Memorandum submitted by the Woodland Trust
1. The Woodland Trust welcomes the opportunity
to respond 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 understanding
and enjoyment of woodland. We own over 1,000 sites across the
UK, covering around 20,000 hectares (50,000 acres) and we have
300,000 members and supporters.
SUMMARY
PSA 27, "Lead the global effort to avoid
climate change", contains a promise to facilitate the transformation
of the UK into a low carbon economy. Clearly reducing the intensity
of the UK's carbon usage is vital if the emissions targets are
to be met, however this aim does not sit easily with the Government's
plans for major infrastructure development of which airport expansion
could be the most damaging.
PSA 27 pays some heed to challenge of adaptation,
however like many other areas of climate change policy it does
not go far enough and fails to address impacts on biodiversity.
PSA 28, "Secure a healthy natural environment
for today and the future", outlines the mechanisms the Government
intends to use for protecting and enhancing our ecological systems.
Nonetheless indicator two, the changes in wild breeding bird populations,
is a very limited way of evaluating success. We have great concern
about management of the natural environment being entirely driven
by the needs of birds, when other indicators, of species at a
similar place in the food chain, such as bats, might point to
a different approach—certainly this would be the case regarding
woodland. A recently proposed indicator from Bat Conservation
Trust shows bat populations increasing significantly in woodland.
Overall the Agreements and CSR fail to demonstrate
a joined-up approach to the challenge of mitigating and adapting
to climate change. A desire to invest in "cleaner, safer
and greener" communities is often expressed by members of
the Government and yet the settlement handed to Defra, the leading
agent in this field, is inadequate. Neither is it clear how the
CSR intends to integrate biodiverse green space with an agenda
which appears to heavily emphasise infrastructure development,
and ensure that the latter will not be at the expense of the very
environmental resources which must be protected in the face of
climate change.
Aviation is one of the key contributors to climate
change and the Woodland Trust is pleased to see that the Government
has now decided to reform Airport Passenger Duty (APD).
The report on "Moving to a global low carbon
economy, implementing the Stern Review" reaffirms both the
economic and moral imperative for taking early action to avert
dangerous climatic change. Again, given that we are dependent
on a healthy ecosystem there is a worrying lack of emphasis on
adaptation strategies.
There is concern that Defra's funding reward
of 1.4% could actually represent a cut when the cost of implementing
policy is likely to rise. This is all the more disconcerting as
Defra will lead on PSA's 27 and 28 and yet the department may
be inadequately resourced to deal with the challenges faced.
Unfortunately the environment chapter in the
PBR contains very little in the way of innovation, and appears
to pay only cursory attention to creating fully functioning and
ecologically robust landscapes that will enables species to migrate
and adapt to climatic change.
PSA 27, "TO
LEAD THE
GLOBAL EFFORT
TO AVOID
DANGEROUS CLIMATE
CHANGE"
2. PSA 27 will determine how Government
intends to adopt policies which will make the UK a world leader
on climate change and secure effective and robust global commitments.
We are pleased to see that the commitment to avert dangerous climate
change is reaffirmed in the PBR. It is critical however that such
a vision is shared across all departments.
3. Biodiversity is alluded to in paragraph
1.6, "The Government also recognizes the need for and supports
a robust and accessible evidence base to support adaptation to
climate change impacts, including an established monitoring network
for detecting changes in biodiversity". To help establish
this network we argue for a landscape scale approach that seeks
to develop an ecologically functional landscape rather than small
isolated sanctuaries of biodiversity. This can be achieved by
conserving all semi-natural (BAP) habitats not just a representative
sample, and showing consideration of the synergies between all
semi-natural (BAP) habitats. Further to this investment is needed
to restore all semi-natural (BAP) habitats planted with non-native
conifers, and targeted habitat creation where biodiversity has
the best chance of survival. Government policy should seek to
increase the resilience of semi-natural (BAP) habitats by targeting
habitat creation to buffer them from negative edge effects and,
should allow the widest biodiversity to move across landscapes
by reducing the intensity of intervening land use. Landscape scale
action will not treat conservation as a segregated activity but
will integrate biodiversity with the wider benefits it delivers,
for example, in relation to soil conservation, air and water quality,
flood alleviation, high quality food, health, employment and recreation.
