Loughs Corrib, Mask, Carra, Conn, Cullin, Arrow and Sheelin are some of the best wild brown trout fisheries in Europe and are collectively known as the Great Western Lakes.
Inland Fisheries Ireland wishes to develop a long term management plan for these lakes to address many of the factors currently impacting on the ecological wellbeing of native fish stocks in their catchments.
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.
The scope of this tender includes the provision of expert advice on interactions between wild fish and aquaculture facilities and the species they farm. The advice provided will support IFI in its role in the conservation and protection of species under its legislative remit.
Scientific studies have demonstrated that sea lice from marine salmon farms, when not adequately controlled, can have a serious impact on local sea trout stocks and migrating salmon smolts. Sea trout are especially vulnerable to salmon lice infestation because, in the sea, they remain feeding and growing in coastal waters where salmon farms are situated.
There is a large body of published literature on the negative interactions of farmed salmon and wild salmonid stocks. Apart from the well documented sea lice-mediated impacts on wild salmonids associated with salmon farming, the interbreeding of salmon farm escapees with wild fish have also been shown to significantly negatively affect the sustainability of wild stocks.
It is anticipated that the contract will be awarded in early September 2022 work commencing immediately.
Includes Appendix on Concerns regarding the Appropriate Assessment of aquaculture activitives in marine SACs and potential impact on Atlantic salmon, and response letter from Minister McConalogue (29 March 2022)
Options report on the current situation at Emyvale weir with a view to altering a proportion of river flow to favour the Mountain Water main channel downstream of Emyvale weir.
Under the current situation, the weir is in use to divert water to Emy Lough. The diverted water does not return to the Mountain Water from Emy Lough but rather flows directly into the Ulster Blackwater river.
This diversion creates a significant impact on hydromorphological conditions downstream as there are insufficient water volumes to sustain natural environmental regimes
The weir is still in use with water being abstracted to generate electricity which is used to power a saw mill with the remaining power being sold to the grid. The water in the headrace is used to power a generator which I turn generates power for this sawmill.
The River Nore is an important salmon river. The weir at Brett’s causes a delay in fish moving upstream to reach their spawning grounds. This delay can have major problems for individual fish and the species population due to predation, loss of eggs, loss of available spawning gravels, and overuse of spawning gravels downstream of the weir.
Tender: Brett’s Weir – The Construction of a Rock Ramp Fish Pass at Brett’s Weir on the River Nore, Co. Kilkenny.
Dawros River in Letterfrack, more commonly known as the Kylemore River locally.
request management plan
River Deel at Askeaton
€105,000 in funding for the preparation of detailed reports and design for the removal or improvement of fish passage at four weirs on the River Deel at Askeaton. Plan will open up 40 kilometres of main river channel and 100 kilometres of tributaries for migrating fish species such as salmon, sea trout, eels and lamprey.
2021 concerns that salmon smolt are being mangled in the hydro-electric turbine run by the Kingspan Aeroboard company
Riddlestown Stream Rehabilitation (River Deel)
€10,000 to West Limerick Deel Anglers for appropriate assessment screening and detailed in-river habitat management plans. These plans help inform appropriate measures and rehabilitation for salmon and sea trout habitats, which is being proposed as part of the Riddlestown stream rehabilitation works.
IFI submission relating to a restoration plan for a section of cut-over bog that has the Esker River flowing through it.
Photos highlight extent of hydro-morphological issues.
IFI hope to carry out restoration measures along much of the Esker River, as there is excellent habitat potential.
Site visits by IFI have highlighted significant modifications to watercourses flowing through, adjacent to and downstream of the proposed restoration sites.
The modifications noted included:
Culverting/piping of waters
Construction of on-line silt ponds
Realignment/straightening of watercourses is problematic for a number of reasons including the fact that it results in a net loss of habitat. Realignment of channels often results in a highly degraded hydro-morphology with the loss of natural sinuosity and natural instream variation characterized by the pool/glide/riffle sequence. Realignment may also negatively impact upon gravel recruitment at the realigned site and in waters downstream.
The widening of watercourses, (regularly associated with realignment and deepening) often results in a highly degraded hydro-morphology with the loss of natural sinuosity and natural instream variation characterized by the pool/glide/riffle sequence. In shallow waters a braided channel with limited depth for fish to reside is often the result, while in deeper waters an over-abundance of aquatic plants clogging the channel is regularly encountered.
