Written Evidence submitted by The Forest Stewardship Council (FSC)(SH0022)

Introduction to FSC UK

  1. The Forest Stewardship Council (FSC) is a global, not-for-profit organisation dedicated to the promotion of responsible forest management worldwide. Our 2050 vision is that a new forest paradigm is realised, where the true value of forests is recognised and fully incorporated into society worldwide, and our mission is to promote environmentally appropriate, socially beneficial, and economically viable management of the world’s forests.
  2. FSC operates an independent, third-party forest management and chain of custody certification scheme, to enable businesses and consumers to make informed choices about the forest products they buy, and create positive change by engaging the power of market dynamics. The detail of FSC’s vision of responsible forest management is expressed through our international Principles and Criteria, which form the basis for nationally adapted forest stewardship standards.
  3. FSC UK (https://uk.fsc.org/) is the national office of the Forest Stewardship Council in the United Kingdom. FSC UK is independent of FSC international. It sets forest management standards for the UK by inputting into the UK Woodland Assurance Standard (UKWAS), promotes the FSC system, and provides an information service. FSC UK (Ephesea UK) is a charity registered in England and Wales (No. 1130203) and a non-profit making company limited by guarantee registered in England and Wales (No. 06792524).

General comment on the scope of the inquiry

  1. FSC UK notes that the terms of reference for this inquiry refer to “all soils” and to “all landowners/land managers”. We also note that some of the inquiry questions are focussed on “agricultural land” and “the wider food and agriculture sector”. While this focus is entirely understandable given the nature and scale of the issues related to farming, we urge the Government not to neglect other soils. Forest soils are hugely significant in tackling the biodiversity and climate crises; see, for example, the estimates for forest soil carbon in Forestry Statistics (https://www.forestresearch.gov.uk/tools-and-resources/statistics/forestry-statistics/).

FSC’s approach to protecting soils in UK forests

  1. FSC’s international Principles and Criteria (https://connect.fsc.org/document-centre/documents/resource/392) are the foundation of our system. Through Principle 6, which requires certificate holders to maintain, conserve and/or restore environmental values, which include soils, and through Principle 10 on the implementation of management activities, FSC forest management certification includes strong protections for forest soils. Specifically, Criteria under Principle 10 require certificate holders to avoid damage to soils through fertiliser use (Criterion 10.6), and to manage infrastructural development, transport activities and silviculture so that soils are protected (Criterion 10.10). Certificate holders are also required to prevent, mitigate, and/or repair damage to environmental values when pesticides are used (Criterion 10.7).
  2. The international requirements in the Principles and Criteria are implemented at the national level through UKWAS (https://ukwas.org.uk/). The currently effective version, UKWAS 4, includes requirements for woodland owners/managers to take measures to maintain and/or enhance long-term soil functions (requirement 2.4.1), for planning of woodland operations to include taking measures to protect soils (requirement 3.1.2), for timber harvesting to avoid damage to soil during felling, extraction and burning (requirement 3.2.1(b)), and for owners/managers to identify and manage areas and features of critical importance for erosion control (requirements 4.5.1(a) and (b)). There is also guidance directing owners/managers to take account of soils in various contexts, including whole tree harvesting or stump removal (requirement 3.2.3). The revised version, UKWAS 5, which, it is hoped, will become effective later this year, introduces further references to soil and soil carbon, including requirements for planning and implementing ground preparation and drainage works to avoid or minimise soil and soil carbon losses (requirement 2.6.2), and using techniques for ground preparation that create the minimum amount of soil disturbance but are still adequate to ensure successful tree establishment (requirement 3.2.5).
  3. Crucially, conformance to these requirements is assessed by independent certification bodies. FSC forest management certification is voluntary, but there are strong economic and societal drivers. According to Forestry Statistics 2022 (https://www.forestresearch.gov.uk/tools-and-resources/statistics/forestry-statistics/), 1.42 million hectares of UK woodland (44 %) are independently certified.
  4. While the requirements in UKWAS to protect soils apply to all FSC forest management certificate holders in the UK, it is now possible for woodland owners/managers to go even further in demonstrating positive impacts on soil conservation thanks to FSC’s Ecosystem Services Procedure (https://uk.fsc.org/forest-management-certification/ecosystem-services-verification). The procedure uses a theory of change approach to link management activities to impacts. For soil conservation, the possible impacts which can be demonstrated are maintenance of soil condition (Impact ES4.1), restoration/enhancement of soil condition (Impact ES4.2), and reduction of soil erosion through reforestation/restoration (Impact ES4.3). As with all FSC requirements, the crucial aspect is that conformance is independently audited, and in the case of ecosystem services claims the impacts must be validated or verified by certification bodies such as the Soil Association.

How can the Government measure progress towards its goal of making all soils sustainably managed by 2030? What are the challenges in gathering data to measure soil health and how can these barriers be overcome?

