Review of Forest Policy Submission from the Irish Peatland Conservation Council 2010

Review of Forest Policy – Submission from the Irish Peatland Conservation Council 2010

Tadhg Ó Corcora, Conservation Officer

Dear Ms. Nolan,

The Irish Peatland Conservation Council (IPCC) welcome the above review and the opportunity to make a submission to you.

Background

It is an objective of Ireland's Peatland Conservation Action Plan 2020, the strategic policy document of the IPCC that all peatland resources in the country should be managed wisely. This document shows that forestry accounts for the loss of 19% of the original area of peatlands (1.2 million hectares) in the Republic of Ireland. In addition out of the 269,267ha of peatlands remaining in a near natural condition with high biodiversity values involving 736 individual sites, our analysis shows that 196 sites have been damaged or threatened by forestry (See Appendix 1). IPCC are campaigning to ensure that formerly afforested peatlands, particularly within an SAC or NHA or Local Biodiversity Area are felled and the priority habitat restored to favourable conservation status.

Equally strongly is our campaign to ensure that no intact areas of fen, raised bog or blanket bog are forested. The extensive losses of original peatland habitat to turbary and to mechanical peat extraction potentially presents a land bank of some 600,000ha throughout the whole of Ireland for which alternative uses need to be found. These may include forestry.

In the interests of securing a future for the rare peatland types occurring in Ireland, IPCC are campaigning to ensure that an adequate portion of the turbary and industrially cut peatland types are managed with wetland biodiversity being the priority.

We look forward to the publication of the results of the BOGLAND project funded by the EPA which seeks to develop a protocol for the sustainable management of peatland resources throughout the country. We would anticipate that there would be interesting best practice information in this document which you might consider before completing your review (see www.ucd.ie/bogland).

Afforestation of peatlands and inventories

The driver for the historical loss of 19% of the original area of peatland to forestry was based on the Government policy of large-scale afforestation. In the 1990's a target of 20,000ha of planting per year was set in the Strategic Plan for the development of the forest sector in Ireland. Ultimately the Government intends to plant 17% of the land area of Ireland by 2030 (Forest Service, 1996). To date, 218,850ha of blanket bog and 6,175ha of raised bog have been afforested. Approximately 80% of this is managed by Coillte, the state owned forestry company (Farrell and Renu-Wilson, 2008).

Since 1980 an estimated 86,000ha of peatlands has been planted on privately owned land. These schemes were funded under the Forest Service grant schemes. In meeting Government planting targets, the Forest Service administers a grant scheme to private individuals for forestry planting. The Forest Service does not have a specific policy in relation to peatland afforestation. Their policy in relation to peatlands, and other land types, is primarily concerned with their suitability for afforestation taking into consideration soil type, soil fertility, exposure, elevation, access, landscape and conservation status (P. Dunne, pers. comm. 2008). The Forest Service grant scheme is now the main source of afforestation on blanket bog. 4,000ha of peatland were afforested in 2006 under this scheme (Black et al, 2008).

·  Recommendation 1: While this scheme screens against designated sites and areas of deep peat, there are a growing number of locally important biodiversity sites that are threatened because they are not designated. These include intact peatland types and regenerating secondary habitats on cutover and cutaway bogs. For example in the IPCC Peatland 2020 Action Plan there are 147 peatland sites with no formal conservation status. In addition we would point out that the National Fen Survey of the NPWS is ongoing. Only Monaghan has been completed to date. The Forest Service needs to be aware of these emerging sources of new information. IPCC recommend that the same regulation and assessment process needs to be put in place for all peatlands of a conservation value regardless of their designated status. We cannot tolerate any further loss of important peatland biodiversity areas simply because they have not been designated.

Cutover & Cutaway bogs

Specific guidelines need to be put in place to regulate afforestation of areas of cutaway and cutover bog habitat. Cutaway refers to sites where there is no economic peat resource remaining (strictly industrial cut sites). Cutover refers to sites where there is an economic resource of peat present (includes industrial and hand cut sites). Cutaway and cutover bogs need to be reviewed on a case by case basis as biodiversity habitat potential varies from site to site. In this regard we would draw your attention to the Bord na Móna Biodiversity Action Plan for cutaway bogs (Farrell 2010). In addition we would highlight the IPCC survey of cutaway and cutover bogs (O’Connell & Foss 1999), which found important biodiversity areas naturally regenerating on abandoned cutover sites.

·  Recommendation 2: In considering future funding of forestry on cutover and cutaway bogs the first priority should be an assessment of the potential of a given area to revert to its natural environment with or without restoration techniques.

·  Recommendation 3: In considering future funding of forestry on cutover and cutaway bogs another priority should be an assessment of their potential for flood control within river catchments.

Peatlands as carbon sinks

In their natural state peatlands act as long-term sinks for atmospheric carbon dioxide. A persistently high water table is necessary for this function. Peatlands are the most important long-term carbon store in the terrestrial biosphere. They sequester and store atmospheric carbon for thousands of years (Charman et al, 2008). The peatlands in the northern hemisphere alone store approximately 450 billion tonnes of carbon (Gorham, 1991). Undisturbed peatlands accumulate carbon from the air at a rate of up to 0.7 tonnes per hectare per year (Pearce, 1994).

The Wildlife Trusts in the UK have estimated that a 2m deep peatland stores 8,000 tonnes of carbon per hectare. Blanket bogs and fens in general are likely to hold lower carbon stores than deep, intact raised bogs. This highlights the need to halt the replanting of forestry on Raised bogs where the potential is there to restore the area to its natural environment. This would require providing a facility where waivers on the replanting of afforested land following harvesting are made available to land owners on raised bog sites. The same waiver needs to be available to land owners of all peatland sites of conservation worth.

In Ireland, peatlands are estimated to store 1085 Mega tonnes (Mt) of carbon, this corresponds to 53% of all soil carbon stored in the island of Ireland on just 16% of the land area (Tomlinson, 2005). Restoration of afforested peatlands can aid in increasing this figure as well as Ireland’s influence in slowing climate change.

·  Recommendation 4: When decisions are being made on the future of currently afforested peatland sites IPCC would recommend that a Carbon Audit be carried out to assess the sites’ potential for the sequestration of CO2. Should the finding be that the site needs to be restored a waiver on the obligation to replant would need to be available. This would involve a change to the 1946 Forestry Act.

The Forestry Act 1946

Realising peatland conservation goals under EU and national legislation requires in some instances a waiver on the need to replant sites.

·  Recommendation 5: Ensure that in the revision of the 1976 Forestry Act, the obligation to replant on afforested peatlands is waived.

COILLTE

Coillte Teoranta is responsible for managing over 58% of Irish forests. Coillte is the largest landowner in the country with an estate of over 445,000ha (6% of the land area of Ireland). In the regulation of Coillte IPCC would draw your attention to the following issues and our recommendations.

·  Nature conservation is a stated aim of the company as outlined in their nature conservation programme. IPCC understands that the company manage 15% of their land holding in each of their 36 Forest Management Units. Our analysis of the designation status of their land holding shows the following: 20,000ha is NHA habitat, 14,000ha of cSAC habitat and 3,750ha of SPA habitat (Malone & O’Connell 2009). This accounts for 8.5% of their land area. We understand that the company completed an inventory of the nature conservation potential of land in each FMU by 2005 with a view to designating 15% for biodiversity conservation. This work was undertaken without consultation with the National Parks and Wildlife Service. The results are not in the public domain.

·  IPCC would recommend that the company publish specific information on the sites they are managing for biodiversity within each FMU. Information on how these sites are being managed/monitored is needed, while public consultation in creating management/action plans for these sites would be of great benefit to include formal arrangements with the National Parks & Wildlife Service.

·  In relation ot sites restored under the LIFE EU programmes there is a need for Coillte to make management plans available on the future of these sites which will involve the ongoing restoration/monitoring of the peatland priority habitats at the expense of the company.

