Specific Details
Ireland's Draft Forest Strategy and Implementation Plan
Intended results
Effective Communication - IFA welcome the commitment in the draft Strategy to continue to improve transparency, efficiency and effectiveness of communication.
IFA propose - that a Customer Service Charter is developed and agreed by all stakeholders as a matter of urgency to stabilise and rebuild confidence in forestry. The Customer Service Charter must ensure that private forest owners are being treated equally with Coillte in relation all issues including licences.
Maintaining a trusting relationship with customers is a key driver of success and consideration should be given to the Customer Service Charter having statutory guaranteed timelines for decision on licences and communication.
Regulatory and Legislative Processes
The current regulatory system needs to be reformed to support the scale of planting and management that needs to take place on farms by 2050. If these targets are to be met the regulatory system needs to be able to process multiple volumes of licences the current system can handle within the legislative timeframe of 4 months.
IFA is disappointed that the recommendation in the Project Woodland Regulatory Review Report do not go far enough to support the scale of planting required to meet the targets.
There are recommendations contained in the report that will, if implemented, streamline the process. However, the recommendation not to exempt thinning operations from the licencing process or to recommend a single integrated licence system is a deficiency in the review, particularly in light of the fact that such an approach is commonplace elsewhere in Europe for smaller private forests.
Furthermore, serious consideration needs to be given to relaxing the replanting obligation. In repeated reviews the replanting obligation has been highlighted as a significant barrier to planting. Relaxing the replanting obligation would reassure farmers and may positively impact forested land values.
In reality most afforested land provides only marginal returns in other forms of agriculture and the high costs associated with returning to agricultural use makes this land use reversion unlikely.
Land Availability and Alignment of Land Uses -
The greater integration of forestry with CAP and particularly ACRES and the Organic Farming Scheme (OFS) is a positive development, and recognises the benefits of forestry to create a valuable landscape mosaic at farm-level.
The challenge to meet the afforestation targets set out in the Climate Action Plan 2021 must not be under estimated. It is essential that all land that satisfies productive and environmental requirements is eligible to plant under the future iterations of the Woodland Creation & Afforestation scheme. The strategy will need to leverage all productive land to achieve the afforestation targets.
IFA propose - that the Strategy commits to undertaking a full review of current restrictions on all land that satisfy the productive and environmental requirements of the Afforestation scheme to remove blanket restrictions on planting land in order to meet the targets.
Intervention 1 - Forest Creation
The extension to the number of Forest Types is a welcome addition in the Forestry Programme 2023 to 2027 as it provides more options for farmers to establish forest types to satisfy their management objectives.
20% native species and ABEs
The increase in the mandatory native species component from 15% to 20% for all conifer forest types reduces the timber production area within a woodland and therefore the economic return on a farmer's investment. This loss of timber production and future earnings from this area of land are only offset for 20-year term of the premium payment.
Furthermore, under the forest creation schemes farmers are required to set aside an additional 15% for areas of biodiversity enhancement (ABEs). This increases the non-timber productive area to 35%.
If we estimate that timber revenue from a Sitka spruce forest over a rotation range from €30,000 to €40,000 per hectare, then the loss of timber revenue on the land set aside for native species and ABEs equates to a loss of timber revenue to between €10,500 and €14,000 per hectare
IFA propose that If farmers are to plant at the scale required to meet the climate action targets, it is vital that the government introduce a Payment for Ecosystem Services (PES) on the native species and ABEs (35%) after the 20- year premium payment period has concluded to adequately compensate farmers for the loss of timber revenue on this land.
The PES would also reduce the risk to farmers considering forestry as a land use option, as should the regulatory framework change in the future and require a farmer to further reduce productive area the PES would offset the risk.
Forest Management Plans (FMPs)
The introduction of a mandatory requirement to submit a Forest Management Plans (FMPs) with all Form 2 applications for the Afforestation scheme is a new and additional requirement under the new programme. This is a welcomed development that will provide guidance and a source of information to farmers when they typically take on the responsibility of management from their forester.
