WoodlandPotentialConsultation.pdf & 2 ed to:

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1 Forestry Commission England & Natural England, The potential for woodland creation in England 1, response to consultation 2 by the Royal Society for the Protection of Birds 3, October Summary The RSPB welcomes the opportunity to respond to this consultation. The RSPB supports woodland expansion in England of the right type, in the right place, that protects and enhances biodiversity and produces other public benefits. The RSPB fully supports the conservation and enhancement of England s native woodland wildlife. It is important that the wildlife of priority habitats and species of existing native woodland remnants is enhanced, as well as considering options to expand, buffer or ecologically link such patches. It is important that any new woodland planting including native woods and forestry plantations is located in places and carried out in a manner that does not damage important wildlife, but enhances it. This includes ensuring that semi-natural grassland, lowland heathland, blanket and raised bogs are not afforested, and also keeping open ground sites for species such as breeding wading birds and high wildlife value flowering plants. The consultation suggests that priority habitats may be considered as sensitive, but we have concerns about how this will be judged in practice, as well as bolted into the design of grants, their operation and any policy push towards an overall woodland expansion target. We also have concerns about how priority non-woodland species, such as lapwing, curlew and snipe, farmland birds, as well as flowering plants are to be protected from inappropriate woodland expansion, including in relation to planting on agricultural land. The RSPB has concerns that the woodland expansion tool proposed the Woodland Potential Calculator may be too crude a method to ensure appropriate location and design of new woodland to protect and enhance public benefits, including biodiversity. We remain to be convinced whether there will be sufficient requirements for appropriate location to protect biodiversity, and assessment of site and cumulative environmental impacts of woodland expansion based upon ecological survey, or a promotion of woodland design and objectives to meet public benefits, including the conservation of priority wildlife. Furthermore, we have concerns that this woodland expansion area target may push policy, guidance, regulatory decisions and grants towards lower biodiversity quality new woodland, and in some cases, biodiversity damaging proposals. The detail of our response is split into two sections A common principles & concerns, and B comments on expansion within individual Natural Character Areas. 1 WoodlandPotentialConsultation.pdf & 2 ed to: wpcresponse@forestry.gsi.gov.uk 3 Contact: Mike Wood, UK Forestry Policy Officer, RSPB, Ground Floor Miller Building, Lochside View, Edinburgh Park, Edinburgh, EH12 9DH; tel: ; mike.wood@rspb.org.uk 1

2 PART A Common Principles & Concerns about woodland expansion The purpose of woodland expansion The RSPB would welcome a strategic approach to woodland expansion in England, to help deliver the UK Government s country, UK, EU and international biodiversity commitments for priority species, habitats and designated sites. A similar strategic approach is needed for the restoration of open ground habitats from inappropriate forestry, building upon the open habitats policy 4 and delivering it in practice. The RSPB would welcome any new woodland that could meet public benefits, in particular improving the wildlife condition of priority native woodland habitats and work for priority species. The RSPB favours approaches that encourage ecological condition improvement to meet biodiversity targets of existing native woodland remnants, rather than an over-riding focus on woodland expansion. This includes improving the biodiversity condition of England s priority native woodland habitats 5 under Section 41 of the Natural Environment and Rural Communities Act 2006 and the England Biodiversity Strategy lowland mixed deciduous, upland oakwood, wet woodland and upland mixed ashwoods, as well as lowland beech and yew woods, lowland wood-pasture and parkland. Work is also needed to improve the biodiversity of native woodland and forestry plantations for priority wildlife species. The RSPB, and other environmental organisations, were concerned about the scale, quality and location of new woodland planting driven by earlier government forestry expansion programmes 6. Although the policy had improved, the RSPB remains concerned about the continuing legacy of the forestry plantations that were created, some of which continue to damage biodiversity. The RSPB also still remains concerned about pressures for woodland expansion which may result in a new wave of inappropriately located forestry in biodiversity sensitive areas. This could occur through a relaxation of regulatory oversight, or new sources of funding that side-step the conventional forestry consenting regime that is tied to land management grants. The RSPB has concerns that a national woodland expansion target could be used at national and local levels to justify poorly located new woodland that causes biodiversity harm, and does not deliver public benefits. This policy development must recognise the negative biodiversity impacts of existing large scale and intensity afforestation, on species such as breeding wading birds, and habitats, such as lowland 4 Forestry Commission England (2010) When to Convert Woods and Forests to Open Habitat in England: Government Policy. March Forestry Commission England, Bristol. 5 UK Biodiversity Action Plan types: See: NCC (1986) Nature Conservation & Afforestation in Britain. Nature Conservancy Council, Peterborough. RSPB (1991) Forests for the Future integrating forestry & the environment. RSPB, Edinburgh. Stroud, D.A., Reed, T.M., Pienowski, M.W. & Lindsay, R.A. (1987) Birds, Bogs & Forestry. Nature Conservancy Council, Edinburgh. Tompkins, S.C. (1986) Theft of the Hills. Rambler's Association, London. 2

