NEER155: MA Asks EFRA Committee to Examine the Evidence Behind Natural England’s “Rigorous Peer Review” Claim
- Andrew Gilruth
- 8 hours ago
- 4 min read
Quick Summary
The MA wrote to the EFRA Committee, questioning Natural England's "rigorous peer review" claim for NEER155.
The Committee Chair asked Defra to address managed burning licensing, wildfire risk and NEER155's role in new regulations.
The MA has asked for records proving the peer review process was rigorous, independent and properly audited.
The issue affects wildfire risk, fuel management and land managers' ability to use practical burning tools.
The Moorland Association has written to the Chair of the Environment, Food and Rural Affairs Committee, Rt Hon Alistair Carmichael MP, to provide supplementary material on NEER155, Natural England’s evidence review on the effects of managed burning on upland peatland biodiversity, carbon and water.
The letter has been sent following the Committee Chair’s letter of 7 July 2026 to the Secretary of State for Environment, Food and Rural Affairs. That letter asked Defra to respond to concerns about managed burning licensing, wildfire risk and the extent to which NEER155 informed the updated burning regulations.
In short, we are asking Parliament to look at whether Natural England and Defra can properly substantiate the claim that NEER155 underwent “rigorous peer review”, because that review is being used in policy decisions that affect burning, fuel management and wildfire risk.
Why we have written
This is part of the MA’s evidence-led approach to parliamentary and regulatory engagement.
The point we are raising is narrow but important. Natural England and Defra have referred to NEER155 as having undergone “rigorous peer review”. The MA has asked them to identify the retained, auditable record that substantiates that stronger public assurance.
In particular, we have asked for records showing:
what reviewers were asked to do
which versions or materials they reviewed
how their comments were assessed and addressed
how independence and conflicts were managed
when the external review stage was completed and signed off
We are not disputing that external expert input took place — Natural England has confirmed that external experts were involved.
The issue is that external expert input, or external review, is not the same as a rigorous peer-review process supported by a retained audit trail.
Why this matters to members
Wording matters here because of what follows from it.
NEER155 forms part of the evidence base being relied upon in relation to controlled burning, upland vegetation management, fuel management, wildfire risk and stewardship.
Those policy and regulatory choices affect whether land managers can use practical, site-specific tools to reduce fuel load and wildfire risk. They also affect stewardship arrangements, site management, regulatory decisions and rural businesses.
The MA supports evidence-led policy. However, where evidence is used to justify restrictions on lawful land-management tools, the evidence base and the assurance claims attached to it must be open, transparent and properly substantiated.
That is especially important where those assurance claims are repeated in ministerial, Parliamentary, regulatory or legal contexts.
What has happened so far
The MA first wrote to Natural England and Defra on 18 February 2026 seeking clarification of the basis on which NEER155 had been publicly described as having undergone “rigorous peer review”.
Further correspondence followed in April and May.
On 1 July 2026, Natural England maintained its confidence in the process followed to produce NEER155. Defra stated that Natural England had responded separately and that Defra would not enter into further correspondence about the peer review of NEER155.
In our view, those responses do not answer the central question. They restate confidence in the review 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 any 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 EFRA should see the correspondence
The EFRA Committee is already considering wildfire, managed burning and the practical consequences of the current licensing regime.
The MA has therefore provided the Committee with the relevant correspondence so that it can consider how evidence is generated, assured and relied upon in wildfire-related land-management policy.
Here's what we're actually asking for. We want Parliament to see the evidence-assurance issue, especially where these reviews are used to restrict practical fuel-management tools. We are not asking the Committee to check NEER155's science line by line.
The Committee may wish to ask Defra and Natural England what process is required before an evidence review is publicly described as having undergone “rigorous peer review”; whether written reviewer instructions, response-to-review records and completion sign-off are required; whether those records exist for NEER155; and whether underlying study-quality and validity appraisal material should be available for scrutiny where the review is relied upon in policy.
What happens next
The MA will continue to place careful, sourced evidence before Parliament, Defra, Natural England and other relevant policy forums.
Our aim is to ensure that future decisions on managed burning, wildfire risk, vegetation management and upland stewardship are based on properly tested evidence and workable regulation.
Members who have experienced practical problems with burning licences, SSSI consent, stewardship requirements or other regulatory decisions should continue to send examples to the MA at info@moorlandassociation.org.
The most useful examples are those showing how delay, refusal or uncertainty has affected wildfire mitigation, conservation outcomes, fuel-load management or rural business viability.
Evidence from the ground remains essential.
Documents
The following correspondence has been published in the interests of transparency:
