My response to that blasted Sell Our Forests consultation

It’s not been the best of weather this weekend, but even so I may have preferred to spend it outdoors rather than sitting in front of a computer screen responding to a boring government consultation document. It’s a task I’ve put off for the last week or so because I was expecting it to be unspeakably dull, and sure enough, it was.

Footpath through English beech woods
Footpath through English beech woods

The consultation in question is the Department for Environment Food and Rural Affairs (DEFRA’s) Future of the public forest estate, otherwise known as the Sell Our Forests consultation. Why I felt it necessary to do this, and get involved in politics after a long period of political apathy, I have talked about in a previous blog post. Despite being confined to my central London flat today, I have the consolation of knowing that I may oh so slightly have improved my chances of going for a pleasant walk in the woods any Sunday I choose for years to come. I have to do my bit in helping to conserve access to our woodlands, and manage it for the benefit of the public and wildlife for future generations.

For what it’s worth, I thought I would record my response for posterity, and in the off chance that it may help anyone else who like me has been procrastinating. It’s the first time I’ve ever responded to a government consultation, and although it may be naive of me, I must confess to being a little shocked by the loaded nature of some of the questions, for they assume that selling our forests is a done deal, the only way forward for the woodlands most of us have been paying our taxes to enjoy all our working lives. It would have been easy to fall into the trap of agreeing to some of the statements in the document, for they seem sensible enough, but only in the context of the sale going ahead, a sale that I’m very much opposed to.

It’s important to understand how the data will be used. By ticking Agree then my response will be included in statistics which claim I agree to the government’s proposals. It’s therefore necessary to select Disagree and caveat it in any comments I make.

My thanks go to @SaveOurForests, for their excellent briefing note on responding to the consultation, without which completing my response would have been much more stressful.

So without further ado, here’s my response. My words are in italics.

1a. Do you agree or disagree with each of these key principles which Government proposes to abide by when making decisions on new owners for the public forest estate?

  • Protect and enhance biodiversity to contribute to a network of wildlife corridors across England – Disagree
  • Maintain public access for recreation and leisure – Disagree
  • Ensure the continuing role of the woodland in climate change mitigation and adaptation – Disagree
  • Protect nationally important landscapes – Disagree

1b. What changes would you recommend making to this list of principles?

I agree that all of the above 4 principles are very important in managing our woodlands. However, the phrasing of your question implies that I agree new owners should be found for our public forest estate. I do not.

2a. Do you agree or disagree that:

  • New or existing charitable organisations should be offered the opportunity to take on ownership or management of heritage forests? – Disagree
  • Opportunities should be created for community and civil society groups to buy or lease forests that they wish to own or manage? – Disagree
  • Commercial operators should be found to take on long-term leases for the large-scale commercially valuable forests? – Disagree

2b. Are there other models of ownership or management that could achieve the Government’s ambition to reduce state ownership without undermining its key principles?

No there are not. The most effective way of enforce the principles stated in section 1a is to keep the forests in state ownership and not sell them at all.

3a. How likely are the proposed models to result in efficiency gains?

Unlikely.

3b. Do you have any evidence or reasons to support your view on the impact on efficiency, and any thoughts on how any barriers to efficiency could be addressed?

It costs the tax payer just 30p per person per year for the Forestry Commission to manage our woodlands. Charitable trusts and community groups are unlikely to be able to manage the forests to the same degree without government grants. Moreover many will lack the experience of highly skilled Forestry Commission staff, so the forests will not be as well managed. Barriers could be addressed by maintaining the status quo, and looking at ways in which the Forestry Commission itself can operate more efficiently without taking the extreme step of selling off its assets.

4a. Do you agree or disagree with this characterisation of the public forest estate?

Disagree.

4b. What other factors might the Government consider when characterising the public forest estate?

That most forests are multi-purpose and a mixture of any of the four classifications. For example, many heritage forests have areas which are managed for timber, while many commercial forests have public footpaths passing through them, permissive paths, and areas of access land.

5a. Do you agree or disagree that the following criteria are right for deciding whether a particular area of the public forest estate is suitable for transfer to a charity?

  • Forest of national historical, biodiversity or cultural significance – Disagree

5b. What other criteria might the Government use?

As you will see by my response to 4b, I am unhappy about the classification model being applied. It is easy for the government to accept that the New Forest and Forest of Dean are heritage woods, but other forests with a smaller heritage element may be classified as commercial and be given little or no protection when sold to commercial foresters.

6a. Do you agree or disagree that the following principles are the right ones to guide the design of a transfer of the public forest estate to a charity?

  • A recipient charity would be expected to manage the forests to maintain and enhance a variety of public benefits – Disagree
  • The charity would have to comply with a set of agreed rules – Disagree
  • The charity would meet existing legal commitments, for example tenancies and timber supply contracts, and partnership agreements – Disagree
  • The forest would be transferred to the charity at no charge for the new owner – Disagree
  • The charity is likely to continue to require continuing funding from Government in return for the public benefits – Disagree
  • The charity would be expected to become less reliant on Government grant over time – Disagree

6b. What other principles should we consider?

While the principles themselves are reasonable enough, they are being enforced already under public ownership. Again, as with 1a above, the question assumes selling the forests to charities is the right approach.

