visitors since Wednesday, May 31, 2000 02:28 PM
A Critique of the Draft Scottish Forestry Strategy

By Ed Iglehart
The author is a long-time resident of the most forested area of Scotland, a member of many conservation organisations, Secretary of Southwest Community Woodlands Trust, a member of the Dalbeattie Forest Community Partnership, and is currently enrolled on the MSc in Human Ecology programme at the Centre for Human Ecology in Edinburgh. Although the observations and comments in the critique which follows are those of the author, they reflect the result of discussions in many fora with many interested parties and colleagues.


In Scotland, one acre in six is busy growing trees, and as a result, one Scot in five hundred has a job. Here in Kirkcudbrightshire, the most densely forested part of Britain, one acre in three provides about one job in fifty. Nationally, timber production is expected to double in the next fifteen years, so the Forestry Commission have been working on a strategy for dealing with this bonanza. More than a year's consultation has produced a draft which is the subject of this critique. It is notable that, although every effort has been made to 'consult' widely, there has been no detectable wide consultation concerning the "agreed economic objectives." As no effort is made to clarify what is meant by "the economy" we must assume the usual proxy, GNP, which counts as positive ALL economic activity.

To one acquainted (sadly) with government documents, the pattern of the draft will be familiar: The principle of sustainability is first invoked as central to the Strategy. Then a series of arguments in support of capital-intensive practices is followed by an earnest acknowledgement of the desirability of employment and other social and environmental benefits. The implication is clear and patently absurd: The expansion in mechanisation (minimising manpower) is assumed necessary to economic development which, if we are fortunate, may allow us to employ a few more people and ameliorate the accumulating environmental damage.

The environmental and social sentiments in the draft are all (or most) quite commendable, but they're mostly window dressing. In almost every case, economic limitations are explicit:

"Thus, at the heart of the Strategy [but third in a list] there must be a strategic direction: - to ensure that forestry in Scotland makes a positive contribution to the environment. ...This must recognise the need to ensure that Scotland's trees, woods and forests are located and managed for long term sustainability and biodiversity in order to make the maximum contribution to the environment consistent with agreed economic objectives."

This statement cannot be criticised as vague. The opening and body are welcome in acknowledging that sustainability is in fact a very long-term concept dependent upon biodiversity, but the sting is in the tail. It is clearly a declaration that environmental considerations are subservient to economic objectives. This embodies the persistent fallacy that the economy contains the environment and that environmental matters are only addressable insofar as they are economically feasible. The reverse is true. The statement is not vague; it's just plain wrong-headed.

"Rather than presenting quick answers, as technocratic culture tends to do, we need to reflect on whether or not we are asking the right questions...[or whether] ...people ‘participate’ in a project without having to decide on the critical issues related to that project."                  -- Pablo Leal

"agreed economic objectives" are referred to, but what is conspicuously absent from the entire strategy is any explicit statement of these objectives. There are numerous occurrences of the term "competitiveness", which is plainly being used as code for the need to keep manpower costs at a minimum, inexorably driving the machine/man ratio higher with the concomitant increase in fossil fuel expenditure and CO2 emissions. This, of course, runs directly counter to the environmental and social objectives lower down the priorities. The strategy as presented in the draft will do very little to further the stated overarching principle of sustainability. If the priority of competitiveness is allowed to stand, it will be a great opportunity missed. Machines will continue to replace humans. Is this why the Nation has forests? To grow subsidised toilet paper?

Introductory Comments

Although it claims as a first principle that "Scottish forestry must contribute positively to sustainable rural development," the more one examines the draft strategy, the more one is troubled by the way it seems to subsume everything under the need for competitiveness through mechanisation, which so far as I can tell, is not a desirable or even an achievable goal within the "global market", any more than we can make our industrial farming 'competitive', no matter what the level of subsidy, or how efficiently we reduce manpower. None of this has anything to do with sustainable rural development.

Worse yet, in pursuit of this illusory competitivity, further large amounts of public money (several million pounds per year) will be required for the infrastructure "improvements" needed so that the heaviest lorries in Europe can use the forests as a drive-through. Heavily mechanised operators are the only beneficiaries of such 'improvements', as these roads are already fully satisfactory for all other uses.

According to the industry's own code of practice, a single 38 tonne vehicle damages a road as much as 12,000 2 tonne vans. Lowering weight limits by as little as 10% would reduce damage by one third; a 20% reduction in permitted weight results in almost 60% less damage and lowering the limit to one half would reduce damage by fully 94%. These reductions could improve competitiveness by reducing the cost of providing suitable forest roads. Employment in haulage using 20 tonne lorries would be approximately doubled, potentially to the benefit of local communities. but the Draft Strategists have already decided :"The alternative - of weight restrictions on rural roads - will increase timber haulage costs, reducing competitiveness." Such competitiveness, it implies will have to be maintained by externalising the costs of upgrading rural roads.

It's worth noting that the strategy is being developed and promulgated in the context of a turf war involving FC, SNH, SEPA and Local Authorities. All of course, are agencies of the Scottish Executive. The Scottish Parliament's role is passed over with minimal mention, and it's very clear that from within the dominant role of the Executive, the Commission (and their industrial and landowning constituency) intend to be thoroughly in the driving seat (literally!), as they have been in the preparation of the strategy, being five out of fifteen of the working party including chair and secretary, supplemented by three more from Rural Affairs. SNH and the others each having one apiece.

The summary of "priorities for action" places the economic objectives right at the top, in case there was any doubt.
The ranking of these objectives cannot be accidental and plainly demonstrates the central priority of economic competitivity according to "agreed economic objectives" which have notably NOT been the subject of any of the consultative procedures.


The following detailed critique is arranged in the form of a dialogue, using
quotations from the Draft Strategy in blue and responses in green. There is a good deal of repetition of argument in the Draft Strategy, and some effort has been made to restrict such repetition in responses, but it has not always been possible.


