COED CADW (THE WOODLAND TRUST) RESPONSE TO THE WELSH ASSEMBLY GOVERNMENT CONSULTATION ON THE RURAL DEVELOPMENT PLAN for WALESMARCH 2006
Introduction
Coed Cadw (the Woodland Trust) welcomes this 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 100 sites across Wales, covering around 1,580 hectares. We have 250,000 members and supporters across the UK.
Coed Cadw’s vision is for a sustainable well-wooded countryside, which has diversity of landscape, biodiversity and rural culture at its heart. As a charity committed to the conservation of our native woodland heritage, and the awareness and enjoyment of it by the public, Coed Cadw is very much aware that the quality of the environment is central to our quality of life. We strongly welcomed the decision by the Welsh Assembly Government to produce an Environmental Strategy for Wales, and we see the Rural Development Plan as an excellent opportunity to deliver some of the key outcomes outlined within that document. That said, the funding available for the RDP during 2007-2013 will clearly be lower that for the previous plan period, meaning that it is all the more important that spending should be targeted towards those areas where it will have the greatest beneficial effect.
We have not attempted to provided answers to all the questions in the consultation document, confining ourselves to those areas where we feel we have some particular insight, experience or expertise to offer.
Summary of key points
• While the document makes a creditable attempt to respond to the challenges facing rural Wales, we do not feel that the draft fully acknowledges the scale of the environmental challenge, particularly in the light of the reality of climate change. The document states that “over 30% of agricultural land is under sustainable environmental management”. This implies, of course, that just under 70% of it is not. The huge decline in farmland birds, referred to elsewhere in the document, along with the huge loss of irreplaceable ancient woodland, around 50% of what remained in the 1930s, and the reality of climate change, underline the fact that biodiversity is today under threat as never before. The Rural Development Plan needs to help address these pressures in terms of adaptation and by protecting, extending and buffering wildlife habitats.
• In general, we feel that the consultation document does not put sufficient emphasis on forestry, as opposed to agriculture. The EAFRD regulations make it clear that forestry and agriculture should have equal status, and we think this is important as it offers the possibility of a more integrated, intelligent approach to managing the countryside as a whole. Woodland can make very significant contribution towards many of the outcomes of Environmental Strategy, in particular in terms of biodiversity, public access and hydrology. If these outcomes are to be delivered, it is essential that as part of the RDP, resources should be channelled into the new Better Woodlands for Wales grant scheme as they were into the old WGS. The Assembly is to be congratulated for continuing to pay WGS consistently, rather than simply discontinuing it mid year, as has recently happened in England in the past, causing real problems for the industry.
• While the document does include a number of outcomes included in the Environment Strategy for Wales, there are others which seem to receive less emphasis, at least in terms of definitive actions. For example, referring to biodiversity and climate change, the ES states that: “We need to ensure that larger areas of habitats remain or are restored to help maintain and enhance biodiversity”. The same document includes the following future outcomes :
• The loss of biodiversity has been halted and we can see a definite recovery in wildlife, in particular those species that need very specific conditions to survive
• The wider environment in Wales will be more favourable to supporting biodiversity and resilient enough to cope with the challenge of climate change.
It is not clear to Coed Cadw how the draft RDP, as it stands, is likely to contribute substantially towards the delivery of these outcomes. In response to questions 1 and 14 below, we suggest how this could be remedied.
• The document places very little emphasis on the role, and the potential role of the voluntary sector in delivering environmental improvements and thereby contributing towards the economic regeneration of rural areas. Last year, for example, Coed Cadw acquired nearly half of Wentwood, Wales’ largest ancient woodland site, in order to restore the site to its former broadleaved glory, helping to make a difference on a landscape scale, and using the site as a showcase of how planted ancient woodland sites can be restored so as to offer substantial public benefits.
• Coed Cadw strongly supports the principle that farmers should receive payments in return for providing benefits to the public, protecting and enhancing wildlife habitats, protecting archaeological remains, ensuring access etc. Overall, however, we believe that the draft RDP is too biased towards the agri-food sector, not focusing sufficiently on general environmental situation and the general socio-economic situation in rural areas.
