NEER155: Defra and Natural England Still Have Not Answered the “Rigorous Peer Review” Question

Quick summary

• External expert input did occur.

• Natural England and Defra have not identified the audit trail that would substantiate the stronger phrase “rigorous peer review”.

• By “audit trail”, we mean the records showing what was reviewed, by whom, against what instructions, how comments were dealt with and when the review was completed.

• This matters because NEER155 is being used in policy discussions about burning, fuel management, wildfire risk and stewardship.

The Moorland Association has written again to Natural England and Defra about NEER155, Natural England’s evidence review on the effects of managed burning on upland peatland biodiversity, carbon and water.

This follows the responses we received from Natural England and Defra on 1 July 2026.

The issue is not whether external experts were asked for comments. They were. The issue is whether external expert input is being presented as something more formal, structured and auditable than the records Natural England has so far identified.

Why this matters to moorland managers

NEER155 is more than an academic document: it forms part of the evidence base relied upon for controlled burning policy, fuel management, wildfire risk, stewardship arrangements and the practical management of upland vegetation.

We have explained these concerns in earlier articles on NEER155 and on Natural England’s treatment of the science on burning and wildfire. For land managers, the distinction has real consequences, shaping how moorland is managed, how wildfire risk is addressed, and how rural businesses are regulated.

The audit trail we asked for

The Moorland Association has not asked Defra or Natural England simply to confirm that external experts commented on NEER155.

We have asked whether the stronger public assurance that NEER155 underwent “rigorous peer review” can be supported by a retained, auditable record showing:

1. what reviewers were asked to do

2. which versions or materials they reviewed

3. how their comments were assessed and addressed

4. how independence and conflicts were managed

5. when the external review stage was completed and signed off

That is the audit trail we have repeatedly asked Natural England and Defra to identify.

What the Freedom of Information documents revealed

Earlier this year, Natural England disclosed that it did not hold a number of the basic records one would normally expect to see if a review process is being publicly described as “rigorous peer review”. We covered that here.

Natural England has indicated that the two senior officers involved in the peer-review process have left the organisation, that access to their historic emails is no longer available, and that it cannot provide a complete email trail showing which drafts were circulated, what was expected from reviewers, and how comments were resolved and closed.

Natural England has also withheld draft versions of the report that may show reviewer comments and edits.

The disclosed material also gives useful context. It shows that at least some review input appears to have been limited in scope or provided under time pressure. In one late-stage email, Natural England described the draft as still “drafty”, said some sections were still being reviewed or completed, and told reviewers it was “not expecting further detailed comments” at that stage.

One reviewer stated that they had “just scanned through” the document to look for references to their specialist area. Another wrote that they would not “pretend to have read it end to end”.

A further comment recorded in the disclosed material raised a particularly important point: that the inclusion and exclusion criteria were not described in enough detail to allow the reviewer to “recreate this review”.

The individual reviewers appear to have provided helpful expert input within the constraints they were given, and these comments should not be read as criticism of them — they simply illustrate why the distinction matters.

Helpful external comments on a draft report are not the same thing as a rigorous peer-review process supported by a clear retained audit trail showing what reviewers were asked to do, what they reviewed, how comments were addressed, and when the process was completed and signed off.

That is why this remains an assurance issue, rather than simply a disagreement about wording.

The 1 July replies: still no audit trail

Natural England and Defra responded again on 1 July 2026. Natural England maintained its confidence in the process. Defra stated that Natural England had responded separately and that Defra would not enter into further correspondence.

In our view, those responses do not answer the central question. They restate confidence in the process, but they do not identify the retained audit trail needed to substantiate the stronger public assurance of “rigorous peer review”.

We have therefore written again to Natural England and Defra asking that future public, Parliamentary, regulatory or legal references to NEER155 distinguish accurately between external expert input or external review, and a rigorous peer-review process supported by a retained audit trail.

Why this matters for wildfire and fuel management

This issue sits within a wider concern about wildfire policy and practical land management. Restoration and rewetting have a role, but they are not a complete operational answer to wildfire risk everywhere, and they do not remove the need for practical, site-specific vegetation and fuel-load management.

If policy is going to restrict one of the key tools available to land managers, then the evidence used to justify those restrictions must be open, transparent and properly assured.

What happens next

The Moorland Association will place the relevant correspondence before the Environment, Food and Rural Affairs Committee because NEER155 is relevant to the Committee’s consideration of wildfire policy, land management and evidence assurance.

We will also continue to consider further Parliamentary, departmental and information-rights steps as appropriate.

Published correspondence

In the interests of transparency, and as indicated in our correspondence with Defra and Natural England, we are publishing the relevant correspondence below.

These documents show the questions the Moorland Association has asked, the responses received, and why we do not consider the public assurance of “rigorous peer review” to have been substantiated on the records identified to date.

What members can do

Members should continue to keep records of any practical difficulties arising from the burning licensing system, including delays, uncertainty, refused permissions, impractical conditions, or situations where fuel-load management is being prevented or delayed.

Please also let the Moorland Association know where NEER155, or general claims about the evidence on burning, are being relied upon in discussions about consents, agreements, inspections or policy decisions.

Real examples from members help us show why evidence assurance is not an abstract issue, but a practical one affecting land management and wildfire risk.

You can contact us at info@moorlandassociation.org.

What this means

Members should be reassured that the Moorland Association is not challenging evidence-led policy. We support robust evidence and proper scrutiny.

What we are challenging is the use of evidence in circumstances where important public assurance claims are made but not properly substantiated when questioned.

This work is part of the Association’s wider effort to ensure that upland policy is based on fair, transparent and properly tested evidence, and that the practical knowledge of those who manage the land is not pushed aside by incomplete or overstated official assurances.

Members dealing with practical problems in the burning licensing system may also wish to refer to our separate guidance on how to make a complaint to Defra about burning licence handling.

We will update members again when the correspondence has been placed before the EFRA Committee or if there are further material developments.