Agricultural Consultants Association
Forestry Section
Discussion paper
Forestry Programme 2014 - 2020
Introduction
The Agricultural Consultants Association (ACA) is a body representing 140 agricultural and
forestry professionals across the nation, advising and disseminating the latest information in
our sector to our 45,000 clients.
This paper outlines the ACA's position in relation to the proposed forestry programme 2014
- 2020. Over two days of meetings ACA forestry and agricultural consultants met and
discussed the issues which we believe the forest industry can improve on and ideas which
will increase the planting programme. The aim of this paper is; Back to basics trees planted
on suitable sites (right trees right site) to create a sustainable, productive, world class forest
industry from nursery to sawmill for all.
Given the dramatic disintegration of the planting programme over the past 5 years ACA
believe that the survival of the industry will depend on how the 2014 – 2020 Programme
will address the many issues that have negatively impacted on planting levels. Now is the
time to make the many changes necessary as it is obvious that the current programme is
failing miserably.
Measure 1 :Afforestation and creation of woodlands
Land Classification: All lands proposed for planting should be considered on an individual
basis regardless of status (enclosed or unenclosed). The classification Enlcosed / Unenclosed
should be scrapped. ACA feel that this classification is outdated and is possibly one of the
main stumbling blocks in the way of achieving our targets. If a site has a yield class 14 or
greater and meets all the other criteria then it should be approved. Professional foresters
through their training should be determining the yield class on a site by site basis.
SAC and SPA's: These areas are covering vast tracks of land traditionally the most
productive and popular areas for planting. In recent years these areas are virtually excluded
from planting due to the designation for the Hen Harrier and acid sensitivity. We suggest
the adoption of a workable quota system in both designated areas. A quota system worked
well in the SPA for the hen harrier prior to the changes with the buffer zones around wind
turbines. The whole restriction on afforestation in the acid sensitive areas needs to be
revisited. It should be possible to adopt an acceptable percentage level of forest cover in
any one river catchment area in the acid sensitive areas.
Farmer status: The ACA welcome the proposed scrapping of the farmer rate of premium
and welcome a one premium for all.
Netting of payments: Currently netting of payments is taken from the establishment grant
usually mandated to the registered forester. We propose the netting should not be taken
from the Grant. The Grant is not an income payment but a capital payment for works done.
The premium payment is income and is the more appropriate source for any netting.
Other Agricultural schemes
At present there are interaction issued between forestry and other agriculture schemes e.g.
the Disadvantage Area Base scheme. The ACA suggest that the new forestry scheme must
be fullly compatible with all other agriculture schemes especially the proposed new GLAS
scheme.
As with FEPS and REPS, applicants planting under the new forestry scheme, planting 5
hectares or more should automatically qualify for GLAS.
GPC
The ACA welcome the two new proposed forestry GPC's agro-forestry and forestry for fibre.
In relation to the GPC's we suggest a less complicated categorisation of payments. Instead
of having the current 8 GPC's and expanding this to 10, we suggest a 4 GPC's system.
GPC 1 Conifer
GPC 2 Broadleaves (including NWS Establishment)
GPC3 Agro-forestry
GPC 4 Forestry for fibre
Grants and Premium:
The 12 year premium duration as outlined is likely to impact on the planting targets in a
negative manner. We suggest that the 20 year premium remains. The longer the payment
period the less the impact will be felt.
Currently the establishment and maintenance grants are paid, 75% year 1 and the remaining
25% in year 4. We suggest in year 1, a 70% payment be made and in years 2 and 3 a further
payment of 10% each year and the final 10% paid in year 4 following a successful forest
service inspection. The reason for this suggestion is that the grant payments will reflect the
timing of costs incurred. It is suggested that payments 1 and 4 be subject to Forest Service
inspection but that 2 and 3 will be paid automatically. If the plantation is not up to the
required standard two year's after the second inspection is due premium payments may
stop.
Also for some species e.g. Norway spruce and some other species the establishment period
should be extended to 6 years and if the standards are not met in a further 2 years then
payments can stop.
All fencing with an allowance for gates should be paid on a per meter / unit basis. At
approval stage the total meters and number of gates and the specification should be agreed
and approved upon.
Grant and premium rates
To reach the 10,000 - 15,000 hectares per annum target the levels of grants and premium
will need to be revaluated. At current grant aid levels the industry is seeing a massive drop
in the planting programme month on month. In 2020, if the real living costs continue to rise
at approximately 3% per annum this will lead to an 18% decrease in the value of the
premium over the life of the programme. The ACA suggest increasing the grants and
premiums to the following.
Afforestation Grants rates
GPC 1 Conifer: € 4,290 /Ha
GPC 2 Broadleaves (including NWS Establishment): €6,500 / ha
GPC3 Agro-forestry: TBA
GPC 4 Forestry for fibre: TBA
Fencing: rate per meter based on specification erected
When calculating afforestation grants VAT should not be excluded as it is the statutory
requirement of all persons and entities to make an individual VAT return.
Afforestation Premium Rates
GPC 1 Conifer: € 590 /Ha
GPC 2 Broadleaves (including NWS Establishment and conservation): €670 / ha
GPC3 Agro-forestry: TBA
GPC 4 Forestry for fibre: TBA
Appeals system
The current appeals system we believe needs to be reformed. Currently there are issues
with delays in decisions, a lack of impartiality and transparency. This process needs to have
strict guidelines applied in relation to the length of time for a decision. The panel
adjudicating on the issues needs to be balanced with independent representation and have
a clear and transparent decision making process.
Administration process
To improve the entire administration process the ACA suggest the current IFORS system be
upgraded to improve efficiency, reduce costs and cut the time that each application
requires. For iFORIS to be fit for purpose it needs to be 100% electronic which is not the
case at present. At Form 1 stage an electronically submitted Form 1 should go to the Forest
service inspector directly. There should be no necessity to digitise at this stage as there are
no payment implications. The system should automatically refer applications if deemed
necessary to the relevant bodies once the fully completed application is submitted. At form
2 stage the mapping done using the system and approved by the forest services inspector
should be taken as correct and should not be superseded by future and better technology
on that individual plantation.
Legal and Taxation
Over the past 5 years land ownership issues at form 2 stage have become a real issue for the
industry. Ownership registration formats and legal technicalities have left many applicants
and foresters waiting length periods before payment. This area of the forestry process
should be reformed and brought inline with all other agriculture schemes, otherwise it will
erode confidence in the whole forestry programme thus impacting on our planting targets.
Currently the tax free allowance for forestry is €80,0000 this needs to be changed to a more
equitable income averaging to reflect the long term investment in the forest over the total
rotation of 35 to 45 years.
Measure 2: Investements in infrastructure: Forest road scheme
The Forest road is an essential part of any forestry plantation and the forest road scheme
allows the state and growers to maximise the return from their forestry investment. Under
the current scheme the specification for roads can not be met by the level of grant currently
available.
The ACA suggest that the harvesting road specification is correct, but the level of funding
needs to be increased to take into account the rising cost of labour and materials and time
required by the forester. At road side there is a much higher cost per meter and this needs
to be taken into account.
Also special construction works needs to be included in any new scheme. A second road
specification should be considered for modified harvesting equipment to accessing
plantations. The 80% 20% payment schedule needs to be reverted back to the original
100% payment on completion of the road. When calculating road grants VAT should not be
excluded as it is the statutory requirement of all persons and entities to make an individual
VAT return. Completion dates on projects; need to be flexible to accommodate different
road construction techniques, environmental restrictions and weather conditions.
Measure 3
Reconstitution scheme
The reconstitution scheme in its current format is primarily used to recover a forest’s
potential after it has suffered damaged through disease, adverse weather and damage from
vermin. The current scheme does not provide any assistance in the case of fire and
windblow. The assumption that insurance is obtainable by all forest owners is flawed
especially with recent widespread windblow that has occurred across the country. Currently
no forest owners are able to get windblow insurance after the storm on the 12 th of
February.
The reconstitution scheme needs to be expanded to meet with the current climate and to
ensure that potential and current forest owners will have a sufficient safety net for the
afforestation scheme.
Grant aid must provide assistance for damage from the following:
Frost,
Deer,
Squirrel,
Beetle,
Windblow,
Fire,
As per the afforestation and road scheme, the costs associated with VAT should not be
excluded as it is the statutory requirement of all persons and entities to make an individual
VAT return. Unlike the afforestation scheme, reconstitution of a plantation incurs greater
costs. Therefore the maximum grant rate level must take this into consideration.
Measure 4
Neighbour Wood Scheme
This scheme is designed to increase the economic, environmental and social value of
forestry in Ireland. This scheme is welcomed by the ACA and will support its extension.
Measure 5
Thining and Tending of Broadleaves
This scheme is required to ensure the productivity of current broadleaf plantations. It is vital
to ensure that the management and cultivation of these sites is preserved as a well tended
crop will be much more valuable in the future.
The scheme however does not at present cover some of the basic management needs of a
plantation and this needs to be looked at. Funding is required to promote the establishment
of management paths and tracks within these plantations. These are required to manage
the site correctly as well as for future applications of fertilizer if they are required.
Measure 6
Native Woodland Scheme
The ACA agrees with the measure to ensure the continuation of the Native Woodland
Scheme. With the greater environmental objectives being put forward by the European
Union, we must look at diversifying the way in which we plant forestry. This scheme helps to
ensure that.
The ACA would also approve the re-introduction of the conservation element. The native
woodlands of Ireland are important heritage and environmentally significant sites. These
sites are not currently being maintained as there is no incentive on any owner of natural
woodland to sustain or protect these sites. The reintroduction of the conservation element
will help promote and encourage people to protect these nationally valuable sites.
Measure 7
Knowledge Transfer and Information Actions
The ACA fully support the creation of knowledge transfer groups. The ACA currently has
45000 clients nationally, therefore we have access to a vast number of clients who would be
interested and gain real value from these groups. With over 140 consultants registered we
are able to distribute the knowledge garnered efficiently and effectively to all our members
on a 1 to 1 or through group sessions. The ACA consultants hold such meetings on a daily
basis as part or their regular duties.
The ACA support the measure to require registered foresters to be a part of a professional
association which has a continuous professional development programme. The ACA already
has a programme in place to foster the development of all aspects of the forestry
programme and would welcome a chance to expand upon it once adequate funding was
available. The ACA suggest a continual professional development programme be introduced
in the format of a bi-annually forestry meetings including all forest service inspectorate and
approved foresters, this will aid in better communication and standardising of works
nationally.
In relation to the knowledge transfer groups, the facilitator will be required to manage,
understand and lead these discussion groups therefore a Level 7 degree in forestry would at
least be required. The facilitator should also be paid directly by the forest Service.
Target training is an important measure and requires funding. For forest owners the focus of
the training should be on Chainsaw use, First Aid, Occupational First Aid, Manual handling,
timber measurement and the use of chemicals.
Measure 8
Setting up Producer Groups
The ACA is in favour of this objective. The funding for this should be in direct correlation
with the amount of timber that each group is producing. There also needs to be strict
criteria on what this funding may be used for.
Measure 9
Investments in Forest Technology
The technology used within the forest industry is advancing at a rapid pace, therefore the
ACA welcomes this measure to invest in the future. The funding should be made available to
forestry consultants who are one of the first to utilize such technologies. Furthermore this
measure would need to be linked in directly with Measure 7. It would be fundamental to
ensure that those receiving money for developing or training in the use of new technologies,
pass on the knowledge they acquire to other parties and individuals within the forestry
industry.
Measure 10
Forest Environment and Climate Services
The ACA believe that this is an important measure that does indeed require funding.
Conifers should be included within this measure. The focus of this measure is towards the
sustainable development of Ireland’s seed production.
Measure 11
Forest Management Plans
Management plans are required to ensure that the forestry plantations are being managed
correctly and that they will generate high quantity and quality of product into the future.
The costs associated with forest management plans will vary depending on the size, species
and quality of the plantation. Funding should be considered for the creation of inspection
paths, as detailed in Measure 4 for broadleaf schemes, for all plantations. This will enable
the forester to generate a management plan of much greater detail and accuracy. All sites,
regardless of the size, should have a management plan and the level of funding should be in
relation to the varying factors that influence the cost of the plan.
END