Response by Coed Cadw (The Woodland Trust) to the consultation on Woodlands for Wales: The Welsh Assembly Government's Strategy for Trees and WoodlandOctober 2008
1. Introduction
1.1. Coed Cadw (The Woodland Trust) welcomes the opportunity to respond to this consultation. The comments that follow are delivered on behalf of 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 and trees, enhancing its biodiversity, expanding woodland cover and increasing public enjoyment. We have over 1,000 sites in our care covering approximately 20,000 hectares (50,000 acres). These include over 100 sites in Wales, with a total area of 1,580 hectares (3,900 acres). We have 300,000 members and supporters across the UK. Coed Cadw has four key aims: i) No further loss of ancient woodland; ii) Restoring and improving the biodiversity of woods; iii) Increasing new native woodland; iv) Increasing people’s awareness and enjoyment of woodland.
1.2. Coed Cadw is an active member of Wales Environment Link and has also signed up to the WEL joint response to this consultation response. This response, however, goes into more detail of our proposals for allowing the people of Wales to derive greater benefits from woodland.
1.3. Woods are crucial to sustaining life on earth. They take in carbon dioxide and return oxygen to us. They enhance the quality of our lives and environment with their richness of experience and biodiversity. It is surely our collective responsibility to protect, restore and enhance the distinctive woods, parklands and forests of Wales. Our vision is to see the wooded landscapes of Wales put in good heart through sustainable management, our rich natural and cultural heritage of ancient woods, parklands and ancient trees protected and broadleaved woodlands expanded. We wish to see woodland and trees enjoyed and appreciated by the public and by government for the wide range of benefits they provide. Trees and woodland help make our lives rewarding and healthy. They give us green spaces for recreation, create attractive landscape, support wildlife, contribute to our historic environment, provide employment, and can produce timber, one of the most sustainable of materials. The public have already given a lead on this. In 2005, 30,000 individual donations were made in support of Coed Cadw’s campaign to acquire and restore a substantial part of Wentwood, Wales’ largest remaining ancient woodland. But it is down to the Assembly and its sponsored bodies to provide leadership in protecting, expanding and making the most of Wales’ woodlands. The Welsh Assembly has made a good start in managing its own woods for the people of Wales. But there is so much more to be done and we hope that the new Woodlands for Wales Strategy can deliver much of this.
2. Key points
2.1. Coed Cadw warmly welcomes the consultation document. If the ideas and suggestions outlined in it are carried through, the new strategy should be a significant improvement on the previous version published in 2001. In particular Coed Cadw welcomes:
• the firmer commitment towards restoring ancient woodlands that have been planted with conifers through a gradual process favouring continuous cover silviculture
• the recognition of the benefits that could result from an expansion of woodland cover in Wales,
• the prospect of increased protection for individual trees, particularly veteran and ancient ones and
• the recognition of the many different ways in which woodlands and trees can help achieve the Assembly Government’s ambitions for Wales and address the problems of climate change.
2.2. The final strategy needs targets. We are very much aware, however, that this document is a consultation paper rather than a statement of agreed policy. We believe that if the many very positive outcomes outlined in the document are to be fulfilled, then the finished document will need to include targets for the delivery of public benefits. These should include the restoration of planted ancient woodland sites, biodiversity, climate change adaptation, landscape, access and historic environment benefits from private, state and public woodland.
2.3. The Assembly’s Environment Strategy for Wales includes a commitment to the outcome that: “The wider environment is more favourable to biodiversity through appropriate management, reduced habitat fragmentation and increased extent and interconnectivity of habitats”. There is also a commitment to the outcome that: “The loss of biodiversity has been halted and we can see a definite recovery in the number, range and genetic diversity of species, including those species that need very specific conditions to survive”. Coed Cadw stresses that if the new native woodland referred to in the consultation document is indeed created, on a significant scale and in the right suitable locations, this could go a long way towards delivering those these outcomes. If this does not happen, it is doubtful whether these commitments will be met at all.
