Draft PEFC Irish Forest Certification Standard Consultation Report - Peter Wilson July 2010

Draft PEFC Irish Forest Certification Standard Consultation Report

Prepared for PEFC Ireland

by Peter Wilson June 2010

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Contents Part 1: Introduction − Background

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− Characteristics of respondents

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Part 2: General overall comments − Structure and layout

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− Content

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Part 3: Detailed comments − Introduction section

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− Section 1: Compliance with the law and conformance with the requirements of the certification standard

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− Section 2: Management planning

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− Section 3: Woodland design: creation, felling and replanting

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− Section 4: Operations

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− Section 5: Protection and maintenance

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− Section 6: Conservation and enhancement of biodiversity

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− Section 7: The community

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− Section 8: The forestry workforce

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− Glossary and appendices

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Annexes Annex 1: Full list of respondents

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Annex 2: Full list of comments allocated to sections of the Draft PEFC Irish Forest Certification Standard

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Annex 3: Deer and forestry in Ireland (Executive Summary)

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1. Introduction Background A public consultation to generate feedback on the Draft PEFC Irish Forest Certification Standard was carried out for 65 days between 25th March and 28th May 2010; at the request of some consultees, the consultation period was extended to 11th June making 79 days in all.

Peter Wilson of Wilson Applied Consultancy who chairs the UK Woodland Assurance Standard (UKWAS) partnership was invited to analyse the responses to the consultation, and this was undertaken during June and July 2010.

The Draft Standard is broken down into Requirements as follows: •

8 principal sections (e.g. 3)

•

30 sub-sections (e.g.3.1)

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73 clauses (e.g.3.1.1)

The electronic feedback form invited feedback for the 30 sub-sections and there was an additional section provided for ‘other comments’. The full comments received have been assigned to each Section and included in Annex 2 to this report with listing by section/ sub-section/ clause number and the respondent’s name against each. Similarly, a list of the general comments by respondent is included in Annex 2.

Concise lists of key summary points have been prepared and included in Parts 2 and 3 of the main body of the report by Section and sub-section; they are categorised and grouped as matters for clarification, proposed additions or, if requiring deeper consideration, as issues. In addition, a short summary is provided of the main issues raised by respondents for each Section. This is intended as the working checklist to make it easy for the drafting team to consider each issue without recourse to the raw responses. However, the reader is recommended to refer to each respondent’s full comments given in Annex 2 since these often contain important elaboration on the summary point.

Characteristics of respondents Ten organisations or individuals responded to the consultation: •

Seven used the on-line response form with some making additional comments by email or in discussion which was later confirmed by email.

•

Three made comment by email or in discussion which was later confirmed by email.

All the comments were from organisations based in Ireland and all can be characterised as being from within the ‘forestry sector’. One respondent was from a government department, one from a semi-state authority, one from a semi-state enterprise, three from private businesses, two from trade associations representing farmers and woodland owners, one from a voluntary woodland initiative and one was from a private individual with a professional knowledge of forestry.

There were no responses from environmental or social NGOs. A full list of respondents is given in Annex 1.

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2. General overall comments Structure and layout There were only two comments on structure and layout of the Draft Standard.

Coillte noted its similarity with the UK Woodland Assurance Standard (UKWAS) and queried whether permission was required; PFCI Ltd suggested including a diagrammatic chart in the introductory section to show clearly the relationships between the different bodies involved in certification and the route a woodland owner would follow to achieve certification.

The lack of further comment suggests that respondents are generally content with the structure and layout adopted.

The full comments are given in Annex 2.

Content Three respondents made general comments on the Standard’s content.

Teagasc welcomed it as a positive contribution to the development of the farm forestry sector but the IFA voiced its concerns about the additional demands and costs for private forest owners and especially for smaller-scale owners. Dr O’Carroll contended that application of the Forestry Act provides sufficient assurance of good forestry practice and was forthright in his criticism of the Draft Standard.

Three respondents made specific suggestions on content including inter alia: •

The virtual exclusion of references to recreation and recreational infrastructure such as forest trails (Coillte)

•

The importance of adopting more use of area thresholds so that the Standard can be made applicable to the typical private grower – a less onerous requirement applying to smaller owners than to larger holdings; only this would make certification economically feasible for private owners (ITGA)

•

The necessity of expanding the list of definitions to aid clarity of meaning (Teagasc)

The full comments are given in Annex 2.

The respondents’ comments on specific sections of the Draft Standard highlighted the importance that respondents attach to accuracy and clarity. Respondents highlighted many points requiring clarification and these are listed under the relevant Section headings in Part 3 of this report.

Overall, the most important point to emerge from the consultation is the problem of accessibility for generally smaller private owners who face direct and indirect costs and have limited capacity to meet the process requirements of certification. Owners’ representatives made it clear that the Draft Standard is more demanding than ‘business as usual’ and expressed their concern that the economic viability of private forestry will be damaged. Many respondents proposed adoption of area thresholds so that the Standard could be more easily applied to smaller scales of operation but others drew attention to the need to balance this with the degree of rigour necessary for certification to be credible.

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3. Detailed comments Introduction section I.F.S. Asset Managers Ltd stressed the importance of correct nomenclature when citing the sovereign state to which the Standard shall apply i.e. ‘Ireland’.

Coillte made specific suggestions to ensure transparency of the standard-setting process including noting who was involved in preparing the Standard, whether they supported the text of the Draft Standard and assurance regarding the independence of key personnel. The importance of transparency and independence of dispute procedures was also raised by Coillte whilst I.F.S. Asset Managers Ltd was concerned that disputes be resolved within realistic timeframes.

Coillte and PFCI Ltd made a specific call for greater clarity of certification options for forest owners and Coillte queried whether there were different requirements according to the scale of the forest enterprise.

The ITGA raised its concern that the Draft Standard does not recognise the structure and nature of Ireland’s private forests. The average size of a private holding is 8 ha and the Draft Standard does not give sufficient recognition to the needs of these owners and the constraints under which they operate. Overall, the ITGA suggests that insufficient attention is given to the economic pillar of sustainability.

Coillte was keen to ensure that, in providing for flexibility in meeting the requirements of the Standard, the Standard would not be so weak that an owner could effectively opt out of key elements leaving the Certification Body with the responsibility of making the key judgements.

Coillte raised a concern regarding the definition of a Woodland Management Unit (WMU) and how different definitions would impact on how the Standard would need to be implemented on the ground.

The full comments are given in Annex 2.

Section 1 Compliance with the law and conformance with the requirements of the certification standard This section proved to be uncontentious except for a major concern regarding the definition of ‘interested parties’ and their scope to contribute to the certification process through direct input.

A detailed summary of points raised is given below for each sub-section and the reader is recommended to refer to each respondent’s full comments given in Annex 2. These often contain important elaboration on the summary point.

Sub-section 1.1: Compliance and conformance Clarifications sought: •

1.1.2 Requirement: ‘relevant’ (Coillte)

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Issues: •

1.1.2 Guidance: is Appendix A exhaustive? (Coillte)

•

1.1.2 Guidance: concern over scope of ‘interested parties’ and suggestion that it should exclude non-forestry groups and those not local to the forest. (I.F.S. Asset Managers Ltd)

Sub-section 1.2: Protection from illegal activities Clarifications sought: •

1.2.1 Requirement: ‘reasonable measures’ (Coillte)

Additions proposed: •

1.2.1 Guidance: additional bullet points – littering, illegal lighting of fires and/ or burning of scrubland (PFCI Ltd/ I.F.S. Asset Managers Ltd)

Section 2 Management planning The IFA raised a major concern relating to management planning suggesting that the Draft Standard’s requirements go beyond current requirements and are an additional cost for the forest owner, especially smaller owners; the level of detail required and the need for a multi-resource inventory were both cited. IFA and Coillte both requested clarifications relating to the documentation required.

The themes relating to the costs for smaller owners were highlighted by the ITGA and IFA with the underlying feeling that the economic pillar of sustainability is accorded insufficient priority. The need for a flexible approach to implementation of the plan was raised to provide for changing ground conditions and timber market factors. Concern over stakeholder involvement was also raised again as was the question of whether and how the requirements would be implemented at WMU level.

A detailed summary of points raised is given below for each sub-section and the reader is recommended to refer to each respondent’s full comments given in Annex 2. These often contain important elaboration on the summary point.

Section 2: Preamble Issues: •

Terminology – is ‘stakeholder’ an appropriate description? Suggested that ‘interested party’ and ‘concerned party’ is what is intended (Dr O’Carroll)

•

Suggested that it is not always appropriate to ‘maintain or increase’ the forest area when habitat restoration and provision of open space, for example, might be more appropriate (Coillte)

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Sub-section 2.1: Documentation Clarifications sought: •

2.1.1 Requirement: expand and define ‘multi-resource inventory’ and what is needed for inclusion in the management plan (Coillte/ IFA)

Additions proposed: •

2.1.3 Requirement: add annual Income & Expenditure estimates (PFCI Ltd)

Sub-section 2.2: Productive potential Clarifications sought: •

2.2.2 Requirement: ‘Demonstrated control of thinning intensity’ (Teagasc)

•

2.2.2 Guidance: Circumstances where harvest levels exceed increment – is this on a WMU basis?

(Coillte)

Issues: •

2.2.1 Requirement: It is not always appropriate to rehabilitate degraded forest ecosystems (Coillte)

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2.2.1 Guidance: Terminology – suggestion that ordering of ‘ecological, social and economic’ inappropriate since the economic function is primary for most owners (Dr O’Carroll)

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2.2.4: suggestion that this section is outwith scope of standard as relates to chain-of-custody (Coillte)

Sub-section 2.3: Implementation and revision of the plan Clarifications sought: •

2.3.2 Requirement: ‘Fauna and flora, particular key indicator species’ (Coillte)

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2.3.2 Means of verification: ‘very vague’ (Coillte)

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2.3.2 Guidance: ‘supervision’ – supervision of whom or what? (Coillte)

Issues: •

2.3.1 Requirement: suggestion that there is need for flexibility in timing and implementation of operations e.g. for ground conditions, market factors, etc. (IFA)

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2.3.2 Requirement: suggestion that excessively costly, and unnecessary, for smaller owners (ITGA/ IFA)

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2.3.2 Requirement: proposed that a Monitoring Record template be provided (IFA)

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2.3.2 Requirement: concern by farmers about making monitoring records publicly available; proposed that shall only be done on basis of anonymity and in amalgamated form (IFA)

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Section 3 Woodland design: creation, felling and replanting An over-arching point relates to references to Irish and UK guidelines which are found to be confusing by respondents; only Irish guidelines are applicable in Ireland. If the UK guidelines are cited as reference material where they are felt to provide additional advice on good practice it is recommended that it be made very clear to readers whether they are simply a source of advice or whether the Standard requires a degree of conformance to them.

