Natural England’s Missing Fire Evidence: How Its Report Overlooked the James Hutton Institute’s Key Findings

When Natural England published its updated Evidence Review on the Effects of Managed Burning on Upland Peatland Biodiversity, Carbon and Water (NEER155) in March 2025, it claimed to provide a complete and up-to-date assessment of all relevant research on controlled burning.

That review now underpins Defra’s policy on heather and grass burning, a policy that will shape how moorlands across England are managed for years to come.

But NEER155 omitted a major piece of work: the James Hutton Institute’s Fire Danger Assessment of Scottish Habitat Types. Published two years earlier and funded by the Scottish Government, the Hutton study was clearly within the scope of Natural England’s review.

It examined the interaction between vegetation, fuel load and wildfire behaviour in upland and peatland habitats, the very ecosystems that NEER155 set out to assess.

Its omission matters because the Hutton study findings contradict several of Natural England’s key claims about managed burning and wildfire risk.

What the Hutton Study Found

The James Hutton Institute report was part of the Scottish Government’s Climate Change Impacts on Natural Capital programme. Its purpose was straightforward: to assess current and future wildfire danger across Scotland’s main habitat types, using satellite data, fire-weather indices and land-cover analysis.

Key conclusions included:

• Wildfires are increasing in frequency and extent across moorlands and peatlands. They occur most often in spring, when dead and dry heather fuels ignite easily.

• Fuel build-up is a major driver of wildfire danger. Long periods without management lead to the accumulation of dry vegetation, increasing the risk of large, intense fires.

• Traditional land management helps reduce risk. The report explicitly recognised that controlled (prescribed) burning and vegetation clearance can reduce fuel availability and have been used successfully as tools to lower wildfire risk, particularly in flammable habitats.

• Climate change will amplify risk. Drier and warmer conditions are expected to make fires harder to control, especially in areas where managed burning has declined.

• Wildfire suppression will become more costly and damaging to natural capital, including peatland carbon stores, freshwater systems and infrastructure.

In plain terms, the Hutton scientists concluded that active management, including rotational burning, plays an important role in preventing catastrophic wildfires by keeping fuel loads in check.

This was not an abstract theoretical model. The report was grounded in real fire-incident data from the Scottish Fire and Rescue Service and satellite-derived burn-scar mapping. It found that unmanaged heather and grass build-up, coupled with changing weather, is already pushing moorland fire danger upwards.

What Natural England Claimed

Natural England’s NEER155 covered 102 studies published since its previous 2013 review, claiming to give a full picture of managed burning’s effects. Its findings were heavily weighted toward perceived ecological harms, such as vegetation change and short-term carbon loss.

On wildfire risk, NEER155 stated that:

“There is evidence from other countries and habitats on biomass management by managed burning to reduce wildfire hazard, but limited evidence from the UK peatland context.”

It further asserted that:

“Out-of-control burns are a cause of wildfire in the UK, particularly in the uplands.”

and concluded that while burning “may be used to contribute to wildfire risk management,” the overall evidence base was insufficient to demonstrate that it reduces risk.

Crucially, NEER155 downplayed the role of fuel load and vegetation structure in determining wildfire severity. Instead, it focused on potential ecological side effects of burning, while treating wildfire primarily as a management failure rather than a natural hazard aggravated by fuel accumulation.

The Contradiction

Here lies the core problem.

The James Hutton Institute study, a government-funded scientific assessment using UK data, directly contradicts NEER155’s suggestion that there is “limited evidence” linking fuel load and wildfire risk in peatland systems.

The Hutton study showed that:

• Wildfire danger in heather moorlands depends strongly on fuel composition and dryness, both of which are directly influenced by whether vegetation is managed through cutting or burning.

• Areas with no recent burning experience the highest fire-weather indices and largest burn scars.

• Controlled burning is an established mitigation measure for reducing the severity of wildfires in fire-prone ecosystems.

Yet Natural England’s 2025 review does not cite, reference or discuss the Hutton study at all.

This omission cannot be explained by timing. The Hutton study was published two years before NEER155, well within the review’s search period for “new studies since 2011.” Nor can it be dismissed as irrelevant: it covers upland peatlands and moorlands, uses empirical UK data, and directly addresses the sub-question “Is there a relationship between managed burning and wildfire?” - one of NEER155’s eight stated aims.

