31/5/21
Submitted by Michael Cantwell, Chairperson, on behalf of the full Working Group
Working Group 1 (WG1) chaired by Mr Michael Cantwell has met 9 times since the announcement by Minister Hackett of Project Woodland. WG1 has responsibility for addressing the backlog issues as outlined in Jo O’Hara’s report. The group has discussed the many variables that have led to and caused the backlog of files in the Forestry Division of the Department of Agriculture, Food & the Marine (DAFM).
The overarching issue according to the group is the issue of the process by which DAFM handles licences in particular the Appropriative Assessment (AA) procedure. The main issue is the number of files in the ecology section. Currently around 75% of files are screened in for AA based on the current procedure deployed by DAFM. The basis of this is that all files regardless of size/type are screened at a 15 km radius to assess impacts on Natura 2000 sites. The European Habitats Directive forms the legal basis of the requirement for a competent authority to carry out an assessment of likely/possible impacts on the network of Natura 2000 sites. The Habitats Directive does not specify a specific distance in the requirement to carry out this assessment.
The group also took time and reviewed an output of data produced by DAFM outlining the status of all files held by DAFM at a point in time. There was some discussion about the number and type of statuses and would they be useful for stakeholders. One of the issues that became apparent was how difficult it is for DAFM to extract accurate data from their IT system IFORIS. A large number of files in the road & afforestation categories had been started by an agent but not submitted to the DAFM amounting to around 950 files. It was generally agreed that only files actually submitted to DAFM should be considered however figures relating to files started but not submitted should be made available to highlight the issue to stakeholders. The group considered that files started but not submitted should be removed from the system after a period of time but only after notifying the applicant.
The Group discussed the new initiatives that are being implemented by DAFM to reduce the backlog including recruiting additional resources, introducing a fee for appeals, etc. The group considered all these actions to be appropriate but also considered that the impact they are making on the backlog is communicated to the industry. This can be accomplished by implementing Recommendation 4 below.
The group discussed in detail the issue of the current road consent system and how it would be beneficial to bring a road grant in at forest establishment stage. Previous forestry programs had a forest management track grant. This provided for access to the forest when the crop was being established for long term management purposes. This would negate the requirement for another road consent process when the site is ready for harvesting albeit some form of upgrade. This management road grant could be applied for at afforestation stage in tandem with the afforestation application. This will also ensure that any access issues on to public roads are dealt with in advance of the site being planted.
Other issues discussed included the need for more training support to forest owners, contractors, foresters and inspectors with a view of improving applications. Training was also identified as a need to address shortcomings in applying the rules and standards. There was broad consensus that forest operations should not have a negative impact on the receiving environment. Therefore, it was considered by the group that dedicated Ecological Training modules be introduced to ensure environmental protection as well as to assist in facilitating the Licence Process.
There was also a collective view that the forest licensing process in other European countries should be examined with a view of changing the current system in Ireland. The group discussed the possibility of removing the need for a licence for thinning operations and even forest roads. In many European countries licences are not required for many operations currently requiring a licence in this jurisdiction.
In addition, the group discussed and questioned the need for licences (AA screening) for all applications regardless of size or species and suggested that these issues and other related issues be considered as part of recommendation 2. Recommendations 1 to 3 will have an immediate direct impact on the backlog, recommendations 3 to 6 will have a longer term indirect impact.
Based on these figures the following licences will be required by the sector to meet those targets/production forecasts for 2022:
