20 February 2009

1. The Woodland Trust welcomes the opportunity to respond to this consultation. The Trust is the UK's leading woodland conservation charity. We have four main aims: no further loss of ancient woodland, restoring and improving woodland biodiversity, increasing new native woodland and increasing people's understanding and enjoyment of woodland. We own over 1,000 sites across the UK, covering around 20,000 hectares (50,000 acres) and we have 300,000 members and supporters.

Summary

• The Northern Ireland Executive should now legislate for a carbon reduction target in order to establish what contribution the province will make to the overarching UK wide targeted cut in carbon emissions of 80 per cent by the year 2050.
• Climate change will continue to have significant, and negative, impacts on both wildlife and people. Accordingly, there is a need for landscape scale action in Northern Ireland to help secure the natural environment and the ecosystem services it provides such as clean air, enhanced soil and water quality.
• Caution should be exercised when imposing a purely economic valuation on the natural environment. Indeed, it is widely accepted that there has been a decline in the quality and diversity of Northern Ireland’s wildlife over the past fifty years, and therefore more must be done to safeguard vitally important environment assets such as ancient and long-established woodland.
• Given the crucial role woodland can play in helping Northern Ireland negate and adapt to climatic change, the Northern Ireland Sustainable Development Strategy should align its woodland creation target to that of the Northern Ireland Forestry A strategy for Sustainability and Growth by committing itself to doubling woodland cover in the province.
• The suite of PSA indicators should be expanded to include protecting, restoring and expanding the most important natural habitats. These habitats, including woodland, can help wildlife and people adapt to the negative impacts of climate change.
• All departments have a role in ensuring that Northern Ireland is able to meet is climate change objectives. As a consequence, the Assembly should be prepared to scrutinise the actions and pronouncements of any Minister whose policies might have an impact on the environment.

a. To identify initial commitments for Northern Ireland that will ensure it plays a fair and proportionate role as part of the UK in meeting climate change targets

2. In the Climate Change Act there is no legally binding emissions reduction target for Northern Ireland, and therefore it is unclear as to what is expected of the province in terms of its contribution to the UK wide target of an 80 per cent cut by 2050. To give clarity and transparency to climate change policy, the Executive could now legislate for its own target; and should at the very least put into statute the commitment in the Programme for Government to ‘Reduce greenhouse gas emissions by 25 per cent below 1990 levels by 2025’.
3. Section 60 of the Climate Change Act, ‘Programme for adaptation to climate change: Northern Ireland’, details the relevant duties Northern Ireland departments will have in relation to adapting to the negative impacts of climatic change. Crucially, the Assembly must be rigorous in its scrutiny of the adaptation programme, and this could take the form of annual report by the Environment Committee judging the actions and performance of the Executive’s departments and agencies.
4. Climate change is already here. It impacts on woodland habitats and the species they support by disrupting life cycles, altering interactions between species, and often requiring them to migrate to more suitable conditions. In light of this dynamic an adaptation strategy should focus on certain principles such as protecting the best of the resource, expanding it where possible, and restoring it where it might have been degraded. This should mean absolute protection of ancient and long-established woodland, creating new woodland where it can benefit either wildlife or people, and restoring ancient woods that were degraded by the planting of non-native conifers.

b. To consider the necessary actions and a route map for each significant sector in Northern Ireland (energy, transport, agriculture and land use, business, domestic, public sector etc)

5. Northern Ireland has a highly fragmented landscape and the likely rates of climate change threaten the survival of its natural world. Accordingly, the Trust expects the Northern Ireland Executive and its departments to recognise the importance of native woodland, in particular ancient and long-established woodland and ancient trees, as the foundation for the restoration of this fragmented landscape.
6. The Trust believes that there is a need to target actions at a landscape scale level (1). When implementing an adaptation programme, the Executive could create new wildlife habitats within a sympathetically managed landscape that allows as many species as possible to adapt, and move, in response to changes in climate.
7. As climate change becomes a pressing issue for Northern Ireland, it is important that the Executive delivers on its commitments held within the following documents: the Northern Ireland Biodiversity Strategy , Northern Ireland Forestry A strategy for Sustainability and Growth, and the Northern Ireland Sustainable Development Strategy. These commit the Northern Ireland Executive to restoring ancient woodland, doubling woodland cover, and protecting important semi-natural habitats.
8. Further to this the Trust has produced its own manifesto, A vision for woodland in Northern Ireland. In response to a parliamentary question, OFMDFM welcomed our document as a ‘useful perspective on the environmental and social aspects of forestry' (2). The Trust now hopes that our document will be incorporated into the wider policy framework.

c. To identify the costs associated with meeting these obligations and compare them with the costs that will be incurred if they are not achieved.

