The Department of the Environment, Climate and Communications has a requirement for a compliance tracking software solution to replace an existing manual process. The Department is now seeking information from providers of compliance tracking software that have a track record in providing secure standards based compliant compliance tracking software solutions.
The current manual process involves up to 80 different external organisations, operating in different sectors of the economy, submitting a Self-Assessment spreadsheet on a yearly basis
These spreadsheets are used to track organisations’ performance against key outcomes and progress of Corrective Action Plans.
These spreadsheets span multiple excel tabs, within each tab there are multiple sections and multiple columns. Organisations assess themselves against these out-comes which are then used by DECC to track performance.
This current manual process has a number of drawbacks such as difficulty to:
compare performance across years
identifying common gaps or issues
identifying areas of good or poor performance
produce reliable and detailed reports
inability to query information easily
The move to replace this manual process is part of a move to increase electronic management of the documents and automation of steps within the compliance process and to provide a secure and user-friendly application for the end users. The change is also aiming to create reliable and timely statistics, detailed reports, audit tracking capabilities and the ability to easily identify gaps to facilitate management of the compliance process as well as reporting to senior management and external constituents on compliance progression.
DECC is seeking information from providers of compliance tracking software that have a track record in providing secure standards based compliant compliance tracking software solutions.
The purpose of this Request for Information is to assist DECC in clarifying its requirements and evaluating potential options for such software solutions.
A contract will be awarded for the out-sourcing of a series of Farm Inspections in various “At Risk” catchments in Co. Donegal.
The specification may include carrying out of Integrated Catchment Management (ICM) and Investigative Assessment in certain agricultural catchments, as required.
The Department of Housing, Local Government and Heritage has allocated some short-term funding to local authorities to increase efforts to deal with several water quality pressures in high risk water bodies, the largest of which is agriculture, under the 2nd River Basin Management Plan and continuing into the 3rd cycle plan yet to be published.
As a first step, an increased programme of agricultural inspections will be compiled and commenced in these water bodies in the coming months. The resources for this work will be drawn from the private sector and this contract is for the engagement of suitably qualified contract staff to carry out the required inspections in various catchments within Donegal County Council’s functional area.
These inspections will focus primarily on farmyards and compliance with the Good Agricultural Practice Regulations, eg – slurry storage, silage pits, manure pits/dungsteads, minimisation of soiled water, drains and adjacent water-courses, including cattle access and farm roadways.
Initial planning, selection of sites and follow-up actions, including enforcement will be carried out by local authority staff. The Council will draw up a weekly programme of inspections in a small number of “at risk” catchments and these will be completed by the contract staff using a pre-set inspection template and recorded in electronic format. Farms to be inspected will include the full range of farm types, including, dairy, sheep and mixed farms.
The revised National Emissions Ceiling (NEC) Directive (2016/2284) requires that Member States ensure the monitoring of negative impacts of air pollution upon ecosystems based on a network of sites that is representative of their freshwater, natural and semi-natural habitats and forest ecosystem types, taking a cost-effective and risk-based approach.
The EPA is now advancing with implementation of the NEMN in Ireland, based on guidance and recommendations included in the NEMN Design Report, plus the slight amendments to the sites as submitted to the EEA/Eionet under the Article 9 / Article 10(4) submission.
The EPA Chemicals and Ecosystems Monitoring Team requires specialised technical support and input, to support implementation activities for the period 2022-2024.
Summary
The revised National Emissions Ceiling (NEC) Directive (2016/2284) requires that Member States ensure the monitoring of negative impacts of air pollution upon ecosystems based on a network of sites that is representative of their freshwater, natural and semi-natural habitats and forest ecosystem types, taking a cost-effective and risk-based approach.
