Evidence, Uncertainty and Policy Judgement: Reading the Parliamentary Answer on Moorland Burning

Andrew Gilruth
Jan 6
3 min read

Members may have seen the recent Parliamentary answer from the Secretary of State for Environment, Food and Rural Affairs addressing managed burning. The answer places significant reliance on Natural England Evidence Review NEER155 as the basis for current policy.

It is entirely appropriate that Ministers draw on scientific advice when developing policy. However, we should be aware of several points about how the evidence base has been characterised and how uncertainty and judgement are presented. This is relevant to the understanding the decision-making context.

This note is intended to inform members, not to dispute the role of Ministers in weighing evidence and setting policy.

1. External review and the status of the evidence

The Parliamentary answer refers to NEER155 as having been externally reviewed. That is correct. It is also worth noting what this means in practice.

NEER155 benefited from external expert comment as part of Natural England’s established evidence review process. This improves robustness and transparency. However, it is distinct from anonymous academic peer review through scholarly journals, and does not, by itself, resolve ongoing scientific debate in areas where evidence remains mixed or context-dependent.

Members may therefore wish to distinguish between:

a review that has been externally scrutinised, and
a body of evidence that is universally settled.

2. Position of NEER155 within the wider literature

NEER155 represents Natural England’s most recent synthesis of evidence on managed burning. It is an important contribution, but it is one of several substantial reviews and research programmes in this field.

Other published work has:

reached more nuanced or conditional conclusions,
highlighted strong context-dependence in outcomes, and
raised methodological questions about how different forms of evidence are weighted.

These perspectives coexist within the literature. Members may therefore wish to bear in mind that no single review captures the full range of scientific discussion.

3. Acknowledged limitations within Natural England’s own review

Natural England explicitly recognises a number of limitations of NEER155, including:

geographic concentration of available studies,
challenges in separating the effects of burning from drainage, grazing and historic degradation, and
variability in outcomes across carbon, hydrology and biodiversity indicators.

These caveats are an important part of the review and help explain why conclusions are often expressed in terms of risk and likelihood rather than certainty.

In Parliamentary summaries, such caveats are necessarily condensed, but members may find it helpful to be aware that they form part of the underlying evidence.

4. Evidence, precaution and policy judgement

The Parliamentary answer reflects a precautionary policy approach. That is a legitimate and well-established basis for environmental decision-making.

It may also be helpful to distinguish between:

what the evidence demonstrates conclusively, and
where Ministers have exercised judgement in the face of uncertainty.

Recognising that distinction does not undermine policy; rather, it clarifies where scientific assessment ends and policy choice begins.

5. Consideration of trade-offs and interacting risks

Much of the current debate focuses on the potential impacts of managed burning. At the same time, other risks (including fuel accumulation, wildfire severity, fire service capacity and smoke exposure) are increasingly discussed in related policy and operational contexts.

Members may wish to note that these interacting considerations are addressed in other areas of government work, including wildfire planning and emergency response, even where they are not elaborated in individual Parliamentary answers.

A final observation

This note is not an argument for or against managed burning in principle. Rather, it highlights the importance of transparency in how evidence, uncertainty and judgement are described when policy decisions are explained to Parliament.

A clear understanding of these distinctions helps maintain confidence in both the science that informs policy and the democratic accountability of the decisions that follow.