Policy paper

Government response to the independent review of protected site management on Dartmoor: by recommendation

Updated 11 April 2024

This was published under the 2022 to 2024 Sunak Conservative government

Applies to England

Introduction 

In April 2023, Defra ministers commissioned the Dartmoor Review Panel, chaired by David Fursdon, to carry out a rapid review of protected site management on Dartmoor.

You can read the terms of reference for the Independent Review of protected site management on Dartmoor, from when it was set up.

The independent review of protected site management on Dartmoor (the ‘Review’) was published on 12 December 2023.  The government thanks David and the Review Panel  for their work.

This is the government’s line-by-line response to each recommendation, in chapter order. It includes progress to date with implementing certain recommendations, and further actions it will take to implement the Review. 

The number in brackets next to each recommendation, relates to the paragraph number in The independent review of protected site management on Dartmoor. 

Vision and governance 

Recommendation 1 (paragraph 18.1) 

Need for a Dartmoor-wide vison at landscape level, supported by a clear delivery strategy.  

Recommendation 2 (paragraph 18.2) 

Recommend Dartmoor National Park Authority (DNPA) Partnership plan as setting that vision. 

Response to recommendations 1 and 2 

We agree that the DNPA Partnership plan, also known as the management plan, provides the landscape level vision and clear delivery strategy that is crucial to Dartmoor. 

The DNPA Partnership plan sets out how different organisations will work together to achieve shared objectives for the future management of Dartmoor. As with every Protected Landscape (National Parks and National Landscapes) this plan must, by law, be reviewed every 5 years.  

Defra is currently reviewing guidance for Protected Landscape management plans and will publish updated guidance shortly. 

To balance the needs of people and place, and embrace positive change, it will be key for those across Dartmoor to come together and support the vision outlined in this plan. 

There are opportunities through the Devon Local Nature Recovery Strategy to ensure that that vision for Dartmoor is integrated with wider strategy and meets the needs of the wider population across the county and England as a whole. 

Recommendation 3 (paragraph 18.3) 

Reinforce Dartmoor’s governance through the creation of a Land-Use Management Group (LUMG). 

Recommendation 4 (paragraph 18.5) 

The LUMG should be tasked with developing a multifunctional land use framework and a land-use plan for Dartmoor. 

Response to recommendations 3 and 4 

We agree and recognise a role for Defra to help facilitate the implementation of a LUMG. Defra will appoint an independent chair who will be supported by a secretariat, provided by the DNPA (funded by Defra) in the day-to-day running of the group.  

The group will primarily be responsible for developing a multifunctional land use framework and land use plan for Dartmoor. 

The group will also be responsible for overseeing other recommendations in the government response, as set out in the vision and governance section. 

The group will run for 2 years. We expect the first meeting to be held no later than this autumn to help inform the next steps for future agri-environment agreements in 2025 and to start making progress more generally, as soon as possible.  

The chair will set the membership for the group (in consultation with Defra) and will be accountable to the Defra Secretary of State (SoS). The chair will report back to the Defra SoS in quarterly progress reports. 

Recommendation 5 (paragraph 18.6) 

Central library of protected site monitoring data to be created, potentially to be held by the National Park. 

Response to recommendation 5  

The government agrees to the need for transparency, clarity and accessibility of protected site monitoring data. Natural England’s information on protected site condition can already be viewed publicly on Designated Sites View. Natural England is committed to ensuring that findings of site checks/monitoring visits are provided to site owners and agreement holders in a timely fashion.   

We also recognise the potential benefits of bringing evidence together from all partners, including those like the Environment Agency (EA), into one place to support a more shared understanding. Natural England will work with the LUMG to investigate how best evidence can be brought together and shared and the priorities for addressing any evidence gaps. 

Protected site management 

Recommendation 6 (paragraph 19.1) 

Protected site legislation should be simplified, to improve clarity and implementation without losing rigour. 

Response to recommendation 6 

The government will continue to work with others on the moor so that sites of special scientific interest (SSSI) legislation is better understood by farmers and implemented in the best way on Dartmoor (and elsewhere), and that landowners and how their management can positively contribute to the delivery of favourable SSSI condition features and fully understand the requirements on them.   

Changing the legal framework for protected sites would require primary legislation. We do not think that is necessary to address the key problems the Review has covered.  

However, government continues to keep the operation of nature protections under review and new mechanisms such as Protected Sites Strategies provided for by the Environment Act can facilitate a multi-site landscape scale approach to integrating management across commons and delivering condition as a site feature level, as suggested in the Review recommendations. 

Recommendation 7 (paragraph 19.2) 

Concept of SSSIs to be reviewed, to ensure they are compatible with a vision to be delivered at landscape/eco-system level. 

Response to recommendation 7 

We believe the current legislative framework for protected sites provides enough flexibility and is adaptive enough to address the challenges and concerns set out in the Review, but that the way this is communicated and implemented needs to change. We want to make it easier for land managers to understand site designations and associated requirements for the land they manage, and we also want to make the monitoring and evaluation process more transparent than it has been to date. 

