Mr David Atkinson DEF0004
Written evidence submitted by David Atkinson BSc Hons Forestry, MicFor. Forestry Manager.
Growing the UK timber industry
The government is very much aware of the projected reduction in the volume of timber production and is also aware of increasing international and domestic consumption. While there are useful and ambitious targets for woodland expansion it is my view that few, if anyone involved in forestry and land management actually take these seriously or believe that the government and the government organisations tasked with delivering these targets believe in them. There is a sense that these targets are glibly put into local plans and regional targets and that by doing so government organisations and local authorities have done their job.
There is little evidence that local authorities, Natural England, DEFRA organisations and most sadly, the Forestry Commission actually want to deliver woodland creation that can produce timber.
Forestry Commission policy, guidance and regulation has overly focused on “resilience” and species diversity with little care or comprehension to the needs of the timber industry or the practicalities of woodland owners. The reality for woodland owners is there remains a handful of species in the UK that produce viable crops of timber and Sitka spruce remains the single most important species.
I work in both Southern Scotland and Northern England.
FC England has in the last 2 years developed a lucrative grant scheme which could be very effective. However, in parallel they have ramped up regulation and guidance and devised a process that it is oppressive and off putting to landowners and agents. It is my view that what ever increased interest the new grant has generated will be quickly lost as landowners and particularly agents will take on fewer projects in future because of the time, cost and high risk of failure.
As an example, up until 2020 our firm actively searched for land to buy in England to plant as an investment for our clients. We now view this as too risky and no longer a safe investment in England. It is possible in Scotland.
There is a real risk that the FC will have increased its staff costs (about 140%), increased grant rates (about 200%+) and may achieve no more planting. This would be a very poor outcome for the government and steps must be urgently taken to greatly streamline and improve the process.
Scotland by contrast has barely changed its grants in over 5 years and demand remains high. That said inflation and increasing costs are making their grant programme look long in the tooth and demand may start to decline unless this is refreshed and better funded.
Scotland has a simpler and more flexible process and they do not have a complex and prescriptive grant funded Woodland Creation Planning Grant.
The Forest Industry has made representations to the DEFRA to learn the lessons from Scotland but to date this has been studiously ignored. There is an urgent need to carry out a review of the Forestry Commission as was undertaken in Scotland by Jim Mackinnon.
Recent changes to the Carbon Code, which now prevent productive plantations being eligible for Carbon registration will have a rapid cooling of demand from new investors. In my view, this is a welcome development as this was causing a spike in land values beyond agricultural values.
Biomass has been a significant and welcome development in forestry over the last 10 years. However, we must also recognise that the burning of virgin wood does generate more CO2 than burning gas or other fossil fuels and as such it does create a problem.
Burning forest residues, waste wood and timber processing residues does have a better carbon footprint and this element should be fully supported.
The biomass industry and support in the form of green subsidies must be carefully regulated to ensure that it does not encourage undesirable practice, such as mass importation of biomass or the fraudulent use of small-scale heat schemes, for example where farms start to burn excess wood to generate excess heat simply to make money.
This is a major failing.
Biodiversity and other environmental goals are the single largest problem in achieving more woodland creation.
The UK has adopted EU law and guidance on priority habitats. However, the EU guidance on priority habitats only required member states to make a published list of priority species and habitats and largely no more; there was no formal protection required. England has gold plated the regulation, and the list is now so comprehensive that nearly all land types other than highly cultivated land are now priority habitat. The FC has created its own guidance and super gold-plated regulation that states that there can be no loss of priority habitat associated with new planting and conifers cannot be planted on priority habitat. This has no legal basis.
Government must fully review the habitat regulations. Priority habitat and species classifications must be reserved for truly priority status. This can also be helpful for biodiversity and conservation, as efforts can be focused rather than the current scatter gun approach of trying to get small and marginal gains (which are easily and often lost) everywhere. Focused priority habitat classification might allow more SSSIs but reduce the regulation on land which currently has priority habitat status (for example many degraded upland heath areas).
It must be highlighted that Scotland takes a more pragmatic and looser interpretation of priority habitat than England.
A quick win could be achieved by the FC revising their guidance such that across their new woodland creation programme there is no net loss of priority habitat. This would allow some planting on priority habitats as longs as a surplus of either new native woodland was created on none priority habitat land or where coniferous woodland was felled and replanted as native woodland or open habitat restoration.
This way the FC can fairly claim to achieving a net biodiversity gain.
This is an obsessive and unhelpful part of FC policy and practice.
The UKFS which sets out regulation and guidance already imposes significant requirements for species diversity in both felling regulation and new planting.
This is unhelpful and must be reviewed as it is particularly poor and unhelpful for small scale farm and estate forestry. For example farm shelter belts are often best planted as single species blocks and trying to impose 10% broadleaves or 25% other conifers is costly and rarely achieves long term gain. The FC must recognise that on a wider scale that many woods (often their own) are being converted to native none timber producing species, but some farms and estates may still want to plant productive woods, and this should be allowed under the guidance rather than trying to impose a scatter gun approach of diversity everywhere.
UKFS must be revised urgently to give more flexibility to farm and estate scale forestry
This also applies to new woodland creation. The majority of woodland creation in England is native so why insist on having 10-20% of native woodland as part of every productive scheme, particularly smaller scale planting?
The effectiveness of UK efforts to reduce global deforestation
I do not know.
It is, however, reasonable to encourage increased home consumption but the UK already has a very high net consumption of imported timber products.
This is a difficult and unfruitful task. The UK can impose requirements for certificated wood as part of procurement. As such we can pat ourselves on the back and say we only buy timber from sustainable sources. However, this is an illusion as it means that other countries unable to afford and source certificated timber will buy it from less sustainable or even illegally logged sources.
The UK has a huge net demand for timber, and this must be indirectly contributing to deforestation. Only by producing more of own timber can we say we are reducing our impact.
As above
I do not know.
International Certification of timber products has failed to address the problem it set out to tackle. It has morphed into an expensive bureaucracy to needlessly regulate timber production in western countries where there is no problem and has deserted developing countries where it might have some value.
The UK government should immediately insist that the FC stops being a member of UKWAS, FSC and PEFC. This will reduce the cost and regulation burden on all timber producers as certification in the UK would immediately be unviable and unable to operate.
Currently no large-scale individual timber processor or grower dare leave certification because of the risk of losing competitive advantage and as such they continue without any of them believing in the value of the certification and all seeing it as burden.
The UK government (through the FC) could simply provide timber producers with a certificate to confirm that it has been felled under licence and is lawful.
This approach would be welcomed by the entire UK forestry industry and seen as the UK government actively reducing costs and burdens.
Working with international partners to tackle deforestation
I do not know.
However, what impact will the UK’s measures to tackle deforestation have on producer countries, indigenous peoples and local communities?
Our net consumption indirectly must have an impact. The UK must first start planting more trees and start doing it quickly.
August 2022