Scottish Forestry Grants Scheme review: Consultation questions.

Scottish Forestry Grants Scheme review: Consultation questions. Use this document to provide your answers to the questions contained in the consultation document. Please use as much space as you require for your answer. Once you have completed your response, send or email it to: Douglas Wright Forestry Commission Scotland 231 Corstorphine Road Edinburgh EH12 7AT Email: douglas.wright@forestry.gsi.gov.uk Responses are invited by 27 June 2006 but you are encouraged to respond earlier if possible. 1

Consultation of the proposed changes to the Scottish Forestry Grants Scheme (SFGS), April 2006 1 Response by the Royal Society for the Protection of Birds Scotland 2, June 2006 Summary RSPB Scotland welcomes the opportunity to comment on these proposals to revise the Scottish Forestry Grants Scheme (SFGS). Forestry Commission Scotland and the Scottish Executive must ensure that the key positive environmental aspects of the existing SFGS are transferred into the new scheme, namely the environmental checks on location, design and management, combined with the funding of targeted work for priority biodiversity. We would like to see increased uptake of the new scheme for targeted work in high biodiversity value woodlands, both native woods and plantations, ensuring that this meets the UK Forestry Standard. The priority for LMC Tier 2 and 3 measures for woodland planting, restocking and management must be for the provision of public benefits, in particular biodiversity. 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 nonwoodland priority species and habitats targets impacted by forestry. This includes improving the biodiversity condition of Scotland s native woods to meet UK Biodiversity Action Plan (UKBAP) targets and designated site condition - restoring important open ground habitats, such as blanket bog, that is currently non-native plantation forestry or neighbouring designated non-woodland sites aversely impacted by it. The SRDP/SFGS must support restructuring of key existing forestry plantations for priority species, such as capercaillie and black grouse. There must also be support for the restoration of ancient woodland sites currently planted with non-native forestry plantations. The current Scottish Forestry Grant Sceheme (SFGS) includes eligibility and targeting criteria for priority biodiversity such as UKBAP non-woodland and woodland priority habitats and species criteria in Stewardship Grant S4 and its targeting FCS Guidance Note 30 and environmental good practice contained in the existing SFGS Specifications (these give operational guidance on how to implement the UK Forestry Standard). The RSPB believes the existing SFGS eligibility criteria and good practice requirements must remain, and be included across all Tier 2 and Tier 3 woodland planting, restocking and management 3. The RSPB believes 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. This will allow the SRDP to comply with the RDR. 1 http://www.forestry.gov.uk/forestry/infd-6p3m99 & http://www.forestry.gov.uk/pdf/revisedsfgsconsultation1.pdf/$file/revisedsfgsconsultation1.pdf 2 Mike Wood, UK Forestry Policy Officer, RSPB Dunedin House, 25 Ravelston Terrace, Edinburgh EH4 3TP. Tel: 0131 311 6500; E-mail: mike.wood@rspb.org.uk 3 Tier 2 Measures: Investment in Holdings Access for sustainable forest management 3 Woodland creation Small scale woodland creation <1 hectare Tier 3 Measures: Maintaining Landscape Character Tree protection & management in a designed landscapes, Screening farm & forestry structures ; Management of Woodland & Scrub Management of ancient wood pasture, Forest Environment Payments, Woodland improvement, Woodland restructuring ; Woodland Creation Woodland creation >1 hectare. 2

