APPENDIX 23
Memorandum from the Woodland Trust
1. BACKGROUND
1.1 The Woodland Trust welcomes the opportunity
to respond to submit written evidence to this inquiry. The Trust
is the UK's leading woodland conservation charity. We have four
main aims: no further loss of ancient woodland, restoring and
improving woodland biodiversity, increasing new native woodland
and increasing people's awareness and enjoyment of woodland. We
own over 1,100 sites across the country, covering around 19,000
hectares (47,000 acres) and we have 250,000 members and supporters.
1.2 Our comments cover both some of the
specific issues raised by the Committee and as suggested, a number
of other issues which we consider relevant.
A: THE DEFINITION
OF "SUSTAINABLE
DEVELOPMENT"
Does the definition of sustainable development
matter?
2.1 The definition of sustainable development
matters greatly. We disagree with the statement that the Brundtland
definition "is excessively narrow and puts an undue emphasis
on environmental concerns". This definition has become widely
accepted and informed the original UK Sustainable Development
Strategy (UKSDS), "A Better Quality of Life", produced
in 1999. Effective action for the environment is likely to be
diluted if the consensus which exists around Brundtland is jettisoned
in favour of a more fluid approach to the definition. This is
an overarching definition which has stood the test of time for
17 years and is capable of continuing to do so.
2.2 We already have a situation where
despite the fact that our dependence upon the natural world is
acknowledged in a concept of sustainable development which attempts
to place environmental concerns on a par with economic and social
ones, decision makers remain seduced by short term economic needs.
As this committee has stated "the barometer clearly shows
the environmental element of sustainable development to be the
"Cinderella" of the three with little indication of
how this situation is being tackled"[56]
2.3 It is vital that the imperative to protect
and enhance the environment as a central part of sustainable development
is recognised in the revised strategy. Any process redefining
the concept must ensure that the desire to provide, for example,
more homes in the South East of England does not compromise our
ability to protect the environment now and in the future. Seeking
a shift to a definition which places less emphasis upon the environment
would seem to be opening the floodgates to an approach based more
on expediency.
3. The SDS requires all four key objectives
to be met at the same time. Is this realistic? Is political support
for this concept based on its ambiguity? Does it fail to place
enough weight on the need to make trade-offs between different
objectives and the relative importance to be attached to them
in that event?
3.1 One of the strengths of the existing
strategy is the emphasis which it places upon the objectives being
met at the same time. This avoids the kind of trade offs described
above. An increasing difficulty that we have found with government
departments including ODPM is a shift away from the integrationist
approach and towards an approach which seeks to "balance"
or trade-off the different aims of sustainable development. This
is a dangerous route to go down because most balancing exercises
involve attempting to rate the economic value of the environment,
which will almost inevitably cause the environment to be undervalued,
although there is a growing body of evidence highlighting the
value of "non-market" benefits of the environment to
society. Instead, sustainable development should value the environment
for its own sake as something worth protecting in its own right.
3.2 We do not doubt that meeting all four
key objectives at the same time is a difficult process, but this
is not a reason for not attempting to achieve this. It is essential
that this process takes place. Development which pursues one of
the four objectives to the detriment of one or more of the others
should not be permitted and this is why the overarching definition
provided by Brundtland is so useful.
3.3 All too often we have found that development
ignores the fact that certain environmental resources such as
ancient woodland are irreplaceable and that their loss cannot
be offset by compensatory tree planting elsewhere, for example.
It is vital that the dilution of the objectives by providing for
the possibility of trade-offs is not promoted in the new strategy.
B: HAS THE
STRATEGY ACTED
AS A
REAL DRIVER?
4.1 One of the strengths of the existing
approach is the way that it has been presented in terms of quality
of life rather than in more austere terms. This has made it easier
for the public to identify with what might be in danger of remaining
an abstract concept.