Whilst habitat creation should be targeted to concentrations of
ancient or semi-natural (BAP) habitat, it is important to note
that the other principles seek to protect and restore semi-natural
habitats across the country and will avoid greater intensification
of agriculture, forestry and built development across intervening
landscapes.
4. The desired outcomes of this PSA are
outlined in paragraph 3.3 and the Woodland Trust is reassured
to see a commitment "to stabilize atmospheric concentrations
of greenhouse gases at a level which avoids dangerous climate
change". Nevertheless if this is target is to retain credibility
then it must be inclusive of shipping and aviation emissions.
5. Another outcome in paragraph 3.3 that
will form a key measure of Government success is "international
action to minimise emissions from land-use and deforestation".
We are reassured to see the Government recognise the key role
of these two factors in relation to climate change and would now
ask that more is done at a UK level to promote environmentally
sustainable land-use. The Woodland Trust is currently contesting
474 cases where woodland is under threat showing that domestic
felling of an ecologically rich and irreplaceable resource remains
a major concern. Not only should government policy seek to prevent
international deforestation it must also be robust domestically
by protecting our own ancient woodland.
6. In paragraph 3.5 Defra has been given
prime responsibility for the successful implementation of the
PSA. Much of this vision focuses upon mitigation and if Defra
is going to have the authority to be successful it must surely
be given the energy portfolio. As the recent EAC report into The
Structure of Government and the Challenge of Climate Change concluded
"the movement of energy to DBERR rather than Defra constitutes
a missed opportunity".[1]
If emission reduction targets are to be achieved then Defra will
need to have a greater influence over a full range of policy areas
including energy and planning.
7. Adaptation strategies will become increasingly
important as the now unavoidable effects of climate change take
root. Paragraph 3.21 details how "Defra will lead on the
development of a cross-government adaptation framework, setting
out priority areas for ensuring the UK is adapting well across
a range of key areas where climate change will have potentially
serious impacts including flood risk and coastal erosion, water
supply and quality, and biodiversity and agriculture". As
stated previously, it is helpful that biodiversity is mentioned,
but nonetheless it is not easy to discern how determined the Government
is to restore, protect and enhance habitats when the Defra settlement
was so low in comparison to other departments. Moreover much of
this money will be invested into flood prevention and coastal
erosion, and will leave little of the settlement for biodiversity
restoration.
8. Planning is a key tool for addressing
climate change, and paragraph 3.24 exhibits how "CLG will
ensure that planning policies developed directly address climate
change mitigation and adaptation, and through the planning policy
statement on climate change, put it at the heart of what is expected
from good planning". Such a statement would appear to be
contradicted by reality as the Planning White Paper offered no
new guarantees that the natural environment will be protected
from development. Once again there is a reasoned argument that
Defra should be given some authority over planning given that
this area of policy impacts so greatly on climate change and the
ecological system on which society is dependent.
9. Another key delivery body will be Natural
England and paragraph 3.42 outlines how they "will work on
national partnerships to promote and develop the understanding
of the natural environment, collaborating with the farming industry
to identify how to enhance the role of land managers as carbon
managers. They will also play a key role in ensuring our biodiversity
and ecosystem services are managed in such a way as to respond
to the threats of climate change and minimize the impacts".
Whilst we acknowledge the important role Natural England can play,
there is as yet little evidence that they will receive enough
resources to fulfill what are ambitious commitments.
PSA 28, "SECURE
A HEALTHY
NATURAL ENVIRONMENT
FOR TODAY
AND THE
FUTURE"
10. The Woodland Trust would support the
Government's vision as outlined in paragraph 1.1 which is to "secure
a diverse, healthy and resilient natural environment". To
achieve the aims outlined in the vision including; sustainable
water use, biodiversity value and safeguarded, sustainable living
landscapes, and people caring for the natural environment, our
research indicates that the Government should adopt a landscape
scale approach. This would involve conserving all semi-natural
habitats not just a representative sample, targeting habitat creation
where biodiversity has the greatest chance of being put on a sustainable
footing, and seeking to increase the resilience of semi-natural
habitats by buffering them through woodland creation from negative
edge effects and land use. In a highly fragmented landscape such
as the UK's activity outside of designated reserves is hugely
important, and as such conservation should not be segregated from
other land uses.