Culverting is potentially damaging to fisheries waters as it may (1) block/impede the free passage of fish, (2) result in a loss of fisheries habitat and (3) hinder the detection of pollution, while (4) poorly designed/under-sized culverts may be prone to blockages with potential for bank erosion and/or flooding.
The construction of on-line silt ponds on fisheries waters results in the loss of fisheries habitat over long stretches of channel and may impede the free passage of fish.
Specific issues noted by IFI during site visits included:
The Doden River which bisects the Esker bog, represents excellent salmonid habitat, however long sections of this important watercourse have been straightened and deepened, while a very large on-line silt pond was created on this watercourse. An electro-fishing survey of this river in May 2021 highlighted populations of brown trout in this watercourse. IFI request that the restoration of the fisheries habitat of this watercourse be included as part of this plan.
A tributary of the Esker River forms the western boundary of the Esker Bog and IFI inspections highlighted that this watercourse represents fisheries habitat. The inspections also highlighted issues including, fish passage related to perched culverts, deepening and widening and the passage of this stream through a large silt pond. An electro-fishing survey of this river in May 2021 highlighted populations of brown trout and lamprey in this watercourse.
Sections of the main Esker River forming the southern boundary of the Esker bog were found to have been deepened significantly. IFI hopes to explore the potential for habitat restoration along these sections of channel and we ask that such works could be included as part of this bog restoration plan.
With regard to the Cavemount site, IFI have identified excellent salmon habitat potential a short distance upstream of here. IFI hopes to explore the potential for habitat restoration along this section of channel. Our inspection of the Bord na Mona property highlighted a significant constriction in the form of a culverted section of Esker channel, which was noted to be partially blocked. IFI request that this plan would include the removal of this culvert and if a crossing is required that the present structure be replaced with an alternative that is not prone to blockages, will not act as a constriction during high flows and does not result in any loss of fisheries habitat.
IFI request that all watercourse crossings be assessed from the point of view of constrictions on flow, loss of fisheries habitat and barriers to the free passage of fish.
IFI request that habitat restoration of the Esker River flowing through the Cavemount site be undertaken as part of this bog restoration plan.
Sections of this channel were straightened in the recent past and we request that the potential for this section of channel to develop some sinuosity and in-stream variation be included. It is likely that restoration of this section of channel will require the re-introduction of some gravels also.
With regard to the proposed rehabilitation plans, IFI have a number of concerns, including:
The plans state that the silt ponds will continue to be maintained during the rehabilitation and decommissioning phases. IFI request that all maintenance/use of on-line silt ponds cease and that habitat restoration of these important watercourses be made an integral component of the bog restoration proposals.
We note that water quality monitoring will be established, with a suite of physico-chemical parameters referred to. IFI believe that biological monitoring of watercourses should be central to any water quality monitoring program.
Our knowledge of this area is that the invasive fish species Dace is present in the Esker River, yet it is not referred to in the section detailing invasive species.
Fishery assessments of the Esker and its tributaries have highlighted populations of brook lamprey an annex II species in the Habitats Directive. The potential for the re-establishment of populations of salmon here should also be included in the section “Species of Conservation Interest”.
IFI request that the re-establishment of populations of native fish species such as salmon, brown trout, European eel and lampreys be included as an important component and target of Ecosystem services linked to these bog restorations.
IFI is keen to build on recent water quality improvements in the Black River, which drains 21% of the Barrow River catchment and to restore and increase populations of salmon and other native fish species over large sections of this system. Existing populations of salmon within the Black River are already an integral component of the Barrow River SAC populations of these species and as these populations expand in numbers and range their importance will increase significantly.
IFI believe that the implementation of restoration plan/plans, throughout the Esker/Daingean/Black River catchment to address the water quality & hydro-morphological issues referred to above, will be an important part of the restoration of populations of salmon & other species for which the Barrow River was SAC designated.
In addition the implementation of such plans will also be central to Ireland’s requirements for the implementation of the requirements of the Water Framework Directive.