Natural England’s new approach of feature assessments enables them to determine how SSSI condition can be assessed across a whole site rather than at a management unit scale.  On large upland sites (such as Dartmoor), this feature-based approach means that contribution to favourable condition made by each management unit (or agreement area) can be tailored to their specific circumstances rather than set uniformly, as is the case with the current agreements. 

There are opportunities to deliver a more strategic approach through new mechanisms and funding streams such as Protected Sites Strategies and Landscape Recovery (LR). Natural England will work with the LUMG to determine which of these could be best used to deliver the vision for nature recovery on Dartmoor. 

Recommendation 8 (paragraph 19.3)  

More scientific monitoring and evaluation required to assess condition of Dartmoor’s SSSIs and to understand the influences impacting on them.   

Response to recommendation 8  

We agree that monitoring and evaluation of SSSIs is key to assessing their condition, and understanding factors that impact on them. On Dartmoor, Natural England is carrying out a further programme of SSSI monitoring and resurveying, which will be completed by the end of 2024. This will bring Natural England’s current understanding of the SSSI condition up to date.

Natural England will share the findings from this monitoring with stakeholders and agreement holders on each common and will explain how this affects their views about SSSI condition and site management. 

Natural England is also in the process of updating their evidence on site condition for all SSSIs in England. This includes updating any required actions to maintain or improve site condition and is expected to be completed by 2028, in line with the Environmental Improvement Plan (EIP) interim targets.   

While the evidence base on the impacts of grazing is well established, the confidence of stakeholders in the evidence base is poor. Natural England will work with stakeholders including through the LUMG, and other partners on the moor, like EA, to:

• improve the efficiency of SSSI monitoring
• improve understanding of and confidence in the evidence base
• make better use of new technologies such as remote sensing
• increase partnership involvement

Recommendation 9 (paragraph 19.4) 

Designation and notification of Dartmoor’s SSSIs to be refreshed, to ensure features are still relevant and no new features need to be added. 

Response to recommendation 9 

The habitat features that were originally designated and notified on Dartmoor SSSIs, are still present and remain of national importance.   

Any proposed changes to current designations would need to be evidence based and undertaken in compliance with existing legislation.

This would be a detailed exercise requiring significant resourcing and consultation. We have not identified that there is a sound evidence case or broad consensus for re-notification of Dartmoor’s moorland SSSIs across government or the wider land use sector, although this will be kept under review. 

Natural England commits to working with the Review’s proposed LUMG to ensure there is a clear and common understanding about which SSSI features are part of the designation notification process, and how these features are linked and affected by different land management practices. 

Recommendation 10 (paragraph 19.5)

Uncertainty over legal position of commoners to be treated as ‘owners and occupiers’ for the purposes of  WCA needs urgent clarification. 

Response to recommendation 10

Under the current legislation, commoners are treated as “owners and occupiers” and need to gain consent for any operations requiring Natural England’s consent listed on a SSSI designation, such as grazing. This position has been clear since 30 January 2001 when the Countryside and Rights of Way Act 2000 made a clarifying amendment to the Wildlife and Countryside Act 1981.

Since Natural England was established in 2006, they have been notifying commoners of SSSI designations, however their predecessor organisations have not always notified commoners of SSSI designations due to the previous lack of clarity in the legislation.

Natural England (in consultation with Defra and stakeholder groups) are working on a strategy for how best to address any gaps in notifications for older SSSI designations. They are also assisting commoners to enter into, and remain in, agri-environmental agreements, pursuant to which they are compensated for agreeing to regulate their grazing rights.

Land use, ecology and biodiversity 

Recommendation 11 (paragraph 20.1)  

Top ecological and environmental priority for Dartmoor is to improve hydrological function and re-wet blanket bogs and peatlands. 

Response to recommendation 11 

The government accepts that the top ecological and environmental priority for Dartmoor is to improve the hydrological function and re-wet blanket bogs and peatlands. The government is committed to improving the conditions of all peatlands on Dartmoor. The government currently provides funding for peatland restoration projects through the Nature for Climate Peatland Grant scheme. Once the scheme ends, the government will fund peatland restoration through Environmental Land Management (ELM) schemes, with the LR scheme expected to play a crucial role in delivering our peatland restoration ambitions. 

Peatlands in good condition deliver a range of environmentally important and economically valuable ecosystem services. The government recognises the importance of peatland projects being able to attract private finance and will continue working to help stimulate the development of high integrity nature markets capable of scaling up private investment for peatland restoration. 

The Review draws attention to the Ministry of Defence’s presence on Dartmoor and the significant costs to the re-wetting of peatland in Dartmoor associated with unexploded ordnance. The Review also notes the scale of military activity in Dartmoor and the government understands that this continues to cause some disruption to peatland restoration work.

The Ministry of Defence recognises the importance of peatland restoration activity in Dartmoor and is committed to working with Defra and the South West Peatland Partnership to address these barriers. Options to address these challenges will include additional financial support and improved knowledge sharing.

Further discussions on this recommendation will be included as part of the new LUMG. 

Recommendation 12 (paragraph 20.3) 

The second priority should be to control Molinia, using a combination of active management practices, including grazing. 

