Scottish Forestry Grants Scheme Consultation
Reforesting Scotland response June 2006
The following is the response made by Reforesting Scotland in June 2006 to Forestry Commission Scotland's April 2006 consultation on proposed changes to the new Scottish Forestry Grants Scheme.
1. Despite the Minister's positive comments about the levels of funding available for forestry, we would like to register our concern over the apparent inadequate budget available to deliver the proposed Scottish Forestry Strategy and other associated Scottish Executive commitments such as targets within the Biodiversity Strategy
2. It must be clearly demonstrated that public money is being used to pay for public benefits, such as nature conservation, community development and economic development. This includes the targeted management of existing native woods and plantation forestry to produce genuine high quality biodiversity, by delivering the Scottish, UK, EU and International commitments for woodland priority species and habitats, and those non-woodland priority species and habitats impacted by forestry.
3. It must be made absolutely explicit that the UK Forestry Standard must be applied to all Tier 2 & 3 funded woodland planting, restocking and management by all grants administered by Forestry Commission Scotland, and by all of the SEERAD family.
4. The 'Principles' of the new scheme (page 4) need to include forestry's
contribution to the delivery of the Scottish Biodiversity Strategy, Scotland's
2005 Sustainable Development Strategy (Choosing Our Future), and the Scottish
Executive's 2002 World Summit on Sustainable Development commitment to increasing
UK Woodland Assurance Standard (UKWAS) forest certification.
Q1. Do you agree with the principle that the creation of small woodlands should be supported in this way?
Yes, more encouragement for small woods should be supported in order to increase diversity of landuse and habitat connectivity. We have concerns that there is the potential for inappropriate planting on, for example, archaeological sites or important open ground habitats. Whilst we understand the need to reduce administration costs, it should be made absolutely explicit that any planting must meet the UK Forestry Standard. We suggest that a key to making this work is to have simple and practical management advice available to anyone who is thinking of entering this scheme - on siting of woodland, choice of species, methods of establishment, maintenance etc, and covering different objectives - biodiversity, recreation, access, shelter, non-timber forest products (including game cover), timber, community involvement, etc. This could be a mini-handbook, in language that is accessible to those who are new to woodland management.
On farms, applications could be based on new small woods being incorporated into a whole farm plan, monitored by agricultural advisors.
Applicants should submit their claim with a map of the area, species used and the rationale for doing what they did.
We also seek reassurance that a reasonable sample of these applications will be checked in order to ensure that, on the whole, these minimum standards are being met.
Given the potential risks of this approach regarding small woods, we would be strongly opposed to anything other than native woodland being treated in this way.
A minimum stocking density of 1100 trees per hectare should apply, with the woodland maintained for at least 10 years.
Will such schemes be eligible for Farmland Premium payments?
A natural regeneration grant should also apply under this scheme, with a contribution to fencing costs paid in year 1 and the balance paid once established. Natural regeneration is still the preferred means of establishing new native woodlands where practicable, therefore natural regeneration should be eligible for this scheme.
Q2. Is the system of support for these woodlands a good compromise between simplicity and the need to adjust rates to reflect different circumstances?
Yes. If these are competitive, then the applicants will need to know in good time whether their projects have been approved and for which financial year, if not the year of application.
Q3. Do these models and rates adequately reflect the range of situations likely to be encountered?
No. It is difficult to comment since it is not entirely clear how some of the woodland types are defined (in particular 'mixed woodland'). The proposed rates themselves seem realistic. However, it is the 'relative rates' that are critical and these are what will dictate what many private owners will plant. For example the owner looking to establish some game cover would seem most likely to plant 'mixed woodland' rather than native woodland simply because the grant rate is more attractive. We feel therefore that the relative rates for native woodland should be increased over other woodland types to reflect the enhanced public benefit they can deliver.
While establishment grants may be supported by management grants for native woodland, native woodland establishment needs to be better supported, especially if it is for 'service' objectives, e.g. amenity and access, landscaping and non-timber forest products (NTFPs) e.g. game, fungi, flora.
