Written evidence submitted by the Woodland Trust
The Woodland Trust welcomes this inquiry and the willingness of the Environmental Audit Committee to examine progress made by Government against the entire breadth of environmental areas identified within the NAO’s analysis, and your proposal to use this to identify policy levers which could be used to secure much needed environmental improvements.
Our submission reflects our position as the UK's leading woodland conservation charity and focuses broadly on forestry policy, as well as touching on the related issues of biodiversity, soil, air pollution, flooding and water and air quality. Our written evidence is augmented by a number of policy papers which are referenced appropriately within our response.
- Executive Summary
1.1. Trees play a vital role in delivering an ecologically resilient landscape and evidence shows that tree planting can have major beneficial outcomes for landowners in terms of improving water quality and quantity, preventing soil erosion and flooding, and providing shelter and shade for crops and livestock. Other important benefits include improving air quality, general mental and physical wellbeing, and improving biodiversity. We believe Government needs to do much more to harness these benefits further.
1.2. Although we welcome the Government’s long-term target to increase woodland cover in England from 10% to 12%, as articulated in their Forestry Policy Statement[1], it’s very clear that annual planting rates remain far too low to achieve this welcomed ambition.
1.3. There is a lack of transparency about what the Woodland Cover Statistics actually mean in practice. Woodland losses are barely referred to in the statistics, and are not being recorded adequately, making their interpretation in terms of overall woodland cover impossible to access. It is vital losses are recorded if any perceived progress towards the aspiration is to be accurately measured and achieved.
1.4. There is no systematic and accurate recording of ancient woodland loss, despite the recognition that this is an irreplaceable habitat of great importance. If recognition of the importance of ancient woodland is anything more than hollow rhetoric, then we believe Government must find a way to record and report losses when they occur.
1.5. Our woods and trees continue to face a battery of assault from climate change, pests and disease, and development. At a time when there is an urgent need to build environmental resilience by increasing planting rates; it is clear that the right incentives are not in place.
1.6. Whilst engineered flood defences will continue to be needed to prevent inundation of many places, we recommend that Government commit to including strategically located trees and woodland within the mix of potential solutions to tackle and reduce flood risk.
1.7. There is a real and significant cost now to the whole of society and to the natural environment from soil erosion. This can be reduced by integrating non-crop habitat into farming systems.
- The Government’s tree planting rates fail their ambition
2.1. Analysis undertaken by the National Audit Office, quoted in the Terms of Reference for this Inquiry[2], illustrates the massive fall in tree planting rates in England over the past two decades. Over this period annual planting has declined from over 6,000 hectares in 2000 to only 2,500 hectares in 2012. This is clearly illustrated in the following table, reproduced directly from the NAO’s report.
Reproduced from NAO’s Briefing for the Environmental Audit Committee
2.2. The Government’s Forestry Policy Statement, which incorporated their formal response to the Independent Panel on Forestry in February 2013, included an important commitment to improve England’s tree cover from the current level of 10%. The report noted that the current rate ‘could be accelerated... to achieve 12% woodland cover by 2060, an average planting rate of 5,000ha per year, provided private investment in woodland creation increases in line with our expectations.[3]’
2.3. We are very disappointed to see, once again, that the latest statistics from the Forestry Commission continue to show that the rate of tree planting is far lower than is needed to meet this important ambition. The latest figures show that only 3,300 hectares of new woodland was planted in England in the 2013-14 planting season[4]. Whilst this represents an increase of 700 ha on the 2012-13 figure of 2,600ha, it is still far short of the target needed to achieve the stated ambition in the Government’s Forestry Policy Statement.
2.4. A further concern we have is that the Department of Environment, Food and Rural Affairs has committed to provide public funding for a maximum of just 2,000 hectares in the 2015/16 planting season[5] leaving the private sector to fund the additional 3,000 hectares required. There is no historical precedent for this level of private sector funded planting and we do not believe the Department has done enough to facilitate the step change in behaviour to achieve this increase.
2.5. We recommend that Government should urgently review the stated approach towards delivering their new planting ambitions and their belief that this can be achieved without the support of the tried and tested grant aid mechanisms available via the Rural Development Programme. We call on the Government to commit to temporary funding arrangements whereby they continue to use grant funding for tree planting to secure the agreed target figure of 5,000 hectares per annum.
- Better designed grant schemes could deliver much greater benefit
3.1. In order to effectively deliver the overall objectives of the New Environmental Land Management Scheme (i.e. biodiversity gain, improvements to water quality and building our response to climate change) we believe that an approach must be adopted which fully embraces the Lawton Principles[6].
3.2. Much of the activity in relation to woodland creation will need to be delivered on land that is part of farmed landscapes. So an approach that is consistent with agricultural systems is critical. The new scheme must be flexible enough to deal with these issues and opportunities where they arise. So buffering and extending ancient woods, and restoring PAWS, will be valuable wherever they occur – although concentrations of these features in particular landscapes suggests that some targeting may be appropriate. In addition, woodland interception strips to deal with water quality issues will need to be at a scale and location that does not compromise farming activity.
