Cutting down trees to restore open habitats – only now a policy emerges
ADDENDUM - April 2009
ADDENDUM - June 2009
ADDENDUM - July 2009
The mania for heathland restoration that I started to document four years ago had a variety of factors that enraged local communities, not least that the first evidence that anything was going on was often the arrival of insensitive contractors with heavy machinery, the terrifying noise that their equipment made, and the devastating destruction that was left in their wake (see Heathland MADNESS - the juggernaut of nature conservation (1)).
The proof of this destruction is given in the eyewitness accounts and occasional photographs in the reports of local and national newspapers – such as the clear felling of trees, the clearance of shrubs like gorse and other scrubby growth, and the major disturbance of the ground layer as it is often scraped through, the latter giving little hope for the survival of what wild nature could have been there before the clearance. A disturbing aspect of this – the destruction of habitat for reptiles - has not made it into the press, but has been the cause of distress amongst the online communities of herpetologists.
Destroying reptile habitat
A thread began in February last year on the Reptiles and Amphibians UK (RAUK) e-forum about the destruction that “tidying up” on nature reserves caused to reptile habitat (2). Photographs posted there show examples of the heavy handed management: one looks more like a clearance in preparation for road building rather than “nature conservation”; and another in Epping Forest shows a clear-felled and scraped-through landscape, completely exposing a hibernation site (hibernaculum) for adders and grass snakes. This destruction was revisited in a second thread on RAUK last May when Al Hyde, who had been observing heathland management in Surrey for many years, noted that the management had been followed by a catastrophic drop in the number of reptiles present, and in some cases complete extinction of reptile populations (3).
A key theme
of the contributors to this second thread is the lack of specialist
knowledge and attention to reptiles given by the conservation industry, to
the point where Suzi added the telling point, albeit in ironic despair:
pointed out, using photographs, how important the natural mulch layer
under gorse and copses of silver birch was as sites of hibernation for
reptiles, and thus had to be part of the heathland mosaic. “Hopefully
we can get past this 'Calluna monoculture syndrome'”, he said. Gemma
Fairchild of the
Kent Reptile and Amphibian
summed it up for many on the thread:
have been talking about Ash Ranges, an MOD site between Ash and Pirbright in Surrey that has
received the full destructive force of the Surrey Heathland Project over
the last few winters (4). Notices of intent for winter working on the
Ranges always stress that large machinery will be used, and has the usual
fig leaf excuse for their effect (5) "Although the work may appear
drastic, it is necessary to maintain the open heath". So drastic in
fact that a press release from Natural England actually boasts about the
giant woodchip pile that has resulted from this winter's destruction (6):
Al Hyde first mentioned the habitat destruction
and extinction of reptiles at Ash Ranges on the RAUK e-forum when he used
an ariel photograph to point out an area that used to have many adders,
grass snakes, common lizards and slow-worms, but had become a bleak desert
after clearance with no sightings of snakes and only two of common lizards
(3). He also marked on the same ariel view the position of hibernacula
that were destroyed during management. Al returned to the destruction on
Ash Ranges when he sought to take the issue of heathland management and
reptile persecution to a wider audience on the Wild About Britain website
(7). Al was right about the wider audience, as his post immediately brought in challenges to his
observations, the apologia-tendency for the conservation industry so often
seen amongst its groupies. Al could only respond with the evidence of his
backed up in this by another observation from armata:
It would be interesting to see how many would put their hands up, after it was pointed out on the thread that bulldozing a hibernaculum and killing reptiles was an offence under Schedule 5 of the Wildlife and Countryside Act, 1981 (8) leading one contributor to wonder how it was that the Wildlife Trusts, National Trust and Natural England were able to get away with it when a building developer would undoubtedly be prosecuted. In contrast to the behaviour of these "conservation" organisations, Bovis Homes recently agreed to co-operate with the translocation of slow worms identified in an ecological site survey before continuing with development (9).