2.3 The consultation document implies there will be significant changes in the way the Assembly woodland estate is managed. In particular, the statement: “We intend to manage all Plantations on Ancient Woodland Sites in line with best practice restoration guidance on the Assembly woodland estate”, is at odds with recent practice in parts of the National Assembly’s woodland estate, for example in Wentwood Forest near Newport. Areas of ancient woodland at Wentwood have been clear-felled over the last two years. Worse still, damaging ground preparation work is being carried out prior to replanting with even more conifers. We believe that this is causing irreversible damage to Wales’ ancient woodland heritage and we hope that the FCW will take on board the vision outlined in the consultation document, and implement it in Wentwood and across Wales. Coed Cadw very much hopes that the Commission will hold back from the final act of planting a further crop of conifers in Wales’ largest remaining ancient forest. We even offer to provide some native saplings ourselves if this helps.
Responses to specific questions
Q1. We propose to deal with the uncertain future demands on Welsh woodlands (including climate change) by increasing the diversity of all woodlands in terms of their tree species and provenance, stand structure, type of management, timber products and biodiversity. Do you?
Coed Cadw response: Agree. In terms of diversifying the forestry estate in general and moving towards mixed woodlands, but this should not mean the same mixed woodlands everywhere and we do not support the dilution of semi natural woodlands by extensive planting of non indigenous species.
What positive or negative impacts can you see to this approach?
In terms of positive impacts, there is an urgent need to implement climate change adaptation strategies to conserve and create landscapes that will be welcoming to wildlife in a time of rapid climate change. The urgency is because of the scale of action required and the timescale needed for habitats to develop to maturity. Such strategies have to focus on whole landscapes rather than on individual sites. Moreover by making natural systems more resilient, not only will biodiversity benefit but human society will also benefit from the ‘services’ which natural ecosystems provide such as flood relief, healthy soils, carbon sinks and future sequestration, water quality and renewable natural resources. Ancient and native woodland, as the most widespread semi-natural habitat in the UK, is uniquely placed to act as a key component of a more sympathetic and receptive landscape for wildlife in the face of climate change.
Developing resilient natural systems in the face of climate change requires landscape scale action. Much of this is sound conservation practice which becomes even more relevant in the face of climate change. In terms of woodland and wildlife this means:
• conserving all semi-natural habitats not just a representative sample of sites,
• restoring all ancient woodland and important semi-natural habitats planted with non-native conifers,
• targeting habitat creation in areas where there is greatest potential to put woodland on a sustainable
footing, namely in the greatest existing concentrations of ancient or semi-natural habitats,
• buffering semi-natural habitats from negative effects of intensive land use and extending their core area
• and reducing the intensity of the intervening land-use practices between semi-natural habitats in order to increase the ability of biodiversity to move across landscapes.
However, in terms of possible negative impacts, Coed Cadw does not subscribe to the view that the management of woods is always and everywhere better for biodiversity. Ancient semi-natural woodland that would be described by foresters as being “over-mature” is actually rich and increasingly rare habitat that should be valued and protected.
Q2: We intend to use continuous cover as the default management choice on the Assembly’s woodland estate and encourage this approach, through grants, for other woodlands. Do you:
Coed Cadw response: Agree
b) What positive or negative impacts can you see to this approach?
Coed Cadw supports the use of Continuous cover forestry, as this is the preferred method for restoring planted ancient woodland to native cover, and we urge FCW to comprehensively adopt and champion this approach on the Assembly’s estate. There are also likely to be landscape and community benefits as the ugliness of clear-felling is avoided. We recognise that there may be situations where continuous cover forestry may not be appropriate, for example a plantation on Western hemlock on an ancient woodland, in which the hemlock will keep regenerating unless it is clear-felled.
Question 3. We intend to increase net woodland cover in Wales. Do you:
Coed Cadw response: Strongly Agree
b) What opportunities or barriers do you foresee?
Coed Cadw warmly welcomes the intention outlined in the Consultation Paper to increase net woodland cover and create new native woodland. We wish to support the Assembly Government in developing and achieving this outcome and a summary of our own woodland creation strategy for Wales is appended. The undertaking in the One Wales Agreement to provide support for indigenous woodlands, including a tree for all new babies and adopted children, helping to create a Welsh National Forest of native trees to act as a carbon sink, means that this clearly needs to be a priority. We fear, however, that good intentions in this regard could remain just that, unless a some sort of target for native woodland creation is adopted.