4.2 The difficulty however, arises from
the extent to which the strategy has remained the province of
Defra and has not appeared to inform the work of other departments
to any meaningful degree. This has been especially apparent with
regard to transport where the Government has pandered to growing
demand for air travel fuelled by its own price subsidies despite
the fact that it is predicted to be one of the largest individual
contributors to climate change by 2050. The proposed developments
at Stansted will include the loss of 86 hectares of ancient woodland,
the UK habitat that contains more threatened species than any
other. This has clearly not been informed by the Brundtland definition
as by its very nature, this would demand protection of the irreplaceable.
We would also question whether the proposals have been informed
by the UKSDS's own definition—there is little evidence of
any attempt to meet all four aims of sustainable development in
the Department for Transport's approach to the issue.
4.3 The production of a new strategy should
be accompanied by a new emphasis on truly cross-Government implementation
and greater efforts to build the understanding of sustainable
development issues within other departments. Number 10, the Cabinet
Office, ODPM and the Treasury have an especially important role
to play in this regard.
5. How effectively has the Strategy
linked to, or acted as the driver for, lower level strategies—whether
topic specific strategies, such as the Climate Change Strategy
and the Air Quality Strategy, or strategies of devolved administrations,
regional and local government?
5.1 A weakness of the current strategy is
that it was developed just before devolution took place across
the UK. As a result there seems to have been little buy-in from
some of the devolved administrations to the UK strategy. Although
Wales has developed a strategy along similar lines, Northern Ireland
is yet to develop one and the Scottish strategy has gone down
a completely different route.
5.2 In terms of specific topic strategies,
the Climate Change Strategy is an interesting example. Clearly
any programme attempting to address the issue of climate change
by cutting emissions and adapting to its impacts must be informed
by sustainable development. However, we would question the lack
of emphasis placed on climate change by the current UKSDS. Although
it does address the issue, we do not believe it places enough
importance on the issue in its current form. Climate change is
perhaps the biggest threat to the natural and human world and
it is essential that the revised strategy places more emphasis
on the need to both reduce emissions, but also on the need to
adapt to the impacts of climate change.
C: HOW EFFECTIVELY
DO THE
INDICATORS REFLECT
THE UK'S
SUSTAINABILITY GAP?
6.1 As the Royal Commission on Environmental
Pollution have noted: "There are seven environmental indicators
among the headline indicators for sustainable development established
for the UK as part of that strategy but although some of them
relate to targets set previously they do not in themselves represent
policy commitments and they do not cover all aspects of the environment".[57]The
Commission went on to recommend an approach similar to that which
has been adopted in the Netherlands and Sweden, with a comprehensive
and definitive statement of priority objectives for the environment
being produced now for each part of the UK and widely publicised.
It also went on to add that the statements should be prepared
on the basis that "sustainable development is achievable
only if the environment is safeguarded and enhanced".[58]This
is an approach which we believe should guide the revision of the
current strategy and which would serve to add greater weight to
its status.
6.2 One of the main strengths of the current
strategy is the breadth of the indicators contained in Quality
of Life Counts. Although there are 150 of them, they do provide
a good broad suite of indicators against which sustainable development
can be measured. It is important that the review of the strategy
does not involve loss of indicators on the basis that there are
too many to monitor, or data not yet being available. As they
stand at present, the indicators present a reasonably balanced
selection of indicators for sustainable development. If an indicator
was worthy of inclusion in the first place, then it still is now
and should be maintained in the revised strategy.
6.3 We are concerned about the hierarchy
that has been created between the headline and the wider suite
of indicators. To some extent this undermines the fact that the
wider suite of indicators are so broad (which is an advantage
of them), by suggesting that in fact only 15 of them are really
important.
