These extended comments are in support and amplification of our letter of response to the document. As outlined in our letter, the comments below follow, section by section, the order of the Consultation Document for ease of reference.

The Consultation Document asserts that grazing by cattle has taken place in the Forest for well over a thousand years. This statement, unsupported by any indication of the number of cattle involved, is put forward as the defining landscape-shaping feature.

However, we would contest this statement. According to the Doomsday Book compiled in 1086 all the Forest parishes between Harlow and the Thames, and, Romford & Ilford to Walthamstow & Waltham Abbey – an area of over 60,000 acres, ten times the size of today’s Forest – contained a mere 212 cattle. Many of these would have been pastured locally and in the river meadows of the Lea and Roding. The number left could have made little significant impact on the Forest landscape or its wildlife.

Furthermore, for centuries the Forest was used as a Royal hunting reserve and strict laws were in place to protect it for the benefit of the King’s deer. This included control of the number of commoner’s cattle that would have competed with the deer for forage.

Lopping (either pollarding or coppicing) also took place, probably dating from before the Norman Conquest and ending only with the 1878 Act. This ensured a continuous supply of firewood that was needed in vast quantities throughout the year for warmth, light and cooking.

Therefore it is our contention that the principal factors affecting the Forest’s landscape were its status as a Royal hunting forest and use as a vital source of timber and wood, especially for fuel. It is likely that much of the woodland had a closed canopy with little herbage on the woodland floor.

Undoubtedly some commoners kept the odd cow or two and grazed them near their cottages – they had to be milked – and utilized the larger grasslands in the Forest.

The view that cattle in significant numbers penetrated the woodland areas, whether pollarded or coppiced or not, except on the fringes for shelter, we believe is exaggerated. Cattle prefer to eat grass rather than trees.

There is a view in nature conservation circles that supports the notion expounded in Franz Vera’s, ‘Grazing Ecology and Forest History’, that ‘wood-pasture’ ( a more open savannah woodland grazed by cattle) might be more representative of the original natural landscape than closed high forest.

However Vera’s argument, that large grazing animals played a large part in this, has not been universally accepted. To quote from English Nature’s ‘Large Herbivores in the Wildwood and Modern Natural Grazing Systems’ :-

This paragraph presents a distorted view of the events leading up to the passing of the 1878 Epping Forest Act. There is a passage quoted across the associated photograph :-

"So fundamental to the saving of Epping Forest had been these grazing rights that they are protected explicitly by the Epping Forest Act of 1878."

             ...but, no source is given for this statement.

The principal determinant for saving the Forest was the fact that after the dissolution of the monasteries, Epping Forest came under mixed manorial ownership. In contrast, the neighbouring Forest of Hainault was largely retained as a Royal possession. There despite similar commoner’s grazing rights, Hainault woodland was disafforested and destroyed without effective opposition in 1851 simply because it was under Royal (i.e. Government) ownership.

The more complicated diverse public ownership in Epping Forest made disafforestation more difficult. Moreover, the public outcry, (see ‘All in a Garden Fair’ by Walter Besant) following the destruction of Hainault Forest gave time for the impetus to save Epping Forest to gather strength.

Thomas Willingale’s action in 1865 defending his lopping rights helped to concentrate public effort and created the first legal challenge to disafforestation.

However it was the public’s desire to save the Forest for its recreational, environmental and historic value that carried the impetus behind the City Corporation’s actions in the 1870’s .

The Lords of the Manors, the private owners of the Forest land, thought that they had the power, after the Crown sold them the Royal Hunting Rights, to enclose their holdings and develop them as they wished having first come to an accommodation with the commoners of the parishes and the extinguishment of their rights. They clearly expected no difficulty over this and generally wanted to protect their freedom to undertake profitable development of the land rather than keep their grazing rights.

Fortunately the principle of inter-commonage of cattle to graze freely over the whole Forest was deployed and the Corporation won the day and the Forest was saved.

It is that very principle that the Conservators, by erecting fences along main roads, will destroy. The Conservator’s own notice/display boards in car parks point out that they successfully claimed in the 1870’s that there should be no barriers to cattle roaming freely over the whole Forest.

The Conservators, rightly, deplore the fragmentation of the Forest caused by heavy traffic on the roads, however that fragmentation would be confirmed and accentuated by fencing those roads.

As is pointed out in this section, there had been a declining trend in cattle numbers throughout the 20^th century caused by the virtual disappearance of cattle-keeping in the increasingly urbanised Forest fringes. After the passing of the 1878 Act, the Conservators embarked on an extensive programme of tree & pollard removal and path & glade creation so that the people – to quote Sir Wm. Addison – ‘could access their new playground.’

