Forestry licences and objection fees

Sir, – Further to your article on the delays in forestry licensing, "Timber industry faces crisis as licensing logjam hampers supplies" (News, July 3rd), the system is clogged with appeals against industrial monoculture plantations because no one but the industry wants them.

If proposals were for mixed-species, mixed-aged, multipurpose woodlands planted in sympathy with our landscapes and respecting water quality, the number of objections would dramatically lessen and our environment dramatically improve.

Instead, the broadleaf percentage of annual planting has fallen from 37 per cent in 2009 (after the EU withdrew its 75 per cent funding on environmental grounds) to 21 per cent in 2017.

Now the proposed programme for government follows a critical review completed last year with a view to removing perceived barriers to planting and the meeting of planting targets.


The critical scrutiny came in the form of a report by Jim Mackinnon, former chief planner with the Scottish government, published in November 2019, and commissioned by the Department of Agriculture, Food and the Marine, called Review of Approval Processes for Afforestation in Ireland.

The report concludes that the opportunities that people have to comment and object to forestry proposals represent a barrier to efficient decision-making.

It states that the case for the introduction of fees for third-party submissions is unarguable, as “an appeals system which allows third parties, at no cost, to challenge decisions of the Department has created further delays with significant administrative costs”.

Mr Mackinnon concludes: “Fees should be introduced as a matter of urgency for making a submission on an application and lodging an appeal.”

The report does not appear to make any reference to the legal context of the current guidelines or the Aarhus Convention, which seeks, among other things, to ensure public participation in our decision-making processes.

While the programme for government contains a lengthy list of forestry related items, they are really only ancillary or presented so vaguely as not to be certain of materialising. This is not the position with the Mackinnon report, however. The text is unambiguous in its commitment to implementing fees for objections.

The Planning Act 2000 implemented the €20 fee for the making of observations on planning applications made to the local authorities. Participation fell by more than half (although no records were kept before the fee came in).

We examined the submissions that were made to the Department of the Environment at the time.

The County and City Management Association, 67 civil society groups and a wide range of individuals, were virtually uniform in their objections – planning authorities gained much relevant information and the decision-making process was improved though public submissions.

A fee to object shifts the cost of examining a project from the developer to a member of the public concerned about the impacts. This reverses the principle of the polluter pays.

We would urge the new Government to ensure that the rights of individuals to participate in our decision-making processes is not diminished once again. – Yours, etc,


Friends of the

Irish Environment,


Co Cork.