CONSULTATION QUESTIONS (boxes can be expanded if necessary) · UK Forestry Standard and Guidelines:...

CONSULTATION QUESTIONS (boxes can be expanded if necessary) Please ensure you complete the respondent information form on page 10 Your name: Mike Wood, UK Forestry Policy Officer

Your organisation (if any): RSPB (Royal Society for the Protection of Birds)

Dunedin House

25 Ravelston Terrace

Edinburgh

EH4 3TP.

E-mail: [email protected]

Date: 30 October 2009

No Question. General Approach 1. Looking at the revision project as a whole, does the approach taken meet

the objectives, set out in para 6, above ? No Comments The UK Forestry Standard and the associated Forest Guidelines revision has resulted in a more coherent and auditable product. The RSPB welcomes this, and much of the content and intention of the revised standard and guidelines, but has a number of concerns. The RSPB is concerned about requirements and associated wording on peatland planting, restocking on open ground habitats, the environmental sustainability of climate change mitigation requirements, as well as the enforcement of the standard. These concerns are detailed in this response. Scope 2. Does the UKFS & Forestry Guidelines series adequately address the elements

of sustainable forest management, as identified by internationally agreed principles and criteria? (UKFS page 12)

Yes No Comments:

1 | UKFS Consultation | C&FS | 06/11/2009

UK Forestry Standard and Guidelines: a Consultation

Requirements 3. Does the range of UKFS Requirements in the table capture the essentials of

sustainable forest management? Yes No

Comments: If no, please state what you think should be added or omitted. We have concerns about requirements and associated wording on peatland planting, restocking on open ground habitats, the environmental sustainability of climate change mitigation requirements, as well as the enforcement of the standard. Clarity and Detail 4. In general, are the UKFS and Guidelines clearly written and adequate in

terms of their length and detail? Yes No

Comments: We have concerns about requirements and associated wording on peatland planting, restocking on open ground habitats, the environmental sustainability of climate change mitigation requirements, as well as the enforcement of the standard. Apart from these concerns, the length and detail is generally appropriate. Additional Guidance 5. Some of the new Guidelines have less practical detail than previous versions,

this will now be covered in supporting publications. Are there particular topics that you can identify where you would like further practical information or guidance?

Yes No Comments: No additional comments. Equality and Diversity 6. In relation to para 13 above, do you feel the UKFS and Guidelines will have

positive and equitable impacts on all groups in society? Yes No

Comments:



No comment. The UKFS - General 7. Do you have any general comments about the scope and content of the

UKFS? Yes No

Comments: Conservation & enhancement of open ground habitats The proposed revised Standard and Guidelines make an unwelcome shift towards permitting planting on peatlands. They also do not properly address the issue of the continued tree restocking on restorable important peatland habitats, and other priority open ground habitats. The current UK Forestry Standard and the FC and DARD practice regulation1 does not permit planting on important peatland habitats – and is more environmentally robust than the revised proposals (in particular BG5 which undermines other biodiversity guidelines which are positive). The new standard must result in the protection and enhancement of the biodiversity value of important peatlands and other priority open ground habitats, including not permitting their restocking. The RSPB does not support the current wording of Requirement PPG16 on Compensatory Planting. There must not be a requirement for compensatory planting for priority biodiversity works, including the restoration of priority open ground habitats and sites for priority open ground species. We are concerned that introducing the ‘compensatory planting’ concept into felling consents, through planning and forestry approval regimes, will impede high quality biodiversity habitat restoration and creation. It may also burden biodiversity projects with an unjust requirement to purchase and plant additional land to ‘compensate’ the removal of low biodiversity value forestry plantations, including those on important habitats. The RSPB fully supports the conservation and enhancement of the UK’s native woodland resource, and is concerned about any losses of ancient and semi-

1 Patterson, G. & Anderson, R. (2000) Forests & Peatland Habitats. Forestry Commission Guideline Note 1. Forestry

Commission, Edinburgh. http://www.forestry.gov.uk/pdf/fcgn1.pdf/$FILE/fcgn1.pdf

& Forest Service (1993) Afforestation – the DANI Statement on Environmental Policy. Forest Service, Belfast. http://www.dardni.gov.uk/afforestation_-_the_dani_statement_on_environmental_policy.pdf



natural woods, including restorable native woodland sites currently forestry plantations2. The UK Forestry Standard should address the issue of the ecological degradation of existing native woods, as well as the loss of native woodland. Carbon science & policy The carbon value, and scientific basis of carbon sequestration by UK forestry is overplayed by the proposed standard and guidelines, including in the actual requirements (such as BG5). The RSPB considers that the main climate change issue is reducing emissions from society at source, rather than afforestation to mitigate a small proportion of the UK’s green house gas emissions. The RSPB does not accept that compensatory planting is an appropriate mechanism to increase woodland area for climate change mitigation reasons. Targeted grants for high quality woodland development and management should be strategically employed, assisting with climate change adaptation for native woods, instead of a project-based ’compensatory’ planting approach. We recognise that there may be some carbon benefits related to woodland management, but these must be part of sustainable multiple benefit forestry. Improving the biodiversity condition of native woods and restoring peat bogs could offer real long-term carbon as well as biodiversity benefits. The UK Forestry Standard in its current form – in particular the current wording of Requirements PPG16, BG5 and CCG8 - could result in a drive for afforestation of low biodiversity value, with such work badged as ‘climate change mitigation’. The proposed revised UK Forestry Standard and its associated Forest Guidelines unfortunately doesn’t properly explain the uncertainty of forest carbon science, and lack of key soils data (for example in Paragraph 54 of the standard). It also fails to accurately place forestry in context of the larger issue of reducing society’s non-forestry greenhouse gas emissions at source. The standard and guidelines overstress the importance of habitat connectivity, while ignoring habitat quality. They also make worrying proposals to include non-local provenance native woodlands in advance of the development of scientifically valid practice guidance on habitat quality and tree specification for climate change adaptation for priority biodiversity conservation. Such guidance needs to be properly worked up and publicly consulted. UK Forestry Standard compliance levels It is unclear in parts of the Guidelines and Standard when a regulator requires UK

2 ‘PAWS’ - Plantations on Ancient Woodland Sites.



Forestry Standard compliance – for example as part of a Felling Licensing, EIA, forest planning approval, agricultural and forestry grant approval or planning permission – whether this means just ‘Legal Requirements’ or includes ‘Good Forestry Practice Requirements’. The RSPB considers that UK Forestry Standard compliance must include both ‘Legal Requirements’ and ‘Good Forestry Practice Requirements’. Section 4 of all the Guidelines ‘Requirements of the UK Forestry Standard’, and Paragraph 110 of the Standard, suggests that this is the case for UK Forestry Standard compliance, but this is not clear in Paragraphs 62 & 82 of UK Forestry Standard, or in all of the Guidelines under ‘Requirements’ in the Preface. Effective enforcement of UK Forestry Standard compliance is important, across all sectors. Monitoring of UK Forestry Standard compliance and enforcement is also needed. The proposal for individual country audit protocols may result in an inconsistent approach to UK Forestry Standard compliance, its enforcement as well as auditing and in country monitoring. There must be a rigorous and UK-wide consistent approach to compliance auditing and enforcement, with public transparency. The development of these systems requires further public consultation. Key to the success of the Standard and Guidelines will be the content of Practice, Field and Technical Guides. We would like to see a list of such guidance and a timetable for the production and revision of the guides. Short rotation coppice and forestry & UK Forestry Standard compliance The RSPB welcomes the requirement for short rotation coppice (SRC) and short rotation forestry (SRF) to conform to the UK Forestry Standard, in the clear statement in ‘Scope’ Paragraph 10. Agricultural and planning UK Forestry Standard compliance The RSPB also welcomes the clear statement in ‘Scope’ Paragraph 11 on UK Forestry Standard compliance for within agricultural and development settings, and the need for competent authorities - which are not Forestry Commission or Forest Service - to require and regulate UK Forestry Standard compliance. We would suggest that there is a need for discussion between the forestry regulators and their respective devolved agriculture and planning departments, as well as local planning authorities, to ensure that UK Forestry Standard requirement is understood and met. This could include publication of guidance



and training for planning departments, agricultural grant officers and perhaps continuing professional development events for professional planners (Royal Town Planning Institute members). UK Forestry Standard compliance auditing & enforcement Effective enforcement of UK Forestry Standard compliance is important, across all sectors. Monitoring of UK Forestry Standard compliance and enforcement is also needed. The proposals lack coherence across countries. It is also unclear whether the resultant systems will ensure effective UK Forestry Standard compliance. The UKFS - Scope 8. Do you feel there are any omissions, or un-necessary inclusions?

Yes No Comments: Section 6: Forest Planning The development and approval processes for forest planning must have a requirement to appropriately consult with stakeholders. The carbon value, and scientific basis of carbon sequestration by UK forestry is overplayed by the proposed standard and guidelines, including in the actual requirements. Paragraph 54 ‘mitigation’ needs to reflect the carbon science uncertainty and lack of soils data, as well as the wider societal issue of reductions of non-forestry green house gas emissions at source. Paragraph 54 ‘adaptation’ should mention priority species and priority habitats as requiring adaptation action, including improving the biodiversity quality of existing habitat patches. The standard and guidelines overstress the importance of habitat connectivity, while ignoring habitat quality. They also make worrying proposals to include non-local provenance native woodlands in advance of scientifically valid, properly worked up and consulted, practice guidance on habitat quality and tree specification for climate change adaptation for priority biodiversity conservation.



The UKFS – Detail 9. Do you have comments about the level of detail contained in the text of the

UKFS (excluding sections 5 & 7)? Yes No Comments: UKFS – Detail Requirements Table and Forest Practice (Sections 5 & 7) 10 Do you have comments about the level of detail contained in the text of

sections 5 & 7: the UKFS requirements table and the forest planning and general forestry practice section?

Yes No Comments: Table 7 – Guideline Bullet Points BG5 changes peatland planting requirements by the addition of ‘unless there are over-riding net benefits’ – the RSPB does not support this shift in policy and regulation, as this will result in further damage to peatland habitats, associated species and designated sites. It undermines the environmental credibility of the whole of the UK Forestry Standard, and the positive progress for biodiversity conservation made in forestry policy, practice and regulation since the mid-1980s. Guideline Bullet Point BG5 must revised to be in line with practice requirements on afforestation on peatland soils, contained in:

Patterson, G. & Anderson, R. (2000) Forests & Peatland Habitats. Forestry Commission Guideline Note 1. Forestry Commission, Edinburgh. & Forest Service (1993) Afforestation – the DANI Statement on Environmental Policy. Forest Service, Belfast.

