This is a post by Guy Shrubsole. Photo: Sticta sylvatica, a temperate rainforest lichen, taken by the author near Colliford Reservoir, Bodmin Moor, Cornwall.

Recently I was contacted by DEFRA, who are consulting ‘stakeholders’ about a possible new Trees Action Plan for England. This made me feel quite old and tired, because I campaigned a lot on the government’s previous England Trees Action Plan when I worked on Friends of the Earth’s trees campaign in 2019-20. As Rust Cohle said in True Detective: “Time is a flat circle. Everything we’ve ever done, or will do, we’re gonna do over and over and over again.”

Anyway, it was nice of DEFRA to ask me to input my thoughts to a new Tree Action Plan – or rather, I should stress, potential new Plan: even that’s not certain yet [UPDATE 1st Dec 2025: the Government today confirmed in their Environmental Improvement Plan that they will be publishing a new Trees Action Plan in 2026]. But I hope DEFRA do produce a new Plan, because the last one left a lot to be desired. And there’s plenty the Government needs to be doing on trees and woods, from restoring England’s temperate rainforests and plantations on ancient woodlands, to better supporting the natural regeneration of trees and scrub (rather than just tree-planting).

To be clear, this isn’t a public consultation (as yet), but as a believer in transparency and openness, I’m publishing here what I submitted. Perhaps it will inspire others to push for these things too.

So, with apologies for the dryness of tone and policy-wonk language, here’s what I sent to DEFRA:

1) “Spatial targeting for biodiversity” & overall priority of the Trees Action Plan

It’s essential that the next Trees Action Plan for England sets out clearly how the creation of woodlands and treescapes will be spatially targeted to maximise benefits for biodiversity. This must be the Plan’s overriding priority, because the Government has made multiple commitments to meet pressing biodiversity targets, including:

• The Government’s international commitment to meet 30×30 (protecting 30% of England’s land and waters for nature by 2030);
• The Environment Act’s 2030 species abundance target (“By the end of 2030, we will halt the decline in species abundance”);
• The Government’s commitment in its updated Keepers of Time policy (2022) to “restore or gradually restore the majority of plantations on ancient woodland sites to native woodland by 2030”;
• The Environment Act’s 2042 wildlife-rich habitat restoration or creation target (“By the end of 2042, we will restore or create in excess of 500,000 hectares of a range of wildlife-rich habitats outside protected sites, compared to 2022 levels”);
• The Government’s commitment under the current Environmental Improvement Plan 2023 to “restore 75% of protected sites to favourable condition by 2042” (the forthcoming revised EIP may update this goal).

DEFRA’s consultation on the Trees Action Plan currently seems framed in terms of how to “meet our statutory tree canopy and woodland cover target” under the Environment Act, which is for England to reach 16.5% tree and woodland cover by 2050. But in fact, all five of the biodiversity targets listed above are much nearer-term and hence more urgent than the 2050 trees target. These near-term biodiversity targets should instead be the focus of the next Trees Action Plan. After all, the previous England Tree Action Plan lasted from just 2021 to 2024, so it is hardly realistic to pretend that the next one will be a long-term strategy.

Indeed, given that the next election is due in 2029, the current Government will face acute political embarrassment if it remains clearly off-track to deliver on its international commitment to meet 30×30 and legally-binding 2030 species abundance target. At present, it is very far off meaning either of these. DEFRA’s own statistics show that just 7.1% of land in England currently counts towards 30×30. Meanwhile, DEFRA’s latest Indicators of Species Abundance for England show a deteriorating trend over the long term (1970 to 2023), and little or no overall change over the short term (2018 to 2023), rather than any signs of recovery.

The next Trees Action Plan for England should therefore set out very clearly how the Government’s work on woods and trees will help meet these pressing goals. Fortunately, there are ways that the creation of woodlands and treescapes can be spatially targeted to deliver optimal biodiversity benefits, help meet multiple targets simultaneously, and therefore deliver greater value for money. In particular:

A) Expanding England’s temperate rainforests

• As the Government’s Temperate Rainforest Strategy for England (2023) recognises, “The United Kingdom is home to globally rare temperate rainforest habitat… We have a very suitable climate for this unique habitat, which is home to many rare species of plants and other wildlife, but research indicates it now covers less than 1% of land in Great Britain.”
• JNCC guidelines for the designation of SSSIs recognise the importance of temperate rainforest for its assemblages of lichens and bryophytes, and state that the UK has an “international responsibility” for “temperate rainforest”, noting: “Woodlands along [the UK’s] Atlantic fringe are the European headquarters for lichens with oceanic and, most importantly, hyper-oceanic distributions”.
• DEFRA’s Land Use Consultation (January 2025) noted that “England has a variety of woodlands, from productive conifer stands to temperate rainforests” (Analytical Annex, p.5).
• Climate Minister Katie White visited a temperate rainforest restoration project in West Yorkshire in November 2025, commenting: “Did you know that Britain has temperate rainforests?… we’re looking at how we can restore and support rainforests from Brazil to Britain.”
• 8 of the 56 Landscape Recovery projects given government funding under rounds 1 & 2 of LSR include temperate rainforest restoration as part of their proposals (see list of these projects here) – thereby further demonstrating that the government recognises this to be a crucially important habitat to restore. These 8 projects, however, are only a drop in the ocean compared to the scale of restoration work required.
• As research by Leeds University has shown, “the UK has more potential for restoration than anywhere else in the world as it hosts a quarter of the world’s unforested temperate rainforest climate zone”. 
• The next Trees Action Plan must therefore re-state the importance of England’s temperate rainforests and our international responsibility for protecting and restoring them, and set out fresh policies for doing so.
• The Trees Action Plan should set a goal of doubling the area of England’s temperate rainforests by 2050. Because of the species-richness of our rainforests, this will help focus woodland creation in areas where there is the greatest opportunity for win-wins on biodiversity and carbon, as well as of course contributing to overall woodland creation goals.
• The Trees Action Plan should also establish a ringfenced, spatially-targeted fund for restoring and expanding England’s temperate rainforests. This fund should be open to applicants in the key counties containing England’s temperate rainforest climatic zone – Cornwall, Devon, Cumberland and Westmoreland (or, alternatively, regionally defined as South West and North West England).
• England’s rainforest zone has been mapped here, and is the subject of ongoing research commissioned by Forest Research. It is not, however, necessary to wait for the completion of this research to be able to spatially target funding for rainforest expansion and restoration to these English counties or regions. Indeed, until they closed, the Regional Woodland Restoration Innovation Funds for the South West and North West encouraged applications for the “restoration of temperate rainforests along England’s Atlantic fringe”.

B) Restoring Plantations on Ancient Woodland Sites

• A second way in which government support and funding for woodlands can be spatially targeted for biodiversity is by prioritising funds for restoring Plantations on Ancient Woodland Sites (PAWS).
• The Government’s Keepers of Time policy (2022) “recognise[s] the value of ancient and native woodlands and ancient and veteran trees in England”, given the immense biodiversity value of ancient woodland.
• However, the Government remains far off-track from delivering on the goals and targets set for PAWS restoration in Keepers of Time. In particular, it is not set to meet its commitment to “restore or gradually restore the majority of plantations on ancient woodland sites to native woodland by 2030”.
• Latest Forestry Commission indicator statistics show that *zero* hectares of privately-owned PAWS woods were restored in 2024-25 (and just 6 hectares in 2023-24 and 1 hectare the year before)– an astonishing policy failure if correct; and if the figures are incorrect, baffling that accurate statistics are not being properly recorded by the FC over a period of several years.
• Nor is Forestry England on track to meet its own goals for PAWS restoration on the Public Forest Estate. Forestry England owns 42,814 hectares of PAWS woods – around a fifth of the total Public Forest Estate in England[*]. The Environmental Improvement Plan 2023 restated a previous commitment that “Forestry England will continue to deliver its commitment to restore all 42,814 hectares of its PAWS”. No date was given for meeting this target, though to be consistent with the overall PAWS goal for England, it would presumably have to be 2030. But analysis of Forestry England’s statistics by the NGO Wild Card shows that “Forestry England will not be able to fully deliver on this target until 2111, more than 80 years late.”
• This is particularly embarrassing for the Government after it this year launched the new National Estate for Nature Group, chaired by DEFRA’s Nature Minister and comprising the owners of c.10% of England – encompassing private, third sector and public bodies, and including the Forestry Commission & Forestry England. All members of the National Estate for Nature Group have committed in its Terms of Reference to “support the delivery of the terrestrial Environment Act targets and related nature recovery objectives such as 30by30, through action on members’ own estates”, pledging to “hold each other accountable on progress”. Members have committed to publishing estate management plans by April 2026; for public sector landowners, this will be the Cross-Government Nature Strategy (CGNS), which is being led by DEFRA. Given its size, the Public Forest Estate has a particularly important role to play in the CGNS; and given how a fifth of the Public Forest Estate is PAWS, it is vital that work to restore this vast area must be expedited. It will be politically embarrassing for the Government to lag behind the other private and third sector landowners represented on the National Estate for Nature, when the public sector should be leading the way in meeting the Government’s own environmental targets.
• The next Trees Action Plan must therefore prioritise work to restore PAWS, particularly on the Public Forest Estate. It should restate the importance of PAWS restoration, and restate the Keepers of Time commitments for PAWS restoration (specifying clearly that Forestry England’s target for PAWS restoration on the Public Forest Estate is 2030). It should refer to the Cross-Government Nature Strategy and National Estate for Nature group, making reference to CGNS spatial plans for the Public Forest Estate and PAWS restoration therein.
• The Trees Action Plan should announce fresh grant funding for Forestry England to expedite PAWS restoration work.
• The Trees Action Plan should also increase the payment rates available for Countryside Stewardship option WS2 (Manage and restore plantations on ancient woodland sites supplement), to cover the true cost of restoring ancient woods.

