BirdWatch Ireland Submission to the draft Forest Strategy and Draft Forest Strategy Implementation Plan

Key Messages


1. Since 2014, the Forestry programme 2014-2022 has sanctioned the planting of 13,719 hectares or 14.1% of forestry planted nationally (Coillte and private planting) in hotspots for 6 of our most threatened breeding waders in Ireland.

2. Since 2014, the Forestry programme 2014-2022 has sanctioned the planting of 6,538
hectares or 6.7% of forestry nationally (Coillte and private planting) in hotspots important
for 28 of our red and amber listed birds of conservation concern.

3. BirdWatch Ireland mapping shows that since 1990 78,606 or 14.6% of total forestry planted
has been in breeding wader hotspots and 37,036 or 6.7% of total forestry planted in farmland
bird hotspots.

4. BirdWatch Ireland mapping shows that the total forestry replanted since 2014, within Breeding Hen Harrier SPAs is 12,382 [hectare] or 12.7% despite there being a moratorium on planting in place in that time period.

5. This is evidence that Ireland is in breach of the Birds Directive and the conditions of the European Commission State Aid Decision granting consent for the provision of €200 million to fund the 2014 Forestry Programme including:
a. Projects must be undertaken in compliance with national and EU legislation (e.g. several articles of the Birds Directive).
b. The condition to avoid planting on environmentally sensitive sites and
c. The inappropriate afforestation of sensitive habitats such as peat lands and wetlands will be avoided, as well as the negative effects on areas of high ecological value including areas under high natural value farming.

6. A disproportionate amount of forestry is being planted in important areas for birds in the wider countryside. There are likely several reasons for this.
a. There is no strategic planning of afforestation in Ireland
b. There is no ornithological assessment of sites/applications being proposed for afforestation.
c. The Land Types for Afforestation document which provides guidance on the land which can be planted, is potentially a driver of loss of Annex 1 habitat and habitat for birds and other biodiversity
d. The payments and tax-free status of afforestation premia are lucrative. No agri-environment scheme which would pay farmers to continue to farm for threatened bird species can compete. This creates the risk that even more areas of land will be opened up for afforestation further threatening bird species.

7. The draft Forestry Implementation plan for 2023-2030 which is underpinned by an almost 7-fold increase in funding does not contain any evident changes in individual environmental assessment of afforestation applications to account for the presence or absence of birds on a site proposed for afforestation compared to the 2014-2022 Forestry Programme. It is clear therefore that we can expect further losses of habitat important for breeding waders and other farmland birds unless changes are made.


8. The environmental assessments of the draft Forestry Programme fail to consider the impacts on the different measures on red and amber listed birds in the wider countryside. There is also woefully inadequate assessment of Annex 1 bird species in the wider countrywide (e.g. geese and swans) in breach of Article 6.3 of the Habitats Directive and various European Court of Justice rulings. The Article 12 reporting research only extracted data relating to Annex 1 species that are qualifying interests of an SPA are considered in this AA report and what is reported is incorrect. Also unclear as to why the BoCCI status of Curlew, a red listed
species for breeding and wintering has N/A status associated with Table 4 in the NIS. The BoCCI status for a range of red and amber listed species is listed as N/A with no rationale as to why. These should be listed.


9. The analysis of the effects of the Programme on Annex 1 species is extremely limited. It focuses in on Annex 1 species with ‘bad’ or ‘inadequate’ status that are already identified as being affected by forestry activities (according to Article 12 code)

10. Species assessments in NIS. The NIS only focuses on Merlin and Hen Harrier and fails to assess impacts on a range of other Annex 1 species or the conservation interests of the SPAs.


11. Incombination assessment of other plans and programmes is extremely general. For example the statement that the IFSIP is ‘broadly in line with the EU biodiversity Strategy’. Afforestation is a significant pressure and threat to a range of threatened bird species whose populations must be restored. Assessment fails to consider this.

12. The cumulative impacts of afforestation, intensification of agriculture, peat cutting, wind farm development etc have not been adequately considered in the environmental assessments of the draft Forestry Programme.

13. It is of serious concern to us that a farmer signed up to an ACRES contract can end that contract to afforest his/her land and not be subject to penalties.

14. The fact that a farmer can receive the Basic Payment which requires adherence to Article Article 3(1), Article 3(2)(b), Article 4 (1),(2), and (4) covering legal protection for birds and a requirement to protect birds in the wider countryside and receive an afforestation payment which wipes out habitat for birds is discordant and an abuse of taxpayers money. Taxpayers are paying on the double for both the protection of habitats and their destruction. This must change.


15. Unless afforestation is planned strategically with clear objectives and processes is put in place to avoid afforestation in important areas for birds, breeding waders in particular could be wiped out as a result of the state’s forestry programme to 2030.

Section 12 Water Pollution Notices – forestry activities in Leitrim – 2022

AIE Request

For the period 1 January 2022 to 31 December 2022 (both dates inclusive) please provide, by email, a copy of all Notices served under Section 12 of the Local Government (Water Pollution)  Act 1977 in relation to forestry activities. (Other non-forestry related  Section 12 Notices are not requested) 

Euroforest Timber Ltd

Water pollution at Attimanus, Kilnagross, Leitrim

Coillte

Water pollution at Tullywana, Gubnaveagh, Leitrim (LM09-FL0043)

Coillte

Water pollution at Crumpaun, Leitrim (LM01-FL0010 & LM01-FL0011)

Irish Forestry Unit Trust (IForUT)

Established in 1994, it manages Irish pension fund and charity investment in forestry. IForUT’s unit holders include many of the major Irish pension funds and investment managers.

The forest portfolio comprises of commercial forest plantations covering over 20,000 hectares.

The assets of the Trust are held by a Trustee on behalf of investors.

IForUT Forestry Management Limited is an authorised Alternative Investment Fund Manager regulated by the Central Bank of Ireland.

Portfolio

Carlow

Summary Plan Carlow MP 2022-2026.pdf

Cavan

Clare

Cork

Donegal

na

Dublin

na

Galway

Kerry

Kildare

South Kildare Summary Plan 2022-2026.pdf

Kilkenny

Laois

Leitrim

Limerick

Longford

Summary Plan Knockagh MU MP 2022 – 2026.pdf

Louth

na

Mayo

Meath

na

Monaghan

na

Offaly

na

Roscommon

Sligo

Tipperary

Waterford

Westmeath

na

Wexford

Monbay Summary Plan 2021-2025.pdf

Wicklow

IRISH FORESTRY UNIT TRUST FORESTRY NOMINEES LIMITED

The Yield Class or Anticipated Yield Class of all compartments of Coillte’s forest estate

AIE Request 20220618

The yield class of timber is a measurement of increment (the amount of solid stem wood added to an area of woodland) in cubic meters per hectare per year (m3/ha/yr).

AIE Request: The Yield Class or Anticipated Yield Class of all compartments of Coillte’s forest estate.

I wish to receive the information in GIS format (ERSI Shapefiles with attribute data including the Yield Class or Anticipated Yield Class, Forest Code, Forest Name and Property Name.”

Appeal to OCEI

Woodland Register | Department of Agriculture, Environment and Rural Affairs (Northern Ireland)

The Northern Ireland woodland register provides data in tabular format on the area of forest or woodland, by forest or woodland type, and whether managed by the Forest Service or not. This dataset is derived from a basemap consisting of forests and woodlands throughout Northern Ireland with a minimum size of 0.1 hectare (Ha).

Details

Forests and woodlands are recorded as broadleaf, conifer, mixed (conifer and broadleaf), short rotation coppice, or, where no information is available, of unknown type. Land classified by DAERA as dense scrub is recorded as broadleaf woodland. Additional categories, such as areas awaiting replanting or awaiting natural regeneration, and open ground considered integral to the woodland (e.g. forest roads, glades, rides and fire breaks) are also included.

The woodland basemap has been compiled using Geographic Information datasets provided by statutory and non-statutory bodies. The 2022 woodland register updates the 2021 woodland register.

The basemap is used to produce a map showing forest and woodland cover. Boundaries shown on the map do not reflect legal boundaries and should be treated as indicative. While every effort is made in preparing material for publication, no responsibility is accepted by or on behalf of the Department of Agriculture, Environment and Rural Affairs for any errors or omissions contained in the map of forest and woodland cover in Northern Ireland.

Although generally synonymous, the terms ‘forest’ and ‘woodland’ are used here to respectively represent a relatively large land holding managed primarily to grow trees for a defined, non-agricultural purpose (such as the supply of wood products for industrial use), and, an area of trees of at least 0.1 hectare (0.25 acre) forming part of a land holding and managed in such a way as to complement the rest of the land holding.

https://www.daera-ni.gov.uk/publications/woodland-register

JOINT COMMITTEE ON AGRICULTURE, FOOD AND THE MARINE: Coillte (13 December 2022)

Ms Imelda Hurley, chief executive of Coillte and Mr. Mark Carlin, managing director of Coillte

Coillte is the largest forester in Ireland, responsible for managing 440,000 ha, that is, 7% of the land area of Ireland

The Group’s forest holdings comprise approximately 365,347 hectares of forestland in the Republic of Ireland and approximately 15,746 hectares of standing forest plantations established on leased land (as per 2021 annual report)

Coillte estate accounts for around half of Ireland’s forests

Employ 840 staff and support approximately 1,200 direct contractors

Ireland has one of the lowest levels of forest cover in Europe, at approximately 11.6%, in comparison with a European average of over 40%

Coillte is comprised of three operational segments, namely, Coillte Forest, land solutions, and Medite Smartply

90,000 ha of estate (20%) is currently managed primarily for biodiversity

Developed a science-based approach called BioForest, which classifies the ecological value of the biodiversity areas in our estate, and allows us to develop ecological and silvicultural plans to enhance or restore sites to improve biodiversity

Coillte land solutions division provides innovative commercial solutions to support industries such as renewable energy, housing, healthcare, education, infrastructure development, water and tourism

2021, with the ESB, launched a new joint venture renewable energy company, FuturEnergy Ireland, to develop wind energy

Coillte Nature is part of our overall land solutions division. It operates on a not-for-profit basis and is dedicated to the restoration, regeneration and rehabilitation of nature through large-scale projects across four strategic themes, namely, afforesting, restoring, regenerating and rehabilitating.

Medite Smartply division consists of manufacturing mills in Clonmel, for Medite and Waterford for Smartply, which produce engineered wood-based construction panels

Aim to enable the creation of 100,000 ha of new forests by 2050

Wild Western Peatlands project will restore and rehabilitate approximately 2,100 ha of Atlantic blanket bog and wet heath, currently planted with spruce and pine forests in Derryclare, County Galway

Coillte to NPWS land transfers

Q. What is the total area for commercial timber at the moment?

A. As a primary goal for wood, approximately 250,000 ha of the estate, which is half the estate. There are approximately another 50,000 ha to 60,000 ha where we still harvest wood, but it is not the primary objective.

Q. Is there a planting obligation on those 30,000 ha (forestry on bogs) or is the Department going to let Coillte out from that?

Felling

Land sales

Public land

Reference to Scottish parliament

https://www.forestryjournal.co.uk/news/23115919.brewdog-gresham-house-forestry-investment-comes-fire/

What is Forestry Partners?

Nature Partners CLG

Project Woodland

Dividends

Coillte paid a €30 million dividend to the State last year

Exports

Grants

When Coillte was formed in 1989, approximately 396,000 ha of forests and lands were under management and today it is approximately 440,000 ha.

Ownership

Duration of the fund

DAFM / Coillte

Coillte Profit Figures

Chairmans closing remarks

AIE Request: Whether Coillte was justified, under article 9(2)(d) of the AIE Regulations, in refusing access to information relating to the construction of a firebreak

Case: OCE-109584-Z8S5F4

Construction / maintenance of fire lines in the Slieve Bloom mountains

The Commissioner annulled Coillte’s decision in respect of record 4. He directed the release of the record, subject to the redaction of information that falls outside the scope of this review.

Forestry appeals, licence application withdrawals, reasons for withdrawals

AIE 22/692

Notes

“Having made enquiries with the relevant licensing sections I have been advised that there is no requirement on the applicant to state their reason for withdrawing an application therefore the information requested above does not exist.” DAFM

Applicants withdraw application (mostly) when under appeal to the FAC

One subject to Judicial Review

Q: How many of these sites had subsequent new applications?  

These cases are not calculated as being successful appeals, as they are withdrawn

AIE request was for correspondence which indicates the withdrawal of the application whether reasons are stated or not – i.e. correspondence. You would expect this correspondence to exist or else how does DAFM know that the application has been withdrawn? Therefore this would be all withdrawn applications?

FAC032/2022 against Licence CN90168, Coillte

CN78293 application withdrawn (Judicial review case, Greenbelt.ie)

CN86376, Western Forestry Co-op

CN81847 Lisiniska East, Sarah Standish

CN84539, SWS Forestry