The RSPB welcomes the opportunity to comment on this draft Forestry Commission Practice Guide. We would also like to comment on the final draft.

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1 Draft Forestry Commission GB Practice Guide Managing Open Habitats in Upland Forests response to the consultation by the Royal Society for the Protection of Birds 1, February The RSPB welcomes the opportunity to comment on this draft Forestry Commission Practice Guide. We would also like to comment on the final draft. GENERAL COMMENTS We are pleased that this guidance is being drafted, showing that open ground habitat restoration is being taken seriously by forestry regulators. This publication should aim to define best practice, rather than just good practice We would like to see a companion Forestry Practice Guide on managing open habitats in lowland forests, covering lowland heathland restoration. This publication for all public, state and private forestry would benefit from a wider range of case studies and examples, beyond the current FE focus. There is no reference to the work we, and the Flow Country partnership, have been doing in Caithness and Sutherland peatlands as part of the LIFE project. This publication would benefit from such evidence from the grey and peer-reviewed literature. Needs to mention country forestry strategy commitments on open habitat restoration, and country biodiversity strategy commitments. The document needs shortening and sharpening to be of use to forest mangers. Publication needs to define priority biodiversity as: UK Biodiversity Action Plan priorities SAPs & HAPs, EU Birds and Habitats Directive priorities and Annexes, country species lists, plus for designated sites SSSI, SPA, SAC and Ramsar. We suggest that criteria for selection for open ground habitat restoration should include: o Listed as a UK Biodiversity Action Plan priority open-ground habitat with restoration targets; o Direct benefit to country biodiversity strategy list species and habitats, UK Biodiversity Action Plan (UK BAP) priority habitats (HAPs) or species (SAPs); o Direct benefit to Priority/Annex 1 habitats under the EU Habitats Directive; o Will enhance the biological condition of designated sites - SPA, SAC, Ramsar, SSSI, NNR - through action within the sites and adjacent to the site; o Restoration potential presence of key remnant features, and technical ability to improve condition; o Scale of restoration must be adequate and produce viable habitat linkages to existing areas/networks of target open-ground habitats. 1 Contact details: Mike Wood, UK Forestry Policy Officer, RSPB, Dunedin House, Edinburgh, EH4 3TP. Tel: , mike.wood@rspb.org.uk 1

2 The guidance should suggest no upper limit on area of forest that can be restored to priority open ground habitats. Good to see the emphasis on the need to manage these habitats once cleared. Good on habitats, weaker on species. Useful outline for non-ecologist foresters for which habitats are most important. This needs to be backed up links to more detailed information on practical management for priority species, as well as habitats. Good emphasis on connectivity, landscape scale, greater value of larger patches and (especially) wider rides. Would prefer that open habitat restoration is used in preference to the term deforestation, with the former for priority habitats and species, with the latter just removing trees in a non-targeted way with low restored biodiversity value. Felling Licences must ensure that Scottish change to conditional Felling Licences under the Nature Conservation (Scotland) Act 2004 is explained. This is a formal change to the Forestry Act 1967 in Scotland, unlike the gentleman s agreement not to require restocking on open habitats in England and Wales (the latter needs mentioning). If this UK, not GB publication, need to mention Forest Service s Environmental Guidelines for Timber Harvesting (1999) and the Statement on Environmental Policy (1993). UKWAS 2 nd Edition explain the difference between open ground creation within a forest (Requirement ), and larger scale forest removal for biodiversity restoration (Requirement Conversion to non-forest land). Planning for large-scale open habitat restoration and management must be focused to directly benefit priority habitats and species (UKBAP, country priorities, EU Bird & Habitats Directives priorities, plus designated sites: SAC, SPA, SSSI, Ramsar), rather than a generalised habitat approach and employing theoretical species. We are concerned that BEETLE, and HaRRPS, are not used in preference to targeted work for these priority habitats and species, but purely as useful tools where appropriate, with forest level planning and policy addressing priority habitats and species. This highlights the need for guidance on development of open-ground habitat networks, alongside the existing Scottish policy and practice guidance on forest habitat networks 2. As an internationally important habitat under the EU Habitats and Species Directive and as a UK it has long been recognised that blanket bog conservation and restoration should extend beyond designated sites to include areas with greatest potential for recovery. Secondly, on many designated blanket bog sites, the hydrological unit may extend beyond the designated site boundary and it would be important to apply measures outwith the designated site to benefit the habitat within the designated area. 2 Scottish Natural Heritage & Forestry Commission (2003) Habitat Networks for Wildlife & People the creation of sustainable forest habitats. SNH, Edinburgh & FC, Edinburgh. 2