2) Ensuring that “grants / funds to support woodland creation and trees outside woodlands” prioritise funding for rainforests, PAWS restoration and natural regeneration

• The new Trees Action Plan for England should set out how DEFRA are allocating the £816m announced for trees in the Spending Review.
• As proposed above, the Trees Action Plan should ringfence spatially-targeted pots of money for temperate rainforests and for PAWS restoration.
• In addition, the Action Plan should announce an increase in funding for natural regeneration, not just tree planting. This is funding that should be available anywhere in England, rather than needing to be spatially targeted.
• Establishing woods, scrub and scattered trees through natural regeneration (also sometimes called natural colonisation), rather than simply through artificial planting of saplings, has many benefits for biodiversity.
• Scrub – the ‘advance guard’ of bushes, shrubs and scattered trees that gets established when open ground is colonised by seeds – is a very important transitional habitat in its own right (e.g. scrub is a vital habitat for Red-Listed nightingales in SE England, and Red-Listed cuckoos across the UK).
• Natural regeneration leads to a better age structure of woods (artificial planting tends to take place in one or two seasons, whereas self-seeding takes place continually), greater structural diversity (scattered trees, ecotones and edge effects rather than uniform planting), and greater species diversity.
• The natural colonisation / regeneration grant introduced under the English Woodland Creation Offer (EWCO) in 2021 has been welcome, but as the FC’s stats show, 95% of EWCO funding to date has gone to tree planting, and only 5% to support natural regeneration.
• The Trees Action Plan should announce that the EWCO natural regeneration grant will be changed to fund regeneration up to 150m from a seed source (not the current 75m rule), and for the grants to last 20 years, rather than the current 10 years.
• It’s currently unclear when or if EWCO will come to an end, or if it will be replaced by new grant options under ELMS. Either way, EWCO’s natural regeneration grants have been seriously under-promoted by the Forestry Commission in favour of tree planting. The Trees Action Plan should transfer administration of the EWCO grant and any replacements from Forestry Commission to Natural England.
• The Trees Action Plan should instruct the Forestry Commission to change the terms of the Woodland Carbon Code (WCC), which penalises natural regeneration. The WCC expects “stocking density of at least 400 stems per hectare” by year 5, an unfeasibly high density which reflects the WCC’s bias towards plantation forests with low light levels and low biodiversity. By contrast, the EWCO natural regeneration grant allows for a much lower stocking density of 100 stems per hectare by year 10: this is the level the WCC should be changed to.

3) Changing the model used that discourages more trees in England’s uplands

• Forest Research’s Ecological Site Classification (ESC) tool is often used to carry out spatial modelling for tree growth potential.
• Whilst the ESC rightly excludes areas of deep and shallow peat from artificial tree-planting, its methodology appears to generate a blanket exclusion of trees from vast areas of the uplands. This is irrational, as it means ruling out even the natural regeneration of scattered trees on upland mineral soils.
• Across Europe, upland habitats generally have far more trees than England’s uplands do today. A visit to south-west Norway would confirm how poor the ESC model is, and how it’s predicated on an unnatural baseline. Historically, England’s uplands have been cleared of montane scrub, birch forests, juniper woods, temperate rainforests, willow carr woodland and many other valuable treescapes.
• The ESC model therefore artificially constrains projects to allow natural regeneration (and limited planting) to restore these lost habitats.
• I recommended in my evidence to DEFRA’s Land Use Consultation earlier this year that the ESC model be replaced with an English version of Scotland’s Native Woodland Model, developed by the James Hutton Institute and Nature Scot. The Native Woodland Model is also based on soil type, climate, NVC woodland types and so on. But it suggests that only a small proportion of the highest and rockiest peaks in Scotland are truly unsuitable for trees – about 3% of the Scottish land mass. It recognises that historically, trees, woods and scrub would have existed virtually everywhere else: from high-altitude birch and pinewoods, to scattered trees growing even on deep peat soils.
• It’s my understanding that DEFRA has been investigating a replacement model for the ESC, and I hope that the publication of the Land Use Framework and the new Trees Action Plan will lead to a new, more ecologically appropriate spatial model being announced. 

4) “Encourage people to engage with our treescapes” – extend public access

• Recent analysis published by Forest Research shows that 73% of woodlands in England have no known public access. Just 26.6% of woods do have public access: either Forestry Commission woods dedicated as Access Land under section 16 of the Countryside and Rights of Way (CRoW) Act 2000, or woods through which public rights of way pass. The Trees Action Plan should acknowledge these figures on lack of access to woods.
• This extraordinary lack of public access to woodlands is clearly untenable. The Government was elected on a manifesto that pledged to “improve responsible access to nature”. It should do so by legislating for a right of responsible access to all woodlands in England, and to the wider English countryside.
• The Government is expected to consult on access reforms through a forthcoming Access Green Paper, but the Trees Action Plan provides another opportunity to also announce an extension of the right to roam in woods, amongst other landscapes.

---

[*] My calculations for the size of the Public Forest Estate in England (which is around 198,000 hectares or 489,000 acres – see Who Owns England?, 2019, p.297); figure for PAWS woods owned by Forestry England comes from the EIP 2023, p.49.