Natural England's "Rigorous Peer Review" Unravels Under Scrutiny

Ministers told Parliament a key burning report was rigorously peer-reviewed. Freedom of Information disclosures tell a very different story.

Natural England's evidence review on managed burning — a document now shaping policy, stewardship conditions, and regulatory enforcement across England's uplands — was assured to Parliament as having undergone "rigorous peer review."

It is a claim that, under the weight of the agency's own disclosed records, appears increasingly difficult to sustain. Freedom of Information disclosures obtained by the Moorland Association have revealed that Natural England cannot produce the basic documentation that any credible peer review process would be expected to generate. There are no written terms of reference for reviewers. No scoring frameworks. No checklists. No formal record confirming that peer review was completed and signed off. The agency's own response to requests under the Environmental Information Regulations is stark: the information is simply "not held."

This is not a dispute about whether external experts glanced at the document. It is a question of whether the British government misled Parliament when it told MPs that NEER155 — formally titled An evidence review update on the effects of managed burning on upland peatland biodiversity, carbon and water — had been subject to rigorous scientific quality assurance.

A Process That Looks More Like Rubber-Stamping Than Review

The disclosed correspondence paints a picture not of structured academic scrutiny, but of a rushed clearance exercise dressed up in the language of scientific rigour. Reviewers were sent what Natural England itself described as a "relatively near complete but not yet edited" and "drafty" version of the report, with key sections — including the Introduction, Methods, Conclusions, and Appendices — still incomplete or under development. They were then given approximately one week to respond.

When reviewers were contacted again at a later stage, the framing was even more revealing. They were explicitly told that "due to time pressure to publish the report," Natural England was "not expecting further detailed comments at this stage." If this is what rigorous peer review looks like inside Natural England, the implications for every evidence product the agency publishes should concern policymakers and the scientific community alike.

Internally, the picture is no more reassuring. The draft was circulated through Natural England's own quality assurance network with instructions to forward it "to anyone who might have an interest," accompanied by the remarkable caveat that "a nil response will be taken as an assumption that you do not object to the report being published." This is not peer review. It is institutional box-ticking with a built-in assumption of consent through silence.

"Reviewers Themselves Raised Red Flags"

Perhaps the most damaging revelations come from the reviewers' own words. One external expert flagged a fundamental methodological concern, noting that the report's inclusion and exclusion criteria were insufficiently described. They wrote that they could not envisage being able to recreate the review based on the methodology section as written. Replicability is not a nice-to-have in evidence-based policy — it is the baseline standard by which any systematic review is judged.

Another reviewer openly acknowledged they had not had the opportunity to examine every section. A third stated candidly that they would not claim to have read the document from beginning to end. A fourth made clear that since the full draft remained incomplete, providing a comprehensive assessment was simply not possible.

These are not the hallmarks of a process that any reasonable scientist, parliamentarian, or member of the public would recognise as "rigorous peer review." They are the hallmarks of a process conducted under pressure, without structure, and without the safeguards that lend evidence reviews their authority.

A further governance concern has emerged around the role of an additional external contributor who, according to Natural England's own disclosure, "provided comments, edited and proof-read the final draft report." Editing and proof-reading a document is a materially different activity from independently reviewing it. The former involves shaping the text; the latter involves scrutinising it at arm's length.

It remains unclear who commissioned this work, whether it was paid, what instructions were given, and — critically — whether this editorial contribution was subsequently presented to Ministers and to Parliament as part of the "rigorous peer review" process. If editing and proof-reading have been conflated with independent scientific review in official assurances, that is not a matter of semantics. It is a matter of public trust.

The irony is that Natural England's own internal guidance — its Technical Publications framework — sets out clear expectations for evidence reviews. Methodology itself must be reviewed to ensure it meets evidence review standards, and confirmation of this should be recorded on the Publication Submission Form.

The submission form for NEER155 records the review as Tier 4, the highest classification denoting external and independent peer review. Yet the same form was submitted on 6 December 2024 and subsequently edited on 18 February 2025. What was changed, by whom, and whether this altered the assurance record are questions the Moorland Association has now formally put to both Natural England and Defra. The absence of answers thus far only deepens concern.

This is not an arcane dispute about moorland management techniques. NEER155 is being deployed as the evidential foundation for regulatory decisions that affect livelihoods, land management practices, and stewardship arrangements across England's uplands. It has been cited in legal proceedings. It has been used to justify policy positions in Parliament.

When Ministers assure MPs that a document has undergone "rigorous peer review," they are invoking the credibility of the scientific method to shield policy from legitimate challenge. If that assurance cannot be substantiated — and the disclosed records strongly suggest it cannot — then the policy positions built upon it are standing on sand.

The Moorland Association has written formally to Natural England Chief Executive Marian Spain and to Defra, requesting specific documents and confirmations within 20 working days. They are asking for answers to questions that should never have needed asking: what versions of the report were reviewed, what reviewers were actually asked to do, how their comments were recorded and addressed, and what documentary basis exists for the assurances given to Parliament. These are not unreasonable demands. They are the minimum that accountability requires.

This episode sits uncomfortably alongside broader concerns about governance, accountability, and evidence standards across Defra's family of arm's-length bodies — concerns that the Environment, Food and Rural Affairs Select Committee has been actively examining. If Natural England cannot demonstrate that its flagship evidence products meet the standards it claims for them, the credibility gap extends well beyond a single report on burning.

Parliament was told the science was rigorous. The agency's own records suggest the process was compressed, incomplete, and undocumented to a degree that makes that claim unsustainable. Natural England and Defra now have 20 working days to explain the discrepancy. The upland communities whose livelihoods depend on the answer deserve nothing less than full transparency.