Respondents’ comments relating to sub-section 3.1 were substantially limited to suggestions to improve clarity and accuracy.

For sub-section 3.2, there was particular concern relating to the costs relating to plan preparation and adherence for small private growers and that the Draft Standard makes little differentiation between large and small owners. Making special provision for smaller owners was advocated by several respondents through use of area thresholds whilst one respondent proposed an additional exception where ‘no useful environmental, economic or social purpose would be served’. The “25% rule” in 2.2.4 was particularly contentious with various proposals put forward for alternative approaches and greater flexibility in application.

As ITGA noted, modern Irish forestry is based primarily on use of non-native species and there was therefore concern at an approach in sub-section 3.3 based on species ratios and incorporation of native species and open areas into the planting matrix. Some saw this as disadvantaging Irish forestry and proposed that this aspect of the requirements be removed or revised, some proposed selecting species on the basis of silvicultural considerations and the owner’s objectives. Others promoted the concept of size thresholds so safeguarding the viability of smaller owners.

The promotion of lower impact silvicultural systems (LISS) in sub-section 3.4 was controversial; so too, on the grounds of cost, was the requirement that a rationale be provided for adopting a silvicultural system based on the owner’s own forest management policy and objectives. The need to take account of local people’s views was also challenged.

Respondents’ comments on sub-section 3.5 were largely restricted to detailed points to increase clarity but there were proposals put forward to amend the conditions that will permit owners to convert woodland to non-forest land.

A detailed summary of points raised is given below for each sub-section and the reader is recommended to refer to each respondent’s full comments given in Annex 2. These often contain important elaboration on the summary point.

Sub-section 3.1: Assessment of environmental impacts Clarifications sought: •

3.1.1 Guidance (bullet) – ‘identification of fauna and flora’ – to what level? (Coillte)

•

3.1.1 Guidance (last paragraph) – reference to a ‘full EIA’ gives the impression that ‘environmental assessment’ mentioned in text above is EIA but not a full one (DAFF)

Additions proposed: •

3.1.1 Guidance: additional text proposed on environmental assessments to include operational impacts on soil, water, biodiversity and people (PFCI Ltd)

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3.1.1 Guidance 4th bullet: add NHA (DAFF/ Coillte) Page 10 of 52

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3.1.1 Guidance (final paragraph) on EIA thresholds: o

Amendment of 50 ha thresholds proposed but seems to be error in the text submitted – check with respondent (DAFF)

o

Additional thresholds to be included on 1) felling/ deforestation for conversion to other land use, and 2) replacement of broadleaf forest with conifer species – see respondent’s text (DAFF)

Issues: •

3.1.1: how will PEFC deal with establishment that wasn’t grant-aided? Will the same assessments/checks be carried out? (Teagasc)

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3.1.1 Guidance: suggested that as proposed it is an unreasonable imposition (Dr O’Carroll)

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3.1.2: how will PEFC deal with changing environmental requirements? E.g. will FEPS guidelines continue to be implemented? (Teagasc)

Sub-section 3.2: Location and design Clarifications sought: •

3.2.2 Guidance: why use diverse provenances? (Coillte)

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3.2.2 Guidance: how much open ground to be retained? (Coillte)

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3.2.3 Requirement: timescale - does ‘gradually restructured’ mean over years or rotations?

(Coillte)

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3.2.3 Guidance: should Irish or UK guidelines be used? (Coillte)

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3.2.4 Requirement: “25% rule” - define ‘woodland area’ (Teagasc); does this mean WMU and should account be taken of neighbouring woods? (Coillte)

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3.2.4 Requirement: does “25% rule” apply to small woods? (Teagasc)

Corrections proposed: •

3.2.4 Requirement: reference to UK Forestry Commission incorrect as it operates only in Great Britain (Dr O’Carroll)

Additions proposed: •

3.2.2 Guidance: add Forestry Schemes Manual (DAFF)

Issues: •

3.2.1 Requirement: why is only ‘diverse woodland edge’ cited? (Coillte)

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3.2.1 Guidance: The requirement covers visual, cultural and ecological values so why does guidance cover only landscape guidelines? (Coillte)

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3.2.1 MoV: design plan is onerous, costly and unnecessary for private owners (ITGA)

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3.2.2 Requirement: suggested that this should not apply to smaller woodlands, only larger ones (IFA/ ITGA)

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3.2.2 Requirement: diversity requirement might frustrate owner’s objectives (Dr O’Carroll)

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3.2.3 Requirement: suggested that this should not apply to smaller woodlands, only larger ones (IFA)

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3.2.3 Requirement: suggested that onerous, costly and unnecessary for typical private forests (ITGA)

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3.2.4 Requirement: concern that the design requirements are ‘not informed by historical planting and practice’ and a proposal that an additional exception be included - "Where the scale / location / species composition of the original design is such that no useful environmental, economic or social purpose would be served” (Woodland Managers Ltd)

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3.2.4 Requirement: are both Irish and (very demanding) UK guidelines required? (Coillte); inappropriate to use UK guidelines, reference should be to Code of Best Practice for Ireland (ITGA)

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3.2.4 Requirement: concern that requirement seems to take no account of woodland size (DAFF) and that it is unworkable for small owners – typical farm forestry plantation is 8 ha (IFA)

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3.2.4 Requirement: design plan preparation and adherence very onerous, costly and unnecessary for typical private forests and should be deleted (ITGA)

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3.2.4 Requirement: “25% rule” considered unworkable and economically costly on much of private forest estate given its scale and typically even aged structure; proposed that this rule should not apply to ‘private forest areas under 100 ha’ (ITGA)

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3.2.4 Requirement: proposed that “25% rule” should provide for a 25-40% range to cater for commercial considerations (I.F.S. Asset Managers Ltd)

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3.2.4 Requirement: concerns relating to consequences of implementing this requirement including inter alia risk of windbreak, financial losses due to premature or delayed harvesting and extended silvicultural management requirements, and loss of flexibility in marketing – see detailed text (Woodland Managers Ltd)

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3.2.4 Requirement: query over whether exception (d) could be met based on existing text (Coillte)

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3.2.4 Requirement: proposed that additional exceptional circumstance be included to cover need to retain windfirm coupe boundaries – see proposed text (PFCI Ltd)

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3.2.4 Requirement: consider including reference to coupe size and justification (Coillte)

Sub-section 3.3: Species selection Clarifications sought: •

3.3.1/ 3.3.2 Requirements: what species are ‘naturalised broadleaves’? (Coillte)

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3.3.1 Guidance: what is meant by a range of genotypes? (Coillte)

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3.3.1 Guidance: comma required after ‘possible’ for clarity (Teagasc)

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3.3.2 Requirement: concept of ‘primary’ and ‘secondary species’ needs defining (Dr O’Carroll)

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3.3.3 Guidance: ambiguous (Coillte)

Issues: •

3.3.1 Requirement: Irish forestry is based on non-native species, this requirement disadvantages Irish forestry and proposed that it be removed (ITGA)

•

3.3.1 Requirement: concern at the use in 3.3.2 of percentage requirements instead of selecting species on basis of silvicultural considerations and objectives. Proposes new text in 3.3.1 reflecting this approach in Requirement (a) and additional text in Requirement (c) – see respondent’s text (PFCI Ltd) Page 12 of 52

[Also see respondent’s proposal below that 3.3.2 Requirement be dropped and related Guidance combined with that in 3.3.1] •

3.3.1 Requirement: flexibility advocated in case of issues relating to quality or availability of planting stock (Teagasc)

•

3.3.2 Requirement: in context of proposed planting ratios, what about native conifers? (Coillte)

•

3.3.2 Requirement: importance of economic pillar of sustainability highlighted and concern raised over the proportion of unproductive area advocated in standard; proposed that open space and native/ naturalised broadleaf requirements should not apply to areas under 50 ha (ITGA)

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3.3.2 Requirement: proposed revising ratios to 68% primary and 17% secondary species in line with Forest Service requirements and to give greater flexibility (Woodland Managers Ltd)

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3.3.2 Requirement: question raised over whether inapplicability of open space requirement to woodlands <10 ha is justified (Coillte); question raised over why open space (‘waste ground’) is obligatory (Dr O’Carroll)

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3.3.2 Requirement: requirement too specific, should be function of management objectives; proposed that requirement absorbed into 3.3.1 (IFA)

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3.3.2 Requirement: consequent on concerns raised above over 3.3.1, respondent proposed that the 3.3.2 Requirement be dropped and its related Guidance combined with that in 3.3.1 (PFCI Ltd)

•

3.3.3 Requirement: why are invasive non-native trees not covered? (Coillte)

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3.3.3 Requirement: Who should monitor introductions? (Coillte)

Sub-section 3.4: Silvicultural systems Clarifications sought: •

3.4.1: ‘lower impact silvicultural systems’ - lower than what? (Dr O’Carroll)

Additions proposed: •

3.4.1 Guidance: additional bullet: ‘economics and value for money’ (Teagasc)

Issues: •

3.4.1 Requirement: suggested that 10% LISS is too high (Coillte)

•

3.4.1 Requirement: proposed that requirement (a) be deleted as too financially onerous for small/ average sized growers (ITGA)

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3.4.1 Requirement: suggested that requirement (b) unduly limits options for forests >100 ha and will have considerable financial impact; also queries whether (b) applies to a 100 ha forest that is fragmented (IFA)

•

3.4.1 Guidance: queries why no mention of small coupe felling or thresholds of coupe size (Coillte)

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3.4.1 Guidance: challenges why ‘views of local people’ should be considered (Dr O’Carroll)

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Sub-section 3.5: Conversion to non-forested land Clarifications sought: •

3.5.1 Requirement: will this reflect changes to the Forestry Act? (Teagasc)

•

3.5.1 Requirement: is onus on landowner to get planning permission before undertaking restoration/ transformation? (Coillte)

•

3.5.1 Guidance: current text based on incorrect understanding of Forestry Act relating to general felling licensing, there is no Ministerial discretion regarding mandatory replanting condition (Dr O’Carroll)

Additions proposed: •

3.5.1 Guidance: insert ‘See Section 3.1.1 for guidance on thresholds for requirement of an EIA’ (DAFF)

Issues: •

3.5.1 Requirement: terminology – proposed that ‘transformation’ should be used in place of ‘restoration’ (Coillte)

•

3.5.1 Requirement: proposed that condition (b) 1 relating to ‘substantial dispute’ should be removed; condition (b) 2 should be amended to incorporate social and economic values as well as ecological values – see text proposed (ITGA)

Section 4 Operations Respondents’ comments are largely confined to promoting greater clarity.