IFI welcome the Bord na Mona, Biodiversity Action Plan 2016-2021 statement that “the main aim of rehabilitation will be to re-wet former production areas as much as possible to maximize the benefits for biodiversity and carbon”.
IFI believe that the benefits for biodiversity referred to above can be increased significantly with the inclusion of river habitat restoration in these plans and we request that applicant expand these bog restoration plans to include a commitment to river habitat restoration throughout the Daingean/Esker and Figile systems.
IFI submission highlights a number of important environmental issues in relation to Bord na Mona landbank
Environmental Impact Assessment Report in relation to applications by Bord na Mona for Substitute Consent for its historic peat extraction activities on 41 individual bog units and future peat extraction activities on selected individual bog units situated across Counties Offaly, Westmeath, Laois, Meath, Kildare and Longford
IFI have reviewed the maps supplied and we note that huge areas of Bord na Mona owned peatlands have not been included. Our understanding is that this EIAR relates only to 41 sites where Bord na Mona proposes continuing the harvesting of peat.
Our knowledge of a number of the Bord na Mona sites which have not been included, is that maintenance of the drainage systems of these peat extraction areas is still undertaken. These drainage maintenance schemes involve the regular excavation of significant quantities of peat and we ask why these sites were not included as part of this EIAR.
IFI concerns relating to water quality issues include:
• The WFD Ecological Status/Potential for numerous waters draining these Bord na Mona peatland areas is “Poor”, while for many the WFD Risk calculation is that they are “At Risk”.
• The WFD Characterization Reports for numerous waters draining these Bord na Mona peatland areas identifies peat extraction as a significant pressure, with organic pollution the main impact associated with peat extraction.
• To facilitate peat harvesting deep drainage channels were constructed throughout these sites. Deepening of fisheries water-courses adjacent to and downstream of peatlands was also undertaken to facilitate this peat harvesting. These significant alterations lowered the water table within surrounding peat-lands and result in the associated peat being exposed to air, facilitating the rapid breakdown of this organic matter, releasing nutrients, principally ammonia to waters.
• The drying out of the peats exacerbates the washout of peat solids to surface waters. The potential for peat particles to become windblown is exacerbated by drying out also.
• Silt settlement ponds are used extensively on Bord na Mona properties, but are likely to retain heavier suspended solids only, with limited retention of dissolved nutrients. The ability of a silt settlement pond to retain fine particles depends upon regular maintenance, as it relates to residence time within the pond and as suspended solids settle out in the pond the retention time for water within that cell and the efficiency of the system reduces significantly. The efficiencies of these ponds in relation to their retention time needs to be considered, with a specific focus upon periods of high precipitation.
• Suspended solids pollution of surface waters from working peatland areas is not limited to carryover from silt settlement ponds, but may occur as a result of direct run-off from haul roads and stockpiles of peat. Wind-blown peat is another significant source. The potential for suspended solids generation from excavations in subsoils below peat deposits should also be considered.
• To date the main water protection/mitigation measure employed by Bord na Mona at peatland sites is the use of silt ponds. Silt ponds do not address the threat of ammonia pollution from working/cut-over peatland areas.
• Peat extraction requires the drainage/pumping of waters from relatively shallow peat deposits. Of concern to IFI is the potential that the temperatures of this drainage water may (at certain times of the year) be significantly elevated when compared to typical groundwater recharge and/or the surface waters to which it is being discharged.
• Following on from the above point, this drainage water is likely to pumped/flow through a large drainage system which may include multiple, large surface area silt settlement ponds. Given the relatively shallow depth of the silt ponds and potential for full sunlight penetration, IFI have concerns that there is potential for a significant increase in temperatures of this drainage water prior to discharge to surface waters.
• Given the important link between water temperature and biological/biochemical reactions, the temperature of drainage waters being discharged to fisheries streams/rivers is critical in that some key constituents of water, either change their form (ionization of ammonia) or alter their concentration, as with dissolved oxygen. Considering that ammonia losses from drained peatland are the principal water quality issue it is important that this issue be adequately addressed.
• These operations involve significant machinery/plant/light rail infrastructure, throughout. Fuels/hydraulic oils/lubricants etc. have potential to pollute both surface and ground waters. IFI ask that this EIAR address the potential for surface/ground water pollution at machinery storage/repair-maintenance/refueling locations.