Principles (page 4) needs to include: Scottish Biodiversity Strategy including the Scottish Biodiversity List, and the Scottish Executive s 2002 World Summit on Sustainable Development commitment to increasing UK Woodland Assurance Standard forest certification. The RSPB works for a healthy environment rich in birds and wildlife. We have considerable experience of informing forestry policies and practices in Scotland, the UK and Europe. Our forestry related work includes advocating changes to government policies, providing advice on conservation management to forest owners and managers, and undertaking research into birds and other biodiversity affected by forestry practice. We own and manage about 9,000 hectares of woodland across the UK, over 60% of which is in Scotland. Our woodland estate is UK Woodland Assurance Standard (UKWAS) certified. Q1. Do you agree with the principle that the creation of small woodlands should be supported in this way? No - the RSPB is concerned about the environmental standards required for small woodland creation, and the biodiversity value of the woodlands that will be created. a) The RSPB believes 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. This will allow the SRDP/SFGS to comply with the RDR. The 2007-13 EC Rural Development Regulation requires the sustainable use of forestry land under Article 36b, in accordance with the Ministerial Conference for Protection of Forests in Europe (MCPFE) agreements (see RDR para 32, p4), which includes the Helsinki Principles of sustainable forest management. The UK implemented the 1993 MCPFE Helsinki Principles via the 1998/2004 UK Forestry Standard. In the existing Scottish Forestry Grants Scheme, including Farmland Premium, woodland creation and management was funded upon a woodland definition of >0.25 hectare and 13metres wide (and in the previous Woodland Grant Scheme and Farm Woodland Premium Scheme). Such grant aided work and felling permissions was required by the Forestry Commission to meet the UK Forestry Standard. The LMC proposals removes the UK Forestry Standard from all woodland creation, both from >0.25 to <1 hectare under Tier 2, (Woodland creation Small scale woodland creation <1 hectare ), and Tier 3 woodland creation >1 hectare. The UK Forestry Standard is also not required for management or restocking under Tier 2. This is an undesirable reduction in the environmental regulation of woodland planting and management. It could result in the creation of woodland of low intrinsic biodiversity value, or poorly located planting on non-woodland habitats of high biodiversity value, neither of which meet Scotland s biodiversity or sustainable forest management commitments: in the Scottish Biodiversity Strategy & its Scottish List of priority habitats and species; for UK Biodiversity Action Plan priority habitats including upland heathland, blanket and raised bogs - and species; in respect to the EU Gothenburg 2010 biodiversity target (an RDR objective); for EU priority species and habitats under the EU Birds and Habitats Directives; & sustainable forestry commitments under the Ministerial Conference for Protection of Forests in Europe (an RDR objective). Such woodland planting and management would also contradict SEERAD and Forestry Commission Scotland s duty to further biodiversity under the 2004 Nature Conservation (Scotland) Act. 3

b) Woodland creation funded under the SRDP must meet UK Biodiversity Action Plan native woodland Habitat Action Plan targets. The creation of poorly located, small, isolated woods can have little or no biodiversity merit. Afforestation of non-agricultural land could be detrimental to biodiversity, for example high quality moorland planted using the SRDP Tier 2 woodland creation measure (<1 hectare). Apart from direct loss and damage of priority habitat, the resultant woodland could be of low biodiversity value due to its small size, isolation and inappropriate tree species. Under current proposals, the UK Forestry Standard s environmental checks and balances on the location, design and specification of woodland planting wouldn t be applied to such situations, and all other Tier 2 measures (as well as excluded from some Tier 3 measures). For afforestation of non-agricultural land, the landowner may not be in receipt of Single Farm Payment under Tier 1, so Good Agricultural and Environmental Condition would not apply and neither would the UK Forestry Standard. The Tier 2 Woodland Creation measure is for providing benefits for habitats and species. Q2. Is the system of support for these woodlands a good compromise between simplicity and the need to adjust rates to reflect different circumstances? No comment. Q3. Do these models and rates adequately reflect the range of situations likely to be encountered? No comment. 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? Yes - the Forest Plan proposal is helpful, but doesn t mention UK Woodland Assurance Standard (UKWAS), merely the UK Forestry Standard. UK Forestry Standard is an environmental minimum, not gold-plating - Forest Plans need to build on this bare minimum, getting woods towards UK Woodland Assurance Standard (UKWAS) certification. UKWAS requires compliance with the UK Forestry Standard, and is independently verified. The UK Government and Scottish Executive have international commitments on sustainable forest management in relation to the UK Forestry Standard 4, and the increased uptake of the UKWAS in Scotland 5. The RSPB believes 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. This will allow the SRDP/SFGS to comply with the RDR in respect to implementing MCPFE agreements We welcome the proposed Management Management Planning & Monitoring activity, and the Independent certification WIG operation these are useful steps to bring about sustainable forest management to UKWAS, particularly for high biodiversity value woodland. The Independent certification 4 UKFS implements MCPFE Helsinki Principles. MCPFE agreements are in the 2007-13 Rural Development Regulation Straegic Guidelines. Increasing UKWAS uptake is a Scottish Executive commitment at the 2002 World Summit on Sustainable Development. 5 Increasing UKWAS uptake is a Scottish Executive commitment at the 2002 World Summit on Sustainable Development, see: www.ukforestpartnership.org.uk 4

