Introduction:

An Taisce have been requested to review the above mentioned paper, thus this is presented as a critical assessment of the concepts contained in the paper; the paper’s presentation of the economic, social and environmental performance of the Irish forestry sector; the of the presentation of the challenges and opportunities facing the forestry sector; and proposals for policy mixes that would improve sustainability prospects over the 2007-13 period.

Background:

While the authors state a minimum cycle of 40 years, COFORD (The National Council for Forest Research and Development) state rotation lengths of 30 years + for alder and 35 years + for Birch.  The minimum cycle stated in the paper should thus be stated at 30 years.

It is also important in the first statement, where the authors list the main aspects of Forestry sector in Ireland, to include that it is also an agent of significant environmental change.  To introduce the activity without reference to this fact does not make for a particularly balanced introduction of the issues. 

1.1  Forest Policy in Ireland

This section would benefit from the inclusion of the following policy framework for the development of the sector:

• The National Biodiversity Plan 2002 – 2006, which contains no less than 13 actions directly recommending specific improvements within the sector for the benefit of Biodiversity, and several additional actions relating to the integration of biodiversity concerns into all relevant sectors, including forestry
• The Heritage Council’s Policy Paper on Forestry and National Heritage, which looks at the potential of large-scale and inappropriate planting to cause considerable damage to Ireland’s heritage. It questions the sustainability of the current forest policy, and makes substantial recommendations for improvement of the sustainability aspects of the sector.  It also calls for national ‘forestry policy with targets for a 1:1 conifer to broadleaved ratio as most appropriate’.  Whilst the Policy Paper was published in 1999, most of the concerns raised in it have not yet been adequately addressed and thus the recommendations remain valid.

1.1.1 SFM

While it is stated in this section that Ireland’s forestry policy is intended to support SFM, it would benefit from referral to Irelands actual obligations to achieve SFM under the ‘Rio Declaration on Environment and Development’, our subsequent signing of the Helsinki Declaration (The quote included at the beginning of the section is taken from this agreement.) and our commitment to the European Forestry Strategy.  The principles of SFM are outlined in the appendix.

1.1.2 Public support for forestry’s social and economic benefits

The presentation in the paper of the importance of premiums paid for afforestation as a decision to afforest also begs questions about the sustainability of the sector.  Incentives to encourage real and early economic returns must be developed to counter this, for example through greater investments in the development of the hardwood timber sector and suitable sustainable broadleaf management systems, such as coppicing and continuous-cover forestry, which provide regular on-going economic benefit from valuable hardwood timber. 

Similarly, the lack of importance placed by the public on the value of timber sales should also be tackled through the positive demonstration of the far greater value of managed hardwood timber.  Instead we have a situation where our National Forestry Company consistently, and incorrectly, inform the public that “Hardwoods are not commercial, do not produce a return and require good agricultural land. If hardwoods are to be planted they should not be regarded as a commercial proposition.” (Michael Lowery, Chief Executive Officer, Coillte Teo).

There is a notable absence from this section of a description of environmental benefits, especially considering the strong public opposition to the sector’s current reliance on conifer plantations, with associated lack of environmental benefits and negative environmental impacts under certain circumstances.

The ‘environmental functions’ listed in table 4, as adapted from a European Commission document, are fully dependant on the type of forestry, with the functions listed bearing no relevance to conifer plantations which comprise of almost 80% of Irish Forestry, a situation not comparable to that of mainland Europe.  For example, industrial conifer plantations planted in linear rows are considered by many to have a negative landscape impact, rather then the ‘enhancement’ function listed.  Similarly, ‘preventing and stopping soil erosion’ is often not the case, where clearfelling at the end of the forest cycle is recognised to result in large scale soil erosion and associated ecosystem damage like siltation.

1.2   Economic performance of the Forestry Sector

One of the attractions stated for planting Sitka Spruce is ‘relatively certain financial returns’.  This comment, unless balanced by a statement of the even greater returns from hardwood due to high demand, a shortage of supply, and a higher intrinsic value, appears somewhat biased.  A ‘percieved’ certainty of financial returns would be a more appropriate comment in this instance.  According to the Heritage Council, global annual demand for industrial wood is set to grow to 2000 million m3 by 2015, with softwood accounting for 67% and hardwood 33%. This provides valid economic justification for increasing the percentage of broadleaved planting in Ireland. 

It is also the case that the economic viability of Sitka spruce is falling as supply exceeds demand and softwoods a face strong international competition. This is an important discussion point for the paper to include, especially with economic arguments forming the main incentive for continued reliance on sitka spruce. 

The failure to reach the 30% broadleaf target, which was set only under pressure from the European Commission, is a most serious failure on economic, social, and environmental terms.  The reasons not included in this paper for this failure include the very negative attitudes embedded in all sectors of the forestry industry towards the viability of broadleaf forestry in Ireland, poor investment in the development of a broadleaf afforestation, and poor investment in the hardwood timber industry.  In addition, Coillte, the State Forestry Board, target well below the 30 % broadleaf afforestation target.  Coillte’s ‘Strategic Plan for Wicklow’ (2006), a county with a long tradition of broadleaf forestry, aim for this district (E1) to reach 10% broadleaves in the next 45 years, falls unjustifiably short of the national target.   Most other plans have similar target figures.   As such Coillte are the only state forestry company not obliged to adhere to national forest policy. 

Environmental Performance

Whilst this section discusses the main policy developments relating to the issues, there is a lack of any real assessment of the actual environment performance as mentioned against policy objectives outlined in section 1.1. 

