Off-Road Motorised Vehicles in the Cambrian Mountains

The Cambrian Mountains Pilot Project for Motorised Vehicles

The project is headed by "the Partnership", a small body which consists essentially of representatives of the Countyside Council for Wales plus the three County Councils (Powys, Ceredigion and Carmarthenshire). The Partnership may take advice from the Stakeholders who include representatives of the motoring lobby and farmers plus the Ramblers' Association, the British Horse Society and the Cambrian Mountains Society. From time to time, the Partnership also calls a meeting of the Forum, which is open to all; the main function here is dissemination of information.

One of the documents circulated to the Forum made clear the original objective of the Pilot Project:

"An opportunity has arisen for a strategic approach to be adopted [to the use of recreational vehicles in the Cambrian Mountains] through funding from the Countryside Council for Wales (CCW) … the primary objective is to identify a network of sustainable vehicular routes that could be promoted" (our bold type).

In the initial Forum meetings the motorised vehicle group identified some 600 km of route they would like to use within the Cambrian Mountains, and in subsequent meetings they made it clear that this was an under-statement of their real demands. Much of this was on Rights of Way currently designated as footpaths or bridleways. The Monks' Trod was included on their wish list as well as many other routes popular with walkers and horse-riders.

The Partnership employed consultants to investigate the suitability of the 600 km and they proposed the use of four criteria - natural heritage, archaeological/ built heritage, tranquillity and carrying capacity.

The Consultants delivered their report in August 2008; click here for details.

The society's detailed response to this report is given below:

Cambrian Mountains Motorised Recreational Vehicle Pilot Project Draft Report
Comments of the Cambrian Mountains Society

General

The Cambrian Mountains Society is a registered charity with over 300 members. It aims to secure greater recognition for the unique landscape, environment and heritage of the Cambrian Mountains so as to benefit both local people and visitors and simultaneously to strengthen the economy of the area by using the environment as a tool of economic growth. It believes that AONB status for the Cambrian Mountains would be a major step towards this end. We are broadly supportive of the wider Integrated Cambrian Mountains Initiative being pursued by WAG and CCW.

The Cambrian Mountains – once designated as a National Park, though not confirmed for political reasons – are recognised above all for their sense of tranquillity, remoteness and quality of wilderness. Within England and Wales, the area is unique in this respect as evidenced, for example, by light pollution maps. With careful planning, sustainable economic benefits can be built on this unique quality, and it is critical to avoid developments that conflict with it – they may attract some newcomers but they are likely to drive others away and, more important, destroy the potential for ever (note 1).

Not surprisingly then, we see the Pilot Project as a major threat to our vision of an economy driven by the environment. We see it as damaging not only to most residents but to all those others who value the increasingly rare resource of tranquillity. In our view it would have been difficult to pick a less suitable place for off-road vehicles in the whole of England and Wales.

More surprisingly, the proposals conflict not only with our own approach but with widely held views of government and others. The concept underlying the Report is identified as "a need to work towards the provision of motorised recreational use of the countryside" (para. 2.0.2), and the consultants were therefore expected to work within the brief "that a network of tracks appropriate for MRV use can be established" (para. 6.1.1). It is for the sponsors of the project rather than the consultant to justify this against the background of:

	the need to limit CO2 emissions because of global warming;
	the need to encourage physical activities in the countryside such as walking;
	the need for both these reasons to limit the use of motorised vehicles in the countryside as represented by government policy in the NERC Act of 2006;
	and the need to protect and enhance biodiversity.

We look forward to being given such a justification before any attempt is made to implement the proposals.

Despite our misgivings, we participated as stakeholders in the development of the proposal in the hope of convincing others of the misconceived nature of the Project. In this comment on the Draft (Consultation) Report we examine the report on its own terms.

Principle and Criteria

The consultant’s Overall Network Assessment (map 7N) confirmed our view that there was no realistic place for MRVs in the Cambrian Mountains. Of the whole 610 km of route on the wish list of the motorised lobby, only 5% (28 km) was found by the consultant to be suitable, and even much of this was in isolated short stretches that went no way at all to making up continuous usable routes. This was precisely what we had said and what we expected.

