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Forest policy in Scotland: will new regulations help a peat paradigm shift?

At RE-PEAT, we’re keen to find out more about how forestry policy interacts with peatland preservation in the UK. This blogpost gives a context for UK Anthology Series #2 on Peatland and Forestry from south west Scotland. Kate Foster lives in Southern Scotland and has noticed much new tree plantation in the uplands. Moorland which has been long been used as grazing is being converted to tree plantation. Big changes in the landscape occur as it becomes industrialised for larger scale commercial operations. Kate became increasingly concerned as she read up about the situation. But then as a more cheerful postscript, she learnt that new regulations might prevent further tree plantation on deep peat: consideration of organic soil depth and tree cultivation methods are really important. RE-PEAT aims for a paradigm shift; possibly this can be glimpsed in the details of this new forestry guidance.

This photo of a former bog in Galloway shows how conifer plantations on peat bogs are wrong. The bog-moss dies, the trees are stunted and fall over, and the carbon is lost from the peat.


Scotland contains unique peat resources that hold huge amounts of carbon. This year, it will host the international Climate Change Conference (COP26).

Peat stores twice the amount of carbon as all forests combined worldwide. So any commercial afforestation which harms peat is a poor decision. Yet this continues in many areas. It is shocking that some of the forestry practices that were found unacceptable decades ago still go on. There is a growing demand that this should halt. Opinions are divided about whether such forestry is economically inevitable, or whether more regenerative land uses are possible.

Some articles caught my attention. One is by Cristopher Nicholson, chair of the Scottish Tenant Farmers Association. He took time to explain the issues behind the forestry, questioning current Scottish climate policy. His question was: Peat, biomass and net zero by 2045. Does it all make sense?

As I read more, I realised ever more acutely why it is high time commercial forestry stopped on deep peat. And the impacts of what has already happened need to be reversed.

It’s frustrating that government policies which claim to be climate-focused are contradictory. Tax breaks and public money subsidise new forestry which causes rough grazing ground to be ploughed up, degrading peaty soils. At the same time public money goes into peatland restoration through the Peatland Action programme. Another issue is that biomass fuels are given public subsidy; yet the biomass industry has negative environmental impacts.

Many people have come to think of tree planting as a climate solution. It may come as a surprise that afforestation is not always good for the environment, and not always the best solution for carbon sequestration.

Planting trees on peatland releases carbon. But afforestation is particularly an issue on peaty soils in the west of the UK. This process is particularly intensive in Dumfries and Galloway, in the south west of Scotland. Commercial conifer afforestation started in this area around 100 years ago and has expanded considerably since the 1950s.

Local people see new plantations for commercial timber, and many are concerned about the resulting environmental damage. For example, new roads for the large-scale operations cut across landscape, and clear-felling causes soil erosion and pollution of rivers and water supplies.

A deep concern for local people is that the new forestry feels like a clearance of communities from the hills, and a way of life too. Unlike hill farming, contemporary plantation forestry doesn’t need people to live locally. Sadly it seems that at the moment mistakes are being repeated without general public awareness and discussion across the country.

Recent afforestation in peatlands, Langholm, Scotland, 2020 / 2021

Photo credits Aeneas Nicholson

Going back to the 70s

The Forest Policy Group regard this situation as a backwards step in terms of sustainability:

Reliance on intensive cultivation is a recurring theme in forestry. We did it spectacularly from the 1960s to the 1980s and were rewarded with plantations that blew down prematurely costing the industry millions, along with sediment in lochs and rivers and, as we now know, large-scale release of soil carbon. (Forest Policy Group, 2019)

Already, in the 1980s, the environmental consequences of commercial afforestation were recognised. Negative impacts were particularly felt in south west Scotland for a combination of reasons. For example, water running off became more acid and freshwater fish were affected badly, although at the time this was blamed on acid rain. There was loss of nesting habitat for wader birds, such as the curlew. The impacts of deep ploughing and ditching led to increased runoff and downstream flooding.

Since then, the evidence has been mounting. Carbon scientists know that if you drain peat, it loses carbon (eg Evans et al., 2017). Water scientists know that ditches running through peatland get peaty and acidic, flood more into rivers, and kill river-life, including salmon (eg Williamson et al., 2021)

Brown (2020), a Scottish policy advisor, warned that “use of simple targets (e.g. trees planted) as headline progress indicators can be misleading, potentially contributing to policy failure.”

Yet the forest industry continues to say there is insufficient evidence, that the data is conflicting, and that the environmental scientists are not well enough informed about forestry.

Does this remind you of how the tobacco industry reacted when people talked about cancer? It is very clear that planting trees on deep peat is a mistake.

2020s - mistakes being repeated with ongoing public funding

Frustratingly, government policy still provides generous taxpayer-funded benefits for commercial forestry to landowners.

Photos from the winter of 2020/2021 show how this is happening on areas of deep peat.

Details of recent afforestation in areas of deep peat, Langholm, Scotland, 2020/2021.

Photo credits Aeneas Nicholson

Even when mistakes are acknowledged, peatland is still being lost:

near Langholm deep peat has been ploughed for a planting scheme approved by Scottish Forestry, around 700 acres thought to be funded by £850,000 of taxpayer support. After being alerted by some locals, Scottish Forestry have put a stop to the works which clearly breach the UK Forestry Standards but it remains to be seen if there will be any reinstatement of peat. (Nicholson, 2020).

Ireland seems to be ahead of the UK, having woken up to the problem that “Ireland’s forestry is a growing source of greenhouse gas emissions rather than acting as a carbon sink”, according to a report produced for the Department of Agriculture (The Irish Times 2020).

So why is the UK so slow? Don’t the forest companies realise that forestry on peat is damaging global climate? Don’t forestry investors realise that they will probably be carbon-taxed for the greenhouse gases they are releasing?

Biomass is not a renewable energy!

As a further complication, many of the newly planted forests are used for fuel. Few people realise that the policy of supporting biomass has resulted in the UK burning more timber each year than is harvested there. An organisation call Biofuelwatch campaigns about this.

People in Southern Scotland are finding out that what is happening to the landscape here is economically linked to the exploitation of forests in other parts of the world:

[The most significant] driver is a renewable energy biomass policy, common across much of Europe, which many now say is so flawed that it is actually advancing climate change and creating global ecological damage: The UK’s biomass power plants now consume each year more timber than is felled in the UK. We rely on wood pellet imports from North Carolina, USA, where vast areas of diverse native woodland are being felled to fuel our biomass requirements, offshoring not only our carbon footprint but also our environmental footprint. Those cleared native woodlands are replaced with monoculture conifers lacking in ecological diversity. (Nicholson, 2020).

Using ‘renewable’ biomass for fuel in Scotland is a long way away from being a regenerative practice.

I sympathise with this perspective:

On the environmental issues around expanding forestry, I support diverse woodland creation - the right trees in the right places. But having spent most of my life in Galloway and witnessed the effect of an ever expanding tide of Sitka Spruce on our flora, fauna and people, I’d say a bit more thought on our forestry policy and practices would be welcomed by many. (Nicholson, 2020).

High time to change forest policy

Political commitment needs to filter down to strengthening regulations. For example, the question: what counts as “deep peat” which is apparently an arbitrary measure, subject to political pressure. The regulatory limit is currently 50 cm (though it seems this is not always enforced). Furthermore, it was made clear recently by DEFRA themselves that they do not have a map of peatlands deeper than 40cm (Avery, 2021)

Of course, from a carbon point of view, all peat needs protection, as it is an almost-fossil fuel. Forestry experts insist there are very strong reasons to limit heavy cultivation of peat to soils under 10 cm - at most.

Recent studies suggest that any net carbon gain from planting on shallow peat will not be achieved until at least the second rotation which takes us to the next century at best. Given that our climate emergency requires us to reach net zero by 2045, planting on shallow peat is counter-productive for that target. (Nicholson, 2020).

