Woodland Trust                            DEF0040

Written evidence submitted by the Woodland Trust

Call for evidence/terms of reference:



  1. The Woodland Trust is the largest woodland conservation charity in the UK, with over 1,200 sites in its care covering over 29,000 hectares. Access to its woods is free. The Woodland Trust has over 500,000 supporters. The Trust wants to see a UK rich in native woods and trees for nature and people. It has three key aims: i) protect ancient woodland which is rare, unique and irreplaceable; ii) restore damaged ancient woodland, bringing precious pieces of our natural history back to life; iii) plant native trees and woods with the aim of creating resilient landscapes for people and wildlife.


  1. Contact: We’re happy to give oral evidence in addition to this document, please contact Cassie Staines to discuss this or any questions about our written evidence.

Growing the UK timber industry

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

  1. It is clear we need an expansion of different woodland types in the UK, including native woodland and productive plantations, which are not mutually exclusive. We support increasing tree cover for a variety of reasons, including sustainable timber supply. To deliver for future timber needs, the focus must not only be on expansion of new plantations, but also on improving the condition and quality of what we already have and providing the skills, biosecure trees and infrastructure needed to support a sustainable market into the future.  

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?

  1. The UK Net Zero strategy sets out the UK Government’s expectation for increased tree cover for carbon sequestration. It is not clear, however, how this relates to policy objectives concerning increased use of domestic timber or primary reasons behind the establishment of new woodland.


  1. Where the Government is providing grant support, this should be about maximising the public value for taxpayer. This includes delivery of public benefits not already provided by the market, such as biodiversity, climate adaptation, water quality and high-quality access. Timber production is not in itself a public good but more a commercial and profitable crop. Grant support through Environmental Land Management (ELM) or other forestry grant schemes in the other UK countries, should focus on additionality, supporting schemes that can deliver additional environmental benefits. Value for public money will be best delivered by those schemes that provide multiple public benefits, bearing in mind that, where biodiversity is an objective, the evidence shows that native trees in structurally diverse woodland are best able to deliver.[1]


  1. We would not support the use of Government subsidies to support short rotation coppice or short rotation forestry for biomass. Given that evidence suggests that biomass is not carbon neutral and that these schemes very frequently involve fast-growing, non-native trees, we would not see this as delivering significantly in terms of public goods. All UK governments should stop grant support for restocking with non-native trees on ancient woodland sites. For example, in England, the Woodland Tree Health grant currently pays £1,750/ha for restocking with non-native trees on ancient woodland sites[2]. Grant support for natural regeneration of woodland should be maintained, with increased efforts to promote take-up, as this can help to support increased resilience of tree species to threats such as climate change (see below).


  1. Government should focus on providing sufficient support for sustainable UK timber market drivers to underpin expansion and ongoing management, so that timber supply is not reliant on subsidies. These could include:


  1. The Government should also look to identify the most suitable sites for increasing domestic timber production in the planned Land Use Framework to be published in 2023. This should seek to ensure that commercial timber plantations are not sited on priority habitats, including ancient woodland, on high-grade agricultural land, or on land that would be better suited to native, broadleaved woodland. The Land Use Framework could also consider to an extent how land use in the UK impacts on land use and possible deforestation elsewhere in the world.


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?

  1. It is unclear whether sustainable sources of biomass are available to meet the UK projections for the sector. Urgent steps are needed to provide clarity on how sustainability should be defined and the subsequent extent of feedstock supply.


  1. The majority of UK biomass feedstock currently takes the form of wood pellets imported from North America and Europe. The sustainability of this source is questionable for two mains reasons:


  1. Future sustainable sourcing of biomass is therefore predicated on:


  1. Subsequent to the above measures being taken, the potential extent of domestic biomass feedstock should be considered as part of a wider evaluation of future land-use. This should include but not be limited to:


  1. With the UK being the second highest importer of wood in the world (82% of all its timber in 2020) and almost a fifth being in the form of wood pellets, we urge the Committee to recommend the government ends all subsidies for biomass electricity. In 2019 the government spent more than £1.9 billion on biomass subsidies, primarily to burn wood imported from forests in other countries, while in comparison only pledging £640 million for tree planting in the UK.


  1. The carbon tax exemption for biomass generators (estimated at £333m per year by Ember) should be removed given that (i) the weight of evidence suggest that biomass is not carbon neutral and (ii) it provides an unfair tax-break, diverting funds away from other cheaper and guaranteed low carbon renewable sources like wind and solar. (Source: https://ember-climate.org/insights/research/the-burning-question/).


