The Irish Farmers' Association - IFA

Lobbying Organisation The Irish Farmers' Association - IFA

Date published 21 May, 2023

Relevant Matter Matters involving public funds

Public Policy Area Environment

Period 1 Jan, 2023 to 30 Apr, 2023

Specific Details Forestry Programme 2023 - 2027

Intended results To highlight farmers' concerns in relation to Ireland's future forest strategy, particularly the barriers that exist which have seen a dramatic decline in farmer planting in recent years. To demonstrate that farmers are crucial to success of future forest strategy - Farmers must be recognised as crucial decision makers with regards to the future forest strategy. Agricultural land accounts for approximately 65% of the total land area of Ireland and farmers will ultimately determine the production systems implemented on their land. - The decline in farmer planting and corresponding increase in investor planting can be linked to the equalisation of premium rates for farmers and non-farmers in 2015, which saw the removal of the farmer premium differential and reduction in the duration of the farmer premium payments from 20 to 15 years. - This shift in policy to significantly increase incentives for investors led to a substantial increase in investor planting, with investors accounting for 40% of the afforestation programme between 2015 and 2020. The decision not to increase the premium rate for farmers and reduce the duration of premium payments, seriously undermined farmer confidence in the programme. This combined with a range of other issues that reduced the land available for forestry, increased the regulatory burden and associated management costs, can be linked to the sharp decline in farmer planting. Barriers to Farm Forestry - The reality is that many farmers no longer view forestry as a safe investment. Under legislation they are locked in under the replanting obligation while they have seen their productive area continually eroded with evolving environmental regulations and a regulatory system that is impeding management and reducing profitability. The lack of support for farmers affected by ash dieback disease has made others wary of entering forestry under the current terms and conditions. - The €1.3 billion funding announced under the new Forestry Programme 2023 to 2027 shows a financial commitment from the Government to forestry. The increase in forest premium rates and the return to 20-year premium payment for farmers are positive steps, and have generated renewed interest in the programme but barriers remain that need to be resolved if this interest is to be converted into land planted. - Despite the work that has been ongoing through Project Woodland including the Regulatory Review Report and the consultations on the draft Forest Strategy and Implementation Plan, many of the substantive barriers to farmer planting remain. If farmers are to re-engage and plant at the level required to meet our climate obligations, then the outstanding issues that are deterring farmers from planting need to be addressed 1. The current licencing system is not fit for purpose for farm forests and places too high a regulatory and cost burden on farmers considering forestry at farm level. Excessive bureaucracy, ineffective administration and spiralling costs have led to forestry no longer being viable at farm scale. A proportionate regulatory burden that reflects the size, the type of operation, and which guarantees a decision within an agreed timeframe is urgently needed 2. The single greatest barrier to planting is the replanting obligation, this must be reviewed, and options proposed if planting targets are to be met. 3. The non-productive areas of forests have increased to 35% (20% broadleaf planting and 15% areas for biodiversity enhancement) in the new programme with no payment to farmers on this land beyond the 20-year forest premium, this needs to be addressed. A payment for ecosystem services must be paid for engaging in good biodiversity management practices within these areas. 4. The proposed pilot Payment for Ecosystem Services scheme under the new programme is asking farmers to further reduce productive area for a seven-year payment, this is unacceptable. The proposed payment must be for engaging in good biodiversity management practices within these areas, not further extending these areas. 5. The treatment of forest owners whose ash plantations have been devastated by disease has undermined confidence and trust in the programme, until this is properly addressed farmers, and the loss of timber earnings recognised, farmers will not commit their land to forestry. IFA is seeking that all infected plantations should be eligible for a 100% reconstitution grant and be paid a forest premium for 20 years on the replanted land to compensate for the financial loss incurred. 6. A voluntary carbon scheme must be introduced to pay farmers for the carbon sequestered. - Despite the announcement in November 2022 of €1.3 billion for the new Forestry Programme 2023 to 2027, we find ourselves in February 2023 with no new programme. The Department has introduced an interim programme, that can process existing applications under the new grant and premium rates, but cannot accept new applications for planting or forest roads.orestry Programme 2023 to 2027 The new Forestry Programme 2023-2027 is expected to come force in early 2023, subject to State Aid approval from the EU Commission, farmers are very concerned that the approval could be delayed and the impact this would have on a forest sector. - If we consider that the average turnaround times for afforestation licences in 2022 were just under 18 months, the delay means that meeting the afforestation targets for 2023 and 2024 is unlikely. Based on current turnaround times if State Aid approval is received at the end of Q3 in 2023, a farmer that applies to plant would have to wait until October 2024 to get a decision on the planting application. - This is an untenable situation, the current average turnaround times for afforestation licences is 4.5 times the legal requirement of 4 months - Changes need to be made to the current licencing system to streamline and speed up turnaround times for afforestation and all forest licence applications. The system must guarantee that a farmer has to wait no longer than 4 months for a decision on forestry licence as set out in the Forestry Act 2014. It is the only way to offset the delay getting State Aid approval and ensure that we have a planting programme in 2023 and 2024. Roadside Ash Dieback - There is growing concern among farmers regarding the amount of roadside ash trees infected with ash dieback disease. Ash dieback is now prevalent throughout most of the island of Ireland and is likely to affect the majority of ash trees over the next two decades. - The Roads Act 1993 places a statutory obligation on landowners to ensure that roadside trees do not present a danger to those using public roads. If a tree or branch falls onto a road and consequently causes injury or damage to an individual or property the owner of the tree may be liable, if found to be negligent. - Farmers feel aggrieved that they are now being held solely responsible for the safe removal of these diseased roadside trees when the Department did not have adequate controls in place to stop the importation of infected plants. IFA is seeking the introduction of a financial support package which would enable farmers and landowners to safely manage infected roadside ash trees, and reduce the risk of injury. Safely removing these trees is costly and needs to be coordinated at a local level with the Local Authorities Forestry Development Agency - The existing structures are failing forest owners and the wider industry. A new and innovative approach is needed to restore confidence and incentivise farmers to plant while addressing issues such as the barriers to afforestation, harvesting and forest road construction to access forests. - There is a need to establish an independent structure, a Forestry Development Agency, to drive the industry. The Agency would be charged with optimising the performance of the Irish forest industry by providing technical expertise, business support, funding to expand the Forest Owner Producer Organisation network and establish a National Forest Certification scheme and promoting responsible environmental practice to support both afforestation and mobilisation of the existing forest resource. To seek clarity on when the Forestry Programme 2023 to 2027 would be approved by the EU as currently farmers are blocked from applying.

Name of person primarily responsible for lobbying on this activity Tim Cullinan IFA President, Damian McDonald IFA Director General, Brian Rushe IFA Deputy President, Jason Fleming IFA Farm Forestry Chair, Geraldine O'Sullivan IFA Senior Policy Executive, Edel McEvoy IFA Policy Executive

Did any Designated Public Official(DPO) or former Designated Public Official(DPO) carry out lobbying activities on your behalf in relation to this return? You must include yourself, and answer Yes, if you are a current DPO or a DPO at any time in the past. (What is a Designated Public Official?) No

Did you manage or direct a grassroots campaign? No

Was this lobbying done on behalf of a client? No

Lobbying activity

The following activities occurred for this specific Subject Matter Area.

Letter (1)

Submission (1)

Meeting (1)

Email (2-5)

Social Media (1)

Informal communication (2-5)

Designated public officials lobbied

The following DPOs were lobbied during this return period on this specific Subject Matter Area. These DPOs were involved in at least one of the Lobbying Activities listed above, but not necessarily all of them. As returns are specific to a Subject Matter Area the above Lobbying Activities may be associated with multiple returns.

Barry Andrews MEP (European Parliament)

Billy Kelleher MEP (European Parliament)

Brendan Gleeson Secretary General (Department of Agriculture, Food and the Marine)

Brendan Smith TD (Dáil Éireann, the Oireachtas)

Brian Leddin TD (Dáil Éireann, the Oireachtas)

Cathal Crowe TD (Dáil Éireann, the Oireachtas)

Charlie McConalogue Minister (Department of Agriculture, Food and the Marine)

Chris MacManus MEP (European Parliament)

Ciarán Cuffe MEP (European Parliament)

Clare Daly MEP (European Parliament)

Colm Markey MEP (European Parliament)

Deirdre Clune MEP (European Parliament)

Denis O'Donovan Senator (Seanad)

Frances Fitzgerald MEP (European Parliament)

Grace O'Sullivan MEP (European Parliament)

Jackie Cahill TD (Dáil Éireann, the Oireachtas)

Joe Flaherty TD (Dáil Éireann, the Oireachtas)

Luke Ming Flanagan MEP (European Parliament)

Lynn Boylan Senator (Seanad)

Maria Walsh MEP (European Parliament)

Martin Browne TD (Dáil Éireann, the Oireachtas)

Matt Carthy TD (Dáil Éireann, the Oireachtas)

Michael Collins TD (Dáil Éireann, the Oireachtas)

Michael Fitzmaurice TD (Dáil Éireann, the Oireachtas)

Michael Ring TD (Dáil Éireann, the Oireachtas)

Mick Wallace MEP (European Parliament)

Paul Daly Senator (Seanad)

Paul Kehoe TD (Dáil Éireann, the Oireachtas)

Pippa Hackett Super Junior Minister (Department of Agriculture, Food and the Marine)

Sean Kelly MEP (European Parliament)

Tim Lombard Senator (Seanad)

Victor Boyhan Senator (Seanad)