6.4 One area with an especially strong contribution
to make to the achievement of sustainable development is woodland,
rightly described in the Rural White Paper as "a true multi-use
activity".[59]This
has been borne out by Making woodland count, recent research on
the contribution of woodland to quality of life carried out for
the Woodland Trust by ERM. This found that woodland was delivering
on 11 of the 15 headline UK indicators of sustainable development
set out in Quality of Life Counts and 21 of the wider set of indicators.[60]
This should mean that any revised strategy recognises the very
wide contribution this resource is able to make to sustainability
and ensures that protection of the most precious resource—ancient
woodland, our richest habitat for wildlife, and expansion of woodland
cover (the UK is one of the least wooded countries in Europe)
are afforded the prominence they warrant if we are to achieve
a more sustainable future.
6.5 If however, as seems inevitable, the
hierarchy between headline and other indicators is maintained,
we believe it is important that the Indicator S11 (Area of ancient
woodland in GB) be included in the headline set. Ancient woodland
(land that has been continually wooded for at least 400 years)
is our richest habitat for wildlife, being home to more species
of conservation concern than any other habitat. Despite this,
we are losing ancient woodland at an alarming rate. The reporting
on this indicator is still too lax despite the fact that we do
have an inventory of ancient woods in Britain and a professed
desire by the Forestry Commission, English Nature and environmental
NGOs to keep this up to date.[61]
The result of this is that the reporting on the figures in the
annual report suggests there is not enough data to assess whether
the area of ancient woodland in GB is in fact declining. In the
absence of such data, the Woodland Trust has had to take action
to attempt to assess this, and we are currently aware of over
300 sites that are under threat. Many of these sites have been
severely damaged or lost and it is important that this fact be
reflected in the reporting process for the strategy.
6.6 Ancient and mature trees harbour a unique
array of wildlife and the Woodland Trust and the Ancient Tree
Forum (ATF) wish to see this priceless legacy conserved for the
benefit of all in our society. It is important that there is no
further avoidable loss of ancient trees through development pressure,
land use intensification, mismanagement or poor practice. We also
believe that ancient trees should be included in the wider suite
of indicators. The Trust and the ATF would therefore like to see
a commitment to auditing the ancient tree resource of the UK fully
and to use the results as the basis of a UK sustainability indicator
to be included in the wider suite.
E: ORGANISATIONAL
STRUCTURES AND
COSTS
7. Do the present organisational structures
and policy mechanisms within Government contribute to the effective
implementation of the Strategy? What improvements could be made
in this respect? Is there a case for rationalising the number
of organisations involved in key sectors?
Is there a need for a more consistent approach
to incorporating sustainable development as an overarching objective
in all Government organisations? Or would the ambiguity of the
term prove unhelpful?
7.1 As described above, there are several
key departments in the UK Government whose actions do not appear
to reflect the objectives outlined in the UKSDS. We believe that
the problems associated with implementing a cross-departmental
strategy have hampered its implementation. Perhaps a better approach
would be to give Number 10 greater responsibility for implementation
of the UKSDS. This would ensure that all departments including
Transport, for example, would be aware of the importance of the
strategy. By its very nature, sustainable development must be
implemented throughout each and every department both in Whitehall
and throughout Scotland, Wales and Northern Ireland.
7.2 A consistent approach to incorporating
sustainable development as an overarching objective in all Government
organisations is vital. It is surprising that this has not been
pursued as a process. The agenda of the strategy is not ambiguous,
it only loses clarity when people try to adapt the definition
to their own ends. Providing consistency of approach across all
departments would be a great step forward. We have seen the benefits
of having sustainable development written into the aims of the
Welsh Assembly and would expect similar results across government
if a more overarching approach was adopted.
May 2004
56 Environmental Audit Committee, Fourth Report Measuring
the Quality of Life: the 2001 Sustainable Development Headline
Indicators, Session 2001-02. Back
57
Royal Commission on Environmental Pollution 23rd report, Environmental
Planning (2002) paras 8.5-8.7. Back
58
RCEP op cit. para 8.10. Back
59
MAFF/DETR (2000) Our countryside: the future, p115. Back
60
Woodland Trust / ERM (2004) Making Woodland Count. Back
61
Forestry Commission / Forest Service (2002) UK Indicators of Sustainable
Forestry, Indicator B1. Back
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