Committee for Agriculture and Rural Development
Draft Forestry Bill
Confederation of Forest Industries (ConFor)
SUBMISSION TO THE AGRICULTURE AND RURAL DEVELOPMENT COMMITTEE ON THE NORTHERN IRELAND ASSEMBLY FORESTRY BILL – COMMITTEE STAGE
ConFor (Confederation of Forest Industries) has been established to represent forestry and wood using businesses from nurseries and growers to wood-processing end-users. ConFor aims to help build the market for timber and timber products, create a supportive policy environment for the forestry and wood using sector and to help members become more competitive and successful. ConFor has by far the largest membership of any representative body in the sector.
Real progress has been made in recent decades in Northern Ireland (NI) to develop a modern, successful forestry and wood-using sector. It is one of the few sectors in NI that can deliver both sustainable economic development and help in the fight against climate change. Growing trees sequesters carbon and sustainably produced wood can be used to lock up carbon and substitute for more energy-intensive materials, such as brick, steel and plastics. Wood can also be used to generate renewable energy.
The NI forestry and wood-using sector is a local source of employment and investment. No other industry can claim that it can profitably integrate economic, social and environmental concerns without damage, and to the benefit of all stakeholders. The wood processing sector in the region has the capacity to increase production and hence provide additional economic activity and carbon benefit if more wood can be brought to market.
It is estimated that wood processing businesses alone provided £9.2m of wages, in addition to the £33.5m of estimated expenditure on goods and services. Latest investment figures are estimated to be approximately £13m a year, including the first Combined Heat and Power plant in the NI forest products sector. The sector is responsible for tens of millions of pounds of investment on the back of supplies of wood.
Wood processing supports the sustainable management of most of NI’s woodlands – both public and private. In other countries of the UK in recent years, government policy has to varying degrees forgotten the important link between woodland and the use of wood, and has had to rediscover it. It is important that this link is not lost in NI.
The Northern Ireland Forest Service (NIFS) has played an important role in helping support the development of the sector, but there is a lot more that can be achieved. It is vital that the new Forestry Bill builds on this record of achievement.
In that context ConFor would like to see a clear reference to the importance of achieving the Assembly’s target to double the area of woodland in NI to 150,000ha by 2050 , and to ensure that there is a continuing and growing supply of sustainably produced wood to support the expansion of a low carbon wood processing sector. At present the area of productive woodland in NI is reducing. Increased new planting would have the dual benefit of locking up carbon and helping to provide future supplies of wood.
Increased new planting will also provide a means to respond to other stakeholders’ requests for more woodland to be managed primarily for recreational access and biodiversity. ConFor recognises that other stakeholder groups will look for the new Forestry Bill to deliver more for their interests and that can be accommodated better through an increase in woodland area. At present NI’s woodland cover is amongst the lowest in Europe – just 6% against an average of 44% in Europe.
Key issues
ConFor is generally content with the draft Bill, subject to the overarching points set out above about ensuring the continued growth of the sector and the need to deliver increased levels of new planting, and the specific comments set out below.
Felling licences
ConFor’s principal concern over felling licences is the intention to charge for a licence. No charge is made in Great Britain or the Republic of Ireland. A charge could well act as a disincentive to plant new woods or manage existing woodlands. This would have the perverse effect of undermining the central purpose of the Bill.
Charging would also add a cost to private woodland owners’ activity that would not also be borne by NIFS, even though both may hold the same certificate for sustainable forest management. If independent certification is a justification for exempting NIFS then it should also be considered for the private sector.
ConFor recognises that there can be benefit in introducing felling licences to respond to increasing government demand for green timber procurement and in response to discussions in the EU on tackling imports of illegally logged wood and putting systems for ‘due diligence’ in place. However, there are major concerns over how felling licences could be introduced, and the potential damage that could have on the Bill’s central aim of promoting sustainable forest management in NI.
Green timber procurement and due diligence policies are aimed at tackling illegal and unsustainable practices overseas, and ensuring that UK imports of wood do not contribute to these. There is not a major problem of illegality or unsustainable activity in NI. Consequently it is important that felling licences are introduced in a proportionate manner, and that they complement, rather than duplicate existing voluntary forest certification.
It is also important that they are introduced in a way that recognises NI’s own situation – in Great Britain felling licensing can be a lengthy process due to the need for consultation with statutory bodies that vary from area to area. In NI the scale of woodland activity is much smaller and NIFS is well-placed to ensure compliance with appropriate policies and legislation, meaning that the requirement for such consultation could be significantly reduced.
Consideration should also be given to providing support for long-term management plans, as is the case in Scotland. These plans both cover the need for a felling licence and promote the long-term sustainable management of the woodland – a real benefit for NI and firmly in line with the aim of the Bill .
Compulsory acquisition of land
ConFor understands that the compulsory purchase clause has been included primarily to provide for situations where there is no effective access to a NIFS woodland to undertake timber harvesting activity, and that it could also be used to purchase small, additional areas of land to enable development on NIFS woodland to proceed, for example for a windfarm. However, there is no limitation set on its potential use and this is an issue of concern.
ConFor believes that there needs to be greater clarity over the purposes for which the power would be used and full consideration of practical alternatives. This could include, for example, a new power of temporary requisition of land with compensation during the period which access is required with subsequent reinstatement to the landowners’ satisfaction. ConFor would also expect that the route of agreed purchase would be explored thoroughly before making a compulsory purchase.
It would also be useful if there was clarification over how any system of compulsory purchase would operate. For example, that its use should follow the principles used in other processes of compulsory purchase.
ConFor recognises that there are situations where wood is ‘land-locked’ and a measure such as this would be appropriate. However, ConFor would also ask that the principle of acting to access land-locked timber was extended to privately owned woodland. In these situations the mechanism is likely to be different from compulsory purchase, for example NIFS supporting negotiation with the owner of land over which access is required.
Controlling vegetation and pests
ConFor recognises that increased rates of new planting will be difficult to achieve as the number of damaging pests, in particular deer, also increases. However, it is important that targeted action is taken, as deer control, for example, is not a problem in all areas.
It is not clear that the route of giving power, through this Bill, to the NIFS to control pests such as deer is the most effective way of achieving the objective. In order to be effective the NIFS needs to support and participate in deer management groups, working closely with private landowners..
Right of access to all NIFS woodlands
If NIFS takes forward a pedestrian right of access to all NIFS woodlands then the impact on owners of sporting rights needs to be fully considered and acted on.