The FoNF 2022 Byelaw Watch Report has been published.
With grateful thanks to the volunteers who contributed to this with their ‘eyes in the Forest’
And those who compiled the results
Click 2022 BYELAW WATCH to read the full report.
The FoNF 2022 Byelaw Watch Report has been published.
With grateful thanks to the volunteers who contributed to this with their ‘eyes in the Forest’
And those who compiled the results
Click 2022 BYELAW WATCH to read the full report.
|Our statement regarding the Solent Freeport at the New Forest National Park Authority meeting on 20th October 2022 included these Notes and Footnotes for the benefit of the Authority Members.
Further context is in THIS article (forthcoming).
New Forest East MP Dr Julian Lewis submitted a question about the seeming inclusion of the whole of the New Forest in the provisional boundary of the Freeport.
|LEVELLING UP, HOUSING & COMMUNITIES – SOLENT FREEPORT  – 21 September 2022
Dr Julian Lewis: To ask the Secretary of State for Levelling Up, Housing and Communities, for what reason the entirety of the New Forest has been included within the provisional boundary of the proposed Solent Freeport. 
[Due for Answer on 11 October.]
The Parliamentary Under-Secretary of State for Levelling Up (Dehenna Davison): By delivering investment on specific priority sites, Freeports will create thousands of high-quality jobs in some of our most disadvantaged communities. These sites have been carefully selected for their suitability for development by the local Freeport coalition, which comprises key private partners and Local Authorities who, importantly, provide democratic accountability for the actions of the Freeport. The development sites sit within an ‘outer boundary’ which sets the limit for how far apart they can be and broadly indicates the area they expect to benefit most directly from the Freeport’s economic impacts. While the Solent Freeport outer boundary intersects with the New Forest National Park, this in no way means that the area has been earmarked for development nor does this confer any special planning status. Local authorities retain all their statutory powers and responsibilities, including responsibility for providing planning permission. Freeport status in no way undercuts the local planning process and there is no change to the current planning and environment status of national parks.
The Government’s assurances in their reply to Julian Lewis [above] do not mention or reaffirm the Duty of Regard to the National Park in the planning process, and given that this government and its predecessors have failed to bolster environment legislation (and may even further dilute), had Natural England assess their own proposals below the standards demanded by legislation, systematically defunded both Parks and the agencies relevant for delivery of environmental and habitat, their ambitious targets seem hollow promises.
[i] Statement on NFDC Website, 14 October 2022
|No changes to planning and environmental protection says New Forest District Council
New Forest District Council leader, Cllr Edward Heron has written to the Secretary of State for Levelling Up, Housing and Communities, in response to the call for expressions of interest to become an Investment Zone which was announced by government on 24 September 2022.
The letter reiterates that as a partner in the Solent Freeport, we are keen to secure the greatest benefits for their residents, as well as the local area.
Councillor Edward Heron writes:
“Within the government’s recent Investment Zone opportunity there is much that aligns and enhances the Freeport benefits, both to the tax site areas, and the wider District. The financial incentives are significantly enhanced and it is important that our businesses and developers have the opportunity to benefit from this new offer. For example, securing tax incentives over a 10 year period to 2032 rather than the current Freeport period which expires in 2026 and will make these sites significantly more attractive as a place to locate businesses.
We are keen therefore to explore with Government, and our partners what an Investment Zone could deliver for the Solent Freeport and ultimately our residents and our environment now and in the future, and I have therefore supported the Solent Freeport Board’s expression of interest submitted today.”
The announcement from government made it clear that Investment Zones would only be taken forwards with the support of the Local Planning Authority.
The letter from Cllr Edward Heron goes on to say:
“New Forest District Council supported the Freeport on the basis that the designation would not impact on the statutory planning process that a landowner would need to go through, to seek consent to develop the site.
The indication of support from this Council as the local planning authority is based on the understanding that the current level of environmental protection is assured for the future and on the clear and unequivocal understanding that conversion of the Solent Freeport to an Investment Zone will not include a streamlining of planning, deregulation, or a dilution of the environmental protections that are currently in place. Should this not be the case, then the Council would not support the designation of the Freeport Tax Site within the District as an Investment Zone.
I understand that this commitment is shared by the Freeport Board and we look forward to shaping a unique Investment Zone that delivers sustainable and inclusive growth for the New Forest and wider region.”
