Revised Comments on the Draft Dartmoor National Park Management Plan 2020–2025

The revised comments below were recently submitted to Dartmoor National Park by our Acting Chairman, Alan Endacott, as The Dartmoor Society’s official response to the Management Plan Review.

The Dartmoor Society broadly supports the vision underpinning the Management Plan and we feel that the overall balance of the Plan itself is fair and demonstrates a genuine willingness to consult with interested parties and to listen to their views. 

It should be stated at the outset that we agree on far more than we disagree on and that the following comments should, therefore, be seen in that context. Where no comment is made on a specific topic or proposal it should be assumed that we are broadly in agreement.

Climate Change

We congratulate the Authority on its own efforts to become carbon neutral by 2025. However, while Dartmoor itself has much to offer in mitigating the effects of climate change regionally, we see certain risks in Dartmoor being seen as the carbon sink for the rest of Devon, especially when it comes to investment from conscience-driven carbon offset schemes. Such activity (such as mass tree planting on peatlands or open moorland) needs to be carefully planned and controlled in order to derive the greatest benefits and to avoid unintended knock-on consequences rather than being largely driven by available funding.

We have similar reservations about some of the current ‘upstream thinking’ policies, including the damming of streams and peatland ‘restoration’. The Society still disputes the historical context of peat denudation on the uplands. We do accept that there are clearly potential carbon gains and other environmental benefits from the consolidation of blanket peat cover but only where it is clearly demonstrated that nature needs a helping hand. We remain opposed to the current overly invasive methodology. Instead, we would prefer to see a softer, more phased approach to the work, for instance, the manual placing of pre-seeded sphagnum in biodegradable nets to form dams and shallow pools to encourage the gradual establishment of sphagnum bog over a greater area, rather than the current use of excavators and intrusive dams that risk releasing more harmful methane than the carbon gains are worth and create deep pools, with the attendant physical and health risks to wildlife and livestock.

With regards to sustainable transport, although there is going to be an increasing demand for vehicle charging points and other infrastructure to accommodate low-carbon transport, it will prove almost impossible to cope with the sheer predicted numbers of electric vehicles in the future and we feel the Authority should take bold steps, along with public and private partners, to aim for a fully integrated public transport system to reduce the number of visitors arriving in cars as well as helping local communities to reduce their car usage. For instance, a network of affordable ‘Park and Ride’ facilities around the outskirts of the National Park, operating with low-carbon buses. Dartmoor could become an exemplar of what can be achieved.

When public infrastructure improvements are considered to provide low-carbon facilities, these should not be limited to vehicle charging points and other technologies, such as hydrogen, should be taken into account, especially around the periphery of the National Park. Flexibility should be built in to any project plans to take account of new or emerging technologies and the specific needs of Dartmoor communities, which will, of course, be quite different to more urban areas, should always be taken into account. 

We welcome the National Park’s commitment to reducing energy consumption through improved building efficiency and the use of small-scale renewable and low-carbon energy technologies and hope that the resources can be made available to back this up. Given that much of Dartmoor’s existing housing stock is of traditional construction and few rural settlements have access to mains gas, there is significant fuel poverty and insulation and heating bring particular challenges, especially with the current high costs of renewable technologies and planning restrictions on their introduction in a National Park. In recognition of this, it would be helpful if there were a specific scheme, administered by the National Park Authority, to draw on Government incentives and advice for home owners and landlords, to take account of the special circumstances of the National Park. 

Better for the Next Generation

While we welcome the aim of including young people in decision making, we feel that this is an issue that relates to all ages with respect to the lack of democratic representation of residents on the National Park Authority, in particular relating to planning issues. However, we acknowledge that this is beyond the scope of this Plan and recognise the willingness of the Authority to listen to the views of all stakeholders in order to shape their decisions.

We share the concerns regarding affordable housing, jobs and skills and would welcome any practical encouragement of traditional skills and knowledge being passed on as well as the other ideas put forward.

We regret the loss of County Council ‘starter farms’ within the National Park and the opportunities they provided for young farmers to get established. If it isn’t already, this kind of opportunity should be borne in mind in relation to Duchy tenancies, with a certain quota specifically for young farmers starting out. How this could be subsidised could be the subject of the new ELMS principles.

Part of the process of young people learning about what is special and how to help conserve and enhance it should be to encourage dialogue with the older generation in order to perpetuate the cycle of received wisdom and experience that is so often overlooked by decision makers who, thus, either re-invent the wheel or repeat the mistakes of the past.

We are a little uncomfortable about the idea of waymarked routes. This can be achieved in theory using GPS technology without the need for intrusive way-markers but, in any case, a big part of the Dartmoor experience is learning how to map read and to enjoy orienteering and using one’s other senses and these skills should be encouraged in younger people rather than risk being overly protective.

