We recently sent a letter to the Home Secretary outlining the very real risk of catastrophic wildfires engulfing our moorlands due to Natural England’s restrictions on managing vegetation. You can read the letter here.
The restrictions have led to a significant increase in fuel load, making the moors highly susceptible to wildfires, particularly with climate change exacerbating the situation.
The letter details the devastating consequences of such fires, including the release of harmful pollutants and the potential for loss of life. It also calls for immediate action from the government to prevent this impending disaster.
Please take the time to read this important letter and share it with others.
Dear Home Secretary,
England’s catastrophic wildfires will be blamed on the Home Office
England’s moorlands provide our northern cities with fresh air and landscapes loved for their heather-clad vistas. Yet these treasures will become a national disgrace when massive wildfires sweep through them. This letter explains why these fires will be much worse than the Saddleworth blaze of 2018, threatening urban areas with fumes and flames.
As the minister responsible for the coordination of wildfire issues within government, you will be held responsible.[1] We therefore make a recommendation on what you can do today to avoid our own Los Angeles style tragedy over the coming months.
Huge wildfires are inevitable when vegetation is allowed to grow unchecked. Sooner or later there will be a spark. Add low humidity and strong winds and the horrors of Los Angeles follow. California’s politicians had failed to heed the warning from scientists that the risk of high-intensity wildfires was being increased by a “longstanding policy failure… to counteract the gradual accumulation of flammable organic materials”.[2]
American policy was negligent, here it is deliberate
Yet while the Los Angeles tragedy was down to political negligence, here, growing the fuel load of vegetation was the deliberate policy of the previous government. For many years Natural England has been blocking land managers from reducing the fuel load on moorland. The extension of these restrictions in 2021 immediately led to a further 73% reduction in fuel load management through traditional winter burns.[3] Neither burned nor mowed, the heather, which was already getting too long, has since been increasing year in, year out.
Natural England’s ‘success’, is your problem. Global wildfire experts have said that such is the growth in the fuel load on our moorlands that the intensity of the coming fires will be too great for our Fire and Rescue Service.[4] This was modelled three years ago in a report instigated by the Peak District National Park.[5] It showed “the frightening potential of fire… reaching extremes both in the rate of spread and flame lengths far beyond the capacity of control of the FRS… Little can be done to control the topography of the area or the increasingly fire supportive weather, but fuel loading can be addressed.”
Experts who have studied the dreadful wildfires in Portugal, Greece and Australia say that we too risk these new types of fires with pyroconvection causing flames to leap huge distances as they generate their own, unpredictable and highly dangerous winds.[4]
The flames will only be part of the problem. Since much of the fuel load is accumulating above areas of deep peat, these carbon stores will belch poisonous smoke for months. We consider Natural England’s current policy of adding fuel to the coming fires is absurd.
Adding fuel to fires is absurd
Given that the experts are shouting, why has Natural England been so deaf? Partly it is due to its fixation with minutiae instead of major policy concerns. We empathise with your cabinet colleagues’ irritation about Natural England’s pettiness over bats and newts.[6] In the case of moorland management, it has buried itself in micro-regulating decisions about where and when to remove vegetation through mowing or winter burns and how rewetting moors can help moss grow. These are issues where people working in the hills are much better positioned to understand what nature needs than officials in glass offices - especially since the science is limited.[7]
The driving force behind this micromanagement is ideological antipathy to grouse shooting - something Natural England shares with its soulmates in the RSPB. The Times has written about how it “twisted” the science over wildfire risks due to its attempts to stop people game shooting.[8] The ensuing tedious overregulation is designed to make grouse moors uneconomic and replace them with the rewilding religion, which make wildfires worse.[9]
Yet this focus on small things, is distracting policymaking from the big issue of how climate change is rapidly amplifying the wildfire risk in the UK.[10] Relative humidity has dropped sharply since 2000 which is causing plants to dry out faster during hot summers.[11] Equally, UK winters are getting warmer and wetter which fosters vegetation growth.[12] The Guardian has explained how in Los Angeles these climate factors added to the fuel load.[13] Here the number of high-risk days for wildfires could quadruple by 2080.[14]
The other overwhelming concern is the harm caused by fires. The Saddleworth disaster in 2018 saw five million people breathe in pollution which included lead and cadmium deposited on the moors during the Industrial Revolution.[15][16] Scientists say dozens died early because of the fumes.[17] There was also the release of huge quantities of carbon from the deep peat catching fire.[18]
Natural England misled ministers
It is disturbing that Natural England has misled ministers by claiming that this fire started at a location where winter burning of heather was taking place.[19] The fire ignited on land where Natural England had a de facto ban – the heather could only be burnt once every 23 years.[20] With the heather growing three inches a year this created such a fuel load that, when the inevitable fires came on both Saddleworth Moor and nearby Winter Hill, the Fire and Rescue Service simply could not cope. Irreparable damage was done to the sub-surface peat, when the purpose of the ban on winter burning had been to prevent such damage.
That was 2018. Now, with so little of the traditional fuel load reductions and firebreaks created by winter burns, it has become a question of when, not if a megafire erupts – a fire far too big for government to extinguish.[21]
Last year’s Parliamentary briefing on wildfires [22] explained that “older heather burns with greater intensity” and that to prevent wildfires “vegetation management must be conducted continuously”. Not every 23 years.
Also of note is the Scottish Parliament’s hearing on the issue where the Scottish Fire & Rescue Service warned that mowing excess vegetation can “leave a dry layer that actually encourages the spread of fire” whereas winter burning “is by far the most effective because it removes a fuel in its entirety”.[23]
We therefore recommend your government immediately instructs Natural England to make unfettered preventative licences its default position and for Defra to issue them within a week of request.
It is deeply troubling that neither body has a single in-house wildfire expert. This is why they come up with flawed alternatives such as mowing and planting sphagnum moss – the latter often becomes so dry as to serve as tinder for any spark.
It also worries us that the National Trust in Howden and the RSPB at Geltsdale have allowed their moorland vegetation to overgrow to the extent that fires could threaten vast tracts of land around them. When dangerous fuel loads exist in urban areas, fire services feel empowered to intervene. We ask you to make clear through legislation that rural fuel loads must also be reduced to safe levels.
Gamekeepers and farmers are passionately committed to preventing wildfires as it is their land that gets destroyed. And it is their lives put at risk, as they are invariably at the front-line fighting these fires. Unless your government’s restrictions on vegetation management are reversed, ministers will have to pray for the wind not to blow towards their constituencies and that no one gets killed in the fire’s path.
Yours sincerely
Andrew Gilruth
Chief Executive
Moorland Association
Sources
[1] Home Office responsibilities. See 3.2.1 & 3.2.2 within the Wildfire Framework for England: https://fireengland.uk/sites/default/files/202112/211220%20Wildfire%20Framework%20for%20England.pdf
[2] America’s policy failure. See Wildfire Management in the United States: The Evolution of a Policy Failure: https://onlinelibrary.wiley.com/doi/full/10.1111/j.1541-1338.2004.00066.x
[3] 73% decrease: an RSPB funded study said that there was a 73% reduction in areas being managed by burning or cutting in the immediate aftermath of the Natural England ban on burning imposed under the Burning (England) Regulations 2021. See “Annual extent of prescribed burning on moorland in Great Britain”: https://zslpublications.onlinelibrary.wiley.com/doi/10.1002/rse2.389 NB the model was unable to “fully separate burning from cutting on moorland” meaning that neither method of reducing fuel load was taking place in the 73% of land where excess vegetation was previously being managed.