However, in the Draft Report as eventually produced for this consultation, the Potential Managed Network had become 173km including a number of long routes in remote and tranquil parts of the Cambrian Mountains. This was achieved only after the routes had been “strategically reassessed”, i.e., the original criteria were relaxed. This confirms our expectation that the requirements of the sponsors of this investigation could not be met even using the criteria they themselves had laid down. “Strategic reassessment” was in effect the only way of producing the result required by the brief.

One of the justifications for relaxation of the tranquillity criterion (para. 7.5.2) was “where those routes appear to have strategic value” [for MRVs]. There could hardly be a more explicit admission that “strategic value” of a route to MRV users weighed more heavily with the consultants (or their sponsors) than its value to those requiring tranquillity.

We now consider how reasonable even the original methodology and criteria were – in our view they were already flawed.

10.

Definition of Survey Network. This was done – we understand before the consultants were appointed – by asking the motorised lobby to indicate every route in the Project Area where they would like to go. No opportunity was given to other interests to have any input. (It appears however that the motorised lobby may have had an opportunity – not made known to other stakeholders – to have a further and later input since some new routes became part of the Potential Managed Network despite the fact that they were not part of the original Survey Network (note 2)).

11.

Visual Remoteness. The consultants originally proposed a criterion of Tranquillity (as has been used in similar studies in England (note 3)) but this was abandoned because no data were available for Wales and the consultants suggested that it was impossible within the time and financial constraints imposed on them to produce such data. They therefore devised the proxy variable of “Visual Remoteness” recognising that this was less than ideal. It was suggested in the Stakeholders’ meetings that, since so much depended on the outcome of the research, resources should be sought to permit tranquillity to be subjected to a thorough study. This was not done. We still believe it to be essential before any recommendations can receive serious consideration.

12.

Further points relating to tranquillity:

	The consultants note that “only the most remote parts of this…area have been identified as not being suitable for use” (para. 6.4.8), i.e., indicating (not for the only time) that the criterion has been applied in the way most beneficial to MRV users;
	It was made explicit by the consultants that the measure they used offers no indication of the absolute remoteness and tranquillity of the Cambrian Mountains as a whole – it only indicates tranquillity relative to other parts of the area. Thus, in effect, no account has been taken of what many see as the unique and distinguishing feature of the Cambrian Mountains – their absolute tranquillity.
	Implicit in the approach is a further problem: given that some MRVs are very noisy indeed, their use in moderately peaceful countryside extends the area which loses tranquillity and, pursuing the same argument ad infinitum, would justify allowing them going still further into the countryside with a continuous creeping loss of tranquillity. The Cambrian Mountains will not be preserved at all if they are subjected to a perpetual nibbling.
	Preserving the Cambrian Mountains as a tranquil area can reduce the country’s carbon footprint by diminishing the extent to which people fly abroad in search of peace.

13.

Archaeology. We note that no routes at all were excluded on archaeological grounds – a remarkable result. We understand that the Royal Commission on Ancient and Historical Monuments in Wales is engaged in continuing surveys of archaeological remains in the Project Area and that new techniques (including aerial surveys for instance) are continually revealing evidence of previously unknown remains. We are not clear whether the consultants held detailed discussions with the Royal Commission and other experts (e.g., at Lampeter University) on these issues. No decision on the opening up of new routes to MRVs should be made without such discussions and a clear indication from the relevant authorities that no serious damage can occur.

14.

We suggest also that in many cases, perhaps most, the routes themselves are historic features – drovers’ roads or miners’ tracks – and could themselves be listed as features to be preserved. This work needs to start urgently.

15.

Natural Features. We note:

	that the criteria for assessing the effect of MRVs on natural features (as described in para. 5.1.2) appear to be weaker than those used in other studies;
	that the assessment of natural features was undertaken by CCW who, as sponsors of the project, had a prior commitment to finding some way of making provision for MRVs. While we do not doubt the objectivity of CCW, this way of producing recommendations on such a controversial subject does not add to public confidence;
	that no mention is made of issues such as the critical importance of robust peat bogs as a means of controlling floods.

16.

