Response 226139262

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50-year vision and 10-year objectives for forestry in Scotland

1. Do you agree with our long-term vision for forestry in Scotland?

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Radio button: Unticked Yes
Radio button: Ticked No
Please explain your answer.
1. Scotland is NOT part of the northern boreal zone as stated: it is in the oceanic Atlantic zone. Hence our forests are ecologically different from boreal forests.

2. "Ever since the first foresters entered Scotland's ancient wildwood over 6,000 years ago, our trees and woodlands have been felled and harvested." Where is the evidence for this? Most modern research indicates natural woodland decline from a postglacial maximum – as would be expected in this, the oligocratic phase of an interglacial. Woodland loss directly attributable to humans has probably been relative small scale.

3. Hence although the "chronic lack of trees" is a "strategic problem for the country" from a timber industry perspective (although it might make more economic sense to import timber from boreal forest zones), in this vision it is conflated with a perceived 'biodiversity problem'. If the open landscape of our hills is largely natural, then there is no biodiversity case for bringing trees back: such intervention will only reduce the naturalness and lower the existing biodiversity value.

4. The fact that Scotland has a lower than average woodland cover compared to the rest of Europe is certainly relevant in creating a timber industry, but provides no justification for expanding woodland cover for the benefit of biodiversity. The 'lower than average' woodland cover is in fact a key biodiversity feature which distinguishes Scotland from Europe and ought to be retained.

5. It should be realised that there is an irreconcilable conflict between maintaining/expanding a forestry industry and the conservation of Scotland's biodiversity and natural landscapes.

6. The statement that 'forests and woodlands help mitigate climate change by absorbing carbon' needs much greater scientific scrutiny: tree planting on organic rich soils (as found in most of the uplands) can release more carbon through soil oxidation than is stored by the trees; can prevent shallow organic soils from going on to develop into peat bogs (which would store more carbon in the long run); and, importantly, by significantly reducing the albedo of the landscape, can contribute to a WARMING of the landscape. Additionally, the soil disturbance associated with modern mechanical harvesting can also liberate the stored soil carbon.

7. Creating new forests on open ground, much of which is recognised as being of international importance under the EU Habitats Directive, in fact, by reducing the naturalness of the landscape, contributes to global habitat loss – and so can be seen as being detrimental to biodiversity conservation. Certainly if trees are planted on moorland, the diversity of species can increase with both woodland and open ground species now being present; but biodiversity conservation is ultimately about maintaining the natural habitats of the region, not adding species willy-nilly.

8. Evidence suggests a natural woodland decline over the past few millennia and reversing such a trend is more about zoo-keeping than nature conservation (sensu allowing natural processes to proceed at the landscape scale). The natural woodland cover of 4-5% cannot really be seen as 'a key part of Scotland's iconic landscapes', but more as adding local landscape interest in a few places. From a conservation perspective, the management of the whole upland landscape should not be predicated on the needs of a habitat types which naturally would play only a minor and declining role.

9. Some of the other benefits of forests are questionable: "purify the air and water" – conifers extract acidic aerosols, causing water acidification; forests will not reduce flood risks from extreme rainfall/snowfall events when most damage is done; landslides on Scottish hill slopes occur on both forested and unforested ones – is there any evidence trees will prevent them?

10. Forests in lowland and urban settings can improve the landscape setting and provide places for recreation. However commercial hill forests are the same across the country, and modern industrial-scale forest access tracks are not very inspiring places to walk along! Modern upland forests are currently in the extraction phase, and the resultant landscape can, for a few years, take on the appearance of a post-apocalyptic wasteland!

11. THE VISION: it is not clear what is the difference between "sustainable modern foresty" and just "forestry".
In my view, there should be no further forest expansion in the uplands for the reasons stated above – and to maintain Scotland's unique and distinctive upland landscapes: instead there should be a moratorium on new forests, with management restricted to existing ones. However there is scope for woodland expansion in lowland and urban settings.
"Multi-purpose forestry" can hide the fact that, for commercial reasons, a sustainable forest income can only be had by a significant proportion of the forested landholding being managed to optimise commercial return (i.e. Sitka spruce monoculture, clear-felled coupes, extensive engineered tracks, mechanical harvesting with resultant soil damage, and mechanical brash clearance).

2. Does the strategy identify the right objectives for forestry in Scotland over the next 10 years?

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Radio button: Unticked Yes
Radio button: Ticked No
Please explain your answer.
1. I think forestry cover in Scotland has reached saturation point (if we want to conserve our distinctive, internationally valued open landscapes); if increased income can be had through better management of the existing forest estate, then that is fine.

2. The main reason why native woodland naturally declined from its post-glacial maximum is that the woodland ecosystem is NOT resilient in the Scottish soils and climate: it is very susceptible to dying out through lack of regeneration owing to multiple causes (including grazing by indigenous herbivores). From a nature conservation perspective aiming to create native resilient forests while maintaining a natural herbivore population is pie-in-the-sky! The reasons why our upland landscapes are open and unwooded is that moorland ecosystems are the resilient ones: to varying climate, soils and grazing. Some ecological reality is needed!
"Healthy and high quality environment" is too vague a phrase to comment on....

Realising the vision and achieving the objectives: the major issues to be addressed

3. Do you agree with our assessment of the major issues likely to have the greatest impact on the achievement of our objectives?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Please explain your answer.
1. Analysis of timber supply and demand is fine. However, to increase supply will need new forests, which conflicts with maintaining Scotland's internationally valued landscapes. Import of timber from nearby European countries with greater natural woodland cover does make economic sense, and is an option which should be considered as an alternative to increasing Scotland's woodland cover.

2. There may be some scope for better integration between forestry and farming at a farm level, although care needs to be taken that the new woods created are not sited on important habitats and will result in the economic return predicted: and that the farmers themselves are happy to be both farmers and foresters!

