Felling Licence Applications – initial insights into the consultation process with Inland Fisheries Ireland

AIE-022-018-IFI

As part of an AIE request, we are seeking to understand the process whereby DAFM Forest Service refer forestry applications to Inland Fisheries Ireland for feedback

Overview

This table outlines the number of forestry applications (nationally) assessed by IFI Environmental Officer for the period January – July 2022:

DAFM FS refer a significant volume of licence applications to IFI, so we took a look initially at just the referrals for the East River Basin District (ERBD), and then focused in on Wicklow, and on just the clearfell referrals.

Note email below to Eastern River Basin District (ERBD) on July 15th 2022 from the Department of Agriculture, Food and the Marine in relation to felling licence applications.

From the licence application list provided the IFI local Environmental Office initially screened out applications in the Wicklow area and then further refined the felling applications to be commented on, based primarily on their proximity to a watercourse and the sensitivity of the watercourse and provided a response in respect of these applications.

There was a total of 79 applications in this tranche for the Wicklow area with a total of 45 responses submitted by IFI from the time of receipt on 15/07/2022 to 04/08/2022.

The responses are generic in their content however there is also individual elements specific to each river or clearfell application contained within each response.

IFI confirmed that the resources to do a deep dive into each application is not available and would probably involve site visits.

FL App RefHarvest Block AreaCountyTownlands
DU02-FL01466.97DublinBallinascorney Upper  
DU02-FL01477.7DublinBallinascorney Upper  
DU02-FL01485.37DublinKillakee, Mountpelier  
DU02-FL01494.05DublinKilmashogue  
DU02-FL01505.91DublinCruagh  
DU02-FL01514.01DublinMountpelier  
DU02-FL01529.02DublinCruagh, Tibradden  
DU02-FL015331.77DublinRathmichael, Shankill  
DU02-FL01552.92DublinCruagh  
DU02-FL01560.41DublinTibradden  
DU02-FL01572.96DublinKillakee  
WW01-FL012220.96WicklowBallynultagh  
WW01-FL01239.19WicklowBallynultagh  
WW01-FL01247.96WicklowBallynasculloge Lower, Ballynatona, Ballysmuttan Upper  
WW01-FL012518.14WicklowBallyfoyle  
WW02-FL01057.37WicklowBallybrew  
WW02-FL010621.37WicklowCloon  
WW02-FL010711.66WicklowAnnacrivey, Ballybrew, Kilmalin  
WW02-FL01081.99WicklowDeerpark  
WW02-FL010911.59WicklowCloon, Tonygarrow  
WW02-FL01106.61WicklowCrone  
WW02-FL01113.67WicklowAnnacrivey, Curtlestown Upper  
WW02-FL011211.13WicklowDeerpark  
WW02-FL01131.65WicklowAnnacrivey  
WW02-FL01142.11WicklowBallyreagh, Crone  
WW02-FL011511.11WicklowBallyreagh, Ballyross  
WW03-FL008413.83WicklowDownshill  
WW03-FL00854.26WicklowGlasnamullen  
WW03-FL00863.18WicklowKilmurry, Merepark  
WW03-FL00876.33WicklowBallinahinch Middle, Ballinahinch Upper  
WW03-FL00888.68WicklowBallinahinch Upper, Callowhill Lower, Callowhill Upper, Kilday  
WW03-FL009081.39WicklowCarrignamuck Lower, Dunran Demesne, Dunranhill, Keeloge Lower, Kiltimon, Mountjohn, Prospect Upper  
WW04-FL01198.45WicklowTrooperstown  
WW04-FL01204.8WicklowDrummin  
WW04-FL01217.17WicklowBallard, Ballard Park  
WW04-FL01225.8WicklowDerrybawn  
WW04-FL01233.37WicklowLugduff  
WW04-FL012416.03WicklowBrockagh  
WW05-FL013110.01WicklowBrockagh  
WW05-FL01324.26WicklowCorragh  
WW05-FL013322.28WicklowBallinagee, Glenbride  
WW06-FL03007.01WicklowBlackrock, Slieveboy Upper  
WW07-FL020812.43WicklowAghavannagh (Revell)  
WW07-FL02093.12WicklowBaravore  
WW07-FL021010.38WicklowDrumgoff  
WW07-FL021111.01WicklowAghavannagh (Revell)  
WW07-FL021225.01WicklowBallyboy  
WW07-FL021310.68WicklowClohernagh  
WW07-FL02144WicklowDrumgoff  
WW07-FL021519.33WicklowCarriglinneen, Kirikee  
WW07-FL02165.9WicklowCullentragh Little  
WW07-FL02174.1WicklowBallyboy  
WW07-FL02184.59WicklowClohernagh  
WW07-FL02198.2WicklowClonkeen,Corrasillagh  
WW07-FL02202.03WicklowCarriglinneen  
WW07-FL022210.17WicklowAghavannagh (Revell)  
WW07-FL02232.81WicklowAghavanagh (Ram), Aghavannagh (Revell)  
WW07-FL022413.09WicklowAghavanagh (Ram), Aghavannagh (Revell)  
WW07-FL02253.18WicklowAghavanagh (Ram)  
WW07-FL022618.95WicklowAghavanagh (Ram), Aghavannagh (Revell), Drumgoff  
WW07-FL02274.35WicklowAghavannagh (Revell)  
WW08-FL02074.87WicklowBallymacsimon  
WW08-FL02085.05WicklowBallinacooley, Kilnamanagh More  
WW08-FL02093.9WicklowBallycullen  
WW08-FL02102.59WicklowBarnbawn, Garryduff  
WW09-FL01884.22WicklowBallintombay Upper, Ballydowling Hill  
WW09-FL01894.46WicklowBallinvally Lower  
WW09-FL01904.69WicklowBallinvally Lower, Ballykillageer Lower  
WW09-FL01916.72WicklowBallyshane  
WW09-FL01925.09WicklowBallintombay Upper  
WW09-FL01932.1WicklowBallyteige  
WW09-FL01945.31WicklowBallinvally (Valentine), Ballydonnell  
WW09-FL01953.18WicklowBallinacarrig Lower  
WW09-FL01964.64WicklowKilmacrea Upper  
WW09-FL019732.51WicklowBollahoney, Mongan  
WW09-FL01982.68WicklowKilmacrea Lower  
WW10-FL024313.4WicklowKilballyowen, Roddenagh  
WW10-FL02457.27WicklowBallygobban  
WW10-FL024611.86WicklowBarnameelia, Farbreaga  
WW10-FL024720.64WicklowBallinagappoge, Rosahane  
WW10-FL02488.53WicklowCoolgarrow  
WW10-FL02497.67WicklowBallyteige  
WW10-FL02508.79WicklowBallinagappoge, Mucklagh  
WW10-FL02510.83WicklowBallinagappoge  
WW10-FL02526.93WicklowBallygobban  
WW11-FL01102.46WicklowBallinasilloge, Knocknagilky Upper, Knocknaskeagh  
WW12-FL00110.66WicklowBallytrasna, Kingston  
WW12-FL0012118.59WicklowAvondale, Balleese Wood, Ballinacarrig Upper, Ballytrasna, Corballis Lower, Kingston, Rockstown Lower, Ticlash, Timullin  
WX01-FL01402.18WexfordBallythomas  
WX01-FL014120.31Wexford, WicklowBallythomashill, Carrig, Curraghlawn  
WX01-FL014211.99WexfordCarrig, Croghan Mountain