7a. Do you agree or disagree that these are the right objectives for any charity which manages one of these forests?

  • High quality access – Disagree
  • Certification of woodland management – Disagree
  • Safeguarding and enhancing biodiversity benefits – Disagree
  • Balancing interests of timber production with those of conservation and recreation – Disagree

8a. Do you agree or disagree that all forest sales, apart from land which is transferred to a charity, and those sales which form part of the 2010/11 – 2014/15 programme, should be offered for sale to community or civil society organisations first?

Disagree.

8b. What other approach might the Government adopt?

Not sell them in the first place.

9a. Do you agree or disagree that the following principles are the right ones to guide the design of the sale of the public forest estate to community or civil society groups?

  • Extra time to prepare to bid for the forest. Groups can also approach the Forestry Commission to discuss buying land which is currently not on the market – Disagree
  • The Forestry Commission will provide a valuation and timetable for decision by the organisation – Disagree
  • The forest would be sold or leased at the market rate – Disagree
  • The groups could apply for forestry grants – Disagree
  • Should the groups be wound up, the land would be returned to the ownership of the Secretary of State – Disagree
  • Any purchasing or leasing organisation would be free to manage the forest in accordance with their own objectives (subject to any lease conditions imposed by the Government to protect public benefits) – Disagree
  • If community or civil society groups chose not to purchase or lease the forest, then the land could be leased on the open market – Disagree

9b. What other principles should we consider?

I doubt very much community groups would be able to manage the forests to the same standards as the Forestry Commission.

10a. Is the approach proposed for sales or leases to community or civil society groups sufficient for the protection of public benefits?

The public benefits would be more effectively protected by a public body funded by the tax payer, staffed by specialists and tasked with managing the forests for the public good, such as the Forestry Commission.

11a. Do you agree or disagree that the following are the right criteria for deciding whether a particular area of the public forest estate is suitable for leasing to the private sector?

  • Where the primary purpose and benefit delivered by the woodland is timber production and other commercial opportunities – Disagree
  • Scope for using lease conditions to safeguard public benefits – Disagree

11b. What other criteria might the Government use?

The Forestry Commission already manages commercial forests more effectively than private owners, as demonstrated by the fact that two thirds of private forests are unmanaged or under-managed. The Forestry Commission also protects public benefits more effectively. This is demonstrated by the fact that only 18% of our forests are publicly owned, but this includes 50% of forests that are publicly accessible.

12a. Do you agree or disagree that these are the right principles to guide the leasing of productive forests?

  • Lessees would be identified through a competitive dialogue process – Disagree
  • Leases would last for 150 years and impose conditions where needed to safeguard public benefits – Disagree
  • Where practical, smaller parcels of land which have particular public value would be considered for separate sale – Disagree
  • Consideration will be given to the potential impact on the supply of timber into the wood-processing industry, in particular during any transition period – Disagree

12b. What other principles should we consider?

The idea of institutional investors owning my forests horrifies me.

13. Are there other safeguards that the Government could consider outside the scope of the provisions of an individual lease (when offering leasehold of commercial forests)?

Leaving our forests in public ownership.

14a. Do you agree that the proposed approach is the right approach for managing the residual estate?

Disagree.

14b. What other approach might the Government adopt?

Leaving our forests in public ownership.

15a. Do you agree or disagree that Forestry Commission England should focus on the delivery forestry policy through:

  • protecting the woodland resource and increasing its resilience to pests, diseases and the impact of climate change – Agree
  • improving the woodland resource to enhance delivery of public benefits – Agree
  • expanding the woodland resource through promoting and creating incentives for planting and naturally regenerating trees, woods and forests of the right type in the right place – Agree
  • empowering and enabling people to determine and deliver the public benefits which they want from woodland – Agree
  • promoting a competitive, thriving and resilient forestry sector – Agree

15b. What other priorities should Forestry Commission England focus on?

Although I agree wholeheartedly that part of our forest estate needs to be managed commercially, the most important principles to me are public access and environmental responsibility. I would like to see our publicly-owned forest estate expanded and made more accessible to us, with more public footpaths, cycle paths, and bridle paths, and more areas classified as access land. This will help to promote a healthy life style and provide a better quality of life to all who use them. I would like to see our forests managed in a way that encourages more native species to return – more native trees, more insects, birds and mammals.  Wherever possible, I would like to see more of Britain return to native forest again.

16. Additional comments

I believe this consultation has been asking the wrong questions. In general, I do not believe our forests should be sold into private ownership. I certainly do not believe in the wholesale disposal of the entire estate in the way that is being proposed. This question should really have been asked first of all. I refer you to the previous consultation you made on this subject, The Long Term Role of the Public Forest Estate in England, in 2009. This concluded:

“The Estate is seen to represent good value for money in providing multiple social and environmental benefits and there is a strong desire for the Estate to increase in size. In particular, expansion is sought to provide social benefits to urban populations and to protect areas with special characteristics. Woodland creation and free public access remain top priorities. There is strong resistance to the Disposal Policy and concern over relinquishing management to third parties, notably the private sector.”

Our forests have been here for thousands of years, and we have been enjoying them for just as long. What was true two years ago is true today.

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