We believe that this has the potential to deliver a whole range of benefits in social, environmental and economic terms. In social terms, accessible woodland can significantly increase the quality of life in towns and cities. Environmentally, it provides not just habitats for wildlife but also potentially a means of better managing water and avoiding flooding. Economically, woodland can provide a sustainable supply of timber, the carbon for which has actually been extracted from the atmosphere. Wales is among the least wooded countries in Europe yet forests, trees and woods are fundamental to our well-being as individuals and as a society.
The Forestry Commission Wales’ policy has been favourable towards woodland creation for some time, yet the rate of woodland creation in Wales in recent years has lagged well behind England and Scotland, and has quite often lagged behind Northern Ireland as well.
In 2006/7 8.5K hectares were planted of which 3.1 was in England, 4.6 in Scotland, 0.4 in Wales and 0.5 in N. Ireland. Planting of broadleaved and coniferous planting totalled 10.4K hectares in the UK.
Therefore, if the Assembly is keen to create more native woodland, in line with the One Wales pledge to create a national forest of native trees, then we strongly urge the Commission to adopt a target figure and to monitor progress towards delivering that. We believe this target should go substantially beyond the existing government commitment to the woodland expansion target within the woodland Habitat Action Plan.
The Scottish Government has made clear its aspiration of achieving 25 per cent woodland cover in Scotland by the second half of this century and has referred to its desire to create 10,000 hectares of woodland a year in order to achieve this. However, this is not limited to native woodland.
Coed Cadw has suggested a target of increasing native woodland cover by two thirds over the next 30 years, from just 5.6% to 9.3%. This implies creating 2,563 ha of new native woodland per year.
Coed Cadw would like to see this target achieved through a properly funded grant system for woodland creation, offering the most generous support in situations where the public benefits are greatest.
We believe that the single greatest barrier to new woodland creation is the interpretation of the GAEC regulations regarding Single Farm Payment. We believe these should be amended to allow farmers to create small areas of woodland on their farms, as the Pontbren farmers have done, without loss of Single Farm Payment. We believe that such areas of woodland could be of great benefit in terms of water management, wildlife habitats and as a supply of biomass. Areas of woodland have been part of the mosaic of the farmed landscape for centuries. New woodland created on this basis could be grazed at some point over, say, a 30 year cycle, thus ensuring that it remains part of the farm economy.
Question 4. We propose using a tiered grant structure to encourage new woodlands in locations relating to strategy outcomes, but allowing the exact location to be market-led within this framework. Do you?
Coed Cadw response: Strongly agree
b) What opportunities or barriers do you foresee to adopting this approach?
Coed Cadw believes that the incentives for woodland creation should vary according to the public benefits that particular schemes offer. There should, in our view, be higher levels of grant per hectare for woodland creation:
o In areas adjacent to ancient woodland, within or adjacent to habitat networks identified by the Countryside Council for Wales. The current targeting within Better Woodlands for Wales needs to be modified to fully support this criterion and
o In areas where woodland creation will increase the number of people who benefit from having at least 2ha of accessible woodland within 500m of where they live, or 20ha of accessible woodland within 4km of where they live.
Question 5. We intend to weigh up whether a change in woodland type or management would bring greater benefits, before agreeing to permanent deforestation for restoration of other habitats or for landscaping reasons. Do you:
Coed Cadw response: Agree – but we are in favour of permanent deforestation in the circumstances outlined below.
b) What advantages or disadvantages can you see to of this approach?
Coed Cadw is aware that there are important open-ground semi-natural habitats, such as blanket and raised bogs and moorland, that were inappropriately planted with forestry in the last century. We support the work which FCW has already done to identify sites like this which would offer greater public benefits, in terms of meeting Habitat Action Plan and other biodiversity targets and in providing ecosystem services as moorland. Once identified, these sites should be restored as open ground habitats.
Question 6: We propose to encourage timber and woodfuel production within sustainably managed woodlands, as the best way to increase the carbon stored in woodlands and timber products. (links to chapters 2 & 5) Do you:
Generally agree but with important reservations outlined below.
b) What advantages or disadvantages can you see to this approach?
