Written evidence submitted by The Wildlife Trusts (TPW0010)


The Wildlife Trusts are a movement of more than 800,000 members, 40,000 volunteers, 2000 staff and 600 trustees, from a wide range of backgrounds and all walks of life. We manage over 2,300 nature reserves for the benefit of wildlife and people. We are providing evidence to this enquiry in our capacity as land advisors and major landowners in our own right. We manage almost 100,000 hectares of land and provide advice to more than 5,000 landowners each year.

Our key recommendation is that a more integrated and spatially strategic approach must be taken to expanding tree and woodland cover in England to deliver multiple benefits and protect open habitats. The Nature Recovery Network, being established under the Environment Bill, should be the key spatial guidance and prioritisation mechanism for expanding and connecting existing woods and establishing new trees and woodlands.

For greater detail, please see our response to the England Tree Strategy consultation document.

  1. Are the UK Government’s targets for increasing forestry coverage, and tree planting, for England and the UK sufficiently ambitious and realistic?

The need to increase tree cover in the UK to address falling biodiversity and rising global temperatures has been recognized in the Committee on Climate Change’s (CCC) net zero advice, which recommends an expansion of UK woodland cover from 13% to at least 17% is needed by 2050[1].

The Wildlife Trusts support the ambition of this commitment, recognising that the UK remains one of the least wooded countries in Europe; in England woodland cover is just 10%[2]. However, the England Tree Strategy consultation document fails to provide any committed targets for woodland expansion in England.

Recent funding announcements suggest that Scotland and Wales are expected to deliver 80% of UK tree planting by 2024[3], which would mean that the England Tree Strategy would direct only a very small proportion of the pledged 30,000 ha of trees per year, and leave woodland cover in England largely unchanged. This is inconsistent with the aims of the England Tree Strategy consultation document for unprecedented afforestation in England, and an ambitious target for tree cover in England is needed which is consistent with the recommendations of the CCC.

Any targets for expansion must not result in perverse outcomes for the environment. Woodland expansion must involve quality, not just quantity. Most importantly, it will require a strategic spatial approach to ensure that new trees and woodland habitats are created in areas where they will benefit nature, people, and the climate.

For trees and woodlands to deliver for nature, areas of tree cover expansion must be informed by a Nature Recovery Network (see Question 2). The Nature Recovery Network should be the key spatial guidance and prioritisation mechanism for expanding and connecting existing woods and establishing new trees and woodlands.

Targets for woodland cover should be set within Local Nature Recovery Strategies, guided by national and regional targets for nature’s recovery, so that they are locally appropriate (see Question 2).

Targets for Open Habitats

Achieving any targets set for woodland expansion must not come at the expense of other habitats of importance for nature. The England Open Habitats Policy (2010)[4] states a target rate of conversion of woodland to open habitat of around 1,000 ha per year (which still maintains reasonable progress on woodland creation given the level of ambition for land-use change). However, the Forestry Commission’s Key Performance Indicators report for 2019-2020[5] show the UK Government is falling far short of this target and has in fact overseen a decrease in open habitats over the past 2 years.

The Government must set out how high-value open habitats, and areas where these habitats could potentially be restored and connected, will be protected from inappropriate tree planting. Protection of habitats must not be limited to their value to capture carbon – habitats such as chalk downland, semi-natural grassland, salt marsh, and heathland have extraordinary value for wildlife and play a large role in carbon capture too[6].

Furthermore, open habitats within woodlands, such as glades, ponds, heathland, and scrub, often provide some of the most biodiverse habitats within woodlands and forests, particularly for rare and declining woodland butterflies such as the small pearl-bordered fritillary and the white admiral[7] and numerous other invertebrates, yet receive no attention within the England Tree Strategy consultation document.

Without a strategic spatial approach to tree cover expansion which recognises the value of open habitats for nature, and comprehensive assessment of existing habitats to inform this approach, these habitats risk continuing to be lost in the drive to increase tree cover to deliver for carbon and timber.

