We write out of concern that the proposed legislative changes in relation to the European Court Judgment of September 21, 1999 may not enable the Irish authorities to prevent the afforestation of "acid sensitive areas" where extensive research has shown that conifer plantations have resulted in unacceptable environmental damage, including fish mortality to species such as Salmo salar protected by the Habitats Directive. Mr. George Kremlis,
Directorate General Environment
Legal Affairs Division,
January 7, 2001
Re: ENVIRONMENTAL IMPACT ASSESSMENT OF AFFORESTATION AND REAFFORESTATION IN IRELAND
Dear Mr. Kremlis
We write out of concern that the proposed legislative changes in relation to the European Court Judgment of September 21, 1999 may not enable the Irish authorities to prevent the afforestation of "acid sensitive areas" where extensive research has shown that conifer plantations have resulted in unacceptable environmental damage, including fish mortality to species such as Salmo salar protected by the Habitats Directive.
In Annex 1 we outline the situation as revealed by the research. More than ten years of research proves conclusively that acidification in these areas results in fish mortality. In Annex II we provide a Bibliography specifically confined to Irish publications which demonstrate the overwhelming scientific evidence which support our concerns. In Annex III we attach a map of acid sensitive areas compiled by the EPA in 1998.
We are greatly concerned that without clear and compelling changes in Irish legislation both new afforestation and restocking [more than 3 times the amount of new afforestation in Coillte 2000 Five Year Plan for West Cork, for example] of unacceptable sites will continue, and we would be most grateful if you would address this issue with the Irish authorities in the context of the assessment of afforestation and reafforestation projects and the setting of thresholds detailed in the Judgment against Ireland.
IRISH FORESTRY AND ACIDIFICATION:
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 Aluminium 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.
Most waters have, to a greater or lesser extent, the capacity to neutralize acid inputs. This is referred to as the "buffering capacity". The response of a lake or stream water to an acidic input is dependent on the strength of the input and the ability of the receiving system to neutralise or "buffer" the introduced acidity. The level of carbonates in the water principally determines buffering capacity. At low concentration ie. acid-sensitive waters in Wicklow, Connemara and Donegal, the water can rapidly become more acid as a result of increased inputs of acidity. In waters with high concentrations of carbonates, ie those in the midlands, there is sufficient "buffering" capacity to neutralise acid inputs that may occur normally.
Alkalinity is a measure of these carbonates in water and it is widely used to express acid-sensitivity or "buffering capacity". The accepted threshold for acid sensitive waters is an alkalinity 20
It is widely accepted that 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. The filtering processes are most pronounced in mature forests with full canopies. 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 (Bowman, 1991; Bowman and Bracken, 1993; Kelly-Quinn et al. 1996; Allott et al. 1990, 1997 and Bowman 1991 have also reported increased acidity in streams draining acid-sensitive afforested soils at locations along the western seaboard where generally low concentrations of air pollutants have been measured.
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 ERU produced one such map in 1991 based on the alkalinity of the water. Subsequently, an EPA funded study produced a similar map based on Critical Loads. These maps are not detailed (low scale) and indicate the principal areas of sensitivity only [Annex III].
The concentration of carbonates and alkalinity is determined by the underlying geology and the type and depth of soil cover. In Ireland the run-off water from catchments with carbonate bearing rocks, such as limestone, and having soils derived from such rocks, have alkalinity values in excess of 300 mg CaCO3/l. These waters are well buffered and not considered acid-sensitive. In contrast the water bodies most sensitive and susceptible to acidification are located in catchments dominated by:
i)Quartz-bearing bedrock, eg Granite and Quartzite, with a shallow, carbonate free soil overburden.
ii) areas with sandy, siliceous soils
iii) highly weathered old leached soils and
iv) deep humic soils (peats) with low buffering capacity.