Response to recommendation 12  

Within existing agreements on Dartmoor, there is flexibility for farmers and land managers to develop management plans that will help tackle over-dominance of Molinia, and we agree to support agreement holders to develop these.

The plans could include short term innovative techniques, such as using salt or mineral licks or cutting of strips to draw grazing animals into Molinia areas. Plans could also address longer term solutions to the problem, by including adaptation of grazing calendars to increase stocking of cattle in summer when Molinia is palatable or restoration of natural drainage. 

The government is supportive of the trialling of experimental techniques and research, with robust experimental design, aimed at reducing Molinia over-dominance and commits to work with the Review’s proposed LUMG to select suitable trial areas and academic partners to carry out the research. 

Recommendation 13 (paragraph 20.4) 

Encourage development of wood pasture and tree growth in suitable locations, particularly along valley sides, as part of an agreed land-use plan. 

Response to recommendation 13 

Trees have far-reaching benefits for farmers, their land, and the environment. Our ELM schemes already pay for the management of existing wood pasture and woodland habitats. We are improving the existing offers by making the actions simpler and more flexible and increasing payment rates to reflect rising costs.   

Our ELM schemes also pay for the creation of new wood pasture where it extends, links or buffers existing scrub, sites with open grown trees, wood pasture or priority woodland habitats. The England Woodland Creation Offer (EWCO) pays for the creation of new woodland, and this will transition to become part of the ELM schemes from 2026. 

From 2024, ELM schemes will also pay for the establishment and management of agroforestry systems. 

We will continue to maintain high environmental and biosecurity standards, ensuring the right tree in the right place. All tree planting should comply with UK forestry standard requirements and seek appropriate regulatory approval. 

Further discussions on this recommendation will be included as part of the new LUMG. 

Recommendation 14 (paragraph 20.5) 

More research and monitoring should be undertaken to understand the full range of environmental factors impacting growth of heather and dwarf shrubs on Dartmoor. 

Response to recommendation 14 

Overgrazing has significant negative impacts on the landscape as well as an individual area.

Evidence from long term monitoring of sites across the UK and from sites on Dartmoor where fencing has been erected to exclude grazing, has demonstrated that this has led to heather recovery. The evidence shows that heavy winter grazing pressure by sheep has the most significant impact on heather. Efforts to restore heathland communities need to take account of this seasonal nature of the grazing impact. 

There are other external factors that can limit heather growth, for example, increased drought through climate change, heather beetle and nitrogen deposition. Heather that is subject to overgrazing has shown to be less resilient to these external factors.

The evidence from the grazing exclosures on Dartmoor, and elsewhere in the country at sites where grazing pressure has been reduced, shows that despite the presence of these external pressures, if grazing is reduced heather can recover. 

Once dwarf shrubs have been lost from an area, successful restoration of heathland condition is likely to be much harder.

Further research into the impact of pests, disease and other external factors will have little influence towards heather and dwarf shrub health in the short term.

The evidence that grazing is negatively impacting heather is robust and we know we need to act swiftly to reduce the grazing pressure on Dartmoor to maximise the chance of recovery. 

Further discussions on this recommendation will be included as part of the new LUMG. 

Recommendation 15 (paragraph 20.6) 

Local scale initiatives to create habitats and restore biodiversity should be promoted and supported. 

Response to recommendation 15  

We support this recommendation of local scale initiatives to create habitats and restore biodiversity. Through the Farming in Protected Landscapes (FiPL) programme, we provide funding for farmers and land managers to work in partnership with National Parks and National Landscape bodies, to deliver projects that achieve positive outcomes for climate, nature, people, and place. This includes projects for positive managements on SSSIs and commons on Dartmoor. 

Our EIP commits us to ensure the best concepts of FiPL are integrated within future ELM schemes. We will also consider how we can support the DNPA to support local projects for biodiversity on Dartmoor.  

We will offer support for local projects or initiatives through CS/SFI schemes. For certain environmental outcomes, we will target our funding towards actions in places where they can have the biggest impacts, in ways that are joined up across larger areas, and are designed to deliver outstanding results. 

Future of agri-environmental (A-E) schemes on Dartmoor 

Recommendation 16 (paragraph 21.2) 

The relationship between A-E scheme prescriptions and the management of protected sites must be transparent and an agreed balance struck between achievement of different objectives in the future. 

Response to recommendation 16 

We agree that prescriptions that support the management of protected sites should be agreed between the Rural Payments Agency (RPA), Natural England and the agreement holder(s). Discussions to support management activities should be agreed collectively and be focused on how to improve the condition of the site.    

A balance needs to be struck between the condition of the site and other objectives that are required to support farming practice and the natural and historic environment, and any actions that support mitigation should be considered carefully and constructively, to ensure a holistic management of Dartmoor. 

Recommendation 17 (paragraph 21.3)  

There is a need for a Dartmoor-wide A-E scheme to encourage strategic improvement and link commoners together. 