The overarching principle for the Strategy is sustainability. Scottish forestry must contribute positively to sustainable rural development, and meet internationally recognised standards of sustainable forest management. The other principles are:
integration: forestry should fit well with other rural activities in Scotland, such as agriculture,         conservation, deer management, fishing, recreation and tourism;
positive value: forests and woodlands should contribute to the well being of the people of Scotland;
community support: forests and woodlands should be managed in ways which enjoy broad public         support;
diversity and local distinctiveness: different types of forest will suit different places.

With the single exception of the opening statement above, the essence of the strategy proposed is clear from the pattern of presentation which is repeated throughout the draft document: A series of arguments in support of capital-intensive practices followed by the desirability of employment and other social and environmental benefits. The implication is clear and patently absurd: The expansion in mechanisation (minimising manpower) is assumed necessary to economic development which, if we are fortunate, may allow us to employ a few more people and ameliorate the accumulating environmental damage. The following from executive summary is typical:

"...Timber production will double over the next fifteen years. The Strategy explains how the forest and woodland resource can be developed to realise the vision, using forestry to:
contribute to the economy;"

As no effort is made to clarify what is meant by "the economy" we must assume the usual proxy, GNP, which counts as positive ALL economic activity. Included in GNP is activity which damages the environment as well as the cost of repairing said damage, cleanup of spillage, destruction of rural character through the building of heavy-duty roads, bypasses, etc. For example, a road accident, by creating employment for ambulances, medical facilities, and panel-beaters, etc. is just as valuable to "the economy" as the same amount of economic activity generated by any other practice.

conserve and improve the environment;

If this is to be taken literally, it will be necessary to consider very carefully how forestry activities are carried out, and in particular, whether this might legitimately require restrictions on the scale of machinery and equipment employed as well as the scale of operations in any particular area, even where this may add to costs. There is little evidence that this is recognised.

enhance the quality of life of all communities.

The same observations apply here, but with regard to the true quality of life, including opportunities for employment as well as protection from intrusive or dangerous heavy traffic which may be unsuited to the rural road system. In the body of the Draft Strategy the presumption in favour of re-making or upgrading the infrastructure to fit the maximum scale of machinery available as opposed to designing operations to fit within existing infrastructure is exceedingly apparent. The underlying justification for this presumption is that the forestry industry must be "competitive," and the primacy of this objective becomes increasingly apparent as the draft strategy develops. Such competitiveness can only be achieved, it would seem, if maximised mechanisation is subsidised and reinforced by externalising the cost of public infrastructure improvements and subsidising the use of alternatives such as rail and water.

"The interaction between these themes is important... There may be local concerns about the impact of timber traffic,...or where the economic benefits of forestry do not remain within the community."

These concerns are not merely a possibility. They already exist, are widespread, and are a major problem which is unlikely to diminish, so long as the requirement of competitiveness through maximum mechanisation is paramount.

"The cumulative impact of forestry expansion on other land uses is also a source of tension in some parts of Scotland. Another tension is the issue of paying for the cost of providing environmental and other "non-market" benefits."

"The Strategy proposes five Strategic Directions for Scottish forestry. They are:
to maximise the value to the Scottish economy of the wood resource becoming available for harvesting over the next 20 years;"

Thus, the top strategic priority refers, as noted above, to GNP. And the second strategic priority:

" to create a diverse forest resource of high quality that will contribute to the economic needs of Scotland throughout the 21st century and beyond;"

And then

" to ensure that forestry in Scotland makes a positive contribution to the environment;
" to create opportunities for more people to enjoy trees, woods and forests in Scotland;
" to help communities use woods and forests to promote development."

Two economic aims followed by three laudable but somewhat vague environmental/social aims.

That the proposed national strategy for Scottish Forestry in the coming century is to be ruled by the increasingly discredited economic assumptions which have led to major environmental destruction on a global scale is implicit in the "Priorities for Action." Top of the list is competitiveness, a codeword for maximising machine use (investment) and minimising manpower use (employment):

"Maximising Value (MV1): Improve competitiveness "by developing a strong forest industries network."
- Because many industry challenges are best resolved through developing a culture of collaborative working.
- Because costs of (for example) harvesting and haulage are lower in other (competing) countries and there is a need to ensure that the Scottish industry can compete internationally.
- Increased contribution to the Scottish economy."
" - Easier for wood processing industry to compete in the international market-place."
" - More investment"
(in machinery!)
"- More jobs."
(last in the list and highly unlikely if competitiveness is the priority!)
- Collaborative working in new and better ways.
- Investment in state of the art equipment."
- Investment in training. ..." (machine minders and operators)

"Maximising Value (MV2): Secure investment in wood processing.
- Because of the need to find high value markets for increased production of timber
coming on-stream over next 15-20 years.
- Increased contribution to Scottish economy.
" - Employment."

Maximising Value (MV3): Develop the timber transport infrastructure.
Because of problems associated with:
- Heavy vehicles on weak public roads.
- Opportunities for sea/rail transport under-used.
- Lorries going through villages and small towns.
- Increased timber production.
- Access to forests for larger lorries,"
(The only beneficiaries)
"..reducing cost of transport."
(and reducing potential employment. This is only achievable by externalising the cost, local authorities being expected to provide upgraded public roads from public funds.)
" - Reduce vehicle movements on roads where sea or rail transport is a viable alternative."
" - Improving rural road network for other uses."
(It is more than adequate for 'other uses' already.)
" - Reduced haulage costs improve competitiveness."

(AGAIN, this is code for reducing use of human beings!)
"- The costs of infrastructure improvement is potentially high (several million pounds per year) but resources are extremely tight making it all the more necessary to ensure good value for money from expenditure. The alternative - of weight restrictions on rural roads - will increase timber haulage costs, reducing competitiveness.

This is the first (and only) acknowledgement that there may be any alternative approach, and it is dismissed out of hand because it would increase timber haulage costs (so long as the costs of road-building and maintenance are excluded from the calculation). In fact, effective weight restrictions might well reduce build and repair costs for forest roads as well as for public roads.

