Lots, the gardening trend we just can’t get enough of.


You’ve all seen it in public gardens and open spaces

that big colourful dramatic wow! of Lots

IMG_2779Like these cowslips in Albert Park, Middlesbrough

IMG_8850-001Or these Scilla at Kew Gardens, London, in March

IMG_6286-002Or Camassia at the Royal Horticultural Society garden, Wisley, in May

Bulbs are often used because they’re relatively cheap, quick to plant, and have an almost immediate effect. Especially useful are the spring-flowering ones because by the summer the leaves have died down and you can use the lawn for other things…

IMG_0533-001like tents-for-events if you are the Scilla lawn at Kew Gardens, and yes it really is the same bit of lawn, but at home you could use for e.g. a deckchair instead.

Lots is, in part, a showbiz tip-of-the-hat for the garden-visitor-who-doesn’t-know-anything-about-plants to admire (because public gardens need to welcome everyone) and part a wish to emulate that look of plants growing in their natural habitat.

IMG_0716Like native bluebells in Wensleydale

IMG_3392Or French Lavender growing wild in Portugal

IMG_4938Or frothy white meadowsweet and dark red bobbles of great burnet in a Tees Valley floodplain meadow

IMG_2641-001or harebells on the sand dunes at South Gare, at the River Tees estuary

But how do you get Lots into a small garden? Well …

IMG_9412Scatter many thin plants through a small space so they take up more visual attention when flowering, than space in the soil they’re planted in…like these pale purple globes of Allium hollandicum in late May, which almost disappear as seed heads later as the herbaceous plants start to flower.

IMG_6896-001and a couple of weeks later

IMG_0413-001Or use a few plants which have many tall flowers which take up Lots of visual space above – here three Stipa gigantea grasses in early July

IMG_2909-001Or have Lots of plants tucked to one side like this purple honesty in early May

IMG_7471And again as papery-white seed heads in early November

IMG_1250Or on a very much smaller scale, a continuous carpet of creeping thyme, almost in flower in early JuneIMG_2020and here as an effective greeny-grey foliage backdrop in September working as a foil for the other plants in the gravel garden, after the thyme has had its ‘moment in the spotlight’ of flower (that I don’t have a photo of, so you will just have to imagine that one then)

IMG_0963-001And you can also try getting Lots with the same plant, but in slightly different colours like herbaceous phlox, here in August with pink, mauve, purple and white – a look that would also work with Michaelmas daisies too.

Lots is not as formal as regular repetition of plants along a border

Cool border 2like this cool border at a Community Orchard in the Yorkshire Dales

IMG_0106or as controlled as the big blocks of planting we often see with heathers, like here at the Royal Horticultural Society garden Harlow Carr, in Harrogate

But is a softer way to have a seasonal wow! of your own, no matter what the size of your garden.

IMG_6220-002Lots of the grass Stipa tenuissima catching the light, early September, in my mum’s tiny garden in the Yorkshire Dales.

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Collecting Data


  • The Priority Habitats Inventory data on MAGIC is not definitive.
  • They have a lot more data still on paper that they can’t afford to digitize.
  • Some of the data is obviously crap or out of date, but they can’t afford to check it and change it.
  • Other organisations have better data, at a local level, that may not be on the MAGIC site.
  • The data is so poor that it is impossible to check whether Priority Habitats are being destroyed.

Let’s run that last one again…there is no way of knowing at a national level whether National Priority Habitats are being destroyed year on year.

I asked the responsible politician to investigate a specific legal issue involving the supporting information for creating a SSSI, the National Statistics mark, and the England Biodiversity Figures.

IMG_7587Example of the Coastal and Floodplain Grazing Marsh layer being obviously crap. The layer is information from 1976 before the shopping centre was created but ‘fitted’ to the modern map. Ironically there is some saltmarsh adjacent to the brown markings (mudflats); it’s not present on the database layer for saltmarsh but it is a Local Wildlife Site.

Back in early August I contacted the environmental statistics department at Defra because I felt that they hadn’t actually understood what their data was revealing about Priority Habitats.

I wrote …”on page  https://www.gov.uk/government/statistics/england-biodiversity-indicators and the section 2a on Priority habitats. You have included a caveat in the Background section to 2a.1. Extent of priority habitats for the Indicator Assessment on Extent of Priority habitats, saying that (to paraphrase) due to the way the data is recorded that you don’t actually know the extent of the habitat and so can’t assess any change in extent.

Logically, if this is the case, you can’t actually say the extent of each priority habitat because you don’t measure it, you only measure the area within which there is priority habitat present. So at the beginning of the document the first sentence “There are 1.87 million hectares of terrestrial and coastal priority habitats across England, representing around 14% of the total land area (Figure 2a.1).”  is incorrect and should say ‘There are 1.87 million hectares of land within which terrestrial and coastal priority habitats can be found, but we don’t know the extent of the priority habitats because we don’t actually record that data.’ “

I then questioned how they could state the Priority habitats were in favourable condition if they didn’t know their extent; measuring the extent would be necessary for the condition assessment. I also made a point of saying I was aware of the lack of funding to carry out their statutory duties, something the Chair of Natural England confirmed on 21 Nov 2018 http://data.parliament.uk/writtenevidence/committeeevidence.svc/evidencedocument/environment-food-and-rural-affairs-committee/chair-of-natural-england/oral/92782.html


Example of data being out of date; what was apparently Lowland Meadow in 1991 but you can see clearly from the photo has since been ploughed up.

The answer (28 August) from the technical person (in charge of the Priority Habitat layer for the MAGIC website) was:-

“1) There have been three published versions of the Priority Habitats Inventory which represent improvements in our mapping of the extent of priority habitats in England.  In order to provide a consistent baseline for reporting on the condition of priority habitats (Biodiversity 2020 indicator 2a.2) version (1) of the inventory has been used each time.  The figure of 1.87 million hectares reflects this baseline extent and, as per indicator 2a.2, the condition of this overall area of priority habitat is improving.

