Sam Kilday, Author at Wild Justice

Waking the Dragon -A community fighting to protect Ceibwr Bay

8th July 2025 8:11 pm Comments Off

Protecting Ceibwr – by Gill Lewis, with the help and contributions from many residents of the community of Moylgrove and Ceibwr.

To any visitor to North Pembrokeshire, Moylgrove appears to be a sleepy coastal village, nestling in a wooded valley that runs down to the rocky inlet of Ceibwr Bay. However, despite its bucolic slumbering charm, Moylgrove has a thriving community of residents who are welcoming to the many visitors who come to enjoy the remote wild beauty, yet fiercely proud and protective of the wildlife we are privileged to have here.

For over a decade, the community has been raising concerns about increasing commercial adventure tourism, in particular coasteering, disturbing the wildlife, damaging delicate ecosystems and detracting from visitors’ enjoyment of the remote, tranquil and wild character of the area.

Many residents feel that our collective voice to protect the wildlife has not been heard. Our fears were confirmed when, despite substantial objections from the community, Pembrokeshire Coastal National Park Authority approved planning for an adventure centre for Moylgrove, set to expand the exploitation of the bay with coasteering and other water-based activities. We reached out to Wild Justice, who use the legal system to get a better deal for wildlife. Wild Justice considered that the planning decision could be flawed and has launched a judicial review which will be heard on the 18^th and 19^th June 2025 at Haverfordwest.

The majority of residents in our community believe that Pembrokeshire Coastal National Park Authority (PCNPA), Natural Resources Wales (NRW), Pembrokeshire County Council (PCC) and the National Trust have prioritised commercial exploitation over nature recovery at Ceibwr and disregarded valid community concerns. They have underestimated this community’s fierce determination to defend Ceibwr Bay, a wild and beautiful place on this far west tip of Wales.

The authorities have poked a Welsh dragon, and now they are feeling the heat of its fire.

This blog will try to explain how our fight to save Ceibwr Bay has arisen.

Ceibwr Bay

Ceibwr Bay is an SSSI and forms part of the Cardigan Bay Special Area of Conservation and the Pembrokeshire Marine Special Area of Conservation and the West Wales Marine SAC. The cliffs are home to nesting razorbill, guillemot, fulmar, herring gull, chough and kestrel. The bay and nearby sea caves are recognised pupping areas for the grey seal, and the foreshore has rockpools teeming with life and a rare biogenic honeycomb reef. A kelp forest reaches out from the lower foreshore into the Irish Sea. Otters frequent the bay. Its character is recognised for being a remote, tranquil and wild part of the coastline.

However, we believe an accumulation of failures from authorities and responsible bodies have brought humans too close to wildlife, causing disturbance and damage to delicate ecosystems.

Coasteering at Ceibwr

Coasteering is a popular thrill-seeking adventure activity defined as ‘movement along the coastline on foot or by swimming.’ Coasteering routes along the Pembrokeshire coastline are drawn up by activity providers and agreed by Pembrokeshire Coastal Forum and the National Trust, who permit access across their land to commercial adventure providers. This agreement is provided in the form of confidential document called the coasteering concordat. From what we understand to be true, no Environmental Impact Assessments have ever been undertaken for the agreed routes.

At Ceibwr, agreed routes have been permitted directly below seabirds on nesting sites recognised by the National Trust, and across and near to seal pupping sites, causing confirmed disturbances.

The National Trust owns a small piece of land at Ceibwr. Adjacent landowners have denied access to commercial adventure providers because they consider that coasteering is damaging the integrity of the SSSI which they have a legal responsibility to protect. Coasteering involves jumps above the mean high tide, and consequently, the agreed routes have facilitated and allowed trespass on neighbouring private land. The relationship between private landowners at Ceibwr and PCF has been fractious at times, with PCF previously insisting that private landowners prove ownership of their land.

For over a decade, the community has been opposing coasteering at Ceibwr, as documented by the minutes of community committee meetings.

The minutes report;

Regular disturbance to wildlife,
Repeated trespass on private land.
Lack of restriction of numbers of coasteerers.
Parking problems preventing other visitors to enjoy Ceibwr.
Absence of any official monitoring.
Escalating abuse to the community from the adventure sector.
Lack of any apparent enforcement by the National Trust and the authorities to evidenced reports of disturbance, trespass and disregard for the community.