This could be achieved by simply requiring compliance with FCGN1 – Forest & Peatland Habitats and the Afforestation – the DANI Statement on Environmental Policy. LCLCR2 This needs qualifying to explain that open ground habitat restoration for priority species, priority habitats and designated site enhancement is permissible under the UK Forestry Standard and forestry legislation, including Environmental



Impact Assessment. In Scotland the Forestry Act 1967 has been amended by the nature Conservation (Scotland) Act to clearly enable this, in England and Wales Felling Licensing of such restoration works is granted without restocking conditions. The proposed Forestry Bill in Northern Ireland considers that open ground habitat restoration will not require restocking. The inclusion of the Guideline Bullet Points (legal and good practice requirements) in the text of the Forest Guidelines has helped the readability of the Guidelines. This has improved the clarity within each Guideline for what action is required to comply with that aspect of the UK Forestry Standard. It is, however, unclear what the purpose and actual function in practice of the ‘Elements of Sustainable Forest Management’ column in the table in the standard is. This is because only the Guideline Bullet Points (requirements) are strongly represented within each set of Forest Guidelines, so the ‘elements’ text and sense may be lost in the operation of each set of Forest Guidelines. Compensatory planting – CCG8, PPG16 & BG5 The UK Forestry Standard in its current form – in particular the current wording of Requirements PPG16, BG5 and CCG8 - could result in a drive for afforestation of low biodiversity value, with such work badged as ‘climate change mitigation’. The RSPB considers that the main climate change issue is reducing emissions from society at source, rather than afforestation to mitigate a small proportion of the UK’s green house gas emissions. The RSPB does not accept that compensatory planting is an appropriate mechanism to increase woodland area for climate change mitigation reasons. Targeted grants for high quality woodland development and management should be strategically employed, assisting with climate change adaptation for native woods, instead of a project-based ’compensatory’ planting approach. We recognise that there may be some carbon benefits related to woodland management, but these must be part of sustainable multiple benefit forestry. Improving the biodiversity condition of native woods and restoring peat bogs could offer real long-term carbon as well as biodiversity benefits. The RSPB does not support the current wording of Requirement PPG16 on Compensatory Planting. There must not be a requirement for compensatory planting for priority biodiversity works, including the restoration of priority open ground habitats and sites for priority open ground species. We are concerned that introducing the ‘compensatory planting’ concept into



felling consents, through planning and forestry approval regimes, will impede high quality biodiversity habitat restoration and creation. It may also burden biodiversity projects with an unjust requirement to purchase and plant additional land to ‘compensate’ the removal of low biodiversity value forestry plantations, including those on important habitats. The RSPB fully supports the conservation and enhancement of the UK’s native woodland resource, and is concerned about any losses of ancient and semi-natural woods, including restorable native woodland sites currently forestry plantations3. The UK Forestry Standard should address the issue of the ecological degradation of existing native woods, as well as the loss of native woodland. CCG2 This must include environmental sustainability – encompassing biodiversity – as well as ‘carbon sustainability’. CCG6 This needs to consider peat bog restoration. CCG7 This must include retaining old growth. CCG8 We do not support compensatory planting for the restoration of priority peatland habitats and other priority open ground habitats. See more detailed comments under ‘compensatory planting’. CCG25 This must be consistent with conserving and enhancing biodiversity. CCG26 The Guidelines must be careful not to start recommending the adoption of non-local provenance trees to native woodlands because:

- Climate data is uncertain; - The risk of loss of ecological generic loss would be too high; & - It is too soon to judge whether this is the correct approach to

climate change adaptation in native woodlands. CCG29 Enhancing the ecological connectivity of woodland species and habitats must not reduce the area, connectivity and condition of priority open ground habitats and 3 ‘PAWS’ - Plantations on Ancient Woodland Sites.



species. CCG31 This needs to include improving the biological condition of existing native woodlands, in addition to expansion, connection and buffering. Woodland expansion must take account of priority open ground habitats and species. Paragraph 74 of the Landscape Guidelines – new Requirement needed We support the comment about considering biodiversity. This needs to be a Guideline Bullet Point (requirement). New ‘People’ Requirements needed There must be a requirement to carry out forest leisure and recreation activities and events in an environmentally sustainable manner. These Guidelines also need to have a requirement on forest businesses, including non-leisure enterprises, to carry out their operations in an environmentally sustainable manner that benefits, not harms wildlife.



Guidelines: Please complete a separate sheet for each Guideline publication you wish to comment on. Comments on the Forests and Biodiversity Guidelines GQ 1 General Do you feel The Forests and Biodiversity Guidelines are adequate in terms of length and detail?

Yes No Comments: GQ 2 Content Do you feel there are any omissions, or un-necessary inclusions?

Yes No Comments: Introduction – needs to mention country biodiversity strategies and site designations (SSSI/ASSI, NNR, SAC, SPA, Ramsar). Paragraph 22 – agree with the message of this paragraph relating to appropriate management for biodiversity, including monitoring and non-intervention. This paragraph must also mention priority species. This Guideline must refer to requirements on afforestation on peatland soils, contained in:

Patterson, G. & Anderson, R. (2000) Forests & Peatland Habitats. Forestry Commission Guideline Note 1. Forestry Commission, Edinburgh. http://www.forestry.gov.uk/pdf/fcgn1.pdf/$FILE/fcgn1.pdf & Forest Service (1993) Afforestation – the DANI Statement on Environmental Policy. Forest Service, Belfast. http://www.dardni.gov.uk/afforestation_-

_the_dani_statement_on_environmental_policy.pdf GQ 3 Technical Bearing in mind the function of the Guideline publications described in the diagram inside the front cover, do you feel the information is pitched at an



appropriate level in terms of technical content? Yes No

Comments:



GQ 4 Guideline Bullet Points Do you have any comments on the guideline bullet points set out under each factor?

Yes No Comments (please include the bullet point reference number) LCLCR2 – this bullet point needs qualifying to explain that open ground habitat restoration for priority species, priority habitats and designated site enhancement is permissible under the UK Forestry Standard and forestry legislation, including Environmental Impact Assessment. In Scotland the Forestry Act 1967 has been amended by the Nature Conservation (Scotland) Act 2004 to clearly enable this, in England and Wales Felling Licensing of such restoration works is granted without restocking conditions. The proposed Forestry Bill in Northern Ireland considers that open ground habitat restoration will not require restocking. BG5 (Paragraph 43). BG5 changes peatland planting requirements by the addition of ‘unless there are over-riding net benefits’ – the RSPB does not support this shift in policy and regulation, as this will result in further damage to peatland habitats, associated species and designated sites. It undermines the environmental credibility of the whole of the UK Forestry Standard, and the positive progress for biodiversity conservation made in forestry policy, practice and regulation since the mid-1980s. Guideline Bullet Point BG5 must revised to be in line with practice requirements on afforestation on peatland soils, contained in:

Patterson, G. & Anderson, R. (2000) Forests & Peatland Habitats. Forestry Commission Guideline Note 1. Forestry Commission, Edinburgh. & Forest Service (1993) Afforestation – the DANI Statement on Environmental Policy. Forest Service, Belfast.

