Wemmergill Moorland Plan

Hen Harrier Marc – last known fix. Image: RSPB

Wemmergill Moor is where a young Hen Harrier ‘disappeared’ in February – the latest of so many.  It is also the first site where NE agreed a Moorland Management Plan with the estate.

These MMPs are the response of Defra and NE to the fact that they have been told by the European Commission that their implementation of the Habitats Directive has been inadequate and that ‘we’ in the UK must properly protect this priority habitat and not let grouse moor owners damage it by burning.  This news has not yet been announced by either the European Commission nor Defra because there are a few loose ends to tie up (!) but it is the reason why NE has been agreeing these MMPs.  They are a vehicle for the regulator, NE, to withdraw consent for damaging burning which they have erroneously been allowing for years.

Thus, and I will say this very slowly, the…whole…point…of…the



But we have already seen with the Walshaw Moor version (which is confusingly called a Catchment Restoration Plan) that the plan is a give-away to the estate, allows burning to go on almost as now, and drives a coach and horses and a 5-km track through the blanket bog it is meant to protect. I also suspect that the Habitats Regulations Assessment for Walshaw Moor was influenced by political direction from on high after completion by expert staff but we’ll see when NE releases the two relevant versions of the document.  So, rather than a clamping down on habitat damage, the plans look like they are a vehicle for allowing intensive grouse shooting estates the ability to carry on regardless and indeeed do a bit more industrialising of our uplands.

How does the Wemmergill MMP shape up?


Here is a link to the plan on the Moorland Association website. First, and just in passing, you’ll struggle to find any mention of birds of prey in this document, which in the light of recent events is a shame. At least mentioning that Wemmergill would be a great place for Hen Harriers to come and be cossetted by the estate would have alerted local people to this bird and might have galvanised them now into action to trace the missing Hen Harrier ‘Marc’ and uncover any dark deeds that may have happened.  Maybe when the plan is renewed in 2042 then? Obviously no rush, no rush at all.

NE were in a strong position to get whatever they wanted through this plan as the HLS agreement expired on 31 January, as did, I believe, the burning consents, and so the estate had nowhere to go if NE put its foot down. But NE did not put its foot down over burning. My understanding is that this new agreed plan (the point of which is outlined in red above) will not limit the amount of burning that the estate can do at all. There is basically no area of blanket bog on Wemmergill that is pristine and so none of it falls into the category of ‘can’t be burned’. Instead it all falls into the amber category and can be burned. This is a massive cop-out and unless I have misunderstood things badly, which is of course possible, means that blanket bogs are no better protected now than they were before this plan. If that is the case, then the plan is a con.

Here is an image of a minister looking happy even though her statutory agency has sold nature conservation down the river, and opened up the possibility that the EC will come down like a ton of bricks on her department, her boss and her government, and a director of the estate and its Head Gamekeeper who may well be smiling because they have got away with it and now have a government minister looking pleased about them getting away with it!

A grouse shooter’s moll and Defra minister. Photo: Natural England

There are other bizarre aspects of these plans.  First, the ability to burn heather on blanket bogs to control Heather Beetle – why?  The supposed point of burning the heather on blanket bogs is to get rid of it to restore those blanket bogs with their mosses so why not let the Heather Beetle do its worst?  Very strange!

Second, the plan talks about ‘heather protection ridges’ which are a new one on me. The photographs show them to be another rather nasty way of mucking about with decent habitat – have a look at pages 50-52 (p52 shows how spectacularly ugly these are!).  And if these don’t exacerbate water loss from blanket bogs then I’d be very surprised. Heather protection ridges look like they are accompanied by drainage ditches to me! They look awful and are a further industrialisation of our moorland, sanctioned by the statutory agency which should be protecting both its landscape value and wildlife value.  I bet you that we’ll see more of these in other MMPs and that they are one of the next ways that moorland owners seek to wreck the uplands.

Third, new tracks!  The Wemmergill tracks aren’t as long as the Walshaw Moor ones but moorland owners are clearly being allowed to use these MMPs (read the red words above again) to build more tracks that are for the benefit of grouse shooters but to the detriment of the environment.

Fourth, just have a look at the agreed vision at the front of the document. Does this sound like a regulator acting for the public good and putting its foot down? No, everywhere that blanket bog is mentioned there is a caveat which amounts to putting grouse shooting on a par with habitat protection. It’s NE’s job to protect the habitat on our behalf and according to the UK’s international legal responsibilities – not to fudge things for the benefit of the hobby of shooting Red Grouse for fun.

Michael Gove is being made to look like a fool by his own statutory nature conservation organisation. He must be thrilled.




