Natural England’s Selective Memory: The Forgotten ADAS Report

Only by submitting a Freedom of Information request last month have we finally obtained a document that, for reasons still unexplained, Defra did not list among the official responses to the Heather and Grass Burning Consultation.

This is important. Because that document, Natural England’s full consultation response, shows that the agency still regards the 130-page ADAS Report (2011), Conservation of the Historic Environment in England’s Uplands, as valid and relevant evidence.

So we decided to read it. And what it says about heather burning, wildfire, abandonment, and rewilding paints a very different picture from the one presented by Natural England’s recent scientific review (NEER155) and its public statements on upland management.

A Forgotten Duty and a Missing Document

As we have blogged before, Natural England has a clear statutory duty under the Natural Environment and Rural Communities Act 2006 to conserve and enhance not just wildlife and habitats, but also “landscapes and features of the built and historic environment which contribute to the sense of place.”

Yet the ADAS report, commissioned by Defra and Natural England themselves, was effectively buried. It was not mentioned in the recent consultation evidence base, nor in the references supporting NEER155, even though it directly concerns the effects of vegetation management, including burning, on the upland historic environment.

What the ADAS Report Actually Says

The ADAS study reviewed the available evidence, consulted stakeholders, and assessed a wide range of management practices. Its findings are extensive, but several points stand out. They show just how selective Natural England’s current narrative has become.

On Controlled Burning

ADAS described controlled burning as “an important vegetation management tool in the uplands” which can reduce the risk of fire and consequent erosion.

It stated that burning on peat had the potential to cause harm, that is the precise word it used. Potential, not inevitable.

That single word, quietly omitted by Natural England in its current consultation response, changes everything. ADAS did not cite empirical evidence of archaeological damage, only that it was theoretically possible in certain conditions. As such, this was a professional judgement, not a proven finding.

It also recorded that slow, hot fires could damage stone monuments, whereas “fast winter burns”, when conditions are damp, were “generally safe and removed vegetation without harming roots or peat.” In other words, ADAS recognised both the risks and the benefits of well-managed, cool-season burning.

On Wildfire

ADAS explicitly warned that reducing controlled burning could increase the risk of wildfire. Stakeholders interviewed for the study highlighted the catastrophic 2003 Fylingdales Moor fire as an example of the damage caused when managed burning is removed from the landscape (and there has just been another one this year).

In contrast, NEER155 (2025) downplays the role of prescribed fire in wildfire prevention and even suggests that burning may “contribute to ignition sources.” This directly contradicts ADAS’s more balanced, risk-based approach and the lived experience of moorland managers across the uplands.

On Abandonment and Rewilding

ADAS could hardly be clearer:“Re-wilding the uplands is potentially very damaging to the historic environment, particularly if it includes tree planting which could damage surface vegetation and would introduce long-term impacts on underlying archaeology.” Natural England made no mention of this ‘potential’ to be ‘very’ damaging. Just an innocent omission?

It also noted that:

“Recent changes in agricultural and environmental policy have resulted in a reduction in livestock in the uplands and therefore the risk of undergrazing, leading to the development of adverse vegetation cover, is now thought to be the more important issue.

”In short, ADAS foresaw what many land managers are now witnessing, the creeping danger of abandonment and rewilding. This is leading to scrub encroachment, bracken invasion, and loss of open landscape. All the very features that define the historic and visual character of our moors.

NEER155, by contrast, contains not one mention of rewilding, undergrazing, or the loss of heritage value. It treats the uplands as laboratories of vegetation chemistry, not as working or historic landscapes.

On Other Management Practices

ADAS reviewed a wide range of management techniques, concluding that:

• Grazing helps maintain open heath and grassland and prevents damaging scrub growth, but overgrazing can expose archaeology.

• Cutting is a viable alternative to burning if machinery is used carefully, though heavy equipment can cause damage.

• Bracken and scrub cause “physical damage to underground historic interest” and “mask landscapes from view.”

• Water management and rewetting can help preserve peat, but “grip blocking with peat and the use of heavy machinery can also damage archaeological layers.”

In other words, every management practice carries risks, and benefits, that must be balanced. ADAS called for flexibility, local knowledge and adaptive management. Natural England’s recent consultation position, that burning on peat is “generally harmful”, is the very opposite of that.

A Tale of Two Natural Englands

In its private submission to Defra, Natural England quoted ADAS approvingly, saying:

“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... We recommend that amended regulations include reference to the historic environment.”

That line makes it sound as though the ADAS report condemns burning. But in reality, ADAS said something far more nuanced. It identified potential risks under specific conditions, recognised the benefits of controlled burning, and warned against the very policies Natural England now promotes, including abandonment and rewilding.

So, Natural England continues to cite ADAS when it suits its case, but not when it doesn’t. The full report, obtained only by persistence, exposes the selective memory behind its public statements.

Why It Matters

The ADAS report remains a Defra-commissioned document, paid for by the taxpayer, peer-reviewed, and still “of standing” according to Natural England itself. Yet its balanced, evidence-based conclusions have been airbrushed out of the current debate.

It is one more example of how inconvenient evidence has been quietly dropped while Natural England pursues a policy line at odds with its own legal duties and earlier scientific work. When a government agency charged with protecting both nature and heritage overlooks half its mandate, public confidence inevitably suffers.

The Slow Leak of Truth

That Natural England released only a partial version of its response the day before the full Freedom of Information disclosure speaks volumes. Presumably, it hoped nobody would check. Well, we have.

And the more we read, the more it becomes clear that England’s uplands are not just habitats to be regulated, they are living historic landscapes that demand balanced, evidence-led management, not ideology.

The truth is leaking out slowly. But it is leaking, and we will keep shining a light on it.

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