Better for Nature and the Natural Beauty

There is possibly a need to define what is meant by ‘natural beauty’ as much of what is popularly seen as the ‘wilderness’ of Dartmoor is, in fact, the product of human intervention over thousands of years. While we accept that there is an important place for nature reserves and a patchwork of different habitats with different degrees of management, if left totally to nature, much of Dartmoor would become inaccessible and it is important that this message gets across to the wider public. 

For instance, there is a tendency for people unfamiliar with Dartmoor’s history to misconstrue the meaning of the historical term ‘Forest of Dartmoor’ and demand that trees should be re-planted on the uplands in order to ‘re-wild’ it. Apart from the fact that broadleaved trees would be unlikely to grow in the prevailing soils and conditions, they would be nowhere near as efficient at carbon sequestration as peat. 

Presumably the proposed landscape-scale ‘nature recovery areas’ will involve the exclusion of people and livestock? We are not necessarily against the principle where there is a clear and demonstratable need but we would be interested to see any specific proposals in due course.

There is also a strong case to be made for bracken and gorse clearance/control and a return to pre Foot and Mouth stocking levels and allowing and encouraging appropriate overwintering of cattle once more in order to reverse the current overdominance of bracken, gorse and Molinia in many areas and to restore the previous biodiversity through better management of the commons by livestock. Bracken is especially problematic in connection with the spread of Lyme disease but also hides (and may even damage) archaeological remains for much of the year, is poisonous to livestock and carcinogenic.

We are supportive of the coordinated approach of the Dartmoor Fires Partnership to tackle the increasing risk of wildfires. However, prevention is clearly the best policy and we would like to see a similar approach to controlled swaling of the commons, providing individual commoners associations are fully involved and in agreement. We believe that, as well as a more strategic approach being applied in order to control vegetation and reduce the risk of wild fires in the first place, a more flexible approach is needed within the overall agreed framework, for instance, where the weather prevents planned burns or an outbreak of heather beetle is noted. 

Better for Cultural Heritage

We applaud the emphasis placed on Dartmoor’s cultural heritage and, in particular, the desire to see that the significance of Premier Archaeological Landscapes (PALs) is recognised by other agencies and given a degree of statutory standing. We would like this to have a similar weighting to SSSIs and other conservation designations. However, we note the reference to potential conflicting priorities and the need for a process for assessing strategic environment priorities to guide decision making in relation to other conservation objectives. We trust that extreme caution will be exercised when setting priorities and precedents and that there will be appropriate consultation with all interested parties.

We welcome the principle of a rolling survey of listed buildings and quinquennial buildings at risk survey and hope that sufficient resources are made available or sought to assist the process and to help with any remedial conservation work required, in partnership with owners and other agencies.

Dartmoor’s international importance to prehistoric archaeology deserves a corresponding level of resource. The encouragement of pro-active research into the Moor’s cultural heritage is very welcome, as is the ongoing work with local communities and volunteers. 

As this Plan is about vision, ultimately we would like to see it go further and recognise the ecocultural value of all of the open Moor by abandoning distinctions between what is considered to be of particular ecological or cultural merit and the often arbitrary boundaries of SSSIs, PALs and other statutory designations, in favour of a single ecocultural designation in full recognition of the equal and symbiotic value of both. We would hope that this would ensure a more even distribution of resources and management to a consistent high quality. 

Better for Farming and Forestry

We are broadly happy with the general principles and aims set out in the Management Plan – subject to the previous comments regarding winter grazing for cattle and the need to redress the balance due to under-grazing, the lack of timely swaling on many commons over recent years and the consequent over-dominance of various species (including bracken, gorse and Molinia). The rise of Molinia in particular has knock-on consequences for the environment as the dense thatch effect produced when it dies down in the winter increases run-off and reduces the ability of the soil beneath to absorb carbon.

As well as recognising the conservation benefits of sustainable farming, we also feel that due consideration should always be given to the importance of home food production over importation, with its additional food miles and ethical considerations, such as forest clearance, the local impact of cash-crop production in the developing world and often poorer animal welfare standards. Taking good farmland out of efficient production here will inevitably have a knock-on effect on other parts of the world and this aspect should always be part of the carbon offset equation. There is little point in planting thousands of trees on good pasture land for instance if a similar area of rainforest is being cleared in South America in order to produce beef for export to the UK on a carbon-fuelled freighter!   

The bottom-up approach to the Farming Futures and Dartmoor Hill Farm Projects is an exemplar of what can be achieved in partnership and it would be good to see this extended to the whole of the National Park, or the commons at least.

