Friends of the Earth (England, Wales and Northern Ireland)              DEF0022

Written evidence submitted by Friends of the Earth (England, Wales, Northern Ireland)

Friends of the Earth welcomes the Committee’s attention to this critical issue, and the opportunity to submit evidence.

A. Growing the UK timber industry

i) Does the UK Government have an adequate understanding of the future demand for timber, including what tree species should be grown?

1. Based on our contribution to the government’s trees and forestry action plan and its delivery through Defra’s stakeholder group, it is too early to say whether the government has a firm grasp of likely demand for timber. Various estimates and industry projections have been made but the government’s trees and forestry aims are still in their early stages and have yet to reach a point where the strategy is being enacted in earnest and in ways which make sense when viewed at from local and sub regional levels to a UK wide perspective.


2. Most importantly, part of understanding likely demand and how to meet that is the government and others being clear how different parcels of land can and should be used for particular aims such as for mixed broadleaf woodlands, which the government needs to help in its aims for restoring nature, improving soils, reducing flood risk, and storing carbon, and for commercial timber production for use in construction and other needs. A coherent land use strategy would help here. The UK and devolved governments also have no shortage of internal and external knowledge, support and evidence including data, mapping and skills to know what trees, woodlands and forests are needed in which locations for what purposes.


3. That firm understanding should arise soon if the government’s plan makes – and is allowed to make - concerted progress. Crucial to that is the UK government also having a firm grip of how each UK nation is contributing to a UK-wide picture, and that requires coordination, cooperation and clarity about each nation’s role in overall ambition, sectoral targets and action to restore nature which should also include fixing the poor state of existing woodlands (the 2020 National Forest Inventory found that only 7% of Britain’s 1.51 million hectares of native woodland is in favourable condition), which requires proper care and skills to address, along with lasting investment.


4. As set out in Friends of the Earth’s 2019 report on tree planting rates and funding, public funding for trees has been modest at best and there is a mixed picture of tree planting across the UK nations. Since that report Scotland has continued to lead UK planting rates although questions must be asked about how well that land and forestry is performing in nature and climate terms, and whether land is being used appropriately. England has set slightly heightened tree planting targets which some have referred to as being ‘ambitious’ although that is relative given historical failures to deliver and continuing to fall short of what is required if England is to contribute at the right levels.


5. The wealth of expertise and goodwill that exists at the disposal of UK governments must not be wasted but it risks being undermined by markets rushing to covet land.

Does the UK government, working with the devolved administrations, have an effective, joined-up plan with appropriate incentives to increase the production and use of sustainable, domestically grown timber in the UK to reduce its reliance on imports?

6. Friends of the Earth highlighted the benefits of and need for a joined-up plan in our new report Why we need more trees in the UK. We highlight the need to address the UK’s overseas footprint for timber, pulp and paper, especially in countries considered high risk for issues such as biodiversity impact, corruption, and land and human rights abuses.


Inadequate targets


7. As part of its Environment Act 2021, the government consulted on a proposal to increase the target for tree canopy cover in England from the recent modest 14.5% to a slightly more ambitious 17.5% by 2050, including woodland over 0.5 hectares, smaller woodlands, groups of trees and individual trees, such as street trees in urban areas. That proposed raised target is still inadequate and needs revisiting not least because we must reduce timber and timber products imported from countries that pose a high risk to global biodiversity. We understand that a majority of respondents to the government’s consultation agreed that the target fell short of what is needed.


8. If the UK eliminated timber imports from high-risk countries such as Brazil, China and Russia, that implies 1 million hectares of new forests planted in the UK primarily for timber production, though managed in ways that are supportive of the government’s species and nature restoration aims and targets.


Woodland creation


9. The UK has considerable potential for woodland creation. Mapping commissioned by Friends of the Earth identified 1.3 million hectares of land suitable for new trees, woodlands, and forest in England alone. At a UK wide level, as much as 3 million hectares could become available by reducing livestock numbers and the adoption of healthier, sustainable diets. While much of this land could be allocated primarily for the restoration of nature to help the government meet its stated aims and targets, the scale of potential land available also suggests significant potential for the UK should aim to use a large proportion of this for timber production so that the UK can reduce and cease imports of wood products from all high-risk countries.




10. There is also considerable potential for agroforestry and with improved support it could displace imports of timber and other commodities such as some fruit and nuts, as well as improve the farmed environment. There is an urgent need to enhance land productivity with genuinely sustainable regenerative farming practices. Agroforestry allows for increased tree planting while land continues in food production, making it a more acceptable option for many farmers and landowners.


