Memorandum submitted by The Woodland Trust
(V05)
1. BACKGROUND
1.1 The Trust is the UK's leading woodland
conservation charity. We achieve our purposes through a combination
of acquiring woodland and sites for planting and through advocacy
of the importance of protecting ancient woodland, enhancing its
biodiversity, expanding woodland cover and increasing public enjoyment.
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 focus chiefly on the areas
outlined by the Committee but also raise a number of general points
which we believe are important.
Key Points
1. The Government should take the opportunity
of the Integrated Agency's creation to also set out its view on
the future of the Forestry Commission. It should also seek to
reform the 1967 Forestry Act as part of any forthcoming primary
legislation on rural affairs.
2. The Strategy does not afford sufficient
prominence to climate change—the biggest long term threat
to the future of the countryside.
3. It is unclear from the Strategy how the
important issue of urban environment fits into the work of the
Integrated Agency. It comes across as an afterthought in what
is, by definition, a Rural Strategy.
4. The Strategy accepts too unquestioningly
the separation of policy and delivery recommended in Lord Haskins'
report
2. THE PROPOSAL
TO ESTABLISH
AN INTEGRATED
AGENCY
2.1 We welcome the proposal to create an
Integrated Agency in the interests of joining up natural heritage
and people. We would question however the extent to which the
Integrated Agency can be regarded as genuinely "integrated"
when it does not include the very significant land management
and environmental expertise which resides within the Forestry
Commission (FC) and the Environment Agency. The FC being the largest
public owner of rural land in Great Britain. The term "integrated"
therefore has a somewhat hollow ring to it. Paragraph 71 of the
Rural Strategy refers to "the establishment of a single independent
statutory organisation championing integrated resource management,
nature conservation, biodiversity, landscape, access and recreation"
but this statement needs qualifying with an acknowledgement that
it will not be the only body tackling these issues.
2.2 A prime example of the result of the
absence of a wholly integrated approach to the environment is
the public forest estate. The majority of sites are managed by
the FC but some of the finest woodlands for biodiversity will
be managed by the Integrated Agency who will inherit English Nature's
estate. Whilst we recognise that this is a continuation of an
existing split, it serves to highlight the fact that a truly integrated
approach to the natural environment has not emerged from this
strategy.
2.3 Paragraph 75 discusses the integration
process and how rapid momentum towards the full Integrated Agency
will be achieved. There seems little difference to us between
this and the "close engagement" of the FC with the Agency
discussed elsewhere in the Strategy. A clearer steer on how the
Forestry Commission will engage with this process would therefore
be welcome and in particular on how its relationship with the
initial "Confederation of Partners" and its involvement
in the strategic group to champion change (p81) will differ from
its relationship with the Integrated Agency once the latter is
established.
2.4 Given these concerns, we welcome the
commitment to review the situation and assess the success of partnership
working between the Integrated Agency and the Forestry Commission
(see Annex C Recommendation 19). The continued uncertainty as
to the Government's long terms plans for the Forestry Commission
has been a damaging feature of environmental policy for a number
of years and is de-stabilising both for the Forestry Commission
and for stakeholders. We therefore call upon the Government to
take the opportunity of the Rural Strategy's publication to make
clear how it sees the way forward for the FC.
2.5 Similarly, there is even less mention
of how the Environment Agency fits in with this process other
than the mention of the development of a concordat.
2.6 More positively, we welcome the establishment
of NDPB status for the Agency and the stated view that it should
be "powerful, authoritative and independent".[1]
This goes a good way towards meeting some of the concerns from
an environmental protection standpoint in the run up to the strategy's
publication. We welcome the reference to "protecting and
enhancing the rural and urban environments" and wish to see
the Integrated Agency given a statutory duty to do so along with
the broadening of access to the natural heritage for all.
2.7 We feel though that the Integrated Agency's
relationship with New Countryside Agency, the RDAs, the remainder
of the Rural Development Service and indeed with Defra itself
could be made clearer, as could be the differences of remit. There
are likely to be significant areas of overlap for example in relation
to environmental justice between the Integrated Agency and the
New Countryside Agency. There are social components to the work
of both and the division of responsibilities could be made clearer.
It is important given the aspirations of the Strategy in this
regard that issues of social justice do not suffer from falling
between various stools. We also seek greater clarity on the Integrated
Agency's relationship with ODPM given the central importance of
that department's responsibility for land use planning to the
protection and enhancement of the environment.
