Forestry Network Newsletter

// FNN 169: Coillte's District Plans - data please

Coillte's District Plans, give me the data. The failure of Coilltes' plans to provide the monitoring data to enable us to evaluate their progress to sustainable forestry. Standish: who's paying the bill? Mussel Moratorium, Lough Ree. Ballyannan Wood management plan. Farmers urged to switch to forestry for income boost. New forestry fund . Review of Coillte Teo.'s District Strategic Plan South Kerry & West Cork 2006-2010.

FOREST NETWORK NEWSLETTER
ISSUE NUMBER 169
JULY 8, 2006
FREE BY EMAIL


1. INTRODUCTION
Coillte's District Plans, give me the data

2. LETTERS
Standish: who's paying the bill?
Mussel Moratorium, Lough Ree

3. NEWS
Ballyannan Wood management plan
Farmers urged to switch to forestry for income boost
New forestry fund

4. ARTICLE OF THE WEEK
Review of Coillte Teo.'s District Strategic Plan South Kerry & West Cork 2006-2010

5. COMING SOON IN FNN

6. ABOUT US

Index


1. INTRODUCTION

Coillte's District Plans, give me the data

For the many readers of FNN who are primarily concerned with the activities of Coillte Teo, the recent publication of their District Plans is a critical issue, and a virtually unknown one.

Coillte Teo., The State Forestry Board, has been given more than 350,000 hectares of our forests to manage on a commercial basis. It has also been given certification by the Forest Stewardship Council [FSC]. FSC requires that Management Plans are published, regularly reviewed, and contain all relevant data to enable the public to assess the organisations silvicultural practices.

In fact, as the submission we reprint this week in relation to this District Plan for South Kerry and West Cork, these documents are neither clear, concise, nor coherent. The structure makes it virtually impossible for the reader to easily access all the information on a related subject. The water quality issue highlighted as an example has information is scattered in 29 different parts of the document.

There is considerable difference between the content of the initial Forest Management Units issued after FSC Certification in 2002 and the District Strategic Plans issued this year.

First, they cover different areas. Thus the documents are not easily comparable. Consequently a review of Coillte's progress towards sustainable forest management is greatly impaired.

Moving the boundaries effectively allowed Coillte to juggle the areas of biodiversity to ensure all FMU's had "identified" 15%, illustrating that decisions on areas of biodiversity and numbers of broadleaves planted are determined by meeting arbitrary criteria rather than informed silvicultral decisions.

The only plan made readily available is the hundred page long District Strategic Plan. The most relevant information is not in this plan but contained in the some 24 Forest Management Units [FMUP] per District. These were not even mentioned in the public consultation advertisements and the FMUPs were not available for interested parties to take away with them at the Public Consultations.

Current forest management of clearfell and reforestation results in significant and often irreversible damage to soils, waters and biodiversity in direct breach of the Environmental Vision given on page 14 of this District Strategic Plan and of FSC Principles and Criteria which are detail in this submission.

The large amount of open space (6,883 ha) begs three questions:

1. Is the majority of this open space within the forest i.e does it form an integral part of the forest area and how much is being used as part of the 15% biodiversity area?

2. If this open space lies outside of the forest area is it included as part of the forest estate's biodiversity?

3. Is Coillte being permitted to allocate its 15% open space anywhere in its Estate while the private owner must 'sacrifice' 15% of each plantation?

Further, no details are given of how the species mix has been determined and exactly how the Company intends to make good on its commitment that 'This [species] imbalance will have to be addressed in the coming years.'

At the same meeting we understood that while farmers have to plant a minimum of 10% broadleaves and leave 15% for biodiversity (total 25%) on EVERY afforestation site, Coillte insist that this does not apply to reaforestted sites. Thus currently 60% of their broadleaves are within areas they have designated for biodiversity and this 15% can be anywhere within a "district". The fact that the Forest Service are allowing Coillte to do this sets a worrying precedent, will private plantations and co-ops will be allowed to ignore Forest Service guidelines when replanting.

The submission we reprint details a number of FSC Principles and Criterion which this Plan infringes, drawing particular attention to Principles 5, 6, and 10, forestry's multiple benefits, environmental impact, and plantations.

Finally, and perhaps most critically, we draw attention to the fact that in the first FMU a monitoring strategy was proposed. Obviously as those were the first plans no data was available. However in the District Strategic Plan 2006 - 2010 not only has the format of the monitoring section changed but STILL no data is made available.

