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Forestry Network Newsletter
// FNN 172: Parliamentary Replies show lack of education
Hostile and Unforgiving? Ministerial replies to forestry questions. Fresh water pearl mussel: the UK approach. Coillte Teo. vs. FNN [Link to audio file] Green argument used against replanting trees. Coillte grant aid to farmers. Review of 1996 Forestry Policy. Fresh Water Pearl Mussel Forestry Guidelines: full terms of reference. The Definition of Peat Soils. Foliar Analysis. Control of unauthorised forestry €50 book token for the best submission on Coillte Teo's application for derogation for the toxic chemical pesticide cypermethrin.
FOREST NETWORK NEWSLETTER
ISSUE NUMBER 172
4 OCTOBER 2006
Editors note: May we remind readers that we are requesting contributions to support the work of FNN? We are most grateful for the response we have had - particularly one substantial donation - but as usual the burden is falling on very few. FNN receives no funding from any source except its readers and its editors receive no payment. Would subscribers please consider carefully if they enjoy and value FNN and its work enough to support us?
Online contributions can be made through our secure credit card donations page
http://www.friendsoftheirishenvironment.net/donate.html
or by post to Friends of the Irish Environment, Allihies, Co. Cork.
Thank you.
The Editors
Hostile and Unforgiving?
Fresh water pearl mussel: the UK approach
Coillte Teo. vs. FNN [Link to audio file]
Green argument used against replanting trees
Coillte grant aid to farmers
Review of 1996 Forestry Policy
Fresh Water Pearl Mussel Forestry Guidelines: full terms of reference
The Definition of Peat Soils
Foliar Analysis
Control of unauthorised forestry
The Definition of Peat Soils
€50 book token for the best submission on Coillte Teo's application for derogation for the toxic chemical pesticide cypermethrin.
7. EVENTS
Hostile and Unforgiving?
Goodness. It turns out the Minister didn't tell the Oireachtas that the new Guidelines for Forestry practices that may impact on the fresh water pearl mussel (Margaritifera margaritifera ) must be ‘cost efficient'.
What is it that Michael Viney called FNN in his article on the fresh water pearl mussel? [NEWS] ‘Hostile and unforgiving', wasn't it?
What other response can one have to the Minister and her senior civil servants in the Forest Service who did not reveal in a reply to a written Parliamentary Question that the terms of reference for Guidelines intended for the protection of an endangered species did not include the words ‘cost effective'? [FNN 168 - The Moratorium on Clearfelling - Good News And Bad http://www.friendsoftheirishenvironment.net/fnn/article.php?sid=197&mode=thread&order=0]
90% of the fresh water pearl mussels in Ireland have been extinguished through pollution of our waters.
And now we are told that the protection of the remaining communities - some as small as a single individual - will not be considered unless it is ‘cost effective' to do so.
Exactly where is this in the Habitats Directive? In our version before economic factors can be considered any plan or project not necessary to the management of the site but likely to have a significant effect must be subject to appropriate assessment. No one may agree to the plan or project until they have ascertained that it will not adversely affect the integrity of the site.
If it does affect the protected species, only after such an analysis can it be considered whether the activity must nevertheless be carried out for imperative reasons of overriding public interest, including those of an economic nature.
The assessment that is initially required must be carried out independently of those with an economic interest - in this case Coillte Teo. - and should include at least one university group that specialises in nutrient movements in soils or has experience in these nutrient issues in a forestry situation in order to ensure that best scientific knowledge is used in the assessment.
In no way does the present fresh water pearl mussel Working Group (with Coillte Teo. as a member) or the Technical Committee meet this standard. Even simple questions, e.g. as to when Low Ground Pressure harvesting machinery should be used, may then be ruled out on marginally economic sites, such as those on peat soils at the headlands of our Rivers - the very sites that need low impact treatment the most.
Let us be quite clear here. Deputy Trevor Sargent asked for the Terms of Reference of the fresh water pearl mussel Steering Group last May. The Minister in her reply stated that she was supplying the ‘the Terms of Reference of that Committee's Technical Working Group'.
But she did not. She did not tell the Oireachtas that economic considerations were part of these terms. She omitted that key sentence which FNN discovered through an Access to Information request.
It is hard not to be unforgiving.
In fact, as we look through the Minister's replies to the forestry questions tabled during the Oireachtas summer recess we grow increasingly so.
Take phosphorus applications.
It turns out that there is in fact no limit to the amount of fertiliser which can be applied to a hectare of forestry in Ireland. 350 kgs may be applied in the initial application. In a ‘small number of cases' there may be one - ‘or more' - further applications.
The felling on Lettercrafroe Lake which allegedly led to the 2004 fresh water pearl mussel kill we featured in FNN 171 and which is shown on the FIE website [http://friendsoftheirishenvironment.net/pdf/clrfell.pdf] - and then in the Irish Independent [http://www.friendsoftheirishenvironment.net/papers/article.php?sid=9121&mode=thread&order=0] - must be one of those ‘small number of cases'.
According to Coillte Teo.'s own figures, this plantation actually received 1550 kgs of rock phosphate (14% P) in 6 applications and 400 kgs of urea (46% N) over its rotation. At these rates, you wouldn't need more than ‘small number of cases' to reduce terrestrial biodiversity and seriously pollute water bodies exposed to the run off.
In fact, the results of the research of the Working Group ‘has elucidated that phosphorus is not being retained by the peat soil and that the P concentration of the soils around Lettercraffroe is negligible' [‘Scenarios to be Investigated by the Owenriff Working Group', Aine O'Connor, National Parks and Wildlife Service, 11 November, 2005].
But nothing could be more absurd, more exasperating, and more likely to turn an NGO from unforgiving into downright hostile than the Department's refusal to amend the definition of peat soils to accord with the European Environmental Agency. [See ARTICLE OF THE WEEK] Their Spatial Analysis Group stands by their conclusion that 84% of Irish forestry planted between 1990 - 2000 was planted on peat soils. [FNN 150: http://www.friendsoftheirishenvironment.net/fnn/article.php?sid=177]
FNN drew the Minister attention to this in November of 2004 to no avail.
The reason the Minister could claim that only 30% was planted on peat soils in this period this was revealed in a Parliamentary reply earlier this year. The Department confirmed its choice of the definition selected from those given in Peatlands of Ireland, ‘Classification of Peat Soils' [R.F. Hammond, An Foras Taluntais, 1979] as being confined to depth only. [‘The definition of peat soils used by my Department is taken from the Peatlands of Ireland, Soil Survey Bulletin by R.F. Hammond, 1979. It constitutes a peat layer greater than 30 cm on drained peats and greater than 45 cm on undrained peats.'] The effect of this is to enable them to continue to claim that only 30% of those 265,738 hectares planted during this period was on peat soils.
In fact planting on peat soils 1990 - 2000 comprised 223,219 hectares - many of them hectares that have been so saturated with phosphates unavailable to the trees that (according to the Department of the Environment emails) ‘water lilies grow 2 - 3 times their normal size'. Given the right (or wrong) conditions, this run off will lead to eutrophication and accelerate the ever-nearing extinction of the fresh water pearl mussel.
By insisting on one definition of peat soils that ONLY considers the soils' depth, other peaty soils, podsols and gleys, are also planted. The peat layer of these soils are equally unable to retain phosphates making them vulnerable to leaching of nutrients into watercourses.
Yet R.F. Hammond makes it quite clear in Chapter 3 of Peatlands of Ireland that a ‘knowledge of the different peat types, their related internal soil factors and fabric arrangement are important in considering the production and adaptability of these soils to various crops, and productivity under defined sets of management conditions can only be quantified when soil properties are known.' He defines peat soils as soils that:
‘have 30% or more organic matter if the mineral fraction is 50% or more clay, or 20% or more organic matter if the mineral fraction has no clay, or proportionally intermediate organic matter contents if the clay fraction is intermediate'.
What is likely to have finally driven environmentalist over the edge was the recent agreement by the same Department of Agriculture under the Nitrates Directive's Schedule 1 (S.I. No. of 2006) to define peat soils as ‘soils with an organic matter content exceeding 20%' - just what Hammond suggests!
But this definition is not to be used for land which is to be used for forestry. [Parliamentary Replies]. Thus, a farmer may have two fields, side by side. The fertilisation of one for - say - sillage is restricted because it is a peat soil, having 20% organic matter. The neighbouring field, however, magically escapes such a definition and its restrictions by virtue of the crop being - trees.
But it is not only soil science that eludes our political mandarins.
We are told in these Parliamentary Replies that the Minister claims foliar analysis [taking samples of conifer needles to determine the rate of application of fertilisers] is the ‘internationally recognised method to determine nutrient requirements, including phosphorous requirements, in forests'. That may have been thought true in the 1960's when the senior members of the Forest Service attended Trinity and UCD.
But in fact, it has been known since 1983 and forms part of any University course in Ecology that ‘measuring the phosphorus content of needles gives no indication of phosphorous deficiencies in the soil'. [Science: Third Level, Ecology, Book 4, Ecosystems, Open University, 1996, 2001.] Further, 'internal translocation of phosphorous within the plants' means that under stress, the plants withdraw what phosphorous they have been able to absorb from the needles. Thus, the Forest Service is taking samples of vegetative material from which what little phosphorus has been taken up has been withdrawn.
Not only is phosphorus in peaty soils largely unavailable to plants, but as the applications of phosphorus increase, studies dating back to 1983 have show that the uptake of phosphorus by the roots decreases! [Dighton and Harrison, 1983] Thus, the repeated applications of fertilizer that are supposed to make uneconomic plantations viable only result in leaving yet a greater level of nutrients available for leaching from the terrestrial ecosystem - especially when the soils are exposed and disturbed during operations like clearfelling.
As FNN goes out this week we are awaiting the publication of draft Guidelines which are intended to protect a species on the verge of extinction. But the Guidelines have had to be produced in a manner that incorporates ‘cost efficiency' - a criterion agreed, the Minister informs us - as if to spread the blame - by all the parties involved. And they have been produced by a Department that lacks even an undergraduate's knowledge of soil science.
Hostile and unforgiving indeed.
Fresh water pearl mussel: the UK approach
Dear FNN,
Congratulations on your freshwater pearl mussel coverage.
The approach in the UK seems so much more mature than Ireland's as can be seen from an extract from their ‘Biodiversity Action Plan' below,
Perhaps Ireland could take the same approach?
Deirdre ni Murchu.
Action plan objectives and targets
Maintain the size of all viable populations.
Increase the size of all viable populations.
Encourage re-colonisation of this species into at least 10 suitable former areas by 2005.
Proposed actions with lead agencies
Policy and legislation
Identify water quality requirements for the species and seek to ensure that these form the basis for setting Statutory Water Quality Objectives, including Special Ecosystem Standards for sites occupied by the pearl mussel. (ACTION: DoE, DoE(NI), NRA, RPBs, SOAEFD, WO)
Seek to ensure that catchment management plans, flood defence activities, water level management plans and freshwater fisheries management take account of the requirements of this mussel, where populations still occur. (ACTION: DoE(NI), IDBs, NRA, MAFF, RPBs, SOAEFD, WOAD)
Encourage favourable land management within catchments where the river supports major populations of the mussel, through appropriate land management and grant schemes. (ACTION: DANI, FA, MAFF, SOAEFD, WOAD)
Site safeguard and management
Consider designating centres of large, self-sustaining populations as SSSI/ASSI, and designate SACs for the most important ones. (ACTION: CCW, DoE, DoE(NI), SOAEFD, WO)
Species management and protection
Review the protection given to the species under the WCA 1981. (ACTION: DoE, JNCC)
Consider re-introduction into formerly occupied areas if conditions become ecologically suitable, using appropriate stock to maintain regional genetic variation. (ACTION: CCW, EN, SNH)
Review the protection given to the species under the Wildlife (Northern Ireland) Order 1985.
1. Coillte Teo vs. FNN
"It is difficult to get a man to understand something when his salary depends on his not understanding it."
Upton Sinclair, as used in the Al Gore film ‘An Inconvenient Truth' and quoted by Tony Lowes in his debate with Gerry Egan on Morning Ireland. Listen to the interview: http://friendsoftheirishenvironment.net/interviews.html
2. Green argument used against replanting trees
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Another Life: When millions of Sitka spruce and lodgepole pine were planted on western bogs and hills in Ireland's "social forestry" of the mid-20th century, who could have guessed what a headache so many plantations would turn out to be?
Given the mature silvicultural knowledge existing by the 1950s, it seems incredible that conifers could have been planted on so many shallow peatland soils where winter storms would stunt them, tear them from the rock and topple them into each other like skittles.
Thinning the trees for better growth became pointless on such infertile ground. Two-thirds of Co Mayo and Connemara forests, for example, will never be thinned, but clearfelled. Even that disfiguring option is now in limbo as clearfell pollution of waterways is blamed for extinctions of Margaritifera, the freshwater mussel that acts as a "miner's canary" for Ireland's last pure rivers.
It was obvious from the beginning that conifer plantations on peat in areas of high rainfall would need fertiliser - notably, heavy dressings of slowly dissolving rock phosphate. Unlike mineral soils, peat does not retain the fertiliser, but nobody worried about the ecological implications. This kind of planting continued into the 1980s.
As plantations were clearfelled and the soil exposed to rain, unused phosphate has flowed downhill. In 2003 Dr Ted Cummins of UCD's Forest Ecosystem Research Group told of forestry ditches and streams running with phosphate at concentrations up to 806,000 micrograms per litre. In rivers with pearl mussels capable of reproduction, the phosphate level is about five micrograms per litre. In such pristine rivers it is phosphate - not nitrogen - that causes algal blooms, smothering the river bed and suffocating young mussels living in the gravel.
This is what seems to have happened in 2004 in the Owenriff River, which flows through Oughterard, Go Galway, and into Lough Corrib. A result has been a ministerial moratorium on clearfelling along Margaritifera rivers and even a temporary ban on new planting in such locations, whether by Coillte or private landowners.
Photographs published on the web by Friends of the Irish Environment show the big block of clearfell at Lettercrafoe Lake, Co Galway, that links to the Owenriff (see: http:// friendsoftheirish environment.net/pdf/clrfell.pdf). Bare ground, with its drainage channels, continues right to the water's edge. Once, it was peat silt from forestry operations that overwhelmed freshwater mussels and trout spawning beds, and silt traps are now a standard mitigating measure. But straw bales are no match for dissolved phosphate in the rainfall that is becoming typical of climate change.
Coillte resists any guilt in the matter, pointing to the decline of Margaritifera in unforested (but still polluted) rivers. The public tone of its spokesman, insisting on "science-based" proof of involvement, has been curiously at odds with the special concern for the welfare of the species expressed in Coillte's published plans for "sustainable" forestry.
Last spring, for example, the Co Mayo and Connemara District of Coillte circulated for public consultation a five-year strategic management plan giving detailed consideration to issues of landscape and nature conservation (see www.coillte.ie/managing_our_ forests/plans/w3.htm). It lists Margaritifera as "one of the most valuable" wildlife species of the region, notes "important populations" of the mussel downstream of one particular forest (Derrada in Co Mayo) and pledges steps to prevent enrichment of the river in agreement with the National Parks and Wildlife Service and the local fisheries board. Such proactive concern extends also to a vulnerable bat, to salmon rivers and to rare plants.
An ecological awareness runs, indeed, through much of the plan, even as it raises the probable need for further boosts of phosphate to trees with lagging growth. As late as the 1980s, apparently, thousands of hectares of Sitka were planted on peatland "in anticipation that site nutrition would be supplemented with fertiliser applied from a helicopter". This has been reviewed for "environmental sensitivities", actual cost-benefit, and the need to safeguard streams and rivers . As with the current rethink on clearfelling, substantial buffer zones would seem imperative.
A major key to all the future treatment of forestry on peatland is the 60-year-old Forestry Act that has compelled the replanting of every felled tree. "Environmental and economic priorities have shifted," says the Mayo-Connemara plan, "and the greater good is now served by releasing low production sites from forestry." Environmental arguments, it seems, can now be used to waive replanting, and many of the region's clearfelled, low-production forests may be left to regenerate largely from self-sown pine seedlings, without new drainage or fertiliser. Why not broadleaves? Because, say the western foresters, that would need much more of both.
Friends of the Irish Environment will, no doubt, continue to match Coillte's ecological promises against what happens on the ground. The NGO's Forest Network Newsletter, generally hostile and unforgiving, but often revelatory, is archived at the FIE website.
Michael Viney
© The Irish Times
1178. Mr. Sargent asked the Minister for Agriculture and Food the date on which Coillte Teoranta reimbursed the Government for the grant aid intended for farmers claimed by Coillte Teoranta, which was clawed back by the European Commission. [29078/06]
Minister for Agriculture and Food (Mary Coughlan): The question of whether Coillte should reimburse monies paid to them under the EU afforestation scheme stems from a decision by the European Court of Justice on the status of the company. The matter is under consideration within my Department and a decision will be made shortly.
1179. Mr. Sargent asked the Minister for Agriculture and Food if she will institute a review of the 1996 strategic plan for the development of the forestry sector in Ireland which reflects the current planting rates and accepts the impossibility of reaching the targets required for critical mass as specified in that plan and in the terms of reference of the review of that plan by a person (details supplied). [29079/06]
Minister for Agriculture and Food (Mary Coughlan): A review of current policy is underway. A High-Level Strategy Group in my Department is undertaking this review in the light of recent developments affecting the forestry sector. These include the Bacon Review, the situation following the introduction of the Single Farm Payment Scheme and the new Rural Development Regulation. The High-Level Strategy Group will be submitting its findings shortly.
1180. Mr. Sargent asked the Minister for Agriculture and Food if she will confirm that she revealed the full terms of reference of the Forestry and Margaritifera Group's technical working group for the proposed forestry guidelines in her reply to Parliamentary Question No. 172 of 1 June 2006, and that no agreement was reached with Coillte Teoranta to ensure that the terms of reference included the requirement for the guidelines to be cost efficient. [29080/06]
Minister for Agriculture and Food (Mary Coughlan): The Forestry and Margaritifera Group was established to identify and address the potential impacts of forestry operations on the freshwater pearl mussel. It consists of two sub groups (a) the Steering Group and (b) the Technical Working Group.
Parliamentary Question No. 172 of 1st June 2006 sought the terms of reference of the Steering Group. As there were no written terms of reference for the Steering Group I provided main terms of reference of the Technical Working Group which are as follows:
The Technical Working Group on Forestry and Margaritifera is to produce agreed guidance for all relevant forestry operations which could affect Margaritifera populations in the rivers designated SAC for that species. The guidance will apply to all relevant forestry operations within those portions of the catchments of these rivers upstream of the Margaritifera populations.
The terms of reference of the Technical Group also refer the methodology to be adopted, including reviewing existing Forest Service guidelines and Coillte's Environmental Impact Appraisal Procedure. Relevant published scientific data was also to be reviewed. The Technical Group was to report to the Steering Group and furnish guidance on the planning and execution of forest operations that would be effective in conserving Margaritifera, while being cost efficient and implementable. The terms of reference including the reference with efficiently were agreed by the Group as a whole.
1181. Mr. Sargent asked the Minister for Agriculture and Food if the definition of peat soils incorporated in Schedule 1 of the Nitrates Regulations 2006 (details supplied) as soils with an organic matter content exceeding 20 per cent will also be applied to soils used for forestry. [29081/06]
Minister for Agriculture and Food (Mary Coughlan): The soil classification used in respect of the 2006 Nitrates Regulations is for one purpose only - the application of fertiliser for agricultural purposes. The classification system for soils, including peat, which is used in forestry has much wider application, including species selection, estimation of potential rooting depth, potential yield, crop stability etc. It is not proposed to change this.
1182. Mr. Sargent asked the Minister for Agriculture and Food if she is satisfied that the foliar analysis, upon which her Forest Service's approval of fertilisation of forestry is based, is sufficient to determine phosphorous deficiency in the soil. [29082/06]
Minister for Agriculture and Food (Mary Coughlan): Foliar analysis is the internationally recognised method to determine nutrient requirements, including phosphorous requirements, in forests. There are recognised levels for different tree species to indicate their nutrient requirements.
A site inspection also takes place to ensure that any nutrient deficiency identified by foliar analysis is not due to silvicultural or environmental factors.
1183. Mr. Sargent asked the Minister for Agriculture and Food the maximum amount of phosphates fertilisers permitted to be applied per hectare for afforestation projects over their rotation. [29083/06]
1186. Mr. Sargent asked the Minister for Agriculture and Food if the Forest Service has the ability to regulate hand fertilisation if it is outside the grant aid period to ensure the protection of the environment. [29086/06]
Minister for Agriculture and Food (Mary Coughlan): I propose to take Questions Nos.1183 and 1186 together.
The application of fertiliser in forestry is governed by the Code of Best Forest Practice, Forestry and Water Guidelines and Forestry and Aerial Fertilization Guidelines, all issued by the Forest Service of my Department. These Guidelines, which reflect scientific findings and international good practice, set out requirements for permanent fertilizer-free buffer strips adjacent to waterways, methods of application, fertiliser formulation, rates and times of application and other stipulations.
A forest rotation in Ireland is typically 35 to 45 years or longer. If phosphate fertiliser is required, it is typically applied at the time of initial afforestation at a rate of 250 kilogrammes of rock phosphate (14.5% Phosphorus) per hectare. Rock phosphate is a slow release fertiliser. On unenclosed land the maximum amount permitted at this time is 350 kilogrammes of rock phosphate per hectare. In a minority of cases one or more additional applications may be necessary during the rotation.
As regards 'hand fertilisation' or 'manual application', this is the typical method used in the early life of a forest before it closes canopy, i.e. before the crop is circa 10 years of age. This is well within the period for which premiums are paid by my Department. After the forest closes canopy, the only practical way to apply fertiliser is by air and this requires specific approval from my Department. In such cases, the maximum amount permitted is 350 kilogrammes of rock phosphate per hectare at a concentration of 11-16% Phosphorus.
1184. Mr. Sargent asked the Minister for Agriculture and Food if she will provide an assurance that sufficient information is required to be provided in the application for all felling licences to ensure that the Forest Service is able to assess the impact on the environment; and if she will further provide the information required for each application. [29084/06]
Minister for Agriculture and Food (Mary Coughlan): The information required for felling licence applications is prescribed under legislation in accordance with the Forestry Act, 1946(Part IV) Regulations, 1949 and is furnished by way of a Felling Application and Notice submitted by the landowner.
Part I of the Felling Notice contains particulars relating to the applicant and the land on which the trees stand together with a declaration of intention to replant and the extent of replanting to be undertaken.
Part II contains details of trees to be cut down including species, number and age of the trees together with an estimate of the value of the timber and reason for proposed cutting or uprooting.
Part III contains details of the trees proposed to be cut down or uprooted and claimed to be "exempted trees" as defined in Section 35(1) of the Forestry Act 1946.
In addition to the above, the application must also include a 6-inch Ordinance Survey map indicating the location of the plantation. A separate report may also be required detailing the felling and replanting operations it is proposed to undertake.
The follow up inspection procedures for approval of licence applications include an assessment of the environmental considerations for the sites in question. This can entail referral of the application to the various consultation bodies such as National Parks and Wildlife Service, Fisheries Boards and Local Authorities for their consideration and recommendations if applicable. Any recommendations made are taken into account by the Forest Service in their decision to grant or withhold a licence.
I believe that the combination of information supplied, subsequent examination and consultation provides a sound basis upon which to assess applications to fell. The appropriateness of the information provided is under continuous review.
1185. Mr. Sargent asked the Minister for Agriculture and Food if the Forest Service has the ability to regulate forest road construction if it is not being approved for grant aid to ensure the protection of the environment. [29085/06]
Minister for Agriculture and Food (Mary Coughlan): I have no authority to regulate non-grant aided forest road construction on private property. Protection of the Environment in such a non-grant aid situation is a matter for the National Parks and Wildlife Service and the Department of the Environment Heritage and Local Government
1187. Mr. Sargent asked the Minister for Agriculture and Food the enforcement provisions she has to control unapproved plantations of trees; and the powers she has to require that the development be reversed and the owner be prosecuted. [29087/06]
Minister for Agriculture and Food (Mary Coughlan): Under the Environmental Impact Assessment (Amendment) Regulations 2001 (S.I. 538/2001), which were introduced by the Minister for the Environment, Heritage and Local Government, my prior approval must be obtained for all afforestation projects, regardless of whether any application is made for grant aid.
A full review of forestry legislation is underway at present in my Department, and the question of providing direct powers in primary legislation for dealing with unapproved plantations, including comprehensive sanctions, is being closely examined.
An anomaly has arisen in relation to the definition of ‘peat' within the Department of Agriculture.
The ‘Nitrates' Regulations 2006 [European Communities (Good Agriculture Practice for the Protection of Waters) Regulations, 2006 (S.I. No. of 2006)] Schedule 1 has been amended to clarify the definition of peat soils. This is given as ‘soils with an organic matter content exceeding 20%'. [Department of Environment, Press Release 19 July, 2006.]
However the definition of peat soils used by the Forest Service was given by the Minister for Agriculture in a written reply to a Parliamentary Question this April. The soils must constitute ‘a peat layer greater than 30 cm on drained peats and greater than 45 cm on undrained peats.' [13955/06]. No reference was made to the organic matter in the soil. For her authority, she referred the Deputy to the ‘Peatlands of Ireland, Soil Survey Bulletin' by R.F. Hammond, 1979.
However, in Chapter 3 of Peatlands of Ireland, ‘Classification of Peat Soils' [R.F. Hammond, An Foras Taluntais, 1979], the author explains that a ‘knowledge of the different peat types, their related internal soil factors and fabric arrangement are important in considering the production and adaptability of these soils to various crops, and productivity under defined sets of management conditions can only be quantified when soil properties are known.'
He gives three definitions of peat soils. At the ‘highest level', the classification is based on ‘phytosociology and genetical concepts' - essentially the plant communities. This definition is useful for the classification of bog types. It was the difficulties the European Environmental Agency [EEA] experienced in interpreting the satellite mapping of Irish vegetation that led to the exchange between Ireland and the EEA over the amount of ‘peatlands' afforested between 1990 - 2000.
Hammond comments that this method of classification is of limited value for peatlands which are being used or are potential areas for agriculture, horticulture, or forestry as ‘such peatlands require a classification scheme which defines the special soil characteristics essential for evaluating their ultimate use.'
The definition given by the Minister is explained by Hammond as ‘from the early days of soil survey a depth of 30cm was taken as constituting a peat soil. This has in part conditioned the acceptance of a definition based on depth.' However, Hammond is adamant that ‘productivity under defined sets of management condition can only be quantified when soil properties are known.'
He therefore gives the third definition which is reflected in Schedule 1 of the ‘Nitrates' Regulations 2006:
‘Organic soil materials that are saturated with water for prolonged periods, or are artificially drained, and have 30% or more organic matter if the mineral fraction is 50% or more clay, or 20% or more organic matter if the mineral fraction has no clay, or proportionally intermediate organic matter contents if the clay fraction is intermediate'
The definition of peat soils is critical to forestry practices in Ireland.
In initial afforestation, the soil type governs the suitability of a site for afforestation and the degree of restrictions necessary for environmental protection. Applications for felling licenses on peat soils must also be treated differently.
This is because there are three specific concerns associated with forestry on peat soils.
Acidification
Peat soils are naturally acid. Acidification is accelerated on poorly buffered soils by afforestation with conifers. In extreme situations, acidification of surface waters can cause mobility of aluminium from the soils and rocks which can be fatal to many forms of invertebrates and aquatic organisms - e.g. salmon and trout.
Siltation
Siltation is likely to occur when fragile peat soils are disturbed because of the lack of soil structure. Siltation in itself can result in mortalities and is responsible for smothering the gravel beds where fish lay their eggs and juvenile mussels live exclusively within the gravel. In cases of extreme siltation (or pollution) the innate response of the fresh water pearl mussel is to ‘clam up' and remain so until the detrimental conditions have passed. If these conditions last for more than a few hours, the mussel becomes stressed and may die from lack of oxygen.
Phosphate enrichment
Phosphorous is generally immobile in mineral soils where leaching is unlikely under forestry, although surface runoff is possible. However, on peat soils recent research [Farrell 2004] has confirmed that phosphorous is leached at clearfell from these soils. The availability of phosphorous to the trees begins to decline at a pH of 5 to be virtually unavailable below a pH of 4. This is the case in acid soils including peat, peaty podsols and peaty gleys, where phosphorous is locked up as insoluble iron or aluminium phosphates and is unavailable as a nutrient for plants. Low pH tends to mobilise ions bound to soil particles and they are then readily leached into watercourses, potentially causing eutrophication which can be fatal to many forms of aquatic life. Phosphorus is used extensively to raise otherwise poor yield classes on peat soils where it is applied at the rate of 350 kg/hectare per application [Forestry Standards, 2001]. This practice can cause significant and long term environmental damage to fragile ecosystems.
The current application form for initial afforestation shows only two soil types, mineral and peat. With the definition based solely on depth, many sites which are peat soils in terms of their soil properties and pose threats to the environment when fertilised remain unconsidered.
At the felling stage, clearfelling on peat soils is especially destructive, creating as it does a pulse of both siltation and nutrients - phosphates and nitrates - which are potentially lethal to vulnerable species, including the endangered fresh water pearl mussel. No environmental information is normally required with a Felling Licence although in these cases the application for afforestation was made 35 or more years ago, when our understanding of soil sciences and forestry was poorly developed.
It would, therefore, be prudent to seek to have the Forest Service apply the same definition of peat soils as that agreed with the Commission for the ‘Nitrates' Regulations 2006 and to ensure that this definition forms part of all considerations of applications for afforestation and felling, particularly in catchments that have been designated for protection for listed species under the Habitats Regulations 1997.
[This document was submitted by registered post to David Byrne, Assistant Secretary of the Department of the Environment in charge of Forestry on 7 August, 2006. Reminders were issued on 1 September, 2006 and again on 21 September 2006. No acknowledgement or reply has yet been received.]
As part of Coiltle Teo.'s certification by the Forest Stewardship Council, Woodmark is seeking submissions on the application by Coillte Teo to seek a derogation for the use of cypermethrin, a toxic insecticide that is on the Forest Stewardship Council's banned list. FNN is offering a €50 book token for the best submission.
5 November 2006, 2.30 PM
Open Day at Manch. The last Open Day of the year at the Irish Natural Forestry Foundation's demonstration site. 5 miles from Dunmanway on the Bandon road in West Cork, 22 hectares of forestry have been planted for sustainable forestry management and 28 hectares of native woodland renewed and extended. Horse Logging demonstrations. Admission Free.
9 February 2007
NATIONAL NGO FORESTRY CONFERENCE - ‘2007 - FORESTRY AT THE CROSS ROADS'
Botanic Gardens, Dublin
The Irish Natural Forestry Foundation's first National Forestry Conference brings the Foundation's perspective to the CAP 2007 - 2012 changes in forestry funding. The theme of the conference explores how Irish forestry can deliver on the new multiple and varying demands on our forestry resources.
The conference will be chaired by Ronan O'Flaherty, the Principle Officer of the Irish Forest Service.
Speakers include:
Franz Fischler, European Commissioner for Agriculture and Forestry 1994 - 2004. European Forestry Today.
Colin Price, Professor of Environmental & Forestry Economics, University of Wales: British forestry policy: shifting cultivation of objectives
Dr. Douglas Macmillan, Reader, Durrell Institute of Conservation & Ecology (DICE) at the University of Kent at Canterbury: Valuing the non-timber benefits of forests
Colin Edwards, Forest Research, UK Forestry Commission: Restructuring / Transforming conifer forests
Declan Little, Chairman, Woodlands of Ireland and Irish Forestry Certification Initiative: The value of native woodland timber
John O'Reilly, CEO Greenbelt, Ireland's largest private Forestry Company and Joe O'Carroll, Managing Director, OC Consulting; formerly Operations Manager with COFORD, the Irish Forestry Research Board 1999 -2005: Forestry beyond 2007 - finding common ground for private and public interests?
Ian Wright. Project Manager for INFF sustainable forestry project at the Manch Estate near Dunmanway in County Cork: The Lessons so Far
Enquiries INFF Hon. Secretary, Caroline Lewis 027 73208
8. ABOUT US
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Tony Lowes
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Ian Wright
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Added: 04/10/2006
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