Avonmore_SC_010 sub catchment

The sub catchment has an area of 141km² and is made up of six water bodies.  It captures all the streams, rivers and lakes that form headwaters to the Avonmore River. It starts in northeast parts of the Wicklow Mountains with Cloghoge and Inchavore Rivers that flow through Lough Tay and Lough Dan to form the Avonmore River. The river then flows south through Annamoe village down to Laragh village, where it meets Glenmacnass River that also rose in the Wicklow Mountains.

Two of the water bodies that make up the sub catchment are are Blue Dot rivers: Avonmore_010 and Avonmore_020, and have a high status objective. Both have fallen to good status and are considered to be at risk of not meeting their objective under the River Basin Management Plan.  Historically these rivers have been at high ecological status which means they have the potential to achieve and maintain high conditions. With the change down to good ecological status we know that these rivers are at stress and need action for the restoration. However, it should also be noted that a third waterbody in the sub catchment has improved to high status and has been high during two monitoring cycles.

The significant pressures in the catchment are forestry and agriculture. This catchment was chosen in consultation with Coillte and the Forest Service as there is likely to be significant forestry activity in the area during the life of the project and will allow appropriate management strategies for high status areas to be developed.

Notes:

Rough figures for Avonmore Sub Catchment

	Ha
Total	14143
SAC	7458	52.7%
Coillte	2607	18.4%
Private	799	5.6%
Forestry Total	3406	24.1%

Sample site: WW03-FL0080 

Ballinrush, Carrigroe, Wicklow

https://forestry-maps.apps.rhos.agriculture.gov.ie/

Type: Coillte Clearfell

Licence Id: WW03-FL0080

Area: 10.08ha

Status: Approved
Date Received: 15-Mar–2021
Date Advertised: 19-Mar–2021
Date Approved/Refused: 01-Sep–2021
Location: Wicklow

Map

Tree Felling Licence issued WW03-FL0080 under Forestry Act 2014

The licensee shall, within a period of 2 years from the end of the harvesting operations carried out under the authority conferred by this licence, carry out the replanting operations.

Species: Sitka Spruce

Percentage: 100%

Stems per Ha: 2500

Urea should not be applied to stumps with the buffer zones

The applicant must adhere to the mitigation measures specified in the Attached Appropriate Assessment Determination Document

Ground stability should be kept under constant review, the felling operation must not create unstable ground conditions or result in post harvesting ground instability.

Appropriate Assessment Determination

Screened In European Sites:

➢ Wicklow Mountains SAC IE0002122: Possible effect due to the location of the project within the Natura site.
➢ Wicklow Mountains SPA IE0004040: Possible effect due to the location of the project within this European site.

The applicant submitted a Natura Impact Statement (completed 14/07/2021) to facilitate the Minister carrying out an appropriate assessment. Niall Phelan, Principal Consultant, Environmental Facilitation Ltd, acting on behalf of the DAFM, subsequently evaluated the submitted NIS.

In relation to Merlin, the following mitigation is required, presented in the form of conditions to be attached to any licence:
A) No Felling or other forestry operations associated with this licence shall take place during the period 1st March to 31st August inclusive, within 100 metres of the forest edge, where such forest edge is immediately adjacent to moors, heathland, peat bogs or natural grassland; or within 100 metres of a clearing in the forest of larger than one hectare. Such operations can commence in sections of the project area furthest away from the 100 metre exclusion zone. Such operations can progress towards this exclusion zone but can only enter it during the period 1st September to 29th February inclusive.

In relation to Merlin and Peregrine, the following mitigation is required, presented in the form of conditions to be attached to any licence:

A) Retain existing scrub on site, to maximise opportunities for prey species.

B) Broadleaves / diverse conifers should be planted along the northwest boundary in an undulating fashion to create a sequence of varying spaces. Sharply defined edges should be avoided to create a gradual transition from forest to open ground. The minimum initial planting density required is 1,100 stems / ha.

In relation to the protection of adjoining / downstream aquatic based species and habitat, the following mitigation is required, presented in the form of conditions to be attached to any licence issued:

A) All operators will be provided with an up to date harvest plan and will be appropriately briefed on all of the conditions set out in the determination.

B) Demarcations will be set out at all sensitive points in the project to ensure machinery does not unintentionally traverse into exclusion zones.

C) Prior to harvesting, all water related hotspots and abstraction points (as defined in Circular 12/2017 and marked on the Harvest Plan submitted for this file) shall be identified on the ground and a clearly marked machinery exclusion zone of 10 metres shall be established around them.

D) Drains must always clearly stop short of buffer zones. If an existing drain has a preferential flow path (effectively discharging directly into aquatic zone or relevant watercourse), use sediment traps or drain blocking as appropriate. Additional sediment traps should be considered where the setback is deemed ineffective. E.g. if not vegetated or where the sediment traps are not fully functional.