11. Indicator 2 paragraph 2.1: "Biodiversity
as indicated by changes in wild breeding bird populations in England,
as a proxy for the health of wider biodiversity", may be
unsuitable for encouraging landscape scale strategies. We have
great concern about management of the natural environment being
entirely driven by the needs of birds, when other indicators,
of species at a similar place in the food chain, such as bats,
might point to a different approach—certainly this would
be the case regarding woodland. The needs of the natural environment
cannot be determined by one taxonomic group. A recently proposed
indicator from the Bat Conservation Trust[2]
shows bat populations increasing significantly in woodland.
12. We are reassured to see that indicator
5 paragraph 2.1 recognises that the Government must measure the
positive and negative impacts of farming. Further reform of the
CAP, and greater investment in pillar two of the agri-environment
scheme would assist in reducing the negative impacts of farming.
13. In paragraph 3.7 Defra "will continue
to take action on biodiversity under the England Biodiversity
Strategy focusing action on protecting the best wildlife sites;
promoting the recovery of declining species and habitats; embedding
biodiversity in all sectors of policy and decision-making; enthusing
people and developing an evidence base". For this commitment
to be met Defra will also require greater authority over planning,
as many decisions currently made at CLG will impact on biodiversity
and its capacity for survival.
14. The continued assertion that the Government
will encourage sustainable farming and food is vital as it will
allow Defra to meet their commitments on biodiversity. Indeed,
in paragraph 3.10 it is argued that "Defra is also developing
a more holistic and integrated framework for policy-making and
delivery on the natural environment, based on an ecosystems approach".
An ecosystems approach as mentioned above reinforces the importance
of the Woodland Trust's landscape scale principles, and as such
lends weight to our belief that indicator 2 may need revising.
15. Sustainable planning is essential if
the UK is to meet the obligations held within the UK Sustainable
Development Framework and the Biodiversity Action Plan. To achieve
this, paragraph 3.24 states that CLG become "a formal delivery
partner for this PSA and will ensure that the planning system
takes full account of the natural environment". However,
given the considerable concern which surrounds the Planning White
Paper, which was informed solely by economic concerns, we are
unconvinced that a planning system reformed along the lines set
out in the Planning White Paper will be capable of protecting
the UK's green infrastructure.
16. As outlined in paragraph 3.28 the Forestry
Commission "has a range of statutory duties and delivery
mechanisms with which to deliver government policy and make a
significant contribution to the woodland aspects of this PSA".
As a major land owner it should be incumbent on the Forestry Commission
to be an exemplar of the ecosystems approach mentioned earlier
in the PSA.
17. Ensuring a healthy natural environment
will in many cases be incumbent upon regional and local bodies,
and these responsibilities are outlined in paragraph 3.36: "Local
Authorities will be key partners in protecting and enhancing the
natural environment at a local level, through Local Strategic
Partnerships, Sustainable Community Strategies, LAAs and their
statutory duties". The Woodland Trust welcomes the recognition
that regional and local bodies are responsible for delivering
environmental as well as economic and social objectives, and urges
a rethink of the proposals set out in the Review of sub-national
economic development and regeneration which seem to be shaped
by the same economic preoccupation as the Planning White Paper.
18. Presently there is a lack of clarity
regarding adaptation strategies for nature, and as a consequence
it is refreshing to see paragraph 3.47 outlining the need for
more work; "The natural environment must be able to cope
with a changing climate and this will require both specific adaptation
measures, as well as reducing other non-climate change threats".
Adaptation strategies can be implemented without the need for
international agreement, and given that society is dependent on
a healthy natural environment a greater deal of Government urgency
and leadership is required to ensure that the UK creates ecologically
functional landscapes. The Climate Change Bill represents a strong
opportunity to move forward work in this area.
THE EXTENT
TO WHICH
THE PSA'S
REPRESENT A
JOINED-UP
APPROACH TO
GOVERNMENT
19. We believe that the PSA structure fails
to represent a genuinely joined-up approach to government, and
that this is vindicated by the conflicting environmental and economic
concerns present within the Agreements.
20. A key example of this is demonstrated
by the PSAs dedicated to local and regional bodies. Such organisations'
will be crucial in pursuing sustainable development, yet despite
an obligation held within PSA 28 nearly all the other measures
of success are informed by narrow economic concerns. Indeed five
out of the seven indicators in PSA 7, "mprove the economic
performance of all English regions and reduce the gap in economic
growth rates between regions" relate to economic development,
and only one deals with addressing climate change. None of the
measurements appear to protect either green infrastructure or
biodiversity.
