Scottish Forestry's Carbon Code Calculations: EIR release

Information requested

You asked for the following information to be disclosed:

Good afternoon,

I would like to make a FOI/EIR request, which is shown below (after 'start of FOI'). Also attached is a document that is referred to in the request.

Thank you for your assistance.

START OF FOI:

On 19 October 2021, Dr Pat Snowdon (Head of Economics and Woodland Carbon Code) was one of several witnesses attending the House of Lords Science and Technology Committee – Nature- based solutions for climate change. The transcript for this session is provided with this FOI request.

In response to question 51, Dr Snowdon states ‘we have modelled the Woodland Carbon Code on the world’s leading global standards such as Verra, the Verified Carbon Standard, and the Gold Standard, so it has the key components of a high quality standard such as measures for permanence, additionality, transparency through the use of a carbon registry, and independent thirdparty validation and verification. These are the central components of a good-quality code’.

1. Verra and other ‘global standards’ may use a range of methodologies which may also be updated over time. Which specific methodologies from these global standards were used for modelling the Woodland Carbon Code (WCC) ? Please provide the specific methodologies ( and their mathematica/scientific workings) used.

2. Did staff working for the WCC and/or Scottish Forestry (and/or other Scottish Government staff) ensure that due diligence measures were taken to assess the credibility of the global standards used to model the WCC? Please provide all information (if any) to show that due diligence measures were made.

3. Was the decision by staff and/or advisors working for the WCC/Scottish Forestry to adopt the temporary sequestration of carbon (with buffers) on site from commercial forestry (by calculating the long-term average stock of carbon) based on a methodology or methodologies provided by one or more of these ‘leading global standards’? If so, what were the methodologies used? Please provide the specific methodologies, and their mathematical/scientific workings used to show that the longterm average stock of carbon on site was used to determine carbon sequestered, if not already provided under point 1 above.

4. The WCC claims there are no leakage effects due to the 1967 Forestry Act and agricultural regulations. It is assumed leakage effects (in this case) refers to carbon emissions occurring from (a) trees being cut down for agricultural production and (b) agricultural intensification of existing agricultural land (both measures being to compensate for loss of food supply from planting new woodlands). Does the WCC state/mean that there are assuming no leakage effects occur in the UK only, or there are no leakage effects at an international level?

5. Was this assumption that planting new woodlands in the UK have no leakage effects derived from one or more methodologies used in the various ‘global standards’ previously mentioned by Dr Snowdon? If so, please provide what these methodologies were. Also please provide all economic forecasting and other claimed evidence (if any) that shows no leakage effects occur.

6. In determining how the WCC was/is calculated, did the WCC/Scottish Forestry staff investigate or research the hypothetical lifecycle (carbon/greenhouse gas) emissions of the (range of) timber products when taken off-site? It is understood harvesting emissions are already considered when computing the long-term average stock of timber on site. If yes, did the WCC/Scottish Forestry consequently establish that these lifecycle emissions meant the alleged projected quantity of longterm carbon sequestration as computed by the WCC calculator for new commercial (harvested) woodland creation sites was therefore untrue?

7. Scientists and others have pointed out that the carbon sequestered by trees (those planted for commercial purposes) is only temporary, as all the carbon sequestered is typically returned to the atmosphere over the lifecycle of the product. Furthermore, there will be emissions from activities such as transport, processing, manufacturing and distribution of the resulting timber products. The quantity of these cumulative emissions (over indefinite, multiple harvest cycles) from these activities will reduce and eventually exceed the quantity of long-term stock of carbon sequestered on site from where the timber was harvested. It appears the WCC/Scottish Forestry decided to ignore the fact that the long-term stock of carbon on site would be reduced and eventually cancelled out by the emissions from consuming the resulting timber products. Was this decision to ignore lifecycle emissions due to the WCC/Scottish Forestry adapting one or more of the ‘global standards’ (or some of the methodologies within these standards) mentioned previously? If so, please provide the methodology or methodologies that was used to ignore lifecycle emissions. Alternatively, was the decision by the WCC/Scottish Forestry to ignore the impact of lifecycle emissions taken by its own staff/advisors?

8. It is understood that there is no requirement for companies that process the harvested timber off site (for the end product) to ‘compensate’ for their greenhouse gas emissions caused by their activities. However, even if there was an obligation to ‘compensate’ for these emissions by for example, ‘offsetting’ through acquiring carbon credits from a different, new commercial woodland creation scheme, there are also product lifecycle greenhouse gas emissions due to the new woodland scheme. Does the WCC/Scottish Forestry hold any information that shows mathematical and scientific proof that using carbon credits from a new commercial woodland creation scheme to ‘compensate’ for emissions from the lifecycle emissions of timber products leads to net removal of greenhouse gases from the atmosphere? The following questions/requests for information relate to governance and decision making by the WCC in determining how carbon sequestration calculations, methodologies and assumptions are approved and/or incorporated into the WCC calculator.