E) Relevant operations must cease during and after periods of rainfall sufficiently heavy to result in the loss of nutrients and/or the mobilisation of sediment, fine organic matter and debris into receiving waters. Ground conditions must be monitored during rainfall, and records of such monitoring and of any resulting operational adjustments and postponements must be kept for possible inspection.

F) No water related hotspot (as defined in Circular 12/2017) shall be directly traversed by any machine.

G) Machinery crossing of internal drains shall be minimised and only be undertaken with the use of appropriate log bridges. With respect to temporary crossings, these shall avoid localised wet and/or hollows banks. Drain banks will not be disturbed during construction. Construction will involve a combination of logs and plastic piping, with a protective brash layer placed on top to catch silt and sediment dropping off machine tracks.

H) Extraction routes are to be planned to avoid hotspots and ensure that individual routes are not used excessively during harvesting operations. Locate timber landing bays at least 50m from the nearest aquatic zone.

I) Brash and branch wood is to be utilised to create and maintain brash mats along all machine routes during harvesting operations at all times.

J) Extra brash will be applied along main extraction racks and at timber stacking areas, to accommodate higher levels of machine tracking, including the use of extra lengths of timber to prevent soil disturbance.

K) Loose brash and lop-&-top will be carefully removed from exclusion zones as and when they fall/ stray into these areas.

L) With respect to temporary crossings, these shall avoid localised wet and/or hollow banks. Drain banks will not be disturbed during construction. Construction will involve a combination of logs and plastic piping, with a protective brash layer placed on top to catch silt and sediment dropping off machine tracks. These will be carefully removed when no longer needed, carefully avoiding sediment release with their removal.

M) Silt traps to adhere to the specifications set out in the Interim Standards for Felling & Reforestation (see Section 7 (or similar), are to be installed before operations commence onsite, and are to be monitored and maintained throughout operations. Any build-up of captured sediment is to be removed and deposited on the forest floor at least 5m from the relevant watercourse.

N) Small logs will be deployed to control movement of silt/sediment in critical areas and throughout site where necessary, as shown in Section 7 of the Standards for Felling & Reforestation (DAFM,2019).

O) Historic mound drains with direct connectivity to relevant watercourse or aquatic zones must be identified prior to commencement of operations. These pathways must be blocked.

P) Rutting must not be permitted to develop from machine trafficking with machine movement and ground conditions monitored throughout operations to ensure soil rutting and the creation of potential pathways for the movement of water do not develop.

Q) Roadside drains must never discharge directly into aquatic zones or relevant watercourses. As with all drainage channels they must taper out before entering the buffer zone. Where deemed necessary, install sediment traps at the intervals along drainage channels to intercept sediment and needles.

R) Maintenance of internal and roadside sediment traps is essential. Inspect periodically to ensure they are free of debris and sediment, undertaking remedial action if necessary. Grassy vegetation in drains is not to be removed as this will filter sediment as water percolates through it.

S) Plants will only be treated with approved insecticide acetamiprid off-site in the nursery, approved by Pesticide Registration and Control Division, DAFM. Any on-site application will only be undertaken following an appraisal using the Integrated Pest Management Policy and applied by manual spot spraying only.

T) Any herbicide such as glyphosate will only be applied by manual spot spraying on local competing vegetation that threaten the survival of the tree following an appraisal through the Integrated Pest Management Policy.

U) As set out in the NIS, fertiliser application will be manual and restricted to elemental phosphate at no more than 42 kgs/ha to support the establishment and growth of newly-planted trees.

V) Chemicals must only be used during dry weather and must only be used in accordance with S.I. 155 of 2012. Store and prepare all chemicals, fuel and machine oils, and undertake all machine refuelling, maintenance and repair, at a dry, elevated location onsite at least 50 m from the nearest aquatic zone or relevant watercourse.

W) Inspect all protective measures periodically to ensure continued functionality throughout operations.

Adhere to all water protection measure guidance relating to sediment management, felling, cultivation, herbicide application, the location of onsite storage depots and the disposal of waste including: Environmental Requirements for Afforestation, December 2016 (DAFM, 2016), Forestry Standards Manual (DAFM, 2015), Felling & Reforestation Standards (v. Oct. 2019) (see Forest Service Circular 14 / 2019), Forestry and Otter guidelines (Department of Agriculture, Fisheries and Food, 2009.

The basis for this AA Determination is as follows:

This 10.08ha clearfell and reforestation project is located on peaty podzols on a steep slope. The project area lies within the Wicklow Mountains SPA and directly adjacent to the Wicklow Mountains SAC. The project area consists entirely of Sitka Spruce. Small pockets of open area occur within the project area. There are no aquatic features within or adjacent to the project area.