Response to recommendation 17 

The government agrees that a single approach is needed to act on the ambition to reduce over-dominance of Molinia and gorse, and we agree with the spirit of this recommendation. The challenge to reconcile the needs of commoners to allow grazing of animals and farmers’ livelihoods, with the need to protect SSSI land from further degradation, would benefit from an overarching agreement framework in which, individual agreement holders would sign up and commit to the goals or plan set out in the framework.

However, a single agreement for Dartmoor would not be practical, and would be very difficult to deliver, given the scope and diversity of the Dartmoor landscape itself. This would be a beneficial topic to discuss collaboratively in the Review’s proposed LUMG.  

LR focuses on bringing landowners and managers together, to deliver large-scale, environmental projects through bespoke, long-term agreements.

Three LR projects are already underway on Dartmoor and are considering how they can encourage land managers, outside of their project areas, to undertake complementary actions across Dartmoor, working towards this whole Dartmoor approach to strategic improvements.

It may also be possible to expand the LR projects, to include more land and land managers. We will be as flexible as possible to help ensure these LR projects and CS actions work for Dartmoor to deliver outstanding results.

Recommendation 18 (paragraph 21.3) 

Commoners should have the possibility to participate in both a local  A-E scheme on their common and a Dartmoor-wide scheme. 

Response to recommendation 18  

As noted in recommendation 17, we believe a Dartmoor-wide scheme may not be practicable or deliverable. However, commoners can and should work together and participate in the management of stock across boundaries, particularly given the open nature of much of Dartmoor.  

Commoners with agreements on their home farm are encouraged to collaborate and join up across the landscape, through our CS and LR schemes.

The bespoke agreements offered through LR will allow participants to take innovative approaches that have not been possible in previous agri-environment schemes. 

Collective agreement of commons rights on grazing within agreements is also important, so that commoners, graziers and owners are clear on responsibilities and actions. 

As with recommendation 17, Defra would support an overarching agreement framework, where individual agreement holders can sign up to the landscape vision, land management plans and objectives, whilst also maintaining autonomy on their individual agreements.  

Recommendation 19 (paragraph 21.3) 

The possibility of introducing a Dartmoor-wide grazing scheme should be considered. 

Response to recommendation 19  

The idea of a Dartmoor-wide grazing scheme is interesting and innovative. The delivery of a landscape level grazing scheme would need careful consideration, including things like setting exclusion areas to help alleviate flood risk.  

Discussions, actions or support that focusses on cross common area grazing could make a real difference to improvement of site condition and to jointly support farming practices and the environment. 

This would be a beneficial topic to discuss collaboratively in the Review’s proposed LUMG.  

In addition, as with both recommendations 17 and 18, the bespoke agreements offered through LR could allow participants to take innovative approaches like this, that have not been possible in previous agri-environment schemes. 

Recommendation 20 (paragraph 21.4) 

Dartmoor Farming Futures should be used as an example of what can be achieved through collaboration and empowerment. Also the current Test and Trials Project taking place on Dartmoor. 

Response to recommendation 20 

We agree that Dartmoor Farming Futures was a good example of what can be achieved in Dartmoor by bringing partners together and empowering them to work together towards a shared vision. Land managers in the LR East Dartmoor projects are already thinking about which elements from the Dartmoor Farming Futures project they can incorporate into their LR plan.   

The projects are also considering how they can encourage land managers outside of their project areas to undertake complementary actions across Dartmoor. 

Farmers in the Dartmoor National Park test were keen to explore a Payment by Results approach based on natural capital values to incentivise enhancement. There remain outstanding concerns on the success of Payments by Results, such as the risk of external factors, for example, bad weather, affecting results. Additionally, the monitoring and verification requirements of Payments by Results systems have been a major challenge to implementing it in practice. 

The recent trial in Dartmoor has provided some useful insights into how to use Payments by Results within commons. We are looking to test a whole farm approach to Payment by Results at a larger scale, as part of our Phase 4 Call for Tests and Trials.  

Further discussions on this recommendation will be included as part of the new LUMG. 

Recommendation 21 (paragraph 21.5) 

Dartmoor’s hill farmers and commoners will need to commit to this new way of working. 

Response to recommendation 21  

The key to the success for any of our agri-environment scheme agreements will be the farmers, commoners and land managers working together to find solutions to complex issues faced by any landscape. It also relies on partnership working with other organisations such as the DNPA, RPA and Natural England. 

We have already seen that those across Dartmoor are capable and willing to work collaboratively and think innovatively across the landscape through LR. 

We are delighted that two projects in Dartmoor (the Central Dartmoor and Walkham Valley LR projects) were recently selected through the second round of the scheme. These will complement the East Dartmoor project, which was selected in the first round and is now halfway through its project development phase. Collectively, the three projects cover over 25,000 hectares of Dartmoor and involve over 100 farmers, commoners, and other land managers. 

Recommendation 22 (paragraph 21.6) 

Where farmers with moorland or commons grazing have an A-E agreement on the home holding, the possibility of introducing a prescription to reward integration of farming operations between inbye land and moorland grazing should be considered. 

Response to recommendation 22 

We recognise the benefits of integrated management between inbye land and open moorland, and effective integration between the 2 is best practice for many commoners.

