§ Sir Hector Monroasked the Secretary of State for Scotland whether he is now in a position to respond to the Nature Conservancy Council's report "Nature Conservation and Afforestation in Britain".
§ Mr. RifkindI have sent the following letter, setting out the Government's views, to the NCC's chairman, Mr. William Wilkinson.
Dear Mr. Wilkinson,
- 1. I am writing to let you have the Government's considered response to the recommendations contained in your report "Nature Conservation and Afforestation in Britain".
- 2. We are indebted to you for producing this comprehensive, clear and helpful view of the interaction between forestry and nature conservation. We particularly welcome the importance attached throughout the report to the need for balance in addressing the issues raised. Forestry and nature conservation have important roles to play in the development of the countryside and it is the Government's policy that forestry should take place in ways that are compatible with other land use interests, including nature conservation.
Forestry policy
3. Your report has come at a time when rural areas in Britain are facing important changes as a result of the need to tackle agricultural surpluses within the EEC. Along with other reports on the future of the countryside, it was a useful contribution in our consideration of policies for the rural economy and environment which resulted in the publication "Farming and Rural Enterprise". Our conclusions on the positive role that forestry has to play as an alternative use for agricultural land were outlined in the document "Farming UK" which formed part of that publication. We propose an expansion of the traditional forestry programme—to 33,000 hectares a year — with due regard being paid to 919W environmental considerations. We shall also be encouraging the planting of an increased proportion of trees on low ground of better quality.4. I hope you will welcome this new emphasis which should offer opportunities for landscape and habitat diversity, including a greater use of broadleaves. We also expect broadleaved woodlands to feature strongly in our new scheme to encourage the development of farm woodlands.5. In the context of encouraging farmers to plant trees, your report suggested that a review of the present tax incentives for forestry should be carried out. We have taken careful note of what you have to say in this regard. Since your views were published, however, the Public Accounts Committee has reported on a review by the Comptroller and Auditor General on the objectives and achievements of the Forestry Commission which also touches on the question of fiscal incentives for private forestry. We shall be responding to the Committee's report very shortly. I am sure you will understand, therefore, that I cannot comment on the point about forestry taxation at this stage.SSSIs
6. We welcome and support the continuing co-operation between the Forestry Commission and the Nature Conservancy Council on the management of the large number of SSSIs on Commission land, as evidenced by the Declaration of Intent signed by both bodies in 1986. We share your concern that SSSIs should, within the terms of the 1981 Act, be protected from damaging operations. I am pleased to note from your report that only one SSSI has in fact been damaged by forestry, and that, I understand, was accidental. I do not believe it would be reasonable, therefore, to put an absolute ban on planting within SSSIs. Unlike the case of NNRs, nature conservation is not the primary land use within SSSIs and the right course is to consider each case on its merits. I very much hope that there will continue to be the closest co-operation between your Council and the Forestry Commission to resolve cases where a balance had to be struck between nature conservation and other interests, with cases being referred to Ministers where this does not prove to be possible.Controlling afforestation
7. As regards methods for ensuring that forestry developments take place in harmony with nature conservation, we do of course have well-established guidelines and mechanisms in place. There is already a strong commitment to conservation on the part of the Forestry Commission—both in its own operations and in its handling of private sector proposals—and it has sought over the years to adopt a balanced and flexible approach in considering each new issue as it arises. The Commission is required to consult, as appropriate, with the Agriculture Departments, local planning authorities and other statutory authorities on applications for grant-aid or felling licences and on draft plans of operations containing planting and felling proposals. The Nature Conservancy Council is consulted whenever a proposal falls wholly or partly within a National Nature Reserve, an SSSI or an area formally proposed for such designation to ensure that conservation factors are fully considered. Special arrangements for consultations on forestry proposals within Environmentally Sensitive Areas have also been introduced after discussion between the Forestry Commission and your Council. To take a recent example, because of the importance which your Council attaches to the flow country of Caithness and Sutherland, the Forestry Commission has further extended its formal consultations with you to embrace all applications for grant aid in these two districts to allow time for the nature conservation interest to be defined more clearly, and