2. Are the right structures in place to ensure that the UK wide target for increasing forestry coverage is delivered?

A Nature Recovery Network

For new trees and woodlands to deliver for nature, areas of tree cover expansion must be guided through a strategic spatial approach informed by a Nature Recovery Network so that they can effectively create more, bigger, better, and more joined-up woodlands, hedgerows, trees and scrub thriving with wildlife and accessible to people, while also ensuring protection of other vital habitats where tree planting may be ecologically damaging.

The Nature Recovery Network should be the key spatial guidance and prioritisation mechanism for expanding and connecting existing woods and establishing new trees and woodlands, providing a mechanism to link woodland expansion to other sectors (such as agriculture and planning/built development).

The Environment Bill includes a requirement for Local Nature Recovery Strategies (LNRS) that cover the whole of England. Each LNRS will include a map of existing areas important for nature (covering protected sites and wildlife-rich habitats) and will identify key opportunities for enhancement – a Local Nature Recovery Network map.

The LNRS, and local Nature Recovery Network maps, should provide the strategic framework for decision making to establish woodland in locations where it will most benefit nature, people, and the climate, allowing for robust and decisive decision making.

Payments for Public Goods

For trees and woodland to deliver multiple benefits, their role in supporting biodiversity, enhancing wellbeing, mitigating climate change, protecting our soils, and reducing the impacts of flooding must be fully recognised and adequately valued.

Financial support for new trees and woodlands should be made available through funding and delivery mechanisms that enable public goods to be delivered in return for public money, which ensure long-term delivery (30+ years) and provide ongoing support to land managers to create and manage high-value woodland habitats and more native trees and shrubs.

The new Environmental Land Management (ELM) scheme can provide this delivery mechanism. Until ELM is operational, the current agri-environment scheme, Countryside Stewardship, should be improved by better incentivising land managers to create and maintain woodlands through simplified application processes and through increased incentives. In addition to this, the Nature for Climate Fund should support land managers to meet government targets on tree planting.

Areas of public funding and private finance should be blended to support landowners to provide a full range of public services and natural capital, and to provide woodland managers with a regular financial return.

Government schemes for woodland creation should be guided through local Nature Recovery Maps, and incentives for planting new areas of woodland must be allocated and valued within Local Nature Recovery Strategies to ensure the right tree is planted in the right place.

Support for Alternative Woodland Creation Approaches

Forest ecosystems are diverse and dynamic environments which are made up of complex ecological networks and relationships, both above ground and within the soils, between a huge array of diverse species. Natural regeneration of woodland should be the preferred method for increasing tree cover where it is possible to create these ecosystems, augmented by the planting of locally native woodland species where necessary from nurseries of local-provenance stock.

Alternative woodland creation approaches, such as natural regeneration, direct seeding, and low-density woodland planting, must receive support through woodland creation incentives. The woodland habitats created through these means are more resilient, more biodiverse, and support woodland species which do not succeed in plantation woodlands.

Work done by Cheshire Wildlife Trust has found that low density planting is far better for biodiversity than dense planting, especially in upland settings where planting is predominantly focussed on semi-improved and unimproved acid grassland cloughs and gullies. A greater percentage of open space allows the grassland interest to persist and, alongside tree and scrub cover, provides excellent habitat for a wide range of invertebrates, which in turn support other species within these ecosystems.

Where woodland creation requires supplementary planting, the Wildlife Trusts believe any tree planting material must be sourced and grown within the UK and be of locally native species and local provenance. However, the current capacity of tree nurseries in the UK is not sufficient to supply the demand which is needed to meet the UK Government’s targets of expanding woodland by 30,000 ha/yr from 2025. Therefore, if alternative methods of woodland expansion are not supported then foreign import of planting material will be required to meet this demand.

Importing foreign material carries the risk of importing pests and diseases which impact tree health, which present a serious barrier to delivering ambitious woodland expansion targets in England and the UK. Ash dieback Hymenoscyphus fraxineus is a single example of an imported non-native disease which could wipe out 95% of the UK’s ash trees, one of the most common species in our landscape. Where possible, natural regeneration of woodland should be favoured over planting, which removes the risk of transporting invasive alien pests and diseases through foreign import channels.