3.3. In relation to the above, the current suggestion that a minimum scheme size of 5 ha will apply (for each individual holding/applicant) poses a very serious barrier to delivering the scheme’s core objectives from a woodland perspective. Farmers in particular are unlikely to want to take 5 ha out of production and consequently may fail to take up tree planting opportunities. Work we have been doing with farmers (inc with Harper Adams) on demonstration projects makes a good case for the environmental and economic benefits of small scale woodland creation integrated into farming systems precisely for the purpose of delivering wildlife and water benefits.
3.4. Whilst the desire to move to a 5ha minimum area may in theory offer some costs savings (i.e. to deliver fewer larger schemes may be cheaper) it runs the risk of seriously compromising the scheme’s core objectives and we feel it must be reconsidered. Whilst there might be strong case for not wishing to fund the creation of a new isolated wood of less than 5 ha in size because of the limited befits it offers in terms of Lawton Principles, a scattering of smaller woods in the 1 -5 ha size range will very effectively deliver the biodiversity and water benefits if carefully located – we certainly see a role for us in promoting and supporting this kind of creation activity but grant availability is crucial to success. Planting and woodland creation below 5 ha without grant is very unlikely to proceed as farmers will lose their Basic farm Payment on such areas.
3.5. We recommend that Government urgently reviews their proposals for the New Environmental Land Management Scheme and reconsiders allowing for the creation of smaller woods which will more effectively deliver both biodiversity and water benefits.
- Better oversight of woodland gains and losses are needed
4.1. A further concern we have with the Woodland Cover statistics is their lack of transparency. To accurately report Woodland Cover, these statistics would need to also accurately measure loss. However, woodland losses are barely referred to in the statistics and these are not being recorded adequately, making their interpretation in terms of overall woodland cover impossible to access. We believe it is vital that losses are recorded if any perceived progress towards the aspiration is to be accurately measured and achieved.
4.2. Aligned to this, we have a longstanding concern that there is no systematic and accurate recording of ancient woodland loss, despite the recognition that this is an irreplaceable habitat of great importance. Whilst Natural England does manage the Ancient Woodland Inventory this does not account for loss and is classed as ‘provisional’ because it is subject to review and update. A further significant shortcoming of the inventory is that it only recorded areas of ancient woodland greater than 2 ha. As a result smaller areas were unrecorded and are subject to greater threat than those within the inventory with very limited protection under the planning system.
4.3. If recognition of the importance of ancient woodland is anything more than hollow rhetoric, then we believe Government must find a way to record and report losses when they occur. The planning system is intended to regulate development and use of land in the public interest. We believe that the public interest is not served when we continue to lose that which is irreplaceable. Unless there is a robust and open system of recording losses the scale of the problem cannot be known and the measures to tackle it will remain elusive
4.4. We recommend that Government complete and extend the Natural England Ancient Woodland Inventory and address the information gap further by developing a central database and analysis of the amount of ancient woodland being lost year on year. We also recommend a revision of the Woodland Cover Statics to include an accurate assessment of woodland loss.
- Government needs to look beyond concrete solutions to flooding
5.1. Recent flooding has highlighted the importance of land use in either contributing to or mitigating flood risk. In particular the suggestion that trees might play an important role in helping reduce flood risk. In 2012 The Woodland Trust and Coed Cymru, on behalf of the Pontbren Farmers[7], commissioned a review of the scientific evidence and the story of how, over the last 15 years, Pontbren farmers have transformed their farms through hedgerow restoration, new hedgerows and shelter belts. These not only created a financially and biologically more sustainable farmed landscape but also reduced flood risk downstream.
5.2. The Pontbren studies demonstrate that planting tree belts across the slopes led to increased infiltration of water into the soil - more than 60 times that of neighbouring sheep grazed pasture without tree belts. This is as a result of the improved soil structure and effect of tree roots. When this effect was modelled across the catchment the result was a potential reduction in peak stream flows of as much as 40%. This is clear evidence that integrating trees into our upland farms will play a part in reducing flood risk downstream.
5.3. This farmer led initiative also showed the importance of an intimate knowledge of the land in designing and siting tree belts. The farmers knew where shelter was needed, but they also knew where runoff was a problem, where land lay wet for much of the year and those areas prone to erosion. They have managed simultaneously to improve the resilience and sustainability of their farms whilst delivering public benefits of improved water quality and flood mitigation. In addition, the new planting and restored hedgerows and woodland have delivered biodiversity benefits and helped store carbon.
5.4. In Cumbria the Woodland Trust has been working with Natural England and the Rivers Trust to bring together people and resources to look at how to manage trees and woodlands in the uplands to benefit rivers. By reducing grazing and allowing taller vegetation and tree planting more water will be retained in boggy areas and percolate deep into the soil. This will mean slower run off and less sediment. The trees should also help river shading which will moderate water temperature, important in successful spawning of fish and for other river wildlife.