The strategy then goes on to describe the "vision" for a new Scotland, renowned as a place of fine trees and better living and working conditions by:
"promoting sustainable economic growth,
Many would argue the terms are mutually contradictive. Sustained growth is by definition exponential and therefore analogous to cancer - exploitative and therefore incompatible with Nature's form of economy.
"taking advantage of Scotland's competitive advantages in terms of resources and infrastructure;"
which has been described above as inadequate and in need of "improvement!"
"enhancing the environment, enriching and extending important woodland habitats and creating attractive landscapes in both town and country;"
"helping to create a more inclusive society, offering opportunities for employment"
(as a last resort, where machines cannot be substituted!)
"- particularly in rural areas - and providing "lungs" for major cities and towns."

"The purpose of the Strategy is to realise these aspirations."

The suitability of Scotland for growing trees is well known, and tree cover has increased in the last century to the present level of 16% of land area, This is still less than half the EU average of 33%, although in the most afforested area (the Stewartry of Kirkcudbright) roughly one third of the land is forested. Over the last two decades there has been an encouraging increase in the proportion of native and broadleaf species in new planting. The draft notes this favourable trend and proceeds to further develop the strategy, starting of course with the contribution to the
money economy, GNP. It isn't long before we are informed that:

"2.2.7 Some rural public roads used by timber lorries were very lightly constructed and are consequently unable to withstand many movements by heavy traffic such as timber lorries. In places, these roads may only need minor upgrading, but others may require substantial improvement works (including bridge strengthening). A number of local authorities have said that they need additional financial support to carry out this work."

Authorities should also consider whether there is a "net benefit" to the locality - That's their function as guardians of the public interest! The present road system in rural areas is already fully suitable for present uses. Any "improvement" required by heavier traffic is purely for the benefit of a single interest group (suppliers and owners of heavy machinery), reduces manpower requirements, and arguably degrades the locality for other users. Load limits on rural roads would reduce the need for costly engineering work on the public roads and to some extent within the forests themselves. This would encourage the employment of more manpower in transportation, the cost of which might be less than the savings from roadworks. When the forests began to be planted, one of the aims was "to arrest the drift from the land". This was in horse-drawn days, and if it was worthwhile then, it is certainly no less so now.

"The forestry industry, supported by the Forestry Commission, considers that the use of public roads by timber
lorries is a legitimate use of public roads by a permanent rural industry."

This statement seems to be an attempt to argue that it is incumbent on public finance to provide the infrastructure without regard to appropriate scale. Using the biggest machinery available means not being in one area very long, and thus can hardly be classed as a 'permanent rural industry' from a local viewpoint. There is scant attention given to any attempt to make the machinery fit the place. It is assumed that if there are huge machines available, it is a "legitimate use," and the roads and countryside must be made to accommodate them. Elsewhere the strategy makes great play of the idea of forests which are appropriate to local conditions, but this principle, if it is such, doesn't seem to apply to transport. Using smaller lorries and machines employs more folk, but the entire strategy is founded on "competitiveness" and the concomitant (but never explicitly admitted) minimisation of employment.

"The forestry industry has nevertheless taken a pragmatic view wherever possible, working with local authorities to identify preferred haulage routes, alternative routes - off public roads - through adjoining forests where these are possible, and elsewhere identifying the priority roads for improvement. In 1998 the industry worked with other stakeholders to produce a Code of Practice for Road Haulage of Round Timber. This draws together and promotes best practice and has been widely implemented by forest managers and hauliers."

Referring to the aforementioned code of practice is very illuminating:

"The normal method of designing roads is to express the design capacity as millions of standard axles, where a standard axle is 8,200 kg- A motorway, for example, may be designed to carry 50 million standard axles, while a forest road could be designed for 0.5 million standard axles. The road will suffer a small deterioration from each axle which passes over it, eventually failing-

"If vehicles are overloaded this process is accelerated. Studies over many years have shown that the damage caused is proportional to the fourth power of the weight. For example a single 38,000 kg gross vehicle will have the same effect as 12,000 2,000 kg- vans. Overloading of a 38,000 kg gross weight vehicle by a small amount can have a major effect on the incidence of damage and the expense of maintaining the road.;"

Under these principles, lowering weight limits by as little as 10% would reduce damage by one third; a 20% reduction in permitted weight results in almost 60% less damage and lowering the limit by one half will reduce damage by fully 94%. These reductions could improve competitiveness by reducing the cost of providing suitable forest roads. Employment in haulage using 20 tonne lorries would be approximately doubled, potentially to the benefit of local communities.

However, as previously noted, the Draft Strategists have already decided :

"The costs of infrastructure improvement is potentially high (several million pounds per year) but resources are extremely tight making it all the more necessary to ensure good value for money from expenditure. The alternative - of weight restrictions on rural roads - will increase timber haulage costs, reducing competitiveness."

and therefore the option of weight restrictions is dismissed out of hand in its first (and only) mention in the strategy paper. Referring again to the code of practice:

"Main forest roads should be designed on the assumption that the maximum gross vehicle weight permitted within the forest is 38.000 kg ( in 1999, this will be amended upwards). There is a need to ensure that forest roads open to haulage traffic are capable of sustaining the loads imparted by the vehicles using the road. Excess loads either on the axle or gross weight cause damage to the road."

This implies the presumption that the public roads leading to the internal forest road network will be upgraded to support the maximum gross vehicle weight allowed on motorways, local authorities providing such upgrades at public expense. Another illuminating comment from the code of practice:

"The Road Traffic Act accepts extenuating circumstances for overload, such as weighbridge or weighing device error or snow or rain. Under no circumstances should payments be made for an excess greater than one tonne (or in cases of smaller vehicles 5% of the Gross Vehicle Weight)."