However, the project area is located on a steep slope, sloping towards Lough Dan (located approx. 150m west). Live validated records of freshwater pearl mussel (Margaritifera margaritifera) were noted <3km downstream however, the records were noted downstream from Lough Dan. Appropriate aquatic zone and watercourse measure protections have been set out including specific otter measures and good practice aquatic measures for the relevant designated features. The above conditions in combination, along with strict adherence to the guidance cited, will eliminate pathways of impact of significance to European sites.

Appropriate Assessment Screening Report & Determination for felling and reforestation project WW03-FL0080, at Ballinrush & Carrigroe, Co. Wicklow

Soil: The underlying soil type is: podzols (peaty)/lithosols/peats (100%)

The project lies between Avonmore_020 (100%)m and Avonmore_Sc_010 (100%)m

Slope: Steep 15-30%

Reforestation: SS (100%)@2500

SAC site: https://www.npws.ie/protected-sites/spa/004040

In Combination

Other Forestry Plans and Projects:

Data from DAFM’s internal records identified various forestry-related projects (either submitted and still under evaluation, with valid licences / approval in place or completed and approved) in the general vicinity of the project

Afforestation Projects

Forest Road Projects

Private Felling Licence Projects

Coillte Felling Licence Projects

This project lies in a rural landscape in Ballinrush,Carrigroe, Wicklow in the River Sub-Basin AVONMORE_020. The River Sub-Basin AVONMORE_020 has approximately 36% forest cover, which is higher than the national average of 11%. At 10.08ha the project is considered medium in scale.

Forestry activity (including afforestation, forest roading and felling) within the sub-basin which have either been submitted and still under evaluation, licenced / approved or completed in the last 5 years, are listed above.

Appropriate Assessment Pre-Screening Report for Clearfell and Reforestation project WW03-FL0080, located at Ballinrush and Carrigroe, Co. Wicklow

NPWS Referral

The Wicklow Mountains SPA is of high ornithological importance as it supports nationally important
populations of Merlin, a species that is listed on Annex I of the E.U. Birds Directive, and has been recorded breeding near the site of this proposed forestry operation.

As such, all forestry operations should take place outside of the breeding season for these species – 1st March until 31st August

IFI Referral

Ground stability should be kept under constant review, the felling operation must not create unstable ground conditions or result in post harvesting ground instability

Local Authority (Wicklow Co Co) Referral

Very steep location on peat with very soft water – acid sensitive – consider replant with native species rather than non native conifer monoculture

IFI Referral

Application

Felling Licence Application Map

Notes:

Wicklow CoCo recommended re-stocking with native species;

“Very steep location on peat with very soft water – acid sensitive – consider replant with native species rather than non native conifer monoculture.”

Licence is for 100% re-stock with Sitka

NPWS submission includes:

The proposed felling area is entirely within the Wicklow Mountains Special Protection Area (SPA) for Birds (Site Code 004040). The Wicklow Mountains SPA is of high ornithological importance as it supports nationally important populations of Merlin, a species that is listed on Annex I of the E.U. Birds Directive, and has been recorded breeding near the site of this proposed forestry operation. As such, all forestry operations should take place outside of the breeding season for these species – 1st March until 31st August.

Licence is not nearly as restrictive  

No Felling or other forestry operations associated with this licence shall take place during the period 1st March to 31st August inclusive, within 100 metres of the forest edge, where such forest edge is immediately adjacent to moors, heathland, peat bogs or natural grassland; or within 100 metres of a clearing in the forest of larger than one hectare. Such operations can commence in sections of the project area furthest away from the 100 metre exclusion zone. Such operations can progress towards this exclusion zone but can only enter it during the period 1st September to 29th February inclusive.

Reason: In the interest of protecting the Special Conservation Interest of the Wicklow Mountains SPA as per the Appropriate Assessment determination for WW03-FL0080.

Notes:

• Forestry Service can disregard the recommendations of prescribed bodies

• Most licences are published on the FLV. View the AA Determination where an AA has been conducted as that will contain mitigation conditions which will be referred to in the licence.
• Key document is the (Interim) Standards for Felling and Reforestation – this is DAFM’s Standards document which details the main criteria that need to be adhered to.
• There are certain areas where forestry operators regularly fall down – brash management, rutting, functioning silt traps, failure to remove materials from the site (used oil cans, disposable gloves, etc);
• Some operators are now using paper bags to transport the re-stock trees. These bags are often left on site to rot down but Sitka Spruce are pre-dipped with chemical at the nursery so the bags could be chemically contaminated.
• Felling licences should have Harvest Plans – private licences would usually have these on the FLV but Coillte does not submit Harvest Plans with its applications. They currently need to be sought from Coillte via AIE
• Two important reference documents are the Irish PEFC and FSC National Standards. These are only relevant to forestry operations that are certified but this includes most big players