Submission by The Society of Irish Foresters to The Public Consultation on the Draft Hen Harrier Threat Response Plan, Environmental Report and Natura Impact Statement

Afforestation is one of the largest land-based, long-term climate change mitigation measures
available to Ireland. Management of our existing forests also provides opportunities to
increase carbon stores.
– Climate Action Plan, 2021ⁱ, 2023ⁱⁱ, 2024ⁱⁱⁱ

FORESTRY AND CLIMATE CHANGE

Successive Climate Action Plans have called for at least a four-fold increases in the current levels of afforestation – to 8,000ha – if Ireland is to achieve “a 51% reduction in emissions from 2021 to 2030″iv and net zero by 2050. The EPA report “Ireland’s Climate Change Assessment” puts Ireland’s climate mitigation challenge in stark perspective: To halt warming, globally and in Ireland, requires rapidly reaching at least net-zero carbon dioxide emissions and substantially cutting other greenhouse gas emissionsv. Referring to research on land use, land use change and forestry (LULUCF), the report calls for “unprecedented rates of afforestation and the rewetting of organic soil along with a significant reduction in herd numbers”.vi

The urgency to achieve dramatic increases in Irish forest cover was outlined in the 2022 Deliberative Dialogue on Forestry. Involving “99 citizens”, this forum was part of a series of consultations conducted by the Department of Agriculture, Food and the Marine to gather the
views of people living in Ireland on forestry issues. When asked about their ambitions for forestry

36% of participants agreed that the aim should be to achieve 18% forest cover by 2050 or
sooner, while a further 52% agreed that the aim should be to achieve an even greater
expansion of forest cover to help combat climate change. Taken together, 88% of
participants endorsed a forest cover target of 18% or more by 2050. vii

While Government policy is to achieve an 8,000ha planting programme, this will need to be dramatically increased if the 18% target outlined in the Climate Action Plan 2019.viii is to be achieved; as much as 16,000haix as estimated by COFORD, the Department of Agriculture, Food and the Marine’s advisory body on forestry and 25,000ha x by Professor Cathal O’Donoghue, University of Galway.

SOCIETY OF IRISH FORESTERS – LAND USE CHANGE AND HEN HARRIER PROTECTION

The crucial role that forestry can play in climate change mitigation is highlighted by the Society of Irish Foresters and is now accepted by Government. The debate on the benefits of dramatically increasing forest cover is now over. What is only beginning is the debate on how this forest expansion can be achieved in a sustainable way to optimise landscape values and to protect biodiversity. Forest expansion, like any other land use, cannot be taken in isolation. Farmers, foresters, ecologists, ornithologists, landscape architects, policy makers and other stakeholders – State and private – that interact directly and indirectly with the natural and built landscape need to 2 consider achieving a balanced approach to land use in achieving net-zero and biodiversity enhancement. Protection of flora, fauna, water quality and other natural resources are interlinked so consideration of any one aspect cannot be taken in isolation if carbon neutrality objectives are to be achieved. The Hen Harrier Threat Response Plan (TRP) must acknowledge the goals set out in the Climate Action Plan and the major switch to afforestation as a land use essential in achieving net-zero. A blanket removal of land suitable for afforestation and banning reforestation in some forests are diametrically opposed to Government forestry policy to achieve 18% forest cover by either mid-century or 2046 as envisaged in the 2019 Climate Action Planxi. Either or both of these measures would result in forestry being a net emitter of carbon rather than a sequester and would reduce timber production and processing in decarbonising the economy. Future approaches to hen harrier protection need to explore land use changes – including forestry – objectively and to acknowledge changing forestry trends in terms of size, species and ownership.

Forestry has been linked with the fluctuating fortunes of a number of bird species including the hen harrier. For example, in 1981, Gordon D’Arcy, maintained in The Guide to the Birds of Ireland: “Were it not for the re-afforestation of this country in the [twentieth] century, this harrier would probably not be found here any longerxii.” He went on to say: “The man-made forests now provide vital sanctuary for this beautiful bird of prey”. As a result, it was widely believed that the relationship between plantation forests and the hen harrier was positive. Many forest owners, foresters and other stakeholders were genuinely surprised that an area of 167,000ha, was designated by the National Parks and Wildlife Service (NPWS) as Special Protection Areas (SPAs) under the Birds Directive on account of its importance for holding hen harrier breeding populations as habitats were in decline. While hen harriers were breeding in young plantations, they “were not to be found in ‘worked’ or mature plantations” as D’Arcy explained in 2014xiii. While D’Arcy’s reappraisal is valid, “worked plantations” are essential in hen harrier protection and can create increased habitats by adopting flexible harvesting regimes. For example an uneven-aged forest can be created to achieve a mature and pre-thicket balance – pre-thicket forests are essential nesting hen harrier habitats.

