Written evidence submitted by The Forestry Commission (PLD0011)

EXECUTIVE SUMMARY

Evidence is submitted by the Forestry Commission, on behalf of Forestry England, Forest Services and Forest Research, focusing on the interaction between woodlands and peat. The key points to note are:

•      Government’s ambitions both for woodland creation and peatland restoration are bold and challenging. Meeting these ambitions will require difficult decisions to be made about land use and land use change. It is important that the strategic approach to peatland restoration does not unnecessarily restrict woodland creation, and does not make achieving government’s ambitions even more challenging by encouraging woodland removal except where clearly justified by the evidence.

• Forestry Commission is working closely with Defra and Natural England to ensure that the ambitions of the England Peat Strategy and of the forthcoming England Tree Strategy are aligned.
• Afforested peats emit carbon as a result of the trees drying out the peat; however, the level of net emissions is uncertain making it difficult to establish a framework for deciding when, from a greenhouse gas emissions perspective, peatland restoration or continued woodland cover should be the preferred option. Decisions on land use change should be informed by natural capital principles and scientific evidence, which FC is working with Natural England to strengthen.
• A robust regulatory framework for woodland creation does not allow new planting on deep peat.
• Approximately 25,000 hectares of productive conifer forest remains planted on deep peat, representing a significant proportion of England’s softwood timber resource.
• An active programme of peatland restoration and management is underway on the Public Forest Estate, with 7,596 ha of priority deep peat habitat[1] currently managed by Forestry England.
• Evidence is emerging that when forest is retained on deep peat, different approaches to management can reduce emissions.
• Some shallow peat is degraded, does not support priority habitat and is not capable of restoration because of the wider hydrology of the area; this represents a resource of agriculturally unproductive land that could be used for meeting Government’s challenging woodland expansion aspirations.

INTRODUCTION

The Forestry Commission[2] (FC) is the non-ministerial Government department responsible for advising on and implementing forestry policy in England. It is accountable to the Secretary of State for Environment, Food and Rural Affairs.

The Forestry Commission manages the 250,000 hectare Public Forest Estate through its agency Forestry England[3], administers grants for expanding and managing forests, and regulates tree felling and Environmental Impact Assessment for forestry activities. It also provides advice to Ministers, undertakes and commissions research through its agency Forest Research[4], sets standards for good forestry practice, underpinned by the UK Forestry Standard (UKFS)[5], and is responsible for protecting England’s forests and woodlands from pests and disease.

1. What is the current state of peatlands in England, and how is it changing?

1.1 Analysis[6] by the Forestry Commission and Natural England, based on the 2012 National Forest Inventory,[7] showed that in England 51,447 ha of woodland is on deep peat (peat soils more than 50 cm in depth) out of a total deep peat area (excluding lowland fens and reed beds) of 391,000 ha[8]; 60% of the afforested deep peat is productive conifer plantation, with the remainder native, naturally colonised, broadleaf woodland. 42% of woodland on deep peat was within the Public Forest Estate and 18 % was on Sites of Special Scientific Interest (SSSIs) designated for either priority habitat or species interest. The analysis also identified that 20,152 ha of the afforested peat resource would, if restored, extend or buffer high quality habitat. Restoration of some or all of this peatland would represent an important contribution to the 25 Year Environment Plan peat restoration target, but would make achieving woodland cover aspirations harder.

1.2 In 2016, of the 20,500 hectares of afforested deep peat on the Public Forest Estate, 3,700 ha was on or adjacent to SSSIs, of which 2,000 ha is of low productivity class and would be expected to be restored to peatland habitat over time; much of the low productivity forest had already been restored. The majority of the afforested deep peat resource on the PFE is isolated from SSSIs with 73% of this defined as moderately or highly productive; were this to be restored, England’s softwood timber supply would reduce by of the order of 25%   

1.3 Government has high ambitions for both peatland restoration and woodland creation. The 25 Year Environment Plan contains a number of commitments around peat including a ‘new ambitious framework for peat restoration in England’, and also includes an aspiration to increase woodland cover from the current 10% to 12% of England by 2060. The 2017 Clean Growth Strategy committed £10 million for capital works to help restore peatlands, while the Committee on Climate Change’s advice to Government on achieving net-zero[9] recommended that 180,000 ha of peatland was restored in England.

1.4 The well-established framework of the UK Forestry Standard and Environmental Impact Assessment (EIA) Regulations[10] ensures that there is no new woodland planting on deep peat.

1.5 However where woodlands already exist on deep peat and are harvested, the decision needs to be taken as to whether to restore the peatland to open ground habitat or to restock. In some cases, this can lead to a conflict between nature conservation and timber production (and woodland retention) objectives for the site. The UK Forestry Standard articulates this process as: “The decision to restock forests on deep peat should be carefully considered, taking into account the balance of benefits for carbon and other ecosystem services.”