3 heathland, blanket and raised bogs, moorland, semi-natural grassland and coastal dune systems. There is a high biodiversity imperative to restore priority open ground habitats, including lowland heathland, from inappropriate afforestation. There is also a need to protect and enhance the biodiversity of farmland habitats. Before considering any further woodland expansion in heavily forested areas in England, such Kielder and Thetford Forests, there is a need to improve the biodiversity condition of damaged open ground habitats and associated species, existing native woods, as well as priority species related to plantations. Appropriate location of planting A key issue for the RSPB is the appropriate location of new woodland, so that it does not damage sites for priority species, priority habitats or designated wildlife sites, such as wetland sites for breeding wading birds, peatland habitats, lowland heathland, SSSIs, SPAs, SACs and Ramsar sites. We also look for woodland expansion to meet priority woodland habitats and species targets, alongside work to improve the biodiversity condition of existing native woodland. The consultation suggests that priority habitats may be considered as sensitive, but we have concerns about how this will be judged in practice, as well as bolted into the design of grants, their operation and any policy push towards an overall woodland expansion target. We also have concerns about how priority non-woodland species, such as lapwing, curlew and snipe, farmland birds, as well as flowering plants are to be protected from inappropriate woodland expansion, including in relation to planting on agricultural land. The RSPB has concerns that the woodland expansion tool proposed the Woodland Potential Calculator may be too crude a method to ensure appropriate location and design of new woodland to protect and enhance public benefits, including biodiversity. We remain to be convinced whether there will be sufficient requirements for appropriate location to protect biodiversity, and assessment of site and cumulative environmental impacts of woodland expansion based upon ecological survey, or a promotion of woodland design and objectives to meet public benefits, including the conservation of priority wildlife. The RSPB is pleased that planting is to stay away from deep peats. It is vital that the current Forestry Commission peatland policy 7 is not watered down to threaten these important habitats. We value the forestry Environmental Impact Assessment process and the requirements of the UK Government s own minimum mandatory sustainable forest management standard the UK Forestry Standard and its associated Forest Guidelines, as well as Appropriate Assessment under EU law. We value the role of the UK Forestry Standard as a condition on state and private sector forest plans approved by the Forestry Commission, as a requirement for Felling Licences and as a condition on all woodland planting and management consented by the Forestry Commission. The RSPB does not view the UK Forestry Standard, Felling Licensing, forestry Environmental Impact Assessment, Appropriate Assessment, the EU Birds or Habitats Directives, or the Forestry Commission s Public Register as gold-plating regulation. A key issue for the RSPB is how the hard and soft regulatory instruments of forestry are applied in the consent of woodland expansion and the related design and operation of woodland and agri-environment grants. This includes at site level for small woodland patches, and cumulatively. 7 Patterson, G. & Anderson, R. (2000) Forests & peatland habitats. Forestry Commission Guideline Note 1. Forestry Commission, Edinburgh. 3

4 The RSPB is concerned that the environmental impacts of woodland creation proposals may not be properly assessed. We have concerns about the rigour and consistency of forestry Environmental Impact Assessment process, particularly in relation to identifying significant impacts of woodland expansion at the scoping stage, and requiring mitigation of what are non-significant impacts at a later stage. We also have concerns that the environmental impacts of proposals for small woodland patches is not properly assessed. This may be due to a number of factors, for example lack of awareness or recognition of the issue by Forestry Commission England and Natural England, lack of a forestry casework approach by Natural England beyond designated wildlife sites, lack of awareness of the UK Forestry Standard by applicants, no requirement for UK Forestry Standard compliance within all scheme rules for the planting and management of woodland (entry and higher level agri-environment schemes as well as Forestry Commission administered woodland grants), or lack of requirements to meet the UK Forestry Standard within schemes, or insufficient requests by the regulator for prior ecological survey and subsequent monitoring. The area thresholds for forestry Environment Impact Assessment, and the definition of sensitive sites, and their application by Forestry Commission, may not fully pick up all wildlife sensitivities, for example for breeding wading birds or patches of high priority semi-natural grassland habitats. We also consider that cumulative environmental impacts of woodland expansion are not properly considered in the consenting of individual proposals this is