Friends of the Irish Environment [FIE} have called on the Forest Service to amend its Forestry Report to the United Nations to eliminate what it terms 'gross misrepresentations'. FIE's response reveals how the Forest Service misleads third parties about the state of Irish forestry. While purporting to support sustainable initiatives like Continuous Cover Forestry [CCF], the truth is that the State Forestry Board has less than 0.25% CCF and continues to plant over 90% exotic species. Perhaps worst of all, the Report list 8 bodies in the NGO sector that it supports when the Minister clearly stated in the Dail that no funds would be provided for the one ENGO that is now prescribed under the legislation for consultation on forestry applications. Read More or see the full text of Government Report to UN and FIE's response
The Report has been prepared for the Fourth Session of the United Nations Forum on Forestry in May of 2004. It was sent out for consultation on December 8 with a deadline for responses of 22 December.

A spokesman for FIE said that 'At the outset, the consultation period for comments on the Report was entirely inadequate and timely requests for extensions were refused on the last day.'

In their submission to the Department, FIE claims that 'while purporting to support sustainable initiatives like Continuous Cover Forestry [CCF], the truth is that the Coillte Teo., the State Forestry Board, has less than 0.25% CCF and continues to plant over 90% exotic species.'

The organisations claims that the Report grossly misrepresents Ireland's actual acehivements in moving towards brodleaves by giveing 'great prominence to the Native Woodland Scheme. Wjhat the Report fails to mention is that government cut backs have all but halted this project. 'In any case, the Native Woodland Scheme does not envisage any new green field native plantings, confining itself to restoration of existing remnant woodlands.'

Further, the group claims that the Forest Service is praising itself for introducing a protocol to control the acidification from forestry which has damaged streams and rivers, but fails to explain that the Protocol does not apply to the more than 8,000 hectares per year of reforestation.

Perhaps worst of all, the Report list 8 bodies in the ENGO sector that the Forest Service supports when the Minister clearly stated in the Dail that no funds would be provided for the one ENGO that is now prescribed under the legislation for consultation on forestry applications. The Minister is well aware that without funding, consultation with Irish environmental organisations is meaningless as they do not have the resources to respond.

While the consultation document comments have been submitted to Dermot Ahern as Minister for Communications, Marine and Natural Resources, the organisation has also written directly to Joe Walsh as Forestry is being transferred from Communications, Marine and Natural Resources on January 1.

'If the Government does not take on board our criticisms, we will be bringing these gross misrepresentations directly to the attention of the United Nations Forum on Forestry' an angry spokesman for the organisation stated.

See the full text of Government Report to UN and FIE's response
NGO Commentary on the application in Ireland of Regulation 2080/92 instituting a Community aid scheme for forestry measures in agriculture
1. Introduction

2. CAP-related objectives

2.1 Unauthorized use of premia payments by the public authority's forestry company, Coillte Teo.

2.2 The high proportion of marginal and "unenclosed land" for afforestation

2.3 The structure of the industry

3 Environmental Policy Objectives

3.1 Environmental Impact Assessment Infringements

3.1.1 Judgement of the European Court of 22 September, 1999

3.1.2 Local Authority controls

3.2 Acid sensitive areas

3.3 Hydrological regimes

3.4 Archaeological preservation

3.5 Rural Environmental Protection Scheme

4. Forestry Related Objectives

4.1 Species Choice

4.1.1 Reafforestation

4.2 Management

4.3 Lack of Research

4.4 Lack of analysis

5. Conclusion

1. Introduction

An Taisce (Irish for 'the treasury') is Ireland's National Trust. It was established as a voluntary organization in 1946. It has more than 20 active Associations throughout Ireland and properties in many counties.

Under the Irish Planning Acts, the Environmental Protection Agency Act, and the Fisheries Amendment Bill 1997, An Taisce is prescribed as a consultative body and its opinions are sought on all planning permissions in sensitive areas, local authority development plans, aquaculture applications, and all integrated pollution control licenses. The organization also leads in educational and awareness programmes, sponsoring in conjunction with the Government the annual Spring Clean and administering in Ireland three of the Foundation for Environmental Education in Europe's projects, Green Schools, the Blue Flag, and Young Reporters for the Environment.

An Taisce has a long established interest in forestry. Members of the organization were central to the establishment of the Tree Council of Ireland, the umbrella organization for trees and are currently represented on this organization's National Council. An Taisce has made submissions nationally and in recent years sought the assistance of the European Commission because of Ireland's failure to adhere to both the letter and the spirit of European funding regulations and Directives. These are summarized in this submission and while some documents are attached, further information is available on request.

Forestry is of particular concern to Ireland because, more than any other European nation, Ireland suffered historically from deforestation. At the turn of the last century, only 1% of the land cover was afforested. Government afforestation began in 1903; European Commission funding began in 1981, assisting in bringing this figure to 9% by 1999, still substantially lower than the EU average of 36%.

In 1996, an Irish Forest Strategy was published with the ambitious goal of doubling the forest cover by 2035. Until 2000, 25,000 hectares were to be planted each year with 20,000 hectares per year thereafter. This would represent a change of land use of 1% every three years, thus making forestry an inescapable factor in the changing face of Ireland.

The period 1996 - 1999 therefore had a target of 100,000 hectares of conifers and 20,000 hectares of broadleaves. In fact, only 58,000 hectares of conifers and less than 9,000 hectares of broadleaves were planted 1996 - 1999, in spite of attractive 75% grants financed under 2080/92 and national exemptions from income tax, inheritance tax, and capital gains.

While it is difficult to evaluate what has been achieved by the Regulation 2080/92, the Interim Report COM 630/97 suggests distinguishing between the three main policies to which the Regulation's objectives are linked, and this brief commentary follows that format.

While the organization is grateful to the Commission for the opportunity to comment, notice of only five days was provided. This cannot be deemed to be adequate and we would be grateful for the opportunity of an Oral Hearing at a subsequent date.

2. CAP-related objectives

The COM 630/97 Interim Report suggests that Regulation 2080/92 has had a small impact on reducing surplus agricultural production. Irish application of the available funding would reinforce this observation. We flag 2 specific concerns.

Unauthorized use of income support by the State Forestry Authority, Coillte Teo.

The high proportion of marginal "unenclosed land" for afforestation (this is also relevant to Forest Policy Objectives below).

2.1 Unauthorized use of premia payments by the State Forestry Authority

The 1997 and 1998 premia payments given to the Irish public authority Coillte Teo have been excluded from community financing. These payments under 2080/92 "normally reflect financial loses resulting from afforestation of their agricultural land and subsequent from the loss of annual income previously obtained from agriculture" and extend for 20 years.

The payments were specifically defended by the Irish Minister for Marine and Natural Resources, Dr. Michael Woods, T.D., in replies to written parliamentary questions by Joe Higgins, TD, in December 1997 and February 1998.

The payments were also defended by EU Agricultural Commission Fischler in a reply on 15 June, 1998 to a question placed by MEP Patricia McKenna . The Commissioner stated that "The Commission does not intend to investigate afforestation by semi-state companies under Regulation (EEC) No. 2080/92 as afforestation undertaken by these companies is not in breach of its provisions." Representations to DG VI Agriculture produced a similar reply from the Director General , as did a petition to the President of the Commission.

It was not until July, 2000, that, consequent upon a complaint by an Irish environmental organization to the Court of Auditors, the NGO's complaint was upheld by the Raport Final of the European Commissions Organ de Concilliation in the context of the clearance of accounts under EAGAFF. It was determined that 3.8 million Irish pounds of forestry funding paid to date to Ireland under 2080/92 did not qualify for this funding. Consequently, a Commission Decision was issued on July 5, 2000 excluding from Community financing certain expenditures occurred by Ireland under EAGAFF.

According to the Chairman of Coillte Teo., Ray MacSharry, the "company was to be considerably disadvantaged by the removal of these forestry loss-of-income premiums which the company has received under Regulation 2080/92 since 1993." MacSharry announced that "the EU Commission has proposed to disallow these premium payments to Coillte from 1 August 1996 on the grounds that the company is considered to be a public entity."

"The total amount involved, receivable up to the year 2013, is IR£37.3 million. While the clawback of the IR£6.5 million received to date would be a significant blow to the company," MacSharry continued, "the loss of the balance of IR£30.8 million receivable into the future would be a very serious matter indeed. This would be further compounded by the fact that, in order to finance the purchase of land necessary to achieve its contribution to the national forestry targets during the period 1993 to 1999, Coillte borrowed certain amounts which were to be serviced from the premiums receivable into the future."

Coillte Teo. land purchases in fact were falling already due to other factors, declining from a peak of 6485 hectares in 1995 to 1411 hectares in 1999. However, during the period of 2080/92 the company used this Regulation to support the purchase of 60,000 hectares, incurring a debt of IRS £50.9 million. This public authority's net debt position has thus risen from IRS £12 million in 1992 to IRS £61.7 million at the end of 1998. Interest payments in 1998 were just over IRS £4 million - all of it made possible by non-compliance with community rules.

Thus, funds which were intended to support afforestation by farmers were used by the Irish state to give Coillte Teo an advantage in the land market to the disadvantage of the farmers seeking to restructure their holdings through legitimate use of community funding.

2.2 The high proportion of marginal and "unenclosed land" for afforestation [See Forest Policy Objectives below].

The value of afforestation as an alternative use of agricultural land under Article 1 of 2080/92 has been diminished in Ireland by the use of marginal land for afforestation. The definition used by the Interim Report of "permanent grassland and pasture" is open to misinterpretation in the Irish context.

It is difficult to believe that more than 20% of the land afforested under 2080/92 was land of significant agricultural value. Irish farmers tend to plant marginal land which is of the least value to them in agricultural terms, in part because forestry historically has been confined to poor species on poor quality land as an employment subsidy, rather than as part of a culture of high quality broadleaf forestry with its value added benefits.

Much of the land planted 1993 - 1999 was actually on unenclosed land which had a demonstrably historically poor capacity for farm production. "Unenclosed land" in Ireland is land which shows no evidence of having been improved and enclosed by man-made boundaries for agricultural use, other than extensive grazing, and its afforestation does not significantly contribute to restructuring of agricultural practices while commensurately impacting heavily on the natural environment and native biodiversity.

These areas represent habitats that are now under the greatest pressure, including scrub, bog, and particularly heather moorland, which has between overgrazing and afforestation become at risk as part of Ireland's biodiversity.

In 1993, 6006 hectares of enclosed land were planted while 3164 hectares were planted on unenclosed land. Through the years 1994 to 1999, the ratio was no better. The peak year of Irish afforestation under 2080/92 was 1996, when 6343 hectares of unenclosed land were planted. 1998 figures show 8804 enclosed hectares and 4123 unenclosed. Although the 1999 figures show an improvement, the new premiums under 99/1257 give the largest increase in premia grants to non-farmers planting 90% conifers on unenclosed land. This could further threaten the remaining habitats and suggests a failure to take on board the experiences of 1993 - 1999.

In particular, we would draw attention to Figures 3 and 4 in the Interim report to the Parliament on 2080/92 and suggest that the "agricultural area" afforested could be misleading unless correlated to the productive capacity of the land classified as agriculture in the Irish context.

The point of restructuring agricultural holdings was further blunted in Ireland by the poor development of forestry activities on farms, fundamentally at odds with mono-culture spruce grown in 40 year clearfell by outside contractors. [See Forestry Policy Objectives below]

Performance and physical indicators are lacking to enable fuller evaluation of the success or failure of this policy. The Common Evaluation Questions in Ireland's 4 February 2000 submission relating to the CAP Plan 2000 - 2006 makes this clear in the unavailability of information to answer the question:

"To what extent have the assisted actions enabled forestry to contribute to the economic and social aspects of rural development by maintenance and development of employment and other socio-economic functions and conditions?"

Answer: "na" [not available].

2.3 The structure of the industry

The structure of the industry was created by the national Industrial Development Authority's support for pulp wood and panel board factories when faced, in the 1980's, with the maturing of the poor quality species planted on poor quality land in the 1950s and 60s. This resulted in three of the largest pulp wood and panel board factories in Europe (Medite, near Clonmel, 1983; Louisiana Pacific & Coillte, near Waterford, 1996; Masonite in South Leitrim, 1997) with heavy American investment. Thus, the current capacity is already more than three times in excess of current Irish production even without noting that Ireland's mills run only single shifts when the international standard is round the clock processing. The sector is economically driven into continual production of low quality fast growing species which they claim are only economically viable in large scale plantations serviced by outside contractors.

One result is an inbuilt disincentive to the growing of broadleaves and so a protection for the exports from America into Ireland of broadleaf timber, particularly veneers and high quality hardwoods.

Another effect of this structure is the failure to develop adequate new markets to utilize the available and increasing raw supply, according to a report to the Minister of Marine and Natural Resources by Allied Irish Banks and Merrill Lynch. The report, which examined the options for the corporate development of Coillte Teo., pointed out that "unless adequate markets are found for sawn timber, Coillte will be unable to sell all of its increasing raw material supply". The Allied Irish Banks and Merrill Lynch report on Coillte Teo. records that since 1997 a "significant surplus of logs has accumulated in the forests".

This is against a background of a growth in the domestic sawnwood market by approximately 60% in the last five years, fuelled by a doubling of Irish house completions from 1989 to 1999 from 20,000 to 40,000 a year. The increase in demand has, therefore, been serviced by imports from other countries, resulting in a decrease in the domestic market share of Irish sawmillers from 55% in 1994 to 42% in 1999. The report identifies "negative perceptions relating to the quality" of Irish timber as one of the causes of the declining market share.

The failure of farmers to find markets for thinnings which would continue an income stream after the expiration of the premia payments also mitigates against successful restructuring. The situation is so critical that the Minister for Enterprise and Employment has now established a Task Force to seek markets for conifer thinnings. The small and remote nature of many of the Irish farmer's plantations, as well as the poor quality of the product and the international commodity nature of the timber trade all have resulted in less value for these thinnings than originally promised by the Irish Forest Service.

The Heritage Council, an independent body established by statute in 1995 to "propose policies and priorities for the national heritage" produced a publication in 1999 entitled "Policy Paper on Forestry and the National Heritage". The Policy Paper specifically draws attention to the lack of research into broadleaves which would support the social fabric or rural Ireland and counter the desertification that poses such a problem across the Community.

It states: "If increased forestry is to be fully integrated at the local level, and is to benefit the national heritage, forestry has to provide real benefit to the local community. The greatest opportunity for forestry to contribute to local communities arises where harvesting and downstream processing is of a scale and nature to maximise local employment opportunities. Forestry development which gives rise to a diverse and local ownership and management structure is most likely to stimulate jobs."

The Broadleaf Task Force Report states that "the best quality logs (hardwoods) are exported in the round, depriving the primary processor of a valuable source of raw material and a substantial quantity of the remainder finds its way into the firewood trade."

This approach cannot encourage the structure intended by Regulation 2080/92.

3 Environmental Policy Objectives

3.1 Environmental Impact Assessment Infringements

99/1257 states that 'for almost two decades, attempts have been made to integrate agricultural structural policy into the wider economic and social context of rural areas; to encourage farmers to serve society as a whole by introducing or continuing the use of farming practices compatible with the increasing need to protect and improve the environment, natural resources, soil and genetic diversity and to maintain the landscape and the countryside'.

In this context, the main value to Irish environmental NGOs of 2080/92 was in attempting to ensure that the funding would 'contribute to forms of countryside management more compatible with environmental balance'.

The method by which the public can assess the effects of these proposals is the Environmental Impact Assessment. We would suggest that the failure of the Irish authorities to properly implement the Environmental Impact Assessment procedures in relation to forestry as outlined in the Judgement of the European Court of September 22, 1999 has contributed in large measure to the failure of this member state to meet environmental objectives. Following on from that failure, substantial damage to the Irish environment has been sustained through ill located and managed plantations.

The failure to assess applications in catchments terms remains a major weakness in Irish forestry planning as does the substantial planting of valuable if undesignated habitats that provide island refuges and wildlife corridors for biodiversity recognized under the Habitats Directive but outside of the Special Areas of Conservation. That these lessons have not been learned has resulted in the recent approval under 1257/99 to fund plantation forestry of conifers in a 40 year clearfell cycle inside areas previously identified and protected under REPS farm plans as "habitat". [See 4.4 below.]

3.1.1 Judgement of the European Court of 22 September, 1999

During the course of the period from the COM 630/97 Interim Report to the present, both the Advocate General's opinion and the final Judgement of the Court were delivered on Case C-392/96.

Of particular concern to the Irish environmental NGOs had been the failure of the assessment process through the absolute nature and high thresholds for forestry EIAs. The 200 hectares threshold governed the first five years of 2080/92, this being reduced to 70 hectares in 1999.

The critical ruling is as follows:

"The absolute nature of the thresholds means that it is not possible to ensure that every project likely to have significant effects on the environment is subject to an impact assessment, because the mere fact that a project does not reach the threshold is not sufficient for it not to be subject to such an assessment regardless of its other characteristics. Under Article 4(2) of the Directive, however, account must be taken of all the characteristics of a project, not the single factor of size or capacity. Furthermore, Article 2(1) refers to a project's nature and location as criteria for assessing whether it is likely to have significant environmental effects."

The judgement of the Irish Courts in relation to the proposed Millennium Tower of Light in the centre of the capital's main boulevard ('The Spike') takes this Judgement further than simply ruling than that the Directive imposes on decision makers an obligation to requite an EIA if a sub-threshold project is likely to have a significant effect on the environment.

The Court found that Dublin Corporation had not properly organized its application of sub-threshold provision of European legislation, having failed to delegate the power to make such a determination. The Court noted "This is not a decision of a simple administrative nature - it is one with profound consequences."

It is difficult to assess the damage that has been done to Ireland's biodiversity through the artificially high thresholds and the failure to address sub threshold applications in sensitive locations.

That such afforestation occurred, and that requirements for suitable assessment under the Habitats Directive have also not been properly implemented, are demonstrated by a complaint to the European Commission by this organization concerning the afforestation of 80 hectares beside a mountain Lough of high amenity and Special Area of Conservation in County Cork which was approved with no assessment.

3.1.2 Local Authority controls

It is argued by the Irish authorities that the requirement to refer forestry applications to the relevant local authority ensures a below threshold environmental appraisal. The threshold for this assessment is 25 hectares. In the years 1993 - 1999, the number of applications each year from private planters over 25 hectares was between 8% and, at its maximum, 12%.

It is important, however, to appreciate that even this system of referrals had to be administered against a background of growing planning applications which under national Regulations had to be processed within 8 weeks. With no such legislative obligation on forestry referrals and a rapidly increasing number of these referrals, the system virtually collapsed during the period 1996 - 1999. The applications referred to local authorities for comment rose from 372 in 1996 to 790 in 1999. Recommendations for refusals, however, fell from 90 to 14, reflecting not a better quality of application but insufficient resources to properly assess the growing workload.

In this regard it is worth quoting the comment of the County Cork local authority's Senior Planner in relation to these referrals: "Mr. Kelleher is not satisfied with the existing consultation process with the Forest Service. The Council lacks specific skills related to forestry and forestry planning, the existing staff are overworked, and there is a period of one month during which the Council are asked to make comments to the Forest Service, which is regarded as too short." Given that this comment was made in 1997, it is difficult not to feel that this issue was of substantial importance to 2080/92.

The three areas to which local authority jurisdiction extends are Outstanding Landscapes, High Amenity Areas, and drinking water supplies.

3.2 Acid sensitive areas

These consequences of the failure of the impact assessment process to ensure that afforestation was compatible with environmental protection are no where more evident than in the afforestation of acid sensitive areas

It is widely accepted that conifer afforestation on acid-sensitive soils can lead to increased acidity and heavy metal concentrations in the run-off waters from these soils. This is due to the crowns of the trees filtering pollutants from the atmosphere and also ion exchange processes which occur at the roots of the trees.

In Ireland instances of increased surface water acidification occurring in areas of afforestation on acid-sensitive soils have been documented at east coast locations where the highest concentrations of air pollutants in the State have been measured. Increased acidity in streams draining acid-sensitive afforested soils at locations along the western seaboard where generally low concentrations of air pollutants have also been confirmed again and again in Irish research.

The acidity of water is a very important factor affecting aquatic organisms as it controls a number of biotic and abiotic processes. The level of acidity also determines the chemical form in which certain metals are present in water. Of particular note in this respect is dissolved Aluminum which can occur in a toxic form between pH 5.0 and 5.5. The streams most severely affected by conifer afforestation in the acid sensitive areas lack acid-sensitive invertebrates and are too acid to support self-sustaining populations of salmonids.

The Aquafor Study, a four volume study which was coordinated by University College Dublin and published in 1997, again confirmed the original studies and noted that acid episodes which were most severe and long lasting in conifer afforested catchments tended to occur in winter and spring which is a particularly vulnerable period in the salmonid life cycle. Mayflies were absent from most acid sites in conifer plantations and these sites held a lower diversity of invertebrates. Fish were entirely absent from sites otherwise suitable. Sites with the most acid waters showed the lowest survival of salmon ova and eggs developed abnormally brittle shells during incubation.

A Literature Review "Assessing the Sensitivity of Surface Waters to Acidification" funded by the Forest Service and the European Commission by University College Dublin and published in January 1998 left no doubt that the afforestation and reafforestation of these acid sensitive areas exceeded the critical loads.

A number of maps have been produced in recent years outlining the areas in the State shown to be sensitive to inputs of acidity. The statutory Irish Heritage Council concluded as early as 1998 that "current knowledge is a sufficient basis for some action to minimize the adverse implications of these interactions between forestry and hydrology and the aquatic environment".

The failure to implement testing which would avoid the environmental damage from conifers in these important areas, in spite of the Environmental Directorate's legal efforts, has meant that European funding has contributed to the damage the native wildlife and ecology of the member state. The Commission is pursuing this matter under a complaint registered from this organization.

3.3 Hydrological regimes

The intimate relationship between the extensive drainage often necessary under Irish conditions to prepare ground for forestry plantations and affected waterbodies can result in substantial damage to the hydrological regimes.

The Fisheries Boards are established by statue as the regional bodies responsible for the development and protection of inland fisheries and the development of angling. The South Western Fisheries Board expressed their concerns clearly in a Case Study undertaken for the Heritage Council in 1997. "The altered hydrology of the upper reaches of catchments where most forestry is located in Kerry can result in more extreme peak river flows which can smother or wash away spawning beds. Drainage, as part of ground preparation, allows water to run-off more rapidly, since the 'sponge' effect of the natural bog vegetation is lost. Plantation fertilisation is also a concern because of the increased phosphorus loading downstream."

The Fisheries Officer continues: "Forestry operations are thus similar to arterial drainage schemes: increased peak flows for shorter periods, leading to increased erosion in the upper reaches, and greater risk of flooding with greater amounts of suspended solids downstream. The greater flood risk in the lower reaches can affect farmers, who may take measures to curb flooding, leading to more potential environmental damage. If the upper reaches of catchments are also subject to overgrazing as well as forestry, there will be additional run-off. It appears that intact bog acts as a sponge, absorbing water during heavy rainfall and slowly releasing it during dry periods, thus acting as a damping mechanism which limits extreme flooding and excessive erosion. After afforestation and overgrazing, this natural damping ability is lost."

The Fisheries Officer concludes: "The Board feels that in a sensitive catchments, there should be a provision for excluding forestry, and not simply grant-aiding forestry in compliance with the guidelines, which are seen as inadequate."

Nor are the effects limited to fish. The Wildlife Ranger in Killarney, County Kerry, noted in the same report: "The nature of the soil, heavy rainfall and relatively steep slopes means that ground preparation and felling lead to greatly increased sediment loads in streams. This has damaging effects on aquatic life, particularly the freshwater mussel, Margaratifera margaratifera, which has been greatly reduced in certain streams, notably the Kerry Blackwater, which flows into the Kenmare River." The author of this report notes that the Kerry Blackwater was apparently one of the top five rivers into the world for this species.

Should the Irish authorities suggest that these practices are confined to the past, we cite a recent letter from the Chief Executive of the North-West Regional Fisheries Board.

The Chief Executive Officer, responding to a public statement from this organization, recounts the failure of the state authority Coillte Teo. to adhere to the best practices which are well know and required by the Forestry Service Guidelines. The case relates to afforestation at Glencar Lake, Co. Leitrim.

The CEO writes: "I personally witnessed a situation whereby huge volumes of silt were being washed directly off a Coillte site into a tributary of the lake and there were absolutely no silt control facilities in place." Having made representation to the Chief Executive Officer of Coillte Teo., the Fisheries Board Executive records that he regrets to say that "he was very unhappy with the reply which did not reflect the seriousness of the situation on the ground or indeed an acceptance of poor management by Coillte in the Glencar catchment."

Not only have the Fisheries Boards been powerless to perform their own roles in protecting the environment against these damaging practices but the weakness of the Irish regulatory authorities has created a climate in which the appropriate recourse failed to ensure that the matter would be addressed.

