This is how I responded to the consultation on heather and grass burning in England. If you’d like to respond too then you have until 25 May, five days, to do so. It’s pretty quick and it is a way to support the campaign to ban driven grouse shooting, or at the very least to reform it, by encouraging the government in England to clamp down on one of recreational shooting’s environmentally damaging practices. Here is the link to the consultation – click here.
My response:
No (I don’t need my response to be confidential)
Details about me: I am a member of the public but I also ticked ‘Other’ and wrote ‘Taxpayer – I am paying for grants to land owners and for the public bodies who should regulate this activity. Visitor to the uplands – I am economically active in the areas affected by these regulations. Nature conservationist – I have been professionally engaged with these habitats, in these locations and the system of site protection and public support for land management for many decades.‘.
Part A:
A1. Do you agree with the proposal to change the boundaries of the Regulations to LFA to protect more upland peatlands? Yes, I welcome it. This should have been done right from the start.
A2. Please use the box below to provide your thoughts, if any, on the proposal to remove protection from those SSSIs that fall outside of the LFA. Such SSSIs, with peat of >30cm should be included in these regulations as the LFA boundary is immaterial to risk of damage to SSSI condition.
A3. Do you agree with the proposed change of the prohibition of burning on peat ‘over 40cm deep’ to peat ‘over 30cm deep’? Yes, This should have been the case right from the start.
A4. Under what ground(s) would you be most likely to apply for a licence to burn? [Leave blank]
A5. Do you agree that ground ‘(d) because the specified vegetation is inaccessible to mechanical cutting equipment and any other method of management is impracticable’ should be removed? Yes.
A6. Do you agree with adding ‘research’ as a ground to apply for a licence under the Regulations? Yes but such licences should be given only very rarely. Generally, the monitoring and enforcement requirements for these measures are not spelled out here and nor are the penalties for breaking the regulations. Without strong measures there is a danger that these regulations will achieve nothing. A ban on driven grouse shooting would remove most of the incentives for such management and should be addressed in the expected debate in Parliament on this petition https://petition.parliament.uk/petitions/700036
A7. Would you support a move to link the revised Heather & Grass Management Code to the Regulations, making it compulsory to follow rather than advisable? Burning vegetation on peat soils can cause serious environmental harm. Clear and strong regulation is needed. What would be the penalties for non-compliance?
A8. Would you support a move to make it a requirement to complete an accredited training course prior to burning under a licence granted under the Regulations? ‘Supervisory practitioners’ is not defined nor is it clear who carries the can if things are done badly. There should be a requirement for completing such courses every few years – I would suggest every seven years.
Part B
Questions 1-5 [leave blank]
B6. In your specific situation, if applying for a licence, who would be responsible for preparing and submitting the application? [Use the text box to make this point] The landowner should be vicariously liable for failings of staff or contractors to abide by regulations.
Part C
C1. Do you currently use burning as a land management tool? [Leave blank]
C2. Where do you currently burn? (Tick all that apply) None of the above. Part C unfairly asks those who want to carry out burning about economic impacts for themselves but there are also economic impacts for those of us who do not want to burn land which this consultation does not easily capture – costs of health, loss of wildlife, damaged landscapes, higher flood risk and higher water treatment costs which are imposed on the general public by those burning for recreational shooting.
Part D
D1. Do you have concerns about the impacts of burning on the environment? Yes, damage to blanket bog habitat in Natura 2000 sites, drying of soil leading to increased greenhouse gas emissions, increase in flood risk (see EMBER study https://water.leeds.ac.uk/our-missions/mission-1/ember/), increased cost of water treatment for particulates (see EMBER study), killing of amphibia and reptiles and ground-nesting birds in April. It is part of a management regime which is damaging to nature conservation interests.
D2. Have you been impacted in any way (positive or negative) by the use of burning as a land management method? Yes, I have unwillingly inhaled smoke in such areas. Have seen peatlands and protected habitats damaged by burning. Burning is largely carried out to increase Red Grouse bags for recreational shooting and is part of a management system which causes widespread and well-documented harm. We are all affected by such unsustainable management practices which benefit a few at the expense of the general public. This consultation is weak on capturing those impacts.
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