There are no plans to provide an additional financial incentive above what is already offered through their A–E scheme agreement(s), as integrated livestock management is a key pillar to any farm business.  

Currently, a commoner would need to be party to 2 separate agreements, one in their name on the ‘home farm’ and one as part of the single entity on the common land. This is because the nature of occupancy and control is different. Formally linking the 2, creates a situation where other commoners could assert some degree of control over each other’s ‘home farm’ agreement.   

In addition, it would be difficult to generate a positive payment rate for an integration action. Part of the answer to this rests with the separate recommendation to develop a holistic plan for the whole of Dartmoor (recommendation 29).  

This plan could look at integration at a landscape level.  Separate to the holistic plan, there would be a need for greater adviser support in developing the required agreements in tandem, to ensure integration without formally linking the agreements together. 

Recommendation 23 (paragraph 21.7) 

Need to develop a ‘safe-space’ to encourage risk-taking, innovation and experimentation by agreement holders.

Response to recommendation 23 

Our £270 million Farming Innovation Programme (FIP) provides funding towards industry-led research and development in agriculture, horticulture, and agroforestry, so helping develop real-world solutions to the challenges being faced by farmers and growers.

This research and development (R&D) is then “pulled through” into real products or systems that can be adopted at scale. Further competitions under the FIP will be run, including those aimed at demonstrating the on-farm viability of new technologies and processes.

Outside the EU’s CAP system, we have an opportunity to make farming regulation fairer, more efficient and better suited to farmers in England. Our changes are having a real impact, with the overhaul of harsh cross-compliance penalties leading to a 40% reduction in financial penalties for minor non-compliances, helping towards creating an environment where experimentation and innovation are welcomed. 

The government is open to proposals for innovative management and is supportive of the trialling of experimental techniques and research, with robust experimental design, to tackle outstanding problems, and commit to work with the Review’s proposed LUMG to select suitable trial areas and academic partners to carry out the research. Within existing agreements on Dartmoor, there is flexibility for farmers and land managers to develop management plans that include novel ideas and we agree to support agreement holders to develop these. 

Recommendation 24 (paragraph 21.8 - 21.13) 

The capacity of Dartmoor commons associations to administer A-E agreements need to be increased and made more resilient. 

Response to recommendation 24 

A management payment is available on commons agreements for agreements with common land with two or more graziers (SP10 paid at £7/ha). This payment provides funding to ensure agreement holders, including commoners’ associations, have the appropriate management and governance structures in place to engage all agreement holders, including both commoners and landowners in supporting the delivery and monitoring of their agreement. 

Part of this recommendation mentions in paragraph number 21.12 of the original Review, that some of the pressure over the distribution of scheme payments for CS agreements could be reduced by introducing set (hypothecated) prescription payments for individual actions. 

Payment distribution on a common has historically always been the responsibility of the commoners through a common land and shared grazing agreement. We have not explored alternative means of payment distribution on commons as part of the 2024 offer.  If we were to consider this, it would require involvement of the RPA as administrators of the schemes. 

In paragraph 21.13, the Review suggests that commoners’ associations and individual farmers should be encouraged to take appropriate professional advice as and when this will add value. 

We are mandating industry recognised standards as part of the SFI funding offer to ensure farmers, including commoners receive quality assured and specialist expertise and advice. 

Over 18,000 farmers have received business advice through the Farming Resilience Fund, and we will continue to fund free business advice until March 2025 to help increase profitability and deliver on environmental outcomes.  

From 2024, we will start funding more sustainable farming advice, this will help more farmers understand what opportunities are available to them and increase adoption of tools such as carbon audits and natural capital assessments, supported by trusted advisers.  

The government would encourage commoners’ associations and individual farmers to take appropriate ecological advice so that they develop a better understanding of the relationship between their farming management and agri-agreement outcomes.  

We recognise the importance of timely and helpful technical advice and will continue to provide this to agreement holders as requested and following agreement site checks and Natural England’s SSSI monitoring programme. 

Communications 

Recommendation 25 (paragraph 22.1) 

Defra and ALBs should be tasked to identify ways of communicating more effectively with individual Dartmoor commoners.  

Response to recommendation 25 

We recognise the importance of clear and consistent communications between Defra and its ALBs, with individual commoners on Dartmoor.   

Defra and ALBs are committed to the creation of a LUMG (and multifunctional land use framework). We believe this will provide a transparent forum where, with an independent chair, we can strengthen communications with regular in person conversations to discuss and provide clarity on any questions around messaging and technical information relating to the SSSI management of ELM schemes.  

Grazing and vegetation management 

Recommendation 26 (paragraph 23.1) 

Dartmoor needs more cattle undertaking conservation grazing to combat the spread of Molinia.  A-E schemes should include options to incentivise this. 

Response to recommendation 26 

We recognise the value of cattle for managing Molinia and the importance of this to support our environmental objectives. 

We understand the value of cattle and pony grazing on some moorland and the benefits they can bring in creating a more varied sward structure.  For that reason, we have included an action for ‘keeping cattle/ponies on the moor.’  