There is currently little knowledge of sustainable and effective management methods for NTFPs and legislation regarding access and harvesting in the UK as a whole are poorly defined. However it has been demonstrated that NTFPs provide significant public benefit in Scotland (in terms of woodland use culture and small-scale enterprise) and associated biodiversity, health and community benefits. Interest in NTFPs is likely to increase and an avenue for SFGS funding to support NTFP management would be through basic monitoring to gather information required to establish sustainable harvesting levels.
It has been suggested that the minimum area for a planting model would be 5ha in any one block, but this could be reduced to 2ha to increase flexibility and compliance with UKWAS in smaller schemes.
It is important that there is more flexibility in how trees are established - both in methods (i.e. not insisting on tree tubes in urban areas where vandalism is the main threat to new trees) and in final density (i.e. lower stocking densities where open woodland is desirable, e.g. montane scrub and wood pasture).
For fencing costs, the actual length will need to be the length along the ground, not the length on the map.
Payment rates should be 70% of the standard cost, or the actual cost, whichever is higher. This means if people want to get 3 quotes to show FCS that fencing in their situation is more expensive than the standard cost - e.g. in remote rural areas - they can get 70% of that cost. 70% of cost is much less attractive to people than 90% of cost, which high priority woodlands were eligible for under the old SFGS. If the real cost of fencing is much higher than standard cost rates, people won't go for it. The other option is to go for a challenge fund top up - more time, paperwork etc, and the risk that you might not even get it. Leaving the option open to get 70% of standard cost means people can go for that if they don't want to get quotes, or if they will put the fence up for less than the standard cost, e.g. by using volunteers, etc.
Farm energy crops: There is increasing evidence to suggest that short rotation coppice is not the best way of using our land to produce biomass. SRC requires high quality agricultural land, which is not abundant in Scotland and should therefore be prioritised for food production. The most efficient (and plentiful) source of biomass can be generated from standard waste from existing woodland management. In the shorter term this refers to commercial plantations. In the long term this will come from a combination of commercial forests (including restoration activity) and management of mixed and native woodlands. Support should therefore be provided to enable existing woodlands to link into local energy supply chains (which is decidedly the most effective way of using biomass).
Q4. Do you agree that Forest Plans are an important way of delivering sustainable forest management and that we should be encouraging owners to enter the scheme?
Q5. Do you have any views on the appropriate level of detail that should be included in a Forest Plan?
Yes. There is a danger that if the requirement is very prescriptive over the format and content of the plan, it will not be appropriate for all circumstances: perhaps over complex and burdensome for the small, simple sites and not sufficient to address large and complex sites. We strongly feel that the guidance in Section 2 of the recently revised UK Woodland Assurance Standard (UKWAS) should be used. This guidance has been developed and agreed over a number of years by a range of stakeholders, allows for very simple plans for simple sites and may encourage more owners to become certified, especially owners of small woodland holdings. The guidance needs to acknowledge the lack of information on certain management activities, e.g. for NTFPs and small-scale biomass. Guidance should welcome innovative approaches where woodlands will be managed for multiple benefits and in all cases (particularly commercial private forestry where this is currently least evident) forest plans should be assessed for their contribution to, and impact on, local communities, public access, biodiversity and landscape.
Forestry Commission Scotland forest planning guidance must be consistent across state and private sectors.
Forestry Practice Guide 12 (1) requires revision, to meet new SFGS Forest Plan needs, but also to connect with the revision of state forest guidance FMM30 (2), which is also currently under review. New 'SFGS' funded Forest Plans need to assist owners to becoming UKWAS certified. It would make sense for FCS as an UKWAS certified woodland manager, as well as non-state forest grant provider, to apply and give consistent forest planning advice. This will also need to connect with the revised UK forestry guidelines.
Q6. Do these rates adequately reflect the costs of preparing a strategic Forest Plan?
