physically supports many features classed as ancient monuments, and erosion is a real threat to their stability.


The work also needs to consider unexploded bombs. The high moor has been used for military training for a hundred years, and this has left a deadly legacy. So before any work takes place, the land is carefully checked.


Peatland restoration is a huge task. To restore just one area of peat requires putting dams across many, many erosion gullies. The ‘before’ and ‘after’ illustration below demonstrates this: each black dot on the second diagram is one of the pools that forms behind a peat dam.


We’ve only just begun


Despite the challenges, peatland restoration work is underway. On Dartmoor it is being delivered through the South West Peatland Partnership, formed in 2009, and locally led by Dartmoor National Park Authority, Natural England, the Duchy of Cornwall, Dartmoor Commoners’ Council, the Environment Agency and South West Water, and informed by the very best science through the University of Exeter.

Restored peat at White Horse Hill in winter; photo by the author
Restored peat at White Horse Hill in winter; photo by the author

There is considerable work being done with 1,205ha under restoration since 2009. with 947ha of restoration works carried out between 2020 and 2024. It is estimated that this 947ha alone will save 356,186 tonnes of CO₂ equivalent over 50 years. This is enormously good value for money, especially when compared to other means of decarbonising the economy. The presence of the blanket bogs as a nationally important habitat also underpins the many farm environment schemes on the moor, making sure that the peat has a real value to the local economy and its farmers and land managers.


All round, peat restoration is one of the cheapest ways by which we can mitigate climate change, restore nature, support the local economy and ensure water quality. Who wouldn’t want to make the most of that! However, the hard work and restoration efforts to date represent just 7.6 per cent of the total deep peat on the moor. We have to do more – a lot more – and provide the necessary money and resources.


Dartmoor is loved for many things: its landscapes, its rural traditions, its archaeology and the space it provides for millions of people to escape into the open air. This was the driving reason for Dartmoor being declared a National Park in those heady and optimistic post war years when people demanded a better life for their sacrifices in WW2.


A better life for future generations rests on the decisions we make now about tackling climate change, the biggest existential threat any of us have ever faced. We must make the right choices, and on Dartmoor that means getting on and restoring all the peatland. National parks, landscapes, rural traditions, archaeology, space, mean nothing on a dead planet.

 
 
 

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. 



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.













 
 
 

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