This ‘opened-up’ Forest was seized upon by a few big graziers, who had commoners’ rights, who then enlarged considerable numbers of cattle onto the Forest.

As traffic on Forest roads increased and as the cattle exhausted the Forest for forage, they spread into fringe suburbs causing outcry from local residents and problems with cars. So much so that the Conservators sought to confine commoner’s cattle to the Forest north of Chingford. They also fertilised the grasslands at Fairmead Bottom, Chingford Plain and elsewhere to try to encourage the cattle to stay in those areas.

These measures were not universally successful and moreover a succession of wet winters caused such serious ‘poaching’ of the Forest floor that the Conservators took powers to bring about the removal of cattle during the winter months, November-April, and financially compensated the commoners for so doing !

Hence it is our view that large numbers of cattle would be required to create the wood-pasture described in the Consultation Document.

However, despite the considerable, though ever reducing numbers of cattle on the Forest throughout the 20^th century, trees still grew and obscured views and scrub still spread on the grasslands as nature contrives. The Conservators still had to remove scrub by mechanical means and fell trees on such places as Pole and Yardley Hills and Big View in Honey Lane Quarters.

More recently, when the Conservators added FernHills to the Forest in 1997, they decided to fence the whole plot and graze cattle upon it. However despite cattle being present for many years and even with initial scrub clearance by machinery, heavy machinery cutting scrub and burning the brash were still required in November 2005 to keep it open!

In the summer of 2005 on Chingford Plain, where grazing took place, we noticed a colourful display of wild flowers outside the electric fenced area – whilst inside the grazed area there was not a flower in sight.

We suspect the statement in the document about all-round-year flowering being promoted by grazing, is made more in hope than on account of evidence.

Areas of bare ground for some seeds to germinate can be created by machinery, as was the case in Long Running, and horse’s hooves, as well as cattle hooves, can create pockets for seeds.

Our concern with this section is the presumed higher value of pasture woodland (" … pasture woodlands are among the most attractive European landscapes") over other kinds of woodland and habitats.

One needs only to look across Britain to see the landscape value of many types of woodland. And, in France too, there are magnificent forests with rich wildlife and veteran trees where cattle are never seen.

The section describes the variety that the Conservators wish to safeguard. All the elements mentioned are now present in the Forest and give it its special character and landscape value.

That is how Epping Forest would appear to have been throughout the ages and how we would like to see it continue.

The Forest is already approximately one third open grassland, which in our view is acceptable. To drastically reduce tree cover over the remaining two thirds will bring about very considerable changes in the Forest’s appearance and ecology that the Conservators should consider very carefully before disturbing.

The justification that the Conservators are protecting the commoner’s ancient rights and implying that there are many commoners clamouring to exercise their rights is misleading. Cattle grazing was in a declining spiral (as the Document states) until BSE brought an end to the remaining handful (3 or 4) of commoners still exercising their right.

Whilst cattle grazing could in theory help make a case for reduced traffic speed, to date it has not done so and it is difficult to see how it could become a major force in future.

Cows, Cars & People

Agreed. We have no comment.

These could be useful at some road junctions and would need to form part of any scheme to manage grazing, but they could not perform a significant control measure in this area.

We are concerned about the use of electric fencing. The Countryside Agency warns landowners and managers that such fencing is inappropriate for use in areas of public access especially where children are present.

Regarding the statement that access gates in the enclosure on Chingford Plain are well used by walkers, our observations suggest the opposite. They are not well used, perhaps simply because of the presence of cattle.

Electric fencing, even when switched off, inhibits use of the Forest at night, for rambling and orienteering activities.

a) Nature and Scale of Fencing

This section seems to suggest that permanent fencing should be constructed (as it is at present along the A104 at Fairmead Bottom) along all the faster roads. This would create a substantial change in the nature of the Forest.

Whilst access points would be welcome, this focus to the debate ignores the major impact of fencing in terms of its visual impact, sense of exclusion and change in the character of the Forest – these are the issues with which we have concerns.

The present fence at Fairmead Bottom along the A104 has only one access gate, for push-chairs, wheel-chairs horse riders & cyclists, in the whole two-kilometre stretch. It has not, as is claimed, stopped the need for further enclosures. As we understand it, the commoner has had problems with cattle straying and consequently it has been thought imperative, even within the permanent fencing, that they be retained in temporary electric fenced enclosures.

We fail to see, as claimed, how fencing in the Forest would create a more tranquil environment for Forest users.

b) Legality

In the 1950’s at the time of the planting of the Coronation Plantation to celebrate Elizabeth’s accession to the throne, the Conservators used

powers to enclose the plantation in order, ironically, to keep the cattle from entering and browsing the young trees !