The magnitude of water quality issues associated to forestry in Ireland is understated in this paper.  Acidification is a major problem, now generally accepted and mitigated against by the designation of ‘acid sensitive’ zones.  Acidification is known to have significant negative effects on fish and other aquatic species. Whilst problems of phosphorous release are mentioned, the recent moratorium on felling in freshwater pearl catchments as requested from the European Commission demonstrates the lack of confidence in the guidelines as a mechanism to tackle these impacts.  Eutrophication caused by excessive fertilization of afforested lands is also a major contribution to the greater problem of eutrophication in Irish surface waters. 

Biodiversity can suffer greatly under afforestation, in the first instance through the loss of habitat, in Ireland mainly blanket bogs and biodiversity rich marginal land.  Biodiversity suffers further through degraded water quality (as above), including siltation of waterways resulting from clear felling operations.  The use of pesticides, particularly those that are toxic and persistent, in forest operations, has negative impacts on biodiversity. 

The extent to which biodiversity can persist in forestry plantations depends greatly on the type of afforestation, with monoculture plantations of alien conifers hosting little biodiversity once the canopy has closed, compared to far greater biodiversity associated with broadleaf plantations.  Thus the failure to meet broadleaf afforestation targets, as mentioned above, has serious implications for biodiversity.  The paper states some of our obligations to integrate the conservation of biodiversity to relevant cross sectoral policies, yet fails to mention that the Forest Service have still not formulated a Biodiversity Plan for the sector.  This could help progress the sector towards biodiversity concerns as a key element of sustainability.

Landscape: afforestation is not prohibited in protected areas of landscape listed in the 1977 inventory of Protected Landscapes.  New afforestation is ongoing in such areas.  This is an issue that needs to be addressed under the licencing procedures of the Forest Service.

2. Key issues and challenges faced for the future

The grouping of challenges under economic and societal must be expanded to include environmental.  These challenges are sufficiently large to be considered in their own right, and not, as is currently, under social challenges.  The challenges to halt and reverse the negative impacts of the sector to the environment and to sustainable development are neglected, and are instead referred to as a failure to achieve the ‘potential to provide environmental goods to society’. This is putting the cart before the horse.

The increased competition to the sector from new European member states must be met with a refocusing of the sector to providing quality hardwood products. This is also necessary to reduce our dependence on imported tropical hardwoods, a major issue in global sustainability terms. Ireland is described as the “most dynamic market in northern Europe”  by one particular company importing illegally felled Brazillian rainforest timber, whose Irish market was worth €2m in 2004 (Sunday Times, 4^th April 2005). According to the WWF, Ireland imports 40,000 cubic metres of wood products from suspect African countries alone.  Developing a native hardwood timber industry will take long term planning. 

3.3 Projected environmental trends

Under ‘business as usual’ there will continue to be damage to water quality, loss of biodiversity, and landscape impacts, all of which result from a lack of commitment from the sector to enforce the relevant legislative obligations and guidelines.  In addition the failure to meet the targets set for broadleaf forestry, that are such an integral component of increasing the sustainability ranking of the sector, will continue.  considerable efforts are required to bring this trajectory in line with the stated aims of sustainable development.

The contribution of financial support to the sector’s provision of amenity services must be regarded in the light of the huge land base that has been provided by the state to Coillte, the State Forestry Company, and the revenue provided to this company from the ongoing sale of this land bank for commercial purposes. 

4. Review of policy changes likely to make trajectory more sustainable

This section appears to focus more on improving the economic sustainability of the sector than reaching the basic environmental standards required to make the sector sustainable.  While several very valid recommendations are made, the paper would benefit from the addition of the following recommendations:

Species selection is only one element of sustainable forestry, but the attitude widely held in the sector regarding the exclusion of broadleaves as non-commercial is preventing the development of sustainable forestry in Ireland. 

The perceived sustainability of the sector as it currently exists is central to the continued support for a forestry policy.  To this regard the Heritage Council’s ‘Review of Ireland's CAP Rural Development Plan 2000-2006’ commented:

“Ironically for a measure emanating from an 'integrated' plan, the forestry measure would seem to be the greatest real threat to Ireland's farmland biodiversity and represents the greatest challenge facing the development of a sustainable rural development policy in Ireland.”

Recommendations for Discussion towards improving the sustainability of the Irish Forestry Sector:

• minimise the negative impacts of forestry through concerted efforts to comply with various International and European obligations placed upon the sector (including the CBD, and European Environment Directives)

• conduct independent research in to the extent to which the various Forest Service guidelines are adhered to; ongoing monitoring of compliance with guidelines, and develop mechanisms to ensure full compliance

• conduct an independent sustainability assessment of the forestry sector in Ireland as a tool to comprehensively ‘stock – take’ the current forestry situation and agree indicators and performance criteria with which to conduct ongoing assessments

• develop a Biodiversity Plan for Forestry in order to map the achievement of the sector towards the 2010 goal (to halt the loss of biodiversity by 2010), as required by the European Communication on Biodiversity, 2006.

• Improve the strategic approach to managing water catchment quality issues to ensure that the thresholds and risks for different geologies, soils and altitudes are being fully taken into account (HC)

• If the state forestry board is to contribute to the goal of achieving sustainable forestry in Ireland,   plantations of mixed species with increased structural and spatial diversity must be created as restocking of the estate proceeds.  This will greatly improve the sustainability of the estate.  Significant and specific efforts must be made in all 5 year plans, currently being finalised, to integrate the consideration of biodiversity in all relevant areas of Coillte’s Forest Management Systems

• Provide greater guidance on species, provenances and planting patterns for meeting specific objectives. In particular a more flexible approach should be taken to planting densities, mixed species stands, early thinning, late felling and creation of open space in order to maximise biodiversity, landscape and recreational benefits (HC)