Options for Forestry

31 March 2005

Mr W Webb

Forest Service Headquarters
Dundonald House
Upper Newtownards Road
Belfast
BT4 3SB

Dear Mr Webb

RE - OPTIONS FOR FORESTRY IN NORTHERN IRELAND - CONSULTATION PAPER

Council welcomes this opportunity to comment on the above consultation paper and would advise as follows: We express disappointment with the main thrust of the original document, concentrating as it did on a continued policy for the production of predominantly low-grade softwoods. Timber prices for low-grade softwoods have been in decline for some time now and in many situations the costs of growing and harvesting far outweigh the income generated. Whilst some of the blame for this can be levelled against the strength of the pound, we must face the fact that timber production is currently based, primarily, around the production and bulk marketing of a low value undifferentiated commodity, traded on an international market that is largely demand led. Forestry strategies seeking to deliver a more competitive coniferous resource should also recognise the presence of the timber processing industry in Northern Ireland that is becoming increasingly dependent on raw material imports and therefore must work to deliver a competitively managed resource that recognises all benefits accruing from sustainable forestry. Consequently Council believes that a policy statement on Forestry in Northern Ireland affords an opportunity, not only to improve and enhance our forests and encourage competitive management but also to highlight their worth in the wider social, economic and environmental context. The policy statement must reflect what society wants, in terms of a well cared for countryside delivering a whole suite of benefits, one of which can still be timber. This need not be just undifferentiated conifer, but rather quality hardwood, grown and used locally.

A forest strategy that recognises all benefits, will encourage the development of woodland and protect some of our unique habitats of established woods. Council suggests that any policy statement must recognise the need to protect our small but precious heritage of ancient woods. Ancient woods are timeless places of great beauty and tranquillity, enriching the lives of those who live near them or are able to visit them. We should not underestimate the emotional response that many people have to trees and woodland. Indeed, their presence or absence may be a defining factor in determining people's perception of the quality of their local environment. All ancient woodland still extant should be deemed worthy of designation; a view that we would wish to see reflected in the statement. Additionally, this limited resource must be afforded protection through the planning system and by the reintroduction of felling licences, bringing Northern Ireland into line with Great Britain. We also see the need to introduce a planning policy statement that says unequivocally that in general development will not be permitted on land were trees have been felled recently to make the land available.

While the statement does refer to the "effect of global warming", the issue of climate change must be addressed in more depth. Because woodland cannot quickly adapt, it and the thousands of life forms that depend upon it are especially vulnerable to the effects of climate change. We must protect, restore and extend ancient woods to make them self-sustaining. This will involve a joint effort with many organisations, departments and individuals working together on a landscape scale. We would like to encourage the development of connectivity between existing woodland areas by the provision of grants for widened hedges, effectively creating linear woodland between the existing woodland pockets and buffering and extending existing woodland. Council suggests that the policy statement should also reflect the wider value of trees and woodland. Trees and woods have a unique role to play because they are host to a variety of wildlife, provide opportunities for recreation, ameliorate pollution, generate oxygen, store carbon, help to stabilise the soil, provide renewable resources and provide us with raw materials and shelter. Of particular value to the urban environment is the role that they play in helping to clean the air, trapping dust, reducing storm water run off, reducing noise and pollution, and helping to reduce asthma levels. Less tangible but crucial is their role from an emotional and recreational standpoint to individuals in providing a tranquil environment for spiritual renewal. The UK Government has rightly identified access to local green space along with quality of surroundings, as indicators of sustainable development.

To reiterate trees, woodland and other green space are all important in fostering biodiversity, in enhancing human health and well being and reducing noise and pollution.

QUESTION I

Is there public support for the proposal to change the statutory basis for the existence of the Department's forests?

Council welcomes and supports a proposal to change the statutory basis, if this was felt necessary to ensure that the major non-monetary benefits of forests are to be recognised and addressed. As the paper rightly highlights, those non-monetary benefits range from quality of life, biodiversity and contribution to mitigating the effects of climate change on our natural heritage. We recognise the damage done by forestry in the past to sensitive habitats such as upland peatland, open moorland or native woodland and would advocate the need for a strategic programme of restoration for these habitats in conjunction with other strategies such as the peatland strategy and relevant species and habitat action plans. We would also like to stress the importance of any future statement addressing the need to restore all Planted Ancient Woodland sites, both in public and private ownership. In the next ten years most of the conifers planted on ancient woodland sites will reach economic maturity. If they are felled and replaced by more conifers, the wildlife dependent on ancient woodland will not survive. We believe expansion should be viewed as an opportunity to increase the area of semi-natural habitat, while also recognising the additional value that it will provide for access, recreation and tourism etc. We would therefore welcome any proposed changes that will ensure that our forest resource is recognised for the many benefits it affords beyond timber production.

QUESTION 2

Will the proposals to transfer responsibility and resources for public access to local authorities improve the arrangements for access to forests?

