IFFPA Submission Re to the Public Consultation on the Environmental Requirements For
IFFPA submission re to the public consultation on the “Environmental Requirements for Afforestation” based on the consultation document provided by the Forest Service
1.Overview
IFFPA broadly welcomes the updating and formalisation of the extensive suite of environmental guidelines that currently exist and sees merit in bringing together these guidelines under one master document.
However, IFFPA would like to stress that the current suite of guidelines is working well and the there are no major environmental problems currently arising from the afforestation programme. Therefore, there is no need to introduce a large number of new requirements and measures. These will impact on the afforestation programme. It is clear from the experience of IFFPA foresters in the field, that reduced planted areas are a major disincentive to the landowner going into forestry.
IFFPA welcomes the attempt to clearly define all relevant setbacks but would bring to your attention the fact that setbacks are currently being discussed within the FS Technical Working Group (TWG).
IFFPA acknowledge that this work is also an attempt to bring more clarity to the sector by documenting how it should address all environmental issues, thus avoiding ambiguity within the sector or between the sector and Forest Service inspectors.
IFFPA, however, do have some major concerns with this document and feel that some of the measures and setbacks proposed are too extensive and are an overreaction to the minimal number of environmental issues that arise whilst delivering the afforestation program.
In particular,IFFPA does not see the need, as proposed in this document, to increase setbacks from archaeological sites and water courses or to redefine what constitutes a relevant water course.
Current setbacks and the current definition of water courses have proven to be more than adequate and IFFPA strongly believes that the current guidelines in conjunction with information and training days are more than sufficient to address any environmental concerns that may arise in delivering the afforestation program.
If the recommendations made in this document are implemented there will be, inter alia:
- A significant rise in the percentage of biodiversity across a large number of sites. This will lead to biodiversity levels that exceed 15% and, where this occurs, land within the forest boundary will become“redundant” in that it will not be eligible to receive neither grant nor premium. This in turn will disaffect land owns who propose to plant and will lead to their deciding not to plant land. It will also make the acquisition of land for forest investment more difficult. Investors will pay for productive ground only and will not pay for land they will be required to leave as redundant due to excessive biodiversity requirements.
We have looked at the impacts of increasing biodiversity levels past 15%. The losses at a local and national level are significant with losses to both rural incomes and timber production. See Appendix 1 ‘Biodiversity cost to landowner’.
- A significant rise in the costs of developing, supervising and managing afforestation projects due to the need to increase the level of site supervision during development and due to the increased level of inputs required by experts such asecologists, hydrologists, etc.
- An increase in the number of proposed afforestation sites being rejected at the time ofinitial site inspection primarily due to the fact that development costs will become too high or because land owners will reject the afforestation proposal due to excess biodiversity and the resultant “redundant land”.
(It is important to note that IFFPA is not anti-biodiversity but simply feel that landowners who offer up their land, permanently, to forestry and biodiversity should be compensated for same)
- IFFPA believes that parts of the document still need to be more prescriptive and less subjective. Much more clarity and specificity is needed in the document. Without it, foresters and inspectors will spend endless hours looking into shallow field drains and debating whether or not they carry water following significant rainfall and, thus, whether or not they are water courses or drains.
- A significant decrease in the commerciality of each plantation because the proposals will lead to additional biodiversity and increased broadleaf planting. It is worth pointing out that for every acre of ground left unplanted when biodiversity levels exceed 15% of the total site area, the landowner is not only required to forgo premium but will alsolose the return from timber production.
- The increased level of form 3 exposure IPFFPA members will experience is unacceptable. With the planting of more broadleaves, and particularly the planting of broadleaves in “strips”, there will be an increase in deer damage, wind and exposure damage and failure rates. This will create problems at form 3 stage with payments being held back due to the condition of strips of broadleaves planted along aquatic zones and road setbacks.
IFFPA believes that these new environmental requirements, as documented, will make the decision to plant more difficult and make planting operations themselves more difficult. This is surely at variance with the stated objectives of the Forest Service and with government policy to increase afforestation levels.
It is hugely important that we do not implement changes that would damage the already precarious position of our afforestation programme.
The current guidelines are effective and robust and improvements can be made through specific training days. Whilst IFFPA understands the need to amalgamate the guidelines under one document, it does not see the need to adjust and increase the burden of these guidelines.
2.Areas ofSpecific Concern
Page 5 (namely Native Woodland Establishment in certain water sensitive catchments)
The requirement to include GPC 9 & 10 of plot width adjoining the water setback raises the following issues of concern both to IFFPA and within the wider forest industry:
- Loss of productive forest area and the resultant loss of softwood saw logcurrently required to supply the commercial sawmilling sector.
- Planting such areas (strips) without adequate deer protection will lead to establishment difficulties. This will lead to difficulties with form 2 & form 3 inspections.
- It is not clearly stated that such areas (strips) are not mandatory where 10% of the site is already planted with broadleaves. It is important to make clear that there is no obligation to exceed the 10% broadleaf requirement per site (site suitability allowing) with such areas (strips).
Page 10 2.4 Water(namely the new definition of Relevant Watercourses)A NEW MEASURE
IFFPA has a major concern with the new definition of relevant watercourses. The inclusion of artificial watercourses, drains and channels and other potential pathways that “may only contain flowing water during and immediately after rainfall” isexcessive and will lead to practical problems on the ground whilst developing sites.
If such a broad range of “drains and channels” are considered to be aquatic zones then the setback conditions as documented in these guidelines must be imposed on all of these drains and channels.
It should be noted that to effectively drain afforestation sites, particularly on wet mineral sites,one needs to be able to utilize bothfield and arterial drains.
Field drains are predominantly mound drains whilst arterial drainage are the drains that have been excavated along ditches and hedgerows and de facto arethe system of drains and channels that carry water at intervals throughout the year and definitely post rain fall. This is their primary function and of course the reason why they were dug in the first place.
The proposed definition of relevant water courses now creates a serious dilemma in that what we have always considered to be an arterial drain now becomesa relevant watercourses and setbacks will be required from these water courses with the field drainage system no longer having the ability to directly access these arterial drains.
This will in turn lead to a serious “lack of connectivity” between the old field andarterial drains.
In effect, what is going to happen on the ground is the creation of a large number of individual drainage systems with no connectivity between fields and no overarching arterial drainage system removing water, in a controlled manner, from the site.
This will lead to blockages in field drains, to the building up of “wet spots” in sites which will not be evident until they createcreeping wind blow in crops or until harvesting equipment gets “bogged” in these wet spots.
This overzealous approach to defining an appropriate water course and the resultant excessive setbacks will de facto lead to an excess of bio on sites.
One cannot make the blanket assumption that across all sites you can forgo hedgerow biodiversity in favour of increased biodiversity along watercourses through increased setbacks. IFFPA does not accept the point that increased biodiversity along water courses will be countered by decreasing the levels of biodiversity provided along hedgerows. Will Bird Watch Ireland agree with the current Forest Service thinking on this point when they see nesting and hedgerow enhancement as essential?
Inevitably, what will happen in practise is that the combined biodiversity levels will push up past 15% of the total site area which will lead to redundant or unpaid areas within sites thus frustrating land owners.
IFFPA suggests that newmeasures should be focused where the flow of water from current field and arterial drainage systems approaches what is currently defined as awater course (marked by an arrow on a 6-inch map) and that any new measures should be focused in the buffer zones as currently defined. For example, increasing the numbers of silt traps and effectively managing the buffer zones as they currently exist should be sufficient.
Improvements can also be made by putting practical measures in place to slow down the flow of water within any site.
In summary, the current guidelines and the current definition of a water course is sufficient. Relevant training should be provided to all registered foresters.
Page 11 2.4.3 Crossing aquatic zonesA NEW MEASURE
IFFPA points out that the possible need for bridges and culverts to cross water courses would constitute a new measure and the requirement to build a culvert or bridge will add significant cost to any afforestation project.
Furthermore, the document suggests that bridges and culverts should be constructed between May and September, months when no afforestation work takes place.
The document focuses on the occasions where one has to build a bridge/culvert and only mentions at the end of the relevant section that “various options are available to create temporary crossings”.
In practice, temporary crossings will prevail and examples should be provided.
Page 13 2.5.1 ABE’s and subsequent tables 3, 4, 5 and 6
Within the document, it is proposed to increase the setback widths from aquatic zones and from archaeological features.
IFFPA insists that the current setbacks are sufficient and that the sector does not need to increase setback widths.
If increased, the percentage of biodiversity within a significant number of sites will jump past the 15% level.This will lead to applications which will contain “redundant ground” i.e. ground that is not eligible to receive grant or premium payments. This in turn could create Basis Payment issues for this land.
