All 15 UK National Parks Have Recognised the Risk of Rising Fuel Loads
Quick summary
All 15 UK National Park Authorities accept that nature-recovery measures can increase fuel loads during the transition.
Wildfire risk assessments should ask what happens if vegetation management does not take place.
Success should be judged by real wildfire resilience on the ground, not by hectares rewetted or trees planted.
Natural England should review the Section 25 fire-risk access guidance and process before the next fire season.
Why wildfire policy must now focus on outcomes, not processes
All 15 UK National Park Authorities have endorsed a new wildfire position statement containing an important recognition: measures designed to improve landscape resilience over the longer term can increase vegetation and fuel loads during the transition, increasing the need for fire-risk mitigation.
The statement commits National Park Authorities to stronger wildfire planning, including Integrated Wildfire Management Plans, wildfire risk assessment, land-manager fire plans, training, firebreaks, management of visitors and consideration of fuel loads.
It follows another exceptionally serious wildfire season and recognises that a changing climate is likely to increase the challenge further.
There is much in this approach that the Moorland Association welcomes. But one passage is particularly important.
Nature recovery can increase fuel loads
The National Parks now recognise that measures intended to deliver nature recovery (including native woodland, natural regeneration, reduced herbivore impacts and greater habitat diversity) may ultimately produce more resilient landscapes.
They also acknowledge that those benefits can take many years to develop and that, in the meantime, “fuel loads will increase”, alongside a corresponding need for fire-risk mitigation. That is important.
For too long, discussion about upland wildfire has sometimes treated intervention as the source of risk and non-intervention as the absence of risk.
The reality is more complicated. Every land-management choice has consequences.
Prescribed burning has risks and must be undertaken professionally and in appropriate conditions. The National Parks statement recognises that a controlled fire which escapes can become a wildfire.
But choosing not to burn does not make wildfire risk disappear. Changing grazing, restoring habitats, establishing woodland, rewetting land or allowing vegetation to develop can all alter the amount, type and arrangement of fuel across a landscape. Some changes may improve resilience in the long term while creating different risks during the transition.
The National Parks' recognition of that transitional risk is therefore important.
What happens if we do nothing?
This points towards a simple principle. When an authority considers the risks of a vegetation-management intervention, it should not ask only what could go wrong if the work is undertaken.
It should also ask: what happens if it is not carried out?
Will vegetation continue to accumulate? Will fuel loads increase? Is there another practical way of reducing the risk? And which option leaves the landscape safest overall?
Doing nothing is not the absence of a decision. It is a decision with consequences of its own.
That is particularly important on moorland, where fuel condition, topography, access, weather, peat depth, vegetation and the availability of trained people and equipment can vary enormously from one place to another.
There is no single intervention that will provide the answer everywhere.
Rewetting is an activity. Wildfire resilience is an outcome.
The National Parks' statement advocates integrated wildfire management. Its list of considerations includes wildfire risk assessment, controlled vegetation burning, wildfire danger assessment, estate and land-manager fire plans, equipment, training, mutual aid, fuel loads, rewetting, firebreaks and woodland planning.
That is the right framework. But it also requires an important change in how success is judged. Too often, delivery of a particular intervention can become confused with delivery of the environmental outcome.
Rewetting land, reducing grazing, establishing woodland or changing vegetation management may all be entirely legitimate tools. But none is, by itself, an environmental outcome.
The important question is what happens afterwards.
Does wildfire risk fall? Does the landscape become more resilient during prolonged dry weather? Or, during the transition, does vegetation accumulate and fuel load increase?
The National Parks' statement is important because it recognises that those transitional risks are real and must be managed.
The publication of this statement should end any assumption that a nature-recovery intervention is successful simply because it has been delivered. Its consequences for vegetation, fuel loads and wildfire risk must also be assessed.
Rewetting, woodland creation or changes in grazing are management activities. The outcome that matters is whether the resulting landscape is genuinely more resilient to wildfire.
Defra and Natural England should follow the same principle
For England, that recognition should have implications beyond the National Parks themselves. Defra has the central government relationship with England's National Park Authorities, while Natural England is a Defra-sponsored arm's-length body. We hope this new recognition will now be reflected across Defra and Natural England policy and regulation.
Nature-recovery interventions should be assessed not simply by whether they have been delivered, but by their real-world consequences for vegetation, fuel loads and wildfire risk.
The principle should be the same whether an authority is considering rewetting, vegetation management, a burning application or public access: what option produces the safest and most resilient landscape overall?
Section 25 now needs a full review
The same principle must apply to public access.
The National Parks statement recognises increasing visitor numbers as a source of ignition risk and identifies recreation and access as part of the National Park Authorities' proactive role in wildfire prevention.
That makes the current difficulties with the operation of Section 25 of the Countryside and Rights of Way Act particularly urgent. The MA has previously highlighted this provision provides a statutory mechanism for restricting access where exceptional conditions create a serious fire risk.
But a preventative power is of little use if it can only be activated once conditions have already become extreme, or if the process takes so long that the period of greatest danger has passed.
The experience of recent wildfire seasons suggests that Natural England's guidance and the operation of the Section 25 fire-risk process now require a full review.
That review should ask whether restrictions can be considered early enough; whether clear wildfire-danger triggers can be used; whether relevant authorities are making appropriate use of their existing power to act proactively rather than waiting for land managers to apply; and whether decisions can be made quickly enough to prevent wildfire rather than simply respond once exceptional conditions have arrived.
If National Parks are now committed to wildfire danger assessment, integrated wildfire planning and active management of recreation and access, the system governing Section 25 needs to be capable of delivering that commitment in practice.
That review should be completed before the next fire season, not during it.
Outcomes, not processes
The National Parks' statement is an important step forward. It recognises that the route towards a more resilient landscape can itself create risks which require active management.
The implication is clear.
Success cannot simply be measured by hectares rewetted, trees planted, grazing reduced or burning prevented. It must be measured by what happens on the ground — including whether people, peatland, wildlife and neighbouring communities are becoming more or less exposed to catastrophic wildfire.
The same applies to access. The National Parks' new position strengthens the case for Natural England to undertake a full review of the Section 25 fire-risk guidance and process before another period of exceptional fire danger.
The lesson is straightforward. Wildfire policy must ask not only what risks an intervention creates, but what happens if that intervention does not take place.
Doing nothing also carries risk.
Success should be judged by what happens on the ground, not simply by whether a process has been completed.