The constant dirty war of "nature conservation"
This is the constant dirty war that is fought by the conservation industry in their chosen need to undo the choices that wild nature makes in regenerating a natural landscape cover. It is a credo within the conservation industry that this natural habitat restoration of scrubby growth and trees is of little value when compared to the species counting they contend will be maximised from their re-opening of the landscape. While heathland has been the major battleground for them with wild nature, the drive to restore open habitats pretty much covers every type of landscape in Britain. Thus I have written before about the protest at the tree and scrub clearance at Harting Down, a chalkland landscape where the National Trust is imposing a particularly obtuse view of nature conservation (see Harting Down - obsession with conserving man-made landscapes (10)). As with heathland sites such as Bickerton Hill in Cheshire, and Swineholes Wood in Staffordshire, it is patently obvious that the landscape at Harting has a variety of habitat that includes scrubby growth and a substantial area of established trees, but that the conservation orthodoxy – and its notification as a SSSI for calcareous grassland - has determined that it be managed as open habitat with the requirement of as low as only 5% of scattered trees (11). I don't think the protestors at Harting Down are aware of this low limit for tree cover, and I am sure there would be an absolute furore if the National Trust sought to comply with it.
I don’t have to look far to find an example of objectors to restoring a different type of open habitat. An article in late February in The Cumberland News reports the alarm of residents to proposals by Natural England to clear oaks and pine from woodland near Crosby-on-Eden (12). The oak and pine grow across White Moss, a raised mire that has been drained and cut for peat at various times. The ordinance survey map shows woodland on the southern and eastern edge of White Moss representing about a fifth of the area of the mire, but a recent ariel photograph and the National Inventory of Woods and Trees show that most of the mire is now covered with trees. Either way, woodland must have been there for many years before 1986, the year that White Moss was notified as a SSSI. In spite of this, none of the units of the SSSI were notified for woodland, only as lowland bog and a small area of dwarf shrub heath (13).
had scrub cleared off the mire in 2001 and 2002, giving rise to what they
describe as an "impressive" recovery in mire groundcover
(13). In that condition report from 2004, it was noted that "a
decision will be taken shortly as to how many of the licensable trees will
need to come off".
This was a reference to the fact that a
felling license would
be required for the tree removal, when it wasn't
for the scrub clearance. Five years on, and Natural England
now want 45 oaks
cut down, some of which could be
150 years old, and 727 Scots pines, the latter being a home for red
squirrels, an increasing rarity in England (and for a similar threat to
red squirrels, see
Forest - a lost opportunity for a new wildwood (14)).
It is not just the loss of red squirrels that is upsetting James
Bainbridge, a Carlisle City councillor for the area (12):
councillor Ray Bloxham agrees, but added the all too familiar infuriation:
Clark, a spokeswoman for Natural England, gave the game away when she
defended the proposals by reference to the pressures from the Public Service Agreement target
for the favourable condition of SSSIs by 2010. She claimed that White Moss
was too small to be a refuge for red squirrels, referring to them as a
transient population, and that:
got short shrift in a letter published in response by Gordon Little from nearby Scaleby, who questioned the logic of the proposals, fearing the constant
saturation of the denuded mire would lead to rapid run-off (15):
Gordon believed that first hand, local experience showed the red squirrel population to be more than a transient population, and pointed to the natural benefits already there that the mix of current landscape cover on White Moss afforded. He saw it as “nothing more than national vandalism” for the proposals to go ahead. The Brampton Red Squirrel Group, a member in Cumbria of Northern Red Squirrels, is also entirely underwhelmed with the priority that Natural England gives to red squirrels. Their view is reported in a meeting a few weeks earlier in February of the Stanwix Rural Parish Council in which the felling application by Natural England was considered (16).
