On 24 March, TD Paul Kehoe asked Charlie McConalogue, Minister for Agriculture, in a written Dáil question, for clarification on why the “buffer zone radius” had been increased “from 3km to 15km for all forestry projects.”
The Wexford TD questioned the need for a 15km zone as he maintained that clear guidance from the National Parks and Wildlife Service (NPWS) states “the distance could be much less than 15km, and in some cases less than 100m, and must be evaluated on a case-by-case basis”.
If there is a possibility of a proposed forestry project (planting, roading or felling) affecting plans or projects on a Natura 2000 site within a 15km radius, then the project is ‘screened in’ for appropriate assessment (AA). In that instance, the Department “can seek the submission of a Natura Impact Statement (NIS) to inform that process”.
The purpose of the NIS is to provide adequate information to enable the Department to undertake and complete its AA of the proposed forestry project.
Applicants can get approval without an NIS, but the Department has informed applicants that without the statement, it will take much longer before an ecologist will be assigned on an AA determination.
Applicants are advised by the Department to submit an NIS, which would reduce the time to complete the AA process to “between two and three months”.
Most foresters contacted by the Irish Farmers Journal regard this time limit as wildly optimistic, given the performance of Department ecologists. To speed up the process, the Department appointed 16 ecologists last year to inspect licence applications and issue their findings.
From November 2020 to the end of March, the ecologists issued 348 licences, compared with the target of 820. This performance has been roundly criticised by the IFA, FII and the Irish Forestry Contractors Association (IFCA), who maintain the monthly targets are modest and should be achievable.
Why are the ecologists struggling to achieve 40% of targets? The answer may partly lie in their inexperience, but there are also more fundamental reasons. The 15km radius Deputy Kehoe refers to is far too large and disproportionate to the scale of forest development in Ireland.
In addition, forestry has been classified as industrial rather than a multipurpose positive environmental and sustainable land use. Minister McConalogue’s justification for the 15km radius as the “industry-norm” places forestry on par with industrial development, which is challenged by Pat O’Sullivan, technical director, Society of Irish Foresters.
“Forestry is not classed as industrial in other countries,” he claims.
“If forestry is assessed as industrial, should not dairy farming, beef and sheep rearing and other agriculture be regarded as industrial? Any reasonable person wouldn’t regard a land use change in these sectors as requiring an NIS.”
Because forestry is classed as industrial, it is treated in combination with other industry projects within the NIS area.
The minister’s assertion that the Department was advised that a radius of 15km “which had its origins in guidance provided by the National Parks & Wildlife Service” contradicts Deputy Kehoe’s claim that the NPWS has a much more flexible approach.
Extending the likely zone of impact from 3km to 15km is a major reason why private and Department foresters – as well as private and Department ecologists – struggle in achieving licence approvals for a viable afforestation and wood mobilisation programme.
A 3km radius requires assessing an area of land covering 2,800ha or 7,000ac, but now foresters and ecologists are being asked to assess a forestry project and its environmental impact covering 70,700ha or 174,700ac. In some instances, this means carrying out an NIS extending over a number of counties.
In Figure 1, for example, a planting site north of Ballyporeen would require an NIS covering not only south Co Tipperary, but parts of counties Limerick, Cork and Waterford, including the rivers Blackwater and Suir catchments, along with other rivers and ?tributaries such as the Araglin, Tar and Duag.
Working within a 15km radius – or 1% of the total land area of Ireland – each forestry site is likely on average to contain a number of Natura sites. These amount to 600,000ha of designated Special Protection Areas (SPAs) under the Birds Directive (EC, 2009) and most of the 1,350,000ha of Special Areas of Conservation (SACs), apart from the maritime sites.
Minister McConalogue also claimed that extending the radius from 3km to 15km was based on advice from the Forestry Appeals Committee (FAC) and private ecology consultants MKO, which, in a stroke, increased the area requiring an NIS by 25-fold.
This decision has to be regarded as ill-considered at best, especially as the average planting site in Ireland is 6.9ha, based on annual programmes from 2010 to 2019.
How an average planting site of this scale would require an NIS covering more than 10,000 times its size needs to be answered by the minister and his Department.
Project Woodland needs to examine why the Department insists on a rigid 15km radius that is totally disproportionate for a land use that is regarded as essential in achieving key climate mitigation targets, as well as social and economic benefits in rural Ireland. Requiring NISs for small-scale planting and felling – each costing up to €1,500 – without a guarantee of licence approval has resulted in farmers walking away from forestry as a land use option.
The answer lies in a flexible approach to licensing, or incorporating a grant payment to cover the cost for applicants who activate their licences.