Woodland Trust response to ‘Sustaining the land’ a review of land management actions under Axis 2
December 2008
Coed Cadw (The Woodland Trust) welcomes the opportunity to respond to this consultation. The comments that follow are delivered on behalf Wales’ leading woodland conservation charity. We achieve our purposes through a combination of acquiring woodland and sites for planting and through wider advocacy of the importance of protecting ancient woodland, enhancing its biodiversity, expanding woodland cover and increasing public enjoyment. We own over 1000 sites across the UK, including over 100 in Wales, covering a total of approximately 20,000 hectares (50,000 acres). We have 300,000 members and supporters across the UK.
The Woodland Trust view
Coed Cadw is pleased to input into this review which provides a key opportunity to promote sustainable land management and establish schemes which are better suited to the future challenges facing farmers, wider society and the environment.
Despite containing many welcome proposals, the document fails to recognise the huge potential of trees and woodland to help meet the key challenges we face and deliver the outcomes that the Welsh Assembly Government has itself identified in the Environment Strategy. For example, it is not clear from the consultation paper how woodland management and woodland creation fit into option 2 or 3 of the consultation paper.
Creating new woodland removes carbon dioxide from the atmosphere and locks it up in the form of wood. Woodland creation can help provide ‘soft’ defences against flooding, turning the landscape into a sponge that can absorb heavy rainfall and then release it gradually. Ancient semi natural woodland is one of the most wildlife-rich habitats we have in the UK, and creating more native woodland would help make the whole landscape more welcoming to wildlife.
We strongly support the commitment in the One Wales document to “provide support for indigenous woodlands…helping to create a Welsh National Forest of native trees to act as a carbon sink.” We also welcomed the Assembly Government’s Woodlands for Wales consultation document issued in July which stated: “We wish to see a stronger link between woodland and other land uses, especially agriculture, so helping to deliver more benefits through integrated land management” as well as: “We intend to increase net woodland cover in Wales”.
Since around 80 per cent of Wales is farmland, this is unlikely to happen unless this vision is incorporated into agri-environment schemes. While we strongly support the Better Woodlands for Wales grant scheme, we recognise that this is not necessarily the most effective way of supporting and encouraging woodland management of small areas of farm woodland. Of more than 17,000 ha of broadleaved woodland on Tir Gofal farms by 2007, only a very small proportion was being actively managed under Better Woodlands for Wales agreements.
We would suggest that the Pontbren scheme in Montgomeryshire, unique to Wales, provides an excellent model as to how this approach might work in practice, how farmers can create and manage native woodland on their farms and by so doing benefit both their own businesses and the wider environment and sustainability.
While Coed Cadw is in sympathy with the underlying aims of the consultation, we believe the important policy that follows would be more effective if it fully recognised what woodland and trees offer for the future of our countryside.
1. Do you agree that current land management schemes deliver only imperfectly against the Assembly Government’s wider environmental objectives?
• The Woodland Trust agrees that the current land management schemes only deliver imperfectly against wider objectives. However we would caution that this will always be the case, to some degree, due to changing objectives and our incomplete understanding of interactions of environmental systems.
• In addition we would comment that the Table in Appendix 1 is unclear. It does not specify where the objectives have come from and gives no description of how the scores have been determined. The Woodland Trust believes that some of the scores in this box are inaccurate.
2. Would a move to an outcome-based approach help to overcome this difficulty?
• An outcome based approach has the potential to overcome this, however how the outcomes are evaluated will be equally as important.
o Ecological systems are difficult to measure and evaluate and as such monitoring may never be able to completely describe whether the outcomes have been reached.
o These levels of uncertainty need to be accepted within the scheme and broad brush ecological measures used to evaluate the schemes rather than narrow ‘box ticking’ measures.
3. Do you agree that a feasibility study should be commissioned to investigate the possibilities of a carbon trading approach in Wales?
• The Woodland Trust does not agree a study should be commissioned at this stage for two reasons
o Firstly due to the scale of the uncertainties around carbon flux, in particular in relation to greenhouse gas emissions from agriculture
o Secondly it is unclear from the consultation document what a carbon trading approach should entail and the justification for it. We are particularly concerned that a carbon trading approach would be subsidised by public money especially if there are financial benefits to the trading.
• A better approach may be to look at farm carbon budgets within GAEC.
4. Have we identified all of the main drivers for future land management support? If not, which other drivers do you think are important?
• We have three main areas to address in response to this question:
o It is unclear from the consultation document what WAG considers drivers/outcomes
o Climate change impacts are not included among the drivers/outcomes
o The need for more clarity on the priority of the drivers/outcomes
• The consultation document lists a number of outcomes and then describes these in more detail, however there are also sections on organic farming and common land. We believe that these are important considerations within a land management scheme yet it is not clear from the document how they fit into the listed outcomes of the scheme.