5. In relation to increasing forestry coverage in England, what should the Government be trying to achieve?

The following policy objectives should be prioritised by the Government:

  1. Promoting biodiversity and nature’s recovery

A Nature Recovery Network

New areas of tree cover expansion must be guided by a Nature Recovery Network (see Question 2) so that they can effectively create bigger, better, and more joined-up treed and wooded habitats, thriving with wildlife and accessible to people, while ensuring protection of other vital habitats where tree planting may be ecologically damaging.

Natural Woodlands

Natural regeneration is the best way of creating new woodlands for wildlife and expanding ancient semi-natural woodland by allowing complex ecosystems to develop. Not only is it more cost effective than planting up sites, trees established by regeneration are more likely to be better adapted to local climatic and environmental conditions and will result in woodlands with a more natural species composition.

Brampton Wood is the second largest ancient woodland in Cambridgeshire, owned and managed by The Wildlife Trusts for Bedfordshire, Cambridgeshire & Northamptonshire. The entire wood was once clear felled and has since naturally regenerated. Now classed as a SSSI providing important woodland habitat to a range of native species, it provides clear evidence for the benefits and effectiveness of using natural regeneration to create new areas of woodland.

To be successful, areas of natural regeneration must be strategically located connected to existing areas of high-quality native woodland habitat using Local Nature Recovery Maps. This provides areas of regeneration with the necessary seed banks and species assemblages required to develop diverse and resilient woodland habitats.

Where woodland creation is not located connected to areas of native woodland or on sites with an existing seed source, planting should be of low density and high biodiversity to kick start the natural regeneration process. This can have particular benefits within urban areas, where natural regeneration opportunities are more limited due to the fragmented nature of land and its multiple uses and ownership. Oak Hill Wood in East Barnet, London, is just one example where London Wildlife Trust has expanded existing woodland within an urban landscape utilising natural regeneration.

A critical element of successful natural regeneration of woodland habitats is the restoration of ecosystem services, and the reintroduction of key species which protect and enhance new woodland regeneration through the control of damaging grazing activity, seed dispersal, soil turnover, and opening up of the woodland canopy. The Wildlife Trusts have championed the reintroduction of native species to restore critical ecosystem services through projects such as Project Pine Marten, the River Otter Beaver Trial, and the Wilder Blean project.

  1. Improving human well-being and health

New areas of woodland expansion need to be close to where people live to deliver the many values of trees and woods to the people who need them most. Access to nature is still worse for people in deprived areas & those with higher proportions of minority ethnic groups[8]; creating access to good-quality green space in the most deprived communities leads to improvements in physical health and psychological and social wellbeing[9].

Creating new woodlands and Community Forests close to these communities will ensure that woods are connected with people who need them most, providing these communities with opportunities to exercise, learn, and engage with nature on their doorstep. The Nature Recovery Network should be the key spatial guidance and prioritisation mechanism for expanding and connecting existing woods and establishing new trees and woodlands in areas where they will provide the greatest benefits.

  1. Mitigating or adapting to climate change

Continuous stands of native woodland habitats have been shown to offer the greatest long-term solution to storing carbon in forests and provide irreplaceable habitat for woodland wildlife[10]. Therefore, the Government must prioritise protecting, restoring, and expanding native broadleaved woodland, or risk compromising the capability of woodland habitats to effectively fight the climate crisis.

Commercial forests will undoubtedly play an important role in tackling the ecological emergency and the climate emergency, but they cannot substitute the habitats provided by native broadleaved woodland and early successional scrub. However, commercial forestry can help to protect and improve existing areas of native woodland if planted in the right place, and can enhance biodiversity if sympathetic management practices are adopted.

The Wildlife Trusts do not see the planting of non-native woodland species within native forests as a solution to tackling the climate crisis, and are concerned that suggestions to introduce species from southern latitudes to UK woodlands to improve their resilience significantly risks compromising national and local biodiversity and importing invasive non-native pests and diseases. Protecting, expanding, and connecting the UK’s areas of native woodland through a Nature Recovery Network facilitates the transfer of existing genetic diversity within woodland populations and allows these habitats to be more resilient to a changing climate.