In 2020 the EPA awarded a framework agreement for technical support and input from a suitably qualified third party to support the review, establishment and operation of the National Ecosystems Monitoring Network (NEMN) over the period from 2020 to 2022. Under this contract, a report entitled ‘National Ecosystem Monitoring Network (NEMN)-Design: Monitoring Air Pollution Impacts across Sensitive Ecosystems[1] (“NEMN Design Report”)’ was developed which proposes methods for air quality monitoring, ecosystem parameters for assessment, as well as sites for inclusion in the NEMN to provide representative coverage across sensitive habitat types and major pollution gradients. This report was the basis of the submission under Article 9 of the NEC Directive that was submitted to the EEA/Eionet during 2022 in accordance with Article 10 (4) of the Directive.
The EPA is now advancing with implementation of the NEMN in Ireland, based on guidance and recommendations included in the NEMN Design Report, plus the slight amendments to the sites as submitted to the EEA/Eionet under the Article 9 / Article 10(4) submission. The EPA Chemicals and Ecosystems Monitoring Team requires specialised technical support and input, to support implementation activities for the period 2022-2024.
Concerns identified by farming representative organisations
The following are the main points raised by the various farming representative organisations at the Consultative Committee:
Farmland in hen harrier areas tends to be relatively unproductive and there is a significant challenge in achieving an adequate income for farm families. Although specific restrictions on activities (ARCs) are few, farming activities are seen to be significantly curtailed by these designations.
It is seen as critical to farming in hen harrier areas that farming and forestry are allowed to co-exist. Farming representative organisations want restrictions on forestry removed. The premia under the Afforestation Grant & Premium Scheme are potentially a substantial and important income stream for farmers and operate on a 15-year contract basis which provides much greater security than a typical 5-year contract life for agri-environment schemes.
The application of rules on eligibility for the Single/ Basic Payment has been seen as penalising farmers who have or are managing their land in a way that is suitable for hen harriers, and complete clarity is required. It was frequently asserted that farmers who allow vegetation, such as heather and rushes, to grow to a height that is optimal for Hen Harrier are liable to penalties under the eligibility rules. There have been reports, including by NPWS to DAFM, that farmers have cleared important habitats on their farm (e.g. scrub, boggy areas, nest and roost sites) to maximise GLAS payments, as the existing habitats were deemed ineligible for Pillar 1 payments and thus GLAS payments also.
The basic value of land for farming in the uplands including SPAs is generally low. However, land value increases if it is eligible under the Afforestation Grant & Premium Scheme. If there is an automatic bar on the Scheme due to an SPA designation, not only are the grant and premiums not available, but the land is worth several times less and is likely to be difficult to sell. This impacts on potential income and also on the value of farms as collateral for bank loans. Farming organisations want to see the DAHG farm plan scheme re-introduced and DAFM agri-environment payments increased.
There is great concern that further restrictions might be placed on areas outside existing SPAs which surveys have shown are important for hen harrier.
Concerns were also expressed about the additional burden in relation to planning permissions and related matters and, more generally, that opportunities for farmers outside but close to SPAs are greater than those available to neighbouring farmers whose land is designated.
The challenge therefore is how best to achieve the long term survival of farmed habitats that suit the hen harrier while providing a reasonable level of income for farmers and recognising that farmers in general want to farm well, and many are keen to improve agricultural efficiency and output where possible. The uncertainty about eligibility of lands for the Single / Basic Payment Scheme is a driver for habitat loss or disimprovement.
Concerns identified by Forest Sector organisations
The forest sector is of the view that the current forestry-related protection measures being enforced within SPAs in Ireland, including the cessation of afforestation and restrictions on forest operations, may not be delivering hen harrier conservation solutions and seeks alternative approaches. The sector notes that successful conservation of the hen harrier in Ireland requires effective and meaningful consultation of all affected parties to ensure their buy-in to the process. The latter view is widely shared by members of the Consultative Committee.
The Forest Sector called for annual surveys of breeding hen harrier in SPAs, rather than the current 5-year cycle. If feasible this could reduce the “red zones” in which management operations are more strictly controlled.