Coed Cadw believes urgent measures are needed to mitigate climate change, reducing greenhouse gas emissions by curbing energy consumption, increasing energy efficiency, and the use of renewable energy sources that provide real carbon savings.
Coed Cadw feels that although carbon sequestration has an important role to play in woodland creation, it should not be the primary policy driver in woodland expansion, but should be one of the associated benefits of multi-benefit native woodland creation. We believe that this provides the greatest range of benefits to people and the environment.
Bioenergy in the UK, and timber production, can offer some positive opportunities to enhance woodland biodiversity, and contribute towards measures to help adaptation of wildlife to climate change. However, there is also a risk that bioenergy developments could have a negative effect on biodiversity and the environment. Coed Cadw supports the development of bioenergy in general and woodfuel in particular where it offers genuine greenhouse gas savings, where it does not negatively impact on biodiversity, and, if possible, delivers positive biodiversity benefits.
If produced sustainably, bioenergy is likely only to be a relatively small part of the solution to the problem of climate change in the UK. Other renewable sources of energy will also play a part, but over-arching all policies on bioenergy must be a recognition by Government and others of the need to reduce consumption through energy-saving measures.
Coed Cadw supports the development of small-scale, local biomass projects such as wood-fuel heat and power, which minimise the costs and carbon emissions associated with transport. However, we have grave concerns about the view taken by others, including the Forestry Commission, that improvement of biodiversity is a rationale for bringing existing “under-managed” semi-natural woods “back into management” to provide wood for the bioenergy markets. It is unclear what sort of management is being suggested, or what sort of biodiversity, or more specifically protected species, is set to benefit. There is a risk that intervention could have a negative impact on biodiversity through eutrophication, importation of invasive species etc. We would prefer to see efforts focused on win-win solutions such as restoration of PAWS and other semi-natural habitats planted with conifers, and planting of new woodland habitats to buffer semi-natural ancient woods.
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.
Current evidence is that the greatest potential greenhouse gas savings can be achieved through burning of woodchip to generate heat, gasification of biomass to produce electricity and the use of second generation biofuels produced from biomass. Coed Cadw would therefore like to see bioenergy policies place greater emphasis on the use of woody biomass crops for these purposes, rather than on agricultural crops such as sugar beet and wheat for the production of biofuels.
Coed Cadw would like to see more research carried out into the biodiversity and landscape impacts of bioenergy crops.
Based on Coed Cadw’s position statement on genetically modified organisms, Coed Cadw is opposed to the development and use of GM crops for bioenergy.
Question 7: We propose to continue supporting initiatives to promote the use of wood as a way of addressing our low carbon policies. (links to chapters 7) Do you:
Coed Cadw response: Agree but with important reservations.
b) What advantages or disadvantages can you see to this approach?
As outlined above, the production of a sustainable supply of timber is one of the economic benefits that woodland offers. It is vital, however, that any promotion of the production of timber is limited to timber that is certified as being produced sustainably, through UKWAS and FSC. Moreover, Coed Cadw does not subscribe to the view that the management of woods is always and everywhere better for biodiversity. Native woodland that would be described by foresters as being “over-mature” is actually rich and increasingly rare habitat that should be valued and protected.
Question 8: We are considering creating a system whereby compensatory planting is required if there is permanent removal of woodland for development (links to chapters 2 & 6)
b) What opportunities or barriers can you foresee in adopting this approach?
Planning Policy Wales (paragraph 5.2.8) makes clear that the destruction of ancient woodland as part of planning applications is not acceptable. In this case, therefore, compensation is irrelevant.
In the case of compensation to local communities where secondary woodland was lost due to development, the compensatory planting of native woodland is likely to offer significant environmental and social benefits and , Coed Cadw strongly supports this approach.
This approach could cause problems, however, in the case of coniferous plantations on what were previously wildlife-rich open ground habitats. It would actually create a barrier to the Forestry Commission Wales doing the right thing by removing the plantation, unless and until a compensatory site had been identified.
