Stitching up the Minister

The 6-week process of consultation on heather and grass burning, launched by Mary Creagh in her role as DEFRA minister, has the appearance of a foregone conclusion or, to be even blunter, a stitch up – although not necessarily in the way it first appears.

The moorland community had been meeting with officials to discuss the workings of the existing code without any suggestion of what was to come. In fact, nothing was said by officials at their last meeting in Birmingham just a few days before the floodgates opened. Then without warning, the community that owns and manages hundreds of thousands hectares of the English uplands – including countless designated sites – and who believed they were taking part in a honest discussion about how to improve the management of the land, found that they had been treated as irrelevant.

Important decisions need careful consideration

A 332-page review of of managed burning, a 43-page definition of blanket bog favourable status, and a 62-page definition of heath-favourable status were all published within days.  These accompanied the launch of a consultation period so brief as to be derisory, and were followed  by the publication of a supposedly 'definitive'-= map of English peatlands.

The plan is that, faced with this mass of dense, technical, and massively referenced paper, no one will be able to argue coherently against the central plan which is to effectively end the use of cool rotational burning as a management tool in the English uplands, and extend Natural England's control over most of the moorland landscape of England.

It is likely that it will succeed. When this was last attempted by largely the same people, the Minister took advice and decided that the banning of burning would only relate to areas where peat was over 40cm deep, and on a designated site. Even then a licence could be obtained to prevent wildfire. It is unlikely that will happen again.

Mary Creagh would have to be very brave to resist this carefully constructed plot. Why should she go out on a limb for a few backwoodsmen? The reason is that there is more in this than meets the eye – although the obvious bits are bad enough. Let's start with them.

Why is wildfire of such little interest?

Wildfire is the elephant in the room. Ironically the plot could not have been triggered at a worse time. At the precise moment that the review 'proving' that rotational cool burning was irrelevant to wildfire mitigation and prevention was published, the scenery caught fire.

It is instructive that the huge review devotes just four pages to wildfire, and much of that is a egregious attempt to suggest that managed burns are a primary cause of wildfire. It is called 'an update', but when it comes to wildfire it is anything but. The only reference to the causes of wildfire ignition is Cosgrave (2004). We can assume this was selected as it paints the worst picture. There is a great deal of evidence available from a range of sources that show that wildfire ignition is rarely from managed burns, but the author completely ignore it, in favour of a 20 year-old reference.

This partiality is minor compared to the review's total silence on the real world which, as experts in their field, they must have been fully aware of. Their plan for the moorlands is set out on page 30 of the Definition of Favourable Status of Blanket Bog, which according to them is anywhere with peat deeper than 30 cm. It states, 'Fully functioning blanket bog is a climax habitat that does not require management intervention. Until the site is fully functioning, management interventions may be needed to fix outstanding drainage issues, inappropriate grazing and burning'.

That is what is generally referred to as the 'Wet and Walk Away' strategy, and it is no longer a novel approach. It has been applied for over a decade on land operated by the conservation industry, and where NE can control what is going on. It is therefore relatively easy to make an assessment of the efficacy of the claim that wildfire is largely irrelevant to the issue of controlled burning, because they can't happen if you define the land as blanket bog. It is in fact so easy that probably nothing condemns the whole process more completely than the authors' utter silence on the subject.

It is inconceivable that they are unaware of the wildfires that have raged across peatland, treated exactly as they propose. Forsinard, Corrimony, Moray, Stac Pollaidh, Loch Ken, Darwin, Winterhill, Stalybridge, Saddleworth, Marsden (repeatedly), Meltham, Crowsden, Dovestones, the Goyt, Woodhead, Howden and on and on. All on land where their prescription is followed to the letter.

Many of these fires burnt for days, some for weeks. The Fire and Rescue Service has said repeatedly that the fires are made uncontrollable by the rate of spread and flame height, and that is a result of the nature of the fuel load. That is the fuel load that has built up because of the authors' belief that, as climax vegetation, what they call blanket bog should not be managed and cannot burn.

These fires did enormous damage. Releasing hundreds of thousands of tonnes of CO2. Burning precious peat stores that will take hundreds of years to replace. They destroyed wildlife on a vast scale, cost millions of pounds to put out, and put lives at risk directly and indirectly. Of all this mayhem we read not a word. The authors in the four pages they devote to wildfire, would rather talk about something else. You can hardly blame them.

The extension of NE control and power

Another issue is the fact that this is a carefully disguised attempt to take control of a vast landscape. If all land with peat more than 30 cm becomes defined as blanket bog, whether it ever was or could be, its management will be subject to consents and enforcement by NE. No one knows how much land will be involved. The estimate for 40cm plus peat or 'blanket bog' in England is around 800,000 acres. No one knows how much the new definition will bring in, but a conservative estimate is a total around a million acres.

To that can be added the intentions in the Heathland document, where we read the following ambition. 'To achieve favourable status the current extent of heathland needs to increase by 135,000 ha to 417,000 ha'. That is over a million acres. Together the plan is to give NE de facto control over what happens on 2 million acres of the British countryside, most of it privately owned. No problem there then. What could be better than having NE taking control of what happens across 2 million acres of England? What could go wrong? They are the experts after all.

