EIR/202600519204 · FOI/EIR · partially withheld
Scottish Forestry - Woodland Carbon Code information: EIR release
Information requested
I have been trying to understand some basic parameters around the Woodland Carbon Code and the rules about registering schemes under it and how these are enforced which do not appear to be clearly described on the Woodland Carbon Code website.
1) Section 1.2 on the WCC website, eligibility states: 'Woodland creation activities shall be eligible if they take place on:
• Land that has not been wooded in the last 25 years'.
Please provide me with all information that Scottish Forestry holds on the definition of 'wooded' as used by the WCC in 1.2 and any guidance to staff and/or developers on how this should be applied.
2) Section 1.6 Additionality. This states 'Projects shall show that, without carbon finance, woodland creation is not the most economically or financially attractive land use' and 'Project developers shall use the cashflow template to demonstrate how the financial test is met. '
The cashflow statement requires developers to show income from Forestry Grants. Please provide me with any information Scottish Forestry holds about a) how the maximum proportion/or total amount of scheme project creation and initial management costs that can be met by forestry grants for schemes to register under the WCC are determined and, b) why landowners being able to receive forestry grants for a proportion of woodland creation costs while also registering PIUs is not treated as double counting and how this mean the 'additionality test'.
3) Section 2.6 states 'Projects and carbon units shall only appear on one carbon registry - The UK Land Carbon Registry.'
Please provide any information Scottish Forestry holds which clarifies the meaning of this and more specifically whether this means that a landowner can register for other carbon offsetting schemes as long as this does not include land included in projects registered with the UK Land Carbon Registry. If landowners are allowed to register for other schemes, please provide me with any information SF holds about the measures it has in place to stop double counting carbon credits and whether any action has taken place to enforce this.
Response
As the information you have requested is ‘environmental information’ for the purposes of the Environmental Information (Scotland) Regulations 2004 (EIRs), we are required to deal with your request under those Regulations. We are applying the exemption at section 39(2) of the Freedom of Information (Scotland) Act 2002 (FOISA), so that we do not also have to deal with your request under FOISA.
This exemption is subject to the ‘public interest test’. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exemption. We have found that, on balance, the public interest lies in favour of upholding the exemption, because there is no public interest in dealing with the same request under two different regimes. This is essentially a technical point and has no material effect on the outcome of your request.
Please see the below responses to your request.
I have been trying to understand some basic parameters around the Woodland Carbon Code and the rules about registering schemes under it and how these are enforced which do not appear to be clearly described on the Woodland Carbon Code website.
1) Section 1.2 on the WCC website, eligibility states: 'Woodland creation activities shall be eligible if they take place on:
• Land that has not been wooded in the last 25 years'.
Please provide me with all information that Scottish Forestry holds on the definition of 'wooded' as used by the WCC in 1.2 and any guidance to staff and/or developers on how this should be applied.
The Woodland Carbon Code takes the term “wooded” to be the same as “woodland” which is defined in the glossary. We are looking at clarifying this in the WCC, alongside the term ‘forest’.
Woodland is defined in the WCC Glossary as:
“Woodland - Land under stands of trees with a canopy cover of at least 20% (25% in Northern Ireland) or having the potential to achieve this. This definition includes integral open space and felled areas that are awaiting restocking (replanting). Consistent with the UK Forestry Standard, this includes short rotation coppice and short rotation forestry, but does not include individual trees, orchards, ornamental or garden trees, tree nurseries or the management of Christmas trees. (This definition is also applicable to ‘forest’).”
Similar definitions can be found in the glossary of the UK Forestry Standard - The governments' approach to sustainable forestry (5th edition).
2) Section 1.6 Additionality. This states 'Projects shall show that, without carbon finance, woodland creation is not the most economically or financially attractive land use' and 'Project developers shall use the cashflow template to demonstrate how the financial test is met. '
The cashflow statement requires developers to show income from Forestry Grants. Please provide me with any information Scottish Forestry holds about a) how the maximum proportion/or total amount of scheme project creation and initial management costs that can be met by grants for schemes to register under the WCC are determined and, b) why landowners being able to receive forestry grants for a proportion of woodland creation costs while also registering PIUs is not treated as double counting and how this mean the 'additionality test'.
