Draft of the SEA Environmental Report of Ireland’s Forest Strategy Implementation Plan, and related records

AAIE 23 418 / OCE-143453-T7Z3T0 Decision & Records

I wish to request under the Access to Information on the Environment Regulations;


1) The latest working draft version and the latest completed draft version of the SEA Environmental Report of Ireland’s Forest Strategy Implementation Plan
2) Related correspondence to Item 1 between the Department and the Consultants producing the Report
3) The latest working draft version and the latest completed draft version of the Stage 1 AA Screening and Stage 2 AA Natura Impact Report (NIR) of Ireland’s Forest Strategy Implementation Plan
4) Related correspondence to Item 3 between the Department and the Consultants producing the Report

Please note that completed draft versions are not covered by Article 9(2)(c). Refusal of working
drafts are subject to the weighing of the public interest. These documents are of significant public
significance and any weighing of the public interest must be specific to the records requested.

Decision Letter, DAFM

DAERA response to Consultation on the Screening Report for the SEA of the Forest Strategy 2022-2030

Consultation on the Screening Report for the SEA of the Forest Strategy 2022-2030

Irish Natura & Hill Farmers Assoc

Recommendations for Ireland’s Forest Strategy Implementation Plan
November 2022

ARUP
DAFM
Ireland’s Forest Strategy Implementation Plan, SEA Statement

Oct 2022

Supporting Information for Natura Impact Statement

SEA Environmental Report

AIE: Assessments of the impact on carbon sequestration / emissions from forestry as a consequence ofStorms Darragh and Eowyn

AIE 25 105 Request

1) Assessments of the impact on carbon sequestration / emissions from forestry as a consequence of
Storms Darragh and Eowyn.
2) An assessment of the impacts on water quality from forestry as a consequence of Storms Darragh
and Eowyn.
3) Maps in GIS format of forest areas impacted by the two storms.

DAFM assesses each licence application on its own merits, part of this assessment includes assessing the potential impact on receiving waterbodies. This was the procedure pre-storm and continues to be the procedure for all applications post-storm. All licences utilised to deal with storm damage arising from Storms Darragh and Eowyn will have undergone this assessment.

Assessment of forest wind damage is ongoing at this time. These spatial data should be available by the end of April 2025, however, this date for completion of the mapping exercise is indicative only as cloud free satellite imagery is required to complete the mapping work and availability of cloud free imagery is weather dependent.

AIE Request: Native Tree Area Scheme

AAIE 24 731 – Decision Letter Issued

For the period indicated October 2024, I wish to receive
1) A copy of all information submitted in relation to applications made under the new Native Tree Area Scheme. This includes additional information to applications that were made prior to the dates indicated.
To include
a) Application documentation, including reference number, excluding any personal information
b) A map of the proposed area in GIS format (shapefile/s and attribute data); please note that these are material information and DAFM hold the information in that format. ****This includes any GIS files submitted by applicants. Please note that any alternative must be functionally equivalent. If DAFM intends to refuse this element of my request under Article 9 (2)(a) then please detail the precise process that would be required of the Forestry mapping team to meet this request.
2) Information on any approvals under the Scheme
3) The number of applications that have been digitised in to mapped format.

AIE: DAFM and the development of standard emergency response procedures in relation to forestry

The Regulatory Review as part of Project Woodland, published in June 2022, contained the following Recommendations;

“The EIA Directive provides that Member States may, through their national laws, disapply the EIA Directive to projects which respond to a civil emergency if the Member State decides that applying the
EIA Directive would have an adverse effect on the environment. The Irish High Court has held that this provision applies only to projects responding to an unforeseen emergency, not to projects intended
to avoid foreseeable emergencies 71. The Habitats Directive and Birds Directive make no provision for projects responding to emergencies 72. The Water Framework Directive provides a very limited
derogation in response to extreme force majeure events.

  1. It is recommended that DAFM consult with the forestry sector and other key stakeholders and prescribed bodies on standard emergency response procedures, which will guide foresters planning for and responding to foreseeable emergencies such as storms, fire, disease etc. Standards may be subject to prior SEA screening and AA screening/AA, as required, prior to adoption. An afforestation licence application would be accompanied by a proposed emergency response plan, prepared in accordance with the standards. Once assessed and approved, it would be up-dated periodically (e.g. 3-5 years) or as frequently as required to take account of changes to the forest and the receiving environment and the different emergency risks which may emerge as the forest matures. The proposed emergency response plan would be part of the project that is assessed before the afforestation licence is granted.
  2. It is recommended that, pursuant to recommendation 14, the Forest Regulations may be amended to expressly exempt from the requirement for a licence any emergency works which are carried out substantially in accordance with an approved emergency response plan. DAFM should be given prior notice before the commencement of emergency works, and DAFM should reserve the right to step in and require a licence application to be made where it considers that there are likely significant effects which must be appropriately assessed before the works are carried out.
  3. It is recommended that the standard conditions to be attached to an afforestation licence should include an obligation to give DAFM prior notice of any proposed emergency works, and that such works shall be carried out substantially in compliance with the emergency response plan as assessed and approved by DAFM.”

Save Leitrim submitted an AIE request to DAFM after Storm Darragh;

We wish to receive under the AIE Regulations, in electronic format;
With reference to recommendations 17, 18 and 19 of the Project Woodland Regulatory Review (June 2022) (see below)
Information related to the development of standard emergency response procedures.
To include, but not restricted to, any consultations, actual or proposed, with
a) the forestry sector
b) other key stakeholders
c) prescribed bodies
To clarify, this could include any information related to consideration or discussion on the introduction of such procedures and changes to Regulation.
There is a very strong public interest case to be made for this information.

Note: Two and a half years after the publication of the Report DAFM cannot find any information which would suggest that there has been any consideration of Recommendations 17, 18 and 19 of the Regulatory Review. In failing to implement the Recommendations DAFM have left Ireland exposed in terms of compliance with European Law for the major clear-up operations that are ongoing in plantations across affected areas.