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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)
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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