The parish council concluded that the number of trees to be felled was too large, and that White Moss is an established habitat for red squirrels, deer, owls, and other flora and fauna such that it would be a breach of its own statutes and regulations if Natural England went ahead. As tellingly, they noted that there is no woodland of a similar size in the area, but that there was an actively growing raised mire already at Scaleby Moss SSSI, only 2.5 miles away from White Moss. The parish council also heard the views from representatives of the nearby Irthington Parish Council, and it was resolved that the two parish councils would object to the felling identified in Application 010/142/08-09 and “formally request that Natural England and, or, the Forestry Commission hold a public meeting”
The discontent rumbles on, now reaching the level of a meeting of the Carlisle City Council Executive on 14 April, where information tabled on the objections from Irthington and Stanix Rural Parish Councils will be considered (Agenda item A17 – see (17)). The information note from the parish councils gives a summary of their earlier meeting, but then has a remarkable critique of the felling proposals in relation to the history of the site, the recent history of management and the condition reports of the individual units of White Moss SSSI, and the context of mire restoration in relation to other locations nearby (16). Their conclusion is that since the majority of White Moss is in a recovering condition, then there would be no justification for the scale of the felling proposed. Moreover, that it would only need the blocking of a drain in one unit, and the removal of the small area of pine in another, to achieve a recovering condition in White Moss as a whole. Their recommendation to Natural England is that they should instead concentrate their efforts at the much larger mire of nearby Scaleby Moss SSSI, where condition reports indicate the mire there to be in a deteriorating condition.
James Bainbridge, a councillor for the City Council ward that covers White Moss has formally submitted written observations to the Executive in support of the information brief from the parish councils (18). In a devastating indictment, he notes the lack of consultation by Natural England, and reveals that residents only became aware of the proposed felling when Cumbria County Council took it upon itself to open up consultation by circulating the details that it had received. In an effort to forestall some of the felling, Cllr Bainbridge calls on the Executive to consider Tree Preservation Orders being made for the oaks on White Moss. (See the Addendum below for the decisions made during the meeting of the Executive Committee of Carlisle City Council).
A felling license is required
The fact that Natural England had to apply for a felling license for the works at White Moss paradoxically takes the decision to restore open habitat out of the hands of the conservation industry, and gives authority instead to the Forestry Commission. I have written before about the Environmental Impact Assessment (Forestry) Regulations 1999 whereby the Forestry Commission has to take into account the environmental impact of felling work where there is no intention of any replanting, before it can issue a felling license (see High price for heath - Loxley and Wadsley Commons (19) and Threestoneburn Forest - a lost opportunity for a new wildwood (14)) but this requirement is only triggered if the area for deforestation is above a threshold of one hectare (no threshold exists for SSSIs in the exemption criteria). This anyway seems to be a pretty coarse way of exempting consideration of significant environmental impact when it is unrelated to the ecological functioning of a site. Does nothing happen on deforestation sites of less than one hectare that would be disrupted by the tree felling? The felling application at White Moss specified an area of 12.23ha, and thus it should have been considered by the Forestry Commission whether consent for the application would need to be accompanied by an Environmental Impact Statement. Considering the substantial extent of the work, the short timescale in which it would be carried out, the disruption to the existing flora and fauna, and that the landowner adjacent to White Moss had not been consulted, but had raised concerns about access over his property for contractor’s plant (16) then it is surprising that the Forestry Commission shows no evidence yet that it requires an Environmental Impact Statement for the felling license application for White Moss.
Even if a requirement was put on Natural England for an Environmental Impact Assessment to be carried out at White Moss, the decision on whether there will be an adverse environmental impact is based on some pretty uninspiring criteria given in a Schedule to the regulations (20). It was perhaps the lack of clarity of these criteria and their irrelevance to contemporary issues such as the contention at deforestation for restoration of open habitat, that it was addressed in the consultation in 2006 on a new woodland strategy for England. A question was asked as to whether restoring open habitats by deforestation should be a national priority where this makes a significant contribution to UK Biodiversity Action Plan targets. As you would expect, I rejected this in my response, and I pointed out that many conservation projects are still being carried out independently of landscape considerations, such as all the trees being removed from heathland or grassland with no attempt to create a mosaic of natural vegetation (see A response to the consultation on England's Forestry Strategy (21)).