This could be achieved by simply requiring compliance with FCGN1 – Forest & Peatland Habitats and Afforestation – the DANI Statement on Environmental Policy. The RSPB does not support the current wording of Requirement PPG16 on Compensatory Planting. There must not be a requirement for compensatory planting for priority biodiversity works, including the restoration of priority open



ground habitats and sites for priority open ground species. We are concerned that introducing the ‘compensatory planting’ concept into felling consents, through planning and forestry approval regimes, will impede high quality biodiversity habitat restoration and creation. It may also burden biodiversity projects with an unjust requirement to purchase and plant additional land to ‘compensate’ the removal of low biodiversity value forestry plantations, including those on important habitats. The RSPB fully supports the conservation and enhancement of the UK’s native woodland resource, and is concerned about any losses of ancient and semi-natural woods, including restorable native woodland sites currently forestry plantations4. The UK Forestry Standard should address the issue of the ecological degradation of existing native woods, as well as the loss of native woodland. Other Comments Other Comments: please use this space to submit any other comments your wish to make on the UKFS & Guidelines The RSPB welcomes the clear statement in Paragraph 11 of the Preface on the inclusion of short rotation coppice (SRC) and short rotation forestry (SRF) in the UK Forestry Standard, and therefore the requirement for SRC and SRF to conform to the standard. We also welcome the clear statement in Paragraph 12 of the Preface, on UK Forestry Standard compliance within agricultural and development settings, and the need for non-Forestry Commission and Forest Service competent authorities to require and regulate UK Forestry Standard compliance. It is unclear when a regulator requires UK Forestry Standard compliance – for example as part of a Felling Licensing, EIA, forest planning approval, agricultural and forestry grant approval or planning permission – whether this means just ‘Legal Requirements’ or includes ‘Good Forestry Practice Requirements’. The RSPB considers that UK Forestry Standard compliance must include both ‘Legal Requirements’ and ‘Good Forestry Practice Requirements’. Section 4 of all the Guidelines ‘Requirements of the UK Forestry Standard’, and Paragraph 110 of the Standard, suggests that this is the case for UK Forestry Standard compliance, but this is not clear in Paragraphs 62 & 82 of UK Forestry Standard, or in all of the Guidelines under ‘Requirements’ in the Preface. 4 ‘PAWS’ - Plantations on Ancient Woodland Sites.



Guidelines: Please complete a separate sheet for each Guideline publication you wish to comment on. Comments on the Forests and Climate Change Guidelines GQ 1 General Do you feel The Forests and Climate Change Guidelines are adequate in terms of length and detail?

Yes No Comments: The RSPB welcomes the continued commitment to multiple benefit sustainable forestry in these Guidelines (for example in Paragraph 22). We would not have welcomed a move to – carbon ‘maxxing’ - focusing only on carbon sequestration. We do have a number of concerns about these Guidelines, including their requirements for sustainable forest management. The carbon value, and scientific basis of carbon sequestration by UK forestry is overplayed by the proposed standard and guidelines, including in the actual requirements (such as BG5). The RSPB considers that the main climate change issue is reducing emissions from society at source, rather than afforestation to mitigate a small proportion of the UK’s green house gas emissions. The RSPB does not accept that compensatory planting is an appropriate mechanism to increase woodland area for climate change mitigation reasons. Targeted grants for high quality woodland development and management should be strategically employed, assisting with climate change adaptation for native woods, instead of a project-based ’compensatory’ planting approach. We recognise that there may be some carbon benefits related to woodland management, but these must be part of sustainable multiple benefit forestry. Improving the biodiversity condition of native woods and restoring peat bogs could offer real long-term carbon as well as biodiversity benefits. The drat revised UK Forestry Standard in its current form – in particular the wording of Requirements PPG16, BG5 and CCG8 - could result in a drive for afforestation of low biodiversity value, with such work badged as ‘climate change mitigation’. The RSPB does not support the current wording of Requirement PPG16 on Compensatory Planting. There must not be a requirement for compensatory planting for priority biodiversity works, including the restoration of priority open ground habitats and sites for priority open ground species.



We are concerned that introducing the ‘compensatory planting’ concept into felling consents, through planning and forestry approval regimes, will impede high quality biodiversity habitat restoration and creation. It may also burden biodiversity projects with an unjust requirement to purchase and plant additional land to ‘compensate’ the removal of low biodiversity value forestry plantations, including those on important habitats. The RSPB fully supports the conservation and enhancement of the UK’s native woodland resource, and is concerned about any losses of ancient and semi-natural woods, including restorable native woodland sites currently forestry plantations5. The UK Forestry Standard should address the issue of the ecological degradation of existing native woods, as well as the loss of native woodland. The proposed revised UK Forestry Standard and its associated Forest Guidelines unfortunately doesn’t properly explain the uncertainty of forest carbon science, and lack of key soils data (for example in Paragraph 54 of the standard). It also fails to accurately place forestry in context of the larger issue of reducing society’s non-forestry greenhouse gas emissions at source. The standard and guidelines overstress the importance of habitat connectivity, while ignoring habitat quality. They also make worrying proposals to include non-local provenance native woodlands in advance of the development of scientifically valid practice guidance on habitat quality and tree specification for climate change adaptation for priority biodiversity conservation. Such guidance needs to be properly worked up and publicly consulted GQ 2 Content Do you feel there are any omissions, or un-necessary inclusions?