operation needs to be to UKWAS. Ecological survey and management planning towards UKWAS needs to be available across Tier 2 and 3 woodland management, not just in Tier 3 SFGS 2. FCS in association with FC England, Wales and Forest Service NI and the UKWAS Steering Group needs to address issues of UKWAS accessibility for small woods. The current guidance on Forest Plans Forestry Practice Guide 12 - Forest Design Planning - needs revising to ensure managers of state, public and private woodlands of all scales, types and locations receive clear guidance on forest plan preparation, implementation and monitoring. Q5. Do you have any views on the appropriate level of detail that should be included in a Forest Plan? Yes make sure that clear management planning guidance towards UK Woodland Assurance Standard (UKWAS) certification is made available to woodland managers in receipt of Tier 2 and 3 woodland creation, improvement and restocking grants, backed up by advice from FCS Woodland Officers. We welcome the proposed Management Management Planning & Monitoring activity, and the Independent certification WIG operation these are useful steps to bring about sustainable forest management to UKWAS, particularly for high biodiversity value woodland. The Independent certification operation needs to be to UKWAS. Ecological survey and management planning towards UKWAS needs to be available across Tier 2 and 3 woodland management, not just in Tier 3 SFGS 2. We recommend that FCS Forest Plan guidance follows the guidance in Section 2 of new UK Woodland Assurance Standard 6 (Guidance Column of Sub-sections 2.1.1 & 2.1.3). This advises on appropriate approaches for management plan objective setting, survey, drafting, implementation and monitoring, rather than requiring the use of a rigid pro-forma. It ties in with UK Forestry Standard management planning guidance. We suggest that Scotland doesn t follow Wales and England by having an overly prescriptive management plan format, but uses this UKWAS Section 2 guidance to define and fund acceptable management planning. Consistency of FC forest planning guidance across state and private sector would be relevant for priority species and habitats. Forestry Commission Scotland forest planning guidance must be consistent across state and private sectors. Forestry Practice Guide 12 7 requires revision, to meet new SFGS Forest Plan needs, but also to connect with the revision of state forest guidance FMM30 8, which is also currently under review. New SFGS funded Forest Plans need to assist to 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? No comment. Q7. Do you agree with the introduction of Forest Environment Payments (FEP) and do you have any comments on the activities to be supported by the proposed FEP? 6 http://www.ukwas.org.uk/assets/documents/ukwas_substantive_changes_since_february_2005.pdf & 7 Forestry Authority (1998) Forest Design Planning a guide to good practice. Forestry Practice Guide 12. Forestry Commission, Edinburgh. 8 Forestry Commission (undated) FMM 3- - Forest Design Planning. Forestry Commission, Edinburgh. 5

Yes, Forest Environment Payments (FEPs) must be for targeted work for priority biodiversity the current proposals do not fully meet this. We are concerned that High Nature Forestry Systems have not been defined the proposed criteria for Forest Environment Payments are incomplete. FEPs must be for targeted work for non-woodland as well as woodland priority species and habitats. Forest Environment Payments must targeted for High Nature Value Forestry Systems, which should be 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 2) forest systems and operations that are used to protect and enhance these features and areas. Such a definition of High Nature Value Forestry Systems should be used as eligibility criteria to target Forest Environment Payments for clear biodiversity priorities. We welcome the proposal that Forest Environment Payments are tied in with an approved Forest Plan, but this plan must be to UKWAS. Q8. Do you support the principle of restructuring WIG and do you have any comments on the proposed rates? No - The priority for LMC Tier 2 and 3 measures, including a restructuring WIG, must be for the provision of public benefits, in particular biodiversity. We are not convinced that these proposals, for effectively a restocking grant, fully meet this. The SRDP/SFGS must not be used to fund the replanting/restructuring of commercial plantation forestry that does not produce enhanced public benefits. We welcome the proposal that the restructuring WIG is tied in with an approved Forest Plan, but this plan must be to UKWAS. Q9. Do you have any comments on the list of proposed WIGs? Yes - new WIGs required: UKBAP priority habitats and species WIG (transplanting SFGS S4 in full). Capercaillie WIG - targeted at key capercaillie areas via the BAP Group, and including a prescription for small scale felling and thinning, particularly in inaccessible areas. Black grouse WIG using targeting from SFGS Guidance Note 30. Open ground habitat WIG. Criteria for prioritising open-ground sites & habitats for restoration need to be developed and should include: 1. Listed as a UK Biodiversity Action Plan priority open-ground habitat with restoration targets; 6