In this action, applicants must have a minimum percentage of their permitted grazing livestock units per hectare (GLU/ha) as cattle or ponies, rather than sheep. This action provides flexibility by offering 3 different rates.  

Our current planned approach will not provide flexibility for targeted cattle and pony grazing for short periods of the year over the selected stocking density. We will however explore this as a potential approach going forwards. If found that targeted, short-term cattle and pony grazing is a feasible offer, we will develop and engage stakeholders on the offer, with a view of it being available from 2025 at the earliest. 

Recommendation 27 (paragraph 23.2) 

Dartmoor’ s pony population is genetically important and invaluable for conservation grazing. Ponies and cattle should not be linked for the calculation of  A-E agreement stocking rates and Natural England should not take actions likely to result in a decline in pony numbers. 

Response to recommendation 27

Whilst we recognise the important role ponies play in conservation grazing on moorlands, ponies, like all livestock, exert grazing pressure.

If ponies were to be excluded from stocking density calculations, we would have no control over grazing pressure on the moorland, and the potential for over grazing would be increased.

This would prevent us from achieving required improvements in habitat condition and therefore impact the delivery of many of our environmental objectives. It would also have implications for animal welfare and the economic, environmental, and social sustainability of grazing on the moor.  

We are aware that previous agri-environment schemes have provided payment for keeping cattle, but not ponies, and that this has been linked with a decline in pony numbers. Under the new SFI and CS moorland actions, we will provide payment to farmers who include cattle, ponies or a combination of the two in their grazing regime.

Applicants must have a minimum percentage of their stock as either cattle or ponies, to be eligible.

Applicants who are grazing with a native at-risk breed of pony (or cattle or sheep) will also be eligible for the native breed supplementary payment.

Additionally, it should be noted that resident pony populations are exempt from stock exclusion action, meaning farmers will not have to remove ponies from the moorland to receive payment for this action.  

We believe that this new approach, which pays farmers for keeping ponies with an additional payment for native at-risk pony breeds, will provide fair reward for stocking with ponies at appropriate densities on moorlands.

This will support the healthy pony population being an essential part of Dartmoor’s future. This approach was supported by stakeholders during our content development meetings, including the Foundation for Common Land. Once the new offer is launched, we will monitor the impact on pony populations and take further action if required.

Recommendation 28 (paragraph 23.3) 

Maintaining 3 species grazing and recognising the contribution that sheep make to Dartmoor’s heritage and biodiversity should be an integral part of the vision for Dartmoor. 

Response to recommendation 28 

The new moorland offer has standardised actions which focus on sustainable livestock management, supporting grazing by cattle, ponies, and sheep, also known as ‘3 species grazing’, acknowledging the benefits this presents to the natural and historic environment.  

The ‘Low Stocking Density’ action aims to incentivise lower stocking densities where it is beneficial for habitat restoration and management. All stock that graze the moor must be included in the stocking density calculations. 

Evidence has shown that cattle graze less selectively than sheep and on coarser forage, creating a more varied sward structure. They also trample bracken, control scrub and graze wetter habitats than sheep.

We have the ‘Keeping Cattle/Ponies on the moor’ action to reward farmers that graze with a percentage of their permitted GLU/ha as cattle or ponies, rather than sheep. 

Applicants choosing the ‘Moving Livestock on Moorland’ action will be paid to take stock off the moorland for periods of time and actively shepherd stock whenever they are on the moor. 

Recommendation 29 (paragraph 23.3) 

Reducing the area of Molinia and ungrazeable gorse to play a central part of a strategy to increase the palatable area of the moor for sheep (and other livestock) and address the localised over-grazing of heather and dwarf shrubs. 

Response to recommendation 29  

Implementing a holistic strategy to reduce Molinia and gorse is unlikely to lead to any substantial increase in the forage available for grazing, however it could play a significant role in how livestock are distributed across the moor.

More effective distribution of livestock will help reduce high grazing pressure on sensitive habitats such as heathland communities.

Grazing regimes that make effective use of the available herbage without causing overgrazing are essential and can be achieved using the ‘3 species grazing’ approach.  

Natural England commits to working with the Review’s proposed LUMG, to help stakeholders and farmers come to a shared understanding of how grazing management can be used collaboratively on the moor, to meet the objectives and vision for Dartmoor. 

Recommendation 30 (paragraph 23.4) 

Immediately, sheep keepers need to demonstrate they can shepherd their flocks to protect heather and dwarf shrubs from being over-grazed. If this isn’t successful, we recognise there will be pressure to remove sheep from affected areas, for at least part of the winter. 

Response to recommendation 30 

Defra welcomes further efforts to protect heather and dwarf shrubs. Agreement holders already receive a shepherding payment that recognises the difficulties and need for shepherding on the commons.   

There is also a payment in the new moorland offer for shepherding stock, which will be available on land above the moorland line.

 The ‘Manage livestock grazing on moorland’ action will pay applicants to take stock off the moorland for periods of time and actively shepherd stock whenever they are on the moor. The action had stepped payments, which offers flexibility in the amount of time stock are on the moor, and farmers can select the months most appropriate to their farm. 

