An Taisce have written to all of Ireland's Senators in advance of tomorrows Committee Stage debate on the Heritage Bill 2016. We have asked that take into consideration the attached letter on upland burning in tomorrow's debate. Recent research has been carried out by Teagasc here in Ireland and in the UK in 2017 which shed some important light on the distinction between controlled burning as a tool for vegetation management and wildfires.

Allowing burning in March as is proposed in Section 8 of the Heritage Bill 2016 will not address the core issues facing upland and marginal farming communities of which increased burning is a symptom. Facilitating burning in March will increase the risk of wildfires which are a serious threat to life, property, the environment and traditional grazing itself.

We hope that they will take our concerns into consideration.We hope some of the points will help to inform the debate tomorrow.

The Burning issue – Seanad Committee Stage – Heritage Bill 2016

Ireland's uplands are important cultural landscapes in which farming communities have shaped the environment and been shaped in turn by the environment since the Neolithic era. Our uplands continue to support the traditional extensive farming practices which have been lost in the lowlands and on which many rare habitats and species are reliant. These High Nature Value farming systems are of vital important given that they continue to support rural communities and indirectly drive industries like tourism. They have important cultural significance and alongside biodiversity they also play an important role in maintaining ecosystem services associated with our uplands such as water and flood regulation and carbon sequestration.

Over the preceding decades uplands have been subjected to the intensive and rapid processes of change associated with rural-restructuring and globalisation. The natural constraints which have preserved many important elements within these communities also pose significant challenges to the socio-economic viability of these communities. These challenges have been evident in the declining populations and ageing populations in many of our upland communities.

Fire has been used for centuries as a tool to generate and manage the semi-natural habitats in our uplands. In particular traditional controlled burns in tandem with sustainable grazing levels have sustained heather moorland habitats which support internationally important and threatened species such as Hen Harrier, Curlew, Red Grouse, Skylark and many more. Burning as a tool has many benefits and drawbacks which are open for debate but what appears clear is that the negative impacts of fires increase in line with their severity, frequency and scale. These negative impacts are felt by the environment in terms of biodiversity loss, water quality, and increased greenhouse gas emissions but also threaten the viability of upland grazing itself.

It is of concern that the debate on burning within the context of the Heritage Bill 2016 to date on whether the burning season should be extended to include March has focused on the issue of whether burning itself is good or bad for our uplands. In reality this kind of dialogue has failed to address the core issues.

• Will the proposed changes improve controlled burns or facilitate more wildfires?

• Why are so many wildfires occurring and are they of benefit to the farming or broader rural community?

• What are the core issues which need to be addressed to ensure the long term viability of farming in marginal areas?

Under CAP headage payments our uplands became over stocked in many areas resulting in overgrazing and environmental damage. This has left a strong impression within the public consciousness of the negative impacts of overgrazing. Less well known or understood are the negative impacts of under-grazing. Under-grazing resulting from destocking or land abandonment is a serious threat to semi-natural habitats which require traditional grazing practices. An excellent example of this are the species rich grasslands in the Burren.

According to recent Teagasc research in the Wicklow Uplands between 1999 and 2014, 66% of the farmers had either reduced their numbers of sheep grazing the uplands or stopped grazing altogether, and a further 16% had done so in the 5-10 years previous to 2014.
Almost all of the respondents surveyed (93%) stated that heather had increased on their commonage in the last 15 years. The majority of farmers (63%) stated that bracken cover had increased on their commonage while 22% of respondents felt that the proportion of grassland had decreased on their commonage. The reduction in grazing has resulted in an increase in woody heather, bracken and gorse. This has impacted on biodiversity by reducing the diversity of semi-natural habitats and it has knock-on impacts for farming by reducing the available grazing habitat.

The loss of grazing land also has other implications for farm incomes as subsidies under the Common Agricultural policy and cross compliance require farmlands to be farmed or in Good Agricultural and Environmental Condition (GAECs). The presence of bracken, woody heather and gorse will result in farmers therefore being penalized. The increase in scrub and the positive incentives for its destruction have resulted in an increase in uncontrolled burning both within and outside the banned window of September – February. The resulting wildfires are a threat to property and life. They cost emergency services nationally a huge amount of time and resources. They damage the environment and degrade farmland.

According to Teagasc these wildfires are also not good for farming. In relation to:

Bracken - Burning in general, speeds up the spread of bracken as the rhizomes are better able to withstand fires than more shallow rooted plants such as heather.

Gorse / Furze / Whins - Gorse regenerates prolifically from the seed bank after a fire, and ideally should be kept under control by grazing. The young fresh regrowth which follows burning is very sensitive to herbicides. Repeated burning without follow-up treatment can lead to a dense carpet-like infestation.The best time to burn is between September and November, avoiding the bird-nesting season and also avoiding January-February which results in increased seed germination.

Heather – Burning should be controlled, irregular and in patches. Burning is only recommended when followed with sustainable levels of livestock grazing. Mechanical cutting of heather can be used to make fire breaks and fire control lines for prescribed burning at a later date.

Severe wildfires must not be confused with managed burns. Management fires are set in winter or early spring when soil heating is minimal. The later in the season burning takes place the drier and more flammable the vegetation will be. If your objective is to carry out a limited controlled burn then having highly flammable vegetation is not helpful. The chances of causing wildfires substantially increases in spring and summer during dry periods. This also increases deep soil heating and the catastrophic burning of peat becomes more likely to occur .

It is An Taisces belief that legalizing burning in March will in fact facilitate more wildfires. It will in no way tackle the core issues driving uncontrolled burning which are the decline in upland farmers and livestock, a lack of training and supports and perverse incentives to burn under land eligibility.

Voting in favour of burning in March is not a vote in support of upland farmers or farmers in the West it is ignoring their plight and compounding the challenges they face.

The core driver of reduced grazing is related to economic returns. This is the critical issue facing marginal farming communities that must be addressed. Market mechanism must be developed such as branding High Nature Value food products, the development of local artisan food products and the diversification of the upland economy into eco-tourism. The distribution of CAP funding towards farmers who provide the greatest environmental goods and services through results base schems will also benefit farmers in marginal areas.

As far as burning is concerned the use of fire as a tool should aim to provide a mosaic of upland landscapes and habitats in conjunction with sustainable grazing levels.

To achieve this we believe that the following actions must be taken:

  • Improved training and research into burning and upland management is needed.

  • There needs to be a review of land eligibility criteria which benefit neither farmers nor the environment. Perverse incentives should be addressed.

  • The under resourcing of the National Parks and Wildlife Services and rural Fire Services needs to be addressed.

  • Where illegal burning does occur regardless of the Heritage Bill 2016 there needs to be a review of the enforcement of Section 40 of the Wildlife Acts and Land Eligibility in relation to illegal burning.

  • Any changes to the existing closed season for burning under Section 40 of the Wildlife Acts must be underpinned by scientific data.

  • Any changes to the existing closed season for burning under Section 40 of the Wildlife Acts should have a clear positive impact on the sustainability of upland farming. This should be clearly set out with reference to Teagasc research.

Is mise le meas

Fintan Kelly

Natural Environment Officer, An Taisce, The National Trust for Ireland