11. Agroforestry has been identified as a high-impact option for climate mitigation through land use, delivers numerous ecosystem services and benefits and can also increase the productive capacity of the land. The Committee on Climate Change (CCC) suggests there should be up to 900,000 hectares of agroforestry and new hedgerows. This is many times the growth envisaged in the government’s draft trees target, which is only 175,000 hectares of agroforestry. The government should set a clear and much more ambitious target for agroforestry and hedgerows, and urgently address the shortfall in financial support, research and advice available to farmers.


Concerns over carbon credits and carbon offsetting


12. It is unclear that the current commitments add up to a coherent plan for the UK that will be delivered and will not be set aside by changes in government priorities. For now, the government has been seeking to stimulate investment in tree planting (and related activity) with the hope of securing private sector finance. That may work although from our conversations with some landowners, farmers and others, it appears that many are biding their time to see how different financial and other incentives compare, alongside other considerations such as options under environmental land management.


13. Meanwhile, it is concerning to see considerable tracts of agricultural and other land being bought up to secure carbon credits largely through plantation forestry, which risks misusing land and displacing other uses, such as food production or nature restoration. These worrying trends in land use change for forestry appear to be being driven by an interest in securing carbon credits rather than an interest in meeting biodiversity, carbon and other aims.


14. It would help if the considerable work to embed natural capital in HM Treasury and other government policy were being more tangibly deployed as a way to lever more funding and reward action. The Office of National Statistics’ woodland natural capital study has, for instance, put the worth of woodland to the UK economy and society at £3.3 billion every year. If some of value were realised as a form of natural capital investment greater certainty could be secured for farmers, landowners and investors including to support good land use decisions and practices and the training, skills and employment potential that would arise with greater tree canopy cover for different purposes.


15. There are growing concerns that the rapid growth in land purchases for carbon offsetting is pushing up land prices and rents, and displacing local communities, while exacerbating an already highly financialised land market. Scotland witnessed a 31% rise in farmland prices in 2021, and a 60% rise for poor grazing and grass land targeted for forestry. A report by the Scottish Land Commission (SLC) said the majority of Highland estates which changed hands last year had been sold off-market in "secret deals", with nearly half sold to corporate bodies, investment funds or charitable trusts, with a rise in overseas buyers.


16. An earlier report by Community Land Scotland suggests the drive to plant carbon offsetting risked widening inequalities in rural areas and effectively denies communities the opportunity to buy land. A similar situation is emerging in Wales. This loss of land for farming directly impacts communities, particularly tenant farmers and their families.

17. More land is needed for woodland creation and timber products, but this change in land use should be done as part of a land use strategy that is determined through democratic debate, with farmers and rural communities having an important voice, rather than a market-driven economic free-for-all.  It is essential that the drive to increase tree cover in the UK is done in a just, fair and equitable way.  Scotland’s Just Transition Commission suggest: “part of ensuring a just transition must be about making sure the benefits of investment in carbon sequestration are felt as widely as possible. Without careful design and meaningful engagement there is a risk that benefits may flow mainly to large landowners and opportunities for community benefit will be missed.”

18. Measures proposed to achieve more equitable outcomes include a public-interest test on significant land transfers, and a community right to buy. Community Land Scotland proposes a range of other policies to diversify land ownership, enable the public to benefit from the nation’s natural capital, and regulate carbon credit certification to ensure carbon sequestration is genuinely additional.

Are there sustainable sources of biomass for UK energy generation either from imported or domestically grown wood for pellet or woodchip? And how can future demand be met from sustainable sources?

Drax and UK imports of biomass wood pellets

19. The UK is a major global importer of wood pellets, importing 0.6 million tonnes in 2010. By 2020 this had risen to 9.1 million tonnes, and now represents a third of all wood product imports. This huge growth has been largely driven by consumption by Drax in Yorkshire. 63% of these pellets are from the United States, 17% from Canada and 10% from Latvia

20. Some of the world’s largest wood pellet manufacturing companies supplying Drax, including Enviva and Graanul Invest, buy their wood from companies that are clearcutting pristine forests.  In the South-Eastern US timber is being harvested from hardwood swamps, hardwood and cypress wetland forests in the coastal areas of the Carolinas and Virginia and bottomland hardwood forests of North Carolina. The North American Coastal Plain is a global biodiversity hotspot[1]. Other sourcing includes Canada’s boreal forests, and clearcutting in countries such as Estonia and Latvia, including ‘protected’ nature reserves and old growth forests[2]. There is clear evidence of significant harm to wildlife in exporter countries[3].

