Royal Commission on Environmental Pollution

Thank you for your letter of 27 March, inviting our views. The Timber Growers Association represents the interests of private sector forest and woodland owners in Great Britain. The following comments relate to the numbering in your Annex A.

1.       Environmental Sustainability
(a)       The term "sustainability" is often used quite loosely. It has certainly given environmental issues a higher profile. Some specific economic and local environmental problems have occurred as the inevitable switch by many timber processors from use of sustainably produced round timber to recycled wood products has further reduced demand for the lower value forest produce in a continuing weakening market (due to the strength of the pound). Because a form of cross subsidy exists where all forest owners subsidise the costs of non-market benefits from the timber sales income - a direct detrimental effect will inevitably occur if prices fall further. A proportion of the Land Fill Tax (which distorts the recycled material market) could be fed directly into contributing to the cost of non-market benefits where there is public gain such as access, landscape and ecological benefit. Local pressures have also been perceived to occur with an increase in fly tipping - often now suggested as a landlord's responsibility to clear up.

(b)       No.

(c)       Regulatory management has been developed and implemented through Felling Contracts, WGS Schemes and the use of the UK Forestry Standard and appropriate guidelines. The role of the Forestry Commission in funding, administrating and managing the natural woodland resource should be recognised and strengthened using these existing standards.

(d)       Forestry land use planning currently presumes in favour of constraints. A more balanced approach including sustainable economic requirements of owners and the nation should be recognised. In particular the importance of setting national and regional forestry targets should be recognised and implemented when local and national planning guidelines such as landscape standards, Forestry Frameworker or Indicative Forestry Frameworks are drawn up and implemented.

(e)       Funds for monitoring have always been insufficient. It is not part of planning responsibilities to manage.

(f)       The new Forest Plans scheme recently introduced by the Forestry Commission recognises cumulative impacts of forestry activities for a period of 20 years or more.

(g)       The extent of Consultation in WGS and in particular Forest Plans is costly, often repetitive, or causes delays in approval which could have been avoided. In particular, the scale of consultation and the importance placed on many of the constraints compared to an owners objectives of potential production and financial return significantly increases the risk of an application failing. This increase risk must reduce applications and therefore contribute to the failure of the governments objectives of forest expansion.

(h)       Planning schemes may wish to specify the use of environmental products such as sustainably produced timber.

2.       Boundaries
(b)       In forestry the recent move to more extensive local consultation has not been matched by the balance of regional and more importantly National Forest Policy. This is typified in the Local Forestry Framework Pilots in Dumfries & Galloway, for example. In these cases local expectations have been raised, without recognition of the National Policies or the significance of the local issues in a regional context. Without very clear feedback to communities, schemes such as these may well frustrate local enthusiasm. Alternatively the outcome of such consultations will become local constraints maps which frustrate the achievement of National Policy.

(c)       Yes.

(d)       G.I.S. can contribute provided the data is sufficiently comprehensive, and contains sufficient detail of natural systems and flora and fauna in rural situations. G.I.S. can most help the planning process through its ability to communicate information, in particular the transfer of information to stakeholders and two-way communication between planners and practitioners who implement activities. Release of information in G.I.S. format needs to be encouraged.

(e)       In forestry extensive control exists through the UK Forestry Standards and related guidelines and the current F.C. felling and grant scheme controls. The Forestry Commission should remain the lead body for Forestry planning and development and we should avoid duplication of effort (and cost) by introducing Forestry into other forms of planning control.

3.       Integration or Co-ordination
(a)       Forestry Commission control generally works well. The introduction of Forest Plans will further improve the environmental planning in forests.

One difficulty in the Forestry Commission Consultation process is the ability of statutory organisations to comment without responsibility. Consideration should be given to comments being restricted to their own area of public benefit or loss. Contribution to costs for environmental proposals beyond the current UK Forestry Standards should come from that strategy consultee. Non statutory consultees should only comment through the relevant statutory committee to ensure the views of a single issue organisation are considered in a balanced way in the wider context.

(d)       Environmental protection already occurs in Forestry through the use of UK Forestry Standards.

(g)       It is not clear what is meant here. Forestry grants carry environmental commitments. The addition of non-statutory procedures will be cumbersome and not always acceptable.

(h)       Any form of further taxation in the countryside will further threaten rural communities and businesses. In forestry in particular the aim should be to reduce taxes and other burdens because of the positive contribution UK forests make to sustainable development.

4.       Subsidiarity and Democracy
(a)       No system is perfect, but subject to guidelines at national (i.e. England, Scotland, Wales) level and adequate resources - the system should work reasonably.

(b)       A balanced professional view - with opportunity for appeal - should be used to resolve conflicts at local, regional and national level. In the case of Forestry this should be carried out by the Forestry Commission. Linked to this should be the feedback or education of local communities on why decisions have been made and the likely consequences.

(e)       National Policy does not need to differ, but may do in several areas. These will then be considered in the context of the UK, regional, local issues when decisions are made.

(f)       The system of Regional Advisory Committees in forestry should continue.

(g)       The cost would be significant.

5.       Assessment Approaches
(a)       Use of agreed thresholds between agencies, eg a regional council may only be informed of forestry proposals if over a certain area. Thresholds may vary depending on land classifications.

(b)       Environmental Appraisals should only be called when significant changes are likely. In forestry the judgement would be made by the Forestry Commission. Such appraisals should be limited to where "significant detrimental change" is possible. In general the improvement of biodiversity or social benefits would reduce the likelihood of an approach being made.

(c)       Greater knowledge of our environment would benefit implementation of national policy. However the total costs of all those involved should be balanced against the potential gains before such tools are invoked.

(d)       In woodlands the knowledge base of commercial forestry is good. However the knowledge base by other agencies and owners of the non commercial benefits is generally poor. Encouragement of owners to use survey techniques - preferably backed up by access to G.I.S. would be appropriate. Constraints are currently financial.

I hope you will find these comments helpful.

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