Who Decides What “Good” Moorland Looks Like?
- Andrew Gilruth
- 1 day ago
- 6 min read
Natural England’s report Definition of Favourable Conservation Status for Blanket bog helps define what “good” looks like for blanket bog in England. That matters because it can influence how moorland is assessed, what restoration targets are set, what management changes are expected and how land managers are judged.
We have asked Natural England to carry out an internal review of its response to our Environmental Information Regulations request about how this report was produced and approved.
The request is narrow. It does not ask for every draft, every email or all underlying datasets. It asks for the audit trail showing how this important document was quality assured, reviewed, approved and published.
Why these documents matter
Natural England’s Favourable Conservation Status (FCS) documents are not academic exercises. In practical terms, the blanket bog definition helps set the benchmark for what Natural England regards as “good” condition for blanket bog in England.
That matters to land managers because it can influence how moorland is assessed, what restoration objectives are set, what management changes are expected, and how estates are judged by regulators, advisers and public funding schemes. It is therefore part of the framework by which upland land management may be evaluated, not simply a technical publication.
The blanket bog definition was also published alongside Natural England’s updated evidence review on managed burning on upland peatland biodiversity, carbon and water, NEER155. Natural England describes NEER155 as an update to its earlier evidence review, drawing on 102 studies and considering biodiversity, carbon, water quality and hydrology.
The Moorland Association has separately raised concerns about the documented basis for Natural England’s description of NEER155 as having undergone “rigorous peer review”.
Those concerns are set out in our earlier blog, Burning Report: How Rigorous Was Peer Review? The point here is similar but separate: where Natural England documents are used to shape policy, regulation and land-management expectations, the assurance process behind them must be capable of public scrutiny.
These documents sit within a policy environment where very large sums of public money are being committed to peatland restoration and land-management change. The Government’s England Peat Action Plan said it intended to invest over £50 million in peatland restoration by 2025, with the Nature for Climate Peatland Grant Scheme managed by Natural England.
The same programme and related schemes influence real land-use decisions by farmers, land managers, conservation bodies and public authorities.
When taxpayer money, regulation and Defra policy are being shaped by technical evidence documents, it is only right that the underlying evidence base and governance process are transparent.
What the Moorland Association asked for
The Moorland Association asked Natural England for a small, clearly bounded set of process records for the blanket bog FCS report, including:
the publication approval or workflow record
the completed QA or peer-review checklist, or equivalent record
the governance record showing Technical Steering Group or equivalent oversight
and a metadata-only version list.
Natural England has now provided a response and four internal sign-off emails. However, having reviewed those papers, we do not believe the response yet provides the full audit trail that Natural England itself says exists.
We have therefore requested an internal review.
What Natural England disclosed
Natural England’s response states that two QA Review Forms were completed for the blanket bog FCS report. It also says that additional specialist comments were provided directly on the draft definition record.
But those QA Review Forms and specialist comments do not appear to have been provided to us, nor does the response clearly explain why they have not been disclosed.
This is important. The question is not whether Natural England says QA happened. The question is whether the public record shows what QA happened, who reviewed the evidence, what comments were made, and how those comments were resolved before publication.
Records identified but not disclosed
Natural England’s response refers to a number of records which appear central to the audit trail, including QA Review Forms, specialist comments, publication workflow records and Technical Steering Group records.
However, the documents disclosed to date appear to consist of the response letter and four short sign-off emails.
That leaves a significant gap between the process Natural England says took place and the records that have so far been made public.
Technical sign-off after changes to the definition
There are also questions around the governance route.
One email from July 2022 says the favourable values had been changed since an earlier sign-off “a few years ago” to reflect a revised split between heathland and blanket bog. It says the revised definition was circulated to the Technical Steering Group and that no member “called-in” the definition for further discussion.
That may be Natural England’s accepted process. But it raises a reasonable question: where a technical definition has changed after earlier sign-off, what record shows that the final revised version received the necessary technical governance approval?
Very brief senior approvals
The later senior sign-off emails disclosed to us are strikingly brief.
The Director of Evidence email from May 2023 says simply: “Great stuff. I am happy to sign off this batch.”
A March 2025 executive confirmation says, in effect, that if others are content, “so I am.”
Another March 2025 email refers to an “ACTION by noon” request and says approval followed a discussion with communications.
Again, these emails may form part of an internal approval process. But they do not, by themselves, explain the technical review, evidence assurance or comment-resolution process behind a document with significant policy consequences.
Timeline questions
There are also timeline questions.
Natural England’s response says approval was confirmed on 21 March 2025, final wording amendments were incorporated on 27 March 2025, and publication took place on 31 March 2025.
The version list also includes final files dated 8 April 2025, after the stated publication date.
That may have a straightforward explanation, but it is exactly the sort of issue that a clear publication workflow record should resolve.
Why we have requested an internal review
Blanket bog management is one of the most contested and consequential issues in the English uplands. Decisions based on Natural England’s advice affect biodiversity, carbon, water, wildfire risk, farming businesses, rural communities and public expenditure.
The Moorland Association supports evidence-led policymaking. But evidence-led policymaking requires openness about the evidence, the assumptions and the quality-assurance process. When Natural England produces documents that influence Defra policy and the spending of public money, the audit trail should be capable of public scrutiny.
This is especially important where Natural England’s conclusions may influence restrictions on land-management tools, restoration obligations, agri-environment agreements and future regulatory expectations.
The internal review asks Natural England to reconsider whether it should disclose, or properly explain the withholding of, the records it has already identified. These include:
the two completed QA Review Forms;
the specialist comments on the draft definition;
any response-to-reviewer or comment-resolution record;
the publication submission, review and workflow records;
the Technical Steering Group meeting note or circulation records;
and any record explaining whether changes made after technical sign-off required further QA or governance approval.
This is not a request for special treatment. It is a request for normal transparency.
Natural England has said these documents went through review and approval. We are asking to see the records that demonstrate that process.
A question of public confidence
The issue is not whether Natural England can produce technical definitions. It can. Nor is it whether peatlands are important. They clearly are.
The issue is whether major public policy documents, used to guide land management and public expenditure, are supported by a complete and transparent audit trail.
At present, the records disclosed to us do not answer that question. We hope Natural England’s internal review will provide the missing clarity.
We will keep members updated on the outcome of the internal review and will publish any further documents disclosed where it is appropriate to do so.
Documents disclosed by Natural England
The documents referred to in this blog were disclosed by Natural England under the Environmental Information Regulations 2004 in response to request EIR2026/02139.
They are published here in the form received, with Natural England’s redactions preserved. Natural England has advised that the material may be re-used for research, criticism, review and news reporting, provided it is used accurately, not in a misleading context, and is acknowledged as Natural England copyright.
The documents disclosed to date are:
These documents should not be read as the complete audit trail. Natural England’s response refers to further records, including QA Review Forms, specialist comments, publication workflow records and Technical Steering Group records, which do not appear to have been provided.
The Moorland Association has therefore requested an internal review asking Natural England either to disclose those records, confirm they are not held, or explain any legal basis for withholding them.
