EPA Submission to NPWS Reform Review

Most of the submissions to the NPWS Review are not in the public domain. EPA submission is, and worth noting:

NPWS should lead a national research strategy for ecosystems and biodiversity and secure multi-annual funding to deliver on strategic (including partnership co-funding) needs.

The current periodically ‘procured’ private enterprise model (Compass Infomatics) for (NBDC) a core national asset is too precarious to assure the essential continuity. We strongly recommend the full integration of the National Biodiversity Data Centre into the scientific enterprise of the NPWS.

EPA staff in the licensing and enforcement areas find that access to actionable information from NPWS is weak (e.g. habitat maps for Natura sites, critical loads and critical levels specified for protected sites), and when submissions are received from NPWS they can often be very generic and thus lacking any site, or action, specificity necessary for the regulatory (assessment and conditioning) processes.

There are also challenges in getting NPWS input on regulatory matters not associated with designated protection sites e.g. Environmental Liability Directive incidents which impact on features outside designated sites.

In order to support environmental decision making, the EPA would ask that the NPWS makes available in web/GIS format maps and searchable resources and the key emissions assessment support information on site-specific critical loads and critical levels for protected areas.

Given the dependency of many national SACs and SPAs on water quality and quantity, it would be important for NPWS to become an active member of the National Water Framework Directive Governance structures

The NPWS chair the national landcover mapping steering committee, which is an important function to provide independent oversight to the OSI national landcover mapping project. Active management of this project including regular meetings of the steering committee and progress reports from the OSI are key to successful delivery for all stakeholders.

NPWS hold important data relevant to the Water Framework Directive register of protected areas and Article 17 habitats directive reports. It can be difficult to get access to NPWS data.

Completion and availability of site-specific data on Special Areas of Conservation and more granular habitat maps would be of enormous help not only to landcover mapping but also to catchment management processes.

Dedicated NPWS resources to facilitate data sharing and to deliver site-specific data for protected habitats would greatly assist the landcover mapping activity (as well as EPA regulatory and Water Framework Directive activities), which in turn would facilitate better assessment of local and regional nature protection issues.

Task Force Review conducted on the NBDC (2021)

The National Biodiversity Data Centre is a programme of the Heritage Council and is operated under a service level agreement by Compass Informatics. (biodiversityireland.ie)

2021 NPWS Report notes,

The NBDC do not have the expertise to run all of the programmes required under the Nature Directives and tend to focus on species level data. The NPWS have requested that the focus of the NBDC is on the collation, cleansing and dissemination of biodiversity data. Because the NWPS deals with some data in addition to the NBDC, there is the potential for overlap, gaps and inefficiencies.

Currently, there is a Task Force Review being conducted on the NBDC, but this was not completed at the time of writing this report, nor were its findings available to the Reviewers.

AIE request on NBDC meeting minutes, agendas and final report

AIE submitted 13/12/22

Why are NBDC funded only to conduct work on species rather than habitat data ? i.e. they map species, but do not map the pressures degrading the habitats of those species

Irish Nature Reserves: GPS locations, Area, Ownership (Public/Private)

https://www.npws.ie/nature-reserves

A Nature Reserve is an area of importance to wildlife, which is protected under Ministerial order. Most are owned by the State. However, some are owned by organisations or private landowners, and persons interested in acquiring statutory protection for their lands can seek advice on this matter from the Department.

https://data.gov.ie/dataset/nature-reserves-points-of-interest

2021 NPWS report notes that limited details of each reserve are available on https://www.npws.ie/nature-reserves. Do NPWS have management plans for the state owned sites? Are there obligations on private owners to publish management plans?

Guide to NPWS Structure and Management

Extracts from 2021 review report

NPWS has no CEO

The Assistant Secretary for Heritage holds responsibility for the NPWS along with other areas of heritage.

