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					                                                                      WMJC/3




                    Law of Property Act 1925 – Section 194

                           Wetley Moor Staffordshire



                              Public Local Inquiry

                                  March 2003




            Proofs of Evidence by Mark Preece, Countryside Officer

    Parks and Countryside Service – Staffordshire Moorlands District Council

                   On behalf of Wetley Moor Joint Committee




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                                  Contents



    Summary                                                  page 1

1   Introduction to self                                     page 4

2   Conservation management objectives at Wetley Moor        page 5

3   Details of conservation management at Wetley Moor        page 8

4   Costs of heathland management work at Wetley Moor        page 10

5   Survey and monitoring                                    page 11

6   Examples of best practice in heathland management from   Page 20
    elsewhere

7   Details of the proposed fencing and access features      page 21

8   How the grazing trial will be monitored                  page 25

9   List of Appendices                                       page 27




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                                     Summary

Conservation management objectives for Wetley Moor Management Plan 2001 –
2006 require enhancing and restoring through Management the lowland heathland at
Wetley Moor.

Between 1995 and 2002 large scale Birch and Willow scrub clearance work has
been carried out. Areas of ground vegetation have been cut with the cuttings being
removed from site. Fires caused accidentally or by vandals have occurred. The
commoner‟s cattle have also carried out some grazing.

The cost of mechanical management methods are significant. Scrub clearance has
cost £1,000 per hectare and ground vegetation cutting has cost up to £1,500 per
hectare. Due to the specialist machinery required it has not been possible to obtain
a contractor to carry out ground vegetation cutting in some years.

Monitoring of the vegetation has been carried out through the following principal
surveys:

         Survey of national vegetation communities and the condition and cover of
          heather, Jerram, 1994

         Heather condition survey, Penny Anderson ecological consultants, 2001

         English Nature lowland       heathland    common    standards    condition
          assessment, 2001

The surveys have indicated that:

         There is a decline in the area of heather cover

         The Purple Moor Grass is out-competing the heather over the site as a
          whole and where cutting or burning has occurred.

         A dominance of over mature and degenerate heather

         A lack of bare ground

         The majority of the vegetation is tall and there is a poor vegetation
          structure.




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The existing management regime is not producing a heathland in „favourable
condition‟ as defined by English Nature. Additional grazing is required to remove
selectively the excess of Purple Moor Grass to provide light and space for heather
seedlings to establish. Grazing is needed to prevent re-invasion of Birch and Willow
seedlings in areas already cleared of scrub.

Best practice from other heathland sites is that grazing is used as a best practice
management tool. Many sites that have used mechanical methods of management,
have successfully introduced grazing. Many of these sites have open public access.
Other heathland sites are successfully using stock that is free ranging within a
fenced enclosure. These include sites within urban areas such as Sutton Park in
Sutton Coldfield.

Fencing is required to prevent livestock straying on to adjacent roads. Ten cattle will
initially graze the trial area in line with recommendations from English Nature for
heathland restoration. As the heathland quality improves it is likely that this stocking
density can be reduced. 480 m of post and wire fencing is proposed.

          Seven self-closing bridle gates and field gates will provide access.

          Grazing will typically be for six months from May to October.

          The grazier will be subject to the terms of a grazing licence.

          Existing ponds will be excavated to provide a water supply and a mobile
           water bowser will supplement this.

These practical arrangements are the same as those at Grange Heath Royal Society
for the Protection of Birds reserve where I took the lead in establishing a successful
heathland grazing project in 1995.

A trail grazing area is required to prove that a grazier can be sustained at Wetley
Moor and to assess the day-to-day practicalities of keeping stock within a fenced
area of the common.




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Monitoring of the benefits of additional grazing will consist of:



          Carrying out an annual English Nature Common standards lowland
           heathland condition assessment inside and outside the trial area to enable
           a comparison of the overall condition of the heathland.

          Repeating the Heather Condition Survey by Penny Anderson Ecological
           Consultants 2001 at the end of the trial.

          Fixed point photographs to provide a visual comparison of the vegetation,
           inside and outside the trial area.




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1     Introduction to self


1.1   My name if Mark John Preece. I commenced employment as a Countryside
      Officer for Staffordshire Moorlands District Council on 18 th October 1999. I
      have been employed for just under three and a half years. I have a degree in
      Biology from the University of Wolverhampton.

1.2   I was employed by the Royal Society for the Protection of Birds (RSPB) from
      1987 to 1999. Between 1992 and 1999 I was employed as an Area Warden
      on the RSPB Dorset Heathland Project Team. During this time I was involved
      in the restoration and management of at least 20 heathland sites across
      Dorset. My duties included supervision of staff, contractors and volunteers
      carrying out heathland restoration, introduction and implementation of
      conservation grazing schemes and ecological monitoring on heathland sites. I
      was also responsible for the establishment and restoration of a new RSPB
      heathland reserve where grazing was introduced for conservation reasons.