2) There are uncertainties over calculating the exact extent of priority habitat in England, which are reflected in the caveats outlined below.  This does however include elements of under-reporting (where areas of priority habitat have yet to been included in the national inventory) as well as over-reporting (where the exact extent of the habitat within a land management unit has not been mapped).

3) Caveats: The Priority Habitats Inventory represents the best available information on priority habitats at an England-wide level; it is not and will never be a definitive dataset for priority habitats across England.  Users of the Priority Habitats Inventory should take into account:

  • For parts of the country, or for specific habitats, there may be more recent or better quality data available, such as that held by local partners, which Natural England has either not had access to or permission to publish.  We also still hold datasets that have not yet been processed for inclusion in the Priority Habitats Inventory and which will be included in future updates.
  • The quality of the inventory is variable: some polygons are derived from recent survey with habitat boundaries mapped accurately and high confidence in the determination of the habitat.  However, for other polygons the information available may be insufficient to confidently confirm the presence of priority habitats.
  • In some cases habitats may not have been mapped in the original data, such as where the original inventory polygons originate from a point dataset, database or from local wildlife site citations (see Table 2 and Table 4 for information on sources), so the site boundary or land parcel has been used as a proxy for the extent of the habitat.

4) To summarise: The new priority habitats’ inventory does not allow for assessing changes to the extent of habitats, as changes to the inventory itself would represent improvements in current knowledge of the extent of priority habitats, rather than actual changes in the extent of habitats. As a result, no assessment of change has been made. Defra, Natural England and JNCC are working to improve the quantity and quality of data on priority habitats, for example by improving standards for habitat mapping, and by investing in research that is developing new methods that combine satellite, remote sensing and field data to provide better information on the stock and change in habitats.

5) We plan to publish the Priority Habitats Inventory methodology/user guide on our website alongside the Open Data download, but we have attached a copy to this email for your information.”

[they did attach a copy – I haven’t read it yet; some more blogs to do be fore there is time for that]


Not Lowland Meadow, but “good quality semi-improved grassland”… except that was in 1991…Natural England’s own photos show it’s been ploughed up and is now arable land.

Given the caveats mentioned above, and that recently the Natural England board have taken the legal step to designate Malvern Common as a Site of Special Scientific Interest using supporting evidence (scroll down for a .pdf here   https://consult.defra.gov.uk/natural-england/malvern-common/ ) stating there is less than 10,000 ha of Lowland Meadow Priority Habitat in existence in England, then the data published by Defra must be wrong because it differs from the Natural England figure which has been used in a legal manner. There is also a National Statistics mark on the Defra web page, so it calls into question Defra’s use of that mark or alternatively the quality of National Statistics as a whole.[I suspect the issue is one of people not understanding precisely what the statistics relate to rather than anything Machiavellian, but we’ll see in time]

I’ve written (26 Nov) to the Parliamentary Under Secretary of State for the Environment – who is, at present, Thérèse Coffey MP – and asked that the matter be investigated and that I am informed of the outcome. (I actually used the defrahelpline email rather than the MP email as I thought the email should be in the Defra capacity rather than their MP capacity so hopefully someone will forward it on). I copied in the National Statistics people and they have already replied and are investigating.


Don’t get me wrong here, the MAGIC site is really amazing – it’s only because it is there and easy for me to use that I can point to evidence of lack for funding in mapping the extent of our shared national cultural heritage of Lowland Meadow plant communities. It just needs better funding.

And if you are wondering why I write such long technical blogs…


This is their map of how much Lowland Meadow there is in my area (the small green bits)


And by way of comparison, this is the extent of Ancient Woodland in my area.

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Keeping Count

HS2 Phase One and 2a will destroy about 1% of England’s National Priority Habitat Lowland Meadow and there will be more destroyed when figures for Phase 2b are confirmed. That’s 80 ha (the second information request, when I basically asked “are you really sure about those figures?”, said 79.8 ha) and the national estimate for the Priority Habitat is around 8000* ha.

Yes, they are going to create** some new Lowland Meadow as mitigation. As far as I can make out it will be 165 ha at Phase One and the rather vague 478.8ha of “habitats of principal importance” “which will include mainly lowland mixed deciduous woodland and lowland meadow.” for Phase 2a apparently following Ecological Principles of Mitigation (EPoM), although both the links given in answers to my questions are to survey methods. They did refuse to commit to best practice for the habitat creation on the grounds of cost “Where reasonable and worthwhile to do so, the collection of seed and/or plants from suitable donor sites will be considered.” (best practice is to use seed/plants from the habitat that is to be destroyed in order to conserve local genetic diversity) and yet when I asked how much money had been set aside “It is not currently possible to provide a ring-fenced figure for ecological habitat creation, monitoring and maintenance. HS2 has been designed, and therefore costed, as an integrated railway, of which ‘environment’ is not seen as an ‘add on’.” <puzzled, thinking-person scratching-their-head emoji>

Natural England and Defra have presumably agreed to this approach. After a bit of internet searching I found there is an “independent Ecology Review Group (ERG)” although I can’t find any contact details…so if anyone knows, then please pass the info on and I’ll check with them when I have time. I’d be particularly interested if they are taking into account the new SSSI guidelines for Lowland Grassland because obviously for something as prestigious as HS2 they will want to be using the latest ecological information. Obviously.



