Environment, Food and Rural Affairs CommitteeFurther written evidence submitted by the Woodland Trust

The Woodland Trust welcomes the opportunity to respond to this consultation. The Trust is the UK’s leading woodland conservation charity. We have three aims: to enable the creation of more native woods and places rich in trees; to protect native woods, trees and their wildlife for the future; to inspire everyone to enjoy and value woods and trees. We manage over 1,000 sites and have 300,000 members and supporters.

Our response focuses upon some but not all of the questions posed.

General Comments

The Woodland Trust welcomes the vision and aspirations set out in the White Paper. In particular we welcome the recognition of trees and woods as especially cost-effective vehicles for delivering ecosystem services. This builds on the clear findings of the National Ecosystem Assessment in this regard. The White Paper also acknowledges the Read Report’s conclusions on the role of forestry in combating climate change as well as delivery of a range of other benefits . Read concluded that this should mean significant woodland creation.

The White Paper also sets out the Government’s ambitions for a “major increase in woodland cover” which we welcome, but what is lacking is a target for this. All other parts of the UK have a target and the NEA noted that the UK Forest Carbon Sink may soon decline because of dwindling planting figures in what is already one of the least wooded countries in Europe. However, the White Paper does make a very welcome commitment to the creation of 200,000 ha of new priority habitat. We believe that new native woodland should be at the forefront of this drive and that we should be planting 15,000 ha a year with the aim of doubling native woodland cover over the next 50 years.

The Independent Panel on Forestry Policy can provide important advice on how we tackle barriers to woodland creation and protection. We believe, however, that the Government needs to provide leadership and a clear map for the journey. This means rooting the Panel’s work firmly within the NEWP and NEA’s aspirations.

We also welcome the White Paper’s emphasis on protection of valuable habitats such as ancient woodland but achievement of this, as we address in relation to question one, requires the commitment of other Government departments—especially around the National Planning Policy Framework—and there is worrying evidence that this is not sufficiently strong. Rather, the NPPF suggests the primacy of economic considerations rather than the ecosystems approach which characterises the NEWP generally.

Finally, where Government itself owns land it should be setting the standard for the rest of society. We welcome the stated desire in the White Paper to see more restoration of plantations on ancient woodland sites but the Government should be showing the way by making a commitment to restore all planted ancient woodland sites in its ownership (around 35, 000 ha).

What actions are required across Government Departments, from local government and by civil society to deliver the White Paper’s proposals to grow a green economy and reconnect people with nature?

1. The cross-Government tone of the Natural Environment White Paper is a very welcome step forward. The innovative National Ecosystem Assessment clearly underlines the centrality of the natural environment to our future prosperity and well-being. This should serve to drive much greater cross-Government action to realise these benefits.

2. However the crucial first test represented by the draft National Planning Policy Framework (NPPF) suggests that this is far from being the case. The draft NPPF is heavily characterised by the primacy of economic considerations above environmental ones. A strong example of this is that of the wording around ancient woodland and other vital habitats where the policy, as currently drafted, will undermine our future efforts to protect ancient woods and trees.

3. This states that:

planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits of, the development in that location clearly outweigh the loss

4. In the context of a document that is characterised by a presumption in favour of development the caveat at the end of the paragraph leaves a habitat like ancient woodland looking decidedly vulnerable. There are already 430 ancient woods under threat due to weaknesses in existing planning policy and countless ancient trees in the countryside left unprotected and at risk. The impression of an innovative White Paper, contrasted with the overall trend of Government policy, is reinforced by High Speed two where little consideration appears to have been given to impact upon the natural environment.

5. Similarly, the inclusion of the environment within the “Red tape challenge” in the same year that the NEWP is talking about “placing the value of nature at the centre of the choices our nation must make.”1 This sends out signals that the NEWP’s aspiration of “mainstreaming the value of nature across society” is not understood across Whitehall.

6. Recognising the wide range of services provided by the natural environment also means recognising the important role of local green infrastructure provision. This may mean more protected budgets for Local Authorities in relation to land management. It should also trigger thinking about how LA landholdings can best be managed. For example whilst recognising the value and importance of open spaces, the report, Trees or Turf—best value in managing urban green space, produced by Land Use Consultants,2 compares the costs of maintaining a number of grassland regimes with those of different woodland types in urban areas. The results show that native woodland creation can provide an attractive and less costly alternative to amenity grassland in the right location as well as important wider policy reasons that are also in line with the NEA and NEWP.

7. The report also outlines the direct or indirect cost savings of the broader benefits to be gained from planting trees, including flood mitigation, increased biodiversity, improved air quality, reduced energy costs for buildings, improved health outcomes and locally sourced timber and woodfuel. The NEWP, when implemented on the ground, should help to deliver on all these benefits.

Will the institutional framework outlined for delivering the proposals (in particular Nature Improvement Areas and Local Nature Partnerships) be effective? Does the proposed Natural Capital Committee have sufficient powers?