It would appear that operators may at times reward drivers for overloading lorries, and the above recommendation in the (voluntary) code attempts to limit the level of this practice. A more rigorous approach might impose financial penalties for malpractice instead of simply limiting its rewards.

2.2.8 A number of groups [are] analysing the likely impact on public roads; identifying where the use of new internal forest roads might remove traffic from vulnerable public roads; establishing the potential use of the rail network and sea transport.

This all sounds very commendable, but it would seem to be an underlying assumption that the problem is to find the most "efficient" method of providing access for the heaviest equipment. No doubt, the fora are dominated by business operators chiefly concerned with "competitiveness", and therefore anything which increases the metal/man ratio is to be preferred. This is certainly an inference easily drawn from a quick glance at the advertising incorporated in the code of practice.

2.2.9 Clearly, rail and sea transport both offer important opportunities for taking timber and forest products off the roads, which currently carry about 95% of the traffic. Rail and sea transport would mainly take traffic off more major roads. There are a number of important requirements:
- the timber must be brought to a suitable rail or sea loading point (usually by lorry) and may need to be stacked there awaiting a train, ship or barge;
- for rail transport, there must be adequate track capability;
- the operation must make commercial sense for the companies involved, taking account (for example) of costs of extra handling
(employment) and the increasing need to offer a "just in time" service to downstream customers; and
- specialised wagons and loading facilities may be required - and the volume of business must justify investment in such equipment.

To encourage freight transport by rail, the Scottish Executive currently offers assistance through the Freight Facilities Grant. This Grant is also available for inland waterways and it is intended to extend eligibility to Coastal and Short Sea Shipping. There is also a Track Access Grant to encourage transfer of freight from road to rail where this is justified in terms of environmental benefits.

This is a good approach, and the environmental benefits could be substantial. It would not, of necessity, require to be serviced by large lorries, and rail and water transport offer reduced "greenhouse gas" emissions when compared to roads.

2.2.10 Major new capital investments..."

Yet another appeal to the false God of "Inward Investment" will save us all! Why don't we ask BMW if they've got any spare cash. Capital investment, as noted above, is essentially directed towards "efficiency" and "competitiveness," and thus heavily favours machinery over manpower

2.2.11 "In recent years, pruning has often been neglected because of the high labour cost," (employment again!) particularly if undertaken on a large scale; it can, however, provide an opportunity for woodland owners prepared to take a long-term to add value to their trees for specialist markets.

This is an important potential source of low-grade and seasonal employment, and can increase direct local involvement with the forests, particularly where efforts are made to employ workers from the immediate locality.

2.2.13 "Product innovation is also important. The technology of engineered wood products provides a way of meeting the construction industry's need for building materials whose properties can be accurately predicted and modelled. (There is already one plant in Scotland making use of this new technology.)...Continued product innovation is also a feature of the panelboard industry."

"This is the big-money, large-scale corporate version. It involves the building of a large factory in a forested region, predictably accompanied by political advertisements about "job creation" and "improving the local economy." This factory, instead of sawing trees into boards, will reduce them to pulp for making paper, or it will grind or shred them and make boards or prefabricated architectural components by gluing together the resulting chips or strands.

"Obviously, there are some advantages to these methods. Pulping or shredding can certainly use more of a tree than, say, a conventional sawmill. The laminated-strand process can make good building material out of low-quality trees. And there is no denying our society's need for paper and for building materials. But from the point of view of either the forest or the local human community, there are also a number of problems associated with this kind of operation.

"The fundamental problem is that it is costly and large in scale. It is therefore beyond the reach of small rural communities and so will be run inevitably for the benefit not of the local people but of absentee investors. And because of its cost and size, a large wood-products factory establishes in the local forest an enormous appetite for trees.

"The very efficiency of a shredding mill-its ability to use small or low-quality trees-necessarily predisposes it to clear-cutting rather than to selective and sustained production. And a well-known inclination of such industries is toward forest monocultures, which do not have the ecological stability of natural forests."
-- Wendell Berry, "Conserving Forest Communities" in Another Turn of the Crank, 1995

Long-term wood supply and demand forecasts are of necessity speculative, but there is little doubt that more forest cover in Scotland, at least up to the EU level of 33% would be of overall benefit for a number of reasons, including import substitution, employment in rural areas (assuming more enlightened approaches to capital intensity) and amelioration of climate change through carbon burial (particularly where rotations are lengthened). Increases in diversity of species and age structure can improve the resilience of forest ecosystems and provide visitors to forests with higher quality experiences. The trend toward increased proportions of broadleaf and native species should be encouraged for the same reasons. That
"Scotland will shortly be a net exporter of wood products," is good news, but we must be aware of the "cash crop" trap. Maximum use of home-grown timber must be encouraged, and exports should be of products with maximum added value.

Niche markets for quality products and non-timber sources of income can provide opportunities for diversified and small scale local enterprise and developments in this direction should continue to be encouraged. Tourism is a mixed blessing, providing employment and other revenues, but also generating increases in CO2 emissions. It is more likely that visitors will enjoy rural areas if the natural heritage features including forest and woodland areas are well cared for, and there are employment benefits involved in the development of access and interpretation, field and nature studies and other outdoor activities.

"In a windy country like Scotland, shelter can clearly have a value, protecting crops and livestock as well as sheltering houses.
"Woods and forests can also provide significant support to the agricultural sector by providing opportunities to farmers to reduce dependence on production and diversify into non-food production

2.2.29 "Some former planting, cultivation and roading practices were detrimental to fishing. These problems - including acidification effects - are now recognised and largely understood,
(so we are asked to believe ) and are avoided in new forests, or where existing forests are felled and replanted. Indeed, carefully designed woodlands alongside rivers can benefit fishing. (An opportunity rightly identified!)

Conserving and improving the environment
Climate change

2.3.1 Climate change is a matter of global concern and the world's forests make an important contribution to storing and recycling carbon.
Scotland's forests are, of course, very small in global terms, but they do have a role in the future options for managing Scotland's net carbon dioxide emissions. (see comments under 2.3.4) Carbon is not only stored in the stem of the trees, but also in the soil, in deadwood and in all other components of the active ecosystem. Clear felling virtually destroys the "active ecosystem".

