RE: Consultation Process - Draft Environmental Requirements for Afforestation
RE: Consultation Process - Draft Environmental Requirements for Afforestation
To Anthony Dowd, Forest Service,
The Draft Consultation Document “Environmental Requirements for Afforestation” is welcomed given the proposed environmental protection measures in relation tonew commercial forest plantations and the Native Woodland scheme. They cover a large range of activities in terms of water, biodiversity, archaeology and landscape. The EPA has the following comments and recommendations:
(1)Sites with > 0.5m Peat
The Environmental Requirements for Afforestation draft document refers to the Forestry Programme 2014 – 2020 which states that “sites proposed for afforestation where significant areas have peat depths > 0.5m will require additional information and assessment”.
Thesesites are not listed as being suitable for afforestation in the Land Types for Afforestation Draft Consultation document (2016). The Grant and Premium Category 1 which covers unenclosedland, states that suitable sites should be of moderate fertility, and have < 50cm of peat. Similarly, the Rural Development Regulation (Regulation (EU) 1305/2013) states that new developments shall “avoid the inappropriate afforestation of sensitive habitats such as peat land and wetlands”.
It needs to be clarified if sites with >0.5m peat are still considered to be suitable for planting as per the 2015 Forestry Programme or are they no longer considered a suitable, as per the 2016 Land Types for Afforestation Draft.
(2)Fertiliser Application
The Land Types for Afforestation Working document (2016) states a productivity requirement of a minimum yield class of ≥14 based on one standard applicationofphosphorus at establishment. The Forestry Standards Manual (2015) allows a split application of Phosphorus on peat soils. Clarification is required as to whether a split application is considered to be “one standard application...at establishment” as per the Land Types for Afforestationdocument?
The split application comes with an increase in the allowance from 350 kg/ha Granual Rock Phosphate in a single application to 400kg/ha GRP in a split application.The EPA are concerned with the increased application for sites in GPC 1, R+N scores 5-5.3. Such sites are at the very edge of suitablility and are likely to be in sensitive areas where naturally oligotrophic water courses are vulnerable to enrichment and may be disporportionalty impacted by a small increase in phosphorus concentrations.
(3)Reafforesation
The Forestry Service Programme states “all afforestation will require replanting after clear fell”. There were an estimated 200,000 ha of coniferous plantations on peat in the West of Ireland (Farrell, 1990) and the 2014 – 2020 Forestry Programme acknowledges that these “afforested sites have sensitive ecological aspects and many forestry plantations pre-date any legal requirement for environmental assessment”. The accumulated scientific evidence indicates that planting and clear-felling on these sensitive peat catchments has an overall detrimental effect on freshwater ecosystems, even while following Good Management Practices (Rodgers et al. 2012a, Rodgers et al. 2012b, O’Driscollet al. 2014, Finnegan et al 2014). It is also unclear if these sites where clearfellinghas or is likely to take place, would meet the minimum yield classset out inLand Types for Afforestation Working document. The EPA recommends that the remit of the Environmental Requirements be expanded to include reforestation activities thereby enhancing the environmental benefits of the document and that the same economic and environmental principles for afforestation would apply to reafforestation.
(4)Freshwater Pearl Mussel Plan
The EPA recommends that the Environmental RequirementsforAfforestation are compatible with and reflect the Forestry and Freshwater Pearl Mussel Planin preparation. The DAFM are preparing the Forestry and Freshwater Pearl Mussel Plan which intends to ensure the protection of priority FPM catchments and will also be applicable to FPM catchments outside of the priority catchments. This is to reflect their protected status in their own right regardless of whether in a priority catchment or not.
(5)WFD 2ndCycle of River Basin Management Planning
The characterisation work currently being undertaken by the EPA under the Water Framework Directive is identifying areas where afforestation appears to be a significant pressure that would need to be addressed. Further investigative assessment and appropriate action in specific locations will be required over the period of operation of the next river basin management plan to achieve improvements in environmental performance. The EPA suggest that this work will inform the future environmental requirements for afforestation and reforestation. The environmental requirements for afforestation should take account of this and reflect that need to consider future new knowledge as it is developed.
References cited.
Farrell, E.P., (1990) Peatland Forestry in the Republic of Ireland. In: Biomass Production and Element Fluxes in Forested Peatland Ecosystems. Hanell, B. (ed.) Imea, Sweden, 13.
Finnegan et al., (2014) Implications of applied best management practice for peatland forest harvesting. Ecological Engineering 63: 12 -26
O’Driscoll., C et al., 2014 Creation and functioning of a buffer zone in a blanket peat forested catchment. Ecological Engineering 62: 83 – 92
Rodgers, M. et al., (2012a) Suspended solid yield from forest harvesting on upland blanket peat. COFORD Connects. Environment No. 12
Rodgers, M. et al., (2012b Phosphorus release from forest harvesting on an upland blanket peat. COFORD Connects. Environment No. 13.
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