1.3   Between 1987 and 1992 I was employed as an Assistant Warden on a range
      of RSPB reserves throughout the UK.

1.4   I have been responsible for overseeing day to day management at Wetley
      Moor since commencing employment with Staffordshire Moorlands District
      Council. I have taken a lead in revising the Management Plan for Wetley
      Moor and producing and implementing a costed annual Countryside
      Management work programme for Wetley Moor.

1.5   Other duties as a Countryside Officer include:

            the management of a promoted rights of way network

            management of other Countryside sites owned by Staffordshire
             Moorlands District Council




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           Advice to community groups, farmers and landowners on aspects of
            Countryside, recreation management, public access and conservation
            management

           The administration of applications to divert public rights of way and
            advice on the environmental implications of planning applications

           Promotion of environmental awareness and environmental education


2     Conservation management objectives at Wetley Moor


2.1   A heathland in good ecological condition has a number of key features:


           Tree scrub cover restricted to 15 percent of the site or less

           A varied age and height structure of heather and other vegetation

           A predominance of heather and other dwarf shrubs (Bilberry and
            Gorse) with grass species such as Purple Moor Grass present but not
            dominant.

           1 – 10 percent cover of undisturbed bare ground


2.2   To achieve this desired state a number of key management problems have to
      be addressed as outlined in the table below:


       Management problem                  Explanation

       Mature tree scrub                   Will shade out heather and cause a
                                           change to woodland.

       Re-growth from cut stumps           Will grow up to form mature tree scrub

       Seedling trees                      Will grow up to form mature tree scrub

       Old heather/vegetation of uniform Will not permit the diversity of fauna that
       age and structure                 a varied age and structure will

       Selective removal of coarse Grasses will out compete heather. This
       grasses in particular Purple Moor will lead to a loss of the heather and the
       Grass                             formation of grassland

       Lack of bare ground                 Bare ground is a vital habitat for key
                                           invertebrates and for annual plants.
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2.3   The Wetley Moor Management Plan approved by Wetley Moor Joint
      Committee in 1995, outlined a programme of heather cutting and Birch and
      Willow scrub clearance, to improve the quality of the lowland heathland at
      Wetley Moor.

2.4   The Wetley Moor management Plan 2001-2006 advocated the following key
      policies to address the management problems at Wetley Moor.

           To enhance, through management the qualities of existing lowland
            heathland communities, by a combination of small scale heather cutting
            with the removal of cuttings from site, on a 15-20 year cycle, together
            with the removal of seedling Birch and Willow scrub. The creation of a
            high quality heathland can only be achieved by grazing.

           To restore areas of heath that have become degraded through scrub
            invasion by removing approximately 5·6 hectares of dense Birch and
            Willow scrub and scattered scrub over the whole site (while retaining
            scattered clumps and individual trees for landscape value and as song
            posts for birds and nectar sources for invertebrates).


2.5   The management techniques that are currently used to address the
      management problems and achieve management policies are summarised in
      the table below with the limitations of each technique. All these management
      techniques have a cost implication.




      Management           Management Technique         Limitation
      problem

      Mature tree scrub    Felling trees                Labour intensive

      Re-growth from cut Treat stumps or spray re- Undesirable introduction of
      stumps             growth with chemicals     chemicals      into     the
                                                   environment.

                                                        Rarely totally effective.

                                                        Labour intensive




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Management problem         Management Technique        Limitation

Seedling trees             Hand pulling                Cannot       cope    with
                                                       quantities   of seedlings
                                                       produce.

                                                       Labour intensive.

                            Cutting on a 15 – 20 year Some areas are too rough
                            rotation.                 / wet to allow machinery to
Old heather / vegetation of                           operate.
uniform age and structure
                                                      Intrusive     and    cannot
                                                      achieve small – scale
                                                      variations in structure and
                                                      age.

                           Burning                     May encourage copycat
                                                       fires.
                           Not used as a deliberate
                           management method at Danger of igniting coal
                           Wetley Moor but many seams.
                           fires due to vandalism.
                                                    Intrusive    and     cannot
                                                    achieve          small-scale
                                                    variations in structure and
                                                    age.

                                                       Wet ground may make
                                                       burning ineffective.

Selective     removal of Cutting                       Machine cutting is non-
coarse       grasses  in                               selective.
particular   Purple Moor
Grass                                                  Some areas are too rough
                                                       to allow machinery to
                                                       operate.

                                                       Off site disposal required.

                                                       Need to repeat annually.

Lack of bare ground        Hand    or     mechanical Intrusive  and     cannot
                           digging                   achieve a small-scale
                                                     patchwork of bare ground.