1.6 From a peatland conservation perspective this is an important choice moment. A large proportion of the peatland forest in this country was planted in the 1950s to 1980s and much of this is reaching the end of its first rotation, a time when they are due to be harvested. An alternative view is that woodland on deep peat is a small proportion of the overall peat resource (7.5% of the deep peat resource) and the focus should be on restoring other, non-forested areas to avoid compromising net woodland cover targets or the very significant contribution that forests on peat make to the feedstock for the domestic timber processing sector (see para 4.4).

1.7 The Open Habitats Policy[11], which was established in 2010 and adopted as a delivery mechanism for Biodiversity 2020[12], recognises the importance of all previously semi-natural open habitats currently under woodland and seeks to balance their restoration with the policy aims of increasing forest cover and maintaining domestic supplies of sustainable timber. The policy uses criteria to define when it is appropriate to remove woodland, and when it is appropriate, whether or not compensatory planting is required. The policy adjusts compensatory planting requirement depending on the overall level of afforestation. Due to recent low level of net afforestation in England, with a net 556 ha decrease in woodland cover in 2015/16 and an increase of only 318 ha in 2016/17[13], the Forestry Commission requires compensatory woodland planting for all woodland removal for open habitat creation except that on statutorily designated sites.

1.8 Government has manifesto and 25 Year Environment Plan[14] commitments to plant 11 million trees in England by 2022 and an additional 1 million in towns and cities. The Clean Growth Strategy[15] and 25 Year Environment Plans also include an aspiration to increase woodland cover from the current 10% to 12% of England by 2060, equivalent to an average net increase in woodland area of nearly 7,000 ha/yr over this period.

1.9 Shallow peat soils, outside of priority habitat, represent a source of agriculturally unproductive land that could be used for meeting Government’s challenging woodland expansion aspirations; the proposed Nature Recovery Network provides a framework for establishing the most appropriate use of such land, adopting a natural capital approach

2. What is the potential contribution of peatland restoration to the UK’s net zero greenhouse gas target, and the consequence of inaction?

2.1 Both peatlands and woodland contain large stocks of carbon, and active bogs and actively growing woodlands sequester (i.e. take-up) carbon. The carbon stock in deep peat soils is generally larger than that in mature forests, but the carbon uptake rate of productive forest is substantially higher than peatlands[16]. Afforestation of peatbogs has usually required drainage to allow tree growth, but drainage usually leads to carbon loss from the soil. However, lower water tables reduce the methane emissions normally occurring in wet, functioning peatbogs. The net balance of these processes is not well characterised for the range of woodlands on peat. A recent report[17] setting out the evidence to support a UK peatland GHG inventory concluded that “both the area estimates and emissions factors associated with afforested peatlands are uncertain, and cannot take into account factors such as the age of forest, differences between tree species or forest management practices”.  The report estimated that peat under forestry contributed 6% of the total annual emissions from peat for England, but noted that the calculation did not take into account the carbon uptake by the trees, or the greenhouse gas benefits from using timber or other wood products to substitute for fossil-fuel intensive materials or energy. A particular challenge in establishing the rate of emissions from afforested peat is separating CO2 emissions from degradation of the peat from emissions arising from tree root respiration and leaf/root decomposition and published emissions factors[18] do not always state whether such sources of emissions have been excluded. 

2.2 If afforested deep peat is restored successfully, the carbon loss from the peat will be reduced, but the carbon benefits of growing trees will also be lost. The balance of the net contribution of these two opposite effects on depends on the productivity of the woodland, the end use of the wood harvested and the likelihood of successful restoration of a functioning peatbog. However, an explicit framework for compensatory planting would ensure that the carbon benefits of continuing forestry are not lost, while irreplaceable peatland habitats are retained.   

2.3 As a general guide, productive forest (Yield Class[19] 8-10 and above, typical of much of Kielder forest) on peat is likely to prove highly challenging to restore to high quality peatland habitat while the carbon benefits of restoring the peat are likely to be outweighed by the abatement opportunities provided by retention of productive forest. In contrast, poorly performing plantations are more likely to restore to high quality habitat and to deliver carbon abatement. The UK Forestry Standard therefore states that “The decision to restock forests on deep peat should be carefully considered, taking into account the balance of benefits for carbon and other ecosystem services.”

2.4 Evidence is emerging[20] that carbon stocks of afforested peat do not decline as rapidly as earlier research suggested, partly because the bulk density of peat under forest stands is higher than open bog (i.e. the forest has in effect compacted the peat). Furthermore, over the second rotation, soil carbon stocks may increase as a result of litter input to the soils, although this would not be as a result of peat accretion. 

2.5 If the decision is taken to restock afforested deep peat evidence20 is emerging that improved management can help to stabilise the peat and reduce rates of decomposition/degradation. Potential management measures include (1) not reinstating forest drains for the second rotation or modifying the drainage network so that it complies with the UKFS’s Forests and Water Guidelines; (2) planting into existing plough-ridges and avoiding further soil disturbance, and; (3) removing above-ground harvesting residues to reduce subsequent rates of soil mineralisation.

2.6 It is very likely that moderate and high productivity forests planted or restocked on shallower peat soils, with limited disturbance, will provide an overall net carbon uptake over one or more rotations. As trees grow, there is net uptake of CO2 with some carbon transferred into the soil through leaf and root litter. However, it is essential that soil disturbance at establishment is minimised. The Woodland Carbon Code provides look-up tables[21] to estimate carbon emissions associated with different cultivation methods for different soil types, highlighting how important this aspect is.

