Specific Details
IFA Submission on Páirc Náisiúnta na Mara, Cíarraí
Intended results
To contribute to the public consultation on the future development of Páirc Náisiúnta na Mara, Ciarraí - Ireland's eighth and largest National Park, with more than 77,000 acres of lands and seas in public ownership included within the Páirc's boundaries.
To highlight that Economic activity must be preserved
- National Parks serve a purpose, in providing adequate protection to nature, however the cultural and economic interests of farmers and existing farm activity, together with those within our Aquaculture sector, must be preserved and protected.
- It is vital too that farmers contribution to wildlife conservation and the protection of nature is fully recognised. Agriculture over many millennia has shaped the landscape of Ireland. Irish farmland is characterised by having a rich diversity of habitats such as hedgerows, field margins, ponds and streams, native woodland, bogs and species-rich meadows and pastures.
- Any protection afforded to National Parks cannot create a new/alternative form of land designation and/or place additional demands already designated lands. Further restrictions on farm or aquaculture activities in/adjoining National Parks will not be accepted.
- The economic viability, value and security of c.35,000 farms on designated lands are already being undermined due to the severe restrictions imposed on them, compounded by the less-than adequate administrative and governance systems. This is unacceptable.
- Farmers within / adjoining National Parks need to feel a sense of ‘ownership' in how sites are managed. Longterm commitments to support farmers to support conservation measures are not there. CAP is stretched in many directions and cannot be the solution for everything. The same applies to those within the Aquaculture sector and the CFP.
- The State needs to adequately invest in Aquaculture and farmers (especially in uplands / designated areas) to deliver for Ireland's obligations, whether legal or moral (for nature, ecosystem services and future generations). Currently, schemes are designed, run for 5 years, and then disappear. Support and compensation should be more permanent.
- A ‘no compensation, no designation' policy should apply. This review needs to better provide full compensation and financial security for those operating on high nature value; upland & designated sites.
- Aligned with above and the protection of priority species/habitats, addressing threats from predators and increased recreational activity will require a targeted and comprehensive approach within the National Biodiversity Action Plan. In collaboration with relevant NPWS stakeholders, the financing of an ‘Active Predator Management' scheme should be established.
Enforcement mechanisms
- National Parks, and associated stakeholders, need to assume greater ownership and responsibility for a number of key and continual concerns of landowners, including amongst others access to privately owned lands; dog control; control of invasive species; and disease control.
- All too often, and indeed of growing occurrence with regard dog control, farmers are being physically/verbally abused; farm animals are killed/injured/worried from ‘entitled' recreational users and dog owners (albeit still very much in the minority) who abuse permissive agreements and the desires of landowners. There have been a number of cases here in Kerry recently. This needs to be rectified as a matter of priority.
The term ‘Invasive species' covers a multitude (e.g deer; grey squirrel; mink; Japanese knotweed; Rhododendron plant; Sitka Spruce etc.). For most, targeted site-specific interventions (e.g culling) with input from local landowners will improve situations over time, while for others (e.g where farm activity/animals may be involved) direct consultation with landowners; incentivised measures and/or reliance on existing governing policies (e.g. Conditionality within CAP Strategic Plans etc.) will b
while for others (e.g where farm activity/animals may be involved) direct consultation with landowners; incentivised measures and/or reliance on existing governing policies (e.g. Conditionality within CAP Strategic Plans etc.) will b
will be required. Simply restricting further / banning certain farming activities in such areas will not be accepted, and indeed prove as ineffective as doing nothing at all. Initial results from Year 1 of the ACRES programme show that much of the habitats within our uplands / areas of high nature value are being hindered because of being under-grazed as much as they are from being over-grazed. Practical, pragmatic, targeted interventions, agreed by all relevant stakeholders, is required.
- In terms of disease control, TB continues to cause enormous hardship on farms, and the ongoing increase in the number of TB reactors must be stopped. Critical to achieving this is a reduction of the prevalence of the disease within the wildlife population; implementation of an effective wildlife control programme and vaccination programme.
- The Irish Deer Management Strategy Group announced plans to reduce the densities of deer in regions where the population is not maintained safely within its natural habitat. The government must provide the funding to implement such a recommendation, and to develop and expand this structure. The same should apply for excessive densities of badgers. This may require a closed period for National Parks during certain times of the year to facilitate.