IFA propose that the FMP payment that currently supports farmers to submit management plan at year 11 should be available to all farmers to submit the required FMP at year 4 in addition to their second instalment payment.
Native Tree Area Scheme
IFA propose that there should be parity between the duration of payments that farmers receive under the Native Tree Area scheme and the general Afforestation schemes. Irrespective of the size of the forest area being established is it important that there is payment parity between forestry schemes.
Intervention 2 - Creation of Agroforestry Systems
The changes introduced in the Forestry Programme 2023 to 2027; such as increasing the duration of the premium payment from 5 to 10 years and the expanding the type of agroforestry schemes to support silvoarable systems are positive developments.
IFA propose that the replanting obligation under agroforestry systems should be relaxed so that farmers can be encouraged to try agroforestry without being locked into trees forever on their land.
Intervention 3 - Infrastructure and Technology investments
Forest Road scheme
The additional elements available under the Forest Road scheme are a positive development providing flexibility to farmers in relation to the design of roads. This flexibility should be extended into the specifications under the forest road scheme, particularly for the designing and constructing forest roads in smaller private forests where options may be limited.
IFA propose that this flexibility should be extended into the specifications under the forest road scheme, particularly for the designing and constructing forest roads in smaller private forests where options may be limited. The ongoing review of the Forest Road Manual should provide for this flexibility and should provide opportunities to adjust specifications on a case-by-case basis to ensure that forest roads are constructed appropriately and the cost of construction is reduced.
Payment for Ecosystem Services Pilot Premium Structure
The pilot PES premium structure proposed and the additional requirements that would further reduce productive area is of serious concern, particularly considering that the duration of the premium payment is only seven years.
Farmers that participated in the short-lived Forestry Environmental Protection scheme (FEPS) that provided additional environmental services, reduced their productive area and received payments for five years have lived experiences of the risks associated with such pilot schemes.
IFA propose that the premium payment should be extended beyond the proposed 7 years, and that payments adequately reflect the income foregone from timber revenue and the costs associated with implement actions depending on the option. IFA cannot support the proposed pilot PES structure without this guarantee .
Carbon Farming Initiative
The potential of carbon farming to sequester CO2 emissions as an option to incentivise farmers to contribute to climate mitigation and deliver on the Ireland's ambition for obtaining climate neutrality by 2050 should be explored in the Strategy. Afforestation, agroforestry and reforestation effective carbon farming practices.
IFA propose - that a measure is included to provide technical guidance on carbon farming, on how to set up, measure and implement carbon farming with the aim of establishing voluntary carbon farming initiatives for private forest owners.
Intervention 4 – Sustainable Forest Management
The ambition to increase the diversity of Ireland's forest estate needs careful planning and active management. The proposed measures need to ‘future-proof' both the State and farmers investment to actively support farmers to manage broadleaf and native forests, so that trees planted now will continue to thrive and be of benefit to future generations.
Measure 6 Forest Management Plans (iPLAN Scheme)
This measure to support and encourage active forest management is a positive development. The possibility of this scheme being used to negate the need to apply for felling licences for thinning operations should be explored, with the possibility of introducing a single consent system for forest management as advocated by IFA to support active and timely management by forest owners.
The ambition to use the iPLAN scheme to support private forest owners to acquire certification is a positive measure however the supports available under the scheme will need to reflect the ongoing management plan requirements under forest certification.
IFA propose - that in tandem with the roll out of the iPLAN scheme the strategy must give a clear commitment to support and increase the level of the certification in the private sector with short, medium and long-term targets through the establishment of a National Forest Certification Scheme, which has been identified as the only sustainable solution that adequately addresses the certification barriers.
