A Welcome Shift from Natural England on Wildfire - Now Policy Must Follow

Quick summary

• Natural England now accepts fuel reduction, grazing, cutting and firebreaks are essential to wildfire prevention.

• Its own evidence, NECR484 and the Humberhead works, shows rewetting alone cannot manage immediate fire risk.

• Public language has shifted, but licensing, consents and Section 25 access rules still delay necessary work.

• Prescribed burning is omitted, despite Natural England using controlled burns on its own Thursley reserve.

Natural England has published a new blog setting out its response to the growing wildfire threat. It contains several important acknowledgements which the Moorland Association welcomes.

In unusually clear terms, Natural England now accepts that reducing vegetation fuel must form part of wildfire prevention. It also recognises the importance of grazing, cutting, firebreaks, maintained access routes, trained staff, specialist equipment and emergency planning.

This moves Natural England closer to the Moorland Association’s long-standing argument that restoring upland habitats and reducing immediate wildfire risk must be pursued together.

Ruth Waters, recently appointed Natural England’s Regional Director for the North of England and author of the blog, deserves credit for addressing these practical issues publicly. Her intervention provides a constructive basis for the more detailed discussion now needed between Natural England and those managing the uplands.

Natural England’s evidence already pointed this way

Natural England’s 2023 report NECR484 examined fires at Thursley, Winter Hill and Hatfield Moors.

Although its author’s views did not necessarily represent Natural England policy, it identified the need for pre-emptive vegetation management, maintained firebreaks, adequate resources and site-specific wildfire plans. The new blog is significant because those lessons are now appearing in Natural England’s own public language.

Active management is essential

On its National Nature Reserves, Natural England says it reduces fuel through grazing, cutting and firebreaks; maintains access for firefighting equipment; provides trained staff and appropriate equipment; and coordinates with the emergency services. Healthy and resilient landscapes depend upon active management by skilled people.

The blog’s conclusion that “prevention is better than cure” is particularly welcome. Preventing fires and managing fuel so that ignitions remain small and controllable is safer, cheaper and less environmentally damaging than attempting to suppress an intense wildfire after it has taken hold.

Natural England’s public language has shifted, but its regulatory position has not

Natural England’s blog changes the emphasis of its public language, but it does not yet change the regulatory position facing upland land managers.

Rewetting and wider ecosystem recovery remain central to Natural England’s long-term approach. The Moorland Association supports properly designed peatland restoration, but it cannot be delivered everywhere or immediately and does not necessarily remove mature above-ground vegetation. Long-term restoration must therefore be accompanied by continuing management of vegetation and fuel.

Natural England’s own commissioned evidence supports that conclusion. NECR484 states that hydrological recovery is slow and that other fire-control measures must continue until water tables recover. At Hatfield Moors, dry heather growing on bunds and baulks carried fire between restored pools: more than 430 hectares burnt and peat smouldered for months.

Hatfield Moors shows why restoration must build in fuel management and wildfire planning from the outset.

The missing part of the toolbox

The blog recognises grazing, cutting and firebreaks, but omits carefully planned prescribed burning. That is striking because NECR484 records that the management plan for Natural England’s own Thursley NNR included “regular cutting or controlled burns of mature areas of heath” to reduce the likelihood of uncontrolled fire.

The report did not evaluate the effectiveness of burning, which will not be appropriate everywhere. It does, however, confirm that prescribed fire has formed part of the wildfire-prevention toolbox on a Natural England reserve.

All available measures (including rewetting, grazing, cutting, prescribed burning, firebreaks and access management) should be assessed objectively and selected according to local vegetation, hydrology, fuel load, topography, access and likely fire behaviour.

Natural England must apply the same principles as a regulator

These active-management measures are described principally in Natural England’s capacity “as a landowner” on its own reserves. If they are necessary there, the same principles should inform the licences, consents and advice it provides elsewhere.

Natural England’s responsibilities as a regulator and statutory adviser should support competent land managers in reducing fuel and preparing for wildfire - not create delays or conditions which make necessary work impossible within the available operational window.

Rewetting and firebreaks are complementary

Natural England’s Humberhead example is particularly instructive. The reserve has received successive multi-million-pound restoration programmes. From 2014, a £2.3 million LIFE+ grant, supported by further match funding, aimed to rewet 28 square kilometres. From 2022, the LIFE Moor Space project received a further €1.46 million plus €1.2 million in matched funding to further restore the site.

Yet Natural England’s 2022 project newsletter placed “creation of a fire break and ditch maintenance” at the top of its list of physical works, and its new blog shows a firebreak being cut.

The firebreak is evidence that Natural England itself treats rewetting, vegetation management and firebreaks as complementary, not a sign that rewetting has failed. Its regulatory system should provide other competent land managers with an equally clear and workable route to combine them.

Even cutting a firebreak is not straightforward

The photograph raises a further question: what conditions governed the cutting? The image cannot establish vegetation measurements, cutting height or whether any condition was breached. It does, however, raise the question of whether Natural England applies equivalent standards to its own land and to land managed by others.

Standard site restoration plan cutting conditions restrict cutting to mature heather over 30 cm tall, where mature heather forms more than half the canopy and heather covers more than half the area.

Cutting is prohibited where Sphagnum is frequent and widespread or where hummocks are developing, and machinery must avoid the Sphagnum layer and developing micro-topography. Similar conditions are commonly imposed through consents outside Countryside Stewardship agreements.

These may be appropriate safeguards for habitat-restoration cutting, but an effective firebreak must follow fuel continuity and likely fire behaviour. It may therefore need to cross shorter, mixed or moss-rich vegetation.

Natural England should explain what conditions governed its work at Humberhead and how other competent land managers can obtain equivalent site-specific flexibility. Otherwise, the photograph risks creating the impression that Natural England permits practical discretion on its own land that it denies to others.

Grazing and favourable blanket-bog condition

Natural England must also explain how its endorsement of grazing fits with RP2967, its published definition of favourable conservation status for blanket bog.

The blog says grazing can help stop fire spreading, while RP2967 says functioning blanket bog requires no management intervention and specifies “No signs of trampling by animals” and “No signs of poaching by animals”.

Although RP2967 distinguishes excessive or unsustainable grazing, it provides no threshold for significant impact. Controlled grazing may leave visible evidence, creating a risk that a measure endorsed for wildfire prevention could later be recorded as habitat damage.

RP2967 recognises that wildfire damages blanket bog but does not expressly assess fuel load, fuel continuity, firefighting access or likely fire behaviour. Natural England should define what grazing is compatible with favourable condition and weigh its limited effects against the potentially catastrophic consequences of non-intervention.

Hurst & Chunal demonstrates the problem

Hurst & Chunal Moor illustrates the gap between recognising wildfire risk and enabling it to be managed. Defra accepted that a current risk existed and granted a ministerially approved licence for proportionate mitigation.

However, a condition requiring further approval before work could begin meant that the licence could not be used before it expired two years later. Permission existed on paper, but the recognised risk remained unmanaged.

A licence that cannot be used is not meaningful permission. Where intervention is delayed or prevented, the consequences of non-intervention (including increasing fuel loads, fire intensity, damage to peat and risks to firefighters) must also be assessed.

Access restrictions also require attention

Natural England’s blog says that access may be temporarily reduced on its most vulnerable reserves in extreme conditions. However, landowners and National Park Authorities still lack a clear, workable and publicly accessible route for obtaining temporary fire-prevention restrictions under Section 25 of the Countryside and Rights of Way Act.

The current interpretation appears to make the Fire Severity Index reaching Level 5 a gateway before individual local circumstances can properly be considered. By that point, the opportunity for preventative action may have been severely reduced.

Natural England should review this system and clarify how exceptional local evidence (including vegetation condition, fuel load, water availability and firefighting access) will be considered before conditions become critical.

Natural England’s report NECR484 reinforces that argument. It records deliberate fires at Winter Hill when the underlying Fire Weather Index (on which the Fire Severity Index is based) was low. Conversely, no fire occurred at Hatfield Moors when the index was exceptionally high because there was no ignition.

Weather is therefore only one part of the risk. Ignition sources, visitor pressure, vegetation and fuel condition, access and local firefighting capacity also matter. A national index should inform, not prevent, site-specific judgement.

Natural England should clarify its role

Natural England should also clarify how this new work relates to the position previously stated by its Legal Services team. In September 2025, it told the Regional Moorland Groups that its role was “not to advise Government, other public bodies, those managing land or anyone else on health and safety or fire safety” and confined its advice to natural environmental and ecological matters.

Less than a year later, Natural England is explaining fuel reduction, firefighting equipment and access restrictions, participating in coordinated wildfire planning and creating a group to consider short-term mitigation and inform its “decision-making and advice to Government”.

There may be a legitimate distinction between Natural England’s roles as landowner and environmental adviser and the operational responsibilities of Fire and Rescue Services. It should nevertheless explain where that boundary lies, whether its position has changed, what expertise the new group contains and how wildfire and public-safety consequences will inform its regulatory decisions.

What can Natural England trained staff actually do?

Natural England should also clarify what it means when it says its staff have specialist training and equipment “to fight minor fires ourselves”. Its own internal guidance, disclosed under the Freedom of Information Act and published by the Moorland Association, instructs staff not to tackle a fire where flame length exceeds 50 cm or where the fire (including a smouldering fire) covers one square metre or more.

If that guidance remains in force, staff may intervene only in very limited circumstances. Natural England should explain what practical capability the training provides, whether the guidance is being reviewed and how staff are expected to respond beyond those thresholds.

A useful new Wildfire Project Group

The new Wildfire Project Group is a welcome and potentially significant development. It should now examine:

1. How NECR484 and RP2967 are reflected in licensing, reserve management and peatland-restoration programmes.

2. Whether licensing, consent and Site Restoration Plan conditions enable the timely and site-appropriate use of grazing, cutting and prescribed burning (including effective firebreaks through vegetation capable of carrying fire) and properly assess the consequences of delay.

3. How Fire and Rescue Service expertise and land-manager experience will inform site-specific wildfire plans.

4. How Section 25 access restrictions can respond to serious local conditions.

5. How different management techniques will be monitored objectively.

An opportunity to turn words into action

Natural England has not yet changed its formal regulatory policy. Nevertheless, its blog publicly accepts several of the Moorland Association’s central premises: wildfire prevention requires active fuel reduction, maintained access, trained people, practical planning and short-term mitigation alongside long-term habitat recovery.

The Moorland Association stands ready to work with Natural England, Defra, Fire and Rescue Services and other partners to turn these principles into practical policy. The question now is whether Natural England will apply to land managed by others the same wildfire-management principles it recognises as necessary on its own.