The increased Freeport opportunities for investment, regeneration, and employment were endorsed by us during the submission of the Solent Freeport business case to the government in March 2022. The business case carefully considered the Freeport within the context of the environmental designation across the area, working to focus on net zero, green recovery and strengthening the environment.
The Solent Freeport focuses on the Council’s Waterside area with the Waterfront tax site covering four specific landholdings; the former Fawley Power Station, Exxon Mobil, ABP’s Strategic Land Reserve and Marchwood Port (Solent Gateway). The whole District, including the New Forest National Park, is included in the Freeport outer boundary which is intended to ensure that the potential funding and broader benefits from the Freeport can be focused across the whole area.
[ii] The Solent Protection Society review of the Solent LEP’s Freeport Consultation response makes these observations (quotes from the LEP response in italics):
Given the large number of local authorities across the Solent Freeport region, Solent LEP go further, proposing “the establishment of a special Virtual Planning Authority that is facilitated by a coordinating institution with the cooperation of relevant local authorities”. This is a direction which Solent Protection Society believe should be pursued with great caution. There are already well publicised proposals, for example the Aquind Interconnector project near Portsmouth and the Southern Water desalination plant near Fawley, where opportunities for public and local authority scrutiny are being overridden by central governments’ declaration of the initiative as a ‘National Infrastructure Development Project’.
The Solent LEP response also proposes “extending the permitted development rights accorded to ports to include assembly and manufacturing though they believe this would still not improve the planning environment enough to act as an incentive to potential investors. While the expansion of permitted development rights would simplify development processes on seaport land, it would still not allow for the greater freedoms or coordination in higher-level planning required to ensure Freeport success.”
In what might seem to some a worrying threat to environmental standards, the Solent LEP go further, suggesting that “existing environmental regulations along much of the UK coastline supersede Permitted Development Rights, further limiting their additional value as an incentive”.
Their updated analysis of Freeport Tax Sites including noting that Dibden Bay is listed as both a Tax and Customs Site (for those trying to disabuse the notion of its development as a port facility). This notes particularly:
Marchwood Port / ‘Strategic Land Reserve’ – Solent Gateway / ABP
Tax site type – Existing Facility / Greenfield
Customs Site – Marchwood Port / ABP ‘Strategic Land Reserve’
Assumed programme delivery priority – High/Medium
It is notable that ABP have only submitted the northern part of their Dibden Bay ‘Strategic Land Reserve’ for definition as a Freeport tax site. Leaving the southern part of the Dibden Bay site out of the Freeport definition enables ABP to retain an option to keep this part of the ‘Strategic Land Reserve’ for future expansion of its non-freeport operations from the eastern shore.
Current environmental regulations give the Dibden Bay shoreline some level of protection from development, however once the freeport is in operation, developments within its boundary will benefit from the government’s proposed relaxation of planning regulations within freeports. As SPS observed in our report from May 2021, the Solent LEP at page 17 of their consultation response suggested that permitted development rights in freeports should be extended to enable those rights to supersede existing environmental development regulations.
Once development of the northern part of the Dibden Bay shoreline has been permitted under the freeport rules, then a precedent would have been set which could then be used to attempt to override the existing environmental protections outside the freeport boundary in the southern part of the ABP ‘Strategic Land Reserve’.
[iii] Two bills effecting planning, with overlapping goals for growth are still proceeding forward, expect if one falls the other to remain:
[iv] Interview with outgoing ABP exec Doug Morrison [including claims for future of Dibden Bay]:
[v] Report to NF NPA Meeting 20/10/2022 by David Illsley, this is the paper that the Authority were to discuss after our statement in Public Questions. It outlines the lack of clear guidance from Government surrounding the Investment Zones, issues of implications of the Freeport and Investment Zones on the National Park, and options for the Members to support.
