1. Given Ireland's and the EU's climate change obligations, the ecosystem services provided by even non-designated bogs, the opportunity to alleviate fuel poverty by the wise application of the public funds being provided, and the obligation to spend public money in accordance with all policy priorities, relocation to other bogs should not be permitted as mechanical turf cutting is not compatible with conservation.


2. If relocation is permitted notwithstanding, it can not be to the 75 Raised Bogs or 73 blanket bogs which Ireland designated in 2003-2005 under national legislation as part of the terms of the agreement with the European Commission for the withdrawal of the Commission’s request to the European Court of Justice for daily fines [C-294/03].


3. Machinery must be removed from all 55 protected sites at the end of this season with carefully made consolidated peat drain blocking to take place on every drain every 12 metres [Guidelines from NPWS required].


4. Roads with no purpose other than access to SAC or NHA bogs which could be used for turf extraction or dumping to be blocked against machinery entry or indicated otherwise when blocking is unrealistic.


5. All SAC and NHA bogs must be signed at all entrances with clear information and warnings (e.g. information sign stating that the site is part of the Natura 2000 network, explanation of site's importance, warnings against damaging activities).


6. The Habitats Directive obligation to undertake surveillance of the habitats and to report regularly on the conservation status must be scheduled comprehensively for 2011 and 2012 with Hydrological/ecological monitoring to be developed for all SAC and NHA bogs and their recovery as seen at Killyconny.


7. Programmed removal of trees invading SAC or NHA raised bogs where appropriate.


8. Rangers must be instructed in writing to report all damage to ALL protected habitats when detected.


9. The forms and manner of enforcement must be made clear.


10. The Qualifying Criteria for Annuity Payment Scheme and the Relocation Scheme will be enforced and no application will be accepted by any party where turf cutting was ceased by Cabinet decision of May 2010 and yet turf cutting or associated activity is ongoing on the property or has occurred in 2011.




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