Consultation – the Scottish Forestry Strategy

The Scottish Government has published its draft Scottish Forestry Strategy, which lays out the Scottish Government’s vision and plans for woods and forests over the next ten years. Or at least, that’s what it should do. In the event, the strategy is strong in some places, and weak-to-non-existent in others. Where it is strong is that it is an excellent summary of existing Scottish Government policies, commitments and powers, and of the issues facing forest management today. Lovers of tables will find lots to like, with meticulous cross-referencing of issues, Scottish Government Strategic Objectives, forestry objectives, policies and priorities.

However, there is a difference between a summary and a strategy, and when it comes to concrete plans for achieving the vision, there is frustratingly little. The section on Delivering the Vision ought to be the heart of the strategy. There is a list of ‘priorities for action’, all of which seem fine, but they are plastered down the left-hand side of a table which dedicates most of its space to a rather pointless analysis of whether the priorities tick Economic, Environmental or Social boxes. Beyond the single-sentence statement of each priority there is nothing on what it entails or how it will be achieved. No targets are given, only the vaguest commitments to ‘increase’ or ‘enhance’. The chapter finishes with a summary of the powers the Scottish Government has in these areas, without saying how they will be used. Perhaps not surprisingly, the chapter on Monitoring and Reporting is little more than a promise to do this later.

The most positive interpretation of the half-there nature of the Strategy is that it is a genuine work in progress which will be substantially revised as a result of the consultation. Working against this hopeful thought is the half-hearted nature of the consultation itself. The strategy is billed as ‘putting forestry at the heart of government’, but if that is so, shouldn’t the Scottish Government be starting a big conversation here, reaching out to schools, communities, businesses and individuals? Instead the strategy largely limits itself to actions at the level of the Forestry Commission and its successors and the conversation seems likely to be limited to those usually interested in such topics.

We’d like to invite everyone to surprise the government with the detail and passion of the public’s response. The consultation is open until the 29th of November and can be found at https://consult.gov.scot/forestry/scotlands-forestry-strategy-2019-29/

The consultation includes a list of questions it would like answers on. We’ll be publishing our responses to these shortly, but the discussion paper below is an attempt to start by stepping back from the prescribed framework and asking what a vision and strategy for forestry at the heart of government would really look like. Please feel free to use parts in your own response. You can also download the document as a pdf.

Forest expansion based on strong design standards

The core of the forestry strategy is the idea of significant forest expansion based on multi-use forestry, described in the strategy as ‘modern, sustainable’ forestry. The key idea behind multi-use forestry is that good forest design can give combined values for wood production, recreation, landscape, climate impact and wildlife that are higher than the value possible if any of these objectives are pursued in isolation.

The draft strategy claims that there is a broad consensus around this approach. We believe this to be true and we are strongly supportive of it. However, it raises two issues that are missing from the draft strategy: the implementation and enforcement of design standards, and the crucial role of land-use planning beyond this plantation-scale approach.

Implementation and enforcement of standards

As the strategy is based so heavily on the ideas of modern, sustainable forestry, it is only as strong as the implementation and enforcement of design standards.  We have seen many examples recently that suggest that these standards are slipping. This can happen at many stages in the planting process and for many reasons, including rushed timescales due to the grant system, poor communication between designers and contractors, lack of skills or a belief that lapses will either not be detected or not have consequences. Heavy grazing pressure from deer can also mean that well designed and planted schemes can end up with only the most resistant trees left.

The forestry strategy needs to spell out how modern sustainable forestry will be achieved, from the largest schemes to the smallest. This should include advice and training, timescales dictated by the needs of the planting project rather than by the grant scheme, requirements for better site management and better enforcement where standards are breached or not achieved.

Beyond plantations

The other weakness of the modern forestry approach is that it largely applies to new planting schemes on a scheme-by-scheme basis. Such schemes and this scale are not the whole of forestry. Multi-use forests will not deliver their full promise unless they are part of a landscape-scale approach which takes into account habitat connectivity, neglected habitat types such as upland scrub and the removal of factors preventing natural regeneration.