Standard referral letter from DAFM FS to IFI

Note: DAFM FS allow a 4 week timeframe for response, but often batch large volumes for consultation on the same day. This is likely to overwhelm the available resources of the consultation body, in this case the IFI. Consultation bodies can apply for an extension.

Dear Sir/Madam,

With regard to applications for felling licences, pursuant to Section 17(5)(a) of the Forestry Act 2014, the Minister may consult any person whom he or she considers to be appropriate. To this end, the Minister issues felling licence referrals to a number of statutory authorities and other bodies of which Inland Fisheries Ireland is one. Inland Fisheries Ireland is now invited to submit comments and observations in respect of the felling licences referenced in the above table. The timeframe in which a response is expected is four weeks. Please note, if no response is received within this timeframe, “No Comment” will be noted in respect of the files listed above. Should you require an extension please notify the Dept as soon as possible.

While the Minister will have regard to any written submissions or observations received in respect of any such felling licence application so referred, he or she must be mindful that where he or she decides to grant a licence, in whole or part, with or without conditions, in attaching any such conditions to the licence, those conditions must be within the powers conferred upon him or her by statute, and will be guided in doing so by the following criteria for the imposition of conditions, namely that they are necessary, relevant to the project or activity for which a licence has been sought, enforceable, precise, and reasonable.