*”…between 7, 282 ha which is cited in the UK BAP targets from 2006 archived on the JNCC website and English Nature Research Report 2000 ‘Monitoring the condition of lowland grassland SSSIs’ No. 315 gives a similar estimate of lowland meadows of 8,400 ha” – pers. comm. Request for information from Defra – Ref: TO2018/07235. So I took 8000 ha as a round number, but basically Defra do not know and haven’t mapped or surveyed it all and that means Natural England don’t know either: See https://theintermingledpot.wordpress.com/2018/04/26/estimates/

** do bear in mind that new habitat is not the same as old habitat for Lowland Meadow. Most examples of Lowland Meadow are likely to be Ancient Grasslands see https://theintermingledpot.wordpress.com/2017/09/27/defining-ancient-grassland/

Broadly, all Lowland Meadow over 0.5 ha in extent is now defined as being of SSSI quality, see https://theintermingledpot.wordpress.com/2018/02/25/all-examples-of-mg5-over-0-5-ha-can-now-be-designated-as-sites-of-special-scientific-interest-sssi-so-why-hasnt-that-happened/

Info. on what constitutes a Lowland Meadow is downloadable from here http://jncc.defra.gov.uk/page-5706

To give you an example of how difficult it is to get a clear answer when asking questions about specific environmental matters; my question (from my second information request from HS2) is in bold below and the answer is given afterwards…

“My understanding regarding the extent of destruction during the creation of HS2 of the National Priority Habitat Lowland Meadow puts it (80 ha) at nearer 1% of the English total (between 7, 282 ha which is cited in the UK BAP targets from 2006 archived on the JNCC website and English Nature Research Report 2000 ‘Monitoring the condition of lowland grassland SSSIs’ No. 315 gives a similar estimate of lowland meadows of 8,400 ha – pers. comm. “Request for information – Ref: TO2018/07235”) – can you please check and confirm this information of the destruction being at around 1%? I presume that total amount destroyed will be greater when the data for Phase 2b are known.”

 “Route-wide combined impacts from Phase One, Phase 2a and Phase 2b are stated in Volume 3 of the Phase 2a Supplementary Environmental Statement and Additional Provision Environmental Statement. Habitats of principal importance directly affected are reported as the number of distinct areas of habitat of principal importance that are within, or partially within, the land required for the Phase One and Phase 2a AP revised scheme. This is reported as 124 instances combined, noting that there are currently no figures provided for Phase 2b.”

Links to those scoping and survey documents I mentioned are below though I can’t find anything about the mitigation except a short slide show to the CIEEM.

  • Phase One Scope and Methodology Addendum (CT-001-00/2)


  • Phase 2a Scope and Methodology Addendum (CT- 001-002) Part 1 –



This is a short blog because I’m busy at the moment, but if you want to follow it up:

From HS2, the information requests I made have the reference numbers FOI18-2056 and FOI18-2072

and from Defra the Request for information – Ref: TO2018/07235

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There is no national oversight for the relative proportions of English Priority Habitats that are placed into SSSI designation even though biological SSSIs “are intended collectively to comprise the full range of natural and semi-natural habitats”

I know because I asked: I was interested to know who was the “opinion of Natural England”  – the legal key to getting land designated as SSSI according to the Wildlife and Countryside Act 1981 – especially as the National Priority Habitat Lowland Meadow is only about 0.3% of national SSSI designation by land area. (see NOTES at the end)

It turns out from the reply I received that

“Only a small proportion of SSSIs are attributable to grassland, however, there is no reason (or national strategy) for this. Sites are selected on a site by site basis, based on their individual merits.”

“Sites are considered initially by local Area Teams within Natural England. If the site satisfies the qualifying criteria, these Area Teams are likely to carry out a number of site visits. All of the available evidence is then submitted to Natural England’s Senior Leadership Team for a final decision.”

If only it were that simple. Let’s look first at the qualifying criteria that the local Area Teams use.

You can find them here http://jncc.defra.gov.uk/page-2303  or rather some of them, because they were due to be updated by 2013/4 but I think only Lowland Grasslands made that deadline. You can see that some have been updated this year; the majority are still under revision presumably because the government hasn’t thought them a high enough priority to fund. The revisions are very good indeed as are the experts who write them, but the people who manage the experts are clearly unable to operate at the same level of expertise and skill.

When all the new guidelines are eventually updated, the original designations of the existing SSSIs will need reviewing and revisiting to see how they fare against the new guidelines (according to https://en.wikipedia.org/wiki/Site_of_Special_Scientific_Interest it took ten years to do this after the changes of the 1981 Wildlife and Countryside Act). And then all the existing habitat survey data needs to be reviewed to see if more SSSIs need creating as a result of the new guidelines.  Also, the local Area Teams will need to take account of the survey data they don’t have, and whether they need new data…all within their reduced budget of course. If, hypothetically, someone brought a court case against the local Area Teams because they didn’t designate a site that met the criteria better than an existing SSSI then they may well be liable to having not undertaken their statutory duty correctly. I suspect it would help their case if, for example, the chairman of the board of Natural England had written to the government explaining that Natural England had insufficient funding to carry out their statutory duty, otherwise I guess the local Area Managers will be left to fend for themselves. Good luck everyone.

Defra publish a set of figures so that anyone can judge the relative proportions of Priority Habitats in SSSI, the latest (2018) are here https://www.gov.uk/government/statistical-data-sets/env09-england-biodiversity-indicators 

(sorry about the quality of the table – I’m not very techie – but it can be found on page 2a of the Excel file on the page above)

habitat file

Why is 158,993 ha of Upland Heathland SSSI, but only 845 ha of Upland Hay Meadow? Who decided that one then? Definitely something that will come under scrutiny after we leave the EU and money is targeted to the management of SSSIs. As a country, would we be wanting to target such a larger amount of the apparently scarce financial resources for SSSI management on species-poor Upland Heathland compared to species-rich Upland Grassland? It will be interesting to see the how the SSSI boundaries for Upland Heathland fit over the “Who owns Britain” information. http://map.whoownsengland.org/

I’m assuming in the point above that the relative proportions are correct in the table because we definitely know the absolute numbers are not. I asked about the figures for Lowland Meadow (and blogged here  https://theintermingledpot.wordpress.com/2018/04/26/estimates/ ) and the 36,000 ha Defra claim above have a reality which is much closer to 8,000 ha. Assuming all the other figures are created in the same way, then the whole table is a completely and utterly misleading or as we say in science “unpublishable”; colloquially we would say “bollocks”. Nor is the extent recorded when the sites are condition assessed (see Report 2a. 1. Background  – about the new mapping system which doesn’t record the extent  https://www.gov.uk/government/statistics/england-biodiversity-indicators ).

SSSIs aren’t even visited often enough any more to check on their condition  https://unearthed.greenpeace.org/2018/09/07/half-england-sssi-sites-not-monitored/ .

And then when we get to actually designating new sites the responsibility for investigating a site remains firmly on the shoulders of the local Area Team managers. They don’t have sufficient money available to check all sites and so must prioritise, but they will be prioritising on the basis of their own area not looking at an assessment of what is necessary to safeguard, say, the genetic variation of a native species where it varies across the country. Also, how can you choose the best examples if you haven’t carried out enough surveys to give an accurate assessment or the surveys available to you are out of date? (I’ve got a blog lined up about the considerable limitations of the MAGIC datasets; I’m just waiting for a reply from them). If the habitat, say Upland Meadow of MG3, mainly occurs nationally within a single local Area does the team designate all of it within the area because it’s nationally rare or only some because it’s not as rare locally; looking at the table above…obviously the latter.

And now to the actual designation process which is time consuming and complex, as landowners don’t always want their land designated. If we take the example of Lowland Meadow, where the new guidelines allow for designation of all examples over 0.5 ha, and if we keep going at the national designation rate of about say 10 Lowland Meadow sites a year then it will take at least 300 years (conservative estimate) before they are all designated (they are mainly very small now (because the larger areas have been destroyed in the past) and so there are lots of them making up the approx. 8000 ha in total; about 3500 ha are already SSSI). Even if all the estimated total of 8000 ha were designated as SSSI, the area pales into insignificance compared to the 159,000 ha of designated Upland Heathland. How could that disparity have even arisen from the published scientific guidelines? (suspicious face emoji).

And yet read any government document and it will tell you SSSIs are crucial to our country’s natural history – they are the living gene banks of our native plants and animals. A quote from the new Conservation 21 document

“High quality designated areas will be central to resilient landscape and ecosystems. They are a key component in establishing the large core area and networks that are the building blocks for resilience – providing refugia and stepping stones supporting adaptation to climate change, and for delivering wider ecosystem benefits.”

I wonder how close we are to the government saying that Natural England isn’t working (because things don’t work well when they’ve been underfunded although obviously they won’t mention that) and would be better privatised? Or started again? And I wonder how much longer the senior, more knowledgeable experts, with all their vast accumulated understanding of our country’s natural history, will want to stay.



I was interested to see who was responsible for designating SSSIs – i.e. who you would legally point the finger at if it wasn’t being undertaken properly and so I asked

“I note in the Wildlife and Countryside Act 1981 it states:-

[F215 28Sites of special scientific interest.E+W

(1)Where [F216Natural England] are of the opinion that any area of land is of special interest by reason of any of its flora, fauna, or geological or physiographical features, it shall be the duty of [F216Natural England] to notify that fact—

(a)to the local planning authority [F217(if any)] in whose area the land is situated;

(b)to every owner and occupier of any of that land; and

(c)to the Secretary of State.

And so I would just like to check with you who is the person or job title with whom the responsibility lies for being the opinion of Natural England as laid out in the above law. From what I have read on your website it would seem to be the Chairman of the Board of Natural England, but I would like official confirmation of that please if I am correct.”

After an email checking as to whether I meant a local site or nationally, the answer I got was :-

“Sites of Special Scientific Interest (SSSIs) are the England’s very best wildlife and/or geological sites. SSSIs include some of the most spectacular and beautiful habitats, and a large proportion of these sites are internationally important for their wildlife and are also designated as Special Areas of Conservation (SACs), Special Protection Areas (SPAs) or Ramsar sites.

Natural England is responsible for identifying and protecting the Sites of Special Scientific Interest (SSSIs) in England under the Wildlife and Countryside Act 1981 (as amended). Only a small proportion of SSSIs are attributable to grassland, however, there is no reason (or national strategy) for this. Sites are selected on a site by site basis, based on their individual merits.

The designation of SSSIs includes a two stage process; notification and confirmation. Natural England has to be of the opinion that an area of land is of special interest because of its flora, fauna or geological or physiographical features. This opinion is based on the exercise of specialist judgement which is informed by scientific guidelines – The Guidelines for selection of biological SSSIs for wildlife (biological) sites.

In order for a site to be considered as a candidate for SSSI designation, it has to support nationally important/rare flora or fauna or have nationally important geological or physiographical features. Anyone can recommend a site for consideration, and Natural England would expect accompanying evidence to be submitted at this stage. Sites are considered initially by local Area Teams within Natural England. If the site satisfies the qualifying criteria, these Area Teams are likely to carry out a number of site visits. All of the available evidence is then submitted to Natural England’s Senior Leadership Team for a final decision.

If you have a site in mind, you will need to supply evidence of it’s qualifying criteria to the mailbox above. The relevant Area Team will contact you directly with their decision.




I take that answer to mean that the “opinion” resides with that of the board (and the chairperson) and so the legal designation is their responsibility, but that the local Area Teams are legally responsible for choosing the sites for consideration. However, you will note that they didn’t answer my question directly.


Also of interest I found

“Natural England has a duty to notify SSSIs when it is of the opinion that an area of land is of special interest by reason of its flora, fauna or geological or physiographical features. This opinion is based on the exercise of specialist judgement which is informed by scientific guidelines.”


“The purpose of SSSIs is to safeguard, for present and future generations, the diversity and geographic range of habitats, species, and geological and physiographical features, including the full range of natural and semi-natural ecosystems and of important geological and physiographical phenomena throughout England. The sites included within the series of SSSIs are intended collectively to comprise the full range of natural and semi-natural habitats and the most important geological and physiographical sites. The SSSI series should therefore include all of our most valuable nature conservation and earth heritage sites, selected on the basis of well-established and publicly available scientific criteria.”

Defra, 2003. Sites of Special Scientific Interest: Encouraging positive partnerships. (via http://webarchive.nationalarchives.gov.uk/20140605123715/http://www.naturalengland.org.uk/Images/Notification%20strategy%20for%20web_tcm6-15235.pdf )

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Bringing Ancient Grasslands into the heart of our towns and cities.

A decline in insect numbers, children losing touch with nature, adults in total ignorance of their local cultural heritage, and local government cutbacks. What can we do to help?


This used to be a municipal incinerator; in 1995 it looked like this https://www.flickr.com/photos/crumplezone/7197765196 

In 2016 Natural England published its Conservation 21 strategy  (https://www.gov.uk/government/publications/conservation-21-natural-englands-conservation-strategy-for-the-21st-century ) which proposes a future based around the following three guiding principles

• creating resilient landscapes and seas
• putting people at the heart of the environment
• growing natural capital

An efficient and sensible way to solve all of the above problems is to bring our rural ancient grasslands into the heart of our urban areas: Cowslip, bird’s-foot trefoil, autumn hawkbit growing on our urban road verges so they can be seen during the year by every child as they walk to school, every adult as they drive* to work, and also used as food plants by the plethora of insects and associated creatures that we could have in our lives again. Get the plants right and pretty much the rest of the wildlife turns up on its own.


It can start immediately**. In the build specifications for every new housing estate, road verge, or public space the default option should be to use locally-collected ancient grassland seed sown on subsoil. Local to keep a sense of local character and distinctiveness, subsoil to slow the growth of the plants so they don’t need mowing as frequently…something that would save a lot of money over the 50-100 year lifespan of the new urban or suburban grassland.

A developer would need a really good reason (a rugby or football pitch) for the local authority to allow the current system of high cost, high maintenance, low biodiversity grassland of rye-grass sown on expensive topsoil (I do rather wonder if planners think this sort of thing through properly).

The existing street verges/urban open spaces can be enhanced with ancient grassland seed or turf removed and seed sown. There isn’t enough local ancient meadow seeds to do it all at once, but a rolling program of culturally important biodiversity change is easily possible and not expensive.

If you want to start straight away, then there is an idea for funding at the end of the blog.


Reasons why people might not want this to happen.
“We can’t collect the hay as we don’t have the equipment and it is too expensive to do”. This isn’t about recreating hay meadows, this is about creating the modern equivalent of medieval wildflower-rich grazed pastures (which once covered about a third of England) although instead of being irregularly grazed by oxen we use a lawnmower 3 to 5 times a year. No hay to remove. Current high-cost low-biodiversity system is to mow 10 to 12 times a year.


“It won’t work”. It does, what did you think the photos I’m using were of?


This is in front of a local police station – no-one has complained yet.

“It will look messy”. How many people will really complain? Ten, fifteen? More than 50% or less than 50% of the population living in the area? And why don’t those complainers want to celebrate their local cultural heritage? And why do they hate children so much that they think children shouldn’t be allowed to see cowslips or bird’s-foot trefoil? And are they going to pay the extra for neatly mown ryegrass?

“It costs more”. Show me your costings; please include maintenance cost estimates for the next 50 years and 100 years because this is the likely road verge plant-community life-span and include the biodiversity costs of the two different systems, then tell me it costs more because I simply cannot see on the evidence in front of me that it costs more.


“I get hayfever”. Me too – at present the drugs I take are excellent (thank you to my NHS doctor for prescribing them), but yes I too would like more research into why the body’s immune system reacts in this way and think it will yield important insights into how our bodies fight infections. Also, as a nation of very skilled horticulturists, we can time the cutting to minimise the amount of grass flowers (and pollen) that are produced and maximise the amount of wildflowers (we really can).

“We will have to change”. Yes; yes you will – we all will. And so we should.


Funding sources.
If you have a local community/horticultural group with its own bank account, then the Heritage Lottery Fund is perfect https://www.hlf.org.uk/looking-funding/our-grant-programmes . You might be able to pick up a few extra local small grants to supplement it. Your project would study your local heritage through maps and field names, study the plants in your local ancient grasslands, engage the local people with their floral heritage and then bring that heritage to a more accessible place into the urban/suburban road verges for everyone to celebrate and enjoy. You will need your local councillors to agree to saving money on future maintenance of the areas first. Otherwise the grant is to raise enough money to pay someone to survey the road verges you want to change first to see if the right plants are there anyway (you’d be surprised what can be there), pay someone else to do all the heavy lifting if turves or soil needs to be removed/replaced, pay someone to help you celebrate the local heritage (archaeology group? Heritage officer?), and to pay for any other advice you receive. If possible always use your grant to pay local people. Talk to your local wildlife trust, county ecologist, or similar custodian of ancient grassland about your project and see how they can help.

If there is house-building occurring in your neighbourhood, money may be available through your council as a result of the house-building. If in doubt ask your local councillor they are only an email away.



*Obviously, please walk or ride a bike at least some of the way to work if you are physically able to do so.

** Technically it should already have started; Section 40 of the Natural Environment and Rural Communities Act 2006, places a duty on all public authorities in England and Wales to have regard, in the exercise of their functions, to the purpose of conserving biodiversity. The National Planning Policy Framework is clear that pursuing sustainable development includes moving from a net loss of biodiversity to achieving net gains for nature. https://www.gov.uk/guidance/natural-environment

Collecting seed or green hay from local ancient grasslands means that those grasslands gain monetary value for what they are – a source of biodiversity. If you are a local council owner of said grassland then it is also a useful way to get someone else (i.e. a housing developer) to help contribute towards the costs of its upkeep.

I get sick to my heart of adults bemoaning the fact that children can’t name wildflowers/don’t connect with nature when adults have deliberately removed virtually all chance of any child meeting most of our wildflowers on a daily basis and most adults are themselves so very ignorant they could not recognize native wildflowers if they fell over head first into a patch of them. Writing books about all the lovely nature that children do not have opportunity to see seems to me either vindictive in the extreme or subversive, hoping for a revolution (fingers crossed for the latter). We should reframe the point. Children should not be blamed for things adults have gone out of their way to relentlessly and systematically eradicate from a child’s everyday existence. Please always frame the argument about the damage done by the adult, not the lack of connection by the child.