Barriers to expansion

Another missing element of the strategy is any analysis of the barriers to woodland expansion. The targets for expansion are welcome, but they are rather arbitrary and not clearly derived from any thinking about where the new forests will go or what the landscape change that we want to see is. While the draft strategy is right to emphasise the importance of complementary land use and to maximise synergies, it should not shy away from recognising where there are conflicts and making hard choices. It should be acknowledged that the main barriers to forest expansion are overstocking of ‘wild’ deer, burning of the uplands and the subsidy system. There is a single paragraph on the issue of wild deer but no detail. It is essential that the Scottish Government puts in place a deer management regime that balances landowners’ rights with responsibilities and ensures that deer populations are at a level that is in balance with their environment.

Integrated land use

A strong theme in the strategy is the need to consider land use in an integrated way instead of having forestry, agriculture and other land uses as separate and exclusive activities, competing for land holdings rather than integrated across them. As the Ministerial foreword makes clear, ‘thinking in silos’ should be regarded as out of date. Unfortunately, it is not enough to simply declare that this is so, and the draft strategy does not say nearly enough in concrete terms about how the integrated vision could be made a reality.

The Land Use Strategy

At the most basic level, integrated land use requires integrated strategies from government. A structure for this already exists, in the form of the Land Use Strategy. The Forestry Strategy should be regarded as part of the Land Use Strategy, building on its approach. At present, the draft strategy makes only two brief references to the existence of the Land Use Strategy. It is impossible to claim that an integrated approach is being taken when this is the case.

Integration at what level?

The strategy needs to spell out what integration means, and at what organisational level it will be achieved. This is important because a previous attempt at integration failed badly and left many land managers supportive of the principle but suspicious of proposals in practice. The Scottish Rural Development Programme (SRDP) for 2007-13 replaced the Forestry Grant Scheme administered by the Forestry Commission for Scotland (FCS) with an integrated system of forestry, agriculture and land use grants administered by the agriculture department of the Scottish Government. Since few people on the ground had expertise across all these areas, the programme was instead designed to run in a bureaucratic, box-ticking manner not requiring any particular expertise from civil servants.

The results of this are a matter of record. The flexibility, common sense and expertise of the FCS were lost and new planting rates plummeted. The problems were eventually addressed by the Mackinnon report (http://www.gov.scot/Topics/farmingrural/Rural/Forestry/JimMackinnonreport). This was the bitter experience that was behind the opposition of many foresters to Scottish Government proposals to bring the Forestry Commission (Scotland) entirely within the Scottish Government. On the face of it this was a sensible measure to integrate forestry more closely into land use planning, but many in the industry saw in it a threat of the same loss of expertise and identity that led to the previous debacle.

The challenge of the lack of sufficient expertise on the ground in integrated land management remains. We believe that land use integration should be achieved instead by

  1. Re-uniting the environment and rural economy committees of the Scottish Government. Joined-up thinking in the Scottish countryside has been hit hard by the separation of these subjects.
  2. Close working between land use agencies and departments, in particular to ensure that grant systems for alternative land uses are at comparable levels so that land managers’ choices are based on the genuine merits of the different choices rather than following the grant. There is a historic opportunity to achieve this with the new flexibility in agricultural grants that will be available with Scotland leaving the EU Common Agricultural Policy.
  3. Significant investment in upskilling and advisory services in integrated land management, particularly farm forestry, building capacity in both land managers and government. This will eventually pave the way for integration at an operational level that works.
  4. Changing farm support to a holding-level approach, as described in Scottish Environment LINK’s response to the consultation on Rural Support.

Regional land use frameworks

It is important that integration also takes place at a regional level, reflecting the very different conditions and priorities in Scotland’s regions. Again, there is an existing model for this in the form of the Regional Land Use Frameworks piloted from 2013 to 2015. Aberdeenshire Council and the Tweed Forum should be funded and supported to develop their pilot work into a Regional Land Use Framework and to take it to delivery, and lead partners should be identified and funded to roll the approach out over the rest of Scotland.

