An Taisce submission Re: Draft Environmental Requirements for Afforestation (2016) An Taisce made the following submission as part of the public consultation on the Environmental Requirements for Afforestation. Our comments were made in response to the following documents: (1) Document: ‘Environmental Requirements for Afforestation’ and (2) Policy change: To remove the application level limit of 20% on GPC1 type land (3) Land Availability for Afforestation - Exploring opportunities for expanding Ireland’s forest resource. In our submission we highlighted the impact of Irish forestry under the headings of Biodiversity, Water, Landscape and Archaeology. We expressed our concern over the environmental impact of the proposed expansion of the national forest estate from a current national land cover of 10.7% to the targeted level of 18% by 2046. Given that afforestation will predominantly occur in areas of marginal land which harbor traditional extensive High Nature Value farming systems and associated semi-natural habitats An Taisce highlighted the inevitable negative impact that forestry will have on habitats and species associated with High Nature Value farming. The proposed expansion of the forestry sector will drive biodiversity loss and is not aligned with our legal obligations to protect habitats and species under the Habitats and Birds Directive or the obligation to prevent the deterioration/loss of High Status Sites under the Water Framework Directive. In particular we highlighted our concerns about the negative impact of forestry on species such as Hen Harrier and the Freshwater Pearl Mussel and on peatlands, rough grasslands and high status rivers. We made recommendations in relation to current forestry practices. Download the submission here.