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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?

Please explain your answer.
Neither.

- We agree that SFM must be not only a long-term commitment, but the driving force of any planting that takes place during the life of the strategy. The ‘bad old days’ of forestry have not yet left Scotland’s landscapes and communities, and they must be ushered out as a priority.

- We agree that the vision should focus on both existing forests and woodlands, and new plantings.

- We feel that the balance in forestry between the three pillars of sustainability is currently skewed too far towards the economic, to the particular detriment of the environment as well as society. The vision goes some way to addressing this, but until we see on-the-ground change the vision remains aspirational.

- Throughout the consultation document to date, ‘woodlands’ and ‘forestry’ are conflated. They are not the same thing, and do not have the same benefits. Native woodlands are a world apart from commercial conifer plantations in terms of biodiversity and complementation of other land uses. Whether intended or not, it appears disingenuous of this document not to expressly set out the difference by this point in the consultation.

- Non-native conifer plantations are not universally good for biodiversity; little else can grow under the dark masses, and for example, their value to several threatened bird species declines rapidly once new plantings reach thicket stage. As well as compromising local biodiversity, such commercial plantations provide refuge for predatory species that predate vulnerable species on adjacent land, a well-known occurrence that contradicts the Cabinet Secretary’s generic introductory statement that forestry complements other land uses.

- Although it is encouraging to see the vision refer to ‘the right tree in the right place for the right purpose’, we are concerned about how this will play out in practice. We do not agree with the expansion of forestry where this destroys other, rarer and more valuable habitat such as the heather moorland and rough pasture combination that is essential for so many of our endangered bird species. We do not recognise the Cabinet Secretary’s portrayal of forestry plantations ‘sustaining our unique wildlife’: waders cannot live in forests, for example. How does this vision ensure the prioritisation of species for whom expansion of plantation forestry sounds their death knell?

- We have a number of questions regarding the vision:
1. Where will this proposed expansion take place? Will easily-accessed, brownfield sites be prioritised for new non-native softwood plantings?
2. How will private forestry companies be persuaded to right the wrongs that rural people are still living with today: soured rivers, dark, oppressive landscapes, denuded biodiversity away from the forest edges compounded by the harbouring of pest species?
3. How will this expansion be balanced against the need to secure food production, non-forest biodiversity and cultural heritage?
4. How will the joined-up policy position described in the SEA look in practice? Forestry cannot be considered or delivered in isolation.

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

Please explain your answer.
Neither

- The three objectives listed are admirable, but we note yet again that the economy has been prioritised as the first objective; we reiterate our previous point that there must be balance.

- Scotland’s natural assets consist of more than just forestry and woodlands; this document speaks as though 'forests = natural capital', when the reality is broader than this. We recognise that this is a ‘forestry’ strategy, but question how it can be integrated into the delivery of the other land use strategies and visions.

- We agree that Scotland’s natural resources should be used to empower more people to improve their health, well-being and life chances, but our community has been consistently ignored and dismissed in this context. Our members are still prevented from accessing their local forest-based natural resources, when other communities are prioritised. Land reform is for everyone is Scotland, not just the publicly-palatable mountain bikers and dog walkers; the Scottish Government has set out clear guidelines on engaging communities in decisions relating to land, but forestry – both public and private – appears not to know that these guidelines exist. How, then, will the third objective be effectively delivered?

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 explain your answer.
Neither

- We are surprised but heartened to see fieldsports finally, expressly referred to in a land-related consultation document (section 4.2). We have sought this recognition for many years now, as our community is usually ignored apart from when we are considered to be a problem. Hunting, in the broad and true sense of the word, is fundamentally a legitimate part of integrated, multi-purpose land use; we are pleased to see this acknowledged.

For example, increased planting of small hardwood or mixed areas, appropriately sited on or adjacent to farmland will increase wildlife habitat as well as providing habitat for hunting opportunities: this fulfils the sustainability requirements for environmental, social and economic benefits. The grant schemes for new planting, and also for management of existing areas of tree cover, must become more flexible to facilitate this. The current grant system is a fundamental and insurmountable barrier to small-scale planting.

- We agree that children and young people should be encouraged to experience the woodland environment. Young members of our community do this by participating in hunting activities, learning about where their food comes from and about the essential role of wildlife management in maintaining a healthy environment. Thinking of the National Forest Estate in particular, our community could help to facilitate forest skills education if they were given the opportunity to do so.

- We are pleased to see express recognition that wild deer are part of forest and woodland ecosystems, as the dominant perception seems to remain that deer are no better than vermin. We have long lobbied for wild deer in Scotland to be afforded the respect they deserve, but the prevailing anti-deer narrative of commercial forestry and the Scottish Government has presented a significant barrier.

‘Sustainable management’ in a wild deer context means finding a balance between the requirements of the forestry sector and the rights of local communities who wish to reassert their inherent right to this important local food source. Currently, the pendulum has swung too far in favour of unsustainably low deer densities in forestry. In particular, the deer management approach adopted by Forest Enterprise is dysfunctional and unsustainable. We wish to know how this strategy intends to correct the balance.

- Water quality remains an issue in many areas. We are aware of locations where forestry plantations drain directly into watercourses that used to be salmon-spawning grounds. Brown trout and other species have all but disappeared because of years of compromised water quality. How will this strategy right these wrongs?

- Landscape quality: many of Scotland’s most iconic landscapes are open. Domestic and international visitors value wide vistas that include heather moorland and open hill, as well as the montane environment. The landscape quality of Galloway, for example, has in the eyes of many people been compromised by commercial afforestation. Similarly, ‘the rolling hills of the Borders’ does not refer to masses of dark conifers. To be truly sustainable, this strategy must recognise that large, non-native conifer plantations are abhorrent to a significant number of people. This view may not suit the Government’s agenda, but to pretend it is an obscure or minority opinion would be disingenuous and against the principles of community engagement.

- Community land ownership/management: we support and encourage this where it is properly resourced, not only financially but also in terms of necessary professional management skills. We have previously requested better access to management of natural resources including wild deer populations for our community; the Scottish Government and its agencies are well aware of this, but have yet to deliver despite the clear social, economic and environmental benefits of our proposals.

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?

Comments.
Neither

- See our earlier comments on the objectives and vision.

- In Table 1, the relationship between wild deer and people should be amended to ‘medium’. It is people who manage deer, and more local people would have access to do so if the principles of sustainability were genuinely followed in the forestry sector.

- To promote the sustainable management of wild deer, the Scottish Government must commit to collaborating effectively with SACS and our community. As we are demonstrably the most forward-thinking, experienced and committed representative of recreational and community deer managers in Scotland, we are clearly a key stakeholder and part of the solution to find equilibrium for wild deer.

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

Comments.
N/A

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

Comments.
N/A

Monitoring and reporting

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

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Please explain your answer.
- We suggest the amendment of ‘area of forests and woodlands that are owned by communities’ to ‘area of forests and woodlands that are owned or managed by communities.’ Ownership is not always the most appropriate option for community groups; management rights can be readily granted via lease or licence, and these options must not be overlooked as they have the potential to significantly contribute to the Scottish Government’s land reform objectives.

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

Comments:
N/A

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

Comments:
N/A

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.
N/A

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

Comments.
N/A

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

Comments:
N/A

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

Please provide details.
N/A

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

Comments.
N/A

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

Comments:
N/A

16. Please provide any other further comments you have on the Environmental Report.

Comments.
- Forestry has greater potential to be a genuinely multi-purpose land use, if an innovative mindset free from prejudice and historic baggage is adopted; however, for commercial conifer plantations, their usage is limited particularly where the solum is concerned. Planting non-native softwoods at commercial density is a land use change of significant scale and impact. Local communities must be given greater influence over the decision-making process.

- We are pleased to see that the Environmental Report recognises that expansion of forestry can pose a threat to deer and deer welfare due to displacement and habitat loss. SACS has repeatedly raised the issue of inappropriate afforestation on traditional red deer hill hefts, for example, but this serious threat to one of Scotland’s most iconic species is ignored by the Scottish Government. It is not clear how the strategy will seek to resolve this.

- We are interested to see that the report states that effective deer management can be challenging. The Scottish wild deer sector is dysfunctional in many ways, but solutions are possible. The Scottish Government and its agencies need to engage more effectively with leading stakeholders such as SACS in order to facilitate these solutions.

Conclusion

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

Comments.
- Grant funding: as previously stated, grant funding must become more flexible and driven by results rather than process.

- The foundation of the delivery of this strategy is people. We have witnessed intransigence, incompetence and protectionism throughout the land management sector in Scotland; mediocrity knows nothing higher than itself, and until problematic personality issues are effectively resolved, successful delivery of this strategy will be extremely challenging. In playing our part in its delivery, we look forward to working with competent individuals who share our vision for equity and genuine collaboration. Where barriers are identified, we hope that the Scottish Government has prepared an effective mediation strategy to move forestry stakeholders towards a resolution for the good of all.

About you

What is your name?

Name
Julia Stoddart

Are you responding as an individual or an organisation?

Please select one item
(Required)
Radio button: Unticked Individual
Radio button: Ticked Organisation

What is your organisation?

Organisation
SACS