9. The WCC website states that the WCC has been in operation since 2011. Is it the case that since the original WCC calculator in 2011, estimated projected carbon sequestration was based on the long-term average stock of carbon in trees over harvesting cycles, such as up to 100 years?

10. Please could you identify all the individuals and their job titles within the WCC/Scottish Forestry (or predecessor organisations such as Forestry Commission Scotland) that were responsible for the original (version 1.0) of the WCC and the associated spreadsheet calculator.

11. It is understood the WCC and the associated spreadsheet calculator has been updated (currently at version 3). From 2011 up to this version, have there been any proposals by WCC/Scottish Forestry staff and/or WCC advisors to cease including the projected carbon sequestration attributable to the long-term temporary stock of commercial (harvestable) trees on site?

12. From 2011 up to version 3.0, has there been any communication from third parties to suggest, advise, or debate discontinuing the inclusion of projected carbon sequestration attributable to the temporary stock of commercial (harvestable) trees on site? If so, please provide all correspondence between Scottish Forestry and these third parties in relation to any possible suggestions, advice or debates to discontinue the inclusion of projected carbon sequestration attributable to the temporary stock of commercial (harvestable) trees on site.

13. Have the WCC and/or Scottish Forestry in the last six years written, or received any reports (published or unpublished) confirming that commercial conifer plantations do not permanently sequester carbon? If so, please provide these report(s).

14. Please could you identify all the individuals and their job titles within the WCC/Scottish Forestry that were responsible for the latest version (version 3.0) of the WCC and the associated spreadsheet calculator. END OF FOI

Response

Response to your questions 1, 7, 8, 9, 12, and 13:

While our aim is to provide information whenever possible, after conducting a thorough search across the organisation, I can confirm that we were unable to provide any information regarding parts 1, 7, 8, 9, 12, and 13 of your request, as Scottish Forestry does not hold any information within this scope. This is a formal notice under section 10(4)(a) of the Environmental Information Regulations (the EIRs), informing you that Scottish Forestry does not hold the information you requested.

We acknowledge the distinction between compile and create under Regulation 9 of the Environmental Information Regulations (the EIRs) (Advice and assist). However, in this particular case, the requested information cannot be compiled, as no Scottish Forestry information in recorded form exists that would fall within the scope of this request.

Under Regulation 10 (4) (a) of the Environmental Information Regulations (the EIRs), we are required to provide only information held at the time of the request.

Under Regulation 9 (Advice and Assist) of the Environmental Information Regulations 2004 (EIRs), we are not required to create new information in order to provide a response. Accordingly, the information you have asked for parts 1, 7, 8, 9, 12, and 13 of your request is not held by Scottish Forestry.

Please refer to Annex A below for a more detailed explanation of the exception applied.

Response to your questions 2, 3, 4, 5, 6, 10, 11, and 14:

The answers to your questions are provided below in the same order as in your request:

Response to question 2: Did staff working for the WCC and/or Scottish Forestry (and/or other Scottish Government staff) ensure that due diligence measures were taken to assess the credibility of the global standards used to model the WCC? Please provide all information (if any) to show that due diligence measures were made.

A public consultation was conducted during the development of the Woodland Carbon Code, and we spoke with a range of carbon market experts and commissioned research to inform our findings. This work included incorporating core principles of good practice (under the Kyoto Protocol at the time) and investigating existing carbon standards and their credibility.

The attached Annex B provides the source of this information and all the information we hold regarding your question 2.

An exception under Regulation 11(2) of the EIRs (personal information) applies to some of the requested information because it is third-party personal data. You will be able to identify where names have been redacted in the released document.

In this instance, we were also unable to provide some of the information you requested because an exception under Regulation 10 (4) (e) of the Environmental Information Regulations (the EIRs) (internal communication) applies to some of the information contained in one document released in the context of your question 2, as explained in more detail in Annex A.

This exception is subject to a public interest test. Therefore, taking account of all the circumstances of this case, we have considered whether the public interest in disclosing the information outweighs the public interest in applying the exception. We recognise that there is some public interest in releasing information as part of open, transparent, and accountable government, and informing public debate.

