Royal Commission on Environmental Pollution

I refer to your letter dated 27 March inviting the Forestry Commission to submit its views on the Royal Commission's study of environmental planning.

I enclose the Forestry Commission's contribution which I hope you will find helpful.

The Forestry Commission
2.      The Forestry Commission is the Forestry Department of the UK Government and of the devolved administrations in Scotland and Wales. The Commission provides policy support and advice to forestry Ministers in England, Scotland and Wales, promotes forestry and encourages good forestry practice. It achieves this through setting standards for forestry, providing information and offering grants for expanding, regenerating and managing forests and woodlands. The Commission has statutory duties to regulate forestry through environmental impact assessment and the control of tree felling, and to protect forests from pests and diseases.

3.      The Forestry Commission is also the largest single land manager of forests and woodlands in England, Scotland and Wales. Through its management agency, Forest Enterprise, the Commission manages some 40% of the forests and woodlands in Great Britain. The Commission's activities are set out in its Corporate Plans for England, Scotland and Wales.

Forestry Policy
4.      The context for the Royal Commission's study is sustainable development. Current forestry policy is based firmly on the principles of sustainable development.

5.      At the 1992 United Nations' Conference on Environment and Development in Rio de Janeiro (the 'Earth Summit'), the UK Government was a signatory to Agenda 21, a plan for attaining sustainable development in the 21st century and, with 170 other countries, adopted a Statement of Forest Principles. This was the first global consensus on the management of the world's forests. The Forest Principles state that:

"Forest resources and forest lands should be sustainably managed to meet the social, economic, ecological, cultural and spiritual human needs of present and future generations".

• Guidelines for the Sustainable Management of Forests in Europe - agreed at Helsinki in 1993;


• Guidelines for the Conservation of the Biodiversity of European Forests - also agreed at Helsinki;


• The Declaration and Resolutions of the Pan European Ministerial Conference on the Protection of Forests in Europe - agreed at Lisbon in 1998.

Sustainable Forestry in the UK
8.      Sustainable forestry is one component of the UK Government's wider commitment to sustainable development. In 1999, the Government published a revised Sustainable Development Strategy A Better Quality of Life which contains a section on Forests and Woodlands setting out the contribution that forestry can make to these wider sustainable development objectives. The Government's approach is based on the sustainable management of existing woodlands and forests and a continuing expansion of the woodland area.

UK Forestry Standard
9.      The international agreements have stimulated worldwide interest in sustainable forestry, and brought pressure to develop internationally recognised measures for it. A range of criteria of sustainable forest management has been agreed for European conditions.

10.      In 1998, the Government published a UK Forestry Standard bringing together in one document the criteria and standards for the sustainable management of forests in the UK. A copy of the Standard is enclosed. The Standard provides a single comprehensive statement of the Government's approach to Sustainable Forestry. The Standard is linked to the developing international protocols for sustainable forestry, and explains how the principles of sustainability will be delivered in practice and what the international commitments mean in British conditions.

11.      The criteria and national sustainable forest management requirements are set out in the Table at Annex 1. The first column sets out the criteria covering the key aspects of sustainable forestry in the UK; the second column shows the requirements for national sustainable forest management.

12.      The Standard now also forms the basis for the UK Woodland Assurance Scheme (UKWAS) - a market-based instrument for the voluntary certification of sustainable forest management (see paras 24-26). In 1999, the woodlands managed by Forest Enterprise were certified under the UK Woodland Assurance Scheme.

Environmental Sustainability
13.      Forestry policy throughout most of the twentieth century was based primarily on an expansion of forest cover. This was driven largely by strategic and economic considerations to create a major new resource of timber. This resulted in an expansion of forest cover from around 5% in the 1900s to around 15% at the end of the century. During the 1970s the single-minded expansion policy led to criticism, particularly from environmental organisations, about the impact of afforestation on other land uses and the loss of valuable semi-natural habitats (for example, heathland and moorland). The legacy of the post-war forestry policy, which had sought to re-establish woodland cover following centuries of deforestation and fragmentation, has been the creation of major new woodland and forest resources. In spite of mistakes, forests have been created again where there had been none for generations. Careful management can now ensure that these become a sustainable resource for the future.

Planning and Regulation
14.      Successful and sustainable forestry is a highly planned activity - otherwise it will fail to achieve its environmental, social and economic objectives. The Royal Commission study (question 2e, Annex A) asks whether the lack of control over forestry and agriculture prejudices the achievement of environmental goals. While forestry, like agriculture, is outwith the scope of planning controls, it is nevertheless a highly controlled and regulated activity. Forestry operations are subject to the provisions of the environmental protection legislation and regulated by the Forestry Commission. The background to these regulations is set out below.

Environmental Impact Assessment
15.      Forestry projects (new planting, deforestation and the creation of forestry roads and quarries) are subject to Environmental Impact Assessment (EIA) for which the Forestry Commission is the competent authority. If an EIA is deemed necessary, it becomes part of the application that goes out to consultation. Where a forestry project which would have required EIA is carried out without such as assessment, the Forestry Commission has enforcement powers to require restoration work to be carried out.

Regulation of New Forestry Planting
16.      Government policy implemented by the Forestry Commission is to regulate the continuing expansion of woodlands by Environmental Impact Assessment and incentives. Grants to plant new woodland are given on the basis that schemes are planned and organised to conform to the UK Forestry Standard. New woodlands planned by Forest Enterprise are regulated through approved Forest Design Plans and are subject to the same scrutiny for conformity to the Standard.

17.      New woodlands require a design plan for approval. Assuming that the plan is properly prepared and conforms to the UK Forestry Standard, it is subject to public consultation procedures operated by the Forestry Commission. The formal consultation procedures involve statutory agencies, the local planning authority and the public. Where problems are found (and most of these relate to environmental protection or to amenity) they are usually resolved by modifying the plan; where they are not a Regional Advisory Committee acts as arbiter; and where objections cannot be resolved a Ministerial view will be sought before a decision is given.

Regulation of Tree Felling
18.      In existing forests, tree felling is potentially the most damaging operation to the environment. This can impact on the landscape, and, if not carried out properly, can damage soil, and cause sedimentation and nitrification of watercourses. Tree-felling operations - and subsequent replanting - must be planned to protect the environment. Guidance is given in the UK Forestry Standard and in a range of supporting guidelines and other literature. Felling requires a Felling Licence issued by the Forestry Commission (except for very small scale felling, or where planning permission has been granted, for example for roads, housing or industrial development). Applications to fell must be accompanied by plans to replant. Felling Licence approval is subject to the same consultation procedures as approval for new planting.

Integration and Co-ordination
19.      Forest planning, both for new planting, harvesting and replanting, is therefore a consensual process. There is a clear, transparent and workable mechanism that can be built on to address some of the concerns relating to integration and co-ordination underlying the Royal Commission's questions in key theme 3 of Annex A. For example, transport of timber is a current concern, especially in Scotland and the Forestry Commission is in discussion with hauliers and local authorities to improve the strategic planning of harvesting and wood haulage.

20.      The Forestry Commission is satisfied that the arrangements noted in the foregoing paragraphs do provide an appropriate balance in answer to question 4a of the study, and that they address the concerns underlying question 4b. As already noted, one of our objectives is to increase local involvement of communities in forestry and we are conducting research to find how this may be done more effectively. We would hesitate to endorse regional or national forestry planning procedures that weakened the opportunity for stakeholders to influence owners, managers and Forestry Commission staff. The importance attached to consulting local interests is made clear in the UK Forestry Standard.