Six years have passed since the first Forest Management Unit Plans were developed and a significant amount of monitoring data should be available which would enable stakeholders to assess the progression of Coillte's move towards sustainable forestry.

This is an issue that must be addressed as it is in breach of FSC Principle 7, Management Plan Criteria 7.2, which states that 'the management plan shall be periodically revised to incorporate the results of monitoring or new scientific and technical information, as well as to respond to changing environmental, social and economic circumstances'.

The matters we raise require urgent action and FSC must ensure that the current District Strategic Plans are redrafted accordingly. We would urge community groups around Ireland to obtain the Plans for their areas and examine them in the light of the Principles and Criterion of the Forest Stewardship Council.

Index



2. LETTERS

Standish: who's paying the bill?

A g h a n c o n C o n c e r n e d R e s i d e n t s A s s o c i a t i o n
C / o T h e E s t a t e O f f i c e
B i r r
C o O f f a l y
D a t e : April 9, 2006
Kathy Sinnott MEP
Irish Environmental Forum
St Josephs
Ballinaberna
Ballinhassig
Co Cork

Re: IPC License 706/320 - Standish Sawmills at Leap Castle Roscrea Co Offaly.

Dear Kathy
Thank you for all of you continued support and assistance in raising the continued non compliance of this facility and the flaws in the supervision of the EPA at this site. We would be grateful if you would raise the following issue at your meeting with Dick Roche. The EPA has appointed the following consultants at the expense of the taxpayer to evaluate sources of pollution and contamination at the sawmills. Dara Lynott when questioned on the 08.03.2006 at a meeting with residents declined to say WHY the EPA were paying for these reports, but suggested that he was going to pay for the reports from the Plastic bag levy funding over which he has control. Out argument here is that the polluter, not the taxpayer should pay for these reports, which should have been decided prior to any licence being granted.
sub total 21% VAT total
Anne Jones - Publicity and Media Consultant €3,500.00 €735.00 €4,235.00
Land Quality Management Ltd €4,990.00 €1,047.90 €6,037.90
Geological Survey of Ireland (estimate) €5,000.00 €1,050.00 €6,050.00
Conservation Services, Ecological and environmental Consultants €2,214.00 €464.94 €2,678.94
Trinity College €5,000.00 €1,050.00 €6,050.00
Aquens Ltd €5,000.00 €1,050.00 €6,050.00
Vincent Gallagher (estimate) €2,500.00 €525.00 €3,025.00
TOTAL: €34,126.84

One of the founding principles of the EPA is that the polluter should pay for any pollution caused, given that this company has been twice convicted of pollution, why should the taxpayer have to pay for these consultants and why is the EPA not recouping these costs?

Yours Faithfully
Paul Byrne on behalf
Aghancon Concerned Residents Association.
CC EU Commission on the Environment.

FNN will be returning to the extraordinary story of the Standish case shortly.


Mussel Moratorium

a chara - when there is 8000 Coillte jobs at stake there is little hope for this fragile 'creature'. The fact is that because this 'weed' sticka spruce induces acidity ( because it 'sequesters' through its pin needle leaves- H+ ions and other acidic ions from acid rains) it therefore lowers the pH of surface waters even further on the natural background acidic sandstone and granite geology. So the Forestry Service CAN NOT AUTHORISE THIS ACTIVITY of growing spruce in the first instance..
Here at Lough Ree subsite 00440 SAC site , a semi -natural native woodland that has mixed conifer stands through it is now threatened through clearfelling for it to be brought into the Native Woodland Scheme. The amount of wood harvested will be estimated at around 10, 000 Euros in value. The significant impacts from the clearfelling on the cSAC site will no doubt compromise the ecological integrity of the site, all for 10.000 euros and jobs for the Coillte employees. Where is the sense in all this. I have proposed using cranes -cutting and wenching away the trees but they say this would be too expensive and no way will they do a costly independant EIS . ANY IDEAS LADS
Regards
Ian Hester


Index



3. NEWS

Ballyannan Wood management plan

Ballyannan Wood is a 24.5 ha ancient woodland near Midleton in east Cork. The County Nature Trust and Coillte have established a steering committee for the management of Ballyannan Wood. This steering committee includes representatives from Coillte, Cork County Council, County Nature Trust, East Cork Area Development Ltd., Midleton Town Council and the National Parks and Wildlife Service. Sylvan Consulting Ecologists have been commissioned to prepare a management plan on behalf of the steering committee. Submissions are now being sought from interested parties and individuals who may have any information relating to the wood (including observations of flora and fauna, historical information, former land uses etc), or who wish to raise issues that should be addressed by the management plan.
Submissions or suggestions should be submitted to the Heritage Unit, Cork County Council, Millview House, Travellers Way, Victoria Cross, Cork.