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3     Details of Conservation Management at Wetley Moor


3.1   The main heathland conservation management from 1995 to the present has
      consisted of heather cutting with the removal of heather cuttings and the
      removal of invasive Birch, Willow and Oak scrub. The table below provides a
      summary of the number of hectares each year receiving different types of
      management.


3.2   Summary of main heathland management 1995 – 2001



      Year               95/96 96/97 97/98 98/99 99/00 00/01 01/02 02/03


      Activity

      Heather        /
      vegetation
                          1·5    2             1·75            1·5              2
      cutting

      Birch / Willow
      Oak     scrub
                                 4        2      5      5       13     6·1     3·5
      removal

      Uncontrolled
      fire                3                            0·5     0·7      5




3.3   Notes relating to the above table


            Though not a deliberate management activity the area of land affected
             by recorded uncontrolled fires is included for information. It has been
             suggested there were very extensive fires effecting the whole site
             during the mid nineteen seventies.




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           Scrub clearance has been carried out by a mixture of contractors and
            volunteers. The stumps of Birch, Willow and Oak scrub were treated
            with a chemical to prevent re-growth.

           Heather cutting has been carried out by contractors using a specialist
            heather cutter. No cutting was carried out in 2001 – 2002 because no
            contractors could be found to carry out the work. Obtaining a
            contractor annually to carry out heather cutting is a major management
            problem. In 2002 no local contractors could be found to carry out the
            work and a contractor had to be employed that was based in Dorset.

           In addition small areas of bare ground have been hand dug in 2001 and
            2002 by volunteers.

           Small areas of 0·1 - 0·2 hectares of invasive Japanese Knotweed have
            been controlled, by spraying with an appropriate chemical between
            2000 and 2002.

           Small areas of gorse coppiced were in 2001 and 2002.


3.4   Between 1996 and January 2002 approximately 38·6 hectares of invasive
      scrub of various densities has been removed from Wetley Moor. The map in
      Appendix A shows the location of removed scrub. Scrub has been removed
      from approximately 50 percent of the heathland Site of Special Scientific
      Interest (SSSI). Midway through the Wetley Moor Management Plan 2001 –
      2006 the planned programme of scrub clearance is on target to being
      achieved.


3.5   Approximately 17·95 hectares of 26 percent of the heathland SSSI has been
      cut or burnt since 1994. The distribution of these cut or burnt areas is shown
      on the map in Appendix B. Cutting has not been possible in some years due
      to difficulties in obtaining the specialist contractors needed.




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3.6   The only grazing management the site has received, between 1995 and the
      present is grazing by the commoner‟s cows. The commoner has the right to
      graze up to 15 cows and seven followers on the common.


4     Costs of Heathland Management


4.1   The costs of scrub clearance can vary according to the density of scrub and
      the nature of the ground conditions. Clearance of 2·5 ha of 50 – 70 % scrub
      cover in October 2002, with chemical treatment of stumps by contractors cost
      £2,500. This gives a cost estimate of £1,000 per hectare for the removal of 50
      – 75% cover scrub. It is anticipated that the cost of scrub clearance will rise in
      the future. Contractors have indicated that they have lost money on recent
      scrub clearance contracts, because they have not adequately considered the
      problems of the terrain on the Moor. Estimated future costs are likely to be in
      the region of £2,000 per ha as indicated in the Wetley Moor Management Plan
      2001 – 2006.


4.2   A specialist contractor can only carry out heather cutting with the removal of
      cuttings. Due to the very rough and wet nature of the ground, a specialist
      heather cutting and collecting machine is required.          Costs of cutting
      operations were nearly £3,000 to clear and remove two hectares of heather /
      ground vegetation in October 2002 at a cost of £1,500 per hectare.


4.3   Small areas of invasive Japanese Knotweed have been controlled by
      chemical spraying at an annual cost of £500 between 2000 and 2002. Up to
      £500 is allocated to carrying out small amounts of gorse clearance on an
      annual basis.


4.4   Between 1991 and 2002 Wetley Moor Joint Committee has received an
      annual Countryside Stewardship grant of approximately £4,000, to offset the
      costs of heathland management.




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5     Survey and Monitoring


5.1   Vegetation and Heather Condition Survey, Jerram 1994


      5.1.1. A vegetation survey of Wetley Moor was carried out in May 1994. The
             survey identified and mapped the national vegetation classification
             communities, as well as the cover and condition of the heather present.

      5.1.2 The survey found that the dominant National Vegetation Community
            was the H9a Calluna vulgaris – Deschampsia flexuosa heath; Molinea
            caerulea sub community with Calluna co-dominant with Molinea. It
            was noted that in some areas Molinea was more dominant than
            Calluna. The local abundance of Polytrichum commune was also
            noted. On well drained slopes H9e Calluna vulgaris – Deschampsia
            flexuosa heath Hpynum cupressiforme sub community occurred. This
            community is characterised by less Molinea, more Bilberry and Wavey
            Hair Grass. The distribution of vegetation communities is shown in the
            summary of the report given in Appendix C.