Yes No Comments: Carbon science, climate change mitigation & adaptation There is current uncertainty in UK forest carbon science and the paucity of data on forest soils – this should be better acknowledged in these Guidelines. The Guidelines need to recognise the need for reduction in society’s mainly non-forestry greenhouse gas emissions at source, rather than woodland expansion and management for limited and sometimes questionable mitigation. There is,




however, real scope to carry out climate change adaptation works for biodiversity, as well as improving the biodiversity and carbon condition of the UK’s peatlands. These Guidelines do not stress the importance of improving the biodiversity condition of existing native woodland – the focus should not just be on woodland expansion and connectivity. Forestry climate change adaptation must also consider adaptation for non-woodland habitats and species. ‘Climate Change Adaptation’ (Paragraphs 31 – 36) – this must mention possible impacts on biodiversity and adaptation action – including for priority species, priority habitats and designated sites. We do, however, welcome the cautious tone of this section. Adaptation action must be taken carefully bearing in mind the uncertainty in models and limited information on likely environmental responses – this should follow the principle of seeking low regret actions first. The RSPB would not support any attempts to reduce action for biodiversity work in areas identified as potentially unsuitable under the UK Climate Impacts Programme scenarios, as these models are not robust enough for focusing appropriate biodiversity conservation action. The Guidelines must be careful not to start recommending the adoption of non-local provenance trees to native woodlands because:

- Climate data is uncertain; - The risk of loss of ecological generic loss would be too high; - It is too soon to judge whether this is the correct approach to

climate change adaptation in native woodlands. The Guidelines need to highlight benefits of restoring favourable condition to damaged woodland habitats which is a key adaptive action for biodiversity – making woodland and its species more robust to effects of climate change. The Guidelines must recognise that forest restructuring and tree removal can help restore long term carbon gains on peat soils. More recognition is needed of the benefit of retaining old growth forest high carbon stock. The Guidelines must recognise that product substitution by timber and wood products, for example for steel, can have as high a benefit or higher than forest expansion.



Adaptation should include tree removal to help restore open ground on areas that can help priority biodiversity and address flooding. The Guidelines must accept that retention of trees and restocking/planting of trees on peat is causing significant green house gas emissions. There are real benefits from tree removal in carbon as well as biodiversity terms. Transport of timber from source to market needs to be considered to help- reduce operational carbon. Expanding habitat networks can be beneficial for climate adaptation for priority species and habitats, but it is important that this considers priority open ground habitat and species conservation, as well as priority native woodland habitats and species. GQ 3 Technical Bearing in mind the function of the Guideline publications described in the diagram inside the front cover, do you feel the information is pitched at an appropriate level in terms of technical content?

Yes No Comments: Taking account of our comments in the previous section.




Yes No Comments (please include the bullet point reference number) Paragraph 71: LCLCR2 – this bullet point needs qualifying to explain that open ground habitat restoration for priority species, priority habitats and designated site enhancement is permissible under the UK Forestry Standard and forestry legislation, including Environmental Impact Assessment. In Scotland the Forestry Act 1967 has been amended by the Nature Conservation (Scotland) Act 2004 to clearly enable this, in England and Wales Felling Licensing of such restoration works is granted without restocking conditions. The proposed Forestry Bill in Northern Ireland considers that open ground habitat restoration will not require restocking. Compensatory planting – CCG8, PPG16 & BG5 The UK Forestry Standard in its current form – in particular the current wording of Requirements PPG16, BG5 and CCG8 - could result in a drive for afforestation of low biodiversity value, with such work badged as ‘climate change mitigation’. The RSPB considers that the main climate change issue is reducing emissions from society at source, rather than afforestation to mitigate a small proportion of the UK’s green house gas emissions. The RSPB does not accept that compensatory planting is an appropriate mechanism to increase woodland area for climate change mitigation reasons. Targeted grants for high quality woodland development and management should be strategically employed, assisting with climate change adaptation for native woods, instead of a project-based ’compensatory’ planting approach. We recognise that there may be some carbon benefits related to woodland management, but these must be part of sustainable multiple benefit forestry. Improving the biodiversity condition of native woods and restoring peat bogs could offer real long-term carbon as well as biodiversity benefits. The RSPB does not support the current wording of Requirement PPG16 on Compensatory Planting. There must not be a requirement for compensatory planting for priority biodiversity works, including the restoration of priority open ground habitats and sites for priority open ground species. We are concerned that introducing the ‘compensatory planting’ concept into felling consents, through planning and forestry approval regimes, will impede high quality biodiversity habitat restoration and creation.



It may also burden biodiversity projects with an unjust requirement to purchase and plant additional land to ‘compensate’ the removal of low biodiversity value forestry plantations, including those on important habitats. The RSPB fully supports the conservation and enhancement of the UK’s native woodland resource, and is concerned about any losses of ancient and semi-natural woods, including restorable native woodland sites currently forestry plantations6. The UK Forestry Standard should address the issue of the ecological degradation of existing native woods, as well as the loss of native woodland. CCG2 This must include environmental sustainability – encompassing biodiversity – as well as ‘carbon sustainability’. CCG6 This needs to consider peat bog restoration. CCG7 This must include retaining old growth. CCG8 We do not support compensatory planting for the restoration of priority peatland habitats and other priority open ground habitats. See more detailed comments under ‘compensatory planting’. CCG25 This must be consistent with conserving and enhancing biodiversity. CCG26 The Guidelines must be careful not to start recommending the adoption of non-local provenance trees to native woodlands because:

- Climate data is uncertain; - The risk of loss of ecological generic loss would be too high; & - It is too soon to judge whether this is the correct approach to

climate change adaptation in native woodlands. CCG29 Enhancing the ecological connectivity of woodland species and habitats must not reduce the area, connectivity and condition of priority open ground habitats and




species. CCG31 This needs to include improving the biological condition of existing native woodlands, in addition to expansion, connection and buffering. Woodland expansion must take account of priority open ground habitats and species. Other Comments Other Comments: please use this space to submit any other comments your wish to make on the UKFS & Guidelines It is unclear when a regulator requires UK Forestry Standard compliance – for example as part of a Felling Licensing, EIA, forest planning approval, agricultural and forestry grant approval or planning permission – whether this means just ‘Legal Requirements’ or includes ‘Good Forestry Practice Requirements’. The RSPB considers that UK Forestry Standard compliance must include both ‘Legal Requirements’ and ‘Good Forestry Practice Requirements’. Section 4 of all the Guidelines ‘Requirements of the UK Forestry Standard’, and Paragraph 110 of the Standard, suggests that this is the case for UK Forestry Standard compliance, but this is not clear in Paragraphs 62 & 82 of UK Forestry Standard, or in all of the Guidelines under ‘Requirements’ in the Preface. Paragraph 50 – replace the ‘Scottish Climate Change Bill’ with the ‘Climate Change (Scotland) Act 2009’.



Guidelines: Please complete a separate sheet for each Guideline publication you wish to comment on. Comments on the Forests and Historic Environment Guidelines GQ 1 General Do you feel The Forests and Historic Environment Guidelines are adequate in terms of length and detail?

Yes No Comments: See comments on content below. GQ 2 Content Do you feel there are any omissions, or un-necessary inclusions?

Yes No Comments: The RSPB would like to see clearer recognition in these Guidelines of the historic environment and biodiversity values of restored open ground habitats. These Guidelines also need to explain the linkage with the forestry Environmental Impact Assessment process for afforestation and woodland removal, including good practice for project planning and design. This would explain the purpose, outline content and timing of an archaeological survey (connecting with Landscape Guidelines, management planning in UKFS and guidance on EIA), as well as design and phasing issues, and how this fits into an Environmental Statement. It would also need to mention monitoring of works, and design of subsequent phases of the project covered by the approved Environmental Statement. The Guidelines should mention the role of local authority and statutory agency archaeologists as statutory consultees and advisors in the approval of forest plans, grants, forestry EIAs and Felling Licensing. GQ 3 Technical Bearing in mind the function of the Guideline publications described in the diagram inside the front cover, do you feel the information is pitched at an appropriate level in terms of technical content?

Yes No



Comments:




Yes No Comments (please include the bullet point reference number) Paragraph 29: LCLCR2 – this bullet point needs qualifying to explain that open ground habitat restoration for priority species, priority habitats and designated site enhancement is permissible under the UK Forestry Standard and forestry legislation, including Environmental Impact Assessment. In Scotland the Forestry Act 1967 has been amended by the Nature Conservation (Scotland) Act 2004 to clearly enable this, in England and Wales Felling Licensing of such restoration works is granted without restocking conditions. The proposed Forestry Bill in Northern Ireland considers that open ground habitat restoration will not require restocking. Other Comments Other Comments: please use this space to submit any other comments your wish to make on the UKFS & Guidelines The RSPB welcomes the clear statement in Paragraph 11 of the Preface on the inclusion of short rotation coppice (SRC) and short rotation forestry (SRF) in the UK Forestry Standard, and therefore the requirement for SRC and SRF to conform to the standard. We also welcome the clear statement in Paragraph 12 of the Preface, on UK Forestry Standard compliance within agricultural and development settings, and the need for non-Forestry Commission and Forest Service competent authorities to require and regulate UK Forestry Standard compliance. It is unclear when a regulator requires UK Forestry Standard compliance – for example as part of a Felling Licensing, EIA, forest planning approval, agricultural and forestry grant approval or planning permission – whether this means just ‘Legal Requirements’ or includes ‘Good Forestry Practice Requirements’. The RSPB considers that UK Forestry Standard compliance must include both ‘Legal Requirements’ and ‘Good Forestry Practice Requirements’. Section 4 of all the Guidelines ‘Requirements of the UK Forestry Standard’, and Paragraph 110 of the Standard, suggests that this is the case for UK Forestry Standard compliance, but this is not clear in Paragraphs 62 & 82 of UK Forestry Standard,



or in all of the Guidelines under ‘Requirements’ in the Preface.



Guidelines: Please complete a separate sheet for each Guideline publication you wish to comment on. Comments on the Forests and Landscape Guidelines GQ 1 General Do you feel The Forests and Landscape Guidelines are adequate in terms of length and detail?


Yes No Comments: The RSPB would like to see clearer recognition in these Guidelines of the historic environment and biodiversity values of restored open ground habitats. The restoration of the open landscape settings of historic environments needs to be considered. These Guidelines also need to explain the linkage with the forestry Environmental Impact Assessment process for afforestation and woodland removal, including good practice for project planning. This would explain the purpose, outline content and timing of visual impact assessment (connecting with Appendix 3), as well as design and phasing issues, and how this fits into an Environmental Statement. It would also need to mention monitoring of works, and design of subsequent phases of the project covered by the approved Environmental Statement. Paragraph 8 ‘Guidelines’ – refers to ‘Biodiversity Guidelines’ when meaning Historic Environment Guidelines. Paragraph 27 ‘Forest Design’ – needs to restate the forest definition here to clarify that it applies to all woodland. Paragraph 33 ‘Landscape & Planning’ – need to name and explain the role of the devolved statutory landscape conservation agencies. For example their statutory consultee role in Forestry Commission/Forest Service sanctioned felling, forest



planning and proposals through Felling Licensing, forestry Environmental Impact Assessment (including visual impact assessment) and woodland planting and management grant approval. This explanation of the role of the agencies needs better explaining in Appendix 1 ‘Landscape: Statutory Bodies’ including when FS/FS are the regulator and their consenting processes, and when they are not, for example development in woodland. Appendix 1 ‘Planning Authorities’ needs also to explain this relationship. Paragraph 58 – Environment & Heritage Service is now Northern Ireland Environment Agency. Paragraph 74 – we support the comment about considering biodiversity. This needs to be a requirement as a ‘Guideline Bullet Point’. Paragraphs 19, 80 & 81 – ‘Spirit of Place’. This should recognise the role of biodiversity – including priority species, habitats and designated sites, and not just trees - in creating and being part of a sense of place. GQ 3 Technical Bearing in mind the function of the Guideline publications described in the diagram inside the front cover, do you feel the information is pitched at an appropriate level in terms of technical content?

