Forest Grant Scheme consultation response

Alan Hampson Head of Policy and Prac­tice Scot­tish Forestry Sil­van House 231 Cor­stor­phine Road Edin­burgh EH12 7AT

Dear Alan

RE: FOREST GRANT SCHEME CON­SULTA­TION – CNPA RESPONSE

Thank you very much for the oppor­tun­ity to com­ment. Over­all, the Park Author­ity are look­ing for a sys­tem that sup­ports mul­tiple part­ners and land man­agers in deliv­er­ing the Nation­al Park Part­ner­ship Plan tar­get for 35,000 ha of new wood­land cov­er by 2045, which:

• Includes a min­im­um of 80% nat­ive woodland.
• Includes a min­im­um of 10,000 ha of nat­ur­al regen­er­a­tion without planting.
• Res­ults in no whole­sale con­ver­sa­tion of in-bye agri­cul­tur­al land to forestry; and
• Min­im­ises the amount of fen­cing in the Park by favour­ing estab­lish­ment through herb­i­vore man­age­ment and remov­ing redund­ant fences.

The cur­rent FGS facil­it­ates some aspects of these tar­gets but could be improved to deliv­er them more effect­ively and efficiently.

Nat­ur­al regen­er­a­tion, fen­cing and herb­i­vore man­age­ment: Most wood­land cre­ation at the moment is car­ried out through plant­ing with fen­cing. The Park Author­ity would like to see how a revised FGS can adjust this pos­i­tion so that in the longer-term unfenced regen­er­a­tion and plant­ing estab­lished via herb­i­vore man­age­ment is bet­ter incentiv­ised (see dia­gram 1 below) and there­fore more ser­i­ously con­sidered by landown­ers as their ​‘go to’ option.

We recog­nise though that in the short term, and in cer­tain cir­cum­stances, fen­cing will still be neces­sary to facil­it­ate tree estab­lish­ment, to pro­tect pub­lic money, and to give assur­ances to land man­agers look­ing to man­age liabilities.

Dia­gram 1 — pri­or­it­ising wood­land creation

[Dia­gram descrip­tion: A fun­nel with ​“Nat­ur­al regen­er­a­tion without fen­cing (i.e. herb­i­vore man­age­ment)” at the top, fol­lowed by ​“Nat­ur­al regen­er­a­tion with fen­cing”, then ​“Plant­ing without fen­cing”, and finally ​“Plant­ing with fen­cing” at the bot­tom. An arrow points upwards along the right side of the fun­nel with the text ​“Increas­ing grant pay­ment rate or incentive”.]

Man­aging risk and uncer­tainty: Our pro­mo­tion of nat­ur­al regen­er­a­tion via herb­i­vore man­age­ment inev­it­ably invokes debate around man­aging fin­an­cial and out­come risk for both Scot­tish Forestry as the cur­rent grant giv­ing body and the landown­er or manager.

We recog­nise that the cur­rent approach of plant­ing and fen­cing means Scot­tish Forestry is apply­ing the highest levels of assur­ance of out­come plus safe­guard­ing pub­lic money, and the land man­ager is least exposed to the liab­il­ity of fail­ure and grant repayment.

How­ever, to meet Nation­al Park Part­ner­ship Plan out­comes, and argu­ably to address the twin crises, a dif­fer­ent approach must be taken.

In order for landown­ers or man­agers to con­sider tak­ing the risk involved with unfenced schemes there needs to be a high­er rate of grant over a longer peri­od, to motiv­ate and main­tain herb­i­vore management.

In order for the grant giver to con­sider tak­ing the risk of fund­ing unfenced schemes the grant needs to; bet­ter sup­port herb­i­vore man­age­ment; accept the eco­lo­gic­al bene­fit versus tim­ber bene­fit of the likely lower dens­ity and patchy nature of nat­ur­al regen­er­a­tion; accept that nat­ur­al regen­er­a­tion may come over a longer time peri­od and thus provide for poten­tially 15 – 20 years of payment.

Deliv­er­ing mul­tiple bene­fits for tim­ber, car­bon, biod­iversity and resi­li­ence: More hab­it­at com­plex­ity and less homo­gen­eity make for a more resi­li­ent eco­lo­gic­al sys­tems, bet­ter able to mit­ig­ate and adapt to the twin crisis.

FGS fund­ing can and should sup­port the prin­ciple of pay­ing for eco­sys­tem ser­vices and hab­it­at cre­ation as well as pro­duct­ive tim­ber out­puts. We would like the FGS to more ser­i­ously explore options that addi­tion­ally incentiv­ise het­ero­gen­eity of hab­it­at, struc­ture, and spe­cies includ­ing for mont­ane and ripari­an woodlands.

Addi­tion­ally, there are mul­tiple bene­fits, not least in car­bon terms, of not plant­ing on peat rich soils of 30 – 50cm depth where they are part of a peat­land hydro­lo­gic­al unit or act­ive peat­land res­tor­a­tion site. If the FGS incentiv­ised wider eco­lo­gic­al out­comes bet­ter this nuance may be bet­ter under­stood and wood­land cre­ation schemes more eco­lo­gic­ally designed.

Integ­ra­tion of FGS with oth­er land man­age­ment and rur­al pay­ments: Bet­ter com­pat­ib­il­ity between fund­ing streams for Agri­cul­tur­al, Peat­land res­tor­a­tion, Deer man­age­ment, and Forestry or Wood­land will bet­ter sup­port integ­rated rur­al land man­age­ment approaches.