We need an Ancient Grassland Inventory https://theintermingledpot.wordpress.com/2017/06/27/we-should-talk-of-ancient-grassland/ so that everyone would know where native grassland seed could be taken from. At present there is no such inventory, the unimproved grassland layer on the MAGIC website is wrong/out of date, Defra have been misreporting the amount of national priority habitat Lowland Meadow both to parliament and to the nation https://theintermingledpot.wordpress.com/2018/04/26/estimates/ , and as a habitat Lowland Meadow is so endangered and there is so little left nationally that any piece over 0.5 ha in size can now be designated a SSSI if the opinion of Natural England is such that it should be https://theintermingledpot.wordpress.com/2018/02/25/all-examples-of-mg5-over-0-5-ha-can-now-be-designated-as-sites-of-special-scientific-interest-sssi-so-why-hasnt-that-happened/ . Scandal is too mild a word for the deliberate eradication of wildflower-rich grassland from our cultural and physical landscape.

Defra have recently appointed a “Tree Champion to drive forward planting rates” https://www.gov.uk/government/news/tree-champion-to-expand-englands-woodland . Native trees and tree planting are one of the biggest conservation success stories of the last Century; there are more mature native trees alive today than there have been for over a thousand years and the amount of woodland in the UK has increased from 5% to 12% of land area, of which about half is broad-leaved woodland https://www.wildlifetrusts.org/habitats/woodland . Biodiversity is still declining, so on the evidence, if I wanted to increase biodiversity, I wouldn’t put my limited money*** into tree planting…I’d put it into replacing a habitat that we have lost a lot of – the biggest example being species-rich grassland. Also, all of this is so obvious that I can’t actually believe I’m having to politely spell it out for all those who work at Defra to read (to be fair the scientists already know so maybe they can pass this blog on to their managers and they can pass it on to their political managers. I still have some more technical data to collect before I start writing about the political and management decisions that took us to where we are and yes I won’t forget about the loss of staff, expertise and etc from the cutbacks that resulted from the government not having fit and proper regulations for the banking sector).

***A bit of checking and I find that the government are relying on money from HS2 Ltd “It will be a further 11 million trees by 2022—in this Parliament. I believe we will do that comfortably, not least because HS2 Ltd is setting aside money, £5 million, for schemes and will plant trees over the next few years, so I am confident that we will go past that target. “ see Column 186WH https://hansard.parliament.uk/Commons/2018-01-11/debates/58783B31-7C4A-431A-BF43-4259F9FA92A2/ForestryInEngland . Oh wait! As you were; it turns out HS2 is funded by the government https://www.gov.uk/government/organisations/high-speed-two-limited

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Before I start on the Defra reply, here is a short explanation which will help you see why what might seem to be a semantic quibble later on is actually crucial to knowing how much Lowland Meadow habitat exists.

When undertaking a field survey we have a set of categories that we can place plant communities into (the National Vegetation Classification (NVC)) and those plant communities may differ across a site depending on soil type, historic/current management, amount of water, etc.

Here is a straightforward example where the size of the national priority habitat Lowland Meadow (the greener bit with flowers in the photo and the green area on the map) is 0.22 ha and the size of the site is 1.3 ha. Please note that the size of the national priority habitat Lowland Meadow is not the same as the size of the site.


Tot Fenny's Field cut

The Defra question arose out of my not understanding the published figures on how much Lowland Meadow habitat existed in England see https://theintermingledpot.wordpress.com/2018/01/07/documenting-ancient-grassland-loss-a-short-ish-review/  (at the end of the blog).

I thought for this blog I would just reproduce the questions and answers.

My question sent to Defra on 23 March 2018 was: –

“Has there been a change in the definition of Lowland Meadows in England as used by Defra in the figures published in 2017 https://www.gov.uk/government/statistical-data-sets/env09-england-biodiversity-indicators compared to the figures used from 2005 http://jncc.defra.gov.uk/page-5848  ?

I can see that for England in the 2016 statistics there is 36,129 ha of Lowland Meadows priority habitat and yet in 2005 there was 7282 ha.”


Their reply on 20 April 2018 was: –

“Thank you for your email of 23 March about the definition of Lowland Meadows in England.

There has been no definitional change. The Lowland Meadows Priority habitat covers the National Vegetation Communities MG4, MG5 and MG8.

Prior to explaining the apparent anomaly in the 2005 and 2016 figures, it is important to stress that since the late 1990s there have been various published estimates of the extent of different semi-natural grassland habitats in England and the UK based on different data sources and sometimes on differing definitions.

There are estimates that have been based on the partial data gleaned from Phase II (NVC -based) grassland surveys in England undertaken over the period 1980 – late 1990s. Thus, this is the source of the lower figure of 7, 282 ha which is cited in the UK BAP targets from 2006 archived on the JNCC website, and more recently in the semi-natural grasslands chapter of the National Ecosystem Assessment (2011). The English Nature Research Report 2000 ‘Monitoring the condition of lowland grassland SSSIs’ No. 315 gives a similar estimate of lowland meadows of 8,400 ha. The larger figure of around 36,000 ha is based on data from the SSSI site condition monitoring, England Priority Habitat inventories and agri-environment monitoring. This figure is much larger and this is largely due to the fact that polygons often do not strictly delimit the actual semi-natural grassland area and may include areas of semi-improved grassland or non-grassland habitats such as scrub. There may also be issues to do with definition such that some areas have been labelled as lowland meadows when in fact they are semi-improved or ‘undetermined’ grassland. Natural England, subject to resources, intends to continually refine the data on semi-natural grassland habitat definition, extent and condition.

However, for now, the smaller estimates of extent are likely to be a more accurate reflection of the extent of the lowland meadow Priority Habitat in England.”