Pembrokeshire Marine Code of Conduct (PMCC)

We feel that one of the major contributing factors to the situation at Ceibwr has been underpinned by the use of the PMCC, which is weaker than other voluntary marine codes of conduct for other regions of the UK, and advice given by DEFRA and RSPCA which all state to keep a minimum distance of 100m from seabirds, seals and cetaceans.

Photo – coasteering onto Carreg Wylan, a nesting site in May 2024 – where an oystercatcher chick was almost stepped upon. Coasteering continues here in 2025 during nesting season less than 20m from nesting birds.

The Pembrokeshire Marine Code of Conduct has been developed as a compromise between conservation stakeholders and the adventure sector, with one conservation charity stating that there was “opposition from some outdoor providers” to extending the distance guidelines.

It raises the question – Is there a conflict of interest if adventure providers who have commercial interest in utilising the coast, are allowed to be part of the decision-making process about the construction of the PMCC?

Pembrokeshire Coastal Forum explains their differing approach to the lesser distances. “This focus on distances means that disturbance reactions become the focus, encouraging a more reactive approach to interacting with wildlife.”

However, we believe this approach is flawed, because it focuses upon the causation of disturbance, which by definition triggers a stress response, potentially losing that animal chances to rest, feed or breed. We should not be encouraging ‘interacting with wildlife,’ but avoiding interacting with it. Prevention of disturbance reactions should be the focus.

Photo – May 2024 – coasteering group in close proximity to razorbill nesting site. All but one razorbill left their nesting sites during this disturbance. Photo – Gill Lewis

If the Ceredigion Marine Code had been applied, as we believe it should with Ceibwr being within the Cardigan Bay SAC, then wildlife would have been protected by the 100m zone, and it is likely that coasteering would never have been permitted at Ceibwr.

The Adventure Hub

In February 2024 Pembrokeshire County Council awarded a Shared Prosperity Fund grant for an adventure hub in Moylgrove. From the outset this has been mired in local controversy. There was no prior official consultation with the local residents, community council, neighbouring landowners including the National Trust, nor any competent authority on the environmental impact that the project may have.

A planning application for the adventure hub was submitted and there were strong objections from the community, local community council, wildlife experts, conservationists and from both the Environmental Law Foundation and Wild Justice. The National Trust did not comment despite the fact that coasteering would be permitted via their land.

A Habitats Regulation Assessment (HRA) was only undertaken at the behest of the Environmental Law Foundation who said Pembrokeshire Coastal National Park Authority could leave itself open to legal challenge if one was not undertaken. A HRA was produced by the PCNPA ecologist. The community had concerns over the content and validity, and asked Wild Justice if they would know someone with experience who could take a look. Wild Justice sought advice, and it was advised that the HRA could be unlawful.

Despite the many community objections to the planning application, which were ‘substantial’ enough in number to have been potentially regarded as material considerations, the planning officer advised the planning committee that the substantial community objections should only be given ‘limited weight’.

The planning application for the adventure hub was approved by committee on the 16^th October 2024.

Lawyers at Leigh Day, working on behalf of Wild Justice, considered that the planning process was potentially unlawful and have been granted permission to challenge Pembrokeshire Coastal National Park Authority in a judicial review on five grounds.

Wild Justice, Leigh Day and community members with seal and razorbill at Cardiff courts to hear that five grounds were granted for the judicial review. Photo – Môr Ffoto

Evidence vs Anecdotes

Undeniably nature is in crisis, with Wales being cited as one of the most nature depleted countries on earth. There is a need for sound science to inform policy and decision making to ensure we can reach the targets set by the Welsh Government to protect 30% of land and sea for biodiversity by 2030. But our community feels that the evidence of disturbances has been ignored, and the science misinterpreted by the authorities to suggest a narrative that diminishes the impact of coasteering on wildlife at Ceibwr.

The looming plans for the adventure hub instigated residents to secure definitive video evidence of disturbances of seabirds by coasteering activities directly below nesting razorbills in April and May 2024.

These videos were sent to Dr Rob Thomas, an expert in seabirds and seabird behaviour. Dr Thomas wrote a statement which confirmed the disturbances to razorbills and that these could reduce breeding success.

