Email from Mr Martin Allen to UK Statistics Authority about England Biodiversity Indicators statistics

Dear Parliamentary Under Secretary of State for the Environment, Thérèse Coffey MP,

As part of legally designating the Malvern Common SSSI Natural England have used supporting evidence that states there is less than 10,000 ha of the National Priority Habitat Lowland Meadow in England (, whereas Defra (, page 2a on the downloadable table) state there is 36,129 ha and then use those figures in Document 2a. Extent and condition of priority habitats (, a page which has the National Statistic mark.

Both these figures for the same habitat cannot be accurate if Defra and Natural England are using the same definition of National Priority Habitat Lowland Meadow. The reply from my information request to Defra (Ref: TO2018/07235) stated that there are between 7,282 ha and 8,400 ha of Lowland Meadow in England; I wrote about this on my blog (

If the figure used by Natural England and the reply to my information request mentioned above is accurate, then Defra have been misleading parliament and the country since 2013 with their England Biodiversity Indicators. Similarly, as a web page which uses data based on the erroneous figures has the National Statistic mark then we can assume that either England Biodiversity Figures have not been checked against the requirements of the UK Statistics Authority code of practice or the code of practice does not prevent the publication of erroneous statistics.

You will no doubt be aware that HS2 Phase 1 and 2a will destroy 80 ha of England’s Lowland Meadow, information I obtained from FOI18-2056 and FOI18-2072 and see my blog ( As you can appreciate the destruction of 80 ha from a total of approx. 8000 ha is very different from destruction of 80 ha from 36,129 ha.

Can you please investigate why Defra are publishing incorrect data and whether the data meets the UK Statistics Authority code of practice, and let me know your findings?

Yours sincerely,
Martin Allen

Cc (it was tricky to find emails leading directly to the correct people, but I’ve done my best)
Natural England board (as they are legally responsible for designating SSSI)
Office for National Statistics (as it is their National Statistic mark that I am suggesting is inappropriately applied)
Environmental Audit Committee (as I think scrutiny of Defra’s data publishing regarding Priority Habitats is part of their remit)


Related Links:

Letter from Ed Humpherson, January 2019