Environment, Food and Rural Affairs CommitteeWritten evidence submitted by the England and Wales Wildfire Forum


Key Messages for NEWP:

Need for greater evidence—to ensure mapping and profiling of wildfire risk across government, landowners, and local communities. Wildfires incidents and their impact are significantly under reported.

Landscape scale working poses opportunities and threats—to building wildfire resilience in forestry system such as woodlands and open habitats.

Increased wildfire from present and future restoration and re-creation of open habitats—due to a poor understanding of wildfire in both lowland and upland areas and principled ecological approaches to its management.

Embedding adaptation into priority species and habitats is critical—and long-term may be more important than protection, conservation and enhancement.

Ensure dynamic and flexible approaches within policy—even if this challenges present interpretations of UK legislation and EU directives.

Building resilience to wildfire—using more resistant species, design planning and appropriate management practices at site and landscape levels.

A risk-based approach to the natural incidents—will ensure an appropriate response, with a focus on preparedness and prevention to reduce the need and impact on response and recovery.

Long term wildfire resilience—by the creation of forestry markets, as part of a green economy and employment, can help reduce vegetation fuels as well as reducing the impact on the taxpayers, especially on open habitats.

Linking together of development planning and land management policy—providing strategic connections to ensure synergies are realised and hazards are reduce to an appropriate level.

Focus on vegetation fuel loadings—in short-term government funding (ie HLS) and long-term biofuel and timber markets.


1. The England and Wales Wildfire Group is made up from the fire and land management sector organisation, covering both public and private organisations. It works with numerous wildfire groups in areas of high wildfire risk.

2. The South East England Wildfire Group represents eleven Fire and Rescue Services and as well as Defra agencies. Its three-landscape scale Fire Operation Groups (FOG) brings together a wider range of both public, private and NGO landowners.

3. Wildfires are vegetation fires that are out of control and affect a range of land uses including forestry, heath and moorlands, agriculture and grasslands across the United Kingdom. Wildfire incidents are natural hazards that require the alignment of numerous factors in order to occur. The majority of wildfires are started by humans and occur due to climate and weather, but the management of its fuel, vegetation, is within our control. The latter’s destiny is in part shaped by government policy.

4. A unique opportunity now exists to rectify this and increase our resilience using the recently published Natural Environment White Paper (NEWP) and draft National Planning Policy Framework (NPPF). For this reason we have chosen to highlight the links and synergies between these two processes to ensure an integrated national approach.

5. In both the NEWP and NPPF are weaknesses and opportunities to increase wildfire resilience and wider natural hazards.

What actions are required across Government Departments, from local government and by civil society to deliver the White Paper’s proposals to grow a green economy and reconnect people with nature?

Too limited focus on natural hazards

6. Wildfire needs to be recognised in the NEWP, along with other natural hazards by government departments, local government and other bodies. Although the NPPF does accept the need to consider planning for adaptation to climate change and promotion of green infrastructure,1 both it and the NEWP restricts their focus on natural hazards to solely on flooding.

7. It is important to note the more holistic approach undertaken by the Cabinet Office’s consultation on natural hazards and national infrastructure,2 especially on wildfire. Ideally any approach should be a risked-based and linked to other sectors such as fire.3 In terms of planning this could be practically achieved by evolving the present toolkit to flooding4 for wildfire, whereby specifying risk areas to both development planning and land management.

Threat to Renewable Energy

8. Responses by both fire and forestry sectors to previous government consultations have highlighted Read Reports5 need for enhanced rural resilience to natural hazards. Without this local renewables and low carbon energy supplies will not be protected. This includes sustainable natural materials and renewable energy systems as well as the infrastructure and utilities used to process and transport them. As the majority of the raw material and infrastructure are to be found in rural locations, they are vulnerable to present or future natural hazards.

Embracing Adaptation

9. It is critical to help reduce the impacts of wildfire that the NEWP strongly promotes a more adaptive future towards species and landscape, as well as habitats. This is partly accepted in NEWP but the focus towards environmental and nature protection is both static and inflexible. The need, to accept change and adaptation, is supported by both the Read Report6 and Natural England.7 Importantly it accepts that at the composition of habitats will change, so “adapting” in high-risk areas is vital.

