1. In the heyday of the Welsh gentry there was at Aber Artro a dower house of the Corsygedol estate.  From beech planted in its grounds may have come the compact beech wood, beautiful in all seasons and spectacular in bluebell time, celebrated in Anne Stevenson’s poem, “May Bluebells, Coed Aber Artro”, and in Dave Newbould’s photograph –

aberartro-woods2.jpg

No more.  The brutal culling of the beech (some felled trees are over 3ft in diameter, no recent arrivals) is captured in Stephen Coll’s photographs (“after-comers cannot guess the beauty been”: Gerard Manley Hopkins, Binsey Poplars felled 1879) –

img_1271_ed.jpg

2. To attempt to unravel the mystery of the damage gratuitously inflicted on Coed Aber Artro (“the Coed”) by Woodland Trust (“WT”) and Countryside Council for Wales (“CCW”) – bodies charged with its protection and wholly or partly funded by the taxpayer – is to embark on a strange and surprising journey to Brussels and back through the ramifications of the EU funded Meirionydd Oakwoods Habitat Management Project (“the Project” – with useful Website www.meirionyddoakwoods.org.uk).  “Holocaust”, “massacre”, “ethnic cleansing” are some of the words used by those appalled at the culling of beech first by CCW at Lletywalter and then by WT/CCW in nearby Coed Aber Artro, the language echoing – is this a coincidence? – a rhetoric, sometimes racial, sometimes romantic, to be found in the Project’s three part Oakwoods Leaflet.  Language, and a rhetoric which disassociates itself from reality, is a key to understanding.

3. The Coed is ultimately governed by the Community Institutions: the Commission in Brussels; the Parliament which divides its expensive time between Brussels and Strasbourg; the Court of Justice in Luxembourg. The role of the EU may come as a surprise.  These rough notes, taken in haste from S. Bell and D. McGillivray, Environmental Law, 7th ed, OUP, 2008, give some idea of the process by which powers drain away from Westminster to Brussels –

There has been a progressive widening of EU powers [185ff].  Single European Act 1986 added whole new title relating to protection of the environment, Arts 174-6, introducing explicit lawmaking powers in relation to environmental matters. Treaty on European Union 1992 (Maastricht) recognized for the first time development of a policy in the sphere of the environment as one of EC’s main activities, Art 3.  Treaty of Amsterdam 1997 continued development of euro environmental policy with new goal in Art 2 of promoting a high level of protection and improvement of quality of environment.

Huge range of environmental Directives includes Birds, 79/409/EEC and Habitats, 92/43/EEC [192-4], the Directives which in terms of direct impact on UK conservation law have had the greatest impact and will continue to be of paramount importance in the future, arguably their greatest impact is in relation to habitat conservation [704].

A central aim of EC law is to designate a Community wide ecological network of sites (“Natura 2000”), consisting of SACs, ie sites containing natural habitat types listed in Annex I of HD and sites containing habitats of species listed in Annex II [705].  These sites are designated, and conserved, under Community law and the legal tool adopted is the Directive, giving member states a certain flexibility about the way in which the Directive’s binding obligations are achieved [704].  Habitat conservation law is one of the most contentious areas of Community law and the HD was only adopted after years of argument within the EC and has been beset by implementation problems.  It has generated more ECJ case law than any other area of environmental law [704-5].

4. The scope of the Project is described in the Website –

There are 58 woodlands and a railway line included in the project area, covering 1,710 hectares. The natural woodlands are considered to be one of the best areas of Atlantic Oak woodland in Europe and so have been designated as candidate Special Areas of Conservation (cSAC)* giving them protection under the Habitats Directive
The woodlands are now remnants of the natural forest that originally covered most of the Atlantic fringe of Europe from Northern Scotland right the way round to Portugal. This coastal fringe is heavily influenced by the Gulf Stream that keeps us warm but wet. The Atlantic coastal climate creates a difference between the oakwoods in the rest of Britain and our Oakwoods. The damp humid conditions create the perfect habitat for ferns, mosses and liverworts (known as bryophytes), lichen and fungi. Some of the species found in our Oakwoods cannot be found anywhere else in the world.
* Once a site has been approved by the European Commission, it is passed back to the member state for confirmation [designation] before 2004. At present no sites in north-west Europe are beyond cSAC stage [but] in terms of legislation, sites which have entered into the consultation process are treated as designated sites.