3.4 Archaeological protection

The Heritage Council points out that at present there is no pre-planting FIEld survey of all proposed forestry developments in order to identify the presence of archaeological sites. While statutory protection is given to sites listed in the Record of Monuments and Places under the National Monuments Act 1999, "to view the Record as a definitive list of archaeological sites in Ireland is to misinterpret its function." This is "only a first stage in an on-going attempt to identify and ultimately protect sites." The report suggests that there are between 150,000 and 200,000 pre 1700 AD sites in Ireland, many of them on the marginal land favoured by forestry.

The Policy Paper notes that the only way in which forestry can proceed under these circumstances is to ensure pre-planting surveys are effectively done through the creation of an archeological unit to carry out pre-afforestation surveys.

Further, the "individual archaeological sites often form part of a larger complex, and their function can only be understood by reference to their setting in the landscape. In these cases, forestry has the potential not only to impact negatively on the specific site, but also to detract from the archeological landscape.

Without such pre-planting FIEld surveys, Ireland is unable to comply with 2080/92's requirements to ensure afforestation is compatible with environmental balance in regard to its considerable archeological wealth.

3.5 Rural Environmental Protection Scheme

As noted, the competition in Ireland between the Measures available from the Commission for agricultural restructuring was not from Set Aside, but from REPS.

One of the reactions to the increasing unavailability of the Irish land on the market that occurred in the mid 1990's with the "Celtic Tiger" was the introduction into REPS in 1997 of afforestation.

As originally implemented in Ireland, REPS farmers under 2078/92 were required to reimburse the authorities for any lands subsequently afforested. REPS and afforestation were alternatives. Excluded from any afforestation, even under these arrangements, were those areas identified as "Habitat" in each REPS plan. These areas included some of Ireland's most valuable biotopes - callow, marsh, dune, peatland, machair, esker, scrubland, and natural or semi-natural vegetation. They could not be afforested.

In spite of this, in a survey of REPS Planners' Agencies in Ireland conducted by the Department of Agriculture and Food in 1999 , the least effective of the 11 REPS Measures was Measure 4, "habitats". It was rated "very effective" by only 4% of the Irish REPS Planners.

The failure of REPS Measure 4 to properly protect habitats, which would have in fact required greatly augmented training and education by ecologists for both REPS Planners and farmers, has resulted in the Rural Development Plan 2000 - 2006 permitting plantings of these habitats, requiring only "the retention of a viable proportion of the identified habitats".

The difficulty of identifying the "viable proportion" of scrub, unimproved grassland, or blanket bog is clear. As one REPS planner has recently pointed out "In the absence of comprehensive regional nature conservation strategies, how can any Planner determine the desirable extent and distribution of such habitats while operating on a farm by farm basis?"

4. Forestry Related Objectives

The Irish Heritage Council "Policy Paper on Forestry and the National Heritage" suggests that

"The increase in afforested area, and the further planned forestry expansion, is often portrayed as being beneficial for contributing to the reafforestation of Ireland. However planting non-native species poor conifer plantations on important habitats offers few of the benefits of indigenous mixed broadleaf woodland, particularly in terms of biological and landscape diversity."

We detail the decline in species variety since the 1997 assessment of COM 630/97. We also note that the changes in premia structures under 1257/99 in fact bring near parity to conifers and broadleaves, suggesting an augmentation of this trend. We also outline the environmental management problems that have been recently highlighted by an independent assessment of Coillte Teo. This assessment determined that it did not qualify for certification from the Forest Stewardship Council.

4.1 Species Choice

Irish forestry planting in the early 1990's showed a very low level of broadleaf afforestation, averaging less than 500 hectares or 3% - 4% of total annual afforestation. As a result of the positive differential in favour of broadleaf species in both the afforestation grant and premium schemes of recent years, the level increased under 2080/92 to 4,500 hectares in 1995, or about 20% of total afforestation.

However, the 20% broadleaf figure on which the 1997 COM 630/97 Interim Report was based in fact represented Ireland's peak broadleaf planting. It has not been met in the years 1998 and 1999, which show a fall to 15.92% in 1998 further reduced to 15.12% in 1999. The 1999 figures give 2000 hectares pf broadleaves planted in that year, less than half of the 1995 figure, with a further erosion of environmental balance and native biodiversity.

The high percentage of unenclosed land afforested discussed above also restricts species choice with the Department database recording no broadleaves plantings on unenclosed land. Grants and premiums only require 10% broadleaf within a site "if the site allows".

A further matter of concern in the Irish context is the failure to ensure geographical balance. While it is undoubtedly true that the Eastern counties are more suitable for broadleaf afforestation than the poorer land of the West, the historic broadleaf cover of Ireland as well as successful plantations of broadleaves in many of these areas belies these generalities.

In County Cork, in particular, the largest county in Ireland, extensive areas of agricultural land in the northern portions of the County would provide ample opportunity for the establishment of profitable broadleaves on land now used for grazing for milk production and arable crops. Yet the figures for 1999 show that even in this county broadleaves accounted for less than 20% of the total afforestation, with 1130 hectares of conifers and only 176 hectares of broadleaves.

In Donegal, for example, where remnants of native woodland demonstrate how well in certain areas broadleaves can and have been grown, 839 hectares of conifers were planted in 1999 and only 37 hectares of broadleaves.

Finally, we have great difficulty in understanding why the Irish authorities have permitted the state owned forestry company Coillte Teo. to set goals of only 10% broadleaves in the face of national policy at 20% and would suggest that this lacuna played a substantial part in the failure of Ireland to meet its broadleaf target in the period funded under Regulation 2080/92. The Forest Management Unit Plans published by Coillte Teo to date for the period 2001 - 2006 continue with a 10% broadleaf target; 1995 broadleaf planting composed only 3% of the total planting, rising to 5% by 1999.

The SGS Qualifor Report prepared for the FSC certification assessment of Coillte address this issue in the following terms: "Not all FMUs currently meet the minimum percentage requirements and do not adequately detail how these percentages will be achieved in the future. Additionally within the selection of species the process is skewed towards consideration of management objectives through the issuance of pre-set targets or limits rather than through an open appraisal which takes due consideration of the capability of the site."

Surely a company like Coillte established by statute with only two shares, each held by a Minister, should show clear adherence to national policy and European funding criterion, especially when the forestry statistics indicate that even the most modest broadleaf targets in the community have not been reached?

