Avery Backs our Call for a Deliverable Bowland Plan
- Andrew Gilruth
- 2 hours ago
- 3 min read
We have previously covered the Bowland management plan consultation and why members should respond. This is a short update: Mark Avery has now publicly made the same “plan quality/deliverability” criticism we have - which materially strengthens our position.
The Forest of Bowland National Landscape draft Management Plan (2026–31) is out for consultation, until 2 March. If you haven’t responded yet, please do. The full MA response can be read here and the 60-second version here.
Why this matters (regardless of what you think of Avery)
Avery has published a blog about this plan and his central criticism is not about who is right or wrong. It’s about whether the draft is a real management plan at all:
“The Draft Management Plan is not a plan for action because it doesn’t identify how much action is needed, of what kind, by whom and by when.”
So now a well-known critic of grouse moor management is calling for the same “deliverability test” we are calling for - the authors of these plans can’t dismiss our comments as “special pleading” from land managers.
“by whom and by when” – a cross-spectrum criticism
We will be incorporating this support on “deliverability” within the MA submission. Not by adopting Avery’s framing or attributions, but these central points that MA members have been consistently asking for:
Clarity on delivery: what action is proposed, where, at what scale, funded by whom, delivered by whom and by when.
Measurable monitoring: agreed indicators, transparent reporting and a timetable for review.
Adaptive management: clear “what happens if it isn’t working” triggers, rather than doubling down on assumptions.
Honest treatment of constraints and risks: if the draft names outcomes, it must also be honest about the risks to delivering them.
The Deliverability Test
What exactly will change (and where/at what scale)?
Who is accountable for delivery (named lead), and who else is involved?
By when (milestones year 1/2/3) and what triggers action?
How is it funded/resourced?
How will success be measured, reported, and reviewed - and what happens if it isn’t working?
We have previously made the same points in the North Pennines consultation and our evidence submission to the Public Accounts Committee.
Those producing plans should be judged by real-world results, not warm words, process or outputs. If it can’t answer the Deliverability Test, it isn’t yet a management plan - it’s a set of aspirations.
Plans must also address constraints transparently, and be compatible with practical, lawful land management (including the consequences of making private investment and day-to-day management unviable).
Gull impacts must also be addressed in Bowland
Many members have raised concerns about increasing gull pressures in parts of Bowland - including impacts on ground-nesting birds, livestock and wider land management. The draft plan should treat this like any outcomes-critical pressure: monitor it, report it and set out who is responsible for action. This is not about rhetoric. It is about ensuring the plan is honest about pressures members are seeing and is capable of delivering balanced outcomes.
What we want the Bowland plan to incorporate
Following this consultation we will be looking for:
Named leads/owners for key actions (not just “partners”).
Timescales (what happens in year 1, 2 & 3 - not just “over the plan period”).
Measurable indicators linked to outcomes (not only activity lists).
Review points and triggers (“if X is not improving by Y date, we do Z”).
A clear approach to trade-offs and constraints (including lawful land management realities).
What members can do before 2 March
Keep it disciplined: deliverability, accountability, monitoring, and consequences.
Use the Deliverability Test above (“by whom and by when”). If gull impacts are an issue where you are, use them as a worked example (monitoring, responsibility, lawful options, review triggers).
Looking for a 60-second submission to the Bowland plan?
Members seeking to make a swift submission can do so here and at question 4 (Vision) make the following points in your own words:
I support a strong, outcomes-led Plan for the Forest of Bowland, but the draft reads too often as aspiration rather than a deliverable management programme. Please strengthen the revised Plan with a clear delivery section: for each priority outcome, set out what action is proposed (and where/at what scale), who is accountable for delivery, how it will be funded/resourced, timescales (year-by-year milestones), measurable indicators, and explicit review triggers (what changes if progress is not being made).
Economic viability is not an optional extra. Viable farming and moorland enterprises underpin the private investment and day-to-day management that maintain landscape character, habitat condition, and wildfire risk reduction. The Plan should avoid “withdrawal by implication” and be explicit that resilience does not mean absence of management.