Question 9: We propose that the scope of the strategy will include urban tree planting for climate change mitigation and wider environmental reasons. (links to chapter 4) Do you:
Coed Cadw response: Strongly agree
b) What opportunities or barriers can you foresee in adopting this approach?
Woods and trees are essential in urban environments because they help to clean the air, trap dust, reduce storm water run off, reduce noise and pollution, and help to reduce asthma levels.
Less tangible but vital to individuals from an emotional and recreational standpoint is their role in enhancing the local landscape, providing a tranquil environment for spiritual renewal. In order to achieve better social inclusion, action to reconnect people with the environment is vital. We must all be connected to the natural world if we are to make sense of our part in it.
We believe that there is a great deal the Commission could achieve by working with local authorities to promote urban tree planting. We believe that the creation of a new area of woodland at Porthkerry Country Park, in Barry, by the Vale of Glamorgan Council in partnership with Coed Cadw, is a good example of how tree planting can enhance a local area. A report on the project is available online here.
One problem that needs to be overcome is the excessively risk-averse attitude of local authorities and other landowners towards mature trees. This attitude is a symptom, of course, of the compensation culture. Nevertheless, unless local authorities are willing to accept that properly managed mature trees pose a very low but unavoidable risk, there is a danger that many will be felled and that the environment and amenity of our towns and cities will be degraded as a result. We believe that there is a role for the Commission in championing urban trees, promoting best practice in their management and helping local authorities to understand that risks can never to reduced to zero.
Question 10: We are considering supporting new planting of short-rotation forestry or coppice to produce wood fibre for wood fuel, where there is established local demand. (links to chapter 5) Do you:
Coed Cadw response: Agree
b) What opportunities or barriers can you foresee in adopting this approach?
In line with our response to question 6 above, we agree with this approach but believe that any production should be certified as being sustainable by UKWAS and FSC. Moreover, based on Coed Cadw’s position statement on genetically modified organisms, Coed Cadw is opposed to the development and use of GM crops for bioenergy.
Question 11: We intend to encourage a more varied approach to involving more communities in woodlands, especially on the Assembly woodland estate. Do you:
Agree
b) What opportunities or barriers can you foresee in adopting this approach?
Coed Cadw is very much in favour of involving communities in their local woodland. Local people themselves are likely to derive real benefits. These might include not only enjoying walking in woodland and being consulted on management, but also practical involvement in management and maybe use of local wood products such as firewood. Moreover, if people value woodland, they will protect it. We believe the CydCoed project has been successful and we hope that some sort of successor funding can be found.
Coed Cadw has the impression that the FCW has been more successful in genuinely engaging with local communities within the Coed y Cymoedd District, where this has been a priority. That is, where the Commission has worked proactively to elicit local opinions and to listen to them and take them on board. If this is not a priority, local communities are less likely to feel that their views have been genuinely taken into account in deciding how to manage woodland.
Question 12: We propose broadening the scope of woodlands for learning from its current focus on children and supporting education for children, towards lifelong learning and skills development and training for adults. Do you:
Coed Cadw response: Agree
b) What advantages or disadvantages can you see to this change?
We are very much in favour of the Commission seeking to engage with wider groups, on the model of the successful Meirionnydd Oakwoods Habitat Management Project. This might involve, for example, teaching of new woodland skills, engaging with different groups and giving them the chance to have positive experiences within a woodland context. We do not, however, believe that this should be take place at the expense of engaging children in woodland.
Coed Cadw believes that every child should have the chance to plant trees and that the emphasis on outdoor education within the Assembly’s education policies is an opportunity for the FCW to expand rather than wind down its successful work with FEI and Forest Schools.
In particular, we believe that the Assembly’s Plant! initiative, to plant a native tree for every child born or adopted in Wales, offers the FCW an excellent opportunity to engage young families. The fundamental point about the project is that, while planting native trees is extremely worthwhile in itself, the really unique and powerful element is the potential it has for public involvement. The scheme was launched at the end of 2007 and has now been running for over nine months. Whilst the scheme is a new one, we believe the FCW could make use of it far more effectively to create positive publicity and to engage young families in caring for and visiting woods.
