Nature Recovery Green Paper: Consultation Response

DEFRA is undergoing a major consultation to determine the future of legislation around protected sites and species. There is a large element regarding woodland creation & regulation, and I am sharing my answers below should anyone else need a point of reference to construct their own responses.

Link to respond to consultation: https://consult.defra.gov.uk/nature-recovery-green-paper/nature-recovery-green-paper/

9. Do you agree that there should be a single process for terrestrial designation?

Yes.

A single process would remove confusion from the perspective of applicants, as well as within competent bodies themselves, who often seem to struggle to understand their own regulations. The problem is not helped by high staff turnover.

However, there should also be a “light touch” / streamlined application process for smaller or less significant impact projects so these are not all lumped together with the most disturbing operations.

10. Should we reform the current feature-based approach to site selection and management to also allow for more dynamic ecological processes?

 No, neither for marine not terrestrial sites
Any reform is likely to result in more complexity, when there should be less.

11. How do we promote nature recovery beyond designated protected sites?

Make it financially worthwhile for farmers and landowners.

12. Do you see a potential role for additional designations?

No

There are too many as is!

13. Do you agree we should pursue the potential areas for reforms on assessments and consents?

Yes

As long as it makes the process more straight forward

18. Do you have suggestions for improving the EIA scope and process for the Defra EIA regimes?

Yes – Forestry EIA regime
The current process is slowing down applications and discouraging applicants from making use of the incentives on offer. The process needs to be streamlined, and allow for a wider range of benefits from projects rather than only considering impacts at the scoping stage. Different parts of Government are in disagreement with each other over what consists a “significant impact” and are making the process excruciating for applicants.

19. What are your views on our proposal to establish priority areas for afforestation?

Sounds good in principle – won’t work in reality unless these zone also come with a reduced regulatory pressure (still in line with industry standards) or additional financial incentives to owners and advisors, above what is being offered elsewhere.

21. What are your views on our proposal to reform forestry governance and strengthen protections for the Nation’s Forests?

We should be cautious in underestimating the benefit of timber production when valuing woodlands. The vast majority of our current woodland cover, which is low as a % of land use compared to the rest of Europe, is there because it was planted as a strategic reserve of timber. We currently import 80% of the timber that we use, and global demand is forecast to surge over the next 30 years, while domestic production will fall. If anything, maintaining timber productivity should be protected as a requirement for forest owners alongside the benefits of biodiversity, water protection and carbon. If owners are not fulfilling their obligations to produce timber, they could be penalised through lower subsidies etc.

22. What are your views on our proposal to adjust forestry permanency requirements for certain project types?

Useful for short rotation & energy crops. Limited life spans of 50 – 100 years for some timber crops could be established in order to encourage some farmers to try diversifying from intensive arable or dairy systems, while retaining flexibility for the future. Much like planting any other crop.

Schemes in receipt of high subsidies to create nature friendly woodlands for the long term should not be viewed as temporary.

29. What are the most important functions and duties delivered by Defra group ALBs to support our long-term environmental goals?

Supporting landowners and managers to achieve their aims. Providing advice and expertise where necessary. Using enforcement and regulation only when absolutely required to avoid damage or harm.

30. Where are there overlaps, duplication or boundary issues between ALBs, or between ALBs and government? How could these be addressed?

Closer working, although not full integration. There remains a benefit to specialist knowledge and proficiencies being contained within each department. Merging these stands to lose technical expertise and demotivate individuals, who currently feel a strong sense of loyalty and duty to their respective Agencies.

However, it should be compulsory to support the work and objectives of partnership bodies, and there should be a more formal arrangement of how this is achieved, including regular conferences and training between them.

31. What are the benefits and risks of bringing all environmental regulation into a single body?

As above. Loss of expertise, demoralisation, confusion from the private sector who no longer know who to deal with or have contacts on a particular issue.

There remains a benefit to specialist knowledge and proficiencies being contained within each department. Merging bodies stands to lose technical expertise and demotivate individuals, who currently feel a strong sense of loyalty and duty to their respective Agencies.

32. What are the opportunities for consolidating environmental delivery functions into a single body? Which programmes and activities would this include?

The RPA is a perfect example of why this doesn’t work – it has been an abject failure in how to do Government well.

There is a risk of turning all activities into a process driven, clerical nightmare, with no technical expertise or knowledge of the programmes allegedly being delivered at the Agency level.

33. Please provide your views on how more effective cost recovery for regulation would affect: a) environmental protections b) businesses

a) it might make people actually pay attention – especially the worst polluters

b) they would have to take this into account in their pricing and business models, ensuring staff are adequately trained.

36. What level of regulation is needed to incentivise private investment in nature while ensuring additionality and environmental integrity? 

accept that there could be an economic production value of land, even if it is being used for nature based projects – be that woodland (carbon) or farming.

