Part II
ENGLISH NATURE'S RESPONSE TO THE ENVIRONMENTAL
AUDIT
SUB-COMMITTEE'S QUESTIONS
3. Q1 WHAT
IS THE
SCALE AND
IMPACT OF
WILDLIFE CRIME?
3.1 Introduction
Like other areas of crime there is uncertainty
about the overall scale and impact of wildlife crime. The compilation
of statistics is difficult and relies on infringements of the
legislation being reported and/or detected in the first instance.
English Nature believes that wildlife crime can be extremely threatening
for a few rare species and habitats and moderately threatening
for others.
3.2 Species: scale
3.2.1 Although we are not responsible for
enforcing species crime under Part I of the Wildlife & Countryside
Act and the Habitats Regulations, English Nature recognises that
there are several types of criminality affecting native species.
These include the illegal persecution of some wild birds, the
collection of birds' eggs and bulbs, such as bluebells, for either
personal use or commercial profit. Wildlife crime for certain
species such as bats and great crested newts is often associated
with development locations. In some cases it is likely that the
criminal activity is driven by a desire to save the costs associated
with considering the presence of protected species and providing
the required level of mitigation necessary to secure an appropriate
licence.
3.3 Species: impact
3.3.1 Through our work with the Partnership
Against Wildlife Crime (PAW) and other organisations, we have
identified species which are at significant risk from illegal
activities. Hen harriers and bats have been identified as species
which are significantly affected by wildlife crime and it is likely
that further species may be identified in the future.
3.3.2 The hen harrier is one of the few
species in England thought to be threatened with extinction as
a direct result of wildlife crime. English Nature's Hen Harrier
Recovery Project (HHRP) has monitored the hen harrier breeding
population in England during the last two years. Only seven successful
pairs were found in 2002 and eight successful pairs in 2003. Research
has indicated that there is sufficient upland moorland habitat
to support at least 230 pairs. The HHRP believes that illegal
persecution is the most important factor in limiting the hen harrier
breeding population. In the past two years birds have been shot,
nests and their contents destroyed, nest sites lost through the
inappropriate burning of heather, and nesting attempts have failed
because of illegal disturbance close to active nests. It is known
that hen harriers breed less successfully on moorland managed
for grouse shooting than on moorland managed with conservation
as the main priority. Hen harriers range over wide areas of countryside
and persecution appears to be sufficiently widespread to hold
the population at a dangerously low level despite the efforts
of conservation organisations.
3.3.3 Other organisations such as the Secretariat
of PAW, RSPB, Plantlife and the National Federation of Badgers
Group will be better placed to provide information regarding detailed
aspects of species related wildlife crime.
3.4 SSSI: scale
3.4.1 There are a wide range of habitats,
species and geological features that make up the SSSI series;
coupled with the innumerable activities which could potentially
cause damage, disturbance or destruction to SSSIs, along with
the often remote location and extensive nature of the sites, make
quantification very difficult.
3.4.2 However we now have a mandatory reporting
system and database for all reported offences under section 28.
This facility allows reports to be generated on the type of incidents
and offences and to identify issues and trends which we can then
focus on in a more pro-active and strategic way. We ensure that
our staff and others are vigilant and report all incidents that
they encounter, in this way we continue to build upon our information
base, monitor trends and respond accordingly in a focused way.
3.4.3 Since the introduction of the Countryside
& Rights of Way Act on 30 January 2001 to 23 April 2004, English
Nature has taken 235 separate enforcement actions: seven prosecutions
(four of which were under the amended provisions of the Wildlife
and Countryside Act and three under the Habitats Regulations[4]—see
Annex 2); two formal cautions; 25 formal investigations; 40 warning
letters from our solicitors; 161 warning letters from English
Nature staff.
3.4.4 We believe from incidents reported
that the illegal use of mechanically propelled vehicles (MPVs)
in the countryside (and within SSSIs) has increased. There is
strong circumstantial evidence to suggest that this is linked
to certain provisions introduced within the Countryside and Rights
of Way Act effectively opening up "lost" rights of way,
used in the past only by eg a horse and cart, but with rights
now lawfully established for use by MPVs. Consequentially, the
majority of users might be undertaking a lawful activity but the
opportunity for illegal off-road use is increased. Defra has recognised
some anomalies within the legislation and have consulted widely[5]
with a view to introduce new legislation which will make it no
longer possible to establish the existence of a byway open to
all traffic by reference to historic (pre-commencement) use by,
or other evidence relating to, non-mechanically propelled vehicles.