£2,223,246, half from EU, half from “partner organizations and private landowners”, was to have been spent by September 2008 when the four year project ended.  This is just one tiny part of “Natura 2000” under the Habitats Directive (“HD”) to which EUR 1.35 billion has been allocated across the EU: “10,000 sites covering 35 million hectares of globally important habitat” are to be protected with the commendable aim of “halting any further decline in European Biodiversity”.  The bureaucratic dimensions of this enormous enterprise, with its 23 official languages, can be glimpsed on  <http://ec.europa.eu/environment/nature/info/memberstates_en.htm>.  For anyone wanting to come to grips with the pros and cons of EU notions of “subsidiarity”, this would be a good place to start.

5. The Project’s mindset is quite clearly articulated in the Leaflet (emphasis added, as in later quotations) –

Exotic and Invasive Species  Species that do not grow naturally in Wales are classed as exotics.  Common exotic trees include spruce, Douglas fir, Western Hemlock, Sycamore and Beech.  Typically they grow vigorously and cast dense shade preventing native species from growing … A general rule for managing exotic tree species is that if there are less than 10% of these species you can take most of lantothem out in one go [2, 7].  None of these species are originally from Wales … For example beech is native to South-East England and was spread further afield by the Romans … It is extremely hardy and can survive in exposed conditions [3, 11].  Where these species are encroaching upon native woodland sites mature trees can be slowly removed by felling [3,12].
Invasive shrubs like Rhododendron, Japanese Knotwood and Himalayan Balsam can even release chemicals to kill all other species and actively take over a site … You should tackle invasive species with the aim of completely removing them from site. [2, 7].

The presence “in Wales” of any species being through invasion, we can categorise as legal immigrants those which have arrived naturally, without human intervention, and as illegal immigrants those, such as Beech and Japanese Knotwood, which have been introduced by man.  Note that the test is national or racial.  If a species is naturally present on the Gower Peninsula, it is a legal immigrant and enjoys freedom of movement across the nation.  If its nearest natural presence is in Oswestry, quite the wrong side of Offa’s Dyke, then it is an illegal immigrant, preferably to be taken out in one go.

6.  A romantic, more seductive, alternative, is expressed on the Website –

The sites that aren’t designated for being in a poor condition [ie for this reason not eligible for SAC status] have been selected because they were once part of the original Atlantic Oak wood of Meirionnydd. They offer us some of the best opportunities to expand the oak woods as they still have plants and seeds present related to the original oak woodland. Removing the exotic and invasive species will allow these species to re-colonise these areas restoring them to their former glory.

The theme is developed in the Leaflet –

Natural woodlands are unique because the tree and plant species present have remained largely unchanged since the last ice age [1, 3].
Exotic species refers to species that have been introduced deliberately or unintentionally to an area that lies outside their natural habitat rangeNative species are natural residents of the area and associate with other native species as they have lived and developed together over thousands of years [3,3].  It is thought that invasive species have caused the second greatest loss of biodiversity world wide after man’s influence [3, 4].

That biodiversity is of the essence is something on which the Website is explicit: “the funding for our project is directly linked to improving the biodiversity of the area”.  The Leaflet enlarges –

This leaflet gives a quick guide to managing your woodlands for biodiversity based on the natural woodlands habitat of the North West of Wales – Atlantic oak woods [2].
Natural Woodlands are unique because the tree and plant species present have remained largely unchanged since the last ice age … Natural habitats support the most biodiversity possible in that area, so it is extremely important that we protect and expand what is left of our natural woodland habitat [1, 3].

7. Beech then is an enemy of biodiversity, especially dangerous because “extremely hardy and can survive in extreme conditions”, and so incompatible with “the most biodiversity possible” even though climate change makes it a potential legal immigrant –

There is some thought that with global warming the natural range of beech is spreading north and west towards Wales and so it may be accepted as a native by the middle of the century [3, 11].

