Brief reports expressing our concerns about works to ‘rewet’ Dartmoor’s blanket peat have appeared in Newsletter 34, pp5–7 and 35, p13. A new phase of activity is about to be launched.
A 5½-page report went to Dartmoor National Park Authority on 8 January 2010, revealing that between £1 million and £1.3 million is to be allocated to Dartmoor National Park by South West Water towards a 5-year project commencing on 1 April 2010, now titled ‘Mires on the Moors Project’. The project will ‘develop plans for and implement restoration of around 110 hectares of blanket bog within the Forest of Dartmoor, in consultation with stakeholders.’
The report states baldly that there are areas ‘where erosion is seriously reducing the quality of Dartmoor’s blanket bogs’ and that ‘most of Dartmoor’s blanket bogs have been damaged or threatened by encroaching erosion’. We have requested data and evidence to support these statements and so far have been sent some rather unconvincing ground images. We are seeking further evidence to support these claims.
Dr Tom Greeves wrote to Dr Kevin Bishop, Chief Executive of DNPA, in January 2010 requesting formally that The Dartmoor Society should have representation on the proposed Project Board, especially as we are the only body to have organised highly relevant public debates on Dartmoor’s Vegetation (2006) and Dartmoor’s Water Resources (2008), as well as hosting a Research Lecture on ‘Climatic & Environmental Change on Dartmoor’ by Dr Ralph Fyfe in 2007 – all of which have been published in our Newsletter and/or website. He replied saying that he would be ‘keen to ensure that we find a mechanism whereby the experience, enthusiasm and contacts of Dartmoor Society members can be used to support and guide the Dartmoor Mires Project along with the views of other partners’, and said that he would discuss our formal request with funding partners in mid-February.
Of significant concern is the fact that existing works on Amicombe Hill and Blackabrook Down, and proposed works on Winney’s Down, are all ‘Works on Common Land’ and fall under the remit of the Commons Act 2006. Large quantities of timber are involved in making the dams (some 200 on Blackabrook Down alone), carbon-emitting vehicles are used, and the turf itself is partly broken to consolidate dams. Consent from the Secretary of State (via the Planning Inspectorate) is required (Commons Act 2006 Section 38) for ‘restricted works’ which include ‘any that prevent or impede access to or over the land. They include fencing, buildings, structures, ditches, trenches, embankments and other works, where the effect of those works is to prevent or impede access’.
Several graziers are very concerned about the impact of the dams on grazing, on the lears (traditional grazing areas to which animals are attached), and difficulties for movement of cattle and sheep through the newly wetted zones. There are also issues affecting archaeological features and general access for the public. Unlawful works under the Act include those that ‘could compromise the cultural, conservation or recreational value, or the openness of the common.’
On 2 December 2009 Professor Ian Mercer stated at a meeting of the Commoners’ Council (of which he is Chairman) that ‘the damming [on Amicombe Hill and Blackabrook Down] has not gone through the right legal processes’. Dr Tom Greeves wrote to Prof. Mercer on 9 December requesting ‘that the Commoners’ Council, as the statutory body with responsibility for management of the commons of Dartmoor, takes the lead in ensuring that formal application is made by all parties concerned to the Secretary of State for existing and any future planned works on the blanket bog of Dartmoor’.
Not surprisingly, Natural England apparently believes the works are exempt. However, this has not been put to the test and, under the Commons Act 2006, ‘Anyone undertaking exempt works must confirm that those works come within the terms of the exemption by posting a notice on site and informing the Secretary of State’. To our knowledge no such notice has been posted at Amicombe, Blackabrook or Winney’s Down. Under the Act ‘if works are carried out that go beyond the scope of an exemption, then any person may take enforcement action against them’.
We believe that application for consent for these works should be made. Under the Act, ‘Applicants must advertise their proposals and make copies of plans available for inspection locally so that the public can make representations’.
There is scope for a public local inquiry or hearing and it seems that such an inquiry would be appropriate in this case, given the scale of the works involved, uncertainties about their purpose and efficacy, and significant concerns among graziers and the general public relating to grazing, access and cultural heritage. We have no objection to the pure research elements of the project (e.g. dating of the peat) but believe the project as a whole is yet another instance of external bodies interfering on Dartmoor, driven by the availability of large sums of money.
The momentum derived from funding, the fashionable pursuit of carbon management and the ‘partnership’ label can, as appears to have happened in this case, lead to a high-handed and arrogant approach, lacking in sensitivity to the traditional users of the ground, and the land itself, which would not have been tolerated if another body had suggested such works on common land.
Professor Mercer is seeking further guidance and clarification from the Planning Inspectorate.
Meanwhile, we ask members to be alert to any advertised notices for consent, or exemption from consent, on the ground or in newspapers. We welcome any information regarding these notices or any comments from members regarding the project in general.