皇家华人believes the proposals suggested within this consultation are not justified by substantiated evidence and represent a continuing reduction to vital management across our upland landscapes. This, in conjunction with a warmer and drier climate, is resulting in increased wildfire numbers.
The consultation assumes all deep peat can be successfully rewetted, thereby leading to a reduced fuel load and lower risk of wildfire. The situation is more nuanced, which the proposed regulations do not address. If Defra鈥檚 ambition is to ban burning as one step towards creating or restoring blanket bog to limit wildfire risk, then research is needed on the ability of these areas of deep peat to be rewetted. A lot of moorland peat in England will never re-wet into fully functioning bog as it is sitting on permeable substratum.
Overgrown vegetation risk
The consultation makes no reference to the social and economic importance of the upland landscape and how farming businesses and our rural economy will suffer because of the measures suggested. Preventing burning will lead to overgrown vegetation. This will carry more ticks and produce less palatable forage, negatively impacting on livestock productivity.
This is particularly pertinent for upland farmers who tend to be tenants or graziers and depend on the livestock for income.
Upland farming businesses are already in a vulnerable position following the government鈥檚 decisions on inheritance tax, the lack of access to ELMs (Environmental Land Management Scheme) and accelerated reduction of delinked payments, and the proposals within the LUF (Land Use Framework).
Multi-functional land use
The NFU鈥檚 response to the LUF argued for multi-functional land use. The proposals in this consultation do not align with that argument, calling for land sparing solely for the purpose of peat management. 听
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In line with England鈥檚 Peat Action Plan鈥檚 commitment to work in partnership with land managers to ensure actions are 鈥減ractical and deliverable,鈥� we urge Defra to pause these proposals until a more evidence-based and collaborative framework can be developed.
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Similarly, the Dartmoor review recognised the need for vegetation control and the role of livestock in managing that vegetation. It highlighted the need for wildfire control and prevention to be afforded a high priority and to recognise the central role played by land managers in this. We encourage Defra to learn from the independent Dartmoor Review before implementing proposals to ban burning.
Policy positions
Peatland restoration requires a mixture of interventions. 皇家华人is concerned that simply restricting burning will not deliver Defra鈥檚 desired outcome to protect air, water, and wildlife, or rewet all peatland. The proposals outlined in the consultation will instead:
- Significantly increase the risk of wildfire in upland areas, putting people, livestock and the environment in danger.
- Undermine the sustainability and profitability of upland grazing livestock businesses by reducing productivity and threatening animal health and welfare.
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皇家华人asks the government to halt these proposals and address these important concerns before mandating a ban on burning.
In addressing these concerns, we ask the government to:
- Carry out a risk and impact assessment of these proposals on wildfire risk, food production, and upland farm business viability.
- Fund research into cool burning to understand its impacts on our environment and its importance in managing wildfire risk. Cool burning could be an alternative to the burning ban proposed in this consultation.
- Assess all moorland in England as to its potential for rewetting and becoming a fully functioning bog.
- Ensure that there is adequate government funding for national roles in wildfire prevention that will support national wildfire preparedness.
If the government proceeds with the proposals, despite NFU concerns, it must ensure that:
- Accredited training courses are only mandatory for supervisory practitioners of burns. This is subject to access and availability of training.
- There is a review of the regulations in three years鈥� time to assess whether the proposals have resulted in a further increase in wildfires.
- Cool burns can be carried out without the need for a licence.
- Research burning licences are only granted when there is obtained consent from the farmer/land manager/landowner and an impact assessment.
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