10. A pragmatic and dynamic approach to habitats, species, heritage and landscapes in NPPF and NEWP landscape scale delivery is now required, future proofing climate-related risks and providing long-term vision, ideal for the land management sector. Stronger consideration should be made to promoting adaptation in NPPF and NEWP. Only where it is appropriate should preservation, restoration and re-creation priority habitats be undertaken. This should be a national priority, as well as helping the transition of priority species as they move in and out of climatic range.

Impact of SR10 on Government Departments and Local Government

11. The present SR10 savings are having a significant impact on wildfire resilience capacity of government departments and local government. Historically National Parks, Forestry Commission, Ministry of Defence’s Defence Estates Foresters and Local Authority Fire and Rescue Services, due to their long-term vision and staffing, played a vital role in building wildfire preparedness and prevention across other government departments and private landowners. Their leadership has been vital in improving the efficiency and effective of wildfire response. The impact of staff reductions risk decreasing national and local wildfire resilience.

What resources will be needed to fully deliver the White Papers’s ambitions and how can these best be provided? Might the value of “services” provided by ecosystems to beneficiaries be translated into spending that will enhance the natural environment?

Knowledge gaps

12. The FIRES seminars8 identified a knowledge gap that appropriate costing tools for ecosystem services especially for non-use regulating and cultural ecosystem services. Using these tools, the indirect costs of a vegetation fire on ecosystem services could be calculated relative to the direct cost of fire-fighting and active fire prevention.

Policy recommendations

13. The FIRES seminars also made the recommendation that economic and social value of all ecosystems should be recognised in relation to wildfires. This includes the calculation of “avoided costs” of damage to ecosystem services to be set against direct costs of wildfire prevention and suppression.

Building resilience to Ecosystem Services

14. In the long-term open habitats, such as upland and lowland heath and moorland, are expected to pose a significantly increased wildfire risk as defined by the UK National Ecosystem Services Assessment9 (2011) and workshops to develop the Climate Change Risk Assessment (2010).10

15. Therefore an increase by so called “restoration” and the re-creation of open habitats will pose serious concerns to future UK resilience. At present this weakness is only being addressed in forest policy by a risk-based approach in the Forestry Commission’s Open Habitat Policy in partnership with Fire and Rescue Services and England and Wales Wildfire Forum.

Market based solutions to reduce fuel loading

16. Critically both the NPPF and NEWP should support and encourage active and sustainable land management and limit the use of non-intervention. For wildfire in the NEWP this should focus on managing vegetation fuel loading. The NPPF could do this by promoting biofuel heating in new development, creating markets for wood residues, chip, pellets and heathland arising. The resulting increase in management would lower fuel loadings at no cost to the taxpayer, move land managers away from publicly funded land management grants and building long term resilience.

Will the institutional framework outlined for delivering the proposals (in particular Nature Improvement Areas and Local Nature Partnerships) be effective? Does the proposed Nature Capital Committee have sufficient powers?

Framework and delivery mechanisms

17. At present there is no detail from Defra in how NEWP’s Local Nature and Green Infrastructure Partnerships (LNP and GIP), as well as their delivery mechanisms, such as Nature Improvement Areas (NIA) and Green Areas, will help build resilience to wildfire incidents and other natural hazards. There is concern that a further layer of designations will increase bureaucracy and red tape.

18. In England, as in the rest of the United Kingdom, the greatest challenge may be embedding greater resilience in both development planning and land management regulators. This is especially the case if they are subject to a more principled view of ecology and/or are vulnerable or sympathetic to single interest lobbying.

19. At present Entry and Higher-Level Stewardship payments for management on high risk lowland heath, especially for grazing, does not provide sufficient safe guards or control measures to build resilience to wildfire incidents.

Landscape scale working

20. As wildfire has no respect of land ownership, the most significant opportunity to address wildfire is at a landscape scale, rather than just within individual sites. This is highly desirable as the risk posed by one land holding may significantly reduce the resilience of another.

21. But wildfire can also take advantage of this as well, with an interconnected landscape of vulnerable habitats increasing in size, scope and impact of incidents. As the landscape approach to management unfolds in response to the NEWP and NPPF, it is important to ensure that appropriate knowledge of wildfire risks is embedded into guidance as well as being suitable financed.