The pattern is a familiar one, part of a cycle repeated many times in the last two million years, species advancing north in times of global warming and retreating south in times of global cooling.  After the great thaw at the end of the last ice age “with temperatures rising 70C in only 50 years … Wales gained a steadily changing and diversifying vegetation as successive species spread north to fill newly available ecological niches”, first juniper then birch and hazel, later oak and elm, ash and lime (Steve Burrow, Catalogue of the Mesolithic and Neolithic Collections in the National Museums and Galleries of Wales, 2003: 3).  The rhetoric which treats alike Beech and Sycamore, Japanese Knotwood and Rhododendron, comes out of Alice in Wonderland.  The whole, essentially backward looking, notion of climate stability merits further examination and seems inconsistent with a central thrust of EU policy as expressed on <http://ec.europa.eu/environment/nature/info/memberstates_en.htm> –

There is now broad scientific and political consensus that we have entered a period of unavoidable and unprecedented climate change. Impacts on biodiversity in the EU are already measurable … This requires in particular securing coherence of the Natura 2000 network. Care must also be taken to prevent, minimise and offset any potential damages to biodiversity arising from climate change adaptation and mitigation measures.  One of the 10 objectives of the Biodiversity Action Plan is to support biodiversity adaptation to climate change.

In other words, species are once again on the march northwards.

8. For present purposes the aim is to understand how the prevailing ideology, coupled with the availability of EU funding, bears on the treatment of the Coed.  Fortunately we have helpful explanations of their viewpoints from both WT and CCW.  This is WT –

The fundamental underlying issue is the future of the sessile oak woodlands in Snowdonia in the face of an inexorable natural process which is leading to the replacement of the oak with beech.  This has been happening for some considerable time in Coed Aber Artro.

In most woods we regard this process as acceptable; for our policy is to regard beech as a native tree and not to seek to remove it.  Unfortunately we cannot take such a relaxed view in Coed Aber Artro, or on the other wood we own near Llanbedr, because both are scheduled as Sites of Special Scientific Interest … and included in a higher level designation for sites judged to be of European importance … CCW … is strongly of the view that it is not acceptable to allow such wholesale change to continue happening in these woods … scheduled for features associated with sessile oak dominated woodland.
The predicted consequence of the dominance of beech in these woods is that there will be a significant loss of the distinctive character and wildlife associated [with] the “upland sessile oak” woods …
Ultimately CCW do have the power to insist on the management they wish to see, but … we came to what I believe is an acceptable compromise.  We agreed to carry out a thinning operation in Coed Aber Artro to reduce the amount of mature beech, but not to a programme for its eradication or long term control … To have done nothing would certainly have been easier … but I believe we have a responsibility to support others in trying to retain something of the area’s distinctive oakwoods.

And this is CCW –

I must admit that I like beech trees and I have always been somewhat ambivalent about the felling of mature beech at these sites.  However, after much experience of beech in the oak woodland habitat in North Wales, I am convinced that this is the correct treatment to safeguard these oak woodlands in the long term.
Beech trees are not recognized as being native in Britain beyond a line drawn between the Wash and the Severn … In Wales, and specifically Meirionydd, beech has been extensively planted … It has then established itself in the oak woodlands by being able to regenerate under dense canopy shade, and by being at home with even the most acidic soils and with the local climate.
However, our reason for removing beech from our Oak woodlands is rather more pragmatic than the species nor being native and having been planted.  A group of beech trees in woodland will result in a patch of bare ground underneath, due to the extremely dense shade cast, due to the highly efficient absorption of light by beech foliage.  Only the most shade tolerant of plant species can survive there, and often it is too shady for any plants to survive under them.  This would have serious implications for rare and restricted lower plant species …
Coupled with the above, and compounding the problem, Beech seedlings and saplings are extremely shade tolerant.  They survive and grow slowly even under a dense and shady oak canopy, and can often be seen scattered through an Oakland where mature beech is present, within a few years after removing or controlling sheep grazing.  I have been in many woods in North Wales where I have seen this process occurring … the end result of this process is domination of beech in the canopy …
These are the reasons why we are effectively treating Beech in some sites as an exotic species, which threatens to alter a valued habitat and its communities.