Forest Owner Producer Organisations
As outlined in the strategy document Irish wood forecasts predict that the annual potential roundwood supply will increase from 4.9 million m3 in 2021 to 7.9 million m3 by 2035, with the majority of the increase coming from the private forest sector. If this level of mobilisation is to be achieved in the private forest sector the system needs support the mobilisation of timber from small scale forest owners.
Internationally forest producer groups have proven to be one of the most effective ways to engage forest owners and create efficiencies in the supply chain through increased economies of scale, better access to support services as well as increasing bargaining power, which helps local forest producers to generate better incomes
IFA wish to highlight that the lack of supports in the strategy to support the ongoing development of Forest Owner Producer Organisation is a serious omission. Forest Owner Producer Organisation are a proven mechanism to address knowledge gaps, promote peer to peer learning and will be crucial in re-activating farmer interest in forestry as a land use option. Furthermore, if properly supported could provide a vital mechanism to support the certification of the private forest estate.
Intervention 5 - Developing skills and empowering the forest sector for SFM
IFA welcome the proposal to develop the training and promotion of the forest sector. 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 to drive the industry, such as exists in other natural resource sectors. It would be charged with optimising the performance of the Irish forest industry by providing technical expertise, business support, funding, training and promoting responsible environmental practice.
IFA propose the establishment of a Forestry Development Agency to upskill and empower the forest sector.
Intervention 6 - Open Forests
Property rights of farmers and private forest owners must be respected regarding an open forest intervention. Potential access and liability issues in the context of forestry recreation activities must be fully considered and the public awareness of legal property rights are important to communicate.
The development of schemes which include measures such as providing public access to forestry needs to be carried out with strong engagement with farm organisations and individual farmers to prevent disagreements or legal disputes and forest owners bearing unnecessary responsibility for public safety.
IFA propose that a Code of Practice should be developed for farmers and private forest owners who are interested in participating in the scheme.
Intervention 7 - Climate Resilient Reforestation
The three elements of a new pilot Climate Resilient Reforestation; Reforestation for Continuous Cover Forestry, Reforestation for Native Forests and Reforestation for Biodiversity and Water Protection Scheme will incentivise species and structural diversity during the reforestation stage. The new measures will provide supports to farmers that want to diversify during the next rotation and is a positive development.
IFA would reiterate concerns previously highlighted under the Payment for Ecosystem Services Pilot Premium Structure should be extended beyond the proposed seven years, in order for payments to adequately reflect the income foregone from timber revenue and the costs associated with implement actions depending on the option.
Intervention 8 - Reconstitution
The proposed Forest Reconstitution intervention to support farmers to restore and retain forest land and forest ecosystems following significant damage by natural causes is a positive development. The payments under the Forest Reconstitution schemes must be fair to all forest owners impacted, that supports their confidence in replanting and reflects the significant of the impact that damage has caused.
Measure 2 Reconstitution and Underplanting (Ash Dieback) scheme
Farmers that have experienced diseases with other agricultural commodities have seen schemes introduced by the Department, which include valuation and compensation measures. Farmers with ash dieback have been treated very differently, with a scheme that does not reflect or compensate for the hardship of affected farmers.
If farmers are to plant, especially more diverse species, they must have confidence that they will be properly supported should their forest be devastated by another disease. The RUS scheme needs to be redesigned to properly compensate farmers for the devastation caused by the disease.
IFA propose that (i) all infected plantations (both grant aided and non-grant aided) must be eligible for a 100% grant to cover costs to sufficiently support forest owners to clearfell and replant with tree species that satisfy their management objectives and (ii) forest premiums must be paid on replanted land for 20 years. In addition, under certain circumstances, the option not to replant, without penalties, must also be available.
Jackie Cahill
TD (Dáil Éireann, the Oireachtas)
Michael Fitzmaurice
TD (Dáil Éireann, the Oireachtas)
Michael Healy-Rae
TD (Dáil Éireann, the Oireachtas)
Barry Delany
Director (Department of Agriculture, Food and the Marine)
Pippa Hackett
Minister of State (Department of Agriculture, Food and the Marine)