Scotland's forestry strategy 2019-2029: SEA post adoption statement

6 Comments on the draft strategy

6.1 General feedback

6.1.1 There was general support for the draft strategy and its contents, with only one section (Priorities for action) receiving more negative than supportive comments. However, there were also numerous and often conflicting requests for changes to be made to the detail, structure and presentation of the document. Views expressed are summarised below.

6.1.2 Many respondents asked for more detail to be provided throughout the document. Changes have been made to specific areas of the strategy to provide better clarity. In particular, greater detail on the rationale for the inclusion of specific priority areas and the types of activity that will be undertaken has been provided. Additions have also been made in relation to implementation and delivery.

6.1.3 There were numerous, varied calls for changes to the presentation of the document to improve clarity, including an improved explanation of the linkages between the vision, objectives, issues and priorities. This has been addressed through redrafting, in particular of sections 4 and 5, focusing on strategic drivers in section 4 rather than the more ambiguous "major issues", and replacing the tables in section 5 with clearer text on priorities for action to improve clarity and logic flow.

6.1.4 Similarly, there were frequent calls for greater demonstration of ranking within the strategy – ranking of objectives, issues and priorities. However, in recognition of the interdependencies of the three components of SFM – economy, environment and society – ranking has not been introduced. This is to ensure the strategy is both balanced and remains relevant throughout its 10-year lifespan, with enough flexibility to adapt to changing circumstances.

6.2 Woodland Trust Campaign response

6.2.1 As noted above, almost half of all responses were identical and were generated via a campaign by Woodland Trust Scotland. These responses called for the strategy to provide clear plans of action, with ambitious targets that are monitored and regularly reported on for the following: native woodland creation; improving the condition of existing native woods; and the protection of ancient woodlands.

6.2.2 Within Scotland's Biodiversity Strategy,^[3] the Scottish Government has already committed to, and set targets for native woodland creation and improvements in native woodland condition. These targets were previously set out in the draft strategy in section 3 on the vision and objectives. To give them more profile they are now detailed in the introduction (section 1). In addition, the sections of the strategy dealing with strategic drivers and priority areas for action now include explicit references to: preventing ancient woodland losses; supporting the creation of native woodlands, protecting woods and forests from the risks posed by invasive non-native species, deer and other herbivores; and improving the ecological condition of native forests and woodlands, including plantations on ancient woodland sites.

6.3 Thematic analysis

6.3.1 Due to the diversity in responses received to the consultation, a thematic analysis of responses was carried out, grouping the content of responses around the three components of SFM (economy, environment and society). The following theme-specific messages were identified.

6.3.2 A common theme amongst those discussing economic concerns was a request for greater recognition of the need for improvements to rural infrastructure to support the sustainable transportation of timber. This has now been covered in both the strategic drivers section, as well as within the priority areas for action (priority 3).

6.3.3 For respondents that commented on the environment, there were frequent calls for the strategy to include a greater focus on biodiversity. To address this, greater prominence has been given to biodiversity throughout the document, particularly within the section on the contribution of Scotland's forests and woodlands, and within the priorities for action section, where a number of biodiversity-related activities are listed under priorities 4 and 5.

6.3.4 Responses from both those with an environmental focus and those with a more social focus, also called strongly for more emphasis on the application of integrated approaches to land management. In finalising the strategy the Scottish Government have strengthened the profile of integration throughout the document and in particular the 50-year vision now includes explicit reference to the integration of forestry with other land uses.

6.3.5 Responses that discussed social issues commonly asked for more comprehensive consideration of small-scale forestry. As such, the new priorities for action make it clear that the creation of a range of types and scales of new forests and woodlands will be supported and that, likewise, businesses of different types and scales will be supported to develop and grow markets.

6.3.6 Another call made in responses that discussed social issues was to raise the profile of the value of forests and woodlands in mitigating the impacts of climate change for the benefit of current and future generations. This has been addressed in the drivers and priorities sections, with greater emphasis being given to the adaptability and resilience of Scotland's woodlands and forests.

