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)
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