Dr Declan little
Project Manager
Woodlands of Ireland
Seismograph House
Rathfarnham
Dublin 14
30th March, 2010
Submission on Forestry Review
On behalf of Woodlands of Ireland (WoI) I am making the following submission re the above under each of the headings outlined in the terms of reference of the National Forestry Policy Review group. As WoI is primarily concerned with the management and expansion of native woodlands, emphasis is placed on the native woodland sector. Within the remit of the National Forestry Policy Review group the following is relevant:
1. the level of afforestation, taking into account its contribution to rural development and employment generation, the funding of the afforestation programme, and the provision of public goods and services, including climate change mitigation.
WoI has worked very closely with the Forest Service and other key stakeholders in the development and implementation of the Native Woodland Scheme. This scheme has cross-sectoral support from the National Parks and Wildlife Service, Heritage Council, the private and NGO sectors and helps to addresses broader national policy objectives other than those concerned with forestry alone, i.e. obligations under the Convention of Biological Diversity, the Habitats Directive, National Biodiversity Plan, etc., as well as SFM, the Helsinki Process, the Code of Best Forest Practise and other international and national conventions. The scheme provides value for money and has enormous potential to address all these policy goals as well as all the criteria listed under item 1 above, but only;
(1) through the provision of adequate funding on a continuous basis. Stop start funding experienced to date undermines public confidence and results in the loss of valuable expertise in the planning and contractor sectors engaged with this specialised sector.
(2) via the management of existing native woodlands (Element 1) biodiversity protection and enhancement is addressed, whilst in recent years a focus on the production of quality native hardwoods is seen as a means not only of generating revenue for owners after the scheme premiums have ceased, but also of providing much-needed income that can be reinvested in their woodlands to protect and enhance biodiversity values, as well as pursuing quality hardwood objectives.
(3) by expanding native woodland cover under Element 2 which also addresses wood production under continuous cover systems (CCF) and also has applications in protecting water quality (riparian woodlands), connectivity and woodland biodiversity expansion. Climate change mitigation through carbon sequestration and the regulation of instream water temperatures are deliverables under this measure.
(4) WoI estimates that on average, a budget for 1000 ha is required for Element 1 and 1500 ha for Element 2 in order to meet demand annually. Jobs would be a spin-off of commercial hardwood production in this sector, i.e. joinery work, carpentry, craft development, coppice work, etc.
2. species composition and structure of the forest estate, taking into account sustainability and competitiveness in wood supply, and the conservation of indigenous biodiversity and tree species
WoI is of the view that though species composition has diversified greatly in recent years, more focus is required to;
(1) diversify species for commercial quality wood production objectives whilst at the same time maintaining and enhancing environmental goals, i.e. biodiversity enhancement and expansion, protection of soil and water, etc. This helps to make forestry more sustainable, providing better value to the taxpayer vis a vis grant aid. There are adequate markets and processing facilities for low quality softwood material and a greater emphasis is needed for the production of higher quality softwood and hardwood logs. To this end matching appropriate trees to prevailing soil and environmental conditions is a pre-requisite to attaining these goals. It also requires ongoing, good management practise, including thinning, shaping, weeding, etc. long after the initial capital grant has been spent and premiums are exhausted.
(2) practically combine commercial and environmental planting schemes. This could be progressed through current afforestation schemes where an applicant may, for example, apply the NWS Element 2 in conjunction with commercial conifer and broadleaf packages, i.e. NWS El. 2 compartments adjacent to streams, rivers, old woodland or scrub. Sustainability of native woodland re wood production can be met if wood production is given equal priority to conservation goals. This would mean that the production of quality native hardwood under a CCF silvicultural approach would be pursued without compromising the biodiversity objectives. It would also expand indigenous biodiversity and tree/woodland species of local provenance.
(3) to address the rising deer population nationally which is increasingly compromising the sustainability of the forest resource. Future quality hardwood and softwood production is in serious doubt unless a national deer management strategy is implemented. Woodlands of Ireland commissioned a report on the issue last year and one of the preferred options to manage the deer herd is via a statutory body (like the Deer Commission in Scotland) which would have the authority to implement the necessary measures. Training for forest managers re forest design and practise vis a vis deer ecology and behaviour is a vital component of this strategy as well as controlling the size of the deer herd via culling and other measures. As the statutory agency responsible for forestry, the Forest Service is urged to lead on achieving solutions to this problem.
(4) expanding existing old woodland stands through afforestation to create large and well-forested landscapes. Applied to native hardwoods, such a policy would create larger areas of native woodlands which would benefit biodiversity and improve water quality. It would also contribute to Ireland’s obligations under the Habitats Directive to expand the area of Annexed habitats, especially oak woodland and alluvial woodland.
3. future roundwood supply and demand and
a. its ability to meet national bio-energy targets;
b. its ability to meet raw material demand for wood product manufacture (including locally based enterprises).
c. investment in forest roads and other infrastructure to mobilise the supply.
(1) WoI believes a feasibility study to assess the requirements of the hardwood production sector and markets for produce are urgently required. This would include assessing what hardwood is currently in the woodland estate, its management requirements, the capacity of sawmills to utilise the resource and the development of downstream value-added products.
(2) Silvicultural systems other than clearfell require more attention and commitment; active management employing CCF and coppice silvicultural systems in pursuit of quality production should be investigated as these have the potential to produce considerable volumes of low grade/quality hardwood suitable for the bio-energy market, including locally-produced fuel/firewood).
(3) The demand for appropriately seasoned hardwood fuel wood is increasing as wood burning stoves are becoming more widely used. This should stimulate the economics of thinning broadleaved woodlands. However, emphasis on developing a standard for marketable firewood is recommended which would address criteria such as maximum moisture content and branding.
4. research and development, and innovation in the forestry sector
(1) Further R&D of local provenance native tree species is required in order to ensure adequate future stocks of planting material. Common alder is a good example where considerable research is required. (2) Research of performance and management over the rotation of hardwood crops would help develop management guidelines in future and help achieve value for money re grant aid in this area. A research component to assess wood production and biodiversity goals is required in NWS projects that have been rolled out.
(3) The development of downstream value-added hardwood products requires marketing and research.
(4) Acid sensitive areas where afforestation is currently restricted and/or subject to testing have considerable potential for environmental, low density planting under NWS and FEPS. Preliminary negotiations with the EPA should be advanced further to pilot this initiative with a view to expanding afforestation in these areas.
5. standards, guidelines and monitoring.
(1) Forestry standards have improved considerably in recent years with Forest Service guidelines, the Code of Best Forest Practice and legislation in related areas such as planning. WoI recommends the implementation of the proposed new Forestry Act as soon as possible - it is long overdue – as it will enhance the sector further.
(2) The reafforestation of upland areas with Yield Class 14 or lower status should be addressed under the new Forestry Act as currently the reforestation clause under the current Act generally applies. Such sites are often on peats, often sloping and generally environmentally and economically unsustainable. Other options should be available for these sites at the end of the current rotation.
(3) Monitoring of a pilot area afforested under NWS and FEPS is recommended to assess the impact of related operations in achieving woodland cover. Monitoring of biodiversity changes as a result of management under the NWS would provide useful data on the effectiveness of management and provide value for money hard data.
(4) A review of the current suite of Forest Service guidelines is required to take on board recent research results and legislative changes, if applicable.