A detailed summary of points raised is given below for each sub-section and the reader is recommended to refer to each respondent’s full comments given in Annex 2. These often contain important elaboration on the summary point.

Sub-section 4.1: General Clarifications sought: •

4.1.1 Requirement: what are ‘sensitive soils’? (Coillte)

•

4.1.1 Requirement: ‘local people’ – what is local? (Coillte)

•

4.1.1 Requirement: what is ‘heavy machinery’? (Coillte)

Additions proposed: •

4.1.1 Guidance: proposed that list of impacts should include ‘people’ (PFCI Ltd)

Issues: •

4.1.1 Guidance: noted that recreational values are affected by forest operations but other forest values can be affected by unplanned recreation (Coillte)

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Sub-section 4.2: Harvesting operations Clarifications sought: •

4.2.2: suggested that the Requirement and Guidance are contradictory and that what is needed is to undertake a properly documented assessment prior to operations – see text (Teagasc)

•

4.2.3 Requirement: why should lop and top not be burned? (Dr O’Carroll)

•

4.2.4 Requirement: minimum loss or damage – to what? (Teagasc)

Additions proposed: •

4.2.1 Guidance: additional relevant sections of Guidelines documents proposed for inclusion – see text (DAFF)

•

4.2.1 MoV: add ‘harvesting plan complete with maps’ (PFCI Ltd)

•

4.2.2 Guidance – add sediment, soil integrity and carbon issues (Coillte)

•

4.2.4 Guidance: add ‘habitats’ (Teagasc)

Sub-section 4.3: Forest Roads Clarifications sought: •

4.3.1 Guidance: do roads over 2km currently require an EIA? Should forest trails be included in this category? (Coillte)

Section 5 Protection and Maintenance The issue of game management, particularly deer management, under sub-section 5.1 raised a number of concerns and alignment of the Draft Standard with legal requirements was proposed. The absence of a national strategy for deer control was said to place a heavy burden on individual owners should they be expected under the Draft Standard to deliver effective deer control. The recommendations of the Woodlands of Ireland report on deer control were commended to the standard setting group for their consideration.

The requirement to minimise use of biological control agents under sub-section 5.2 was cause for comment by several respondents and it was considered contradictory to seek to minimise both pesticides and biological control agents when the latter might replace pesticide control methods. A number of revision options were put forward.

Sub-sections on fencing and waste management were apparently uncontroversial.

A detailed summary of points raised is given below for each sub-section and the reader is recommended to refer to each respondent’s full comments given in Annex 2. These often contain important elaboration on the summary point.

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Sub-section 5.1: Planning Clarifications sought: •

5.1 Deer Management: the requirements relating to deer are ‘a bit vague to say the least’ and depend greatly on what category deer are considered to fit into – “game” , “invasive species” , “exotics” ,“ non-wood products”, “forest pests” or all the above? (Coillte)

•

5.1.3 Requirement what does ‘locally’ mean? (Teagasc)

•

5.1.4 Guidance: is hare not a protected species? (Coillte)

•

5.1.4 MoV: ‘wildlife officer’ should be changed to ‘NPWS Conservation Ranger’ (Coillte)

•

5.1.6: suggests a Fire Plan is a Forest Service requirement (Teagasc)

Additions proposed: •

5.1.1 MoV: include Fire Plan (PFCI Ltd)

Issues: •

5.1 Game Management: raised several concerns regarding control of hunting activities and, rather than expecting owners to set targets, proposed that the standard should reflect the current legal situation regarding hunting and shooting making reference to the NPWS as the regulatory authority for control of sustainable hunting levels (Coillte)

•

5.1 Deer Management: proposed that recommendations of WoI report on deer and forestry should be considered (see Annex 3) (Woodlands of Ireland)

•

5.1.3 Requirement: suggested that, given the spread of deer across Ireland and the lack of a national strategy, it is challenging for an individual owner to have ‘other than aspirations with regard to deer management objectives’. Proposed that this section reviewed to identify a practical/ pragmatic approach to deer management in Irish forests (PFCI Ltd)

•

5.1.6 Requirements: suggested that a Fire Plan should be required for all sites (Coillte)

Sub-section 5.2: Pesticides, biological control agents and fertilisers Clarifications sought: •

5.2.3 Guidance (5th bullet point): what does this mean? Give clearer instructions – the area of the site should be given (DAFF)

•

5.2.3 Guidance (6th bullet point): What does this mean? What is the difference between this and the 5th bullet point? Give clearer instructions (DAFF)

•

5.2.5: adopt consistent spelling of fertilizer/ fertilizer (Coillte)

Additions proposed: •

5.2.1 Guidance: add ‘Reporting of pest/disease to relevant authority, where appropriate’ (DAFF)

•

5.2.3 Requirement: requirement (a) contains a contradiction relating to ‘biological control agents’ and ‘non-chemical methods’ – options to address this are proposed (Coillte)

•

5.2.3 Guidance (first sentence): insert ‘and the Guidelines for the Use of Herbicides in Forestry’ (DAFF)

•

5.2.4 Guidance: add ‘Disposal of empty containers to be in accordance with procedures as set out in 5.4.1’ (PFCI Ltd)

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•

5.2.5 Guidance (second sentence): Insert ‘and in the Forestry and Water Quality Guidelines’ (DAFF)

Issues: •

5.2.2 Requirement: requirement to minimise use of biological control agents challenged; proposed that the statement ‘minimise the use of pesticides and biological control agents in the forest’ be amended to ‘minimise the use of chemical pesticides and promote the use of biological control agents’ (Coillte)

•

5.2.2 Requirement: lack of reference to biodegradable lubricants queried (Coillte)

•

5.2.3 Requirement: proposed that biological control agents should not be included in this section which should be confined to pesticides (Coillte)

•

5.2.5 Requirement: the need for foliar analysis in all cases is challenged (Dr O’Carroll)

Sub-section 5.3: Fencing Additions proposed: •

5.3.1 Guidance: insert that ‘fencing requirements are specified in the Forestry Schemes Manual’ (DAFF)

Issues: •

5.3.1 Requirement: the need for this requirement challenged since managers would avoid cost of fencing wherever possible (Dr O’Carroll)

Sub-section 5.4: Waste management No comments received

Section 6 Conservation and enhancement of biodiversity A major focus for respondents’ concerns was that, under sub-section 6.2, 15% of the woodland area shall be managed with biodiversity and conservation as the primary objective. Concerns raised included undermining of the economic viability of the woodland and a variance between the Draft Standard and Forest Biodiversity Guidelines’ requirements; proposals for area thresholds to apply, so excluding smaller woodlands from the requirement, and revised percentage ratios were proposed.

A second focus, under sub-section 6.3, was concerns raised over the definitions for old woodland sites and POWS and over the economic impacts on smaller owners; proposals that the requirement only apply to woods >100 ha was put forward.

Concerns relating to game management, sub-section 6.4, centred on the difficulty for owners if required to ascertain the viability of quarry species populations.

A detailed summary of points raised is given below for each sub-section and the reader is recommended to refer to each respondent’s full comments given in Annex 2. These often contain important elaboration on the summary point.

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Sub-section 6.1: Protection of rare species and habitats Clarifications sought: •

6.1.1 Guidance (first paragraph): this relates to statutorily designated areas including National Parks; however, all the National Parks, apart from the core area of Killarney National Park, are not statutorily designated – they are protected as state owned land. (DAFF)

•

6.1.2: does this include both flora and fauna? (Teagasc)

•

6.1.2 Guidance: “significant” woodland management operations - clarify what constitutes significant (Coillte)

•

6.1.3 Requirement: ‘where a rare or endangered species is known to be present…’ – is this ‘known’ due to following requirements 6.1.1 and 6.1.2? (Teagasc)

•

6.1.3 Requirement: standard states ‘where a rare or endangered species is known to be present’ but other standards specify where significant populations of such species are known (Coillte)

Additions proposed: •

6.1.1 Guidance: lack of reference to pNHAs and Nature Reserves queried (Coillte)

•

6.1.1 Guidance (end of last paragraph): insert ‘Notifiable Actions do not apply where a licence or permission is needed from a planning authority (e.g. planning permission) or another Minister (e.g. a felling licence or afforestation approval)’ (DAFF)

•

6.1.1 MoV: add proof of consultation with statutory agencies (Teagasc)

•

6.1.2 Guidance (end of first paragraph): insert ‘and the Forestry Schemes Manual’ (DAFF)

•

6.1.3 Guidance (second paragraph, end of first sentence): insert ‘and Threat Response Plans’ (DAFF)

•

6.1.3 Guidance (second paragraph, second sentence): insert ‘and TRPs’ after SAP (DAFF)

Issues: •

6.1.2: Requirement: challenges whether biodiversity should be ‘the primary object of management’ (Dr O’Carroll)

Sub-section 6.2: Maintenance of biodiversity and ecological functions Clarifications sought: •

6.2.1 Requirement: does 15% requirement apply to the woodland, WMU or landscape unit?

(Coillte)

•

6.2.2 Requirement: clarity needed on what constitutes ‘some’ over-mature trees (Coillte)

Issues: •

6.2.1 Requirement: concern that this additional unproductive area undermines economic viability and proposes that requirement for open space and native or naturalised broadleaf should only apply in forests over 100 ha (ITGA)

•

6.2.1 Requirement: variance with Forest Biodiversity Guidelines which require 5-10% retained (woodland or non-woodland) habitat not a minimum 10% woodland habitat (DAFF)

Page 18 of 52

•

6.2.1 Requirement: concern expressed over reduced income generation, proposed that 10%, not 15%, of area to be managed with conservation and biodiversity as primary objective (IFA)

•

6.2.1 Requirement: a 10% threshold for woodland habitat retention not always appropriate- e.g. on raised bogs; proposed that requirement instead refers to 10% retained for biodiversity (Coillte)

•

6.2.1 Requirement: advocates that hedgerows and light scrub areas are counted as ‘woodland habitat’ (Woodland Managers Ltd)

Sub-section 6.3: Conservation of semi-natural woodlands and plantations on old woodland sites Clarifications sought: •

6.3.1Requirement (a), (b), (c): should this be read as (a) and (b) and (c) rather than or? (Teagasc)

•

6.3.1: LISS does not specify threshold for small coupe felling size (Coillte) (This comment seems to be misplaced)

•

6.3.1: does the FIPS 1998 planning system identify “semi-natural” woodlands? What are the explicit criteria; they should be outlined in this document (Coillte)

•

6.3.2 “Remnant features” of old woodlands - a list of such features should be appended to the document (Coillte)

•

6.3.2: “Operations should not adversely impact the sites’ values” - what values are these?

(Coillte)

•

6.3.2: monitoring the “response” of remnant features - response needs to be clarified, how are such features intended to respond? (Coillte)

•

6.3.2: “Assessment of the current state of biodiversity” may be impossible to realise on the ground as it encompasses all plants, animals and fungi associated with forest ecosystem - needs to be changed (Coillte)

•

6.3.2 Guidance: spelling: principal vs principle (Teagasc)

•

6.3.3 Requirement (first paragraph): is natural regeneration of native species also acceptable?

Sentence is confusing (Teagasc)

•

6.3.3: definition of native species for Ireland along with a list needed (Coillte)

Issues: •

6.3: ‘old woodland’ definition should be changed to cover only areas ‘with continuous forest cover since 1830’ (Coillte)

•

6.3.2 Requirement: concerned that requirements too onerous for typical private owners, are unworkable and will discourage owners from getting certified; proposed that requirement should only apply to areas over 100 ha (ITGA)

•

6.3.2 Guidance: concern over owners’ access to 1830s Ordnance Survey maps (Dr O’Carroll)

•

6.3.2 Guidance: ‘a more detailed definition’ definition of POWS may be preferable now (Teagasc)

•

6.3.3 Requirement: concerned that requirements too onerous for typical private owners, are unworkable and will discourage owners from getting certified; proposed that requirement should only apply to areas over 100 ha (ITGA)

Page 19 of 52

Sub-section 6.4: Game management Clarifications sought: •

6.4.2 Requirement: sentence is confusing and open to different interpretations (Teagasc)

Additions proposed: •

6.4.2 Requirement: proposed that should acknowledge the legal protection that some predator species enjoy should be and restrictions on predator control (Coillte)

Issues: •

6.4 Deer Management: proposed that recommendations of WoI report on deer and forestry should be considered (see Annex 3) (Woodlands of Ireland)

•

6.4.1 Requirement: hunting should not threaten the viability of “any” particular species – suggested that this definition is far too wide since it may be impossible to ascertain the viability of all or any species (Coillte)

Section 7 The community Respondents highlighted the burden of consultation required under sub-section 7.1 with one respondent proposing a more exclusive interpretation of ‘local people and organisations’ to reduce the extent of the consultation exercise.

Woodland access requirements (sub-section 7.2) were felt to have insufficient regard for private property rights by the ITGA but to be unduly weak in some areas by Coillte.

The requirement under sub-section 7.4 to respond positively to respond positively to local requests for forest products or services was questioned on the basis of legality.

A detailed summary of points raised is given below for each sub-section and the reader is recommended to refer to each respondent’s full comments given in Annex 2. These often contain important elaboration on the summary point.

Sub-section 7.1: Consultation Clarifications sought: •

7.1.1 Requirement: ‘local people’ – what is local? (Coillte)

•

7.1.1 Requirement: is a land sale classed as a ‘high impact operation’? (Coillte)

•

7.1.1 Requirement: does consultation have to be with all local people and organisations? (IFA)

•

7.1.1 Requirement: what level of consultation is required? (IFA)

•

7.1.1 Requirement: is consultation required for every operation or just high impact operations?

(IFA)

Issues: 7.1.1 Requirement: concern raised at burden on smaller owners of consulting with local people and relevant organisations; various clarifications sought as listed above (IFA) 7.1.1 Requirement: proposed restriction of scope of ‘local people and relevant organisations’ to exclude ‘certain non-forestry groups’; proposed definition of ‘interested parties’ to include those Page 20 of 52

within close proximity (say 5 km) of forest or groups with registered membership over 5,000 (I.F.S. Asset Managers Ltd) Sub-section 7.2: Woodland access and recreation including traditional and permissive use rights Issues: •

7.2.1 & 7.2.2: noted that Irish land law is complex so care needed in wording the standard – suggested that, for example, the word ‘customary’ is difficult to define legally and perhaps best omitted (PFCI Ltd)

•

7.2.2 Requirement: suggested that there is insufficient regard for private property rights and that owner should not have to make the case for excluding public access – proposed deletion of ‘in certain circumstances’ (ITGA)

•

7.2.2 Guidance: suggested that guidance is unduly weak as all access may be denied under first bullet (Coillte)

Sub-section 7.3: Sites with recognised specific historical, cultural or spiritual significance Additions proposed: •

7.3.1: proposed that text should make reference to the terms Recorded Monuments, Registered Historic Monuments and Monuments in State Ownership (DAFF)

Sub-section 7.4: Rural economy Clarifications sought: •

7.4.1 Requirement: questions whether requirement is legal under EU/ Irish law (Coillte)

Issues: •

7.4.1 Requirement: proposed revision of requirement so that owner/ manager should ‘consider’, rather than ‘respond’, to local requests (ITGA)

Sub-section 7.5: Minimising adverse impacts Clarifications sought: 7.5.1 Guidance: proposed changing wording of ‘timber traffic’ but alternative not specified (Coillte) Additions proposed: •

7.5.1 Guidance: add keeping of a Complaints Register (PFCI Ltd)

Section 8 The forestry workforce This section proved to be uncontentious with respondents’ input relating only to minor points.

A detailed summary of points raised is given below for each sub-section and the reader is recommended to refer to each respondent’s full comments given in Annex 2. These often contain important elaboration on the summary point.

Page 21 of 52

Sub-section 8.1: Health and safety Additions proposed: •

8.1.1 Guidance: add Accident Record Book (PFCI Ltd)

Sub-section 8.2: Training and continuing development Clarifications sought: •

8.2.1 Requirement: confusing sentence (Teagasc)

Sub-section 8.3: Workers’ employment rights No comments received Sub-section 8.4: Insurance No comments received

Glossary of terms See detailed points in Annex 2.

Appendix A: Forest Service Guidelines, Other Industry Codes of Practice and Rules and Selected Bibliography See detailed points in Annex 2.

Appendix B: Selected Bibliography See detailed points in Annex 2.

Appendix C: Forest Service Guidelines, Other Industry Codes of Practice and Rules and Selected Bibliography See detailed points in Annex 2.

Appendix D: Irish Red Data Books and Lists No comments received.

Appendix E: Forest Service Referral and Notification System See detailed points in Annex 2.

Page 22 of 52

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Page 23 of 52

List of Annexes Annex 1: Full list of respondents

Annex2: Full list of comments allocated to sections of the Draft PEFC Irish Forest Certification Standard

Annex 3: Deer and Forestry in Ireland: A Review of their current Status and Management (Executive Summary)

Page 24 of 52

Annex 1 Full list of respondents

Respondent

Organisation

Category

Philip Carr

Forestry Division, Department of Government department Agriculture, Fisheries and Food

Michael Keane

Coillte Teoranta

Semi-state enterprise

Harry Rynn

Woodland Managers Ltd

Private company

Donal Whelan

Irish Timber Growers Association (ITGA)

Trade association

Tony Mannion & George O’Malley

PFCI Ltd

Private company

Paul Brosnan

I.F.S. Asset Managers Limited

Private company

Steven Meyen

Teagasc

Semi-state authority

(The Agriculture and Food Development Authority) Dr Niall O’Carroll

Formerly Chief Inspector, Forest Private individual Service

Declan Little

Woodlands of Ireland (WoI)

Voluntary woodland initiative

IFA Farm Forestry Committee

Irish Farmers’ Association (IFA)

Trade association

Page 25 of 52

Annex 2 Full list of comments allocated to sections of the Draft PEFC Irish Forest Certification Standard General overall comments General comments on the standard’s structure and layout Coillte Teoranta

•

The draft seems very similar to the UKWAS Standard. Is permission required from that organisation?

PFCI Ltd

•

The inclusion of a diagrammatic chart early in the introduction setting out clearly and unambiguously the relationship between PEFC Council, PEFC Ireland, the Certification Bodies (CBs), and thereby delineating the route to be taken by the woodland owner(s) aspiring to become certified.

General comments on the standard’s content Teagasc

•

Teagasc Forestry Development Unit very much welcomes the draft PEFC Irish Forest Certification Standard and believes that it can play a positive role in the development of the farm forestry sector.

Dr Niall O’Carroll

•

In general the conditions proposed in the Draft Standard appear to be a typical example of bureaucracy gone berserk, a scheme that might have been drawn up by an insane administrator (perhaps it was!). No serious forest owner or manager with a commercial objective would wish to complete this hotchpotch of miscellaneous material in order that his timber may eventually be sold in, say, Japan.

•

I am quite sure that the essential details of a scheme to ensure sustainability (which is what I assume is intended) could be boiled down independently to a reasonable and acceptable size.

•

I would add that in my view adequate policing to ensure adherence to the terms of the 1946 Forestry Act 'in accordance with the general practice of good forestry’ (See the Act, passim) would result in sustainability.

•

IFA have concerns about the additional demands and the cost implication of acquiring PEFC certification for private forest owners.

The demands of the standard particularly for small-scale forest owners will make certification costs prohibitive.

•

In many instances the requirements for small-scale forest owners are disproportionate to the type and scale of the private forest sector in Ireland. The burden of meeting the standard is too great for many small-scale forest owners.

•

The cost of compliance with PEFC forest certification versus the benefit is a major barrier for farmers. Farmers are familiar with quality

IFA

Page 26 of 52

assurance standards, however the requirements of the PEFC Standard far exceeds those placed on food producers by agricultural quality assurance standards.

•

Overall the requirements on small-scale forest owners must be reduced to reflect the nature of private forestry in Ireland.

Specific suggestions on content Coillte Teoranta

•

There is almost no mention of recreation or infrastructure such as trails.

ITGA

•

It is proposed that in any final PEFC Standard that the application and use of area thresholds are more widely employed so as the PEFC Standard is workable and economically feasible for the typical private grower. Specifically it is proposed that the Requirements outlined in this Comment Form do not apply to areas under 50 hectares or that the Requirements for such areas are amended considerably for private forest holdings.

Teagasc

•

Some definitions are not present. It would be helpful if a more concise list of definitions was provided.

•

Some spelling and grammar issues that make for confusing reading.

•

Will an analysis of certification costs be undertaken?

Introduction Preparation of the draft PEFC Ireland Forest Certification Standard Coillte Teoranta

•

•

Page 2: o

The last paragraph should state the names and affiliations of the representatives of the various interests who took part in the preparation of the draft and state whether these people have signed off on the draft.

o

How can we know if the Chairman of the Forum and TWG is independent?

Page 3: o

I.F.S. Asset Managers Limited

•

First paragraph. How do we know the consultant is independent?

Reference to the ‘Republic of Ireland’: This should be changed to ‘Ireland’.

Republic of Ireland is not a country it is an Act of the Oireachtas enacted in 1948 of the same name declaring the name of the state as Ireland.

