Environment and Water Services,
Clare County Council,
Áras Condae an Chláir,
New Road,
Ennis,
Co.Clare.
Tel: 065-6846331
Forest Service,
Depatrment of Agriculture, Fisheries and Food,
Johnston Castle Estate,
Wexford.
Date: 31st March 2010
Re:
Submission on forestry Review
Below are general comments in relation to issues that should be addresses through the
review of national forestry policy, from the perspective of a local authority’s
environment section with legal responsibilities and obligations towards the protection
of the environment, water quality (surface and groundwaters) and drinking water
quality, and, Freshwater Pearl Mussel sub-Basin Management Plans, Shellfish Waters
Pollution Prevention Programmes, Bathing Waters, etc.
1. The projected targets for afforestation in this country seem to be in the region
of up to 20,000Ha per annum. While supporting documents state that
afforestation takes place on agricultural land, past experience has seen that this
is not always the case and in many instances applications for afforestation are
for lands that are less productive agriculturally due to their peaty or glay soil
content. The Programme of Measures and Standards Forestry and Water
produced under the Western River Basin working group has identified
planting on peat as an issue of concern in so far as potential impacts to water
quality are concerned with regard to sedimentation, eutrophication and the
application of fertilizers. It is well established that planting on peat has a
significantly higher risk of P leaching to waters due to the poorer binding
capacity of P in such soil types and the fact that peat or glay soil particles can
cause sedimentation in watercourses due to their erodable nature. This is of
concern where waters are of a sensitive nature or where they may affect a
drinking water supply but equally now with the objectives that need to be
achieved under the Water Framework Directive (WFD) through the River
Basin Management Plans, in achieving at least good status for all waters.
2. In Fresh Water Pearl Mussel Catchments afforestation on peat or glay soils
can affect the objective of attaining a satisfactory level of conservation status
where sedimentation of river beds in such catchments can have devastating
effect on Pear Mussel populations. National policy needs to define its
approach to this more clearly so that relevant bodies operate in tandem on this
issue.
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3. Currently the Code of Best Forest practices sets out to ensure that potential
environmental impacts from forestry are kept minimal. This Code is non
statutory and while there are penalties for non-compliance with the Code, the
review process needs to take account of enforcement actions undertaken for
non-compliances and the effectiveness of these actions, to ensure enforcement
is effective and applied thoroughly. The trees are (usually) already planted, so
the action needs to be effective in identification of impact and specification of
remediation measures to reverse the impact. This of course implies staffing
resources to regulate forestry activity from afforestation, replanting, thinning,
felling etc, to ensure adequate assessment of compliance levels. Is this being
addressed?. With the proposed increase in afforestation, local authorities need
to be assured that the grant of planting approvals ensures that sites comply
with all means available in protecting the surrounding environment and in
particular watercourses/ waterbodies.
4. Leading on from the previous point above, under the River Basin Management
Plans, Water Management Units (WMUs) are defined in each county where
waters can be managed so that objectives of the WFD can be met. Under these
WMUs, waterbodies are delineated on the basis of a catchment or minicatchment approach. Forestry development policy and afforestation for the
future must be looked at within this waterbody delineation where it should be
ascertained and certainly regarded as to the robustness and assimilative
capacity of any catchment in supporting forestry together with other land uses.
The state or health of a catchment is seen in the quality of water within the
catchment through biological, physio/chem., monitoring, fish life,
macrophytes etc. The projected rate of growth proposed for forestry must
support a healthy catchment and be sustainable in so far as allowing forestry
development without negative consequence to water quality or deterioration in
quality status whereby objectives of the WFD/RBMP are not compromised or
put at risk of not being achieved.
5. With the current economic crisis in this country it is expected that more land
will be taken up with afforestation. The rate of afforestion for each county
should be assessed as some counties with less productive agricultural land are
expected to have greater afforestation applications and approvals. Again as set
out above, this cannot compromise agreed objectives that Ireland has already
signed up to and all responsibly bodies/ parties must be aware of specific roles
and concerns in this regard. Re-planting after felling should be reviewed
where it might be found that re-planting in areas that are now known to be
acid sensitive, where there may be plans in place for the protection of
particular species and where water quality has been affected should be reassessed by the forestry regulator and local authorities.
Tracey Duffy
Asst Scientist
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