The forest sector also opposes any restrictions on forestry in the non-designated areas that are important to hen harrier.
Concerns identified by eNGOs
The eNGOs consider that more SPAs for hen harrier should have been designated in the first instance, and assert that, as per EU case law in c-374/98 Basses Corbières, the 3 areas of concern should have been protected under Article 4(4) of the Birds Directive as if designated.
They argue that hen harrier SPAs are not performing, that some breeding populations are now unviable and are concerned that there are as yet no conservation objectives for hen harrier SPAs. They consider that populations outside of SPAs are equally under threat.
The eNGOs identify forestry as the main threat to the hen harrier in Ireland, and that there is too much forest in the SPA network, with no transparency on afforestation decisions. They support a review of the “red zone” procedure, but subject to seven conditions set out in their submission.
In their submissions, the discrepancy between the length of Forestry incentives and the typical period of Rural Development Plan infrastructural Investment schemes is listed as a critical issue, and that the RDP could and should provide for longer contracts. There should be local engagement to develop locally-relevant incentives for restorative land management.
On agriculture, the eNGOS consider the GLAS prescriptions for hen harrier should be revised. The capped GLAS payments are not a sufficient incentive for farmers and the cap should be removed. Because of eligibility issues, destruction of Hen Harrier habitat is continuing. Pillar I and II issues on eligibility should be resolved. There also needs to be an agri-environment scheme for wintering hen harrier.
Guidance on birds and wind energy development is needed, along with wind energy development impact assessment guidelines.
Finally, they argue for education of farmers and local communities for positive change.
The hen harrier (Circus cyaneus) is a territorial ground-nesting bird of prey that typically breeds in open upland bog and heather moorland, and their associated habitats.
The most recent (2015) National Hen Harrier Survey estimated the breeding population to be between 108 and 157 pairs in the Republic of Ireland. Outside the breeding season, it ranges more widely across both upland and lowland areas.
Along with a number of other species and habitats, the hen harrier is under threat in Ireland due to a number of factors, but primarily due to the loss of suitable habitat through afforestation/forest maturation, agricultural reclamation and intensification, and wind energy development.
Some of these land-use changes may also cause unsustainable rates of nest loss, due to increased levels of associated predation. In addition, there is a very low survival rate for juvenile birds through their first winter. As a result, the national population is in decline.
Following the designation of the six breeding hen harrier SPAs in 2007, an agreement (the “Hen Harrier Protocol”) was reached between the Forest Service of the Department of Agriculture, Food and the Marine (DAFM), the NPWS of the then Department of Arts, Heritage and the Gaeltacht (DAHG), landowner representatives and forest industry interests, on the management of afforestation within the SPAs.
However, the European Commission considered the protocol to be a “plan”, and as such, it could not lawfully be applied in the absence of a strategic environmental assessment. On foot of that and other concerns, the Protocol was suspended.
It was then agreed that a Threat Response Plan would be prepared that would address issues that had been identified as affecting land use in the hen harrier SPAs, as well as affecting the conservation status of the species.
The draft Plan is being made available for public comment, as required by Regulation 21, and will be published upon its adoption.
The draft Plan will also undergo a screening for Strategic Environmental Assessment (SEA) and Appropriate Assessment (AA), and any further assessments that are indicated as necessary.
The SEA will be commissioned and undertaken by NPWS-DHLGH; NPWS will also commission the Natura Impact Statement for Appropriate Assessment, while the AA determination itself will be made by the Ecological Assessment Unit, pursuant to Regulation 42a of the Regulations.
The final Plan will be adopted by Government.
Detailed site-specific conservation objectives are being set and published for each SPA selected for breeding hen harrier, based on the established NPWS-DHLGH process that aims to define favourable conservation condition at a specific Natura or European site, for a particular habitat or species.
Using the parameters that define favourable conservation status of species, specific attributes for the species and its supporting habitat are set, along with targets that define the favourable reference value for that attribute.