There is no country called Republic of Ireland and the official name of the country is Ireland as recognized by the EU and the UN. Page 27 of 52

In 1989 the Irish Supreme Court rejected an extradition warrant that used the name "Republic of Ireland". Justice Walsh ruled: "if the courts of other countries seeking the assistance of this country are unwilling to give this State its constitutionally correct and internationally recognised name, then in my view, the warrants should be returned to such countries until they have been rectified."

Certification options for forest owners Coillte Teoranta

PFCI Ltd

•

Regional Certification. What is a defined region?

Are there different requirements for small and large landowners?

•

Clarification that it is the CB, and not PEFC Ireland, that issues the Forest Management Certificate to the successful woodland owner(s).

This will include clarification that the contract is between the woodland owner and the CB; and should also include a sample of the CBs contracted to conduct certification audits on behalf of PEFC Ireland.

•

Clarification of the definition of Regional Certification, and indeed whether this needs to be included at all in an Irish context. Also how to differentiate between a region and a group.

•

‘Group manager’ is too loosely defined, and also that perhaps any group seeking certification would need to be a legal entity in order adequately to deal with possible disputes amongst group members.

•

Concern about the possibility of potential pitfalls with multiple site ownership where not all the forests are certified. For example, an owner with three forests, A, B and C opts to certify only A & B but is subsequently shown to be managing forest C in an unsustainable manner; or he is found to be exceeding his permitted output of logs from A & B by adding produce from C.

Procedures for use of the standard Coillte Teoranta

•

Page 4: From your definition of WMU, we are taking a WMU to mean a Coillte “forest”, each of which has it’s own Forest Management Plan.

•

Further clarification: The problem has to do with the definition of the scale of the WMU. From your description, this would suggest that, for Coillte, the WMU is our "forest".

However, if we have targets for e.g. biodiversity, LISS, etc. then this means that for each forest we would have to have e.g. 15% biodiversity. At the moment, this requirement under FSC is at our "District" level - this is a much larger area than our "forest". The forest level would create a much greater problem for us.

Application to different scales of woodland Page 28 of 52

ITGA

•

This paragraph which forms the basis of this Standard does not recognise the structure and nature of Ireland’s private forests.

With our private forest estate’s small average size holding of c. 8 hectares and its fragmented nature this draft Standard does not accommodate the typical private forest owner and many of the Standard’s Requirements are onerous and economically unattainable for timber growers.

The private grower is considerably disadvantaged by the application of the requirement that ‘All woodlands seeking to obtain certification, regardless of size, must comply with the requirements of this standard.’ Their poor economies of scale work against achieving certification on the basis of this requirement and consequently private forest owners are considerably disadvantaged in this draft Standard.

Economic sustainability forms one of the pillars of sustainable forest management and consequently should form part of the PEFC Standard by recognising the constraints on private forest holdings.

Flexibility in meeting requirements Coillte Teoranta

•

Page 5: o

This is quite weak and suggests that if a forest owner cannot reach the standard, then he/she can opt out and the CB has the responsibility of making the call.

o

What does “appropriate specialist” mean?

Transparency •

Page 6: For real transparency, the names of the people involved in the process should be on the document.

Coillte Teoranta

•

Independent body for dispute settlement – again, how do we know if this person/body is independent?

I.F.S. Asset Managers Limited

•

Disputes need to be resolved quickly and efficiently and we would suggest specific realistic timeframes be established to ensure that commercial considerations of forest owners are not impacted due to unnecessary delays or abuse of the system.

Coillte Teoranta

Dispute procedures

Interpretation and revision of the standard I.F.S. Asset Managers Limited

•

Reference to ‘Republic of Ireland’ in Company’s objectives: This should be changed to "Ireland". (See under ‘Preparation of the draft PEFC Ireland Forest Certification Standard’ above.)

Page 29 of 52

Section 1 Compliance with the law and conformance with the requirements of the certification standard Sub-section 1.1: Compliance and conformance •

Coillte Teoranta

Section 1.1.2:

•

I.F.S. Asset Managers Limited

o

What does “relevant” mean?

o

Is Appendix A exhaustive e.g. freshwater pearl mussel?

1.1.2 Guidance I think it would be important to outline the term “interested parties” to exclude certain non-forestry groups and those who seek to promote their own agenda. Perhaps a definition of “interested parties” could ensure that only those parties living in close proximity to a certain forest area e.g. within a radius of 5km, or those groups with a registered membership of more than 5,000 e.g. Birdwatch Ireland could raise issues of non-compliance. This would ensure that compliance will not be hindered by groups seeking to achieve notoriety at the expense of forest owners.

Sub-section 1.2: Protection from illegal activities Coillte Teoranta

•

1.2.1 What does ‘reasonable’ mean? Bye-laws may not be sufficient in relation to unauthorised recreational use

PFCI Ltd

•

1.2.1 Add to Guidance - littering.

I.F.S. Asset Managers Limited

•

1.2.1 Guidance: Suggest adding the illegal lighting of fires and/or burning of scrubland.

Section 2 Management planning Preamble Dr Niall O’Carroll

•

I am at a loss to understand the fashion for use of the word ‘stakeholder’ (primary meaning: An independent party with whom each of those who make a wager deposits the money wagered. Source; Shorter O.E.D.) when what is actually meant is ‘interested party’ or ‘concerned party’.

IFA

•

Management plans are desirable at forest level and assist a forest owner to maximise return from the forest, however it must be recognised that the detail required in management plan as well as multi-resource inventory go beyond current requirement and place an additional cost Page 30 of 52

on the forest owner.

Coillte Teoranta

•

“should aim to maintain or increase……” not in all cases.

What about creation of open space in riparian areas or tree clearance for bog restoration?

Sub-section 2.1: Documentation Coillte Teoranta

•

2.1.1: Multi-resource inventory needs to be defined. What needs to be included in a Management Plan?

PFCI Ltd

•

2.1.3: Add – There shall be an annual budget estimate prepared on forest income and expenditure.

Rationale - the forest business plan (FBP) will use the forest management plan and the annual forest budget estimate as information sources.

IFA

•

2.1.1: Please could you expand on what level of information will be required in the multi-resource inventory? There is no additional information in the Glossary or Appendices.

Sub-section 2.2: Productive potential Coillte Teoranta

Teagasc

•

2.2.1 It may not always be appropriate to rehabilitate degraded forest ecosystems e.g. really poor lodgepole pine area on very wet bog where the measures to rehabilitate may cause ecological damage.

•

2.2.2 Circumstances where harvest levels exceed increment – is this on a WMU basis?

•

2.2.4 Is this not Chain of Custody rather than forest certification?

•

2.2.2: Requirement and guidance are not very clear-cut.

Verification: "demonstrated control of thinning intensity" does this mean that continuous thinning control is required or is it sufficient to have one thinning control plot?

Dr Niall O’Carroll

•

2.2.1: Guidance. Why are the functions of woodlands consistently listed in the order 1. ecological 2. social and 3. economic, when woodland owners invariably regard the economic function as the primary one? Is this form of PR window-dressing?

Sub-section 2.3: Implementation and revision of the plan Coillte Teoranta

ITGA

•

•

2.3.2: o

Fauna and flora, particular key indicator species – this needs clarification.

o

Means of verification – very vague and needs clarification.

o

Guidance on supervision – supervision of whom or what?

2.3.2 Requirement:

Page 31 of 52

For a small woodland owner the information requirement is excessive, costly and ultimately unnecessary for small forest areas, particularly: The parameters monitored will at a minimum include: Woodland composition and structure, Fauna and flora, particular key indicator species, Other ecological, social and economic aspects.

IFA

•

2.3.1: It is very important that flexibility is maintained in the management plan to allow for factors as varied as market opportunities and ground conditions etc. The PEFC standard should not be an extension of farming by calendar, operations should take place at the best time to maximise the management objectives.

•

2.3.2: The monitoring of the forest represents a significant additional time and cost burden for forest owner. It would be very helpful if a Monitoring Record template was produced to provide the requested consistence and assist forest owners/managers. Farmers also have concerns about making this information publicly available and would suggest that information is only available anonymously and in amalgamated format.

Section 3 Woodland design: creation, felling and replanting Sub-section 3.1: Assessment of environmental impacts Forestry Division, DAFF

Coillte Teoranta

•

Section 3.1.1, Guidance, 4th bullet point – insert NHA.

•

Section 3.1.1, page 16, Guidance, last paragraph – thresholds for requirement of a full EIA – gives the impression that environmental assessment mentioned in text above is EIA but not a full one.

•

Section 3.1.1, page 16, Guidance, last paragraph – thresholds for requirement of a full EIA. Amend > 50ha to > 50ha.

•

Section 3.1.1, page 16, Guidance, last paragraph – thresholds for requirement of a full EIA. Insert:

•

o

Felling: deforestation for the purpose of conversion to another type of land use, where the area to be deforested would be greater than 10ha of natural woodlands or 70 hectares of conifer forest.

o

Replacement of broadleaf high forest by conifer species, where the area involved would be greater than 10 hectares.

3.1.1 Guidance: o NHA should be included. o ID of fauna and flora to what level?

PFCI Ltd

•

3.1.1 Guidance: additional guidance proposed for requirement ‘….shall be assessed before operations, in particular soil –disturbing operations, are Page 32 of 52

implemented …..’: consider including in the guidance notes the following sentence - “Environmental assessments to include operational impacts on soil, water, bio diversity and people”.

Teagasc

Dr Niall O’Carroll

•

3.1.1: how will PEFC deal with establishment that wasn’t grant-aided?

Will the same assessments/checks be carried out?

•

3.1.2: how will PEFC deal with changing environmental requirements?

E.g. will FEPS guidelines continue to be implemented?

•

3.1.1: Guidance. I believe this would place an unreasonable imposition on forest owners/managers.

Sub-section 3.2: Location and design Forestry Division, DAFF

Coillte Teoranta

•

Section 3.2.2, page 18, Guidance, second last line – insert ‘Forestry Schemes Manual’.

•

Section 3.2.4, Requirement – does not appear to take consideration of the size of the woodland.

•

3.2.1:

•

•

•

Woodland Managers Ltd

o

The requirement mentions a range of visual, cultural and ecological vales but the guidance only covers landscape guidelines.

o

Why only ‘diverse woodland edge’?

3.2.2: o

Use of diverse provenances – why?

o

Retention of open ground – how much?

3.2.3: o

Gradually restructured – over years or rotations?

o

In guidance, should you use the Irish or UK guidelines?

3.2.4: o

Are both Irish and UK guidelines required? Stepping up to the UK standard would be very demanding.

o

No mention of felling coupe size or justification for such coupes.

o

25% of the woodland area – is this the WMU?

o

No mention of taking into account adjoining woodlands.

o

Difficult to see D standing on its own.

