Half the Truth: What Natural England Tried to Hide About England’s Past

Photo by Andrew Smith

Last month, the Moorland Association submitted a Freedom of Information request to uncover Natural England’s full response to Defra’s Heather and Grass Burning Consultation. What we found has been revealing and troubling.

While Defra’s website still carries no mention of Natural England’s submission, even though the Environment Agency’s is publicly listed, Natural England quietly published a selective extract of its response the day before the full version was due for release under our request. Presumably, it hoped nobody would check.

Well, we did. And the truth is now clear. Even as Natural England acknowledged that land management can damage archaeological features, it failed to integrate that duty into the wider evidence base or its conclusions. A striking contradiction at the heart of its own advice to Defra.

What the Law Actually Says

Under the Natural Environment and Rural Communities Act 2006, Natural England’s legal purpose is “to ensure that the natural environment is conserved, enhanced and managed for the benefit of present and future generations.” The Act defines the natural environment to include “landscapes and features of the built and historic environment which contribute to the sense of place.”

That means Natural England is responsible not only for wildlife and habitats, but also for the archaeological and cultural heritage that give our uplands their distinctive identity. Earlier legislation, the Environment Act 1995 and the Countryside Act 1968, confirms that “natural beauty” embraces “the physical and cultural heritage which contributes to the landscape’s character.”

Our peatlands, moors and heaths are not just ecological systems, they are archives of human history, preserving ancient trackways, settlements and artefacts. These are landscapes shaped by generations of stewardship and skill.

Natural England’s Selective Acknowledgement

To its credit, Natural England’s response did contain one brief reference to the historic environment. It stated:

“Evidence (e.g. ADAS, 2011; Yorkshire Moorlands Assessment Project, 2010) also shows that burning on peat can cause upstanding stone archaeological features to shatter and become unstable. In addition, subsurface burning can affect buried archaeology and paleoecology. Vehicle access in an emergency (e.g. wildfire response) is another potential cause of archaeological damage. We recommend that amended regulations include reference to the historic environment, in line with the [Heather and Grass Management] Code.”

That short paragraph shows Natural England is aware of its responsibilities and of the potential for damage fragile historic features. Only selecting a few short lines from a 130-page report. More intriguing it only used the few lines that suit its own agenda. More on this soon.

But beyond that isolated statement, there is no evidence anywhere in the supporting review (NEER155) or in the wider response that this legal duty was carried through into its assessment, conclusions, or recommendations. The line feels more like a footnote of compliance than a commitment to action.

The Deeper Omission

Natural England’s flagship evidence review, NEER155, remains narrowly ecological. It contains no discussion of archaeology, heritage or cultural landscape values, despite the clear statutory duty to consider them.

This omission repeats exactly the problem that Natural England’s own commissioned research identified fourteen years ago. The ADAS Report, Conservation of the Historic Environment in England’s Uplands (2011), written for both Natural England and Defra, warned:

“In considering competing interests in the uplands the historic environment is often ignored.”

Fourteen years on, Natural England’s approach has not changed. A single paragraph nodding to heritage does not fulfil a duty established in law.

Why This Matters

Policies built on incomplete evidence risk unintended harm. Peatland rewetting, tree planting and blanket bans on controlled burning can damage or obscure archaeological features, promote scrub encroachment, and increase wildfire risk to both nature and heritage.

When the agency charged with protecting the environment omits half of what the law defines the environment to be, it undermines its own authority and public trust. Natural England’s founding legislation makes clear that the natural and historic environments are inseparable, two halves of the same inheritance. Recognising that only in passing is not enough.

A Slow Leak of Truth

That Natural England released only a partial version of its response on a Friday, the day before the full Freedom of Information release was due, raises uncomfortable questions about transparency. Presumably, it hoped nobody would check. Well, we have.

The truth is leaking out, slowly but surely. Natural England knows the uplands hold the story of England’s past as well as its wildlife. The Moorland Association will keep insisting that policy reflects both, because these are not just ecosystems to be managed, but also living landscapes of memory, work and heritage that deserve the full protection the law demands.

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