particularly an issue for small new woodland blocks, which may themselves have not been adequately assessed for their site impacts. There may be a disparity between how forestry Environmental Impact Assessments are requested for non-state forestry and the assessment of significant environmental impacts on the Public Forest Estate through Forest Design Planning. We are uncertain whether there is a consistent approach between afforestation and deforestation proposals through forestry Environmental Impact Assessment, for example how biodiversity concerns are addressed in woodland expansion and biodiversity opportunities in open ground habitat restoration proposals. We have concerns about regulatory creep related to compensatory planting - UK Government and its delivery bodies at all levels should remember the requirements of the UK Forestry Standard and current English open habitats policy. The RSPB has concerns about any moves to site-based compensatory woodland planting conditions for consent for any open ground habitat restoration projects that plan to restore priority open ground habitats. The RSPB considers that the UK Government adopts a partial approach to the implementation of the UK Forestry Standard. UK Forestry Standard compliance is the part of the UK government and devolved administrations international commitments to sustainable forest management 8. UK Forestry Standard compliance must remain a condition for all woodland planting and management grants, Felling Licences, forestry Environmental Impact Assessment and management of the Public Forest Estate. The UK Forestry Standard is the UK Government and devolved administrations approach to sustainable forest management for all of the UK s woodland. It is a soft law regulatory instrument that is a condition of Forestry Commission consenting regimes, not codified in the Forestry Act 1967 or the Environmental 8 For example the Ministerial Conference for Protection of Forests in Europe (MCPFE) agreements, including the 1993 MCPFE Helsinki Principles for Sustainable Forest Management, see: 4

5 Impact Assessment (Forestry) (England and Wales) It is inappropriate for UK Forestry Standard compliance to not be required for woodland expansion and management on farms under agrienvironment schemes, or through the town and country planning system. We note that the Forestry Commission has sustainable forestry and biodiversities duties and obligations, for example under Section 1(3) of the Forestry Act This must include ensuring the appropriate location and design of all woodland planting to protect and enhance wildlife. The RSPB has concerns about the intensity of compliance checking for the UK Forestry Standard by the Forestry Commission, the rest of the Defra family and by strategic and local planning authorities. We also have concerns about the systems level checking and evidence collected for Forestry Commission England Forest Services areas and country level reporting of UK Forestry Standard compliance. We note that an objective of the Government s GB forestry research strategy, as well as a task for Forestry Commission s own research agency Forest Research is UK Forestry Standard compliance and implementation monitoring. The RSPB also has concerns about the implementation of new silvicultural systems and tree species for biomass planting, such as short rotation forestry using eucalyptus, without proper consideration of biodiversity impacts. We are concerned that Forestry Commission s own trials of short rotation forestry across GB did not undergo a site-based Environmental Impact Assessment for every site, and for those in Scotland, a Strategic Environmental Assessment. This shows an unfortunate regard for the precautionary principle, particular for such experimental works. The RSPB would like to discuss with Forestry Commission England and Natural England methods of assessing the appropriate location and design of all woodland expansion. The RSPB would be keen to input to the development of Forestry Commission England guidance on site selection for woodland expansion. Our work in Scotland and Wales on assessment of bird sensitivity for woodland and windfarms could provide a useful basis for the development for sensitivity mapping for woodland expansion in England. Landscape scale approaches to woodland expansion Landscape scale woodland expansion must benefit priority species and habitats as well as designated sites. Large-scale woodland expansion and restoration policies, grants and projects must directly benefit real priority species, habitats and designated nature conservation sites. The development of forest habitat networks must not be at the detriment of open-ground habitat networks. A 'regional' scale can be a useful way of thinking for ecological, nature conservation and multi-purpose forestry objectives. This does not replace the need for site based ecological survey and management planning, backed up by suitable grant measures and requirements. The National Character Areas should not be the only scale or boundaries used for landscape scale work for woodland management and expansion. We note that the National Character Areas are not designed to take count of the biological condition of priority non-woodland or woodland priority habitats, or the populations of priority species. Landscape/regional scale approaches could be used to target woodland expansion grants. Such an approach could also be a useful scale to understand economic and rural development issues and potential, for example the ecological condition of native woodlands and scope for ecological improvement through fostering co-operative and collaborative approaches to ecological survey, management planning, management, felling, extraction and marketing. 5