FUTURE FORESTS

The perception still exists that Irish afforestation – in terms of scale and location – is carried out on a large-scale, monoculture basis. Statements such as the “drive to afforest vast areas of farmland”xiv by BirdWatch Ireland conjures up images of large tracts of land being planted. This ignores the fact that average forest size in recent years is approximately 7.5ha compared with large blocks often over 100ha in the 20th century State afforestation programme. These new plantations must contain at least 15% open biodiverse areas. In this regard, there is need for more research into hen harrier habitats and the relationship with forests and forest sizes as the mosaic of small forest lots results in different felling regimes and potential for hen harrier nesting sites.

Where forests are located will have an impact on hen harrier nesting habitats. BirdWatch
Ireland states:

One of the most pressing concerns for BirdWatch Ireland is that afforestation will be strategically targeted on marginal agricultural land, particularly in areas where low intensity land uses such as hill farming have persisted for generationsxv3

Again, this misinformation ignores the fact that virtually no upland new plantations have been established since 2012 even though there are opportunities to establish native woodland in a proportion of these areas including hen harrier designated areas.

LOOKING AT OTHER EXPERIENCES IN HEN HARRIER CONSERVATION

When preparing the TRP, there is a need to examine the approaches to hen harrier conservation within the island of Ireland and in other countries, particularly in Scotland.  Despite a reduction in numbers in Northern Ireland the last survey in 2016 found “46 territorial pairs”xvi compared with an “estimated at 85 confirmed and 21 possible breeding pairs (85-106) in 2022″xvii in the Republic. There are lessons in this data which suggests an all-island approach because on a pro rata land area basis hen harrier habitats are more than twice as high in Northern Ireland than the Republic.

Scotland places strong emphasis on current evidence – breeding sites, hen harrier mobility, etc. – rather on historic trends. Also, Scotland places greater emphasis on wider consultation with all stakeholders. Protection of the hen harrier is a key objective in Scotland but it has managed also to increase forest cover to 18% of the land area. While the threat to the hen harrier is acknowledged by the Game & Wildlife Conservation Trust, its report is objective and optimistic:

A hen harrier report for SNH [Scottish National Heritage] is awaited later this year, which will incorporate the results of the latest national survey in 2010. It is expected to show a population of around 500 breeding pairs; lower than the 633 recorded in 2004 but higher than the 436 pairs in 1998. The hen harrier population is likely to have increased since 2010, and 2014 in particular has been a good breeding year. For example, at the Langholm Moor Demonstration Project, there have been 12 active hen harrier nests this year compared to 2-3 in previous years, with 46 chicks successfully fledged and ringed in 2014.Other areas in Scotland also appear to have had a good harrier breeding yearxviii..

The report illustrates conservation methods and threats:

But as well as potentially improving hen harrier conservation by reducing predation and increasing food, man’s activities can have a negative impact. Illegal persecution may be affecting recruitment of breeding birds in recent years; in 2013 there were two recorded crimes involving hen harriers. In 2012 two hen harriers were killed after colliding with wind turbines and a recent study supported by the RSPB [The Royal Society for the Protection of Birds] suggests that the collision risk is greater than previously thought.

All of these challenges mean it would be better if more hen harriers were distributed across Scottish regions in relation to apparently suitable habitat. Central to such sustainable harrier conservation is finding a managed balance between benefits and risks.  Heather habitat, abundant food and low predation pressure that benefits harriers are delivered by moorland, managed by those who want to shoot red grouse. However ,research has shown that there is a real risk as harriers can suppress red grouse numbers below the level where they can be shot sustainably. This conflict is recognised in the Langholm Moor Demonstration Project, which is attempting to find the managed balance between hen harrier conservation and red grouse management and by other conservation
approaches being discussed in England.

Forestry is not mentioned in the Trust’s report as a contributory factor in hen harrier mobility. Contrast this with the recent hectoring emailxix from BirdWatch Ireland leading up to this TRP public consultation. It makes no reference to a balanced land use programme to ensure a viable agricultural, forestry and climate mitigation programme. While this communiqué totally ignores the wider implications of forestry and its role in climate change mitigation, farmers, forest owners, forestry companies, contractors and timber processors don’t enjoy this luxury. Achieving climate change objectives through afforestation and protecting our bird life are not mutually exclusive but they do require an understanding of how we can achieve both objectives. It requires dialogue between all parties and honesty between the state agencies and departments in particular the Departments of Agriculture, Food and the Marine, Housing, Local Government and Heritage, and Environment, Climate Change and Communications.

RELEVANT ISSUES – DISCUSSION AND RECOMMENDATIONS

The Society of Irish Foresters fully supports a strategy to ensure sustainable forestry is compatible with the protection of the hen harrier. This requires a plan that is developed at local and national level.

Local level

Much can be done practically at local level. For example, landowners, farmers, foresters and contractors repeatedly point to outdated information on Red Zones including their location. The inevitable inaccuracy of data on Red Zones presents major difficulties in carrying out sustainable forest management that can help protect the hen harrier. Red Zones need to be reassessed and backed up with an effective and well researched survey regime. Achieving this will require open and transparent dialogue with forest owners, forestry companies and their foresters, and other relevant stakeholders as well as a significant increase in funding.

