UK Forestry Standard and Guidelines - a Consultation (Forestry Commission 2009)
Submission from ALGAO Countryside Committee
Date: 2 November 2009
UK Forestry Standard and Guidelines: a Consultation
COMMENTS ON THE FORESTS AND THE HISTORIC ENVIRONMENT GUIDELINES
GQ 1 General
Do you feel The Forests and the Historic Environment Guidelines are adequate in terms of length and detail?
Length appears to be fine but there are issues of detail that need to be addressed to ensure that historic environment issues are covered appropriately across the UK, not least because of the different arrangements that exist in the constituent countries.
Paragraph 24 states that ‘local authorities have responsibility for some historic environment issues within their area and may designate areas of historic importance…....Local authority archaeologists in England and parts of Scotland, Archaeological Trusts in Wales are asked to comment on forestry proposals to ensure the impacts on the historic environment are considered’.
This seems to be a summary of the various arrangements that exist or don’t exist between local authorities (LAs) and FC in the UK. In Scotland no explicit agreements are known to currently exist between FCS and LAs.
In Scotland various arrangements exist that have recently been articulated by FCS in ‘Historic Environment Information and Advice for Woodland Managers in Scotland’. The arrangements describe the numerous approaches to archaeological information exchange, advice, curation, management, of historic environment issues that exist across Scotland. While it is acknowledged that FCS is ultimately responsible for ensuring that these issues are addressed, this document should be cross referenced in the HE guidelines.
ALGAO suggests that it would perhaps be most appropriate to make it a requirement that the forestry industry seeks its own advice, which should ensure that case all of the UK should be appropriately covered.
If the above comment is considered to be either not acceptable or not appropriate, then ALGAO suggests that it would be beneficial for the basis of the consultation process to be regularised across the UK countries – whether this be through voluntary agreement, service level agreements or some other process - in order to ensure a consistency of advice for and management of the historic environment across the UK.
LCLR2, as drafted, could lead to confusion as to who is submitting proposals. An alternative phrasing is suggested, to avoid confusion – ‘In Great Britain (and under proposed legislation in Northern Ireland), proposals for felling or thinning must be submitted to the appropriate forestry authority for approval. Following felling, replanting will normally be required.’
Paragraph 30 refers to ‘Biodiversity effects’ when presumably this should read ‘historic environment’? LCLR5 has a catch-all phraseology not affected by this, but clarification would be useful.
Paragraph 34 Historic landscapes section does not mention Historic Landscape Assessment or Designed Landscapes that are instead covered in Forestry and Landscape Guidelines paras 54 – 59. It is recommended that both sets of guidelines should be consistent in the information they give under the sub-headings ‘Historic Landscapes’. Paras 54-59 of Landscape guidelines should be inserted into Historic Environment guidelines, and vice versa so that consistency is achieved with regard to content on ‘Historic Landscapes’ in both HE guidelines and Landscape Guidelines.
Paragraph 37 – ALGAO recommends that the first and second sentences of this paragraph should be extracted, given policy numbers and be in bold type – this is the actual protection bit for designated and undesignated archaeological sites. The two following policies (HEGFPR 4 and 5) don’t actually address the meat of the paragraph, but are rather supplementary. Without such a step, there is not actually a policy for protecting archaeological sites.
In HEGFPR4, ‘..should been taken..’ should read ‘..should be taken..’.
Paragraph 42 does not recognise that in many upland areas, e.g. Scotland, there has not been adequate survey and that this may have to be done by those proposing forestry.
Paragraph 44 – ALGAO suggests that reference could be made here to the recent Scottish survey by FC of information sources for archaeology.
References to local authority archaeology services
There are many references to seeking advice from a local authority, e.g. para 37 – protect important heritage features through on-site evaluation, taking advice from local authority or equivalent archaeological service.
HEG1 – contact relevant local authorities for information about historical context and any special policies that apply.
Para. 44 calls for close collaboration with local authority archaeologists etc.
HEG4 – Record the nature and position of any archaeological feature......and report them to relevant local archaeological authority.
HEG7 – seek advice from local authority archaeological body about potential effects of forestry proposals.
HEG20- Inform the archaeological authority if operations are planned near a scheduled monument (SM), or if other features of interest are thought to exist.
Para 63 – protection during site operations – good communication with local archaeological authority is essential
The recommendation that advice should be sought from and information provided to local authority professional officers is welcomed by ALGAO but this approach appears to be unique to the HE Guidelines. It needs however to recognise, perhaps more specifically (e.g. paragraph 37), that the local authority archaeological function in Wales is predominantly delivered by the Welsh Archaeological Trusts. In addition, there needs to be recognition that, depending on the level of input or output required from such services, there are inevitably resource implications that may have to be met.
HEG2 states that ‘where historic character is important, consider the impacts of woodland management and of new planting, particularly in open areas’.
ALGAO recommends that ‘where historic character is important’ should be deleted as every area will have an ‘historic character’ and that the reference should read ‘consider the impacts of woodland management and of new planting on the historic character of the landscape, particularly in open areas’. It is not clear who will determine the significance or importance of any particular historic character. ALGAO recommends that, in line with the comments immediately above regarding contact with local authority archaeological services, this guideline should recommend contact with the LA archaeological specialist.
HEG 5 should not just read “woodland areas”. As noted in the comments above against Paragraph 42, there are many areas where there is inadequate information to inform decision-making with regard to new areas of forestry. The same levels of access and assistance should be made available in these circumstances as well as for woodland areas.
Paragraph 48 notes that ‘In some situations, the archaeological evidence will be such that no planting will be appropriate and existing trees not restocked.’ ALGAO welcomes this clear statement and looks forward to its members providing the advice and guidance that will inform this and other aspects of the decision-making process with regard to forestry and the historic environment.
'Scheduled Ancient Monuments (SAMs)' should read 'Scheduled Monuments (SMs)' for consistency within the document.
Paragraph 49 – It is recommended that the end of the second sentence should read '..on operational and other plans.'.
ALGAO also welcomes the suite of guidelines HEG6 to HEG13.
Paragraph 54, line 3 '..will identify and any..' should read '..will identify any..'.
Paragraph 55 – it is recommended that the final sentence should end '..with care and appropriate specialist advice taken.'.
HEG20 '..scheduled ancient monument (SM)..' should read '..Scheduled Monument (SM)..'
ALGAO is concerned that, if the yellow boxes are indicative of the size of illustration that is proposed, that these will be too small to be meaningful. If this is the case, then consideration should be given to illustrations at least twice the size of the boxes indicated.
Ditches, trenches, and ponds – 'By there very..' should read 'By their very..'
Appendix 1 The RCAHMS ‘Pastmap’ is noted as the principal source of information for Scotland. However, ALGAO is aware of the FCS initiative that has surveyed all sources of information, as noted in the comments on paragraph 24 above. This should be included either instead of or as well as the reference to ‘Pastmap’.
GQ 2 Content
Do you feel there are any omissions, or un-necessary inclusions?
Please see comments above under GQ 1
GQ 3 Technical
Bearing in mind the function of the Guideline publications described in the diagram inside the front cover, do you feel the information is pitched at an appropriate level in terms of technical content?
Generally yes, but please see comments above under GQ 1, where a few issues of additional detail are addressed.
GQ 4 Guideline Bullet Points
Do you have any comments on the guideline bullet points set out under each factor?
Ken Smith Convenor, ALGAO Countryside Comittee