In this context, a recent article published on 13 April 2021 came as good news. The Forest Policy Group praised a significant direction of new Scottish Forestry guidance. This group has been busy researching the effects of forestry operations on soil carbon, and what might constitute best climate practice.

The group’s article supports proposed new regulations, in the form of “Applicants’ Guidance for Cultivation for upland productive woodland creation sites.” From both FPG and Forestry Scotland’s research, it now seems beyond doubt that policy on ‘peat biomass and net zero by 2045’ has not made sense.

“ … cultivation and drainage of peaty soils leads to the release of significant amounts of carbon; and where more intensive cultivation techniques are used, there is a high likelihood that more carbon dioxide will be emitted than absorbed by the trees for the next few decades. This means that those techniques would fall foul of Scotland’s efforts to reach net zero carbon by 2045. (Forest Policy Group, 2021)

The proposed guidance reinforces the reasons to limit heavy cultivation of peat to soils under 10 cm. Attention to detail is vital! I began to see how the words in such guidance really shape the landscape. It seems it is really important to minimise drainage. It turns out that could be a a temptation to argue that drainage is ok, and this might be be used as a get-out clause to take advantage of current disjointed subsidy systems. But the Forestry Policy Group would say: No! Draining peat to turn it into forestry is not good for global climate. To reiterate, draining peat releases greenhouse gases from the peat, and damages rivers. Draining peat soils is not the way to achieve carbon-positive forests!

There is also a discussion about the best methods of tree cultivation. I began to have a specific hope, that as I walk in forest areas, I learn to see what the recommended ‘inverted mounding’ looks like!

The Forestry Policy Group see a need for a shift in mindset:

“What is needed is a shift in our professional mindset, from considering peaty soils as unpleasant substandard soils needing remedial action, to them being important large-scale stores of carbon that need to be carefully managed. The task at hand is to enhance their carbon storage potential by carefully adding trees, not to embark on their wholesale alteration in order maximise the early growth of those trees. Sustainable forestry requires a little more patience and skill at the start of the rotation, using cultivation solutions that are more “nature based” and less in hock to forestry’s overly technocratic recent past.” (Forestry Policy Group, 2021)


Writing this has affirmed to me that commercial afforestation of peatlands just cannot be justified. UK forest policies undermine the climate emergency aim of net zero by 2045. The proposed regulations from Forestry Scotland must be enforced to prevent further planting on peat soils. Damaged areas need to be reinstated.

If this does not happen, a climate-damaging policy will continue to be implemented through grants and tax relief, at public expense.

At a local level, I learn that nature-based forestry would make both landscapes and communities more resilient to future changes. It has to be wrong to subsidise forestry to cause climate and environmental damage. Instead, foresters should be regenerating the type of trees that can live on and with peat-forming mosses, such as birch and pine.

RE-PEAT’s call for a paradigm shift is reflected in the details of new forestry guidance. I’m really hoping this guidance helps change patterns of land use in the moorlands!

If you’re interested in forests and peat, join RE-PEAT’s event on Tuesday 27th April from 7-8.30 GMT. Sign up here


Iain Brown, Challenges in delivering climate change policy through land use targets for afforestation and peatland restoration, Environmental Science & Policy, Volume 107, 2020, Pages 36-45.

Christopher Nicholson. Rethink on Forestry’s Failure to Protect Peat. Press and Journal. 29 December 2020.

Forest Policy Group. 30 May 2019. Back to the 70s. Flared trousers & forestry ploughing.

Forest Policy Group. 13 April 2021. Long-awaited Scottish Forestry Guidance on forestry cultivation gets a good “A”

Mark Avery, April 14 2021, DEFRA #omnishambles doesn’t have a clue – for peat’s sake!

The Irish Times, Oct 29, 2020, Irish forestry ‘net emitter of greenhouse gases’,


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