NEER155: Defra and Natural England Fail to Address “Rigorous Peer Review” Question

The Moorland Association is publishing this correspondence because members, Parliament and the public deserve to know whether government policy on controlled burning is being built on evidence that has been checked properly and described honestly.

NEER155, Natural England’s 2025 evidence review on managed burning on upland peatland, is part of the evidence base being relied upon in relation to controlled burning policy, fuel management, wildfire risk, stewardship arrangements and the practical management of upland vegetation. This is not a technicality. It affects how moorland is managed, how wildfire risk is addressed and how rural businesses are regulated.

Defra and Natural England have repeatedly relied on the phrase “rigorous peer review”. We have asked them to identify the paper trail that supports this phrase. To date, they have not done so.

The Moorland Association supports evidence-led policy. But when evidence is used to justify restrictions on land management, it must be open to proper scrutiny.

In brief

We asked Defra and Natural England to show the paper trail behind the claim that NEER155 underwent “rigorous peer review”. Their replies restate confidence in the review but do not identify the audit trail. Because NEER155 is being relied upon in decisions that affect controlled burning, fuel management and wildfire risk, we are publishing the correspondence and submitting it to EFRA’s wildfire inquiry.

What is NEER155?

NEER155 is Natural England’s updated evidence review on the effects of managed burning on upland peatland biodiversity, carbon and water.

The concern is not that Natural England sought external views. It did. The concern is whether the stronger public assurance that NEER155 underwent “rigorous peer review” can be substantiated by a retained, auditable record.

External expert comment may support describing a report as externally reviewed. It does not, by itself, substantiate the stronger claim of “rigorous peer review”. For that stronger assurance to be meaningful, one would expect a paper trail showing:

That is the audit trail we have been asking Defra and Natural England to identify.

What we asked Defra and Natural England

On 18 February 2026, the Moorland Association wrote to Defra and Natural England asking them to explain the basis for describing NEER155 as having undergone “rigorous peer review”. That letter set out why this mattered: NEER155 was being relied upon as part of the evidence base for government policy and had been described publicly in terms that implied a robust assurance process.

We then wrote again on 10 April 2026, following Natural England’s internal review response to one of our information requests. That second letter addressed further issues arising from Natural England’s refusal to release underlying material, including the study-quality and validity scores used in NEER155.

Together, those letters asked Defra and Natural England to identify the paper trail that would substantiate the public assurance of “rigorous peer review”, including reviewer instructions, scope, versions reviewed, response-to-review records, independence checks, methodology assurance, completion/sign-off, and the documentary basis for ministerial assurances.

Why we asked for the paper trail

Our concern arose from Natural England’s own disclosures under a freedom of information request. Those disclosures confirmed that Natural England did not hold several basic documents one would ordinarily expect to evidence a structured peer-review process.

In particular, Natural England said there was no specific brief, terms of reference or guidance provided to reviewers; no review template, scoring framework or checklist; no document defining which materials were subject to peer review; and no documents confirming completion and sign-off of the peer-review process.

The disclosed material also showed that reviewers were at points sent incomplete or evolving drafts, that some reviewers were asked for comments under compressed timescales, and that Natural England was “not expecting further detailed comments” at a late stage.

That does not prove that no useful external expert input was received. It was. But it raises a serious and legitimate question about whether the phrase “rigorous peer review” is supported by the paper trail.

A continuing transparency concern

Members may recall that we previously updated you after Natural England initially refused to engage with our request for records supporting the “rigorous peer review” assurance, citing an “ongoing judicial review”. Later the same day, Natural England’s Chief of Staff apologised and confirmed that the earlier reply had been sent in error.

However, the responses now received from Defra and Natural England still do not answer the central question: where is the retained audit trail that substantiates the public assurance that NEER155 underwent “rigorous peer review”?

Taken together, the sequence of correspondence raises a serious concern that transparency is being avoided or delayed at precisely the point when clarity is most needed.

NEER155 is being relied upon in relation to controlled burning policy, wildfire risk, stewardship arrangements and rural businesses. Members, Parliament and the public are entitled to know whether the evidence base has been described accurately and whether the records exist to support those assurances.

What Defra and Natural England said in response

Defra and Natural England responded on 27 April 2026. Both maintained confidence in NEER155. Defra pointed to external expert input, internal scrutiny, governance checks and Director-level sign-off. Natural England said the review and assurance process followed good practice and rejected the need for corrective action.

But neither response identified the paper trail we asked for. They did not answer the questions about reviewer scope, instructions, versions reviewed, comment handling, independence checks, methodology assurance, or completion/sign-off of the external review stage.

In short, the replies confirm the problem rather than answer it.

 Why this matters to moorland managers now

This matters now for three reasons.

1. NEER155 is part of the evidence base relied upon by Defra and Natural England in relation to controlled burning policy. These policy choices affect fuel management, wildfire mitigation, upland land management, stewardship arrangements, rural businesses and rural livelihoods.

2. The EFRA Committee has launched an inquiry into the growing threat of wildfires. That inquiry is considering how wildfire risks are mitigated through land management, monitoring, and the responsibilities and oversight of government agencies. NEER155 is directly relevant to that work.

3. Natural England has repeatedly refused to release the underlying study-quality and validity scores for NEER155. Those scores matter because they go to how evidence was appraised, weighted and synthesised. That issue is now with the Information Commissioner.

4. At the very time when Parliament is examining wildfire risk and land-management policy, clarity about the evidence base is essential.

If land managers are being asked to change long-established practice, it is not acceptable for government bodies to rely on evidence while withholding, or failing to identify, the records needed to scrutinise how that evidence was reviewed, scored and assured. Policy affecting controlled burning, fuel management and wildfire risk must be based on evidence that can be examined and tested.

What we are doing next

We have now written again to Defra and Natural England.

Our latest letter explains that we do not accept that the 27 April responses answer the central concern. It asks Defra and Natural England to ensure that any future public, Parliamentary, regulatory or legal references to NEER155 distinguish accurately between external expert input / external review and a “rigorous peer review” process capable of being substantiated by the paper trail.

We have also made clear that we remain willing to resolve this constructively if Defra or Natural England can identify the paper trail on which the public assurance rests.

Why we are publishing the correspondence

We are publishing the correspondence now in the interests of transparency. Members, Parliament, policymakers and the public should be able to see the questions we asked, the evidence on which our concern is based and the responses we received.

This is not about rejecting evidence. It is about ensuring that important government policy is based on evidence that has been properly generated, properly assured and properly described.

If a document is described publicly as having undergone “rigorous peer review”, and if that description is used to support policy decisions affecting land management, wildfire risk and rural livelihoods, then the audit trail should exist and should be capable of being identified.

At present, Defra and Natural England have not provided that audit trail. They have restated confidence in the review. That is not the same thing.

Members can be assured that the Moorland Association will continue to challenge policy claims about controlled burning where those claims affect practical moorland management and are not backed by transparent evidence.

The Moorland Association will continue to press for transparency, proper scrutiny and fair evidence-led policymaking on controlled burning and wildfire risk.