The Minister will also have due regard to other statutory obligations placed upon him or her, as well as taking account of the relevant policies or objectives of the Government as regards the development and promotion of forestry in a manner that maximises the economic, environmental and social value of forests within the principles of sustainable forest management.

Applications referred to you are available to view in the Forestry Licence Viewer.  The FLV may be found here https://forestry-maps.apps.rhos.agriculture.gov.ie/ .  The user will be able to see the site boundaries and can see other applications for forestry licences in the area (applications from 1st January, 2018).  Looking at a specific application by keying in the reference number in the search box, the user can view the application documents, including maps.

Please quote the above Felling Licence reference numbers in all correspondence, and return any response to Felling.forestservice@agriculture.gov.ie

Kind regards,

Clerical Officer, Felling Section,  Forest Service

__

An Roinn Talmhaíochta, Bia agus Mara

Department of Agriculture, Food and the Marine

Eastát Chaisleán Bhaile Sheáin, Co. Loch Garman, Y35 PN52

Johnstown Castle Estate, Wexford, Y35 PN52

Records released (Schedule)

The proposed clear felling refers to lands in the upper catchment of the Ballydonnell Brook_010 which has a current WFD status of Moderate and which must be improved to a minimum of good status.

The Ballydonnell Brook is a tributary of the River Liffey which flows into Poulaphouca Reservoir, the main drinking water supply source for the greater Dublin area.

The clear-felling is in an area of peaty soils, raises concerns about peat deposits entering watercourses resulting from forestry harvesting activities, posing a significant environmental threat to water quality.

Poor water quality will impact upon fish, benthic invertebrates and aquatic flora and these are the primary biological elements used in the classification of waters in the context of the WFD.

The proposed clear felling refers to lands in the catchment of the River Liffey_30 which has a current WFD status of Good and which must be maintained.

The River Liffey at this point flows into Poulaphouca Reservoir, the main drinking water supply source for the greater Dublin area.

The clear-felling raises concerns about suspended solids and nutrients entering watercourses resulting from forestry harvesting activities, posing a significant environmental threat to water quality.

Poor water quality will impact upon fish, benthic invertebrates and aquatic flora and these are the primary biological elements used in the classification of waters in the context of the WFD.

The proposed clear felling refers to lands in the catchment of the River Liffey_30 which has a current WFD status of Good and which must be maintained.

The River Liffey at this point flows into Poulaphouca Reservoir, the main drinking water supply source for the greater Dublin area.

The clear-felling raises concerns about suspended solids and nutrients entering watercourses resulting from forestry harvesting activities, posing a significant environmental threat to water quality.

Poor water quality will impact upon fish, benthic invertebrates and aquatic flora and these are the primary biological elements used in the classification of waters in the context of the WFD.

The proposed clear felling refers to lands in the catchment of the Glencree River_010 which has a current WFD status of Good and which must be maintained.

This Glencree river is an important salmonid system supporting populations of Atlantic salmon, Sea trout and Brown trout.

It represents a valuable resource both in terms of local natural heritage (biological diversity value) and particularly from a native fisheries perspective.

The clear-felling raises concerns about suspended solids and nutrients entering watercourses resulting from forestry harvesting activities, posing a significant environmental threat to water quality.

Poor water quality will impact upon fish, benthic invertebrates and aquatic flora and these are the primary biological elements used in the classification of waters in the context of the WFD

The proposed clear felling refers to lands in the catchment of the Glencree River_010 which has a current WFD status of Good and which must be maintained.

This Glencree river is an important salmonid system supporting populations of Atlantic salmon, Sea trout and Brown trout.

It represents a valuable resource both in terms of local natural heritage (biological diversity value) and particularly from a native fisheries perspective.

The clear-felling raises concerns about suspended solids and nutrients entering watercourses resulting from forestry harvesting activities, posing a significant environmental threat to water quality.

Poor water quality will impact upon fish, benthic invertebrates, and aquatic flora and these are the primary biological elements used in the classification of waters in the context of the WFD.

The proposed clear felling refers to lands in the catchment of the river Dargle_020 which has a current WFD status of Good and which must be maintained.

This Dargle river is an important salmonid system supporting populations of Atlantic salmon, Sea trout and Brown trout and is a designated in accordance with Salmonid River Regs (S.I. 293) affording the river extra protection in law.

It represents a valuable resource both in terms of local natural heritage (biological diversity value) and particularly from a native fisheries perspective.

The clear-felling raises concerns about suspended solids and nutrients entering watercourses resulting from forestry harvesting activities, posing a significant environmental threat to water quality.