Excessive biodiversity requirements and redundant land will lead to difficulties with land owners who will feel that they are committing their land to a long term land use change and that they should be compensated for their land for the first 15 years at least.
It is important to remember that increasing the areas of biodiversity above 15% will also lead to reduced commerciality and to reduced productive area. Therefore, if the landowner foregoes future timber revenue, they should not they be penalised at a premium level as well.
It is further suggested that Annex 1 habitats could be considered as ABE.
Page 29 2.10 Further Environmental Assessment and rising COSTS
The document in general pushes responsibility onto the registered forester to ensure that no breech of environmental guidelines happens during the development of sites.
The document also outlines the increasing need for further consultation pre-submission of form 1’s and suggests that inputs from hydrologists, ecologists plus others will be required.
The document specifically refers to mammals, amphibians, reptiles or invertebrate species protected under the Wildlife Act.
Given the current population of deer, hares, foxes and badgers, IFFPA can see a situation where objectors to afforestation projects (now easily done with the appearance of site notices) will comment that the proposed afforestation site contains for example deer, a protected species under the Wildlife Act. Will the Forest Service Simply note this comment on the file or will it request the inputs of an appropriate expert?
These additional inputs from experts will lead to large additional costs.The Forest Service needs to consider how it will handle such objections.
This also raises the point that the appeals system is not functioning well. In the absence of an efficient appeals system, forestry companies are left in a predicament if the Forest Service suggests remedial works.
With regard to referrals to relevant experts such as a hydrologist, it is too often used as the default position by inspectors. The inspector should have to provide more significant justification for referral to an expert in each case.
IFFPA insists that the increased costs of carrying out afforestation projects, especially where additional expertise must be provided, should be reflected in increased levels of afforestation grants.
Regarding landscape architects, in the past, a landscape plan and photo montage was sufficient to be provided by the registered forester. Many registered foresters have attended week long course on Upland Forest Design delivered by Simon Bell, of The Forestry Commission. A registered forester who should be sufficient to provide this information.
Page 30 3.2 Recording site visitsA NEW MEASURE
Is the recording of site visits a recommendation or a requirement? Will service providers be asked to forward dates of their site visit with their Form 2 submissions?
Page 31 3.4 ContingencyA NEW MEASURE
The document provides a sample “contingency sheet” to be completed where relevant and made available on site.
This is close to a hazard or risk assessment document and needs to be updated in real time for example for high rainfall events or for incidents that may occur on site.
Is this a recommendation or an obligation?
Processing and updating contingency field reports would add enormously to costs and requires foresters to be on site more regularly. This is not practical and is too costly.
Page 32 3.5.1 Implementing set backs
The document proposes to increase setbacks from water courses and from archaeological sites and features.
As well as increasing the percentage of biodiversity and open space above and beyond the 15% level, increasing open space on a site will improve site conditions for deer grazing and browsing.
The proposals contained within this document make forest sites more amenable and more favourable to deer yet these proposed changes are not madein conjunction with an effective deer control policy.
Increased deer populations will lead to increased costs making more sites economically unviable to develop.
Page 33 3.5.2 Forest Edge Treatment
The document proposes that broadleaf planting is required around setbacks from dwelling houses and from public roads.This broadleaf planting is to take place in a 10m strip which is to be planted “behind” the relevant setback.This requirement does not take into consideration the overall % of broadleaves planted on the site.
For example, if there is NWS planting i.e. GPC 9 and 10 along a water course and possibly a broadleaf plot planted within the site,then the additional requirement to plant broadleaf strips along setbacks will drive the percentage of broadleaves planted on sites up past 10%.
IFFPA advises that increasing the level of broadleaf planting particularly in strips will lead to deer damage and Form 3 issues.
IFFPA recommends that if the level of broadleaf planting in plots or along aquatic zones already equals or exceeds 10% of the site area, further strip planting of broadleaves should not be required.
Page 35 3.7.1 Drainage and Cultivation
IFFPA members would bring to the attention of the Forest Service that “inverted mounding” can only take place in a small number of sites and inverted mounding on sites with higher water tables will not lead to satisfactory crop establishment.
The document also advises that “on site works should cease” during periods of HEAVY RAINFALL.This terminology is subjective and requires an almost constant presence on site.