2.3.2 Scotland's soils also represent an important part of the carbon store. While new forestry planting on mineral sites will help lock up carbon, this does not apply on organic soils if the net effect (over what timescale?) (for example through the drying out of peat) is to release carbon dioxide. In general however, tree cover tends to improve soils by increasing the amount of organic matter in them, and by developing better soil structure down to greater depth. e.g. long-term burial of Carbon.

2.3.3 Under the 1997 International Kyoto Protocol and EU agreements, by 2008-2012 the UK must reduce its 1990 baseline emission of six greenhouse gases by 12.5 per cent. The Scottish Executive have agreed to join in a programme to move the UK as a whole towards the domestic goal of a 20 per cent reduction in carbon dioxide emissions by 2010.

These projections do not agree with those included in the recent document:
Greenhouse Gas emissions % change expected as result of policy action 1990-2010
Energy Sector -18%
Business -14%
Transport +8%        (implies an underlying acceptance of continued growth of transport!)
Public Sector -10%
Agriculture, forestry and land use -15%
TOTAL CHANGE -10% of which CO2 -3%

This goal will be achieved largely through cutting emissions, but increasing forest cover could help meet targets through associated reduction in carbon dioxide concentrations. The exact basis for accounting for forestry's contribution under the Kyoto Protocol is not yet clear, but forests planted before 1990 are unlikely to count.

2.3.4 Some estimates suggest that, on an annual basis, Scotland's forests absorb 10 per cent of the carbon dioxide emissions attributable to Scotland.
(for 16% of the land area? This wants examination.) The role of forests as carbon sinks can best be pursued through sustainable forest management: forests should not be planted with the sole aim of carbon sequestration, without any consideration of other impacts. The greatest sequestration gains are likely to come from forests growing high quality timber (which will be put to long-lived end uses) on long rotations, in complex forest ecosystems with soils of low organic content.

This amounts to an admission that "productive forestry" (the new codeword for short rotation conifer forestry) has virtually no role to play in carbon sequestration, and by inference also that such forestry does not constitute "sustainable forest management" (above).

2.3.5 The increased used of wood as fuel, substituting for burning of fossil fuels, is another measure that could reduce net carbon emissions.

THIS IS PATENTLY ABSURD! Carbon burned is carbon burned; the NET effect is ZERO (ignoring chainsaw fuel and transport)!

Native Woodlands provide the richest and most diverse terrestrial ecological systems. TOO TRUE!
Some suggested long-term targets, for example that by the end of the century about half Scotland's woods and forests should consist of native species.
New native woodlands are especially valuable if they can be located so as to expand and create links between existing native woodlands. There are biodiversity advantages in using natural regeneration wherever possible and in creating new native woodlands on a large scale, preferably as part of a network. Scottish Natural Heritage has produced a series of maps depicting woodland potential to help provide an ecological basis for planning woodland expansion of this sort. The concept of Forest Habitat Networks is to enlarge and reconnect existing woods, thus alleviating the consequences of fragmentation. In this way, species can benefit from reduced isolation and restored connections.

2.3.11 "Habitat Action Plans for upland birch and lowland mixed broadleaves is under consideration."

It would seem by the information provided in the draft strategy that the only expansion of lowland mixed woodland envisaged at present is as wood-pasture. (or the wet and otherwise useless bits) Certainly this needs attention.

2.3.12 The figures in the paragraph don't agree with the tables, or if they do, it is far from clear.

Enhancing the biodiversity of other woods and forests:
2.3.14 "... North American conifers in Scottish forests can be managed to provide levels of biodiversity, including numbers of important key species, that may approach those found in some semi-natural woodlands."

Damned with faint praise! i.e. The best of exotic woodlands can be almost as good as the worst of the semi-natural...!

2.3.15 "High values of woodland biodiversity are generally associated with a high degree of naturalness and variation in woodland structure. The potential of woodlands for biodiversity can best be realised by maintaining or increasing naturalness of composition and structure. Many upland forests were created over a very short timescale and contain little diversity. Improving forest structure and composition is particularly important in these forests. This process, known as "restructuring" or "transformation of plantation forests" is a key element in achieving greater biodiversity within such forests. If benefits from native species are to be optimised it is important to plan this work on a catchment or landscape scale. There is a danger in using rigid targets, such as having to plant 5 per cent broadleaves within every coupe, since this can lead to sub-optimisation of the use of such species. Instead the principles of achieving scale and of creating networks should be adopted. Landscape ecologists sometimes speak of "nodes" and "corridors". Thus, for example, pockets of existing semi-natural woodland can form the basis of "nodes" that can be connected - perhaps along water-courses - to create a network of permanent native woodland and open space within the forest. This, in effect, becomes a matrix within which stands of the main production species are felled and replanted."

This is one of the best paragraphs in the whole strategy! The catchment scale for planning should also include consideration on the scale of "sub-catchments" as in the Local Forest Frameworks exercise.

2.3.16 "Forest managers are making increasing use of silvicultural systems that are based on natural processes, ...By changing the physical structure and age class distribution of forests, biodiversity levels can be increased. Opportunities for this are, however, restricted to more sheltered sites on well-drained soils."

Only if "natural gap-formation" is an absolute No-No!

2.3.17 Forest operations that have low impacts on natural features help to conserve the natural diversity of woodlands. The increasing interest in continuous cover forestry (where this is feasible) is of benefit here. The targeted use of herbicides and the "minimum necessary" use of cultivation and fertilisers are other important examples. These principles are recognised in the UK Forestry Standard, and have been adopted in the voluntary UK Woodland Assurance Scheme Standard.

(How does this play with FSC certification standards?, Herbicides and fertilisers are, by definition, not tools of sustainability.)