For further information about the history and ecology of Ballyannan Wood and details of CNT proposals for nature conservation management of the wood, see http://countynaturetrust.tripod.com

Further information about the management plan is also available on the Cork County Council Heritage website:
http://www.corkcoco.ie/co/web/Cork%20County%
20Council/Departments/Heritage/News%20&%20Events

Tom Gittings
County Nature Trust: http://countynaturetrust.tripod.com



Farmers urged to switch to forestry for income boost

MORE than 40,000 farmers are being encouraged to convert part of their land to forestry to boost their incomes and rural employment, under a new campaign launched today.

The National Forest Strategy is aiming to cover 17pc of the Republic with forest by 2030 as Ireland currently has the lowest level of forestry among the 25 EU States.

Mary Wallace, Minister of State for Forestry, said: "While forest cover has increased substantially over the past 15 years, Ireland still has the lowest level of forestry in the 25 EU member states.

"Just 10pc of our land area is under trees, compared to 38pc for the EU as a whole. The National Forest Strategy has set a target of 17pc forest cover by 2030 and this campaign aims to re-invigorate planting to ensure that this target is met."

Ms Wallace said the campaign was particularly aimed at low-income drystock farmers, part-time farmers and those who have low Single Farm Payment entitlements.

The minister said concessions allowing farmers to plant up to 50pc of their farms while still retaining their full EU Single Farm Payment offered people an opportunity to significantly boost their income.

"A unique advantage of forestry is that the cost of planting is covered by state grants. There are grants for pruning, shaping and forest roads as well as annual premiums of up to €499 per hectare, tax-free," she said.

Ms Wallace said the timber crop can yield €15,000 a hectare tax-free.

George McCarthy, chairman of the Irish Forest Industry Chain, said: "This is a vital future income source and pension fund for these farmers and their families. It will create a sustainable supply of raw material that will enable the sawmilling and timber processing sectors to invest and become internationally competitive."
Louise Hogan
© Irish Independent



New forestry fund

PRIVATE investors are displaying enthusiasm for forestry, looking at the demand for a recently launched fund.

Dun Laoghaire, Co Dublin, based IFS Asset Managers has now launched a second forestry investment fund after a fund it launched in May became oversubscribed in the course of three weeks.

This latest 2nd Forestry Growth Plan will result in a further €2m of Irish forestry plantations offering a compound projected 8.5pc per annum tax free rate of return over a 12-year term to investors, the company claimed.

The minimum investment in this asset backed Forestry Growth Plan is €750. Utilising EU and Government grants, the €2m raised will be used to purchase approximately 85pc semi-mature plantations and 15pc bare land.

At the end of the 12-year term, the company will be wound up and the afforestated lands will be sold on the open market with all profits being distributed tax free to the investors. There are now €62.5m of forestry assets on 15,500 acres.
© Irish Independent

Index



4. ARTICLE OF THE WEEK

Review of Coillte Teo.'s District Strategic Plan 2006-2010
District S4 South Kerry & West Cork.

Overview.

Coillte have recently reviewed their planning structure and formed 13 forest management districts known as District Strategic Plans. A brief description is given on Coillte's website as given below:

DISTRICT STRATEGIC PLANS
Coillte's estate is divided into 317 Forest Management Units (FMUs) which are combined into 13 forest management districts. Coillte has developed plans for each of these Districts, which describe Coillte's forests in the area and set out the long term vision for the management of these forests. The plans address a wide range of economic, social and environmental objectives and include details of how the forest will be expanded and restructured, how the mix of tree species in the forests will change over time, how nature will be conserved and recreational facilities provided, among other issues.
These plans are now available for viewing.

(http://www.coillte.ie/managing_our_forests/plans/plan.htm
Accessed 11/04/2006)

On the Coillte website there is reference to both Coillte's national Corporate Strategic Plan (2004, 2013) and the 317 Forest Management Plans (FMP). However, these documents are not made available.

The District Strategic Plans in PDF format are available for download but no indication is given as to how or when submissions can be made.