Grazing regimes that make effective use of the available herbage without causing overgrazing, are essential and can be achieved using the ‘three species grazing’ approach. Natural England commits to working with the Review’s proposed LUMG, to help stakeholders and farmers come to a shared understanding of how grazing management can be used collaboratively on the moor, to meet the objectives and vision for Dartmoor. 

Recommendation 31 (paragraph 23.5) 

If sheep do need to be removed over winter, the possibility of creating a service to match those offering sheep-keep with those requiring it should be considered. Also, more support for providing sheep accommodation on home-farms. 

Response to recommendation 31 

The government accepts the difficulties faced by commoners when it comes to off wintering livestock or providing accommodation for sheep over winter.  

This will be explored as a potential approach going forwards. 

We commit to work with the LUMG, to investigate what potential support or services may be developed, and how we can bring in private sector funding, to sit alongside other funding, for example through the Farming in Protected Landscapes Programme (FiPL) which can deliver innovation in this area. 

Recommendation 32 (paragraph 23.6) 

Positive action needs to be taken to address the issue of livestock straying.   

Response to recommendation 32 

The government agrees that positive action is required to help address the issue of livestock straying across the moor. We will welcome the employment or agisters or reeves by the Dartmoor Commoners’ Council or other stakeholders. The government will also agree to the use of any additional shepherding where it would lead to improved management of grazing livestock.  

Payments for the management of shared grazing on commons, that agreement holders receive currently, could be used towards the funding of this additional shepherding or the employment of agisters or reeves. 

The Farming in Protected Landscapes (FiPL) programme is another option available to support action on livestock straying. FiPL provides funding for grazing management equipment, such as gates, cattle grids, and handling facilities. It also offers bespoke or innovative grazing management technology, including NoFence virtual fencing.

Defra commits to reviewing the use of this innovative management technology through FiPL and will determine whether it would be appropriate to fund similar through the ELM in future.  

Further discussions on this recommendation will be included as part of the new LUMG. 

Recommendation 33 (paragraph 23.7) 

The future role of swaling needs to be fully debated. 

Response to recommendation 33 

Most Higher-Level Stewardship (HLS) agreements on Dartmoor have swaling plans already agreed with Natural England and are used where swaling contributes to habitat management or supports wildfire management.  

However, the practice of swaling needs to be considered carefully in the wider context of policy development, when it comes to managed burning of vegetation and wildfire mitigation. For example, frequent swaling may have contributed to current Molinia over dominance in some areas and directly inhibits reducing flood risk.  

Swaling is unlikely to contribute to effective Molinia control unless carried out alongside additional measures like re-wetting to improve hydrology, and appropriate post-burn grazing management. 

Swaling may have an ongoing role in management of heath on mineral soils, and may have a role for targeted wildfire mitigation, but only when applied in accordance with a comprehensive wildfire management plan. Its use on peat should be a last resort where no other intervention method is viable. 

Further discussions on this recommendation will be included as part of the new LUMG. 

Recommendation 34 (paragraph 23.8) 

Wildfire control and prevention needs to be afforded a high priority on Dartmoor.  

Response to recommendation 34 

Wildfire control and prevention is a high priority on Dartmoor. Actions that improve the moorland’s health and help achieve favourable SSSI conditions also reduce fire risk. These actions can be funded through the ELM schemes. In addition, Defra is exploring how to further support farmers to mitigate wildfire risk, on significant high-risk habitats such as moorlands.  

However, wildfires are unpredictable and any assistance offered by Defra to mitigate against them cannot prevent them entirely. Farmers and landowners are solely responsible for the condition of their land and its susceptibility to the risk of wildfire. 

Landscape-scale habitat management, supported by both SFI and CS, will also play a crucial role. As the Home Office carries out an England Wildfire Strategy and Actions Plan scoping exercise, it is vital that commoners actively contribute to this to ensure their voices are heard and their unique land management practices are considered. 

The Dartmoor Fires Partnership already affords wildfire control and prevention a high priority. The aim for this partnership is to develop an all-embracing fire plan for all commons and access land, with ongoing support from agencies and individuals. Natural England agrees to continue working with the Dartmoor Fires Partnership to support and co-ordinate wildfire management on Dartmoor. 

Roll-over of HLS agreements 

Recommendation 35 (paragraph 24.1) 

The current 1 plus 4 extension formulation should move to default 2 plus 3. Three plus two should also be considered. 

Response to recommendation 35 

We have already written to agreement holders to set out our proposals for agreeing further annual extension to HLS agreements, into 2025.   By offering a second 1 year extension to all those who previously received a one-year extension we have implemented the 2 plus 3 recommendation.  

We want to work closely with agreement holders over the next period to help them to prepare to apply for a new CS/SFI agreement at a point when the time is right for them to do so.  

Alternatively, we also want to work closely with agreement holders who want to agree further HLS extensions, if required, with a plan of action and trajectory to further improvement of SSSI site condition.  

There are several other tools that are available to help support farmers and land managers, including grants. There are grant offers available for feasibility studies and implementation plans to help support applying for a new agreement, and to look at opportunities for improvement of specific features on land.  

