Chapter 4: Assessing impact
The consultation paper notes that this consultation marks the start of processes to assess the equalities, business and regulatory, privacy and environmental impact of the plans. Respondents were asked to comment on each of these four issues in turn.
Question 11: Are there any likely impacts the proposals contained in this consultation may have on particular groups of people, with reference to the 'protected characteristics' listed above? Please be as specific as possible.
The protected characteristics referred to in Question 11 are: age; disability; gender reassignment; marriage and civil partnership; pregnancy and maternity; race; religion and belief; sex and sexual orientation.
Although 229 respondents answered Question 11, the substantial majority of the answers did not provide further material for analysis, for example because the respondent simply stated 'No' or 'Nothing I can think of'. Only 20 respondents made a substantive comment, and many of these were brief. They included noting that the Scottish Government's policy on equality and diversity is either admirable or acceptable and that bringing FCS and FES under that policy is to be welcomed (Ind, O). However, it was also suggested that FCS and/or FES has a good reputation or is already doing good work in terms of inclusivity (Ind) but that this might be compromised by the changes (Ind).
In terms of areas which should be priorities for future action and/or challenges which need to be addressed, many of the comments focused on increasing employment opportunities and employability. Groups highlighted included:
- Women (Ind, Pu, Pr). Some commented that the forestry sector is traditionally male-dominated and it was suggested that the proposals present an opportunity to strengthen existing initiatives which aim to increase hands-on forestry training for young women (Pu). It was suggested that facilitating women's equal participation in all areas of forestry will provide opportunities to foster higher skills and wages opportunities associated with STEM (Science, Technology, Engineering and Mathematics) programmes (Ind).
- Young people (Pu, Th). It was suggested that there should be systematic engagement with young people in relation to training and employability (Th). It was noted that a gender-balanced approach to apprenticeship and graduate level employment would increase entry of young people into the sector (Pu).
- People from the Black and Minority Ethic community. It was suggested that communities risk being marginalized due to social, cultural and economic barriers and that work should be done to open up routes into employment in the sector (Th).
- People living in populations experiencing multiple deprivation. It was suggested that there should be investment in local forest management to increase employment and training opportunities and promote entrepreneurial development (Th).
Other comments tended to focus on community engagement and/or increasing access to the forest estate (Ind, Th). They included that it will be important to maintain and promote access for all visitors, with particular groups identified including people with a physical disability, people with physical or mental health problems, older people and pregnant women.
Business and regulation
Question 12: Do you think that the proposals contained in this consultation are likely to increase or reduce the costs and burdens placed on any sector? Please be as specific as possible.
A total of 223 respondents answered Question 12. Many of these respondents caveated their answers heavily, or commented on only a restricted element of the proposals, while others made comments on matters beyond the proposals in the consultation paper. It is therefore difficult to draw general conclusions on any balance of opinion beyond the following points:
- The majority of those who took a clear view indicated that they thought the proposals would increase costs and burdens;
- Approximately half as many thought there would not be an increase, or said they could not think of any reasons there would be;
- Some of the respondents who did think costs and burdens would increase thought this was justified in view of the potential benefits;
- Some respondents identified parts of the proposal where they expected costs to increase and areas where they thought savings might be made;
- Some respondents answered on the basis of what they expected in the short term, but stated that the future outcomes depended on how changes were implemented;
- Some respondents indicated that there was insufficient detail in the consultation paper to make an informed judgement;
- Some respondents said they did not know.
Given this ambiguity, the points outlined below are divided simply according to whether they were cited as reasons for thinking costs or burdens would be increased or reduced.
Reasons identified for thinking costs and burdens might/will increase
Many of the comments focused on increased bureaucracy leading to increased costs. In particular, it was suggested that there are likely to be increased costs, including to the forestry industry and the public purse, if current UK functions are duplicated in Scotland or if other cross-border arrangements are put in place (Ind, Pr, Th).
It was also suggested that there would be additional costs associated with a new land management agency and that, if the proposed agency is required to take on large amounts of land that is poor quality, costly and resource-intensive to manage, then the agency will be more costly to run (Ind).
There were also concerns that poor delivery of any new division/agency functions could lead to adverse outcomes for other public and private sector organisations, the forestry industry more widely and/or the Scottish Government. Specific comments included that loss of expertise could slow down the management and monitoring of the Forestry Grants process (Th). It was also suggested that the recent experience of the Welsh Government and Natural Resources Wales demonstrates that the risks of considerably increased costs, fragmentation of skills, and dilution of forestry-specific strategy are very real (Ind).