Can NE manage peatland?

Don't be so sure. NE has direct responsibility for the condition of some designated peatland sites. This allows an assessment to be made of their ability to deliver prescribed outcomes. How successful are they? In the lowlands they manage Woodwalton Fen, our oldest nature reserve. It is a Site of Special Scientific Interest (SSSI) and 50% of it is in 'Unfavourable Declining' condition. In the uplands they have managed Moorhouse in Upper Teesdale since the 1950s. It contains 25 SSSIs. Only 5 (20%) are in favourable condition, even worse than Woodwalton. The remaining 20 are either unfavourable, declining or in one case gone altogether. Is this a level of performance that  justifies giving the people responsible power over the management and use of 2 million acres of English countryside?  Of course not. An under-resourced gamekeeper could do better than that.

The cost. Why don't they mention the cost?

If pressed, a reason for this poor performance will be lack of finance. NE will explain that it cannot afford to do everything needed to meet it statutory duties. This inevitably raises the other hugely significant matter, about which the documents are entirely silent, the financial consequences of the decision the Minister is about to take.

Nowhere in these hundreds of pages is there a word about cost. Not a word. It is as though the whole thing was free. Turning 333,000 acres of farmland or forest into Heathland. Cost? Zero? Apparently so, otherwise the authors would surely have mentioned it. The cost of the almost casual remark that, 'Until the site is fully functioning, management interventions may be needed' is similarly unspecified, but as 'Peatland Restoration' has cost the public purse over £250 million in the last decade the costs are likely to be huge.

But that is only a fraction of the cost. There is the cost to the landowners and farmers who will no longer be able to manage over 2 million acres without permissions from NE. On the basis of what is already happening where NE has a degree of control, the disruption to daily life and normal management operations will be considerable.

There will be the cost of fighting the wildfires which the authors infer cannot happen, but which are occurring with increasing frequency and severity. These papers are probably the only government documents relevant to the predictable consequences of climate change that chooses to not mention the most obvious and relevant impact-wildfire.

What the papers do contain are vague references to cleaner water, flood prevention and carbon storage and capture. What they fail to make clear is that these functions are already being discharged by the landscape as it exists, and is managed now. The greatest risks, with the associated costs of remediation, are posed, not by the exclusion of 30 cm peat from the ban on controlled cool burning, but by wildfire.

In 2018 the Stalybridge wildfire occurred on land where NE would not permit rotational burning as they considered that the vegetation was reaching it's climax state, and required no management. This resulted in the loss of an average of 7cm of peat across the entire 18 square miles of the fire, and the release of an estimated half a million tonnes of CO2 into the atmosphere. The costs of this wildfire were obviously enormous, not least in its impacts on drinking water, flood prevention, and carbon storage and capture.

Why didn't they want the Minister to know?

Nowhere in the four pages devoted to wildfire do the authors of these documents even mention this incident. Is it not surprising that they think it unnecessary to mention the costs of this, and the dozens of other similar catastrophes to the Minister before she makes her decision? Do they think that they shouldn't bother her with unpleasant facts. Perhaps they think it is irrelevant that their belief that 'Fully functioning blanket bog is a climax habitat that does not require management intervention', may have a catastrophic downside.

Don't confuse the Minister with management detail

To these costs must be added the additional resources needed by NE to police the new land brought under their direct remit. No one knows how large this will be or how much more money NE will need – so why bother pointing it out to the Minister? The authors don't know, and bizarrely the Peat Map does not even attempt to specify, choosing instead a category of 20-40 cm not 30-40 cm, and is thus irrelevant in resolving this important matter.

Unfortunately, this may be only one of the Peat Map's failings. The first three comments on the Government's own website relate to errors immediately spotted by people who know the land in question. An entire farm with no peat soils, a series of farms in Devon that are entirely mineral soil, and the famous Dartmoor Tors, rocky outcrops visible from space, are all covered in deep peat according to the Governments new 'definitive' map.

What to do?

It seems that it is not just moorland communities that have been stitched up. The same applies to the Minister. The more you study the documents the more you can hear Sir Humphrey murmuring, 'I really don't think we need to confuse the Minister with the contradictory facts'.

The pace of this is a give away. This has been in production since 2021 when the same people, supported as ever by their chums in the peatland restoration industry, (who stand to receive hundreds of millions of pounds from the taxpayer on the basis of these documents), failed to get their way. The burning season is over and it will not come round again for months.

Why the rush? Is it because the same people who have been pushing this agenda since it became one of the greatest cash cows the uplands have ever seen, are afraid that what they have constructed may be beautiful in theory, but is as at risk of going up in flames as the moorland that they say can never burn?

If the Minister is wise, and we have no reason to believe that she is not, she will slow everything down and insist on hearing all sides. She will make sure that she does not go down in history as the person who exposed the English moors to endless wildfire. She will notice that the same names keep appearing, verifying their own, and each others assumptions, and she will ask what is this really going to cost. That would be the wise thing to do. We are due a bit of wisdom.