6 There is scope to use proposed new Articles under the EU Rural Development Regulation on cooperation to foster management approaches, ecological survey, management planning and actual management for larger-scale ecological restoration, for example for existing native woodlands and priority species within them. There is also potential to fund vital advisory support to woodland owners considering native woodland restoration, management as well as expansion. The data, studies, plans, strategies and partnerships that went into regional woodland strategy processes could be useful sources of information for woodland expansion opportunity and sensitivity mapping, and approaches to management of the existing native woodland resources. Assessment of cumulative environmental impacts of woodland expansion would be a useful part of this process. This scale would also be useful to think of ecological network development for real - not theoretical - priority woodland and non-woodland species and habitats. Open ground habitat network development as well as woodland habitat development. We have concerns about the biodiversity merits of the current applications of Forestry Commission Forest Research s BEETLE landscape modelling tool. The RSPB would welcome the UK Government issuing guidance on the policy/project use of habitat network modelling tools to ensure that country, UK and EU priority species, habitats and designated sites are considered alongside the development of habitat networks. There is much interest in the design of new woodland habitat networks for wildlife and people. While the RSPB welcomes such an innovative approach to wildlife conservation, we currently have concerns that such work may be progressing without proper consideration of the impacts on real priority species and habitats actually present, many of which do not neatly fit into some of the computer modelling tools being employed, such as the Forestry Commission s BEETLE programme 9. It is important when planning new networks of woodland and greenspace that important nonwoodland, as well as woodland habitats, are looked after. The design of networks for woodland and greenspace must take account of the existing priority wildlife species and habitats actually present. Bailey 10 has reviewed the evidence on biodiversity benefits of using such tools for forest planning in the UK, and concluded a lack of firm empirical evidence that species increase following attempts to increase connectivity in fragmented woods and also an over-emphasis of the importance of habitat fragmentation per se as a threat to biodiversity. Computer models, such as Forestry Commission s contract research organisation s BEETLE tool, are being used by policy makers and project planners to generate maps identifying areas to target woodland expansion. Such an approach may not benefit actual priority biodiversity, due to ecological inappropriateness of such models for some species, lack of consideration of impacts on important nonwoodland habitats, or being the main focus of all biodiversity action in an area. 9 Forestry Commission Great Britain s own contract research organisation Forest Research has developed a model to assist the development of habitat mosaics, BEETLE (Biological & Environmental Evaluation Tools for Landscape Ecology; see: and HaRRPS (Habitats and Rare, Priority and Protected Species ) a decision support tool for landscape-scale species and habitat planning (see: : 10 Bailey, S. (2007) Increasing Connectivity in Fragmented Landscapes an investigation of evidence for biodiversity gains in woodlands. Forest Ecology & Management. Vol. 238, pp

7 Such modelling tools are based upon how theoretical and some real species move between patches of woodland, through the notional or actual linking corridors of suitable habitat. Such an approach may be inappropriate for actual bird species of conservation priority for which such corridors do not actually provide ecological linkage between habitat patches, or which disperse at different rates to the idealised focal species used in these models. BEETLE is based upon a focal species approach, which Forestry Commission itself has warned against taking this out of context 11 the RSPB shares this concern. Forest Research is looking to improve the ecological robustness of such generic species models, taking account of real species data 12,13. Management of existing woodland We note that improving the condition of native woodland priority habitats is are biodiversity objectives and targets under the England Biodiversity Strategy and the UK Biodiversity Action Plan (UKBAP) native woodland habitat action plans that underpin this. The condition of priority native woodland habitats was a concern in successive UKBAP reporting rounds for native woodlands, and the development of forestry and woodland strategies and the grant schemes. Neither agricultural and forestry grants for woodland planting or management, state forestry or the market has fully met the challenges within the government s own biodiversity targets for woodland and non-woodland habitats and species. Public benefits, particularly non-market benefits such as biodiversity, have yet to be fully realised on England s public, state or privately owned woodland. A high proportion of native woodland - the most valuable woodland resource for wildlife and other public benefits - is currently not being accessed by government s policy delivery mechanisms. Only about a third of England s woodland is native woodland, the majority of which is privately owned. Many of these native woods are small, isolated fragments, in need of remedial work and onward management to protect and enhance their biodiversity value. Such woods may be termed under-managed and may have been so for a long time, perhaps for a range economic and other reasons. Much of England s native woodland is not in receipt of existing grants for positive woodland management that could help enhance their value for wildlife and other public benefits. Such woodland is also seldom certified against the voluntary UK Woodland Assurance Standard, and if not in receipt of grant or felling licence will not be engaged with the Forestry Commission, or required to meet the Government s mandatory UK Forestry Standard. 