Other comments focused on the costs of re-branding, given the strength of the Forestry Commission brand and range of branded materials, such as stationery, websites, vehicles, signage, publications and corporate clothing (Ind, Pr).
Other costs or burdens identified included:
- Cost to private contractors. It was suggested that costs and administrative burdens will increase due to the inevitable desire by the Scottish Government to improve environmental, health and safety and other forestry standards (O).
- Impact on local government. Depending on the area-based structures adopted, there may be an increased burden on local government (Ind).
- Cost to public health. Schemes such as 'Woods In and Around Town' offer benefits to public authorities and local communities. If such commitments do not continue, the costs or burdens placed on other sectors would increase proportionately (Ac).
- Potential for third sector burden in terms of limited resources for grant funding and income generation through Scotland's forestry assets (Th).
- Indirect infrastructure costs. It was suggested that the proposals should recognise that 'promoting forestry' will create requirements for transport infrastructure and that the Scottish Government must ensure mechanisms and resources are in place for the modernisation of freight transport infrastructure (O).
Reasons given for thinking costs and burdens will not increase
Reasons given to suggest costs or burdens may not increase included:
- Management and regulation will be simpler (Ac). Restructuring of the NFE and introducing a lighter regulatory system offer opportunities to reduce the costs and burdens. This should be an objective of the restructuring (Ind).
- After the initial costs involved in setting up the new organisation, more revenue should be available to Scotland from forestry management (O).
- Streamlining planting proposals and planting on more accessible land will allow the forest industry to reduce costs and increase competitiveness (Pr).
Question 13: Are there any likely impacts that the proposals contained in this consultation may have upon the privacy of individuals? Please be as specific as possible.
As at Question 11, only a small number of respondents made substantive comments at Question 13. Although 203 respondents answered the question, only around 50 respondents made a comment which informs the analysis  and some these were simply to note that privacy is important, or that it is important to be sensitive to the rights of individuals, be they landowners, resident in or near the forest estate, or visitors to the forest.
A small number of respondents suggested that landowners, and particularly estate owners, may be the group most likely to be affected by, or to feel that their privacy is being compromised by, the proposed changes (Ind, Th).
Other comments tended to focus on information and data-related challenges, such as:
- Providing all transfers of personal information and equipment to any new organisations are handled properly, the proposed changes should not impact on privacy. This transfer of potentially sensitive data was sometimes connected with information held on existing staff of FCS (Ind, O).
- Access to a public register for consulting on tree planting or felling, along with transparency about grant payments, could potentially have an impact on the privacy of those involved (Ind, O).
Question 14: Are there any likely impacts the proposals contained in this consultation may have upon the environment? Please be as specific as possible.
A total of 248 made a comment at Question 14. Of those which directly addressed the question, comments tended to focus on those factors which might have an impact on the environment, be that either positive or negative. However, it was suggested that, without detail on how a new land agency would balance a remit to deliver specific economic, environmental and social outcomes, it is difficult to answer this question fully (Th). Many other respondents were of the view that the outcome will depend on the manner of implementation.
Two general points made were that:
- Since the NFE and other woods and forests cover 20% of Scotland's land area, the potential impact of changes in forestry activities could be significant, and these should be assessed through the Strategic Environmental Assessment ( SEA) process (Ind, O, Pu, Th).
- Key evidence must be collected and be used to guide policy decisions. This requires commitment to collecting appropriate data to inform decision making, and then monitoring the effects of any changes (Ac).
Possible environmental benefits
Respondents who expected neutral or broadly positive environmental outcomes, often pointed to the importance of the better integration of policy and the management principles that should be employed on NFE land.
A small number of respondents made statements concerning the nature of the forest management regime required for positive environmental impacts to be delivered. These included that:
- Commercial forestry, the environment and recreation are not mutually exclusive. Sustainable forestry principles and active management can ensure that multiple objectives are delivered from the same forest (Pu).
- Active management of the forest estate in line with the suggestions contained in this consultation will maintain an appropriate balance (Ind, Pu).
- An environmentally more inclusive and holistic approach to land management as proposed is likely to have balanced, long-term beneficial impacts on the environment (Pu).
A small number of respondents noted the potential for better policy integration with other land uses to deliver a wide range of improved environmental outcomes such as meeting climate change targets, flood mitigation and improving biodiversity (Ac, Ind, Pu).