Question 13: We intend to prioritise the development of woodland recreation opportunities close to where people live – especially in areas of greatest need in terms of health inequalities. Do you:
Coed Cadw response: Strongly Agree
b) What advantages or disadvantages can you see to this approach?
Coed Cadw believes that the Assembly should improve our health and quality of life by ensuring that:
• 30 per cent of the Welsh population has at least 2ha of accessible woodland within 500m of their home. Just 16 per cent have at present.
• 80 per cent of the Welsh population has at least 20ha of accessible woodland within 4km of their home. 70 per cent have at present.
There is a growing awareness that accessible green spaces, especially woodland, can promote public health and community development. Yet most people in Wales cannot reasonably walk to a local wood.
Question 14: We propose to support the development of woodland-based small and emerging enterprises. (links to chapter 5) Do you:
Coed Cadw response: Agree
b) What would be the best ways to support such enterprises, overcoming any barriers you may foresee?
We believe Government should encourage a wide range of enterprises which develop any of the benefits that derive from woodland, and not focus exclusively on timber. Government should particularly encourage the reputation of woodlands and timber as a sustainable resource and assist businesses in understanding that the potentially strong public support for woodland related enterprises is dependent on a genuine commitment to sustainability. Training and support for businesses in developing and using UKWAS and FSC production and supply chain certification is necessary, as is support for appropriate marketing.
Skills development should be encouraged with the objective of ending low skill and low pay employment in UK forestry and to this end support should be give for training which helps business employees and contractors secure skill certificates.
Question 15. How important do you think the following are to help the forest sector develop in response to the home-grown woodland resource becoming more diverse? (1 – not at all important, not important, important, very important)
a) Support for product innovation 3
b) Promotion of wood use 4
c) Accurate information concerning the quality and quantity of utilisable
timber 2
d) Support for market development 3
e) Grants for capital investment 2
f) Facilitation of UKWAS certification 4
g) How else can we encourage the sector to take advantage of the new
opportunities increased diversity will offer?
By providing appropriate training, particularly in marketing.
Question 16: What are the best market ‘pull’ and grant ‘push’ mechanisms, or combinations of both, to get more woodlands into sustainable management and producing usable wood products? (links to chapter 2)
Authoritative and convincing marketing of woodlands and timber as a sustainable resource. Independent audit and certification is key to this. The Assembly’s forest estate should be the exemplar in the public mind of sustainable forest management and this objective should be paramount and not compromised by short term financial targets.
Public funding of private enterprise should push in the direction of long term and sustainable woodland management, and should deliver public benefit.
Question 17: What are the best ways to address the skills shortage in the forestry sector, particularly in the light of the new skills that will be needed in future? (not at all effective, not effective, effective, very effective; links to chapter 4)
a) Continue to develop relevant training courses to meet the needs of employers
b) More long term contracts for contractors to encourage skills retention and development and investment in new machinery
c) Support the provision of practical modern apprenticeships
d) Raise awareness of career opportunities through Woodlands for Learning
e) Work with training organisations, industry and others to develop paths into employment
f) In what other ways can we address the skills shortage?
Coed Cadw supports the FCW’s efforts in addressing the skills shortage in the forestry sector. We also suggest that FCW might like to look at the adequacy of the balance of skills within its own organisation, particularly in relation to expertise in public and community engagement, communications, marketing and the management of forests for non timber benefits.
Question 18: We believe more accurate information on the location of ancient woodlands and veteran trees would enable us to offer them more protection. (links to chapter 2) Do you:
Coed Cadw response: Strongly agree
b) What other ways could we offer these important old woodlands and trees more protection?
Ancient woodland already has firm protection from development due to paragraph 5.2.8 of Planning Policy Wales, the Welsh Assembly’s planning policy, which states clearly that: “Ancient and semi-natural woodlands are irreplaceable habitats of high biodiversity value which should be protected from development that would result in significant damage.”
We believe that the FCW could further increase the effective protection by making objections to planning applications which are contrary to the policy above. This consultative role is provided for in the paragraph 5.5.15 of the same document which states: “In the case of a site recorded on the inventory of ancient woodland produced by CCW, authorities should consult with the CCW and, if relevant, the Forestry Commission, before authorising potentially damaging operations.”
