Written evidence submitted by Natural England (TPW0088)




Date: 20th September 2021





Neil Parish MP

Chair of the Environmental Food and

Rural Affairs Select Committee

House of Commons











Written evidence submitted by Natural England (TPW0088)


Dear Neil,


It was a pleasure to provide evidence to the Environmental Food and Rural Affairs Select Committee at the session on 14th September 2021 as part of your inquiry into tree planting and woodlands. I know that the end of our session was curtailed by the division bell and you asked that we write with further observations on some of the issues we covered during our discussion including resources. Please find that outlined below.


Agricultural transition

We noted with interest the point made in relation to competing land use requirements and also those relating to the cultural barriers to tree planting. We would like to add that if we want to see more woodlands and trees in the wider farmed landscape (and indeed elsewhere) we need incentives that act over the long term, and provide economically viable alternatives to some of the less profitable agricultural activities. Payments for the provision of ecosystem services (including biodiversity, carbon capture, water purity, flood risk reduction and nutrient capture) can do this, but presently that market is very immature, driven more by theory than practical possibility, and currently only serves aspects of carbon capture. 


If we are to see a rapid take up of new tree establishment we need new mechanisms to create confidence between sellers and buyers so that investments begin to flow. This in part can be assisted through the more structured quantification of the benefits being created and for these to be certified so as to generate certainty for buyers, such as companies seeking to meet corporate sustainability goals. Natural England is working with Defra colleagues on this challenge and we are confident that a further investment of effort in this area might unlock considerable opportunities. I see an important role for Natural England in in certifying the flow of benefits being generated through woodland expansion (and other aspects of Nature recovery) and in accrediting the market that will generate value for landowners and managers.


Another way that we trees can be incorporated into the agricultural landscape, without the need for repurposing land, is through the wide take up of agro-forestry. This has agricultural benefits and opportunities associated with it but will require outreach and advice as highlighted by witnesses in earlier sessions.



Priority habitats

Ensuring ready access to high quality environmental data is key to ensuring new woodland and trees enhance existing environmental features rather than damage them.  We know there remain gaps in our knowledge of the location of priority habitats, of populations of priority species and of the extent, depth and condition of peatlands.  We have been working hard to address these gaps in a number of ways to enable better, safer, spatial decision making.


With respect to our Priority Habitat Inventories (PHI) current work is focused on developing an improved update process to allow new and updated habitat data to be added more regularly and with great efficiency. We are also actively exploring opportunities for longer term, strategic improvements such as more efficient data management, an improved data submission process and integration with related habitat datasets being created/updated this year, including Living England, the new Ancient Woodland Inventory and the National Habitat Map.


We are working in partnership with the Botanical Society of Britain and Ireland (BSBI) and the Woodland Trust to better identify additional areas of species rich habitat not included on the PHIs by coincidence mapping records of plants reliably found in high quality habitats. This work will be helpful in screening woodland establishment applications but also inform spatial decision making in other strands of the 25 Year Environment Plan including ELM, Net Gain and Planning consultations more generally.


Natural England are also embarking on a comprehensive update of the peat map and associated metadata on peat depth and condition. This multi-year project will ensure more effective targeting of the peat restoration activity so necessary to reduce emissions from degraded peatlands, including those under forestry, so helping them to return to becoming carbon stores.


We have also worked in partnership with Forestry Commission (FC) ecologists to develop and launch new and improved pre-planting survey standards. Where existing data is insufficient to inform a safe decision, it is vital that field survey is undertaken to establish what environmental interest exists so this can inform woodland design plans and the overall suitability of the site for woodland/trees. Under the Woodland Creation Planning Grant FC fund these surveys to establish the presence of peat, breeding waders and priority habitats on and around proposed woodland creation sites. 


Approvals and regulation

On the issue of forestry approvals and the streamlining of regulation Natural England feels that effective regulation should not be portrayed as a blocker to woodland establishment. Instead it must be seen as an enabler to delivering the tree target in a way which is fully aligned with delivery Governments other environmental ambitions, including nature’s recovery.   Without proper care and scrutiny of woodland establishment projects to understand the existing environmental features present on and around the establishment site there is a risk of large scale and incremental environmental damage through inappropriate planting schemes. History has shown that high rates of UK afforestation in the past were achieved without adequate environmental safeguards resulting in harm both to biodiversity and carbon stocks. This harm for example in peatland and lowland heathland restoration is still being rectified today several decades later at significant public expense.