- Careful consideration also needs to be given to expanding existing recreational routes, and the displacement effect it may have on existing inhabitant animals onto adjoining lands. IFA recognises the importance of recreational routes such as Greenways and Blueways, in promoting agri-tourism and economic activity in rural areas.
However, they also have a significant impact on farming activity and rural communities which needs to be considered, spanning privacy, safety, and security; anti-social behaviour; litter; animal disease, wildlife and environmental issues. To date, consultation with landowners has been haphazard and, in some instances, non-existent. Landowners are the most critical stakeholders in the development process.
In line with Government Strategy for the Future Development of Greenways and the Greenway Code of Best Practice greenway projects must maximise the use of public lands and minimise the impact and disruption on privately owned lands and farms.
- Ultimately, practical, pragmatic, targeted interventions, agreed by all relevant stakeholders, is required to restore damaged ecosystems (including within National Parks), together with the realisation that interventions need time to take effect.
Education and Outreach
- The lack of engagement with farmers and those in the Aquaculture sector at local and national level has been a key barrier to the effective implementation of conservation objectives in the past. The review must ensure that engagement is maximised and that the engagement provides an opportunity to build consensus that balance conservation goals with economic and social drivers.
- More broadly, participants in recreation activities (in / around National Parks) should be aware that there is no legal right of access to the Irish countryside. Those who enter onto land owned by others, for the purpose of recreation, do so due to the goodwill and tolerance of landowners. Where a landowner or occupier asks you to leave the land, you should do so.
- Ireland's waymarked trails are “permissive routes” that have been developed with the landowners' agreement. They are not public rights of way and the landowner is entitled to withdraw their consent to access.
- Investment in new/increased signage is required, in various languages (incl Irish), with greater profiling (& enforcement) of ‘No Dogs Allowed'; ‘No Littering' and ‘Respect rights of Landowners'; ‘Park only in designated car parks' is undertaken. Many of our National Parks are / within vicinity of productive farmed lands. The economic interests and rights of farmers need to be better preserved.
Amenities in Parks
Numbers within National Parks should be restricted to available designated car spaces. We cannot have situations where vehicles are parked on public roadways, limiting access to private dwellings/farmed land, and creating potentially obstructions for emergency vehicles.
Aquaculture
- In addition to that outlined above, specifically regarding Aquaculture, a significant majority of Irish Aquaculture sites already operate within or adjacent to existing Natura 2000 sites, and have complied in recent years with Appropriate Assessment and EIS/EIAR requirements.
The Aquaculture sector complies with obligations outlined in a number of environmental laws such as; Habitats Directive 92/43/EEC, Birds Directive 2009/147/EC, Water Framework Directive 2000/60/EC, Consolidated Environmental Impact Assessment Directive 2014/52/EU; and under the current aquaculture licensing system,
the Aquaculture sector is required to comply with more environmental legislation than any other sector in the marine space, thereby ensuring the healthy and sustainable use of Ireland's seas.
- Aquaculture needs a viable marine environment in which to operate, as an industry that works with nature in order to produce high quality food produce. We are fully cognisant of our obligations in relation to conservation objectives.
- Aquaculture provides an important social dividend, providing employment in rural coastal & island communities through the sustainable production of high-quality food with low-carbon footprint. The sector's contribution in sustaining vitality and viability in coastal areas must not be ignored or underestimated.
- Aquaculture also contributes to the control of nitrogen/phosphorous removal as shellfish are filter feeders which aids to reduce and mitigate eutrophication effects of Irish coastal waters. Shellfish, as filter feeders, actually increase water quality and habitat quality in Irish coastal waters. Shellfish provide a nutrient removal service through feeding which enhances bacterial denitrification, sedimentation rates, reduces turbidity as well as contributing to nutrient sequestration.
- The National Marine Planning Framework (NMPF) recognises the important role of seafood production, fishing and aquaculture as a source of economic and employment activity, most notably within those coastal communities which are more economically dependent on these activities than alternative sources of employment
- It is recognised in the NMPF that any future designations of marine area of the will be informed by continuous engagement between the State and wider seafood sector to ensure that co-existence becomes a reality. The Aquaculture (& Agriculture) industry must be represented in any stakeholder engagement groups relating to the proposed future development of Páirc Náisiúnta na Mara, Ciarraí.