The videos were sent to Natural Resources Wales, but NRW failed to respond, despite repeated requests to do so. Neither the videos of confirmed disturbances, nor Dr Rob Thomas’ statement were acknowledged by NRW, PCF or the National Trust. The planning officer at Pembrokeshire Coastal National Park Authority dismissed the statement in the objection as ‘informal’.

Natural Resources Wales did respond to community concerns by commissioning a 2024 bird survey to ascertain the impact of coasteering on the breeding success of razorbills and guillemots at Ceibwr. Whilst the baseline data for these birds is welcome, we felt the cost of the study could have been avoided if the standard 100m distances from nesting birds had been applied, and if regard had been given to the currently available scientific studies that show human presence in close proximity to these birds reduces breeding success.

NRW produced a Position Statement for the 2024 Bird Report which we feel misinterpreted the results and diminished the potential impact of disturbances. Perhaps more concerning was the reliance on ‘several anecdotes’ which have been used and quoted as evidence to suggest (incorrectly) that there was minimal disturbance at Ceibwr and that the birds arrived after the advent of coasteering.

In response to Wild Justice’s and a local seal expert’s objection to the hub, the PCNPA ecologist tried to justify individual disturbances of seals and said they could be paradoxically beneficial if people learn about nature during these activities.

We believe that disturbance to individual seals sets a bad example to members of the public, causes animal suffering and may inadvertently lead people to break the law. There is growing scientific evidence to show the detrimental long-term widespread impacts of individual seal disturbances upon populations.

Grey seal pup at Ceibwr (LHS) and approaching coasteering group (in water) that came onto the beach. Seal pups often tuck themselves away among the rocks waiting for their mothers to come and feed them. Missing a feed could mean life or death for a young pup. Coasteering groups regularly use this side of the bay during pupping season.

Photo – screenshot from a video taken by Graham Young September 2024

Ceibwr Bay, the National Trust and Wynford Vaughan Thomas

In the late 1970s, Wynford Vaughan Thomas, a leading figure in Welsh broadcasting and Welsh cultural heritage, gifted land at Ceibwr to the National Trust to be kept in trust.

In his book Wales, Wynford Vaughan Thomas writes;

“I am certain that the landscape of Wales really is as splendid as I have maintained it is. Not all of it I regret to say, for many Welshmen themselves treat the legacy of beauty we have received from the past, as if it can be easily exploited for the profit of the present. They ignore the condemnation of the future.”

What would Wynford Vaughan Thomas have thought about commercial adventure tourism at Ceibwr? Would he have approved of people hollering and leaping from cliffs directly below nesting seabirds and trudging on the foreshore within ten metres of young seal pups? The National Trust and the Pembrokeshire Coastal National Park Authority, both say they promote their ‘access for everyone’ policies as one of the reasons to support commercial adventure tourism. But would Wynford Vaughan Thomas have considered that ‘Access for Everyone’ means access for all, for everywhere? Or would he have disapproved?

Would he, like many in our community, have regarded coasteering at Ceibwr as profit of the present, ignoring the condemnation of local communities, conservationists, wildlife experts, environmental lawyers and future generations?

The Future of Ceibwr

We believe that adventure tourism does have a place in Pembrokeshire and is important to the economy, but that the current model of self-regulation is unsustainable and needs to be addressed. We feel that the authorities have prioritised commercial exploitation over nature recovery, and that for many years we have been fighting a losing battle to protect the wildlife at Ceibwr. As the adventure sector pushes out into ever more remote, previously inaccessible coves and beaches, there may be no safe places left for wildlife.

We sincerely hope that Wild Justice wins this judicial review, not only for the wildlife at Ceibwr Bay, but for wildlife across Pembrokeshire. Change needs to happen to align the commercial adventure industry with nature recovery. We believe the adventure sector has held too much sway in the decision-making processes. The conservation sector and wildlife scientists need to take the lead with regard to marine codes of conduct, coasteering routes and carrying capacity of sites. We need NRW to step up to ensure these protected sites are truly protected and do not exist only as paper-parks. There needs to be greater education for all outdoor providers with regard to awareness around wildlife. We believe that licensing must be considered to ensure safety for the public and protection for wildlife and communities.

