Wildfire, Peat and Policy Certainty: What Natural England’s Freedom of Information Disclosures Reveal

Andrew Gilruth
1 day ago
4 min read

Natural England (NE) has, in recent years, presented its approach to wildfire risk, peatland management and land use change as evidence-led, coherent and settled. Publicly NE consistently conveys confidence that the policy direction is clear, the science sufficiently robust and the operational framework fit for purpose.

However, documents released under the Freedom of Information Act (FOI) tell a more nuanced story.

They do not show impropriety, nor do they demonstrate that NE lacks concern for wildfire risk or staff safety. What they do show - clearly and repeatedly - is that within the organisation itself, key elements of wildfire and peat policy are actively debated, contested and acknowledged as unresolved.

That distinction matters.

A gap between external certainty and internal caution

The disclosures reveal extensive internal correspondence between operational staff, health and safety professionals, senior managers and policy teams grappling with the real-world consequences of wildfire guidance as it is currently framed.

In particular, internal emails and briefing notes demonstrate:

Acknowledged uncertainty about how existing wildfire definitions apply to peat fires, especially slow-burning peat smoulders that fall awkwardly between ‘vegetation fire’ and subsurface combustion.
Concern that rigid thresholds embedded in health and safety guidance - such as fixed flame height or area limits - may not reflect the operational realities of peatland wildfire management.
Explicit internal disagreement about whether the current policy framework adequately balances staff safety, environmental protection and statutory conservation duties on SSSIs and SACs.

None of this appears prominently, if at all, in public-facing policy documents.

Peatland wildfire: an acknowledged special case

Internally, experienced NE staff raise repeated concerns that peatland wildfires are being treated as a subset of generic vegetation fires, despite behaving very differently in practice.

FOI material records staff pointing out that:

Smouldering peat fires can persist long after surface flames are extinguished.
Leaving such fires unmanaged can result in progressive peat loss and long-term ecological damage.
Fire and Rescue Services may not always remain on site for extended ‘damping down’, creating practical dilemmas for land managers.

These concerns are not speculative. They come from staff with decades of site-based experience, particularly on National Nature Reserves.

Yet externally, NE’s published material tends to present wildfire policy as settled and sufficiently comprehensive.

Health and safety versus conservation duties

One recurring theme in the disclosed correspondence is tension - not conflict, but tension -

between:

Natural England’s duty of care to staff and volunteers, and
Its statutory responsibilities to protect designated habitats, including peatland SACs and SSSIs.

Internally, staff question whether current guidance adequately reflects the need to balance these duties, rather than prioritising one through inflexible rules. They ask whether policies designed for generic wildfire scenarios are being applied to peatland contexts without sufficient adaptation or review.

These questions are raised constructively and professionally. They are not ideological. But they are real.

Evidence, confidence and caveats

NE’s public narrative frequently relies on external evidence summaries - most notably around peatland rewetting and wildfire resilience. Those summaries are legitimate contributions to the evidence base.

However, the same evidence documents often include their own caveats: data gaps, limited UK-specific baselines and warnings against over-generalisation from overseas studies.

FOI disclosures show that internally, these caveats are well understood. Externally, they are less visible.

This creates a risk - not of error, but of over-statement. Policy may appear more settled than the underlying evidence and operational experience currently support.

Why this matters

Transparency is not just about releasing documents. It is about ensuring that public confidence is grounded in an accurate understanding of uncertainty, trade-offs and ongoing policy development.

The FOI disclosures do not undermine Natural England’s legitimacy. On the contrary, they show an organisation wrestling seriously with complex issues under conditions of climate change, increasing wildfire risk, and evolving land management practice.

But they do raise a legitimate question:

If internal documents acknowledge that policy is still contested, evolving and context-dependent, should external communications present it as effectively settled?

A case for openness, not accusation

This is not an argument for abandoning peat restoration, weakening wildfire precautions, or disregarding staff safety. Nor is it an allegation of bad faith.

It is a case for greater alignment between internal understanding and external presentation.

Acknowledging uncertainty is not a weakness in public policy. It is a strength - particularly where long-term land management, ecological restoration and wildfire risk overlap.

The FOI disclosures show that Natural England knows this internally. The challenge now is whether that candour can be reflected more clearly in public-facing policy discussions.

Transparency does not require unanimity. It requires honesty about where debate still exists.