Environment, Food and Rural Affairs CommitteeSupplementary written evidence submitted by the Royal Society for the Protection of Birds

Introduction

1. The RSPB1 welcomes the opportunity to give evidence to this inquiry.

2. Diseases, pathogens and pests on trees and in woodland in the UK is not a new issue. These plants, animals, fungi and bacteria can be a natural part of the wildlife cycle in native woods, but can also seen by the forestry industry as threats to the quality and volume of timber, particularly in non-native forestry plantations.

3. The international trade of trees and plants can bring, and has brought new pests, diseases and pathogens into the UK, some of which have the potential to harm wildlife. The movement of young trees across the UK in the amenity and production horticultural trade and for woodland planting can speed up the rate of spread of infection of tree diseases.

4. The biodiversity implications of any tree diseases may be complex, and may not always be harmful to wildlife. Many of the UK’s mature native woodlands are already in need of remedial management to regain their wildlife value for important habitats and species both on, and off designated nature conservation sites (“priority” native woodland habitats and species under biodiversity, environment and forestry strategies in the UK). This can include opening up the tree canopy to provide more light and space for trees and other plants to thrive, as well as to increase the amount and variety of decaying wood to help a range of plants and animals.

5. Note that Forestry Commission England, Forest Service Northern Ireland, Forestry Commission Scotland, Natural Resources Wales2 and the statutory nature conservation agencies in the UK all recognise the biodiversity importance of so-called “deadwood” species and habitats in native woodlands, and the need to improve the diversity and volume of deadwood in such important wildlife habitats.3

6. Government’s forestry policy, regulation, grants, research, survey, monitoring and state forestry must continue to be for sustainable forest management for multiple public benefits. Forest plant health must not be the only objective, or activity of government when it comes to trees, woods and forests on state, public or private land. The UK Government’s approach to woodland and non-woodland trees must be to protect and enhance public benefits, including biodiversity.

7. The RSPB is working to better understand the potential positive as well as negative impacts of tree diseases on wildlife, and trying to ensure that the UK Government and devolved administrations take this into account when deciding on how to tackle tree diseases through research, tree felling and other measures. This raises questions about the underlying sustainability of how plantation forests are designed and managed, and concerns about what the biodiversity impacts may be of new tree species planted to replace those prone to disease. Tree health is a wildlife concern, not just a timber quality or forest industry issue.

8. Tree diseases, pathogens and pests can give rise to a range of control responses from forestry regulators depending on the infected tree species, the forest management objectives, the extent and severity of impacts. Disease control measures could negatively as well as positively impact wildlife, causing wildlife disturbance, for example to birds during the breeding season due to poorly timed tree felling, or loss of biodiversity important insects due to chemical control measures, in addition to possible biodiversity impacts of the spread and populations of tree pathogens, pests and diseases.

9. The key tree and woodland pathogens and disease concerns for the RSPB in the UK are currently:

Phytophthora ramorum—a concern if this jumps onto heather or blaeberry (Vaccinium myrtillus)—a threat to important moorland and heathland habitats across the UK, and to the habitat of the capercaillie in Scotland, as well as opportunities to improve the wildlife value of internationally important Atlantic oakwoods in the UK, through removal of Rhododendron ponticum (a Phytophthora ramorum host);

Chalara fraxinea (ash dieback)—potential threat to the wildlife of native ash trees in upland mixed ashwoods and lowland broadleaved woodland, hedgerows, field and urban trees in the UK;

Dothistroma needle blight (red band needle blight) which is an issue for the conservation of native pinewood in Scotland;

Phytophthora austrocedrae (juniper dieback)—possible further wildlife impacts on upland juniper scrub in Britain; and

Acute oak decline—possible threat to native oak trees across the UK.

10. More information on the RSPB’s current conservation concerns with tree pathogens, diseases and pests in the UK can downloaded from: http://www.rspb.org.uk/Images/uk_tree_diseases_tcm9–336884.pdf

11. We note the devolved approaches to tackling tree diseases. For example in Scotland and Northern Ireland, the protection of important upland native ashwoods in North West Scotland in the Scottish Government’s Chalara action plan,4 and the publication of an all Ireland control strategy for Chalara5 which aims to eradicate Chalara ash dieback and keep native ash trees and woodland disease free. Wales also has a Chalara management plan.6 England’s current Chalara management plan6F7 followed an interim GB Chalara control plan.8

12. The RSPB was a member of Defra’s Chalara [ash dieback] Core Stakeholder Group until spring 2013 when the group was reduced in size, and is a member of the Scottish Government’s Tree Health Advisory Group.

13. Are the roles and responsibilities of public agencies for monitoring incidences of plant and tree diseases or pests sufficiently clearly defined?

14. Tree, forest and plant health and biosecurity must be considered in the context of the UK Government and the devolved administrations’ long-term sustainable multi-purpose forestry commitments, which have been in place since September 1991.9 This includes protecting and enhancing biodiversity, conserving historic environment, landscape and access, as well as economic and social concerns.

15. “Sustainable” approaches to tree health and plant biosecurity must encompass control measures being carried out in sustainable manner. For example by avoiding disturbance to wildlife species in the timing and location of any sanitation felling, considering potential wildlife impacts of control measures, such as how habitat quality in native woods will change as a result of removal of trees and other host plants, as well as disease eradication, to which pathogens, pests and diseases are selected for research, survey and monitoring and how is this carried out.

16. Are the Defra, Forestry Commission and Food and Environment Research Agency (Fera) contingency plans for managing a disease outbreak, such as Chalara fraxinea, adequate and appropriate to control its spread and mitigate the impacts of disease?

17. No comment.

18. How effective is co-ordination between agencies such as Natural England, the Forestry Commission and Fera?

19. No comment.

20. Are there sufficient resources for research to provide effective evidence on the emergence of new threats to trees and plants and for management of existing threats? Is there sufficient coordination of research effort and does the UK have an adequate pool of the right skills to draw upon?

21. The RSPB values the woodland research, survey and monitoring work, and forestry standards and practice development that Defra currently funds as reserved functions of the Forestry Commissioners through Forestry Commission “Great Britain”10 including knowledge transfer work, practical publications and seminars. This work is of value in helping to develop approaches to forest plant health, biosecurity and sustainable forestry across the UK, including countries outside the Forestry Commission’s responsibility (Northern Ireland from 1922 and Wales from April 2013) as well as in England and Scotland.

22. The RSPB, however, has concerns about the research priorities that government sets, commissions and funds in respect to the scope and extent of biodiversity work and the continued emphasis on plantation forestry.

23. The RSPB has concerns about the relative research priorities within the Government’s Science and Innovation Strategy for British Forestry11 and how this impacts biodiversity work, via Forestry Commission Great Britain’s research commissioning process and the work of its own Forest Research agency. We note that the majority of the government’s research funding for forestry is spent with Forestry Commission Forest Research.

24. The RSPB also has concerns about the limited level of stakeholder involvement in the oversight of research commissioning, setting of research programmes, advisory panels on research, and the corporate objectives of the Forest Research agency. There is also insufficient clarity on how country forestry research objectives are set and met via the Great Britain level research commissioning process.

25. Are sufficient resources being put into developing effective responses to plant health threats, such as improving resistance, biocontrols and chemical or management responses?

26. The RSPB has concerns about the relative research priorities within the Government’s Science and Innovation Strategy for British Forestry12 and how this impacts biodiversity work, via Forestry Commission Great Britain’s research commissioning process and the work of the Forest Research agency. We note that the majority of the government’s research funding for forestry is spent with Forest Research.

27. The government’s research priorities for forestry have become drawn to ecosystem services, climate change mitigation and disease control (primarily for commercial forestry), with limited work on meeting intrinsic biodiversity commitments or climate change adaptation for wildlife. We welcomed the inclusion of priority species, as well as priority habitats, in the “Ecosystems & Biodiversity Theme” of the Science & Innovation Strategy.

28. The current and future responses to Chalara ash dieback and other tree pathogens, pests and diseases need to be considered in respect to biodiversity and other public benefits, not just as commercial forestry problems that require research, survey, monitoring and control. The current disease control measures for Phytophthora ramorum—felling larch plantations and removal of rhododendron plants in woodlands—and Dothistroma band needle blight (removal and not restocking of Corsican pine trees in forestry), need to be considered in broader terms of protecting and enhancing public benefits, such as wildlife and the historic environment, and carried out in a sustainable manner.

