Forest Service,
Department of Agriculture, Food and the Marine,
Johnstown Castle Estate,
Co Wexford,
23/04/14
Re: The public consultation on the Forestry Programme 2014-2020
Dear Sir/Madam,
The stated goal of the National Forest Policy is “promoting economic, social and environmentally
sustainable farming, fishing and forestry”. The department intends to adopt the goals of Smart, Green,
Growth espoused by the governments FH2020 vision. The Department of Forestry has identified that in
order to achieve sustainable growth they must collaborate with other organisations to deliver policies on
environmental sustainability. An Taisce is a statutory consultee in the forestry consent system under
Environmental Impact Assessment (Amendment) Regulations 2001 (S.I. No 538 of 2001). As such An Taisce
are well placed to comment on this the proposed National Forestry Policy 2014-2020.
Historically, Ireland has been notable for the denuded nature of its landscape. Since the onset of the
Neolithic Ireland’s primeval forests have been incrementally felled and replaced in the main with pasture.
This has resulted in Ireland having one of the lowest levels of forest cover in Europe. The situation has
improved since the 1800’s when forest cover was at its lowest causing arboreal species such as the red
squirrel (Sciurus vulgaris) and the great spotted woodpecker (Dendrocopos major) to go extinct. One of the
aims of Ireland’s national forestry policy is to encourage planting by private landholders in order to achieve
a forest cover of 18% by the year 2046. An Taisce believes that an 18% forest cover is a conservative goal
given the fact that the EU average is above 30%. An Taisce would encourage any increase in native
woodland species cover, however; we are deeply concerned with the departments policy of using nonnative conifer species such as Sitka spruce (Picea sitchensis), lodge pole pine (Pinus contorta) and Japanese
larch (Larix kaempferi). This policy is regrettably resulting in the situation where afforestation may now be
considered as a significant threat to Ireland’s biodiversity. Non-native monocultures offer very little in
aesthetic or biodiversity terms. Traditionally landowners have chosen to afforest the least productive areas
of their farms. These low input areas are unfortunately the last refuges for many species which have been
marginalised by the intensification of agriculture. In this way afforestation can often result in the direct loss
of important habitats.
An Taisce are also all too aware of the treat posed by afforestation with non-native species to Irelands
Natura 2000 network and the species it provides sanctuary to. The NPWS (The Status of EU Protected
Habitats and Species in Ireland, 2013) have identified further afforestation as the greatest threat to their
conservation status. Despite this An Taisce continues to receive a litany of applications for afforestation on
a daily basis for plantations in some of Ireland’s most precious protected areas. The seriousness of this
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situation is highlighted by the current prohibition on afforestation in hen harrier (Circus cyaneus) SPA’s.
Irelands Natura 2000 network is extremely important not only in terms of the biodiversity it protects but
also in terms of the ecosystem services it provides. Non-native species are more often than not completely
inappropriate within these sites of national and European importance. In many cases afforestation is
disastrous due to the fact that it results in the direct loss of habitat as well as habitat fragmentation and
deterioration in soil and water quality. Deteriorating water quality is particularly problematic as it affects
freshwater ecosystems. The fresh water pearl mussel (Margaritifera margaritifera) for example is
threatened with extinction due to the fact that very few rivers exist within Ireland which are clean enough
for them to reproduce. Forestry has unfortunately played a significant role in the deterioration in water
quality in many catchments. An Taisce would like to see that in situations where the appropriate
procedures have been followed and it is deemed that afforestation will not have a significant negative
effect on the integrity of a Natura 2000 site that native species are used.
An Taisce considers that the appropriate assessment procedure currently being used by the forestry
services is not stringent or transparent enough. All too often afforestation is approved despite the fact that
it will clearly have a significant negative effect on one or more Natura 2000 sites. An Taisce proposes that a
database be established similar to the E-Planner online database that is currently used by the local
authorities in the planning system. This would involve that the Forestry Services uploading documentation
relating to their their site visits and any submissions made by NGO’s, government bodies such as the NPWS
or the general public. This data base would be open access. This would in our opinion significantly increase
the transparency of the appropriate assessment procedure.
An Taisce believes that the continued proliferation of non-native tree species is not environmentally
sustainable and as such it runs counter to many of the departments advocated goals. The proposed
Forestry for Fibre (GPC 10) programme for example will involve the establishment of even greater areas of
non-natives such as Italian alder (Alnus cordata), Hybrid aspen (Populus tremula ) and Eucalyptus species.
An Taisce would strongly encourage the use of native species of willow (Salix), alder (Alnus glutinosa), birch
(Betula pendula and Betula pubescens) using coppicing for management.
An Taisce also considers that the deleterious effect that commercial forestry has on soil and water quality
has to be adequately quantified. Further research is needed so that the existing Forestry and Water Quality
Guidelines (2000) can be further refined.
An Taisce are fully supportive of the measure to invest in improving the resilience and environmental value
of forests:- Native Woodland Scheme. Native woodlands provide a wide range of economic, environmental
and social benefits. Support for the establishment of new, and enhancement of existing, native woodlands
is desirable.
Forestry is one of the tools which must be fully utilised nationally to deal with the threat posed by climate
change. By increasing Irelands forest cover a significant carbon sink will be established. Forestry must also
be utilised to help mitigate against the increased threat of flooding. Riparian forests and wetlands are an
underutilised tool to prevent flooding and alleviate soil erosion. At the moment aquatic buffer zones of
broadleaves are often established between a plantation and a watercourse to prevent deterioration in
water quality. This usually consists of two rows of birch trees. The riparian planting of linear forests of
mixed native species such as birch, alder and native willow species would increase the capacity of these
buffer zones to prevent nutrient run off and erosion as well as increasing their biodiversity value.
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Please acknowledge our submission and advise us of any further periods of consultation. An Taisce would
be happy to meet with the Forest Service to discuss the above.
Yours sincerely,
Fintan Kelly
An Taisce
Natural Environment Unit
naturalenvironment@antaisce.org
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