new strategy for England’s Trees, Woods and Forests launched in 2007 was
resoundingly uninspiring in many ways (see my
on the strategy (22)) but there was a commitment to put some effort into a
decision process for felling to restore open habitats, although the
wording was particularly loaded (23):
I’ve been watching the development of this policy by the Forestry Commission since early October last year (24). The timescale has slipped over the months, but the usual “stakeholder workshop” of conservation professionals is reported; a very useful summary of policy evidence was posted (25) and a consultation on the policy options was eventually launched a couple of weeks ago (26). The consultation document (27) recognizes that the restoration of open habitats from woods and forests is driven by the England Biodiversity Strategy, but that these woods and forests already deliver a range of public benefits and goods so that many people do not like to see them being removed. Another important point made in the proposals, often overlooked when Government ends up always footing the bill (as at Ash Ranges - see above) is that open habitats are usually more costly to manage than woods and forests. The aim with this policy is thus to enable effective decision making about when it is right to remove woods and forests on potential open habitat and when it is right to retain them. The hope is that this will make sure that we have landscapes that deliver more public benefits overall, and a process of change if approved that is supported by most people.
The support of people is
given significant emphasis in the policy consultation, and it is likely
that the decision process will seek evidence that there has been high
quality local engagement before deforestation proposals will be
considered. As the document rightly says:
If only this attitude
had prevailed over the last ten years during which the tensions with the
conservation industry have risen to the level of anger. In reality, we
should have had this policy developed many years ago,
at the same time that the BAP
targets for restoration of open landscapes were being set.
There were people like Peter Marren, writing in 1999, who foresaw the damage
that would ensue (28):
There is a presumption in the proposals against removal of ‘mature native woodland’. It is defined as sites currently composed of native broadleaves that have been wooded for at least 80 years. This seems very stringent in relation to some of the contentious heathland examples, especially since Scots pine is very much in the scene, but it would seem to be an argument against deforestation at White Moss where 150-year old oak are for the chop. Moreover, there is a commitment amongst the policy options to ensure that the deforestation does not lead to an overall drop in national woodland coverage, inadequately low as it is already. It is a sad fact that the potential rate of deforestation for open space habitat as represented in the BAP targets has the potential to exceed the current derisory rate of woodland creation in England (see Woodland creation - in need of strategic direction and larger scale (29)) and there is an estimate in the proposals that this could be the case if clearance for open habitat restoration were to approach or exceed 1,100 ha each year. There is also a proposal to seek compensatory planting to reduce some of the potential negative impacts from woodland removal. A range of ways in which this could be applied are given, and include imposing a condition as part of accepting woodland removal; seeking twinning between deforestation and woodland creation projects; or just encouraging applicants to do the right thing. I should note that one of the participants at the stakeholder meeting asked the question during the plenary that if open habitats are created in England, does it count if trees are planted in Scotland? And you wonder why the ordinary public is disdainful of the conservation industry.
I intend to respond in detail to this policy consultation, but there is an aspect that especially caught my attention. For the first time ever, I have seen information on Common Standards Monitoring presented in a way that reveals the frightening extent of control over landscape cover in open habitats that the system of SSSIs exerts (see Table 6 in the summary of policy evidence (25)). Grouped together are the percentages for maximum tree cover allowed for favourable condition in the range of open habitats covered by SSSIs. It starts at a low of 5% of scattered trees for most meadow, grassland and lowland bog habitats; rises to 10% for fens, lowland (wet) and upland heath, and upland bog; and only reaches 15% for dry lowland heath. I have described the implications of this process of maintaining land in a prescribed stasis as a "McDonaldising" of our countryside (see Swineholes Wood - 'Too many trees being cut down' (30). I have also noted above (and many times before, such as in (1)) that there would be a public outcry if these standards were rigidly applied as many locations notified for open habitats have existing tree covers far exceeding these limits. Consider how the residents around White Moss will react if the required upper limit of 5% tree cover (10% at the margins) on lowland bog were to be enforced there.
