UK Forestry Standard, 3rd Edition, Consultation Draft 1 1 consultation response by the Royal Society for the Protection of Birds 2, January 2008.

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1 UK Forestry Standard, 3rd Edition, Consultation Draft 1 1 consultation response by the Royal Society for the Protection of Birds 2, January The need for an effective minimum standard for sustainable forest management The RSPB welcomes the opportunity to comment on this initial draft of the 3 rd Edition of the UK Forestry Standard (UKFS). We wish to be involved in further discussions on the revision of the UK Forestry Standard and its associated UK Forestry Guidelines. The RSPB welcomed the 1998 introduction of the original UK Forestry Standard 3, and its 2004 refresh 4, as an essential environmental check to ensure sustainable forest management, from location, design and management of afforestation, to restocking and operations within existing woodland. The RSPB considers that it is vital that the UK Government and devolved administrations continue to prevent inappropriate tree planting on priority non-woodland habitats. For example blanket and raised bogs, lowland heathland, heather moorland, semi-natural grasslands and breeding wader sites; as well as undesignated sites important for priority species and UK, EU and internationally designated wildlife sites. It is also important that the standard drives the enhancement of the ecological condition of native woodlands, not just on designated sites, and the restructuring of forestry plantations to benefit priority biodiversity, such as black grouse and capercaillie. We are concerned that the proposed changes to the UK Forestry Standard do not achieve this, and may in fact reduce government s commitment to delivery of its international sustainable forestry agreements first set out in Issues with the current standard The UK Forestry Standard states: The purpose of the UK Forestry Standard is to set out the criteria and standards for the sustainable management of all forests and woodlands in the UK. This does not exempt forests and woodlands that are grant aided through agricultural grants, or work consented under the town and country planning system. The RSPB remains concerned that the UK Forestry Standard and its implementation is inconsistent about trees on important non-woodland habitats afforestation is not encouraged, but restocking is permitted. It is important that open ground habitats are restored from inappropriate plantation forestry the very areas that would not be allowed to 1 presented by Forestry Commission Great Britain to the Revision of the UK Forestry Standard & Forestry Guidelines Seminar, 27 November 2007, Pollock Halls, University of Edinburgh. 2 Contact details: Mike Wood, UK Forestry Policy Officer, RSPB, Dunedin House, Edinburgh, EH4 3TP. Tel: , mike.wood@rspb.org.uk 3 Forestry Commission & DANI (1998) UK Forestry Standard the Government s Approach to Sustainable Forestry. FC, Edinburgh & Department for Agriculture NI, Belfast. 4 Forestry Commission & DARDNI (2004) UK Forestry Standard the Government s Approach to Sustainable Forestry. 2 nd Edition. Forestry Commission & Forest Service, Department of Agriculture & Rural Development Northern Ireland. 5 UK Government (1994) Sustainable Forestry - the UK Programme. Cm HMSO, London. 1

2 be newly planted under the standard, but continue to be replanted. We want the new version of the UKFS to effectively resolve this issue. The RSPB is concerned that the current version of the UK Forestry Standard is not being universally applied by local authority town and country planning departments, e.g. windfarm felling, or for non-forestry Commission/Forest Service sanctioned agricultural woodlands, or short rotation coppice. We want the new version of the UKFS to effectively resolve this issue. The UKFS must not be eroded in scope or function. If the UK Forestry Standard is to be revised it is important that it becomes more auditable - more of a standard - and that forests and woodlands are actually audited for UKFS compliance by forestry regulators and government agencies. It is important that the language of the requirements in the tables is carefully chosen, for example precision on the use of 'should' and 'shall', and the hierarchy, role and fit between UKFS, its Guidelines as well as connection with UKWAS (ISO compliance). Comments on the draft 3 rd Edition of the UK Forestry Standard Minimum compliance levels The proposed UK Forestry Standard has partially disconnected the standard from the Guidelines by having two levels of compliance. Basic level legal compliance requires little or no compliance with the content of the Guidelines, whereas the good forest [sic] practice links with the Guidelines. The previous versions of the standard did not make this distinction UK Forestry Standard compliance connected with the practice outlined in the Guidelines. It is inclear in the requirements tables (pages 23-33) what is the minimum for UK Forestry Standard compliance, as the standard now includes two levels basic level legal compliance and higher level requirements of good forest practice (page 19, paragraphs 81, 82 & 83). For example, the minimum requirement for location of all afforestation away from important habitats and species all forestry and woodland management should meet the requirements of the good forest practice column, connecting to the Biodiversity Guidelines. It is important that the UK Forestry Standard, and government grants, require good forestry practice and preferably best forestry practice. Despite the assurances in paragraph 83, that the offer of incentives for forestry will be conditional upon meeting the requirements of good forestry practice is not certain that this will be taken up by devolved administrations in the Rural Development Plans for all woodland planting, not just traditional forestry grants. It is unclear how the requirement tables and their two levels fits in with the voluntary UK Woodland Assurance Standard (UKWAS). UKWAS is a third level best forestry practice. We are concerned that changes to UKFS will have unintended impacts on the meaning and operation of the UKWAS standard. It is perhaps time for the UKWAS Requirements to remove all mention of the UK Forestry Standard, merely referencing the UK Forestry Guidelines. Standard Notes discontinuation (page 3) The RSPB values the locational environmental checks on afforestation that Standard Notes 1, 2 and 3 provide, as well as requirements for management of existing woodlands. We think that environmental sustainability of the forest management that the proposed UK Forestry Standard is weaker, due to the proposal to remove the Standard Notes to the Guidelines and their contents only apply to good forest practice. We are particularly concerned about the reduction in standards for location of new forest planting, as well as management of existing woodlands. 2