2.7 Climate change may affect the long-term integrity of much of England’s peatlands,[22],[23] although peatland carbon is likely to be retained for longer on sites that have been restored. However, the long-term potential for the site and impacts of climate change on the productivity of the forest are material considerations when deciding whether to restore or restock; the evidence is not clear and requires addressing as a matter of urgency.

2.8 The evidence base needs improving to support robust decision-making over future land use change involving trees and peat, including: (1) the likely impacts of climate change on afforested peatlands, with and without tree cover; (2) agreed life-cycle carbon assessments including future uses of harvested timber; (3) robust GHG emissions factors for afforested deep peat; (4) a comprehensive assessment of productivity of afforested peat outside the Public Forest Estate to help prioritise restoration programmes, and; (5) an understanding of how sequential tree rotations may affect the likelihood of successful peat restoration over time. 

3. What are the other economic, ecological and cultural benefits of restoring and maintaining peatlands?

n/a

4. What are the costs of peatland restoration, and what wider societal and economic adaptations might it require?

4.1 While the retention of forests on peat is likely to generate net forestry income, restoration to open habitat and subsequent management will represent a net cost beyond the initial capital works. If there is no long term plan for financial support, there is a high chance that such sites will revert to scrub or woodland, potentially dominated by invasive species.

4.2 Forestry England has experience of peatland restoration from an afforested landscape through the Border Mires project in Kielder forest. The total area of bog restored over the past 30 years has been 1,158 hectares, including 361 hectares of woodland removal. The total cost of restoration has been £5,100/ha, broken down as: £3,000/ha for mulching; £2,000/ha for grip-blocking and; £100/ha for administration/contract management. Ongoing, annualised, management costs for the removal of natural regeneration amounts to £100/ha.

4.3 Kielder forest and other woodland in the Border Uplands represents the greatest opportunity for peatland restoration, but the impact of the loss of productive woodland, in the absence of compensatory planting, on England’s timber processing sector and wider natural capital should be considered as a cost in any cost:benefit analysis.

4.4 The 1967 Forestry Act[24] charges the Forestry Commissioners with the production and supply of timber and other forest products. The majority of Kielder Forest is highly productive with an average yield class of 12-14 m3/ha/yr Extensive peatland restoration in Kielder would impact significantly on the long term national timber supply and the local economy. 500,000 m3 of timber is harvested annually from Kielder forest, around 50% of Forestry England’s softwood production and 25% of total softwood production in England[25]. £25 million/yr income is generated to reinvest into public benefit on the Public Forest Estate. The economic activity is also a significant employer and driver of the local and regional economy through harvesting, haulage, processing and marketing and GVA has been estimated as up to £2billion/yr.

4.5 Kielder Forest Park also attracts 426,000 visitor days/yr, hosts more than 600 events, results in £25m visitor spend in the local economy and supports/safeguards 470 jobs[26]. The contribution of Kielder Forest to wildlife conservation should also be recognised, hosting England’s most resilient Red squirrel stronghold, England’s largest breeding population of Hen harriers and six successful osprey breeding sites. Each year, an ongoing restructuring programme provides 100 ha new open ground habitat (peatland) and 100 ha new riparian/native broadleaved woodland.

5. What should be included in the forthcoming England Peatland Strategy?

5.1 The Strategy could include an acknowledgement of Government’s ambitions to both increase net woodland cover and increase priority habitat, including restoration of peatlands. It should acknowledge the existing framework of the UK Forestry Standard, EIA regulations as they apply for afforestation, which ensures that new planting is appropriately sited and designed and the Open Habitats Policy. 

5.2 The strategy could include an encouragement for a joint assessment of tree felling applications falling within a priority area for peat restoration identified by the joint NE/FC/FR 2014 report or any updated data-sets.

5.2 The Strategy could seek opportunities to integrate peatland, woodland and other land use policies, promoting principles and methodologies of decision making which protect and increase our natural capital. The England Peatland Strategy might be strengthened further by having strong links with other relevant strategies and policies, for example the developing proposal for a Nature Recovery Network, future England Tree Strategy, or developing work around biodiversity and net environmental gain.

5.3 Opportunities may arise post-CAP if a reduction in Basic Payments encourages landowners in some marginal farming situations to look at diversification options. Natural England and the Forestry Commission are working closely with Defra to ensure that a future ELMS is able to support a range of land use and management scenarios that optimise the delivery of public goods. The Strategy could seize opportunities to provide support at the whole landholding level for woodland removal from afforested peat and woodland creation on the same land holding, helping to achieve Government’s objectives for increased woodland cover and peatland restoration together. 

5.4 The Strategy could identify gaps in the evidence base highlighted in this submission, as set out in paragraph 2.8. The Strategy could further highlight the role of the peat pilots in helping to draw consensus on how to proceed with and prioritise its implementation, in the absence of some of this key information. 

September 2019