[4] Wildfire experts. See presentation by Mark Castellnou, Fire Ecologist University of Lleida (Spain) and fire officer in the Catalan Fire & Rescue Service to the Wildfire Impact, Risk & Mitigation Workshop (18 Jan 2023) chaired by Lord Deben, then chairman of the Climate Change Committee. Pages 25-30: https://www.gwct.org.uk/media/1381625/GWCT-Wildfire-workshop-report-and-proceedings-web.pdf
[5] “frightening potential”: See Peak District National Park report page ii: p2 https://www.peakdistrictwildfire.co.uk/_files/ugd/9c9ad7_a594c151525a4878a241bac12e93d409.pdf
[6] Starmer and Rayner concerns about excessive environmental regulations: https://www.left horizons.com/2024/12/28/starmer-blames-bats-and-newts-but-who-are-the-real-blockers/
[7] The limited science over methods of vegetation management is discussed in “A Critical Review of the IUCN UK Peatland Programme’s “Burning and Peatlands” Position Statement”: https://link.springer.com/article/10.1007/s13157-021-01400-1
[8] Scientists accuse RSPB of having “twisted” scientific data: https://www.thetimes.com/article/rspb-twisted-data-in-campaign-against-grouse-shooting-qwhl6wb83
[9] Rewilding increases wildfire risk. See page 40, Table 5.1, Sustaining Ecosystems 2022: https://www.gwct.org.uk/media/1319617/Sustaining-ecosystems-English-grouse-moors-LR.pdf
[10] Wildfires and climate change. See page 2, Parliamentary Office on Science and Technology briefing on wildfires: https://researchbriefings.files.parliament.uk/documents/POST-PN-0717/POST-PN-0717.pdf [11] Relative humidity in the UK has fallen sharply since 2000 https://climate.metoffice.cloud/humidity.html#:~:text=While%20there%20is%20now%20more,%5D%20%25rh%2010yr%2D1. See also that 40% humidity is the wildfire threshold: https://www.gov.scot/publications/fire-rescue-service-wildfire-operational-guidance/pages/15/
[12] Met Office predicting 30% wetter winters https://www.metoffice.gov.uk/weather/climate-change/climate-change-in-the-uk See also: UK winters getting warmer and wetter: https://www.carbonbrief.org/analysis-how-uk-winters-are-getting-warmer-and-wetter/
[13] LA fires came after wet winters, which had caused “vegetation to sprout” adding “literal fuel to the fire” were followed by drought and low humidity: https://www.theguardian.com/us-news/2025/jan/08/fire-map-la-palisades-explainer
[14] Danger days for UK wildfire risk could quadruple by 2080: See Box 3.1 on page 12 in “The Third UK Climate Change Risk Assessment Technical Report”: https://www.ukclimaterisk.org/wp-content/uploads/2021/06/CCRA3-Chapter-3-FINAL.pdf
[15] Saddleworth fire exposed 5 million to dangerous pollution: https://www.bbc.co.uk/news/uk-england-manchester-52208610
[16] Saddleworth pollution included lead and cadmium: “because of extensive toxic fallout from factories a century ago… “There’s 100 years’ of pollution buried along with the peat as it formed,” says [Professor Hugh] Coe.” See New Scientist: https://www.newscientist.com/article/mg23931853-300-smoke-from-moorland-wildfires-may-hold-toxic-blast-from-the-past/
[17] 28 premature deaths: “over the 7-day period 28 (95% CI: 14.1-42.1) deaths were brought forward, with a mean daily excess mortality of 3.5 deaths per day”: https://www.researchgate.net/publication/340286590_Impact_on_air_quality_and_health_due_to_the_Saddleworth_Moor_Fire_in_Northern_England
[18] Carbon released. Centre for Ecology and Hydrology estimated that the 2018 Saddleworth Moor wildfire released half a million tonnes of carbon dioxide into the atmosphere (Martin 2018). Equivalent to yearly CO2 emissions from over 100,000 cars. See p8: https://ippr org.files.svdcdn.com/production/Downloads/nan-valuing-our-northern-uplands.pdf
[19] Saddleworth fire blame risk: Natural England claimed that “The majority of the fire (c.800 ha) took place on the Stalybridge Estate which is managed by rotational burning for driven grouse shooting.” See Section 2, Table 8.1 in Appendix 8: https://publications.naturalengland.org.uk/publication/4741162353295360
[20] Natural England say that the Saddleworth fire started at https://w3w.co/grub.slams.dart The headkeeper says it started nearby at https://w3w.co/violinist.circular.speakers . Both spots are in an area which Natural England only allowed to be burnt once every 23 years. This Natural England ban is documented under the agency’s 2014 Higher Level Stewardship plan for this moor.
[21] Locations where the fuel loads already are already higher than the Fire and Rescue Service can fight. See the 2022 Peak District Wildfire Risk Assessment, at pages 85-98: https://www.peakdistrictwildfire.co.uk/_files/ugd/9c9ad7_a594c151525a4878a241bac12e93d409.pdf
[22] “older heather burns with greater intensity”. See page 11, Parliamentary Office on Science and Technology briefing on wildfires: https://researchbriefings.files.parliament.uk/documents/POST PN-0717/POST-PN-0717.pdf [23] Scottish Fire Service says burning excess vegetation is “most effective”: https://www.gwct.org.uk/blogs/news/2023/june/the-wildlife-management-and-muirburn-(scotland)-bill-expert-insights-in-scottish-parliament/