The initial research in 1990 [ALLOT et alia] concluded that conifer afforestation in these poorly-buffered catchments promotes an increase in acidity, aluminium and dissolved organic matter. Extensive peer group review has confirmed these findings. BOWMAN 1991 observed that run-off from extensive evergreen forests on soils of poor buffering capacity was found to have increased acidity and an associated deterioration in water quality. The Conservation of the Heritage of North West Mayo, by the National Parks and Wildlife Service for Mayo County Council , confirmed environmental damage from acidification in Letterkeen and Maumaratta in County Mayo.
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 [AQUAFOR 4].
Increasing acidity is responsible for mobile inorganic aluminium levels which presents toxic conditions for both fish and macroinvertibrates [AQUAFOR 3].
In general most soils are derived from the underlying bedrock. Due to natural and/or mans' influence pockets of soils with relative high carbonate content can occur overlying bedrock of low carbonate content. Thus, it is not possible to deduce from the maps of acid-sensitive areas, that have been produced to date, whether the run-off water from a specific field or fields is acid-sensitive.
The statutory Irish Heritage Council concluded in 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 [HERITAGE COUNCIL 1998]. Yet at a recent conference organized on November 15 by COFORD [The National Council for Forest Research] The Forest Services' Environmental Auditor stated that no applications could be refused on grounds of acid sensitivity because no assessment procedure to assess the acidification potential of a proposal is in place.
In the following circumstance Environmental Impact Assessments are particularly critical for the protection of Ireland's water quality. Such an assessment must ensure that No further planting or replanting of existing clearfelled land with evergreen trees take place in the following catchments:
1) Acid-Sensitive Catchments of lakes and reservoirs used as sources for potable supplies. Many of these waters are located in the Natural Heritage Areas.
2) Acid-Sensitive Catchments of developed Salmonid Fishery Waters. Such fishery waters to be indicated by the Central and Regional Fisheries Boards and Bord Fáilte who market game angling in these waters. Included are some areas designated as Special Areas of Conservation (SAC's) under the EU Habitats Directive.
3) Acid-Sensitive Catchments of important Salmonid nursery streams. These streams should have been identified as part of Ireland's agreement to protect the Salmon under the Habitats Directive by consultations with the Central and Regional Fisheries Boards.
4) Acid-Sensitive Catchments of first order streams not included in 1 - 3 above.
These measures can be achieved by the Forest Service ensuring an appropriate assessment that will allow them not to grant aid forestry applications in these catchments and by withdrawing the requirement in a clearfelling license that replanting occur at the same site after clearfelling.
Forestry as a factor in Irish surface water acidification:
background and bibliography
A decrease in the diversity of macroinvertibrate communities in acid-sensitive lakes and rivers, resulting from increased acidity, has been reported from Scandanavia (Hendrey and Wright 1975, Engblom and Lingdell 1984), Britain (Harriman and Morrison 1982, Baker and Schofield 1982) and North America (Schindler and Turner 1982).
These changes to macroinvertibrates communities have been shown in response to reduced pH (Raddumand Fjellheim 1984) and to the physiological effect of the combined impact of low pH and the resulting elevated concentrations of metals, such as aluminum; monomeric aluminum, particularly in the inorganic or labile form, has been shown to be toxic to aquatic organisms (Hall, Driscoll, Likens 1987, McCahon et al. 1987). Macroinvertibrate communities can also be altered indirectly by pH induced changes in invertibrate food supply (Friberg et al. 1980) and have been inferred from changes in food abundance (Sutcliffe and Carrick 1973).
Since 1990, there have been a number of studies in Ireland related to the influence of forestry on water quality. The first such study was by Allott et allia (1990), who examined the influence of closed canopy plantation forests on surface water chemistry in Connemara and South Mayo. The study concluded that afforestation promotes an increase in acidity, aluminum and dissolved organic matter in these poorly-buffered catchments.