•

Taken as referring to 3.2.4 Requirement: this point does not seem to be informed by historical planting policy and practice. While the design plan could perhaps address it there should be an exception "Where the scale / location / species composition of the original design is such that no useful environmental, economic or social purpose would be served”.

•

3.2.4 (a): This would probably apply to most coniferous plantations growing on wet mineral soils in the western half of the country. In Page 33 of 52

woodlands which are less than windthrow classification of 4 there may be little risk of windthrow but an increased risk of windbreak when small coupes are felled within the wood.

ITGA

•

(d): Owners right to sell timber at a time of their choosing to improve returns when timber prices are high, or to generate cashflow at anytime because of personal circumstances could be severely restricted. It could be very difficult demonstrate that there would be a financial penalty in premature/delayed felling - it is not easy to forecast prices.

•

There is also the additional management and silvicultural operations to be considered where felling would have to take place over a twenty period if applied to individual properties. Depending on the length of roadline within the wood subsequent harvesting operations could have to be extracted over previously felled and restocked areas, causing problems with rutting and ground compaction due to a lack of brash on extraction routes. If the principle is applied on a broader scale in the sense that individual owned woods can be felled within a management unit, there would be issues in deciding this with any fairness when all owners may want to fell when market conditions are good.

•

3.2.1 Means of Verification: Design plan – This is a very onerous, costly and unnecessary requirement for private forests.

•

3.2.2 Requirement: This should not be applicable to smaller forest areas.

•

3.2.3 Requirement: This is a very onerous, costly and unnecessary requirement for typical private forests.

•

3.2.4 Requirement: o

It is not appropriate to employ the UK Forestry Commission Forestry Practice Guide; the Code of Best Forestry Practice for Ireland should be referred to here.

o

The requirement that ‘All felling and replanting shall be in accordance with a design plan appropriate to the scale of the proposed felling and the sensitivity of the landscape’ is a very onerous, costly and unnecessary requirement for typical private forests and should be removed.

o

The requirement that ‘The rate of felling shall be in accordance with the design plan and shall not exceed 25% of the woodland area in any five year period except in one of the following circumstances’: This is not workable in a significant proportion of the private forest estate due to the even aged nature and structure of private woodlands and should be deleted from the Standard for all private forests including areas up to 100 hectares. To only allow 2 hectares to be felled in the average 8 hectare even aged private forest over a 5 year period is entirely uneconomic and unworkable and this requirement should not form part of the Standard for private woodlands.

o

With reference to exceptions (a) to (d): there is a considerable economic cost in these requirements on private forest owners and Page 34 of 52

they should not be required for private forest areas under 100 hectares.

PFCI Ltd

•

3.2.4 – Consider including in the list of circumstances: “(c) Where clear fell would expose the remainder of the woodland to premature or attritional wind blow.”

I.F.S. Asset Managers Limited

•

3.2.4 With reference to the rate of felling not exceeding 25% of the woodland area in any five year period: suggest a range of felling rate of 25% to 40% to take account of commercial considerations which may present.

Teagasc

•

3.2.4:

Dr Niall O’Carroll

IFA

o

What is the definition of a woodland area?

o

Are small woodlands subject to the 25% rule or is that catered for under d)?

•

3.2.2: (Diversity). Insistence on diversity may frustrate the owner’s objectives. (What has diversity to do with sustainability, which I thought was the main aim of the certification process? I know of no rigorous experimental or observational evidence that there is any such connection.)

•

3.2.4: Requirement. The Forestry Commission operates in Great Britain only, not the UK.

•

3.2.2: The demands of this requirement are excessive for small-scale forest owners. It may not be possible or viable from a production perspective for a small forest to provide such a range of species diversification, phased planting, etc. This requirement should be for large forests only.

•

3.2.3: Again this may not be possible in small forests and should be a requirement of larger forests only.

•

3.2.4: This requirement is unworkable in small-scale forests. The average size of a farm forestry plantation is 8 hectares, this would that the maximum area that could be harvested at one time should not exceed 2 hectares. This would mean that mechanised harvesting would not be an option and would significantly reduce the viability of harvesting. Too demanding for small-scale forest owners and should be amended.

Sub-section 3.3: Species selection Coillte Teoranta

•

3.3.1 What is meant by a range of genotypes?

•

3.3.2: o

What about native conifers?

o

What species are naturalised broadleaves?

Page 35 of 52

o •

Woodland Managers Ltd

•

Should open space requirement not also apply to woodlands <10ha.

3.3.3: o

What about invasive non-native trees?

o

All introductions shall be carefully monitored – by whom?

o

It reads as if the standard will require the re-introduction of oncenative animals?

3.3.2: This should be altered to 68% primary species (80% of 85%) and 17% secondary species (20% of 85%) to comply with Forest Service requirements.

In areas prone to frost damage Norway spruce is often planted pure, and flexibility is required in such situations.

ITGA

•

3.3.1 Requirement (b): This provision infers that non native species should be inherently disadvantaged in species selection unless ‘it shall be shown that they will clearly outperform native or naturalised species in meeting the objectives’. This proposal disadvantages Irish forestry and should be removed.

If this provision formed the basis of Ireland’s national forest policy from the 1940’s we would not have the forest industry we enjoy today which is based on non-native conifers. Back in the 1940’s we were not in a position to ‘clearly’ show that the most successful non-native conifers ‘will clearly outperform native or naturalised species in meeting the objectives.

This requirement acts against innovation and development in species selection.

•

3.3.2 Requirement: Economic sustainability forms one of the pillars of sustainable forest management and should form an equal part of the PEFC Standard. To have this proportion of unproductive area works against the economic sustainability of forestry. The requirements for open space and native or naturalised broadleaf should not apply to areas under 50 hectares.

PFCI Ltd

•

3.3.1 and 3.3.2: One of the problems associated with modern planting grant schemes and replanting conditions is the unscientific practice of planting to percentage numbers e.g. 80% SS 20% JL. Why not use species silvicultural characteristics , soil nutrition and stability and landscape attributes as decision makers in the selection of species rather than a craven response to the numbers game based on the whims of a few and certainly not forest owners or managers.

It is suggested that section 3.3.1 (a) be replaced as follows: Page 36 of 52

o

“the planting of trees and selection of species shall be based on the principle of planting the right tree in the right place, having due regard to the land owners objectives in terms of economics , social benefits and environmental considerations.”

o

Add in to Section (c) as follows: “up to 15%” of the site shall be managed for biodiversity including up to 10% allocated to open space.

Teagasc

Dr Niall O’Carroll

IFA

•

Based on the forgoing is it suggested that requirement 3.3.2 be dropped and guidance relating thereto be combined with guidance re 3.3.1.

•

3.3.1: are allowances being made if quality / appropriate stock may not be available at that particular time?

•

Spelling: 3.3.1 guidance – comma required after possible.

•

3.3.2 Requirement:

•

o

The concept of ‘primary’ and ‘secondary’ species needs to be defined.

o

Why is ‘open space’ i.e. waste ground, obligatory?

3.3.2: Too specific, the composition of the woodland should be dependent on the management objectives of the forest. IFA propose that this requirement is incorporated into 3.3.1.

Sub-section 3.4: Silvicultural systems Coillte Teoranta

•

3.4.1: o

10% requirement for LISS is far too much.

o

In guidance, no mention of small coupe felling or thresholds of coupe size.

ITGA

•

3.4.1 Requirement: This provision should be amended by deleting requirement (a) which is too onerous a requirement for the small and average sized growers - this standard must be economically sustainable if it is to work.

Teagasc

•

3.4.1: add the following bullet point under Guidance: "economics and value for money".

IFA

•

3.4.1: There are considerable economic consequences associated with this requirement which limit the management options available to forest owner/manager if forest is over 100 hectares.

If the forest is 100 hectare but fragmented into a range of smaller forest parcel is the farmer still required to adopt a low silvicultural system with a preference to natural regeneration?

Dr Niall O’Carroll

•

3.4.1 Guidance:

•

Also define ‘lower impact silvicultural systems’ (lower than what?)

Page 37 of 52

•

This appears to be an attempt to eliminate clearfelling. Clearfelling is the ‘historical management practice’ in Ireland.

•

Why should ‘views of local people’ be taken into account since it is well known that such people will invariably object to any change? Adherence to general legislation and guidelines should be adequate.

Sub-section 3.5: Conversion to non-forested land Forestry Division, DAFF

•

Section 3.5.1 Guidance – Insert ‘See Section 3.1.1 for guidance on thresholds for requirement of an EIA’.

Coillte Teoranta

•

3.5.1 Requirement:

ITGA

•

o

Replace restoration with transformation.

o

Is the onus on the landowner to get the planning permission before the transformation?

3.5.1 Requirement: o

(b) 1: ‘there is no evidence of substantial dispute’ should be removed.

o

(b) 3 bullet 1: should be amended: ‘the new land use will be more ecologically (add socially or economically) valuable than the woodland’.

It must be recognised that there are 3 pillars to sustainable forest management.

Teagasc

•

3.5.1 Requirement: will this reflect changes to the Forestry Act?

Dr Niall O’Carroll

•

3.5.1: Guidance. In the case a general felling licence the imposition of a replanting condition is mandatory (Section 49 (3) Foretry Act 1946; “There shall be attached…” emphasis added) and is not therefore ‘at the Minister’s discretion’.

Section 4 Operations Sub-section 4.1: General Coillte Teoranta

PFCI Ltd

•

4.1.1 Requirement: o

What are sensitive soils?

o

What is local?

o

What is heavy machinery?

•

4.1.1 Guidance: in terms of recreation, operations may effect recreation and unplanned recreation may influence other forest values.

•

4.1.1 – Guidance – Impacts to include people.

Page 38 of 52

Sub-section 4.2: Harvesting operations •

Section 4.2.1, page 24, Guidance – best practice for harvesting operations in the Forest Harvesting and the Environment Guidelines is not confined to the section on Harvesting Operation Guidelines – it also includes the section on Harvest Planning Guidelines and Harvest Site Restoration Guidelines.

•

Section 4.2.1, page 24, Guidance – relevant section in the Forestry and Water Quality Guidelines also includes the section entitled Chemicals, Fuels and Machine Oils.

Coillte Teoranta

•

4.2.2 Guidance – no mention of sediment, soil integrity or carbon issues.

PFCI Ltd

•

4.2.1 – Verification to include harvesting plan complete with Maps.

Teagasc

•

4.2.2: The Requirement and the Guidance contradict each other: the Requirement refers to a risk (potential negative impact), the Guidance refers to a result (there has been negative impact). Verification does not clarify this. What is required is a properly documented assessment prior to such operations.

•

4.2.4 Requirement: Minimum loss or damage to what?

•

4.2.4 Guidance: No reference to habitats in Guidance.

•

4.2.3: Requirement. Why must there be ‘no burning of lop and top’?