21. Drax claims that for every kilowatt hour (kWh) of electricity it produces, it releases around 124g of carbon dioxide. This is disputed, with other analyses suggesting the true figure may be four times as much[4].  Drax’s calculation ignores emissions from changes in carbon stored in forests. It argues that trees growing elsewhere capture an equivalent amount of CO2 and claims “the CO2 emissions are absorbed by new forest growth”[5] and the forest area where it sources its pellets is growing[6]. This claim is contested by numerous scientists and environmental groups who argue that Drax’s activities are increasing harvesting, and even with regrowth there is a less carbon stored than if the forest were left to grow undisturbed.

22. A Forest Research report [7] for the government says that burning sawmill residues or other types of wood that would otherwise be wasted is better than burning gas for energy production. However, it notes that burning stem wood (round wood) is worse than burning gas. It has been shown that Drax burns large quantities of round wood, partly because there isn’t enough genuine sawmill residue or waste wood to keep its furnaces burning, but also because of the chemical harm that burning only waste wood could do to its furnaces[8].

Bioenergy with carbon capture and storage (BECCS) and UK potential

23. The government is currently considering the role of biomass in energy generation, particularly fitted with carbon capture and storage to make the power plant carbon negative. It is unclear whether this will be carbon negative in practice. Given that global sustainable timber supplies are limited and global demand is high and rising, any use of pellets should be in the most efficient power plants possible, and not in converted coal-fired power stations like Drax which are hugely inefficient[9].

24. The UK’s import of wood pellets should be reduced substantially, by closing the power stations that burn them and replacing the electricity they produce with additional cleaner wind and solar power. If a strategy of negative emissions from biomass is deemed necessary, then the biomass should be homegrown from new wildlife-friendly plantations and used in a highly efficient power plant.

25. As previously mentioned, the Committee on Climate Change has suggested as much as 3 million hectares of land could become available across the UK by reducing livestock numbers and the adoption of healthier, sustainable diets. A large proportion of this land could be used for timber production, with associated waste wood and sawmill residues.

How effectively is the UK strengthening the resilience of its tree stock to ensure it is resilient to the future impacts of climate change, as well as to pests and diseases?

26. UK governments recognise the threat of pests and diseases related to a changing climate and to imports and have strengthened biosecurity measures especially following the Chalara infection of ash trees and nursery stock in 2012. It is less clear how governments are ensuring the resilience of both existing trees, woodland and forests, which are under stress for a range of reasons including drought and a lack of aftercare, which can then make them even more vulnerable to pests and diseases, and any new trees planted under government plans.


27. Having repeatedly failed to hit past tree planting targets, the UK government and its agencies appear to understand that there is no point in promoting renewed tree planting without also raising the skills and long term commitments which are needed to ensure the sustained health, management and care of what is planted, including on both preventing and controlling pests and diseases and ensuring their suitability and resilience to adverse climate conditions (temperature) and inclement weather (storms, floods etc).


28. UK governments have the data, mapping and other technical information at their disposal to ensure they and others make well informed decisions about the location of new planting for nature and other environmental aims and for commercial timber, and how to ensure trees mature well. That data and information includes projections for climate effects from temperatures to effects on soils, water availability and more. That sophisticated information should inform the development of land use strategies to inform, guide and ensure that good actions are taken on the right land for the right reasons over time.


29. At the time of writing, it is not clear how trees lost to storms, fires, disease and other harms will be replaced. We understand that restocking grants are being looked at for England, although when the Woodland Creation Offer was launched up to £10,000 for each hectare of new woodland created was being offered without consideration of the costs of restocking following storm damage. Storm Arwen in November 2021 alone resulted in the loss of an estimated eight million trees in Scotland and four million trees in England being damaged or lost entirely, and proper planning of restocking following natural events would seem to be sensible just as restocking is planned for in commercial woodlands.


30. The 2018 Tree Health Resilience Strategy recognised both “a national shortage of skills” (page 36) and the need for “dynamic knowledge transfer that link scientists and specialists with advisors, practitioners and students that cuts across the disciplines of arborists, foresters, horticulturists, land managers, environmentalists and agronomists” (page 37). It will be important to see how various government initiatives which do recognise climate resilience and pests and diseases work, such as the Keepers of Time policy, the updated GB Plant Biosecurity Strategy, the proposed guidance to local authorities on creating local tree and woodlands strategies, the new Centre for Forest Protection, and even the Green Jobs Delivery Group.

B. The effectiveness of UK efforts to reduce global deforestation

In what ways and to what extent are UK value chains (in the form of public procurement, goods, services, or the private sector) contributing to global deforestation?

