An analysis of land resources to assess “the potential availability of land for afforestation in the Republic of Ireland” was performed in 2013 with the aim of providing an understanding of the potential land resources that could potentially be available for forestry to achieve government afforestation targets (see attached paper Farrelly and Gallagher 2016)
Peer reviewed paper in pdf format, land availability forestry 2013 supporting document and map output in GIS gridded data format (ESRI grid).
Note: some of the input data used in this analysis is already in the public domain and available on line (through Teagasc and NPWS map portals) and some of the data is not, as it has been made available from OSI under national mapping agreement and other data agreements with Forest Service
A note on the potential availability of land for afforestation in the Republic of Ireland
An analysis of land resources to assess “the potential availability of land for afforestation in the Republic of Ireland” was performed in 2013 with the aim of providing an understanding of the potential land resources that could potentially be available for forestry to achieve government afforestation targets (see attached paper Farrelly and Gallagher 2016).
The analysis was based on developed spatial analysis techniques involving a range of datasets representative of landuse in Ireland, which were available from a range of National mapping agencies under licence agreement (e.g. Ordnance Survey Ireland, Navtech, etc.) in Table 1, Farrelly and Gallagher (2016). Some of the inputs utilised in the analysis are in the public domain and available on line (soils, sub-soils, landcover, etc.) at http://gis.teagasc.ie/soils/map.php and some of them, are subject to specific request for national responsible agencies (e.g. Forest Service, DAFM).
The data utilised for the analysis represented the best source of data available for the study at the time of preparation in 2012. Some data are subject to limitations of scale, with scales varying from 1:50,000 to 1: 500,000, the latter for published soil maps. Some of the input datasets used are time and date specific, being representative of agricultural land use and soil survey from the mid to late 1900’s https://www.teagasc.ie/environment/soil/soil-maps/ The landcover and habitat maps utilised are based on landsat data taken in 1995, these are perhaps obsolete and are being superseded by new maps (e.g. OSI prime II, see https://webapps.geohive.ie/mapviewer/index.html which may be subject to continuous updating and revision.
Additional data some of which was not used in the original study is available which may have potential to modify some of the results of the 2013 study. Additional forests have been planted, new environmental designations, county development plans, etc. would all have implications to land availability for forestry.
The spatial analysis performed in this study was intended to be utilised for tabular reporting and not for the production of map based data and the resulting raster dataset G&R_LA2013 is presented at 1 x 1km in ESRITM grid format and categories are described below.
The use of such maps at finer scales can cause misunderstanding and misrepresent the level of accuracy and detail of mapping of input datasets and are not suitable for use at a field or site level.
The interpretations derived from this map does imply suitability for afforestation, and does not eliminate the need for due process in the application for afforestation which are subject to DAFM guidelines and which are administered on a case by case basis subject to onsite sampling, testing, and detailed study of habitats, guidelines commensurate with Forest Service procedures for afforestation grant aid. Users are responsible for the appropriate application of this map.
Land most likely to have potential for forestry
Land suitable for productive agricultureab
Land marginal for economic agricultural productionab
As 41, but is fishery sensitiveb
As 42, but is fishery sensitiveb
b Productive and marginal are defined by Gardiner and Radford – soil associations and their land use potential, An Foras Taluntais, Dublin.
bc Application of appropriate screening of forestry applications in fishery sensitive areas may be subject locally applicable
* Application for afforestation licenses is administered on a case by case basis subject to onsite sampling, testing, and detailed study of habitats and other appropriate assessments and guidelines commensurate with Forest Service procedures for afforestation grant aid.
“There is enough evidence observed to warrant that the file is forwarded to the EIA section for their assessment. The location is tonashammer, it is north of castlepollard and west of dromone. Over 500 metres of hedgerow has been removed (not trimmed) and nothing is remaining only bare soil. The total area of the works is ca 6.5 ha and there are wetlands present. Part of the area overlaps or is adjacent to a pNHA”
Report from site visit conducted following a cross report of a possible breach of Environmental Impact Regulations (Agriculture) in relation to work being carried out on lands at Tonashammer, Co. Westmeath
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
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.
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.
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.
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 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.
