Milestone 02


Protected: Aggregated Woodland Planting Model


Identify and Work with Sellers


Project overview

Environmental Farmers Group (EFG) is a farmer-led organisation focused on delivering environmental improvements across farmer clusters and landscapes, where payments are derived from the sale of nature market credits and ecosystem services.

As part of EFG’s broader portfolio of work, EFG partnered with Zora (formerly Zulu) Ecosystems to develop an Aggregated Woodland Planting Model with over 21 farm businesses across southern England. The model aims to support farmers and land managers in developing a joint woodland project under the Woodland Carbon Code (WCC). The aims of the project include helping to reduce costs, improving farmer understanding of carbon models, and building carbon credit buyer confidence. Project activities include woodland creation, implementation of buffer strips, soil enhancement, flood management, and watercourse improvement, all through woodland creation and management.

Governance for the project is provided by EFG, including the management and sale of carbon units, and Zora Ecosystems provides estimations for ecological potential of woodlands across EFG’s wider membership. The project identified 478 hectares of woodland creation, providing 293,347 Woodland Carbon Units.

 

Milestone 1: Initial Project Scoping

Often the initial task is to understand the site(s) you want to use and the land use change needed for nature restoration or creation. This includes considering the goals of the land managers involved, the vision within the wider catchment or neighbouring area, and whether there are permits or planning consent needed for any proposed changes.

At this stage, you can also conduct a high-level assessment to determine which revenue streams can be generated from ecosystem services , e.g. carbon credits, flood reduction cost savings, or biodiversity units, which will be crucial for identifying buyer interest.

Finally, it is useful to have an idea of the costs of the project and potential grant funding that may be available to support initial development.

Milestone 2: Identify and Work with Sellers

Initial ownership of the ecosystem services will belong to the landowners or, in some cases, the tenants of the sites that the project is using. However, these can be passed onto others, such as third-party project developers, with appropriate legal arrangements and compensation. In some cases, there may be a sole seller of the ecosystem services, where the site or landholding is large enough that it delivers the volume of ecosystem services needed to cover the costs of the project and attract buyers.

However, in order to achieve scale and impact, a project will likely involve multiple sellers, such as neighbouring farmers and estate managers. Scale of land is often needed to deliver significant environmental outcomes, and also to attract private finance.

Where they are not the land managers in question, project developers must plan how they initially contact and engage with these sellers going forward, building their wants and needs into the project.

Milestone 3: Baseline and Estimate Ecosystem Services

At this point, you will have understood the vision for the project and identified a particular ecosystem service or set of services to be sold. The next step will be to carry out detailed analysis – baselining each ecosystem service and quantifying what will be able to be delivered from the interventions, as well as planning how to monitor and maintain these interventions. You will need to rely heavily on ecological expertise for this more scientific Milestone.

At this step, standards, verification and accreditation methods will be considered in more depth.

Milestone 4: Identify and Work with Buyers

Based on your earlier market analysis in initial project scoping, you will have identified one or more groups of beneficiaries who may be willing to ‘buy’ or pay for the ecosystem service(s) to be created, restored or maintained. Buyers vary – as do their requirements – but at this step, greater buyer engagement is now needed to develop a deal that channels money towards the nature-positive outcomes that your project wants to deliver.

 

 

Milestone 5: Develop Business Case and Financial Model

You’ll have started building your business case and financial model in earlier steps – laying out your project’s vision, the market proposition and estimating costs and income. This step offers a review, in addition to providing details needed to build out the financial model and business case more fully. Both of these key documents will be iterated throughout project development, and will likely be altered during project delivery as new information emerges. These documents are interlinked and, if developed correctly, will ensure your project’s viability and help you with discussions with stakeholders – including sellers, buyers and future investors.

The financial model will also enable you to better understand the type of structure your project may take to attract investment (i.e.a loan, an equity investment, a bond) and what sort of returns you can afford to pay/offer.

Milestone 6: Develop a Governance Structure

A governance structure will inform the way in which the project is run when fully operational and for what purpose. It identifies appropriate decision making processes, who is responsible for what actions, and what controls are in place to make sure that the project is meeting its stated goals, all while abiding by the risk appetite of its engaged stakeholders. The legal entity to host the project will be a key driver in this, and the appropriate choice of entity will be dependent on several factors that are outlined below.

Your governance structure should align with and underpin your business case, as a necessary component of how the project will deliver its environmental outcomes and other strategic targets.

Milestone 7: Identify and Work with Investors

It is important to note that not all projects will need up-front investment, but for those that do, this section provides a framework for thinking around the development of the investment model. This does not constitute financial advice – as the GFI is not licensed to do so. However these considerations are based on the insight offered by project developers and other market stakeholders.

An investor will be a new core stakeholder in your project, and it’s just as important to think of what you require from investors, as much as what they require from you – so that you can build a positive and collaborative relationship with them.

This entails defining the investment ask (in line with the financial model), the strategy for approaching the right investors, and the negotiation of terms that can then be formalised in contract development (Milestone 8).

 

Milestone 8: Establish Legal Contracts and Closing

When all relevant stakeholders have been engaged and their terms of engagement are clarified as much as possible, this is the time to fully develop the legal contracts and close the deal. This stage is positioned with in the Toolkit as last because legal fees are expensive, and it is generally advised to determine as much as possible in previous stages before starting to draw up contracts in earnest. However, you may have engaged legal advisors ahead of contract design on issues like tax, permitting and effective governance structures, which are covered in previous Milestones.

Note: The information in this Milestone does not constitute any form of legal advice but instead serves as practical advice on how to manage engagement with lawyers and the process of contract development. The Green Finance Institute is not a firm of solicitors or connected in any way with the courts. The information and opinions we provide in this section and across the Toolkit do not address your individual requirements and are for informational purposes only. They do not constitute any form of legal advice. We recommend that appropriate legal advice should be taken from a qualified solicitor before taking or refraining from taking any action.

Community Engagement

Community engagement is highly advisable for any project that aims to sell ecosystem services, to ensure fair outcomes for local communities and the long-term success of the project. Project developers can build connections with local stakeholder groups early on to spot both risks and opportunities.

Policy and Regulation

Project developers and enterprises will need to keep a continuous check on how current and future policy may affect the project, and also opportunities for the project to inform policy. The role of private finance for nature across the UK is being encouraged by the UK government and its devolved administrations, and new rules, standards and markets are being developed.

 
Quick Stats
  • Location: Hampshire Avon, Dorset Stour, Test & Itchen catchments
  • Size of land: 478 ha of woodland creation
  • Tenancy & Ownership: Mix of tenanted and owner-occupied farm holdings
  • Nature Market Focus: Carbon finance via the Woodland Carbon Code (WCC)
  • Project Partners: Zora Ecosystems, Land Family Business, Thrings Solicitors.
Acnowledgements 

With many thanks to the following individual for their time and insight:

Hamish Drake, Project Manager at Natural Capital Advisory, working with EFG

 

 

 

 

 

 

 

Date Published: 25/01/2025

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Key points

  • The aggregation model is designed to centralise MRV (lowering costs), reducing the administrative burden on individual landowners while allowing each farmer independence to manage and maintain their individual woodland creation project.
  • Grants such as England Woodland Creation Offer (EWCO) and Woodland Creation Planning Grant (WCPG) are essential to the model and underpin early-stage financial feasibility.
  • The financing approach evolved over the course of the project: although the initial plan involved an SPV, the project demonstrated that EFG should instead act as the sales point for carbon credits, as the WCC already provides mechanisms for grouping smaller projects together.
  • The final model separates operational delivery from commercial execution, supporting farmer buy‑in while ensuring market-facing consistency for buyers.
  • Legal and tax advice from Thrings and Land Family Business confirmed that the structure avoids land transfers and removes Capital Gains Tax (CGT) and Stamp Duty Land Tax (SDLT) risks.

Background

The Environmental Farmers Group (EFG) developed and tested an Aggregated Woodland Planting Model in collaboration with Zora Ecosystems (formerly Zulu Ecosystems), supported by a one‑year grant from Round 3 of the Natural Environment Investment Readiness Fund (NEIRF). The purpose of this model was to assess whether grouping farmer‑led woodland creation projects could effectively overcome long‑standing barriers relating to scale, cost and administrative complexity.

EFG wanted to test the model within catchments where EFG’s cooperative approach was the strongest, with a dense membership base spread across a large land area. The catchments chosen were the most advanced in EFG’s model and were ready for woodland aggregation at the time.

There was a clear alignment between EFG and Zora. Prior to the NEIRF project beginning in 2024, Zora had already started woodland landscape assessments across these catchments in 2023, identifying the best opportunities for woodland creation by analysing land cover, soil types and available grants, and approached EFG given its existing cooperative model in the landscape.

Recognising that a woodland aggregation framework would require significant background research and detailed farmer engagement, the partners applied jointly for NEIRF funding to support the necessary development time. A Memorandum of Understanding (MoU) was established to outline how the organisations would work together, building on their complementary strengths. While Zora brought technical expertise, mapping tools and experience in carbon market processes, EFG contributed local relationships, farmer trust and an established mechanism for coordinating environmental delivery across multiple holdings.

EFG’s conservation planning involves identifying opportunities at individual farm level for enhanced environmental delivery and aggregating them to align with broader government targets. As Hamish Drake, Project Manager at Natural Capital Advisory (which provides the executive function for EFG) explained, the catchment‑level planning process aimed to “work out what our farmers need to deliver to try and match those targets or beat them.” These targets drew on the EIP 2023 goals for woodland and hedgerow creation (insert what they are?).

 

Early Engagement

Early engagement demonstrated the complexities of developing an aggregated model and the importance of personalised engagement with farmers.

Given EFG’s existing membership base in the catchments, EFG used its regular meeting rhythm to introduce the proposed NEIRF project. The woodland aggregation model was first introduced as part of a standard membership meeting, where initial feedback suggested interest but also uncertainty. Early engagement continued through follow‑up conversations, email communications and invitations for farmers to participate in one‑to‑one discussions. Although interest was evident, uptake was initially slow. This was due in part to the practical difficulty of scheduling individual meetings with busy farmers, some of whom later dropped out due to time pressures or uncertainty. Seasonal timing also played a major role, as farmers often faced peak workloads at critical decision‑making points.

Several farmers expressed concerns during these early engagements. Some felt their farms already had sufficient woodland, while others preferred to use their available environmental land for alternative habitats. Several farmers had preconceived notions about woodland creation, viewing it as potentially bureaucratic or complex.

To address these barriers, EFG and Zora placed significant emphasis on personalised engagement.

Each farmer met one‑to‑one with an EFG cluster facilitator or environmental consultant to discuss their land and ambitions. EFG ensured that farmers retained autonomy in their decisions, providing support and guidance rather than instructions. For example, EFG sometimes helped identify suitable woodland creation areas by reviewing historical hydrological maps, but the final choice always remained with farmers.

In addition, every farmer who expressed interest was offered a one‑to‑one scoping meeting with Zora Ecosystems. These meetings were essential in clarifying how the WCC operates, what commitments it requires and how long‑term obligations, such as the WCC’s 100‑year permanence requirement, might affect future ownership or land management decisions.

Following this targeted engagement process, over 21 farm businesses across southern England joined the project. These farms varied significantly in scale, from 70‑hectare family farms to 3,500‑hectare estates. Their knowledge of woodland creation and carbon markets also varied. Larger estates often had dedicated woodland managers or estate managers, while smaller farms were generally less familiar with the Woodland Carbon Code (WCC).

Farmers were also integral to the design of the projects, contributing local knowledge that improved the accuracy of mapping. For example, Drake noted that, during the mapping review, a farmer might point out that a certain area of a field was at risk of flooding that hadn’t been picked up by habitat mapping, which helped refine the suitability assessments.