These costs are fine for really huge woods (FE size, or large landowners) but the minimum payment is too small. Small woods can be equally as complex as larger ones, even more so. £750 is enough for three days of a consultant, maybe four at a push. That's not very long to include survey, data collection, plan prep and consultation - particularly where woodland managers are seeking to generate multiple benefits, as promoted strongly by the new SFS
If the forest plan costs much more than the grant available for its preparation, most people will be put off at this first hurdle, particularly if it may be in time obligatory to prepare a forest plan to get a WIG.
This is a good opportunity to ensure that local people have a say in the management of their local woods, but there's no way any effective consultation with local communities can be undertaken with the proposed plan preparation rates. Problems in being too prescriptive, but FCS could receive guidance from experts (e.g. those who were on the Forestry for People panel, Community Woodland Association, Reforesting Scotland and others) on some simple ways to ensure community input into forest plans, particularly for woodlands well used by visitors, or close to communities.
Q7. Do you agree with the introduction of Forest Environment Payments and do you have any comments on the activities to be supported by the proposed FEP?
Yes. FEPs must be for targeted work for 'non-woodland' as well as 'woodland' priority species and habitats within forest areas. Appropriate grazing systems should be recognised as eligible for FEPs.
Forest Environment Payments must target woodland management for high priority conservation, defined as:
1. Features and areas of significance for biodiversity:
a. priority species & habitats: EC Habitats Directive Annex 1 species and habitats, UK Biodiversity Plan priority species & habitats, Scottish Biodiversity List;
b. designated areas covered by Natura 2000 Payments: Special Areas for Conservation, Special Protection Areas;
c. other designated areas: Ramsar Sites, National Nature Reserves, Sites of Special Scientific Interest;
d. all ancient woodland on the inventory of ancient woodland, and other known sites which meet the same criteria, including ancient semi-natural woodland, other semi-natural woodland, plantations on ancient woodland sites, semi-natural features in plantations on ancient woodland sites;
e. other sites where owners working in partnership with SWT/RSPB/SNH
2. Forest systems and operations that are used to protect and enhance these features and areas.
Q8. Do you support the principle of a restructuring WIG and do you have any comments on the proposed rates?
Yes. Acceptable reasons for not restocking PAWS or HAP priority woodlands with native species should be defined and should be restricted to circumstances where natural regeneration is being used as part of a continuous cover system where an element of non-native species is inevitable. There should be an enhanced rate for restocking native species on such sites in recognition of the enhanced public benefit and possible opportunity costs of the owner.
Where site preparation is required to encourage natural regeneration on some restock sites, 50% of grant should be paid once work completed and 50% on satisfactory establishment.
The precautionary principle should be applied to 'genetically improved' planting stock with these being restricted to genetic improvements through breeding rather than genetic modification.
Q9. Do you have any comments on the list of proposed WIGs?
Improving Economic Performance
We are pleased to see the inclusion of 'independent certification'. We would also like to see specific reference to UKWAS.
Specific reference could also be made to non-timber forest products. This could be under forest plan preparation or in WIGs - tier 2 for training and tier 3 for diversification, skills development and organic forestry.
Improving the efficiency of small-scale forest product harvesting.
We would like to see the following added:
- 'Small scale felling and thinning' and 'pre-commercial and uneconomic tree removal' included under this section (essential for native woodland restoration).
- Ancient tree protection and management.
- Priority open ground habitat restoration and management.
- UKBAP priority habitats and species WIG (transplanting SFGS S4 in full).
- Capercaillie WIG - targeted at key capercaillie areas via the BAP Group.
- Black grouse WIG - using targeting from SFGS Guidance Note 30.
- Habitats that promote a sustainable forest culture (i.e. rich with a diversity of NTFPs).
It would be good to have scope for alternatives to chemical and mechanical removal of exotics - e.g. bio-mechanical methods, so some flexibility should be allowed in the standard operations if alternatives are cost effective and meet the objectives.
Improving Recreation, Access and Community Relations
Despite the latter part of the title there are no activities relating to community participation. We would recommend a discretionary payment (perhaps capped and based on a percentage of costs) for education, participation and interpretation costs where this was separate from provisions under "support for community projects". The current SFGS contributes to interpretation panels, but ranger services have been SNH funded. It would seem to make sense to build ranger services into land management contracts where it is part of a strategic ranger plan for a wider area - e.g. National Park/Local Authority area.