5.5. Modelling undertaken by Forest Research show that woodland strategically located on floodplains can mitigate large flood events by absorbing and delaying the release of flood flows. Research based on the River Cary in south-west England suggested that a 2.2km reach of floodplain woodland could increase flood storage by as much as 71%, delaying the flood peak progressing downstream. Further work at Pickering as part of a project called Slowing the Flow has shown how tree planting and other natural measures can help reduce flooding. This suggests there are opportunities for creating strategically placed floodplain woodland to alleviate downstream flooding, particularly the increased risk associated with climate change.
5.6. Whilst engineered flood defences will continue to be needed to prevent inundation of many places, we recommend that Government commit to including strategically located trees and woodland within the mix of potential solutions to tackle and reduce flood risk. Woods and trees also improve water quality, contribute to biodiversity conservation, store carbon and help support more sustainable farming practices. It is these multiple benefits which make it such a compelling option – for farmers as well as Government, its agencies and the many communities impacted by flooding.
- Government needs to act now to tackle the significant costs of soil erosion
6.1. The series of prolonged wet periods in recent years, not least the torrential rain of last winter, have highlighted vulnerability of UK soils. Around 2.2 million tonnes of top soil are eroded annually in the UK – in winters such as the one that has just passed the loss would have been much greater.
6.2. For farmers losing topsoil is fundamental – soil provides the medium and the nutrients which support primary production. Erosion loss damages soil structure and washes away vital (and expensive to replace) nutrients and organic matter. It can require repeat operations because of lost seed beds or damaged crops, brining a real and substantial cost to the farm. Developments in agriculture over the last 50 years, such as increase in field size, use of heavier machinery, changes to cropping, and loss of hedgerows have increased the risk of soil erosion. Climate change and predicted increase in frequency of severe weather is likely to magnify the impact.
6.3. Erosion also leads to sedimentation and contamination of streams and rivers, damaging fisheries and wildlife, and increasing water treatment costs. Although soil sediment enters water bodies through natural erosion, around 70% of soil sedimentation is estimated to come from agricultural sources[8]. Erosion contributes to the turbidity of water (the cloudiness caused by suspended soil particles) affecting the gills of some fish and their ability to feed. Sediment on gravel beds affects spawning of fish and impacts on economically important fresh water fisheries. Many invertebrates are also adversely affected by sedimentation.
6.4. An estimated 25% of the phosphates and 50% of nitrates in rivers are from agricultural sources[9]. Faecal indicator organisms (FIO) such as E.coli, associated with manures, can also contaminate water supplies. Enrichment of water bodies with high concentrations of nutrients leads to eutrophication – excessive growth of algae which, as it dies and decomposes, depletes the water of available oxygen, causing the death of fish and other wildlife. Pollution from agriculture is a major cause of failure of river catchments under the Water Framework Directive.
6.5. Whilst changing agricultural practices can be an important first step in reducing erosion, some residual issues will persist. Targeted tree planting is one of the ways to mitigate runoff and pollution from agriculture. Where they are present, existing hedgerows and shelter belts may already be helping to reduce impacts. However planting trees and the creation of tree belts with their associated vegetation incorporated into farming systems mitigate pollutants and safeguard water resources. Trees and woodland intercept and capture pollutants, increasing water infiltration rates and slowing the flow of transported sediments.
6.6. There is a real and significant cost now to the whole of society and to the natural environment from soil erosion. The longer term costs of failure to tackle soil erosion are even more significant. The Woodland Trust calls upon Government to take a critical look at the way in land management contributes to soil erosion and how to integrate non-crop habitat – trees, shelter belts, other habitat – in to farming systems in ways which can support production while also helping to reduce the risk of erosion.
- Recommendations for Government
7.1. The Woodland Trust has identified a small number of recommendations that we would like the Committee to consider which resolve many of the concerns we have highlighted above.
7.2. Recommendation 1: Government should urgently review the stated approach towards delivering their new planting ambitions and their belief that this can be achieved without the support of the tried and tested grant aid mechanisms available via the Rural Development Programme. We call on the Government to commit to temporary funding arrangements whereby they continue to use grant funding for tree planting to secure the agreed target figure of 5,000 hectares per annum.
7.3. Recommendation 2: Government should complete and extend the Natural England Ancient Woodland Inventory and address the information gap further by developing a central database and analysis of the amount of ancient woodland being lost year on year. We also recommend a revision of the Woodland Cover Statics to include an accurate assessment of woodland loss.
7.4. Recommendation 3: Government should urgently reviews their proposals for the New Environmental Land Management Scheme and reconsiders allowing for the creation of smaller woods which will more effectively deliver both biodiversity and water benefits.
7.5. Recommendation 4: Government should commit to including strategically located trees and woodland within the mix of potential solutions to tackle and reduce flood risk.
7.6. Recommendation 5: The Woodland Trust calls upon Government to take a critical look at the way in land management contributes to soil erosion and how to integrate non-crop habitat – trees, shelter belts, other habitat – in to farming systems in ways which can support production while also helping to reduce the risk of erosion.