Yes No Comments: None




Yes No Comments (please include the bullet point reference number) Paragraph 74 – we support the comment about considering biodiversity. This needs to be a Guideline Bullet Point (requirement). Paragraph 39: LCLCR2 – this bullet point needs qualifying to explain that open ground habitat restoration for priority species, priority habitats and designated site enhancement is permissible under the UK Forestry Standard and forestry legislation, including Environmental Impact Assessment. In Scotland the Forestry Act 1967 has been amended by the Nature Conservation (Scotland) Act 2004 to clearly enable this, in England and Wales Felling Licensing of such restoration works is granted without restocking conditions. The proposed Forestry Bill in Northern Ireland considers that open ground habitat restoration will not require restocking. Other Comments Other Comments: please use this space to submit any other comments your wish to make on the UKFS & Guidelines The RSPB welcomes the clear statement in Paragraph 9 of the Preface on the inclusion of short rotation coppice (SRC) and short rotation forestry (SRF) in the UK Forestry Standard, and therefore the requirement for SRC and SRF to conform to the standard. We also welcome the clear statement in Paragraph 10 of the Preface, on UK Forestry Standard compliance within agricultural and development settings, and the need for non-Forestry Commission and Forest Service competent authorities to require and regulate UK Forestry Standard compliance. It is unclear when a regulator requires UK Forestry Standard compliance – for example as part of a Felling Licensing, EIA, forest planning approval, agricultural and forestry grant approval or planning permission – whether this means just ‘Legal Requirements’ or includes ‘Good Forestry Practice Requirements’. The RSPB considers that UK Forestry Standard compliance must include both ‘Legal Requirements’ and ‘Good Forestry Practice Requirements’. Section 4 of all



the Guidelines ‘Requirements of the UK Forestry Standard’, and Paragraph 110 of the Standard, suggests that this is the case for UK Forestry Standard compliance, but this is not clear in Paragraphs 62 & 82 of UK Forestry Standard, or in all of the Guidelines under ‘Requirements’ in the Preface.



Guidelines: Please complete a separate sheet for each Guideline publication you wish to comment on. Comments on the Forests and People Guidelines GQ 1 General Do you feel The Forests and People Guidelines are adequate in terms of length and detail?


Yes No Comments: These Guidelines unfortunately do not properly consider the environmental aspects of forest leisure and recreation, from guided walks to mountain bike trials, and music concerts to motor car rallying. There must be a requirement to carry out forest leisure and recreation activities and events in an environmentally sustainable manner. This includes avoiding disturbance to sensitive wildlife species, habitats and designated sites. This includes the establishment, maintenance and operations of permanent facilities and activities, as well as the set-up, running and knock-down of individual events. The Guidelines need to stress the importance of good design, timing and management of leisure and recreational activities and events, and related forest planning and operations. The Guidelines also should mention the monitoring of environmental impacts. These Guidelines also need to have a requirement on forest businesses, including non-leisure enterprises, to carry out their operations in an environmentally sustainable manner that benefits, not harms wildlife. The regulatory and advisory roles of the statutory nature consideration agencies should be explained. Environmental non-government organisations may also be



a useful source of information. GQ 3 Technical Bearing in mind the function of the Guideline publications described in the diagram inside the front cover, do you feel the information is pitched at an appropriate level in terms of technical content?

Yes No Comments:




Yes No Comments (please include the bullet point reference number) There must be a requirement – ‘Guideline Bullet Point’ - to carry out forest leisure and recreation activities and events in an environmentally sustainable manner. This includes avoiding disturbance to sensitive wildlife species and habitats. The Guidelines need to stress the importance of good design, timing and management of leisure and recreational activities and events, and related forest planning and operations. The Guidelines also should mention the monitoring of environmental impacts. These Guidelines also need to have a requirement on forest businesses, including non-leisure enterprises, to carry out their operations in an environmentally sustainable manner that benefits, not harms wildlife. Paragraph 32: LCLCR2 – this bullet point needs qualifying to explain that open ground habitat restoration for priority species, priority habitats and designated site enhancement is permissible under the UK Forestry Standard and forestry legislation, including Environmental Impact Assessment. In Scotland the Forestry Act 1967 has been amended by the Nature Conservation (Scotland) Act 2004 to clearly enable this, in England and Wales Felling Licensing of such restoration works is granted without restocking conditions. The proposed Forestry Bill in Northern Ireland considers that open ground habitat restoration will not require restocking. Other Comments Other Comments: please use this space to submit any other comments your wish to make on the UKFS & Guidelines The RSPB welcomes the clear statement in Paragraph 11 of the Preface on the inclusion of short rotation coppice (SRC) and short rotation forestry (SRF) in the UK Forestry Standard, and therefore the requirement for SRC and SRF to conform to the standard. We also welcome the clear statement in Paragraph 12 of the Preface, on UK



Forestry Standard compliance within agricultural and development settings, and the need for non-Forestry Commission and Forest Service competent authorities to require and regulate UK Forestry Standard compliance. It is unclear when a regulator requires UK Forestry Standard compliance – for example as part of a Felling Licensing, EIA, forest planning approval, agricultural and forestry grant approval or planning permission – whether this means just ‘Legal Requirements’ or includes ‘Good Forestry Practice Requirements’. The RSPB considers that UK Forestry Standard compliance must include both ‘Legal Requirements’ and ‘Good Forestry Practice Requirements’. Section 4 of all the Guidelines ‘Requirements of the UK Forestry Standard’, and Paragraph 110 of the Standard, suggests that this is the case for UK Forestry Standard compliance, but this is not clear in Paragraphs 62 & 82 of UK Forestry Standard, or in all of the Guidelines under ‘Requirements’ in the Preface.