21. A lack of emphasis on adaptation strategies
and the provision of only one indicator for measuring biodiversity
appears to prove that despite environmentally friendly rhetoric,
the Government's emphasis is upon economic rather than sustainable
development.
THE REFORM
OF AIR
PASSENGER DUTY
(APD)
22. With aviation being one of the major
contributors to climate change it is reassuring to see the proposed
reform of APD. A further action that would make flying accountable
for its cost is the inclusion of both aviation and shipping emissions
in the emissions reduction target.
23. Another Government led action that would
demonstrate a genuine desire to mitigate against climate change
and protect the natural environment is a moratorium on all airport
expansion. At present it could be argued contradictory to state
a desire to cap emissions by at least 60% in 2050, whilst simultaneously
expanding airport capacity.
"MOVING TO
A GLOBAL
LOW CARBON
ECONOMY: IMPLEMENTING
THE STERN
REVIEW"
24. "Moving to a global low carbon
economy: implementing the Stern review" reinforces the imperative
for early action to mitigate against climate change. There is
a clearly defined triangular policy framework for mitigation which
now includes establishing a carbon price (paragraph 1.16), accelerating
technology (paragraph 1.18) and encouraging behavioral change
(paragraph 1.18).
25. However a policy framework on adaptation
is less easily discerned, and as outlined in paragraph 1.24, the
ideas are solely focused on human requirements without considering
how Government policy can encourage a healthy natural environment.
26. We are pleased to see the role of deforestation
highlighted in paragraph 3.9, "With up to 18% of global greenhouse
gas emissions coming from deforestation, an international framework
needs to include efforts to reduce emissions from deforestation,
and to enhance carbon sinks by sustainable forest management and
land use practices". Indeed given the very limited coverage
of ancient woodland and trees in the UK, it should be incumbent
on Government to act and protect an irreplaceable resource here
in the UK as well as taking action internationally.
27. UK wide adaptation is discussed through
paragraphs' 4.77 to 4.82, yet the report pays negligible attention
to creating ecologically sustainable landscapes. The UK is dependent
on a robust and fully functioning natural environment for the
delivery of our air, water and food quality objectives, and as
such failing to outline any strategies for the natural world appears
a major missed opportunity.
THE DEFRA
SETTLEMENT
28. The 1.4% a year settlement to Defra
appears meagre given the size of the challenges and could demonstrate
a lack of ambition, vision and determination on the part of the
Government.
29. The amount of investment that will reach
projects designed to help protect, enhance and restore biodiversity
may be entirely inadequate as a substantial percentage of the
settlement will be taken by flood prevention and coastal erosion.
30. The final figures show a lack of impetus
from the Government which does not square with the urgency of
the problems faced.
PBR CHAPTER 7, "A
MORE SECURE,
FAIR AND
ENVIRONMENTALLY SUSTAINABLE
WORLD"
31. We support the setting of binding targets
for emissions reductions, although the present 60% is insufficient
given recent scientific evidence. This should now be upped to
80% as this gives the UK a better chance of averting dangerous
climate change.
32. However it is disappointing that once
again this chapter of the PBR lacks emphasis on adaptation, and
fails to demonstrate how the Government intends to allow for an
enhanced emphasis on built infrastructure provision including
airport expansion, and, simultaneously protect the UK's green
infrastructure.
33. We agree that sustainable development,
as outlined in paragraph 7.60 is a crucial principle and agree
that policy needs to recognise "the importance of protecting
and enhancing our natural environment so that domestic growth
is more environmentally sustainable". This though appears
in direct contrast with the economic drivers that informed the
potentially environmentally damaging conclusions of the Planning
White Paper and sub-national review.
34. In paragraph 7.61 the Government outlined
the three main challenges they believe will affect the UK and
these are, improving water quality, dealing with waste and reversing
the historic decline in biodiversity. What is now needed is an
understanding across all Government departments' that these challenges
are a shared responsibility.
November 2007
1 The structure of Government and the challenge
of climate change, House of Commons Environmental Audit Committee
(Ninth Report, Session 2006-07), p 25. Back
2
The Bat Conservation Trust at, http://www.bats.org.uk/nbmp/documents/NBMPAnnual
Report2005.002.pdf Back
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