Bob Milton writes to David Webster, Chief Executive Officer [interim], Natural England
and sends copies to the following:
Secretary of State for DEFRA Rt. Hon Caroline Spellman MP,
Planning Inspectorate Sir Mike Pitt,
Rt. Hon Jeremy Hunt MP,
Rt Hon Richard Benyon MP,
Hugh Craddock, Defra common land policy
"I was dismayed to learn that even though Natural England’s raison d’etre defines an equal weighting of ‘Public Access’ and ‘Land Management’, the Land Management department of NE has 700 staff, whereas ‘Public Access’ has 3. Small surprise, then, that there have been so many access problems with fencing schemes."
Says Bob Milton
HLS schemes for Fencing and Grazing of Commons
Thank you for providing one of your senior staff to liaise with me on this important and complex matter. It has been helpful in proceeding to a common understanding of the issues and likely routes to their resolution. I was dismayed, though, to learn that even though Natural England’s raison d’etre defines an equal weighting of ‘Public Access’ and ‘Land Management’, the Land Management department of NE has 700 staff, whereas ‘Public Access’ has 3. Small surprise, then, that there have been so many access problems with fencing schemes.
The issues of independence of the Planning Inspectorate and the supposed statutory duty is a major one in what we the public users of ‘by right common land’ find is a stacked deck in favour self interest groups within Natural England and its funding stream.
I participated in the recent quarterly meeting of the Greenham Common Commissioners. (J. Newman of NE was also present).
At this meeting, it was admitted that the implementation of the HLS agreement had failed in its objective of maintaining the flora to the level specified. Additionally, gorse growth over the last five years has obliterated some 50% of the specialized grass flora on the lozenges. It was also admitted that even overgrazing has failed to prevent the scrubbing up of the common, which continues unabated.
This is a typical example of the HLS agreement unfortunately not delivering the conservation benefits it was designed to provide. There are many others.
There is little truly independent research available on this topic, however the comprehensive results of one independent study, produced by Professor Newton of Bournemouth University, have, apparently not been included in briefings to NE officers. This is disappointing as the study indicates that fencing/ grazing schemes often have only very marginal benefit and frequently have adverse effects outweighing any benefits which are achieved. These findings are consistent with the Greenham Common experience mentioned above.
The grazing schemes have formerly been financed by a combination of Single Farm Payments and HLS funding. However Single Farm Payment should not have been, and will not, in future, be available to any organization which does not hold an appropriate tenancy or lease. You will be aware that Single Farm Payment has already begun to be withheld from some Wildlife Trusts who act as graziers on the Defence Training Estate.
HLS funding requires, under the Common Agricultural Policy, that the farmer is ‘in control’ of the land. Licensed graziers (and other land management contractors) who do not have an appropriate legal beneficial interest in the land should have been excluded from HLS payments for grazing. Again, by definition, graziers cannot be ‘in control’ of commons held for other purposes eg military training or public access [s193 or CA1899]. They are but contractors
For these reasons, it now seems likely that the grazing schemes, while well intentioned, have been constructed on unsound principles, both environmentally and financially. I strongly suggest that it would be prudent to suspend action on all schemes which are currently in planning, including those which are currently with the Planning Inspectorate, until these significant financial issues are concluded and objective research has been carried out on other commons. I feel this would be an appropriate action which would minimize possibly wasted expenditure and also prevent Wildlife Trust and other graziers from being financially committed to unsustainable projects.
I am of course aware that there are several organizations involved in these matters and have therefore copied the heads of these organizations in this letter. I look forward to your timely response.