22. This may or may not fit with evolving NIA and LNP areas, overlap or create gaps with other nature conservation, heritage and landscape (UK and EU) designations, so presently their need is questionable from a strategic and operational point of view. We suggest that all designations are reviewed and rationalised first with a framework created before NIA and LNP are implemented.

What further research and/or evidence is required to develop practical programmes sufficiently detailed to deliver the White Paper’s ambition to fully embed the value of nature into policy delivery?

23. The FIRES seminars have identified the following knowledge gaps:

A comprehensive, accurate, spatially robust and accessible evidence base on UK wildfires.

Acceptable multi-discipinary criteria for assessing and measuring fire severity.

Change regional fire regimes.

Appropriate fire regimes.

Synergy and conflict between policies.

Appropriate costings tools for ecosystem services.

Stakeholders attitudes to wildfire.

Improved technical tools for UK conditions: species, habitats, management practices etc.

Knowledge exchange and research partnerships with fire managers.

Further details on the above can be found in the FIRES seminars Policy Brief.11

What evidence is there from other countries that the approaches proposed in the White Paper can be successful applied in practice?

Looking to the future—international good practice

24. As you may expect none of what is suggested above is new. The use of integrated planning policy and land management to reduce wildfire is a common in North America and the Commonwealth of Australia. In Victoria12 and Tasmania13 use a partnership approach across the planning control/development,14 Fire and Rescue Services and Land Management. This effectively embeds integrated approaches into land use planning, habitat management and building regulations, whilst building considerable resilience to all but the most extreme incidents.

What resources will be needed to fully deliver the White Paper’s ambitions and how can these best be provided? How might the value of “services” provided by ecosystems to beneficiaries be translated into spending that will enhance the natural environment?

25. With reference to wildfires the answer across England is dependent upon habitats, landowners, changing climate etc and therefore varies. To build wildfire resilience within the NEWP only a modest, but long-term investment is required.

26. Defra and government should look to invest first in existing government departments and local government frameworks, current partnership (England and Wales Wildfire Forum and local Wildfire Groups) and research networks (eg Forest Research, NERC/ESRC), before creating further bureaucracy in developing and funding LNP and GIP. This will ensure that decision making and spending on ecosystem services is set against national priorities and is cost effective.

Does the White Paper set out an accurate assessment of the barriers to public engagement with the natural environment and make the most effective proposals for re-engagement?

27. We believe the SR10 saving, and its impacts on government departments and local government, must be considered as a barrier to public engagement with the natural environment.

28. Additionally wildfire must be included in the scope of the NEWP to ensure that the management of vegetation fuel is fully considered.

26 September 2011

1 p 43 “Minimise vulnerability to climate change and manage the risk of flooding”

2 Keeping the Country Running: Natural Hazard and Infrastructure http://www.cabinetoffice.gov.uk/sites/default/files/resources/Guide-NaturalHazards-Infrastructure-2011-consultation.pdf

3 “Integrated Risk Management Planning Steering Group Integrated Risk Management Planning: Policy Guidance: Wildfire”. Communities and Local Government. 2008

4 “Planning Policy Statement 25: Development and Flood Management”

5 Combating Climate Change – a role for UK forests: Main Report. An Assessment of the Potential of the UK Trees and Woodlands to Mitigate and Adapt to Climate Change (2009).

6 Accepting that new cultural landscapes will develop in response to the new climate conditions.

7 Climate Change Policy, NE97 Natural England, 2008.

8 Fire Interdisciplinary Research on Ecosystem Services (FIRES): Fire and Climate Change in UK Moorlands and Heaths: Knowledge Gaps www.fires-seminars.org.uk/downloads/FIRES_policy%20Brief_final.pdf

9 Chapter 5: Mountains, Moorlands and Heaths Natural Hazard regulation: wildfire risk

10 CCRA Biodiversity Sector Workshop Record (CEOSA 0901) and Appendix

11 www.fires-seminars.org.uk/downloads/FIRES_policy%20Brief_final.pdf

12 http://www.dpcd.vic.gov.au/planning/plansandpolicies/bushfire-planning-and-building-resource/planning-for-wildfire-protection

13 www.tasman.tas.gov.au/.../files/Busffire_Management_Plan_Guidelines.pdf

14 http://www.buildingcommission.com.au/www/html/2421-new-residential-building-standard-and-your-bushfire-attack-level-bal.asp

Prepared 16th July 2012