6.4 Vision and objectives section

6.4.1 The majority of respondents agreed with the draft strategy's vision (64% of those that responded to the question) and felt that the objectives set out in the draft strategy were the right ones (60% of those that responded to the question). There were no consistent messages regarding requests for revisions to either the vision or objectives, and instead comments tended to focus on giving greater emphasis to a particular issue or area of SFM, or requested a level of detail not appropriate for a strategic vision and objectives. The vision has therefore been refined, and the objectives have been re-drafted to improve their clarity and ensure they are measurable (which was an issue raised by some respondents).

6.5 "Major Issues" section

6.5.1 Just over half of respondents agreed with the assessment of the major issues within the draft strategy (54% of those that responded to the question). Some respondents described the presentation of the issues as confusing. To address this the Scottish Government have reframed this section of the document, clarifying its purpose and focusing on strategic drivers rather than 'issues'. This better reflects its content and improves the logical flow of the document.

6.5.2 There were numerous and wide-ranging requests for additional issues to be included in this section. All comments have been considered in light of the revised focus on strategic drivers. Where appropriate, specific comments have been incorporated into the text.

6.6 Priorities for action and policies for delivery section

6.6.1 Just under half of respondents felt that the ten priorities identified in the draft strategy captured the areas where action is most needed to deliver the objectives and vision of the strategy (48% of those that responded to the question). Negative responses to this question tended to focus on aspects of the presentation, structure or discussion rather than the priorities themselves. There was also a sense that the priorities could be more clearly linked to the vision, objectives and issues, and should be sufficiently quantifiable to be able to measure progress.

6.6.2 To improve clarity, the priorities section has therefore been redrafted. The information included previously is now presented in a different way and the tables have been removed. The number of priorities has been reduced from ten to six and these are higher-level, broader and more strategic. This approach allows the priorities to be more cross-cutting across the three key objectives, which better reflects the principles and the multi-purpose nature of sustainable forestry.

6.6.3 While the number of priorities has been rationalised from ten to six, more explanatory detail has been provided below each priority. For example, an improved rationale has been included for each priority area for action to strengthen the linkages with other sections of the strategy, enhancing the overall logical flow. In addition, information on the types of activity that will be undertaken within the priority action areas has also been provided. The finalised priorities have also been drafted in such a way as to improve their measurability.

6.6.4 There were calls for greater detail on how the strategy will be implemented and delivered, and calls for a commitment to engaging with stakeholders in the development of plans for implementation and a monitoring and reporting framework.

6.6.5 To address these requests, delivery, monitoring and reporting is now covered in a distinct section of its own in the finalised strategy. This section provides greater clarity on the delivery, monitoring and reporting process and the role of government and other stakeholders within it.

6.6.6 Respondents shared numerous examples of effective delivery mechanisms and suggested several indicators which could be included in a monitoring framework. These suggestions will be considered during the delivery phases, after the strategy has been published and then laid before Parliament.

6.6.7 A key finding from a survey which targeted young people was that respondents felt that a crucial current benefit of forests was their contribution to reducing climate change and that this will grow in importance over the next 50 years. This has been addressed in the final strategy by improving the profile of climate change mitigation and adaptation throughout the document, including within the priorities for action. The benefit identified as the most important currently and ranked second in importance in the future was the provision of habitats for wildlife. The priorities section of the strategy now makes a specific commitment to safeguarding priority habitats and species.

6.6.8 The structure and content of this section of the strategy have been refined and improved and the Scottish Government is content that there have effectively been no new additions that would necessitate a further strategic environmental assessment to be carried out.

6.7 Impact Assessments – Equality Impact Assessment

6.7.1 Feedback on the partial Equality Impact Assessment (EQIA) suggested that diversity should be considered in a wider sense within the strategy, covering forestry and woodland users as well as those working within the sector. To address this, explicit reference to both attracting diverse talent to the forestry sector, as well as to encouraging a more diverse range of people to value and use forests and woodlands have been included within the priorities section.

6.8 Business and Regulatory Impact Assessment

6.8.1 Feedback on the partial Business and Regulatory Impact Assessment (BRIA) suggested respondents would have liked a wider range of organisations to have been consulted during its creation. However, there were no consistent calls for changes to be made to the assessment or associated changes to be made to the strategy. Taking account of changes made to the strategy following the consultation, the BRIA was updated and finalised.

6.8.2 Both the BRIA and the EQIA are available at: https://www.gov.scot/policies/forestry/forestry-strategy-project/