This will allow land man­agers to make prac­tic­al decisions suit­able to their spe­cif­ic loc­a­tion and pre­vail­ing issues and ensure the chal­lenges of the twin crises are met. Simply put any future FGS needs to be bet­ter integ­rated than it cur­rently is with the oth­er streams of pub­lic fund­ing avail­able for rur­al land management.

Gen­er­at­ing income and sup­port­ing the forestry industry: Com­mer­cial forestry in the Cairngorms is unique in that it is pre­dom­in­antly nat­ive spe­cies, and it is import­ant this remains the case. We recog­nise that tim­ber is often the main viable income stream to many estates in the Park and that plant­ing will con­tin­ue to be the primary means of estab­lish­ing wood­lands in the Park in the short-term even if over time we move to increased herb­i­vore management.

The Park Author­ity will con­tin­ue to pro­mote and sup­port suit­able tim­ber pro­duc­tion in the Park where that con­trib­utes to the Scot­tish Forestry Strategy, Scot­tish Biod­iversity Strategy and Nation­al Park Part­ner­ship Plan targets.

Yours sin­cerely

Andy Ford Dir­ect­or of Nature & Cli­mate Change

Response ID ANON-VEPG-2G13‑F

Sub­mit­ted to Future Grant Sup­port for Forestry Sub­mit­ted on 2023-05-16 16:26:45

Min­is­teri­al Fore­word — Forestry in Scot­land is a sec­tor that we can be justly proud of.

1 — Intro­duc­tion and Rationale for Provid­ing Grant Sup­port for Forestry

1. Do you agree that grant sup­port for forestry should con­tin­ue to be improved and developed as a dis­crete scheme with­in the over­all pack­age of land support?

Yes Please explain your answer in the text box.: Over­all, we want to see a forestry grant scheme that is about wood­land hab­it­at cre­ation, deliv­ers the Nation­al Park Part­ner­ship Plan tar­gets and thus tackles the twin cli­mate and biod­iversity crises.

Grant sup­port for forestry should be about more than just grow­ing tim­ber, align bet­ter with the Scot­tish Biod­iversity Strategy and be designed and admin­istered in the con­text of integ­rated land management.

We agree with the con­tinu­ation of a dis­crete scheme with­in the over­all pack­age of land sup­port — as long as it is has strong align­ment with oth­er schemes, close integ­ra­tion with the rur­al pay­ments régime, and works in con­junc­tion with deer man­age­ment mechanisms.

With­in the Cairngorms Nation­al Park, agri­cul­ture, deer man­age­ment, woodlands/​forestry and peat­land res­tor­a­tion are all uses of land sup­por­ted by the pub­lic purse but all are cur­rently pro­moted via dif­fer­ent dis­crete schemes.

Giv­en the mul­tiple prac­tic­al over­laps between these uses of land, and Scot­tish Gov­ern­ments aspir­a­tions for integ­rated land­scape scale rur­al land man­age­ment, pub­lic fund­ing for these land uses, even if via dis­crete schemes, must also be well integ­rated and simple to util­ise so that the over­all pack­age of rur­al land sup­port is coher­ent and functional.

1. Are there any changes that would allow for bet­ter com­ple­ment­ar­ity between the forestry and agri­cul­ture fund­ing options?

Yes Please explain your answer in the text box.: With­in Cairngorms Nation­al Park most of the agri­cul­tur­al land is farmed under ten­an­cies from large estates.

Under cur­rent Agri­cul­tur­al Ten­ancy law, ten­ants need the con­sent of their land­lord to plant areas of trees and the land­lords can take a share of any car­bon cred­its gen­er­ated by affor­est­a­tion (ref 1).

In addi­tion, the rules around con­tinu­ing to qual­i­fy for Basic Pay­ment Scheme (BPS) pay­ments where farmed land becomes affor­es­ted only rel­at­ively recently changed (ref 2) mean­ing many farm­ers still incor­rectly fear they will lose BPS if they plant trees.

The com­bined effect of all this is that agri­cul­tur­al ten­ants can be reluct­ant to plant trees.

The FGS could help over­come this if it was improved bey­ond the cur­rent Small or Farm Wood and Agro­forestry options to become more flex­ible in the allow­able grant­able options and/​or was bet­ter integ­rated with the pro­posed Tier 3 or 4 indir­ect agri­cul­tur­al pay­ments (ref 3) as pro­posed bey­ond 2025.

As an addi­tion­al idea could an option, sim­il­ar to the cur­rent Forestry Co-oper­a­tion Grant, be developed spe­cific­ally for land­lords and ten­ants of agri­cul­tur­al land? Whereby a land­lord and sev­er­al con­tigu­ous ten­an­cies were incentiv­ised to devel­op land­scape affor­est­a­tion pro­pos­als across sev­er­al agri­cul­tur­al ten­an­cies to the bene­fit of both ten­ants and landlord?

Such a grant option would need to provide for the forestry agent fees to devel­op the scheme, and per­haps be dir­ectly linked to addi­tion­al Tier 3 or 4 pay­ments as men­tioned above, to make it attract­ive to land­lords and ten­ants work­ing together.