I am now giving careful consideration to the proposals you have made in that regard in your report 'Birds, Bogs and Forestry'. Local authorities are also encouraged to consult widely, for example with voluntary conservation groups.8. Under the terms of a Ministerial Direction, where objections are raised which cannot be resolved, the application has to be referred to the Commission's Regional Advisory Committee, which makes further efforts to find a solution acceptable to all the parties; as you know, ways of widening the representation of non-forestry interest on these Committees and of making them more publicly accountable have been the subject of a review by the Forestry Commission, and I hope that an announcement can be made reasonably soon. It is also 920W important to bear in mind that where an authority consulted under these procedures maintains its objections to an application beyond the Regional Advisory Committee stage, the Forestry Commission may over-ride them only with the endorsement of Ministers. There are therefore important safeguards for the environment built into the present procedures.Planting licences
9. Your report proposes the introduction of a system of planting licences to strengthen the existing controls which operate through the forestry grant schemes. As I have said above, however, we consider that the present procedures have generally proved to be an effective form of control. That the private sector supports this voluntary approach is evidenced by its remarkably good record over the years; there have been very few instances where the consultation procedures have been side-stepped and the grant forgone. The Government therefore considers that there is insufficient evidence to suggest a need for the existing arrangements to be supplemented by statutory controls such as planting licensing, although this will be kept under review.The wider countryside
10. There has been an important shift of emphasis on the part of the Forestry Commission in recent years in response to changing perceptions on environmental matters, including nature conservation, and in the light of advice it has received from the Nature Conservation Council and other statutory authorities such as the Countryside Commissions. The statutory remit of the Forestry Commissioners has been extended to include a duty to endeavour to achieve a reasonable balance between timber production and the environment. That is not to suggest that the pursuit of this new duty will necessarily avoid conflicts of interest in every instance, but the Government believes that such conflicts will be reduced as the Forestry Commission's policies and practices develop. In this connection, I was pleased to learn that discussions have begun between the Forestry Commission and yourselves aimed at the provision of constructive advice on nature conservation issues in the wider countryside. Such a move can only be to the benefit of rural development and, with goodwill and a realistic approach on both sides, should lead to a better mutual understanding.Return on investment in new planting
11. Your report placed some stress on the need to determine criteria for estimating an acceptable return on timber production, both for the Forestry Commission's own planting and as a qualifying threshold for grant-aid. It also suggested that the grant-aid function should be used as a regulator to achieve a reasonable balance between afforestation and other land uses in any county or district. Taking this last point first, the Government takes the view that the best method of achieving an acceptable balance between forestry and conservation, and of taking account of other legitimate land-use interests, is through the present consultation system rather than by means of regulation. The current conditions for grant-aid involve the careful examination of applications to ensure, as far as practicable, that proposals are sensibly drawn on nature conservation, land use and landscape ground before the consultation process is begun. The Forestry Commission is also required to satisfy itself that the proposed planting scheme is silviculturally suited to the site and will produce a utilisable crop of timber. Market forces also infuence the choice of species, and the main requirement for the wood-processing industry is for softwood. There is no evidence that setting a financial rate of return would in general help to safeguard nature conservation interests. It could, for example, militate against the use of broadleaves in many circumstances since these produce a lower return on all but the most fertile lowland sites. The Government would not therefore wish to stipulate acceptable rates of return which are, and should remain, matters to be determined by those investing in forestry.12. As far as the Forestry Commission's own planting is concerned, a financial return on investment is calculated for each site taking into account such factors as soil and site characteristics and the species to be planted. However, this is only part of the evaluation process. Other factors have also to be considered, including employment, effective integration with agriculture, environmental safeguards and, where appropriate, opportunities for public access and recreation.Increased planting of better agricultural land 921W
13. Your report recommends a closer inter-relationship between forestry and agriculture, and the planting of enclosed agricultural land. This is in line with the Government's report "Farming UK", which confirmed our commitment to increasing the proportion of planting which takes place on low ground of better quality than hitherto. In addition, the consultation paper on the Farm Woodland Scheme proposed measures which should increase planting on agricultral land. In recent years, most planting has taken place in Scotland, and last year I announced changes in the criteria for the approval of agricultural land for forestry which are already providing new opportunities for planting, including, in certain circumstances, planting on enclosed agricultural land. There are few agricultural restrictions on new planting in England and Wales. The Forestry Commission will also keep in mind the need to encourage planting on better quality land in their regular reviews of grant rates.Design and management of forestry schemes
14. I note that the report is deeply critical of "blanket" afforestation; however, we believe that there can be scope for large-scale afforestation, provided that a balance is reached with other relevant land use interests. New planting—on whatever scale — should continue to reflect the economic, landscape and nature conservation needs of the locality, and we agree entirely with you that appropriate design and management practices should be adopted in all forestry schemes. Applicants for grant aid are required to provide sufficient information in the draft plan of operations, which forms part of the application, to determine whether a reasonable balance can be achieved with other land use interests. This draft plan is sent to the appropriate statutory authorities for comment under mutually agreed arrangements, and those authorities are encouraged to give copies to, and seek views from, local interests including voluntary conservation bodies. Because the plan of operations prepared under the present system should take account of conservation factors where appropriate, we do not feel it is necessary to adopt your suggestion for a separate conservation plan.15. We are certainly in total agreement when it comes to the need to develop and adopt silvicultural practices which minimise the adverse impacts of forestry on the environment. I know that the Forestry Commission has devoted considerable effort to this over the years. For example, the techniques of ploughing have been developed to minimise soil erosion; planting well back from stream-sides has also been promoted as good practice for some time, as has the avoidance of fertiliser run-off and the minimum use of pesticides.Increasing the nature conservation value of forests
16. The Government fully endorses the suggestion that the Forestry Commission should continue its efforts to maximise benefits for wildlife within existing forests. To this end conservation plans have been drawn up for all Commission forests with the help and assistance of a wide range of voluntary and statutory conservation organisations, including the Nature Conservancy Council. The recommendation in your report for establishing experimental conservation areas could be useful in both a research and a demonstration sense, although the Forestry Commission intends to apply good conservation practice to all its forests.17. While changes in attitude and approach towards conservation will be reflected in new planting where measures are considered from the inception of a scheme, because of the long-term nature of the industry it will take some time for dramatic changes to be seen in existing forests. Opportunities for diversification and modification will occur, however, when felling commences, and advantage can be taken at the time of subsequent restocking to introduce positive conservation measures.Research
18. I am pleased to record that the research activities recommended in the report are being covered by the Forestry Commission's wildlife conservation research studies. I am also glad to learn that joint programmes of research between the Commission and the Nature Conservancy Council have been started and that opportunities will be sought to do more. Your Council's membership of the Forestry Research Co-ordination Committee, which we established in 1982, gives 922W you the opportunity to comment on the Commission's research programmes, to the mutual benefit of both bodies. We commend such co-operation and look to its continuing development.Training
19. The Government fully endorses the suggestion that opportunities should be taken for forestry staff in the public and private sectors to receive training on management for nature conservation. I understand that the Forestry Commission has already run courses with help and advice from the Nature Conservancy Council.Conclusion
20. May I conclude by expressing once again the Government's gratitude for the helpful suggestions in your report. These have provided us with a timely and important contribution to the debate on the role of forestry in the countryside. It is appropriate that I should have directed my last remarks to the subject of training since this is of crucial importance if we are to continue to build upon the progress already made in protecting our natural heritage. I know that you have this question of education and the promotion of a more positive attitude to nature conservation very much in mind, and I would like to assure you that the Government supports most warmly all constructive attempts to achieve this very desirable objective.