Best Practice
21.      Annex A of the draft Commission's study makes a number of references to protection of water quality and quantity. It is therefore worthwhile to note that evaluation of planting or felling plans includes close attention to water protection. Best practice is laid down in the Forestry Commission's Forests and Water Guidelines. The issue of acidification is of special concern. The presence of conifer forests, especially in the uplands, can increase acidification through their ability to scavenge pollutants from the atmosphere. Watercourses are routinely protected by special provisions for management of the riparian zone - another vital facet of forestry planning. However, in highly sensitive geologies this is not thought to be sufficient and a critical loads approach is adopted. Further afforestation is not approved in areas where critical loads might be exceeded. Reappraisal of the critical loads is a function of collaborative work by the Forestry Commission, the Environment Agency and the Scottish Environmental Protection Agency and expressed through revision of the Forests and Water Guidelines.

22.      Guidelines have also been published for landscape design, nature conservation, recreation, soils and archaeology. These all support the UK Forestry Standard by providing detailed guidance on issues, methodologies and practices.

Monitoring and Compliance
23.      Compliance with the provisions of the UK Forestry Standard and its supporting literature is monitored by Forestry Commission staff. There is also a national programme of monitoring the Standard carried out by independent third parties. It is also the responsibility of the Forestry Commission to monitor and re-examine the Standard itself, to ensure that its provisions do indeed represent sustainable practice and to reflect the findings of research on environmental protection.

Independent Forest Certification
24.      Forest certification under the UK Woodland Assurance Scheme (UKWAS) is an interesting recent development that we believe is relevant to the Royal Commission's consideration of environmental sustainability and protection. Following concerns about global deforestation and illegal logging of timber, a number of environmental and forestry organisations jointly set up the Forest Stewardship Council (FSC) to promote sustainable forestry through the independent assessment of forest management. The FSC's forest certification scheme provides a "label" for forest products that come from forests that are managed according to criteria derived from international agreements on sustainability. The forestry sectors in most countries have been slow to accept certification. However, in the UK in 1998, the Forestry Commission, FSC and the wider forestry industry recognised that they shared a common aim - of sustainable forest management - and that the FSC's Standard was similar to the government's UK Forestry Standard. Negotiation, facilitated by the Forestry Commission, produced a Standard for the certification of forest management which has the support of all parties - the UK Woodland Assurance Scheme Standard.

25.      Woodlands judged by auditors to comply with the Standard are awarded a certificate which enables products from those woodlands to carry an FSC label. This label has strong market credibility, especially amongst retailers in the UK, and is becoming a common requirement for traded wood products. An increasing number of UK woodland owners and managers are seeking to achieve certification. Their woodland is inspected annually to ensure compliance. As a market based instrument, forest certification has the potential to usefully complement the Government's promotion and regulation of sustainable management.

26.      The UK Forestry Standard and the UKWAS cover a very wide range of issues directly relevant to the protection of the environment, the landscape, cultural and spiritual heritage, and to the welfare and livelihood of local communities. This combination of market demand and Government regulation promotes a culture of "plan, monitor and manage" (this is relevant in response to question 1e of Annex A) in woodlands in the United Kingdom.

Conclusions
27.      The current environmental planning procedures in forestry have been developed over the years to reflect the cyclical nature of the activity. As noted above, we believe that they work well and provide a robust platform for future improvement. They include a mix of statutory regulation, market-based mechanisms, and incentives. As a result the level of "fixing" (question 3a of Annex A) required to cope with future pressures may well be small. In relation to climate change, which is referred to in a number of your questions, we anticipate a need to integrate forestry activities more closely with other land-uses, particularly where protection of water resources and conservation of biodiversity are priorities. In both cases, the siting of woodland and its design can help in achieving national objectives, and forestry can play a direct role in reducing global warming.

28.      We are confident that the present safeguards can continue to protect and enhance the woodland environment. This will, however, increasingly require partnership and collaboration with other organisations, agencies and individuals. That partnership has deepened and widened in recent years and we are aware of no obstacle to further progress.

DELIVERING SUSTAINABLE FOREST MANAGEMENT

Back to Index of evidence to the Environmental Planning Study