Following the conclusion of relevant research outputs from the Hen Harrier Programme and the mid-term review of the Plan implementation, the SSCOs will be reviewed with a view to their update, if necessary.
The Department also intends to publish conservation objectives for the two wintering hen harrier SPAs in 2023 (Wexford Harbour and Slobs SPA and Lough Corrib SPA), following the conclusion of ongoing relevant research in 2022.
An SPA-network-level conservation objective will also be established, informed by the site-level objectives, so that the breeding SPA network will operate as a coherent whole, and effects that may arise on one SPA can be considered in the context of the whole network.
Due to the proportion of the hen harrier population that occurs outside the SPA network, it is also the Department’s intention to publish a national conservation objective for the species, and to explore the establishment of an all-Ireland objective with Northern Ireland, following the conclusion of the 2022 National Hen Harrier Survey.
Main Threats and Pressures Affecting Hen Harrier
The primary potential threats and pressures to breeding hen harrier, as identified through the consultation process for this Plan, concern forestry, agriculture and wind energy development.
As previously mentioned, detailed reports on each of these sectors and their interactions with hen harrier have been produced to support the Plan’s development. The issues arising are summarised below.
Other potential threats to hen harrier include disturbance from recreational activities, persecution, wildfires and turf cutting, predation and climate change, all of which can affect other species and habitats.
A further forestry-related threat is the increased risk of predation, and nest predation in particular.
The Department will keep the relative importance of these pressures and threats under review as part of the Threat Response Plan implementation process, as well as through the Strategic Environmental Assessment.
Forestry
The breeding hen harrier SPAs include commercial coniferous forest plantations (more than 50% by area).
These were included in the SPAs during the designation process, as surveys at that time showed that a large proportion of the national hen harrier population was using parts of the plantations for nesting and foraging. Notwithstanding that, the natural habitat of the hen harrier is open bog and heather moorland, with rough grassland also favoured.
Hen harriers find young forest plantations attractive to breed in, and the population is thought to have increased in Ireland in the 1960s and ’70s due to new afforestation. However, breeding success is compromised by the loss of open space as forest canopies close. By 10 years or so after planting, a forest is of little habitat value for hen harrier until clear-felling takes place.
In a balanced, mixed-age forest landscape, approximately one-quarter of the forest estate is in pre-thicket stage at any one time. Currently, however, forests within the hen harrier SPAs lack this mixed-age balance.
Agriculture
Lightly grazed heath/bog, with some scrub, is the most suitable habitat for nesting hen harrier. Lowland tillage, in combination with open heath/bog and rough grasslands, is important for both foraging and roosting outside the breeding season, which constitutes a significant portion of the year.
The quality of rough grassland, or indeed improved grassland, for hen harrier can be influenced by a range of agricultural practices, including grazing intensity, grazing periods, grazing types, fertiliser/slurry usage, rush control etc.
Hedgerows are also important, providing foraging networks throughout the year.
Habitat loss, fragmentation, and degradation due to agricultural intensification have already significantly reduced the availability and quality of open heath/bog and open grazed wet grassland habitats in areas important for breeding hen harrier. There are also significant concerns about the low survival rate of young hen harriers, particularly over winter. Appropriate grazing of these open habitats is an effective means to deliver suitable farmland habitats for hen harrier.
Areas of abandoned land with scrub, though not considered extensive at a landscape-scale, can be utilised by nesting and/or roosting hen harriers in particular. It is also important to retain natural and semi-natural habitats in the landscape, as well as to ensure that the quality of appropriately-grazed habitats is not negatively affected by other pressures.
While heather, rush and scrub are among the most important habitats for hen harrier, the eligibility of such land for entry to the Basic Payment Scheme (and subsequently ANC and GLAS) has been problematic, and there have been many instances where area or payment reductions were applied due to their presence.
In parallel, many landowners have cleared or burned extensive areas of such habitats to maximise eligibility for payments. Such habitats may even be seen as a hindrance to the earning potential of land under schemes such as BPS, ANC and GLAS. There are ongoing challenges around the communication and implementation of land eligibility.