      5.1.3 The percentage ground cover of heather plants was estimated and
            mapped at 1:2,500. It was assigned to the six percentage cover
            categories:

            > 75%
            51 – 75%
            26 – 50%
            10 – 25%
            < 10%
            Absent




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      5.1.4 The height of heather plant was recorded in the following three
            categories:

            > 30 cm
            15 – 30 cm
            < 15 cm

      5.1.5 For the purposes of the survey heather was defined as the following
            dwarf shrubs:

                   Heather or Ling (Calluna vulgaris)
                   Bell heather (Erica cinerea)
                   Cross Leaved Heath (Erica tetralix)
                   Bilberry (Vaccinium myrtillus)
                   Crowberry (V vitis-idaea)
                   Cowberry (Empertrum nigrum)

      5.1.6 The survey found that the heather was mature to over mature
            throughout. The survey recommended a programme of tree and scrub
            removal followed by the reintroduction of grazing to control Birch
            regeneration. It was recognised that grazing may help to increase the
            species diversity of the heathland communities. A programme of
            heather cutting was recommended to create firebreaks and a variety of
            heather age structures.


5.2   Heather condition survey Penny Anderson Ecological Consultants, 2001.


      5.2.1 A heather condition assessment of Wetley Moor was repeated in 2001,
            following the methods used in 1994 by Jerram. A copy of the heather
            conditions survey carried out by Penny Anderson Associates,
            Ecological Consultants is presented in Appendix „D‟.

      5.2.2 Pages 3 – 6 of Appendix „D‟ detail the results. In summary:

            a)     only a third of the site has heather cover exceeding 50% ground
                   cover. On a heathland site in favourable condition it would be
                   expected that the heather component would be at 50% or more
                   across the whole site.




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            b)     81·5% of the heather is over 30 cm tall. A range of heather of
                   different heights would suggest a heathland in favourable
                   condition.

            c)     78% of the heather is mature of old heather. A mosaic of
                   different ages would indicate a heathland in a more favourable
                   condition.

      5.2.3 Pages 9 and 10 give concluding remarks. Of critical concern is the
            indication that the Purple Moor Grass (Molinea caerulea) is out-
            competing the heather leading to a decline in the heather cover. New
            seedlings find it difficult ot establish if the grasses are able to grow
            unchecked.


5.3   Comparison of the Heather Condition Survey in 1994 and 2001.



      5.3.1 Pages 6 and 7 of Appendix „D‟ provide a comparison of the Survey
            carried out by Penny Anderson in 2001 with the survey carried out in
            1994 by Jerram. There appears to have been a significant decline in
            heather cover at Wetley Moor since 1994. The graph on page 7 shows
            a:

                  30% decline in the area of heather cover class 51 – 75% heather
                   cover

                  25% increase in the area of heather cover 10 – 25% heather
                   cover

      5.3.2 The map in Appendix „E‟ provides a visual comparison of the
            distribution of heather cover classes in 1994 and 2001. Large areas
            that were formerly in higher heather cover classes, have been replaced
            by a lower heather cover class. The maps provide strong visual
            evidence that heather is declining at the expense of Purple Moor
            Grass.




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5.4   Results of heather cutting and fire damage.


      5.4.1 Appendix „F‟ shows the location of areas where heather and other
            vegetation has been cut and removed and areas that have received fire
            damage. On drier slopes where there is less Purple Moor Grass
            present heather regeneration has been good after cutting. Point 1 on
            the map shown by Photograph 1 recorded in January 2003 shows good
            heather regeneration from an area cut in 1998. This cut was carried
            out in the H9e Calluna vulgaris - Deschampsia flexuosa heath Hyynum
            cupressiforme sub community occurred.            This community is
            characterised by less Molinea, more Bilberry and Wavey Hair Grass.

      5.4.2 Photograph 2 taken at point 2 on the map in January 2003 shows an
            area cut in October 2000. This is in the dominant National Vegetation
            Community at the Wetley Moor – the H9a Calluna vulgaris –
            Deschampsia flexuosa heath; Molinea caerulea sub community with
            Calluna co-dominant with Molinea.         The photograph shows a
            dominance of Purple Moor Grass.

      5.4.3 Photographs 4 and 5 of Appendix „F‟ show the typical vegetation
            structure across the H9a community. A dominance of Purple Moor
            Grass, sparse old Heather and a lack of bare ground are visible. The
            uniform tall structure of the vegetation can be seen. These areas
            received extensive fire damage in the mid nineteen seventies.