31. As acknowledged in the call for evidence, extensive loss of tropical forest occurred in 2021, including 3.75 million hectares within tropical primary rainforests - areas of critical importance for carbon storage and biodiversity. Brazil lost 1.5 million hectares of tropical primary forest – the vast majority of this in the Amazon – which represented over 40% of the global total. Global Forest Watch has noted the rate of primary forest loss in the tropics has been consistent over the last few years, and also pointed to unprecedented tree cover loss in boreal forests in 2021. [10]

The UK’s footprint

32. The call for evidence also notes the role of the international trade in agricultural and timber products as a key driver of deforestation, and the WWF and RSPB estimate that UK imports of just 7 ‘forest risk’ commodities account for a land footprint equivalent to 88% of the UK in size every year.  The JNCC estimates that UK consumption of agricultural commodities (excluding livestock) was responsible for 20,196 ha of tropical deforestation in 2017.

33. The UK is an important global market for commodities associated with deforestation, ecosystem conversion and human rights risks. Despite countless claims and assurances to the contrary, UK and international businesses continue sourcing deforestation-risk products which are entering the UK marketTheses have been well documented - some recent examples include the following cases involving beef, soy and palm oil:

Examples of UK companies linked to deforestation

34. In October 2021 it was reported that beef linked to Amazon deforestation was tracked to products supplied by JBS to European supermarkets. Monitoring of cattle purchases in the state of Pará identified JBS had 300,000 cattle of doubtful origin in its supply chain in the 18-months to June 2019, despite a supposed moratorium on deforestation.[11] 

35. An investigation in 2019 by Friends of the Earth found that Co-Op, Morrisons, Waitrose, and Iceland were selling corned beef from JBS slaughterhouses in Brazil[12].  

36. Research documented 118,000 ha of deforestation on soy farms in the Amazon between 2009 and 2019, most of it illegal.  Shipments of soy from municipalities with hidden deforestation were traced to European countries, involving top traders Bunge and Cargil[13]

37. A report released in March 2022 by Friends of the Earth US and Friends of the Earth Indonesia (WALHI) found palm oil company, Astra Agro Lestari (AAL) responsible for longstanding land rights abuses and environmental destruction in operations undertaken without proper legal permitsAAL supplies palm oil to leading consumer brands including Procter & Gamble, PepsiCo, Unilever and Danone and to major palm oil traders such as Archer Daniels Midland, Bunge and Cargill.  AAL is majority-owned by Jardine Matheson a British conglomerate incorporated in Bermuda. [14]

Vertically integrated companies

38. In some cases, international agribusinesses linked to deforestation are vertically integrated and control multiple elements of the international and UK supply chain, demonstrating significant focus on forest risk commodities. They are not only producing or sourcing forest risk commodities overseas, but operating livestock business in the UK which consume those commodities – particularly soyIn such cases where UK subsidiaries operate, we would expect UK due diligence legislation to exert pressure/apply to parent companies. 

39. Brazil’s JBS is the world’s largest meat company.  It has an 80% stake in US-based Pilgrim's Pride Corporation, which itself owns Northern Ireland-based Moy Park. Pilgrim’s Pride owns the UK’s biggest pork producer Tulip, and in 2021 JBS acquired Kerry Group.  Moy Park is also the second largest chicken producer in the UK.

40. Cargill dominates the soya trade into the UK, controlling about 70% of the market. The company ships more than 100,000 tonnes of soybeans to the UK every year from Brazil’s Cerrado region alone. Cargill is a joint owner of Avara, the UK’s 3rd largest chicken producer.  It is also a major supplier of soy to the UK’s dairy industry

UK finance driving deforestation

50. UK-based financial institutions play a major role in financing deforestation. They were the single biggest source of international finance for six of the most harmful agribusiness companies involved in deforestation in the climate-critical forests of Brazil, the Congo Basin and Papua New Guinea, providing £5 billion over the period 2013-2016[15].

51. A recent report by Friends of the Earth Europe found that European banks, insurers, and pension funds continue to invest in forest-risk commodities. A number of UK companies were amongst the biggest European creditors and investors in soy and beef supply chains linked to illegal deforestation, fires and slave labour in Argentina, Brazil and Paraguay. HSBC and Barclays provided credit worth 1288M Euros and 548M Euros respectively over the period 2016 to 2022. UK investments included 81M from Odey Asset Management, 27M Euros from Legal and General 27M, and 23M from Schroders[16]

The need for demand reduction

52. It is vital that the UK takes steps to reduce demand overall for deforestation-risk commodities. This includes our demand for unsustainable biomass, particularly for use in Drax biomass plants in Yorkshire, responsible for deforestation of old growth forest in South Eastern USA (see paragraphs 19-22 above); and a reduction in meat and dairy consumption - meat and dairy consumption and consequent demand for livestock feed is one of the leading drivers of global deforestation. Up to 90% of our soy imports 38% of PKE imports, and palm oil/pko are for livestock feed, in particular intensively produced pork and poultry.