9. There is much research going into whether it is possible to impose an economic valuation onto the natural environment – something that remains deeply controversial because it is easier to place a value on biodiversity or ecosystem services that can be traded, whereas it is it is near impossible to do this for those that are not marketable. The Assembly should therefore be cautious, and possibly avoid trying to evaluate environmental policies by using a purely economic rationale.
10. Nonetheless, The Economics of Ecosystems and Biodiversity (TEEB report) (3) and an investigation into The Economic and Social Aspects of Biodiversity Benefits and Costs in Ireland (4) have sought to impose an economic valuation on the natural environment. The TEEB report concluded that: ‘The loss of biodiversity and ecosystems is a threat to the functioning of our planet, our economy and human society’ (5). Such sentiments justify spending public money on protecting the environment and improving the public’s engagement with, and understanding of, the natural world.
11. Moreover, in 2007 a piece of research, The Environmental Economy of Northern Ireland, put the gross value added accruing from forestry in the province at £3 million (6). Tourism was a vital component in this success, and therefore protecting the best of the resource is vital if the province is to continue attracting inward investment and visitors.
12. Northern Ireland suffers from a legacy of habitat removal with 13 per cent of ancient and long-established woodland that survived to the 1960s being lost; representing a total of 273 ancient and long-established woods that have been cleared altogether . Additionally, the Executive is committed in the Programme for Government to reduce significantly the loss of wildlife by 2010 and halt wildlife decline by 2016. In response to this point it is quite legitimate that any climate change adaptation programme ensures that biodiversity is able to adapt in the face of climatic change. In respect of woodland conservation this should mean absolute protection for ancient and long-established woodland, restoration of those woods previously degraded by the planting of non-native conifers, and targeted woodland creation to benefit both people and wildlife.
13. A DOE led adaptation strategy should afford an opportunity to implement landscape scale action and impress upon the public conscious the value of the ‘services’ that Northern Ireland derives from a healthy natural environment. For example, this could be an ideal moment to create new woodland and restore those woods previously degraded by non-native conifers. In support of this the Trust has evidence demonstrating the economic benefit of restoring ancient woodland (7), and perforce restoring PAWS should be a key strand in an adaptation strategy.

d. To identify a formal cost effective mechanism for assessing the potential impact of new policies on climate change / CO² emissions. (Akin to Regulatory Impact Assessments/Rural Proofing)

14. No comment.

e. To make recommendations for appropriate targets/actions that could be included in the new Northern Ireland Sustainable Development Implementation Plan

15. The original Northern Ireland Sustainable Development Strategy committed the Executive to increasing the area of forestry by 500 hectares per annum. This though is a less ambitious target than the one in Northern Ireland Forestry: A strategy for Sustainability and Growth that pledged to double woodland cover in the next 50 years. The Trust hopes that any revision to the Northern IrelandSustainable Development Strategy furnishes an ambitious woodland creation target – primarily broadleaved woodland given its ecological value – in recognition of the benefits the province could derive from expanding its wooded resource.
16. It is estimated that Northern Ireland has 87,000 hectares of woodland, and therefore to double woodland cover there will need to be approximately 1,740 hectares of new woodland planted per annum. This then, is the figure the Trust would like included in the Northern Ireland Sustainable Development Strategy.
17. In the past OFMDFM admitted that they were unable to measure the increase of wooded area in Northern Ireland as they did not know comprehensively the location of the resource (8). Another action that should be identified in the Northern Ireland Sustainable Development Strategy is the creation and maintenance of a record of all woodland in the province. The Trust has already compiled an inventory of ancient and long-established woodland, and would now ask the Executive to take over the mantle by creating and then maintaining a comprehensive inventory of all woodland. Such an amendment would deliver upon the recommendations in the Northern Ireland Biodiversity Strategy.

f. To make recommendations on a public service agreement for the DOE Climate Change Unit’s commitments in the second Programme for Government that will ensure Northern Ireland will meet its climate change obligations.

