Forestry policy and scientific evidence

European Commission is right to express concern

Sir, – Regardless of who undertakes it, that the current forestry programme has been subject to strategic environmental assessment (SEA) and therefore public consultation is greatly to be welcomed as a serious contribution, after the failure to do so for the last (2014-2022) programme.

What is less reassuring is the adamant and repeated refusal of the Department of Agriculture to accept repeated scientific advice about two critical issues highlighted in the public consultation response.

The first is the advice from our top experts on the fresh water pearl mussel that no planting of any trees – native or exotic – should take place in the eight catchments holding 80 per cent of one of the species closest to functional extinction in Ireland.

Both native or non-native trees take up water needed in our rivers to avoid low-flow summer episodes and subsequent mussel deaths from overheating. A recent Life project (the Life programme is the EU’s funding instrument for the environment and climate action) demonstrated that reduced flows shrink the potential habitat to narrow pockets often associated with bends and island edges. Only here does the velocity still provide the necessary clean conditions. The project also highlighted that at catchment level run-off from “marginal lands” provide an important food supply to juvenile mussels. “These juveniles are particularly vulnerable and this food source helps to ensure their survival to adulthood.”


The second issue is that our best peatland scientists are being ignored in their pleas to redefine peat soils where planting should not take place to ensure continued sequestration – rather than the emission of greenhouse gases through the disturbance of organic soils.

Ireland’s current Forest Service 2017 guidelines require a depth of 50cm before qualifying for protection as a peat soil, a threshold originating in plough depth. The scientists are urging the Department to adopt the recent United Nations recommendation for classifying the depth of peat soils to be left undisturbed at 10cm “to account for peatlands’ contribution to climate” (Global Peatlands Assessment: The State of the World’s Peatlands, UN 2022). According to the assessment, a similar change from 30cm to 10cm in Russia almost triples the area best left alone.

The final correspondence on the SEA from the European Commission dated November 22nd, 2022, pointed out that, “The fact that the advice of the scientists does not appear reflected in the SEA report is itself of concern.” – Yours, etc,


Friends of the Irish Environment,


Co Cork.

A chara, – It is more than 15 years since I lost a significant sycamore to sooty-bark disease, a fungal infection that requires warmer temperature than Ireland traditionally enjoyed. Now I note the slow decay of my ash trees, and the spectacular dying over the last 12 months of my modest stand of cupressus ( the unloved Lawson cypress), victims, having been stressed during a period of drought, of fungal infection.

While only the cupressus was planted in proximity to other trees of the same species, I now fear for the monoculture of spruce trees comprising more than 60 per cent of Irish forests.

Prudence would suggest, over and above any consideration of biodiversity and flood mitigation, that a greater variety of trees should be planted, deciduous and conifers, to protect what is a multigenerational investment in forestry and an existential investment in the environment. – Is mise,


Dublin 6.