Route Surface. It was assumed that the objective of MRV users was “a firm, dry and reasonably level surface, preferably not metalled…” (para. 3.2.4). Anyone using the countryside will have noted:

	that most MRV users appear to want – and do in fact make use of – routes much more demanding than this implies;
	where “firm and dry” routes exist they are serve mainly as a conduit to open countryside for MRVs engaging in illegal activities;
	that wherever “firm and dry” routes are provided they are likely to be used by all categories of motor vehicle, not just MRVs;
	that many “firm and dry” routes already exist – they are called roads – and their increasingly heavy use by motorised vehicles has already destroyed their one-time value as means of access to the countryside for all those who are not motorists.

17.

In relation to all the above criteria the consultants note that “all assessments have been based on vehicles remaining on the track” (para. 7.1.4). It is a common observation that this simply does not happen. Thus this small paragraph destroys at one stroke all the evidence on which the report’s recommendations are based.

18.

Criteria Not Used in the Report

	Current legal status of routes to be investigated. Because of the way that the Survey Network (see 9 above) was selected, much of it turned out to be on existing Rights of Way – often footpaths or bridleways. Such existing designations should have been a criterion which would have ensured that these routes were normally excluded (for reasons including health and safety).
	Uncertainty of legal rights. Many of the routes shown on the report’s map (7Bii) are shown as “legal status unknown”, and – perhaps for this reason – a large number of these are ones that subsequently appear as part of the Potential Managed Network. These routes of uncertain status seem to fall into one of two main categories (note 4): In neither of these cases then is there any reason to suppose that the uncertain legal status implies that they are or might be legally available to motorised vehicles.
	Inclusivity. By focusing exclusively on the needs of the motorised lobby, the study failed to consider other valid interests such as walkers, cyclists, horseriders, carriage drivers and those who are disabled. The motorised lobby were in effect singled out as being deserving of special treatment.
	Economic benefits. The Report claims that motoring tourism is “undoubtedly significant”, but admits that this is based on anecdotal evidence of Enduro events. Such events already take place and are subject to special arrangements that appear to have little relationship to this study. The fact is that economic benefits of MRVs were not included as a criterion to be used by the consultants and no evidence is adduced. There is however strong evidence on the economic benefits of, for instance, walking in the countryside (note 5), and specifically that what walkers value is precisely the tranquillity that the Cambrian Mountains offer – and which would be lost if there were a significant increase in MRVs.
	Prediction. The report provides no predictions of the effect that its recommendations might have on future usage. Given the signage etc. proposed there could well be a very large increase in motorised usage. Until plausible predictions are made neither the consultants, sponsors nor anyone else can say with confidence what the consequences might be.

Individual Routes

19.

It is not practicable to comment on each and every route included in Project, but there are some which stand out as demanding attention.

20.

Monks’ Trod. This unique linear ancient monument has been significantly damaged by MRVs over the years and has still not recovered despite the temporary protection it has recently been accorded. We welcome the fact that it is not included in the Potential Managed Network, and believe it is essential that it now be fully protected by banning MRVs on a permanent basis, by enforcing such a ban, and by protecting other routes in the vicinity so that the tranquillity of the Monks’ Trod can be permanently preserved.

21.

Cambrian Way. Known as the “Mountain Connoisseur’s Walk”, this is a long distance route from Cardiff to Conwy that has been in existence for many years (note 6) and certainly attracts overseas visitors as well as British. No account of the need to protect this route has been taken, several parts of it being included within the Potential Managed Network (784394 – 783402, 783408 -783419, 765758 -738762). These need to be removed from the Network.

22.

Hafod Estate. Many of the historic walks on this well-known estate associated with the name of Thomas Johnes and the picturesque movement have been restored in recent years by the Hafod Partnership (Hafod Trust and Forestry Commission Wales). The underlying objective of the whole project has been quiet and peaceful enjoyment and a continuous policy has been in force to exclude all but essential traffic. Only this year the efforts have led to an Award of the Georgian Society. The proposal to include a route through the estate as part of the Potential Managed Network is completely unacceptable.

23.

Even these few examples are sufficient to indicate that much more careful consideration of all the routes is necessary before proceeding further.

What Next?

24.