2.8 In similar vain, we believe that the
important issue of the urban environment sits uneasily within
the strategy and is not afforded the attention it warrants. The
document is, by definition, a Rural Strategy and the mention of
"protect and enhance the rural and urban environments"
set out in paragraph 69 leaves a lingering impression that "urban"
has been added in as something of an afterthought. We would therefore
like to see a statement made on how the Government proposes to
address this matter. Clarity is needed that this will be a core
part of the Integrated Agency's work, as it was for English Nature.
The link between the quality of the local environment and human
health is increasingly recognised and biodiversity is far from
being a purely rural matter—it is important that people
living in urban areas are not disenfranchised from an experience
of nature. English Nature has undertaken some valuable work in
the urban realm and direct contact with green spaces rich in wildlife
is key to broadening people's understanding of the natural world.
2.9 The integration of the Rural Development
Service (RDS) into the Integrated Agency should be viewed as an
opportunity to achieve an holistic approach to countryside management
for public benefit and careful consideration should be given to
how this can best be achieved. The Government needs to ensure
however, that the effect of the budget size and volume of staff
numbers brought to the Integrated Agency by the RDS does not serve
to skew the "on the ground orientation" of the agency
towards broader countryside management issues rather than considerations
of conservation and public enjoyment. With the New Countryside
Agency shorn of its access and landscape responsibilities it is
all the more important that the advocacy of such concerns is not
subdued.
2.10 An enhanced role for the RDAs in rural
policy delivery is a prominent feature of the Strategy but there
is also a need to ensure a strong regional presence for the Integrated
Agency in order that conservation and access interests have a
strong voice to balance the drive for economic growth. The agency
should therefore have a central role in regional arrangements
for the environment and spatial planning and be well placed to
inform regional policy development when necessary.
2.11 Finally, we believe that there is a
need for more information to be forthcoming on the likely cost
of the agency's creation.
3. THE PROPOSED
STREAMLINING OF
RURAL, AGRICULTURAL
AND ENVIRONMENTAL
FUNDING SCHEMES
3.1 The strategy accords considerable prominence
to its promised reduction of the number of funding schemes down
to three. Whilst we welcome the adoption of a more strategic approach,
this comes across as unconvincingly simplistic. Closer scrutiny
suggests that rather than such a wholesale reduction, what is
taking place is a synthesising down to three over-arching themes.
There also exists a natural overlap which should not be ignored
in the pursuit of straightforwardness. Farming and sustainable
land management are inextricably bound up with each other for
example. The position we have arrived at since the publication
of the Curry report has been about making things simpler for the
applicant rather than administrative tidying up for presentational
purposes and in any case the key objective overall must remain
how best to achieve the desired shape of the countryside.
3.2 There also remain questions of who will
control and deliver these schemes. There is a lack of evidence
of people being able to work in an integrated way in developing
grant schemes whilst the timescale for radical simplification
by April 2005 seems somewhat over-ambitious. The document also
does not give a sense of how this links with the rest of the strategy
and there is a need for more detail on how these reforms are to
take place.
3.3 More specifically, paragraph 78 addresses
the new Environmental Land Management and Natural Resource Protection
Funding Programme which will include the agri-environment schemes
of the ERDP and other nationally-funded grant schemes. This seems
to be in conflict however with paragraphs 86 and 87 which talk
about HLS and EWGS still being separate. Overall the language
is confusing with a tendency in general to move between the present
and the future without reference to how we will get to such a
single scheme. The only hint is in relation to the section on
the ERDP on page 43 which talks about the funding framework being
"further rationalised in future as part of our streamlining
of funding programmes."
4. THE IT STRATEGY
UNDERPINNING THE
STRATEGY
4.1 We welcome the emphasis upon the extension
of broadband and in particular the Government's stated intention
(page 13) to ensure that the full potential of broadband for delivering
public services and increasing productivity is realised in rural
areas.
4.2 The proposal for a single IT based handling
system for all Defra, Defra agency and FC grants to accelerate
process and payment times and reduce the transaction costs is
also very welcome and we hope that a smooth transition to this
system is able to take place.
5. THE EXTENT
TO WHICH
THE STRATEGY
INCORPORATES THE
RECOMMENDATIONS OF
LORD HASKINS'
RURAL DELIVERY
REVIEW
5.1 As the strategy acknowledges, primary
legislation will be required in order to pursue the reforms proposed.
