ACAN together with the Construction Declares Steering Group have been working on a response for DEFRA’s new England Tree Strategy consultation.
“This consultation will inform a new England Tree Strategy which we will publish later this year. The strategy will set out policy priorities to deliver our ambitious tree planting programme. It will focus on expanding, protecting and improving our woodlands, and how trees and woodlands can connect people to nature, support the economy, combat climate change and recover biodiversity. This will ensure that trees are established and managed for the many benefits they provide for people, the economy, the climate and nature itself.”
While we see the England Tree Strategy proposals to be a step in the right direction, we have identified opportunities for the strategy to go further to support the construction industry, and to help us to make better places for people to live. We felt a responsibility to respond to the consultation and share our position with DEFRA.
ACAN & Construction Declare’s response
The Where the Wild Things Aren’t thematic group have led the consultation response from within ACAN, and together with the Construction Declares Steering Group we have reached out to experts from beyond the architecture profession to ensure our response is robust, and addresses concerns beyond our professional silo. We have collaborated with a range of experts in forming our Key Messaging, including landscape architects, bee experts, representatives from the forestry industry and those working in tree mapping data. This has helped us to identify shovel ready ideas for the government to implement to help support timber industry and biodiversity of our woodlands, forests and cities.
DEFRA’s consultation is not in a format conducive for us to give a useful response from the architecture profession’s perspective. The consultation is limited to multiple choice options, and the questions are framed largely from the perspective of those in forestry management. This is a missed opportunity to gather in-depth insights from a wide range of respondents, and the consultation format has been criticised by the Arboricultural Association, the Landscape Institute and others already. DEFRA needs to also ensure it develops the strategy for tree planting in conjunction with other planned legislative changes and other government departments to ensure it is not working in opposition to other plans (e.g. the combustibles ban and the upcoming planning reform). Any strategy should also be developed to work in conjunction with strategies by the devolved Welsh, Scottish and Northern Irish governments.
As such, in addition to our formal consultation response, we have chosen to write an open letter to Lord Zac Goldsmith with an appended Key Messaging document outlining our position. We are hoping to gather signatures of support to these ahead of the consultation deadline of the 11th September.
You can read our full Key Messaging and sign our Open Letter here.
Both ACAN and the Construction Declares Steering Group regard large scale tree planting to be an important part of the pathway for the UK to achieve net zero carbon emissions. We believe the UK needs to massively increase it’s canopy cover. The Friends of the Earth states we could double the existing tree cover in the UK as just ‘13% of the UK’s total land area has tree cover (compared to an EU average of 35%)’. The DEFRA target for English tree planting would take English tree cover from 10% to 12%, so we believe that there is room for the strategy outlined by the government to be far more ambitious. The planning for this increase in canopy cover will need to be developed with the input of built environment professions, as we need to be growing trees in close proximity to and within urban areas, not only rural areas. Our proposals for how this increase in canopy cover are twofold.
1. The construction industry needs productive and diverse working woodlands
There is huge potential for the UK to grow a thriving domestic timber industry, to incentivise land-owners and investors to grow and nurture trees. Timber construction sequesters carbon and is one of the many strategies architects are seeking to reduce the embodied carbon associated with their building designs.
With a successful British timber industry, we can reduce our dependence on timber imports (the UK is one of the world’s biggest timber importers). We acknowledge that the UK imports many timber products that the UK already grows, including Oak, Ash and birch, and there is already scope to vastly increase domestic timber production with only 50% of existing forests and woodlands currently under management. The construction industry and architecture profession should be more involved in strategic definitions of tree planting in the future, to ensure the working woodlands are able to support the industry
To foster this, we suggest that the government should encourage the use of certified British grown timber within publicly procured buildings, and the use of British grown timbers in all construction. We have highlighted that other legislative changes are at odds with this objective - see ACAN’s Save Safe Structural Timber campaign for more information. We believe that construction should be the priority end-use for home grown timber outputs, rather than for combustion and carbon credits. Timber construction enables carbon to be sequestered for 60+ years in buildings, and extends the benefit of growing trees in the UK to aid the construction industry in meeting its targets for carbon reduction.
2. We need to increase tree canopy cover in our towns and cities
We know that trees in urban areas are hugely important to those living in cities and towns for health and wellbeing. Trees also offer a multitude of environmental benefits to communities - giving shade in summer (and losing their leaves in winter allows for solar gain), acting as drainage, reducing air pollution, supporting biodiversity and reducing the urban heat island effect.
Often trees in cities and towns are seen to be in conflict with maximising space utilisation in new development, and not given sufficient protections in proportion to the value they offer. We propose that tree canopy cover should be used as a compulsory measure in planning of trees in our urban areas, as opposed to solely numbers of trees (e.g. a 150 year old plane tree cannot be compared in environmental and biodiversity value to a 6 year old birch tree planted in its place). Mature trees can bring myriad value in cities and towns, and this needs to be better safeguarded. We have also identified a potential existing conflict of interests, that may limit the safeguarding of trees in urban areas. Local authorities are currently able to permit the felling of trees in negotiation with developers, while also being responsible for the issuing of Tree Preservation Orders. We have therefore proposed a new central body responsible for all these aspects (data management, TPOs) - as an equivalent to Heritage England for trees. Data mapping of trees has already started to be undertaken on a piecemeal basis in Britain, and the benefits of this can be seen through the public’s engagement with platforms such as TreeTalk. We see a need for a centrally run and maintained mapping of all British trees, by the same body responsible for TPO register maintenance. Trees should be given similar protections in proportion to the value they bring, and could be graded similarly to buildings.
We believe all these actions should be accompanied by raising public awareness of the importance of increasing british forests and woodlands, and of urban tree canopy cover. Access to nature should be a universal right, and tree planting should be targeted to make our society more equitable and share the benefits living in proximity to green space can bring to our communities. Communities who stand to benefit the most from new tree planting should be targeted as priority. We see potential for an expanding british tourism industry to be supported by increasing demand for wilderness tourism at home, and that making places more biodiverse and well-managed will encourage more people to interact positively with nature.
Next steps
We hope that DEFRA and Lord Zac Goldsmith will appreciate the suggestions in our response, and that they will be open to future meetings and conversations with ACAN and Construction Declares to help ensure that any future tree planting strategy is delivered in the best possible way for people, places and the planet.
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