8. We warmly welcome the concept of Nature Improvement Areas. The landscape level action which they embody has long been a central tenet of the Woodland Trust’s own conservation approach. However it is important to recognise that twelve areas alone will not herald the “step change” in biodiversity conservation that the NEWP and England Biodiversity Strategy claim. Rather the twelve areas need to be viewed as exemplars. Whilst recognising the difficult financial context, it needs to be noted that the funding is limited and for only three years. This does not recognise the length of time many habitats need even to simply become established without considering the long term biodiversity declines they are supposed to be tackling.

9. The landscape scale model represented needs to be rolled out very quickly and should effectively cover the whole country. In other words, nature needs to be “improved” everywhere, and NIAs should simply be the local expression of an action plan based on an ecologically sensible boundary. Having a series of discrete NIAs covering a very small proportion of the country will have little impact and could serve to draw funding away from elsewhere. They are also dependent on funding of landowners to undertake measures. However it is not clear that anything in the proposals will make this happen given the current levels of funding for the pilot schemes.

10. The success criteria of LNPs and NIAs should also be defined nationally. For example, Defra needs to show how the delivery achieved by LNPs and NIAs will contribute to key measurable ambitions within the White Paper such as the creation of 200,000ha of priority habitat.

11. Similarly, the Government may need to do more than simply “encourage” Local Nature Partnerships, LEPs and Health and Well-Being boards to work together given the potential for conflicting objectives. Tapping into private investment through LEPs will be crucial to ensuring the NIAs are viable.

12. Overall however, until some mechanisms for transfer of funding from beneficiary to provider are developed it is difficult to see what will change in terms of landowner engagement. Government will have to intervene to create markets or to ensure transfer via fiscal arrangements eg tax incentives.

13. We welcome the emphasis upon natural capital and the fact that the Natural Capital Committee will report in to the Economic Affairs Committee. It is unclear at present however how the Natural Capital Committee will operate. It will be important that the scoping study for a natural capital asset check due to be carried out this year builds on the NEA.

14. The reduction in staff and responsibility at Natural England also inevitably weakens the institutional framework upon which much environmental work was based. Whilst recognising that the Government would like local communities to take over some of this responsibility it is unclear that the mechanisms or funding systems are in place to enable that to happen.

15. Finally, concerns about the extent to which the NEWP really is a cross Governmental policy are reinforced by the fact that even within Defra, the catchment pilots—set up to achieve Water Framework Directive targets but with much biodiversity potential—remain unrelated to other environmental work with no obvious mechanism to coordinate work.

What further research and/or evidence is required to develop practical programmes sufficiently detailed to deliver the White Paper’s ambition to fully embed the value of nature into policy delivery?

16. An important starting point is to institute a shared understanding of sustainable development. We would wish to see the 2005 UK Sustainable Development Strategy definition of sustainable development embraced across Whitehall.3

17. The NEA has clearly demonstrated the links between the environment and wider Government policy but there are several areas within NEA where this could be followed up in more detail.

18. Despite the ever growing body of knowledge available illuminating the value of nature to society, certain individuals and groups still do not act upon this. The barriers which prevent such action should therefore be a priority area for research.

19. Finally, another key area is the primary issue of how, especially at the level of individual land holdings, society values ecosystem services and rewards the appropriate land owners for their provision. What mechanisms can be devised? How will they operate? How do the public, private and voluntary sectors ensure that money flows from the beneficiary (including the whole of society) to the supplier ie the landowner? What other barriers (social, cultural and economic) are there to landowner action? How will actions be mentored and measured? How will quality and sustainability be ensured?

What evidence is there from other countries that the approaches proposed in the White Paper can be successfully applied in practice?

20. A very good example here is the recent Forest Research report on woodland measures to deliver the Water Framework Directive (WFD) which had examples from other parts of Europe and the US.4

Does the White Paper set out an accurate assessment of the barriers to public engagement with the natural environment and make the most effective proposals for re-engagement?

21. In general there is a good deal to welcome in the chapter on reconnecting people and nature and we applaud the ambition shown. The lack of readily accessible greenspace is at the heart of the disconnection from the natural world which the White Paper rightly seeks to address. It could therefore be strengthened by taking greater account of existing tools such as the Woodland Access Standard and the Accessible Natural Green Space Standard.5 It should be made clear that the benchmarks these set out represent a key starting point for the work of the Green Infrastructure Partnership. The recent findings of the ONS consultation on work towards an index of national well being which found that accessible green space was the biggest environmental concern of respondents should also be a spur to action.6

22. We welcome the recognition in the Public Health White Paper of the important role of greenspace, and trees in particular, in relation to public health7 and wish to see a strong emphasis on partnership working between Local Nature Partnerships and Health and Well Being Boards.

23. The proposed new Green Space Designation is a very welcome step forward but initial signs are that the criteria proposed are quite restrictive.

24. Finally, whilst recognizing the pressures on the National Curriculum, we would like to see a strong commitment to embed outdoor more firmly in the Curriculum. Ensuring every child has the opportunity to plant trees as part of their education would be a straightforward action which could move this agenda forward.

28 September 2011