Regarding the remit of the Forestry Schemes Review Group the following is relevant:
o Examine the extent to which Forestry Scheme's objectives have been achieved to date, and comment on the effectiveness with which they have been achieved
(1) WoI is most familiar with the NWS and believes that initial targets were almost certainly over-ambitious, though not helped by stop-start funding. However as it is a relatively new scheme this was to be expected. Since 2000, the Forest Service and WoI have conducted annual native woodland scheme training courses which will continue as the scheme continues to be rolled out. This training is targeted at Forest Service Inspectors, NPWS personnel, scheme applicants and practitioners. Training will assist in the implementation of this scheme more effectively in future as well as being a means to accrediting practitioners involved in its implementation, i.e. foresters and ecologists. To date, approximately 700 people have attended these courses. It is essential that future training needs are met.
(2) Future funding streams re the NWS should re-engage the state sector, i.e. NPWS and Coillte in particular, as there is good woodland management experience in this sector as well as many good quality conservation native woodlands under state care that require urgent management.
(3) Regarding the Woodland Improvement Scheme WoI believes this scheme has considerable potential in bringing woodlands, especially old broadleaf woodlands, into production but is underutilised and almost certainly does not nearly reach its targets. This scheme requires a technical support group (similar to that which exists for the NWS) chaired by the Forest Service. Premium payments are necessary and/or the restructuring of this package altogether to make it attractive to applicants.
o Evaluate the degree to which the objectives warrant the allocation of public funding on a current and ongoing basis and examine the scope for alternative policy or organisational approaches to achieving these objectives including:
§ appropriate tax incentives;
§ examining the level of grants and premiums, given the overall fall in costs in the economy
§ private sector investment being leveraged in afforestation through public-private partnerships involving pension fund and/or other investment vehicles.
(1) Since WoI provides technical support and training to the Forest Service vis a vis the implementation of the NWS, it is our view that WoI should be a member of the Forestry Liaison Group (FLG). As a non-statutory partnership umbrella organisation representing many diverse interest groups and native woodland stakeholders, WoI can represent the views of a wide cross section of the general public, as well as providing technical support and assistance regarding policy objectives. One issue that WoI would bring to the attention of the FLG is that the resource and expertise built up gradually in recent years to support the development and implementation of the NWS is very specialised and valuable, i.e. foresters, ecologists and contractors, and would be very difficult to rebuild quickly if the NWS was seriously under-funded or dispensed with and later re-launched with adequate funds.
(2) As the NWS is central to Irelands national and International policy objectives vis a vis biodiversity, climate change and SFM, yet does not currently focus on a financial return as a primary objective, it will require public funds on an ongoing basis. WoI believe an indicative budget of between €1.5 and €2.5 million/annum is required to implement the NWS adequately.
With respect to the Coillte Review Group the following is relevant:
1. Business Areas- forest management from afforestation through to log production, panel production, land use and renewable energy;
(1) WoI believe that there is considerable scope for Coillte to produce quality hardwoods. More focus on the establishment and management of broadleaf woodlands for timber production is required in the national interest. It would also help to supply the Dundrum sawmill which processes hardwood, thereby making it more viable in the future.
(2) A hardwood strategy should link silviculture, processing (i.e. the Dundrum mill) and marketing opportunities in the pursuit of a successful outcome. Short term financial goals should not compromise medium and long term objectives inherent in hardwood production. A focus on the shorter rotation hardwoods such as ash, sycamore, cherry, birch and alder is the preferred option in order to generate returns on a more viable basis (compared to oak and beech).
2. Public Goods- climate change mitigation, recreation and protection of the environment, biodiversity, landscape, water resources and heritage;
(1) WoI is a partner with Coillte in the People’s Millennium Forests Project (PMF) and has been closely involved in the conception and implementation of the project. WoI believe that the draft Memorandum of Understanding (MoU) drawn up for the Project Management Boards consideration should be ratified and signed off as soon as possible. The MoU effectively confers the responsibility of managing the PMF sites on Coillte whilst doing so for the people of Ireland, primarily to meet biodiversity goals and outside Coillte’s normal commercial business. Therefore the sites would be held in trust for the general public under Coillte control. The MoU ensures that if Coillte was ever privatised that the PMF sites would not be sold off as part of that process.