53. Efforts to cut food waste must also be intensified, through a legally binding target to reduce food waste from farm to fork by 50% by 2030.

How effectively is the Government monitoring the UK’s contribution to global deforestation and its progress in tackling the issue? And what progress has been made by Government to develop an indicator on overseas environmental impacts of UK consumption of key commodities?

54. In February 2022 the House of Commons International Development Committee reported on international climate finance, pledges at the Glasgow COP26 and UK aid to halt deforestation and biodiversity loss. The Committee asked the government to respond to its report and important recommendations within six months, but that timescale has not been met, we understand, making it hard to know how the UK government is making progress following COP26 and in general.

55. The government has however responded the same Committee’s excellent recommendations in its report on Global Britain in demand: UK climate action and international development around COP26.

56. In terms of indicators we understand that a new global biodiversity indicator for the impacts of UK economic activity / sustainable consumption is still being developed.

How effective are the measures to improve due diligence and ban imported products of illegal deforestation in the Environment Act 2021? Do these measures target the right sectors? Given that they do not extend to all products of deforestation, are they adequate?

57. The measures set out in the Environment Act 2021 (Schedule 17), and in the Defra proposal for secondary legislation[17] are inadequate. The Committee on Climate Change recognises this, recommending in its progress report this year that the Government to build on the Environment Act provisions to address illegal deforestation and “develop new policy to remove unsustainable legal deforestation from UK supply chains[18]

58. The weaknesses in the Government’s approach are set out in points (a)-(e) below.


a)      Scope of commodities

59. The proposed secondary legislation only covers seven deforestation-risk commodities (cattle [beef and leather], soy, palm oil, cocoa, coffee, rubber and maize). This is a significant limitation. Friends of the Earth’s view is that the legislation should apply to all products - including the products of mining, timber (as there have been few cases raised to date via timber regs therefore concern re. its effectiveness) as well as rare minerals for the renewables industry.

60. Land use is interchangeable between many agricultural commodities. A ban on one commodity can simply leave space for another deforestation driver or displace the deforestation elsewhere. Indirect deforestation is common, such as soy displacing cattle ranching, driving further ranching in the agricultural frontier.  The Amazon Soy Moratorium led to a significant reduction in soy deforestation in the Amazon, but led to increasing soy deforestation rates in the Cerrado.  Emerging commodities will add further deforestation pressure, eg. Papua New Guinea is already a deforestation front for palm oil and a hotspot for illegal logging, but the PNG government’s recently announced plans for ambitious increase coffee production[19]

61. It is important to note that ‘land footprint and deforestation risk of commodities isn’t necessarily the same thing, although often used interchangeably. An analysis of UK forest risk commodities by the Stockholm Environment Institute [20] noted a number of emerging commodities that have a high deforestation risk but are not included in the Environment Act secondary legislation proposals. Sugar, coffee and pepper have significantly higher deforestation risks than commodities with a high land footprint such as rubber.  They noted that these commodities are much less extensively studied in the literature and may warrant further research and consideration. 

Mining and deforestation risk

62. Mining is not included in Schedule 17 of the Environment Act, but is a major contributor to deforestation, particularly its indirect and cumulative impacts. Up to one-third of the world’s forests may already be affected by mining, with regions such as the Amazon, the Congo Basin and Southeast Asia at particular risk.[21] It’s been suggested that 10% of the deforestation in the Brazilian Amazon between 2005 and 2015 was due to mining activities[22].

63. In Indonesia, thirteen corporate groups have both large palm oil and mining and businesses. This includes Astra (AAL - see above). Ironically, while Astra has adopted a palm oil sustainability policy, it has not extended this to its mining operations.  In late 2021 it was reported that Astra continued destroying habitat of the critically endangered Tapanuli orangutan at their Martabe gold mine in North Sumatra, despite calls from the IUCN to halt expansion.  The Tapanuli orangutan (Pongo tapanuliensis) is the rarest of the 3 orangutan species, numbering only 800 individuals, and was only identified as a new species in 2017.

b)      Timescales for implementation

64. Defra are proposing a phased approach to the seven commodities, ranging between introducing 1-2 commodities initially (taking 18-24 months for implementation), to introducing 5-7 commodities initially (taking 4-5 years). These long timescales imply a worrying lack of capacity in the department, particularly given the fact that the legislation only covers illegal deforestation, and companies should already be clear on the need to comply with relevant local laws.

