RSPB                            DEF0028

Written evidence submitted by the RSPB

About the RSPB

The RSPB is Europe's largest wildlife conservation organisation. The RSPB manages 222 nature reserves in the UK covering an area of over 158,751 hectares, providing a home to over 18,500 species. The principal objective of the RSPB is the conservation of wild birds and their habitats. The RSPB attaches great importance to all international and national law, policy and guidance that assists in the attainment of this objective and champions the cause of biodiversity conservation within the wider debate on sustainable development.

Our Submission

The RSPB strongly welcomes this inquiry into sustainable timber and deforestation to provide a vital evidence base for the future. Sustainable timber means a nature positive, net zero approach that addresses the nature and climate emergency. Expanding tree cover can reduce our reliance on imports. Demonstrating best practice at home legitimises our demand for higher standards from our overseas timber supply chains. The RSPB’s own woodlands are UK Woodland Assurance Scheme certified to demonstrate our own commitment to sustainable forest management.


Growing the UK timber industry 


The Call for Evidence shows that the UK Government understands the future demand for construction timber. It recognises that timber demand will rise both globally, and in the UK, and that promoting the use of timber products for construction is, as it should be, part of the UK Government’s Net Zero Strategy.


However, future demand for timber includes other wood products (such as Furniture, Woodfuel, Pulp and Paper). It is not immediately apparent from the Call text or references that these products have been analysed.


Furniture is a long-lived carbon product with a carbon substitution value. Demand for FSC/PEFC certified hardwood furniture made from UK native broadleaves exists, but prices are exorbitant because supply is lacking. Despite Timber and Timber Products Placing on the Market and UK FLEGT Regulations, imported timber, including wooden furniture may derive from less well governed, if not illegal, sources (Forestry Statistics do not include furniture in the list of selected wood products that they report sources for). The UK Government should promote productive native broadleaves and a domestic hardwood furniture industry.


Woodfuel. This will be considered in more detail in question 3 below.



Pulp and Paper. The global trend towards lower demand for paper in recent years has been increased by Covid, and policies are changing:


‘Regulatory policies that are expected to be implemented within the next few years are likely to favor forest products that enjoy extended usage: for example, wood construction over pulp and paper, which in turn is preferred over biofuels. [1]


It is vital that the UK Government understands how wood products demand is changing and whether our domestic forest resource and international supply chains is suited to future needs.


The debate on species choice can become polarised but most of the forest industry and environmental NGO sector would agree that we need trees for multiple objectives. The RSPB advocates a Right Place, Right Reason, Right Tree approach through which tree species choice becomes a function of decisions around site suitability and purpose after which Forest Research’s excellent Ecological Site Classification Decision Support System (ESC) can, if correctly used, inform the species choice.




Forestry is a devolved matter, each administration reports targets in different ways, at different times and for different timescales. These targets change over time, for example the Environment Act Targets consultation indicated that England’s target may change to the equivalent of 16,000 ha per year up to 2050. A single table that reported annually showing the targets for each devolved administration, the extent to which they are being achieved and the match across to UK targets would be helpful. Furthermore, it is often not clear what proportion of tree and woodland cover targets is for timber production. Without clear differentiated targets increasing woodland cover for different purposes (the Right Reason) it is impossible to assess whether the incentives are appropriate. The RSPB advocates individual targets for:


1. native woodlands for nature, climate, human health and well-being,

2. commercial (non-native and native) forests established primarily for timber production,

3. trees outside of woods,

4. silvo-pastoral agroforestry systems.


The RSPB understands that setting targets for these components involves compromise because different stakeholders will wish for different proportions to be allocated to each individual target. For example, we would hope to see a greater proportion allocated to native woodlands for conservation, whereas we would expect Confor to hope for a greater proportion allocated to commercial forestry. However, we believe that both Confor and ourselves would welcome greater clarity to know what targets we are aiming for now, whether we are achieving them, and for UK Government and devolved administrations to be able to adjust regulations and grants towards those desired outcomes over time. Such clarity would also enable UK Governments and devolved administrations to revisit targets in future if new evidence led to changed priorities.


It is even less clear what the plans are for improving the management of existing woodlands for multiple objectives including timber production, climate adaptation (resilience), climate mitigation, biodiversity, and other objectives. In the short to medium term domestic timber supply may be increased from under-utilised woodlands and from ecological restoration work. For example, restoration of Plantations on Ancient Woodlands sites necessitates the removal of non-native and inappropriate native tree species, some of which may be timber quality. Thus, a win-win situation exists where greater incentives for restoration would mean more wood to market.




Incentives to burn forest biomass for energy carry an intolerable level of sustainability risk and should be removed.

Current financial incentives have generated a vast discrepancy between sustainable feedstock availability and usage.

Our current woody biomass supply chain is almost totally reliant on imports, and has increased rapidly: around a third of the UK’s timber imports between 2016 and 2018 were in the form of fuelwood – equivalent to 1.4 million trees - and has doubled since 2015, because of increased demand for bioenergy production[2]. The challenges of international governance can be insurmountable. Under existing sustainability standards, wood sourced using damaging logging practices routinely enters the UK energy market.[3] In Estonia, recent investigations found that logging on land owned by wood pellet companies was occurring in protected habitats,[4] likely violating UK sustainability standards.[5]

We recognise that UK Woodland Assurance Scheme accredited thinning practices in the UK are beneficial for silvicultural reasons and may have biodiversity benefits, however, these cannot be separated from the carbon and nature risk of incentivising wood burning for electricity or BECCS. Arisings from silvicultural management in the UK may be suitable for small-scale bioenergy use, however the market should not be distorted by subsidy to encourage this end use over others such as leaving in the forest.

Future targets for biomass use must be scaled down to facilitate this reduction in feedstock availability.



We recognise the need to reduce pressures that drive deforestation globally, including the role of commercial forestry in meeting a greater proportion of demand, including via approaches which deliver greater biodiversity and climate resilience, with more diverse trees and more use of productive native broadleaf trees.


We have recommended the need for a strategic, UK-wide approach to identify the best places for new woodland and forests and produced mapping as an indication of potential for expansion beyond sensitive sites, which should be informed by a robust approach to EIA, better data and site surveys for soils and sensitive species.

In upland areas of the UK this includes a need to ensure woodland and forest expansion is compatible with the ongoing protection and restoration of peatlands and breeding populations of waders and other ground nesting birds that are a conservation priority. As an organisation with experience of monitoring and restoring upland habitats and bird populations, we have welcomed opportunities to provide feedback on new guidance where this is being developed and remain willing to help develop robust approaches. 

To deliver biodiversity recovery, we have also recommended prioritising native woodland, with a focus on restoration, expansion, and reconnection of existing ancient woodlands as our most biodiversity rich woodland habitats. Bringing more of our existing woodlands into sustainable management can be a source of wood products, but must also recognise the value for biodiversity of features such as veteran trees and deadwood.




The impacts of climate change are upon us. The UK is already experiencing greater incidence of wind, drought, flooding and fire, and climate change is also a very probable contributing factor to the increased incidence of pests and diseases in recent years. For example, the larger eight-toothed spruce bark beetle (Ips typographus) flies at an air temperature of 11.7 to 16.5 C and reaches maximum activity at 25 to 30 C. Higher summer temperatures made the windblown arrival that has occurred from the continent in 2021 and 2022 more likely and future dispersal more probable.


Forest Research undertake important research to determine which non-native tree species may have a future role. Funding for this work should be increased to ensure Forest Research has the capacity to properly test the suitability, and guard against the invasiveness of more novel species, such as Paulownia clones, that are being suggested for timber production by energy companies. Alongside this, the greater genetic variation within native tree species and their suitability within the UK should not be underestimated. The resilience of the UK’s tree stock really depends on species diversity rather than the characteristics of individual tree species. For example, Corsican pine was among the most suitable tree species for future UK climate conditions in 2005 (Forest Research, 2005), immediately prior to the arrival of Dothistroma Needle Blight which led to a moratorium on planting this species in 2006. If Ips typographus transfers from Norway spruce to Sitka spruce in mass attack conditions, the UK (Scotland, Wales, and Northern Ireland in particular), will be underprepared.


Climate change related risks from pests, diseases and abiotic threats indicate that diverse mixtures are needed for resilience. Large contiguous single species monoculture blocks are still permitted by the UK Forestry Standard (up to maximum of 75% of a single species can be planted, with no limit set on the size of a contiguous block). 


The effectiveness of UK efforts to reduce global deforestation 


Rates of forest loss are on the rise, and commodity agriculture (including timber) continues to be the leading cause of global forest loss. The destruction and degradation of forests is despite international commitments and pledges, most recently at COP26[6].


The UK is a key consumer market for commodities associated with deforestation, ecosystem conversion and human rights risks. The UK’s global deforestation footprint is assessed in RSPB and WWF-UK’s Risky Business 2017and Riskier Business 2020 reports. The latest Riskier Business report found that the largest share of the UK’s footprint was associated with timber (7.9million hectares), followed by pulp & paper (5.4m ha), beef & leather (3.8m ha), soy (1.7m ha), palm oil (1.09m ha), cocoa (1.06m ha) and rubber (0.2m ha).[7]


The UK is also heavily reliant on products that require extractive industries. Mining and fossil fuel extraction have a huge impact on global deforestation and habitat conversion as well as wider environmental and social impacts. For example, the Democratic Republic of Congo has recently opened licensing rights for oil and gas extraction in parts of the world second biggest rainforest and critically important peatland[8].


The private sector also has a large responsibility for its value chains contributing to deforestation and other impacts and the UK is a globally important financial centre. Analysis has shown that the worlds largest banks (in 2019) invested more than 2.6 trillion USD in sectors governments and scientists agree are the primary drivers of biodiversity destruction[9].