The Society makes the following recommendation at local and forest level:

1. Forest owners, forestry companies, contractor and sawmill purchasing and production
   managers should have full access to all relevant data on hen harrier to inform decision
   making, planning, and operations.
2. Rebalancing of age class distribution and species should be considered in reforestation
   rather than banning reforestation.
3. The new Forest Types (FT) which have a mandatory requirement to allow at least 35%
   of all afforestation programmes to include broadleaves and open spaces should be the
   criterion for future planning.
4. Realistic measures, as carried out in Scotland, to allow collaboration between all
   stakeholders in the field to provide measures to reduce the impact of fire, predators,
   illegal hunting and other negative impacts on hen harrier habitats

National level

Local initiatives need to be supported by a strategic plan that incorporates land use at landscape level. The TRP needs to be informed by the proposed Programme for Government’s Land Use Review to ensure that optimal land use options inform all relevant
Government decisions. It is envisaged that the first phase of this exercise “provides an evidence base to determine the environmental, ecological and economic characteristics of land types across Ireland”.

National issues that need to be discussed with all stakeholders in finalising a hen harrier TRP:

1. Afforestation targets outlined in successive Climate Action Plans, EPA report “Ireland’s
   Climate Change Assessment” and studies carried out by COFORD and University of
   Galway need to be an intrinsic part of a future Hen Harriers TRP.
2. TRP needs to be informed by the proposed Programme for Government’s Land Use
   Review.
3. An up-to-date survey on threatened bird habitats – especially threatened species – needs to
   be fully resourced and structured in a way that provides relevant date to the forestry sector,
   to inform decision making and planning.
4. Agree increased investment in a research programme on Hen Harrier and other threatened
   species to ensure policy actions are correct and effective.
5. The forest sector should be recognised as an important stakeholder in all environmental
   discussions and policy developments, including this Hen Harrier TRP and an acceptance
   of the social, environmental and economic impacts of the TRP.

SUMMARY

All discussions must take account of national policy on sustainable forestry in achieving net zero and must acknowledge forestry as a renewable resource not only in sequestering carbon in the forest but also in displacing fossil based material and fuels in energy and construction, the greatest greenhouse gas emitter in the world. There is no escaping the need to expand afforestation as outlined by Ireland’s Climate Advisory Recent analysis: There is cause for concern as to whether the current targets for afforestation (8,000 hectares) are sufficient to deliver carbon neutrality within the AFOLU sector. Realistic scenarios suggest that, in order to address the historical pattern of afforestation and forest management practices, target afforestation rates need to be approximately 18,000 hectares per year to reach carbon neutrality by 2050xx
.

Meeting this objective and protecting the Hen Harrier are central to the outcome of the Public
Consultation on the Draft Hen Harrier Threat Response Plan.
Society of Irish Foresters
Glenealy
Co. Wicklow
19 February 2024

1. Government of Ireland. 2021. The Climate Action Plan: Securing Our Future, Dublin.
2. Government of Ireland. 2023. Climate Action Plan: Changing Ireland for the Better, Dublin.
3. Government of Ireland. 2024. The Climate Action Plan. Dublin.
4. Ibid
5. EPA. 2024. Report “Ireland’s Climate Change Assessment: Synthesis Report, Environmental Protection Agency, Wexford.
6. Ibid.
7. Department of Agriculture, Food and the Marine. 2023. Ireland’s Forest Strategy. Government of Ireland, Dublin. https://www.gov.ie/en/publication/89785-irelands-forest-strategy-2023-2030/
8. Government of Ireland. 2021. Climate Action Plan: To Tackle Climate Breakdown, Dublin.
9. COFORD. 2022. Forests and wood products, and their importance in climate change mitigation: A series of COFORD statements. COFORD, Department of Agriculture, Food and the Marine, Dublin.
10. O’Donoghue, Cathal. 2022. “The Economics of Afforestation and Management in Ireland: Future Prospects and Plans”, University of Galway, Biorbic Sfi Research Centre, Auxilia Group, Naas.
11. Government of Ireland. 2019. Climate Action Plan: To Tackle Climate Breakdown, Dublin.
12. D’Arcy. G. 1981. The Guide to the Birds of Ireland. Irish Wildlife Publications. Dublin
13. D’Arcy. G. 2014. “I feel some clarification is required on my part” (letter). Irish Farmers Journal, Dublin.
14. BirdWatch Ireland. (2024.) “Forestry: Driving a Root and Branch Reform of Irish Forestry”,BirdWatch Ireland. Greystones. https://birdwatchireland.ie/our-work/advocacy-policy/agriculture-forestry/forestry/
15. Ibid
16. National Parks & Wildlife Service. 2023. “Threat Response Plan for the Hen Harrier 2024-2029. Government of Ireland, Dublin
17. Ibid
18. Game and Wildlife Conservation Trust Scotland. 2023 (accessed), “The status of hen harriers in Scotland”, Fordingbridge, Hampshire.
19. BirdWatch email. 2024 (12 February). “We urgently need you to take action to Save the Skydancer”, BirdWatch Ireland
20. Climate Change Advisory Council. 2023. Annual Review, Dublin