2.3.18 The alternative is rigorous culling,(MUST BE DONE!) Too much grazing pressure can prevent regeneration; there may be (IS) a need to manage domestic stock in areas of existing woodland to promote the regeneration and enhancement of woodland and associated flora.

Impact on other habitats and species:
2.3.19 2.3.20 It is important that the expansion of forests and woodlands takes account of these key habitats. The Forestry Commission is publishing guidance indicating when deforestation is likely to be permissible in relation to restoration of peatland habitats.

(Undoing the damage inflicted by earlier well-intentioned but ill-advised planting)

2.3.21 For example, the majority of priority bird species depend on open ground habitats and, for these species, it is forest location rather than forest design which is the critical factor affecting their conservation status.

(open ground is PART of "forest design")

Water, air and soil:
2.3.22 The principle of sustainability requires the maintenance of the quality of soil, water and air resources, as well as vegetation and wildlife. Woodlands generally benefit the physical environment. Good practice and design, as detailed in the UK Forestry Standard, should avoid any damage to these resources.

2.3.23 Such riparian woodlands can also improve habitat quality, preventing bank erosion, providing shade and shelter for fish, and increasing the invertebrate populations.
(totally agree!)

2.3.24 There is evidence to suggest that woodlands may intercept more water than other types of vegetation, and this has been identified as a potential problem, particularly in catchments where water supplies depend upon small residual summer flows.

(usually only a problem on land which has been drained in the past to maximise runoff?)

2.3.25 Climate change is expected to result in more extreme weather patterns in Scotland. This is likely to increase the risks of flooding particularly in the west. It has frequently been demonstrated that urban and agricultural developments within flood plains can lead to disproportionate flood protection costs. Consequently, the land-use planning system now discourages vulnerable developments within flood plains. As a consequence there may be an increasing role for the development of woodlands within flood plains, which can benefit flood control and improve water quality.

(totally agree! Somewhat topical, considering Mozambique.)

2.3.26 By virtue of their deep and rough canopy structure, woodlands tend to intercept more air-borne pollutants than other types of vegetation. This filtering effect can improve local air quality, an outcome that may be of particular benefit around towns and cities. However, in sensitive rural catchments increased interception of acidic pollution can damage soil and watercourses.

This reads like a horoscope! Where might information be found on the relative effects of broadleaves Vs conifers?

2.3.27 The presence of forests can enhance the deposition of acidity by removing acidic particles from the atmosphere more efficiently than open moorland.

This sounds like an advantage or improvement the way it's worded. (exacerbate might be substituted for enhance )

2.3.28 In order to prevent further damage to Scotland's freshwaters... The redesign of existing forest cover as part of the felling and replanting process will play an important role with improvement of water quality and freshwater habitats being a key feature. ... moving coniferous planting away from river banks and planting more native broadleaves... removal of higher elevation forests to provide greatest benefit in reducing scavenging of pollutants. Where would they go otherwise? Somebody else's problem?

2.3.29 "...forestry is not the cause of acidification."

(Methinks you protest too much! Not the cause, but a strong link in the chain of acidification.)

2.3.30 "Research has demonstrated how these ill-effects can largely be avoided by good management practice,

So we are asked to believe, and to hope that practice will follow intent

2.3.31 "Forestry can play a useful role in assisting the recovery of salmon fisheries by addressing some of the environmental problems, such as diffuse agricultural pollution and acidification, which have contributed to this decline."

Having had a part in the causes, there is an obligation not only to discontinue the harmful practices (including sloppy road-building) but also to contribute positively to ameliorative efforts.

2.3.32 On certain sites forests can reverse soil degradation. This is particularly true where trees are planted on reclamation sites.

(Totally agree, and on other sites. Forests are the main source of the fertility utilised (and depleted) by agriculture over thousands of generations!)

2.3.33 " is important to plan on a catchment" (or sub-catchment) "or landscape scale. ...targeting expansion of native woodlands to fit in with Forest Habitat networks, for example using riparian woodlands to create strategic linkages between core areas of native woodland."

It is important to avoid too large an overall unit, as intimacy and appreciation of local diversity decreases in proportion to overall scale of projects and leads inexorably to a "top down" centralist approach. The network concept is an example of a valid use of top-down thinking, but will only work in conjunction with local intimacy.

The wider landscape:
2.3.34 "..Sometimes it is the loss of a favourite view"
(and sometimes the opportunity for opening a new view arises!) "...enabling the changing forest to become a permanent - though dynamic - feature within the local landscape." (Agreed!)

2.3.35 "Scottish Natural Heritage's Landscape Character Assessments should be valuable in helping to plan for landscape improvement."

They will indeed be valuable if local forest frameworks are encouraged. The LFF exercise has been exemplary in the level of participative workshops, the thorough examination of baseline data and considerations of the impacts on the natural heritage in general. The hand of Scottish Natural Heritage is clearly evident, and local folks' concerns have mostly been well answered. More of this sort of fine-grained treatment with increasing local empowerment would be a hopeful sign, but it is only a 'pilot' exercise, and it has cost considerable money, as a senior council official informed me.

2.3.36 "The design of new forests and woodlands needs to respect the local landscape character..." Agreed

Improving the setting of towns and cities

2.3.37 & 2.3.38 "Like other environmental programmes this can have a profound effect on the quality of life of people who live in surrounding communities and help make the area more attractive for new economic development."

These comments also apply to quite small towns and settlements. The thinking should not be restricted to the larger urban expanses.

Archaeological features:
2.3.39 "Land use change needs to be informed by an understanding of heritage values as well as an understanding of landscape character. Scheduled Ancient Monuments and their settings are protected by law."

This is particularly topical, considering the present application under consideration in Eskdalemuir! Such matters should not have to be an occasion for marshalling opposing forces to prevent attempts to subvert the spirit of environmental considerations!

2.3.40 "...there are large areas of landscape that can tell their own story is important to safeguard this historical evidence." (totally Agreed!)