29. The RSPB submitted written evidence to the House of Commons Science & Technology Committee Inquiry on Forest Research in June 2011, see pages w24-w27 of: http://www.publications.parliament.uk/pa/cm201012/cmselect/cmsctech/1200i/1200vw.pdf

30. Does the international regime for trade in plants and the EU plant health framework provide a sufficiently flexible and responsive framework to respond to newly identified pests and diseases or to those that are spreading? Can these regimes impede stronger import controls?

31. The RSPB is concerned about how many new tree diseases may have reached the UK. We consider that the trade in plants and animals, for horticulture, agriculture and forestry needs tightening up. The practice of collecting seeds in the UK, but growing the plants in infected areas elsewhere and re-importing these trees with infection is exposing wildlife to unnecessary and preventable threats. The work of the UK Government’s Expert Taskforce on Tree Health and Plant Biosecurity13 did not fully explore this issue to identify practical solutions to comprehensively address it in a sustainable manner that protects biodiversity.

32. The Expert Taskforce on Tree Health and Plant Biosecurity was also too focused on Chalara dieback of ash, with insufficient examination of the current and potential threats to biodiversity posed by Dothistroma needle blight, Phytophthora ramorum, Phytophthora austrocedrae and Acute oak decline, and potential practical solutions to address this within country forestry consenting regimes and UK and EU trade measures, as well as within UK, EU and International biosecurity mechanisms.

33. The Expert Taskforce on Tree Health and Plant Biosecurity also did not seem to fully recognise the UK Government and devolved administrations’ long-term commitment, policy, research and regulation for multi-purpose sustainable forest management, ie including biodiversity, landscape conservation, historic environment, recreation as well as timber and economic aspects of forestry planting and woodland management.

34. New native woodland planting must not pose a disease threat to established wildlife in mature native woods. There also needs to be improved “biosecurity” measures and traceability in the plant trade—so that anyone buying a tree to plant can be sure what it is, where it comes from, that it is disease free, and knows where and how it was grown and transported.

35. We welcome moves to improve the UK’s biosecurity with regard to species movements, to minimise further damage to the natural environment from pathogens and other invasive non-native species (INNS). The draft EU legal instrument due in September 2013 is a great opportunity to secure better regulation of INNS at the required international level. As an island nation with strong trading links, the UK stands to gain greatly by having trading partners brought to a shared minimum standard of biosecurity in this regard.

36. We would welcome improvements to the UK’s existing Forest Reproductive Materials system,14 and associated policy and land management grant requirements, to ensure traceability and transparency, from tree seed and initial plant parts to the final tree planting site, including the location of nursery grown stock and their transport routes. This would help those specifying and purchasing trees to know that the plant material had high levels of biosecurity throughout the production and supply processes, reducing the threat to the wider natural environment and to the plants being procured.

37. There also needs to be better biosecurity and traceability for the trade, production and specification of non-woodland trees in amenity horticulture, landscape management, commercial and retail plant trade, and agriculture.

38. We were disappointed that the UK Government’s Expert Taskforce on Tree Health and Plant Biosecurity final report15 did not examine the scope to refine the Forest Reproductive Materials system to enhance traceability of forest plant material in the UK, tied into land management grant scheme rules and compliance with the Government’s own UK Forestry Standard, as well as not exploring the need and scope to develop a companion system for traceability in horticulture. The RSPB considers that voluntary industry initiatives for plant biosecurity and traceability, while welcome, are insufficient on their own to effectively tackle this problem without statutory minimum requirements.

39. Are plant health controls sufficiently broad to cover trade in tree and plant products such as biofuels?

40. No. It is unclear how imported woody biomass (tree trunks, branches and roots—whole, chipped, pellets or otherwise processed) for the large-scale generation of electricity and/or heat, can be checked in a manner that will ensure no threat to the UK’s wildlife from imported pathogens, diseases and pests. Currently there seems to be little regulatory protection from this threat.

41. What lessons are being learnt in the UK from the management of Chalara dieback of ash in other EU Member States: for example on trade in plants, management of infected trees including saplings, and development of resistant trees?

42. No comment.

August 2013