An update on “Leaving no Trace”

I was asked how the trees mentioned in one of my previous posts – here – held up after the recent battering from Storm Arwen.

They have actually done surprisingly well. One of the exposed edges was North facing, so caught the full brunt of the wind, but I think because it is down in a depression escaped relatively unscathed. A few scattered trees have come down, but nothing major, and it seems like both the older & taller trees elsewhere and those on higher ground have fared the worst. Pine particularly has been badly affected, which is unusual.

A citizen-science project was launched last week by Forest Research, with the aim of using real life feedback from Foresters & land managers to verify and help calibrate the machine learning of various remote sensing techniques to detect changes in canopy cover, and therefore damage, from the storm. If you are out looking at woods and are able to feed into the project, see the link below.

https://windblow-assessment-forestergis.hub.arcgis.com/

Tall Trees, Short Stories Vol. 20 – review

I was happily surprised to be granted my request for a review copy of this new collection of tree-related short stories by author and well known Silvologist Gabriel Hemery (Sylva Foundation, “The New Sylva”). I listened to the audiobook version during a long trip to the Wye Valley and Forest of Dean, and I can think of nothing better suited for getting me in the mood to be surrounded by some fantastic trees.

As everything I have read of Gabriels’ in the past has largely been connected with scientific research or otherwise the art and science of growing trees (Silviculture), I didn’t really know what to expect from this short story format. All I knew was that it was going to be wood related, which is always a good start! I have to say I was pleasantly surprised.

I’m really impressed by the range of styles across the stories, which are all unique but definitely flavoured by the technical and scientific knowledge possessed by the author. Some of them start mysteriously, and it was hard to know where the story might be taking you or how it was going to come back around to trees. My personal favourite is set in some dystopian future landscape, and another explores the relationships between microscopic entities in an alternative reality that mirrors our own.

The audiobook is well produced and thoughtfully narrated; this format worked well for me and kept my attention throughout. There’s something here for everyone, from the experienced forest manager to the tree obsessed lay person, to entertain and learn more about tree science, functions, history and place within our culture.

Hemery has shown himself to be truly versatile writer, ranging from the factual and biographical to science fiction, folklore and beyond. I’m looking forward to hearing or reading the next book in this series, and recommend checking out some of the other publications listed above. Gabriel is currently working on an anthology of woodland “chronicles”, that you can contribute to with stories from interesting Woodlands around the country to feature within.

http://www.gabrielhemery.com

Leaving no trace

A few weeks ago, just as the days were starting to close in, I had a nice walk through the woods. I wanted to have a look at some felling work I knew had been going on during a period of wet weather and see the results. The area in question had been a fairly even-aged crop of Norway spruce (Picea abies) that had been planted along a burn (no buffers, pre UK Forestry Standard / UKFS). The forester was planning to remove the crop of spruce away from the burn and replant / allow to naturally regenerate with alder, willow, oak and other native broadleaves.

An oak sapling retained above the cleared burn (a Northern / Scottish word for stream).

This woodland (unlike others nearby) is not designated as a Planted Ancient Woodland Site (PAWS), though it would not be too much of a stretch to assume that this would have been broadleaved riparian woodland in the not too distant past.

A small oak. Remnant from a distant relative, or more recent addition?

This area of Hexhamshire is rich with hairy wood ant (Formica lugubris) which relies on sunny woodland clearings and rides to build its nests using pine or spruce needles. A nice side effect of the felling will be increased sunlight and better conditions for this species over the next few years before the new trees grow.

I was really impressed at how little ground damage there had been, given this was down in the soggy valley bottom next to a watercourse. The operators had used brash (tops) from the felled trees perfectly and protected their timber extraction route, which could have easily become rutted. Given that this was such a long, thin strip to work, there would have been a lot of traffic back and forth, especially to the far end to reach all of the timber. The results speak to a well planned operation and conscientious operators keen to achieve best results for the wood.

The area to the left of the picture below will continue to be thinned and managed as a productive Scots pine woodland (this area is also a red squirrel stronghold), and this one burn is just part of a much larger forested network that delivers many benefits including growing timber that will be used to build houses, create packaging and generate warmth.

The forester was not forced into removing the conifers from this watercourse; it was their own recognition of bringing the management of the woodland in line with UKFS and sacrificing a relatively small area in terms of productivity to bring extra benefits. It’s living testament to #ForestsThatWork delivering ecological, economic and landscape value.

In any case, all this is to say; this is what modern day, mixed, commercial forestry can look like. I feel like it needs to be spoken about more widely, as there are so many misconceptions.

I also found a really nice rock in the woods and sat on it like Simba on Pride Rock.

Thanks for visiting the blog, and it’s great to recognise good practice – Colin Stevens forestry did the harvesting, managed by Euroforest. Ben Anderton is the Forester at Edwin_Thompson charged with organising the felling licences, sale, and with overall responsibility for the forest.

Cheerio!