Dedicated To Restoring The Relationship Between

People And Their Native Woodlands

C/o East Clare Co-op, Tel: +353-(0)87-9933157

Main Street,

Scariff,

Co. Clare,

Ireland.

Submission On OverallIrishForest Policy 2010

Incorporating reviews of all aspects of Coillte,

forestry legislation & policy and forestry grants premiums.

Submitted to the Department of Agriculture, Fisheries and Food - with responsibility for Forestry

March 2010:

Forest Service

Department of Agriculture, Fisheries and Food

JohnstownCastle Estate

Wexford

Contents

i. Acronyms

1. Introduction

2. Context

3. Priorities

3.1Biodiversity

3.2Water & Soil Protection

3.3 Climate Change & Carbon Sequestration

3.4 Biomass

4. Forestry Legislation & Policy

5. Funding, Grants & Premiums

6. Communities As Stakeholders

7. Coillte

8. Summary

Appendices

Appendix 1 - Criteria & Indicators for Sustainable Forest Management In Ireland

Appendix 2 – Coillte’s Breaches of FSC Principles

i. Acronyms

SFMSustainable forest management

EUEuropean Union

UNUnited Nations

FSCForest Stewardship Council

MDFMedium Density Fibreboard

FLEGHTForestLawEnforcement, Governance and Trade

OPWOffice of Public Works

NGONon Governmental Organisation

EPAEnvironmental Protection Agency

TPOTree Protection Order

NRANational Roads Authority

RDPRural Development Plan

NDPNational Development Plan

CHPCombined Heat & Power

SEAStrategic Environmental Assessment

EIAEnvironmental Impact Assessment

CPOCompulsory Purchase Order

IENIrish Environment Network

1. Introduction

The Renewed Programme for Government 2009/2010 aims to initiate a review of the Forestry Acts and programmes and states that this review is to reflect and include sustainable, social and environmental objectives. In our view the current review process splits these 3 objectives into distinct, narrowly defined areas instead of integrating them into a coherent, comprehensive review that is badly needed.

The terms of reference for the three forestry policy review groups are too narrow and specific to have any positive impact on the future of Forestry in Ireland. Forestry policy and legislation must be completely revamped and overhauled and not only focus on the areas and terms of reference as defined for the three review groups.

These are basically divided between environmental biodiversity and climate change pressures; funding of forestry schemes; and review of Coillte – instead of looking at creating a context for forestry to thrive in Ireland by prioritising ecological sustainability, resilience and biodiversity, which is in fact the only way to create long-term public wealth based on the natural wealth that sustainable use of our forests can provide.

Therefore we wish to express our disappointment at what we consider to be the inadequate scope of these reviews. Furthermore we feel the consultation period of three weeks for the public to participate is in itself unsustainable and a clear breach of the Aarhus convention.

We also take issue with some of the figures presented in the background paper called Irish Forestry Review. This paper claims a total State/Public owned forest area of 397,000ha, primarily managed by Coillte. In numerous Coillte publications they claim the forest estate to be comprised of 445,000ha. This shows 48,000ha of public forest land unaccounted for.

There are also wide discrepancies in employment figures between various publications making it impossible to ascertain the correct numbers of people employed in the forest industry. This hinders proper evaluation of the industry, e.g. the figure of 16,000 employed has been constantly quoted since the 1990's.

A review of the Forestry Acts has been ongoing for 18 years since the Forest Principles attached to the Rio declaration on the environment in 1992 created the new understanding of what constitutes SFM (Sustainable Forest Management). Despite an abundance of rhetoric surrounding the term SFM, the focus of the Irish Forestry Policy remains oriented towards the primacy of economic profit and timber production. The industry remains self regulated and reliant on guidelines to steer the forestry sector in Ireland, which is not how SFM should be implemented.