Another vitally important way of protecting ancient woodland is by restoring those ancient woodlands that have been planted with non-native species, rather than clear-felling them and replanting with a further crop of conifers. Coed Cadw very much hopes that at a result of this review of the Woodlands for Wales Strategy, the FCW adopts a clear policy to restore all ancient woodland in public ownership, and to ensure that private owners of such woodland are offered meaningful incentives to do likewise.
Ancient trees
In terms of individual ancient, veteran and notable trees, we believe that these should be protected as ‘green monuments’ through planning and environmental policies. Wales, along with the rest of the UK, is the area of northern Europe with the greatest concentration of ancient trees. They are a part of heritage and culture and have immense value for wildlife and yet they have no special protection in planning policy in Wales.
Crucially, in our view, this should include positive help and support, including where appropriate grants, for landowners to manage trees in a sensitive and responsible way, as well as penalties for those who damage trees which are protected.
Question 19: We propose to improve the ecological functionality of the landscape by targeting our efforts around focal (for generalist species) and core (for specialist species) woodland networks. (link to chapter 2) Do you:
Coed Cadw response: Strongly agree
b) What advantages and disadvantages can you see to this approach?
As outlined above, ecological opinion is clear that the wildlife benefits from native woodland creation will be greatest in areas adjacent to ancient woodland, and within ancient woodland concentrations. Such an approach will therefore deliver much greater wildlife benefits than would an entirely untargeted one. We look forward to this issue being raised in the new proposed Woodland HAP group.
Also response to Q1 ref landscape scale working, and to Q4 on the geographical targeting of support for woodland creation.
Question 20: We propose to use the Wales Biodiversity Partnership’s Non-native Species Forum to help tackle threats to woodland such as overgrazing (e.g. deer, sheep) and non-native invasive species (e.g. grey squirrel and rhododendron). (links to chapter 2) Do you:
Disagree
b) What advantages and disadvantages can you see to this approach?
Coed strongly agrees that with non-native species such as rhododendron, which cause significant and widespread damage. a coordinated response is needed. We are not convinced, however, this Wales Biodiversity Partnership subgroup is the right vehicle for leading on less specific threats to woodland.. We believe that overgrazing by agricultural animals such as sheep is best dealt with through agricultural policy, agri-environmental schemes and by the effective application of the recent legislation on the management of common land.
We do strongly support FCW in taking the lead with the newly proposed Woodland Ecosystem (HAP) Group, and this group may be an appropriate forum for discussions of conservation priorities for native woodland, but not for threats to forestry in general.
Question 21: We intend to manage all Plantations on Ancient Woodland Sites in line with best practice restoration guidance on the Assembly woodland estate and encourage this approach through grants for other woodlands. (links to chapter 2) Do you:
Agree strongly, but we do not believe that best practice restoration guidance is yet applied comprehensively on the Assembly’s own estate.
b) What advantages and disadvantages can you see to this approach?
Ancient woodland is our richest wildlife habitat and is scarce, covering only around 2% of Wales’ land area. The need to protect what is left is paramount, yet unless urgent action is taken now, vast areas of ancient woodland are in danger of losing their wildlife value forever.
The priority are those woods which are heavily coniferised. The vast majority of these still have restoration potential and for these woods the securing and enhancing of their surviving ancient woodland features is now urgent. This can be best achieved by gradual thinning and by continuous cover management.
Between the 1930s and 1980s, thousands of hectares of ancient woodland were replanted, mostly with commercial conifers or a mixture of conifers and broadleaved trees. The communities of plants and animals that depend upon the stable environment that ancient woodland provides were devastated if not by felling and clearance using heavy machinery, then by chemicals used to prevent regrowth, by the dense shade cast by closely planted new trees, or smothering from deep layers of conifer needles.
Research shows that in the next ten years most of the conifers planted on ancient woodland sites will reach maturity. If they are felled and replaced with more conifers then the wildlife dependent on ancient woodland will not survive. More than a quarter of ancient woods are now covered by conifer or mixed plantation.