19 Replies to “Wemmergill Moorland Plan”

  1. Mark,
    my question would be that there can’t be that many keepers employed to cover said area during the time in question, right? One? Two? Three maybe?

  2. It’s very easy to see that the last location of Marc is right in the centre of the map in the agreed infrastructure map. No, really!!!
    Raptors are mentioned.
    “… works should not take place within 200m of the nest until the young have successfully fledged and left the nest.”
    That of course is just below a photograph of a huge digger bucket, if you have difficulty finding it in the text.
    Is there a way this can be challenged, together with any other productions from the Moorland Association, in cooperation, if that is the word, with Natural England.

    1. Yes Merlin and Short-eared Owl are mentioned in passing and there is a photo of an un-captioned Red Kite.
      The fact that, as RPUK points out, Wemmergill ‘is also part of a Special Protection Area (SPA) designated specifically for hen harriers‘ gets no mention in the plan. I wonder why?
      Perhaps it has something to do with the fact that 2 Short-eared Owls were shot and buried here in 2015.
      Are the RSPB going to do something about all this?

  3. For fuck’s sake!
    ‘Areas of acid grassland (‘white moor’) will be sprayed off with glyphosate (‘round up’) and
    seeded with an appropriate moorland seed mix, including heather, to regenerate or create
    upland heathland habitat for grouse moor \ nature conservation purposes’

  4. What can one say the whole business of Moorland Mangement Plans produced by Natural England and, of course, this Government standing right behind them, is rotten to the core. One day hopefully there will be a change of Government and this whole rotten business will be swept away.
    However, we must congratulate you Mark for your great efforts in highlighting all these moorland abuses and for your determination and perseverance. One day thanks to you ,we will make moorlands a much better place for wildlife.

  5. Mark the ‘Infrastructure works within 200m of breeding location of raptors’ section (page 31 of the MMP) states ‘no works within 200m of nesting birds (presumably raptors) until young are fledged. This is much closer than allowed for other works, e.g. wind farm construction, and also contradicts research. It also doesn’t mention disturbance of breeding waders. another sop to the industrial grousers. See http://www.snh.org.uk/pdfs/strategy/renewables/birdsd.pdf (e.g. page 91 for HH and page 134 for merlin. Short eared owl is less studied but stated as 100m-600m, page 164).

  6. Mark just watching a programme on salmon in rivers and how they have declined and how they need extensive clean river gravel for laying their eggs. Of course, with with the burning of moorland heather and the much more rapid water run off due to drainage, this will not only cause flooding but also lead to increased sediments in our rivers and hence may well be a cause for salmon decline.
    Just a point worth considering.

    1. I’ve lost count of the number of times I’ve contacted angling organisations and clubs about the EMBER study from Leeds University that underlines the damage you mention and so much else, virtually no response. There’s potentially major conflict between two branches of the field sport sector that’s only being made infinitely worse politically by the clear avoidance in dealing with the issue by those paid to represent anglers – these are the same people who make hysterical accusations about beaver threatening salmon and have called for the control of everything from mergansers to seals, yet they’re not bothered about their pals in tweed killing off streams.

  7. I’ve certainly watched (and badly photographed) short eared owls quartering alongside the road from Brough to Middleton in the past – have got a feeling it may well have been the pair that were later shot (or met the same fate that year).
    It’s a rarely visited spot, which will enable the illegal shooting to go on (not far from Hannah Hauxwell’s lonely old farm) but well worth the drive/detour if you’re up this way.

  8. “It’s NE’s job to protect the habitat on our behalf and according to the UK’s international legal responsibilities – not to fudge things for the benefit of the hobby of shooting Red Grouse for fun.”

    I think this is where you are out-of-date, Mark.

    The “job” of Natural England was subverted by – not the Tories nor the Coalition Government – but the Labour Government. Look up the Hampton Principles, as commissioned and implemented by Tony Blair…


    2 A year later (2005) Philip Hampton published his report, ‘Reducing administrative burdens’, in which he set out his vision for a risk-based approach to regulation. He argued for the creation of a regulatory system, at both a national and local level, in which risk assessment was the basis for all regulators’ enforcement programmes. The Government accepted his recommendations in full.

    4 A key pillar to achieving this is to remove the burden of unnecessary regulation and
    old style routine inspection and enforcement

    5 It is also no longer true that most businesses, if unregulated, will act irresponsibly.

    7 For example, since the Hampton report, the Environment Agency’s risk-based assessments have led to a 20 per cent reduction in the number of inspections and this is set to increase as their risk-based system is extended across their regulatory regime.

    9 Regulators should recognise that a key element of their activity will be to allow, or even encourage, economic progress and only to intervene when there is a clear case for protection

    6.14 The five principles of good regulation (regulation should be transparent, accountable, proportionate, consistent and targeted) provide a baseline standard for regulators, while the code of practice provides a more detailed set of principles for regulators to have regard to.