9. This is all very well in the abstract but can it be applied to the Coed when the CCW leaflet, “your special site and its future”, itself envisages that it [the SSSI] “will continue to be broadleaved woodland dominated by oak and birch but with fewer beech than present in 2007″ (sadly this is already the case)?  Is Beech really a threat to the oak woodland?  This assessment is from Stephen Coll

The occurrence of beech in Cwm Nantcol and Cwm Bychan is in small discrete areas, in the main distinct from the more ubiquitous and larger areas of mixed deciduous woodland. The only large area of planted beech to the exclusion of other species, is the plantation on the steep banks of the Artro just east of the confluence with the Nantcol. Elsewhere in Cwm Bychan, the beeches are discrete stands of beautiful mature examples, some of which are exceptional. It is very clear that these extant beeches were planted – for whatever reasons, aesthetic or otherwise. It is equally clear that they have not subsequently been aggressively colonising the surrounding landscape like striding Ents.
There are very few beeches in Cwm Nantcol –  these are almost exclusively to be found in a relatively small area of Coed Aber Artro. Dominant oak deciduous woodland is well represented in Cwm Nantcol but there is very little regeneration. This, not because of the ‘threat’ of beech, but because of the depredations of sheep (and therefore humans) and particularly on the north side of the valley, the depredations of goats.
It is understood that the Woodland Trust can only have a mandate for the areas of woodland that it actually manages but that woodland should not be viewed in isolation but in local context – in this instance Cwm Nantcol and Cwm Bychan. In both places oak generally thrives and discrete stands of mature beech are something to be treasured rather than regarded as the enemy.
As far as the CCW is concerned – a blanket bureaucratic approach out of immediate context, is to be appalled. Their mandate for the protection of threatened existing oak woodland in the two valleys would be better extended by enabling incentives for stock proofing  overgrazed moribund areas. In Cwm Nantcol, the two areas that best need that protection are the small area of decaying oak, birch and ash woodland on the edge of the myrtle marsh (which is itself gravely threatened) in the western shadow of Foel Wen; and the extensive area of oak and mixed deciduous to the east of Craig Isa on the south side. There is not a beech to be seen in either area.
With regard to one aspect of the Woodland Trust management of Coed Aber Artro – there are clearly good conservation objectives in allowing felled timber to lie – but the effect created in the sheer scale of the arbitrary work here – has been that of the aftermath of a hurricane. It is all very well to say that time and nature will heal the wounds – inevitably it will  – but that is not sufficient reason to destroy the beeches in the first place. To be even more candid, I can’t think of any reasons that bear scrutiny as to why the work should ever have been done.

10. WT have, helpfully, put their next five year management plan out for consultation (though is the very culture of such plans more problem than solution?).  The Leaflet offers an alternative, minimum intervention, model –

Natural reserves  These woodlands are deliberately managed with the minimum amount of intervention possible … Basically nature is left to manage the sites, so trees will die and fall over naturally creating the gaps we were creating through thinning, which naturally will fill in with regeneration [1, 12].

This is how the Coed flourished as unspoiled woodland before the arrival of EU funds for the promotion of biodiversity.  It makes a useful starting point: departures from minimum intervention?  Here are some suggestions for WT’s (Rhydian Roberts) draft plan due in mid-July.  Restore to whatever extent possible the previous unspoiled woodland through removal of traces of WT’s sometimes insensitive management, such as (one example) the necrophiliac display of felled and mutilated trees around the intersection of path and tarmac lane from Aber Artro; no more culling of beech; a stop to the practice which leaves beech shorn of their lower canopies; regeneration of beech in culled areas to be encouraged (exposure through culling has increased the vulnerability of shallow rooted trees); removal of beech seedlings and saplings only if a threat to the general predominance of oak.  WT have given CCW “feedback on … the strong ill feeling towards the control of mature Beech within the SSSI and SAC”. If the response of CCW is positive, then the next chapter in the history of this much loved and much visited wood may be less unhappy than the last.

PETER LUCAS

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