An Taisce Submission Re: Forests, Products and People Ireland’s Forest Policy – a renewed vision

An Taisce are Ireland’s oldest and one of its largest environmental organisations. An Taisce is a charity that works to preserve and protect Ireland’s natural and built heritage. An Taisce recognises the important role that the forestry sector has to play in supporting the development of the rural and national economy. We are also aware of the potential positive and negative impacts of forestry on our environment and the negative role that forestry can play in postponing meaningful climate action in the land use sector. An Taisce welcomes the opportunity to contribute to this public consultation which should be viewed in parallel with the views and concerns expressed in our submission on the Forestry Programme 2014-2020 and on the mid-term review of the same. As a statutory consultee in the forestry consent system under the European Communities (Forest Consent and Assessment) Regulations 2010 (S.I. 558 of 2010) and as key stakeholders in the development of the forestry related policies such as the Hen Harrier Threat Response Plan and the National Biodiversity Action Plan 2017-2021 An Taisce are well placed to comment on the shortcomings of the Irish approach to forestry.

An Taisce submission on the Consultation on the Forestry Programme 2014-2020 (2014)

An Taisce Submission Mid Term Review – Forestry programme for 2014 – 2020

The current Forestry Programme had set out to encourage planting by private landholders in order to achieve a forest cover of 18% by the year 2046. The Forestry Programme 2014-2020 proposed the establishment of over 46,000 ha of new forests, the construction of 960 km of forest roads and improved levels of support for the establishment and conservation of native woodlands. All of this had to be achieved while adhering to the overarching EU Policy Framework Europe 2020 strategy for “smart, sustainable and inclusive growth”. Under the EU’s Strategic Environmental Assessment Directive, the Department of Agriculture, Food and the Marine (DAFM), as the programming authority, must assess the likely significant effects of its plans and programmes on: “the environment, including on issues such as biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors, material assets, cultural heritage including architectural and archaeological heritage, landscape and the interrelationship of the above factors” including “secondary, cumulative, synergistic, short, medium, and long-term, permanent and temporary positive and negative effects”.

An Taisce originally highlighted in the public consultation on the Forestry Programme and in numerous consultations in the mean time that we are deeply concerned that many aspects of the current programme fall short of the overarching objectives to achieve a sustainable and environmentally friendly forestry sector. Indeed many aspects of the programme are just a continuation of Ireland’s historically unsustainable forestry model whose practices over the preceding decades have negatively impacted on biodiversity, landscape, soil carbon and water quality. Commercial forestry plantations have a number of negative impacts on the environment. Non-native conifer plantations negatively impact on soil erosion and water quality and drive biodiversity loss through habitat loss and degradation. Non-native blocks of conifers sustain low levels of biodiversity compared to native ecosystems and traditional semi-natural habitats associated with High Nature Value farming systems. What has also become increasingly clear since 2014 is the negative socio-economic impact that commercial forestry is having on many parts of the country. These concerns have been raised by An Taisce with Minister Doyle himself at the inaugural COFORD Forest Policy Review Group (CFPRG) stakeholders meeting. These concerns have more importantly been repeatedly raised by affected communities in places like Leitrim within the national press and by the local Irish Farmers Association reps and by Macra Na Feirme. The Macra na Feirme afforestation policy position in particular has raised the impact which afforestation grants is having on the cost of land and land mobility. They have also highlighted their concern for the negative impact of forestry on High Nature Value farming which is shared by ourselves.

Afforestation Policy Macra na Feirme (2017)

There is a clear lack of a national dialogue and accountability in relation to the inevitable consequences of the market pressures have been released by the lifting of the dairy quota and the payments/tax breaks available for commercial forestry. The socio-economic consequences of these actions are accepted to result in the decline of small farmers and number of farming families, the loss of traditional hill farming/marginal farming in many areas with associated impacts on the structure of rural communities. This is likely to manifest itself in the irreversible decline and collapse of social cohesion in many rural communities around the country. The negative impacts of rural decline such as emigration and an aging population will only be exacerbate by the replacement of farming with a passive land use like forestry. The long term costs/benefits of such drastic changes for the effected communities have not been adequately debated. Groups who have voiced genuine concerns such as local IFA reps in Leitrim and Macra na Feirme and eNGOs like An Taisce have been discounted. Fact based arguments about the negative impacts on water quality and freshwater ecology and farmland biodiversity have yet to be adequately addressed. The incompatibility of certain models of forestry and indeed afforestation in general in certain areas is clear from the role that forestry has played in national conservation issues such as the Hen Harrier Threat Response Plan and the Curlew Action Plan. The announcement in recent months that the European Investment Bank has announced funding of over €200m for forestry related investment in Ireland and that Dasos a private forestry investment fund is looking to buy up Irish forestry only increases the concern that communities and wildlife will be displaced by foreign investors and sitka spruce plantations.

Within the COFORD Forest Policy Review Group (CFPRG) Minister Doyle and the forestry sectoral expressed the view that the decline of farming in certain areas was due to the lack of interest from younger generations due to the hardship and poor financial returns. The forestry reps felt that forestry was stepping into the void created by other forces rather than driving the negative trends in rural decline. An Taisce accept that the forestry sector is not alone responsible for these negative trends but that it is a contributing factor which is exacerbating rural decline in certain areas. Increasing the profitability of HNV farming through agri-environmental schemes, market supports such as certification and the diversification of the rural economy through the promotion of ecotourism and the delivery of broadband where strategically feasible would breathe life back into many marginalised communities. Without a national dialogue on the social and environmental consequences of the collapse of farming in marginal areas there can be no mandate for the inevitable consequences of government policies such as the Forestry Programme 2014-2020.

The Forests, products and people Ireland’s forest policy – a renewed vision report has not gone anywhere near far enough in identifying the range of environmental issues or societal concerns with the forestry sector which need to be addressed if the stated strategic goal “To develop an internationally competitive and sustainable forest sector that provides a full range of economic, environmental and social benefits to society,” is to be achieved. We hope that the following issues we wish to highlight can be addressed moving forward and that our recommendations may provide some helpful guidance in bringing about the transition to a truly sustainable and holistic forestry sector.