This move is welcomed.
3.5 SSSI: impact
3.5.1 The impact of any activity could result
in varying severity within sites of national or international
importance, impacts occurring in both the short and long term.
Some SSSIs may be the remaining stronghold for one particular
habitat or species. The most frequently reported illegal activities
that cause damage and disturbance to SSSIs are as a result of
dumping, vehicle activities and the removal of fauna and flora.
We can also report that during the period April 2003 to March
2004, the special interest features that are mainly being damaged
or disturbed as a result of illegal activities are grassland,
heathland, moorland and woodland.
3.5.2 For instance, the single activity
of ploughing a hay meadow grassland, a nationally and internationally
rare community, could result in that habitat being lost forever
on that SSSI and in a national and international context. In other
cases, it may be that one repetitive activity on a particular
area of land over a period of time, for example 10 people cycling
over the same piece of heathland for six months, causes the heathland
to be become bare. An area affected by damage or disturbance may
recover with appropriate management or restoration measures within
a short period of time, whereas other damage may take several
years to recover naturally, by simply being left alone but monitored.
3.5.3 Illegal vehicle use can subject the
flora and fauna of a SSSI to considerable damage, disturbance
or destruction by rutting and the widening of illegally established
tracks. There are reports of on-going damage from around England,
the activities being more prevalent within upland and coastal
sites and within Common land.
3.6 SSSI and species: effective reporting
of wildlife crime
3.6.1 We note that the majority of wildlife
crime offences not only in relation to SSSIs, which result in
cautions or prosecutions, are not classed as recordable offences
and thus are not recorded on any central system as crimes because
the governing legislation does not provide for this. We support
the PAW initiative to consider the scope for a UK wildlife incident
recording system and the possibility of certain wildlife offences
being formally recordable offences (as is currently possible for
some offences in Part I of the Wildlife & Countryside Act
1981), to give a more accurate overview of levels of offending,
to then identify trends, which in turn affects the deployment
of resources.
4. Q2 IS
THE FRAMEWORK
OF NATIONAL
AND EUROPEAN
LAW AND
OF INTERNATIONAL
REGULATION ROBUST
ENOUGH TO
DEAL WITH
WILDLIFE CRIME
EFFECTIVELY?
4.1 Species
4.1.1 Legislation has a key role to play
in preventing the release of non native invasive species. Invasive
non-native species are widely recognised as a major threat to
biodiversity, causing losses of native species and diluting the
distinctive character of native flora and faunas.
4.1.2 At present this legislation is ineffective
and extremely difficult to enforce and thus the legislative framework
preventing the release of non-native species needs to be amended
considerably. For example, anomalies currently exist with regard
to the legality of, and ability to control, the release, sale
and keeping of non native species in Great Britain. The most conspicuous
and problematic anomaly is the non-inclusion of plants (other
than the few specified in Schedule 9[6]).
Given this, and the significant import of large numbers of non-native
plant species, a statutory mechanism is urgently needed to regulate
these.
4.1.3 The Joint Nature Conservation Committee
(JNCC) agree with English Nature that there are currently insufficient
legal constraints and controls to address problematic non native
species. The legislative amendments are only one aspect of action
which is needed to address problematic non native species, such
measure need to be combined with both increased education and
the development of codes of conduct for all relevant sectors in
a participative fashion.
4.1.4 Non native species policy has been
the subject of a Defra working group and national consultation.
It is envisaged that a range of legislative amendments will be
addressed via the pending review of Part I of the Wildlife and
Countryside Act.
4.2 SSSIs
4.2.1 Broadly the legislation acts as a
deterrent to some and enables us to have a stronger, more robust
role in the enforcement of wildlife crime on SSSIs.
4.2.2 The introduction of the Countryside
and Rights of Way Act has given English Nature more powers than
were afforded under the Wildlife and Countryside Act 1981, in
relation to the protection and the enforcement of wildlife crime
on SSSIs. These include the power to regulate potentially damaging
activities affecting SSSIs; take enforcement action where compliance
breaks down or damage, disturbance and destruction of SSSIs occurs;
obtain and enforce restoration of SSSIs following a successful
prosecution; enter SSSI land where voluntary access is denied
to ascertain whether an offence has been or is being committed;
and raises the statutory level of fines that can be given for
these offences.
