Chapter 5: Other comments
The final main consultation question asked respondents if they had any other relevant comments to make.
Question 15: Do you have any other comments that you would like to make, relevant to the subject of this consultation, that you have not covered in your answers to other questions?
Around 220 respondents made a comment at Question 15. These were often brief and frequently reinforced points made elsewhere in the submission. Other submissions were longer, with the inclusion of additional reports or materials in a small number of instances. The analysis below focuses on issues which are relevant to the subject of the consultation and do not feature, or have very limited coverage, elsewhere in this report. The final section sets out a very brief summary of the key themes raised at Question 15 and elsewhere throughout the consultation responses.
Although tourism and recreation are highlighted in the introduction to the consultation, some felt that the main body of the consultation paper lacks recognition of tourism. It was noted that both FCS and FES have been at the forefront of formulating best practice in managing public access to the NFE for leisure and recreation, benefiting the tourism sector and local communities dependent on visitor income. It was suggested that any changes to commercial forestry activities should be sensitive to the impact that this would have on the tourism and recreation activities (Pr, Th).
It was suggested that any legislative changes to the Forestry Act 1967 should ensure continued provision relating to 'Requirements for haulage facilities' such that landowners are required to enable effective and sustainable access to the forestry resource (O).
Concerns were raised as to the economic pressures on contracting businesses. It was suggested that these businesses create employment and invest in technology and training of existing staff. However, it was reported that they work to very narrow margins and get little recognition for their role in the industry. This includes being ineligible for grant support. It was suggested that a government forestry agency should support the industry to raise standards, including by paying at an appropriate rate for good quality contracting work (O).
It was noted that the NFE incorporates streams and stillwaters often leased to angling interests. However, there was a concern that, although the consultation paper mentions environmental outcomes and wildlife, it does not reference fish and angling. It was also noted that the Scottish Government is currently engaged in an all species Wild Fisheries Reform and should ensure that future forestry policy views publicly-owned waters, such as those in the NFE, as national assets which are available to the angling public (O).
It was suggested that a future land agency should consider use of natural resources, including hunting of game for food, on public land. This suggestion was sometimes associated with deer control (see below) (Ind, Th).
Recreational deer stalking
The limited use of recreational stalkers to control deer on NFE land was noted (O, Th). It was suggested that by providing more opportunities to those who have relevant qualifications, deer can be controlled in the public interest but at less cost to the tax payer than when professional stalkers are employed to cull deer. It was suggested that completion of the devolution of forestry provides an opportunity to review current arrangements (O).
It was suggested that the Scottish Government should consider their proposals from an international perspective, including considering that global timber shortages are putting increasing pressure on remaining natural and semi-natural forests. It was further suggested that by expanding its commercial forest, Scotland will contribute to increased roundwood production internationally, with the aim of reducing the pressure on the world's remaining fragile natural forests (Ac).
Review of environmental functions
There was a call for the Scottish Government to undertake a more comprehensive review of its environmental functions, rather than looking at the Forestry Commission in isolation. Suggestions included the creation of a body which monitors effectiveness, similar to Audit Scotland, and the means of appeal in cases of conflict, such as environmental courts (Th).
It was suggested that 'National Forest Estate' gives a strong indication that forestry, and in particular commercial forestry, is the top priority and that this is out-dated. Alternatives proposed for the public forest as better reflecting wider environmental and social concerns included: Sustainable Forests Scotland; Scotland's Community Forest; Scotland's Forest and Environment; and Forest Ecosystems Scotland (Pu).
Suggestions for alternative names for the proposed Forestry and Land Scotland Agency have been noted elsewhere in the report. At Question 15, it was suggested that it would be appropriate to consult on the name, possibly from a short list of suggested titles (Ind).
Acknowledgment of the role of the private sector
It was noted that private sector holdings make up two thirds of Scotland's forest area. It was felt that the role of private forestry in contributing to Scotland's rural economy, and to other land-based outcomes, such as mitigating climate change, reducing the impact of flooding and improving biodiversity, could be better recognised (O, Pr).
The importance of a regional presence was raised, particularly in relation to the importance of retaining high quality jobs. It was suggested that forestry management and functions should be delivered predominantly at a regional level (Ind, O, Pu).
Summary of major themes throughout the consultation
As noted above, many respondents used their answer at Question 15 to summarise their position on the issues raised throughout the consultation. In this respect, the comments at Question 15 broadly reflect some of the key themes to otherwise emerge from the consultation analysis process, such as:
- Respondents often expressed a clear, and apparently strongly held view, on the future structures for managing Scotland's forests.
- Although some respondents saw benefits in a closer integration of the policy and/or estate management functions and other government structures, there were concerns about publicly-owned forests becoming vulnerable to shorter-term thinking and/or politically-driven decision-making.
- The need to respect and retain the skills and expertise of those working in the forestry industry was a central concern for many and was often focused on the current teams within FCS, FES and Forest Research.
- The future of the NFE is a key issue for many. For some, there is a concern about declining productivity and a desire to see better restocking and new planting. However, many respondents stressed that Scotland's national forests are much more than a timber resource.
- In relation to the proposal for a land agency, some respondents saw considerable potential in an agency which managed a broad range of publicly-owned land, while others had concerns that the focus on the forestry function would be overly diluted.
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