Moorland Association Calls for Natural England to Withdraw Its New Document Defining Favourable Conservation Status of Blanket Bog

Natural England’s new document 'Definition of Favourable Conservation Status for Blanket Bog' should be withdrawn and rewritten.

The document gives a one-sided view and doesn’t reflect the full range of expert knowledge about blanket bogs.
Many of the statements are based on opinion, not solid scientific research.
There’s not enough use of proven, peer-reviewed studies.
The referencing of evidence is inadequate.
It doesn’t properly explain the differences between types of bogs. Not all blanket bogs are the same - some form in valleys, others on hills, and each type works differently.
Different bogs hold, move and use water in different ways. Because of that, they develop different plants, structures, and ecological conditions.
Natural England has treated all blanket bogs the same, even though conditions vary a lot depending on the region, soil, water flow, and climate.

Concerns with the Science and Method

The targets used, such as saying 95% of a bog area needs to be in ‘good’ condition, aren’t backed up by science. These numbers appear made up.
The assessment focuses mostly on which plants are present, without recognising that different types of plants naturally grow in different places because of variations in water and landscape - even when the land is managed the same way.
Natural England doesn’t focus enough on how the bog is functioning, for example, how it holds water or stores carbon.
Important features like water flow, soil condition, and how the bog supports wildlife are not well incorporated within the assessment.
Historical data, such as peat cores, are used in ways that are misleading. Natural England have used these to draw conclusions that don’t account for changes in climate or natural bog development over time.

Abuse of Evidence

Much of the evidence used is weak or limited. Natural England doesn’t make enough use of strong scientific research.
Natural England does not consider major known flaws in key studies (eg EMBER) and makes not enough use of robust studies.
It ignores or downplays research that doesn’t fit Natural England’s view.
It gives confidence ratings such as ‘high’ or ‘moderate’ to its own findings, but it’s unclear how these were decided.
It is particularly concerning that Natural England has used very few references. Of the references used, many are not published in peer-reviewed papers, they are just opinions or reports.

Technical Concerns

The plant species used to judge bog condition aren’t clearly linked to how well the bog is working. For example, heather is treated as a sign of damage even though it does form peat and it represents a well-documented key and likely climax species for certain peatlands.
Natural England wrongly assumes that only certain plants can form peat. In reality, almost all plants can contribute to peat-building if the water conditions are right.
It paints an overly simplistic, one-sided picture and conflates many issues. Whilst drainage is a well-documented and possibly the main cause of most degradation, burning and grazing are described as bad without recognising their clearly documented potential benefits when done properly.
Natural changes - like erosion in older bogs or shifts in the types of plants that grow due to water and site conditions - are not taken into account, even though these are normal parts of how bogs develop over time.

Natural England’s Failure to Follow Its Own Rules

The document doesn’t follow Natural England’s own guidance, which says definitions should be clear, measurable, based on good evidence, and include natural limits like slope and climate.
It fails to fully include key factors like water, soil, and air quality when describing what a healthy bog needs.
Maps and data sources used to describe where blanket bogs are located are not properly included or referenced.
It doesn’t make a clear difference between what’s based on expert opinion and what’s backed by solid scientific data.
Natural factors like slope, underlying rock, and climate should help decide what a blanket bog can realistically be like - but these are hardly mentioned.
Key decisions and judgments are not explained clearly, even though guidance says they should be.

Summary

This Natural England document, in its current form, isn’t suitable for conservation or for guiding land management decisions because:

It oversimplifies a complex and diverse habitat.
It doesn’t meet scientific or policy standards.
It uses vague rules that aren’t supported by evidence.
It is mostly based on opinionated statements without clear or robust evidence.
It ignores important natural differences between sites.

Natural England needs to make major changes to ensure the document is clear, accurate, and useful for real-world decisions. It should also involve key experts who have been left out and make sure the evidence used is complete, robust and relevant.

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