The environmental integrity of Irish forestry in the context of the EU’s effort sharing decision (2016)

Hunting female Hen Harrier by Radovan Václav
Species Rich Orchid Grassland by Fintan Kelly
Clear-cut Forestry by Mark Robinson
Wtaer Quality Impacts by Neil Foulkes

Dear Mr Jos Delbeke (Director-General of the European Commission's Directorate-General for Climate Action),

When speaking to MEPs at the agriculture committee (AGRI) in June, Commissioner Cañete indicated that the Commission intends to keep emissions from the Land Use, Land Use Change and Forestry (LULUCF) sector separate from those in the non-Emissions Trading Sector and significantly that "only those type of credits that fulfil accounting standards of high environmental integrity" would be allowed and that access to such credits "cannot be unlimited". I am writing to you to inform that the Irish forestry sector cannot be considered as having high environmental standards. Commercial forestry in Ireland is a major driver of biodiversity loss, a major source of water pollution and is non-compliant with the requirements of the EU’s environmental legislation.

The negative environmental impact of the Irish forestry and agricultural sectors will only increase if further afforestation is incentivised through the EU’s policy on LULUCF. Irish agriculture output is set to increase over the next decade under Ireland’s Food Harvest 2020 and Food Wise 2025 programmes. The intensification of the agricultural production under these programmes will mean that greenhouse gas emissions within the sector will continue to increase up to 2020 and beyond (EPA, 2015). This is at a time when deep and sustained emissions reductions are needed (Price, 2015). Allowing the Irish agricultural sector to offset emissions through loopholes in the EUs LULUCF policies will allow the perpetuation of a model of food production which is damaging the environment, failing to protect the well-being of many farmers and damaging the health of the public and the world’s poorest people.

On a fundamental level the argument that emissions from livestock can be offset with afforestation is scientifically flawed because the off-set available is only a small fraction of potential fossil fuel emissions (Mackey, et al., 2013). Also, as highlighted by the Intergovernmental Panel on Climate Change (Ciais, et al., 2015), such land sequestration is impermanent (relative to the thousands of years of mitigation required), highly uncertain, and subject to carbon cycle rebound effects that seriously reduce their value. The unreliability of this carbon sink is amplified by factors such as variations in harvesting rates, wood utilisation trends and forest age class structure (Black, et al., 2012). Forestry is projected to become a carbon source in Ireland by the mid-2030s and continue to be a source of emissions up to 2050 unless afforestation rates above 10,000 ha per year are maintained (Black, 2007). Given that Ireland’s current Forest Programme (2014 – 2020) will only support afforestation of 6000ha in 2015 rising to 8000ha in 2020 it is highly likely Irish forestry will be a significant carbon source over the coming decades (Service, 2014). Implementing climate policies which will result in an increase in greenhouse gas emissions over the coming decades will seriously damage the credibility of the EU’s commitment to tackle climate change.

Is mise le meas

Fintan Kelly

Natural Environmnet Officer An Taisce