• While Coed Cadw supports payments to farmers and landowners, we feel that these should be on the based on the provision of benefits to the public. For this reason, we would support an increase in the level of modulation from Pillar 1 to Pillar 2, up to the maximum of 20 per cent. Bearing in mind that the total funds available for the RDP have been reduced due to the budget settlement, we fear that this sort of modulation may be the only way to reach the Assembly’s laudable targets regarding the uptake of Tir Gofal and Tir Cynnal.
• Clearly, the movement towards the Single Farm Payment and the growth of agri-environmental schemes has in the recent past changed the nature of the relationship between the individual farmer and the Assembly. There is now a much greater emphasis on verification that given prescriptions are being followed. The resulting situation has been described by some as an “arms race”, as farmers understandably attempt to maximise their income, while civil servants try to clamp down on possible abuse of the system. The risk here is that more and more RDP funding could be taken up with administration and verification, rather than actually supporting and promoting sustainable economic activity in the countryside. We believe that the best way round this problem is for agri-environmental schemes to be based much more on outcomes rather that prescriptions.
• There is a widespread view amongst observers that state support for farming through the CAP is likely to be progressively reduced over the coming decade. Coed Cadw would strike a note of caution, however. The Environmental Strategy includes a whole raft of outcomes, relating to biodiversity, hydrology and landscape, which are utterly dependent on how the land if farmed. As far as we know, no one has carried out research to determine how much it might cost to ensure these outcomes in the absence of agricultural support, and we feel it would be a grave mistake to assume that these outcomes could be achieved more cheaply without it.
Consultation questions
Q1 Do you think that the Commission requirements as set out in the Working Paper have been met? If not, why not?
Generally, we believe that the document does make a creditable attempt to do this, but Coed Cadw does believe that the draft RDP is too biased towards the agri-food sector and that it does not focus sufficiently on general environmental situation, and the general socio-economic situation in rural areas. As mentioned above, we also feel that the consultation document does not put sufficient emphasis on forestry, as opposed to agriculture. The EAFRD regulations make it clear that forestry and agriculture should have equal status, and we think this is important as it offers the possibility of a more integrated, intelligent approach to managing the countryside as a whole.
In paragraph 22 on page 5, we particularly welcome the emphasis on “Developing a coherent approach to rural development and environmental management by building on rural development initiatives and agri-environmental schemes through coordinated action within targeted geographical areas.” This suggests a landscape scale approach to biodiversity which we support.
Planted Ancient Woodland Sites
We do stress, however, that any analysis of the major environmental challenges and opportunities facing Wales is incomplete without reference to the 27,000 hectares of irreplaceable ancient woodland that was planted with non-native trees during the last century. Over the next 20-30 years, we have a once-and-for opportunity to restore this woodland, before it is clear-felled and replaced with a new crop of conifers.
Coed Cadw’s successful campaign to acquire 352 hectares of Wentwood, Wales’ largest ancient woodland, demonstrated clearly how strongly people in Wales feel about the small areas of ancient woodland that remain. Ancient woodland is one of our richest natural habitats and, having evolved over thousands of years, it is irreplaceable. Although planting with non-native trees was a huge blow to its conservation value, ancient woodland planted with non-native trees can be restored, as Coed Cadw and the Forestry Commission Wales and Coed Cymru are demonstrating at a range of sites around Wales.
European funds are already being used to restore such sites within the Objective 1 areas, through the FCW’s excellent Reclaiming our Forgotten Inheritance Project, which Coed Cadw strongly supports. However, the RoFI itself will restore less than 6,000 hectares of planted ancient woodland, leaving nearly 80 per cent to deteriorate further under what is often a dense canopy of conifers. Coed Cadw hopes therefore that restoring planted ancient woodland sites will remain a priority and will be incorporated into the RDP.
Such a move would be very much in line with the draft Habitat Action Plan targets submitted from Wales to BRIG, the Biodiversity Information Reporting Group. These propose that by 2030, 17,177 hectares of planted ancient woodland should have a restoration plan, a further12,883 hectares should be in the process of restoration that on the remaining 8,588 hectares this restoration should have taken place.
Q2 Do you feel that for each of the areas covered, they key strengths and weaknesses have been captured? If not, what else should be included?