65. The potential for illegal deforestation linked to UK company supply chains to continue for up to 5 years under these proposals is unacceptable.

66. Friends of the Earth would encourage the introduction of all seven commodities from the start and within 12 months of adoption of the regulation.

c)      Legality

67. The fact that only products of illegal deforestation are included in the scope of Schedule 17 of the Environment Act is a major weakness. Banning imports causing deforestation deemed illegal in the country of origin is insufficient where those countries’ laws are inadequate, their governance weak, or corruption widespread. The Committee has noted WWF/RSPB analysis highlighting the large proportion of commodity imports arising from ‘high-risk’ countries for deforestation and corruption. This is starkly evidenced by the situation in Brazil, where we have witnessed the dismantling of state institutions responsible for environmental protection, key staff have been removed, legislation weakened, demarcations of indigenous and community lands delayed, and exploitation of Brazil’s biodiverse regions encouraged by the government of Jair Bolsonaro

68. In 2020, Funai changed one of its regulations to allow private properties to be registered on indigenous lands that had not yet completed their demarcation process. This violated previous rules that protected all indigenous lands regardless of their demarcation status. It is suggested that this has unleashed a new rush of land grabbing, with over 400 illegal farms occupying nearly 240,000 hectares registered on indigenous lands. Clear evidence of the impact is revealed in a recent investigation by Earthsight – when Cargill was challenged over its sourcing of soy from a demarcated indigenous territory, the company was able to claim no illegality had occurred.[23]

d)     Companies in scope


69. Defra proposes only to include large companies in the scope of the legislation. This is problematic as setting a turnover threshold would result in illegally produced forest risk commodities continuing to be imported into the UK:


70. Friends of the Earth’s view is that all companies using forest risk commodities in their UK commercial activities and supply chains should be included in the scope of the regulations without exemption.

71, Covering all companies would:

72. Furthermore, the Global Resource Initiative recommended that all businesses should be included in the scope of the regulations, along with finance and public procurement[25] which Friends of the Earth strongly supports. Inclusion of public procurement would show leadership and that government is getting its own house in order.

To what extent have the Global Resource Initiative (GRI) Taskforce’s recommendations on deforestation and land conversion been met by the Government?

73. Disappointingly, most of the excellent GRI recommendations are not being met. Government published its response the the GRI Taskforce in November 2020.

-          There is no commitment for a Strategic Sustainable Commodities Action plan

-          There is no framework for reporting on the GRI recommendations

-          There is no legally binding target to end conversion within UK agricultural and forestry commodity supply chains no later than 2030

-          Due diligence measures are being introduced under the Environment Act, but they are much more limited in scope than the GRI envisaged (see answers to question above on due diligence) and fail to extent to human rights.

-          GRI called for support for a consumer transition to more sustainable and healthy diets and to reduce food waste in supply chains – the government is failing miserably on diets. Much of this was farmed off to the National Food Strategy, but government repeatedly refuses to address diets, despite the clear and multiple benefits to society and the environment.

74. On this, Friends of the Earth would encourage the Committee to ask Government why it refuses to take action to encourage sustainable, healthy diets with less and better meat and dairy, and more plant proteins to reduce UK demand for soy from South America in animal feed. This is despite expert agreement (including from the IPCC, Committee on Climate Change, Henry Dimbleby’s Independent National Food Strategy, Chatham House) that we need to reduce meat and dairy consumption to address both the climate and biodiversity crises.

75. The Eating Better alliance (Friends of the Earth is a founding member) in its ‘Better by Half’ Roadmap, has set out the actions that need to be taken by Government and across the food and farming industry to drive the shift to less and better meat and dairy in the UK.

What role can sustainable certification and Government Buying Standards (GBS), have in tackling deforestation? How can the UK Government support the private sector to reduce its contribution to furthering deforestation?

76. Voluntary sustainability of commodities has a limited role to play. Evidence to date shows that certification alone will not guarantee sustainable supply chains, particularly in the case of commodities like palm oil – eg through the Round Table on Sustainable Palm Oil (RSPO) and soy through the Round Table on Responsible Soy (RTRS).

77. A 2021 report by Greenpeace[26] documents concerns over the robustness of a number of commodity certification standards including how the governing bodies are failing to enforce their own standards, concluding: “certification is a weak tool to address global forest and ecosystem destruction”.

78. As an example, a Friends of the Earth International investigation found major palm oil producer IOI, (operating in Indonesia and Malaysia and one of the co-founders of the RSPO), involved in numerous breaches of law, as well as requirements set out in the RSPO. This included expanding plantations into forest and peatland without Environmental Impact Assessments. It took 6 years of concerted NGO campaigning for the RSPO to suspend the company in 2016, and then only for 5 months.

79. The reasons these schemes have failed to prevent deforestation and clean up supply chains include:

Mandatory human rights and environmental due diligence needed

80. Instead of relying on commodity certification, Friends of the Earth would like to see government support for robust legislation to ensure the environment and communities aren’t harmed by UK supply chains. This includes wide ranging mandatory environmental and human rights due diligence measures, with liability, as called for by businesses, investors, civil society and over 125,000 citizens.

81. A recent YouGov poll found high levels of public support, with 87% supporting new laws to prevent businesses from exploiting people in their supply chains and 83% support new laws that would force companies to ensure their supply chains do no avoidable damage to the environment.

Public procurement and the Government Buying Standards

82. We also urge the inclusion in Government Buying Standards, particularly the GBS for Food currently being updated, a requirement to reduce use of foods that contain or require high levels of imported commodities - including products that contain palm oil and soy in their supply chains. This should include a reduction of procurement of ultra-processed foods that are more likely to contain palm oil and soy ingredients, and a preference for suppliers of meat and dairy that do not use imported soy animal feed, and instead source locally grown alternatives to soy feed. Alongside this, as recommended by the Committee on Climate Change, should be a requirement to rebalance menus across the public sector in favour of healthy, plant-based proteins, wholegrains and vegetables, and away from meat and dairy – in line with the Eatwell Guide.

83. The CCC has recommended a reduction in meat consumption of 20% by 2030 and 35% by 2050. Friends of the Earth and the Eating Better alliance recommend a more ambitious reduction of 50% by 2030. As well as reducing UK demand for damaging imported commodities such as soy for animal feed, rebalancing menus across the public sector in this way would help meet Net Zero targets, and improve public health.

C. Working with international partners to tackle deforestation

How effectively is the UK engaging with international partners to tackle deforestation? Is the Glasgow Leaders Declaration on Forests and Land Use an effective mechanism for halting and reversing forest loss? How can the UK ensure its £1.5bn commitment to the Global Forest Finance Pledge is used to best effect?

84. The Glasgow Leaders Declaration by more than 140 nations representing 90 per cent of the world’s forested nations was an important step in accepting the urgent need to shift to sustainable land use, and away from the kind of land use and degradation that are widely recognised by governments and their advisers including the IPCC and the IPBES as being lead drivers of nature’s decline and rising vulnerability to the effects of climate change, with consequences for food production, for the resilience of land, and for land and human rights.

85. The Glasgow Declaration builds on the 2014 New York Declaration on Forests and Land Use and is similarly voluntary and non-binding albeit with 2030 rightly set as the date to halt and reverse forest loss and land degradation once and for all. Given the patchy record, at best, of decades of loose, unenforceable, voluntary and incremental approaches to the halting and reversal of nature’s decline at the pace required by science (as witnessed by the collective failure of governments to meet both the 2010 and the 2020 dates pledged in the past) the Glasgow Declaration has a long way to go to realise its ambitions, and it is not yet clear what will be different this time.

86. Recognising the importance of forests in reversing biodiversity loss and curbing the worst of climate change is fine but is not especially new. It is well known that deforestation is responsible for some 15% of global carbon emissions and is an important driver of biodiversity loss. It is also well established how trees, woodlands and forests support nature, maintain soils, help reduce flood risk, influence weather patterns and provide for lasting livelihoods above and beyond what can be done by any activity that replaces them whether logging and subsequent monocrop plantations, cattle ranching, mining and shifting and commodity agriculture.

87. To be effective, and to avoid being another empty declaration, the UK and other signatories will need to directly address the drivers of deforestation, especially the unsustainable production of globally- traded commodities, and change the current ineffectual, fragmented and weak protection and governance of forests, including strengthening the proper role of indigenous people and local communities who have a better understanding and record on forest protection, but who tend to be ignored and often abused. The Declaration’s financial pledge also must be seen in the content of funds which are still driving damage and harm, often directly against the interests of local and indigenous peoples.