Forestry Division, DAFF

Dr Niall O’Carroll

Sub-section 4.3: Forest Roads Coillte Teoranta

•

4.3.1 Guidance: o

Do roads over 2km currently require an EIA?

o

Should forest trails be included in this category?

Section 5 Protection and Maintenance Sub-section 5.1: Planning Woodlands of Ireland •

I would like to submit the recent document commissioned by WoI on deer and forestry. In particular the recommendations in the Executive Summary should help re the draft standard.

N.B. Executive Summary is in Annex 3.

Full report: http://www.woodlandsofireland.com/DeerStrategy.pdf

Coillte Teoranta

•

General comment on game management: The main concern here is the control of hunting activities in order to Page 39 of 52

protect declining or endangered game and other quarry species.

Hunting levels in Ireland are currently controlled under the Wildlife Acts 1976 (as amended) 2000 through the “open seasons” order which specifies which species can be legitimately hunted and during what periods. There are currently no bag limits imposed on these species, and bag returns are not a legal requirement.

It would not be practical for Coillte or other landowners to appraise abundance of these quarry species or have the skills or expertise in setting target levels.

We would like to see the standard to reflect the current legal situation regarding hunting/shooting in this country and refer to the role of the NPWS , as being the regulation body to control sustainable hunting levels in this regard.

•

Deer Management: The requirements of the standard for land managers/owners with regard to deer is a bit vague to say the least, and depends greatly on what category you consider deer to fit into – “game” , “invasive species” , “exotics” ,“ non wood products”, “forest pests” or all the above.

This certainly needs clarification.

•

PFCI Ltd

5.1.4: o

Replace wildlife officer with NPWS Conservation Ranger.

o

Are hare not protected?

•

5.1.6 Should a fire plan not be required for all sites?

•

5.1.1 – Verification to include fire plan.

•

5.1.3 – This writer is not aware of an over arching National Policy, Strategy or Action Plan relating to the management of Deer in Irish forests. For example, deer are a very serious problem for forest owners in County Wicklow and becoming a problem for forest owners in the west of Ireland where there was no deer problem 20 years ago. Managing the problem is all the more difficult due to the scattered nature of forest locations, the size of forest blocks and the difficulty of forest owner cooperation generally.

Co-operation at national level between FS, NPWS, forest owners and various deer interest groups is weak.

Based on the foregoing it is a rather tall order to expect an individual forest owner to have other than aspirations with regard to deer Page 40 of 52

management objectives at this time.

Teagasc

•

5.1.3 - Needs to be revisited with a view to the practical/ pragmatic management of deer in Irish Forests.

•

5.1.3: what does locally mean?

•

5.1.6: isn't a fire plan a Forest Service requirement? See Forest Service Protection Guidelines.

Sub-section 5.2: Pesticides, biological control agents and fertilisers Forestry Division, DAFF

Coillte Teoranta

•

Section 5.2.1, page 29, Guidance – suggesting adding ‘Reporting of pest/disease to relevant authority, where appropriate’.

•

Section 5.2.3, page 30, Guidance, first sentence – insert ‘and the Guidelines for the Use of Herbicides in Forestry’.

•

Section 5.2.3, page 30, Guidance, 5th bullet point – what does this mean – give clearer instructions – the area of the site should be given.

•

Section 5.2.3, page 30, Guidance, 6th bullet point – what does this mean – what is the difference between this and the 5th bullet point – give clearer instructions.

•

Section 5.2.5, page 31, Guidance, second sentence – insert ‘and in the Forestry and Water Quality Guidelines’.

•

5.2.2 Why should you minimize use of biological control?

Biological control is a fundamental component of integrated pest management so any sustainable integrated pest management strategy should seek to increase (rather than decrease) the use of biological control, where the risk to non target organisms has been established as small by the scientific community. One of the well recognised functions of enhanced biodiversity is that it maintains / enhances the habitat available to natural enemies and provides stable refugia where natural enemy populations can be sustained (e.g. field margins in agriculture). If on one hand in sustainable systems we aim to increase biodiversity in order to enhancing predator-prey interactions, it is then illogical to also state that the use of biological control agents should be minimised in sustainable forest management. Therefore, we suggest the statement ‘minimise the use of pesticides and biological control agents in the forest’ be amended to ‘minimise the use of chemical pesticides and promote the use of biological control agents’.

•

No mention of biodegradable lubricants.

•

5.2.3 Pesticides and biological control should not be included together as they are here.

Herbicide guidelines in Appendix A are way out of date now.

•

5.2.3 This statement ‘Where pesticides and biological control agents are Page 41 of 52

to be used : the forest owner shall justify the usage and the reason for not selecting ‘non-chemical methods’’ appear to be a contradiction. As biological control agents are ‘non-chemical methods’, this criteria should be amended to read either: A ‘Where chemical pesticides are to be used : the forest owner shall justify the usage and the reason for not selecting ‘non-chemical methods’’, or B ‘Where pesticides and biological control agents are to be used : the forest owner shall justify the usage and the reason for not selecting ‘cultural control methods alone’’.

•

5.2.5 Be consistent in whether the English or American spelling of fertiliser is used.

PFCI Ltd

•

5.2.4 – Add to guidance – Disposal of empty containers to be in accordance with procedures as set out in 5.4.1.

Dr Niall O’Carroll

•

5.2.5. Requirement. Foliar analysis is not always necessary as a basis for forest fertilization. An experienced forester can diagnose nutrient deficiencies by means of visual assessment.

Sub-section 5.3: Fencing Forestry Division, DAFF

•

Section 5.3.1, page 31, Guidance – Insert ‘Fencing requirements are specified in the Forestry Schemes Manual’.

Dr Niall O’Carroll

•

5.3.1: Requirement. This requirement is absurd. See Forestry Act 1946 Section 41 (1) (a) (ii) and (b). Any sensible forest manager will avoid the cost of fencing if possible.

Sub-section 5.4: Waste management No comments received.

Section 6 Conservation and enhancement of biodiversity Sub-section 6.1: Protection of rare species and habitats Forestry Division, DAFF

•

Section 6.1.1, page 33, Guidance, first paragraph – all the National Parks, apart from the core area of Killarney National Park, are not statutorily designated – they are protected as state owned land. The Department of the Environment, Heritage and Local Government, endorsed by successive governments, abides by the criteria and standards for National Parks as set by the IUCN.

•

Section 6.1.1, page 33, Guidance, end of last paragraph – Insert ‘Notifiable Actions do not apply where a licence or permission is needed Page 42 of 52

from a planning authority (e.g. planning permission) or another Minister (e.g. a felling licence or afforestation approval)’.

Coillte Teoranta

Teagasc

Dr Niall O’Carroll

•

Section 6.1.2, page 33, Guidance, end of first paragraph – Insert ‘and the Forestry Schemes Manual’.

•

Section 6.1.3, page 34, Guidance, second paragraph, end of first sentence – insert ‘and Threat Response Plans’.

•

Section 6.1.3, page 34, Guidance, second paragraph, second sentence – insert ‘and TRPs’ after SAP.

•

6.1.1 Guidance note fails to reference pNHAs and Nature Reserves.

•

6.1.2 Guidance note states “significant” woodland management operations. Clarity over what constitutes significant required.

•

6.1.3 The requirement states where a rare or endangered species is known to be present. Other standards specify where significant populations of such species are known.

•

6.1.1: Verification: proof of consultation with statutory agencies.

•

6.1.2: does this include both flora and fauna?

•

6.1.3: are rare and endangered species known to be present as a result of 6.1.1 and 6.1.2?

•

6.1.2: Requirement. What serious forest manager will regard maintenance of biodiversity as ‘the primary object of management’?

Sub-section 6.2: Maintenance of biodiversity and ecological functions Forestry Division, DAFF

•

Section 6.2.1, page 34, Requirement – Forest Biodiversity Guidelines do not require minimum of 10% retained woodland habitat – it requires 5 – 10% retained habitat which may be woodland and non-woodland habitat.

Coillte Teoranta

•

6.2.1 The minimum 15% requirement is unclear whether this is the woodland itself, woodland management unit or landscape unit.

The 10% threshold of retained woodland habitat may not always be appropriate, e.g. raised bog habitat. Better to change it to 10% retained area for biodiversity.

•

6.2.2 “some” over mature trees. Clarity required over what constitutes some.

Woodland Managers Ltd

•

6.2.1 Requirement: Woodland habitat should recognise hedgerows, light scrub areas.

ITGA

•

6.2.1 Requirement: It is important for the Standard to recognise that economic sustainability forms one of the pillars of sustainable forest management and should form part of this PEFC Standard. To have this additional proportion of unproductive area works against the economic Page 43 of 52

sustainability of forestry. These requirements for open space and native or naturalised broadleaf should not apply to areas under 100 hectares.

IFA

•

6.2.1: This places an additional cost burden on forest owner through loss of income generation. The requirement to manage a minimum of 15% with conservation and biodiversity as the primary objective should be reduced to 10%.

Sub-section 6.3: Conservation of semi-natural woodlands and plantations on old woodland sites Coillte Teoranta

ITGA

Teagasc

Dr Niall O’Carroll

•

6.3 Old woodland definition is poor. Areas that had forest cover in 1830 may now be developed for other land use. Needs to be changed to include areas with continuous forest cover since 1830.

•

6.3.1 LISS does not specify threshold for small coupe felling size. Does the FIPS 1998 planning system identify “semi-natural” woodlands. What are the explicit criteria, they should be outlined in this document.

•

6.3.2 “Remnant features” of old woodlands is cited frequently. Clarity is required and a list of such features should be appended to the document.

“Operations should not adversely impact the sites’ values” ~ what values are these? Monitoring the “response” of remnant features ~ response needs to be clarified, how are such features intended to respond?

“Assessment of the current state of biodiversity” this sentence may be impossible to realise on the ground as it encompasses all plants, animals and fungi associated with forest ecosystem. Needs to be changed.

•

6.3.3 Definition of native species for Ireland along with a list needs to be included.

•

6.3.2: The requirements are simply too onerous for the typical private forest owner and are unworkable and will work against the Standard being adopted by private growers. The above requirements should not apply to areas under 100 hectares.

•

6.3.3: The requirements are too onerous for the typical private forest owner are unworkable and will work against the Standard being adopted by private growers. The above requirements should not apply to areas under 100 hectares.

•

6.3.1: a, b and c. This should be read as a and b and c rather than or?

•

6.3.2: a more detailed definition may be preferable.

•

Spelling: 6.3.2 guidance - principal vs principle.

•

6.3.3: first paragraph of Requirement: natural regeneration of native species is also acceptable? Sentence is confusing.

•

6.3.2: Guidance. Must all forest owners and managers have access to the 1830s O.S. maps, which are not available in print?