The Woodland Trust therefore strongly supports aim of adopting a comprehensive policy of restoring all planted ancient woodland sites within the Assembly woodland estate and of encouraging this approach through grants for other woodlands to private woodland owners.
We stress, however, that in the case of some areas of planted ancient woodland, certainly in Wentwood and probably elsewhere, this will imply a break with current practice. Areas of ancient woodland at Wentwood have been clear-felled over the last two years. What’s worse, FCW have carried out damaging ground preparation work before replanting with even more conifers.
We believe that the continuation of these practices will cause irreversible damage to Wales’ largest remaining ancient woodland and we hope that the FCW will take on board the vision outlined in the consultation document, and implement it in Wentwood and across Wales. We even offer to provide some native saplings ourselves if this helps.
Question 22: We propose to use appropriate and targeted new woodland planting to help reduce diffuse pollution, soil erosion and flood risk. (links to chapters 2 & 3) Do you:
Coed Cadw response: Strongly agree
b) What advantages and disadvantages can you see to this approach?
The advantage is that this approach can be an effective remedy for flood risk, soil erosion and diffuse pollution and that this can be achieved without the potentially high cost of alternatives and in a way which positively enhances the natural environment rather than damaging it. Costly battles to improve water quality, prevent flooding and combat pollution from nitrates and pesticides should enlist a natural and often unrecognised ally – trees and woodland.
Earlier this year the Woodland Trust published a major report Woodland actions for biodiversity and their role in water management, together with Forest Research and the University of Newcastle. This analyse worldwide literature and highlights the often-unheralded role that woodland can play in overall water management, a role that Coed Cadw believes should be seized upon by water and land managers alike. The review assesses the impact of trees and woodland on water resources. It spells out how protecting, restoring and increasing native tree cover can help tackle threats posed by climate change, intensive farming and development.
At present 93 per cent of river water bodies in England and Wales, and 45 per cent in Scotland, risk failing to reach their required ‘good’ status under new Water Framework Directive legislation. The annual cost of removing harmful pesticides and nitrates from drinking water is put at £7 for every water customer.
Woodland creation in the right place can reduce pollution entering water courses by as much as 90% without putting additional strain on water resources, says the report. Sites where ancient woodland is being restored through conifer removal can also reduce nitrate concentrations by up to 90% and increase local water quantity by 20-50 per cent.
More information on the report and a copy of the report itself can be downloaded here.
General Questions
Question 23:
a) Within each chapter, what impacts or trade-offs do you feel we have overlooked?
b) Between the chapters, what impacts or trade-offs do you feel we have overlooked?
We feel we have already addressed these issues in our previous responses.
Question 24: We aim to ensure that where our strategy involves people it is truly inclusive and representative of the population we serve.
a) Can you see any areas where a particular section of the population might be unfairly disadvantaged by our proposals?
Coed Cadw response: No
b) If yes to a), please explain which section / proposal
c) If yes to a), please suggest how we could amend our proposals to be more equitable
Question 25: Please comment on any other aspect of the proposals that are not already
addressed above
Question 26: In terms of this consultation, please rate the following on a scale very poor, poor, good, very good
a) The overall consultation process
b) Accessibility of information on the consultation
c) The clarity and presentation of the consultation document?
d) The overall tone and content of the consultation document
e) Ease of responding to the consultation
f) Level of feedback we intend to provide to consultees
g) What could we do differently next time to improve our consultation
process?
Coed Cadw rates this consultation process good. Ample time has been allowed, and the consultation paper gives a clear view of the direction in which the FCW and the Assembly Government is minded to move, while giving ample opportunity for comment.
We do feel, however, that some of the questions are worded so that to answer them one way or another amounts to making a very sweeping statement. This needs to be taken into account in analysing the responses.
Coed Cadw (the Woodland Trust), Afallon, Tanygrisiau, Blaenau Ffestiniog, Gwynedd LL41 3RH.
www.coedcadw.org.uk
www.woodlandtrust.org.uk/campaigns
www.epolitix.com/forum/woodland-trust
For further information please contact:
Rory Francis on 01766 832563, email: roryfrancis@woodlandtrust.org.uk
Jerry Langford on 01570 471568, email jerrylangford@woodlandtrust.org.uk