Later these powers were made more specific in the City of London Various Powers Act 1977, which reads :-

As regards no time limit being placed on the enclosures, Mr Biggs Davison M.P., who led the MP’s delegation, was addressed by the City Remembrancer in a letter of 31st January 1977 as follows :-

It is clear from the above that in taking powers to enclose parts of the Forest, the Conservators thought to exclude cattle from previously overgrazed areas, not to contain cattle within them !

We suggest judging from the above that the Conservators then did not regard themselves as being empowered under the Act to make enclosures in the Forest otherwise they would not have sought specific powers to do so.

The intention to permanently fence large areas or ‘zones’ within the Forest is to enclose areas of the Forest. We consider this is clearly at variance with the letter and intent of the Epping Forest Act of 1878.

Any change allowing enclosures in our view must be by Act of Parliament, as was the case in 1977, not by ‘expedient’ interpretation of the Act.

One of the great and attractive features of Epping Forest is that it is accessible and visibly accessible at any point. Fences hold messages of ‘private – keep out’; that is what fences are normally for.

The Conservators claim that they wish to attract wider social groups to use the Forest, a view with which we concur. The extensive fencing that would be required to contain the number of cattle will, we believe, act as a deterrent to access.

We would of course, like to see slower traffic speeds on Forest roads. If an enforced 20 mph. speed limit were imposed, there would be little need for fences and cattle could in most cases cross roads in reasonable safety for all parties. But in our view it will not happen. In circumstances where the Government wishes, through the East of England Plan, to build half-a-million more houses, there will be ever more traffic generation over Forest roads.

If cattle grazing is to be restored to all parts of the Forest from Wanstead to Epping, which is said to be the objective, fencing will be called for on all main roads. Once that is done there will be little chance of any further speed reduction. The Highway A uthority will regard the hazard problem as having been solved.

Frightened deer caught between two lots of fences will be likely to feel trapped and rush into speeding traffic. Deer have already been killed on the fenced section of the A104. Walkers and horse-riders have had concerns about crossing Forest main roads for many years . Despite this problem being raised regularly, little or no improvement has come about.

All these features of the Forest Transport Strategy – slower speeds, better crossings and other improvements, should be put into effect irrespective of whatever proposals are made for cattle grazing. They should not be, misleadingly, held out as a future gain resulting from cattle grazing.

All of the other open space areas mentioned have conditions and circumstances very different to those in our Forest. All of them are in a rural setting whereas Epping Forest is embedded in a densely populated urban area and is within easy reach of millions of visitors. Lessons from other open access areas that are un-grazed, such as Hampstead Heath, would have been more relevant.

Regrettably the Conservators give no real indication of the proposed increased cattle numbers, other than they envisage a "significant increase in cattle numbers back to earlier levels" . How much ‘wood-pasture’ do the Conservators wish to create ? How many cattle would be required to maintain the area of ‘wood-pasture’ concerned ?

In the Oostvaardersplassen in the Netherlands, mentioned in the late Superintendent’s ‘Bucolic Forest’ lecture, an area of 2000 hectares, somewhat smaller than Epping Forest, contains 500 cattle, 450 horses and 400 Red Deer .

In the New Forest mentioned in ‘ learning the lessons’, an area of 20,000 hectares, there are approximately 2,500 deer, 2,750 ponies, and 1,750 cattle.

Proportionately Epping Forest would be grazed by something like 1,000 animals.

Should this be the case, then what would happen to the animals in winter? Cattle have to be off the Forest during the period November to April. Is it proposed that they are moved to the buffer lands?

The Conservators have recently opened parts of the ‘buffer’ land to access on foot, and we very much welcome this. But it seems to us that this opening-up, intended to be for public benefit, will be largely fruitless if cattle are present in the areas concerned as the public, as a general rule, will not readily access fields containing cattle.

A number of people have already complained to The Corporation about hostile and out-of-control cattle. This is bound to increase if there are more cattle. The danger to people from large herbivores should not be ignored or set aside as an ‘educating-the-public’ problem. That is patronising, the dangers are real. The HSE reported 14 major incidents involving cattle including 5 human fatalities in UK fields between 1990 & 1995.

This increased grazing will be at what cost? Housing the animals over winter, acquiring additional land etc. all take resources.

We think the public’s response to the Document is reduced in value significantly whilst the Document lacks information on ….

• the number of cattle to be grazed on the Forest.
  

• the amount of ‘wood-pasture’ proposed’

• the quantity of fencing that will be required and the implications for access

• the plans for accommodating the cattle in winter

• an assessment of the likely changes to the character of the Forest landscape, its woodland areas and biodiversity

Therefore we would urge the Corporation to assess and question much more comprehensively the feasibility of extending grazing, before any resources are sought to introduce such landscape – scale changes to the Forest environment.