Response of the Dartmoor Society to “Protected Landscapes – Natural England’s Draft Policy for Consultation 2009”

1. The Dartmoor Society (hereafter ‘The Society’) was established in 1998 and now has more than 600 members.  It is not a ‘national park’ society but is ‘an independent voice for those who find Dartmoor a source of livelihood or inspiration’. Its charitable aims are educational in the broadest sense.
2. The Society notes [final para of ‘Context’] that the European Landscape Convention definition of landscape is claimed to form the basis of the approach to management of AONBs and National Parks in England, emphasising ‘the integration of people and nature over time, and the importance of involving local communities living in or near them in their management’. While applauding the principle, the Society finds that actual management, at least in the context of Dartmoor, falls far short of this ideal.
3. Paragraph 4 under ‘Issues’ states that the ‘character of designated landscapes is generally being maintained or enhanced’, based on evidence from the mid-1990s. The Society believes this statement is now woefully out of date as the management of the moorland areas of Dartmoor have reached a critically damaging state (especially in terms of hill farming culture, the cultural heritage and access – see below). There needs to be impartial research to assess the present condition of designated landscapes in terms of human culture as well as ecological health.
4. The Society believes (re paragraph 5 under ‘Issues’) that there is a fundamental problem with the ‘natural beauty designation criterion’ of protected landscapes and that this needs radical reappraisal and probably new legislation.
5. IUCN ‘Category V Classification’ (paragraph 8 under ‘Issues’). The Society is surprised at the claim that there is ‘insufficient attention to nature conservation objectives’ in protected areas. On Dartmoor the opposite is true, with ‘nature conservation’ dominating agricultural and land management policy relating to moorland, with a consequent detrimental effect on hill farming, on cultural heritage and on access, largely through a rapid overgrowth of vegetation. If a new principle was established that nature conservation should ‘take priority over other objectives in cases of conflict’ this would exacerbate the situation on Dartmoor and would undermine and limit ‘holistic’ approaches which integrate nature and culture. The Society believes that greater emphasis needs to be placed on nature conservation, and other conservation measures, in the ‘ordinary’ landscape and unprotected areas of country, town and city, in order to prevent so-called protected landscapes becoming ‘reserves’ surrounded by increasingly degraded landscapes.
6. Policy 1 – the mention (regarding England’s ‘nationally protected landscapes’) of ‘a healthy and accessible natural environment’ without reference to any other interests (e.g. cultural environment) is flawed as it has little meaning on the ground. The statement (para 2) that ‘England’s system of landscape designations affords the highest level of statutory protection for our nationally important landscapes’ is highly debatable. What precise protection does national park or AONB status bring? – on Dartmoor and elsewhere a ‘national park’ label has done nothing to protect hill farming culture nor has it prevented the calamitous overgrowth of vegetation on much of the moorland. There needs to be a debate as to whether national park and AONB designations are really appropriate in the 21st century when there is an urgent need to treat all land with equal care in respect of our natural and cultural heritage.
7. Policy 2 – the stated aim that protected landscapes ‘should demonstrate exemplary environmental management’ is a principle the Society supports but, within Dartmoor, despite 60 years of existence as a national park, this goal seems almost as far away as it was in 1951 (when Dartmoor was designated) with the national park being openly hostile to some environmentally sustainable enterprises, and having a very poor record on conservation of historic buildings (especially those of more recent  date), having a housing policy that has allowed a great increase in dwellings, and being generally ineffective when dealing with Natural England and/or DEFRA.
8. Policy 3 – the Society welcomes the acknowledgement of ‘the legally vague concept of “natural beauty” ’ (para 3). This should be done away with altogether as almost meaningless. What is meant by ‘a more transparent and meaningful duty of care’ (para 4)? 
9. Policy 4 – the Society welcomes the statement (para 3) that ‘the family of landscape designations cannot grow indefinitely’. There are far too many overlapping and confusing designations. What is needed is overarching legislation that protects every piece of land from inappropriate development by requiring a period of pause and rigorous analysis of information about the qualities that that land contains (in terms of ecology and culture in the broadest sense). As a starting point in the planning process there should be a presumption against development until its proposed benefits can be demonstrated as overriding any ecological and cultural values the land contains.
10. Policy 5 – Heritage Coasts. The Society has no specific view on this policy.
11. Policy 6 – the Society welcomes the statement (para 2) that ‘agri-environment schemes must be clearly working’. In the case of Dartmoor’s moorland, they have been disastrous in the past 15 years or so. Natural England and DEFRA should in future play a purely advisory role, assisting the Dartmoor Commoners’ Council. The latter has a statutory brief (under the Dartmoor Commons Act 1985) to manage the moorland, which is reinforced in Dartmoor National Park Authority’s Management Plan 2007-2012 (December 2007), p.31 which states ‘Under the Dartmoor Commons Act 1985, the Dartmoor Commoners’ Council governs the exercise of common rights, animal husbandry and vegetation management on the commons’. This seems clearcut, but Natural England and DEFRA have usurped this role and have applied quite inappropriate land management and husbandry policies (re grazing and burning) with (in the words of a Dartmoor hillfarmer) ‘total ignorance and frightening arrogance which has left a deep wound on both Dartmoor and the farming community.’
12. Policy 7 – European Landscape Convention. The Society endorses the need for ‘Exemplary management, knowledge and good practice’ of all landscapes, and advocates a radical change in the whole culture of management of protected landscapes. The Society believes that the very label ‘national park’ can lead to woolly, comfortable and mediocre thinking, and that there needs to be debate about removing it, as being both unnecessary and potentially damaging for the sound management of Dartmoor and the non-designated areas surrounding it.

Tom Greeves