By the Hutton study, Natural England effectively ignored the only recent UK-wide assessment that quantifies wildfire danger and fuel dynamics in these habitats.

The result is an incomplete and one-sided evidence base, one that portrays managed burning as ecologically harmful while overlooking its preventive role in wildfire management.

Why It Matters

1. Evidence-based policy demands completeness

Under the Environment Act 2021, public authorities have a legal duty to base environmental decisions on the best available evidence. Defra and Natural England both rely on NEER155 to justify restrictions on controlled burning. If the evidence base is selective or incomplete, the resulting policy risks being unsound.

By omitting a government-funded study whose findings challenge its narrative, Natural England undermines confidence in both the integrity and neutrality of its advice to ministers.

2. Selective science erodes trust

Natural England states that NEER155 used a “comprehensive search” of all relevant studies. Yet the exclusion of the Hutton study, despite its clear relevance, raises legitimate questions about how “comprehensive” that search really was.

When public agencies appear to exclude inconvenient evidence, it damages trust not only among land managers but across the scientific community.

3. Ignoring fuel dynamics increases wildfire danger

Wildfire risk is not theoretical. The 2025 wildfire season caused an estimated £460 million in damage across the UK, destroying peat, wildlife and infrastructure. The Hutton research warned precisely of this trend, linking rising wildfire frequency to fuel build-up where traditional burning has declined.

By downplaying fuel management and focusing solely on short-term vegetation impacts, NEER155 risks encouraging policies that inadvertently increase wildfire severity and associated carbon emissions.

4. Economic and social consequences

Upland communities depend on managed moorland for employment, grazing, and access. When wildfires destroy these landscapes, the cost is borne by farmers, gamekeepers, and taxpayers alike.

The Hutton study explicitly recognised that unmanaged vegetation increases the cost and difficulty of firefighting, an issue already straining public budgets. A balanced policy should therefore support practical fire-prevention tools, not prohibit them on the basis of selective evidence.

Beyond Omission: A Pattern of Selectivity

This is not the first time Natural England has been criticised for selective use of evidence. Its earlier reviews have repeatedly emphasised studies suggesting negative impacts of burning while sidelining research that shows benefits for wildfire mitigation, biodiversity structure, or carbon resilience.

The absence of the Hutton study fits a pattern: conclusions appear to have been drawn first, with the evidence assembled afterwards.

That approach fails both science and policy. Evidence reviews should illuminate complexity, not erase it. Upland management is multifaceted; it involves trade-offs between biodiversity, carbon, water, and fire safety. To focus on one aspect while excluding others misleads policymakers and the public.

The Broader Implications

If Defra now relies on NEER155 to extend burning restrictions in England, it risks basing regulation on a partial record. That could have several serious consequences:

• Higher wildfire frequency and intensity, as unmanaged fuel accumulates on moorlands and peatlands.

• Greater carbon emissions, since wildfires release far more carbon than controlled cool burns.

• Loss of public confidence, as land managers and rural communities see evidence of bias in environmental decision-making.

• Legal vulnerability, because failing to consider the “best available evidence” may breach statutory duties under environmental and administrative law.

Good governance requires transparency. All relevant studies, including those that challenge prevailing assumptions, must be part of the record.

Conclusion

The James Hutton Institute’s 2023 Fire Danger Assessment of Scottish Habitat Types is one of the most relevant recent studies on upland fire behaviour in the UK. It confirms that fuel load, vegetation management and climate trends jointly determine wildfire danger, and that managed burning can play a positive role in reducing that danger.

Natural England’s NEER155 review, published two years later, ignored this evidence completely. In doing so, it presented an incomplete picture that risks misleading policymakers and the public about the true drivers of wildfire risk.

This is more than an academic oversight. It is a failure to meet the standard of balanced, evidence-based policy that the public expects, and that the law requires.

If the government’s goal is to protect both people and landscapes, then all relevant research must be on the table. That includes the work of the James Hutton Institute, whose findings remind us that tradition and science need not be at odds.

Managed burning, when done responsibly, remains one of the few proven tools for preventing catastrophic wildfires. Ignoring that fact will not make it untrue, but it may make the consequences far more costly.

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