• Most of the main drivers and outcomes are detailed in the consultation document. But climate change impacts are not directly addressed. It is unclear whether such impacts will be considered within the other outcomes such as biodiversity and landscape.
o Carbon management alone does not address the current and future climate change impacts which we are already locked into.
• A number of drivers/outcomes are detailed in the document and it would be useful for more clarity on how and if these have been prioritised.
o The Woodland Trust feels that all these outcomes are important and so should be given equal weighting, biodiversity in particular seems to have a much lower profile and role within the document and the proposed scheme options. As such carbon management, and possibly climate change impacts if these are included, could be drawn out as cross cutting outcomes, but this should not confer precedent over other outcomes. Could mention that biodiversity, in particular, seems to take rather a back seat in this section?
5. Are the management actions identified in section 4.1 and Appendix 2 for conserving soil carbon the right ones? Will they be effective? Are there others we should consider?
• The Woodland Trust has eight areas to address in response to this question:
o The actions are not sufficient in improving resilience to climate change impacts
o The actions are purely for soil carbon and ignore the other functions of soil
o The need for certification of bioenergy crops
o Concern than other emissions from agriculture are not addressed
o Woodland protection should be listed as an action for soil carbon conservation
o Support for woodland planting to increase soil carbon sequestration
o Disagree with the statement that woodlands need to be managed
o Concern for SRC planting on grassland
• The management activities highlighted in section 4.1 and Appendix 2 may be effective at conserving soil carbon, but they will not be effective in improving resilience to climate change impacts and there is a risk that they could be detrimental to other aims.
o Improved resilience is stated as a WES outcome. Actions to achieve this need to be over a wide range of areas including biodiversity and landscape. Biodiversity actions are especially urgent and need to focus on protecting, enhancing and increasing the areas of semi-natural habitat whilst also ensuring that intervening land uses are as sympathetic to wildlife as possible. Conserving carbon, product substitution and sequestration alone will not achieve this.
o The Woodland Trust is concerned that a focus purely on carbon could lead to the planting of conifer monocultures which would detrimental to biodiversity and landscape aims.
• Land management schemes also need to consider the role of soil in delivering other ecosystem benefits and ensure that actions for soil carbon do not impinge on the ability of soils to perform other functions. WES outcome 16 is stated in the consultation document and refers to other functions of soils yet the consultation focuses on soil carbon only.
o It is important to consider soils, and the wider environment, holistically rather than viewing functions/benefits in isolation. Soils, and soil health, are fundamental to ensuring sustainable land-use that delivers a wide range of benefits, in terms of both biodiversity and ecosystem services.
o It might be better to focus on a concept of “soil health” which includes soil carbon as a key component, rather than on soil carbon alone. This in turn needs to be viewed in context with other elements such as water and air quality, and land management.
• To ensure that bioenergy delivers genuine greenhouse gas savings, without negative environmental impacts, it must be subject to a robust system of assurance or certification. For the production of woody biomass this means UK Woodland Assurance Standard and Forest Stewardship Council certification, but there is currently no equivalent for agricultural crops. Any certification system must be internationally agreed to avoid the problems simply being pushed overseas.
o In the absence of such a system of certification, it is crucial that systems are put in place to ensure that bioenergy crops produce maximum greenhouse gas savings, without negative environmental impacts, and where possible produce positive environmental benefits. For example, short rotation coppice and forestry could provide beneficial habitat, especially if native species are used, and if sited adjacent to existing ancient and semi-natural woodland where they will provide a buffer against the effects of more intensive land use.
• Carbon and carbon dioxide are not the only greenhouse gases. Natural England’s CALM report (2007) points out that methane and nitrous oxide are the two major agricultural emissions for most farm types. Climate change mitigation strategies based on changes to agricultural practices need to address these far more potent greenhouse gases in order to ensure that any new schemes do genuinely deliver on climate change.
• The consultation document states that the greatest soil carbon density in the UK is found beneath woodland. As such we find it imperative that woodland protection, i.e. no loss of woodland area, is added to the list of management actions to conserve soil carbon. The value of soils in ancient woods, in particular has not been well-researched, but by virtue of their long continuity and lack of disturbance these soils are especially important for their carbon content and their biodiversity.
• The Woodland Trust supports the need to plant new permanent woodland for soil carbon sequestration, which will also have benefits for biodiversity, especially where native woodland is created. However we think that woodland planting should be targeted to areas of mineral soils where the carbon content is low. This planting could also have additional biodiversity benefits if native species are used and if sited adjacent to existing ancient and semi-natural woodland where they will provide a buffer against the effects of more intensive land use.
o In addition we feel the picture presented in the consultation document is very much simplified and the amount of carbon sequested is highly variable and needs further investigation.
