Submission on Forestry Review
Forest Service, Dept. of Ag. Fisheries & Food
Johnstown Castle Estate
Wexford
31 March 2010
Re: Review of Forestry Policy
Dear Sir,
With reference to the Review of Forestry Policy and your call for submissions, our
comments are as follows. The Forest Service publications, “Forestry and Water
Quality Guidelines”, “Forest Harvesting and the Environment Guidelines” ( and
others ) have gone some distance to address water quality issues linked to forestry.
However many water quality problems with links to commercial forestry relate to
sites that were planted long before these guidelines were published. In most cases
these are “difficult” sites at high altitude, located on steep slopes and with
accessibility problems. In most cases it would be our opinion that such sites would not
now be considered as suitable sites for afforestation.
One problem with afforestation on such “difficult” sites is the potential for significant
nutrient losses during and post clearfelling operations. For example the Ow and
Avonbeg Rivers are important salmonid tributaries of the Avoca system and represent
excellent spawning and nursery habitat for salmon & trout. Unusually high levels of
algal growth have been observed by Board staff in upper reaches of both Rivers
during recent Summers. These growths of algae coincided with significant clearfelling
in the upper reaches of these systems and with a marked loss of biological quality in
the headwaters of these systems. Our contacts with the EPA suggest that
eutrophication is the reason for the loss of High Status ( Q4-5 / Q5 ) at these upland
sampling stations. The EPA state that this loss of water quality may be related to
forestry activities. While an improvement was noted in the biological quality
recorded at most sites in the Avonbeg in 2006 ( most of the afforested lands in the
upper reaches of the Avonbeg is not being replanted and will be transferred to the
NPWS to become part of the Wicklow Mountains National Park), both sites
monitored on the Ow catchment, recorded unsatisfactory Q3-4 ratings in the most
recent EPA survey. The problem in the OW and Avonbeg catchments was
exacerbated by the fact that limited thinning had ever been carried out, due to
problems relating to the site access, difficult sites and / or fear of wind throw.
Clearfelling on such sites has a far higher, associated risk of erosion, run-off of
nutrients / suspended solids, as little or no vegetation has established beneath the
“closed” canopy. We question the sustainability of replanting on sites if there are
likely to be feasibility issues relating to thinning on that site in the future.
The Board welcome the Protocol for Acid Sensitivity set up by the Forest Service. We
are however aware of a number of heavily afforested sites which were planted some
time before this porotocol which suffer from acidification problems. The current
Guidelines do not adequately address the issue of acidification of these waters. Once
again it is our opinion that such sites would not now be considered as suitable sites for
afforestation.
One of these sites is the Lugduff River which flows into the Upper Lake in
Glendalough. The Biological Survey of River Quality 2000 states that abnormal
acidic effects were again indicated in the Glenealo River downstream of the Upper
Lake, Glendalough. There is strong evidence to show that forestry is primarily
responsible for this acidification problem. The EPA carry out annual monitoring on
Glendalough Lake Upper and its two main tributaries ( the Lugduff & Glenealo
Rivers ), these studies as reported in “Water Quality in Ireland 2001-2003” show that
the lake shore and Lugduff River ( heavily afforested catchment ) are severely
impacted by acidification while the Glenealo River ( upstream of the Upper Lake )
with no commercial forestry within its catchment was not subject to any acidification
pressures. The paper by Bowman & Bracken, The Effect of run-off from afforested
and non-afforested catchments on the survival of Brown Trout in two acid sensitive
waters in Wicklow, Ireland demonstrated that it was the high levels of labile
aluminium, combined with increased acidity on the Lugduff which were responsible
for the trout mortality on the Lugduff ( 12 out of 15 trout placed in the Lugduff died
within five days ), while trout placed in the Glenealo River upstream of the upper lake
Glendalough were unaffected. It is the opinion of this Board that commercial forestry
operation in the Lugduff catchment is contributing to artificial acidification of the
Lugduff River, the Upper Lake Glendalough and the Glenealo River downstream of
the lake and that that current forestry practices in the Lugduff catchment are
environmentally unsustainable. The Water Framework Directive requires that all
water shall be of good quality ( minimum of Q4 ) by 2015, at present the Q value at
the EPA station downstream of Glendalough upper lake is 3/0. A Q value of 3 relates
to moderately polluted water while the 0 indicates toxicity. Since this site was
included in the EPA’s Biological Survey of River Quality in 1990, on every sampling
occasion a Q3 or Q3/0 was awarded.
With regard to the Margaritifera margaritifera ( Freshwater Pearl Mussel ), in the
Eastern Region the Board are aware that populations of Margaritifera are found on
the Bann River ( Slaney tributary ), at various different locations of the Slaney Main
channel and in the Derry River another Slaney tributary. Other populations of
Margaritifera in the Eastern region are located within the Avoca catchment, with
populations in the Aughrim River and a number of its tributaries and in the upper
reaches of the Avonmore River. The Board request that these populations are
recognised by the Forest Service to mitigate against potential damage by forestry
operations in these catchments.
The Board ask if the Forest Service would see any merit in incentivizing buffer-zones
along watercourses through grant aiding. Bank erosion is a serious problem in many
catchments, for example the Derreen catchment ( Counties Carlow & Wicklow ),
where bank erosion throughout is leading to siltation of the substrate and is a
significant issue for salmon recruitment. The soils throughout much of this catchment
are composed of glacial schist outwash gravels and are especially prone to erosion. In
most areas where bank erosion was noted buffer zones were absent / fencing was
inadequate. We ask if a scheme similar to the existing Supplementary Measure 4 (
Riparian Zones ) of the Rural Environmental Protection Scheme would be appropriate
in these circumstances. A scheme such as this would have the added benefit of
providing protection to watercourses on lands where intensive farming practices
precluded the landowners from entering REPS. Any such scheme would also have to
address the potential for tunneling / excessive shading on these watercourses.
Yours faithfully
Pat Doherty
Chief Executive Officer