SustainableForest Management must place equal value on the Social, Environmental and Economic resources provided by multi-use, diverse species woodlands, with the emphasis on natural Native woodlands, which are characterised by a higher level of biodiversity – in terms of their genetic resources, species and habitat diversity – than any other terrestrial ecosystem. The IrishState’s current industrial forestry model with its reliance on exotic conifers needs to be completely overhauled.

If nothing is done to change the present unsustainable model and its dependency on 100 per cent grants, then Ireland will never achieve SFM. After twenty years of 100 % grants one would think that forestry could sustain itself, the reality is the sector remains incapable of being profitable/economically sustainable, which bodes ill for achieving social and environmental sustainability. Action must be taken now to ensure that future generations have a model that delivers a better quality of life and reaps the benefits of Sustainable Forest Management that is based on:

-Biodiversity enrichment,

-Natural regeneration of native woodlands,

-Water, air & soil protection,

-Community based local economies,

-Carbon sequestration,

-Quality hardwood market,

-Non-timber products.

Falling short of a complete overhaul and failure to address the issues will leave the Irish public burdened with paying into the future for the costs of polluted water and soil, loss of biodiversity, landslides, lack of rural economies and a dependence on fossil fuels, which are the documented consequences of the current model.

2. Context

Ireland's outdated Forestry Acts cannot deliver SFM or protection to what is left of our Native woodlands, and as such our EU and UN obligations instruct us to update our Forestry Acts in order to make them compatible with EU environment laws/forest policies. The acts have been under review since 1992 and one of the most problematic aspects is that the 1988 Forestry Act which established Coillte has a purely economic mandate to return a profit at any cost to the environment and local communities. All of our current forestry acts including 1946 and 1956 were created in the last century when there was very little value placed or understanding of our environment or social obligations.

“We, the undersigned, senior members of our world’s scientific community, hereby warn all humanity of what lies ahead. A great change in our stewardship of the earth and life on it is required if vast misery is to be avoided and our planet is not to be irretrievably

mutilated”.

This statement was signed by 58 of our world’s most prestigious scientific academies in 1993, at the Rio Earth Summit Convention on Biodiversity. The UN Rio Summit was a response to a new consciousness of ecology throughout the world and was endorsed by 170 nations including Ireland in addition to half of all living Nobel Laureates and 1600 leading scientists. Threats to our global home listed by the signatories included deforestation, loss of topsoil, acidification,

acid rain, shortages of water and loss of biodiversity, leading to and compounding climate change. These threats are compounded by global industrial forestry methods of the type carried out in Ireland.

Ireland’s natural environment is native tree cover- at 87,298 hectares (Higgins 2005), Ireland has by far the least natural environment in Europe (less than 1.1% of territory). The average ‘meaningfully protected’ landscape in the 26 O.E.C.D. countries is 7.7% of national territory- in 1997, Ireland had no territory protected as Scientific Reserves (I); Natural Monuments (III), or Protected Landscapes (V).

If natural plant succession (natural regeneration of woodlands) is the foundation of native biodiversity in Ireland, how well are we equipped to honour our endorsement of the 1993 Convention? Over the next twenty years (1996 Strategic Plan) the forestry sector is scheduled to increase to 17% of national territory i.e. a 2.5 fold increase. The Heritage Council (June 1999) expressed concern that Ireland’s landscape should not be overwhelmed through our ‘over dependence on non-native conifers’.

This target of 17% forest cover by 2030 means a minimum level of planting of approximately 20,000 hectares of each year for 20 years. This is a very crude target that is based on current practice, weaknesses and constraints. Ireland has the lowest tree cover in the EU. We believe the target could be accelerated and increased by focussing attention on creating a forestry, tree and woodland culture in Ireland, with the right incentives attached. This should incorporate the harnessing of natural regeneration (currently over-looked and shown to be successful through neglect and highlighted in the Millennium Woodlands audit by Fergal Molloy in 2007) as stated above.

From information submitted by the Irish Forest service to the UN Geneva timber & forest discussion papers (2003) on employment trends and prospects in the EU forest sector we get a figure of 12,651 employed in the year 2000 and 10,241 as the projected figure employed in 2010. A definitive figure is required to give a better picture of the employment situation.

