WHY DOES THE FOREST OF DEAN DESERVE TO BE DESIGNATED
AN AREA OF OUTSTANDING NATURAL BEAUTY?

The beauty of the Forest of the Dean (FOD), its landscapes and its unique culture have been recognised for a very long time.  It was not by chance the Late Saxon, Norman, and Medieval Kings took possession of it and used it as their “Forest” for hunting and other pursuits.  Since then, numerous writers have celebrated its scenery, the culture of its inhabitants, and its heritage, in their works; as do artists and photographers in the visual arts. 

Despite this, the charm of the District’s landscape and the settings of the existing buildings in it were not officially recognised until 1938, when 27,000 acres (11250 hectares) of the afforested area between the Wye and the Severn, were designated England’s first ever National Forest Park. 

However, rather than building upon this recognition of the District’s beauty and its many varied attributes and uniqueness, the importance of its National Forest Park designation has been allowed to decline to the extent that the only remaining vestige of formal planning law protection covering the majority of the District is the very limited shelter provided by the recognition of Special Landscape Areas (SLAs).  As if that was not bad enough, the intentions of the latest FOD District Local Plan, supported by the findings of the Inspector following the recent Local Plan Inquiry, is that even mention of SLAs will cease, leaving all the Forest of Dean District’s outstanding landscapes with no more protection than that afforded to ordinary open countryside.

The necessity for strong legal protection for outstanding landscapes was recognised in the 1945 Dower Report.  The Forest of Dean was a specific area considered in the background to that report.

A second document, the Hobhouse Report, produced in 1947, recommended to the Government the need for the “statutory protection of our finest landscapes for the nation’s benefit.  This was the impetus for an Act of Parliament The National Parks and Access to the Countryside Act 1949 that led to the establishment of National Parks and Areas of Outstanding Natural Beauty (AONB).  At that time, 17 candidate areas for designation as AONBs were identified.  The Forest of Dean was one of the areas included, and during more than the half century that has passed since then, it has been included on every other subsequent list of candidate areas.  It would be nice to know why it has been consistently ignored.  Could it be anything to do with its mineral and aggregate wealth?

In 1972 the UK Government designated the Wye Valley an AONB.  Included in the designated area was the western edge of the FOD District.  The reason given for not including more of the FOD District was not that it was of inferior quality to be included in the designation, but that it was seen as already benefiting from its core “Statutory Forest” protection, and as such, the Countryside Commission considered it was in the “safe hands” of the Forestry Commission.

In April 1997 following considerable campaigning by local people for Special Status covering the rest of the District, Frank Dobson, the then Shadow Environment Secretary, promised that if elected a Labour Administration would give greater (special) planning protection for the Forest of Dean.  The campaign, sparked by the issue of large-scale mineral extraction from the FOD, was quickly joined by other ongoing concerns related to the increasing pressures of development on the whole of the District

In June 1998, the Environmental Appraisal for the FOD District Local Plan stated that “the incoming Labour Government appeared to wish to confer some form of special planning status on the FOD and that the FOD District Council resolved to support the proposal for improved status”.

Following on the heels of this, in response to a House of Commons debate request from the FOD Constituency Member of Parliament (Diana Organ MP), the Minister of the Environment (Rt. Hon. Michael Meacher MP) requesting the Countryside Commission/Agency, as their advisory body on landscape quality, to assess the quality of the FOD landscape with regard to AONB status.

In April 1999, in responding to this ministerial request, the Countryside Agency (CA) formally issued a report “Forest of Dean Review of Special Status”.  Commissioned from Land Use Consultants (LUC), the main findings conclusions of the report were:

(a)    That the then existing policies and designations would be inadequate to safeguard the long-term interests and values of the Forest of Dean.

(b)    That some form of special status was required.

It recommended that the Forest of Dean should be declared an AONB with enhanced status, interpreted by a need to satisfy social, cultural and economic objectives.

In June 1999, at an extraordinary meeting of the FOD District Council’s Full Council held to consider the CA’s LUC produced report, it was resolved to support AONB designation of the District with enhancement as appropriate.

In November 1999, responding to CA Paper AP99/37 – Addressing Social, Economic and Environmental Needs of the Forest of Dean, the CA’s Board confirmed that the Forest’s landscapes are of national importance, certainly equal to the qualities of other areas that had been designated as AONBs, and decided to:

(a)    Advise Gloucestershire County Council (GCC) that the Forest of Dean should be treated as if it were an AONB for the purposes of the county’s minerals local plan.

(b)    Commission further work to explore FOD Integrated Rural Development as a pilot project.

In February 2000, the Chairman of the CA (Sir Ewen Cameron) wrote to the Minster for the Environment (Rt. Hon. M Meacher MP) advising him of the CA Board’s November 1999 decisions and seeking a statement from him on how the FOD should be regarded for the purpose of GCC’s Minerals Local Plan Inquiry.  He noted that the District’s present designations of Special Landscape Area and Forest Park do not carry statutory weight, and that although the CA was not currently pursuing a designation, the quality of the area merited AONB status, and that this should be accepted by those involved in the Inquiry. Finally he called upon the Minister to give GCC “a clear steer that AONB designation is a serious probability”.