The proposals accept the limits as an unchallengeable reality for SSSIs, but then it is questioned whether a more flexible and dynamic approach should be taken for restoration of open habitats outside of SSSIs. It argues that in this dynamic approach, a landscape cover of about 30% permanent woodland, 30% permanent open habitat and 30% temporary open space or woodland, could deliver so much more in terms of landscape connectivity, ecological process and resilience. I noted this myself for Harting Down (10) and I believe it is vital that our conservation thinking develops in this way, especially if it leads to a much needed questioning of the basis of the SSSI system. Only then will we be able to live up to one of the key elements of the proposals “to treat woodland and open habitats as potentially mutually beneficial habitats”. It would certainly provide better protection for the homes of our adders, grass snakes, common lizards and slow-worms on heathland sites, and it would give much needed support to the many local populations, like that around White Moss, who have genuine reasons for objecting to the destruction that is caused by the unthinking restoration of open habitats.
Mark Fisher 26 March 2009, revised 10 April 2009
ADDENDUM - April 2009
The Executive of Carlisle City Council resolved at their meeting on the 14 April 2009 to write to the Forestry Commission and Natural England, expressing their concern at the proposals to fell trees at White Moss (31). Members of the Executive considered the information against the proposal from Stanwix Rural and Irthington Parish Councils, and also heard from the Head of Planning and Housing Services that the City Council through its officers had itself, when consulted in January, raised concerns that the felling of the trees should be phased and replacements planted elsewhere. The Executive were also concerned at the lack of consultation with the Parish Councils and the general public, noting that the County Council had left little time for Parishes to consider a response. The Executive concluded that the felling would cause disruption to the wildlife and fauna such as the Red Squirrel and Roe Deer.
The local press was quick to report the
outcome of the Executive meeting, drawing forward a commitment from
Natural England to hold a joint public meeting with the Forestry
Commission in May about the plan, and hire an independent expert to
discover whether White Moss is a refuge for red squirrel (32). You would
have thought that they would have done this in the first place, before
making the felling application. It is likely to be a fiery meeting in
which the defence of the felling proposal by Susan Clark of Natural
England by hiding behind the SSSI designation – “We have a statutory duty
to restore that site” – will get short shrift. City councillor Ray
Bloxham, who lives in Irthington, and is going to pursue having tree
preservation orders placed on the pines and oak at the White Moss, has
been getting local feedback:
John Harris, chairman of Irthington
Parish Council, goes to the heart of the issue when he says:
It is this point – that notification of the mire occurred when there was already a considerable presence of trees – that is a key issue in many of the disputed management programs all over England. There is no natural justice in the situation that Natural England and its predecessors can have condemned what is often naturally regenerated woodland in such an arbitrary way. It has made a mockery of their notification system for SSSI, and pretty much discredits the Common Standards Monitoring guidance for the condition of SSSIs that was implemented across Great Britain in 1999 (33). The latter is described as a means of “defining the state of the site that is required and identifying the need for any further conservation management action” but it is in effect a retrospective imposition of a notional ideal composition of vegetative components. It is a lumpen mentality that seeks to defend it, and hide behind it when, to many, it seems Natural England just makes things up as they go along. It is time that it is openly challenged.
I would also strongly question why the Forestry Commission did not, on receipt of the felling license application, require Natural England to go through the process of compiling an Environmental Impact Statement that is then submitted before the felling application could be considered (see above). It begs the question of whether Natural England filled in a Determination Enquiry form for Environmental Impact Assessment. While the threshold for this is one hectare for non-sensitive land areas (see above) all felling on SSSIs irrespective of felling area have to be assessed for whether an Environmental Impact Assessment is required (34). It seems to me that there are legitimate concerns at the environmental impact of the proposed felling in terms of the short timescale, access for heavy machinery, and the substantial impact on the existing wild nature. Thus it seems puzzling that if Natural England did fill in a Determination Enquiry form, that the Forestry Commission were of the opinion that an Environmental Impact Statement was not required. Having to undertake the process of compiling an Environmental Impact Statement would force Natural England to publicise widely their intentions for White Moss, and work closely with local people to discuss and agree the significant issues of concern that must be addressed by Natural England in their preparation of the Statement. On receipt of the Statement, the Forestry Commission can grant consent but with specific conditions, or refuse consent altogether. I would suggest that this requirement on Natural England for an Environmental Impact Statement needs to be a minimum required outcome of the May meeting.