Regarding additionality, projects can only be validated under the WCC if they meet both the legal and financial tests. Woodland creation must not be required by law or any legal agreement (legal test), and it must not be financially viable without carbon credit revenues (financial test).
In practice, if support through the Forestry Grant Scheme is sufficient to make a project financially viable, it will fail the additionality test. As a result, it will not be validated, and no carbon credits will be issued. Each project is assessed individually using a cashflow spreadsheet based on its specific costs and revenues, meaning there are no standardised levels of grant support that guarantee passing the financial test.
Regarding double-counting, public funding through FGS grants for private woodland creation does not transfer ownership of carbon credits to the government. The same principle applies to other outputs, such as timber or tourism. Carbon credits remain the property of the landowner or any party that purchases them, and the government cannot use them to offset its own emissions. Therefore, double-counting does not arise.
The national GHG Inventory will still record emissions and removals across the entire forest estate, but this serves only as a national accounting mechanism.
3) Section 2.6 states 'Projects and carbon units shall only appear on one carbon registry - The UK Land Carbon Registry.'
Please provide any information Scottish Forestry holds which clarifies the meaning of this and more specifically whether this means that a landowner can register for other carbon offsetting schemes as long as this does not include land included in projects registered with the UK Land Carbon Registry. If landowners are allowed to register for other schemes, please provide me with any information SF holds about the measures it has in place to stop double counting carbon credits and whether any action has taken place to enforce this.
The carbon registry acts as a “single source of truth” for the status, ownership and use of all carbon credits issued under the Woodland Carbon Code. The Code supports the use of a single registry, which is currently operated by S&P Global. One of the registry’s key functions is to record publicly the location of all projects, enabling any potential overlaps to be readily identified.
Landowners may also register for other carbon offsetting schemes. The Woodland Carbon Code applies a number of measures to prevent double-counting arising from overlaps with other schemes:
Validation checks: The WCC team checks for overlaps with existing WCC projects and maintains a publicly available geospatial layer of validated projects, ensuring that no land area is registered more than once within the Code. This process also highlights where projects fall within areas that may be eligible for other nature schemes, where geospatial data is available (e.g. Nutrient Neutrality in England). In addition, the WCC team conducts weekly manual checks of the Verra and Wilder Carbon registries to ensure that Woodland Carbon Code projects are not registered elsewhere. These are currently the only other standards likely to include woodland creation projects in the UK. Signed landowner declarations Third-party validation by UKAS-accredited validation and verification bodies
Where a site is found to have been used for multiple carbon credit schemes, the Woodland Carbon Code may take enforcement action. This can include disqualifying the project and cancelling all associated credits from the UK Land Carbon Registry. No such cases have occurred to date.
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Contact Please quote the FOI reference Central Correspondence Unit Email: contactus@gov.scot Phone: 0300 244 4000 The Scottish Government St Andrew's House Regent Road Edinburgh EH1 3DG
Detected exemption language
1) Section 1.2 on the WCC website, eligibility states: 'Woodland creation activities shall be eligible if they take place on: • Land that has not been wooded in the last 25 years'. 2) Section 1.6 Additionality. 3) Section 2.6 states 'Projects and carbon units shall only appear on one carbon registry - The UK Land Carbon Registry.' Please provide any information Scottish Forestry holds which clarifies the meaning of this and more specifically whether this means that a landowner can register for other carbon offsetting schemes as long as this does not include land included in projects registered with the UK Land Carbon Registry. We are applying the exemption at section 39(2) of the Freedom of Information (Scotland) Act 2002 (FOISA), so that we do not also have to deal with your request under FOISA. This exemption is subject to the ‘public interest test’.
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