Ref­er­ences: 1: An Inter­im Guide to Secur­ing Trade­able Car­bon Cred­its in an Agri­cul­tur­al Hold­ings Situ­ation (landcommission.gov.scot) https://www.landcommission.gov.scot/downloads/6225dd8ba66c1_TFC Inter­im Guide to Secur­ing Trade­able Car­bon Cred­its in an 2:Woodland Cre­ation (rur​alpay​ments​.org); https://​www​.rur​alpay​ments​.org/​t​o​p​i​c​s​/​a​l​l​-​s​c​h​e​m​e​s​/​f​o​r​e​s​t​r​y​-​g​r​a​n​t​-​s​c​h​e​m​e​/​w​o​o​d​l​a​n​d​-​c​r​e​a​tion/ ​‘Grant Supp­port’ page; ​“From 2015, farmed land that is eli­gible for the Basic Pay­ment Scheme and is affor­es­ted under the Forestry Grant Scheme, will con­tin­ue to be eli­gible for the Basic Pay­ment Scheme sub­ject to meet­ing the Basic Pay­ment Scheme eli­gib­il­ity require­ments spe­cif­ic to land used for wood­land cre­ation.” 3: https://www.gov.scot/publications/delivering-vision-scottish-agriculture-proposals-new-agriculture-bill/pages/4/

2 — Forests Deliv­er­ing for Scotland’s Cli­mate Change Plan

1. How can the sup­port pack­age for forestry evolve to help tackle the cli­mate emer­gency, to achieve net zero, and to ensure that our wood­lands and forests are resi­li­ent to the future climate?

Please explain your answer in the text box.: For resi­li­ence and car­bon cap­ture more wood­land estab­lish­ment via nat­ur­al regen­er­a­tion, as opposed to plant­ing, is needed as well as great­er spe­cies diversity and struc­tur­al com­plex­ity with­in the wood­lands established.

Over­all, we favour nat­ur­al regen­er­a­tion estab­lish­ment via herb­i­vore man­age­ment but recog­nise that this won’t be pos­sible every­where and in the short to medi­um term fen­cing will still be needed.

A fur­ther prac­tic­al caveat here is the need for an exist­ing seed source for the nat­ur­al regen­er­a­tion to occur. Where there isn’t a suit­able seed source then of course plant­ing is needed. Where nat­ur­al regen­er­a­tion is unlikely to be diverse in terms of spe­cies com­pos­i­tion some spe­cif­ic enhance­ment plant­ing would be appropriate.

We agree that the best way to ensure appro­pri­ate spend of pub­lic funds in grants for nat­ur­al regen­er­a­tion is to pay for res­ults as the cur­rent FGS mod­el does, but we feel a great­er fin­an­cial incent­ive with­in FGS, i.e. an enhanced rate, for nat­ur­al regen­er­a­tion in com­par­is­on to tree plant­ing is needed to pro­mote nat­ur­al regen­er­a­tion over planting.

In addi­tion, any res­ults-based grant for nat­ur­al regen­er­a­tion would need to be more flex­ible in future to accom­mod­ate the longer estab­lish­ment times­cales and some­times patchy stems per hec­tare dens­it­ies of nat­ur­ally regen­er­ated trees.

This means pay­ments bey­ond the usu­al 5year fund­ing win­dow would be needed, and per­haps a slid­ing scale of pay­ments depend­ing on the dens­ity of regen­er­ated trees.

We under­stand that in terms of soil dis­turb­ance and car­bon emis­sions, ground pre­par­a­tion for plant­ing via the inver­ted mound­ing tech­nique is pre­fer­rable to oth­er ground pre­par­a­tion meth­ods. We sug­gest that inver­ted mound­ing is also encour­aged or incentiv­ised via FGS to help with the over­all aim to achieve net zero.

1. Private invest­ment through nat­ur­al cap­it­al and car­bon schemes can make a valu­able con­tri­bu­tion to cli­mate change. Do you agree that the grant sup­port mech­an­ism should have more flex­ib­il­ity to max­im­ise the oppor­tun­it­ies to blend private and pub­lic fin­ance to sup­port wood­land creation,

Yes Please explain you answer in the text box.: We agree that the grant sup­port mech­an­ism should have more flex­ib­il­ity to allow for blend­ing private and pub­lic fund­ing. This flex­ib­il­ity would also help to deliv­er the NPPP pri­or­it­ies by allow­ing private fin­ance to con­trib­ute where possible.

Per­haps dur­ing the life­time of any grant fun­ded scheme, landown­ers should have to declare any addi­tion­al fin­an­cial inputs they receive which are asso­ci­ated with the estab­lish­ment of a new wood­land that is under grant fund­ing. Scot­tish Forestry should then have the power to alter levels of pub­lic fund­ing if levels of private fund­ing are sub­sequently included.

A slid­ing scale of FGS pay­ments that could have adjustable para­met­ers to accom­mod­ate private fin­ance con­tri­bu­tions would be help­ful here. The cur­rent Peat­land Action fund­ing with­in Cairngorms Nation­al Park already works like this and could be used as a model.

1. How could the cur­rent fund­ing pack­age be improved to stim­u­late wood­land expan­sion and bet­ter man­age­ment across a wide range of wood­land types, includ­ing nat­ive and pro­duct­ive woodlands?

Please explain your answer in the text box.: Cur­rently the bal­ance of incent­ives embed­ded in FGS, and the way the car­bon mar­kets work via the Wood­land Car­bon Code, means plant­ing new wood­lands is much more attract­ive to land man­agers than expan­sion and/​or man­age­ment of exist­ing woodlands.