Sadly, experience tells me that I can make a prediction that the report from the “independent expert” will likely dismiss White Moss as a refuge for red squirrels. It will need representatives of the Brampton Red Squirrel Group to interpret, as the report may go into conifer cone density, cone nutrient content, number of “squirrellled” cones, age range of conifers, diversity of tree species, proximity of grey squirrels and the likelihood of transfer of Squirrelpox virus, and the long-term capacity of the site to support a red squirrel population versus the ability of the existing population to translocate elsewhere (see Threestoneburn Forest - a lost opportunity for a new wildwood (14)). The one key piece of evidence missing in the report will be the opinion of the red squirrels themselves that seem to have made White Moss a home.
Mark Fisher 25 April 2009
ADDENDUM - June 2009
Its not normally a good idea to leave a consultation response to the last minute before the closing date, but it is fortunate that I did with my response to the consultation on Restoring and expanding open habitats from woods and forests in England. The Forestry Commission added two further evidence documents only three weeks before the closing date, and very likely after many organisations and individuals had already replied.
The new evidence document on the impact of a deforestation policy on the confidence of the timber sector in England had little of direct interest for me (35) but the second new evidence document had some very revealing information. This document contained a survey of the potential for open habitat restoration on the publicly-owned, Forestry Commission estate. The report looked at the social restraints on open habitat restoration (Section 6 in (36)) and concedes that a strong local response usually influences the emerging Forest Design Plan. If only that was the case for deforestation proposals by the conservation industry on other publicly owned land, such as the heathland, chalkland and mire commons that cause such public contention. The authors go on to forecast the "social acceptability" of the bulk of the potential sites identified on the FC estate, and it is no surprise to me that only 4.4% of the potential lowland heath area was considered to be where there would be little or no opposition to open habitat restoration.
I argued in my consultation response that proposals by the conservation industry for deforestation to restore open habitats take for granted that these habitats will be successfully restored. As many local communities observe, this is often specious. Numerous examples of supposed heathland restoration result in only acid grassland communities. Thus it should not be the case that just because local opposition may not be strong that rigor should not be required of all deforestation proposals. This would imply that deforestation in a hopeless cause is somehow more acceptable if it is out of sight, or that local people have little interest in the location. I stressed that the emphasis should be on the proposer to fully explore the impact and outcome of their proposals, and to do this with the local community. You can read my full consultation response here.
Mark Fisher 6 June 2009
ADDENDUM - July 2009
meeting that Natural England had promised with local people finally took
place on 1 July when about 30 turned up to hear Deborah Rusbridge, in
place of the incredulous Susan Clark, announce that the felling
application had been withdrawn. Rushbridge admitted that the application
process had been badly handled by NE (37):
Rusbridge said that there were no immediate plans to submit a new application, but then outlined plans for a survey of the area over the next two years, leading people at the meeting to believe that it was only a matter of time before a new application would be submitted. Was it a slip of the tongue when Rushbridge said “previous” application?
Bainbridge, Carlisle City Cllr for Stanwix Rural, was at the meeting and
he tells me that Rushbridge seemed genuinely unhappy about had happened.
He confirmed that very little (if any) study work had been carried out by
NE on White Moss before the felling application. Equally concerning is
that the Church Commission, which owns much of the land, does not appear
to have been consulted either. James remarked on how fortunate events had
unfolded, alerting local people to the potential threat to White Moss:
having to talk their way out of their own disasters, NE staff in the NW
region should take note of the public commitment that they have made about
their methods of working. In the NW regional section of the NE website, it
has that the NW team will take an evidence-based, long-term approach to
their responsibilities that demonstrates clear benefits from their
interventions in land management. It then says (38):
Be sure that the local people living around White Moss will hold them to this.