However, there is a greater public interest in allowing officials ‘safe space’ within which options can be properly explored and considered, and well-informed, evidence-based, good decisions can be made. Premature disclosure is likely to undermine the full and frank discussion of issues between Scottish Forestry and other UK public sector officials, which in turn could substantially undermine the quality and objectivity of the decision-making processes at all levels.

You may also be interested in consultation documents proactively released online: Woodland Carbon Code V3.0 consultation document_April 2025.pdf

Response to question 3: Was the decision by staff and/or advisors working for the WCC/Scottish Forestry to adopt the temporary sequestration of carbon (with buffers) on site from commercial forestry (by calculating the long-term average stock of carbon) based on a methodology or methodologies provided by one or more of these ‘leading global standards’? If so, what were the methodologies used? Please provide the specific methodologies, and their mathematical/scientific workings used to show that the long-term average stock of carbon on site was used to determine carbon sequestered, if not already provided under point 1 above.

The approach taken to modelling net CO2 removals from woodlands that involve clear-felling was based on research and consultation referred to above under question 2. The long-term average carbon stock had been used in other standards such as the VCS, and following extensive investigation, it was decided that it would provide an appropriate approach for the Woodland Carbon Code. It should be noted that the Woodland Carbon Code does not currently allow for the carbon stored in harvested wood products (unlike the VCS) and that, therefore, it takes a conservative approach to estimating net CO2 removals from clear-felled woodlands. Guidance is provided here.

Where information is already publicly available, links to the relevant webpages have been provided. Under Regulation 6 (1) (b) of the EIRs, we are not required to provide you with information that is readily available online.

Response to question 4: The WCC claims there are no leakage effects due to the 1967 Forestry Act and agricultural regulations. It is assumed leakage effects (in this case) refers to carbon emissions occurring from (a) trees being cut down for agricultural production and (b) agricultural intensification of existing agricultural land (both measures being to compensate for loss of food supply from planting new woodlands). Does the WCC state/mean that there are assuming no leakage effects occur in the UK only, or there are no leakage effects at an international level?

The Woodland Carbon Code does not consider reduced emissions from agriculture as a result of planting a woodland. The reduction in net agricultural emissions on site is not included in a Woodland Carbon Code project’s carbon calculations and, therefore, does not require adjustment in case of leakage, whether this occurred in the UK or overseas. The Forestry Act (and the Forestry and Land Management (Scotland) Act 2018 in Scotland) provides protection against leakage because existing woodlands are subject to felling licence regulations, which prevent permanent deforestation for agricultural purposes.

The Woodland Carbon Code does not claim that leakage is not possible. The code requires that land managers confirm any intention to change or intensify the use of land elsewhere on a holding as a result of woodland creation. Projects carry out an assessment to see if any expected leakage would result in greenhouse gas emissions – if significant emissions were expected to occur (i.e. over 5% of the project’s carbon sequestration), they shall be accounted for in the net carbon sequestration of the project. Further details are provided here.

Where information is already publicly available, links to the relevant webpages have been provided. Under Regulation 6 (1) (b) of the EIRs, we are not required to provide you with information that is readily available online.

Response to question 5: Was this assumption that planting new woodlands in the UK have no leakage effects derived from one or more methodologies used in the various ‘global standards’ previously mentioned by Dr Snowdon? If so, please provide what these methodologies were. Also please provide all economic forecasting and other claimed evidence (if any) that shows no leakage effects occur.

Details on how the Woodland Carbon Code handles leakage are described here. There is a potential risk of leakage whereby the agricultural activity displaced by a new woodland is moved elsewhere, increasing emissions outside the project boundary. However, two aspects can help ensure leakage is minimised in the UK.

As stated above, the Woodland Carbon Code does not account for emissions from the previous land use in the baseline, nor for the reduction in emissions from the previous land use within the project carbon accounting. This reduces the requirement to account for leakage emissions if that activity were moved outside the project boundary.

Also stated above, UK laws protecting semi-natural habitats and existing woodlands make such leakage from land-use intensification outside the project boundary unlikely. These laws include the Forestry Act (protection against deforestation), the Environmental Impact Assessment Regulations (presumption against removing woodland), and wildlife, nature conservation, and access legislation (protection of biodiversity and semi-natural habitats).

The approach taken by other carbon standards was examined during the design phase of the Woodland Carbon Code, but we considered it important that the Woodland Carbon Code’s approach to leakage was informed by the policy and regulatory framework within which forestry operates in the UK (e.g. the Forestry Act and Environmental Impact Assessment regulations).

Where information is already publicly available, links to the relevant webpages have been provided. Under Regulation 6 (1) (b) of the EIRs, we are not required to provide you with information that is readily available online.

