Independent Review of Protected Site Management on Dartmoor. Submission by Dr Tom Greeves

We are always keen to hear what Tom Greeves has to say about Dartmoor and were especially keen to read his submission to the Dartmoor Independent Review. Here is is in full.

Independent Review of Protected Site Management on Dartmoor

Submission by Dr Tom Greeves, MA PhD, Chairman of the Dartmoor Society 1998-2019

  1. My name is Tom Greeves. I was born in Plymouth in 1949 and have known Dartmoor all my life. It has been the core of my professional life as an archaeologist and historian. From 1979-1985 I was archaeologist to Dartmoor National Park Authority but have worked independently since 1990 as a cultural environmentalist. From 1998-2019 I was Chairman of the Dartmoor Society.
  2. The Dartmoor SSSIs and their criteria

The two largest SSSIs on Dartmoor (North Dartmoor and South Dartmoor) were created in 1952, and East Dartmoor in 1976, together totalling nearly 25,000 ha of accessible moorland. Their scientific criteria were restricted to the natural environment and geological features. 

  1. Why SSSI designation has created an imbalance in thinking about land management on Dartmoor

3.1 The scientific criteria of SSSIs are intrinsically valid, but are no longer fit for purpose as applied to Dartmoor. The fundamental change since the early 1950s has been in awareness of the significance of Dartmoor’s cultural landscape. 

3.2 In the early 1950s there was no perception of landscape having cultural significance –  only a few individual (usually prehistoric) sites were noted as being of national importance. 

3.3 There was no mention of culture in the purposes of national parks in the National Parks Act of 1949.

3.4 In the 1970s, for the first time, county-based Sites & Monuments Registers (now known as Historic Environment Records) were established by local authorities, and archaeologists began to be employed by national parks (I was the first archaeologist for Dartmoor National Park, appointed in 1979).

3.5 The 1970s coincided with increased grazing pressure on moorland due to headage payments to farmers, reaching a peak of cattle in 1985 and of sheep in 1990 (Mercer, 2009, 310). The result was the re-emergence of numerous prehistoric and other features that had been at least partially obscured by vegetation, and awareness that the whole landscape of moorland Dartmoor was of cultural significance. 

3.6 Although there was an increase in grazed moorland grassland, Dartmoor remained diverse in terms of vegetation and the grassland itself contained a mosaic of vegetation types.

3.7 Revealed was a world-class cultural landscape, with an unrivalled suite of prehistoric features, the finest tinworking landscape from medieval times onwards, besides exceptional stonecutting, peatcutting, military and other features.

3.8 Importantly, much of Dartmoor, at least in the 2nd millennium BC, must have been closely grazed grassland, in order for the often small-scale stone monuments to be seen. Likewise, in medieval times, tinners collected rainwater run-off from hillsides into reservoirs and this too would have required relatively closely-grazed moorland in order to function properly.

  1. The Environment Act 1995

4.1 In the Environment Act 1995, for the first time, national parks were required to include among their statutory primary purposes the ‘conserving and enhancing’ of the ‘cultural heritage’ of their areas, alongside natural beauty and wildlife. Thus, the expectations of society were formalised into the need for an holistic approach to land management, giving nature and culture equal weight. 

4.2 Dartmoor has the potential to contribute to the wellbeing of society as one of the most complete cultural landscapes in the world, with tangible remains of 6,000 years of human presence and activity, in symbiosis with its natural environment. 

4.3 In terms of research, education, recreation and stimulation of imagination, the cultural landscape must be considered equal to the experience of nature and wildlife in the same landscape.

4.4 The continuance of current overriding SSSI criteria for 25,000ha of moorland is completely at odds with this notion, creating an imbalance in thinking and management.

  1. Awareness of the failure of policies of English Nature/Natural England applied to SSSIs

5.1 Even before the introduction of Environmentally Sensitive Areas and the start of reduction in stocking levels in 1994, there was awareness among Dartmoor people that nature conservation policies as applied to Dartmoor had a particular and unwarranted emphasis on heather, and were being strongly influenced by the management of grouse moors in the north of England in Scotland, which gave heather moorland on Dartmoor a higher priority than it deserved. Professor Ian Mercer, in his book Dartmoor noted that ‘many ecologists will point to heather-dominated stands of vegetation as among the least species rich’ (Mercer, 2009,113).

