Our Draft EFRA Submission Is Ready — Read It, Comment, and Have Your Own Say Before 26 June

✅ Key Takeaway: Our draft submission to the EFRA Committee’s inquiry on the uplands is now ready for you to read and comment on — and you can still send your own short response to the Committee before the 26 June 2026 deadline.

A couple of weeks ago we told you that the House of Commons Environment, Food and Rural Affairs (EFRA) Committee had launched a call for evidence on the future of upland farms and landscapes, and we promised to publish an initial draft of the Moorland Association’s response for you to comment on.

That draft is now ready.

👉 Read the full draft submission here

This post sets out what it argues, so you can read it and tell us what we have got right, what we have missed, and where your own experience could make the case stronger. The deadline for submissions to the Committee is 26 June 2026, so please have a look soon.

What our submission argues

The heart of our case is simple: Defra’s upland policy needs a delivery reset — in plain terms, the people who manage the land need to be in the room from the start, not handed decisions to comment on at the end.

The problem is not a lack of ambition. Government has plenty of targets for carbon, nature, water and climate. The problem is the way policy is delivered. Too often, decisions are designed centrally, turned into plans, guidance, funding rules and consents, and only then shown to the people who actually manage the land.

That does not work, because upland outcomes are practical, local and connected. Peatland, grazing, vegetation, wildfire prevention, species, water, farming and sporting management cannot be split into neat administrative boxes.

A decision that looks cautious on paper can increase risk on the ground if it removes a tool, delays action, or makes a business unviable.

We are clear throughout, and it bears repeating: we are not asking for weaker regulation. We are asking for better regulation — locally informed, evidence-led, proportionate, and judged by whether it actually delivers results.

Our members manage around one million acres of upland England and Wales, and the submission is backed by ten annexes of evidence and case studies.

The key recommendations

Our submission asks the Committee to recommend that Defra:

• Co-design before consultation — involve landowners, farmers, commoners, graziers, gamekeepers and estate teams in shaping policy from the start, not at the end.

• Set up regional upland delivery boards — practical, place-based bodies that align funding, consents, wildfire planning and monitoring, led by those with responsibility for the land.

• Allow land-manager-led 25-year management plans — long-term plans for your own land, agreed against clear standards and subject to audit and Natural England oversight, so routine works can be pre-approved rather than re-approved every time.

• Apply a “workability and outcomes test” to licences, consents and scheme conditions — before a condition is imposed, ask whether the risk is evidenced, whether the condition can actually be used, and what happens if nothing is done.

• Make wildfire resilience a core upland objective across the main schemes and policies.

• Create a fast public-safety consent route for urgent fuel-reduction work, including prescribed burning where justified.

• Stop non-statutory plans and maps from creating new restrictions by implication.

• Keep the evidence transparent — where evidence is used to restrict a management tool, the process should be auditable and open to Parliamentary scrutiny.

• Recognise reliable managers through earned recognition for those with strong compliance and delivery records, backed by audit.

• Protect the economic viability, skills and private investment the uplands depend on.

Why this matters on the ground

Two short examples in our submission show why being workable matters more than simply having a process.

Hurst & Chunal

Defra accepted there was a current wildfire risk and granted a licence for controlled burning on deep peat. But a restoration-plan condition attached to the licence had to be signed off before any burning could begin, and it was applied in a way that made the licence impossible to use within the licence period.

The result: an acknowledged wildfire risk went unmanaged. As the submission puts it, permission in form became refusal in substance — and in wildfire work, delay is never neutral, because fuel keeps building and the weather window closes.

Hen harrier brood management

This was developed through a Defra-supported recovery framework as a lawful, licensed conflict-management tool. The trial indicated it could operate safely and helped build confidence among the land managers taking part.

The point we make is narrow and practical: where a tested tool already works under licence and safeguards, the regulatory question should be how it continues safely and proportionately — not how to rebuild, from scratch, the evidential burden of a trial that has already been completed. The oversight stays; it is the needless repetition we question.

Both cases show the same pattern: an environmental objective is accepted in principle, but the process makes delivery slow, costly or impossible.

Wildfire: the test of upland policy

We give wildfire particular weight, because it connects everything — peat, wildlife, water, public health, access and community safety.

Our central argument is that wildfire policy must shift from suppressing fires after they start to reducing their severity before they start. Climate change is making fire weather worse, but it is land management that decides whether a spark becomes a controllable surface fire or a damaging blaze in the peat.

That means supporting active fuel management — grazing, cutting, bracken and scrub control, rewetting where it works, and prescribed winter burning where the evidence justifies it. Rewetting helps, but it is not a complete answer on its own.

It also means people. In remote uplands, the first effective response often comes from farmers, keepers, shepherds and estate staff who know the ground, hold the keys and have real fire experience. If active management becomes uneconomic, that local, privately funded capacity is lost — and it should be recognised as part of national wildfire resilience.

We want your views on our draft

This is your submission as much as ours, so please tell us what you think once you’ve read it. We would especially welcome:

• practical examples from your own experience — where policy is helping or hindering;

• figures, case studies, short notes and photographs we can draw on;

• anything we have got wrong, overstated, or left out.

Please send your comments to agilruth@moorlandassociation.org.

Make your own submission too

Reading our draft is not a substitute for your own response. The Committee has said it wants to hear directly from the people who manage these landscapes, and your voice carries real weight on its own.

Your response does not need to be long or technical. One well-explained example from your own experience — what a policy looks like on your ground, what works and what does not — can be more useful to MPs than pages of policy language.

You can submit your evidence through the EFRA Committee website in a simple Word document, and you can say in it that you would be willing to give oral evidence. The deadline is 26 June 2026.

The uplands are living, working landscapes — and the surest way to keep them that way is to make sure the people who manage them every day help shape the rules they live by.