4.1.1 Reafforestation

An additional factor in the decline or Irish biodiversity through forestry arises in Ireland because substantial planting in the 1950s and 1960s is now being felled. While reaforestation is not directly funded by the community and the activity involves no land use change, the broadleaf planting rate on these restocked areas is 11%, eroding the EU funded target and leaving a true figure of Irish planting of broadleaves of 13%, a further loss of environmental balance and native biodiversity. Coillte Teo.'s broadleaf planting rate for reafforestation is 2%.

While a certain amount of the planting during this period, which historically sought to increase rural employment, was on poor land, it is worth noting that the 1995 Irish Broadleaf Task force identifies clearfelled land as prime broadleaf potential, the competition from weeds no longer being a problem. The acceptance of such a low rate of broadleaf planting in these circumstances would not appear to be in the spirit of the European community.

4.2 Management practices not "adapted to local conditions compatible with the environment".

A useful outline of the management practices not compatible with the environment has been provided by an SGS Qualifor study of Coillte Teo. for The Forest Stewardship Certification process in July of 2000 . While the organization no longer is purchasing and planting land at the earlier rate, it remains a principal player through "farm partnership" and its role as the largest contractor in the country.

The report makes the following comments:

"While some restructuring is ongoing this is limited in extent and is not being carried out in a systematic planned manner. Forests are being dealt with in a coupe or piece meal basis rather than as an entire forest as a whole. It is not clear from current policy and practice that there is a commitment at national, regional or FMU level to achieve any increase in the use of alternatives to clearfell in the long term."

"Adequate assessments of impacts at strategic and tactical levels are not always carried out prior to commencement of works."

"There is no overall strategy in place to ensure that features with biodiversity value are protected and that 15% of the forest area is managed as conservation areas and long-term retentions. Current policy does not ensure these requirements are met, nor are they being implemented under current planning. "

"Extended coupe sizes greater than 25 ha are evident in areas not justified through landscape or design reasons."

We would note that single age structures subject to clearfell can not generate the positive environmental effects available from good practices noted by the Community, such as curbing erosion, preventing desertification, encouraging biodiversity and regulating hydrological regimes.

The weakness of the national regulatory authority to ensure the implementation of its own Guidelines is demonstrated by the letter attached from the Chairman if the North West Fisheries Board to An Taisce in relation to the proposed certification of Coillte Teo.

The company's "inadequate care of forests" was attributed to "cost-cutting", according to a report on Coillte by the joint Oireachtas Committee on State sponsored bodies in 1997. Chairman Liam Kavanagh TD (Lab) saw this as a threat to EU grants.

4.3 Lack of Research

We would draw your attention to the Forest Service Funded 'Broad Leaf Task Force Report' of 1996, the recommendations of which make clear that the lack of broadleaf planting in Ireland is due to the failure to research the economic value of broadleaves in both the short and long term. As far as we have been able to ascertain and in spite of continued representations, this research has not been done on the grounds that such work might endanger the 1996 Forest Strategy which limits species diversity through the policy of having "due regard" to the "attainment of the identified critical mass".

4.4 Lack of analysis

In the Economics of Irish Forestry, a 1999 study by Dr. Peter Clinch of University College Dublin funded by COFORD, the Irish Forestry Research Council, found "the magnitude of the forestry subsidies appears to outweigh the social and environmental benefits provided by the Strategic Plan."

Clinch continued to suggest that "If community funds are available to Ireland for alternative use the Government Strategic Plan for Forestry fails cost benefit analysis" and that "the proposed increases [under 99/1257] in subsidies magnifies this situation".

Clinch asked three questions which to this date have not been addressed:

¬? What is the rationale for forest subsidies in Ireland?

¬? Where is there an evaluation of forestry subsidies and compliance?

¬? Can these goals be achieved through other measures?

5. Conclusion

Early 1980 estimates of the potential of afforestation within CAP reform were considerably overestimated because "they did not take into account the various environmental, economic, and social constraints framing choices of how to use released agricultural land".

The COM 353/97 Interim Report on 2080/92 in Ireland suggested greater achievement than the subsequent afforestation was able to deliver and at a greater cost to the environment than was anticipated.

The failure to avail of farm woodland improvement schemes or to seek funding for market and planting research further inhibited the beneficial effects of the measure 2080/92. The over riding considerations noted in the Interim Report COM 353/97 "to create more diversified habitats, encourage recreational activities and increase attractiveness in terms of tourism" succumbed instead to the national policy to strive for an undefined "critical mass" in conifer production as part of the unrealistic goals of the national 1996 Forest Strategy.

The failure by the Irish authorities to integrate application of the Regulation into overall regional planning policy focusing on the countryside and environmental aspects has greatly hindered the purposes of 2080/92. In fact the measure, combined with a weak national Regulatory Authority, has permitted irregularities in funding and failures in impact assessment. All of these have required considerable resources from Ireland's NGOs in seeking redress from the national authority and, when this has failed, from the European Commission itself.

An Taisce, The Tailors' Hall, Back Lane, Dublin 8.

March, 2001. Internet Ver. 1.

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Has the Commission ensured that Council Directive 85/337/EEC on the assessment of certain public and private projects on the environment are respected in relation to the use of forthcoming community grant aid?


Has the Commission ensured that Council Directive 85/337/EEC on the assessment of certain public and private projects on the environment are respected in relation to the use of forthcoming community grant aid? In the case of Ireland what steps has the Regional Development Commissioner taken to ensure that the forthcoming community grant aid is not given to Ireland for further infringements of this Directive as identified in the Judgement of the European Court of Justice against Ireland of 21 September 1999 [C-392/96] on the environmental impact of afforestation land reclamation and peat extraction.

Of particular concern are the small scale forestry initiatives being promoted by the Irish authorities under the Rural Environmental Protection Scheme which will fund the planting of commercial monocultural plantations of non-native species by small farmers with a consequent fragmentation of native bio-diversity already under critical pressure through rapid economic development in the rural landscape. Specifically the Court judgement noted that "even small scale projects can have substantial effects on the environment... where by reason of its nature there is a risk that it will cause substantial or irreversible change in those environmental factors irrespective of its size."