Large scale habitat planning and connectivity

The strategy needs to make a strong commitment to engaging in landscape-level planning for forestry, to complement the commitment to strong design standards in individual schemes. Several examples of this already exist. In the Cairngorms the FCS has been a partner in the Cairngorms Connect partnership, which co-ordinates the activities of a group of large landowners to better achieve common aims. Other emerging partnerships include the ‘Coast to Coast’ collaboration in the northern Highlands and the ‘Wild Heart of the Southern Uplands’. From mid-Wales we have the example of the O’r Mynydd i’r Môr / Summit to Sea project, which is notable for bringing together a wide range of stakeholders, not just large landowners, and establishing clear principles for this type of co-operation. The Endangered Landscapes Programme, established with private funding, has funded projects across Europe working at this scale.

Some objectives can only be achieved by thinking at this scale, including the movement of plants and animals and ensuring that populations have a connected range large enough to ensure genetic integrity. With climate change this will become especially important as species have to shift their ranges. While the activity from private and charitable actors in this area is welcome, some things can only be achieved by governments and there is a need for the Scottish Government to match the ambitions of non-governmental groups.

This could be achieved by several parallel means:

  1. Committing the new Forestry and Land Scotland Agency (FLSA) to engaging in large-scale, collaborative projects wherever possible.
  2. Producing a Scotland-scale plan, taking into account neighbouring regions of England, for habitat connection and the movement of species responding to climate change and recovering from historical persecution.
  3. Providing a strong framework of regional forums. The Regional Land Use Frameworks have already been mentioned. There are also the existing Regional Forestry Forums. No mention is made of these in the draft strategy. Does this mean that they are to be discontinued?
  4. Bringing forestry into the planning system, an existing system that provides democratic control, considers all scales and is integrated across sectors.

Resilience in the Land, the People and the Economy

Reforesting Scotland emphasises two interconnected sides to forests and forestry: the Land and the People, or the natural and the human. Land aspects include Scotland’s soils, water, species, ecosystems, landscapes and climate. People aspects include land tenure, mental health and wellbeing, culture and tradition, communities, economic production, landscape and the value to people of natural functions such a flood reduction and carbon fixing. A strong country is one that is resilient and diverse in all these ways, and this should be a recurring theme throughout the strategy.

The draft strategy contains a welcome recognition of the three aspects of forestry that it calls the economy, the environment and people. In particular we welcome the new concept of ‘sustainable and inclusive growth’. This recognises that while growth is an objective, it does not improve lives if it is merely turning natural assets into financial ones or if the benefits accrue only to a small sector of society. While sustainable growth is now a well established concept (as defined by the Brundtland Report of 1987), inclusive growth is poorly defined. We would welcome more detail on how this will be defined, how it will be achieved and how it will be measured and monitored. At present it should be recognised that land use subsidy is uncapped and tends to give most to those who have most.

What is less welcome is the strong impression given in the report that economic considerations are ‘more equal’ than others. They are mentioned first in every list and are generally given more space. We welcome the recognition of the economic importance of forestry to Scotland, but it cannot come at a cost to other objectives. The strategy should be rewritten to make it clear and explicit that the human and natural aspects are at least equal and that all three are interdependent.

A resilient land

The draft strategy identifies soil and water quality, climate change, tree pests and diseases, deer management, invasive species, woodland condition and the protection of ancient forests as issues affecting natural resilience. This is a fair summary, but there is a lack of clear commitments and targets.

Pests and diseases. Under tree pest and diseases, tree breeding cannot be the only approach. There is a need to face up to the role of international trade in spreading the ever increasing list of pests and diseases threatening native species and to commit to tightening up the nursery trade in particular.

Climate change. Growing and using more trees has a role in improving Scotland’s carbon budget and ‘carbon forestry’ will likely play an increasing role in Scotland’s landscapes. It will be important to ensure that payments for carbon offsetting support rather than undermine the multi-use approach. What is not mentioned in the draft strategy is the importance of large-scale landscape planning in allowing the movement of species and adapting to climate change.

Habitat quality. The draft strategy points out that 46% of natural woodland is in favourable condition. This is a rather positive way of saying that 54% is not! While increasing the amount of woodland in favourable condition is given as a priority, there is no indication of whether this is an increase of 1% or 50%. Again, clear targets are needed and we should be aiming for the great majority of woods to be in good condition.