The DSP is 108 pages long. It is split into five main sections. When writing this submission it was apparent that it was very difficult to make a comprehensive analysis. One thing would be said in one section, another in another and so on. This results in constant cross referencing throughout the document, a time consuming and somewhat complex procedure even for those used to dealing with such publications.

If we take water and water monitoring as an example, in order to gain a full picture of Coillte's proposals the following pages would have to be referred to:

Page 7 tells us the importance of rivers for Fresh water pearl mussel (it doesn't mention they are a protected species) is given on page 7,
Page 9 under Challenges & Opportunities E.U directives and the importance of water/species protection & monitoring are referred to.
Page 14 assures us of the conservation of water resources.
Page 19 under species tells us that they will 'establish buffer zones of broadleaf species along all streams and rivers
A fact repeated on page 20 under restocking.
Page 28 gives us details of water quality monitoring;
Page 34 under Nature Conservation refers to the Fresh Water Pearl Mussel (3rd mention)
Page 36 Special habitats mentions freshwater habitats & riparian zones and states all habitats will be monitored.
Pages 37 & 38 list a few specific aquatic sites and gives the five year objective as restoring bog, heath & riparian habitats on selected sites.
Page 41 Natural reserves, non forest habitat protection for the Freshwater Pearl Mussel and Natterjack Toad.
Page 46 b- Riparian Buffer Zones again mentions the Freshwater Pearl Mussel and important river catchments.
Page 51 tells us how EIA's will be carried out for high impact operations which includes impact on water. (EIA's are mentioned again on page 57 under Action plan but water is not specifically referred to).
Page 58 refers to the conversion of riparian zones to broadleaves to fulfil the species mix obligation.
Page 68 refers again to water monitoring,
Page 70 refers to the sub division of the District into 19 forests some based on river catchments,
Page 72 refers to riparian zones,
Page 73 mentions Biodiversity Action Plans for rare and protected species and completion of EIA's both of which relate to water quality issues.
Page 74 mentions the retention and protection of open and non forest habitat and the restoration of riparian habitats on selected sites, (no details given)
Page 76 refers again to protected species,
Page 79 again refers to the creation of riparian zones on selected sites and consultation with the fisheries board and NPWS.
Page 84 refers to EIA's & consultation
Page 89 the Strategic Impact Matrix refers to water monitoring, riparian buffer zones and protected species.
Page 91 lists a brief outline of possible conflicts and mitigation relating to water, here it states riparian buffer zones are being developed for all water ways in the region.
Page 92 refers to biodiversity & EIA's, no direct mention of water but these realte.
Page 93 mentions impacts on water through raod making and harvesting.
Page 95 refers to ground preparation and the impact on water.
Page 96 refers to the impact on water of Farm Partnership schmes,
Page 97 refers to the impact of chemicals on waterways,
Page 101 gives Environmental parameters, including water monitoring & biodiversity.

This shows clearly that the document is neither clear, concise or coherent. The structure should be changed to enable the reader to easily access all the information on a related subject such as the water quality issue outlined above.

This could be done by restructuring in the section condensing relevant information into one place where ever possible and where this is not possible must include clear references including page numbers and/or section headings.

Incidentally there are no maps in the map section (page 103) and references to FSC Principles and Criteria appear to be missing from Section 4 - Action Plans.


Stakeholder consultation.

These District Strategic Plans (DSP) are the product of the 5-year revision of the Forest Management Unit (FMU) plans which ran from 2000, 2004 inclusive. This 5-year revision is part of the requirements of Coillte FSC certification. As there is a considerable difference between both the content of the initial FMU's and the DSP's and the areas they cover, a review of Coillte's progress towards sustainable forest management is made very difficult as the documents are not easily comparable. For the successful monitoring of the effect of forest management and the public consultation process within such a long term project as forestry there must be continuity.

We question the decision taken in the approach to the review of the original FMU's to a less specific more generalised form, covering a larger area, and wonder if any public consultation occurred in relation to the changes.

Additionally it appears that the only opportunity to have an input to the FMP's is to attend the relevant consultation meetings. The newspaper advertisement for the S4 district states that:

'All community groups, interested parties and customers are cordially invited to attend and Coillte staff will be on hand to respond to any queries. If you wish to see a copy of the plan in advance of the meeting a copy can be downloaded from Coillte's website at www.coillte.ie or from the local Coillte office. Any queries or submissions can then be addressed within one month to ….'.

There is no mention of the FMP's or Management Unit (MU) plans and yet it is these that will contain the most relevant information. Their lack of availability is unacceptable and these FMP's must be made readily available both from Coillte's website and on request from any Coillte office.

Although a few of these FMPs were available for people to see at the consultation meeting there were no copies for people to take away in order to be able to make submissions. Additionally the language and terms used were too technical for the average well informed stakeholder to readily comprehend.

In the DSP for S4 on page 11 it states:

'The plan will take into account the views and recommendations of other statutory bodies, local communities and organisations, thus ensuring that resources are targeted to priority areas whilst delivering national objectives and addressing local needs.'

And goes on to say:

'Consultation will take place at District level and meeting will be held in geographical areas where Forest Management Plans (FMP's) can be clustered to take account of areas which are most affected by operations within the District. Following these consultations the DSP will be updated and finalised.'

Within the newly formed 13 District Strategic Plans there are 317 Forest Management Units each with its own management plan, an average of 24 per District. As previously stated these Forest Management Unit plans are not available on the section of the Coillte website dealing with Forest Management Plans. The District Strategic Plans are available but they contain few details and are vague and inspirational.

So to summarise the consultation process an advert is placed in the paper and the meetings are held in the area most central to where the bulk of the high impact operations will occur. The only plan made readily available is the hundred page long District Strategic Plan. The most relevant information is not in this plan put contained in the some 24 FMP per District which are not even mentioned in the advert. The 'drop in' style meeting lasted 4 hours so this would give 10 minutes per plan without a minute to spare, to read, comprehend and make a submission or at least notes. These 24 FMP are not available for interested parties to take away with them.

This failure to make full information available is of great concern as it reinforces the public perception that a prolonged and protracted struggle is required simply to access information about Coillte's activities.

At the S4 meeting dialogue with the district manager was disturbing. It was made evident that Coillte have no intention of taking peoples viewpoints on board. This was explained in the District Manger's response to concerns about environmental or social degradation - as long as it's OK with the Forest Service its OK with Coillte. And if it's OK with the Forest Service it's OK with Woodmark, Coillte's auditors for FSC certification. This attitude does not appear to allow for any meaningful consultation process.


Sustainable Forestry.
Coillte claims to practice sustainable forest management. However as far as Coillte are concerned sustainable forestry means that they don't harvest more timber than is growing. This is what the district manager stated during the public consultation meeting.
This is not the definition used by other countries for example the United Nations Forum on Forests (UNFF) provides the following working definition of SFM:
… the stewardship and use of forests and forest lands in a way, and at a rate, that maintains their biodiversity, productivity, regeneration capacity, vitality and their potential to fulfil, now and in the future, relevant ecological, economic and social functions, at local, national, and global levels, and that does not cause damage to other ecosystems.
SFM is about striking a balance among all the different uses of the forest, while ensuring its continued ecological functioning so that the benefits (to all living things) and functions can continue into the future.
( http://www.parl.gc.ca/information/library/PRBpubs/prb0513-e.htm#definingtxt )

To summarise sustainable forestry management as defined by the United Nations maintains not only productivity but also biodiversity, regeneration capacity, vitality, and does not cause damage to other ecosystems. Forestry should have a beneficial effect on the environment.

The Forest Stewardship Council (FSC) also has clear definitions of sustainable forestry outlined in their ten Principles & Criteria, offering protective functions similar to those given by the United Nations. (see http://www.fsc.org/en/ )
Coillte must comply with FSC Principles & Criteria to maintain there certification status..


Compliance with FSC Principles and Criteria.
Clearfell with thinning will be the major silvicultural system.
Current forest management of clearfell and reforestation results in significant and often irreversible damage to soils, waters and biodiversity. This is in direct breach of the Environmental Vision given on page 14 of the S4 DSP and of the following FSC Principles and Criteria:

Principle 5: Benefits from the Forest: Forest management operations shall encourage the efficient use of the forest's multiple products and services to ensure economic viability and a wide range of environmental and social benefits.

Criteria 5.1 Forest management should strive toward economic viability, while taking into account the full environmental, social, and operational costs of production, and ensuring the investments necessary to maintain the ecological productivity of the forest.

Criteria 5.3 Forest management should minimize waste associated with harvesting and on-site processing operations and avoid damage to other forest resources.

Criteria 5.5 Forest management operations shall recognize, maintain, and, where appropriate, enhance the value of forest services and resources such as watersheds and fisheries.

Principle 6: Environmental Impact Forest management shall conserve biological diversity and its associated values, water resources, soils, and unique and fragile ecosystems and landscapes, and, by so doing, maintain the ecological functions and the integrity of the forest.
Criteria
6.2 Safeguards shall exist which protect rare, threatened and endangered species and their habitats (e.g., nesting and feeding areas). Conservation zones and protection areas shall be established, appropriate to the scale and intensity of forest management and the uniqueness of the affected resources.
6.3 Ecological functions and values shall be maintained intact, enhanced, or restored, including: a) Forest regeneration and succession. b) Genetic, species, and ecosystem diversity. c) Natural cycles that affect the productivity of the forest ecosystem.
6.5 Written guidelines shall be prepared and implemented to: control erosion; minimize forest damage during harvesting, road construction, and all other mechanical disturbances; and protect water resources.
6.6 Management systems shall promote the development and adoption of environmentally friendly non-chemical methods of pest management and strive to avoid the use of chemical pesticides.


Principle 10: Plantations: Plantations shall be planned and managed in accordance with Principles and Criteria 1 - 9, and Principle 10 and its Criteria. While plantations can provide an array of social and economic benefits, and can contribute to satisfying the world's needs for forest products, they should complement the management of, reduce pressures on, and promote the restoration and conservation of natural forests.
Criteria.
10.2 The design and layout of plantations should promote the protection, restoration and conservation of natural forests, and not increase pressures on natural forests. Wildlife corridors, streamside zones and a mosaic of stands of different ages and rotation periods, shall be used in the layout of the plantation, consistent with the scale of the operation. The scale and layout of plantation blocks shall be consistent with the patterns of forest stands found within the natural landscape.
10.3 Diversity in the composition of plantations is preferred, so as to enhance economic, ecological and social stability. Such diversity may include the size and spatial distribution of management units within the landscape, number and genetic composition of species, age classes and structures.
10.4 The selection of species for planting shall be based on their overall suitability for the site and their appropriateness to the management objectives. In order to enhance the conservation of biological diversity, native species are preferred over exotic species in the establishment of plantations and the restoration of degraded ecosystems. Exotic species, which shall be used only when their performance is greater than that of native species, shall be carefully monitored to detect unusual mortality, disease, or insect outbreaks and adverse ecological impacts.
10.5 A proportion of the overall forest management area, appropriate to the scale of the plantation and to be determined in regional standards, shall be managed so as to restore the site to a natural forest cover.
10.6 Measures shall be taken to maintain or improve soil structure, fertility, and biological activity. The techniques and rate of harvesting, road and trail construction and maintenance, and the choice of species shall not result in long term soil degradation or adverse impacts on water quality, quantity or substantial deviation from stream course drainage patterns.
10.7 Measures shall be taken to prevent and minimize outbreaks of pests, diseases, fire and invasive plant introductions. Integrated pest management shall form an essential part of the management plan, with primary reliance on prevention and biological control methods rather than chemical pesticides and fertilizers. Plantation management should make every effort to move away from chemical pesticides and fertilizers, including their use in nurseries. The use of chemicals is also covered in Criteria 6.6 and 6.7.
10.8 Appropriate to the scale and diversity of the operation, monitoring of plantations shall include regular assessment of potential on-site and off-site ecological and social impacts, (e.g. natural regeneration, effects on water resources and soil fertility, and impacts on local welfare and social well-being), in addition to those elements addressed in principles 8, 6 and 4. No species should be planted on a large scale until local trials and/or experience have shown that they are ecologically well-adapted to the site, are not invasive, and do not have significant negative ecological impacts on other ecosystems. Special attention will be paid to social issues of land acquisition for plantations, especially the protection of local rights of ownership, use or access.

No comprehensive economic analysis has been undertaken to assess the viability of current forest management practices and species mix.

Current forest management does not take into account social and in particular environmental costs.

Clearfell and replanting pollutes water and significantly damages aquatic ecosystems

Exotic conifer plantations degrade fragile soils and increase acidity significantly damaging soil ecosystems.

Ecological functions and the integrity of forests are not maintained. Large monocultures and the clearfell regime are susceptible to insect attack and disease and do not promote environmentally friendly non-chemical methods of pest management.

There is no indication in the action plan as to how these negative effects are to be mitigated or monitored.