[vi] The Duty of Regard has already been eroded by NFDC in their most recent local plan:
During the 2019 examination both the Wildlife Trust and RSPB stated categorically that not only had the NFDC failed to show the efficacy of their current mitigation, but NFDC had in no way shown that they could possibly mitigate for their four-fold increase in housing development in the new plan. (also see Endnote ix below)
[vii] HCC failed to initiate the most basic habitat assessment before or since consultations around the proposals for widening the A326. Also, given the years of NFDC consistently overdeveloping the Waterside and permitting development up to the edge of the road, any widening will inevitably impinge on the Forest.
viii] The Campaign For National Parks wrote a brief analysis of the Investment Zones and Freeports, (including the claim that the current sea life disaster off the North York Moors coast are due to dredging at Teesside):
|“The Government’s proposed Investment Zones may impact 7 National Parks and 29 Areas of Outstanding Natural Beauty – together accounting for 2 million hectares of our most special landscapes. This follows announcements on Freeports that include the New Forest, Dartmoor and North York Moors National Parks, along with many AONBs, within their boundaries. We only need to look at the ecological disaster unfolding on the North York Moors coast, with growing evidence suggesting this is a direct effect of the Teesside Freeport, to know that unregulated development in these precious landscapes would not end well.”|
Their comments on the Government’s Response:
|There is much to be concerned about in the current Government’s proposals to boost growth by “liberalising” planning and doing away with many vital environmental protections. One of the things we’re most concerned about is the proposed investment zones which, as analysis we published last week shows, could impact seven National Parks and 29 Areas of Outstanding Natural Beauty (AONBs). These areas account for a combined 2 million hectares of landscape, pulling in 250 million visitors last year, and generating an annual economic contribution of £24 billion.
We wrote to Simon Clarke, the new Secretary of State responsible for planning, to highlight these concerns and seek a formal commitment to excluding National Parks and AONBs from investment zones. Our letter also asked for reassurances that there will be no downgrading or removal of the additional planning protections which apply in these areas, including the presumption against major development.
We’ve now had a response from Simon Clarke, which makes lots of positive references to the benefits National Parks deliver, but unfortunately doesn’t give us the reassurances we need. It is good to see that the Secretary of State recognises the contribution of these Protected Landscapes to our identity, economy and environment, and his acknowledgement of the important role for these areas in achieving nature recovery commitments. But rather than ruling out any possibility of investment zones in Protected Landscapes, he says that they will only be allowed where there is local consent.
This doesn’t give us the reassurance we need. The Secretary of State must go further and confirm that there is no way that Investment Zones will go ahead in National Parks and AONBs. Placing the emphasis on local planning authorities to make those decisions brings huge risks, particularly for AONBs which are not planning authorities and have no formal role in decision making. Indeed, the Government set out proposals in the Landscapes Review earlier this year to make AONBs statutory consultees for planning precisely because they don’t currently have a strong enough role in planning decisions.
Dr Rose O’Neill, Chief Executive of Campaign for National Parks said: “We welcome warm words from the Secretary of State, but we need to see firm commitments in policy that Investment Zones will not go ahead in National Parks and AONBs.”
Campaign for National Parks is also very concerned about the impact that investment zones in other areas close to their boundaries could have on National Parks and AONBs. Increased development in neighbouring areas will only increase pressure for new roads and other infrastructure inside Protected Landscapes.
Rose added: “It is absolutely vital that our Protected Landscapes are protected from the impacts of damaging development outside their boundaries too. We only need to look at the ecological disaster unfolding off the coast of the North York Moors National Park, and the growing evidence linking this to the neighbouring Teesside Freeport, to see why it’s so important to protect our most precious landscapes from unregulated development.”
Campaign for National Parks fought for the creation of National Parks over 70 years ago. That they, and AONBs, have been stewarded safely and protected from irresponsible development ever since is one of the biggest successes in public policy in this country. The rules in place to protect them are not “burdensome requirements”: they are a vital part of ensuring we pass this inheritance to future generations.
The ongoing issues with Teesside Freeport dredging and the DEFRA response to mass sea life poisoning, noted in the CNP’s response:
The RSPB response to recent proposals including “Investment Zones”
[ix] Additionally, the conservation charities agreed with the NFA contention that the mitigation regimes inappropriately use the formula developed by Natural England for Thames Basin Heaths, which does not scale appropriately to the Forest because a) the Forest is much richer in features and biodiversity at threat and should cost developers more b) the morphology of the Forest is different: Thames Basin Heaths spatially has greater opportunity for alternative spaces, where the Forest, surrounded, creates more of a siege situation (with only one major SANG to the West at Moors Valley, and plans for similar facilities to the East not yet realized).