3 We are concerned that moving the Standard Notes into the Guidelines means that the minimum level of environmental compliance is reduced currently the Standard Notes, and the whole of the UK Forestry Standard, is for all forestry and woodland management; in the revised UKFS these will only be for the higher level good forest practice. We are concerned about the discontinuation of the Standard Notes as they relate to discernable forestry operations, and are therefore accessible to woodland managers. The Standard Notes should be retained within the standard and made more auditable by having discrete requirements. We are not convinced that the Standard Note contents can be adequately translocated into the Guidelines. If this proposals remains, there needs to be a table tracking the move of the Standard Notes across all whole suite of Guidelines, as well as what remains in the requirements table of the standard that applies to all forestry and woodland management. Purpose of the UK Forestry Standard (box, page 3) The previous two versions of the standard stated: The purpose of the UK Forestry Standard is to set out the criteria and standards for the sustainable management of all forests and woodlands in the UK this should remain in Edition 3, but also be effectively implemented across all forestry and woodland land use. We support the commitment to UKFS monitoring, but suggest that this must be compliance auditing of actual forests and woodlands, rather than reporting of the number or area of forests that have agreed to meet the standard by signing up to a forestry grant, or subject to a Felling Licence or EIA. International Priorities (page 10) This needs to include UK Government and devolved administrations commitments to sustainable forest management and certification at the 2002 World Summit on Sustainable Development 6. Climate change policy in the UK (page 11, paragraph 41) This should include devolved commitments and policy development, as well as UK policies. The standard seems to be ramping up, and possibly overstating current policy in this area. Consultation on the standard should explain where, and why such changes are being introduced. UN Convention of Biological Diversity (page 11) This needs to explain the link with the UK Biodiversity Action Plan process, country biodiversity strategies, country forestry strategy biodiversity commitments as well as the ecological condition of designated sites and priority species and habitats under UK, EU and International commitments and law (designations SSSI, NNR, SPA, SAC, Ramsar plus EU Habitats Directive priority species & habitats). Timber Procurement (page 14) This should mention devolved administrations sustainability strategies and guidance for public procurement of timber/wood products 7. Forests & Climate Change (page 15) The standard seems to be ramping up, and possibly overstating current policy in this area. Consultation on the standard should explain where, and why such changes are being introduced. 6 See: 7 For example Scottish Government Policy: & Scottish Local Government Policy: 3

4 Page 16, paragraph 65. Forestry in Northern Ireland is under the Forestry Act (Northern Ireland) , not the GB only Forestry Act Policy priority for replanting (page 16, paragraph 68) There is not yet a policy priority across all of the UK countries to replant trees for supposed climate change mitigation. Currently there is no presumption for compensatory planting. The standard seems to be ramping up, and possibly overstating current policy in this area. Consultation on the standard should explain where, and why such changes are being introduced. EIA Regulations in Northern Ireland (page 17, paragraph 71) The current Environmental Impact Assessment regulations for forestry in Northern Ireland are the Environmental Impact Assessment (Forestry) (Northern Ireland) Regulations , not the 2000 regulations. Felling Licensing (page 18, paragraph 75) This must reflect the changes to Felling Licence conditions in Scotland not requiring compulsory replanting when restoring important open ground habitats (Schedule 7 of the Nature Conservation [Scotland] Act 2004 amended Sections 10 & 12 of the Forestry Act 1967 in Scotland 10 ). Strategic Monitoring The National Inventory of Woodlands & Trees is a GB survey, not a UK survey (page 20, paragraph 91). We would like to see a clearer, and more robust justification of the benefits of scrapping the UK Indicators of Sustainable Forest Management. Would like to see consultation similar to when the original indicators were developed 11. There is still a need for biodiversity indicators 12. We are not convinced that using the reporting for the UN Forest Resources Assessment and Ministerial Conference for Protection of Forest in Europe is the most appropriate or effective way to assess effectiveness of the UK Forestry Standard in delivering sustainable forest management (page 21, paragraph 93). This should detail the plans for forest monitoring in Northern Ireland currently only GB mentioned (page 21, paragraph 97). We welcome the monitoring of un-certified woods, we hope this means meeting UK Forestry Standard good forest practice. We would be very concerned if all woodlands were deemed as meeting the UK Forestry Standard purely on the legal compliance minimum, allowing a simple greenwash that every woodland in the UK is managed sustainably. This may enable UK Government in international reporting of legality and sustainability to increase the area reported, but may actually result in no practical improvement in the sustainability of the UK s forests and woodlands. This highlights problems with such a crude risk based approach to setting forest management standards, auditing and international reporting (page 21, paragraph 98). We are not convinced of the wisdom for CPET Category B driving forest 8 See: 9 See: 10 See: 11 See: & 12 See: & 4

