Nature New Mills has responded to the Defra England Tree Strategy consultation that was launched in June and closed 11^th September.  

The consultation sought views on the following:  

• how to expand, protect and improve our public and private trees and woodlands,  
• the increased role that trees and woodlands can play in supporting the economy,  
• how best to further connect people to nature, and  
• the most effective way in which trees and woodlands can be created and managed to help combat climate change.  
  
  Defra Press Release: https://www.gov.uk/government/news/consultation-launched-on-the-england-tree-strategy  
  
   
  The consultation strategy included an introduction from the Forestry Minister, Zac Goldsmith, commending it as a way forward. The consultation consisted of 45 questions, and information to facilitate responses to the questions. The consultation document can be found in pdf form via the following link: https://consult.defra.gov.uk/forestry/england-tree-strategy/  
  
  As a group, Nature New Mills decided it was important to respond to the strategy. We collated responses from the group and fed those into the consultation survey. It took us a good half a day to do this and we hope that time has been well spent. As one of us said, ‘the Defra Document is a bit overwhelming’ 😉  
  
  We felt that the information given to help us respond to the consultation was carefully set out, though we would have appreciated further references, particularly to the scientific expertise informing the document.  
  
  We thought that there are some useful aspects to the proposed strategy. The strategy, for example, refers to natural regeneration and the need to encourage greater biodiversity. It emphasises the need for diversity in tree planting, as opposed to the establishment of tree monocultures, the need to ensure the resilience of woods in the face of climate breakdown, the need to control browsing by deer and other mammals, the value of tree corridors (to encourage biodiversity), the benefits of encouraging appropriate tree coverage along rivers as a means of controlling flooding, and the importance of trees and woodland for wellbeing, particularly in urban contexts. The strategy document emphasises the need to support and incentivise tree planting and regeneration projects financially. It also refers to the need for local community involvement, for example in mapping local areas. This last point is relevant to Nature New Mills and doubtless other areas of socio-environmental activity related to Transition New Mills.  
  
  All of this is heartening. However, as we noted in our response to the consultation, the overall target for tree coverage  (from 10% to 12%) is nowhere near sufficient, in a country with much less tree coverage than other European countries .We were also concerned that the strategy is more oriented around tree planting than it is with ‘reducing carbon and increasing biodiversity through better management of natural systems’. Our concern was that ‘a tree planting rush’ could happen at the expense of ‘other valuable habitats which may also play important roles in those objectives’.  
  
  Alongside these concerns, we were also unconvinced by the use of the term ‘ecosystems services’ in the strategy. We felt that this ‘service’ orientation would result in perverse incentives and constituted a ‘spurious cost-benefit tool which attempts to put a monetary value to woodland and nature’. Connectedly we questioned the desire for ‘energy forestry’ using ‘fast-growing trees which are planted and specially grown on a short rotation to provide biomass for power generation’ (Strategy consultation document, Page, 34). We wondered how much of the additional 2% forest cover would be given over to short rotation for wood biomass ( the strategy consultation document gives no indication that we could find).  Finally and substantively for us, the document does not explicitly mention the grouse shooting industry or industrial scale sheep farming (though it does mention deer and squirrels). We felt this was an omission and so raised it as a consideration in relevant parts of the consultation.  
  
  Alongside these key points we made the following points in the consultation (we have not included the exhaustive list of points made):  
  
  Creating space for nature  

• Ensuring natural regeneration should be at the top of the hierarchy of approaches (as recommended by Rewilding Britain in relation to the strategy): helping people to understand how natural regeneration  works, timescales, and to value the evolving landscape even though it might look messy to some and not result in instant gratification.  
• Natural regeneration is less costly than tree planting  
• Reduce barriers to species re-introduction (e.g. beavers) to help manage ecosystems.  

Local communities and local authorities  

• Local councils should be required to have a tree strategy which involves local non-governmental organisations.  
• Connected to the previous point, a need for greater publicised transparency on land ownership and current subsidies.  
• Facilitation of urban natural brown field regeneration and planting by community.  
• Raise awareness of the health and wellbeing benefits along with promoting a sense of ownership of civil spaces.  Increasing opportunities for dialogue and involvement with communities through agential activities.  This facilitates the smooth running of local government and ultimately the implementation of central government initiatives.  
• Advice and encouragement for communities to collect and grow trees for local planting in appropriate places.  
• Actively promote citizen planting of trees in gardens which have been paved over; incentives and support to unpave and plant permaculture lazy gardens.  
• More emphasis on help with whole ecosystem management, rather than just tree management. More accessible information for NGO’s, communities and general public education.  
  
  
  Planning and regulation  
  
• Planning guidance for new developments to take more account of tree planting and connections between natural areas. Incentivising not just tree planting, but ongoing maintenance and survival of trees 5 or 10 years later.  
• The planning system should be able to refuse development where this impacts ancient woodland. We also need to take better account of the cumulative effect of habitat loss.  
• A means to put protection orders on trees along with a register for why trees are felled, who felled them and contract numbers.  
•  Making it easier for town’s people to plant up trees in urban tarmac spaces can help with drainage issues and provide greened environment conferring health benefits.  

Supporting the economy:  Ecotourism  

(Note: The England Tree Strategy is interested in tree planting as a means of supporting the economy. Nature New Mills has made mention of ecotourism in meetings. Eco tourism could well be a useful way of supporting the economy, so we referred to it in the strategy document as below:  

• clearer routes to helping design sustainable services involved in tourism management  
• We would like people to be employed in this sector as conservationists and with a view to fostering eco-tourism around unique ecologies  
• Eco-tourism has the greatest potential for drawing together multiple economic stakeholders whilst maintaining and growing sustainable landscapes