Mr. Brendan Lacey:

It has been widely accepted that forestry has great potential in providing jobs and contributing to the environment, recreational amenities and the economy.

Therefore, a Bill that promotes that industry would be very welcome. The title of the proposed Bill states that it is to provide for the development and promotion of forestry in a manner that maximises the economic, environmental and social value of forests within the principles of sustainable forest management. It also goes on to say in the explanatory memorandum that it is envisaged that the Bill will incur no significant additional cost for the Exchequer or forest owners.

The reality is that the harvest from private forests is forecast to increase tenfold within 15 years. The retention of a similar general felling licence procedure to that currently in place, as outlined in this Bill, will prove to be costly and an administrative burden on both growers and the Forest Service. This will also act to discourage future afforestation. The ITGA maintains that for forest plantations, a felling licence should be for a considerably longer period than five years, as is proposed in the forestry Bill 2013, and should include all thinnings up to the final felling of a forest. It seems unnecessarily burdensome to have to apply for separate felling licences each time as part of the normal management process, which is possibly a thinning every four years or so, when it is part of the normal day-to-day management of that forest. We believe a felling licence should cover all thinnings in bringing that forest up to its final clear-fell stage. There should also be workable timeframes and timelines included in the Bill so that felling licences would be issued within three months of an application being submitted.

The requirement to supply a management plan and inventory information, which must then be approved, is a further administrative barrier to wood mobility, which will also increase management costs to forest owners. The other aspect of this is that giving the Minister the power to decide what one grows and how it should be grown and to dictate what should be included in a management plan seems to be stepping beyond what the role of the forest authorities should be in that they are taking on the role of the manager as opposed to that of an administrative authority.

In order to encourage wood mobility and the afforestation of more lands, and to ensure that the new forestry Bill will not result in additional costs to the Exchequer or business, the Bill should be subject to an economic impact assessment. There should be a requirement for a regulatory impact assessment before any new regulations that would be enabled by the Bill are enacted.

The requirements for reporting by forest owners as included in the forestry Bill will add cost, be an administrative burden on woodland owners and act as a disincentive to afforestation. For example, the provision of a timeframe of 28 days to a forest owner to provide an inventory of his or her woodland to the Forest Service is in stark contrast to the lack of any timelines that the Forest Service would give in respect of providing a felling licence. The other aspect is that within 28 days, one can imagine an ordinary forest owner having to hire a forestry consultant to carry out that work, which would be an extra cost to the forest owner. If the forest owner does not deliver that within 28 days, he or she faces the threat of imprisonment or fines. That certainly seems very draconian. Another aspect is the position of authorised officers where no competency requirement is specified within the Bill, so anybody can be appointed as an authorised officer, but the powers they have in terms of entering lands to search, seize property and question individuals without any form of warrant seem excessive.

In respect of barriers to wood mobility and new costs to industry, the forestry Bill will result in significant additional costs to the Exchequer, business and future potential timber growers. These costs will act as a barrier to wood mobility and afforestation in the future and, therefore, act as a barrier to getting the most out of the forest industry. Forests are central to our future green economy. They provide employment, biodiversity and recreation and are also a carbon-fixing and renewable energy resource. We need to expand forest cover to maintain and increase these benefits. Creating new forests is a long-term business requiring clear and sustained policies, which will benefit not only us but also future generations. In this context, the ITGA stresses the importance of a facilitating forestry Bill. A forestry Act must play a role in achieving these core aims. The forestry Bill affords great opportunities to do this but, as it is currently drafted, it will act as a barrier to both new planting and getting timber to market. I will conclude by saying that Irish forestry is about jobs, the environment, recreation and the economy, and there is an opportunity to provide us with a lot more in the future.