Wind energy developments
There is considerable overlap between the breeding range of hen harriers and the upland areas in which wind energy development has been concentrated in Ireland.
Over two hundred and fifty wind turbines occur within the hen harrier SPA network.
There is now some evidence that hen harrier breeding productivity may be impacted by wind turbine development close to nesting areas.
This is particularly relevant as the Habitats Directive requires that planning decisions must ensure that there are no adverse effects on the integrity of European, or Natura, sites, for a project or plan to be consented to under Article 6(3) of the Habitats Directive.
Summary assessment of pressures and threats
Existing Measures to Address Hen Harrier Conservation Requirements
Restrictions arising from the designation of SPAs
Restrictions or additional duties that arise on lands designated as SPAs fall into two main categories: a. Requirements of planning and licensing authorities (including the Forest Service) b. Activities requiring consent (ARCs)
Under the EU Nature Directives, and as interpreted through the Irish Courts and the European Court of Justice, consenting authorities can only consent to activities in an SPA if they are clear that there will not be an adverse impact on the species for which the SPA has been designated.
ARCs
These are activities that might be damaging to a Natura 2000 site but that do not require planning permission or another form of consent. In such cases, prior consent is needed from the Minister for Housing, Local Government and Heritage. Obligations as set out above in relation to screening for appropriate assessment, and appropriate assessment as necessary, also apply to ARCs.
The rules of the Basic Payment Scheme also require that farmers must not undertake these activities without prior consent from the Minister.
There are currently three ARCs relevant to hen harrier SPAs: – Agricultural improvement of heath or bog. – Construction, removal or alteration of fences, stone walls, hedgerows, banks or any field boundary other than temporary electric fencing (consent is not required for normal maintenance). – Off-road recreational use of mechanically propelled vehicles.
Agri-environment Schemes Relevant to Hen Harrier Areas
NPWS Farm Plan Scheme (2006-2015)
The NPWS Farm Plan Scheme was launched in 2006. The main purpose of the scheme was to promote a focused, targeted and innovative approach to farming for the conservation of habitats and species of conservation concern, where they were not adequately covered by other national agri-environment schemes.
In total, 377 NPWS farm plans, based on a five-year contract, were put in place with farmers in hen harrier SPAs. Following the financial crisis of 2008, and subsequent budgetary cutbacks, the NPWS farm plan scheme was closed to new applicants in April 2010 and most plans reached their end-of-life by 2015. Over €14 million was paid to the participating farmers, with an average payment of €7,347 per annum.
This scheme was funded solely from the national exchequer, i.e. no EU funding was allocated. The NPWS farm plan scheme was never resourced to the extent that it could provide suitable habitat at a landscape scale for hen harrier, with less than 10% of the farmers in the SPAs participating.
GLAS (2014-2023)
The Green Low Carbon Agri Environment Scheme is the current agri-environment scheme, which is part of the RDP 2014-2020 (extended to 2023). The GLAS standard ‘package’ is up to €5,000 for eligible farmers per annum, with an additional package of €2,000 per annum for those in GLAS+, in return for exceptional environmental commitment.
Farmers in hen harrier areas (SPAs and other relevant areas identified in the national 2015 survey) are eligible for GLAS and GLAS+. DAFM has estimated that more than €23m per annum is available for hen harrier actions alone in GLAS and GLAS+. As of August 2022, there were 2,476 farmers taking up hen harrier actions in GLAS, with 1,350 of these also in GLAS+.
Hen Harrier Programme EIP (2018-2022)
The Hen Harrier Programme is a €25m European Innovation Partnership (EIP) that has operated between 2018 and 2022. The Hen Harrier Programme has been pivotal in piloting measures for the hen harrier and associated conservation interests, including habitats, wider biodiversity, water and carbon, as well as delivering community buy-in.
