Bogs need water not fire.
The Government should introduce a ban on burning blanket bog in England to prevent ongoing losses of carbon, increase their resilience to climate change and restore their rare wildlife to good health. This is one of the Natural Climate Solutions essential to confront the climate change and biodiversity crises. It would also help achieve the draft ambition of the proposed England Peat Strategy for 'all of our peatlands to be functioning healthily for the needs of wildlife and people…safeguard(ing) the carbon they store'.
England’s upland blanket bogs are globally rare ecosystems, protected under UK and international law. Blanket bog is vital in the fight against climate breakdown and the Government’s ambition of net-zero emissions by 2050: the habitat’s peat soils lock up billions of tonnes of carbon. Covering hundreds of thousands of hectares, our uplands ought to be a haven for wildlife.
And yet for decades, some moorland owners and tenants have been given legal permissions or consents to damage these sensitive habitats, subjecting them to intensive management practices for the purpose of maximising the number of grouse for shooting. Information from Natural England suggests there were over 400 consents to burn blanket bog on grouse moors in north England’s European protected areas, covering around 950 square kilometres of the (deep) peat soils this precious habitat depends on.
This case began way back in 2012 with the RSPB's concerns over Natural England's actions in relation to an upland grouse shooting estate, Walshaw Moor, in the South Pennines (see here). It expanded to cover the way in which Natural England and the UK Government permits and financially supports the ongoing burning of our globally important upland peatland habitats, particularly blanket bog in protected Special Areas of Conservation in northern England.
Why blanket bog is so important and why burning needs to end
Blanket bog is found in only a few parts of the world and the UK has a special responsibility at a national, European and global level to restore and conserve it. The blanket bogs and dwarf shrub heath and some of their associated species of the English uplands are protected by the highest UK environmental designations.
Where blanket bog has been damaged by atmospheric pollution (largely historic), drainage and managed burning, the vegetation is often dominated by heather and may resemble dry heath - on many such areas, the layer of underlying peat suggests such areas of vegetation should properly be regarded as degraded blanket bog requiring restoration.
Burning blanket bog dries out the underlying peat soil and damages the ecosystem, releasing climate-changing stored carbon to the atmosphere. Soil carbon is also released into watercourses, degrading drinking water quality and requiring costly treatment. Continuing this outmoded practice of burning peatland habitats in our dangerously warming 21st century is wholly inappropriate. It will make legally binding climate change targets much harder to reach by continuing to add carbon emissions to the UK total, undermining efforts to reach the Government’s goal of net-zero carbon by 2050.
This burnt, degraded blanket bog is also less able to slow the flow of water across the bog surface, leading to heavier floods after torrential rainfall, affecting communities downstream of the moors. Similarly, desiccated and damaged blanket bogs are less able to withstand worsening heatwaves, reducing ecological resilience in the face of periods of drought. Drier habitats are associated with increased wildfire risk and impact, with unknown impacts on local air quality in our northern towns and cities.
Having made a formal complaint to the European Commission about Natural England’s damaging actions at Walshaw, the RSPB gathered further evidence from Natural England to better understand what was happening in respect of the management of blanket bog on other upland sites in England also protected under the Habitats Directive and Birds Directive. This information was shared with the European Commission (see our 2014 and 2016 updates in the Downloads section).
We confirmed Natural England had permitted the widespread burning of blanket bog in north England’s protected areas and that the practice of burning was confined to grouse moors. This went against Natural England’s own evidence that burning damages blanket bog and prevents its restoration. The majority of the consents we discovered were Higher Level Stewardship agri-environment agreements, with a value of around £108 million. This is in addition to any payments the shooting estates received by way of Basic Payments under the Common Agricultural Policy.
Based on even more recent information provided to the RSPB by Natural England we now believe Natural England had given consent to burn blanket bog on an area which covers around 950 square kilometres of the (deep) peat soils that should be maintained or restored to healthy blanket bog.
Acting as the environmental watchdog and using the RSPB’s evidence, the European Commission started its own legal action in April 2016. They argued the UK had failed properly to protect the globally important blanket bog in these European protected areas and to take positive measures to make sure it was restored to good health.
Lack of progress by the UK led to the EC escalating its legal action in April 2017. By the end of 2017/early 2018, the UK Government had responded. We understand the Government committed to end burning of blanket bog in the SACs by June 2019 by:
- Asking Natural England to negotiate with each estate requesting they voluntarily give up their (402) legal consents to burn blanket bog;
- If this was not successful in ending all burning, Government to introduce a legal ban.
Initially Natural England sought to tackle the 402 consents by agreeing new, long-term (25 year) plans with each estate. We and others criticised these heavily because they:
- Perpetuated burning under the guise of “restoration burning” (see below)
- Allowed each estate to pretty much decide where and when they would burn blanket bog and how frequently;
- In some cases, facilitated the burning of perfectly healthy blanket bog;
- In other cases, gave permission where there was no pre-existing consent or it had lapsed.
In June 2019, the Government confirmed in a parliamentary answer that Natural England had been able to revoke or modify 180 of the 402 consents to burn blanket bog in the five northern England Special Areas of Conservation. This should have signalled a move by Government to legislate to bring an end to burning of blanket bogs in these special places - but to date, the Government has not acted.
The "restoration burning" myth
As part of its response to the European Commission’s legal action, the UK Government introduced the concept of "restoration burning": the idea being that in some situations one last burn could help remove dominant heather or grass cover and allow the delicate Sphagnum mosses to thrive. This appeared to the RSPB to be a weakness that might be exploited, allowing burning to continue. Our fears were confirmed when it became apparent that early long-term plans approved by NE had insufficient controls in place to ensure that such a practice could only be tried after everything else had failed.
The RSPB has continued to challenge "restoration burning" as fundamentally flawed and contrary to Natural England’s own 2013 review of the scientific evidence, which concluded that burning undermines blanket bog restoration. We consider burning has no place in the toolkit to help restore degraded blanket bogs to favourable condition.
In February 2019, Natural England issued revised guidance to set out the position it would take when a request was made to burn blanket bog for restoration purposes (with a subsequent revision published in November 2020). A key part of its new approach is that Natural England would no longer consent “restoration burning” through long-term plans or leave landowners to make decisions on where and when burning could take place. Natural England now makes clear that burning is a measure of last resort: it will only be allowed in "exceptional circumstances" once all other measures have been tried and appear not to be working after at least 10 years. Importantly, Natural England will now only grant separate, short term consents (usually up to 3 years) and require evidence to show recovery is not already underway.
These changes are a step in the right direction: but they are only a form of damage limitation as they still accept burning has a role in restoring blanket bogs to good health. Our key concerns with the revised position are:
- It goes against growing scientific evidence on the damaging impacts of burning on restoration, both Natural England’s own as well as that from other research studies. Natural England accepts the evidence against burning has continued to get stronger and that there is no evidence restoration burning works. As well as its 2013 review, this includes internal advice from April 2018 as well as recently published scientific papers co-authored by its own scientists;
- It accepts burning can take place on blanket bogs with up to 12 % cover of Sphagnum mosses. These bogs should be viewed as recovering, and other non-damaging measures used to help that recovery;
- The use of "exceptional circumstances" has strong (and worrying) echoes of the misused “special circumstances” system under the Heather and Grass Burning Code of Practice 2007 which led to Natural England granting the hundreds of burning consents in the first place;
- It allows additional “exceptions” without any obvious rationale e.g. "exceptional site-specific circumstances".