Enhancing the quality of life of all communities: Community aspirations:
2.4.1 "There are communities that want to become more actively involved in the management and perhaps, ownership of their local forests; others do not want this degree of involvement but do want to be consulted about plans and proposals.

Communities should be in the driving seat where woodlands are in the immediate vicinity! In the case of public land, the involvement of neighbouring communities offers the best likelihood of maximising overall public benefit - surely the highest priority and the chief justification for public ownership.

"Transport infrastructure [must] be considered alongside any expansion ... why on earth did they not think about how they were going to get the timber out when it was planted"

They did! It was intended that horses would be adequate, and they still could be, if we were to place humans above machines for a change! Again the assumption that infrastructure must or should be restructured to accommodate the largest machinery available surfaces. The alternative of considering how to adjust method to existing infrastructure must be considered together with the aim of "arresting the drift from the land" which was one of the founding justifications for encouraging the expansion of forestry. Alternative methods of getting the timber out are virtually certain to provide far more employment in rural areas than the capital-intensive methods assumed throughout the draft strategy.

2.4.2 ...Recreation in forests and woodlands can make a positive contribution to the health of communities. 2.4.3 ... All Forestry Commission land is open to the public and it contains a very wide range of facilities....a general right of responsible access to all land in Scotland, 2.4.4 "Community Woodland Supplement , ranger services 2.4.5 & 2.4.6 clear need to widen opportunities for woodland access especially by bringing woodland nearer to people, as well as by ensuring that people know what is available."

Every community should have its forest, integrating the educational potential with participation, recreational and interpretive development. The employment of community rangers in some areas is a welcome initiative.

2.4.7 "...the vision for the Strategy is one of creating a more inclusive society, particularly by developing employment opportunities in remoter rural areas."

This is an excellent sentiment, and it may be genuine, but it is immediately rendered meaningless:

2.4.8 "An inevitable trend over the last half-century has been the mechanisation of forest operations and the increased costs of labour. These have been highly desirable developments, leading to higher living standards and better quality jobs, as axe and saw have given way to chainsaw and then harvesting machine. It has, however, had an impact on forestry employment patterns. Although 80 per cent of the forest workforce still live within 20 miles of their workplace, far fewer employees live in the woods where they spend most of their working life. The corollary to this is that villages that a generation ago were inhabited by large numbers of people working in local forests may now have only one or two (or maybe none at all).

"Eventually this mechanistic line of thought brings us to the doctrine that whatever happens is inevitable. Actually, this stark determinism is altered in general use to a doctrine that is even more contemptible. Every bad thing that happens is inevitable. For every good thing that happens there are mobs of claimers of credit. Every good and perfect gift comes from politicians, scientists, researchers, governments, and corporations. Evils, however, are inevitable; there is just no use in trying to choose against them. Thus all industrial comforts and labor saving devices are the result only of human ingenuity and determination (not to mention the charity and altruism that have so conspicuously distinguished the industrial subspecies for the past two centuries), but the consequent pollution, land destruction, and social upheaval have been "inevitable."
-- Wendell Berry, Forward to "The Unsettling of America"

2.4.9 "...Where the choice is one of offering work either to local people using less capital intensive equipment, or to others from further afield using more efficient equipment, there may be a cost penalty attached to providing local employment."

The possible 'cost penalties' of offering work to local people are very likely to be the result of the distorted economic assumptions and hidden (externalised) costs of the machine-intensive current practice.

2.4.10 , 2.4.11 , 2.4.12 2.4.13 All good "community involvement" sentiments, worthy and desirable if not rendered "inevitably" impractical by the need for "competitiveness" or the "efficiency" which means maximum speed of operations as opposed to a pace more suited to providing small, locally based enterprises with the continuity referred to in 2.4.9, above without necessarily requiring heavy capital investment.

2.4.14 "Over the centuries, the drift of people from rural to urban areas, coupled with the general loss of forest cover, has cut the link between people and forests...This is a trend recognised across Europe."
Another inevitability?

2.4.15 & 2.4.16 Agreed on the need for fullest possible development of educational possibilities.

Section 2.5; Interactions; Introduction
2.5.1 "...In some cases the interactions are positive and mutually reinforcing, giving rise to important opportunities; in others they give rise to tensions.

Opportunities: multi-benefit forestry

2.5.2 two - of particular importance - are the recognition of:
- the potential economic contribution of native woodlands;
- the potential conservation contribution of non-native woodlands.(see comment below)

Opportunities: employment and integration with other rural activities

2.5.3 "...complementary activity to farming, ...A number of skills ...readily transferable" 2.5.4 ...diversification opportunities for farmers, ...for niche markets, shooting recreation activities. 2.5.5 Tourism, a forestry strategy must be developed within the wider context of rural development and related land use issues; a viable economy supporting quality jobs and attracting investment in infrastructure, training and capital equipment. 2.5.6 converting farmland to forest or woodland, forestry expansion which is well-integrated with farming, thus retaining local links with the land.

Generally quite good, and, for once, jobs are mentioned before infrastructure and capital.

Opportunities: wood as environmentally friendly raw material
2.5.7 Wood shows up well against other materials

It should be noted that this is on the basis of wood's generally low "embodied energy." The embodied energy increases with intensity of mechanisation, and wood's advantage on this criterion is therefore diminished.

Opportunities: diversity:
2.5.8 "...should reflect the rich diversity and local distinctiveness...planting species to match site will bring long-term economic and environmental benefits; select species that were well suited to their site and to have a range of species within forests and woods. This of course chimes well with the view that ecologically sound forestry is necessary to delivery economic benefits.

The admission that "ecologically sound forestry" is necessary is welcome. It is to be hoped that this awareness will inform decisions about scale of operations, i.e. size of felling coupes, scale and weight of machinery, minimisation of soil disturbance and other collateral damage. Ecologically sound forestry must also necessarily take the long term view, considering the advantages of extending rotations, varying age structure as well as species mix within woodlands, and balance of land use on catchment and sub-catchment scale.