We believe that the opportunity should also be taken to reform
the 1967 Forestry Act as part of such a Rural Affairs Bill. This
legislation is overdue for revision, as was recommended by the
Agriculture select committee in 2001[2],
and should be addressed at the same time in order to better ensure
that the Forestry Commission and the forestry sector are attuned
to the needs of society. The 1967 Act enshrines a heavily economic,
timber based view of forestry which does not reflect the public
benefit oriented agenda of forestry in the 21st century. It also
constrains the Forestry Commission's ability to enter into partnerships
which can maximise the great ability of the sector to deliver
on all three strands of sustainable development.
5.2 The strategy appears to have bought
rather heavily and unquestioningly into the emphasis of the Haskins
report upon the separation of policy and delivery when a more
measured approach to this recommendation would have better served
the interests of rural policy. Such a simplistic split would seem
to be a recipe for reinforcing the existence of ivory towers in
the policy world and the potential undermining of closer understanding
between policy formulation and action on the ground. One of the
strengths of the FC's approach in many respects is the fact that
policy and delivery have been present in the same body. They have
rightly been able to argue that they have the opportunity to develop
a policy and then see it through on the ground and in turn use
the ramifications of this to inform future policy development.
Such a process seems to us to represent good pragmatic policy
making sense which is placed in jeopardy by too dogmatic a split
between policy and delivery.
6. GENERAL POINTS
Priorities for Rural Policy
6.1 We note the priorities identified for
the Rural Strategy—"Economic and social Regeneration",
"Social Justice for All" and "Enhancing the Value
of our Countryside". We believe that there is a need here
to make very clear up front that protection of natural resources
is a key part of the overall approach as is described in paragraph
69. The Strategy is otherwise rather light in terms of the attention
it pays to the actual protection of our most valuable habitats
and landscapes, given their fundamental importance in the countryside
both environmentally and economically.
Definition
6.2 Annex A covers the "New Rural Definition"
and provides a good deal of data and discussion of how the definition
has been arrived at but does not actually set out clearly what
this definition is. Greater clarity here would be helpful in terms
of targeting work on enhancing access to woodland in both urban
and rural areas.
Climate Change
6.3 A forward looking strategy, as this
aspires to be, needs to afford more prominence to the threat of
climate change. This is identified as a priority for action on
page 40 but the last sentence, referring to the UK Climate Change
programme, conveys the impression that responsibility lies elsewhere.
The issue is so significant for the future of the countryside
that it must be integral to the whole of the strategy rather than
a bolt-on extra. It would be useful, for example, to discuss the
Integrated Agency's role in relation to the UK Climate Change
Programme and plans to ensure that climate change will be at the
heart of its thinking. The agency has a key role to play in achieving
cross-cutting action on this crucial issue.
Access to the Natural Heritage
6.4 We welcome the emphasis upon promoting
public enjoyment and an accessible countryside for all. The desire
to address the evidence base and improve the quality of data in
this regard is also very welcome and fits with the Woodland Trust's
own priorities. We shall shortly be publishing Space for People
setting out our strategy to increase public access for woodland
by creating new woodland where necessary, based on the findings
of a joint research programme with the Forestry Commission which
has identified for the first time the true extent of the accessible
woodland resource in this country.
6.5 Issues about access and recreation are
not specific and unique to the countryside however. There is no
mention, for example, of the importance of quality access to green
space close to communities. This serves to reinforce a view that
access to the natural environment is primarily a rural policy
issue and as with the issue of urban biodiversity, discussed in
the section on the Integrated Agency, it underlines concerns about
how the urban environment sits in relation to the reforms proposed
in the strategy. We believe that the creation of agency should
actually be taken as an opportunity to adopt a more holistic view
of the natural environment reflecting the considerable overlap
between the rural and urban in relation to core Government agendas
such as "Sustainable Communities".
6.6 The strategy is also somewhat light
on how the enhanced access it wishes to see will be encouraged.
This links very heavily into the theme of funding and of the existence
of delivery mechanisms which have no funding attached to them—the
dedication of land for public access under the Countryside and
Rights of Way Act for example. The provision of public money to
reward and incentivise public benefit delivery should be a key
theme of the Strategy
16 September 2004
1 Department of the Environment, Food and Rural Affairs,
Rural Strategy 2004, (London, 2004), p 82. Back
2
House of Commons Select Committee on Agriculture. Fifth Report
2000-01: "The Work of the Forestry Commission" paragraph
8. Back
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