2. Direct benefit to Scottish Biodiversity List species and habitats, UK BAP priority species, or be a key UK Biodiversity Action Plan (UK BAP) or Priority/Annex 1 habitats under the EU Habitats Directive; 3. Will enhance the biological condition of designated sites, and adjacent areas 9 SSSI, NNR, SAC, SPA, Ramsar; 4. Restoration potential presence of key remnant features, and technical ability to improve condition; 5. Scale of restoration must be adequate and produce viable habitat linkages to existing areas/networks of target habitats. We support the list of operations under Biodiversity activity in Table 2 (page 15). We d like to see grass mowing encompass heather mowing, or have a separate heather management/mowing WIG operation under the Biodiversity activity. All the current funded operations and eligibility criteria of SFGS Stewardship grant S4 need to be in a new WIG including operations that were in SFGS S4, but are now missing from the Table 2 proposals, such as hanging watergates and dyke upgrade (SFGS activities 71, & 72 & 73). We support the Management Planning & Monitoring activity, in particular the HAPs & SAPs Management Plan for UK Biodiversity Action Plan priority species and habitats. We support the Pre-commercial tree removal, Small scale felling & thinning, Re-spacing natural regeneration and Independent certification operations under the Improving economic performance activity, as operations that could produce biodiversity benefit. Independent certification needs to be to UKWAS. Q10. Do you agree with the principle that Forest Plans should become a prerequisite for access to WIGs in the future? Yes, but Forest Plans must meet the UK Woodland Assurance Standard, as well as the UK Forestry Standard. 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? Yes the RSPB is concerned that the integration of forestry into LMCs will result in a reduction in the environmental standards of woodland planting and management funded. The 2007-13 EC Rural Development Regulation requires the sustainable use of forestry land under Article 36b, in accordance with the Ministerial Conference for Protection of Forests in Europe (MCPFE) agreements (see RDR para 32, p4), which includes the Helsinki Principles of sustainable forest management. The UK implemented the 1993 MCPFE Helsinki Principles via the 1998/2004 UK Forestry Standard. In the existing Scottish Forestry Grants Scheme, including Farmland Premium, woodland creation and management was funded upon a woodland definition of >0.25 hectare and 13metres wide (and in the previous Woodland Grant Scheme and Farm Woodland Premium Scheme). Such grant aided work and felling permissions was required by the Forestry Commission to meet the UK Forestry Standard. The LMC proposals remove the UK Forestry Standard from all woodland creation, both from >0.25 to <1 hectare under Tier 2, (Woodland creation Small scale woodland creation <1 hectare ), and Tier 3 woodland 9 This includes for woodland & non-woodland designated sites, species & habitats; such as improving botanical SACs & SSSIs that are surrounded by forestry, e.g. by pulling back forest edges to expand species rich grassland. 7

creation >1 hectare. The UK Forestry Standard is also not required for management or restocking under Tier 2. The RSPB believes 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. This will allow the SRDP to comply with the RDR. This includes: Tier 2 Measures: Investment in Holdings Access for sustainable forest management 10 Woodland creation Small scale woodland creation <1 hectare Tier 3 Measures: Maintaining Landscape Character Tree protection & management in a designed landscapes, Screening farm & forestry structures ; Management of Woodland & Scrub Management of ancient wood pasture, Forest Environment Payments #, Woodland improvement #, Woodland restructuring #; Woodland Creation Woodland creation >1 hectare. # the only Tier 2 & 3 measures currently proposed to require UK Forestry Standard compliance. This is an undesirable reduction in the environmental regulation of woodland planting and management. It could result in the creation of woodland of low intrinsic biodiversity value, or poorly located planting on non-woodland habitats of high biodiversity value, neither of which meet Scotland s biodiversity or sustainable forest management commitments: in the Scottish Biodiversity Strategy & its Scottish List of priority habitats and species; for UK Biodiversity Action Plan priority habitats including upland heathland, blanket and raised bogs - and species; in respect to the EU Gothenburg 2010 biodiversity target (an RDR objective); for EU priority species and habitats under the EU Birds and Habitats Directives; & sustainable forestry commitments under the Ministerial Conference for Protection of Forests in Europe (an RDR objective). Such woodland planting and management would also contradict SEERAD and Forestry Commission Scotland s duty to further biodiversity under the 2004 Nature Conservation (Scotland) Act. Afforestation of non-agricultural land could be detrimental to biodiversity, for example high quality moorland planted using the SRDP Tier 2 woodland creation measure (<1 hectare). Apart from direct loss and damage of priority habitat, the resultant woodland could be of low biodiversity value due to its small size, isolation and inappropriate tree species. Under current proposals, the UK Forestry Standard s environmental checks and balances on the location, design and specification of woodland planting wouldn t be applied to such situations, and all other Tier 2 measures (as well as excluded from some Tier 3 measures identified above). For afforestation of non-agricultural land, the landowner may not be in receipt of Single Farm Payment under Tier 1, so Good Agricultural and Environmental Condition would not apply and neither would the UK Forestry Standard. The Tier 2 Woodland Creation measure is for providing benefits for habitats and species. The current SFGS includes eligibility and targeting criteria for priority biodiversity which need to continue in the new scheme such as UKBAP non-woodland and woodland priority habitats and species criteria in Stewardship Grant S4 and its targeting FCS Guidance Note 30 and environmental good practice contained in the existing SFGS Specifications (these give operational guidance on how to implement the UK Forestry 10 NB The UK Forestry Standard and associated Forestry Commission guidance covers the location and construction on roading, including soil conservation, water quality, landscape and biodiversity loss and disturbance considerations. 8