5.5   English Nature common standards lowland heathland condition assessment.



      5.5.1 Appendix „G‟ presents a summary of a Heathland Condition
            Assessment based on a method devised by English Nature that was
            carried out in October 2001 by Staffordshire Moorlands District Council
            Countryside Officer.




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     5.5.2 The survey involves assessing “attributes” (indicators of the quality of
           the lowland heath) against defined targets. A target is defined as the
           value or range of values that define the desired condition of the
           attribute. Failure to meet any of the attribute targets will define the
           SSSI as being in an unfavourable condition. If an unfavourable
           condition is not being addressed by management, and the site is likely
           to deteriorate as a result, then a “declining” status will be designated.

     5.5.3 For example for the attribute degenerate heather the target is not to
           exceed ten percent cover on average within each 2 x 2m sampling unit.
           For the attribute young heather the target is to exceed 15% cover in
           each 2 x 2m sample.

     5.5.4 A structured walk was carried out in each management compartment.
           An indication of the route of these structured walks is shown on the
           map in Appendix „G‟. Ten 2m x 2m quadrats were sampled at 50 pace
           intervals along each route. Details of the attributes and targets
           sampled in each quadrat are shown on the recording sheet on page 3
           in Appendix „G‟. It is not intended to reproduce all the recording sheets
           but an example is shown on page 5 and 6 in Appendix „G‟.

     5.5.5 The results for each quadrat are combined to produce an overall result
           for the attribute within that compartment. A summary of the overall
           results for all compartments at Wetley Moor is presented on pages 3,4
           and 7 of Appendix „G‟.

     5.5.6 All management compartments surveyed showed estimates below the
           expected target values. In particular:

                 Excessive quantities of old heather

                 Lack of a mosaic of young, building, mature and old heather

                 Dominance of Purple Moor Grass and mats of acrocarpous
                  mosses.

                 A lack of bare ground




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      5.5.7 All these characteristics combine to define Wetley Moor SSSI as in an
            unfavourable condition.


5.6   Vegetation monitoring transects


      5.6.1 Three vegetation monitoring transects were established in 2000. The
            location of these is shown on the map in Appendix „H‟. A total of 38 2 x
            2m sampling quadrats were recorded along 3 transect lines across
            Wetley Moor. The conclusions from the transects are:

                   The average height of the shrub layer is in excess of 30 cm.

                   The heather is largely tall and over mature with holes developing
                    in it.

                   There is a high percentage cover of Purple Moor Grass (Molinea
                    caerulea).

                   Little bare ground was recorded along any of the transect lines.

      5.6.2    This data supports the English Nature Condition Assessment detailed
              in Appendix „G‟ and supports the definition of a heathland in
              unfavourable condition.


5.7   Other Survey and Monitoring


      5.7.1 A range of other surveys/monitoring has been carried out at Wetley
            Moor as shown below.

                   Staffordshire Wildlife Trust Survey 1990

                   Baseline    Invertebrate    survey,    Ecosurveys      Ecological
                    Consultants 1994

                   Baseline survey of Amphibians, Reptiles and Mammals,
                    Echotech 1999

                   Survey of Hymenoptera (Bees, Wasps and Ants) - J Webb 2000

                   Survey of Invertebrates of water bodies, - Linda Holloway 2000

                   Annual monitoring of Birds of Conservation Concern 2000, 2001
                    and 2002

                   Survey of Bryophtes (Mosses and Liverworts) 2002
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      5.7.2 The Baseline Invertebrate Survey, Ecotech 1994 showed Wetley Moor
            had a typical assemblage of heathland/moorland invertebrates. One
            nationally notable ground beetle Pterostichus angustatus was located.
            This species requires early successional stages of heather and would
            benefit from an increase in grazing intensity. The survey of Bees
            wasps (Hymenoptera) 2000 revealed a community typical moorland
            assemblage of species, with one species Andrena tarsata not recorded
            elsewhere in Staffordshire.


      5.7.3 None of the base line surveys indicate that there are rare or sensitive
            species present that would suffer from increasing grazing at Wetley
            Moor.


5.8   Conclusion and management Implications from survey work


      5.8.1 The heather condition survey by Penny Anderson 2001 (Appendix „D‟)
            states in section 3·19

                  the regeneration potential is present to replace heather if it is
                   removed, by whatever means. There is, however substantial
                   competition from the Purple Moor Grass particularly and in
                   several places the heather appears to be out competed by this
                   species.

      5.8.2 Competition from Purple Moor Grass is most evident where cutting or
            fire damage has been carried out in the dominant National Vegetation
            Community at the Wetley Moor – the H9e Calluna vulgaris –
            Deschampsia flexuosa heath; Molinea caerulea sub community with
            Calluna co-dominant with Molinea.


      5.8.3 The Heather Condition Survey carried out by Penny Anderson in 2001
            (Appendix „D‟) further concludes in section 3·20 that:

                  It appears that the Purple Moor Grass is becoming more
                   abundant at the expense of the heather, as might be expected if
                   new heather seedlings find it difficult to establish and that the
                   grasses are not contained by grazing.