And my reply on 26 April 2018 was: –

“Thank you for the very clear and thorough reply, which is much appreciated.

Whilst I genuinely appreciate the financial restraints that have been placed around accurately recording the extent and condition of the National Priority Habitat of Lowland Meadow, I will still point out the following error in the presentation of the current figures that Defra have decided, for whatever reason, to use.

If there has been no definitional change (as stated) then all the labelling in the tables after the measurement change should reflect the change that has occurred. i.e. the table records the (accurate) area of a site within which an (unspecified) amount of the target priority habitat occurs. For example, in ENV09 – England biodiversity indicators 2017 assessment, page 2a, the title states “Status of threatened habitats: Extent and condition of priority habitats” but the consequences of the reply are that the title should read “Status of threatened habitats: Extent of the site within which the [unspecified amount of] priority habitat is present and the condition of priority habitats within the site”. ‘Extent of priority habitat’ is not the same as ‘extent of the site in which priority habitat is present’. In the table, or as a footnote, I think Defra should also state what the estimate of the extent of each priority habitat type is and the date when that estimate was made and the data on which the estimate was based and make it clear that the priority habitat has not been adequately surveyed nationally to give an accurate figure of its extent and that the best information possible at the moment is an estimate based on old surveys. Or perhaps Defra could survey the priority habitats properly and publish that data.

There is obviously a similar issue with the presentation of the extent data regarding priority habitats within SSSIs.

Someone from Defra, in the interests of interdepartmental consistency within Government, might wish to discuss this issue with the Office for National Statistics to assist with this report  https://www.ons.gov.uk/economy/environmentalaccounts/methodologies/uknaturalcapitaldevelopingseminaturalgrasslandecosystemaccounts where Table 11 states clearly that there is 13,406 ha of Lowland Meadow within SSSIs in England “Source: Joint Nature Conservation Committee Protected Areas Designations Directory (2010)” and this is not the case; there is 13,406 ha of SSSI in which the priority habitat Lowland Meadow is present, but the extent of the priority habitat Lowland Meadow is not known. There seems also to be some confusion with the definition of semi-natural grassland (SNG) in Table 2 which apparently includes “…sown grassland strips alongside arable fields, long-term set-aside or fallow land…” enabling the comment that “SNG is a fluid habitat and can be readily converted to arable land and improved grassland through cultivation, re-sowing and fertiliser application. It can also be restored and recreated from arable or improved grassland precursors.” but later in part 11. Cultural Services states “Semi-natural grasslands (SNGs) are part of the cultural landscape of the UK. Most are remnants of traditional farming practices and are the product of thousands of years of human interaction with landscape and its wildlife.” Perhaps all the Government departments could use the same definition of Lowland Meadows.

The confusion apparent within the Office for National Statistics’ report neatly sums up the wide range of seemingly similar sets of data that are mislabelled, and the lack of accurate up-to-date knowledge on the extent and condition of the priority habitat Lowland Meadow.

Whilst I understand the (GIS mapping) reasons why they have arisen, I think that the present figures are not fit for the purpose of conservation of priority habitats, completely misleading in their presentation, and any policy based upon them will be flawed.

I will be blogging about the Defra answer and my above reply at https://theintermingledpot.wordpress.com/ as I mentioned in the original question on this topic sent to you on 19 January 2018 to which I didn’t receive a reply.“


If you have read this far and are wondering about how one of the wealthiest countries in the world has got to a point where the extent of one of its iconic ancient national priority habitats is not known, then let me remind you that how government money is allocated is a function of the politicians that we all elect; I can only assume that the politicians are not interested enough in our heritage to fund a survey to see what is actually there rather than use an estimate.



Geographical Information Systems (GIS) is basically a big computerized map. All the habitat statistics now seem to report the size of the site (the ‘polygons’ mentioned in the reply), because that is known and easy to measure, rather than the size of the habitat within the site because that requires digitisation of a skilled site survey which would cost more.

The Excel table relating to ENV09 – England biodiversity indicators 2017 assessment can be downloaded from here https://www.gov.uk/government/statistical-data-sets/env09-england-biodiversity-indicators

The 2016 statistics showing 36,129 ha of Lowland Meadows priority habitat includes information from the Defra Higher Level Farm Scheme (HLS) – the agri-environment monitoring mentioned in the Defra reply. This scheme was appraised in the report that can be found here http://randd.defra.gov.uk/Default.aspx?Menu=Menu&Module=More&Location=None&ProjectID=19358&FromSearch=Y&Publisher=1&SearchText=grasslands&GridPage=3&SortString=ProjectCode&SortOrder=Asc&Paging=10#Description I haven’t read the whole report and I found the summary difficult to understand, but apparently not all the surveyed sample sites in HLS are national priority habitat, those that were non-priority habitat on entering HLS showed little progress (only 17% improved), HLS doesn’t make much positive difference in the majority of sites they surveyed. 16% of the 118 site sample “…were unsuitable for the establishment of species-rich grassland…”. Basically this is the bit where something in the figures is termed Lowland Meadow when it is not actually Lowland Meadow; obviously Lowland Meadow means Lowland Meadow except for those occasions when it doesn’t *sigh*. And also “50% of the HK6 sample were found to be correctly targeted (Group 3)…” which I took to mean the expertise at Defra was as good as tossing a coin, which must be wrong – so maybe lets just conclude that the advice to farmers from Defra is not perfect. Actually, what is really depressing is that there are some very skilled and knowledgeable people working within the Defra group and I wonder how much longer they will stay – we really do need them, because the situation would be abysmal (rather than just completely awful) if they weren’t there.

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Available data

I got an answer to my questions about implementing the new grassland SSSI designation guidelines from Natural England on 23 March. Replies are normally meant to arrive within 15 working days; I sent the first email on 31st January. Anyway, they apologised, so perhaps it won’t happen again. Many (genuine) thanks to the support advisor (the second I’ve spoken to – I think the first one left) who managed to force an answer from someone.

