The Dartmoor Society
Larkhill, Devon House Drive
Bovey Tracey, Devon TQ13 9HA
Mark Baxter DEFRA
Protected Sites National Biodiversity
Bristol BS1 5AH
16 September 2022
South Dartmoor SSSI: Appeal against Refusal of Consent Notice
Thank you for contacting us regarding this appeal.
The Dartmoor Society is interested in how grazing animals can help to maintain healthy ecosystems on Dartmoor. This includes their role in keeping archaeological sites visible and the part they play in keeping Dartmoor accessible on foot. Grazing animals are part of a farming culture stretching back for generations. We have witnessed significant increases in vegetation cover Dartmoor-wide and the rapid spread of Molinia and gorse, so we welcome the opportunity to comment.
We have read the appeal document prepared by Mr and Mrs Radmore and we understand that this application is to continue to graze Hentor and Willings Walls Common at previously agreed levels of 450 breeding ewes in summer and 350 in winter, summer grazing of 100 cattle and a herd of 20 ponies. So we are not talking about an application by the Radmores to increase stock but to maintain current levels. These current stocking levels are half or less what they have been in the past for both sheep and cattle.
The Dartmoor Society has argued for more than 20 years that the impact of any intervention on Dartmoor should be judged from an environmental and a cultural perspective. By cultural, we mean that consideration should be given to the accessibility and visibility of archaeological remains which, on Dartmoor, are found on a landscape scale and are of international significance; and to the continuation of farming traditions and sheep learing on the Dartmoor Commons.
We are mindful that learing is threatened when long-established patterns of grazing are disturbed, i.e. when stocking levels are reduced, regimes are changed or if some flocks are withdrawn from grazing their traditional place on the Common. Mr and Mrs Radmore mention that their family has grazed this land since the 1960s and that the heritage of this flock goes back 120 years. Our very real concern is to protect the tradition of learing sheep on Dartmoor from becoming fragmented and lost.
Field observations show that the vegetation sward is long on this Common. The increased vegetation cover over this area compared to that 25 years ago is stark. This is a complex archaeological landscape of prehistoric field systems and monuments, and remains dating from the more recent past. On Dartmoor, startling new finds have been discovered in the past 20 years. Access to study and record the archaeology and to make new discoveries is becoming increasingly difficult as the vegetation cover increases year on year and Molinia spreads over the landscape due to the above-mentioned reduced stocking levels. Archaeological features and sites that were clearly visible years ago have all but disappeared under vegetation.
Within the recent past the face of Dartmoor’s uplands has changed. Farmers have been encouraged to sign up to environmental agreements and these agreements can be divisive. One commoner can negatively affect other farm businesses from progressing their own management agreements.
These agreements have resulted in a dramatic reduction in the numbers of livestock that are grazed on the open moor. The system has failed in its aim to improve environmental conditions on the Dartmoor Commons and the encroaching vegetation has made it difficult to walk freely across the moor so it is dangerous for anyone to cross it as depressions and trip hazards are obscured.
We have not been given access to the data that Natural England used to refuse to allow continued grazing on this Common, but we see the reasons given in their Refusal of Consent document.
Natural England refuses this application to continue to graze on the basis that ‘a reduction in grazing pressure is required to avoid further damage to the features and to achieve restoration to a favourable condition’
We cannot agree with this statement as we believe that further decreases in stocking levels on this Common will not by themselves bring about ‘further enhancement and restoration of key SSSI features present’
Natural England’s second reason for refusing is that ‘an adverse effect cannot be ruled out on the SAC features from the proposal’
As the dramatic reductions in grazing Dartmoor-wide over the past 25 years have not led to the desired ‘favourable conditions’ we cannot agree with the argument that further reductions now, will suddenly turn the tide and lead to the desired favourable conditions.
If these animals are withdrawn from their traditional grazing pastures this will simply cause grazing pressure elsewhere and at the same time destroy a 120-year-old heritage grazing regime.
Chair, The Dartmoor Society