Possible environmental risks
Respondents were, however, more likely to highlight subjects they saw as posing a risk of a negative environmental impact. Most frequently-noted amongst these were: loss of FCS expertise; increased focus on productivity; and planting trees in inappropriate locations. These are discussed below. It should be noted that there were respondents who made positive comments on these subjects (with the exception of the points on FCS staff), but the balance of opinion was that negative environmental impacts were likely.
A number of respondents identified loss of FCS and/or FES staff expertise as having the potential to cause indirect environmental harm, often through bad decision-making or poor management (Ind, Th). In particular, it was suggested that the potential environmental benefits from adopting the longer-term view might be lost if the existing functions of the FCS are taken into a government department (Th).
A small number of respondents also highlighted the potential impact of an increased focus on productivity. Points made included that:
- A focus on productivity gives cause for concern that environmental objectives would not be met (Ind, O).
- There may be pressure to dispose of unproductive land which, if sold to the private sector, could be managed with less regard for environmental protection (Ind, Th).
A small number of respondents noted their view that restocking and new planting targets are positive, being good for aspects such as carbon sequestration, wildlife and flood mitigation (O, Pr). However, others raised concerns about where such planting might take place and the potential harm that might be caused. Points made by these respondents included that pressure to increase forest area may result in loss of open, upland and/or moorland habitats (Ind, O, Pr, Th). Further points included that:
- This risk extends to the plant, animal and bird species found in these and other priority habitats, in potential conflict with national and local BAPs (Ind, Th).
- Parcels of forestry in otherwise open habitats can act as a reservoir for predator species, leading to increased predation of ground-nesting birds several hundred metres from the forest edge (O).
- Tree planting on peatlands results in loss of sequestered carbon, and there is a concern that the current FCS commitment to Planted Ancient Woodland Site ( PAWS) restoration might be diluted or removed with reorganisation (O, Th).
Other suggestions included that there should be a strategic vision for these habitats to balance the effect of the Forest Strategy (O). It was also suggested that the value of non-statutory wildlife sites (notably local authority Sites of Importance for Nature Conservation or similar designation, and/or Scottish Wildlife Trust Wildlife Sites) should be recognised with a presumption against planting (Ind).
Alternative views expressed included that re-afforestation of upland areas would be beneficial (Ind) or that growing more trees will present an opportunity to reduce reliance on imported timber (Ind, Pr).
A small number of respondents commented on the potential for negative impacts to arise in circumstances where the provision for flexible use of NFE land is used for purposes that are not tree-related. This tended to be associated with the development of windfarms (Ind, Th). Further points made included that:
- There is a danger that bio-energy and wind-energy projects may increase deforestation, unless specific checks and balances are in place (Th).
- The deforestation and loss of peat that has already occurred in Scotland to facilitate wind energy production, is a vast loss of a natural, irreplaceable, major carbon store (Ind).
It was also suggested that any type of building work or installation of major recreational infrastructure could potentially impact on wildlife, habitats and protected sites. There was a call for strong regulations for assessing potential environmental impact and that, if land is sold or given to community groups, safeguards should be in place to ensure they use that resource sustainably and without risk to the environment (Ind).
Respondents also commented in smaller numbers on a range of other subjects where they could foresee a risk of an adverse environmental impact. These included:
- Felling and specifically on felling targets. It was suggested that clear-felling results in environmental damage and that a better alternative would be the implementation of a model where trees are harvested selectively (Ind).
- Restocking targets. Enforcement of restocking targets was welcomed as enhancing carbon sequestration and thus having positive environmental impacts (Pr). However, it was suggested that some trees have been planted where they should not have been, and past errors should be corrected not repeated (Ind, Th).
- Tree health, pests and diseases. It was noted that unless cross-border co-operation remains effective for plant health issues, any cuts to research funding could adversely affect ability to control pests and diseases (Th). It was also suggested that new introductions should be minimised through the implementation of adequate plant and phytosanitary policies (Ind, Pr).
- Environmental assessments. A small number of respondents questioned the value of EIAs and SEAs for small scale developments, suggesting these processes do not give enough recognition to important local sites and species, and it was also suggested that even small scale planning applications should have to include analysis of forestry issues (Ind).
- Generation of waste materials through rebranding. It was suggested that there would be negative environmental impacts associated with waste materials generated by re-branding of the Forestry Commission (Ind).