About a third of RCT is already wooded. This is very unusual for a heavily populated area. Even our towns have moretrees than most towns in Wales.

Do you think the Council is right to focusresources on protecting and managing existingtrees? Especially older and larger trees which arestoring the most carbon and providing thegreatest climate mitigation benefits for residents?

Yes, we are happy that the Council aims to focus resources on protecting existing trees, especially older and larger trees. Friends of the Earth Pontypridd wrote to RCT CBC earlier this year, on behalf of our members, regardingcare for established trees across RCT. Our members are extremely concerned about the protection of established trees and consider the scale of the tree felling that has taken place in the borough in recent years to be excessive.
In the Pontypridd area, for example we would point to the felling of trees in Ynysangharad
War Memorial Park, alongside roads, rivers and railways and before the inspection of the
White Bridge on Berw Road (despite written assurances that no tree felling would be needed there).
Residents of the Rhondda and Cynon Valleys have mentioned the same concerns. Looking forward, the decision RCT Councillors took on the Cynon Valley bypass will result in a road that passes through Tir Mawr a Dderi, Lwydcoed SSSI and impacting an area of Ancient Woodland which contains trees covered by a Tree Protection Order. We cannot allow developments of this kind to take the lives of ancient, protected trees within and around an SSSI.
Too often planners and developers fail to consider the value of standing trees on development sites. The Local Development Plan must ensure that development plans on sites with standing trees are modified to incorporate the trees into the design of the site. It is not good enough to cut down standing trees and plant saplings in their place. Where trees
are incorporated in paved areas they must have access to structured soil. During construction of developments or maintenance work, extra steps must be taken to protect trees from damage.
Our tree monitors note with grave concern that many apparently healthy trees have been marked with an orange X for removal. We would like to see a holistic Tree Care Plan for RCT which includes care for all established trees. It will take very many years for newly planted trees to sequester significant levels of carbon and the science shows that a tree’s carbon absorption rate accelerates as it ages.
As well as impacts on biodiversity, the natural landscape, carbon sequestration, air quality and oxygen generation, felling trees impacts on the ability of land to absorb the increased rainfall that we expect to see as a result of climate change. That means felling trees increases the likelihood of flooding.
Friends of the Earth Pontypridd want to see all options considered before any tree is cut down. Policy needs to shift, so that our local trees are seen as a natural resource that we need to preserve. During the pandemic, people have spent much more time close to home and they have come to value the local environment as never before. It’s important that you listen to their concerns. Trees, in particular, greatly improve our quality of life. Many of the trees that have been felled were loved and enjoyed by local people, bringing benefits to mental health and wellbeing and a close connection to nature. In certain instances, a tree may need to be felled, for example where the tree becomes storm damaged and is therefore a risk to public safety. Otherwise, the presumption should be that our mature trees will be cared for.
We want to see local people involved in and informed about decisions on tree felling (unless the tree poses an immediate risk to public safety).

Council’s have lots of responsibilities regarding trees, not only for the trees on Council land (like parks & schools), but also for roadside trees, trees on development sites & protected trees. The draft strategy proposes that the Council should consider the long term benefits of trees and other natural habitats in tackling the Nature and Climate emergencies.

Do you agree that the Council should take this approach?

Yes, the long term benefits of trees and other natural habitats should be considered and these are not limited to the nature and climate emergencies. RCT CBC is yet to officially recognise and declare a Nature and Climate Emergency. This would be a first step in enacting the proposal outlined here. We would also recommend that RCT CBC adopt the principles outlined in the recent Friends of the Earth report on trees in the UK. [1]

There is a temptation to use tree-planting schemes and forested land to “offset” the ongoing failure to end dependence on fossil fuels. Yet carbon emissions from burning fossil fuels will remain in the atmosphere for hundreds or thousands of years, whereas carbon locked up in forests is less permanent due to losses from pests, fires, storms and human activities. In other words, you cannot offset fossil fuel emissions with tree planting. And attempting to do so risks higher cumulative emissions and provides an excuse to further prolong the use of fossil fuels.

The draft strategy suggests we should focus tree planting initiatives in the built up areas. This would provide the greatest climate, nature & wellbeing benefits for local people and businesses. Areas where there is less than 15% tree cover would be a priority.

Do you think the Council should focus tree planting in the areas where people live and work and especially where there are not many trees already?