Given that the Irish Minister for the Environment informed the Irish Parliament in a reply to written parliamentary questions [22228/99 2222/29 222230/99 attached] on 9 November 1999 that he was unable to indicate what amendments to national procedures were necessary to comply with the Judgement of the European Court against Ireland will the Commission ensure that the Irish decision making process complies with this judgement and that appropriate procedures are in place before approval is given for further community support for these activities?


If you go down to the woods today you're in for a big surprise for it seems the Irish timber industry is facing serious problems - and that's a according to a report published on the internet by Friends of the Irish Environment.
The Pat Kenny Show

RTE Radio 1
Thursday 16 January 2003

Pat Kenny, Presenter
Pat Lehane, Chairman, Forestry Section, The Irish Farmer's Association
Tony Lowes, Friends of the Irish Environment

PK: If you go down to the woods today you're in for a big surprise for it seems the Irish timber industry is facing serious problems - and that's a according to a report published on the internet. Friends of the Irish Environment claim its contents were revealed only after they pressed for details under the Freedom of Information Act. Joining us to discuss these developments, Tony Lowes of Friends of the Irish Environment and Pat Lehane, National Chairman of the Farm Forestry Section of the IFA. Good Morning.

Tony you got the documents you required under the Freedom of Information Act so what's the problem?

TL: We also put in a request under the Freedom of Information Act to see why the Report wasn't published because they denied us a number of documents and they said they wouldn't release them until the Report was published. So we went into the records of this Report which was presented to the Minister last December.

The first memo that appears on the file is a note for the Tanaiste saying in February that the Tanaiste would formally launch the Report in March. There is big sloppy handwriting in the margin saying "Yes" which I assume is from the Minister.

Next on the paper files appears a letter from the man who I think is speaking to us this morning. Do you remember writing this letter, Pat?

PL: I do indeed.

TL: In this you said that the Chief Executives Forum which was proposed was "certainly not an option" and that you were afraid that the "launch of this report would do little to inspire confidence in potential farm foresters and existing growers?

PL: That's that's - well…

PK: Are you saying that Pat actually succeeded in suppressing this report?

TL: Well the next record as the tale goes on is a meeting between - I don't think Pat was at this - it was your secretary of the IFA …

PL: What meeting is this now?

TL: The Tainaiste had a short meeting with the Frank Fahey, the Minister for Marine and Natural Resources at 7 PM on the 17th of April. Minister Fahey was accompanied by the Secretary of the Irish Farmer's Association." These arguments were put forward again and the Tanaiste said "No immediate decision need be taken on this matter and she would consult privately with Minister Fahey."

PK: Anyway the bottom line is that almost a year later the Report is out there because you got it and you put it on the internet. Why is it is such a bombshell that people might not have wanted it to be published?

TL: I think it's the first authoritative analysis of what is facing the current growing policy. We're in a really serious situation. I don't think its wrong to call this a "Doomsday Report". The timber that is coming out there is no market for, the Baltic States are coming in, our quality is not there. The only bright spark is that we could set up biomass generators around the country and burn it. But for sure no farmers should be planting any more.

PK: That particular scenario, the biomass generation of power or whatever or even using it as starter for a fermentation process - that is something that down the road farmers may be queuing up to supply.

TL: Well there's going to be a lot of them queuing up from the forecasts in these reports - and some of the comments on the forecasts. People were really astonished when they saw the amount of residue that is going to be left.

PK: What's the problem? If there is no money in it then farmers and other investors will have to do something else!

TL: Absolutely, absolutely. Economics are the bottom line.

PK: Ok. Pat Lehan. What is your problem with this Report? I mean it does suggest there are no markets there, you'll be swamped with timber from the Baltic States of higher quality…

PL: Yes…

PK: That the thinning that you have only a certain amount will be absorbed by the local timber composites market…

PL: Look I'm amazed that this is a news item today because this document while it hasn't been officially launched it has been in the public domain with - look - probably 12 months - we have issued Press Releases about it - it has been covered by some of the Press - some of the Press didn't bother - some of the people didn't bother reading it - its 70 pages.

PK: It's a very repetitive document, I have to say, having read…

PL: Look we agree with most of what's in it. We have a problem with solutions and I think the document highlights problems but it doesn't actual give solutions. Now we're amazed that it's a news item today because we've highlighted this at the Society of Foresters conference, at the IFA forestry conference, this is going back months - probably 12 months - at a UCD conference I spoke there and I've highlighted it…

TL: We've…

PL: Even before the report came out we've been highlighting some of the problems…

TL: Pat…

PK: Ok Tony…

TL: Pat we've written to both Ministers asking them to launch this report. Would you change your mind about this and agree with us and write to the Minister and ask her to publish the Report properly so that the farmers can find out what's really going on?

PL: Well we're not concerned of the Report is actually launched or not. What we're more concerned about is that solutions are found. Ok, there are problems with marketing every product, whether it is milk or beef or whatever and you don't - just because you produce something it doesn't mean there's a market there automatically for it.

PK: Isn't it a problem with forestry that the maturation period even for thinning is on a different cycle than say beet production so therefore if I invest today I mightn't find I had made a mistake, unless I had the proper analysis I mightn't find I had made a mistake for five or six years or maybe even longer and then I'm stony broke.

PL: Nobody is going to be able to predict what is going to be the market in 40 or 50 years time when this crop is going to be ready.

PK: Even for thinning and so on…

PL: What we do know if is we don't try and manage the market and try and have a proper structure there for marketing and managing this product then we will have a problem. So effectively what IFA are looking for is that we have a proper structure set up, that we have a body set up probably like Bord Bia that will actually look at the problem and deal with it. There is a market for timber there will always be a market for timber, it is actually growing…

PK: But it might not be an economic market - you can get rid of it but don't…

TL: Listen to what the Irish Timber Growers Association said actually say in their comment to the Minister on just the residues alone: " It could be pointed out that with 600,000 cubic meters of a projected surplus of pulpwood and residues by 2005, (see page 58 and 60) and the further projected increase from forest - excluding resides - by 2015 of almost 700.000 cubic meters - a total projected surplus of 1.3 million cubic meters is possible by 2015. Incredibly, this serious potential surplus has not been addressed in this report."

PL: Look it's a balance between having the processing for the product and having the product available. No one is going to set up a processing unit or whatever unless the product is there - until such time as that product comes on stream. What has happened historically is that as the product has come on stream, then the processing unit has developed.

PK: Ok I want to ask Tony Lowes finally, is your solution to stop doing these typical commercial crops like Sitka spruce and move to traditional Irish woods? Is that where the Friends of the Irish Environment are coming from.

