Key Messages

1. Since 2014, the Forestry programme 2014-2022 has sanctioned the planting of 13,719 hectares or 14.1% of forestry planted nationally (Coillte and private planting) in hotspots for 6 of our most threatened breeding waders in Ireland.

2. Since 2014, the Forestry programme 2014-2022 has sanctioned the planting of 6,538
hectares or 6.7% of forestry nationally (Coillte and private planting) in hotspots important
for 28 of our red and amber listed birds of conservation concern.

3. BirdWatch Ireland mapping shows that since 1990 78,606 or 14.6% of total forestry planted
has been in breeding wader hotspots and 37,036 or 6.7% of total forestry planted in farmland
bird hotspots.

4. BirdWatch Ireland mapping shows that the total forestry replanted since 2014, within Breeding Hen Harrier SPAs is 12,382 [hectare] or 12.7% despite there being a moratorium on planting in place in that time period.

5. This is evidence that Ireland is in breach of the Birds Directive and the conditions of the European Commission State Aid Decision granting consent for the provision of €200 million to fund the 2014 Forestry Programme including:
a. Projects must be undertaken in compliance with national and EU legislation (e.g. several articles of the Birds Directive).
b. The condition to avoid planting on environmentally sensitive sites and
c. The inappropriate afforestation of sensitive habitats such as peat lands and wetlands will be avoided, as well as the negative effects on areas of high ecological value including areas under high natural value farming.

6. A disproportionate amount of forestry is being planted in important areas for birds in the wider countryside. There are likely several reasons for this.
a. There is no strategic planning of afforestation in Ireland
b. There is no ornithological assessment of sites/applications being proposed for afforestation.
c. The Land Types for Afforestation document which provides guidance on the land which can be planted, is potentially a driver of loss of Annex 1 habitat and habitat for birds and other biodiversity
d. The payments and tax-free status of afforestation premia are lucrative. No agri-environment scheme which would pay farmers to continue to farm for threatened bird species can compete. This creates the risk that even more areas of land will be opened up for afforestation further threatening bird species.

7. The draft Forestry Implementation plan for 2023-2030 which is underpinned by an almost 7-fold increase in funding does not contain any evident changes in individual environmental assessment of afforestation applications to account for the presence or absence of birds on a site proposed for afforestation compared to the 2014-2022 Forestry Programme. It is clear therefore that we can expect further losses of habitat important for breeding waders and other farmland birds unless changes are made.

8. The environmental assessments of the draft Forestry Programme fail to consider the impacts on the different measures on red and amber listed birds in the wider countryside. There is also woefully inadequate assessment of Annex 1 bird species in the wider countrywide (e.g. geese and swans) in breach of Article 6.3 of the Habitats Directive and various European Court of Justice rulings. The Article 12 reporting research only extracted data relating to Annex 1 species that are qualifying interests of an SPA are considered in this AA report and what is reported is incorrect. Also unclear as to why the BoCCI status of Curlew, a red listed
species for breeding and wintering has N/A status associated with Table 4 in the NIS. The BoCCI status for a range of red and amber listed species is listed as N/A with no rationale as to why. These should be listed.

9. The analysis of the effects of the Programme on Annex 1 species is extremely limited. It focuses in on Annex 1 species with ‘bad’ or ‘inadequate’ status that are already identified as being affected by forestry activities (according to Article 12 code)

10. Species assessments in NIS. The NIS only focuses on Merlin and Hen Harrier and fails to assess impacts on a range of other Annex 1 species or the conservation interests of the SPAs.

11. Incombination assessment of other plans and programmes is extremely general. For example the statement that the IFSIP is ‘broadly in line with the EU biodiversity Strategy’. Afforestation is a significant pressure and threat to a range of threatened bird species whose populations must be restored. Assessment fails to consider this.

12. The cumulative impacts of afforestation, intensification of agriculture, peat cutting, wind farm development etc have not been adequately considered in the environmental assessments of the draft Forestry Programme.

13. It is of serious concern to us that a farmer signed up to an ACRES contract can end that contract to afforest his/her land and not be subject to penalties.

14. The fact that a farmer can receive the Basic Payment which requires adherence to Article Article 3(1), Article 3(2)(b), Article 4 (1),(2), and (4) covering legal protection for birds and a requirement to protect birds in the wider countryside and receive an afforestation payment which wipes out habitat for birds is discordant and an abuse of taxpayers money. Taxpayers are paying on the double for both the protection of habitats and their destruction. This must change.

15. Unless afforestation is planned strategically with clear objectives and processes is put in place to avoid afforestation in important areas for birds, breeding waders in particular could be wiped out as a result of the state’s forestry programme to 2030.