  1. We believe that Government should recognise the value of independent, third-party certification systems which require landowners to adopt good practice in relation to soil management. Given the protections which FSC forest management certification affords to soils, we believe that it provides a clear indicator of responsible soil management, just as FSC certification is used to demonstrate the extent of sustainable forest management in UK national and international reporting, including on the Convention on Biological Diversity. In particular, FSC ecosystem services claims have the potential to demonstrate independently verified positive impacts on soil conservation. FSC UK encourages the Government to make use of these existing, credible mechanisms for demonstrating responsible management.

Do current regulations ensure that all landowners/land managers maintain and/or improve soil health? If not, how should they be improved?

  1. The forest sector in this country relies on the UK Forestry Standard (UKFS, https://www.gov.uk/government/publications/the-uk-forestry-standard), as the Government’s approach to sustainable forestry, to summarise legal requirements on a number of subjects, including forests and soil. It is clear from the current (2017) version of UKFS that there are no legal requirement relating directly to soil protection, only good forestry practice requirements, and that the few legal requirements which have been identified relate to waste management and the control of pesticides. We are not aware that the revision of UKFS, currently underway, has identified any further relevant legal requirements.
  2. The good forestry practice requirements in UKFS do also carry weight, of course, as they “complete the framework for the exercise of the regulatory powers of the forestry authorities in the UK and for the payment of grants”. They currently address the protection or enhancement of the quality of forest soil, the maintenance of forest soil fertility levels, the planning and management of forest operations to avoid damage to soil structure and function, and the avoidance of adverse effects to the environment adjacent to forests effects due to water run-off, contamination or erosion arising from forest management practices. These are all important requirements; the question is, how well is compliance monitored and enforced? Our understanding is that there is a very limited staff resource for forestry authorities to monitor compliance in the field by felling licence and grant applicants. We are not aware of any active monitoring of compliance in woodlands where there is no felling licence or grant.
  3. FSC UK supports a robust regulatory environment, in which impactful regulations are subject to meaningful enforcement. In the case of UK forest management, given the limits of the soil requirements in the UKFS and our understanding of the monitoring and enforcement regime, we believe that we are still some way from achieving this. At the very least, better resourced monitoring and enforcement of the existing limited requirements would be welcome. In the meantime, while voluntary FSC forest management certification cannot take the place of robust regulation, it can play some role in filling regulatory gaps by providing for independent, third-party checks of conformance with standards in the field.

Will the standards under Environmental Land Management schemes (ELMs) have sufficient ambition and flexibility to restore soils across different types of agricultural land? What are the threats and opportunities for soil health as ELMs are introduced?

  1. As per our general comment, while FSC UK understands this focus given the nature and scale of the issues related to farming, we urge the Government not to neglect forest soils. We have no specific comments in relation to agricultural land.

What changes do we need to see in the wider food and agriculture sector to encourage better soil management and how can the Government support this transition?

  1. As per our general comment, while FSC UK understands this focus given the nature and scale of the issues related to farming, we urge the Government not to neglect forest soils. We have no specific comments in relation to the food and agriculture sector.

What does the UK Government need to do to tackle other stressors on soil health such as soil contamination?

  1. While issues such as diffuse pollution (addressed in UKWAS 4 requirement 3.7.1) are important in forest management, we would draw particular attention to the issue of pesticide usage. Pesticide usage in the UK forest sector is a fraction of that in agriculture, but that does not mean that we should be complacent about potential impacts. FSC Criterion 10.7 requires certificate holders to use integrated pest management and silviculture which avoid, or aim at eliminating, the use of chemical pesticides. Certificate holders may not use any chemical pesticides prohibited by FSC policy. When pesticides are used, certificate holders must prevent, mitigate, and/or repair damage to environmental values and human health. The short-term objectives of our Pesticides Policy (https://connect.fsc.org/document-centre/documents/resource/208) are to promote best practices to minimise associated risks to human health and the environment when using chemical pesticides, to reduce the overall volume and number of chemical pesticides in use, and to eliminate the use of the most hazardous chemical pesticides. The long-term aim of the Policy is to eliminate the use of chemical pesticides in certified forests. FSC’s requirements in relation to pesticides are implemented in section 3.4 of UKWAS 4, and are expected to appear in substantially revised form in UKWAS 5. If approved, the revised UKWAS requirements will strengthen the focus on integrated pest management, and FSC UK encourages the Government to do the same in both forest and non-forest settings; to concentrate on regulating for and supporting practices which avoid the need for pest control in the first instance. We also urge the Government to strengthen, or at least maintain, the existing regulation of pesticides, particularly in relation to any chemical identified by FSC as a Highly Hazardous Pesticide (https://connect.fsc.org/document-centre/documents/resource/315).


February 2023