For comparison, Switzerland, a country half the size of Ireland with a forested area of approx 1.2 million hectares equating to 33% of total land area and twice the size of the Irish forest estate.

Mainly due to the fact that the Swiss have a long established forest culture and tradition, they have over 120,000 people employed in their forest sector. Their forest policy involves no planting, clear-felling or use of chemicals, and a gradual removal of exotic species planted in the past. The Swiss voluntarily created an SFM forestry standard in 1997 to comply with their commitments to the Forest Principles agreed at Rio. They concluded the only way to truly achieve SFM was via natural regeneration of their native species and a close to nature management system based on coppicing, continuous cover, selective felling and mixed species & ages.

It would be wise, regarding Ireland's current plan to almost double it's forest estate by 2030, to examine the highly successful Swiss SFM model, which delivers social, environmental and economic value from it's forests which are mostly in public ownership, and are not reliant on grant aid. Swiss forests pay their way.

The Irish Forestry Contractors Association carry out most of the direct work in forestry, which is mainly through the use of machines. They are currently claiming severe hardship among their members and highlighting the failure of the sector, many of their members who bought harvesting machines at a very high cost are facing bankruptcy as the promised harvesting contracts to pay for their machines, have not materialised. We feel they should be assisted, compensated and re-trained as they were in effect given bad advice by Coillte leading them to become contractors in the first place.

The differences between present forestry practice and sustainable woodland management are listed below.

(Extract from Ben Laws book "The Woodland Way" a guide to sustainable woodland management in the 21st century)

Present forestry practice.

Trees are viewed as timber.

Industrial management-use of pesticides, fertilisers and large machinery.

All trees are of similar age.

Short length rotations.

Clear-fell is main management practice.

Monoculture plantations are favoured.

All forest is managed.

Timber is the only forest product.

Traditional forest knowledge is seen as outdated and ignored.

No sacred places or woodland celebration.

Economics based on short term monetary thinking model.

Forest workforce trained as timber harvesters.

Timber transported long distances.

Management plans drawn up after brief visit.

Forest designed around machinery operations.

Management has high capital investment (large machinery).

Sustainable woodland management

Trees are an integral part of a diverse ecosystem.

Sustainable management: no chemicals, small-scale machinery and biological resources (horses to extract).

Trees of all ages (seedlings to veterans).

Long rotations (leaving veterans).

Selective felling and coppice management.

Diversity is favoured.

Areas are left for their own evolution.

Woodland offers diversity of products, timber and non-timber, recreation,etc.

Encouragement of traditional knowledge, coppice woodmanship, craft-work, herbalists.

Woodland offers environment for celebration,contemplation and spiritual growth.

Economics based on long-term sustainability of the whole woodland eco-system, its diversity and multifunctional yield.

Woodland training through observation, traditional knowledge, and understanding of the whole ecosystem.

Timber and non-timber produce sold locally.

Management plans drawn up after long term observation through different seasons.

Woodland design based upon permaculture principles.

Management is people (labour) based and locally sourced.

3. Priorities

3.1. Biodiversity

"A forest is a society of living things the greatest of which is the tree."

(Richard St Barbe Baker, founder of the international tree foundation.)

We believe the following communication to be the guiding principle for the urgently needed reform of Irish forest policy and legislation. It is also very clear that EU forestry funding streams will reflect these priorities. The current EU green paper on the protective role of forests proposes legislation to ensure sustainable forest management throughout the union. It would be irresponsible to ignore the strong direction where EU forestry policy is inevitably heading.

EC communication to EU Parliament: Options for an EU vision and target for biodiversity beyond 2010:

From the introduction of this communication:

Biodiversity – the variety of ecosystems, species and genes – is the world’s natural capital. It is integral to sustainable development by providing vital goods and services, such as food, carbon sequestration, and seas and water regulation that underpin economic prosperity, social well-being and quality of life. Together with climate change, loss of biodiversity is the most critical global environmental threat and gives rise to substantial economic and welfare losses. European Environment Commissioner Janez Potocnik said Europe’s forests are a precious resource that must be protected against the harmful impacts of climate change and biodiversity loss.