Natural England are working closely with Forestry Commission to ensure that the processes associated with scoping and screening applications under the Forestry Environmental Impact Assessments are completed in as timely and efficient a way as possible.  A key aspect of this work is ensuring that applicants understand the scope and standard of the environmental information they must provide to FC in order for the requisite EIA checks to be completed in a timely way. Delays in the process most often arise because insufficient information is supplied with an application to allow FC to safely assess the likely environmental impact of a scheme. In such cases applicants are asked to provide additional information which may involve completion of new surveys. This has the effect of delaying a decision on the scheme but is clearly not an inefficiency in the process.   Natural England has worked with Forestry Commission to develop best practice survey protocols which provide clarity on the scope and survey standards for the environmental  surveys that applicants can have funded under the Woodland Creation Planning Grant.  This work helps ensure that the survey information supplied with applications for peat, priority habitats and breeding waders, is of the requisite quality and comprehensive, so reducing risk of delays in FC reaching a decision on a given scheme.


Natural England and the Forestry Commission are also working hard to address data gaps (e.g. in relation to limitations in the accuracy of spatial datasets underpinning the FC’s Low Risk map) and develop more effective processes. With improved joint working and more reliable and accessible environmental data we are able to support FC in discharging the existing Forestry EIA Regulatory framework in as efficient a way as possible. Furthermore we are working together to expediate strategic solutions to some key environmental constraints such as guidance on peatlands and on breeding waders. This ensures applicants are clearer about the likelihood of progressing a successful woodland creation application in a given area.



As you are aware overall we have experienced some challenges in relation to resources in the past and therefore very much welcome the decision by Defra to increase Natural England’s budget for 2021/22 following the Spending Review. A £63 million uplift to revenue and capital funding will be used to carry out our statutory duties and to achieve, with our partners, the big ambitions for Nature’s recovery in England. As well as enabling us to invest in our staff, our National Nature Reserves, new technology and a better evidence base it will also mean we can increase our external programme budget as we seek to deliver outcomes through partnerships with others.


But even so there is a lot to do in one short year and we must continue prioritising our efforts to the maximum benefit and create efficiencies in how we operate. The Committee may like to note that we have encapsulated and expressed this is our Action Plan for 2021/21 Natural England action plan 2021 to 2022 - GOV.UK (www.gov.uk) which has been underpinned by four main shifts to the way we work including:


  1. To visibly drive the Nature Recovery Network:


  1. To develop plans for places



  1. To tackle barriers to Nature


  1. To be evidence and evaluation led


There are of course parts of our work which have not yet received the required funding. For example, our responsibilities for marine protection and development, the need to improve the quality of our protected sites and our duties for landscapes and access.


As we noted during our session with you, the Environment Bill, the 30 x 30 Leaders Pledge, ELMS and other measures emerging from strategies on air, water and peat as well as forestry point towards a promising ‘wider toolkit’ of measures at our disposal - all of which will require suitable funding to realise the very promising and encouraging ambitions they represent. Integrating and embedding them across Government and working with partners at a local and national level will be key to unlocking their potential and realising the Governments vision as set out in the 25YEP.


We are optimistic and very much look forward to working alongside our sponsors in Defra to secure the funds needed from public and private sources to continue the public and government’s wish to invest in Nature on a long-term basis. I am pleased to confirm that as part of this year’s uplift in funding Natural England has strengthened our frontline staff capability in relation to delivering more trees as well as peatland restoration, both using the first year of Nature for Climate funding.  We have recently sought funding to sustain, and indeed further grow this capability, in line with government’s increasing delivery ambitions over the coming three years.  Funding of this will of course be determined through the current Spending Review.


I hope that these points provide some helpful additional background for the Committee and as ever should you have any queries or require any further information please don’t hesitate to contact me.


I look forward to seeing you again soon


With all best wishes,