The RSPB has just had its worst summer for wildfires, yet now it wants to license everyone else's moorland.

This summer the RSPB has watched three of its own reserves burn yet it is now asking the government to license everyone else. That is not conservation. It is a distraction, and it is being paid for by people who have not been told the full story.

Consider the timing. The RSPB's chief executive gives an interview in which she describes herself as exhausted after "three devastating wildfires" on RSPB reserves this summer.

Her staff, she says, are still putting out hotspots. And the campaign she chooses to lead with is not what went wrong on her own land. It is an "evidence sprint" to license grouse moors.

When an organisation's management has failed in public, the story has to go somewhere else. This summer, the RSPB has decided it should go to the uplands.

A licence for everyone but the RSPB

Try a thought experiment. Suppose the government licensed land management. Every owner gets a five-year licence and a code of practice. Suffer repeated wildfires, lose peat to fire, preside over falling wader numbers, and the licence goes.

The National Trust's Marsden Moor has burned repeatedly over the past decade. The RSPB has lost three reserves to fire in a single summer. Under an outcomes-based licence, both would have been stripped of the right to manage their land and had it handed to someone who could keep it from burning.

Nobody proposes this, because it is absurd to punish a whole organisation for what happened on a few sites, or to hand an official the power to end a management regime on the strength of last April. Yet that is precisely what Beccy Speight is asking Defra to do to grouse moors. The only difference is who holds the clipboard.

The obvious reply is that fires start with a dropped barbecue or an arsonist, while a poisoned eagle is deliberate. True, and beside the point. The RSPB's scheme does not require an estate to have done anything either. It requires only that a dead bird was found "on or near" its land.

That is a licence revoked for what happened on the ground, not for what the licence holder did. If that is the standard, it cuts both ways: an ignition may be accidental, but whether it dies at a firebreak or burns for a week into the peat is a management outcome, every bit as much as a satellite tag going dark near a boundary. Either the people responsible for land answer for what happens on it, or they do not. The RSPB cannot demand one rule for keepers and another for itself.

What the campaign is actually for

Speight is candid about her organisation's purpose: "It's the job of the RSPB to drive its cause." The RSPB is a campaigning body with an income of well over £125 million a year, and campaigns need villains. A gamekeeper in tweed is a better villain than a peat fire on a reserve with no firebreaks. Every satellite tag that goes dark becomes an appeal. Every eagle found dead becomes a press release before anyone knows what killed it. Licensing is not a policy so much as a product, and the market for it is the RSPB's own membership.

Those members deserve some facts they are not usually given. The RSPB shoots foxes and crows on its own reserves to protect ground-nesting birds, which is exactly what gamekeepers do on grouse moors, and for exactly the same reason. The RSPB walked out of the government's hen harrier recovery plan in 2016; the species has since had its strongest breeding seasons in England for decades, with many nests on or beside moors managed for grouse, and without the RSPB's help.

The satellite tag data the RSPB uses to accuse estates is held by the RSPB, not by an independent body, and the "tip of the iceberg" argument is deployed to explain why the evidence for the rest can never be produced. And the reserves its members pay to protect are the ones that burned this summer, while keepers' winter firebreaks held.

None of that appears in the appeal emails. It should. Supporters who sign up to protect birds are entitled to ask why their money is funding lawyers and lobbyists for a licensing scheme rather than the fire management their own reserves plainly lacked.

Unnecessary, because the law already exists

The stated target of licensing is the illegal killing of birds of prey.Killing a raptor is an offence under the Wildlife and Countryside Act, carrying an unlimited fine and prison. A conviction ends a keeper's career. Natural England can already withdraw general licences from land where there is evidence of persecution, and has begun to. Police wildlife crime units, satellite tags and the RSPB's own well-funded investigations team all exist.

The problem the RSPB describes is not an absence of sanction. It is the difficulty of detecting and proving a crime. A licence does not solve that. It lowers the bar for a punishment the courts can already impose, and takes the court out of the process.

A person prepared to lay poison for an eagle is already breaking the law. A licence condition will not deter someone the criminal law has not. What it does is shift the risk from the guilty individual to the compliant majority: one rogue act on one beat, and an entire estate loses its licence, with its keepers, beaters, tenancies and local businesses, while the culprit walks unless the police can prove it.

The Dorset eagles show the method. The Health and Safety Executive is still investigating whether a rodenticide was used in breach of the rules. Nobody has said by whom or on what land. The RSPB has already filed them as evidence for licensing shooting estates.

And within a few sentences of describing licensing as a response to crime, Speight explains it would "probably result in more [small scale] shooting at the start...". That is the tell. This is not crime prevention. It is using a licence to reshape an industry to a campaign group's taste, sliding from pheasant release numbers, a lowland matter, to grouse moors, where not a single bird is released. Scotland, the model on offer, is barely a year into its scheme and has produced cost, uncertainty and legal exposure for estates, and not one raptor demonstrably saved.

Judge management by results

If the RSPB wants land judged on outcomes, the moorland community welcomes it. Managed grouse moors are where curlew, lapwing and golden plover still breed in numbers. Winter cutting and cool burning turn heather into a patchwork of fuel breaks, which is why fire crews head for managed moors when they need somewhere to make a stand.

Speight herself says heather is "incredibly flammable" and dried peat "very susceptible to fire". The people who cut firebreaks every winter have been saying so for years. The organisation whose reserves burned this summer was not among them.

Defra says any change will begin with evidence gathering and go to public consultation. Good. The evidence is wader counts, fire records, peat restoration on estate land and hen harrier nests, and moorland communities will bring all of it. But ministers should ask a simpler question first. A charity that cannot keep its own reserves from burning wants the power to decide who else may manage the hills. Before anyone hands it that power, its own supporters might ask what, exactly, they have been paying for.