5.2 Within a few years of 1994, due to fewer grazing sheep and cattle, farmers were already experiencing problems gathering animals due to increased vegetation (especially gorse and molinia), and tensions regarding monetary payments were causing rifts between commoners (Greeves, 2015, 29-32).

  • The  ‘overgrazing’ and ‘overburnt’ mantras

6.1 Often repeated comments, even now, about the vegetation of SSSIs and the commons of Dartmoor are that they are ‘overgrazed’ and ‘overburnt’.  Grazing and burning (swaling) are assumed by many to have caused changes in vegetation which did not fit the specific criteria that Natural England wished to apply, or thought they should apply, to Dartmoor. 

6.2 However, it is disingenuous of Natural England to continue to argue, after some thirty years, that ‘overgrazing’ and ‘overburning’ are still the causes of loss of heather, when their prescriptions required reduction of livestock of 70-80% on most commons, and very limited burning.

6.3 The reasons for the loss of heather specifically are probably complex and may include heather beetle infestation, warming of the climate, and also nitrogen deposition encouraging the growth of molinia. But the reduction of thousands of grazing livestock must be the primary cause of increased vegetation growth.


  1. Consequences

7.1 The failure of Natural England’s policies, supposedly based on sound scientific criteria, is stark, and should alert us to the possibility that those scientific criteria are flawed.

7.2 The consequences of thirty years of misplaced policies for the farming community are very severe, as graziers no longer have an incentive to put livestock on the moorland, and the whole structure of hillfarming culture on Dartmoor is at risk of collapse. 

7.3 At meetings of the Dartmoor Commoners’ Council, highly skilled commoners, whose families have generations of experience in managing the commons, have deplored the rigidity of Natural England and, sometimes, their bullying tactics, to the extent that some have expressed heartfelt despair in these public meetings, saying ‘we have destroyed our living’ and ‘we are indigenous people being pushed and pushed and pushed’ (Greeves, 2015, 30). 

7.4 Social and economic factors are supposedly outside the remit of SSSIs, but lack of attention to these is bound to lead to poor quality decision-making.

  • Gidleigh Common – the best case study

8.1 In 2018 the Dartmoor Society hosted a day event to discuss the condition of Gidleigh Common. Natural England staff, and commoners, were present, along with others. Presented in the report of the day (A Report on Gidleigh Common, Dartmoor, 18 July 2018) is some of the best and most compelling data of deleterious changes to the Common as a result of prescriptions by Natural England, and it can be considered as representative, at least in a general sense, of most commons on Dartmoor. The report is attached to this submission.

  • Conclusion and the Future

9.1 There has been a colossal scientific failure, extending over three decades, by Natural England in clinging to an assumption that heather should become the dominant moorland vegetation if animal grazing was reduced. 

9.2 Natural England has also failed to properly understand the benefits to society of the grazing pressure (so-called ‘overgrazing’) of the 1970s-1990s that revealed the full extent of Dartmoor’s outstanding cultural landscape, assisted by traditional burning (swaling).

9.3 For the future, society has the potential to create whatever Dartmoor it wants, but we need to understand what the Dartmoor landscape contains both in terms of nature and culture for the  wellbeing of society as a whole.  

9.4 If Natural England persists in sticking to the limited ‘natural environment’ criteria of SSSIs then they must support graziers to bring back stocking levels to what they were in the late 20th century, which should result, as before, in a mosaic of different vegetation types, including heather, reflecting the diversity of Dartmoor’s rainfall, soils etc. 9.5 Better still would be the recognition that SSSI criteria are no longer fit for purpose, and that new designations and new management thinking are required to combine culture and nature on Dartmoor for the greatest benefit to society as a whole.



Greeves, Tom (2015) ‘Dartmoor & the Displacement of Culture: Analysis & Remedy, Transactions of the Devonshire Association, 147, 1-44

Greeves, Tom (2018) A Report on Gidleigh Common, Dartmoor, 18 July 2018 (The Dartmoor Society)

Mercer, Ian (2009)  Dartmoor – A Statement of its Time (Collins, New Naturalist Library)


Tom Greeves, Penzance, 16 September 2023