191 Pages, Zero Gamekeepers: The Forest of Bowland's Draft Management Plan Fails its Own Landscape

The draft 2026–2031 Forest of Bowland National Landscape Management Plan is out for consultation. It closes on 2 March. At 191 pages across multiple documents, it represents a significant investment of time and public money. It also represents a significant missed opportunity — because the people who actually manage most of this landscape, the gamekeepers, appear to have been written out of it.

The Forest of Bowland is one of England's most important upland landscapes. Its character — the wide open moorland of the Bowland Fells, the blanket bog, the seasonal colour of heather — exists because it has been actively managed for generations. Gamekeepers are central to that management. They control predators, manage bracken, maintain tracks and drains, monitor wildlife and act as the first line of defence against wildfire.

In 191 pages of consultation documents, the word "gamekeeper" does not appear once. Not once.

This is a landscape where gamekeeping is one of the principal land management activities. Gamekeepers are the people who are out on these moors every day of the year. They know where the waders nest. They know where the peat is moving. They know where the bracken is advancing. And the plan that is supposed to guide the management of this landscape for the next five years has managed to pretend they don't exist.

This isn't an oversight. It's a choice. And it's a choice that undermines the plan's own stated ambition to be a "shared vision" developed through "partnership."

You cannot write a credible management plan for an upland landscape and airbrush out the people who manage it.

Buried in the plan are aspirations around species recovery, including for black grouse. This is welcome in principle — black grouse are an iconic upland species and any serious attempt to recover them in Bowland deserves support.

But there is a glaring omission. The plan talks about habitat. It does not talk about predator control.

Anyone with even a passing familiarity with black grouse ecology knows that habitat alone is not enough. You can create the finest mosaic of heather, bog myrtle and rough grassland in the country, but if you are not also managing foxes and corvids — legally and professionally — your black grouse chicks will be eaten before they fledge.

This is not theory. It is precisely what happened at RSPB Lake Vyrnwy in mid-Wales. The RSPB took over management of nearly 5,000 hectares of moorland that once supported healthy populations of black grouse, red grouse and breeding curlew. Decades later, the results speak for themselves. A peer-reviewed study found that predation by raptors accounted for almost two-thirds of black grouse deaths, and that recruitment was insufficient to balance mortality. Numbers collapsed. Curlew fell from 32 breeding pairs to just one possible nest. A local stakeholder forum warned that black grouse and merlin would cease to breed in the area entirely.

The lesson from Vyrnwy is brutally clear: you cannot recover ground-nesting birds without effective, sustained predator control. The Bowland plan proposes to try exactly that — aspiration without mechanism. If the drafters are serious about black grouse, they need to say so plainly: predator control is an essential component of species recovery in the uplands, and gamekeepers are the people who deliver it.

The plan has plenty to say about grassland. It has remarkably little to say about heather moorland — the habitat that defines the Bowland Fells and gives the landscape its most distinctive character.

The previous management plan (2014–19) described the Forest of Bowland as "internationally important for its heather moorland, blanket bog and rare birds." The 2023 Nature Recovery Plan similarly recognised heather moorland as a core habitat. Yet the new draft appears to have quietly downgraded it. The emphasis has shifted to peatland restoration and grassland, with heather moorland sliding into the background.

This matters because heather moorland is not just a landscape feature — it is a functioning ecosystem that supports red grouse, merlin, golden plover, short-eared owl and a host of invertebrates. It requires active management to maintain it. Without rotational burning or cutting, heather becomes leggy, loses its value as nesting habitat and is eventually replaced by grass, bracken or scrub.

A management plan for the Forest of Bowland that marginalises heather moorland is like a management plan for the Lake District that forgets about the lakes. Every serious plan needs a risk register — a clear-eyed assessment of what could go wrong, linked to specific actions that will be taken if it does. The Bowland plan has something it calls a risk register. In practice, it is word soup.

