The MA’s New Standard for Moorland Management Plan Consultations

Andrew Gilruth
2 hours ago
4 min read

✅ KEY TAKEAWAY: The MA is deploying a rigorous new quality-assurance framework to evaluate upland landscape plans. Drafts failing our Gateway Test will be deemed "not consultation-ready" until fixed.

The last two National Landscape management plan consultations have presented familiar problems. 150+ page draft documents are being sent out for consultation with avoidable gaps that force everyone into long, repetitive responses about basics.

So rather than focusing on genuine choices, trade-offs, and what will actually work on the ground – the MA is now producing 10,000 word responses dealing with foreseeable and avoidable issues.

To fix that, the Moorland Association has now adopted a consistent quality-assurance approach for upland protected landscape plans.

This is not a template for members – but it is what the MA will use.

Together, these give us a practical, repeatable way to assess whether a draft is genuinely consultation-ready, and if not, what exactly needs to be fixed.

Why we’re doing this

We’re doing this to drive up the quality, clarity and deliverability of upland plans - so that consultation is about substance, not preventable drafting churn.

It also responds directly to the wider, recurring critique seen in public scrutiny of environmental delivery: plans that are ambitious on paper but weak on implementation detail, accountability, and feedback loops. Our answer is to turn those recurring weaknesses into a transparent set of consultation-readiness expectations that can be checked quickly and improved quickly.

What “good” looks like

A consultation-ready draft should be: decision-useful, legally robust, deliverable, operationally realistic and co-designed/understandable.

Importantly, a strong draft does not need to be perfect - but it does need to be clear, time bounded and implementable. And to keep the tone constructive (and avoid any impression we’re inventing quasi-regulation), the framework deliberately uses drafting language like:

“A consultation-ready draft should…”
“Minimum content for a consultation-ready draft…”
“MA will assess drafts against…”

How the MA will apply this

From now on, when we are asked to review an upland protected landscape management plan or consultation pack, the MA will apply the framework in three parts.

Part A - Red Flag Scan (mandatory pre-check)

Before we score anything, we review it to identify drafting patterns that reliably create avoidable conflict, drift or implementation ambiguity.

Output: a short Red Flag Register noting:

the phrase/pattern
where it appears (section/page)
why it matters (one line)
which Gateway item / scoring category it affects

Annex A is explicit about what these red flags tend to look like and how to fix them (for example: “not binding” used as a shield; “we expect/must” with no basis; “will deliver” without a delivery route; “partners will…” with no named lead; or risks listed with no linked actions).

Part B - Gateway Test (consultation-ready minimum: PASS/FAIL)

The Gateway Test is a rapid quality check. If a draft fails any Gateway item, the headline result is: NOT YET CONSULTATION-READY (fixable drafting/readiness issue)

The Gateway items cover essentials like:

status/scope and “no policy-creep” safeguards
legal robustness and signposting (HRA/SEA as applicable)
delivery realism
wildfire operational reality (where relevant)
a Plain English “what this means for land managers”
evidence of co-design (not consultation-only engagement)

A key addition here is stakeholder stress-testing: consultation-ready drafts should show evidence they’ve been tested for how they read to those expected to deliver them (including structured land-manager review sessions). Where there’s no evidence of this, it’s treated as a quality red flag.

Part C - Weighted maturity score (0–100)

If the Gateway test is passed, the draft is scored using a maturity model:

0 = Absent

1 = Mentioned

2 = Defined

3 = Implementable

4 = Embedded

Scores are weighted and total /100, with an interpretation guide:

80–100: strong draft
60–79: usable but needs targeted strengthening
<60: material weaknesses likely to generate avoidable conflict/churn

Important: we may still score a plan that fails Gateway, but it will be reported as a Diagnostic score (Gateway failed) so a number can’t mask a fundamental readiness issue.

What will change in MA outputs

You should expect MA consultation outputs to increasingly follow a consistent format:

Red Flag Register (short, specific, actionable)
Gateway PASS/FAIL (and which items failed)
Score /100 (or diagnostic score if Gateway failed) plus:
- required fixes to pass Gateway
- priority improvements (lowest-scoring categories)

This will make our feedback easier for those involved to act, and easier for members to see where the real issues are - fast.

What we need from members

We do not expect members to become template-users or to spend time “scoring plans” unless they want to. What we do want:

Flag any “red flag” wording you spot - especially anything that reads like new requirements without a stated basis, or aspiration statements presented as delivery commitments (send to agilruth@moorlandassociation.org).
When you engage locally, encourage protected landscape teams to use the checklist as a pre-publication quality assurance step, so consultation can focus on choices rather than preventable ambiguity.

The aim

This is about better plans, faster, with less avoidable churn and more realistic delivery on the ground. We’ll stay constructive. We’ll also be consistent. And from here on, the MA will be clear: if a draft fails Gateway, it’s not yet consultation-ready - and we will say so, with the specific fixes needed to get it over the line.