The primary objectives of the Hen Harrier Programme were: 1: To ensure the sustainable management of High Nature Value farmland in the most important breeding areas for hen harrier in Ireland. 2: To promote a stronger socio-economic outlook for marginally agriculturally productive upland areas that are generally difficult to manage. 3: To develop an effective model for future sustainable management of hen harrier areas. 4: To foster continued positive relations through locally-led solutions between the people who have managed these landscapes for generations and the relevant Government Departments. This relationship is central to maintaining and enhancing the biodiversity that exists on these lands.
It has targeted approximately 24% of the land area of the hen harrier SPAs and pays farmers to undertake actions to reach the Programme’s goals, the success of which is measured in the field. It has been delivered on the ground by a specialist locally-based intermediary team (between DAFM and the landowners), which was appointed through competitive tender (hereafter ‘the Hen Harrier Programme Team’). The Programme is overseen by a Steering Group, comprised of representatives from DAFM, NPWS, Teagasc, participating farmers and Hen Harrier Programme Advisors.
The Hen Harrier Programme is operated on the basis that payments are for the habitat and support actions delivered during each breeding season. All payments under the Programme are made “in arrears” and are based on the habitat quality and actions delivered by the farmer by August 15th each year, i.e. the latest date for submitting a claim for payment to the Hen Harrier Programme Team.
The delivery of the Hen Harrier Programme is supported at farm level by three types of payments: • A Results-based Habitat Payment • A Supporting Actions Payment • A Hen Harrier Payment
The Hen Harrier Programme has acted in parallel to GLAS. Participation in the Programme was not linked to GLAS participation, and all payments through the Hen Harrier Programme were separate from GLAS. It forms part of a package of supports available to farmers in hen harrier SPAs that also includes the Basic Payment Scheme (BPS), Areas of Natural Constraint (ANC) and GLAS schemes.
The CAP 2023-27 will incorporate hen harrier SPAs (and some other important hen harrier breeding sites) into a new Cooperation Project approach, where it is intended that multiple biodiversity interests will be addressed at a landscape scale.
RAPTOR LIFE project
IRD Duhallow, a community-based Rural Development Company, secured €3 million LIFE+ funding for Raptor LIFE 2015 to 2019, after an 85% decline was recorded in the local hen harrier population.
It sought to connect and restore habitats for priority species, including the hen harrier, within the River Blackwater (Cork/Waterford) SAC and the Stacks to Mullaghareirk Mountains, West Limerick Hills and Mount Nagle Special Protection Area (SPA). The latter is the most important SPA site for hen harrier. From 2016-2019, its monitoring showed that this sub-population has had poor productivity (overall fledging rate of less than 1.2 young fledged per breeding attempt).
The RaptorLIFE project drafted a Management Plan for the Stacks to Mullaghareirk Mountains, West Limerick Hills and Mount Eagle SPA.
Hen harrier-specific actions within the plan include:
management of forests in the SPA with a target of 23 pairs or more for the SPA by 2025, along with a stable/increasing population trend.
a reduction in nest losses to predators,
no nest failures to disturbance or fire,
no losses of adults or nests to persecution, along with
maintaining or increasing the area/quality of HNV farmland, hedgerows, retaining important nesting areas in scrub, and restoring degraded heath/bog habitats.
Joint Oireachtas Committee Hearing
In 2015, the Joint Committee on Agriculture, Food and the Marine published its report on the “Designation of Lands as SPAs for the Conservation of Breeding Hen Harriers”. The Committee met with representatives of “Irish Farmers with Designated Lands”. The JOC‘s report contains 18 recommendations, reproduced in Appendix 6; these have been used to inform the Threat Response Plan, and many of them have been incorporated into actions in this draft Plan.
Land value and compensation
Regulation 41 of the Regulations provides for compensation where the Minister refuses consent to an activity that had been carried out within the previous five years. The Regulations do not give the Minister powers to make payments for reduced land value per se, nor for the loss of collateral value.