FGS should incentiv­ise the expan­sion and bet­ter man­age­ment of exist­ing wood­lands as well as pro­mot­ing new wood­land cre­ation. We believe the expan­sion of exist­ing wood­lands is best done through nat­ur­al regen­er­a­tion so our com­ments about FGS sup­port for nat­ur­al regen­er­a­tion under Ques­tion 3 also apply here.

In addi­tion, per­haps a dis­crete item like a ​‘wood­land eco­sys­tem’ pay­ment could be developed with­in FGS. This could pay land hold­ers for provid­ing and main­tain­ing the eco­sys­tem ser­vices and nat­ur­al cap­it­al that are inher­ent with­in eco­lo­gic­ally healthy and long-term resi­li­ent wood­lands. How­ever, this would need to be care­fully spe­cified as an eco­lo­gic­ally healthy and long-term resi­li­ent wood­land is com­posed of much more than just trees (see explan­a­tion in our response to Ques­tion 6 below).

Improv­ing the con­di­tion of exist­ing wood­land allows for a dir­ect link to the Scot­tish Biod­iversity Strategy (ref 4) and any enhanced FGS ​‘wood­land eco­sys­tem’ type pay­ment should ref­er­ence this.

Fur­ther, there is a link to herb­i­vore man­age­ment since the spe­cies diversity and struc­tur­al com­plex­ity of wood­land eco­sys­tems is dis­pro­por­tion­ately impacted by herb­i­vore impacts via pref­er­en­tial brows­ing of pal­at­able species.

Ref­er­ences: 4: https://www.gov.scot/publications/scottish-biodiversity-strategy-2045-tackling-nature-emergency-scotland/

1. Do you agree that it should be a require­ment of grant sup­port that wood­lands are man­aged to ensure that they become more resi­li­ent to the impacts of cli­mate change and pests and disease?

Yes How can the grant scheme sup­port this?: Yes, and this aligns with the aims and object­ives of the Nation­al Park Part­ner­ship Plan.

Long-term resi­li­ence of a wood­land eco­sys­tem is embod­ied by its cur­rent and future struc­tur­al com­plex­ity, spe­cies diversity and over­all eco­lo­gic­al health which is about much more than just the trees.

Although the FGS has fea­tures with­in it that allow for some more eco­lo­gic­al ele­ments with­in schemes, its proven­ance is from the effi­cient grow­ing of mature trees for tim­ber and less about wood­land ecosystems.

The FGS should encour­age even great­er resi­li­ence and there­fore incentiv­ise the inclu­sion of a vari­ety of fea­tures with­in schemes which enhance wood­land eco­sys­tems and hence their resilience.

This should include, but is not lim­ited to;

• giv­ing schemes more space in the land­scape so nat­ur­ally regen­er­at­ing trees have the free­dom to self-select the best place to grow;
• increas­ing the phys­ic­al con­nec­tions between areas of wood­land includ­ing for dif­fer­ent forms of wood­land such as montane;
• hav­ing a great­er vari­ety of spe­cies of trees, bushes and ground flora;
• provid­ing for a much longer term and con­tinu­ous cycle of sprout­ing, growth, matur­ity and death among the trees, bushes and ground flora.

In our view the FGS needs great­er flex­ib­il­ity with­in its options and more focus on wood­land eco­sys­tems to enable it to sup­port more resi­li­ent wood­lands. We think this is likely to mean that the FGS will also have to improve its links to herb­i­vore management.

Cur­rently Nat­ive Scots Pine can be mixed with oth­er spe­cies at a ratio of 85:15 (under the Scots Pine or Nat­ive Broadleaves options). To pro­mote spe­cies diversity a more bal­anced mix would be bet­ter, per­haps a 60:40 or even 50:50 mix between Scots pine and nat­ive broadleaves (or vice versa). Per­haps options would be improved if the defined ratios were scrapped and replaced with a slid­ing scale of grant sup­port for a wide range of mixtures.

In addi­tion, a bet­ter fin­an­cial incent­ive with­in FGS for cre­ation of rare mont­ane wood­lands (high alti­tude wood­land mostly com­posed of short­er, shrub­bi­er, spe­cially adap­ted tree spe­cies such as Alpine Wil­lows and Dwarf Birch) would be helpful.

This is espe­cially valu­able here in the Cairngorms Nation­al Park where we cur­rently have some of the very last remain­ing rem­nants of mont­ane wood­land in Scot­land. Mont­ane wood­land cre­ation is a tar­get of the Cairngorms Nation­al Park Part­ner­ship Plan which out­lines an intent to recre­ate this hab­it­at at a large scale.

Cur­rently, mont­ane wood­land is best rep­res­en­ted with­in FGS as the Low-Dens­ity Nat­ive Broadleaves option, which is lim­ited to a max­im­um of 10 ha as a stand-alone scheme (or a max of 25 ha as a pro­por­tion of a lar­ger scheme using oth­er options). The altern­at­ive is to use the Nat­ive Upland Birch option, but have great­er flex­ib­il­ity in the alti­tudes per­mit­ted (i.e. high­er up than FGS would typ­ic­ally allow) and prob­ably increas­ing the allow­ance of woody shrubs from the cur­rent 20% to 40 or 50%.

Neither of these cur­rent FGS options allows us to suf­fi­ciently sup­port the cre­ation of mont­ane wood­land at large scale here in the Cairngorms. 3 — Integ­rat­ing Wood­lands on Farms and Crofts

1. Which of the fol­low­ing meas­ures would help reduce the bar­ri­ers for crofters and farm­ers want­ing to include wood­land as part of their farm­ing busi­ness? Please select all that apply.

Bet­ter integ­ra­tion of sup­port for wood­land cre­ation with farm sup­port mech­an­isms, Clear­er guid­ance on grant options, Flex­ib­il­ity with­in options, Sup­port with cash­flow, Inform­a­tion on how cur­rent land use could con­tin­ue with trees integ­rated through­out Are there oth­ers not lis­ted above?: Yes, see our response to Ques­tion 2.

1. Estab­lish­ing small wood­lands can have high­er costs. What spe­cif­ic mech­an­isms would bet­ter sup­port small scale wood­lands and wood­land ownership?

Please explain your answer in the text box.:

The FGS is com­plic­ated to nav­ig­ate and usu­ally requires the ser­vices of a pro­fes­sion­al forestry agent to effect­ively access all the rel­ev­ant parts and put togeth­er a wood­land scheme with accom­pa­ny­ing grant package.

A spe­cif­ic pack­age with­in FGS that pays for forestry agent fees to work up schemes smal­ler, say less than 100 – 150 hec­tares, would help here.

A sim­il­ar mod­el to The Wood­land Trust ​‘Croft Wood­lands’ pro­ject (ref 5), which is already proven and work­ing, would be a good option.

Altern­at­ively, a much sim­pler, less admin­is­trat­ively com­plex for both Scot­tish Forestry and the land owner/​manager, scheme could be developed spe­cific­ally for small woodlands.

Also, as stated in earli­er responses, we are keen to see wood­land estab­lish­ment, wheth­er via nat­ur­al regen­er­a­tion or plant­ing, achieved without the need for fences where feas­ible. For small wood­lands, per­haps on smal­ler own­er­ships in a mixed land use land­scape and out­side the reach of Deer Man­age­ment Groups, herb­i­vore man­age­ment will still be needed.

A bet­ter way, via the FGS, of pay­ing for deer con­trol ser­vices is needed. Per­haps this could be co-ordin­ated across sev­er­al smal­ler own­er­ships thus ensur­ing enough work to pay for full-time deer con­trol. Ref­er­ences: 5: https://​www​.wood​landtrust​.org​.uk/​a​b​o​u​t​-​u​s​/​w​h​e​r​e​-​w​e​-​w​o​r​k​/​s​c​o​t​l​a​n​d​/​c​r​o​f​t​-​w​o​o​d​l​ands/

4 — Forests Deliv­er­ing for People and Communities

1. How can forestry grants bet­ter sup­port an increase in eas­ily access­ible, sus­tain­ably man­aged wood­lands in urb­an and peri-urb­an areas?

Please explain your answer in the text box.: No response

1. How can grant sup­port for forestry bet­ter enable rur­al com­munit­ies to real­ise great­er bene­fits from wood­land to sup­port com­munity wealth building?

Please explain your answer in the text box.: Con­tinu­ation, enhance­ment, and bet­ter pro­mo­tion of the cur­rent Com­munity Grant Scheme to pro­mote com­munity led activ­ity in wood­lands is import­ant. Could this also include small scale wood-fuel businesses.

Addi­tion­ally spe­cif­ic meas­ures could be put in place to pro­mote pro­cure­ment with loc­al con­tract­ors and/​or social enterprises.

We would wel­come any trails or exper­i­ment­al schemes that Scot­tish Forestry wished to under­take in this regard with­in the Cairngorms Nation­al Park.

Also, many com­munit­ies are keen to provide trails of some sort, walk­ing, moun­tain bik­ing etc. and in some cases could do so with the agree­ment of the landown­er rather than hav­ing to pur­chase the woodland.

In this case could a future FGS provide grant aid to com­munit­ies to get a com­munity bene­fit in a loc­al wood­land that remains in private ownership?

See also our answer to Ques­tion 8 above.

1. How can the forest reg­u­lat­ory and grant pro­cesses evolve to provide great­er oppor­tun­it­ies for com­munit­ies to be involved in the devel­op­ment of forestry proposals?

Please explain your answer in the text box.: Upskilling of com­munit­ies may be required before they can take any great­er oppor­tun­it­ies to be involved in devel­op­ment of forestry pro­pos­als. Bet­ter under­stand­ing is required about how FGS can bene­fit com­munit­ies and how com­munit­ies can work through FGS schemes.

Some ini­tial guid­ance on how forestry pro­pos­als are developed, what factors are involved, the way that access to FGS is enabled, the roles of the land own­ers, agents, Scot­tish Forestry and Scot­tish Gov­ern­ment tar­gets for wood­land and forestry would all be needed first, as a tool­box that com­munit­ies can access before they can then use this learn­ing to then get effect­ively involved in the devel­op­ment of proposals.

Fur­ther to this, more involve­ment in the decision-mak­ing pro­cess for FGS is needed, as asked for in Ques­tion 12 below.

1. How can the forestry reg­u­lat­ory and grant pro­cesses evolve to ensure that there is great­er trans­par­ency about pro­pos­als and the decisions that have been made on them?

Please explain your answer in the text box.:

The cur­rent ​‘front end­ing’ of the FGS pro­cess, to ensure all issues are dealt with before final sub­mis­sion to Scot­tish Forestry and there­fore that an applic­a­tion pro­ceeds through the form­al stages quickly and eas­ily, has the dis­ad­vant­age of lim­it­ing the abil­ity of any­one to get involved with the decision-mak­ing pro­cess and/​or influ­ence the out­come. It can seem to stake­hold­ers like a ​‘fait accompli’.