In April 2000, building on the November 1999 decisions taken by the CA Board, an internal CA paper was produced by a CA Officer (V Kirby) entitled “Countryside Agency Scope of Interest in the Forest of Dean”.  Its quoted objectives were:

(a)    To pursue designation of an AONB for the FOD if Ministerial response to the CA letter indicates that this is desirable.

(b)   To develop an Integrated Rural Development (IRD) programme in the FOD, in partnership with others, using the countryside as the main driver and emphasising locally generated projects and other initiatives within a strong policy framework.

(c)    To ensure that minerals planning policies and proposals with the Dean reflect the national importance of the area’s landscape.

The timetable for action was scheduled to begin in July 2000 by the presentation of a CA Board paper recommending that the FOD AONB designation process should start and take 2 years, and at the same time a 3-year FOD IRD programme should begin. 

On 13th July 2000 the CA Board met.  However, the minutes of the meeting make no mention of the “Countryside Agency Scope of Interest in the Forest of Dean”, any timetable for the programme of work scheduled in the report, or of any related discussion concerning the Forest of Dean or its well-being.  This is despite the urgent exchanges that had taken place between the Environment Minister and the CA.

At its July 18th 2000 meeting, the Forest of Dean Regeneration Partnership Executive Group was informed of the CA’s intentions as set out in the “Countryside Agency Scope of Interest in the Forest of Dean” paper, and of the Environment Minister’s response to the CA Chairman in which the Minister had informed Sir Ewen Cameron that the CA would not be allowed to take the “middle ground” on the matter of designation, and asked how the CA Chairman was progressing the IRD proposal.  The Forest of Dean Regeneration Partnership Executive Group were told that the “Countryside Agency Scope of Interest in the Forest of Dean” paper had not been taken at the CA Board’s July 2000 meeting, but that a paper recommending AONB designation would be put to the CA Board’s September 2000 meeting.

Later, on 25th July 2000, the CA wrote to the GCC Minerals Plan Inquiry Programme Officer enclosing further written evidence to the Inquiry, a summary, a number of appendices, a map, and a copy of the CA’s April 1999 report “Forest of Dean Review of Special Status”.  Paragraph 5.7 of the evidence clearly stated that “at a meeting on 13th July 2000 the CA’s Board once again confirmed that the Dean’s landscape is of national importance and staff were exploring a range of options that would deliver not only landscape protection but would contribute to the area’s sustainable rural regeneration.  These would be considered by the Board at its meeting in September 2000.  Several would feature AONB designation as well as a continuation of the already developing IRD programme – the two concepts were mutually supportive”.  Reiterating the main text, the Summary advised GCC to regard the Forest of Dean as if it were an AONB for the purpose of the plan.  In constructing an IRD programme for the Forest of Dean, it was stated that the CA had not lost sight of AONB.  The two were complementary.  It also emphasized that the CA had grave concerns that the nationally important landscape of the FOD was not being afforded sufficient protection.  The key conclusions presented were:

(a)    The very high quality and national significance of the landscape of the FOD is well established and has been recognised since the 1930s,

(b)   There is a strong case for some form of special national status for the Dean, not least in respect of its landscape, and,

(c)    It is likely that this special national status (i.e. AONB designation) will emerge during the life of the GCC Minerals Local Plan.

Included in the CA’s recommendations were that:

(a)    It is a recognised fact that the landscape in the area (Forest of Dean) is nationally significant.

(b)   Following the precautionary principle, the absence of current statutory protection should not mean that it (Forest of Dean) should not be given Primary Constraint status.  

(c)    The Forest of Dean should be recognised as a Primary Environmental Constraint for its own landscape qualities as a special area of national importance, and be added to Policy E2 of the GCC’s Mineral Plan by name (i.e. given the same planning protection as if it was already designated an AONB).

GCC subsequently refused the CA’s recommendations, and to date no satisfactory published explanation appears to have been provided by them for their negative, and potentially very damaging to the FOD, response.

On 31st July 2000 the FOD Constituency MP (Diana Organ MP) wrote to the CA Chairman following her receipt of a copy of the “no middle ground” letter from the Environment Minister (Rt Hon Michael Meacher MP) to Sir Ewen Cameron.  She noted that the Minster had indicated that his opinion of the way was to ensure the Forest of Dean gained protection from further quarrying by granting the area AONB status.  She expressed concern that GCC was unwilling to take on board any of the recommendations of the CA, and urged the CA to seriously consider the Minister’s proposal (for AONB) at their September 2000 Board meeting.  Her reason for this was “the great fear that unless some form of protection is afforded to the FOD in the very near future the County Council will be able to allow further destruction of what is now recognised as an area of national significance”

On 29th August 2000, Sir Ewen Cameron responded to the Forest of Dean MP’s 31st July 2000 letter to reassure her that the CA Board would consider the issue thoroughly at its September 2000 meeting.  He stated the CA’s commitment to a positive package of measures that combined rural regeneration and protection for a nationally significant landscape, and he noted that “the Board would consider whether an AONB, an IRD process or a combination of the two would meet the objectives for the Dean, not just the short need for clarity in the minerals planning process”.

