Written evidence submitted by Friends of the Lake District (TPW0022)
FRIENDS OF THE LAKE DISTRICT REPONSE
Friends of the Lake District is an independent charity and the only membership organisation dedicated to protecting and enhancing Cumbria's landscapes. We believe that the Lake District offers some of the most spectacular and precious landscapes in the UK. We welcome the Government’s drive to increase tree planting, this new inquiry and are pleased to be able to comment upon it. As an organisation we own and manage several small woodlands and are part of the Lake District National Park Partnership. We respond to local, regional and national policy issues that influence on how landscapes in the Lake District and wider Cumbria are managed. We answer the questions posed by the inquiry in the order they are set out.
We welcome ambitious tree planting proposals but they would rely upon a number of measures to support them, this is where the realism of any ambitious target would rest. Rather than simply looking at sheer numbers the right trees must be planted in the right places, from a physical and environmental perspective and also from a policy perspective.
The Lake District National Park is also designated as a World Heritage Site (WHS) and this creates an additional sensitivity when deciding where trees should be planted. It is important that the World Heritage Inscription is recognized within the England Tree Strategy- it is potentially the only designation of a scale in England that should have direct influence over the strategy.
Additional tree planting should seek to protect and enhance the outstanding universal values set out by the inscription document. Cultural features should be taken into account in all decisions about where new woodlands are located but the UNESCO designation requires it within the context of the Lake District National Park. The inscription document and the landscape character assessment for the Park should be viewed positively in that they will together guide landowners to where woodlands should be expanded.
New planting should recognize a process called Historic Landscape Character Assessment which is something that the Lake District National Park Authority is currently looking at. This will identify features and areas that are sensitive in landscape terms to planting, in some cases this will include open fell sides which are characteristic of the agro pastoral landscape in the Lake District which led to its WHS designation.
Ambition should be very much rooted in the nature and quality of any planting rather than just sheer numbers. Ancient woodlands within the National Park is a valuable natural and cultural resource, as are the soils associated with them. Expansion from the existing areas would allow the best quality woodland to be created allowing the organisms associated with the soils of ancient woodland to expand to neighboring newly planted areas. New woods planted in isolation from existing woodland can never really achieve this quality.
From a conservation viewpoint we consider there to be a need for more flexible planting densities. This would encourage landowners to carry out more planting in gills and in field margins. The withdrawal of wood pasture from the CS is negative in landscape terms. While creation is still allowed restoration and management is not. Wood pasture is an important means of encouraging woodland within the Lake District.
We believe our Ancient Woodlands should be proportionately buffered with new woodlands following guidance within Managing ancient and native woodland in England details here: https://www.gov.uk/government/publications/managing-ancient-and-native-woodland-in-england and Managing England’s Woodlands within a Climate Emergency: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/872285/Climate_Change_Full_Guide.pdf
We have also questioned in our main response to the England Tree Strategy consultation whether commercial conifer forestry is appropriate at all in a National Park/World Heritage Site.
In the broadest sense the England Forestry Strategy can set the direction, framework and targets but the gap between strategy, actual policy and implementation on the ground is not so strong. In Scotland Regional Forestry Strategies have been used in the past to provide a link between national direction and planning for forestry on the ground. This is something that can be lacking in England. In terms of National Parks, National Park Management Plans could become a means of integrating woodland with other management priorities. In the Lake District the next iteration of the management plan will effectively be the management plan for the WHS so this level could provide an option to balance sensitivities and priorities. National Park plans elsewhere could also perform this function at a level where nature recovery strategies, woodland strategies and cultural landscape strategies should meet.
I am not aware of the existing arrangements for coordination between the four nations. However, Scotland has a very different pattern of landownership to England and this means that larger planting proposals can be put together without the need for agreement and co-ordination between large numbers of smaller landowners.
In terms of plant health and biosecurity Forest Research at Alice Holt provides information and updates on tree disease and biosecurity for all nations- it is important that this work is co-ordinated with a central database to hold relevant information on tree diseases and spread.
There are a lot of different organisations and mechanisms involved in tree planting and simplification would be welcomed.
Targets were perhaps too ambitious. Scotland exceeded their targets, but this was based on less competition for land use and some expansion in commercial forestry together with expanded conservation woodlands. FLD would urge that an emphasis is placed upon measuring the quality of new woodland as well as the broad areas and number of trees planted.
The payments are based on approaches that can be too dense for many potential tree planters. The approach needs to be more joined up with recognition of the value that other forms of woodland can be offer in terms of their contribution to hedgerows, field margins, gill woodland, field corners and wood pasture. A message to farmers in a designated landscape would be not about losing big fields to woodlands but how additional features and enhancement of those features (which are often already of high natural value) can assist a farmers business.
We believe that to some extent this question can be turned back to the questioner in the sense of what are the Government’s priorities and how do they sit with each other an appreciation of the differing areas highlighted above. Mitigating or adapting to climate change has an overarching influence upon all the others and could very quickly change any strategy in terms of what and where we plant new woodlands- increased rainfall and what we anecdotally think are increased wind speeds in our uplands will be factors that influence all of the other priorities moving forward. Consequently, the climate change objective and nature recovery (as it provides part of the solution the first objective) should be priorities but filtered through the protection of natural and cultural heritage- what is in effect required by the WHS designation in the Lake District.
The effects of other legislation on existing woodlands are crucial. Our existing ancient woodlands are incredibly important and the effects of planning policy and legislation are an example of another policy area where they can be damaged or protected and enhanced. There appears to be an approach to try to compensate in some cases for the loss of older woodlands to development by planting new woodlands. However, there is little evidence that new woodlands can compensate for old given the points made above about the importance of woodland soils and the mycelium networks that support those older woodlands.
While there is certainly room for more woodland our key point is that some landscapes such as a WHS/National Park designation will be more sensitive to landscape changes than other areas. We would have concern that any targets for increased woodland cover having a County or regional element and some areas will have more capacity for planting than others. For instance during the Covid 19 pandemic much emphasis has been placed upon people being able to access the countryside near to where they live. A number of England’s cities are surrounded by green belt of varying environmental quality. Investigations should take place as to whether they would be a significant opportunity for new woodlands here while meeting a multitude of objectives from production to nature conservation and recreation.