The detailed delivery of these aims and policies will, no doubt, be the subject of much discussion between farmers and the various agencies involved over the life of the Plan and as the post-Brexit situation becomes clearer. The Dartmoor Society will be pleased to take part in such discussions where appropriate and helpful. We have a Hill Farming Sub-committee, looking in more detail at issues affecting farming in the National Park and the Society’s position on such matters.

It may be of interest to note that the Society already organise regular farm and woodland visits and that these are reported on our website and in the members’ thrice-yearly Newsletter.  

Better for People

With regard to visitor pressure on the roads, see comments above regarding a sustainable transport network.

We feel that there is a conflict between the promotion of Dartmoor as a physical activity playground and a suitable place for potentially destructive pastimes, such as foraging, and the long-term well-being of the environment and local communities. While we respect the rights of individuals to legally indulge in such pastimes, we don’t think they should be widely promoted in the media (e.g. BBC Countryfile) and marketing campaigns and should not be actively promoted by the National Park Authority.

Equally, the emphasis should be on managing, encouraging and educating those who wish to visit the National Park of their own volition rather than campaigns to increase overall visitor numbers. There are some excellent examples of sustainable tourism models within the National Park and these should continue to be encouraged, as should initiatives to help underprivileged groups (such as CHICKS or the Jubilee Challenge) to enjoy and feel inspired by the experience.    

We are concerned about the increasing number of large-scale events being staged in the National Park, the damage they can cause and the impact on local communities and farmers. We feel that there are insufficient controls and opportunities for those communities and farmers affected to have their say. 

Better for Communities and Business

Recent years have seen increasing numbers of closures of banks and Post Offices, not only in rural areas but in the larger towns that service Dartmoor communities. This is causing significant hardships to individuals and communities as well as to the surviving Sub-Postmasters who are having to take on more work, including outreach services to villages that have already lost their Post Offices, for little extra money. It also means that, with a lack of public transport, people are being forced to drive (or be driven) significant distances to transact their affairs and this also leads to an increasing sense of isolation for those who can’t travel. 

Poor reception for mobile phones and slow internet connections for those who can use online facilities (and there are still many, particularly elderly residents, who can’t) exacerbates the problem. There needs to be a Dartmoor-wide strategy to protect such vital community services.

Unfortunately, part of the problem is that the viability of many service and retail businesses within the National Park is affected by the increasing tendency for new residents to commute and have little to do with the local community. This is in part a cultural issue as many choose not to mix or get involved, not having experienced village life before. Obviously, this is a personal choice but needs to be taken into account in the consideration of support for businesses and community initiatives and ways of changing perceptions.

Key Challenges

The examples given in the introduction are a little provocative – presumably deliberately so. However, the semantics are dangerous and run the risk of undoing all the goodwill engendered through the consultation process and undermining any subsequent consensus. It could be interpreted as a power of veto and that, regardless of whatever anybody else says, at the end of the day ‘Nanny knows best’.

Of course, as with all plans, the devil will be in the detail and any general statements may give the wrong impression but they appear to pre-suppose that environmental ‘improvement’ will always take priority over all other aspects of the landscape and so a cultural landscape that may be thousands of years old and is ‘considered to be of international significance’ is seen as less important than whatever the current fashion of environmental management or ‘enhancement’ is. This could be seen as rather an arrogant proposition and the justification open to dispute.

The term ‘nature recovery’ itself is actually a culturally loaded term as it presupposes that the flora and fauna of an inherited, culturally managed landscape isn’t ‘natural’ and, by imposing the exclusion of large mammals (including humans), we are making a cultural choice rather than leaving it to nature. Having said that, we aren’t necessarily against the idea and the unaided re-generation of valley-side woodland is clearly particularly effective. We simply want to see that in individual cases, all angles and views are taken into account with open minds.  

Having said all of that, the succeeding assessment of the challenges and issues is fair and balanced overall and we would respectfully suggest that the introduction is revised to reflect the overall consensus rather than concentrate on potential conflicts.


Additional indicators could include:

  • Percentage of total housing stock not permanently occupied
  • Percentage of households greater than a mile from the nearest Post Office or shop
  • Public spend per ancient monument/listed building (including staff resources) 
  • Climate change indicators such as earliest ground nesting dates (and other observational data), temperature and rainfall data etc
  • Satisfaction survey data
  • Farm incomes/profitability comparisons pertaining to different agri-environment schemes and farm support areas within the Park in order to assess effectiveness alongside the respective environmental outcomes
  • Support for carbon reduction measures per household
  • Number of large-scale events and average number of participants, set against previous years