88. In a related Race to Zero Financial Sector Commitment Letter on Eliminating Commodity-driven Deforestation some corporate and investor parties to the Declaration have pledged to end all investments in agricultural commodities that fuel illegal deforestation by 2025. That would be an immense and much needed change in the right direction and at the pace needed. Notably, though, Global Canopy’s 2022 Forest 500 report identified that “Far too many the companies that are most exposed to deforestation are still not doing enough and that:

- nearly three out of four (72%) of companies assessed lack a deforestation commitment for all of the forest-risk commodities in their supply chains;

- one-third of companies lack deforestation commitments of any kind;

- just 11 of the 28 companies which did produce new commitments on deforestation in the previous year still lack a deforestation commitment for all of the commodities they are exposed to;

- many companies with commitments are still failing to provide evidence of how they are implementing those, particularly for soy, beef and leather commodities and supply chains; and,

- no company assessed had a comprehensive approach to human rights.

89. Add in the role of organised crime groups and the sums further dwarf the amounts being re-deployed to end deforestation. As far back as 2012 INTERPOL and the UN Development Programme estimated that the illegal trade in timber was generating funds for organised crime of between US$30-100 billion annually. It cannot be ruled out that illegality overlaps with legitimate company activity. And, of course, in some ‘high risk’ nations there is a thin line between what counts as legal and illegal. Brazilian President Bolsonaro‘s policies are, for example, directly implicated in the infringement of land and other rights on indigenous people and local communities, and in the plundering of natural assets which are very likely to enter ‘legal’ supply chains.

90. Away from PR claims and advertising and often unreliable product labelling by companies, how would someone buying a chocolate bar know that their choice of product is no longer part of the deforestation scandal from which companies, producer nations and complex and often illegal players in supply chains have profited, while being blind to, for decades?

91. The test is whether these and other initiatives add up and are clearly accounted for in a coherent, transparent overall action plan that delivers weekly, monthly, and annual progress and change which can be tracked in the short, medium and long term to 2030. A clear action plan with specific standards and targets and benchmarks for each strand, including predictable funding, progress on ending harmful investments, and means of verification and reporting needs to be presented at the forthcoming COP27 climate and COP15 biodiversity summits.

What impact will the UK’s measures to tackle deforestation have on producer countries, indigenous peoples and local communities?

92. This important question is hard to answer with certainty as doing so depends on how well local communities and indigenous people are supported and empowered by any plans and how that support and commitment is sustained over time.

93. In its December 2021 response to the House of Commons International Development Committee’s October 2021 report on Global Britain in demand: UK climate action and international development around COP26, the government usefully stated (on page 2) that:

94. “More specifically, the Indigenous Peoples’ and Local Communities’ (IPLC) Forest Tenure Pledge, led by the UK and supported by 22 bilateral and private philanthropies, has committed to advance security of forest tenure rights in partnership with IPLCs, through channelling support and activities to strengthen land and resource rights. This pledge specifically commits to promote the effective participation and inclusion of IPLCs in decision-making and include, consult and partner with them in the design and implementation of relevant programmes and finance instruments.

95. “The UK is committed to continuing to place locally-led adaptation at the forefront of its work on adaptation and resilience. We prioritise locally-led action with a strong grounding in the local context and needs, targeting marginalised groups. Our programmes seek to understand and tackle the drivers of underlying vulnerability as well as those introduced or worsened by climate change. We work hard on evaluating not just how much we’re spending on adaptation but how effective that spend is.

96. “FCDO programmes consider local needs from the very start. Programmes are designed in partnership with local experts and use our network of in country development specialists. Programme concept notes and business cases consider risks before they are approved.

97. “The FCDO has also recently strengthened its approach to climate risk by integrating a climate and environment rule into the Programme Operating Framework. This rule requires all new FCDO ODA programming to align with the Paris Agreement, assess climate and environmental impact and risks, and take steps to ensure that no environmental harm is done.”

98. That and other aspects of the government’s response to the Committee are encouraging but they will need to be followed through not just via the UK’s Presidency of the UNFCCC and its hand over to Egypt, but in the new government’s policies and commitments.

Support for Community Forest Management

99. The UK should provide support for the principles and implementation of Community Forest Management (CFM)[27] also referred to as Indigenous and Local Communities Conserved Areas (ICCAs)[28] .  CFM is a way of life developed by Indigenous Peoples and Local Communities, based on their cultural and spiritual vision of what nature is, and advocated by Friends of the Earth International. The communities manage their territories in a way that ensures the conservation and sustainable use of nature alongside the social, environmental, cultural and even economic benefitsCFM entails the political control of communities over their territories and resources through horizontal decision-making mechanisms, including transparency and accountability to the rest of the community The UK should support the direct funding of Indigenous Peoples and local communities in local projects to strengthen CFM and ICCAs.

100. The UK should also give its full support to UN treaties on Indigenous Peoples Rights and the UN declaration on the rights of peasants.


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