Areas of tension: Local concerns
2.5.9 Benefits...not necessarily...where the trees grow. Large-scale processing compete ...not ...local processing...transported elsewhere...timber traffic, and its impact on local settlements and the rural road network...sense of grievance...amplified if other parts...benefit from downstream employment ...local people do not get the work...available...near their homes.

All these concerns are valid and must be addressed. It is not likely to happen if the emphasis remains on maximum mechanisation and economies of scale.

Areas of tension: impacts on other land uses:
2.5.10 ...people feel that there is already "enough" or "too much" forestry and they do not want any more...loss of heather ground habitat for birds such as the curlew...cumulative impact of successive planting...DGC/FC/SNH [tripartite] Local Forestry Frameworks to address this issue of the balance between land uses. This pilot exercise will categorise some areas as having very limited potential for forestry expansion, effectively ruling out forestry as an alternative to farming on this land.

It is worth noting that as this response is being prepared, an application is being considered which would, if approved, run counter to the expected result of the LFF exercise. This pilot exercise has taken well over a year so far and is not yet in draft form, but the likely outcome for the land which is the subject of the current application will be classification as totally inappropriate for planting. The corporate owner is therefore attempting to beat the process by forcing the application through and collecting substantial subsidy for acting counter to the spirit of the new criteria before they can be adopted. The application has been referred to the top level of the Forestry Commission, which has resulted in that rarest of occasions - an actual site visit, in fact more than one! The issues raised by this situation highlight the desirability of a strategic framework which allows local interests at least the same weight as the interests of distant corporate ownership, whether private or public.

National Parks will also need forestry strategies, or frameworks, as part of their Park Plans. Indicative Forestry Strategies may call for the use of more detailed studies, such as Local Forestry Frameworks,

As noted earlier, the pilot LFF exercise in Dumfries & Galloway has been exemplary in the level of participative workshops, the thorough examination of baseline data and considerations of the impacts on the natural heritage in general. It would be beneficial to extend the approach to other areas. It is important that the catchment/subcatchment approach is maintained and the temptation to 'economise' by increasing the scale or decreasing the depth of consultation and breadth of baseline data is resisted. There is, however, a danger that if it is seen to be subverted or bypassed or dominated by corporate interests, members of the public who have devoted considerable unpaid effort to the exercise may become disillusioned and much good work done to empower local communities may be destroyed.

Conclusions and Strategic Directions (from part two)
2.6.1 Strategic Directions have been identified.
- to maximise the value to the Scottish economy of the wood resource becoming available for harvesting over                 the next 20 years.
- to create a diverse forest resource of high quality that will contribute to the economic needs of Scotland                 throughout the twenty first century and beyond.

As throughout the section, GNP first, and then:

"Thus, at the heart of the Strategy (but third on the list!) there must be a strategic direction:
- to ensure that forestry in Scotland makes a positive contribution to the environment.
"This must recognise the need to ensure that Scotland's trees, woods and forests are located and managed for long term sustainability and biodiversity in order to make the maximum contribution to the environment consistent with agreed economic objectives.

This statement cannot be criticised as vague. The opening and body are welcome in acknowledging that sustainability is in fact a very long-term concept dependent upon biodiversity, but the sting is in the tail. It is clearly a declaration that environmental considerations are subservient to economic objectives. This embodies the persistent fallacy that the economy contains the environment and that environmental matters can only be addressed insofar as they are economically feasible. The reverse is true. The statement is not vague; it's just plain wrong-headed! Two more woolly add-on enhancements follow:

- to create opportunities for more people to enjoy trees, woods and forests in Scotland.
- to help communities use woods and forests to promote development.

These 'strategic directions' generate the priorities for action in section 3:

Maximising Value;
MV1: improve competitiveness by developing a strong forest industries network
MV2: Secure investment
MV3: Develop the timber transport infrastructure
MV4: Promote more use of timber
MV5: Develop products that meet market needs
Future Forest Resource;
FFR1: Expand the area of well-designed productive forest
FFR2: Improve timber quality by following good forest practice
FFR3: Develop forests of mixed species
FFR4: Exploit non-timber outputs and other benefits of woods and forests
FFR5: Tackle deer problems
Positive Contribution to the Environment
PCE1: Improve management of semi-natural woodlands
PCE2: Extend and enhance native woodlands by developing Forest Habitat Networks, especially in         lowland Scotland
PCE3: Increase diversity of the farmed landscape
PCE4: Aid recovery for acidified rivers and lochs and improve riparian habitat
PCE5: Encourage alternatives to clear felling
PCE6: Contribute to a radical improvement in the quality and setting of urban areas
Opportunities to Enjoy Trees, Woods and Forests
ETWF1: Provide woodland recreation opportunities near towns
ETWF2: Improve information about availability of opportunities
ETWF3: Increase forestry's contribution to tourism
Community Benefits
CB1: Create wider employment opportunities
CB2: Increase opportunities for community consultation
CB3: Provide opportunities for greater community involvement in forestry
CB4: Support community ownership where this will bring local benefits

The ranking of these objectives cannot be accidental and plainly demonstrates the central priority of economic competitivity according to "agreed economic objectives" which have notably NOT been the subject of any of the consultative procedures.

Ed Iglehart
Background materials:

Pablo Leal, Participation, Communication and Technology in the Age of the Global Market, in Forests, Trees and People Newsletter No. 40/41:


FAO 1999 Global forest Products Outlook:

Forest product market developments: the outlook for forest product markets to 2010 and the implications for improving management of the global forest estate: (891k)

FA Roundwood Haulage Working Party. (1996). Road Haulage of Round Timber Code of Practice. Forest Contracting Association Ltd. (Tel: 01467 651368).

Langholm/Lockerbie Local Forestry Framework: Working Papers August 1999 and draft Framework documents March 2000;
Dumfries & Galloway Council, Forestry Commission, Scottish Natural Heritage