Yes, it seems logical to prioritise areas of low tree cover but this must be undertaken following discussion with local people and businesses. It is essential to engage the community in tree planting initiatives, especially in built up areas to understand where the best locations for tree planting may be and any concerns residents may have. Engaging with the community is essential to gain buy-in and engender care for establishing trees. On new developments, the Woodland Trust recommend a target canopy cover of at least 20 per cent will be pursued through the retention of important trees, appropriate replacement of trees lost through development, ageing or disease on a ‘two for one’ basis and by new planting to support green infrastructure. [2] Perhaps a minimum of 20% cover could be considered for all built up areas, not least to support cooling during heatwaves.
A street tree planting programme offers opportunities to look at integrating other infrastructure at the same time for example Electric Vehicle Charging on streets. Where urban trees are planted in paved areas they must have access to structured soil and sufficient canopy space. Thought must be given about how any trees planted will be cared for, including watering in dry weather. This could be achieved through development of rainwater harvesting systems from nearby buildings to store water for use in times of drought.

Do you agree with the 6 aims in the draft strategy?

Protecting existing trees & woodland

All new development should integrate important existing trees. Development which would result in the loss of ancient woodland, aged trees or veteran trees should not be permitted. For trees at risk, can RCT CBC provide a map of high risk trees in the borough and use it to begin a conversation with residents about the trees, the benefits they bring and the risks they pose?  The purpose of having these proactive conversations is to prepare communities for necessary safety works and to highlight to the council instances of special value or opportunities to do work differently. In addition, we would like the strategy to include detail on how RCT CBC will protect existing trees and woodland on a global level through it’s supply chains and investments – see recommendations below on how this can be supported through Size of Wales Deforestation Free Procurement Toolkit.

Encouraging natural regeneration or colonisation to increase tree cover.

We welcome the encouragement of natural regeneration but this approach cannot be relied upon for growing timber. The strategy needs to include detail on how RCT CBC will work with local landowners and the community to grow timber sustainability to reduce reliance on imports for construction and heating.
In terms of increasing woodland cover without affecting existing semi-natural habitats, is it possible for RCT CBC to pro-actively approach land-owners to see if they are prepared to sell their land or enter into schemes that deliver woodlands for a range of benefits? Currently, engaging landowner to increase tree cover is not being done adequately. 

Increasing urban tree cover especially where below 15%

It seems logical to prioritise areas of low tree cover but this must be undertaken following discussion with local people and businesses. It is essential to engage the community in tree planting initiatives, especially in built up areas to understand where the best locations for tree planting may be and any concerns residents may have. Engaging with the community is essential to gain buy-in and engender care for establishing trees. On new developments, the Woodland Trust recommend a target canopy cover of at least 20 per cent will be pursued through the retention of important trees, appropriate replacement of trees lost through development, ageing or disease on a ‘two for one’ basis and by new planting to support green infrastructure. [3] Perhaps a minimum of 20% cover could be considered for all built up areas, not least to support cooling during heatwaves.
A street tree planting programme offers opportunities to look at integrating other infrastructure at the same time for example Electric Vehicle Charging on streets. Where urban trees are planted in paved areas they must have access to structured soil and sufficient canopy space. Thought must be given about how trees planted will be cared for, including watering in dry weather. This could be achieved through development of rainwater harvesting systems from nearby buildings to store water for use in times of drought.

Looking after ancient hedges

Providing a framework for decision making

We would like to see a transparent framework for decision making that involves local people and proactively informs communities about decisions on tree felling and tree planting.

Forestry guidance on ash die back

We are concerned by the numbers of seemingly healthy ash trees being felled across RCT. Forestry Commission guidance states that ‘with the exception of felling for public safety or timber production, we advise a general presumption against felling living ash trees, whether infected or not. This is because there is good evidence that a small proportion will be able to tolerate H.fraxineus infection’. [4] Trees with a natural immunity to ash die back or able to recover from an infection will undoubtedly be important in helping the ash population to recover in future. This is why the widespread felling of entire ash trees over recent months is so concerning.

The draft tree strategy 25 point Action Plan – Do you agree with the 25 point Action Plan?

Action 1: Create a cross-disciplinary working group. We would like to see community representation in the monitoring of the action plan and the Cross-disciplinary working group.
There are many different community groups with different areas of expertise that it would be good to bring into this working group.

Action 11: Develop and adopt a Tree Risk Assessment Management tool for making decisions about tree felling, pollarding, pruning and coppicing. Members of Friends of the Earth Pontypridd would also like this to include detail on the use of Ecoplugs and in particular their impact on the health of neighbouring trees. As indicated previously, this could include a map of high risk trees to enable proactive conversations with local communities.