While we would support most of the draft text, we feel that paragraphs 11 and 12, relating to forestry, fail adequately to recognise the environmental importance of this sector. We would therefore suggest that this should be expanded to include:
• The importance of restoring ancient woodland planted with conifers (see question 1 above) and
• The importance of the Assembly supporting sustainable forestry through certification of timber production.
• The opportunity of that woodland creation represents, and the benefits it could bring in terms of delivering the outcomes in the Environment Strategy with regard to biodiversity, public access and hydrology.
Q3 Do you feel that for each of the areas covered the right challenges have been identified?
We support the challenges outlined in general terms. We do feel, however, that both the sections on the environmental challenges, and the socio-economic challenges, put insufficient emphasis on the quality of the natural environment and in particular the local amenities available to communities. This is particularly important bearing in mind that the Assembly’s “Climbing Higher” strategy has set targets that involve increasing the percentage of people using the natural environment for outdoor activity from 36% to 60%.
Coed Cadw welcomed the emphasis in Assembly’s Environment Strategy on ensuring adequate green space within easy access of where people live, and the importance of this in terms of quality of life. This is an issue in rural as well as urban areas, as farmland and woodland is not necessarily accessible to the public. As a national charity committed to increasing people’s understanding and enjoyment of woodlands, Coed Cadw has carried out and published the first ever UK-wide GIS study of the availability of publicly access woodlands in all communities throughout the UK. The aim of Space for People; targeting action for woodland access , is to identify those areas which lack publicly accessible woodland within easy reach of where people live, so that provision of such areas can be more rationally targeted. We believe that given the wide role of benefits woodland can deliver, that it has an important role to play as natural greenspace. The Woodland Access Standard provides a toolkit for delivering the wooded greenspace within the CCW toolkit for all greenspace.
Trees and forests are crucial to life on our planet. They stabilise the soil, generate oxygen, store carbon, play host to a spectacular variety of wildlife, and provide us with raw materials and shelter. They offer us respite, inspire our imagination, creativity and culture, and refresh our souls. A world without trees and forests would be barren, impoverished and intolerable. Woods bring many benefits, and people appreciate them in all sorts of ways. But for everyone to enjoy them, visit them or indirectly gain from them, they need to be located near to where people live. Space for People suggests that we would need a minimum of a further 3,817 hectares of woodland to ensure that everyone in Wales lives within 500m of an area of woodland of at least 2 hectares.
Hence, we urge that, the lack of accessible woodland be included as a challenge with the RDP. RDP funding could make a huge difference in terms of meeting public aspirations for a better local environment.
Q14 Do you agree with the approach set out for Axis 2?
Coed Cadw strongly welcomes many of these actions points, particularly “Managing the environment as a whole”, “Contributing to the achievement of wider nature conservation objectives including the target of halting the loss of biodiversity by 2010”, “Ensuring that the majority of Welsh agricultural land is farmed sustainably”, “Maintaining an enhancing high quality woodlands which contribute social and community benefits, support thriving communities and contribute to a better quality environment”, “Contributing to sustainable development by protecting landscapes, enhancing habitats and managing diffuse pollution” and “Encouraging spatially targeted integrated programmes that deliver environmental and economic benefits and conserve natural resources”.
We do, however, think that there should be more emphasis on the delivery of Habitat Action Plan targets. If we are to have any hope of meeting the ambitious outcomes included in the Environmental Strategy (BIO1), particularly that the “Loss of biodiversity has been halted and we can see a definite recovery in wildlife, in particular those species that need very specific conditions to survive”, then this needs to be one of the priorities within the RDP.
As mentioned above in answer to question 1, we are particularly keen to see the delivery of the revised Habitat Action Plan target for Wales, that by 2030, 17,177 hectares of planted ancient woodland should have a restoration plan, a further12,883 hectares should be in the process of restoration that on the remaining 8,588 hectares this restoration should have taken place.
We would also stress the importance of recognising the economic importance of tourism, and the importance of a high quality environment if this industry is to thrive, as recognised in paragraph 14, page 4 of the consultation paper.
The forthcoming review of agri-environmental schemes
We note that in paragraph 19 on page 21 and paragraph 24 on page 22, there is reference to a forthcoming review of agri-environmental schemes. Coed Cadw welcomes this, as it provides the opportunity develop a new top-tier scheme, as well as improving the effectiveness of Tir Gofal and Tir Cynnal in the light of experience. We hope, however, that this will include a public consultation, as these schemes are of great public interest, and indeed the benefits they provide to the public provide the justification for them.
Integration of agri-environmental schemes with BWW
The review will also provide an opportunity for the integration of Tir Gofal, Tir Cynnal and a new top tier agri-environmental schemes with the Better Woodlands for Wales grant scheme. In Scotland, agri-environmental and woodland grant schemes are now being integrated, and this is now starting to happen in England as well, in line with the EU strategic guidelines for EAFRD. Coed Cadw would strongly support this, as a major step towards a more integrated, holistic and intelligent way of managing our countryside.
An top tier agri-environmental scheme
We very much hope that the worthy objectives outlined in paragraph 13 on page 19 will be translated into reality, amongst other ways, through the creation of a top tier agri-environmental scheme, one which would be aimed particularly at attracting joint applications from neighbouring landowners, and which would be able to deliver biodiversity and hydrological benefits on a landscape scale. Such a scheme would be similar in some respects to the Pontbren scheme northern Powys, though it would doubtless be much more comprehensive. In our view, one of the crucial characteristics of such a top-tier scheme would be that joint applications were not just permitted, but specifically encouraged. Paragraphs 16 on page 20, and 18 on page 21, suggest such a scheme, but the diagram on page 31 specifically does not include it, which we find worrying. We would therefore like to see this point clarified.
Targeting or focussing with agri-environmental schemes
We believe that if such a scheme were to deliver the landscape scale biodiversity benefits mentioned in the Environmental Strategy , then it would also make sense for actions to be targeted, or focussed, towards the environmental opportunities and threats in different areas of the country. We could particularly stress the importance of targeting woodland creation within those areas of Wales where there are concentrations of ancient woodland, and where this is therefore the greatest chance of native woodland wildlife being able to survive and adapt to climate change. Such areas have been mapped by Coed Cadw (the Woodland Trust) and published in the document Space for nature: landscape-scale action for woodland biodiversity which is available on web.
Coed Cadw recognises that this biological reality is only part of the full picture, and we have also carried out a spatial analysis of where woodland creation is necessary to ensure that everyone has accessible woodland within easy reach of their homes. This research is referred to in our response to question 3.
Biomass and renewable energy
With regard to biomass and renewable energy, we support paragraphs 26-30 on pages 22 and 23. In principle we would support the Assembly in promoting biomass production, as it has the potential to contribute significantly towards mitigation of greenhouse gas emissions, as well as providing a alternative sustainable land-use, if properly certified, and employment opportunities in rural areas. However, valid questions have been raised as to the possible effects on biodiversity. We believe it is vital that, if biomass is to be promoted, this should happen in a way which supports and does not erode biodiversity and all public benefits. We therefore urge the Assembly Government to be open to the idea of working with the business, the social and the environmental sectors to promote a consensus on how biomass can be promoted in a truly sustainable way.
Question 17 Do you agree with the key actions identified under Axis 3?
We generally support this list. With regard to the section key action “Improving the physical environment of villages and conserving natural heritage”, we would particularly stress the importance of provision of publicly accessible green space, as referred to in our response to Questions 3 above.
Question 25 Do you agree with the intention to have a regional Wales network?
Coed Cadw would support the creation of a Welsh regional Rural Network, and we would be keen for the voluntary environmental sector to be represented on such a body, as environmental NGOs have a great deal to contribute towards the delivery of sustainable rural development in Wales. Nevertheless, resources are limited, and few ENGOs have staff time available to regularly attend such all-day meetings. If voluntary sector representation is considered important on such a body, we suggest that part of the ring-fenced funding available for it, be used to enable representatives from the voluntary sector to attend.
Coed Cadw (the Woodland Trust), Yr Hen Orsaf, Llanidloes, Powys SY18 6EB
www.woodland-trust.org.uk/campaigns
www.epolitix.com/forum/woodland-trust
For further information please contact:
Rory Francis on 01766 832563, email: roryfrancis@woodland-trust.org.uk
Jerry Langford email: jerrylangford@woodland-trust.org.uk
