Moorland Association Submits Defra Response: Grouse Moor Management Must Be Judged on the Evidence
Quick summary
The Moorland Association has responded to Defra’s Call for Evidence, urging an objective assessment of grouse-moor management.
Red grouse are wild birds, not reared and released, so evidence on other gamebirds should not automatically apply.
Individual practices, such as predator control, burning and grazing, should be judged by their measured outcomes.
Defra must assess realistic alternatives and show any new regulation is necessary, proportionate and likely to work better.
The Moorland Association submitted its response to Defra’s Call for Evidence on Gamebird Release, Shooting and Welfare During Rearing on 1 November 2026, calling for an objective assessment of grouse shooting and its associated land management.
Our central argument is that grouse moor management cannot be treated as either uniformly beneficial or harmful. Defra must examine the effects of individual practices, recognise both positive and negative evidence, and consider what would happen to England’s uplands under alternative management arrangements.
We would like to thank the MA members who reviewed our first draft and took the time to provide comments and suggestions. Your feedback was carefully considered and incorporated into the final submission. You contributed valuable practical knowledge and helped us strengthen the evidence and arguments presented. We are extremely grateful for the time and effort you put into this.
Wild Red Grouse Are Different from Released Gamebirds
An important distinction runs throughout our response: red grouse are wild birds that live and breed naturally on the moor. They are not reared and released for shooting.
This makes grouse shooting fundamentally different from systems involving the breeding and release of pheasants, partridges and mallard.
Our submission therefore concentrates on wild red grouse and the management of England’s uplands. Evidence about the release of other gamebirds should not automatically be applied to grouse shooting.
What Our Submission Says
Grouse-moor management involves several activities, including lawful predator control, vegetation management, grazing, habitat restoration, wildlife monitoring and wildfire prevention.
Each can produce different outcomes depending on the species, habitat and location concerned.
Our submission examines six main areas.
Conservation of ground-nesting birds. An eight-year field experiment found that lawful control of generalist predators increased breeding success by around threefold, on average, for several moorland bird species, including curlew, lapwing and golden plover. Separate observational research found curlew productivity approximately four times higher on the grouse moors studied than on paired non-grouse moors.
Habitat and vegetation management. Burning, cutting, grazing and rewetting have different ecological effects. Research shows that these approaches are not interchangeable, and no single technique is appropriate for every site. Their effectiveness must be judged against the habitat conditions and conservation outcomes being sought.
Wildfire prevention. Accumulated vegetation fuel, weather conditions and peat moisture influence wildfire behaviour. A 2026 study examining 206 wildfires in England and Wales found that fires in areas managed by burning were smaller than those in unmanaged areas. However, it did not establish that burning caused this difference or reduced fire severity. Our submission argues that peatland restoration and appropriate surface-fuel management should be assessed together, alongside the capacity to prevent and respond to wildfires.
Protected habitats and SSSIs. The condition of Sites of Special Scientific Interest cannot automatically be attributed to grouse moor management. Our analysis of official records shows why distinctions between favourable, recovering and declining conditions matter. Defra should identify the specific pressures affecting protected habitats and assess whether proposed interventions would improve their condition.
Bird-of-prey crime. The MA unequivocally condemns illegal killing and persecution of birds of prey. We acknowledge the peer-reviewed evidence that illegal killing has harmed hen harrier populations and support effective investigation and prosecution. We also ask Defra to distinguish confirmed offences, suspected incidents, unexplained satellite-tag disappearances and statistical evidence of wider patterns. Each is relevant, but they do not establish identical conclusions.
Rural employment and communities. Grouse moor management supports employment, specialist skills, conservation investment, local businesses and community participation. Gamekeepers and other land managers also provide practical support during wildfires. Any future policy must consider what would happen to these activities, the people undertaking them and the resources supporting them.
Why Defra Must Consider the Alternatives
A central point in our submission is that existing grouse moor management should not be compared with an assumed alternative in which environmental risks simply disappear.
If shooting or associated management were restricted or removed, the consequences could extend beyond the activity itself.
Lawful predator control, vegetation management, wildlife monitoring, conservation investment and wildfire-response capacity might all change. Some activities could continue under alternative arrangements, but others would require replacement funding, personnel or infrastructure.
Defra must examine what would realistically happen under different management approaches, rather than assuming that existing benefits would either continue unchanged or disappear entirely.
This applies equally to environmental concerns. Where credible evidence demonstrates harm from a particular practice, that harm should be addressed. But a policy intended to remove one pressure must also be assessed for its possible effects on other species, habitats and conservation objectives.
What We Are Asking Defra to Do
We welcome Defra’s assurance that this Call for Evidence does not prejudge future regulation.
Our submission asks for an assessment that is transparent, consistent and open to different conclusions.
In particular, we are calling on Defra to:
Publish its evidence-assessment methodology, including how studies are selected, assessed and weighted, and how conflicting findings and uncertainty are handled.
Judge individual management practices by measured outcomes, rather than treating grouse shooting as a single environmental pressure.
Examine realistic alternatives, including the environmental, economic and social consequences of changing existing management.
Consider proportionate responses, including better enforcement of existing law, improved standards, adaptive management and recognition of demonstrably good practice, alongside any case for additional regulation.
Establish clear tests of success for any future intervention, including monitoring arrangements and reviews capable of strengthening, simplifying or withdrawing requirements where the evidence justifies doing so.
Any additional regulation must be shown to be necessary, proportionate and likely to produce better outcomes than the available alternatives.
Read Our Full Submission and Seven Supporting Annexes
Our complete submission provides the detailed research, official records, operational evidence and analysis supporting these arguments.
rting documents also identify important limitations and areas where further research is needed.
We encourage members, policymakers, conservation professionals and anyone interested in the future management of England’s uplands to read the full response and examine the evidence for themselves.
