The Woodland Trust welcomes this opportunity to respond to this document. The comments that follow are delivered on behalf of the United Kingdom’s leading charity solely dedicated to the conservation of native and broadleaved woodland. We achieve our purposes through a combination of acquiring woodland and sites for planting and through wider advocacy of the importance of protecting ancient woodland, enhancing its biodiversity, expanding woodland cover and increasing public enjoyment. We own over 1,100 sites across the country, covering around 18,000 hectares and we have 250,000 members and supporters.
The Trust and the Ancient Tree Forum (ATF) are working together in promoting the conservation of ancient trees. The ATF has always pioneered the conservation of ancient trees and is the main UK organisation concerned solely with their conservation.
Ancient trees are trees that because of their great age, size or condition are important in the landscape, culturally or for wildlife. They harbour a unique array of wildlife and echo the lives of past generations of people in ways that no other part of our natural world is able. Ancient trees in the UK represent a very high proportion of the northern European ancient tree population and are therefore of international importance. However ancient trees despite their value for biodiversity are remarkably under protected.
The ATF seeks to secure the long-term future of ancient trees through advocacy of no further avoidable loss of ancient trees, good management of ancient trees, the development of a succession of future ancient trees, and seeking to raise awareness and understanding of the value and importance of ancient trees.
This response is a joint response from the two organisations. We have answered these questions from the perspective of our joint interest in ancient landscapes and ancient trees.
Do the draft lists reflect Welsh priorities and obligations?
Although ancient trees are recognised for their contribution wood-pasture and parkland habitats, we do not believe that the UK BAP process as a whole adequately addresses the importance of ancient trees and decaying wood habitats. This is endorsed by a recent report prepared for the Forestry Commission by the Oxford Forestry Institute: Protected forest areas in the UK, which recognises that the UK is renown for its parkland and urgently calls for a protective mechanism to cover non- SSSI parkland trees and pasture.
Ancient trees and decaying wood habitats are not restricted to wood-pasture and parkland, they are also found in many other woodland and non-woodland situations but they are not recognised in other HAPs. Therefore significant concentrations of ancient trees that exist outside wood pastures and parklands have no mechanism for protection. In a recent survey of a dozen scattered ancient trees in a few fields in Gloucestershire the trees were found to be host to an exceptional array of nationally rare invertebrates making the area of at least UK importance. In addition the scheduled fungus species
Piptoporus quercinus was recorded on one of the trees, a tree that had its roots badly damaged by ploughing. This example demonstrates the importance of ancient trees in our wider countryside.
We recognise that in some circumstances the designation for Registered Parks and Gardens may give ancient trees some protection however this designation is for historic, man- made landscapes which may override the biodiversity value of the ancient trees.
As individual trees, ancient trees are extremely vulnerable. A single ancient tree is not recognised as a distinct habitat and yet one tree can be host to a single species of beetle eg the Moccas beetle. Ancient trees, of any native species, are rare in themselves but, as the tree species itself is not rare, they cannot be protected through rare species legislation. Tree Preservation Order legislation has been used in certain circumstances to protect important landscape trees however there is no guarantee that TPOs will be applied to important ancient trees. A dead standing ancient tree may be exceptional value for biodiversity but would be excluded from TPO legislation.
We therefore consider that much greater attention must been given urgently to reviewing the habitat status and species lists in Wales to reflect the cultural, landscape and wildlife value of ancient trees, decaying wood habitats and their associated flora and fauna.
Can the Woodland Trust contribute to the conservation of the proposed additional habitats and species?
The Woodland Trust owns a number of sites in Wales with ancient trees (give examples?). We recognise the importance of old growth woodland (sites with trees over 200 years old with a continuity of old trees reaching into the past). We are currently researching into ways the protection of ancient trees can be improved and how mechanisms to give owners greater incentives to manage them appropriately could be developed. This research is scheduled to be completed in March 2002.
Suggestions for additional species/ habitats
We welcome the inclusion of four Lobaria species of lichen in the species lists because of their association with ancient trees.
However ancient trees in Wales are host to a great many saproxylic invertebrates that are in Categories 1-3 of Red Data Lists or nationally scarce but many of these are not recognised as SAP species or scheduled under the Wildlife and Countryside Act, 1981. Invertebrate RD Lists were published twenty years ago and are in need of extensive revision and should only be used as a guide and not as a definitive list of species in need of protection. CCW has completed a national survey of parkland in Wales and through this has identified invertebrate species which are associated with a continuity of ancient trees and are indicators of important sites. We would like to see this important work taken into consideration in the review of the SAP lists.
It is also now increasingly recognised that, despite their ecological importance, conservationists have neglected the Fungus Kingdom. There is no current UK Red Data List for fungi. However there are many species of rare fungi which rely on a continuity of ancient trees and decaying wood habitat.
A provisional list of fungus species has been proposed for inclusion in the European Bern Convention. One of the species on this list,
Podoscypha multizonata is a species of parkland with ancient trees and has been recorded on the British Mycological Society database from sites in Herefordshire. We believe all relevant fungus species on the Bern Convention list should be included as species of principal importance in Wales.
We believe there should be an urgent full review of the SAP species lists to include appropriate plants, fungi and animals which reflect the importance of habitats with ancient trees and decaying wood.
Furthermore we would wish to see government agencies actively seeking expertise in invertebrate and fungus ecology to develop policies and strategies to ensure previously under recognised taxa are properly included in the UK BAP process.
Will action plans address conservation needs?
We welcome Habitat Action Plans and Species Action Plans as a mechanism of raising the profile and focusing attention on aspects of our UK biodiversity at risk. We would however strongly recommend that action should be focussed primarily on habitat conservation to ensure continuity of suitable environments for species into the future. We would therefore wish to see greater government funding for implementation of HAPs.
(Would we be prepared to be lead partner for an action plan? Eg Podoscypha multizonata?)
Do we agree with the exclusion of the UK BAP species or habitats that are not relevant to Wales?
In principle we agree with an approach that recognises that the production of an action plan needs to have clear benefits for the conservation of the habitat or species and therefore resources should be concentrated on species of high priority.
What should be the review period for the lists?
We believe that the review process should be timed to ensure that its conclusions dovetail as effectively as possible into reviews of other species and habitat legislation.
The Woodland Trust, Autumn Park, Grantham, Linclonshire, NG31 6LL
http://www.woodland-trust.org.uk
For further information please contact either:
Ed Pomfret on 01476 581 111, Email: edpomfret@woodland-trust.org.uk, or
James Cooper on 01476 581 127, Email: jamescooper@woodland-trust.org.uk
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