18. Adapting to climate change will be one of the great challenges facing DOE in the coming years. To return the natural environment onto a sustainable footing it will be necessary to improve the connectivity between habitats in order that wildlife can migrate to more suitable conditions. This will involve protecting the most valuable semi-natural habitats, restoring those that have been degraded, and expanding the resource.
19. A new suite of public service agreements could be created to improve the current commitment to declare 75 ASSIs by 2011 held within the Programme for Government. This could include a commitment to protect all ancient and long-established woodland, to restore those sites previously degraded by the planting of non-native conifers, and to double the area of woodland in Northern Ireland.
20. The current target in the Programme for Government to increase by 1650 hectares the area of forests in Northern Ireland by 2011 will fail to double woodland cover. Indeed, this target will only increase the area of woodland in the province by approximately a quarter, and sits uneasily with other commitments. Any new public service agreement should seek to rectify this anomaly by providing a realistic target that is going to allow the Executive to deliver a doubling of woodland cover in 50 years.
21. There is broad ranging political support for creating new woodland in the Assembly as demonstrated by the cross party support for the Ulster Unionist no-day named motion stating:

    That this Assembly notes the limited target set in the Programme for Government for increasing the area of forest and woodland; and calls on the Minister of Agriculture and Rural Development to detail the strategies that are in place to achieve the 2006 Forestry Strategy target of doubling woodland cover in the next fifty years (9).

g. To consider what secondary legislation raising powers within the UK Climate Change Act would contribute to Northern Ireland’s commitment to the UK Climate Change Bill.

22. No comment.

h. To express views on if and how the Assembly might conduct more effective scrutiny of climate change responsibilities across all relevant departments.

23. All government actions can have a significant impact on the success of climate change policies. It therefore behoves the Executive to test all of its policies against any negative impacts they might have on climate change. So as to ensure compliance with commitments in the Climate Change Act, the various departmental committees in the Assembly should be prepared to challenge ministerial pronouncements whenever appropriate. Additionally, the responsibility to challenge the Executive as a whole rests with the OFMDFM Committee, and therefore the Trust would hope that their inquiries reflect the importance of negating, and adapting to, climate change.
24. Moreover, the Assembly could also give the Environment Committee the power to scrutinise all aspects of policy that might affect climate change irrespective of whether the issue under consideration falls within the remit of the DOE.

Annex One

Landscape-scale principles for Northern Ireland

Northern Ireland has a highly fragmented landscape and likely rates of climate change threaten the survival of its natural world. Accordingly the Woodland Trust expects the application of landscape-scale principles to allow the widest range of species to move, survive and evolve in the face of climate change. This could involve:

• Conserving those species believed to be fundamental to wildlife habitats; and using individual species to promote wider protection, restoration and creation of wildlife habitats.
• Affording absolute legislative protection to all ancient and long-established woodland and ancient trees and other habitats in the NI Biodiversity Action Plan, and recognising this resource as the foundation for the restoration the province’s fragmented landscape.
• Restoring all ancient woodland, in both Forest Service and private ownership, previously planted with non-native conifers and also other NI Biodiversity Action Plan open habitat previously planted with conifers.
• Creating new habitats, including native woodland, where wildlife is best placed to survive. In practice this could involve creating new habitat where ancient woodland and other semi-natural habitat is already in abundance.
• Implementing habitat creation to buffer ancient and long-established woodland from negative land-use.
• Ensuring that the wider countryside is managed sustainably in order that wildlife can easily move across it. Climatic uncertainty dictates that it is not sufficient to simply physically link existing habitats.
• Demonstrating the benefits that society derives from a healthy natural environment. These include improved air and soil quality, flood alleviation, high quality food and timber, improved public health and opportunities for recreation and employment. As an exemplar, wooded habitats should be protected and expanded where it offers benefit in regard to either public amenity or wildlife conservation.

For more information, please contact:

Lee Bruce at LeeBruce@woodlandtrust.org.uk 08452 935 551

Woodland Trust, 1 Dufferin Court, Dufferin Avenue, Bangor, County Down, BT20 3BX

www.woodland-trust.org.uk/campaigns

Footnotes

(1) See Annex One, Landscape scale principles for Northern Ireland.

(2) Northern Ireland Assembly, Written Answer, ref AQW 1851/09 (7 November 2008) http://archive.niassembly.gov.uk/qanda/2007mandate/writtenans/2008/081107.htm

(3) Pavan Sukhdev, The Economics of Ecosystems and Biodiversity (2008).

(4) Government of Ireland, The Economic and Social Aspects of Biodiversity Benefits and Costs in Ireland (2008).

(5) Sukhdev, The Economics of Ecosystems and Biodiversity, p. 14.

(6) Northern Ireland Green NGOs Group and the Environment and Heritage Service of Northern Ireland, The Environmental Economy of Northern Ireland (April 2007), p. 48.

(7) Woodland Trust, The cost of restoring plantations on ancient woodland sites – an analysis of the economics of future management options.

(8) Northern Ireland Assembly, Written Answer, ref AQW 2962/2 (1 February 2008) http://archive.niassembly.gov.uk/qanda/2007mandate/writtenans/080201.htm

(9) Northern Ireland Assembly, Official Report (4 November 2008), http://archive.niassembly.gov.uk/record/reports2008/081104.htm#6