3. CLIMATE CHANGE: The stated benefits of new Scottish forests in mitigating climate change are questionable: see comments above on Qu.1. For example, an IPCC report of 2007 concludes "Surface albedo change may therefore provide the dominant influence of mid- and high-latitude land cover change on climate." Tree planting could in fact accelerate climate change owing to the reduced albedo of forests being of more importance than the carbon storage.

4. WILD DEER: Certainly deer to be managed if woodland cover is the desired outcome. However, the damage to trees by wild deer is a natural process and one reason why Scotland has an open landscape. It must be realised that if woodland and deer are to be kept in balance, then the result will be an unnatural ecosystem with skewed trophic levels; this is because the carrying capacity of the vegetation for trees is an order of magnitude less than that to allow young trees to flourish. Hence there is a direct conflict with woodland conservation and nature conservation.

5. The notion of GOOD CONDITION of our native woodland is based on the assumption that all woodland should be regenerating. There is no recognition here of the conflict between allowing natural processes (i.e. ongoing millennial-scale succession to open moorland) and woodland retention (which means going against natural processes).

6. "Protecting and preserving our ancient woodlands" is certainly a challenge because it means reversing natural successional trends. Additionally, the concept of site-based "ancient woodland" needs scrutiny in that our native tree species tend to regenerate at the edge of the woods and so move around the landscape over time. Are any truly 'ancient'?

7. The role of woods in providing ecosystem services has been discussed in my answer to Qu.1. Some of the quoted benefits are questionable. In terms of enhancing landscape quality, certainly in a few locations native woods are a key feature of the landscape, but you should not generalise from this that woodlands are, at a strategic level, a key feature of the Scottish landscape. The actual key feature is the rarity of woodland in the landscape!

8. In terms of the priorities of action, my view is that there should be a moratorium on any new upland planting while the issues discussed here are thrashed out, and have a more solid evidence-base.

Delivering the vision: priorities for action and policies for delivery

4. Do the ten priorities identified capture the areas where action is most needed to deliver our objectives and vision?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Comments.
Priority 1. It is not clear to me what is meant by "sustainable forest management."

2. No! Have a moratorium on all new upland planting.

3. Wood supply should only increase with time if this can be achieved within the existing forest estate.

4. Certainly ensure there are strict import controls to stop new pests arising. However, once extant in Scotland in many cases it might make more sense to allow them to spread rather than attempt the often impossible task of eradication.
Management of deer to benefit existing woodland may be appropriate, but, from a nature conservation perspective, to manage deer across the whole upland landscape to benefit one naturally rare habitat type (woodland) makes little ecological sense and results in unbalanced ecosystems.
There is 10,000 years of post-glacial evidence to indicate that native woods are not particularly resilient in Scotland: it is hard to see how this reality can be changed.

5. Fine to encourage community ownership in appropriate places, but difficult in remoter areas.

6. Fine.

7. Waffle, with little evidence-base!!

8. Yes, in urban areas.

9. Yes.

10. Yes

5. Can you provide any examples of delivery mechanisms that have previously been effective in delivering similar objectives and priorities?

Comments.
All the evidence suggests that most land-use change is driven by grant availability.

6. For any delivery mechanism examples given in answer to question 5, please explain why they worked well?

Comments.
No comment

Monitoring and reporting

7. Do you think the proposed progress indicators are the right ones?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Please explain your answer.
They are certainly in accordance with the strategy as drafted ...

8. Do you have any suggestions for other indicators we could use to measure progress (especially ones which draw on existing data)?

Comments:
No comment

9. For any indicators suggested in answer to question Q8, please explain why you think they would be appropriate.

Comments:
No comment

Impact assessments

10. Would you add or change anything in the Equality Impact Assessment (which includes our assessment of the potential impact of the strategy on inequalities caused by socioeconomic disadvantage – Fairer Scotland Duty)?

Comments.
No comment.

11. Would you add or change anything in the Business and Regulatory Impact Assessment?

Comments.
No comment.

12. What are your views on the evidence set out in the Environmental Report that has been used to inform the assessment process?

Comments:
No comment.

13. Should any additional evidence sources be used in the Environmental Report?

Please provide details.
No comment.

14. What are your views on the predicted environmental effects as set out in the Environmental Report?

Comments.
No comment

15. Do you agree with the conclusions and recommendations set out in the Environmental Report?

Comments:
No comment

Conclusion

17. Do you have any other comments you would like to make about the draft strategy for forestry in Scotland?

Comments.
This is a very one-sided document in the sense that, unsurprisingly, it refers to woodland/forestry in isolation.

There is no analysis of the Scottish landscape as a whole, particularly the upland landscape, with an associated identification of the special qualities of the landscape. For example, most of the upland landscape is still moorland (acid grassland, dry heath, wet heath, peatland, montane) and there is no 'MOORLAND STRATEGY' to balance this forestry strategy.

There is no assessment of the landscape value of the country as a whole, the aspects which appeal to residents and visitors, and no rationale for changing the land cover which has evolved over thousands of years, and which has shaped Scotland's history and culture: no analysis of why forestry is a better land use than other land uses; on the impact of such land use change on upland farming, deer stalking, grouse shooting or wild land – and the increased compartmentalisation of upland landscape. Forestry always comes associated with new tracks, fences and ploughing/mounding which have major landscape impact.

Additionally, most of the uplands are covered with natural vegetation types of international importance (dry heath, wet heath, montane) and tree planting here contributes to the ongoing and serious issue of global habitat loss. Again, there is no analysis of this.

A good point is that there is now no target of 25% of Scotland under trees [unlesss I missed it].

There is more to the Scottish landscape than trees...

About you

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Name
James Fenton

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