NFDC’s standards for SANG’s are not sufficient to create landscape scale alternatives for recreation of sufficient quality to take pressure off the New Forest. Initiatives to create effective and meaningful landscape scale mitigation projects to relieve recreation pressure on the Forest have been stalled continually, but their fruition should have been a prerequisite to any further development within the District. A HIOW Wildlife Trust assessment of greenspace provision within Hampshire ranked NFDC third from bottom, just above Portsmouth and Southampton, yet developers seek to erode the NFDC’s already minimal standards for SANG delivery. The Plan released Green Belt sites for development, rather than considering its potential for large landscape scale alternative greenspace for mitigation.
The Plan also undermined Duty of Regard by making the Fawley Waterside allocation dependent on the destruction of a SINC (Site of Interest to Nature Conservation) within the National Park, which was opposed by some National Park members.
|We made this statement regarding the Solent Freeport at the New Forest National Park Authority meeting on 20th October 2022. The Authority agenda included a discussion of the Freeport, its possible bid for announced Investment Zones, and whether the inclusion of the District, including the Park in the “outer boundary” of the Freeport would undermine the Park, or the habitat protections of the Park’s designated land.
Currently the Solent Freeport Board includes representatives of Hampshire County Council, New Forest District Council, Southampton City Council, Portsmouth City Council, Eastleigh Borough Council and Havant Borough Council, and representation from Associated British Ports (ABP), Solent Gateway and the Solent Local Enterprise Partnership(LEP). The National Park Authority is not a Solent Freeport Board member, but attends meetings in a non-voting capacity.
Text below in square brackets [ ] was omitted from the reading to the Authority, in order to remain within the time requirements for public speaking at Authority meetings. Notes provided for Authority Members, along with this statement, may be read here, and are given as direct footnote links below. Further context is in THIS article (forthcoming).
The case for excluding NFNPA from a formal decision-making role in relation to the Solent Freeport has not been made. Policy objectives for the Freeport are likely to conflict with both the Statutory Purposes of National Parks, and the 25 Year Environment Plan, notably regarding responsibilities for the protection, conservation, and natural capital enhancement of environmentally sensitive areas. In those respects, the New Forest is of unique global importance which must be recognised. We are deeply concerned by the prospect of further pressure on the special qualities of the National Park due to the proposed Solent Freeport. Simple retention of an ordinary planning regime[i], as promised by New Forest District Council (NFDC), will not ease our concerns, for these reasons:
The Duty of Regard is key, the National Park will be negatively impacted by Freeport development. The National Park should have oversight through direct representation. The overlapping private interests of ABP, Solent LEP and Solent Gateway should not have disproportionate control.
[The notion that the Freeport could be a useful source of mitigation funding from developments is deeply flawed. The current level of development already in the NFDC Local Plan is well beyond the potential for mitigation. Development beyond these levels involves accepting irreversible damage which cannot be balanced by such small benefits. [ix]]
The Dibden Bay SSSI, an important site in its own right, is a vital support to winter waders that breed on the Open Forest. Its protection, as well as the many other sites for nature connectivity, wildlife corridors and green infrastructure, should be part of the priorities for this Authority outside the park, where nature doesn’t recognize administrative boundaries.
We ask this Authority to thoroughly weigh the implications on the Park’s Purposes, before supporting a Freeport or Investment Zone, or any planning regime that undermines the Duty of Regard. And if it goes forward, regardless of where the boundaries are drawn, the Authority should demand a place on the Board of the Freeport as a full voting member, and pursue a clear policy to block the destruction of the Dibden Bay SSSI.
The annual National Parks Societies Conference was held in Snowdonia last week.
Recognising the present scale of the nature and climate emergency, the Friends of the New Forest proposed a resolution calling on governments in England and Wales to give Protected Landscapes (National Parks and Areas of Outstanding Natural Beauty) their full backing in legislation. This was unanimously agreed by all National Park Societies and Campaign for National Parks who signed the joint declaration below
Declaration from the National Parks Movement:
At a time of nature and climate emergency, we must retain and strengthen the laws and policies which protect the Protected Landscapes of Wales and England. This means there must be:
We need to and will strongly support governments’ commitments to new purposes, duties and powers to ensure that Protected Landscapes can deliver more for nature, climate and people in future.
The statement was signed by the following organisations:
Campaign for National Parks, The Broads Society, Snowdonia Society,
Dartmoor Preservation Association, The Exmoor Society, Friends of Pembrokeshire Coast National Park, Friends of the Brecon Beacons, Friends of the Dales, Friends of the Lake District, Friends of the New Forest, Friends of the Peak District, Friends of the South Downs, North Yorkshire Moors Association
Delegates at the Conference (photo CNP)
This declaration will be used to engage with Parliamentarians and demand they do more to back National Parks and ensure their protection.
