Flawed Report, Flawed Policy: Natural England Failure on Heather Burning

Andrew Gilruth
May 8
4 min read

Natural England’s recent evidence review on heather burning was presented as a definitive scientific update. Instead, it stands as a case study in how selective methodology, excluded expertise, and misrepresented findings can produce a flawed and unbalanced document.

This matters because the document is being used by Defra to shape national policy on land management, peatland protection, and burning regulation. This is not just an academic concern, the potential real-world consequences of poor policy based on poor evidence are profound.

If left unchallenged, the policies derived from this report risk causing environmental damage of a far greater magnitude than the government’s own historically damaging policy of cutting drainage ditches across Britain’s peatlands - a practice we now know caused extensive habitat degradation and hydrological disruption.

Weak Methodology Undermines Credibility

Natural England reviewed over 100 studies, yet repeatedly fails to apply rigorous standards to assess quality or context.

For example, the EMBER project is treated as central to the evidence base, despite several significant and long-standing concerns about the project: preexisting differences between the study sites mean that the results were not comparable, those differences were not adjusted for in the analysis, a technique was used which substituted different areas to represent the passage of time (space-for-time approach), and some of the results suggest that there were errors in measurement. These points were published in a peer-reviewed scientific journal yet have still been ignored.

Meanwhile, the University of York’s Peatland-ES-UK project, which employed a robust BACI research study design, and is the only project to study long-term outcomes thus far, is marginalised.

This is a risk because Defra is building national policy on data that would not withstand peer review in any neutral academic setting.

Impartiality Compromised by Omission and Association

Numerous academics point to the exclusion of critical expert voices from the review process. At the same time, authors with direct links to previously contested studies were engaged without disclosure of potential conflicts of interest.

The lack of transparency, both in who shaped the report and what was included, casts serious doubt on the reports objectivity. In such a context, it is highly inappropriate for Defra to treat this document as the basis for blanket national regulations.

Misrepresented Findings Skew the Science

Natural England simplifies or misrepresents complex dynamics, particularly around carbon cycling and vegetation.

For example, Natural England state that 76–80% of aboveground carbon is lost during controlled winter burning. But this excludes compensatory processes like charcoal formation, increased regrowth, and fertilisation from the ash. These points are all well-documented in the scientific literature.

By failing to present a complete carbon picture, the report gives a false scientific basis for banning practices that may, in specific contexts, enhance long-term carbon stability.

Burning Criticised, Cutting Ignored

Natural England consistently frames burning as uniquely damaging, while failing to evaluate the impacts of alternative interventions, such as mechanical cutting, with equal scrutiny.

For instance, the report highlights bare ground exposure as a post-burn concern but completely overlooks the fact that cutting can also result in bare ground. This imbalance distorts the risk to the landscape, potentially pushing policy toward less effective, or even more harmful, interventions.

Wildfire Risk: A Misleading Narrative

The report links managed burning to wildfire risk without adequate evidence. Internal fire authority data suggests out-of-control burns constitute less than 5% of wildfires, and that managed burning can significantly reduce high-risk fuel loads.

Natural England makes sweeping generalisations about the benefits of rewetting peatland to improve wildfire resilience without appreciating the importance of site-specific context and hydrological variability.

Policies based on this distorted logic could restrict beneficial fuel management and increase the risk of catastrophic summer wildfires.

Ignored Counter-Evidence and Published Rebuttals

Despite presenting itself as a comprehensive review, Natural England excludes or plays down key published critiques, responses, reports, and clarifications. These include:

Rebuttals to Gregg et al. on carbon
Alternative reviews (e.g. Ashby 2020) using higher methodological standards
Published critique of EMBER study

Such omissions not only bias the report - they mislead Defra into thinking there is a scientific consensus where there is none.

A Warning from the Past

The UK’s past policy of digging drainage ditches across upland peatlands was based on well-intentioned but deeply flawed assumptions. It led to decades of environmental damage, with degraded habitats, eroded carbon stores, and damaged hydrology that we are still trying to reverse.

The danger now is repeating that mistake - this time not with drains, but with a blanket policy to prohibit controlled burning, driven by equally flawed science.

We urge Natural England to:

Withdraw its report on heather burning immediately.
Commission a fully independent, transparent, and balanced review, with rigorous study quality assessment, input from critics, published conflicts of interest, and fair treatment of all evidence.
Pause all policy development based on this report, until a revised, credible evidence base is available.

Upland landscapes and the communities who manage them deserve policy rooted in facts, not selective interpretation. Let’s not repeat the mistakes of the past – it’s time to use science in a balanced way to produce better outcomes for all.