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     5.8.4 Heather condition surveys carried out in 1994 and 2001, English Nature
           common standards condition assessment 2001 and the vegetation
           monitoring transects 2000, all indicate the site is in an unfavourable
           and declining condition as a result of the following:

                An excess of Purple Moor Grass

                Dominance of old tall heather

                Thick carpets of acrocarpous moss

                A lack of bare ground

                Lack of a fine mosaic of different ages or heights of heather

     5.8.5 Current management techniques are not creating a heathland SSSI in
           favourable or improving condition.

     5.8.6 Between 1995 and 2001, 29 hectares of scrub were cleared under the
           Wetley Moor Management Plan 1995. The remaining areas of invading
           scrub have been prioritised for clearance in the Wetley Moor
           Management Plan 2001 – 2005. At a cost of £1,000 per hectare this is
           expensive and not sustainable by Wetley Moor Joint Committee in the
           long term.    Without grazing to follow up this scrub clearance
           programme Birch and Willow seedlings will invade and cause the
           heathland to change to woodland.

     5.8.7 Since 1995 there has been extensive heather cutting and accidental
           fires at Wetley Moor as shown in Appendix „B‟. Heather cutting is not
           an option that can be used across the entire site due to the very
           tussocky, mossy, wet ground that exists in some places. The results of
           surveys indicate these are areas suffering most from loss of heather
           and where heather is being out competed most vigorously by Purple
           Moor Grass. Obtaining the specialist contractors on a regular basis to
           carry out heather cutting has been problematic.




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     5.8.8 Burning as a management tool is no more effective than cutting – some
           wet areas of the site would preclude the use of burning. There is the
           added complication of copycat uncontrolled fires, caused by vandals if
           burning was used as a management tool. Burning may also ignite
           underlying coal seams. Because of the old degenerate nature of the
           heather burning may further encourage regeneration by Purple Moor
           Grass. The dominance of Purple Moor Grass on areas of the
           heathland that have been subject to fires caused accidentally or by
           vandals would support this theory.

     5.8.9 Cutting and burning are both much more intrusive in terms of their
           landscape impact than grazing. Cutting will always create rectangular
           or oblong landscape scars, because of the very nature of the machines.

     5.8.10 In areas where cutting has been carried out, there is evidence that
            Purple Moor Grass is out-competing the young heather plants. Cutting
            alone has not led to an improvement in the ecological condition of the
            heathland. Neither cutting nor burning can mimic the fine mosaic of
            different vegetation types and height that can be created by grazing.
            This allows the creation of a range of microhabitats that can not be
            achieved through more artificial methods. Neither cutting or burning
            can selectively remove Purple Moor Grass this can only be achieved by
            grazing.

     5.8.11 Present levels of grazing carried out by the commoner is inadequate to

                 Remove enough vegetation to create bare areas of ground to
                  enable heather to set seed.

                 Stop Purple Moor Grass and thick carpets of acrocarpous moss
                  dominating the site

                 Create a fine mosaic of heather heights and ages across the site

     5.8.12 Additional grazing is required to meet these conservation management
            needs.




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6     Examples of best practice in heathland management from elsewhere


6.1   Best practice from other heathland sites indicates that grazing is used as an
      important management tool, to keep the heathland in favourable condition.

6.2   Between 1989 and 2000 free ranging summer grazing involving the erection
      of fencing and access features, was established on at least 8 heathland sites
      in Dorset. All these sites have access for the public by way of Public Rights of
      Way. Summary details for these sites is given in Appendix „I‟.

6.3   Arne Royal Society for the Protection of Birds (RSPB) reserve in Dorset is a
      large heathland site managed by the Royal Society for the Protection of Birds.
      Despite at least 20 years of intensive management involving scrub removal,
      burning and rotational cutting of vegetation using teams of residential
      volunteers and up to four permanent staff it was still felt necessary to
      introduce summer grazing by cattle in 1998. Between 1998 and 2001
      intensive monitoring suggested grazing was having a beneficial effect on the
      vegetation structure of the heathland communities.

6.4   Grazing is an important management tool at heathland sites in the Midlands.
      Grazing is essential for the maintenance of Sutton Park, a large 900 hectare
      urban heathland site with open access in the centre of Birmingham managed
      by Birmingham City Council.

6.5   Grazing has been introduced to Bickerton Hill in Cheshire. Bickerton Hill is a
      114 hectare heathland site managed by the National Trust. Grazing was
      introduced following an intensive programme of Birch and Pine scrub removal.
      Grazing is being used to stop the re-invasion of scrub and is already helping
      to create a varied age structure in the heather communities.




