North Pennines National Landscape Management Plan: MA Response Submitted

Thank you to all members who took the time to send in comments, evidence and suggested wording on our draft response to the North Pennines National Landscape Management Plan (2026–2031). The quality and depth of feedback was exceptional and has materially strengthened the Association’s final submission.

We can now confirm that the Moorland Association’s formal response has been submitted.

What changed since the first draft we shared on our website?

Members will recall that an earlier draft was circulated to support discussion and comment. Following member feedback, the final submission includes significant revisions and additions, including:

• Clearer and more explicit safeguards around policy status. The final response strengthens the argument that a National Landscape Management Plan is a non-statutory partnership document, not a policy instrument. It sets out, in much clearer terms, the risks of “policy by guidance” and regulatory creep if aspirational language is later treated as binding.

• Stronger treatment of Habitats Regulations, SPAs and HRAs. New sections were added highlighting the absence of a clear Habitats Regulations Assessment (HRA) screening, despite the draft Plan introducing material changes affecting land use across areas containing, or functionally connected to, Special Protection Areas (SPA) and Special Areas of Conservation (SAC).

The response now makes clear that beneficial intent does not remove the legal requirement for assessment, and that plan-level clarity is essential to avoid procedural and legal vulnerability downstream.

• Explicit links between land management systems and protected species outcomes. Member evidence helped strengthen sections explaining how actively managed moorland contributes to SPA qualifying features (including hen harriers and upland waders), and why strategic plans that implicitly signal management withdrawal cannot safely rule out likely significant effects.

• Clearer governance and accountability concerns. The final submission now goes further in setting out the risks of unclear decision-making pathways between public bodies, and the practical consequences for land managers if conflicts between conservation objectives, public safety and regulatory requirements are not transparently resolved.

• Comparative reference to Forest of Bowland. We explicitly reference the draft Forest of Bowland Management Plan (2026–31) as an example of a more balanced and constructive approach. That plan is notably more positive towards those already managing land, clearly framing the landscape as living and working rather than transitional or problematic. More from us shortly on the Bowland consultation.

Why this matters beyond the North Pennines

Members should note that concerns raised in this response are not isolated. The issue of how policy is being developed and applied through non-statutory plans is a central theme in the Moorland Association’s recent submission to the Public Accounts Committee.

In that submission, we highlighted a growing pattern across environmental governance:

• policy being shaped indirectly through guidance and plans

• ambiguity being relied upon to extend regulatory expectations

• insufficient scrutiny of evidence, cost, deliverability and legal process

The North Pennines draft Plan illustrates exactly why this matters. Once published, such documents are routinely relied upon by planning authorities, regulators and third parties who were not part of the drafting process and are not privy to informal assurances about “intent”.

That makes clarity, proportionality and legal robustness essential, not optional.

Raising these issues now is about protecting good governance, legal certainty, and confidence for those managing land, not about opposing conservation objectives.

Reminder: individual submissions can still be made

Deadline: Tuesday 10 February.

Individual responses can still be submitted and help reinforce the breadth of concern and demonstrate that these issues are shared across those working in the landscape, not confined to one organisation.

We will continue to keep members updated as the consultation progresses and will share further detail on related consultations, including Forest of Bowland, very shortly.

Thank you again for the time, care and expertise members have contributed – it has made a real difference.