4.2.3 Prior to the Countryside and Rights
of Way Act, we were unable to enter SSSI land to ascertain whether
an offence was being, or had been, committed, (except in limited
circumstances where a Nature Conservation Order[7]
was in place). As such we were reliant on obtaining the permission
from the landowner of the site, which in cases where we were investigating
a potential criminal offence, was not always forthcoming. If voluntary
access was denied it proved difficult to collect evidence in relation
to an offence and therefore take any enforcement action.
4.2.4 The Countryside and Rights of Way
Act also brought in "triable either way"[8]
offences for certain provisions of the SSSI legislation. This
classification and the level of statutory fine is recognition
of the importance that Parliament puts on this type of environmental
crime. One of the problems previously under the Wildlife and Countryside
Act was the need to start legal proceedings within six months
of the damage occurring; damage to sites would often go undiscovered
for many months and this used to prevent prosecution. Although
we still aim to take enforcement action as soon as practicable
after the offence has occurred and usually within six months of
the report of the incident, the triable either way offences allows
a longer timescale to start legal proceedings following the offence
and avoids the circumstance whereby prosecution is precluded where
the damage is not immediately noticed.
4.2.5 Since its implementation we have used
the legislation to bring four successful prosecutions under section
28, in relation to damage and destruction of SSSIs, one of which
resulted in a record fine for this type of offence (£13,000[9]).
Additionally, in three[10]
of these cases we have successfully applied to the Court for a
Restoration Order to repair the damage caused to the special interest
features as a result of an offence being committed. The ability
to enforce restoration under this legislation is a powerful tool
and can make a real difference to the wildlife of special sites.
4.2.6 The Countryside and Rights of Way
Act has also created a new offence whereby any person, without
reasonable excuse, would be liable to a prosecution if they knowingly
damaged, disturbed or destroyed the special interest features
of a SSSI. This is another valuable tool in tackling wildlife
crime on SSSIs, since 109 of the offences (44% of total) which
were reported to English Nature's Enforcement Unit since January
2001 were as a result of the activities of third parties. We have
brought one prosecution[11]
under this provision, against a person who damaged a nationally
important grassland site by depositing spoil from an excavated
pond smothering an orchid population. Had this incident happened
under the previous legislation we would have probably been unable
to take any enforcement action.
4.2.7 It is, however, worth noting that
due to the nature of some activities carried out by third parties
(particularly the illegal use of MPVs), it is not always easy
to stop the alleged offenders and prove the elements of the offence
to the required standard. For example, by the nature of extensive
sites in the uplands it is difficult to prove that the alleged
offender knew the land was a SSSI and that they intentionally
or recklessly intended to damage or disturb the special interest.
Additionally, it is very difficult to "police" such
sites. English Nature has no powers to stop persons and demand
names and addresses and thus identify offenders. Therefore, unless
we can effectively engage and work with partners we are often
limited in the enforcement action we can take.
4.2.8 The Countryside and Rights of Way
Act extended our powers to make byelaws on SSSIs. Whilst we acknowledge
that byelaws can be a useful provision in controlling third party
activities, we face the same practical problems of "policing"
sites and activities. However, where appropriate we will not hesitate
to use them. We understand that Defra will be drawing up model
byelaws and we welcome being part of the consultation exercise.
4.2.9 Whilst neglect is not wildlife crime
per se, powers have been provided via management schemes
and notices to ensure that SSSIs do not suffer simply from a lack
of appropriate management where necessary voluntary management
is not forthcoming.
4.2.10 In summary, English Nature welcomes
the improved legislative powers. Our recent experience in implementing
this legislation has, however, highlighted areas that, in our
opinion, would benefit from the provision of further new legislative
powers or amendment of existing provisions. Such changes would
avert potential damage and disturbance and allow us as a prosecuting
authority to deal with enforcement cases more effectively and
efficiently.
4.2.11 The additional powers proposed are
akin to those currently available to other enforcement bodies,
such as the Environment Agency and Local Planning Authorities.
English Nature believes it would be helpful to have the following
powers to:
— stop people and vehicles within SSSIs
and request names and addresses;
— require restoration following damage
and disturbance to a SSSI, at the offender's own cost, when it
is not in the public interest to bring a prosecution;
— prevent activities being carried
out which are in contravention of the legislation;
— demand statements to enable enforcement
action to be taken and investigations to take place; and
— require information as to those persons
having an interest in SSSI land.
