Responses on Pests and Diseases
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BSW Timber Response to Consultation on the Natural Resources Body for Wales (additional consultation) Your name: Hamish Macleod Organisation (if applicable): BSW Timber Email / telephone number: [email protected] / 01228 674221 Consultation questions Question 1: Do you agree with our proposal for the duties of the body in respect of conservation and natural beauty? Yes /Mainly/Not at all Question 2: Do you agree with the proposals in respect of public access and recreation duties? Yes/ Mainly/Not at all If not how would you change it? : BSW Timber is the UK’s largest domestic sawmilling group, processing around fifteen per cent of the UK timber harvest. The group has an annual turnover in excess of £175m, directly employing over 900 people; indirect employment in timber harvesting and haulage accounts for another 2,500 jobs. The company has six mills in the UK (and one in Latvia), including one in Newbridge-on-Wye. It has been involved in sawmilling since 1848. The company is currently implementing a five-year capital investment programme, worth £52m, in modernising the mills and expanding capacity to produce more than 1.3 million m3. As such it is one of the largest buyers of timber in the UK. BSW has invested £6m in the Newbridge mill over the past five years. This has allowed for an extension of working hours and the creation of 29 full-time jobs in addition to the 140 full-time staff already employed at the mill. BSW is supportive of the Welsh Government’s efforts to streamline environmental management in Wales through the creation of a single delivery body. The company has previously set out its concerns about the inclusion of the Forestry Commission Wales (FCW) in the body, particularly regarding the potential for the loss of FCW’s commercial forestry function. Some of these concerns have been addressed by the Welsh Government, however it is important that they continue to be given full consideration as the new Natural Resources Body for Wales is developed. BSW supports the Welsh Government’s proposal that the body will be subject to the FC’s ‘balancing duty’ in regards to forestry work. It is important that the ‘development of afforestation, the management of forests and the production and supply of timber’ are given the focus they need within the body to support the commercial forestry sector. The alternative approach of removing the balancing duty and only maintaining ‘the duty to have regard to the desirability of nature conservation’ would potentially damage the necessary commercial functions of the body regarding forestry. It is important that there is a statutory duty for the body to develop those commercial forestry aspects so that the forestry sector remains confident in continuing to invest in Wales. By maintaining the balancing duty the Welsh Government will help to provide that confidence. BSW also supports the proposal in the consultation document that ‘In managing forestry the new body will continue to take account of the needs of both timber production and public access in much the same way as the FC does currently.’ BSW is supportive of efforts to increase public access to forestry but it is important that the right balance is maintained between access for the public and access for commercial timber requirements. It is positive that the Welsh Government recognises this and will be looking to maintain this balance as it currently exists in FCW. Although BSW appreciates that the Welsh Government will be maintaining the balance between public and commercial forestry access this is not specifically outlined in Box 3. This is implied by paragraph (2) (b) (i) ‘applies only to the extent that it is consistent with any other duty imposed on the NRBW by an enactment’, however there is no explicit mention of a duty to ensure the needs of commercial forestry in terms of timber production are taken into account as well as public access requirements. BSW believes that the forestry sector would feel more confident in the body if this point were made more specifically in the second order. Question 3: Do you agree with these proposals for the high level forestry duties? Yes/Mainly/ Not at all If not how would you change them? : It is positive that the Welsh Government recognises the importance of transferring the duty to promote forestry interests to the new body. Similarly BSW supports the transfer of management powers of the Welsh Ministers’ woodland estate, the duty to promote woodland cover and, crucially, the ‘support of forest industries through the management of forests and the harvesting of timber products’. These are all vital powers and duties for the forestry sector and therefore it is positive that current proposals are to ensure that they are maintained by the new body. However, what is unclear from the consultation document is if FCW’s power to give unrestricted assistance or advice on the general planting/management to woodland and forest owners will also be transferred. It is important that this is also transferred so that woodland owners will continue to have consistent access to expert forestry advice and guidance. Although the proposals for the high level forestry duties are generally positive BSW is concerned by the proposal to make the Welsh Ministers the competent authority for the protection of forest trees and timber from pests and diseases. This is a role currently held by FCW who provide significant research and key operational responses on pests and diseases. Although the new body will have ‘explicit powers’ to ‘implement legal orders made by the competent authority’ BSW is concerned that making decision making the responsibility of Welsh Ministers, rather than the forestry experts working for the body, may create bureaucracy that delays decisions and actions being implemented. This could be costly for the forestry sector and Welsh woodlands as a whole. In order to provide the best response to pest and disease outbreaks and avoid any detrimental long-term impacts to Welsh forestry it would be better for the new body to take on the role of competent authority in the same way that it is taking on the rest of FCW’s powers and duties. Question 4: Do you agree with the general proposals for cross-border arrangements? Yes/Mainly/ Not at all If not what would you change? : It is positive that the proposals recognise the need to have cross-border agreements for operational issues such as managing plant health and to ensure powers for FC to share data with the new body and vice versa. One of the crucial aspects of the work of FCW and the FC as a whole is on research and actions to eradicate forest diseases and pests. It is vital that this is not lost in the new body and that links are maintained with the wider FC to maintain the work that is currently undertaken in Welsh forests. This is a crucial matter for Welsh forestry and therefore BSW believes that a more specific proposal for addressing pests, diseases and forestry research across borders should be included in the second order. In addition, it is also important that the Welsh Government bears in mind the need to protect any other existing UK wide arrangements within the wider FC. It is possible that merging FCW will result in the eventual dissolution of FC as a whole; in this event it will be essential that there is a UK wide body that has an overview of forestry at a national level in order to maintain the valuable national functions of the existing FC and ensure the best outcomes for Welsh and UK forestry in the longer term. Question 5: Do you agree with the proposals for the statutory consultee role? Yes/Mainly /Not at all If not what would you change? : Question 6: Do you agree with the proposals to provide internal separation of decision-making, improve transparency and ensure Welsh Ministers have the opportunity to call in significant issues? Yes/Mainly/Not at all If not what would you change? : Question 7: Do you agree with the proposals for permitting? Yes/Mainly/Not at all If not what would you change? : Question 8: Do you agree with these proposals for charging? Yes/Mainly/Not at all If not what would you change? : Question 9: Do you agree with the proposals for public registers? Yes/Mainly/Not at all If not what would you change? : Question 10: Do you agree that the new body should be a listed body under the Regulatory Investigatory Powers Act 2000? Yes/Mainly/Not at all Question 11: Do you agree that the new body should have powers to use civil sanctions? Yes/Mainly/Not at all Question 12: Do you agree with the proposals for appeal arrangements? Yes/Mainly/Not at all If not what would you change? : Question 13: Do you agree with the proposals for cross border monitoring? Yes/Mainly/Not at all If not what would you change? : Question 14: Do you agree with the proposals for statutory planning and reporting? Yes/Mainly/Not at all If not what would you change? : Question 15: Do you agree with the proposals for Civil Contingencies and Control of Major Accident Hazards (COMAH)? Yes/Mainly/Not at all If not what would you change? : Question 16: Do you agree with the proposals for UK wide arrangements? Yes/Mainly/Not at all If not what would you change? : Question 17: Do you agree with the proposals for transitional arrangements? Yes/Mainly/Not at all If not what would you change? : Question 18: If you have any related issues which we have not specifically addressed, please use this space to report them : NATURAL RESOURCES BODY FOR WALES – ADDITIONAL CONSULTATION OCTOBER 2012 1 Natural Resources Body for Wales – additional consultation Welsh Local Government Association – October 2012 INTRODUCTION 1.