5 management in the UK, and reducing the rigour of the UK Forestry Standard, and hence potentially reducing the ambition, rigour and positive impact of The Government s approach to sustainable forest management. For monitoring UK Woodland Assurance Standard compliance, how will Forestry Commission or Forest Service plan to monitor minor and major non-compliance will they contact auditors? (page 21, paragraph 98). Requirements Tables (pages 23-33) Comments: 1. We are unhappy with the reduction in sustainable forest management requirements in the UK Forestry Standard by the introduction of two categories legal Requirement & Requirement of Good Forestry Practice. It also is no longer clear what meeting the UK Forestry Standard means. 2. An assessment needs to be done how these requirements connect with UKWAS requirements. This mapping needs to be explained and issued with subsequent consultation for this UKFS revision. 3. Requirements need numbering to allow them to be quoted by regulators. 4. Requirements need to be worded according to ISO convention, in relation to should & shall. 5. General Forestry Aspects & Legal Conformity - reasonable measures needs more careful wording to be legally appropriate. 6. Forest Design & Planning we welcome this Forestry Aspect, but note that it only covers felling and thinning. Management planning should cover planting and all management. The forest plan is mentioned current FC & FS guidance 13 only relates to large-scale upland forests, rather than a range of woodland types and contexts. It is not generally used by state forestry, which relies in GB of its own internal guidance 14 and meeting the UKWAS. UKFS guidance will need to be relevant to different countries in UK which have developed management planning in a range of ways, tied into grant mechanisms. The Guidance under UKWAS Requirement provides a useful approach to defining appropriate management planning Forests & Biodiversity this lacks sufficient rigour on location of new planting in relation to protecting biodiversity. We are also extremely disappointed that there may be a push for a legal minimum approach to sustainable forest management, with no drive to enhance biodiversity to meet country, UK, EU or international biodiversity commitments. The devolved Forestry Commissions and Forest Service have a range of legal duties related to biodiversity, for example for FC England and FC Wales duties under Section 40 of the Natural Environment & Rural Communities Act 2006 (and FC England s Public Service Agreement targets), Forestry Commission Scotland s duty under Section 1 of the Nature Conservation (Scotland) Act 2004, as well as the biodiversity duties for FC across GB under Section 1 of the Forestry Act 1967 (as amended). We would like to further consider the detailed requirements and their effectiveness in discussion with the Forestry Commission, Forest Service, Countryside Agencies and other stakeholders. Layout issues The detailed requirements of the standard do not commence until page 19. The content of the first 18 pages should be cut down, by splitting this material into an introduction and the remainder, such as background on the international context, moved to an appendix. 13 Bell, S. (1998) Forest Design Planning a guide to good practice. FPG1. Forestry Commission, Edinburgh & Forest Service NI. See: 14 Forestry Commission (2007) Operational Guidance Booklet See: 5

6 Comments on the Biodiversity Guidelines & other Guidelines We will send additional comments on these Guidelines, probably once there is more clarity on the content and operation of the proposed UK Forestry Standard. Mike Wood UK Forestry Policy Officer 31 January The RSPB is the UK charity working to secure a healthy environment for birds and all wildlife, helping to create a better world for everyone. Our UK forestry policy work includes advocating changes to country and regional policy, providing advice on conservation management to woodland owners and managers, and undertaking research into birds and other biodiversity affected by forestry practices. For more information see: The RSPB owns and manages about 8,800 hectares of UK Woodland Assurance Standard (UKWAS)/Forest Stewardship Council (FSC) certified woodland (SA-FM/COC-1349). This includes areas of plantation forestry undergoing restoration to lowland heathland and blanket bog, meeting UKWAS and FSC requirements. Registered Charity England and Wales no ; Scotland no. SCO