 

Building Woodland Creation Scenarios

Once initial buy‑in was achieved, EFG and Zora worked closely with the participating farms to estimate their potential woodland creation areas. This process involved detailed mapping, modelling and one‑to‑one consultations to identify suitable planting opportunities. It also required early conversations about land tenure, future ownership and the implications of long‑term woodland management obligations. Many farmers expressed concerns about committing land to woodland for up to 100 years under the WCC, particularly where uncertainty existed around future land succession or business strategy.

A project‑level scoping report was produced for each participant, providing a clear picture of the potential risks and rewards associated with woodland carbon credits. These scoping reports included cashflow expectations, granting pathways, and project timelines. For many farmers, these financial details were particularly important in assessing viability, as woodland creation involves substantial early‑stage expenditure.

Many farmers also asked questions about commercial woodland operations, such as whether commercial felling could be incorporated into WCC projects. These decisions remained entirely under farmers’ control. As Drake noted, “NCA advises EFG members on matters relating to natural capital  and leaves independent or existing advisors to work on non-natural capital decisions for the farm business, such as timber or other developments”.

Governance and Aggregation

During the early stages of the project, EFG explored the possibility of establishing a Special Purpose Vehicle (SPV) to host the WCC Group Agreement and manage carbon revenues. However, detailed legal and tax advice from Land Family Business and Thrings Solicitors highlighted several drawbacks. An SPV would introduce a double layer of taxation, as revenues would first flow into the SPV and then out to farmers. It might also trigger CGT or SDLT liabilities and risk farmers’ eligibility for Business Property Relief. This analysis led EFG to reject the SPV model.

The legal report recommended instead adopting a single Group Agreement under the Woodland Carbon Code. This structure would streamline administration by validating multiple projects under a single framework, while ensuring that projects were linked only administratively and not through shared liability. Long‑term MRV and carbon trading responsibilities would be managed via the WCC Group Agreement and supported by EFG’s Membership Agreement.

The final model also formalised a clear separation between operational delivery and commercial execution. Independent project developers would take responsibility for project development, woodland scoping and administrative tasks, while EFG would handle market engagement and the sale of carbon credits. This dual structure enhanced farmer engagement by ensuring authenticity and local trust, while providing the consistency and professionalism required by the marketplace.

Limits to the Model

The project also revealed several limitations. Smaller farms faced proportionally higher costs for woodland development, verification and MRV, even under an aggregated model. Timing was another challenge, as many farmers missed planting windows because of delays in decision‑making or competing farm priorities. The long‑term nature of woodland carbon commitments required detailed early-stage discussions on land tenure and succession planning, and some farmers were hesitant to make commitments extending beyond their business planning horizon.

Cashflow constraints were another barrier. Woodland creation involves significant upfront expenditure on planning and establishment before grants or carbon income can be accessed. This led EFG to begin exploring investment models to help bridge early-stage funding gaps. Bureaucratic hurdles within the WCC process, combined with the lack of stacking options, added further complexity and slowed progress. Although no farmers formally dropped out of the scheme, several paused their involvement due to timing challenges and uncertainties around long‑term commitments.

Key Learnings

The NEIRF project demonstrated substantial potential for replicating the woodland aggregation model across other catchments. The cooperative structure, the ability to group multiple projects under the WCC and the support provided by grant funding all contributed to the project’s scalability. Project leaders observed that farmers were particularly interested in creating woodland on marginal or unproductive land, where the economic trade‑offs were more favourable.

However, they also identified areas for improvement. Earlier and more diverse communication with farmers would have helped to align expectations from the outset. Additional resources for farmer engagement would have helped to overcome early delays, while more detailed early-stage project scoping would have helped set clearer budgets, verification milestones and timelines.

Next Steps

Collectively, the participating farms identified just under 500 hectares of potential woodland creation, equating to an estimated 257,000 tonnes of CO₂e sequestered over 100 years.

Following the completion of the NEIRF project in June 2025, EFG plans to move forward by registering an initial 100 hectares under the Woodland Carbon Code. EFG will also finalise commercial agreement with a project developer and establish a Group Agreement to enable smaller projects to participate more easily. EFG will continue exploring investment mechanisms to address upfront cashflow challenges, ensuring that participating landowners have the financial support needed to enter and benefit from the woodland carbon market.