3 DETAILED COMMENTS Page 2 Glossary UKWAS is the UK Woodland Assurance Standard, not UK Woodland Assurance Scheme (see: Page 4 Introduction Needs to mention country forestry strategy commitments on open habitat restoration, and country biodiversity strategy commitments. Pleased to see clear mention of UKBAP, needs to mention EU Birds & Habitats Directive commitments for priority species and habitats (particularly those outside designated sites). What are open habitats. Good to make specific reference to freshwater bodies (peatland pools and lochs). Page 5 The Guide focuses on upland forests, particularly planted, commercially-managed and of non-native conifers because these are where managing the open habitats gives the greatest biodiversity gains it needs to include upland native woodland schemes, particularly largescale ones. Add in a final paragraph alluding to the potential benefits to dependent species, e.g. birds, mammals and some invertebrates, of appropriate management of open space, through linkage, broadening rides/roadsides, appropriate riparian plantings, grazing/swiping etc. Page 6 Why are they valuable Paragraph 2: In commercial forests, stands are generally even-aged and often of a single species so their internal habitat diversity is low add: however there importance to nature conservation is not diminished because of this as some species prefer these e.g. capercaillie, goshawk, if key elements are present. Page 7 Add freshwater bodies (see page 4). Paragraph 2 also mention open habitats important to UKBAP species e.g. black grouse, nightjar, capercaillie, hen harrier, short-eared owl, golden eagle. Page 8 Flushes: These are also very important as food sources for wader and grouse chicks (both black and red), and there is often much opportunity for enlarging wet areas to increase biodiversity benefits. First bullet point: (HaRRPS) the impact of forestry operations on them, and appropriate management for them - this should be one of the major drivers of what type of management is required of a particular forest open space. In addition, to pointing managers of open space to HaRPPS in respect of important species, there is a required step before that to identify these. So, contact and consultation with RSPB, LBAP partnerships, SNH/NE/CCW/EHS (UK, or just 3

4 GB publication?), Raptor Study Groups should be undertaken in order to assess the species priorities of all forest open space. Planning for large-scale open habitat restoration and management must be focused to directly benefit priority habitats and species (UKBAP, country priorities, EU Bird & Habitats Directives priorities, plus designated sites: SAC, SPA, SSSI, Ramsar), rather than a generalised habitat approach and employing theoretical species. We are concerned that BEETLE, and HaRRPS, are not used in preference to targeted work for these priority habitats and species, merely as useful tools where appropriate, with forest level planning and policy addressing priority habitats and species. Third bullet point: add to the end: and important birds (e.g. peregrines, eagles, ptarmigan, ring ouzel). Page 9 Getting information about location, connectivity and condition Also important to highlight forest open space adjacent to existing nature reserves belonging to RSPB, Wildlife Trusts, Woodland Trust etc, which will have management plans that should be used as a starting point for potential management of the forest open space. Third paragraph mentions forest design plans need to call these forest plans, which includes non-fe forests, FDPs only refers to state forests in GB. NB not all these forests will be covered by a forest plan not even FE has 100% FDP coverage. FPG12 Forest Design Planning 3 needs updating it has been overtaken by good practice under UKWAS, and development in support and requirements plan preparation under the revised country Rural Development Plans ( ). FE across GB does not use FPG12, instead using its own FMM30 and UKWAS. There is some variation across GB in what level of plan is likely be funded under the RDPs in revised country grant schemes Wales is very closely tied into UKWAS, England strong connection with UKWAS, and Scotland just requiring a plan to meet UK Forestry Standard. This guidance needs to reflect, and assist the development, of current good practice in forest planning. Page 10 Getting information about location, connectivity and condition Add in a new paragraph ahead of Box 3, pointing out that surveys of dependent species are necessary if an holistic approach is to be taken to management of open space, and this is desirable. So, surveys of invertebrates, birds and mammals would be a good starting point, and again existing information may be held by RSPB, Butterfly Conservation, Raptor Study Groups etc. Page 12 Open Habitats in Forest Design Reword opening line to read: General design principles for open habitats in new and existing forests. This change is required because there may be exceptions to some of these to manage for particular species or habitat priorities, rather than aiming for maximum diversity. Second bullet point design large habitat patches (see also Box 6, page 14): Need to strike a balance between creating a mosaic of microhabitats and a mosaic at a coarser scale. Should state somewhere that what constitutes a large habitat patch will depend on the species. Design large habitat patches - except for dragonflies, nightjars etc. 3 Forestry Commission (1998) Forest Design Planning. Forestry Practice Guide 12. FC, Edinburgh. 4

5 Add in new final bullet: Consider disturbance issues, from forest operations and events, likely to affect the open habitat or dependent species when managing/ linking open habitat or forests around them (NB new FCS guidance: plus current FCE & FCW guidance, see extract: Quality of restoration work: when creating new open space, need to mention good practice for biodiversity, such as general desirability of removing brash. This will be a key issue as more owners decide to withdraw sections of plantations from forestry for economic, rather than biodiversity objectives. Page 13 Box 5 - Implementation add in point explaining that: care is also needed to avoid decreasing the existing or potential value of open space to dependent priority species, either on-site or nearby. Therefore, an assessment of the existing and potential value of the open space habitat should be made prior to management, especially the creation of new habitats from fewer existing ones. How should open ground be distributed : this needs to mention that there may be species requirements that may be important for deciding on the distribution of open ground habitat patches, for example for black grouse. Rephrase last 2 lines: Some habitat types not regarded as priorities can still be extremely valuable for biodiversity, especially if in good condition or with potential to be so, and are worth considering retaining and managing. Upland acid grassland and upland neutral grassland fall into this category. Page 14 Linear open ground habitats : The consideration of tree species planted along the edge of linear and other open space can be important for certain species, e.g. black grouse birch, larch, hawthorn, rowan. Box 6 Design large habitat patches - except for dragonflies, nightjars etc. Page 15 Balancing open habitats against other interests competing for space : Add to end of first line: and indeed should do so in a well designed, modern forest. This section needs to discuss priority habitats and species, not just the prioritisation of management of habitats of any quality. This section needs to clearly identify what are priority species and habitats: UK Biodiversity Action Plan priorities SAPs & HAPs, EU Birds and Habitats Directive priorities and Annexes, country species lists, plus for designated sites SSSI, SPA, SAC and Ramsar. Redesigning for open habitats in existing forests Make the following changes to the last line: Undesignated and biodiversity-poor habitat patches unlikely to serve a useful purpose could be earmarked for planting over in future in exchange for some deforestation to restore habitats elsewhere in the forest that are likely to be of higher ecological value when restored. However, great care needs to be taken in such decisions because in some situations restoration of open space is unlikely to provide greater benefits than retention of existing areas. 5

6 Need to mention forestry EIA (under English & Welsh regs; Scottish regs & NI regs) and GB Felling Licences. Last paragraph Given the statutory requirement to maintain Britain s woodland area, deforestation for habitat restoration will generally have to be balanced in area terms by new afforestation and/or infilling of existing open ground this is NOT in line with current country and UK forestry and biodiversity policy, and practice. There are policy commitments to priority woodland and non-woodland HAPs and SAPs under UKBAP, as well as under the country biodiversity strategies. In England and Wales there is a Forestry Commission understanding ( gentleman s agreement ) not to require restocking on open habitats of high biodiversity value. In Scotland, the Nature Conservation (Scotland) Act 2004, formally changed conditional Felling Licences under the Forestry Act 1967 in Scotland, removing compulsory replanting for restoration of priority open ground habitats. Page 16 Open Habitat Networks We are pleased to see discussion of this concept. This highlights the need for guidance on development of open-ground habitat networks, alongside the existing Forest Habitat Networks FCS & SNH publication. Page 17 Second paragraph: In the end, it may come down to prioritising habitat types and favouring the higher priority type when conflict of interest arises between different types include examples of how to do this. Box 7. Implementation. We feel that reference to dispersal of 5 km in unclear and unhelpful. Needs something a bit more objective driven here. If patch big enough, open areas would be used by dunlin, golden plover, greenshank, which move further than 5km in the autumn. We are not convinced this approach can work for all flora/fauna - e.g. invertebrates, reptiles/amphibians, small mammals, large mammals, birds - all function at different scale. Page 18. BEETLE. Planning for large-scale open habitat restoration and management must be focused to directly benefit priority habitats and species (UKBAP, country priorities, EU Bird & Habitats Directives priorities, plus designated sites: SAC, SPA, SSSI, Ramsar), rather than a generalised habitat approach and employing theoretical species. We are concerned that BEETLE, and HaRRPS, are not used in preference to targeted work for these priority habitats and species, merely as useful tools where appropriate, with forest level planning and policy addressing priority habitats and species. Page 19 - General principles for managing open habitats Sixth bullet point: include deer as well as sheep: Inappropriate grazing, particularly overgrazing by sheep and deer, can degrade upland habitats. 6

7 Encourage disturbance. This raises the issue of fencing/deer management and forest planning without fencing there may be less need for disturbance. Not clear how this can be practically delivered at micro-scale. Grazing etc (Box 10). This is unlikely to happen at the micro scale. Priority sites. Needs to be defined as: UK Biodiversity Action Plan priorities SAPs & HAPs, EU Birds and Habitats Directive priorities and Annexes, country species lists, plus for designated sites SSSI, SPA, SAC and Ramsar. Page 22 - Box 9 Add that swiping/burning can disturb/destroy ground nesting birds. Needs to mention current guidance on disturbance avoidance 4. Page 25. Habitat-specific principles: Heathland Fourth paragraph: to the last sentence Livestock stocking levels need to be very low to prevent overgrazing, consequent loss of dwarf shrubs and eventual conversion to acid grassland add the following: but may need an initial intense burst of grazing (or cutting/burning) if dominated by rank heather due to previous undergrazing Add to section: Scarifying ground, especially acid grassland, to encourage heath restoration. Some birds, notably golden plover, will only use extensive open areas without scrub, whereas black grouse and some insects prefer such scrub Encourage wetland creation by drain blocking in heathlands important for moorland breeding birds. Page 26. Habitat-specific principles: Grassland Add to section: Piece on restoration of heathland from grassland Encourage wetland creation by drain blocking in heathlands important for moorland breeding birds. Page 26- Bogs Second last paragraph. Also important not to damage surface vegetation either by burning or inappropriate grazing. Page 27 Bogs First paragraph. We disagree with the premise of the first paragraph, that in their natural state bogs are too unproductive and too wet to sustain grazing this needs clarification, as their may be conservation grazing needs, as well as grazing by small mammals, deer. Page 27 Rocky Habitats Add to section: 4 See new FCS guidance: plus current FCE & FCW guidance, see extract: 7

8 Their inaccessibility makes for good bird nesting and roosting habitats, particularly for raptors. Page 31 - Table 2. This is more useful compared to dense text. Comments on Table 2, pages 31-31, and Table 3 pages follow in bold underlined: 8

9 Table 2. Management options for open habitats Habitat type Management option Purpose Comments Heathland Burning Diversify structure of heath, creating flush of new Usually impracticable. Unnecessarily negative? growth with some insect and bird benefits. Damaging unless very infrequent and restricted to part of habitat patch. Grazing * Excluding grazing Cutting Blocking or infilling drains Controlling deer population Scraping off vegetation Controlling foxes and crows Grassland Grazing * Reduce grazing Prevent succession. Increase microhabitat diversity. Reverse effects of overgrazing. Encourage scrub development. Diversify vegetation structure. Increase microhabitat diversity. Prevent overgrazing. Encourage scrub. Create bare ground invertebrate habitats, and bird habitats. Favour ground-nesting birds Prevent succession. Maintain or increase structural, species and microhabitat diversity. Allow recovery of dwarf shrubs where acid grassland has resulted from overgrazing of heathland. Sustainable only if stocking density low. Ideally a temporary measure. May lead to succession and/or deterioration and need for cutting. Must collect cuttings unless very fine May conflict with maintenance of access Only necessary in extreme cases which management option does this refer to? Livestock prefer calcareous grassland to other vegetation types and this can lead to overgrazing. Hay meadows require grazing in May and from mid-july until late autumn. On acid grassland stocking levels must be low to avoid damage to the nests and eggs of waders. 9

10 Bog Mowing Blocking or infilling drains Prevent succession. Maintain or increase species diversity in meadows or on pastures not being grazed. Raise water table to rewet the ground Cut material should be removed. Hay meadows are best cut around mid-july. May constrain access Pulling or cutting tree seedlings Prevent succession on damaged bogs Unsustainable in the long term Fen Grazing * Controlling foxes and crows Blocking or infilling drains Prevent succession on dried bogs Favour ground-nesting birds. Raise water level to rewet site Very low stocking level required Influence incoming water quality Maintain or restore former water chemistry Rocky habitats Cutting Grazing * Non-intervention Coppicing of scrub Fencing ground below crags Prevent succession Prevent succession Allow succession to scrub or carr Maintain a range of successional stages Encourage spread of grazing-sensitive plant species. Low stocking level for short periods only to avoid excessive poaching Likely to lead to complete loss of open fen May require cutting Cutting shrubs and trees Bulldozing in quarries Slow down succession Renew succession Care may be needed to avoid disturbance of nesting birds applies to all quarry/crag practices NB FC guidance on disturbance avoidance 10

11 Non-specific Cutting back forest edge Prevent too much shading. Discourage tree natural regeneration. Quarry working may achieve this Controlling bracken Planting broadleaf trees on forest edge Prevent loss of valued habitat to bracken Enhance habitat for key invertebrate and bird species, e.g moths, and black grouse Bracken can be a habitat for rare ferns and butterflies Species selection will depend on biodiversity objectives Stocking rates and other recommendations concerning grazing regimes are given in section of The Upland Management Handbook (Backshall et al., 2001) 11

12 Table 3. Restoration management options. Habitat type Restoration management option Comments Heathland Harvesting trees Removal of brash will benefit a range of flora and fauna and hasten restoration. Grassland Bog Felling to waste or chip Disturbing needle layer (e.g. raking) Avoiding disturbing needle layer Grazing Cutting heath Burning Cutting trees Allowing succession Controlling bracken Grazing regime Mowing with offtake Harvesting trees Harvesting brash Chipping whole trees or brash If harvesting is not practicable Where trials show that this favours dwarf shrubs over grasses Where trials show that disturbance favours grasses over dwarf shrubs Not until dwarf shrubs sufficiently well established. Low stocking level. If no grazing Not until heath seedbank replenished. Usually impracticable in forest situation. If unacceptable degree of regeneration. Only if partly wooded heath is acceptable or desired. Management needed eventually to prevent loss of heath to complete woodland cover. Where extent of loss of heath becomes unacceptable Always desirable. Annually in late July on restored hay meadows and areas not grazed. Brash left on site acceptable if well spread out and there is no evidence of nutrient enrichment We disagree with this. Brash removal is preferable for a range of key raptors, black grouse etc. Removal of brash will benefit a range of flora and fauna and hasten restoration Only where rapid revegetation important and/or there is evidence of nutrient enrichment. Enables rapid revegetation but chips need removed if there is evidence of nutrient 12

13 Fen Felling to waste Rewet by blocking drains Rewet by blocking plough furrows Partly open by felling trees Restore water chemistry enrichment. Danger of dead trees protecting tree seedlings from browsing Always essential. Beneficial if summer drying hinders bog species recovery. If subject to succession. Consider rotational coppicing. Difficult to influence neighbours land management. DETAILED COMMENTS continue on the next page 13

14 DETAILED COMMENTS continued Page 35 Paragraph 2 : Quality of existing forest. This paragraph needs stressing, as it easiest for a forester to assess a site which they are familiar with. Page 40 - Table 3. Bog. Clarity needed on the point that drains and furrows are different in terms of their overall impact on water. Pages Good practice boxes (Boxes 14-17): This publication, and these boxes, should help define best practice, rather than just good practice This publication for all public, state and private forestry would benefit from a wider range of case studies and examples, beyond the current FE focus. There is no reference to the work we, and the Flow Country partnership, have been doing in Caithness and Sutherland peatlands as part of the LIFE project. This publication would benefit from such evidence from the grey and peer-reviewed literature. 14