Bowman (1991) observed that run-off from extensive evergreen forests on soils of poor buffering capacity was found to have increased acidity and an associated deterioration in water quality. Acid-sensitive areas were identified, which are characterised by rain-fed peat soils with high concentrations of organic acids.
Bowman (1992) In a comparison of a non-afforested and afforested catchment demonstrated that while fish were health in the non-afforested catchment, in the afforested catchment stress and was observed, the fish tended to lie at right angles to the flow of water, showing evidence of disorientation and loss of energy followed by death. Post mortem examinations showed extensive coating of aluminum and mucus on the lamella of their gills.
The most comprehensive research project on forestry and water to date was AQUAFOR. It was initiated in 1990 and published as four volumes in 1997.
Part 4 (Allott et allia, 1997) concluded that forestry increases the acid status of streams in poorly buffered catchments by scavenging acidifying ions (pollutants or sea salts) from the atmosphere and on peat soils, by increasing the level of organic acids. The most severely affected streams in the West lacked acid-sensitive invertebrates and were too acid to support self-sustaining populations of salmonids.
Part 3 (Kelly-Quinn et allia, 1997), carried out in Wicklow, highlighted the potential susceptibility of trout stocks and aquatic invertebrates in poorly buffered streams to the effects of forestry-mediated acidification, and recommended changes in the Forestry and Fisheries Guidelines and criteria used to designate sensitivity and recommended forestry practices in the area.
Part 2 (Giller et al, 1997) examined the effects of forestry on surface water quality and ecology in Munster. It concluded that there were no broad-scale detrimental effects of afforestation on stream water quality amongst the sites examined. It also concluded that over-generalisation of the influence of afforestation on stream ecosystems is not possible at a national level. Detailed knowledge of study areas at a local scale is needed for a fuller understanding of the ecological interactions and their causes and solutions.
Part 1 (Farrell et al, 1997) examined the chemistry of precipitation, throughfall and soil water in Cork, Wicklow and Galway. It concluded that in one of three study sites (Roundwood in Wicklow), plantation forestry was generating effects which may be contributing to a deterioration in soil water quality in the forest, while some lesser negative effects were apparent in the study area in Galway (Cloosh).
A literature review, funded by the Forest Service and the EU, by Ryan and Farrell in January 1998 concluded that critical loads should be determined on a catchment basis which "can not be accomplished, however, in the absence of a complete and detailed soil survey for the country."
It is An Taisce's contention that sufficient research now exists to assess the environmental impact of future afforestation in these acid sensitive areas and that any new legislation relating to forest and the EIA process must assure such assessments are undertaken.
Ahern, J. and E. P. Farrell, 1995. Acidification and the Environment. In: Assessing sustainability in Ireland. F Convery and J. Feehan (Eds.) Proceedings of a conference held at University College Dublin, April 18th and 19th, 1995. 53-55.
Allott, N. A, Stream Chemistry of Forest Cover in ten small West of Ireland Lakes, in Environmental Effects of Forestation, Studies in History and Ecology of Afforestation in Western Europe. 1990
Allott, N.A., Mills, W.R.P., Dick, J.R.W., Eacrett, A.M., Brennan, M.T., Clandillon, S., Phillips, W.E.A., Critchley, M. and T.E. Mullins (1990). Acidification of Surface Waters in Connemara and South Mayo. Current status and causes. du Quesne Ltd., 4 Merrion Square, Dublin 2. 61p
Allott, N. 1993. Evaluation of the effects of forestry on surface water chemistry and fishery potential in Ireland. EOLAS Contact ER/90/76. Final Report, Executive Summary. 5p.
Allott, N.A., Brennan, M., Cooke, D., Reynolds, J.D. and N. Simon (1997) A study of the effects of stream hydrology and water quality in forested catchments on fish and invertebrates. AQUAFOR Report, Volume 4. Dept. of Environmental Resource Management/COFORD, UCD, Belfield, Dublin 4.
Bellamy, D., 1986. Bellamy's Ireland, the wild boglands. Wild Ireland Library, County House, Dublin Ireland, p 178.
Bowman, J., 1991. Acid Sensitive Surface Waters in Ireland. The impact of a major new sulpher emission on sensitive waters in an unacidified region. Environmental Research Unit, Dublin. 107 p., 10 Appendix.
Boyle, G.M., Farrell, E.P. and T. Cummins, T., Aherne J., and R. van den Beuken, 1996. Continued monitoring of a Forest Ecosystem in Ireland, BAL23 Poroject, Final Report. Forest Ecosystemn Research Group Report Number 17, Ballyhooley. Department of Environmental Resource Management, University College Dublin.
Boyle, G.M., Farrell, E.P. and T. Cummins, 1997 a. Intensive monitoring Network-Ireland, FOREM 2 project, Final Report. Forest Ecosystem Research Group Report Number 18. Department of Environmental Resource Management, University College Dublin.
Boyle, G.M., Farrell, E.P. and T. Cummins, 1997 b. Monitoring of Forest Ecosystems in Ireland, FOREM 3 project, Final Report. Forest Ecosystem Research Group Report Number 21. Department of Environmental Resource Management, University College Dublin.
Farrell, E.P, 1995. Atmospheric deposition in maritime environment and its impact on terrestrial ecosystems. Water, Air, and Soil Pollution, 85: 123-130
Farrell, E.P., Cummins, T. and G.M. Boyle (1997) Chemistry of precipitation, throughfall and soil water, Cork, Wicklow and Galway regions. AQUAFOR Report, Volume 1. Dept. of Environmental Resource Management, UCD, Belfield, Dublin 4.
Giller, P., O'Halloran, J., Kiely, G., Evans, J., Clenaghan, C., Herhan,
R., Roche, N. and P. Morris (1997) An evaluation of the effects of forestry on surface water quality and ecology in Munster. AQUAFOR Report, Volume 2. Dept. of Environmental Resource Management, UCD, Belfield, Dublin 4.
Jones, S.M., Cummins, T., Boyle, G.M., Aherne, J. and E.P. Farrell, 1998. A pilot study into the effects of clearfelling on nutrient losses and sustainability. MONSTAC Project, Final Report. Forest Ecosystem Research Group Report No. 22, Dept. of Environmental Resource Management, UCD, Belfield, Dublin 4.
Kelly-Quinn, M., Tierney, D., Coyle, S. and J.J. Bracken (1997) Stream chemistry, hydrology and biota, Wicklow region. AQUAFOR Report, Volume 3. Dept. of Environmental Resource Management, UCD, Belfield, Dublin 4.
McGarrigle, M.L., Norton, R., Champ, W.S.T., Shiel, S., Moore, M. and Cox, M (1997) Lough Conn Progress Report. Lough Conn Task Force, Aras an Contae, The Mall, Castlebar, Co. Mayo.
McGarrigle, M.L., Champ, W.S.T., Norton, R., Larkin, P, and M. Moore
(1998). The Trophic Status of Lough Conn: An Investigation into the Causes of Recent Accelerated Eutrophication. Mayo County Council, The Mall, Castletbar, Co. Mayo.
National Parks and Wildlife Service, The Conservation of the Heritage of North West Mayo, for Mayo County Council, Castlebar, Co, Mayo, 1993.
National Parks and Wildlife Service, Briefing Status Report, Lough Leane, County Kerry. September, 1997, Office of Public Works, 52 St. Steven's Green, Dublin 2.
Ryan, M.G and E.P Farrell, 1998. Assessing the sensitivity of surface waters to acidification: A literature review. Forest Ecosystem Research Group Report No. 25, Dept. of Environmental Resource Management, UCD, Belfield, Dublin 4.
Whilde, A (1993): Threatened mammals, birds, amphibians and fish in Ireland. Irish red data book 2: vertebrates. HMSO, Belfast.