Take bracken. Bracken is one of the most serious threats to upland habitats in Bowland. It is spreading rapidly across moorland and in-bye land. It suppresses heather regeneration, increases tick burdens on ground-nesting birds, reduces grazing value and harbours sheep ticks that transmit Lyme disease. The 2023 Nature Recovery Plan acknowledged bracken as a significant and growing problem.

In the new management plan, bracken appears as a concern. But that concern is not linked to any specific action, target, timeline or responsible body. There is no stated objective for bracken control, no area target, no mechanism and no accountability. The risk is identified. The response is silence.

This pattern repeats across the risk register. Concerns are listed as though naming them were the same as addressing them. It isn't. A risk register without linked actions is not a risk register — it's a worry list.

As far as wildfire goes, it would seem that their plan is to create a plan. Wildfire is an increasingly serious threat to upland landscapes. The severe fires on Saddleworth Moor in 2018 and Winter Hill in the same year demonstrated the devastating consequences of uncontrolled burning on moorland with deep peat. Wildfire risk in upland areas is driven by the accumulation of fuel — rank, unmanaged vegetation — combined with drying conditions, and is expected to increase significantly under climate change projections.

The Bowland plan's approach to wildfire is, in essence, to ensure that estates have their own wildfire plans. That's it.

There is no landscape-scale wildfire risk assessment. There is no mapping of fuel loads. There is no assessment of which areas are most vulnerable. There is no coordinated prevention strategy — such as ensuring adequate heather management to break up fuel continuity. There is no analysis of water infrastructure, access routes or mutual aid arrangements. There is no discussion of the role that controlled burning plays in reducing wildfire risk, despite strong evidence that well-managed rotational burning creates firebreaks and reduces the severity of accidental fires.

Instead, the plan delegates wildfire to individual estates. This is the equivalent of a local authority's flood plan consisting of telling homeowners to buy sandbags. It is not a landscape-scale response to a landscape-scale risk.

The Moorland Association has recently published a new quality-assurance framework for assessing upland protected landscape management plans. Under that framework, a consultation-ready draft should be decision-useful, legally robust, deliverable, operationally realistic and co-designed.

Against those criteria, the Bowland draft has some way to go:

Decision-useful? The plan describes aspirations without providing the specifics needed to guide decisions on the ground. Outcomes are vague and lack measurable targets.

Legally robust? The plan does not demonstrate adequate regard for the statutory purposes of the designation, nor does it evidence compliance with Habitats Regulations Assessment or Strategic Environmental Assessment requirements.

Deliverable? Key delivery mechanisms — such as predator control for species recovery, or coordinated wildfire prevention — are either absent or delegated without accountability.

Operationally realistic? A plan that does not mention gamekeepers, does not address the practical requirements of species recovery and does not provide a credible wildfire strategy cannot be described as operationally realistic.

Co-designed? A plan that excludes the terminology, the roles and the expertise of one of the landscape's principal management professions has not been adequately co-designed.

The consultation closes on 2 March 2026. We would encourage anyone who lives, works or spends time in the Forest of Bowland to respond.

The plan can be found at www.forestofbowland.com/management-plan-2026.

In particular, we would urge respondents to make the following points:

• Recognise gamekeepers. They manage this landscape. They should be named, acknowledged and involved as partners — not written out of the plan.

  
  

• Be honest about predator control. If the plan is serious about recovering black grouse, curlew and other ground-nesting species, it must acknowledge that legal predator control is an essential part of the toolkit. The Vyrnwy experience shows what happens when you don't.

  
  

• Restore heather moorland to its proper place. This is one of the defining habitats of the Forest of Bowland. It needs active management, and the plan should say so clearly.

  
  

• Fix the risk register. Every identified risk should be linked to a specific action, a responsible lead, a timeline and a measure of success. A risk without an action is not a plan — it's a shrug.

  
  

• Take wildfire seriously. The plan needs a landscape-scale wildfire prevention and response strategy, not just a line about estate-level plans. That strategy should recognise the role of heather management in reducing fuel loads.

  
  

The Forest of Bowland is a magnificent landscape. It deserves a management plan that matches it. This draft, in its current form, does not. But the consultation process exists precisely so that it can be improved — and we will be making our views known.