Thursday, 6 March 2014

A Review of Natural England's Upland Evidence Review

The first phase of Natural England’s Upland Evidence Review was completed at the end of May, last year, with the publication of the five topic reports that covered:
  • Tracks on blanket peat
  • Restoration of blanket bog
  • The effects of managed burning on upland peatland
  • Upland hay meadows
  • Moorland grazing and stocking rates
Full details and downloads are available from the Natural England website.

On behalf of the Trust, I supported the Upland Evidence Review by contributing to the production of the Tracks report, and I am also a member of the Defra Upland Stakeholders Forum, which has had a role overseeing the Review.  

As a result of this involvement, I have seen the draft internal guidance that Natural England is now producing.  This next phase of the work is the ‘evidence to advice’ phase that is developing the evidence established in the five topic reviews into guidance that Natural England can give to its staff when dealing with land management issues.  Note that this is internal advice for Natural England staff and is not advice for the owners and managers of land.

The internal guidance is being developed at three levels:
  • Quick start – things to think about
  • Upland Principles – summary guidance
  • Upland Practitioner – detailed guidance 
The quick start guidance provides context and I have no issue with this.  The Upland Principles have been drafted in four sections, as the burning and restoration topics have been addressed in one paper.  I am happy with the approach that has been adopted for three of the papers but I have difficulty with the burning and restoration paper.

The burning and restoration paper was published after the other three and was circulated for discussion at the meeting of the Best Practice Burning Group, last month.  The late circulation of this report and its contents was bound to produce some fireworks, and we were not disappointed.  The challenge was that I found myself as Chairman of the meeting and had the task of producing a coherent response to the paper from the meeting.

The week following the Burning Group meeting I was treated to another review of the Upland Principles papers at a meeting with Natural England in Newcastle.  This was part of the stakeholder engagement process and the Moorland Association and the RSPB joined me.  Again the main bone of contention was the burning and restoration paper.

We were also given an insight into the development of the Upland Practitioner detailed guidance and a sensible approach seems to have been adopted to this.

So what are the sticking points with the process, the development of the Upland Principles guidance and the burning and restoration paper in particular?

I am not content that effective stakeholder engagement has taken place.  I have been privileged to be invited to attend several meetings and the Upland Stakeholders Forum has been briefed by Natural England.  However, I am not convinced that the feedback that has been provided from these meetings and briefings has been acted on.  There is a feeling that this process has been window dressing and box ticking, rather than meaningful engagement.  On many occasions, I have been presented with the Natural England solution to the issue in a paper a few days before a meeting and asked to comment on it.  This does not feel like a two-way, engagement process to me and appears to be more focused on obtaining external validation to the views that Natural England want to express anyway.

The burning and restoration paper has several 'red line' issues that relate to a stated objective of stopping burning on blanket bog.  I am fully supportive of the principle that burning should only take place where it is going to achieve benefit and that peatland is a sensitive area where burning may not be appropriate.  However, in my view the statements in this draft guidance go beyond the evidence, and I cannot support this as it is drafted.  I believe it to have approached the issues from the wrong direction: it has started highlighting where conflict exists whereas it would make much more sense to me to establish positions of agreement and work from these. The direction of travel set out in this paper can be supported, but the presentation and the final objective goes too far and appears to be aimed at alienating the managers of peatland.  If this is its aim, it has been effective.

I would like to finish this rather lengthy post on a positive note:
  • I fully support the Upland Evidence Review process;
  • Natural England have tackled a difficult job effectively;
  • The 'evidence to advice' phase is a critical part of the process if it is to have long-term value;
  • Much of what has been produced is very valuable; and
  • People with knowledge and experience to enhance that available within Natural England stand ready to help develop the guidance.
The message to Natural England is several fold:
  • Help is available but it must be harnessed into the process that develops the guidance, not kept at arms length;
  • Presenting the solution is not stakeholder engagement;
  • Genuine engagement with stakeholders to achieve partnership working is the only way that we can make progress;
  • Any drive that exists within Natural England to influence the nature of the advice, regardless of the evidence, must be resisted; and
  • All the review documents in the world will achieve nothing unless there is appropriate action on the ground; this requires support and understanding from the managers of the land.
A final thought: it has been muted that there are groups of landowners in Northern England who might on their own initiative be willing to work together to deliver multiple objectives across a large area of land.  What a revelation this could be! Such a group would be able to achieve far more overnight than the current system, with all its expensively produced guidance, could ever achieve.  If Natural England wants to provide long-term, lasting benefits for the uplands of England, ways to support such an approach should be sought.

Natural England might have to sacrifice some control but the benefit to the land, to the communities and the diversity of species could be enormous.

Maybe that is what this is all meant to be about.