If this project is to be taken further we believe more work must be done before the recommendations could be imposed on the substantial sector of the community that is opposed to them. This would include all of the following:

Areas of work identified earlier, in particular a full study of tranquillity and of archaeological implications, and inclusion of the protection of existing footpaths and bridleways (with replacement routes wherever existing footpaths/bridleways and restricted byways are upgraded).

Provision, education and enforcement. The consultants refer to this “three pronged approach”, and state that they have only dealt with provision. We agree with the consultants that if further work is to be done in this area, the other two prongs deserve equally detailed treatment.

Management. The report identifies a “Potential Managed Network” of 173km. This raises a number of issues:

a.	What will be managed? If it is only the Network, then MRVs would in practice go illegally off the Network without hindrance. There should be an assurance that the whole of the Project Area would be managed and that any MRV which was off the Network – either on a route of some kind or just in the countryside – would be dealt with appropriately. (This would offer some assurance of protection for those existing routes and areas often used illegally but not included in the Network.)
b.	How will it be managed? What evidence is there from other regions of the success of management?
c.	What finance will be available for management (and upkeep) and who will provide it? Maintaining the routes themselves and enforcing legal usage only is likely to be an extremely expensive activity which would need special hypothecated Assembly funding.

Traffic Regulation Orders are proposed for some routes that have been illegally used in the past. It needs to be made clear that these are a formal part of the proposals, that they would be a permanent integrated part of the scheme and that they would they be enforced.

The stakeholders’ group should be expanded to include other strong interests not currently represented – above all, landowners (many of whom say they are unaware of the proposals) and others such as cyclists.

Legal Aspects. The report needs to address more fully the legal aspects of implementation.

Signage. We note the references to signage. We accept that if proposals such as those made in the report were to go ahead, then significant signage would be necessary. To us this presents yet another reason why the proposals are misconceived. To litter the Cambrian Mountains with signage would be to introduce precisely that urbanisation that people want to escape when they come.

Conclusion

25.

The survey has provided an opportunity to assess the two opposing views – on the one hand that there are opportunities for additional routes for MRVs in the Cambrian Mountains, and on the other that the Cambrian Mountains is no place for such activities. Because some may consider that further work is necessary before a decision can be reached, we have outlined in the previous section some areas of possible further investigation. However, this is not our preferred way forward. In our view any additional investigation can only add strength to the conclusion that this report has already demonstrated which is that the Cambrian Mountains is an unsuitable area for MRVs. Any other conclusion can only be reached by relaxing the original criteria, by ignoring other important criteria, and by assuming that vehicles will always remain on the track. We believe that the only sensible way forward is to abandon this proposal entirely.

Notes

We were pleased to note that the consultants appear to agree with much of this (paras 4.1.2 and 5.3.4) – “the remoteness of the Cambrian Mountains is therefore of national significance” – but that they fail to note that this significance will be lost if the report is implemented. Back

For example, east of the Arch (near Cwmystwyth). Back

LUC, Tranquillity Mapping in Cannock Chase AONB (2007) Back

These are:

Other Routes with Public Access. “ORPAs…are routes which are not shown on the Definitive Map… but which are recorded on the Highways Authority’s list of streets… Inclusion of a way on the list gives no guidance as to the nature of the rights that exist over it (other than that inclusion on the list does prove that at least a right of way on foot exists). Thus where a way appears on the list, evidence from other sources would be needed to establish the existence of a bridleway or vehicular rights.” All that the list of streets means is that they are “highways maintainable at public expense” (John Riddall and John Trevelyan, Rights of Way, fourth edition, 2007, pp 158 and 397).

Former RUPPs which had been reclassified by the old Dyfed County Council as Bridleways but which led to objections. It is believed that in most cases the objections were from landowners who believed the routes were footpaths rather than bridleways. In such cases there is no suggestion that they are or ever were open to motorised vehicles. Back

Wales Tourist Board and others. The importance of tranquillity to visitors is demonstrated by a random visitor survey amongst the 400,000 visitors per year visiting the Elan Estate: the main reasons for visiting were scenery and peace and quiet, followed by wildlife watching and walking. Back

A.J.Drake, Cambrian Way (2008) is now in its sixth edition. Back

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