• We are concerned with the blanket statement on page 21 of the consultation document which states the need for bringing farm woodlands into management. While active intervention and management may be beneficial in some woodlands it is not suitable for all. Ancient semi-natural woodlands in particular harbor a wide range of species with a preference for undisturbed habitat and ecological continuity. Interventionist management of such woods may not be the best way to conserve and enhance their biodiversity value.
o In addition intensive forest management systems can damage soils leading to a loss of carbon. As forest soils store more carbon than the woody biomass of trees this should be avoided.
o Any management undertaken needs to be sustainable and adhere to the UK Forestry Standard and where possible UKWAS/FSC certification.
• The Woodland Trust is concerned with the statement on page 21 on the need to plant SRC on grassland. We believe this statement should be amended to say ‘improved grassland’ as unimproved grassland is an important semi-natural habitat for biodiversity which should not be destroyed for bioenergy production.
6. Do you agree the Assembly Government should support the development of renewable energy based on woody biomass by stimulating local demand?
• The Woodland Trust agrees that there may be a role for the Assembly Government in stimulating local demand and supporting development of the appropriate infrastructure to enable viable markets for woodfuel. However we feel this is not appropriate for the Axis 2 budget and should be financed from Axis 1 or other sources.
o We are concerned however that the consultation document does not discuss the need or rationale for stimulating local demand and as such a stronger case may need to be developed for funding.
7. Do you agree with the proposed approach to water quality and quantity management? If not bearing in mind the legislative drivers, what approach should we adopt?
• We agree with the proposed approach with some caveats. We have three comments below:
o Pleased with the catchment approach
o Concerned with the acceptance that water quality will get worse
o Support for tree and shelterbelt planting for water quantity issues
• The Woodland Trust is pleased to note the need for water management to take place across catchments and for measures to be targeted at whole catchments.
• We are concerned with the description on page 23 that water quality is expected to get worse at the end of the plan period. We feel this is unacceptable given the Water Framework Directive aim of preventing deterioration.
o Allowing deterioration will make the step to good ecological status that much harder to achieve.
• The Woodland Trust supports the proposed measures for water quantity improvements including streamside tree planting and contour shelter belts.
o Our recent research has shown the benefits trees and woodlands can have for controlling sediment, overland flows and flooding which you may find useful: www.woodlandtrust.org.uk/water
Additional comment
• The Woodland Trust is particularly concerned that the consultation questions do not address biodiversity
• Our view is that the biodiversity section expresses some good sentiments but is somewhat contradictory. For example the document states the need to act across the countryside rather than focus effort on designated sites. However the next paragraph then discusses the need to target action.
• We support the need to act across all of Wales but are concerned this action for biodiversity does not appear to flow through to the proposed options
• The Woodland Trust is also concerned that biodiversity does not seem to be given adequate weight within the consultation document and the proposed options.
o All the aims must be considered equal, even if we are at the very least to retain those benefits generated by the previous schemes
8. How should land management schemes be targeted to meet wider objectives?
• The intent of this question is unclear. If it refers to meeting the outcomes listed in the consultation document then we support the ‘pyramid of support’ approach.
o As such, meeting wider objectives requires making basic improvements across whole landscapes rather than targeting specific locations.
o Such basic improvements need to be informed by the objectives and outcomes of the scheme, which currently are unclear in the consultation document.
o For biodiversity we would suggest that this could be evaluated through simple measures such as area of wildlife habitat, areas of contiguous wildlife habitat and areas of habitat creation adjacent to existing habitat.
9. Do you agree that Better Woodlands for Wales should continue to provide support for woodland management? If not, how should this be best achieved?
• The Woodland Trust partly agrees and has a supportive comment on grants and licensing
• Better Woodlands for Wales should also be looking to increase woodland planting levels in Wales.
o Woodlands are important for a variety of reasons, including water management, carbon management, and biodiversity as the consultation document states.
o A focus on woodland management would therefore miss this important activity.
• With regard to comments on page 29 about amalgamation of woodland and agricultural grants the Woodland Trust is in support of this where it simplifies grants for the customer and reduces overheads.
o However such an approach would need to resolve the disparity in payment rates and methods between the woodland and agricultural schemes.
10. What improvements should be made to increase the impact of support for landscape and the historic environment?
• We believe that it is important for ancient trees to be considered as part of the landscape and heritage environment. Trees are often only considered in landscape terms but ancient trees in particular have high heritage value and close ties to communities.
o We would be pleased to work with the Assembly Government on this and have developed a number of Ancient Tree Guides which give information and guidance on the importance of ancient trees and how to look after them. For example: www.woodlandtrust.org.uk/publications/publicationsmore/ancienttreesandfarming.pdf
11. Is the intention to target support for permissive access on strategic routes appropriate? Can it be improved?
• [no response to this question]
12. Are the proposals for fully integrated monitoring and evaluation appropriate? How should we determine what outputs and outcomes should be measured?