John Ward, Chairman of the Friends of the New Forest agreed with Dr Rose O’Neill, Chief Executive of the Campaign for National Parks that it was fantastic to see the National Parks movement in England and Wales come together to make a powerful, positive case for why these landscapes matter.
Unfortunately the signals we are getting from the UK Government in Westminster suggests they are heading in the wrong direction. Any government who is seen to be undermining these aspirations risks suffering a political price at the next election.
Just CLICK HERE to register your support for this Declaration
|This month’s announcements about cycling responds to a few of the preliminary observations from this year’s Byelaw Watch shared in the September Court by our Vice Chair, Gale Pettifer.|
At our last court the New Forest Association reported from its byelaw watch over 700 instances of cycling off the way marked routes in a period between 25th July and 31st August this year.
Regrettably this came as no surprise. The Verderers have over many years expressed to Forestry England their concerns about the ever increasing amount of cyclists who regularly trespass off the approved cycle routes. In recent months we have expressed those concerns both to the Deputy Surveyor and his team and direct to the Chair of Forestry England, providing information about the scale of the issue and its consequences. The result of the New Forest Association’s recent byelaw watch, emphatically reinforces what has been said by the Verderers to Forestry England many times. This is an issue which can no longer be treated by Forestry England as a low priority.
In commenting on this it is all too easy to characterise the Verderers as anti-cycling. That is emphatically not the case. The Verderers are very well aware of the many benefits of cycling and support the existence of the Cycle network. I am not the only Verderer who makes use of the network from time to time.
It is therefore a good time to set out the Verderers’ position in relation to cycling off the approved cycle routes.
Cycling on the Forest is prohibited by Forestry England byelaws (byelaw 6). This is to be contrasted with the position of those on foot who have access to the Forest by right as do horse riders. The grazing stock is also there by right and delivers enormous conservation benefits. The grazing stock has shaped and continues to maintain the Forest’s mosaic of rare, interesting and important habitats.
The Forest of course provides excellent recreational opportunities. However it is also a working forest and an area of remarkable conservation importance and rarity designated as a SAC (Special Area of Conservation) and SSSI (Site of Special Scientific Interest). Critically it still retains strong elements of a wilderness with areas where both nature and the stock are left largely undisturbed.
In 2015 a study resulted in the drafting of a map, identifying the level of disturbance across the Forest. The Forest was divided into 5 zones. Zone E was the most tranquil, where there were no well-used cycle tracks and no moderate passive recreation. Zone D in which there were no camp sites and there was no intensive passive recreation. Zone C had no all-year campsites greater than 150 pitches. Zones B and A were the least tranquil. The Tranquil Areas map has been used to reduce and where possible eliminate, disturbance from activities, including organised recreational activities which would significantly impact nature conservation in those sensitive areas.
However, the advent of the mountain bike and now electrically assisted bicycle means that it is ever easier to access vast areas of the Forest. They have contributed to the significant increase in the number of cyclists all over the Forest. Headlamps now throw a beam many metres ahead which can be seen from far away; these facilitate more and more night time cycling, apparently regardless of the impact on nocturnal animals. Tyres often incise into the soft ground, contributing to erosion and as one track becomes impassable another is created. As more and more houses are built within easy driving distance of the Forest the recreational pressure, including cycling, will only increase.
The Verderers recognise that different types of route cater for different cyclists. Some wish to travel from A to B. Others wish to use a circular route returning usually to the car park from where they started. The Verderers do not rule out participating in a review of the Cycle network but such a review must be against the backdrop of control of illegal off route cycling. In any such review preservation of the tranquil and undisturbed areas, links to the car parks, the interests of nature conservation and protection of the fragile environment together with the interest of the commoners must be taken into account as well as the interests of those who wish to use the Forest for recreation.
The issue of concern is not that of the cyclist who gets lost, or the family who inadvertently strays from the network. The issue is those who persistently flout the byelaw. Dog owners whose dogs harass or attack stock are dealt with by the police as are those who drive motor vehicles over the Forest without permission. The Verderers ensure that the commoners comply with our byelaws. Forestry England must ensure that its byelaws are policed and enforced. That is the only right and proper course and it is in the best interests of the Forest.