Mark Fisher 9 July 2009
(1) Heathland MADNESS - the juggernaut of nature conservation, Self-willed Land Oct 2008- Mar 2009
(2) Destruction of habitat by tidying up, 7 February 2008, Reptiles and Amphibians UK e-Forum
(3) Management and Population Extinctions, 5 May 2008, Reptiles and Amphibians UK e-Forum
(4) Winter work, Heathland news and events, Surrey Heathland Project February 2009
(5) Heathland restoration at Ash Ranges - November 2008, Surrey Heathland Project
(6) Giant woodchip pile to aid Surrey’s heathland species, Natural England Press release 26 January 2009
(7) Heathland Management, 28 November 2008, Reptile and Amphibian Forums, Wild
(8) Legislative protection for the UK’s herpetofauna England and Wales, Herpetological Conservation Trust
(9) Slow worms delay building work: Work on a new housing estate has been delayed - thanks to a hibernating colony of slow-worms, Daily Telegraph 9 April 2009
(10) Harting Down - obsession with conserving man-made landscapes, Self-willed Land 4 November 2007
(11) Common Standards Monitoring Guidance for Lowland Grassland Habitats, JNCC February 2004
(12) Alarm at plan to fell nearly 800 trees in woodland near Crosby, Julian Whittle, the Cumberland news, 20 February 2009
(13) Condition of SSSI units, White Moss, Crosbymoor, Natural England
(14) Threestoneburn Forest - a lost opportunity for a new wildwood, Self-willed Land 30 December 2008
(15) Felling trees to create a swamp will not relieve flooding problem, Gordon Little, Letter to The Cumberland News, 27 February 2009
(16) White Moss SSSI - a briefing on the Application for a Licence to Fell Growing Trees, Stanix Rural parish Council
(17) Agenda for Executive 14 April 2009, Carlisle City Council
(18) White Moss SSSI Cllr Bainbridge comments
(19) High price for heath - Loxley and Wadsley Commons, Self-willed Land 7 August 2008
(20) Schedule 3: Projects having significant effects on the environment: Selection Criteria, The Environmental Impact Assessment (Forestry) (England and Wales) Regulations 1999
(21) A response to the consultation on England's Forestry Strategy, Self-willed Land 8 August 2006
(22) Strategy for England Trees, Woods and Forests - a commentary, Self-willed Land 25 June 2007
(23) A Strategy for England’s Trees, Woods and Forests, DEFRA 2007
(24) Restoring and expanding open habitats from woods and forests in England: developing policy, Forestry Commission
(25) Restoration of open habitats from woods and forests in England: developing Government policy: evidence, Forestry Commission November 2008
(26) Restoring and expanding open habitats from woods and forests in England: Consultation, Forestry Commission March 2009
(27) Restoring and expanding open habitats from woods and forests in England: a consultation, Forestry Commission March 2009
(28) Britain’s Rare Flowers, Peter Marren (1999) A & C Black ISBN 0-85661-114-X
(29) Woodland creation - in need of strategic direction and larger scale, Self-willed Land 30 November 2008
(30) Swineholes Wood - 'Too many trees being cut down', Self-willed Land 18 February 2008
(31) Minutes, Executive
14 April 2009, Carlisle City Council
(32) Outrage over plan to fell wood near Carlisle, Phil Coleman, The Cumberland News 17 April 2009
(33) Guidance for Common Standards Monitoring, JNCC
(34) Environmental Impact Assessment projects and thresholds, Forestry Commission
(35) Open Habitat Restoration Policy and its impact on the confidence of the timber sector in England, Forestry Commission 2009
(36) Open habitats and open habitat potential on the Forestry Commission Public Forest Estate in England , Jonathan Spencer and Rachael Edwards, Forestry Commission May 2009
(37) Plans to chop down woodland near Brampton dropped, Thom Kennedy, The Cumberland News 3 July 2009
(38) Meeting the challenge in the North West, Natural England, NW Region