The current forestry regime in Ireland is completely out of touch with what the EU requires, instead it narrowly focusses on using plantation forestry for economic recovery, growth and profit. Ireland in this review process should take cognisance of these trends that actually include the cost of biodiversity loss and build a forestry sector resilient to climate change impacts (and the associated costs of these) which can best be accomplished with native broadleaf tree species that are sustainably managed.

This review process should actively engage with the content of these debates. Forestry policy is now about responding to biodiversity loss and climate change. Immediate input and response from the current review process and review groups are required on this.

The value of native woodlands.

Below is a list of the number of insect species associated with our native tree species.

Oak 284 Willow 266 Birch 229

Hawthorn 149 Aspen 97 Scots Pine 91

Alder 90 Hazel 83 Rowan 28

Here is the comparison of two non-native trees.

Sycamore 15 Horse Chestnut 4

(D.A.N.I. 2000)

In a Woodland Trust publication of 2001 we discover that in one acre of native woodland there are:

Bacteria 4 tons

Fungi 1.5 tons

Field Plants 0.5 tons

Earthworms 500lbs

Protozoa 340lbs

Slugs and snails 90lbs

Spiders 50lbs

Beetles 9lbs

...and all busy building themselves from carbon and sustaining local biodiversity. Carbon sequestration is therefore inextricably linked to biodiversity enhancement. Native woodlands provide the foundation for native biodiversity and must be given consideration in any new forest policy.

Forestry Policy must focus on prioritised biodiversity actions & native broadleaf species.

Biodiversity actions:

  • First and foremost Forestry policy must prioritise protection, conservation and expansion of our existing native woodlands.
  • The expansion of Natura 2000 forestry sites on public and private lands.
  • Natural regeneration areas

Identify areas and pockets of land suitable for natural regeneration, fence off to protect from deer and let nature do its work. The UK Woodland Trust concluded that natural regeneration is the most desired and sustainable method to re-establish natural woodlands in the UK. By allowing for the natural succession of plant & tree species it ensures the highest level of biodiversity and it is also the most economical way to create natural woodlands. There is currently no emphasis or attention being paid to the benefits of this concept.

To date, no provision for natural expansion of old growth; secondary etc. native woodland exists in Ireland. George Peterken (internationally renowned natural & ancient woodland expert) recommends that “natural regeneration” is the foundation of biodiversity but coupled with his injunction for planting, to source and collect seeds “no further away than 10 miles” - i.e. indigenous soils and local provenance - lest we “damage nature conservation interests”.

  • Phase out the planting of non-native, monoculture plantations and introduce measures to mitigate their negative effects. By selective felling of coups within plantations and allowing the succession of native species through natural regeneration, these contaminated sites (the legacy of over-use of pesticides and fertilisers) can be re mediated naturally harnessing the trees extraordinary abilities.
  • Trees as shelterbelts
    The planting of a continuous shelterbelt along the west coast using native species (and non natives initially to get cover up and running) the seed of the native species most suited would be collected from salt resistant remnants of the ancient forests still to be found along our coast. This would act as a first line of defence against increased storms coming in from the Atlantic, trees act as tremendous wind barriers. This would help with stopping wind and salt damage to crops further inland and could be a component of agri-forestry as well as increasing the fertility of the surrounding land by building soil and protecting micro-organisms.
  • Riparian zones.

The repair of watercourses in existing forestry plantations is necessary and planting with suitable native species. Where conifers have been planted too close to watercourses, cut back, and replant as above creating riparian nature corridors, including increased forest cover over main groundwater reservoirs. Creation of swales and other measures to alleviate flooding.

3.2. Water & Soil Protection

“To protect your rivers- protect your mountains”