  1. Current subsidies and exemptions provided by the government are providing an artificial and unmerited stimulus to demand for a form of energy production that damages forests and emits more carbon into the atmosphere. Government subsidies and other incentives should be directed towards genuine sources of renewable energy such as solar and wind.


How well is the UK Government managing its plans for the domestic timber industry in tandem with meeting its woodland creation targets and related climate change, biodiversity and other environmental goals?

  1. At UK level, approximately 13 thousand hectares of new woodland have been created annually in recent years[3], with slightly more conifers planted each year than broadleaves since 2016. Most of the productive planting in the UK is being created in Scotland, largely driven by land prices and other socio-economic factors. In England, Wales and Northern Ireland, relatively low levels of any type of woodland are being created, although this is expected to increase in England because of the Nature for Climate Fund.


  1. Although the UK Net Zero strategy sets out the UK Government’s expectation for carbon sequestration from increased tree cover, there is no UK-wide strategy or policy on how and where such expansion should happen. While recognising that land-use and environmental policy are devolved issues, the absence of any UK-level process on policy or reporting makes assessing progress difficult.


  1. The Government should focus its support on well-regulated market mechanisms to underpin a growth in sustainable UK timber supply.  Government grants should be directed towards delivery of public goods such as nature, water, and access.  There is no reason that a grants model focussed on delivery of public goods cannot also support timber production as a by-product/additional private goods benefit for land managers creating woodland.


  1. Currently, the Government uses the UK Forestry Standard (UKFS) to underpin the sustainability of existing and new plantations. Whilst on paper the UKFS has some important requirements on biodiversity, carbon capture, public consultation, historic environment etc, significant parts of it only require sustainable actions to be “considered” rather than actually adopted. There is insufficient current evidence that the UKFS is adopted on the ground beyond management plans and areas in receipt of grants. The UKFS needs stronger requirements and agencies such as Forestry Commission England need sufficient resources to do both supportive handholding to help land managers meet the UKFS and monitoring to show national progress on the ground (beyond paper-based checks).


  1. As the Woodland Trust’s State of Woods and Trees report[4] showed, the condition of the UKs tree cover is in crisis. Whilst woodland cover has slowly increased, woodland wildlife continues to decline. New GB wide evidence (2020) has been published showing just 7% of native woodland in Britain is currently in good ecological condition overall. Breaking this down into the nine priority habitat types (i.e. habitats that have been identified as being the most threatened and requiring conservation action) and two non-priority habitat types (‘non-native conifer plantations’ and ‘other broadleaf’) shows broadly similar results for most of the condition indicators. All woodland types are lacking in deadwood, veteran trees and open space.


  1. A stronger focus of Government targets on headline outcomes (wildlife, woodland condition, access, jobs etc), rather than just area of trees would help to create a better framework for joined up policy making on wood and trees.

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?

  1. The threat of tree pest and diseases is accelerated with the impacts of climate change. Warmer winters are predicted which is likely to contribute to greater overwintering success of pathogens and/or associated insects, leading to increasing disease occurrence and severity. Pest and disease threat can no longer be considered in isolation, instead we must consider this threat in light of future climate trajectories.


  1. Committing to scaling up UK timber production to reduce the reliance on imports from a biosecurity perspective is welcome. Wood borers are the primary threat in wood production and exportation/importation. Current threats from overseas include the emerald ash borer, bronze birch borer, Asian and citrus longhorn beetles and various species of Agrilus all of which are on the plant health risk register. Reducing reliance on imported timber could help to prevent against these threats from arriving onto UK shores. However, it’s also important to ensure the biosecurity credentials are strong in the initial procurement phase of the seeds or saplings to be planted to upscale the UK timber industry. The focus should be on procurement of UK grown stock which is the single most effective biosecurity tool that can be implemented as international trade in plants poses such high risk, even with the border infrastructure implemented. Recent events such as the February 2022 interception of Pine Processionary Moth demonstrate this.


  1. We are awaiting the GB Plant Biosecurity Strategy to be published, which will set the governments vision for plant biosecurity for the next 5 years. This strategy needs to be sufficiently ambitious to counter the threat of imported pest and diseases.