6. Are the right policies and funding in place to appropriately protect and manage existing woodlands in England? How will prospective changes to policy and legislation effect this?

While new trees and woodlands are needed to address the nature and climate emergencies, the UK’s existing woodland habitats must be better protected and managed for nature first. The latest figures from the Forestry Commission show that only 7% of native woodland area is in favourable condition, with the greatest contributing factor to this being poor historic management of woodlands[11]. The Wildlife Trusts would expect the Government to set an ambitious target for improving the proportion of existing woodland in favourable ecological condition as a priority.

Trees and woodlands in the UK must not be managed for carbon storage at the expense of biodiversity. Any incentives to increase management of woodlands must be holistic and recognise the wide range of ecosystem services provided by different woodland habitats and open habitats within woodlands, such as glades, ponds, and heathland, which often provide some of the most biodiverse habitats within woodlands and forests.

There is huge potential for the nation’s forests to be used as an exemplar to demonstrate this more ecological approach, including expanding the area of new native woodland on the public forest estate and expanding the estate itself through land acquisition.

Restoration of ‘Plantations on Ancient Woodland Sites’ (PAWS) should be a priority to re-establish areas of biodiversity-rich ancient woodland. This has long been an aim of Government policy, but the level of restoration has been far below that needed for these habitats to recover.

Trees in urban environments must be better protected so they can continue to play vital roles in providing clean air, noise reduction, flood alleviation, and carbon storage. The value of trees as critical elements of green infrastructure must be recognised and the benefits they provide better factored in to economic decisions that may affect them. Sheffield & Rotherham Wildlife Trust have worked closely with a number of key local stakeholders in the development of the Sheffield Street Tree Partnership which sets out a working strategy that recognises the multiple benefits of street trees, as well as outlining new ways of working to ensure the city’s network of street trees is well maintained and sustained for the future.


October 2020

[1] Net Zero Technical Report (2019) Committee on Climate Change https://www.theccc.org.uk/publication/net-zero-technical-report/

[2] Forest Research Woodland Statistics https://www.forestresearch.gov.uk/tools-and-resources/statistics/statistics-by-topic/woodland-statistics/

[3] Spring Budget 2020, HMT https://www.gov.uk/government/publications/budget-2020-documents/budget-2020#budget-report   

[4] When to convert woods and forests to open habitat in England: Government policy https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/713805/england-open-habitats-policy-march-2010.pdf

[5]Forestry Commission Key Performance Indicators Report for 2019-20 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/901578/Forestry-Commission-Key-Performance-Indicators-2019-20-.pdf

[6] The Wildlife Trusts (2020) Let Nature Help: How nature’s recovery is essential

for tackling the climate crisis https://www.wildlifetrusts.org/sites/default/files/2020-06/Let%20Nature%20Help.pdf

[7] Robertson, P. A., Clarke, S. A., & Warren, M. S. (1995). Woodland management and butterfly diversity. In Ecology and conservation of butterflies (pp. 113-122). Springer, Dordrecht.

[8] Marmot, M., Allen, J., Boyce, T., Goldblatt, P., & Morrison, J. (2020) Health equity in England: The Marmot Review 10 years on. London: Institute of Health Equity

[9] Bragg, D., Wood, C., Barton, J., & Pretty, J. (2018) Wellbeing benefits from natural environments rich in wildlife. A literature review for The Wildlife Trusts by the University of Essex


[10] Crane E, (2020) Woodlands for climate and nature: A review of woodland planting and management approaches in the UK for climate change mitigation and biodiversity conservation. Report to the RSPB.

[11] NFI Woodland Ecological Condition, Forest Research https://www.forestresearch.gov.uk/tools-and-resources/national-forest-inventory/what-our-woodlands-and-tree-cover-outside-woodlands-are-like-today-8211-nfi-inventory-reports-and-woodland-map-reports/nfi-woodland-ecological-condition/