There also need to be incentives for landowners to talk with and negotiate with local communities and to involve them in planning and implementation if appropriate. Many communities will be unaware of this opportunity available to them, and a 'local community group' as envisaged here might not be in existence in that area. An owner who wishes to engage more effectively with the local community should be encouraged to do this, and a 'community group' might then form as a result of this process.
Drainage for paths should be included.
Management Planning and Monitoring
The proposed list seems rather prescriptive and again, despite the title of the section, does not seem to include any monitoring. However, if a defined list is required, we would like to see the following added:
- Ancient Woodland (including PAWS) management plan.
- People involvement plan (this might include community engagement or audience development which goes beyond just recreation).
- Monitoring management of non-timber forest products.
Q10. Do you agree with the principle that Forest Plans should become a prerequisite for access to WIGs in the future?
Yes, so long as there is flexibility on the complexity of the plans based on the scale of the woodlands.
Q11. Do you have any views on the general principle of integrating the forestry support measures into an umbrella support scheme delivered through the LMC system?
We strongly support the principle of integrating land management grants leading to a more holistic view of land management. However, we would be concerned to see any lowering of current standards. It must be made absolutely explicit that all forestry grants issued by FCS and/or SEERAD must meet the UK Forestry Standard. At present this does not appear to be the case. It is essential that there is a consistency of environmental standards and targeting across all Tier 2 and 3 woodland creation, improvement and management grants.
A key to integrating forestry into Land Management Contracts will be to have locally based staff who can advise effectively on the value of multi-benefit forestry.
Q12. Do you agree that top up mechanisms should be used to deliver extra support for particular activities?
Yes, where there is demonstrable public benefit and where they do not appear to be being delivered through 'standard' rates This will be particularly important where benefits do not have direct/ immediate economic benefits, such as securing community involvement or the development of local supplies of wood fuel. Again it should be recognised that relative costs for small woodlands may be greater.
Q13. Do you have views on which woodland types and/or geographical locations should be the highest priorities for extra support through top up mechanism?
Yes, where there are well-recognised additional costs and/or where SFS priorities are clearly not being delivered. We would support the proposal in the consultation (assuming "woodland creation and management in areas adjacent to communities" refers to urban areas).
We would like to see the following added:
- Ancient Woodland management and buffering (including PAWS restoration).
- Restructuring of plantation forestry for priority biodiversity, such as black grouse and capercaillie.
- Restoration of important open ground habitats, such as active blanket bog, by forestry removal - this must be include all the impacted area, not just 20% of it.
- Native woods to meet UK Biodiversity Action Plan native woodland Habitat Action Plan targets.
- Training and capital support for new types of woodland enterprise, such
as development of wood fuel business or adding value to non-timber forest
Q14. Do you have views on this or other mechanisms for supporting community groups?
Why does this have to be a challenge fund? It should be capped, and perhaps paying a fixed % of actual cost, rather than forcing community groups to go through the lengthy, frustrating process of applying for a challenge fund.
We would support the proposal for a challenge fund described. However we feel that this challenge fund should be open to owners, as well as community groups, who wish to engage with local communities.
Where FE budgets do not stretch to carrying out feasibility or participatory appraisal studies to establish partnership working, there may be justification for constituted community groups to receive some element of this challenge fund where they are working in partnership with FE. It may help them feel as though they have the same opportunities to funding as independent community woodland groups and extend their options for engagement in the woods.
The grant support should be open to communities entering the National Forest Land Scheme, or those working on woodland crofts or affordable housing projects in/associated with woodland.
Non-timber forest product harvesting should be an eligible item to encourage local people to engage with local woodlands.
(1) Forestry Authority (1998). Forest Design Planning - a guide to good practice, Forestry Practice Guide 12. Forestry Commission, Edinburgh. (Back to main text.)
(2) Forestry Commission (undated). FMM 30 - Forest Design Planning. Forestry Commission, Edinburgh. (Back to main text.)