Getting the best from our land, consultation on a draft Land Use Strategy for Scotland 2016 - 2021

Research Park
Riccarton
Edinburgh

The Vision, Principles and long-term Objectives are still fit for purpose, but there is now additional current / proposed legislation such as the Community Empowerment Act and Land Reform Bill which will impact on the implementation of the Land Use Strategy. An implementation plan should be introduced to accompany the Strategy so that agreed actions are delivered in the next 5-year phase.

General Comments / Introduction:

• Scottish Woodlands Ltd is one of the country’s leading forestry management companies and is predominantly an employee-owned company. The core activities are forest management, new woodland creation, timber harvesting, and generation of new forestry investment as well as utilities, landscaping and renewable energy. Scottish Woodlands operates from a network of 17 offices throughout the UK, utilising the company’s biggest asset - its staff. The business had a turnover in 2014 of £74 million.

• Woodland cover in Scotland is now 18%, with a current target of 10,000 hectares of new woodland creation per year. It is expected that the private sector will have a significant impact in achieving this target though it has not yet been achieved. There is willingness by landowners to establish new woodlands but regulation and incentives should be fair across all land uses, e.g. in comparison with forestry, agriculture enjoys significantly more support for its industry.

• In conjunction with the current Land Reform Bill, a vital question for the Land Use Strategy to address is the availability of land, especially within forestry where targets exist but land availability is a particular issue. The Regional Frameworks within this Strategy should identify where suitable land exists for different land uses; and in these cases, there should be a presumption in favour of productive woodland creation with associated deregulation. As well as producing timber and enhancing landscapes, forest habitats can assist with water and flood management in upper catchment areas in particular to reduce water flow downstream, as was seen in Pickering in North Yorkshire in the recent floods.

• In bringing land-based industries together within this Strategy, it is recognised that there are challenges in integrating and optimising land use across sectors and throughout the country, and in the context of wider climate change, adaptation and improving biodiversity. However, in supporting Scotland’s Economic Strategy “to create a more successful country, with opportunities for all of Scotland to flourish, through increasing sustainable economic growth”, the forest industry is well placed to provide many benefits.

• The forest industry contributes £1 billion GVA to the Scottish economy and employs 19,500 people in forestry and timber processing as well as providing many other environmental and social benefits.

• It is welcomed that the Scottish Forestry Strategy is to be reviewed. Achieving the forestry targets, which can help towards climate change adaptation, is a significant but necessary issue to confront. Scottish Woodlands Ltd would be keen to assist Forestry Commission Scotland with this review process.

• In addition, the Land Use Strategy should enable a mechanism that will ensure that all land managers, whether owners or tenants, are able to integrate forestry on their holdings and farms. Other public benefits will follow if a sustainable forest industry exists in Scotland.

• Scottish Woodlands is a founder member of Confor and is a member of the Timber Transport Forum. The company would support the issues raised in any responses submitted by these organisations as well as the Institute of Chartered Foresters.

• Scottish Woodlands welcomes the opportunity to comment on this draft second Land Use Strategy for Scotland, and is willing to be consulted further in relation to it.

An ecosystems approach allows the many benefits and impacts of land use to be considered in a holistic way. As is now widely acknowledged, in addition to timber production, woodlands can also help in water and flood risk management to slow river flows in the upper reaches of water catchments, sequester carbon, diversify biodiversity, enhance landscapes while offering opportunities for employment in rural areas and health/recreation. Land use integration enables forestry to be integrated with other land uses such as agriculture, sport and conservation, and this can be demonstrated in recent woodland creation schemes, despite the challenges in getting the schemes approved. For an ecosystems approach to work successfully, land use managers and other stakeholders need to have some understanding of each other’s land use and how they can work together.

The diagram on page 14 of the consultation document is helpful to set out the policy context for the Land Use Strategy. The diagram demonstrates the complexities and links of many of the issues which need to be considered in the context of Land Use, to assist with increasing sustainable growth of Scotland. We would be interested to know how this may be affected to any changes that arise from further development of the Land Reform Bill.

As discussed above, other relevant Policies and Strategies should link with the Land Use Strategy; Scottish Government and stakeholders should recognise any impacts between actions undertaken under other Policies and Strategies and implementation of the Land Use Strategy framework. Relationships between them may enable different delivery mechanisms to achieve successful outcomes in the long-term.

In light of recent weather events and the pilot projects under LUS1, planning at a catchment / landscape scale might be appropriate to assess land use at a local level, to find solutions appropriate to that area. There might need to be some integration and understanding between projects within the statutory planning regime and those that are administered by other organisations. In forestry, local Forest and Woodland Strategies and Agreed Route Maps for timber haulage should be used to allow presumption in favour of woodland created where areas have been designated; this will enable the planting of the ‘right tree in the right place’ in a timely manner.

The current Scottish Forestry Strategy (SFS) was published 10 years ago with a target to increase woodland cover in Scotland to 25% by 2050 (EU average is 38%) which has subsequently changed to 100,000 hectares of new woodland creation by 2022. So far, the annual target has been missed each year so a review of the Scottish Forestry Strategy is to be welcomed, to review achievements to date and adjust annual targets to ensure ongoing timber production, take account of climate change and other policies which have gained prominence in the last decade, the increasing economic contribution of forestry as well as ecosystem services delivered.

The review should also address issues to completing devolution of the Forestry Commission Scotland (FCS) as well as the impacts and the balance between private and state forestry in Scotland. At a time, when the many benefits of forestry and forest products has been recognised, alongside ongoing effects of climate change, particularly in relation to flooding and pest and disease outbreaks, it is important to retain the forestry expertise within FCS and Forest Research. Plant Health inspections at points of entry into the country are important to minimise further introductions of pests and diseases, from out with Scotland and the UK. While it is useful that different land use sectors are collaborating in new ways, resulting from LUS1, it becomes more important to retain specific sectoral knowledge when working on multi-disciplinary projects.

In the last 10 years, technological innovations, especially with regard to GIS and digital mapping has given land managers access to information which was not previously readily available. However, forest managers and woodland officers still need to understand silviculture and know their forests in addition to the many other issues which are now considered routine such as EIA, diffuse pollution, and forest certification.

Any review of SFS should be carried out in liaison with any revision of UK Forestry Standard (UKFS) and UK Woodland Assurance Standard (and CPET A – UK Government rules on sustainable sourcing of timber) so that the new Scottish Forestry Strategy is appropriate to Scotland but complies with UKFS, Scottish Land Use Strategy, and current best practice across the forest, timber and biomass industries. This should enable some simplification of regulation, if UKFS and LUS regional targets are complied with (up to targets), to deliver woodland creation in a more effective way, productive woodland in particular.

While transparency of land ownership is to be welcomed, the availability of land and how it is used is important. Within forestry, targets exist for new woodland creation and in the long-term, the area of woodland cover. A revised Land Use Strategy should enable publicly stated targets to be achieved, and in combination with the revision of other strategies such as the SFS.

Various models and GIS tools are already used within forestry, as well as public consultation in connection with applications for ScotGov support, e.g. under Forestry Grant Scheme (CAP pillar 2 funding). Without re-inventing any wheels, it would be useful to enable the various mapping layers from different sources to be available through one portal, e.g. Scotland’s Environment website. There should be better collaboration and cooperation between stakeholders so that practical solutions to achieve the targets in the most efficient way are possible. While this may happen across different organisations within the public sector, it would be useful to include other constraints where possible, such as utilities companies and access to overhead power lines. This would enable the consolidation of data and would be most useful if the data could be accessed via WMS services, e.g. as already done by FCS and SNH.

While increased use of GIS tools is to be encouraged to better inform land-use proposals, the mapping resources need to be coordinated better. An example is FC’s reference to local authority Forestry Strategy documents in targeting woodland creation where the strategy documents provide map-based information on preferred areas for woodland creation but the map data is not made available in a GIS format so that the regional detail cannot be accessed.

As Policy 5 proposes, there should be a clear presumption in favour of making map data held by public bodies freely available in shapefile format for use in GIS systems.

Don’t re-invent any wheels.

The pilot project partnerships have brought different land users together. Where there is greater understanding between land managers and local communities, local solutions which are appropriate to the area can be agreed. Regional Forestry Forums, Timber Transport Forums as well as Local Access Forums are well established groups which involve different stakeholders and community interests in relation to land use. As time is a precious commodity for many participants, new groups should not be created without good reason but links between different groups would be important to ensure liaison between them.

Depending on how a ‘region’ is defined, it might be more appropriate to define at landscape/water catchment level rather than purely along Local Authority boundaries. Where a ‘region’ covers a National Park area, it would be appropriate for the NPA to lead on the Regional Land Use Partnership initiatives. It might depend on the ‘region’ as to which body would be the most appropriate to lead any initiatives.

Some funding for collaborative land use projects may be appropriate under SRDP funding but this might depend on future CAP reviews in the UK / EU. Alternatively, it might be appropriate for Scottish Enterprise / Highlands & Islands Enterprise or planning authorities to support some of these regional land use initiatives.

No

Regional land use frameworks could be used to inform decision making. While there is merit in bringing a framework of Strategies together, they need to be informed by expert advice and not diluted. The rationale supporting these Strategies and Policies should help to guide regional land use frameworks rather than introduce any additional layers of regulation. For instance, forestry projects are usually guided by the principles of UK Forest Standard and UKWAS (where a forest is certified under a recognised scheme, such as FSC or PEFC). In these cases, strict guidelines will have been adhered to in creating the design plan so to ease regulation, schemes could be approved in a more timely fashion (up to stated targets) as long as UKFS is complied with.

These Regional Frameworks may be designed using ecosystems services where there will be complex interactions between different elements. Multi-disciplinary teams will be required to understand and work through practical solutions which will work locally / regionally. It will be important to understand the impact of decisions in one area of policy may affect another land use (ref. diagram of LUS Policy context on page 14 of the consultation document). Flexible implementation of national policy may be required at local / regional level to deliver the most appropriate solutions.

Strong leadership will be required to ensure that the most appropriate priorities are identified across different land uses measured against differing regional and national priorities. Confor updated a report last year to compare a theoretical upland sheep farm with a woodland in Eskdalemuir; in economic terms (+/- subsidy) the woodland outperformed the farm.

Greater understanding by stakeholders of proposals for woodland creation schemes, designed to strict regulations and guidelines would enable projects to go ahead in a timely fashion, getting trees in the ground and saving taxpayers’ money in extensive consultations. There should be a presumption in favour of woodland creation projects, up to target levels, with lighter touch regulation in some circumstances, e.g. woodlands which are already certified. A facilitation process to enable efficient decision making in relation to land use could be useful to assist communities, landowners and stakeholders to resolve differences and improve understanding.

The planting of trees is a well-proven carbon sequestration methodology. Establishment of woodland crops can also help to attenuate water flows in catchment areas as well as give shelter to livestock and crops. As we have demonstrated in some of our recent new woodland creation schemes, modern forestry is truly multi-functional. Timber production sits alongside other ecosystems services such as biodiversity, conservation and water catchment management, with agriculture on the same land holding, as well as offering landscape enhancement and recreation. The forest industry is working with ENGOs to improve understanding of what modern forestry constitutes; that integrated land use management is possible and that forest design in 2016 is very different from 30 years ago. However, if climate change / carbon targets are to be achieved, tree planting needs to be effected more efficiently, and with better value to the taxpayer, than in the recent past where some woodland schemes have taken much consultation over several years.

Current forest design guidelines advocate similar localised map-based assessments to ascertain the suitability of land and certain species. Ecological Site Classification (a forest decision support tool) can indicate the suitability of tree species to different areas depending on various parameters such as soil type, aspect, altitude and ecological requirements of the species in question. Another tool, ForestGales can help to determine the probability of wind damage in a stand of conifer trees, which would indicate how long a stand should grow before harvesting.

Further targeting of support in the next SRDP could be informed by an assessment of ‘ecosystem health’ and a spatial approach alongside any Regional Frameworks agreed under the auspices of this next Land Use Strategy. However, there should be some flexibility in case any projects come forward which offer appropriate solutions but not precisely according to the factors used in a ‘targeted approach’.

Where urban land use is being considered, there may be differences in how projects are implemented between urban and rural areas, such as in green spaces. In urban areas, most development will be governed by the statutory planning system, however, woodland creation projects, if supported by the Forestry Grant Scheme would not fall within the planning regime beyond current consultation processes. This might be an area to be explored in any pilot project to ensure that any woodland project created, especially for water management or carbon sequestration objectives are created in a timely fashion.

While a strategic vision for the uplands could be useful within the Land Use Strategy and how the uplands can contribute to climate targets, any vision should sit within the context of other Policies relating to Land Use (ref. policy context diagram on page 14 of the consultation document), Land Reform and Community Empowerment such as forestry, agriculture & crofting and peatlands. There is to be a Land Use and Responsibilities Statement within the Land Reform legislation, so it might be appropriate to include the strategic vision for the uplands within this document to keep things as straight forward as possible.

As a broad-brush, the 10 indicators are still fit for purpose to give an indication of some aspects of land use. However, going forward it would be expected that more targets relating to climate change, e.g. carbon, will be included as and when data is available. If land use becomes more integrated, there should be some way of monitoring the overall ecosystems benefits of such schemes which will hopefully add up to more than the sum of their parts.

Future monitoring should make the most of existing data sets or those data sets collated by other organisations which would be relevant. These data sets may exist at local, regional, national, international levels. Monitoring should be carried out in an efficient way, which optimises the public benefit in recording any indicator in comparison with the cost/effort of collecting that data – for the land manager or government agency.

When undertaking activities to achieve the outcomes of the Land Use Strategy, existing expertise and knowledge should be used to make the most of scarce resources so that the most appropriate priorities and projects go ahead, at local / regional / national / international level. Within the policy context diagram (page 14), the Land Use Strategy should, without doubt, inform Scottish Government policy, and its implementation should properly utilise available resources.

No

Whether people in Scotland live in rural or urban areas, they should all be treated equally in the services that they use and require. This includes items such as fuel prices, connectivity and access to broadband and other services, such as banks and post offices, which enable rural businesses as well as households to function efficiently. Rural and urban areas depend upon each other for economic stability, environmental and social reasons, and there should be better understanding and support of the issues concerned.