• The Dept. of Agriculture and the Marine document, “Land Types for Afforestation” Working Document 2016, includes former and existing industrial cutaway peatlands as an example of lands unsuitable for afforestation. Commercial afforestation on such peat deposits poses a significant environmental threat to water quality. In addition such afforestation is likely to require the bog drainage system is maintained, leading to continued ammonia run-off to surface water. A significant threat comes from forest harvesting on such sites, especially where such plantations, which are now maturing, have been established prior to the implementation of the Forest Service guidelines. IFI ask if such sites have been included in the maps relating to the 41 bog units supplied and we ask that this EIAR consider commercial afforestation on all Bord na Mona peatland sites.
• We note that a number of the sites relate to the production of peat and the processing of peat for use in horticulture. Certain aspects of this production are likely to include the addition of nutrient/minerals and other materials to peat. IFI request that the potential for contamination of ground and surface waters by such nutrients/minerals at these facilities be addressed.
• Thermal pollution from the Edenderry Power Plant is of concern to IFI. Given the important link between water temperature and biological/biochemical reactions, the temperature of cooling waters being discharged to fisheries rivers is critical in that some key constituents of water either change their form (ionization of ammonia) or alter their concentration, as with dissolved oxygen. Considering that the ammonia losses from drained peatland are the principal water quality issue and the extensive peat workings on both sides of the Figile River for some considerable distance upstream, it is important that this issue be adequately addressed.
• Relating to the above point the section of the Cushaling River (upstream of Edenderry Power Plant) in County Kildare represents some of the best salmonid habitat within the Figile catchment. This potential was underutilized because of a number of water quality issues, including run-off from peat-lands. IFI do however hope that fish stocks in this section of channel will improve significantly as a result of improvements/upgrading of Derrinturn WWTP and significant upgrades at a large industrial site, both of which were contributing to the unsatisfactory biological conditions. IFI believe that the improvements in water quality referred to above will lead to the restoration of salmon spawning in the Cushaling River, and that when this happens, these Cushaling salmon will be an important/integral component of the salmon populations of the Barrow SAC.
• The addition of biocides to cooling waters at power generation plants to prevent biofouling of their cooling systems is a widespread practice internationally. With reference to the Edenderry Power Plant IFI request that this EIAR address if such practices are undertaken at this facility.
• In relation to the above point, trihalomethanes (THMs), a large group of organic compounds are formed when organic material reacts with chlorine. Given the high organic content of the Figile River water (from which the Edenderry power plant abstracts cooling water) linked to extensive Bord na Mona peatlands through which the Figile and its tributaries flow, IFI have concerns regarding the potential for significant discharges of THMs to the Figile River. IFI request that the potential for negative impacts upon the aquatic biota of the Figile River by discharges of THMs be addressed in this EIAR.
• The potential for large scale fires on cut-over/”peatlands being worked” is significantly greater compared to sites that have not been subject to drainage/drying out or sites that have been rewetted. IFI request that the potential for run-off of significant quantities of deleterious matter to surface waters following a large scale fire on cut-over peatland, and the likely makeup of the run-off be considered.
• The use of borrow pits/quarrying on Bord na Mona peatland sites may lower water levels within surrounding peats and act to exacerbate drying out of such peats, with an increase in release of ammonia to surface waters. Quarrying operations also represent a potential source of suspended solids pollution of surface waters.
IFI concerns relating to habitat/hydro-morphology include:
• An examination of OSI 6 & 25 inch sheets highlight significant modifications to watercourses flowing through, adjacent to and downstream of these peatland sites. The modifications noted (through both desktop checks and on-site visits) included:
o Realignment/Straightening o Deepening o Widening o Culverting/piping of waters o Construction of on-line silt ponds to facilitate commercial peat extraction. o Differences in height where waters are lifted to facilitate drainage
• Realignment/straightening of watercourses is problematic for a number of reasons including the fact that it results in a net loss of habitat. Realignment of channels often results in a highly degraded hydro-morphology with the loss of natural sinuosity and natural instream variation characterized by the pool/glide/riffle sequence. Realignment may also negatively impact upon gravel recruitment at the realigned site and in waters downstream.
