Written by Henerietta Appleton, Policy Officer (England)
Last week we submitted our response to the North Pennines National Landscape Partnership’s (NPNL) consultation on its draft management plan for the next 5 years. You can download a copy of our response.
Reading the draft management plan raised several concerns not least that the greater focus on Protected Landscapes, which refers to National Parks and National Landscapes (formerly AONBs), in meeting government targets is providing the framework for them to seek to increase their influence beyond existing governance boundaries. The recently released Environmental Improvement Plan 2025 had a commitment to prioritising action in Protected Landscapes: “Enable Protected Landscapes organisations to make land greener, wilder, and more accessible to all.”
This ambition was reflected in the draft management plan for the NPNL with a distinct direction of travel towards greater restrictions on certain management activities. Despite core principles of supporting and rewarding sustainable land management and partnership working. While the outcomes and measures in the draft plan are ambitions and are not compulsory, it is how they are interpreted and adopted that is key. The Levelling-up and Regeneration Act strengthened the duty on relevant authorities (such as local authorities and utilities) to ‘seek to further’ the statutory purposes of Protected Landscapes. This includes relating their functions to the Protected Landscape’s management plan. Indeed, why have these stated ambitions with supporting measures, if you do not intend for them to be considered and delivered?
Consequently, we were particularly concerned by the following:
- The measure to restrict the release or feeding of non-native gamebirds within 500m of sensitive locations (so not just SACs and SPAs), which is in excess of current Defra or Natural England policy. This approach is seemingly based on the negative impacts of gamebird releasing alone and on flawed or anecdotal evidence.
- The lack of joined up thinking between measures. For example, a consideration of wildfire risk and its mitigation not being linked with the desire to increase tree and shrub cover on the peatland edge or the reduction in vegetation management via ending rotational burning* and cutting and reduced grazing. (*Their term which is a policy construct and does not reflect how burning practices have changed on the ground).
- The failure to acknowledge the hill-fringe grey partridge as a “champion” species (NPNL term) given that the NPNL holds some of the most important populations.
- The lack of acknowledgement of the impact of climate change on adaptation measures such as peatland restoration, and wildfire risk.
- The trade-off between access ambitions and nature recovery.
- While there is a desire for engagement with land managers/farmers there is no acceptance of the time and cost of this to them nor an acknowledgement that many of the measures rely on their involvement. The seeming lack of pre-consultation engagement with a key stakeholder/delivery group does not engender confidence that on-going engagement will be genuine.
There was also the mechanism for responding. Given the importance of the management plan, we would have like to have seen an alternative way to comment on the plan, not just the online form. This made it difficult to attach scientific papers etc and to provide a detailed and evidence-based comment. The lack of a single PDF covering the plan was also frustrating. The current trend across government and its agencies towards consultations and calls for evidence being online only is, to my mind, restricting the ability of respondents to provide quality, robust and evidence-led responses. In some cases, the word number is also restricted. Thankfully, this was not the case for the NPNL.
The Forest of Bowland National Landscape Partnership draft management plan is also out for consultation Management Plan 2026-2031: Consultation | Forest of Bowland National Landscape. Anybody in the area who is interested in responding needs to do so by 2nd March. GWCT will be sending in a response.
Whilst the ambition behind such management plans is welcomed, there is a feeling of de ja vu in the measures to support them. The wilder, rewetted mantra that now accompanies upland policy is followed doggedly without any real attempt to adapt it to different scenarios, both climatic and geographic. This top-down approach to land managers and farmers is only going to increase as legally defined targets for nature recovery and net zero get closer. It is important we make it clear to those seeking to influence legitimate, evidenced land management practices the impact that these changes in pursuit of net zero and nature recovery will have. As once they’re gone, they’re gone.