Recommendation 36 (paragraph 24.2) 

Our recommendations for the conduct of negotiations over HLS extensions should be adopted. 

Response to recommendation 36 

Negotiations between parties (after the 2 year period) will be conducted carefully and sensitively and look at ways in which the overall condition of protected land can be improved, as well as how sustainable land management and traditional farming practices can be supported alongside this.  

Discussion and negotiation began with individual commons associations in January 2024 for 1 year rollover of HLS agreements. 

Natural England will commit to discuss issues of threat or damage to SSSI features with the Review’s proposed LUMG and will implement remedial solutions through the group where possible. Members of the group with statutory duties will retain those responsibilities and will need to exercise those functions independently. 

Recommendation 37 (paragraph 24.5) 

Discussions over the roll-over of HLS agreements should be broadened to include future options for the affected commons. 

Response to recommendation 37 

As noted, above, we have already written to agreement holders to set out our proposals for agreeing further annual extension to HLS agreements, into 2025.    

We want to work closely with agreement holders over this next period to help them to prepare to apply for a new CS/SFI agreement at a point when the time is right for them to do so.  

Recommendations for Natural England’s future operations on Dartmoor

Recommendation 38 (paragraph 25.1) 

Natural England  must recognise the scale of the challenge it faces to rebuild trust and confidence on Dartmoor. Significantly increased staffing resource will be required to achieve this. 

Response to recommendation 38 

The government recognises there is a need to rebuild confidence and trust with commoners and stakeholders on Dartmoor. Natural England has already taken action to appoint a principal adviser to oversee the implementation of the Review’s recommendations and have new, dedicated senior advisers working on the ground. Natural England also supports the establishment of the Review’s proposed LUMG and is already working through existing stakeholder groups to start to rebuild relationships. 

At the Oxford Farming Conference earlier this year, the SoS committed to reviewing interactions between Defra group organisations and farmers. Defra has initiated a project focused on improving relationships between farmers and all parts of Defra group, including but not limited to Natural England, aiming to reduce any feelings of suspicion or distrust. This includes reviewing our communications to make sure they are clear and the language and tone is respectful. Defra is also creating new opportunities to listen to farmers about their recent experiences interacting with Defra, so that further improvements can be identified. 

Recommendation 39 (paragraph 25.2) 

There will also need to be a complete change of approach to the way in which Natural England engages on Dartmoor. Openness and the creation of partnerships are the key to successful delivery. Protocols will need to be established for visits and inspections. 

Response to recommendation 39 

We recognise there is a need to rebuild confidence and trust with commoners and stakeholders on Dartmoor. Natural England has already taken action to appoint a principal adviser to oversee the implementation of the Review’s recommendations and has new, dedicated senior advisers working on the ground.  

Natural England is working to re-establish its capacity and are working to put in place resources that will allow agreement holders and SSSI owner occupiers to get the advice they need. Natural England also supports the establishment of the LUMG and is already working through existing stakeholder groups to start to rebuild relationships. 

Natural England has identified additional resource to support more time for engagement on Dartmoor. This will allow more time for farm visits, including a focus on face-to-face communication and feedback, whilst supporting the fostering of open working relationships. Natural England will continue to work on improving their co-ordination with RPA for visits and notice to our customers, to support this. 

Recommendation 40 (paragraph 25.2) 

Natural England should have a dedicated and senior communications lead for Dartmoor, at least as an interim measure.   

Response to recommendation 40 

Natural England has appointed a Principal Adviser to lead communications for Dartmoor.   

Recommendation 41 (paragraph 25.3) 

Natural England  will also need to consider how the SSSI condition monitoring can be made more transparent and fit for purpose. 

Response to recommendation 41 (paragraph 25.3) 

Natural England undertook an extensive monitoring survey across the SSSIs on Dartmoor and expects the findings of this survey to be available by the end of the year (2024). Natural England commits to sharing the findings with stakeholders and agreement holders on each common and will explain how this effects their view about SSSI conditions and site management.  

Natural England commits to working with the Review’s proposed LUMG to ensure there is a clear and common understanding about which SSSI features are part of the designation notification process, and how these features are linked and effected by different land management practices. 

Dartmoor statutory bodies 

Recommendation 42 (paragraph 26.1) 

The structure and operation of the Dartmoor Commoners’ Council should be reviewed to identify ways of reinforcing its effectiveness. 

Response to recommendation 42 

The Dartmoor Commons Act 1985 under which Dartmoor Commoners’ Council (DCC) was constituted, provides DCC with the ability to reinforce its effectiveness in its core function - to maintain and promote the proper standards of livestock husbandry and management of the commons. DCC already takes an active and robust role to secure regulations and best practice, whilst enabling the grazing of livestock within the Dartmoor National Park. 

We have agreed to the creation of the LUMG, as recommended by the report in recommendation 3, and therefore need to consider how this group can work collaboratively with the DCC. An option for consideration could be for DCC to inform the LUMG on issues of livestock management and regulations and enable a 2 way process for the LUMG to act as a buffer for DCC to reduce levels of contention.