Includes “general observations from the National Parks and Wildlife Service (NPWS) in relation to forestry application referrals”
a copy of all site reports and related information produced by conservation and ecological staff of the NPWS as a result of forestry and felling licencing referrals received from the Forest Service during 2022 for counties Wicklow and Leitrim that are logged on the DATS
a copy of all submissions made to the Forest Service in response to forestry and felling licencing referrals received during the same period for counties Wicklow and Leitrim. This can exclude no comment responses but include one example of a standard email response issued to the Forest Service for no comments.
Proposal to clearfell Sitka Spruce plantation at Conaghil & Kilcoosy townlands, Co. Leitrim
NPWS Recommendation: This proposed development should be screened for appropriate assessment based on the considerations outlined above as per Regulation 42(1) of the 2011 Birds and Natural Habitats Regulations
Felling Licence Application TFL00769822 at Drumrane, Co. Leitrim
NPWS Recommendation: This proposed development should be screened for appropriate assessment based on the considerations outlined above as per Regulation 42(1) of the 2011 Birds and Natural Habitats Regulations.
Application for felling licence reference number TFL00801122 at Corrachuill Townland, Co. Leitrim.
The application provides insufficient information to be assessed properly with regard to its potential impacts on protected species (See Section 1): o The application does not provide the information required and outlined in the Forest Harvesting and Environment Guidelines (2000). o The application does not provide the information required and outlined in the Felling and Reforestation Policy (2017). o The application does not provide information on the presence/absence of species protected under the Wildlife Act (1976, as amended) within the application site. o The application site region is known to host Red squirrel, Common Buzzard and other passerine species. o There are concerns for the stream and water course which flow by the boundary to the northern side of the application lands. This boundary forms a wooded historic Townland border. o There is no reference or recognition to the historic infield boundaries within the plot 432 o There are concerns for the lakeshore and riparian Woodland/scrubland which occur around a significant portion of the plot 432. These have not been identified within the felling application documents submitted. o Concerns for possible replanting of conifers along the northern stream side border of the lands.
Application for TFL felling licence reference number TFL 00806322 Kilnamaddyroe Townland, Co. Leitrim
The application provides insufficient information to be assessed properly with regard to its potential impacts on protected species (See Section 1). o The application does not provide the information required and outlined in the Forest Harvesting and Environment Guidelines (2000). o The application does not provide the information required and outlined in the Felling and Reforestation Policy (2017). o The application does not provide information on the presence/absence of species protected under the Wildlife Act (1976, as amended) within the application site. o The application area is now known to host Common Buzzard, Mistle Thrust and other passerine species
Location; Derrinivver Co. Leitrim. NPWS have reviewed this CN84099 file which has been re-submitted by FS Dept. Ecologist due to the area being recognised as a regionally important (non- designated) area for Hen Harrier.
Excluding a handful of Inspectors who have certified less than 10 licences the figures show that Inspectors certifying Coillte applications are, on average, certifying more than twice as many licences as their counterparts who deal with private licence applications over the same period. (160 compared with 70).
How is the difference explained?
Are Coillte licence applications subject to less scrutiny?
DAFM has a dedicated unit for processing Coillte felling licences. Coillte felling licence applications are not processed on iFORIS and so do not undergo EIA Screening. Private licences do.
How many field visits are carried out by the dedicated Coillte unit (based in Johnstown Castle) prior to issuing licences? Is this part of the reason for the difference? Regional Inspectors may be taking more time in actually visiting the sites that they are issuing licences for?
Forest Management carried out by Foraois Growth Ltd (SA-PEFC-FM-007488) of Enterprise House, Marina Commercial Park, Cork, T12 X4YW, Ireland.
In September 2022 we (the Soil Association) will carry out a The Programme for the Endorsement of Forest Certification (PEFC™) assessment of forest management by Foraois Growth Ltd in Ireland. They will be assessed against the requirements of the PEFC Irish Forest Certification Standard (Jan 2014).
We would welcome any comments you have on the forest management carried out by Foraois Growth Ltd.
Can you please make publicly available, through the Dasos website, management planning documentation, or a summary of its primary elements, including those listed in 2.1.1, 2.1.2 & 2.1.3. as required under 2.1.4 of the PEFC Standard.