    This two-pronged approach provides the Government with the levers to achieve the culture change that Hampton recommended, and ensures regulators are making the necessary behavioural changes in order to be Hampton compliant before the Code comes into effect.

    I believe the above opened the door for unscrupulous civil servants and politicians to collaborate with their developer and land-owning friends against the interests of wildlife…

    It certainly exposed Natural England to having to consider the economic consequences of their actions – and not just to consider the protection of valuable habitats – when Natural England have no economic expertise to call upon with which to counter-argue.

  9. Talking to a birder two weeks ago she said her father was a beater there. He had being doing this sinc he was a teenager. He stopped doing this last year, not because he was eighty but what was happening to the moorland and wildlife. Sadly after she had gone i had an afterthought,wouldn’t it have been nice to have met him. Im sure he could have given me some nice info. Hope i bump into her again.

  10. It would be really interesting to compare this plan with the previous consent(s) and see if it allows burning to be intensified.

    Is this really the best NE can manage?

  11. A question to both Mark Avery and Chris Packham. It is quite clear that your are both left wingers whos primary objective is to end all shoiting starting with grouse shooting as it fits the left wing agenda of moors range rovers shot guns tweeds etc. just like hunting did with Labours left wing of hounds horses country houses.

    As you both blame game keeprs for every disappearancesof any bird of prey so you can further your anti shooting agenda and should you ever be successful it could result in a tit for tat whith all hen harriers being killed as well as other birds. So what would you actually have achieved with your anti class ridden agenda? Their would be no grouse no hen harriers etc. You both would be better off spending your time working with the shooting community rathetr thsnnuding them and birds of prey to further both of your political left wing agends.

    1. mike – no point asking Chris questions here, it’s not his blog is it?

      As for me:
      1) I am a left winger and a member of the Labour Party, which I don’t hide and is actually mentioned here https://markavery.info/home-2/about/ The political party which is against all ‘bloodsports’ is the Green Party. Unfortunately the Labour Party isn’t very good on nature conservation and, as far as I can tell, hasn’t yet made up its mind what it thinks about driven grouse shooting. I’m a Labour member much more for my left wing extremist views on wanting fairness and equity, supporting the NHS, believing in internationalism etc rather than there being any Labour agenda on shooting etc.
      2) my aim is not to end all shooting, my aim is to get driven grouse shooting banned. I’ve said that loads of times and I’m happy to say it again. Thank you for giving me the chance to say it again.
      3) I do not blame gamekeepers for every disappearance of every raptor – could you provide evidence that I do? But you’ll be aware that most convictions (not cases or prosecutions, but convictions) for wildlife crime against birds of prey are indeed of gamekeepers rather than writers, nurses or bus drivers.
      4) I guess your fingers must be cold because there are a few typos in your comment

      1. There’s nothing these scumbags deserve more than a good, old-fashioned thsnnuding!

    2. So can you explain why in areas of grouse shooting hen harriers have practically disappeared (England when there is room for over 250 pairs) or have started to decline in numbers again (Scotland) and why birds of prey with satellite tags like eagles and harriers disappear over grouse moors? Can you explain why in Northern England (United Utilities land) places where there were lots of breeding peregrine falcons now have none? And how come all the prosecutions that have been successful (and many cases that have to public disgust not been pursued) have all involved gamekeepers? Who has most to gain from killing raptors and mountain hares and bulldozing roads through moorland for the 4 x 4s of the shooters? who has the most to gain from subverting government bodies which once protected nature? Nobody is against people because they wear tweeds or have shotguns, but everyone is against individuals and organisations that use their wealth to degrade landscapes and detroy wildlife. WE all know who they are. The questrion bnow is stopping them.

  12. I have been on Wemmergill and have spoken to the keepers up there and they are rightly proud of the success of THEIR hen harriers breeding and of the other ground nesting birds that thrive because of their efforts. The way the moorland is managed to support grouse shooting has massive benefits to other wildlife, including hares.
    I also walk on other moorland, where grouse shooting, and therefore keepering, has been stopped, and it has become a barren and sterile wasteland. All the grouse have disappeared as have all the other ground nesting birds and there are no raptors at all. The heather has reverted to grassy hag and even the flora have declined dramatically. The underlying peat no longer is able to act as the carbon dioxide sink and this adds massively to global warming. The only wildlife to be seen are crows and magpies and a few rabbits. The corvids prey on young lambs and cause untold harm.
    You are totally misguided and blind to the facts; the massive benefits that good gamekeroershave on the moorland environment.

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