This is currently Niall O’Donnchu

https://whodoeswhat.gov.ie/branch/housing/Heritage/niall-odonnchu/628/

The NPWS is managed by four Principal Officers as four distinct Directorates/Sections, each containing 4-5 Units, reporting to the Assistant Secretary

Andy Bleasdale (scientific advice)

https://whodoeswhat.gov.ie/branch/housing/biodiversity/andy-bleasdale/638/

Ciara Carberry (peatland and land designation)

https://whodoeswhat.gov.ie/branch/housing/Peatlandissues/ciara-carberry/636/

Trevor Donnelly (national parks / nature reserves)

https://whodoeswhat.gov.ie/branch/housing/strategy/trevor-donnelly/637/

Vacancy (Legislation, Licencing, Property Management)

https://whodoeswhat.gov.ie/branch/housing/licensing/vacancy-4/639/

The functions and work-streams of the NPWS are the responsibility of one or more business Units, and many are directly undertaken by regional staff, supported by staff based at Headquarters in Dublin (and Wexford (Development Applications, Raised Bog Turf Compensation/Site Protection and Peatlands Management Units).

The Strategy, Regional Operations and Property Management Section manages NPWS regional staff

Frontline Conservation Rangers are managed through a Divisional and Regional structure. There are four Divisions and nine regions; 16 Districts and 84 ranger areas. This Section/Directorate manages and administers National Parks and Reserves, and deals with Property Management issues.

There is a dual structure in the NPWS of professional and technical staff in the field, and administrative civil servants and technical staff at HQ.

Existing Units:

Conservation Planning

Agri-Ecology

Ecological Assessments Unit

Two New Units:

New Wildlife Crime Unit has been established in the Legislation and Licencing Section, to provide information and guidance, operational support, intelligence, training, records and a national database, reviews of evidence, PR and awareness and liaison with the Legal Division

In response to the Infringement case brought by the EU Commission against Ireland (2006/2015) on the need to set site-specific conservation measures for SACs, a new Conservation Measures Unit to build national capacity has been set up.

AIE to NPWS on Flyover Photos Taken by AirCorp of Illegal Extraction of Peat in SACs/NHAs

AIE: 23/01/22

2021 data for the number of bog plots being cut in raised bog Special Area of Conservations (SACs) and Natural Heritage Areas (NHAs)

How the number of plots cut is related to Ha / volume of peat extracted

Any analysis conducted from the data collected

Most recent flyover photos for each SAC/NHA flown in 2021

Enforcement actions taken in 2021 based on the above

Review of the NPWS 2021: Final report on the key findings and recommendations

A report to the National Parks and Wildlife Service, of the Department of Housing, Local Government and Heritage


Prepared by Jane C. Stout and Micheál Ó Cinnéide

June 2021

Note: All or part of this publication may be reproduced without further permission, provided the source is acknowledged. This report is based on research undertaken from 2 February to 31 May 2021.

Unauthorised peat harvesting in Ireland – who do you report suspected illegal peat extraction to ?

Response from EPA 

Further to my phone conversation with you today. Possible illegal peat harvesting on an SAC site,  should be reported to National Parks and Wildlife Services (NPWS).

NPWS can be contacted on nature.conservation@chg.gov.ie or 1890 383 000. Contact information for the local Conservation Ranger can be found at https://www.npws.ie/contact-us.

Regarding bog drainage and illegal peat harvesting on Bord na Mona sites,  could you please send the EPA the details and address of this site via environmentalcomplaints@epa.ie

Other illegal peat drainage and harvesting at sites below 50 hectares should be reported to the relevant City/ County Council  via https://www.housing.gov.ie/local-government/administration/local-authorities/local-authorities

 

Trusting this will be of assistance to you.

 

Kind regards,

 

Cyrina Okoro

Programme Officer – Networks and Legal Team – Complaints Unit

Office of Environmental Enforcement, Wexford

The Regulatory Framework Applying to Peat Extraction – A Guidance Document

From Department of the Environment, Climate and Communications 

Published on 17 January 2022

Prepared by Des Johnson and Padraic Thornton (Planning and Environmental Consultants)

Guidance document commissioned by Department and the National Parks and Wildlife Service.

This document contains information regarding the regulatory framework (primarily that aspect which relates to the Planning System) which applies to peat extraction at the time of publication, January 2022.

It addresses the differing regulatory requirements which apply to peat extraction at specific thresholds (in terms of hectarage), the relevant application and appeals processes, and the opportunity/requirement for public participation in the consent process.

The Guide includes tables indicating the regulatory requirements for new and extended peat extraction areas, and for various scenarios which may arise in existing peat extraction areas.