Evolving landscapes. However, the concept of favourable condition only takes us so far and there is a need to consider how we stop site designation becoming a straitjacket for the landscape. Ecosystems always evolve, and we can now expect landscape changes in response to man-made changes. Climate change and nitrogen deposition are changing our ideas about where trees will grow and raising the treeline. Do we adapt to this changing reality or do we attempt to freeze the treeline at some past point?

In countries such as Norway, what we call ‘moorland’ is more of a mosaic, with scattered trees and a healthy scrub community that supports birds such as red grouse. Equally, upland ‘woodland’ can include much open space. By applying simplistic categories we can end up simplifying the landscape itself to fit through our management. Burning the landscape both simplifies the ‘moorland’ ground layer and erases these transition zones between forest and open moor. The strategy should include a recognition of montane scrub as a community which has been almost wiped out in Scotland and which could be restored.

Ancient woodlands. We welcome the recognition of the value of ancient woodlands, which can preserve relationships between species such as plants and fungi that we are only even becoming aware of and act as reservoirs of species for restoring surrounding areas. Alongside the commitments to protecting and restoring these sites, there is also an opportunity to expand them through management of surrounding areas for natural regeneration.

Natural regeneration. There is a strong emphasis on tree planting in the strategy. There also needs to be encouragement of natural regeneration as a way of protecting diversity and resilience.

Resilient people, communities and society

People. It is now well established that people feel better when they are able to spend time in natural environments, particularly complex, enveloping environments such as woodlands. This is as true of greenspace in cities as it is of natural forests in the countryside. Learning outcomes for children have also been shown to be improved when education takes place in such environments. There is a social inclusion aspect to this, in that quality public greenspace has been shown to have the greatest benefits for the worst off, probably because these have the least access to quality environments in other ways. The health benefits are both physical and mental. With children, the benefits to outdoor and forest education are also highest for those children who do not fit well with traditional indoor education.

The draft strategy recognises this and the priority of increasing the use of Scotland’s forests to improve health and wellbeing is welcome. In addition to this, the strategy should commit to supporting and increasing ‘forest school’ type education, which is otherwise only mentioned in the context of producing future forest workers. A recognition of the importance of not only being in woods but interacting with them through activities such as foraging and play would also be welcome.

Developing new ways of connecting urban populations to the land is another way in which we can increase the use of forests for health and wellbeing. The strategy should recognise the importance of hitting in this regard and support it.

Forest ownership. The recognition of the importance of community woodlands and the commitment to increase this form of ownership and management are welcome, but there is a need to increase the diversity of ownership and management beyond this. In Scotland, land is still typically bought, sold and invested in in very large units that are beyond the great majority of the population. The government should do more to encourage small-scale ownership of woodlands in its land sales. It should bring in a land value tax to reduce the incentive to hold on to land for speculative and subsidy reasons. It could take a lead in exploring new funding methods such as crowdfunding to invest in new high-ecological-value plantations with shared ownership, analogous to the growth in crowd-funded hydro schemes. It should also recognise and support projects to match under-utilised forests with aspiring forest managers, such as the Scottish Woodlot Association.

A resilient economy

The Forestry Commission has done much to support the development of forest industries by guaranteeing the stability of timber supplies. This has allowed a processing sector to emerge for high-volume, uniform softwoods and we welcome the commitment that this will be continued by the Forestry Commission’s successor bodies in Scotland. Now is the time to commit to doing the same with quality broadleaves. While broadleaves are generally slower growing than softwoods, they have higher additional benefits and lend themselves better to supporting an ecology of local, small-scale business adding value that can far surpass that of softwoods. The strategy mentions the potential for new technology to increase efficiencies, but it is worth noting that far higher conversion rates can already be achieved with human control of a log on a saw, producing a range of value-added products.

Hardwood sawmills such as Scottish Wood already show the potential, but the sector faces a chicken-and-egg situation. Foresters do not plant quality broadleaves because the market for them is uncertain and hard to predict. Therefore the resource is not available and a mature processing sector cannot develop. Therefore the lack of incentive to plant remains. Government commitment is needed to bridge this gap. Broadleaves are too often treated as being there only for wildlife or simply for visual reasons. Thus they are not planted at densities that would achieve good timber quality or managed well. The Scottish Government should encourage the planting and management of quality broadleaves both on the Scottish forest estate and through its grants.

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