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6.6   In 2002 Cannock Chase District Council was given permission from the
      Secretary of State to install fencing and access features at Hendesford Hills
      Common under the Law of Property Act 1925. Hendesford Hills is an SSSI
      lowland heathland and grazing was considered necessary to manage the site
      in a sustainable way. A copy of the decision letter relating to Hendesford Hills
      appears in Appendix „J‟. The issues relating to Hendesford Hills highlighted
      on page 2 of Appendix „J‟, closely match those in the application submitted by
      WMJC.


7     Details of the Proposed Grazing Trial



7.1   Details of fencing and access features

      7.1.1 Fencing is essential to enable grazing to take place. Fencing will stop
            stock from straying on to roads surrounding the trial area and causing a
            danger to traffic and themselves. The alternative to fencing would be to
            have continuous shepherded grazing. The feasibility of this was
            investigated during the consultation process. An advert was placed for
            shepherded grazing in local newspapers but here was no interest.
            WMJC concluded shepherded grazing was not a practical option. Best
            practice from other recently established heathland grazing schemes is
            that stock is enclosed within a fenced area.

      7.1.2 The map in Appendix „K‟ shows the location of the proposed 480
            metres of fencing. All fencing will consist of post and three strands of
            barbed wire. The longest stretch of proposed fencing is 190 metres.
            This fencing is the upgrading of existing fencing as shown in
            photograph 1 of Appendix „K‟. The existing fencing has been in place
            at least 12 years and a previous fence was in place along the line of the
            existing fence prior to that.

      7.1.3 The current plain wire fence will be replaced by barbed wire. A further
            70 metres of new fencing is proposed next to the boundary of the
            common adjacent to an existing stone wall at point 2 on the plan. [It is
            recognised that as these 2 sections of fencing follow the line of fencing
            that has existed for more than 12 years and that permission under the
            Law of Property Act 1925 for the fencing may not be required]




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     7.1.4 Appendix ‟K‟ shows the location of 120m of roadside fencing next to
           Eaves Lane shown by photographs 3 and 4. The fencing will be
           parallel to a line of bollards and be positioned 2 metres back from the
           road edge. The bollards have been in place since 1985. Photograph 5
           shows 60 metres of proposed fencing again along an existing line of
           bollards next to Swift Lane. These bollards have also been in place
           since 1985.

     7.1.5 Forty metres of internal fencing is proposed. This fencing will occur at
           two-pinch points where access is already restricted as shown in
           photographs 6 and 7 in Appendix „K‟. The fencing will surround field
           gates and bridle gates that will provide access through these pinch
           points. Three-quarters of the proposed trial grazing area is already
           fenced. The new fencing will have little additional visual impact and
           present no practical restriction to access.

     7.1.6 Photograph 8 shows the location of the cattle-grid. The cattle-grid
           would occupy the width of the road. A cattle-grid specification is
           included in Appendix „L‟. The cattle-grid would not necessarily be a
           permanent feature and could be removed and filled in at the end of the
           trial if this is necessary.

     7.1.7 Seven self-closing bridle gates would be installed.            A design
           specification for these is presented in Appendix „M‟. Standard 12 feet
           wide wooden field gates would be installed at the locations shown on
           the map to allow access for the Commoner and grazier. A photograph
           showing an example of the type of gate is given in Appendix „M‟. This
           is exactly the same type of gate installed at the request of residents in
           1990 on other parts of Wetley Moor to stop vehicles illegally driving on
           the common. Five gates of this type already exist at the locations
           shown on the attached plan.




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7.2   Details of livestock management


      7.2.1 Ten cattle will initially be grazed in the trial grazing area. The number
            is in line with recommendations from English Nature, of the number of
            cattle required to restore the heathland vegetation communities.
            Grazing will be for a six-month period typically between May and
            October each year. The total number of cattle may adjusted on an
            annual basis dependent on the results of monitoring the condition of the
            heathland vegetation.

      7.2.2 Cattle are the preferred grazing stock on Wetley Moor for a number of
            reasons:

                  Wetley Moor has a history of cattle grazing

                  The wet nature of the site makes it more suitable for grazing by
                   cattle

                  Sheep would tend to avoid the wetter parts of the site – the very
                   areas where there is the most problems of Purple Moor Grass
                   out-competing heather.

                  Other heathlands with wet conditions have used cattle for
                   conservation grazing.

                  The problem of dogs worrying sheep on a site heavily used by
                   walkers and dog walkers.

      7.2.3 The grazier will be subject to the terms of a grazing licence. This
            system operates successfully at other sites owned and managed by
            Staffordshire Moorlands District Council such as Biddulph Grange
            Country Park, Ladderedge Country Park in Leek and Brough Park
            Fields in Leek. The use of grazing licences has been successful in
            other heathland grazing schemes. For example at Arne RSPB reserve
            and Grange Heath RSPB Reserve in Dorset.