More sites must have restricted access where wildlife can remain truly undisturbed if we are to reach the promised 30 by 30 targets. If Ceibwr, a triple SAC and SSSI, is not protected from disturbance and damage from commercial adventure tourism, then where else will be safe?

We believe that the Sandford Principle, which is enshrined in law, must be applied to Ceibwr where the purpose of commercial adventure tourism is in direct conflict with conservation of nature.

“If it appears that there is a conflict between those purposes, the National Park Authority must attach greater weight to the purpose of conservation and enhancing the natural beauty, wildlife and cultural heritage of the area.”

Communities like ours are the guardians of these last wild places. We will not rest until Ceibwr is added to the agreed restricted access areas to ensure it is protected for the wildlife, for the many visitors who come to appreciate the remote wild beauty, and for the future generations who deserve a chance to see it.

Our Pembrokeshire case in the courts

8:10 pm Comments Off

Members of the local community from Moylgrove attending court

Community thoughts on the Judicial Review of the Pembrokeshire Coastal National Park Authority (PCNPA) planning decision to approve an outdoor activity adventure hub at Moylgrove.

By Gill Lewis and Dagmarr Moore

This judicial review has been a milestone date in the diary for the majority of the residents of Moylgrove. Our community has been raising concerns for over a decade about the detrimental impact that coasteering is having upon the integrity of this Special Area of Conservation and SSSI. We felt that our voices were not being heard, and we were thrilled that Wild Justice joined our fight and sought a judicial review of the planning decision for the adventure hub.

Many of us had not experienced a courtroom and were a little surprised to have to form a long orderly queue to have our bags checked airport-style, even having to surrender make-up mirrors and toothpaste to the security guard. It was good that some residents could join online, as those of us present filled the seats in the courtroom. It was also great to have the support of the community council and a local wildlife expert.

We were incredibly grateful to Dr Mark Avery and Lucy Lapwing from Wild Justice, and the legal team from Leigh Day for making the long trip to Haverfordwest. We hope they had some time to enjoy the sea and the sunshine. We felt truly privileged and humbled to have David Wolfe KC, one of the UK’s leading barristers, fighting our corner. We were in awe of his ability to have all the facts at his fingertips and to argue the case and points of law with such clarity and depth. Together with his colleague barrister Barney McCay, they worked at lightning speed with meticulous attention to detail, juggling files, documents and arguments. Post-it notes flew between them – thoughts flying from one brilliant mind to another.

Whilst the Judicial Review was argued on points of lawfulness of the planning decision in October 2024, everyone in the community was very aware that the mitigating measures referred to in the Habitats Regulations Assessment have not been implemented prior to the planning decision, as there have been multiple incidents of trespass, wildlife disturbance and disrespect to the community by the adventure sector in the past. The mitigating measures also appear not to be working for this current 2025 season, and we understand that an adventure provider is not even signed up to the secret concordat yet continues to cross National Trust land to gain access to coasteer and trespass knowingly on private land and designated nesting sites, breaching the Pembrokeshire Marine Code of Conduct and causing disturbance to birds.

The group representing the community (Cymdeithas Trewyddel) met with PCNP, NRW, National Trust and Pembrokeshire Coastal Forum in March 2025 and were shown a proposed site guide for coasteering at Ceibwr. We were very concerned to see differing and shorter nesting dates for given for Ceibwr compared the National Trust and PCNP guidance, which would allow coasteering in the Easter and Summer school holidays. Also worrying were agreed routes permitted all year on designated nesting sites and seal pupping sites. We have asked to know the relevant expertise of the authors involved in creating these site guides for all of Pembrokeshire, and if any environmental impact assessments have been undertaken, but have received no response as yet.

We await the decision of the Judicial Review with apprehension, as Ceibwr provides a litmus test. We believe the authorities have been failing the wildlife at Ceibwr. But will the points of law be sufficient to protect this bay, a triple SAC and SSSI? The outcome could determine the protection of all sites across Pembrokeshire, Wales and nationally. To ensure we protect and enhance biodiversity in Wales and reach the 30×30 targets set by government, this is not a fight we can afford to lose.

Read a blog summarising the background of this case, written by Gill Lewis, here.

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Waking the Dragon -A community fighting to protect Ceibwr Bay

Our Pembrokeshire case in the courts