Natural England Must Not Be Both Judge and Jury on Moorland Regulation
- Andrew Gilruth
- 7 hours ago
- 2 min read
“You cannot both design the rules and write the evidence to justify them.”
Trust in Natural England rests on a simple principle: it must provide independent, impartial evidence to government. Yet recent publications show a worrying blurring of roles that risks undermining this trust.
In 2022, senior Natural England officer Alistair Crowle co-authored an article in the ornithology journal Ibis. In it, he argued that if driven grouse shooting declined, alternatives such as sheep grazing or afforestation would not inevitably follow because of existing regulatory constraints. In other words, regulation was presented as the deciding factor in upland land-use futures.
Fast forward to 2025, and the same officer is one of the lead authors of Natural England’s official evidence review on moorland burning (NEER155). This review is now being used to justify tighter regulatory controls on grouse moor management.
Taken together, this sequence creates the appearance of predetermination. First, regulation is presented as the framework through which land use must change. Then, as an official review author, the same individual contributes to the body of “evidence” underpinning the case for greater regulation.
This is not about the science itself. It is about process and integrity. Natural England staff cannot both advocate for regulation and then author the evidence base that government relies on to impose it. That is being both judge and jury.
The Moorland Association is calling for a clear separation of roles. Defra must take the lead on land-use policy decisions, drawing on evidence that is demonstrably impartial and not pre-shaped by the preferences of those producing it. Otherwise, the credibility of Natural England’s advice (and confidence in how our uplands are managed) will be badly damaged.
By the Numbers – Upland Reality in England
Grouse moors generate £121 million a year in local economic activity when grouse numbers permit shooting.
Over 3,000 people are involved on a typical driven day across 58 moors alone (including beaters, pickers-up, drivers and caterers).
The sector spends £7.4 million annually with contractors, much of it with small rural businesses within 20 miles of moors.
In just three years, gamekeepers improved 186,000 acres of moorland (including peatland restoration, rewetting and bracken control).
Gamekeepers’ management supports around 53% of the UK’s curlew population and 42% of lapwings on English grouse moors.
They are also frontline responders: in one year alone, keepers helped members of the public in distress on 1,500 separate occasions.
Moorland communities, gamekeepers and rural businesses deliver huge public and environmental benefits. Policymakers must recognise and safeguard this value, not undermine it with conflicted and unfair regulation.
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