On 14th September 2000 the CA Board met at which it took a paper AP00/35 “The Forest of Dean – Options for Integrated Rural Development and Landscape Protection and Enhancement”.  The paper noted that in November 1999, following a visit to the Forest of Dean, the CA Board had commissioned work to address the needs of the area.  While some work was already under way, an enhanced programme of action was now recommended to:

(a)     Ensure the protection and enhancement of the Dean’s unique qualities through a new, community based approach to landscape, including culture, heritage and tourism, and,

(b)     Build on existing Agency involvement in a community based regeneration and sustainable development programme for the district, working with the Forest Regeneration Partnership.

A view was expressed that the programme would “create an example of integrated rural development which can serve as a national pilot for areas of special heritage such as the Forest of Dean”.  It went on to say that “while there was still pressure in some quarters for AONB”…”in opting for a special programme of work last year, the Board decided against starting any such designation”.  It did not say why!

Taken as a whole, the outcome of the 14th September 2000 CA Board Meeting constituted a complete volte face with respect to virtually everything the CA had said previously in its evidence to the GCC Minerals Plan and its correspondence with the Minister (Rt Hon. M Meacher MP).  To date, no explanation has been provided for this. There was no mention in either the paper or the minutes of the Board meeting as to related correspondence with the Environment Minister, GCC, or the Minerals Plan Inquiry evidence that the CA had published.  Instead, they simply noted that the Chairman said, “the Board were unanimous on the objective of a programme of work to meet the local needs of the Forest of Dean.  On balance, they believed that this could best be achieved through the integrated rural development approach…” and that they should “monitor and evaluate the pilot IRD and be ready to return to the designation issue in 3 years time.  At that point the difference between the IRD approach and a new deal for AONBs approach would be clearer”.  The only reference to AONB designation was the “the Agency will return to this issue (of AONB) after three years, after a review of the Dean’s needs and the impact of the Agency’s work.  Meanwhile the district wide Local Plan Review gives us the opportunity to see how policies can be tailored to meet the special needs of this kind of are while also conserving the special environment”.  The CA made no such representation to the subsequent FOD Local Plan Review, nor, with respect to the FOD, did they make any significant input to HMGs Rural White Paper. 

In December 2000 the Countryside and Rights of Way Act 2000 came into force.  Part IV – Areas of Outstanding Natural Beauty, confirmed the strengthening of AONB provisions in line with those afforded a National Park, and the means for creating Conservation Boards.  As such it went a long way to providing the mechanism for enhanced AONB designation as identified in the CA’s 1999 Report “Forest of Dean Review of Special Status” from Land Use Consultants.

In the three years that followed, the CA claimed that it spent £1.1M on its Forest of Dean IRD Programme.  However, on closer inspection, with a few exceptions, it would appear that most of the work conducted was on activities to which the CA was already committed within the general rural sector, either County or nationwide. Little concrete was achieved, and at a community meeting in Cinderford on 27th January 2003, the CA representatives present admitted that IRD would provide no statutory designation or protection under planning law for any of the FOD District, and that if this latter was wanted, it could only be provided by AONB. It is noteworthy that despite many in the room hearing what was said on this point, in the CA’s formal notes of the meeting there is no mention of AONB, or the admission. 

At their meeting on 10th April 2003, the IRD programme poor achievement was reported to the CA Board via Paper AP03/06.  Despite this, through the Chairman, the response of the Agency’s Board was to opt for a further two-year “Phase 2” FOD IRD programme.  No meaningful consideration was given to landscape or any form of statutory protection either in the paper or during the discussion.  The Chairman solely stated “the option of AONB designation could be considered at some time in the future”. 

Currently, the CA has work ongoing in connection with its Phase 2 IRD programme, the Forest of Dean District Council has had the Planning Inspector’s Report in which he accepts the removal of Special Landscape Areas from the Local Plan, and there is talk of “supplementary planning guidance” being applied to the Forest of Dean District.  So far, there are no details available of this latter guidance, but from experience of other occasions that such measures have been invoked, it seems very unlikely that it will provide anything approaching the statutory planning protection that the District deserves. 

The general population do not want their environment degraded and destroyed for the enrichment of a few developers, and it was set against this background that Friends of the Forest were formed.  Friends of the Forest recognises that without some current form of statutory designation to protect the District, it is just a matter of time before its natural and man made high quality landscapes will be lost, as will its extensive biodiversity, and its unique heritage and culture.  Principally this will be as a result of attack from unjustified unsustainable development and creeping urbanisation.

It is Friends of the Forest’s view that the statutory protection needed is already available via application of the United Kingdom Parliamentary Law that allows the designation of portions of the England and Wales as Areas of Outstanding Natural Beauty.  Friends of the Forest seek your support to gain that protection for the Forest of Dean District.

Supporting evidence

The way forward

History

Biodiversity in the Forest of Dean