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      7.2.4 The grazing licence will stipulate that liability for the welfare of livestock
            will be with the grazier. Liability for any damage caused by livestock to
            adjacent property, should cattle escape from the trial grazing area, will
            lie with the grazier. The grazing licence will insist on daily monitoring of
            stock by the grazier. WMJC will have the right to terminate the grazing
            licence agreement should any breach in the terms of the agreement or
            damage to the trial area become apparent.


      7.2.5 Existing ponds would be widened and deepened to provide water for
            grazing livestock. If additional water was required during dry periods
            then a mobile water bowser and water trough would be used. These
            methods of providing water have proved to be highly effective at
            Grange Heath RSPB reserve in Dorset where I helped establish a new
            grazing project on this 69 hectare heathland site in 1995.

      7.2.6 The public would be informed of the presence of grazing cattle by signs
            erected at every access point to the proposed trial grazing area.


7.3   Health and safety – mining features


      7.3.1 A survey to identify mining features at Wetley Moor was carried out by
            consultant mining engineers in 1995 and 2001. There are no known
            mining features recorded within the proposed trail grazing area. The
            map in Appendix „N‟ shows the location of recorded mining features at
            Wetley Moor. The mining features were classified as being low risk to
            the public. The mining consultants concluded that increasing the
            number of grazing livestock would not increase the likelihood of a
            mining feature collapse occurring.




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8     How will the grazing trial be monitored


8.1   The aim of a trial grazing area is to confirm that grazing can be carried out
      effectively at Wetley Moor. The aim of introducing grazing is not to create a
      scientific trial to compare grazing with cutting and burning as management
      methods. There is ample evidence that grazing has improved the quality of
      the heathland ecosystem at many other sites.

8.2   The aim of monitoring is to see if grazing can bring additional benefits in
      reducing the dominance of Purple Moor Grass and acrocarpous mosses,
      increasing the amount of bare ground and young heather. Additionally the
      aim of the trial is to allow the practicalities of grazing Wetley Moor to be tested

      a)     to prove that an annual grazier could be sustained under a grazing
             licence before the expense of fencing the entire common was carried
             out.

      b)     To assess the day to day practicalities of keeping stock within a fenced
             area on Wetley Moor.

8.3   Removal of invasive scrub will be carried out inside the trial area and outside
      the grazing compartment. However, vegetation cutting with the removal of
      cuttings will only be carried out outside the trial grazing area on other areas of
      the common. This would allow a comparison of grazing and cutting as
      different management methods.

8.4   Monitoring of vegetation on Hartland Moor in Dorset by English Nature
      showed a significant difference in the structure of the vegetation over a 5 year
      period. The suggested monitoring period of 5 years should be sufficient time
      to show a significant change in the condition of the heathland at Wetley Moor.




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8.5   Monitoring would consist of carrying out a Common standards lowland
      heathland condition assessment on an annual basis using the methodology
      described in Appendix „G‟. A similar condition survey would be carried out
      outside the trial grazing area. This monitoring will provide a comparison of the
      overall condition of the heathland inside and outside the trial area, by
      reference to a nationally accepted target for heathland quality.

8.6   The Heather Condition Survey carried out by Penny Anderson Ecological
      consultants in 2001 would also be repeated after the 5 year trial to allow a
      comparison of the trial area with the rest of the heathland area.

8.7   Fixed point annual record photographs would be taken of the trial area and of
      areas outside the trial for comparison. This would allow a visual analysis of
      the structure of the vegetation and a proportion of heather.




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9    List of Appendices


     Appendix A:          Map showing the location of scrub removed 1995 -
                          2002

     Appendix B:          Map showing the location of heather cutting areas and
                          known accidental fires 1995 – 2002

     Appendix C:          Summary of heather condition survey and vegetation
                          survey by Jerram 1994

     Appendix D:          Heather condition survey        by   Penny   Anderson
                          Ecological Consultants 2001

     Appendix E:          Maps showing a comparison of the heather condition
                          survey 1994 and 2001

     Appendix F:          Map showing the location of photographs of heather cut
                          areas and areas suffering fire damage

     Appendix G:          Summary of English Nature common standards lowland
                          heathland condition assessment 2001

     Appendix H:          Vegetation monitoring transect data 2000

     Appendix I:          Table summarising        best practice management
                          techniques at other heathland sites, where grazing has
                          been introduced

     Appendix J:          Copy of a decision letter relating to Cannock Chase
                          District Council‟s successful application under Section
                          194 of the Law of Property Act 1925

     Appendix K:          Map and photographs showing the location of proposed
                          fencing and access features

     Appendix L:          Specification for cattle grid

     Appendix M:          Design of bridle gates and field gates

     Appendix N:          Wetley Moor Mining Study 2001 – extracts from maps




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