Action 14: Establish a robust partnership and community engagement programme. This action is key to successful delivery of the strategy and offers significant opportunity. Many people have a special relationship with trees, especially mature trees which act as landmarks or have heritage or cultural significance. As detailed elsewhere in this response, more needs to be done to engage local communities to foster a better understanding of trees and woodland, their importance to our wellbeing and how best to care for them. There is a significant opportunity to engage the community in seed saving initiatives, community tree nurseries, accessing land to support sustainable growing of timber, food, supporting biodiversity. This could be supported by organisations like Llais y Goedwig [5] and Coed Lleol [6] for example.

Any other further comments or suggestions regarding the draft tree and woodlands strategy, please write below:

Growing timber
Less than 20% of wood consumed in the UK is homegrown, the rest is imported making the UK a major global importer of timber and wood products. Wood is used for a wide variety of purposes, from housebuilding to furniture-making to paper manufacture. RCT CBC can ensure it is helping to protect trees and rainforest on a global level through it’s supply chains and investments for example by implementing recommendations in the Size of Wales Deforestation Free Procurement Toolkit. In addition, RCT can work with local landowners and the community to grow timber sustainability to reduce reliance on imports for construction and heating and to support agroforestry and biodiversity. There are excellent local examples of community woodland initiatives, for example Welcome to our
Woods. [7]

We urgently need to grow more timber and deepen our woodland resources. While natural regeneration of trees is welcome, it cannot be relied upon to grow timber. Working with Natural Resources Wales to make best local use of the public forest estate is also an important action in this regard.

Global impact

At COP26, Welsh Government Minister for Climate Change made a commitment for Wales to become a deforestation free nation. To deliver on this commitment would require public bodies in Wales to do all they can, within their decision making ability and power, to eliminate imported deforestation from supply chains and investments. In practice, this means:

• Ensuring all public procurement is deforestation free.
• Ensuring that all investments, including pension funds do not contribute to deforestation overseas.
• Introducing sustainable food policies and practices that do not contribute to overseas deforestation (addressing the use of soy in animal feeds in particular). [8]

Doughnut economics four lenses
In order to highlight some of the considerations needed for a more globally responsible tree strategy, we have used doughnut economics tools. Doughnut economics offers a vision of what it means for humanity to thrive in the 21st century and supports the mindset and ways of thinking needed to get us there. The Doughnut acts as a compass for human prosperity in the 21st century, with the aim of meeting the needs of all people within the means of the living planet.
The Doughnut consists of two concentric rings: a social foundation, to ensure that no one is left falling short on life’s essentials, and an ecological ceiling, to ensure that humanity does not collectively overshoot the planetary boundaries [9] that protect Earth’s life-supporting systems. Between these two sets of boundaries lies a doughnut-shaped space that is both ecologically safe and socially just: a space in which humanity can thrive. Unrolling the doughnut provides a framework for thinking about how to ensure the Tree Strategy delivers maximum benefits across each of the 4 lenses created. Doughnut economics four lens approach (see appendix) asks us to reflect on:

• a. How [the draft tree strategy] supports the wellbeing of the people that live [in RCT] so that we are all able to thrive? (local social foundation)
• b. How can [the draft tree strategy] be as generous as the wildland around us in supporting nature to thrive? (local ecological ceiling)
• c. How can [the draft tree strategy] respect the wellbeing of all people? (global social foundation)
• d. How can [the draft tree strategy] respect the health of the whole planet? (global ecological ceiling)

Appendix

Doughnut Economics Four Lenses

^[1] https://policy.friendsoftheearth.uk/sites/default/files/documents/2022-06/Trees%20Report%20Final%20220622.pdf   

^[2] https://www.woodlandtrust.org.uk/media/1762/local-authority-tree-strategies.pdf

^[3] https://www.woodlandtrust.org.uk/media/1762/local-authority-tree-strategies.pdf

^[4] https://www.forestresearch.gov.uk/tools-and-resources/fthr/pest-and-disease-resources/ash-dieback-hymenoscyphus-fraxineus/

^[5] https://llaisygoedwig.org.uk/

^[6] https://www.smallwoods.org.uk/en/coedlleol/

^[7] https://welcometoourwoods.org/

^[8] https://cdn.sizeofwales.org.uk/wp-content/uploads/2020/11/Eng_deforestation-free-nation_Final.pdf

^[9] https://www.stockholmresilience.org/research/planetary-boundaries/the-nine-planetary-boundaries.html

^[10] https://cdn.sizeofwales.org.uk/wp-content/uploads/2020/11/DFN_Toolkit-_Final_2021_Eng.pdf

^[11] https://www.wwf.org.uk/sites/default/files/2021-11/wwf_risky_b_wales.pdf

^[12]https://pont-mbale.org.uk/what-we-do/environment/