(a) Council is pleased to note and agree the Forest Service view (Para 18) of the existing and potential 'public good' value of the Forest Service estate. It is therefore all the more important to ensure the optimisation of that publicity owned recreational and tourist resource. However there are other publicly owned lands and recreational facilities e.g. Water Service, DCAL and Local Authority Estates and CNCC, acting within its statutory advisory role on amenity, would urge that an all embracing strategic approach be adopted to the use of the total publicly owned estate in NI for recreational and tourism purposes. Forest Service is to be commended for initiating that debate with its proposal to transfer responsibility for development and management of recreation and tourism facilities in its forests. Council believes that DoE should initiate a study of the potential for an integrated strategy for recreation and tourist use covering the total public estate. That study should be pursued with public health and quality of life objectives as well as development of tourist facilities for economic reasons.

(b) Council gives a qualified welcome to the Forest Service proposal to create a statutory right of access on foot to its forests which presumably means statutory assured access to anyone using the forest estate for walking recreation. While this proposal is welcome it makes a clear distinction between a right to have walking recreation and a right to use of Forest Service Lands for any of the many other non-walking recreational activities to which those lands lend themselves. Council would be concerned that the granting of a statutory right to a specific activity might in practice provide grounds for curtailment of other recreational, management and tourist activities.

If there is an assumption for multiuse access and not just one statutory activity allowed we would recommend that a review is carried out on potential conflicts between activities and access issues.

As to the Forest Service proposal per se it is perhaps not timely in view of the current Review of Public Administration. The uncertainties involved, both in relation to the number of Councils and the range of functions, make assessment of the merits or otherwise of the Forest Service proposal quite difficult. There must be real concern about the consistency of delivery of a transferred function across 26 Councils. Although the situation would be relatively better with fewer (and stronger) Councils. In this context an examination of the record of the 26 Councils in delivering their existing statutory public rights of way functions shows such variation in performance as to raise concerns regarding the overall benefits of the Forest Service proposals. Pressure on Council budgets can lead to prioritisation of functions which can impact on delivery of meaningful or effective outdoor recreation facilities.

(c) Irrespective of where the Forest Service proposal on transfer to LAs leads it is worth noting in the context of access the Woodland Trust's recent study 'Space for People'. In addition 'Woods for People' is the first time that an attempt has been made to collate spatial information on accessible woodland and has enabled a detailed analysis to be undertaken of where these woodlands are located in relation to homes.

The Woodland Access Standard developed by the Woodland Trust will help to identify where new access opportunities are needed within existing woodlands or by creating new woodlands. The importance that woodlands in private ownership might contribute cannot be over emphasised and we recognise a need for incentives to make this happen.

QUESTION 3

Do the proposals for future afforestation provide an appropriate balance between encouragement of forest expansion, the needs of agriculture and protection of the environment?

We welcome the idea of a more strategic approach in respect of future planting. Council believes that the work of Woodland Trust currently underway to produce an inventory of long established and ancient woodland in Northern Ireland, should be seen as the first step in identifying areas suitable for woodland expansion, in order to ensure the conservation of what exists and to ensure its continued existence through buffering and expansion.

It is our view that the effects of other land uses, such as intensive farming on land surrounding semi-natural habitats, should also be addressed in any future policy statement. Strategic identification of land for commercial production recognising land use policy changes, potential climate change and habitat action plans would allow appropriate development to support the timber processing industry in Northern Ireland. This highlights a need to recognise the potential impacts of other sectoral policies.

QUESTION 4

What aspects of tree felling and forest management should be controlled through regulation?

In respect of regulation, Council suggests that in the first instance a need for a statutory designation to ensure the absolute protection of our long-established and ancient woodland as established by the ancient woodland inventory. In addition we would wish any policy statement committed to reviewing the correct protection afforded to ancient/long-established woodland, including planted ancient woodland sites, ancient trees and the introduction of new measures to ensure the future protection of this most precious of resources. We are not convinced that Tree Preservation Orders or the need for an Environmental Statement or CMS and ESA schemes provide adequate cover against the destruction of woodland and would welcome the reintroduction of a requirement for felling licences. Within the commercial sector, consideration should be given to forestry operating under independent certification such as UKWAS. Like all controls, it should be appreciated that there will be a requirement to resource their enforcement.

Council has no objection to proposals to amend the Forestry Act to provide powers to monitor and, if necessary, control deer and other large mammal populations.

QUESTION 5

What other measures are required to secure timber production, ensure forest regeneration and equitable use of minor roads?

Council would advocate that in agreeing a forestry strategy for NI that recognises forestry's economic environmental and social benefit there should be a review of supporting strategies and land use incentives to ensure the continuation of delivery of benefits outside government. For example, the woodland grant scheme should encourage woodlands to be managed under a continuous cover regime, and whether continuous or clear fell/ restocking woodlands should be encouraged to be managed under a certified scheme. Grants given should encourage the strategic planting of private woodland to provide a resource for both habitat protection and access provision that delivers a greater benefit than that of small disparate pockets of woodland Accountability of one sector for damage to roads should also recognise the impact on the road infrastructure for all sectors including agriculture and quarries. We would recommend parity of treatment across sectors.

QUESTION 5

How consistent is Forest Service's preliminary analysis of the equality implications of its policies with the experience of people within any of the Section 75 groups? Council has no comment.

Finally, we understand that the current revision in respect of the current UK Forestry Guidelines will afford an opportunity to look at some of the practical issues in relation to delivering some of the issues raised above. I trust these comments are helpful.

Yours sincerely

Dr Lucinda Blakiston Houston
Chairman