So today the minister for @DEFRA introduced a new bill to restrict #managedburning in the #Uplands. It is an idiotically ill-informed and poorly considered piece of legislation that runs this risk of being utterly counter productive (1/n)

The basic premise is that burning on deep (>40cm) #peat *within protected areas* will be prohibited except under license. I will make it clear up front that I actually support a general license scheme and professional qualification for burn management (2/n)

The assumption is that peat bogs are necessarily sensitive to fire and that burning, in and of itself, damages bogs and reduces their ability to sequester carbon. The evidence for that is thin.

Many of the UK's blanket bogs are degraded but tying that to fire alone is tricky as multiple processes are at play not least drainage, atmospheric pollution and grazing (and combinations of the above with each other and with fire)

Let's go with it though (even though undrained intact bogs are highly resilient to fire) and follow through the bill through. There's a number of caveats to the licensing requirement.

First and most obviously it doesn't apply to areas with organic soils < 40 cm deep. Thin organic soils are at greater risk of ignition and fires in such locations tend to be more severe. Burning will become concentrated in these areas despite their lower resilience

Secondly it doesn't apply to areas with slopes > 35 degrees so go ahead and burn freely on steep slopes despite the significantly increased fire behaviour and likelihood of thin soils, increased severity and increased erosion in such areas.

Thirdly it doesn't apply to areas where more than 50% of the area is covered by rock or scree. I don't know what constitutes an "area" (presumably the protected area?)

but once again burn as much as you like on areas where soils are thin, susceptible to ignition and erosion and there are likely to be sensitive species within fire refugia and on the scree itself (e.g. saxicolous lichens and other cryptogams)

If you want a permit it has to be issued by the Secretary of State but presumably this will be managed by @naturalengland who are reportedly declining to provide licenses even for research purposes

Here's what you can get a license for. Basically everything but there's no clarity on how this will be interpreted in practice.

Note the reference to cutting. The legislation contains the implicit assumption that cutting is less "damaging" than burning. So the issue here is not about managing peatlands but about the mechanism to do so

Apart from the stellar work by @AndreasHeinem there is almost nothing known about the ecological impacts of cutting. If memory serves areas subject to cutting had higher CH4 emissions than burned areas so there's going to be complex tradeoffs.

Here's some hypotheses as we push managers towards cutting rather than burning: 1) visually intrusive regular checkerboard patterns appear across the landscapes; 2) dead fuels and brash from cutting accumulate increasing fire risk; 3) complex bog microtopography is damaged...

4) Comparatively shade-intolerant Sphagnum mosses are "mulched" by Molinia and Calluna litter from cutting leading to reduced abundance

Back to licensing though. The Secretary of State quite fairly has the ability to decline license requests but there is no information available on what the grounds for for declining are.

Presumably there will be a presumption against burning without evidence for benefit but what level of benefit is required and what level of tradeoff is acceptable

Other questions. Where does suppression fire sit in all of this? Can the fire and rescue services use fire against fire on deep peat or have they got to get a license? I'm exhausted just thinking about it all

Bottom line. None of this has anything to do with the ecology of fire or does anything to reduce management intensity. This is all about appearances and placating socially-constructed ideas of fire as being "bad". Grow up.

This will just shifts us from one form of management to another while 1) encouraging free use of fire in the least resilient parts of the landscape; 2) increasing wildfire hazard; 3) reducing our ability to maintain resilient, structurally diverse moorland landscapes.

This is a wasted opportunity to improve and, where necessary constrain, practice. Did anyone @DefraGovUK bother to consult on any of this or think it through?