Page 44 of 52

Sub-section 6.4: Game management Woodlands of Ireland •

I would like to submit the recent document commissioned by WoI on deer and forestry. In particular the recommendations in the Executive Summary should help re the draft standard.

N.B. Executive Summary is in Annex 3.

Full report: http://www.woodlandsofireland.com/DeerStrategy.pdf

Coillte Teoranta

Teagasc

•

6.4.1 Hunting should not threaten the viability of “any” particular species.

This definition is far too wide. It may be impossible to ascertain the viability of all or any species.

•

6.4.2 This requirement needs to respect and acknowledge the legal protection that some predator species enjoy in Ireland and predator control may only be conducted in accordance.

•

6.4.2: sentence is confusing and open to different interpretations.

Section 7 The community Sub-section 7.1: Consultation Coillte Teoranta

•

7.1.1 Requirement: o

What does local mean?

o

Is land sale considered a high impact operation?

I.F.S. Asset Managers Limited

•

Local people and relevant organizations should be defined to exclude certain non-forestry groups and those who seek to promote their own agenda. Perhaps a definition of “interested parties” could ensure that only those parties living in close proximity to a certain forest area e.g. within a radius of 5km, or those groups with a registered membership of more that 5,000.

IFA

•

7.1.1: Consultation with local people or relevant organisations places significant burden on small-scale forest owners. Do you have to consult with all local people and organisations? What level of consultation is required? Is it required for every operation or just high impact operations?

Sub-section 7.2: Woodland access and recreation including traditional and permissive use rights Coillte Teoranta

•

7.2.2 Guidance is quite weak as all access may be denied under bullet one.

Page 45 of 52

ITGA

•

7.2.2 Requirement: Remove ‘in certain circumstances’.

The Standard should recognise private forest ownership rights and the forest owner/manager should not have to make a case for not allowing forest access to the public.

PFCI Ltd

•

7.2.1 & 7.2.2: Irish Land Law, including access and other rights is complex hence care is needed re the use of language and words in 7.2.1 and 7.2.2, for example the word “Customary” is difficult to define in legal terms and perhaps best left out.

Sub-section 7.3: Sites with recognised specific historical, cultural or spiritual significance Forestry Division, DAFF

•

Section 7.3.1, page 41. Include the terms Recorded Monuments, Registered Historic Monuments and Monuments in State Ownership.

Sub-section 7.4: Rural economy Coillte Teoranta

•

7.4.1 Is this actually legal under Irish/EU law?

ITGA

•

7.4.1 Requirement: Replace ‘respond’ with ‘consider’ in: ‘….shall promote the integration of woodlands into the local economy and respond positively to local requests….’

Sub-section 7.5: Minimising adverse impacts Coillte Teoranta

•

7.5.1 “timber traffic” – change wording.

PFCI Ltd

•

7.5.1 – add to guidance – Keeping of a complaints register.

Section 8 The Forestry Workforce Sub-section 8.1: Health and safety PFCI Ltd

•

8.1.1 – add to guidance – Accident record book.

Sub-section 8.2: Training and continuing development Teagasc

•

8.2.1: the ‘and/or’ refers to? Confusing sentence.

Sub-section 8.3: Workers’ employment rights No comments received.

Sub-section 8.4: Insurance No comments received.

Page 46 of 52

Glossary of terms Appropriate assessment Forestry Division, DAFF

•

It is not a screening study. The definition as per the recently published guidelines by DoEHLG is ‘An assessment carried out under Article 6(3) of the Habitats Directive of the implications of a plan or project, either individually or in combination with other plans and projects, on a Natura 2000 site in view of the site’s conservation objectives’.

Lower impact silvicultural systems (proposed addition) Dr Niall O’Carroll

•

Also define ‘lower impact silvicultural systems’ (lower than what?)

•

At end of definition insert ‘Notifiable Actions do not apply where a licence or permission is needed from a planning authority (e.g. planning permission) or another Minister (e.g. a felling licence or afforestation approval)’.

Notifiable Actions Forestry Division, DAFF

Appendix A Forest Service Guidelines, Other Industry Codes of Practice and Rules and Selected Bibliography Biodiversity Forestry Division, DAFF

Coillte Teoranta

•

Insert ‘Forest Service (2008). Forestry and Freshwater Pearl Mussel Requirements. Site Assessment and Mitigation Measures. Forest Service, DAFF, Johnstown Castle Estate, Wexford’.

•

Insert ‘Forest Service (2008). Forestry and Kerry Slug Guidelines. Forest Service, DAFF, Johnstown Castle Estate, Wexford. http://www.agriculture.gov.ie/forestservice/forestservicegeneralinforma tion/kerryslugandotterguidelines/

•

Freshwater pearl mussel?

General Forestry Practice and Management Forestry Division, DAFF

•

Insert ‘Ward, D. (Ed) (1998). Guidelines for the Use of Herbicides in Forestry. 2nd Edition. Produced for the Forest Service by Coillte. The Forest Service, DAF, Johnstown Castle Estate, Wexford’.

•

Insert Forest Service (2000) Forestry and the Landscape Guidelines published by the Forest Service in the Department of the Marine and

Page 47 of 52

Natural Resources.

Coillte Teoranta

•

Insert Forest Service (2006) Forest Recreation in Ireland; A Guide for Forest owners and Managers published by the Forest Service, Department of Agriculture and Food.

•

Herbicide guidelines in Appendix A are way out of date now.

Appendix B Selected Bibliography Woodlands of Ireland WoI report: Deer and Forestry in Ireland: A Review of Current Status and Management Requirements.

Appendix C Forest Service Guidelines, Other Industry Codes of Practice and Rules and Selected Bibliography Legislation Forestry Division, DAFF

Dr Niall O’Carroll

No mention of: • Page 50 - the Habitats Regulations or the Environmental Liability Directive.

• Page 50 – no mention of National Monuments Acts 1930 to 2004 or of Cultural Institutions Act 1997.

Appendix C includes a reference to Maguire, B. A Review of Legislation that impacts on Irish Forestry (COFORD, 2001). This publication incorporates an error in that it appears to imply that it is an offence to uproot any tree under 10 years old.

Appendix C (b) Forestry Division, DAFF

No mention of: • The European Convention on the Protection of the Archaeological Heritage (was ratified by Ireland in 1997).

Appendix D Irish Red Data Books and Lists No comments received.

Appendix E Forest Service Referral and Notification System SACs and SPAs Forestry Division, DAFF

•

Afforestation is not automatically excluded from these areas.

Consultation period with NPWS is 2 months and if within a designated area the FS await a response from NPWS. Page 48 of 52

Annex 3 Deer and Forestry in Ireland: A Review of their Current Status and Management Requirements A report prepared for Woodlands of Ireland (Coillearnacha DĂşchasacha) by Paddy Purser MSIF M.Agr.Sc. (Forestry), Faith Wilson BSc (Hons) CEnv MIEEM, Dr Ruth Carden B.Sc. (Hons. Zoology), Ph.D. (Science, Zoology) - November 2009 Executive Summary There is no national deer management policy in Ireland and no co-ordinated system of deer population distribution or density measurement. There is no single authority with jurisdiction over the necessary components of a comprehensive deer management policy. Due to a number of factors, deer populations in Ireland are increasing at unsustainable rates and in many areas are already at unsustainable levels. Deer are currently impacting significantly on both the economic and biodiversity values of forest habitats and these impacts will reach catastrophic levels in the next ten years if the current system of lack of management remains unchanged. The consequences of not addressing deer management will result in deteriorating conservation status of native woodland as well as a reduction in hardwood and conifer wood quality, an inability for broadleaf woodland to regenerate thereby compromising their future viability, increasing damage to agricultural crops as a result of increasing deer grazing pressure, severe difficulties regarding the control of disease outbreaks such as foot-and-mouth, and an increase in collisions between motor vehicles and deer, which may result in serious injuries or death for the motorists involved.

Deer population management in Ireland is not practiced to any significant extent and foresters and forest owners have an ill-founded reliance on recreational hunters to achieve the necessary levels of deer management which will only be achieved through the use of professional deer management personnel. There is no properly established quality control system in place that could facilitate the development of a domestic market for venison. Without such a market, there is little chance for a sustainable future for deer management given the high cost of carcass disposal and the need for a disproportionate cull of females over males, for which some sporting revenue can be generated.

Deer management is not taught in any of the Irish 3rd level institutions, not even as a module of any of the three forestry schools. The financial cost of deer damage is difficult to quantify. It includes loss of timber value (estimated at â&#x201A;Ź34 million for recently planted broadleaved plantations), loss of biodiversity, reconstitution costs, potential EU fines for non-compliance with the Habitats Directive and potential loss of investment through failure to achieve the objectives of Forest Service grant schemes. In commercial conifer crops there is recent data that suggests that in areas of Ireland that have high deer densities presently, up to 22% of the potential revenue of the crop amounting to â&#x201A;Ź3,800/ha may be lost. Much is to be learnt from our European neighbours where there are established deer management cultures, policies and practices. There is an immediate need for a fundamental change in deer management in Ireland. This can only be achieved through the establishment of a dedicated national or all-Ireland deer management unit, similar to the Scottish Deer Commission or the UK Deer Initiative.

It is recommended that an Irish deer management unit be established with adequate statutory powers and budgets to effect the necessary regulatory, management, research, educational and developmental changes that can result in a deer management system that is fully integrated with forest management and other land use and related policies. A National deer management unit can be established within an existing government Department, e.g. Department of the Environment, Heritage and local government via NPWS, as an interdepartmental agency or as an independent agency.

Page 49 of 52

It is also recommended that the general public is made aware of the negative impacts of deer to counteract the current benign and vulnerable perception many people have of deer. This will require a public relations campaign at national level as well as educational initiatives starting at primary school level.

Other key recommendations are provided relating to the development of: · A national or all-Ireland deer management policy. · Formal deer management training in Ireland. · A consistent and verifiable all-Ireland deer distribution records database. · Regionalised professional deer management strategies. · A cadre of professional deer managers capable of implementing deer management policies and strategies, leaving recreational hunters to hunt recreationally. · A consistent and verifiable all-Ireland deer densities records database. · A domestic venison market and the development of a quality assurance scheme for venison. · A recreational deer hunting strategy. · A more strategic approach to forest design, establishment and management taking deer management into consideration. · A number of pilot local deer management groups. · An awareness amongst road engineers and planners of the potential implications of increasing deer populations. · A database that includes all records of collisions between motor vehicles and deer, i.e. instigated by the Road Safety Authority in co-operation with An Garda Síochána and Local Authorities.

Full report: http://www.woodlandsofireland.com/DeerStrategy.pdf

Page 50 of 52

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