TL: Pat we've spent three years trying to get funds to demonstrate the short term economic potential of broadleaves - now were not talking about 80 or 100 years - we're talking about 15 and 20 years, we're talking about new techniques of laminating and finger jointing, we're talking about the value of alder - we're talking about the value of birch! And this is not happening because the current Government policy sets a target of 20,000 hectares a year of this kind of conifers - and until that is changed, until the Minister readdress the 1996 Forestry Plan, we're all at sea.

PK: Is your message to the farmers that they can make money doing the other thing?

TL: No, until we have the research we can't promise them anything but we believe its there, its there in other countries, there's no reason we can't make it work in Ireland.

PK: So this is a plea for that research to be done?

TL: And to re-examine that forestry development plan…

PK: We'll leave it there. Tony Lowes and Frank Lehane, thank you very much.

The Irish Coalition for Sustainable Forestry has grown out an increasing recognition that Irish national forestry policy is unacceptable to many concerned with the conservation of Ireland's natural heritage.

(full document available from contacts below)

The Irish Coalition for Sustainable Forestry has grown out an increasing recognition that Irish national forestry policy is unacceptable to many concerned with the conservation of Ireland's natural heritage.

These concerns are generated by the commercial short-term plantations of single ages and monocultures that began to appear everywhere in the Irish countryside, supplanting native biodiversity in all its aspects. The 1996 Forest Strategy calls for 20,000 hectares a year of these plantations for the next 30 years, doubling the land covered by forestry from 9% to 18%. The policy is supported by 75% EU funding as well as by national income, capital gains and inheritance tax exemptions.

While Ireland was once ancient broadleaved woodland, plantations with 80% non-native conifers, often rising to 95% and even 100% on the unenclosed lands of many of our counties, have become the norm. England has reversed this trend. The European planting average is 27% conifer and 73% broadleaves. The Irish planted 87% conifers and 13% broadleaves in 1998 and 1999. Coillte, the public authority charged with the management of Ireland's forest estates since 1988, each year plants only 5% broadleaves and has never been asked by our weak regulatory authorities to conform to even the current inadequate broadleaf planting target.

The situation will worsen under the new Rural Development Plan 2000 -2006. The greatest single increase in premiums is for conifers grown by farmers on severely-disadvantaged land (51%). The second greatest increase is for non-farmers to plant conifers on unenclosed land (50%). Non-farmers will only receive an additional £10 per hectare (£4 per acre) for planting broadleaves compared to planting conifers, reducing the differential between conifers and broadleaf from £29 to £8.

Against this kind of pressure the only native bio-diversity protected by European and national nature designations are Natura 2000 sites [Special Areas of Conservations and SPAs]; even there, the Forest Service permits plantings up to the edge of these protected areas with no referral to the appropriate national authority. This is required by the Habitats Directive not just for developments within designated sites, but for those adjacent. And we will now never know how much of our archaeological heritage has been lost under the great dark plantations

The adverse effects on fish life of conifer afforestation on poorly buffered and peaty acid soil has been demonstrated by studies which began in the late 1980's in Connemmara. Forestry phosphate applications required to produce "economic" growth rates are now alleged to account for up to 20% of the phosphate load in a given catchments against a background of deteriorating surface water quality throughout Ireland. Erosion, siltation, and flooding have devastated catchments of northern lakes. All this is now well documented. It remains unclear how many lessons of even the early pre-1990 planting - before these effects were researched - the regulatory authorities have taken on board today.

In spite of the critical differences in every site, Environmental Impact Assessments [EIAs] were only required for plantations of over 200 hectares. This threshold was reduced to 70 hectares when the European Commission began infringement proceedings. The 70 hectare threshold was struck down in a European Court Judgment on 21 September, 1999 as "exceeding the limits of a member state's discretion" as the "absolute nature" of the thresholds means that it is not possible to ensure that "every project likely to have a substantial or irreversible change on the environment" is subject to an EIA, irrespective of its size. Ireland's failure to date to revise its legislation accordingly is now the subject of further proceedings by the Commission.

The Coalition's great concern has remained the limited research and encouragement for broadleaved species which are publicly derided by the sector. It is the Forest Service's stated policy that they will not develop the commercial potential of planting broadleaves until the 1996 Strategic Plan's unquantified "critical mass" has been achieved. With new and developing technologies there is a huge potential for developing a commercially viable industry based on native and naturalized timber. COFORD have done many studies researching the commercial viability of growing broadleaves, including a recent report indicating that 43% of Ireland's land would grow Poplar with better returns for farmers than cereal crops. Our greatest frustration to date is our failure to obtain funding to collect and publicize the studies and trial results that would demonstrate the commercial short term value of broadleaves and overcome this mental barrier.

On the other hand, the Woodlands of Ireland promise more than 2,000 hectares a year for seven years of new broadleaf planting as well as restoration of equal areas and the creation of 570 hectares of millennium forests. Green eco-labels such as the Forest Stewardship Council offer the hope of encouraging better standards in the future. Only those wearing rose-tinted spectacles, however, can claim that this process is an end in itself.

The Coalition's concerns over the possible certification by FSC for Coillte reflects the widespread public representations made to us about the poor forest practices and poor consultative mechanism of this important company which holds in trust almost 400,000 hectares of Ireland's land. The company faces the return of IR£ 6.2 million in EU grants intended to compensate farmers for loss of income which Coillte used to finance loans to purchase more land from farmers - as well as the lose of IRS £32 million in future grants. Even more worrying, questions are now being raised about the company's apparent failure to even maintain the size of the productive forest estate it was given ten years ago, in spite of loans used to purchasing more than 60,000 hectares of land over the period.

And this is without commenting on other critical subjects, such as misinformation relating to carbon sinks.

The work of the Coalition to discover and address all these problems has brought forth a number of documents in the last year. The purpose of this first version of the Handbook is to identify and make easily available key documents for the Coalition's members - and for those who wish to be better informed about current Irish forestry policy and the alternatives we seek.

Irish forestry policy is a complex mixture of economic, political, social, and ecological elements. Achieving "sustainable forestry" in Ireland must allow for commercial rewards while protecting environmental and social values. This may be the most difficult challenge facing those concerned with the conservation of Ireland's natural environment.





Jacinta French at Voice: 01 661 8123

Tony Lowes of FIE: 027-73025