Poor water quality will impact upon fish, benthic invertebrates, and aquatic flora and these are the primary biological elements used in the classification of waters in the context of the WFD.

The proposed clear felling refers to lands in the catchment of the Glencree River_010 which has a current WFD status of Good and which must be maintained.

This Glencree river is an important salmonid system supporting populations of Atlantic salmon, Sea trout and Brown trout.

It represents a valuable resource both in terms of local natural heritage (biological diversity value) and particularly from a native fisheries perspective.

The clear-felling raises concerns about suspended solids and nutrients entering watercourses resulting from forestry harvesting activities, posing a significant environmental threat to water quality.

Poor water quality will impact upon fish, benthic invertebrates, and aquatic flora and these are the primary biological elements used in the classification of waters in the context of the WFD.

The proposed clear felling refers to lands in the catchment of the Glencree River_010 which has a current WFD status of Good and which must be maintained.

This Glencree river is an important salmonid system supporting populations of Atlantic salmon, Sea trout and Brown trout.

It represents a valuable resource both in terms of local natural heritage (biological diversity value) and particularly from a native fisheries perspective.

The clear-felling raises concerns about suspended solids and nutrients entering watercourses resulting from forestry harvesting activities, posing a significant environmental threat to water quality.

Poor water quality will impact upon fish, benthic invertebrates, and aquatic flora and these are the primary biological elements used in the classification of waters in the context of the WFD.

The proposed clear felling refers to lands in the river Vartry_010 catchment, and which has a current WFD status of Good and which must be maintained.

This Vartry river at this point is an important nursery system supporting populations of Brown trout. It is also part of the water supply to the Vartry water treatment works.

It represents a valuable resource both in terms of local natural heritage (biological diversity value) and particularly from a native fisheries perspective.

The clear-felling raises concerns about suspended solids and nutrients entering watercourses resulting from forestry harvesting activities, posing a significant environmental threat to water quality.

Poor water quality will impact upon fish, benthic invertebrates, and aquatic flora and these are the primary biological elements used in the classification of waters in the context of the WFD.

The proposed clear felling refers to lands in the catchment of the Newtownmountkennedy river_020 which has a current WFD status of Poor and which must be improved to Good Status by 2027.

The Newtownmountkennedy river is under severe pressure from various sources and must not be subjected to any further activities that will exacerbate the status of the river.

The clear-felling raises concerns about suspended solids and nutrients entering watercourses resulting from forestry harvesting activities, posing a significant environmental threat to water quality.

Poor water quality will impact upon fish, benthic invertebrates, and aquatic flora and these are the primary biological elements used in the classification of waters in the context of the WFD.

The proposed clear felling refers to lands in the catchment of Ballymacahara and the Inchanappa streams, both of which has a current WFD status of Good and which must be maintained.

Both streams are of important nursery habitat, supporting populations of Brown trout.

The clear-felling raises concerns about suspended solids and nutrients entering watercourses resulting from forestry harvesting activities, posing a significant environmental threat to water quality.

Poor water quality will impact upon fish, benthic invertebrates, and aquatic flora and these are the primary biological elements used in the classification of waters in the context of the WFD

The proposed clear felling refers to lands in the catchment of the Avonmore_040 which has a current WFD status of High and which must be maintained.

The Avonmore River is an important salmonid system supporting populations of Atlantic salmon, and Brown trout.

The area of felling is directly adjacent to the Wicklow Mountains SAC which must be protected.

It represents a valuable resource both in terms of local natural heritage (biological diversity value) and particularly from a native fisheries perspective.

The clear-felling raises concerns about suspended solids and nutrients entering watercourses resulting from forestry harvesting activities, posing a significant environmental threat to water quality.

Poor water quality will impact upon fish, benthic invertebrates, and aquatic flora and these are the primary biological elements used in the classification of waters in the context of the WFD.

The proposed clear felling refers to lands in the catchment of the Avonmore_050 which has a current WFD status of Good, and which must be maintained.

The Avonmore River is an important salmonid system supporting populations of Atlantic salmon, and Brown trout.

The river represents a valuable resource both in terms of local natural heritage (biological diversity value) and particularly from a native fisheries perspective.

The clear-felling raises concerns about suspended solids and nutrients entering watercourses resulting from forestry harvesting activities, posing a significant environmental threat to water quality.

Poor water quality will impact upon fish, benthic invertebrates, and aquatic flora and these are the primary biological elements used in the classification of waters in the context of the WFD.

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