April 2021

The NPWS proposal for a “peer review” of Rhododendron control/eradication in Killarney National Park arose following a complaint to the European Commission by Groundwork Conservation Volunteers. The Groundwork complaint contended that a widespread significant deterioration had occurred in the conservation status of the Habitat Directive Annex I oakwood habitat in the west of Killarney National Park which constituted a breach of 92/43/EEC Article 6(2).

The habitat deterioration was caused by a deterioration in the rhododendron status of c.350ha of the western oakwoods which were cleared and maintained clear (sensu Irish Wildlife Manual No.33) of rhododendron by Groundwork in the period 1981 to 2005. This deterioration occurred when the woods in question were managed according to the procedures and methods then applied by KNP subsequent to the termination of the Groundwork maintenance.

In April 2017 NPWS contacted Mr Colin Edwards (Environment Policy Advisor at Scottish Forestry) stating that NPWS “is currently reviewing its strategy and methods for rhododendron management in Killarney National Park” and further stating “There has been some recent criticism of the progress and efficacy of the National Park’s management programme, and there is now a need for the most recent strategy to be
reviewed.” Mr Edwards’ immediate response to the initial short email was that he would be “happy in principle to act as an external reviewer”. A series of communications were exchanged between Mr Edwards and NPWS over several months, but Mr Edwards entered into no agreement to participate in the project (as revealed in AIE records). Nevertheless, in answer to a parliamentary question on 14 July 2020, Minister for Culture, Heritage and the Gaeltacht Catherine Martin (briefed presumably by NPWS) stated, “Despite agreement to participate from an independent overseas expert, it has subsequently not proved possible for him to undertake the review.”

“Happy in principle” (having received a six-line introductory email) and an “agreement to participate” are not the same thing.

In its UNESCO Biosphere Review of 2017, NPWS committed to an independent peer review to examine current rhododendron management practice in KNP. The review stated, “There has been some disagreement between the National Park authority and two stakeholder NGOs concerning the effectiveness of the maintenance programme …It is therefore planned to address this by … peer review of management practice…”

In its 2019 letter to the EU attempting to refute GW’s second formal complaint, NPWS stated that it had “put in place measures to provide independent expert review and advice on the rhododendron programme in Killarney National Park”.

In its letter to the Irish Times of 27 May 2019 NPWS stated, “This Department has also already commenced the process of a peer review ..” In her answer to the parliamentary question on 14 July 2020 Minister for Culture, Heritage and the Gaeltacht Catherine Martin stated “the NPWS contracted an expert environmental company to undertake part 1 and 2 of this review. This work is now under way. The NPWS is open, and indeed is expecting, that the review will look at all relevant methods, issues and approaches, including that of the group mentioned by the Deputy.” We are aware that MKO is the expert environmental company referred to by the Minster and we believe that the “group” mentioned in the PQ
response is Groundwork.

On 6 August 2020 Groundwork was informed by Dr Philip Buckley (NPWS) that “The Peer Review is ongoing and currently under preparation by the consultants …” On 5 October 2020 Mr Trevor Donnelly (NPWS) further informed Groundwork that “the scope/approach of the review was finalised with the consultants in July 2019”. From the outset NPWS has emphasised the preeminent importance of the independent / external aspect of the proposed review. In February 2019 NPWS stated to the Irish Times “We hope it will be a fundamental and thorough review of all aspects of the work on rhodo in Killarney. We intend to bring the Groundwork reports (and work) to the attention of the reviewer(s), but exactly what they will focus on we can’t say or dictate.” In May 2019 NPWS informed MKO that “The review should seek to document what work has been done in KNP over the years, and determine as quantitively as possible how effective or not that has been. Both the strategy, programme and specific measures should be reviewed/evaluated. …Given we want it to be an ‘external process’, what how you go about/structure (sic) the review after that may be largely for you to decide.”

Given the independent /external nature of the review; given the stated centrality of Groundwork’s methods, programmes and views to the review; given that Groundwork’s methods, programmes and views have over a period of years been consistently and publicly criticised/ rejected by NPWS; and given that eighteen months after the scope/approach of the review was finalised no contact has yet been made with Groundwork by the reviewers, it would appear that Groundwork’s methods, programmes and views have been channelled/ articulated to the consultants by NPWS. This is obviously inappropriate as it nullifies the review, the primary purpose of which is to serve as independent enquiry.

To redress this, we have compiled the present submission

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