Natural England seem to have lost the West Pennine Moors

West Pennines-1

I view the north of England pretty much as an enigma wrapped in a cloth cap and walking a whippet.  I’m better on the east of the country than the west where everywhere seems to be a town beginning with B, and it is indeed the area between Bolton and Blackburn with which we are concerned in this blog. Well, we are concerned because it seems that Natural England has lost the West Pennine Moors off the map.

These are moors that qualify at least as SSSI and perhaps could be even higher rated – but they are certainly of SSSI quality – with that, it seems, no-one disagrees.  And so, it could be just the matter of a few days, weeks or months for Natural England, once known as a nature conservation organisation working on behalf of nature, to notify them as SSSI. But no, the information has been available for years to notify this site of 7000ha of mostly moorland and blanket bog and yet it still remains unprotected.  This lack of designation means that the area shows up on the developers’ maps as open ground with few people and little constraint to development.  One windfarm has already been built on the deep peat (which is such a bad idea).

This site was surveyed by the Nature Conservancy Council back in 1991 but its successor body, English Nature, passed on the file to Natural England in 2007 and more surveys have been completed since 2012.  Local naturalists, many of whom helped collect the data, were hopeful that the site would be notified by December last year, but it wasn’t. It’s so easy to forget things at the tops of hills in the north of England.

It has taken a certain amount of ingenuity for NE not to notify this site. Late last year they introduced a concept of ‘Gate Zero’ – perhaps a gate through which no useful designations can pass?  Gate Zero (for heaven’s sake!!), means that the NE Executive Board will pick and choose which sites should progress to attain the protection that the surveys on the ground indicate are merited. No longer will notification be judged on nature conservation criteria, but now one fears that a very large dash of politics is thrown in too.

Could it be that NE would not want any large extra upland SSSIs to be added to the suite of existing sites if their arrival could prejudice the chances of NE, and Defra, meeting their targets for favourable condition?  A bit like doctors turning away ill people so that the hospital doesn’t have too many deaths on its records?

This is how NE, in a recent letter, describe what they are up to:

To date our forward notification programme has often lacked a strategic approach, where early consideration is given to the environmental outcomes, benefits and desirability of developing the case for a new SSSI. As a consequence of this, the past few years has seen the growth of a long list of possible sites in which it is unclear where the priorities for designation should be, and why. As you are only too well aware, some sites on this now substantial list of possible sites have been there for many years and, in some cases, considerable efforts by our own staff and a variety of interested stakeholders has been expended.

In order to break out of this cycle and to provide us with a more manageable, transparent and strategic programme, we have, therefore, established a new step in our processes which will enable the Executive team to make clear decisions on which sites should be taken forward as part of a coherent designations programme and when. All of the potential sites currently in hand will go through this screening process. This is part of ongoing work to develop our conservation and designation strategies, and this new process step will be really important in the coming years to give us confidence that we are using our resources to best effect on the sites that really matter.

So, the NE Executive Board, that is, staff of NE (not the appointed Board members) will be using a bunch of unknown criteria in secret discussions in order to choose which qualifying sites should be allowed to progress to their deserved protection. What is going on here?

No, really – what is going on here?  Does the real Board of NE (Andrew Sells, David Hill, William Cockbain, Teresa Dent, Andy Clements, Simon Lyster, Julia Aglionby, Joe Horwood and Nigel Reader know that SSSI notification is being ‘filtered’ and notification is being delayed and ‘prioritised’?

The West Pennine Moors qualify for SSSI protection, and that has been known since 2007 (if not earlier), but they may fall by the wayside if their protection is deemed not to be ‘manageable’, ‘strategic’, ‘coherent’ or ‘desirable’. This isn’t industry talking – it’s the statutory nature conservation agency (sorry – delivery body).

Derek Ratcliffe must be spinning in his grave and even many of his less renowned and less deceased successors must be shaking their heads and wondering what on earth is going on these days.  Maybe NE would like to tell us their plans?



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21 Replies to “Natural England seem to have lost the West Pennine Moors”

  1. Mark, I have always been understood that if a site met the published criteria for SSSI designation then the relevant SNCO had a "duty" to designate it. This is contained in the Wildlife and Countryside Act 1981. They can't pick and choose which to designate, they are legally obliged to designate any that meet the criteria.


    2. No... the evidence has to come before the delegated (usually top level) committee and they have to confirm the opinion. When that is done the duty kicks in.

      So right to the boss at EN and ask the question..."Does this site meet the criteria for SSSI designation?" Oh and back it up with an FOI request for all reports, memos and internal papers which discuss the matter.

    3. It has been some time since I was properly involved in nature conservation (too much of what remains of my "brain" is occupied by H&S, medication (not mine) and earning the pittance for which people on the front line of LD and mental health "care" are rewarded by UK/US capitalism; 'sans' pay rise for 7 years now) but as I remember there are duties re environmental transparency in EU law so I am copying this blog to NE as an FoI question that will try and invoke UK duties re EU law. Hope thats OK.

  2. There was pressure on EN/NE even under Labour not to add to the SSSI area; would it be paranoid to suggest that NE may have been nodded, winked and then kicked in a sensitive place into designating virtually no more SSSIs whatsoever & regardless ?

  3. Winter Hill should certainly be a Site of Special Sinister Interest, given all the dead souls up there, at Two Lads, Scotsmans Stump, and the many air crash sites. I always felt Rivington Pike was sinister, a brooding presence glowering down over Horwich. There is a chapter about Rivington in The Horwich Hennets

  4. It is grimly ironic that the letter talks about a more "transparent" approach to designation of sites. It would seem that, on the contrary, the aim is to throw a cloud of obscurity over the process.

  5. Love it - focus on 'the sites that really matter'. The other sites, one assumes, thus 'really don't matter', and can be trashed! They have been identified as sites of national nature conservation importance. ALL sites on the SSSI designation 'pending' list 'really DO matter'!

  6. And straight into the (ever-expanding) short list for the Environment Audit Committee to prod a bit once a new government is in place, goes this.

    Of course, if there are any potential SSSIs that might be considered to be in 'favourable or recovering' condition then there's an argument for immediate designation as a way of improving the SSSI statistics overall.

    Given the repeated re-organisations, loss of staff and budget cuts that undermine effective operation it's hardly surprising the agency (whatever it's called this week) isn't able to take, let alone deliver on a strategic approach. Not that any Government Scientists are permitted to tell you that of course - there's an election on. You'll just have to make do with comparing and contrasting good science with Defra policies and approaches on, badgers, pollinator strategies and neonicotinoids, hen harriers....

    Last month the Fabian Society suggested that NE be tasked with ensuring an effective, joined-up approach to green infrastructure and ecosystem services in relation to the ongoing demise of public parks {Notice the disappearance of local government anyone?} and the need to look after these better. Given how ill-resourced NE and unloved by Government NE is, the Fabians might possibly care to reconsider the wisdom of that particular proposal.

    And the conservation 'community' really does need to ensure that there is a more effective watchdog for wildife and also give thought to the facts that not only is the SSSI system not really working but in relation to climate change in particular it isn't fit for purpose. And as for NE...

    So the two and a half pence (and a button) that now forms the Natural England Budget will be used to best effect on the sites that 'really matter'. One wonders what the gap is between the available budget and the amount needed to support appropriate management.

    Oh wait, of course 'Conservation Covenants' will save the day...

    Personally, I think there are a whole quantity of DA Ratcliffe's predecessors rotating at high velocity.

    And if that was a verbatim transcription provided in the blog, it loods at though NE also need to employ a proff reader. Oops.

    Yes, an inquiry into Natural England's ability to achieve what is important in relation to protection and conservation really ought to be high on it's agenda.

  7. All of this just re-enforces my view that we need something akin to the Environmental Investigation Agency addressing British wildlife - a British Wildlife Campaign, say - able to critically evaluate the real performance of UK conservation and all involved in it.

    A distinct mission to those NGOs we already have - publicly critical friend and wholly independent auditor.

    A British Wildlife Campaign could be a charity governed by a Board of objective scientists with a small team of investigators, publishing hard-hitting, fact-based audits of things like wildlife site condition, the state of the Public wildlife-rich estate (MoD- and FC-held land, etc), quality of advice offered Scientific Advisors (naming no names, but the quality of Defra's Professor Ian Boyd's advice might benefit from scrutiny), the efficacy of some of our conservation solutions (yes, I am thinking brood management!) Its audits would be robust and unimpeachable.

    The RSPB is outstanding, it fills a critical niche, polite, largely behind the scenes. The Wildlife Trusts do some good campaigning but are sometimes still too meek, perhaps compromised on occasion by having non-profit ecological consultancies, though even without such things Trusts still seem averse to hard, long fights for nature. I don't know what the Woodland Trust does. BugLife is outstanding but is just bugs. Butterfly Conservation - top-notch science, not really into fights.

    I'd love to see the likes of Mark, Tony Juniper, Simon Barnes, Miles King, Peter Marren etc get together and form such a group.

    1. Hang on a sec: 'just bugs'?

      Remember that's 65% of all life on this planet and over 39,000 terestrial and marine species in the UK Perhaps I'm reading more into this than was intended, but I would have liked your comment if it hadn't been for that sentence.

      Whilst I agree with the general premise of your argument, this and similar statements make me think that in order to be truely impartial the proposed 'British Wildlife Campaign' would need to consider all biodiversity equally, independent of whether it has fur or feathers. Only then could it really critically evaluate the work of UK conservation, and then I think it could be hugely beneficial.

      1. Yes, Mike, I was kidding - apologies. I'm a hoverfly fanatic personally, so I'm with you regarding the importance of bugs!

    1. Many NNRs are SSSIs as well as SACs and SPAs & our erstwhile "guardians" have failed to get some of our local ones into FCS. Interestingly though, if a Water Level Management Plan is written they get an automatic upgrade, one notch!

      Remember also that attempts to divest forests are being hatched through the backdoor. NNRs are a costly commodity with civil service salaries and pensions etc. Factor in that quality science is expensive (didn't they 'cull', or was it described as retired many of their scientists in favour of PR manager types?). If all NNRs are designated open access then the government will be able to offload as country theme parks (able to generate revenue) to quasi quangoes?

      Desperately in need of serious reform, the discussion above is a start and Mark is an excellent 'chair' to encourage and facilitate the 'review' and reformation.

      Some of you might recall that in 1997 there was a report published following a review of English Nature undertaken by a House of Commons sub-committee, see

      A variation is long overdue and in parallel a plan developed for a replacement wholly independent, but accountable organisation? On past performance, previous incumbents need not apply, radical change is needed. "A muzzled watchdog" (1997) became 'a toothless terrier' and is now sadly 'a lapdog?

  8. Sorry for my ignorance but I'm looking for updates on this proposed SSSI, as a resident in the area and recieved periodic updates but I have heard nothing now since Dec 15, did this go ahead or has it all been forgotten, I would appreciate any update


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