Today I submitted a response to the Scottish Government consultation on Forestry Strategy1. The text of my response follows, although you might need to look at the consultation paper to make most sense of it. Responses were invited to a series of specific (if rather open) questions addressing each of its main sections, which perhaps makes for a rather disjointed read. But I hope my plea for more ambition, better collaboration and sustained partnership effort is clear enough.
Q1. Do you agree with our long-term vision for forestry in Scotland?
The vision lacks ambition. Scotland needs more trees – many more trees. We should strive to put right the grievous damage inflicted over many centuries. I agree that Scotland needs more diverse, multi-purpose woodlands, looking beyond a narrow focus on timber production to embrace recreation, carbon capture, catchment protection, landscape enhancement and all contributing to restoration of our plant and animal biodiversity.
The vision aspires to forest expansion, but alas has no sense of scale. Although we cannot be sure, our best available evidence is that prehistoric Scotland once enjoyed woodland cover of more than 50% of land area. This fell to less than 5% around 1900. Through the 20th Century, led by the Forestry Commission, this has increased fourfold, a substantial achievement. Now we need a 21st Century ambition, perhaps aiming to reach 30% over the next half century, which would restore around half of the prehistoric woodland extent.
Q2. Does the strategy identify the right objectives for forestry in Scotland over the next 10 years?
Aligning the objectives with the Scottish Government’s National Outcomes and associated UN Sustainable Development Goals makes sense up to a point, but the resulting objectives adopt lacklustre language. They are too vague to inspire ambition and do not do enough to show how the 10-year horizon can set the scene for realising the long-term vision.
For example, adopting a vision to reach 30% forest cover implies an extra 850,000ha of woodland over 50 years, as well as maintaining and regenerating existing woodlands. Such ambition to increase Scotland’s woodland cover by 17,000ha per annum obviously has many implications, especially for other land uses. I believe these implications can successfully be managed, but the consultation paper is sadly deficient in failing to address them. The ten-year objectives must establish the framework within which success can be achieved.
Close co-operation and collaboration is most essential with farming, recreation, conservation and especially local community interests. The consultation paper recognises that pursuing forestry in isolation, or in opposition with these other interests, would be a recipe for failure. Yet it does not say nearly enough about how a joined-up approach can be made a reality.
Q3. Do you agree with our assessment of the major issues likely to have the greatest impact on the achievement of our objectives?
The major issues are listed, but the assessment in the accompanying text fails to spell out a response to these capable of realising the ambition.
Section 4.2, in particular, gives no assessment of the barriers to expansion or how these can be tackled. As Section 2 makes clear, the strategic importance of forestry needs to engage a wider community far beyond professional foresters. The silo mentality criticised in the paper is reinforced when foresters talk mainly to each other. A step-change in style is required, and this Strategy is the opportunity to spell this out and map out the first steps towards its achievement.
Q4. Do the ten priorities identified in table 2 capture the areas where action is most needed to deliver our objectives and vision?
These are broadly the right areas, but fail to set out what success looks like, in terms of progress towards the long term vision.
Q5. Can you provide any examples of delivery mechanisms that have previously been effective in delivering similar objectives and priorities?
Examples include Cairngorms Connect2, the Borders Forest Trust3 and similar initiatives. At a regional scale, indicative forestry strategies4 have important lessons. But experience of failure is also important, drawing out and applying lessons learnt. For example, the SRDP experience and implementation of the recommendations of the Mackinnon Report5. This shows that close working between land use agencies and departments has been sporadic, and that grant applications tend to be treated in isolation rather than as contributions to an overall pattern and direction of landscape improvement.
Q6. For any delivery mechanism examples given in answer to question 5, please explain why they worked well?
These operate at a landscape scale, engaging a range of land management and community interests to achieve a joined-up approach.
Q7. Do you think the proposed progress indicators are the right ones?
These are too narrow, they need to address the terms of the strategic vision and set out milestones towards its achievement.
Q8. Do you have any suggestions for other indicators we could use to measure progress (especially ones which draw on existing data)?
There is a lot of material to draw on in the Environmental Report pp79-906.
Q9. For any indicators suggested in answer to question Q8, please explain why you think they would be appropriate.
There’s a implied focus in the Consultation Paper on tree planting, when regeneration is very important in many areas and essential to meet woodland expansion ambitions. But land management to secure regeneration especially requires a range of measures engaging with other land management interests.
Q10. 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)?
Nothing to add
Q11. Would you add or change anything in the Business and Regulatory Impact Assessment
Nothing to add
Q12. What are your views on the evidence set out in the Environmental Report that has been used to inform the assessment process?
This is a fair summary of a wide range of available evidence, although it rests heavily on the priorities set out in Table 2 of the consultation paper. If these are amended, then additional evidence and analysis will be advantageous, especially to clarify the nature of barriers to woodland expansion.
Q13. Should any additional evidence sources be used in the Environmental Report? Please provide details.
Where relevant and available – the Environmental Report is wide-ranging but there may well be additional sources of evidence and these should be used as appropriate.
Q14. What are your views on the predicted environmental effects as set out in the Environmental Report?
Priority 4 should make more of the environmental effects of wild deer and other herbivores (including domestic livestock) – for example drawing on the sources listed on pp80-82.
The assessment of Priority 5 is too narrow, since the benefits of community engagement are not limited to population and human health.
Q15. Do you agree with the conclusions and recommendations set out in the Environmental Report?
These are too broad, and would benefit from drawing out more specific priority areas which can inform actions, commitments and milestones.
Q16. Please provide any other further comments you have on the Environmental Report.
The indicators at Table 10 are too thin, and need to be strengthened to reflect improvements along the lines recommended in response to questions 2, 3 and 4.
Q17. Do you have any other comments you would like to make about the draft strategy for forestry in Scotland?
A lot of good stuff here, but could do so much better. Let’s have a much sharper, inspirational and inclusive vision for Scottish Forestry in the 21st Century!