Cur­rently very little detail of a wood­land or forestry scheme applic­a­tion for FGS are avail­able to the pub­lic (unless they were spe­cific­ally included in pre-applic­a­tion stage con­sulta­tions) until it’s fully sub­mit­ted and then it’s only on the web-based pub­lic register for 1 month.

Fur­ther detailed inform­a­tion is then only avail­able by con­tact­ing Scot­tish Forestry dir­ectly. By the time someone has seen an applic­a­tion on the pub­lic register, con­tac­ted Scot­tish Forestry, sub­sequently received fur­ther details and then con­sidered if they have com­ments etc, there is little time left for them to return a con­sulta­tion response with­in that 1 month window.

More lead-in time on pub­lic register might help, but to avoid excess­ive delays for the applic­ant, per­haps the pub­lic register should have a pre-applic­a­tion sec­tion that allows a pro­pos­al (that may or may not even­tu­ally be sub­mit­ted) to be out­lined, per­haps using the cur­rent ​‘concept map’ used in forestry pro­pos­als, well ahead of actu­al sub­mis­sion to give the pub­lic time to see, absorb and engage with any forth­com­ing forestry pro­pos­als in their area.

In addi­tion, we sug­gest that Scot­tish Forestry make use of the for­ums of Com­munity Coun­cils or for instance the Asso­ci­ation of Cairngorms Com­munit­ies to talk people though how and when they can make comments.

Con­tex­tu­al inform­a­tion, so stake­hold­ers can under­stand the over­all situ­ation and have the vocab­u­lary to input, should also be avail­able about a wood­land or forestry pro­pos­al. This should include brief details of the landowner’s jus­ti­fic­a­tion for the scheme, and how this fits with loc­al and nation­al gov­ern­ment targets.

In addi­tion, issues logs should be made freely avail­able, per­haps on the pub­lic register, so that people can see what issues have been con­sidered and how these have been resolved or decided on.

1. Forestry grants have been used to stim­u­late rur­al forestry busi­nesses by provid­ing sup­port with cap­it­al costs. Do you agree that this has been an effect­ive meas­ure to stim­u­late rur­al business?

Not sure a. How could this approach be used to sup­port fur­ther forestry busi­nesses?: Sup­port tree nurs­er­ies in pro­du­cing a wider range and diversity of nat­ive trees and woody shrubs. This avail­ab­il­ity of seed­lings would then allow for great­er diversity of plant­ing in FGS fun­ded schemes and con­sequently con­trib­ute to more eco­lo­gic­ally healthy wood­land eco­sys­tems that are resi­li­ent longer-term.

We also think there could be a bet­ter link between the FGS and to com­munity led loc­al devel­op­ment schemes like the EU LEAD­ER pro­gramme (ref 6). FGS could oper­ate with some options for com­munity bene­fit and per­haps link across to the pro­posed Tier 3 and 4 Agri­cul­tur­al pay­ments. Ref­er­ences: 6: https://www.ruralnetwork.scot/funding/leader

b. How could this approach be used to sup­port fur­ther skills devel­op­ment?: Using the example above of sup­port for tree nurs­er­ies per­haps busi­ness sup­port could be linked to the nurs­ery provid­ing the oppor­tun­ity for staff to achieve hor­ti­cul­tur­al qual­i­fic­a­tions such as SCQF or HNC (ref 7)? Ref­er­ences: 7: For example the fol­low­ing hor­ti­cul­ture courses are avail­able at Uni­ver­sity of High­lands & Islands; https://​www​.moray​.uhi​.ac​.uk/​c​o​u​r​s​e​s​/​?​a​u​t​o​=​&​k​e​y​w​o​r​d​=​h​o​r​t​i​c​u​lture

1. How could the FGS pro­cesses and rules be developed to encour­age more com­pan­ies and organ­isa­tions to provide train­ing pos­i­tions with­in the forestry sector?

Please explain your answer in the text box.:

We are unsure how the spe­cif­ic FGS pro­cesses and rules can help but addi­tion­al fin­ance to provide fully fun­ded appren­tice­ship places with­in the forestry sec­tor, at no or little cost to the host forestry com­pan­ies and organ­isa­tions would pos­sibly help.

Also see answers for Ques­tion 10 about com­munity grant scheme since grants to schools or loc­al social enter­prises or train­ing organ­isa­tions to assist with train­ing pos­i­tions in the forestry sec­tor could be very valu­able. 5 — Forests Deliv­er­ing for Biod­iversity and the Environment

1. The primary pur­pose of FGS is to encour­age forestry expan­sion and sus­tain­able forest man­age­ment, of which a key bene­fit is the real­isa­tion of envir­on­ment­al bene­fits. How can future grant sup­port bet­ter help to address biod­iversity loss in Scot­land includ­ing the regen­er­a­tion and expan­sion of nat­ive woodlands?

Please explain your answer in the text box.:

Biod­iversity loss: In terms of biod­iversity, we should be con­sid­er­ing the eco­lo­gic­al health and long-term resi­li­ence of the wood­land eco­sys­tem, not just the trees. We should also encour­age biod­iversity through the use of nat­ur­al regen­er­a­tion as opposed to tree plant­ing. See our responses to Ques­tions 3, 5 and 6.