Basically, the reply was links to the guideline documents Natural England use for assessing SSSI designations (which to be fair to them, they can hardly say “we’re really strapped for cash; heeeeelp!” in an official reply) and also the phrase…

“These are guidelines and do not bind Natural England or the other GB statutory conservation agencies as such to notify all areas of land that may qualify or to set any timetable for notification.”

I checked again with the advisor about this phrase just to make sure that was what they meant to say as I wanted to use it in my blog, and the subsequent reply was to refer me to para 12.2 in the summary section of Part 1 of the GB SSSI guidelines (Rationale & operational approach) which sets out the status of the guidelines. http://jncc.defra.gov.uk/pdf/SSSI_GuidelinesPart1_PUBLICATION_Dec2013v2.pdf

It contains the phrase “Using this guidance, country agency staff should be able to determine and explain any selection case in the most objective manner possible.” Good! I find the best way to proceed is by being objective too; and they go on to say each case rests on expert judgement which should be “based on an assessment of the available data.”

“Available data” – what does that mean to you? The government have a dataset of unimproved grasslands on their MAGIC data site. The data-mapping concept itself is fantastic and whoever pushed for it to be created is a complete star – I really love maps and what they tell us about our culture.

IMG_9582However, in my area there are some ‘divergences’ between the mapped information and the present reality of unimproved grasslands. One site listed as 0.67 ha MG5 (surveyed 1991) is now covered in scrub and bramble (above pic), and part of an adjacent one (0.28 ha) is also scrub covered. One site 1.54 ha (again 1991 survey) was ploughed and reseeded in the mid-2000’s when the old farmer retired and a new one took over (you can see this if you switch the aerial photographs layer on). Another site of 1.38 ha of MG5 is listed with the comment “Uncertainty as to whether vegetation classification is MG5 or MG6 as site was “difficult to access”; when I was last there much was covered with scrub. Yet another site of 0.54 ha shows, as scrub or perhaps new woodland, on the aerial photograph.


Not shown on this MAGIC Map layer are 20 sites (all info in the public domain including NVC surveys – some paid for by Natural England – pic above is 2.24 ha of MG5 publicly owned) that would fit the current SSSI guidelines criteria including one estimated to be 100 ha; this last a particular bone of contention (I’ve never managed to get access permission to survey) and I contacted my local Natural England team about this (for context, 100 ha puts it into the top 10% of this priority plant community in terms of size in England); they said “I have also checked our mapping systems for any records of priority habitat within the [redacted by me] boundary, and the only site is a small section of open mosaic habitat at the north of the site and to the immediate west…” and yet I directed them to an independent ecologist’s report (paid for by the landowner as part of a planning application and so publicly available) that makes it clear Natural England’s data is wrong and the site is unimproved grassland.

Do you see where I am going with this? My area, the Tees Valley, is tiny (79,495 ha compared to the whole of England’s 13,027,900 hectares) and the Natural England official map layer for ‘unimproved grassland – Lowland Meadows’ is substantially inaccurate. What about really complicated and big areas like Northumberland or Durham or Yorkshire? How wrong are they? Just how accurate is the available data that the Natural England experts make their assessments on?

Going from a local viewpoint up to a national one, the 2016 Priority Habitat figures from Defra show 89,173 ha of deciduous woodland is SSSI in England and for Lowland Meadows SSSI it is 13,415 ha. A single SSSI, the North York Moors which contains the largest continuous tract of heather moorland in England, is 44,094.41 ha (I think used mainly for driven grouse shooting).

Looking at the whole of the country I’m left wondering how did our iconic English meadows and wildflower-rich grasslands, which were once one of the largest habitats in England, get to a point where they are now at least 10 times rarer than ancient woodland? Natural England’s scientific evidence says to protect all sites of 0.5 ha and over, and yet there is no timetable or even intention to act on the available data.



I think the 2016 Priority Habitat figures Defra give for Lowland Meadows are misleading and have emailed in a question about their use of the term ‘Lowland Meadows’ (they said they would reply in 15 working days) but I have used their figures anyway. You can find them here https://www.gov.uk/government/statistical-data-sets/env09-england-biodiversity-indicators on sheet 2a.

They are contradicted by the Technical Information Note 147 on MG5 grassland and the Biodiversity Action Plan figures, although since my emails with the JNCC (very helpful) over this issue they have added a note to make it clear their figures date from 2005 http://jncc.defra.gov.uk/page-5848  . Some Biodiversity Action Plan pages are archived now and, depending how you access them on the internet, are available only in Welsh.

The Woodland Trust claim about 2% of the United Kingdom (couldn’t find a figure for England only)  is Ancient Woodland https://www.woodlandtrust.org.uk/about-us/ancient-woodland-restoration/  which would be 2% of 24249500 =  484,990 ha. Defra claim 36,129 ha of Lowland Meadow exists in England which would mean there was at least 13 times more Ancient Woodland than Lowland Meadow. The last BAP figures for Lowland Meadow were 7,282 ha in England which would mean 66 times more Ancient Woodland than Lowland Meadow. I think I’ve been cautious with my 10 times claim in the absence of clear figures on Ancient Woodland, or indeed Lowland Meadow.

My Local Nature Partnership ran a 3-year scrub-cutting project across 15 separately-owned LWS sites across the Tees Valley to help clear scrub from our ancient grasslands…sadly we couldn’t do all sites that needed it.

The MAGIC site is fab. and here http://www.natureonthemap.naturalengland.org.uk/MagicMap.aspx tick the habitats box and if you rootle around in there you can find the “Priority Habitat Inventory – Lowland Meadows (England)” box. SSSI sites are under the designations section. Scroll down and tick the box for aerial photos.

Last summer I did email the people who look after the MAGIC dataset and they are aware it has limitations; they have more data on paper than they can process. They sent me guidelines so that I could help them improve their dataset. At the time I was busy and as yet still have not replied. When I was younger I would have just done this in my own time; now I am far less inclined to cover-up government underfunding.

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