• The Woodland Trust believes it is important for monitoring and evaluation to be integrated into the schemes and support the Assembly Government in achieving this.
o The measures chosen to evaluate the schemes are particularly important as we described in our response to questions 1. and 2. above.
o We believe that the style of outcomes, evaluation and description the Assembly Government has used in its GAEC standards is a good model and a similar style should be used in the Axis 2 schemes.
13. Have we identified all of the main options for future land management support? If not, what other options do you think should be explored?
• We do not believe all of the options have been explored in the paper. Of greater concern to us is the absence of any information on woodland management for two of the three options (options two and three). The protection and management of woodlands is of crucial importance to the biodiversity, landscape and communities of Wales.
o We are also concerned at the lack of explanation and justification for the options included
14. Do the options fully address the key objectives underlying public expenditure on environmental land management? Do you think that one or more of the options represent value for money?
• The Woodland Trust do not believe the options presented address the objectives underlying public expenditure for two reasons
o Firstly, two of the three options do not mention woodland management
o Secondly, the objectives and their priority have not been fully justified. The document leans heavily towards carbon and water management, neglects the other objectives and fails to address the need for climate change adaptation. Yet the reasons for this are not described or explained.
15. Which option(s) do you prefer, and why?
• We believe that options two and three have the most potential and detail our reasons and concerns below.
• Option two follows the accepted pyramid of support model but should improve upon how this is currently delivered in Wales.
o This would seem a logical choice that is relatively simple to implement and communicate to land managers.
o We do however have some concern about the basic level of this option as it would be developed from Tir Mynydd. Whilst we recognise the difficulties of hill farming if this part of the scheme is to be funded from Axis 2 money we believe it needs to be solely focused on delivering environmental benefits and as a result helping to support rural communities. An approach which focuses on explicitly supporting local communities and economies should be funded from Axis 1 and/or 3.
• Option three is more radical in its approach, which would make it more difficult to implement. However the concept behind it is sound and this approach could deliver a great deal more in terms of public benefits and sustainable improvements to the environment.
o Advantages:
• It would result in much greater joined up landscape scale action, rather than the current piecemeal approach.
• A greater proportion of the budget could be spent on significant environmental improvements as basic protection and management is encompassed within cross compliance.
• This approach may make it easier for Welsh farmers to adapt to future reforms of the CAP. These reforms should include abolishing the current two pillar system and adopting a European sustainable land management fund instead, as detailed in the publication Beyond the Pillars. http://www.wcl.org.uk/docs/Link_Beyond_the_Pillars_11Mar08.pdf
o Concerns:
• The approach to woodland management is not mentioned
• A focus on carbon and water exclusively in the first ‘tier’ of the scheme is unacceptable. Whilst it may be appropriate to focus on water and soil and make these compulsory elements there should be options for the other objectives especially biodiversity. This is not only to retain and build on the improvements that will have been made under other schemes but to ensure the scheme offers the best value for money and delivers the greatest amount of public benefit. Without options for biodiversity across all of Wales the Assembly Government is unlikely to reach the biodiversity outcomes set out in the Environment Strategy.
• Whilst we support in principle moving basic land management actions into cross compliance we are unsure how effective this will be. Land managers in other parts of the UK have been particularly resistant to new measures within cross compliance. Without significant monitoring and on farm checks we are not convinced this will be delivered.
• Current monitoring is not adequate to ensure that cross compliance is adhered to or to gauge the impacts of this option.
• ‘Tier’ three of this option describes a modified Tir Gofal which is primarily focused on protected areas. We are concerned at this targeting as it suggests there may be some areas of Wales which will not be eligible for any agri-environment money (as the basic actions will have moved into cross compliance). In order to ensure environmental improvements have the greatest effect and are sustainable actions need to be taken across the whole Welsh landscape.
• The Woodland Trust would like to see more emphasis on climate change adaptation rather than simply mitigation. The effects of climate change are already apparent and given the long-term nature of land management processes, the sooner work begins on adaptation measures the better.
Coed Cadw (the Woodland Trust), Unit 3, Coopers Yard, Curran Road, Cardiff CF10 5NB
www.coedcadw.org.uk
www.woodlandtrust.org.uk/campaigns
www.epolitix.com/forum/woodland-trust
For further information please contact:
Rory Francis on 08452 935 860, email: roryfrancis@woodlandtrust.org.uk or
Fran Hitchinson on 01746 581142, email: franhitchinson@woodlandtrust.org.uk