The FGS should be bet­ter aligned to dir­ectly deliv­er the Scot­tish Biod­iversity Strategy (ref 8) aims and objectives.

Anoth­er cru­cial aspect of biod­iversity loss how we bet­ter man­age our exist­ing wood­lands. Any future FGS needs to bet­ter incentiv­ise the effect­ive eco­lo­gic­al man­age­ment of our exist­ing wood­lands and not be skewed towards cre­at­ing new woodlands.

Regen­er­a­tion and expan­sion of nat­ive wood­lands: Regen­er­a­tion and expan­sion of our nat­ive, espe­cially ancient, wood­lands is often only pos­sible by nat­ur­al regeneration.

For instance, for nat­ive Pine­woods on Scot­tish Forestry’s’ ​‘Cale­do­ni­an Pine­wood Invent­ory’ list (84 pine­woods cov­er­ing approx­im­ately 18,000 hec­tares across Scot­land) plant­ing in a defined sur­round­ing zone (which extends 600m bey­ond the mapped ​‘edge’ of the pine­wood) is spe­cific­ally pro­hib­ited to pro­tect the genet­ic pur­ity of the trees.

Thus, the only route for expan­sion of these wood­lands is via nat­ur­al regen­er­a­tion. If we are ser­i­ous about their eco­lo­gic­al health and long-term resi­li­ence then nat­ur­al regen­er­a­tion needs to be fun­ded at a high­er rate. New rates should be suf­fi­ciently flex­ible so as to deliv­er pay­ments for a range of tree dens­it­ies and allow fund­ing for at least 15 – 20 years. Ref­er­ences: 8: https://www.gov.scot/publications/scottish-biodiversity-strategy-2045-tackling-nature-emergency-scotland/

1. Herb­i­vore brows­ing and dam­age can have a sig­ni­fic­ant impact on biod­iversity loss and restrict regen­er­a­tion. How could forestry grant sup­port mech­an­isms evolve to ensure effect­ive man­age­ment of deer pop­u­la­tions at:

Land­scape scale?: Effect­ive man­age­ment of deer pop­u­la­tions at land­scape scale needs more incent­ive. A high­er grant rate per hec­tare for long term land­scape scale deer con­trol such that eco­nom­ic­ally it does become bet­ter ​‘value’ to the applic­ant to under­take deer con­trol versus installing fences.

Small scale mixed land use?: We are unsure of the best approach to this and acknow­ledge that the situ­ation is com­plic­ated not just by mixed land use but often by mixed ownerships.

Some kind of col­lab­or­at­ive struc­ture for deer man­age­ment, with joint liab­il­it­ies, that must be in place before you can access FGS might be appro­pri­ate l.e. ensur­ing deer man­age­ment ser­vices are avail­able across the mixed land use/​ownership.

Could FGS also con­trib­ute to, or oth­er­wise help facil­it­ate, the appro­pri­ate deer man­age­ment cov­er for an area? If you wish to make any oth­er rel­ev­ant com­ments, please do so in the text box below.

Please add your com­ments here.: Com­plex­ity: A much sim­pler, less admin­is­trat­ively com­plex for both Scot­tish Forestry and the land own­er or man­ager, forestry fund­ing scheme would be wel­come. Our exper­i­ence of the cur­rent sys­tem is such that applic­a­tion bur­eau­cracy can be over com­plic­ated, espe­cially for smal­ler, or primar­ily com­munity bene­fit, schemes. We would wel­come any steps Scot­tish Forestry can make to sim­pli­fy­ing the applic­a­tion process.

Flex­ib­il­ity: The cur­rent FGS has tar­get areas, of which Cairngorms Nation­al Park is one, that attracts a high­er per hec­tare pay­ment for some tree plant­ing options, and an increased fen­cing rate to reflect the dif­fi­culties of fen­cing in upland areas.

This is bene­fi­cial but, if the FGS had slid­ing scales, with cer­tain upper and lower lim­its that could be adjus­ted in cer­tain geo­graph­ic­al zones, then it would be a lot more flex­ible. Vari­ous out­comes could be facil­it­ated by FGS and could be more suc­cess­fully tar­geted in vari­ous areas of Scotland.

As a crude example, in the Cairngorm Nation­al Park, where we want to encour­age nat­ur­al regen­er­a­tion of nat­ive spe­cies without fences, the fen­cing rates pay­able could be reduced and incent­ives for deer man­age­ment increased. Sim­il­arly, nat­ur­al regen­er­a­tion of nat­ive spe­cies could be incentiv­ised over rates for plant­ing non-nat­ive species.

Tree plant­ing and peat or car­bon rich soils: FGS is clear about not sup­port­ing tree plant­ing on peat great­er than 50cm depth. In addi­tion, sev­er­al addi­tion­al guid­ance doc­u­ments are provided on the FGS Rur­al Pay­ments & Ser­vices web pages that refer to deal­ing with peat rich and wet soils (e.g. GWDTE, Assess­ing mar­gin­al sites).

How­ever, the UK Forestry Stand­ard (UKFS) word­ing is to ​“avoid estab­lish­ing new forests on soils with peat exceed­ing 50 cm in depth and on sites that would com­prom­ise the hydro­logy of adja­cent bog or wet­land habitats.”

In our view FGS does not deal well with the lat­ter part of this guid­ance and cur­rently some­times does sup­port plant­ing on sites that could com­prom­ise the hydro­logy of adja­cent bog or wet­land habitats.