·  Outside of the 15% land area designated for biodiversity IPCC are aware that Coillte own substantial areas of intact peatlands. We are anxious that peatland sites owned by Coillte that are currently not designated should not be afforested in the future. Without an inventory of their land holding and its status how can their activities be screened?

·  In planning for future uses of their land Coillte should address the Irish Standard for Forest Management which is being developed by FSC and is due to be published shortly as well as the BOGLAND report detailed above. IPCC would highlight the need for after-use plans for peatlands which are currently forested.

·  Other alternative commercial projects are now being undertaken by Coillte. IPCC stress the need for proper regulation of these projects. We would highlight in particular the need for proper planning of windfarms on peatlands. Previous windfarm developments have resulted in bog bursts (e.g. Drumskieran, Co. Leitrim). Outside of bog bursts the main damaging activities to blanket bogs from the construction of wind farms include the construction of an associated road network across the peatland, service structures, drainage, soil conduits for power cables, turbine foundations and electricity pylons (Malone & O’Connell 2009). The construction of a new road network opens the peatland up for a range of damaging activities such as dumping of household waste, accidental fires, peat extraction or placement of grazing stock (Anonymous, 2006).

Conclusion

Forestry in the wider countryside needs to be planned with biodiversity conservation, climate change and economic returns in mind. All commercial and private afforestation schemes should comply with the Forest Stewardship Council (FSC) forest certification process until such time as the Irish Forest Certification Initiative (IFCI) is completed. This aims to promote environmentally, socially and economically sustainable forest management.

IPCC's sites database shows that of 736 conservation worthy peatlands, 196 sites have been partially afforested. 28 sites have been restored by Coillte to date with financial assistance from the EU Life funds. As afforestation has serious impacts on peatland hydrology, carbon function, species composition and nutrient status, restoration of all affected sites of conservation concern in Coillte's ownership and privately owned should be a priority.

It should be noted that surveying of Irelands peatlands has not been completed and it must be ensured that extensive habitat mapping is carried out in any location proposed for afforestation.

References

Anonymous (2006). Assesment, Monitoring and Reporting under Article 17 of the Habitats Directive. The National Parks and Wildlife Service, Department of Environment, Heritage and Local Government, Dublin

Black, K., Gallagher, G., O Brien, P. Redmond, J., Barrett, F. & Twomey, M. (2008). (in review) Peatland afforestation in Ireland: dispelling a rural myth. Submitted to Irish Forestry

Charman, D., Joosten, H., Laine, J., Lee, D., Minayeva, T., Opdam, S., Parish, F., Silvius, M., & Sirin, A. (2008). Assessment on Peatlands, Biodiversity, and Climate Change. Global Environment Centre and Wetlands International.

Farell, C. (2010). (in review) Bord na Mona Biodiversity Action Plan 2010 – 2015, ‘Cutaway bogs for biodiversity: wetlands, woodlands and peatlands of the future’

Farrell, E.P. & Renou-Wilson, F. (2008). A New Paradigm for Irish Peatland Afforestation. In: Farrell, C. & Feehan, J. (eds.), Proceedings of the 13th International Peat Congress

Forest Service (1996). Growing for the future – A Strategic Plan for the Development of the Forest Sector in Ireland. Forest Service, Department of Marine and Natural resources, Dublin

Gorham, E. (1991). Northern peatlands: Role in the carbon cycle and probable responses to climate warming. Ecological Applications

Malone, S. & O’Connell, C. (2009). Ireland’s Peatland Conservation Action Plan. Irish Peatland Conservation Council, Lullymore, Rathangan, Co. Kildare

O’Connell, C. & Foss, P. (1999). A survey of Cutover and Cutaway Bogs Habitats of the Irish midlands. Irish Peatland Conservation Council, Dublin

Pearce, F. (1994). Peat Bogs hold the bulk of the Britain’s carbon. New Scientist: 6

Tomlinson, T. W. (2005). Soil carbon stocks and changes in the Republic of Ireland. In: Journal of Environmental Management. 76. 77 - 93