11 Focal species should be regarded as part of an evaluation toolkit, which allows an assessment of the relative merits of landscape change, rather than as direct targets for conservation action in themselves. This objective information can then be used in the wider decision making process. See: See: Watts, K., Humphrey, J.W., Griffiths, M., Quine, C. & Ray, D. (2005) Evaluating Biodiversity in Fragmented Landscapes: Principles. September Forestry Commission Information Note 73. Forestry Commission, Edinburgh BEETLE is designed to be an adaptive evaluation tool which will be refined by ongoing monitoring and research. Further validation of the model will be achieved from the continual improvement of both spatial and species data, in: Watts, K., Humphrey, J.W., Griffiths, M., Quine, C. & Ray, D. (2005) Evaluating Biodiversity in Fragmented Landscapes: Principles. September Forestry Commission Information Note 73. Forestry Commission, Edinburgh. 13 See Conclusions & Future Research, p.6 in: Eycott, A. et al. (2007) Evaluating Biodiversity in Fragmented Landscapes - the use of focal species. October Forestry Commission Information Note 89. Forestry Commission, Edinburgh. 7

8 There is a need to encourage and facilitate more widespread positive management of native woodlands to improve the quality of priority habitats and populations of priority species. This could be done via harvesting and marketing co-ops, using techniques and machinery appropriate for native woods, training for woodland survey, skills development for management planning, woodland survey and monitoring as well as appropriate harvesting, extraction, processing and marketing of wood and timber products. There could also be support for certification of small/low intensity managed woodlands to the UK Woodland Assurance Standard (UKWAS) to assist market access, generate consumer confidence on sustainability, and to promote positive management approaches. Government has an important facilitation role in bringing native woodlands into good condition to meet its own biodiversity commitments; and not just through woodland grants and state forestry, but by other mechanisms too. There is scope for government to innovate in this area, for example by finding ways to enable co-operative woodland management planning and group certification, and fostering collaborative approaches to harvesting, extraction and marketing of products. Woodland planting & management grants The objectives, funding and operation of woodland planting and management grants must be for high quality public benefits, including biodiversity, and done in a targeted manner to achieve this. There needs to be targeted woodland planting (and also management) grants for work to restore and enhance priority wildlife, including priority species, priority habitats as well as designated sites. This includes work for both woodland and non-woodland priority species and habitats, for example from priority native woodland habitats, such as upland oakwood and lowland mixed deciduous woodland, to the restoration of lowland heathland, semi-natural grassland and peatland habitats by tree removal, hydrological restoration (for bogs) and onward vegetation management, work for broadleaved woodland birds and black grouse. This is more an evolution of the existing English Woodland Grant Scheme. This continues the development of woodland grants to meet multiple objectives sustainably since GB policy changes in 1991 for sustainable multi-benefit forestry, changes in 1985 to the Forestry Commissioners' statutory duties, and the subsequent English forestry strategies, and related development of the Woodland Grant Scheme and its successors. There is scope to use proposed new Articles under the EU Rural Development Regulation on cooperation to foster management approaches, ecological survey, management planning and actual management for larger-scale ecological restoration, for example for existing native woodlands and priority species within them. There is also potential to fund vital advisory support to woodland owners considering native woodland restoration, management as well as expansion. Woodland planting (and management) grants need to ensure any work is done in a environmentally sustainable manner; this means as a minimum UK Forestry Standard requirement and compliance checking (currently not in place for all parts of Rural Development Plan for England [RDPE]). There also needs targeted biodiversity work above this to meet country biodiversity targets and international commitments. New woodland planting must be carefully located to avoid adverse impacts on priority wildlife species and habitats, such as priority open ground habitats and sites for breeding wading birds, as well as on the condition and features of designated wildlife sites including those adjacent to/potentially impacted by any proposals. 8

9 Woodland management and felling proposals need to be carefully planned to avoid wildlife damage and disturbance, and preferably enhance priority wildlife. This need to consider woodland expansion in an environmentally sustainable manner relates to the UK Government meeting its international sustainable forestry commitments, for example by introducing and requiring UK Forestry Standard compliance and GB, then English forestry strategies. In light of England having no forestry strategy, following withdrawal of England s Trees, Woods and Forests, there is a question mark of how, and if, sustainability is to be bolted into the woodland aspects of RDPE. This also raises the issue of how biodiversity objectives will be bolted in too - traditionally Forestry Commission England has followed the biodiversity elements of the forestry strategy, plus the biodiversity strategy. RDPE must meet the English Biodiversity Strategy, including for woodland habitats and species, but also nonwoodland habitats and species impacted by forestry. On agricultural holdings, preference should be given for woodland grants for improving the priority wildlife quality and other public benefits of existing priority native woodland habitats, rather than planting new woodland. Some of this new planting may be proposed for important non-woodland habitats and sites for priority species, e.g. lapwing, which may not have been picked up by ecological survey, which was not asked for, and was not part of an environmental impact assessment. This targeting must happen at application stage, as well as in scheme design, RDPE drafting and Natural England annual targeting/prioritisation processes. In order to produce best quality and high priority wildlife benefits, we would welcome the retention of higher tier woodland grants in new scheme design, with lower level agri-environment woodland grants that are not designed or targeted to produce high quality priority wildlife benefits not being offered. Environmental assessment of woodland expansion needs to done for all proposals to pick up significant environmental impacts, including via ecological survey. This must also consider cumulative as well as single site proposals. We have concerns that the environmental impacts of small woodland blocks are not being fully considered. This is an issue for RDPE and scheme design, scheme approval and administration. This requires good working between Natural England and Forestry Commission England, and needs to be protected and enhanced in any organisational changes and mergers. Consultation. The Forestry Commission's Public Registers for woodland planting, management and felling proposals need to be retained, and include all grant proposals, Felling License applications as well as environmental assessment consultations and forest plan proposals for public, private and state forestry. This includes all woodland work, regardless of whether it is badged as 'Higher Level Stewardship', 'English Woodland Grant Scheme', or Entry level Scheme' and their successor schemes, and regardless of which government body or agency is administering these schemes. Advisory & management planning. There is a need to have high quality advisory input to woodland schemes to ensure that high quality work is funded that meets public benefits. There is still a need for supporting management plan preparation including ecological survey, particularly to assist the provision of public benefits. We do not automatically advocate the Forestry Commission England management plan proforma, but appropriate plans for the site that meet nature conservation requirements for priority wildlife, as well as plans for designated sites. The guidance in the UK Woodland Assurance Standard on management planning is useful in this regard. 9

10 We support the continuation of management planning towards UK Woodland Assurance Standard (UKWAS) - this is still a UK Government commitment that was made at the 2002 World Summit on Sustainable Development. England Woodland Grant Scheme (EWGS) and Higher Level Scheme (HLS) merger. We have yet to see, or consider, any future proposals. But any merger needs to ensure public benefits delivery, including for priority wildlife and fund environmentally sustainable work for multi-purpose forestry. This should mean keeping the most targeted bits of HLS and EWGS that fund particular actions for priority wildlife (so meets the England Biodiversity Strategy and EU and International commitments for wildlife), require UK Forestry Standard compliance (so no environmentally damaging forestry practices), within the context of site and cumulative environmental assessment and larger-scale approaches to woodland management and creation. There is an issue of without a country forestry strategy what are the priorities of the RDPE woodland measures. The RSPB considers that it is vital that RDPE woodland measures must meet the objectives of the English Biodiversity Strategy and the priority species and habitats under Section 41 of the NERC Act. This raises the issue that if the EWGS is merged into HLS and therefore under Natural England s control, then how are Natural England s annually set priorities going to be set and what will they include. PART B Potential for Woodland Expansion in National Character Areas More detail to follow in a separate response. The RSPB is a registered charity: England and Wales no , Scotland no. SC The RSPB speaks out for birds and wildlife, tackling the problems that threaten our environment. We have over a million members. We own and manage about 8,800 hectares of woodland in the UK, a quarter of which is in England. Our UK forestry-related work includes advocating changes to devolved country and local policies, providing advice on conservation management to woodland owners and managers, and undertaking research into birds and other biodiversity affected by forestry practices. A summary of our forestry policy work is at: including responses to recent government consultations. END of consultation response. 10