  1. We must urgently see government invest in the domestic nursery sector in order to begin to reverse the reliance on imported seed and stock. Since the 1990s we have seen an increased reliance on international trade in trees, in some cases meaning it’s become more cost effective for nurseries to import saplings and established trees from abroad rather than grow them domestically. This has led to at least 20 serious tree pests and diseases being inadvertently imported into the UK, resulting in the loss of tens of millions of trees. Urgent investment in the form of grant aid, both existing and new avenues should be explored as well as specific focus on ensuring a sustainable seed supply.


  1. We must see government commit to better regulation around plant passporting, specifically improving plant passporting regime to offer clarity and transparency around the origin of material. Strengthen the UK Plant Passporting scheme to prevent plants being sold as ‘UK grown’ when they may not have spent their entire lifespan in the UK. Combatting confusing plant labelling will help to drive the market for domestic production and incentivise nurseries to commit to UK grown.


  1. Improved and meaningful periods of quarantine. It is vital government enforces meaningful periods of quarantine, which are based on scientific evidence rather than economic imperatives.  As research continues into specifics of different pests and diseases, and the science and understanding evolves, this should inform GB’s response to certain pest and diseases.


  1. The evidence base on tree species and provenance for a changing climate is complex, with large gaps and should not be oversimplified.  For example, for conservation objectives, the evidence does not support the need to import southerly provenances of native tree species to support adaptation to climate change, and that this practice carries significant tree health and survival risks. The evidence indicates that native trees have a high capacity to adapt to change if given regular cycles of natural regeneration. However, the evidence case is stronger for use of southerly provenance for those with timber production objectives. Advice depends on site, objectives and rapidly evolving evidence, there is no one size fits all.  Woodland Trust’s position statement on this topic can be found here . However, biosecurity cannot be deprioritised where seeds or trees are imported for resilience reasons. Government must consider scars of the past, where imported stock has resulted in devastation to commercial forestry such as the introduction of great spruce bark beetle (GSBB) and green spruce aphid, both of which decrease the viability of the harvested product.


  1. Over half of all the stocked conifers in GB are sitka spruce[5]. This dominance of a single species leaves the timber sector at high risk given the major increase in new pests and diseases being imported into the UK. For example, Phytophthora ramorum was first discovered in the UK in 2002 on an imported Viburnum plant. Phytophthora ramorum spores can spread over long distances via mists, air currents and watercourses; once it reaches a new environment it can move quickly. International trade in plants has accelerated the movement and allowed the disease to reach new shores that it otherwise would never have been able to. Unfortunately for the UK, we cannot eradicate this disease and must now begin to learn to live with the impacts through management. Before its discovery there were approximately 154,000 hectares of larch planted in Great Britain, 5% of the total woodland area. A major proportion is now lost. There is a need to diversify existing plantations and move away from single species clearfell models. Currently the UKFS allows up to 75% of a single species, which we believe is too high given the risks. There are a wide variety of both native and non-native trees that can already be used in the UK to diversify without introducing new non-natives.


  1. Another consideration and driver for ensuring strict biosecurity is around the arrival of any new pest or disease often results in transport restrictions through demarcated zones as an attempt to prevent the spread. This could very likely be realised during a phase of upscaling forestry and challenge the process if timber cannot be moved due to the regulation. For example, currently in the Southeast there are ongoing restrictions around the movement of susceptible tree material such as spruce wood, bark and branches to control the eight toothed spruce bark beetle. The Trust sees this as another longer-term consideration for ensuring biosecurity is at the heart of the entire supply chain, from seed to source.



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?

Reports suggest mature hardwood trees are being logged in USA, Canada, Estonia, Latvia and Lithuania for export as wood pellets to the UK. The destruction of old growth forest to support the UK biomass industry is unacceptable. This practice is also undermining the ability of other countries to protect 30% of their land and sea for nature; a cause which the UK government has championed.

September 2022

[1] Ennos, R. et al., 2019. Is the introduction of novel exotic forest tree species a rational response to rapid environmental change? – A British perspective. Forest Ecology and Management, 432(October 2018), pp.718– 728.

[2] Woodland tree health grant: Countryside Stewardship - GOV.UK (www.gov.uk)

[3] https://www.forestresearch.gov.uk/tools-and-resources/statistics/statistics-by-topic/woodland-statistics/

[4] https://www.woodlandtrust.org.uk/media/49731/state-of-the-uks-woods-and-trees-2021-the-woodland-trust.pdf

[5] https://cdn.forestresearch.gov.uk/2022/02/pws_2021.pdf