Guidelines: Please complete a separate sheet for each Guideline publication you wish to comment on. Comments on the Forests and Soils Guidelines GQ 1 General Do you feel The Forests and Soils Guidelines are adequate in terms of length and detail?

Yes No Comments: The RSPB has a number of concerns about the conservation and enehecment of peatland habitats, detailed below. GQ 2 Content Do you feel there are any omissions, or un-necessary inclusions?

Yes No Comments: These Guidelines need to briefly explain their context in relation to biodiversity and carbon issues related to afforestation and the restoration of priority open ground habitats, such as blanket and raised bogs and lowland heathland. This should include mention of government and devolved administrations’ country, UK, EU and International commitments to open ground habitat conservation, including in forestry and biodiversity strategies. It would be useful to mention the unimproved land EIA regulations – these may be applied for certain types/thresholds of woodland expansion where the Forestry Commission/Forest Service are not the competent authority, or the forestry EIA regulations do not apply. These Guidelines should explain that open ground habitat restoration is part of sustainable forest management policy and regulation, which can be consented under the UK Forestry Standard and forestry legislation. These Guidelines already outline measures to minimise soil and water impacts appropriate to open ground habitat restoration and onward management. The Guideline must refer to current practice requirements on afforestation on peatland soils, contained in:

Patterson, G. & Anderson, R. (2000) Forests & Peatland Habitats. Forestry



Commission Guideline Note 1. Forestry Commission, Edinburgh. http://www.forestry.gov.uk/pdf/fcgn1.pdf/$FILE/fcgn1.pdf & Forest Service (1993) Afforestation – the DANI Statement on Environmental Policy. Forest Service, Belfast. http://www.dardni.gov.uk/afforestation_-

_the_dani_statement_on_environmental_policy.pdf GQ 3 Technical Bearing in mind the function of the Guideline publications described in the diagram inside the front cover, do you feel the information is pitched at an appropriate level in terms of technical content?

Yes No Comments: No additional comments.




Yes No Comments (please include the bullet point reference number) These Guidelines should explain that open ground habitat restoration is part of sustainable forest management policy and regulation, which can be consented under the UK Forestry Standard and forestry legislation. This is needed to put the bullet points in context, for example SG30. These Guidelines already outline measures to minimise soil and water impacts appropriate to open ground habitat restoration and onward management. Paragraph 33: LCLCR2 – this bullet point needs qualifying to explain that open ground habitat restoration for priority species, priority habitats and designated site enhancement is permissible under the UK Forestry Standard and forestry legislation, including Environmental Impact Assessment. In Scotland the Forestry Act 1967 has been amended by the Nature Conservation (Scotland) Act 2004 to clearly enable this, in England and Wales Felling Licensing of such restoration works is granted without restocking conditions. The proposed Forestry Bill in Northern Ireland considers that open ground habitat restoration will not require restocking. Other Comments Other Comments: please use this space to submit any other comments your wish to make on the UKFS & Guidelines It is unclear when a regulator requires UK Forestry Standard compliance – for example as part of a Felling Licensing, EIA, forest planning approval, agricultural and forestry grant approval or planning permission – whether this means just ‘Legal Requirements’ or includes ‘Good Forestry Practice Requirements’. The RSPB considers that UK Forestry Standard compliance must include both ‘Legal Requirements’ and ‘Good Forestry Practice Requirements’. Section 4 of all the Guidelines ‘Requirements of the UK Forestry Standard’, and Paragraph 110 of the Standard, suggests that this is the case for UK Forestry Standard compliance, but this is not clear in Paragraphs 62 & 82 of UK Forestry Standard, or in all of the Guidelines under ‘Requirements’ in the Preface.



RESPONDENT INFORMATION FORM

CONSULTATION ON THE UK FORESTRY STRATEGY (UKFS) AND GUIDELINES Please complete the details below and return it with your response. This will help ensure we handle your response appropriately. Thank you for your help. Name: Amanda Campbell, Corporate and Forestry Support Postal Address: Silvan House, 231 Corstorphine Road, Edinburgh, EH12 7AT Are you responding: (please tick one box) (a) as an individual (b) on behalf of a group/organisation 2a. Do you agree to your response being made available to the public (on the Forestry Commission website)? Yes (go to 2b below) No, not at all We will treat your response as confidential 2b. Where confidentiality is not requested, we will make your response available to the public on the following basis (please tick one of the following boxes) Yes, make my response, name and address all available Yes, make my response available, but not my name and address Yes, make my response and name available, but not my address

SHARING RESPONSES/FUTURE ENGAGEMENT We will share your response internally with other Forestry Commission policy teams who will be addressing the issues you discuss. They may wish to contact you again in the future, but we require your permission to do so. Are you content for the Forestry Commission to contact you again in the future in relation to this consultation response? Yes No


CONSULTATION QUESTIONS (boxes can be expanded if necessary) · UK Forestry Standard and Guidelines:...

Documents

Transcript of CONSULTATION QUESTIONS (boxes can be expanded if necessary) · UK Forestry Standard and Guidelines:...