This is necessary information in the context of the public consultation.
2.1.4 Requirement While respecting the confidentiality of commercially and/or environmentally sensitive information, woodland managers, upon request, shall make publicly available management planning documentation, or a summary of its primary elements, including those listed in 2.1.1, 2.1.2 & 2.1.3.
The above is a certification audit for a private forestry company.
There is a consultation running on their forests but they don’t actually disclose where the forests are!
Files (Dropbox files are the Summary Management Plans, etc that relate to the “Forests” that are the subject of this consultation):
Under the Forestry Regulations the following are “consultation bodies”;
(a) where relevant, a Minister of the Government,(b) the Environmental Protection Agency,(c) the National Parks and Wildlife Service of the Department of Arts, Heritage, Regional, Rural and Gaeltacht Affairs,(d) Inland Fisheries Ireland,(e) the relevant local authority (as defined under section 2 (as amended by the Local Government Reform Act 2014 (No. 1 of 2014) of the Local Government Act 2001 (No. 37 of 2001)),(f) the National Roads Authority,(g) An Taisce — The National Trust for Ireland,(h) any other person having a statutory function or a specialist skill or expertise in or knowledge of a particular relevance that the Minister considers appropriate having regard to the matters referred to in the application;
(h) is rarely exercised (eg referrals to Irish Water where drinking water could be affected)
Q: have there been any direct referrals to eNGO’s that are involved in relevant survey works, such as Birdwatch Ireland, Irish Raptor Study Group, Golden Eagle Trust, etc who may have more up to date information than the NPWS. A case in point is where a Hen Harrier nest location has been identified within the last week with three successful fledglings (as part of the ongoing National Survey). This is not, as yet, on any official record accessible by the Forest Service. There are around a dozen projects still in the licencing process or licenced but unexercised that are within the 1.2km “Red Zone” buffer but have no protection provisions for the Hen Harrier as it is not flagged on the FS system.
FS has a referral protocol. Most of this protocol has been developed unilaterally by DAFM – i.e. the prescribed consultation body does not get a say in which applications are referred to it.
The Forestry Regulations give total discretion to the Minister as to when to consult.
Notice to consultation body
9. (1) Where the Minister receives an application under Regulations 5, 6 or 7 and it appears to him or her that the proposed development— …………………………
There is significant individual discretion left with Forestry Inspectors to make referrals.
The response from Inspectors at appeal when questioned as to why referral was not made to a particular body is that it wasn’t ‘mandatory’ – this ignores the fact that all referral is discretionary under the Forestry Regulations.
Referrals are made on the basis of a protocol, not required under statute.
What is more significant is how often the FS disregards the recommendations of the Consultation bodies. There is an AIE in at the moment which requests referrals and responses between FS and NPWS. This AIE may give some insight into the process, and if/where NPWS recommendations are taken onboard.
There are multiple examples of NPWS, IFI and County Councils objecting (in their referral response) to afforestation or re-forestation of sites.
Example: In the case of Leitrim County Council this is where the Council considers the works to be in contravention of the County Development Plan. Forest Service proceeds with the application and gives no reasoning in its decision making process for not following the recommendation of the consultation body.
Volunteers are doing some important work on local authority consultation responses (going back around 20 years) where the FS has been ignoring the Council recommendations.
NPWS have been routinely recommending leaving 25% Open Space at re-stock on licences within the Slieve Blooms SPA to support the conservation objectives of the Natura Site (Hen Harrier). Forest Service response (at appeal to the FAC) is that this would involve deforestation and is contrary to the obligation to replant.
Note: The obligation to replant can be waived on over-riding environmental grounds.
Consultation bodies are the bearers of inconvenient truths to the FS.
This situation highlights the (legally problematic) potential conflict of interest between DAFMs promotional role for forestry (replete with planting targets) and its its licencing function. Is there an inherent bias towards approvals to meet targets?
Those dissatisfied with a decision made on applications for licences for afforestation, tree felling, forest road works and aerial fertilistaion, can make an appeal to the Forestry Appeals Committee (FAC).