5. Q3 DO
RESPONSIBLE BODIES
WHO DEAL
WITH THIS
TYPE OF
CRIME HAVE
SUFFICIENT RESOURCES
AND POWERS
TO DO
SO? DO
THEY TREAT
WILDLIFE CRIME
WITH PROPER
AND DUE
GRAVITY?
5.1 Introduction
5.1.1 English Nature has resources to deal
with the majority of wildlife crime in an appropriate and effective
manner in our capacity as a prosecuting authority. However we
recognise that we cannot tackle some aspects of environmental
crime on SSSIs on our own eg in relation to activities by third
parties. This type of environmental crime can be tackled by working
with local communities, landowners, the general public and other
agencies such as the police and local authorities.
5.1.2 On the species side, the police sometimes
request certain levels of advice and assistance, that, due to
budgetary constraints we cannot always provide. This in turn might
reduce the effectiveness of enforcement action.
5.2 SSSI: resources
5.2.1 As we have mentioned earlier, we work
with 32,000 owners and occupiers and this requires a relationship
management role to achieve legislative compliance and protection
of SSSIs. This positioning is important to us, as is the need
for the long term management and protection of SSSIs. We consider
that we are a firm but fair regulator in relation to our enforcement
role and will use enforcement powers where appropriate in relation
to offences on SSSIs. We believe that the resources we invest
with those responsible for managing SSSIs should repay gains in
protecting SSSIs and therefore reducing wildlife crime offences
(at source) and the need to pursue enforcement action.
5.2.2 We are reassured by the fact that
we have had to use our enforcement powers on very few occasions
within the 4,111 SSSIs. Since 31 January 2001, we have dealt with
115 reported enforcement cases (46% of offences) involving SSSI
owners and occupiers. We have taken three prosecutions against
owners/occupiers of SSSIs under the new legislative provisions.
We do not see this as a failure to use our enforcement powers,
but of having a successful positive partnership with the majority
of our customers.
5.2.3 We cannot realistically hope to enjoy
the same relationship with those people who neither own nor occupy
SSSI land but who commit offences within them (third parties).
Although we will use our enforcement powers in such circumstances
where we have the necessary evidence and it is in the public interest
to do so, this type of activity has resource implications for
the organisation. On our own we cannot "police" SSSIs
throughout England, therefore we look to work in partnership with
others, mainly the police, to assist us in the prevention and
detection of this criminal activity. We are in the process of
establishing pilot projects in three police regions, primarily
aimed at tackling illegal MPV use within SSSIs.
5.2.4 We believe that pro-active enforcement
action also plays a beneficial and positive role in raising awareness
and educating others in relation to this type of wildlife crime.
A good example was a "motorcycle awareness day" aimed
at scrambling enthusiasts, organised by a local authority with
input from the police, English Nature, local scrambling clubs
and bike dealers. The event was organised to promote safe and
legal motorcycling.
5.3 SSSI: powers
5.3.1 As stated in our response to question
2, whilst we now have the legislation to protect and enhance SSSIs,
we have highlighted some areas of the legislation that would in
our opinion benefit from amendment, or provision of new powers,
to reflect the problems we have come across in dealing with enforcement
on SSSIs.
5.4 SSSI: principles
5.4.1 As a prosecuting authority we are
guided by the Code for Crown Prosecutors, Home Office guidelines
relating to cautioning and the Police and Criminal Evidence Act.
English Nature staff deal with enforcement cases using internal
guidance giving details of the action to be taken in relation
to the varying degrees of damage or disturbance to SSSIs and continual
non-compliance. A dedicated Enforcement and Protection Unit will
progress and manage high level enforcement cases and is always
on-hand to provide general advice and guidance. We have clear
and strict controls and levels of delegation on the use of enforcement
options and how our staff are expected to use them in relation
to the gravity of the offence committed.
5.4.2 It should be noted that we will imminently
be publishing our public policy statement on enforcement.
5.4.3 The importance that we put on our
enforcement role is demonstrated by the following principles and
considerations that we take account of in any enforcement case:
— investigate all reported incidents
of damage or disturbance to SSSIs fairly and quickly;
— judge all cases individually but
consistently;
— have a balanced approach in deciding
the level of enforcement action against the nature and seriousness
of the offence, the attitude of the person responsible and the
damage or disturbance to the SSSI, in a local, national and international
context;
— take account of any mitigating factors
relating to the case;
— be open when dealing with all enforcement
cases, decisions made and action taken;
— create an understanding of the legislation
and responsibilities, and clearly explain this and any restoration
needed;
— where damage is being caused by other
people, work closely with owners and land managers of those SSSIs
to decide the most appropriate course of action to take;
— work with and support other enforcement
agencies to encourage the use of appropriate powers to tackle
environmental crime; and
— in all cases, consider the overall
benefits to nature conservation.