The Joint Oireachtas Committee on Agriculture, Food and the Marine (see above and Appendix 6) recommended that payments should apply only to the curtailment of current or past activities and current or past income foregone.
Furthermore, payments should not apply to potential or future income; and payment should not be made for failure to secure either planning permission or a rant for new development.
The CatchmentCARE project aims to establish three cross-border, fresh water quality improvement projects in the Finn (Donegal—Tyrone); the Arney (Fermanagh-Leitrim-Cavan); and the Blackwater (Armagh-Tyrone-Monaghan) Catchments; as well as installing 51 boreholes across the region.
River Works in Blackwater Catchment One of the main outputs of the CatchmentCARE project is to deliver a range of riparian and in-stream works aimed at helping improve existing water quality across the project’s three catchments.
Riparian and in-stream works around the Ballygawley area, which suffers badly from silt deposition / runoff and excessive nutrient loading.
‘Ballygawley Phase 1’ will entail a range of measures being implemented, including: – Installing fencing along rivers to help decrease erosion of banks by cattle; – Supplying and installing livestock drinkers for local farmers; – Installing field gates and stiles to provide access for farmers and local user groups; – Planting native species of trees and riverside vegetation to help stabilise riverbanks and create a buffer strip between the river and agricultural land; – Installing bank revetments and other in-stream works such as rubble mats and flow deflectors (to create a more diverse flow and habitat in the river channel). This work will involve partnership with DEARA Fisheries.
I refer to your request on for a review of the decision made by this Department on 15th August 2022 not partially release the records to which you requested access under the European Communities (Access to Information on the Environment) Regulations 2007 to 2018 (S.I. No. 133 of 2007, S.I. No. 662 of 2011, S.I. No. 615 of 2014 and S.I. 309 of 2018) (hereafter referred to as the AIE Regulations).
A list of all unexpired and unexercised forestry licences (whole or part) (all schemes); a) within the six SPA’s designated for the protection of the Hen Harrier b) which contain mitigation to protect Hen Harrier during the breeding period
I was assigned to review your request. I made a decision on your review request on 12th September 2022. My decision on review is an entirely new and separate decision on your request and is explained below. I must inform you that I have not found any grounds to reverse the decision made by the initial decision-maker and accordingly I affirm her decision to refuse access to the records requested under Article 9(2)(a).
The Department does not collate information on unexercised forestry licences. In order for the Department to collate this information, the Department’s forestry inspectorate would need to visit every site for which an application has been made within those areas and provide a report on each site in question. This information would then have to be collated and cross-checked to create the list of sites which you refer to in your request.
Your request therefore would, in my opinion, place an unreasonable demand on the Department’s resources and would disrupt the Department’s ability to perform its core licencing functions.
In arriving at a decision on your request, I confirm that I have had regard to the provisions of Article 10 of the Regulations.
In line with Article 10(3), my deliberations have included weighing the public interest served by disclosure against the interest served by refusal.
The factors in favour of release of this information are to contribute to the already open nature of the forestry licencing process.
The factors in favour of withholding this information are those set out above.
There is no public interest in diverting the Division’s resources to compile the list that is being requested here. All the licences in question have undergone the full licencing process and were legal approved.
I have decided therefore that, on balance, the public interest in this case is best served by withholding this information.
Under Article 12 of the AIE Regulations you may appeal this decision, by writing to the Commissioner for Environmental Information at the address given below:
Office of the Commissioner for Environmental Information 6 Earlsfort Terrace Dublin 2 D02 W773 Phone: +353-1-639 5689 It is also possible to appeal on the website of the Commissioner http://www.ocei.gov.ie.
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.
The Shared Vision for Forests was crafted by Project Woodland and finalised following extensive stakeholder engagement and public consultation throughout 2021/2022.
A summary of the methodology used, the results of the consultations, and the influence of the consultation and engagement on the National Shared Vision is available here:
