Remove Microplastics from forestry: EIR release

Information requested

Can you please advise what additional measures are taken to remove/reduce the pollution of microplastics from forestry tree planting?

Response

As the information you have requested is ‘environmental information’ for the purposes of the Environmental Information (Scotland) Regulations 2004 (EIRs), we are required to deal with your request under those Regulations. We are applying the exemption at section 39(2) of the Freedom of Information (Scotland) Act 2002 (FOISA), so that we do not also have to deal with your request under FOISA.

This exemption is subject to the ‘public interest test’. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exemption. We have found that, on balance, the public interest lies in favour of upholding the exemption, because there is no public interest in dealing with the same request under two different regimes. This is essentially a technical point and has no material effect on the outcome of your request.

Response to your request.

Sources of microplastics from forestry tree planting.

Sources of plastic waste in tree planting are plastic tree bags, tree shelters and vole guards, all of which require careful management. Shelters and guards are primarily used to protect young trees from grazing, especially for deer.  Where possible, deer control or deer fencing are the preferred methods of protection and tree shelters tend to be used for smaller woodland creation schemes.

Statutory measures for managing pollution of microplastics from forestry tree planting

The Environmental Protection Act 1990 places a duty of care on any person who produces, keeps, manages or disposes of controlled waste to take all measures to apply the waste hierarchy. This hierarchy involves following these principles in a way to deliver the best overall environmental outcome: prevention preparing for re-use, recycling, recovery and disposal. In the forestry context, tree shelters are considered controlled waste as defined in the Environmental Protection Act 1990. Breaches of environmental legislation are regulated by Scottish Environment Protection Agency (SEPA).

Non-statutory measures for managing tree shelters.

The UK Forestry Standard is the technical standard for internationally agreed sustainable forest management principles which is endorsed by all UK governments.
The UK Forestry Standard 5th Edition, which comes into operation 1 October 2024, stipulates:

• The use of plastics, whether made from oil based or bio-based polymers, should be avoided or reduced as much as possible [and redundant products] should be removed and recycled to avoid the impacts of bio-accumulation in the forest soil.
• Manufactured products such as fencing, plastic packaging and bags, and tree guards and shelters, should be managed appropriately when they stop having a functional value in the forest environment. They should be collected and disposed of, and the costs and likely timeframe for recovery from the site will need to be addressed in the forest management plan.

Those in receipt of Forestry Grant Scheme funding must comply with legislation and the UK Forestry Standard. Environmental legislative breaches are regulated by SEPA whereas UK Forestry Standard compliance forms part of Forestry Grant Scheme contracts and is managed by Scottish Forestry. Failure to remove tree guards is considered a Forestry Grant Scheme contractual breach (only for grants received after July 2022 when this stipulation was introduced), which can also be reported to SEPA for potential non-compliance with waste regulation.

Where woodlands are certified under the (voluntary) UK Woodland Assurance Scheme, the relevant requirement for waste (which includes plastic tree shelters and tree bags) is for disposal to be in accordance with current waste management legislation and regulations.

Tree protection funded by Forestry Grant Scheme

Since the introduction of the current forestry Grant Scheme in 2015, 166 million trees have been funded, of which 3.1 million trees have been protected by plastic tree shelters (less than 2%) and 26.4 million (16%) protected by vole guards. Tree bags are not funded by the Forestry Grant Scheme and their use is not monitored by Scottish Forestry.

Additional measures and activities to reduce plastic pollution from forestry tree planting.

The Scottish Government is fully supportive of efforts to reduce, remove and recycle plastics used in the woodland and forest environment. This includes encouraging the development and use of viable biodegradable alternatives to conventional polymer plastic tree shelters, in line with the waste hierarchy.

Scottish Forestry is a member of the UK wide Forest Plastics Working Group, established 2020. The group consists of scientists, waste experts, government policy representatives, as well as public and private forestry sector representatives. The focus of the Forest Plastics Working Group is on the reduction of single and temporary use of plastics in UK tree planting and recently published a guidance document on Reducing The Use of Plastic in Woodland and Amenity Planting. The group is currently supporting research to test alternatives to conventional single use plastic tree shelters and bags. Results are yet to be delivered and evaluated, but the conclusions will be considered alongside broader studies looking at how biodegradable shelters behave in natural environments and inform any possible changes to the Forestry Grant Scheme.

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