5.5 SSSI: enforcement options
5.5.1 As with other prosecuting authorities
we use a range of enforcement options to deal with offences on
SSSIs. Depending on the circumstances of the incident, we may
use one or more enforcement options at the appropriate time during
different stages of the case.
Prosecution
We have a discretionary power, not a duty, to
prosecute for offences relating to SSSIs. We will only prosecute
where the evidential and public interest tests are met. For example,
a recent prosecution[12]
was taken against a SSSI occupier who had committed an offence
by not obtaining English Nature's consent for causing works to
be carried out on that site which resulted in significant damage
to nationally rare plant species. If we prosecute, we will always
try to recover the costs of the formal investigation and legal
proceedings.
Caution
In cases where we are of the opinion that a
prosecution is not appropriate but a high level of enforcement
action should be taken, we will then consider a caution. We will
only consider a caution where the necessary evidence we have collected
from the formal investigation shows that there is a realistic
chance of conviction.
Formal investigations
In certain circumstances, for example where
the level of damage is significant or where continual non-compliance
with the legislation occurs despite previous enforcement warnings,
we may decide that a formal investigation is appropriate to ascertain
the full facts of the case. Following a legal assessment of the
case we will then decide whether we have the necessary evidence
to pursue the matter with a higher level of enforcement action
and whether it is in the public interest to do so.
Letters (solicitor, Director, Enforcement Unit, Area
Team)
If we send an enforcement warning letter we
may ask those responsible to agree that the unauthorised activities
will stop and restoration work will be carried out. We will take
account of any co-operation when deciding on the appropriate action
to take. However, those responsible will not avoid eg prosecution,
just because they have carried out, or offered to carry out, restoration
work.
Civil mechanisms
In certain limited circumstances, the only option
to prevent damage, disturbance or destruction to SSSIs is for
English Nature to commence civil proceedings eg injunctions or
possession orders. We will only commence these proceedings after
voluntary co-operation or other enforcement methods have been
explored and there is still a serious threat to the SSSI.
6. Q4 IS
THERE SUFFICIENT
DIALOGUE AND
CO-OPERATION
ACROSS GOVERNMENT
AND AMONGST
THE VARIOUS
BODIES RESPONSIBLE
FOR DEALING
WITH THIS
TYPE OF
CRIME?
6.1 SSSI and species
6.1.1 From a historic perspective we consider
that co-operation and dialogue has not been that good in dealing
with the prevention, detection and enforcement of wildlife crime.
However, there is now established dialogue with some bodies, such
as the police, which is a positive move to achieve co-operation
and to benefit nature conservation.
6.1.2 Although we feel that there are areas,
probably more at local level currently, where this co-operation
is happening, we also feel that there is benefit in taking a more
strategic view of this nationally. This would identify areas of
best practice which can be used as a model and also identify where
we can encourage more partnership working to tackle wildlife crime.
6.1.3 Up to 60% of SSSI land is owned or
managed by Government or by other public bodies, or by private
companies that have statutory conservation responsibilities. Parliament
greatly strengthened the environmental obligations on these bodies
through the Countryside and Rights of Way Act. English Nature
advises these bodies, as we do with other owners and occupiers,
on their responsibilities to hopefully avoid instances of damage
and disturbance to SSSIs and the need to pursue criminal prosecutions
and penalties. We also expect that these bodies who are responsible
for regulating and enforcing legislation affecting SSSIs and species
should consider their obligations and powers to benefit nature
conservation.
6.1.4 As mentioned before, illegal activities
undertaken within SSSIs might also be in contravention of other
legislation, such as the Road Traffic Act, Land Drainage Act or
planning legislation. Where these incidents affect SSSIs, we recognise
the benefit of engagement and co-operation with other enforcement
bodies, such as the police, Environment Agency and Local Planning
Authorities, to decide upon the most appropriate and effective
legislation and enforcement action to take to benefit nature conservation.
For example other bodies may have the legislative powers to be
able to secure restoration of the SSSI, unlike ourselves, who
would have to successfully prosecute and apply to the Court for
a restoration order to ensure that the restoration work to the
SSSI was undertaken and enforceable.
6.1.5 In a recent incident of damage to
a SSSI, which was in breach of both the Wildlife and Countryside
Act and the Land Drainage Act, both English Nature and the Environment
Agency brought prosecutions[13]
at the same time under the respective legislation. It is hoped
that by bringing joint enforcement action such as this, it demonstrates
the seriousness in which these offences are held, by those enforcing
the legislation.
6.1.6 At a national level we have already
met with the representative of both the Association of Chief Police
Officers and PAW. We have made a commitment to work with both
the police and PAW on their conservation objectives as they apply
to England. This includes the persecution of hen harriers; unlawful
development and its implications for bats; SSSI habitat protection,
in particular the problems associated with third party off-roading
activities; illegal dumping of motor vehicles and illegal burning.
6.1.7 Following the identification of the
hen harrier as a priority for action, there has been good co-operation
between the various statutory and voluntary bodies involved in
the monitoring of the populations and those with responsibility
for tackling illegal persecution. The police launched "Operation
Artemis" this year which is a high profile project to try
to tackle the illegal persecution of hen harriers, which we welcome.
English Nature and voluntary organisations such as the RSPB and
Raptor Study Groups have invested considerable resources into
gathering information and identifying the factors limiting hen
harriers.
6.1.8 English Nature is producing a "toolkit"
for the police forces to use which will detail: offences under
the Wildlife & Countryside Act 1981 as they apply to both
species and SSSIs; provide warning letters to give to offenders;
information notices to be used on site and recording forms to
enable information to be put on our database of third party vehicle
activity. In some areas of the country English Nature already
benefits from working with the police, in particular in tackling
illegal off-roading activities. In some cases this has resulted
in joint operations on SSSIs where the police have taken enforcement
action under the Road Traffic Act. We are also actively establishing
pilot projects where both bodies can work together at either force
or regional level on both species and SSSI offences.
6.1.9 Whilst we appreciate that the judiciary
do not come across this type of offence on a regular basis we
have been pleased with the sentences that the Courts have given
to the three prosecution cases that we have taken under the new
legislation in relation to damage to SSSIs (the fourth is awaiting
sentence[14]).
6.1.10 We are currently working with the
Magistrates Association to have input into their revision of the
"Costing the Earth" toolkit to include information on
the Wildlife & Countryside legislation as it applies to offences
on SSSIs, which we hope will raise the awareness amongst Magistrates
of this type of wildlife crime.
6.1.11 Given the infrequent number of these
types of cases we are conscious of the need to present the Court
with detailed information on the scientific interest of the SSSI
and the gravity and impact that the offence has caused on the
habitat in a local, national and international context (if applicable).
Where appropriate we will always submit to the Court an application
for a restoration order, which if granted, will put in place appropriate
measures to ensure that the area damaged or disturbed would be
restored. We will also make the Court aware of any financial gain
that we believe the offender has accrued or appears likely to
accrue as a consequence of the offence.
4 Prosecutions under Regulation 23 of the Habitats
Regulations for offences under Special Nature Conservation Orders. Back
5
"Use of mechanically propelled vehicles on Rights of Way"
Defra 2003. Back
6
Wildlife and Countryside Act 1981 (as amended). Back
7
Nature Conservation Orders were made under section 29 of the
Wildlife and Countryside Act 1981 and subsequently repealed by
the Countryside and Rights of Way Act 2000. Back
8
offences that can be heard at either the Magistrates or Crown
Court. Back
9
English Nature v Ennstone Breedon Ltd February 2004 (River Camel
Valley and Tributaries SSSI, Cornwall). Back
10
Awaiting Courts consideration and decision on application of
a Restoration Order in English Nature v Hall April 2004 (River
Camel Valley and Tributaries SSSI, Cornwall). Back
11
English Nature v Wickens 2003 (Sutton Lane Meadows SSSI,
Wiltshire). Back
12
English Nature v Gold 2005 Ltd December 2003 (West Cornwall
Bryophytes SSSI, Cornwall). Back
13
English Nature v Hall April 2004 (River Camel Valley and
Tributaries SSSI, Cornwall). Back
14
English Nature v Hall April 2004 (River Camel Valley and
Tributaries SSSI, Cornwall). Guilty plea made before the Court
on 21 April 2004 and adjourned for sentencing on the 6 May 2004. Back
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