Natural England’s Missing Evidence: FOI Unmasks Contradictory Burning Advice

On 3 October, Natural England published a blog by its Director of Strategy, John Holmes, titled “Natural England’s response to Defra’s consultation on heather and grass burning.”The post presented itself as the organisation’s formal submission and claimed to set out the key evidence underpinning its advice to government.

However, the full consultation response, obtained through a Freedom of Information (FOI) request, tells a different story. It reveals omissions, altered emphasis and missing context that materially change how Natural England’s position appears to the public.

This matters. Natural England’s advice underpins Defra’s regulatory decisions on moorland management. If the public version of that advice misrepresents or overstates the evidence, it undermines trust in the policy process and risks creating regulations that are neither balanced nor effective.

What NEER155 Actually Found

NEER155, Natural England’s evidence review published in March 2025 concluded that:

“The evidence base remains incomplete and context dependent.”

“Results vary between sites and over time.”

“Further controlled experimental work is required to quantify impacts under different site and management conditions.”

In other words, the review did not find conclusive evidence that burning is uniformly damaging. It instead highlighted major evidence gaps and called for more research, particularly controlled field experiments to study long-term and site-specific effects.

What Natural England Told Defra

In its formal consultation response, Natural England stated:

“Managed burning can influence characteristic peatland flora and fauna, water chemistry and the functions of carbon cycling and water regulation.”

It also argued:

“Ceasing burning on peatlands is necessary to restore condition and maximise the full suite of ecosystem services.”

And under Question D1 (Do you have concerns about the impacts of burning on the environment?), it added:“

In the last burning season we received several letters from members of the public concerned about the air pollution impacts of moorland burning... The visual effects of geometric burning plots and plumes of smoke can impact on their special qualities.”

These same passages appeared almost word-for-word in the John Holmes blog, which Natural England published as its “response” to the consultation.

What Was Omitted or Changed in the Public Version

The Freedom of Information release shows that the Natural England blog omitted important qualifications and altered tone and context in ways that matter:

- Scientific uncertainty removed.- Public concerns cast as evidence.- Key recommendation deleted.- Licensing language softened.- Research contradiction introduced (inconsistent with its own review NEER155).

In summary: the released document shows that Natural England itself recognises that controlled burning can have legitimate ecological purposes. For example, managing heather dominance, maintaining open habitat for ground-nesting birds and reducing fuel continuity. That admission directly contradicts the absolutist tone of Natural England’s public statements, which suggest that all burning is inherently damaging.

Comparing the Claims with the Evidence

A direct comparison between Natural England’s policy claims and its own evidence reveals multiple inconsistencies:

Claim made by Natural England in its consultation and/or blog	What NEER155 actually found	Support status
Burning permanently alters peatland hydrology and species composition.	Reported short- to medium-term changes with recovery possible. No evidence of permanent damage.	Overstated
Burning increases dissolved organic carbon and discolours water.	Mixed and inconsistent results.	Inconsistent
Burning releases tonnes of carbon into the atmosphere each year.	Short-term carbon loss; long-term balance uncertain.	Partially supported
Burning makes peatlands more susceptible to wildfire.	Limited UK evidence; some studies show reduced severity.	Contradicted
Lowering peat-depth threshold from 40 cm to 30 cm is evidence-based.	NEER155 contains no reference to peat-depth thresholds.	Unsupported
Cutting and rewetting are sustainable alternatives.	Little comparative evidence; NEER028 warns of peat compaction and archaeological risks.	Speculative
Burning causes air pollution harmful to health.	NEER155 did not assess air quality.	Outside remit

What the Full Consultation Response Adds - and Omits

Cutting is not a universal alternative

Natural England’s full consultation response warns against treating cutting as a one-size-fits-all solution. It cites NEER028, which notes risks such as peat compaction and damage to archaeology.

Burning for restoration

The full response admits Natural England may apply for a licence to burn on its own reserves where this would “accelerate restoration” and where no other viable option exists, a clear acknowledgement that burning can, in specific contexts, aid conservation.

Presumption against research

Despite NEER155 urging more controlled studies, Natural England’s submission argues against licensing burning for research, claiming the evidence base is already sufficient. That stance directly undermines its own call for better data.

Double standards in practice

While discouraging others, Natural England continues to allow burning on its own land. This contradiction raises a wider concern: decisions appear driven by optics rather than consistent science.

Why This Matters

Natural England has statutory duties under the Natural Environment and Rural Communities Act 2006, the Civil Service Code, and the Regulators’ Code to ensure its advice is objective, honest, and evidence-based.

When uncertainty is edited out and selective conclusions are presented as fact, those duties are at risk. This is not just an internal issue, Defra’s regulations rely directly on Natural England’s guidance. If that guidance is skewed, policy itself becomes unbalanced.

The consequences are far-reaching:

• For the environment: poorly designed interventions risk harming the very habitats they aim to protect.

• For science: discouraging research slows understanding and improvement.

• For rural livelihoods: land managers face rigid, top-down rules that ignore site differences and practical experience.

• For public trust: selective communication erodes confidence in regulators and widens the divide between government and those who manage the land.

The Wider Context

The FOI release also shows that burning is listed as a pressure on just 25 Sites of Special Scientific Interest (SSSIs), a small fraction of upland sites. Yet Natural England still permits winter burning on five National Nature Reserves.

This contrast underscores the need for balance: if the practice remains acceptable for Natural England’s own land in specific circumstances, then it cannot simultaneously be dismissed as universally harmful elsewhere.

Transparency, Trust and Partnership

Effective conservation depends on collaboration. When statutory bodies selectively interpret their own evidence, it alienates the very people whose practical knowledge is essential to good environmental outcomes.

Transparency is not a courtesy, it is a foundation for progress. Policymakers, scientists and land managers must work from a shared understanding of the evidence, including its uncertainties. Only then can moorland management policy be both scientifically credible and workable on the ground.

Time for Honest, Evidence-Led Policy

Natural England’s public blog, its full consultation response, and its own scientific review do not align. The omissions revealed by the FOI release show a pattern of selective presentation, one that downplays uncertainty and ignores legitimate ecological uses of controlled burning.

If public bodies expect trust, they must first earn it through openness. The Moorland Association and its members will continue to call for policies rooted in full, transparent evidence, not ideology or convenience.

It is time to end selective science, rebuild trust, and work together to safeguard England’s uplands through honest, evidence-led stewardship.

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