Only 6 permanent water testing sites are in place in the whole district and testing is only carried out 3 times a year. No results of any monitoring are given and the whole process is of self assessment. [See also monitoring , Principle 7.]


Economic
Principle 5.4 states that 'Forest management should strive to strengthen and diversify the local economy, avoiding dependence on a single forest product.'
5.2 Forest management and marketing operations should encourage the optimal use and local processing of the forest's diversity of products.

The predominance of low grade Sitka Spruce particularly in areas of high windthrow where thinning cannot be carried out results in timber suited to the manufactured board/pulp industry. These industrial plants are located in towns such as Clonmel and Waterford and make little to contributing to the rural economy.

For example if we look at the original West Cork FMU, which forms approximately half of the new DSP, the area of Sitka spruce is given at 72.7% of the forest estate with other conifers at 14.2% and broadleaves at 2.6%.

In this part of the DSP, a large area covering the whole of West Cork, the percentage of Sitka and other conifers is greater than in the Kerry section. It appears that there will be no obligation on Coillte to increase levels of broadleaves & diverse conifers in the entire West Cork region as the DSP is seen as one unit under FSC certification.

This dependence on a single forest product - and species - contravenes this principle and does little for the local economy or diversification.

We request details of how the species mix has been determined, and that species mix takes full account of Principle 5.4.

Monitoring
In the first management plans a monitoring strategy was proposed. Obviously as this was the first plan no data was available. However in the DSP not only has the format of the monitoring section changed but no data is made available. Six years have passed since the first Forest Management Plans were developed and a significant amount of monitoring data should be available which would be of significant interest to stakeholders enabling them to see the progression of Coillte's move towards sustainable forestry. This is an issue that needs to be addressed and we request that this information is incorporated into the DSP.

This is in breach of FSC Principle 7: Management Plan Criteria 7.2 which states that 'the management plan shall be periodically revised to incorporate the results of monitoring or new scientific and technical information, as well as to respond to changing environmental, social and economic circumstances'.

The DSP states that only a summary of the monitoring results will be publicly available and then only at the end of the five year plan. This is unacceptable and full results of ongoing monitoring must be made publicly available.


Species mix.
On page 6 Coillte tells us that they own 27,865 ha in this district of which 40% is high level blanket peat, 22% low level blanket peat, 28% podsol; 5% brown earth and 5% other soil types.
Species breakdown within the forest estate is Sitka spruce 59%; Lodgepole pine 8% (Lodgepole pine was downgraded by Coillte to a secondary species in order to fulfil certification requirements.); diverse conifers 5.2% (of which Scots pine makes up 0.7% - see page 19).

The Plan states that

'This imbalance will have to be addressed in the coming years.'

No details are given as to the time frame within which this imbalance will be addressed only a statement saying over one rotation. Neither is any indication given as to what the balanced position is to be. The Heritage Council has called for afforestation with 50% broadleaves and Forest Service policy is for 30% broadleaves. These government recommendations must be reflected in Coillte's planting.

Broadleaves are suited to podsols, brown earths and certain species may grow on peat.

For example in the West Cork FMU the percentage of blanket peat is given as 51%, podsols 35%, acid brown earths at 7% Gleys at 5% and Lithososl at 2%. This range of soils gives ample opportunity to extend the native species cover which will help prevent soil degradation , improve biodiversity and protect vulnerable water bodies. This would also apply to the Kerry region.


Areas for Biodiversity.
The large amount of open space (6,883 ha) gives rise to two questions:

Is the majority of this open space within the forest i.e does it form an integral part of the forest area and how much is being used as part of the 15% biodiversity area?

If this open space lies outside of the forest area is it included as part of the forest estates biodiversity?

The Forest Service Biodiversity Guidelines clearly state that:

'…approximately 15% of the forest area must also be treated with particular regard for biodiversity.'

And goes on:

… 'Between 5-10% of the forest should comprise open space. In sites less than 10ha this should be designed in conjunction with neighbouring land use and may be reduced. .'

For example if a farmer planted some land with forestry 15% of this forest area would have to be set aside for biodiversity .The farmer could not use land outside the afforestation as part of the area for biodiversity.

FSC requires compliance with all Forest Service Guidelines therefore this point needs to be clarified and rectified where necessary.


Economic Viability
The plan tells us that sites are:

 Inaccessible due to narrow twisting roads with low load bearing capacities.
 Often small blocks in remote locations.
 Unstable plantations due to high rainfall and peat soils with a high risk of windthrow A no thin policy will be adopted on unstable sites

Poor access, remote location and a high risk of wind throw typically results in economically unviable plantations. (All of this district is at high risk from windthrow according Irelands wind zone map) Has this been assessed and management options proposed for reverting the plantations to native woodland/habitat. If exotic conifer plantations are uneconomic what harm could this approach be?


Designated areas
Page 7 tells us that:
'almost 5,800ha has been designated as ecologically sensitive. The Blackwater, Caragh and Bandon/Caha rivers contain freshwater pearl mussel. Most of the Iveragh peninsula has been designated as acid sensitive.'

And goes on to tell us that obligations under the Water Framework Directive require:

'Preventing further deterioration to aquatic ecosystems and terrestrial and wetland systems dependant on them.'

Additionally FSC requires the biodiversity in all forests to be:
Forest management shall conserve biological diversity and its associated values, water resources, soils, and unique and fragile ecosystems and landscapes, and, by so doing, maintain the ecological functions and the integrity of the forest.

Are Coillte not aware of the nutrient peaks and siltation in aquatic environments following forestry operations particularly clearfell. [Clear fell is defined as any one felled area over 2.5ha]. Best current Scientific Practice suggests elimination of clearfell particularly on peat soils . Peat soils form 62% of the soils in this DSP and in addition the 28% podsols are also likely to be peat based with pockets of peat soils (A peat soil is a soil based on organic matter with a depth greater then 30cm).

In addition the Water Framework Directive requires that waters are protected and measures put in place that prevent further deterioration to aquatic ecosystems and terrestrial and wetland systems that depend upon them.

We submit and require assurances that fertilisation and clearfell will be eliminated, particularly in the headlands of rivers which have been designated as SAC's and on peat soils. The details of any assessments, measures, monitoring and monitoring results and data must form part of the publicly available management plans.


On page 10 under 'Modern Society' two of the opportunities are given as;

1. Providing sites for waste disposal
2. Providing sites for alternative energy'

How do these opportunities fit into sustainable forest management which is supposed to conserve and enhance forestry. It is difficult to see how the provision of land for waste disposal falls into the ethos of sustainable forest management and object to its inclusion. Additionally the sale of large tracts of public forestry land for alternative energy is questionable to say the least and this practice should be discontinued as should the sale of any public forests. Ireland has the lowest forest cover in the E.U. it is illogical in the extreme to give grants for afforestation whilst selling forested land for development.


In the section on page 13 under Economic vision, what does the flowing statement mean:

'Due to the location of sawmills in the District it is vital that produce is fully optimised during harvesting'

If this means that large clearfell are essential for economic viability then this does not comply with any of the Environmental vision given on page 14.

In Section 3 page 15 it gives details of the predominant silvilcultural system which is thinning and clearfell. Clear fells of 20ha or more are environmentally unacceptable.

What is the average clearfell size in this District and what restructuring plans are being implemented to reduce the clearfell size and the associated environmental and social impacts? This information should be included in the plan.

What area is assigned for Low Impact Silvicultural Systems (LISS) and Long Term Retentions (LTR's). Details should be given in the Plan.

The Irish Natural Forestry Foundation
12 May, 2006


EDITORS NOTE: FNN has been informally told that Coillte is preparing a reply to this submission. We will be pleased to print this reply in full and if there are any errors of fact, correct them at the earliest opportunity.


Index



5. COMING SOON IN FNN

Standish Sawmills: Licence granted in spite of EPA Inspector's Report ruling company 'unfit' to hold a licence - with transcripts from the Dail committee hearing.

The Mussel Moratorium, the inside story from Access to Information requests.

The Ticknock mountains above Dublin: Is clearfelling our amenity woodlands being done on a 'commercial basis'? Eamon Ryan, TD, brings it to the floor of the Dail.

And as preliminary figures suggest the 2005 planting rate will be less than half the Government's 20,000 target and EU funding is reduced, what are the implications for the failure to reach 'critical mass' for Irish forestry?

Coillte land sales: what, when, where, and how.

Index



6. ABOUT US

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Tony Lowes
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Ian Wright
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The editors take collective responsibility for what they publish. The omission of an authors name indicates that the editors generally agree with and stand over the contents. There may be and often are a number of collaborating authors on each article and additionally some authors may for valid reasons not wish to be identified. This does not mean the editors never make mistakes and they look forward to having their attention drawn to any factual inaccuracies in any articles they have published.

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Index