• The deepening of watercourses in, or adjacent to peatland sites, (in addition to the release of ammonia and suspended solids to surface waters) may result in the removal of all/most gravels from long stretches of fisheries waters where the excavation depth extends down to the subsoils beneath the watercourse. In such cases the potential for natural restoration in waters flowing through peatland areas is usually limited, given the relatively low gradient and other hydro-morphological issues referred to in the above point. Human intervention is likely to be necessary to facilitate recovery of the fisheries habitat on long stretches of watercourses draining peatland areas.
• The widening of watercourses, (regularly associated with realignment and deepening) often results in a highly degraded hydro-morphology with the loss of natural sinuosity and natural instream variation characterized by the pool/glide/riffle sequence. In shallow waters a braided channel with limited depth for fish to reside is often the result, while in deeper waters an overabundance of aquatic plants clogging the channel is regularly encountered.
• Culverting is potentially damaging to fisheries waters as it may (1) block/impede the free passage of fish, (2) result in a loss of fisheries habitat and (3) hinder the detection of pollution. Our experience is that many of the culverts on Bord na Mona peatlands to facilitate the industrial light rail system are very long. The depth at which such culverts were installed also acts as a control re drying out of peats, as all peats upstream of the culvert at a higher elevation will be subject to drying out.
• Construction of on-line silt ponds results in a loss/degradation of fisheries habitat. The efficacy of any silt pond relates to residence time in the pond and as peat settles out in the pond the ability for the pond to retain peat is reduced. Because of this, these ponds are subject to regular maintenance whereby accumulated peat deposits are removed.
• Pumping operations and flow control weirs have potential to impact on both upstream and downstream fish passage, watercourse base flows and water quality. We request that this AIER address these issues.
• IFI have noted significant gradient differences on watercourses on peatland sites where water is lifted from one to the other using archimidean screws. Such practices represent a barrier to the free passage of fish.
• With reference to the Edenderry Power Plant and any other Bord na Mona industrial facility IFI request that any abstractions from surface waters and/or groundwater be considered with a focus upon potential impacts on flow rates in associated surface waters and also recharge of groundwater to surface water bodies.
• With reference to the Edenderry Power Plant and any other Bord na Mona industrial facility that includes an abstraction from surface waters, the issue of screening to prevent fish and other aquatic animals becoming entrained within the abstracted water and/or impinged upon screens should be addressed. Of particular concern is the potential for significant mortalities, where fish become trapped on screens and/or enter cooling water systems. Numerous factors influence the likelihood of fish mortality at/in such sites including, but not limited to:
o Flow velocity in the vicinity of screen o Rate of abstraction relative to total flow in river/flow attraction o Screen spacing o Size of fish resident and migrating through the location o Potential for screens to become clogged which is likely to increase flow velocities in the vicinity of screen o Angle of the screen o Surface area of the screen
• IFI consider that any abstraction should protect all age classes of all fish species resident within the area of the abstraction or likely to migrate through that section of watercourse.
IFI is keen to build on recent water quality improvements in the Black River, which drains 21% of the Barrow River catchment and to restore and increase populations of salmon over large sections of this system while the Shannon Salmon Restoration Project is a key IFI project is committed to the restoration of sustainable stocks of salmon throughout the Shannon Catchment. Large areas of the catchments of the above named rivers are dominated by Bord na Mona peatlands.
Habitat restoration in rivers such as Inny, Brosna, Figile and Philipstown Rivers will be central to these plans.
Many of the watercourses draining directly from Bord na Mona peatland sites have small catchment areas with limited flows, and should be regarded as highly sensitive to anthropogenic inputs/alteration. Other larger and important fisheries watercourses flow through, adjacent to and downstream of the Bord na Mona sites and while many of these represent excellent fisheries habitat, in many cases the habitat of these watercourses has been degraded by deepening/widening, realignment and silt deposition.
IFI request that this EIAR examine the hydro-morphological damage to watercourses outside the boundary of the boundary of the Bord na Mona sites.
We request that the applicant address the root causes of the elevated ammonia concentrations in surface waters/pumped waters from their peatland sites.
IFI welcome the Bord na Mona, Biodiversity Action Plan 2016-2021 statement that “the main aim of rehabilitation will be to re-wet former production areas as much as possible to maximize the benefits for biodiversity and carbon”.