Ms Anja Murray:

I thank the committee for inviting us here to speak today. We are here from Environmental Pillar, which is an advocacy coalition of 27 national environmental NGOs. We have six working groups and one of these is the Treecover working group, which produced the report before the committee today. I am sure all of the members have read the submission we circulated. Sustainable development is the crux of what we are talking about from an environmental perspective. The classic definition of sustainable development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs. There has been political agreement on the need to reach this objective, although in many sectors implementation is still very much lacking. This is also true of Irish forestry. Many Irish people care deeply about sustainable development and the benefits it provides to the country but, as a State, we have still not taken serious on-the-ground action. Irish forestry and forest management still lacks many elements that would make the industry truly sustainable, and we look for this Bill to incorporate these elements to ensure the transition to sustainable development in Irish forestry. The Bill is an opportunity to reform forestry practices in line with the principles of sustainable development.

Our first precise request, which is in the document provided, is for sustainable forest management to be defined in the Bill. It is referred to in the Bill although there is no actual definition. There is also a reference to a sustainable yield of forest goods and services in the wording which is not appropriate for or capable of achieving sustainable forest management.

The second main request is compliance with nature conservation legislation. Afforestation has a number of very serious impacts on the natural environment, including the key impacts of planting new forestry on habitats. There are many issues with regard to breeding waders, pollinating insects and a diversity of wild flora, many of whose habitats are native and semi-natural grassland habitats. These are of a protected type and their extent and quality have declined drastically in recent years. Forestry is but one of the pressures on these species-rich grassland habitats. I use this as an example. There are several habitat types that are under threat from poor forestry practices, so what we have been seeking, which echoes a major recommendation in the BioForest report produced by a couple of different academic institutions, is for all afforestation sites to be surveyed for the presence of semi-natural and species-rich grassland before consent is granted for afforestation. This is a legislative issue and not something that should be left to policy makers, who have for years neglected to address this issue satisfactorily. The forestry Bill 2013 must ensure compliance with the birds and habitats directives, particularly in respect of protected habitats. We have recommended a very specific wording in our submission.

Water quality is another issue. There are serious impacts on water quality from afforestation and forest management, particularly in upland areas near areas with thin or otherwise fragile or erodable soils. The impacts include nutrient enrichment, sedimentation and consequent loss of ecosystem services. Water pollution presents a very real cost to society in terms of the loss of valuable ecosystem services, damage to fisheries and increased costs for the treatment of drinking water. The reference to the water framework directive in the Bill is thus welcome but it needs to be strengthened. Again, we have put in very specific recommendations for the wording that needs to be amended.

At the moment, there exists a set of guidelines for forestry and the environment, which were published around 2000 and 2001. These need to be updated. There has been some discussion for a while and there is no disagreement about the fact that they need updating. We also seeking for the Bill to put these on a statutory footing. They need to be binding rather than being a suite of recommendations that the better foresters go to the trouble of adhering to and others choose to ignore.

Native woodlands are another issue. Ancient native woodland habitats are a relatively rarity in Ireland. They make up only 0.1% of Ireland's land cover. These sites are very ecologically and culturally important. There is a lack of positive conservation management in these ancient native woodland habitats.

We have asked that this matter be referred to in the duties of the Minister and the Forest Service to promote the expansion, restoration and positive management of natural and semi-natural woodland habitats, including the remnants of ancient native woodland, and ensure appropriate conservation and management. This is the specific wording suggested. It is necessary to ensure the protection and long-term viability of a much-neglected aspect of our heritage.

Another issue arises in respect of the cumulative impacts of forestry and other practices. It is quite technical and we have requested a detailed wording to address cases in which there is a certain catchment area. While one or two bits of forestry might not be a problem for water quality or the environment, etc., developments such as wind farm construction or forestry can collectively have a significant impact. There should be a reference to cumulative impacts.

Climate change has been mentioned. Sustainably managed forests can mitigate the impacts of climate change through the sequestration of carbon by growing trees. Forests, especially the ground litter or the layer of litter on the soil, act as significant stores of carbon. Forestry can also assist in adaptation to climate change. It will be needed for us to adapt to climate change.

Many Irish habitats provide valuable ecosystem services in terms of climate change mitigation and adaptation. These include peatlands and bogs. Peat soils are significant storers of carbon. When they are drained, they release large quantities of greenhouse gases, contributing to rather than mitigating against climate change.

Continuous cover approaches to forest management provide for more diverse structures and mixed species. Through various research, especially in the UK, these approaches have been shown to lock up more carbon for a longer time, given the reduced soil disturbance. The ground litter stores up to 90% of forest carbon. When a management system disturbs that soil, it can be detrimental and release many greenhouse gases. Forests managed using continuous cover approaches are also more resilient to drought, which has become a major problem in recent years, as well as fire, pests and diseases. We are seeking specific statutory guidelines to address climate change mitigation and adaptation. We would like to Bill to allow for this.

A further issue arises from the Bill relating to the removal or destruction of vegetation on land. The measure is more or less copied from the 1946 Act and is alarming in that it provides for the removal of vegetation that might be a fire hazard where it is adjacent to a forest. We must ensure that appropriate safeguards are in place. The way in which the vegetation is removed or destroyed - normally, it is burned - can have significant impacts on the environment. When there is a deep burn, it goes right down through the peat and loosens the soil into waterways, causing a great deal of habitat destruction downstream. This can damage salmonid and salmon, trout and other aquatic habitats. The greenhouse gas emissions from deep peat burns can be problematic. We have proposed a specific wording for section 14 on the removal or destruction of vegetation on land.

In terms of forest management, we are seeking provisions on a greater diversity of tree species. Issues arose with regard to exempted trees. Within ten metres of a public road is the distance listed in the Bill. This needs to be reduced to five metres, as the current provision allows for too much removal of trees that are not right beside the road. Another provision refers to 20 cm in diameter at breast height. This needs to be reduced to 10 cm for hedgerow trees, as many mature and valuable hedgerow trees form a part of our cultural heritage and are important landscape features. The current provision sets too high a bar for the removal of hedgerow trees.

Pre-afforestation, ecological surveys should take place on all new afforestation sites before consent and grant aid are granted. This issue must be provided for in the new legislation.

We also have recommendations on Coillte. The Forestry Bill 2013 must cater for an expected review of the 1988 Act, thereby improving the consistency of Coillte's objectives and operations in line with sustainable forest management and the Rio forest principles.

I will not go through the rest of the recommendations, although there are three or four more specific ones. For example, hedgerows are important. The Bill provides for them as part of tree cover. We want it to acknowledge how important the species-rich hedgerows are from a culture and heritage point of view. An appraisal system was recently developed with Woodlands of Ireland and a number of the NGOs that set limits on the removal of ancient townland boundary and species-rich hedges, which differ significantly from smaller or less diverse hedges.