Standard). The RSPB believes such eligibility criteria and good practice requirements must remain, and be included across all Tier 2 and Tier 3 woodland planting, restocking and management 11. The priority for LMC Tier 2 and 3 measures for woodland planting, restocking and management must be for the provision of public benefits, in particular biodiversity. 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 nonwoodland priority species and habitats targets impacted by forestry. This includes improving the biodiversity condition of Scotland s native woods to meet UK Biodiversity Action Plan targets and designated site condition - restoring important open ground habitats, such as blanket bog, that is currently non-native plantation forestry or neighbouring designated non-woodland sites aversely impacted by it. The SRDP must support restructuring of key existing forestry plantations for priority species, such as capercaillie and black grouse. There must support the restoration of ancient woodland sites currently planted with non-native forestry plantations. Below are our comments for the Scottish Rural Development Plan (SRDP) consultation, in relation to woodland capital works. There needs to be consistency of environmental standards and targeting across all Tier 2 and 3 woodland creation, improvement and management grants. This requires an integrated approach to the design and operation of woodland elements of Land Management Contracts, both by SEERAD and by FCS. This must mean that the UK Forestry Standard, and targeted work for priority species and habitats is fully, and evenly applied across LMCs. Comments on proposed Capital Grants in Annex G of the SRDP Capital Item Concerns 9 Deadwood management This needs to be done in accordance with the UK Forestry Standard and Forestry Commission deadwood guidance to ensure the creation of high biodiversity quality deadwood management, not very low biodiversity value log piles. 15 Deer Fence 16 Deer Fence marked to reduce bird collision orange barrier netting. It is unclear how this differs from Capital Item 19. 11 Tier 2 Measures: Investment in Holdings Access for sustainable forest management 11 Woodland creation Small scale woodland creation <1 hectare Tier 3 Measures: Maintaining Landscape Character Tree protection & management in a designed landscapes, Screening farm & forestry structures ; Management of Woodland & Scrub Management of ancient wood pasture, Forest Environment Payments, Woodland improvement, Woodland restructuring ; Woodland Creation Woodland creation >1 hectare. 9

17 Deer Fence marked to reduce bird collision wooden droppers. 18 Deer Fence marked to reduce bird collision chestnut palling. 19 Deer Fence marked to reduce bird collision orange barrier netting. It is unclear how this differs from Capital Item 20. It is unclear how this differs from Capital Item 16. 20 - Deer Fence marked to reduce bird collision wooden droppers. 22 Dismantling deer fences It is unclear how this differs from Capital Item 17. This Capital Item must be used to remove fencing in high bird-strike risk areas for capercaillie and black grouse. If targeted in this way we would welcome this item. Missing Capital Grants in Annex G of the SRDP Missing Capital Purpose & operation Items Forest removal for priority habitat restoration To restore priority open ground habitats, such as active raised and blanket bogs, that are currently covered with plantation forestry. Criteria for prioritising open-ground sites & habitats for restoration need to be developed and should include: 10

a. Listed as a UK Biodiversity Action Plan priority open-ground habitat with restoration targets; b. Direct benefit to Scottish Biodiversity List species and habitats, UK BAP priority species, or be a key UK Biodiversity Action Plan (UK BAP) or Priority/Annex 1 habitats under the EU Habitats Directive; c. Will enhance the biological condition of designated sites, and adjacent areas 12 SSSI, NNR, SAC, SPA, Ramsar; d. Restoration potential presence of key remnant features, and technical ability to improve condition; e. Scale of restoration must be adequate and produce viable habitat linkages to existing areas/networks of target habitats Q12. Do you agree that top up mechanisms should be used to deliver extra support for particular activities? Yes, but only for genuine public benefits, such as the targeted delivery of priority biodiversity. Q13. Do you have views on which woodland types and/or geographic locations should be highest priorities for extra support through the top up mechanism? Yes: restructuring of plantation forestry for priority biodiversity, such as black grouse and caperciallie; 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. Q14. Do you have views on this, or other, mechanism for supporting community groups? No comment. 12 This includes for woodland & non-woodland designated sites, species & habitats; such as improving botanical SACs & SSSIs that are surrounded by forestry, e.g. by pulling back forest edges to expand species rich grassland. 11