Response to your question 6: In determining how the WCC was/is calculated, did the WCC/Scottish Forestry staff investigate or research the hypothetical lifecycle (carbon/greenhouse gas) emissions of the (range of) timber products when taken off-site? It is understood harvesting emissions are already considered when computing the long-term average stock of timber on site. If yes, did the WCC/Scottish Forestry consequently establish that these lifecycle emissions meant the alleged projected quantity of long-term carbon sequestration as computed by the WCC calculator for new commercial (harvested) woodland creation sites was therefore untrue?

The Woodland Carbon Code does not account for carbon stored in harvested wood products. Only long-run on-site carbon is included in the carbon calculator. All emissions from forest management operations are included in the carbon calculator. The carbon stored in harvested wood products is effectively treated as a carbon loss, which is a significant under-estimate of the net GHG effects of wood products. This means that Woodland Carbon Code carbon calculations are expected to underestimate net CO2 removals of these projects. More detail is provided in the Code here.

Where information is already publicly available, links to the relevant webpages have been provided. Under Regulation 6 (1) (b) of the EIRs, we are not required to provide you with information that is readily available online.

Response to your question 10: Please could you identify all the individuals and their job titles within the WCC/Scottish Forestry (or predecessor organisations such as Forestry Commission Scotland) that were responsible for the original (version 1.0) of the WCC and the associated spreadsheet calculator.

Scottish Forestry did not exist when Version 1.0 was designed. Some of these names can be found in the governance section of the Woodland Carbon Code website, but others will not be listed now because they are no longer working on the Woodland Carbon Code and/or have moved to different roles.

While our aim is to provide information whenever possible, I can confirm that Scottish Forestry does not hold any recorded information relevant to this question, apart from the information provided on the webpage above. This is a formal notice under section 10(4)(a) of the Environmental Information Regulations (the EIRs), informing you that Scottish Forestry does not hold the information you requested.

Where information is already publicly available, links to the relevant webpages have been provided. Under Regulation 6 (1) (b) of the EIRs, we are not required to provide you with information that is readily available online.

Response to your question 11: It is understood the WCC and the associated spreadsheet calculator has been updated (currently at version 3). From 2011 up to this version, have there been any proposals by WCC/Scottish Forestry staff and/or WCC advisors to cease including the projected carbon sequestration attributable to the long-term temporary stock of commercial (harvestable) trees on site?

No. Woodlands are restocked over successive rotations (in line with forestry legislation), thereby establishing an average carbon stock into the very long-term. It should be noted that carbon credits are only allocated to the first rotation and only to the level of the long-run average carbon store. Further guidance is provided here.

Where information is already publicly available, links to the relevant webpages have been provided. Under Regulation 6 (1) (b) of the EIRs, we are not required to provide you with information that is readily available online.

Response to your question 14: Please could you identify all the individuals and their job titles within the WCC/Scottish Forestry that were responsible for the latest version (version 3.0) of the WCC and the associated spreadsheet calculator. END OF FOI

Pat Snowdon, Head of Economics and Woodland Carbon Code, Scottish Forestry Vicky West, Woodland Carbon Code Senior Development Manager, Scottish Forestry Andy Baker, Woodland Carbon Code Senior Operations Manager, Scottish Forestry Other (more junior) members of the Woodland Carbon Code also contributed to the development of Version 3.

You may be interested in the video presentation available on the Woodland Carbon Code Organisation website, hosted by Scottish Forestry on behalf of all the UK governments, which gives you a virtual experieence of meting the Scottish Forestry Carbon Team:

https://www.woodlandcarboncode.org.uk/news-events/woodland-carbon-code-version-30

Where information is already publicly available, links to the relevant webpages have been provided. Under Regulation 6 (1) (b) of the EIRs, we are not required to provide you with information that is readily available online.

Note that decisions on the Woodland Carbon Code, including the design of Version 3, are made by the WCC Executive Board, which includes representatives of the Forestry Commission, the Welsh Government and the Northern Ireland Forest Service. At a strategic level, the Woodland Carbon Code is overseen by the Woodland Nature Markets Strategy Board – details on both of these groups are here.

You may also be interested in exploring the documents that have been proactively released on the Woodland Carbon Code website at https://www.woodlandcarboncode.org.uk/version-history and https://www.woodlandcarboncode.org.uk/view-the-code

Where information is already publicly available, links to the relevant webpages have been provided. Under Regulation 6 (1) (b) of the EIRs, we are not required to provide you with information that is readily available online.

Please refer to Annex A below for a more thorough explanation of the exceptions applied.

About FOI

The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at https://www.gov.scot/foi-responses.

EIR 202600512427 - Information Released - Annex A and Annex B

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