The 2015 Forestry Com­mis­sion Scot­land guid­ance note on ​‘Decid­ing future man­age­ment options for affor­es­ted deep peatland’9 has a more com­pre­hens­ive approach to deal­ing with hydro­lo­gic­ally linked areas of shal­low­er peat but is cur­rently not ref­er­enced on the FGS guid­ance pages.

Vari­ous dif­fer­ent ​‘rules’ for defin­ing deep or true peat are used across the peat res­tor­a­tion and forestry sec­tors to identi­fy where it is or isn’t appro­pri­ate to plant trees.

The situ­ation is fur­ther com­plic­ated by report­ing in the sci­entif­ic press about net car­bon fluxes from tree plant­ing on car­bon rich soils. We fully under­stand and acknow­ledge that there are nuances here and the type of car­bon emis­sions that may occur when plant­ing hec­tares of com­mer­cial Sitka Spruce on car­bon rich soils using drains (refs 9 & 10) are not the usu­al situ­ation in Cairngorms Nation­al Park where we are largely plant­ing nat­ive spe­cies on undrained soils. How­ever, we must guard against any pos­sib­il­ity that tree plant­ing with­in the Nation­al Park could be det­ri­ment­al to our efforts to achieve net zero.

Over­all, the situ­ation can be unclear for applic­ants and avail­able guid­ance is not well aligned or nuanced and confusing.

We would like FGS imple­ment­a­tion to be bet­ter aligned with the avail­able guid­ance on crit­ic­al peat depths and hydro­lo­gic­ally linked hab­it­ats. Ideally this would require the applic­ant to provide a more robust or appro­pri­ate assess­ment of peat depths and cru­cially an assess­ment of hydro­lo­gic­al con­nectiv­ity to adja­cent bog or wet­land habitats.

This will help safe­guard our valu­able peat­lands and secure their car­bon seques­ter­ing role, while ensur­ing that wood­lands con­tin­ue to ful­fil an optim­al and bal­anced role in achiev­ing net zero targets.

Com­munity bene­fits — pub­lic good from pub­lic money: Future grant sup­port for forestry in Scot­land should work harder to embed deliv­ery of social, envir­on­ment­al and com­munity bene­fits as a require­ment of good forestry practice.

The UKFS provides the over­arch­ing frame­work and guid­ance with­in which wood­land own­ers and man­agers must oper­ate to bal­ance eco­nom­ic, social and envir­on­ment­al benefit.

How­ever, our obser­va­tion is that achiev­ing the good prac­tice require­ments of the UKFS are often not suf­fi­ciently com­pelled with­in the wood­land and forestry schemes that receive FGS fund­ing. We would like to see more emphas­is put on ensur­ing pub­lic bene­fit is delivered by those receiv­ing pub­lic fund­ing for forestry and woodland.

For instance, with regards access, we often see that see FGS recip­i­ents com­ply­ing with the min­im­um leg­al require­ments of the Scot­tish Out­door Access Code (SOAC) but noth­ing fur­ther. We would like to see any future FGS pro­mote applic­ants being more pro­act­ive, i.e. seek­ing to under­stand loc­al com­munity usage and demand for access dur­ing ​‘due dili­gence’ stages of applic­a­tion and hence design schemes that not only com­ply with SOAC but enhance it.

In addi­tion, could a revised, improved, grant scheme require that a cer­tain per­cent­age of over­all expendit­ure on wood­land creation/​management must be alloc­ated to non-com­mer­cial (includ­ing com­munity) benefits?

The WIAT wood­lands grant should be improved. This grant cur­rently applies to wood­lands with­in 1km of a pop­u­la­tion set­tle­ment of 2000+ people. Clearly this excludes most of the com­munit­ies of the Cairngorms Nation­al Park so to have great­er reach and pos­it­ive impact we feel this pop­u­la­tion threshold should be lowered to 1000 or less. This would then bet­ter reflect the value of wood­lands nearby smal­ler com­munit­ies such as Anagach Woods next to Grant­own on Spey for instance. This would enable a great­er vari­ety of forest own­er to access fund­ing for com­munity bene­fits such as path improve­ments and wood­land restruc­tur­ing. Ref­er­ences: 9: https://forestry.gov.scot/publications/1032-cultivation-for-upland-productive-woodland-creation-sites-applicant-s-guidance 10: https://​www​.sci​en​ce​dir​ect​.com/​s​c​i​e​n​c​e​/​a​r​t​i​c​l​e​/​p​i​i​/​S​0​2​6​4​8​3​7​7​2​3​0​01436 About you

What is your name? Name: What is your email address? Email: fionaholmes@​cairngorms.​co.​uk Are you respond­ing as an indi­vidu­al or an organ­isa­tion? Organ­isa­tion What is your organ­isa­tion? Organ­isa­tion: Cairngorms Nation­al Park Author­ity Scot­tish Forestry would like your per­mis­sion to pub­lish your response. Please indic­ate your pub­lish­ing pref­er­ence: Pub­lish response only (without name) We may share your response intern­ally with oth­er Scot­tish Forestry policy teams who may be address­ing the issues you dis­cuss. They may wish to con­tact you again in the future, but we require your per­mis­sion to do so. Are you con­tent for Scot­tish Forestry to con­tact you again in

rela­tion to this con­sulta­tion exer­cise? Yes I con­firm that I have read the pri­vacy policy and con­sent to the data I provide being used as set out in the policy. I consent