The UK governments JNCC data and experimental statistic presents interactive data on the agricultural commodities that are driving the UKs deforestation footprint and its domestic consumption. This is a welcome resource that can continue to be strengthened and updated. Support should be given to allow for continued collection, analysis, and improvement of data.


The provision in the Environment Act is welcome but there are areas where significant improvements need to be made in the Secondary Legislation for it to deliver a truly world leading and effective set of measures. According to WWF and RSPB’s Riskier Business report, a total of 21.3 million hectares of land is required, every year, to meet the UK’s demand for only seven forest-risk commodities, a third of this being in countries with high rates of deforestation and conversion and poor records of labour rights and rule of law. If the government wants to more than halve its deforestation footprint, then it needs to be more ambitious than what is being currently proposed.

The government's proposals are already limited in scope by just considering illegal deforestation. There is also significant evidence of illegal deforestation risk associated with all forest risk commodities proposed and excluding any would leave a large part of the UK’s illegal deforestation footprint out of scope. We must not make decisions on commodities in scope and delivery timeline based on businesses perceived preparedness to implement the legislation nor on resourcing constraints inside government. The DDO should also apply to the finance industry.

Due to the UK's influence and responsibility to lead by example and the commitment to make this world-leading legislation we should at a minimum match or go beyond the scope and ambition of similar processes in the US and EU.



Strategy and Monitoring: A strategic action plan has not been published. No single stand-alone action can solve deforestation and a coordinated approach is critical.

Legally binding target to end conversion within UK agriculture and forestry commodity supply chains no later than 2030: While the Government signed onto the Glasgow Leaders Declaration, it has not matched this with the recommended legally binding domestic commitment.


Due Diligence Obligation: The introduction of a DDO in the Environment Act is welcome, however the planned system will only assess and mitigate the risks of illegal deforestation (the GRI recommendation extended to environmental and social criteria) and current proposals are limiting commodities in scope (see above). The DDO should also apply to the finance industry.


Sustainable, Healthy diets: further detail and commitment is needed on this recommendation.


Aligning collective global action: The UK mobilised global leaders to sign the Glasgow Leader’s Declaration supported by the Global Forest Finance pledge. It also brought together producer and consumer countries through the FACT Dialogue and Roadmap. These are valuable initiatives, and it is critical that they continue to drive forward and move meaningfully from development stages into implementation and impact on the ground.


Accelerating change and tracking progress: it is unclear how much of this recommendation has been taken forward, but it will need funding and support to ensure that the traceability, monitoring tools, and data are fit for purpose and that mechanisms are in place for data sharing and other supporting infrastructure.




We recommend that at a minimum, all commodities included in scope of the due diligence regulations are brought within the GBS, including those currently not listed like beef and leather (which present the highest deforestation risk embedded in UK consumption according to JNCC analysis).


Working with international partners to tackle deforestation  


The UK demonstrated via the commitments and initiatives launched at COP26 that it can effectively work with international partners to deliver ambitious commitments for global forests. (GLD, mobilising climate finance for forests, FACT, and other). Improvements can be made through:

-          Improving ambition and accountability in the FACT Roadmap – clear targets timelines for implementation and monitoring.

-          Linking the initiatives to the UNFCCC and CBD processes

-          Engage with key stakeholders from across international partners on a regular basis to support implementation and accountability

-          Clarify the connections between these initiatives and other processes such as the CBD and NY Declaration on Forests etc.




The government has showed leadership by announcing and maintaining its commitment to a doubling of International Climate Finance to £11.6 billion over 5 years from 2021 to 2026. New funds such as the Biodiverse Landscapes Fund need to integrate poverty reduction, environmental and climate risks and outcomes from the start. They need to give agency to the people and communities whose lands and livelihoods they will impact, championing the land rights and knowledge of local communities, including Indigenous Peoples. Many millions of people depend directly on the forests that are being destroyed, and many more directly and indirectly from the ecosystems that are being lost. But the UK’s measures can only have positive impact if commitments are backed up by action and enforcement at all levels. This includes strong sustainability criteria in new trade agreements.


For any further information, please contact:

Dr Andrew Weatherall MICFor,

Principal Policy Officer (Woodlands and Policy),



September 2022

[1] Perspective on paper and forest products in 2022: How can CEOs navigate today’s era of transformational change? Online

[2] WWF and RSPB report Riskier Business: The U.K.’s overseas land footprint (2020)  

[3] NRDC, Dogwood Alliance, and the Southern Environmental Law Center (2019) Global markets for biomass energy are devastating US forests.

[4] Estonian Fund for Nature and Latvian Ornithological Society (2020) Hidden inside a wood pellet: intensive logging impacts in Estonian and Latvian forests. Online.

[5] Cut Carbon Not Forests (2022) Biomass Sourcing in Estonia May Violate UK Sustainability Standards for Biomass. Online.