The Verderers therefore call upon Forestry England to take the following actions: –
|Announcements shared with kind permission of the Verderers.
This month’s other announcements regarding Dogs, Brambles, Fees & New Verderers are on this link.
In November 2017 we made a presentment stating our concerns and objections to a medium sized night time cycling recreation event which was sponsored by a head lamp manufacturer. We were concerned about the effect on wildlife and livestock by the unprecedented size of the nighttime event, which had not been notified to Natural England, and the promotion of particularly bright lamps (some equal to car headlights) for use on protected habitats.
Collage by Brian Tarnoff.
|This month’s announcements include the management and importance of brambles, controlling dogs in bird nesting season, pleas to not feed livestock, marking fees, and the appointments of the Forestry England and Natural England Verderers.|
We are very pleased to welcome Mr Mark Gammon and Mr Clive Chatters to our Court today.
As announced by the Deputy Surveyor in July, Mr Gammon has been appointed by Forestry England as its representative on the Court. Today is, however, Mr Gammon’s first time in attendance. Mark is a retired senior Crown prosecutor who specialised in wildlife crime and animal cruelty offences. Previously he was a solicitor in private practice and he has a good understanding of enforcement. Mark has lived in the Forest for many years and he has a good working knowledge of local wildlife and conservation.
Mr Clive Chatters is Natural England’s newly appointed Verderer. Mr Chatters brings with him a wealth of knowledge and experience of conservation issues in the New Forest and beyond. He has a considerable understanding of the pressures arising from the need to balance the interests of agriculture, conservation, and recreation in the Forest.
We are confident both will prove to be a very valued member of the Court.
Peter Roberts made a presentment in July, urging this Court to pressurise Forestry England into changing its bylaws so that dogs are only allowed on the Forest on short leads in the bird nesting season.
There is no doubt that ground nesting birds are under very significant pressure in the New Forest and indeed elsewhere. Loss of suitable habitat, predation and disturbance are the three key factors. All three need to be addressed satisfactorily to ensure that ground nesting birds such as curlew and lapwing can breed successfully.
Mr Roberts objects to the strapline of NFDog “on the Forest, off the lead”. However, it is right to point out that its website also says” Keep to the main tracks when birds are nesting on the ground (usually March to July)”.
The Verderers have been engaging constructively with NFDog for some time to support and encourage its work which seeks to ensure that all dog walkers exercise their dogs responsibly when on the Forest. That engagement continues and our discussions will focus on, amongst other things, the need to achieve maximum protection for ground nesting birds in the nesting season from disturbance by dogs.
The Verderers do not rule out the possibility of seeking a change in Forestry England bylaws at a future date.
Concern was expressed by Mary Gray about the extent of brambles on the open Forest. The Verderers agree that bramble needs to be managed on the Open Forest especially where it encroaches on valuable grazing. I understand that Forestry England manage brambles and will continue to do so. Browsing by deer and commoners’ livestock contributes to that management. It may be of interest to those present to know that there are many species of bramble in the Open Forest which straddles two of the richest regional bramble floras in Britain with its heathland and pasture woodland soils.
After much debate and discussion in Committee, we regret that marking fees for 2023 will have to increase.
The marking fee for ponies, cattle and donkeys on the Forest
will be increased by £2.00 to £26.00 per head.
The Common rate of marking fee, for those commoners whose animals qualify, will be £13.00 per head for ponies and donkeys and £3.25 per head for cattle, which is 1/8th of the Forest fee.
Marking fees for sheep also increase by £2.00 per head. Sheep on the Forest will therefore be £10.00 per head and on the Commons, it will be £5.00 per head.
The marking fees for pigs remain unchanged. On the Forest they are £4.00 per head and on the commons £2.00 per head.
|Announcements shared with kind permission of the Verderers.
This month’s other announcement regarding Cycling is on this link.
Image notes: Mark Gammon’s WWF Lifetime Achievement Award for his work on wildlife crimes for the Crown Prosecution Service from the 2021 Wildlife Crime Enforcers Conference, Bramble image excerpted from : 2005-07-05 Renardeau (licensed under the Creative Commons Attribution-Share Alike 2.0 Generic), the cover of “Heathland” by Clive Chatters (one of his two current volumes for the Bloomsbury Wildlife imprint); Clive is currently Chair of the Habitat and Landscape Committee of the Friends of the New Forest. Other image elements and collage by Brian Tarnoff.
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