The stark reality of where Irish forestry fits into the new Common Agricultural Policy (CAP) was illustrated in last week’s Irish Farmers Journal 40-page magazine CAP supplement.

That forestry didn’t feature at all simply reflects its absence from all CAP negotiations and lack of presence at EU level.

Trees are mentioned in the CAP “space for nature” (SFN) initiative. This covers tree-related projects such as hedgerow enhancement and small woodlands but afforestation is absent.

Forestry was part of the CAP up until 2006 when it was co-funded by the EU and Exchequer.

The Department withdrew from this arrangement in 2007 and since then the forestry programme – in particular afforestation – has been funded solely by the Exchequer, so doesn’t fall under the CAP remit.

Without consultation with stakeholders, Department officials believed at the time that this approach better suited Ireland, which still has an underdeveloped forestry and forest products sector.

A forestry programme tailored for Irish needs would be more flexible, especially in catering for the farming community.

For example, if forestry was part of the CAP, the introduction of a 20-year premium period for farmers might be questioned by member states with well-established forest cultures and a possible lack of appreciation of Ireland’s unique forestry history.

Exchequer funding would also allow Ireland the freedom to initiate ambitious forestry programmes such as the current programme (2023 to 2027) worth an estimated €1.3bn, if realised.

Strategically, this approach allows Ireland to take a long-term approach to forestry when future CAP funding is likely to decline.

A nationally driven programme also made sense because of Ireland’s low forest cover and the potential to increase the land area under forest and attract more farmers into forestry.

The official target now is to increase forest cover from 11% of the land area to 17% by 2050 as envisaged in Ireland’s Climate Action Plan 2019.

While the reasons behind going it alone made sense, the increased interest in farm forestry and achievement of viable afforestation programmes failed to materialise.

The reasoning has been further questioned by DG Environment (DG ENV) in the Commission. Even though Ireland’s new afforestation programme was announced last November by the then Taoiseach Micheál Martin, it is still awaiting State aid approval from Brussels as Department officials continue to provide answers to a plethora of questions from DG ENV.

Worse, DG ENV has questioned the programme on environment grounds, where the Department and many stakeholders believe it is strongest.

For example, it supports a strong native woodland establishment programme with massive incentives for planting indigenous broadleaves, while commercial forestry is virtually precluded.

Commercial afforestation

Farmers and other private landowners who favour commercial afforestation cannot now plant more than 65% of their land with conifers under the new programme.

The strict but legitimate intervention by DG ENV has now collapsed the new programme indefinitely not because the Department hasn’t the answers but because the submission of the programme to the Commission was far too late.

A different and maybe less attractive programme might have emerged from the CAP but at least it would now be approved and ready for implementation since 1 January.

As it is, the new programme has gained no traction with the Commission. DG Climate (DG CLIMA), for example, should be well disposed towards it because it demonstrates how afforestation is a core land use in Ireland’s Climate Action Plan.

Ambitious targets

The ambitious afforestation targets to achieve carbon neutrality would have resonated with the European Green Deal which pledges “to plant at least three billion additional trees in the EU by 2030, in full respect of ecological principles”.

The success of this pledge depends on the performance of individual member states with a major onus on Ireland, which if it wishes to achieve carbon neutrality by 2050 will be required to increase forest cover to 420,000ha.

This equates to 360m plants by 2030 or 1.2bn trees in the ground by mid-century if the 17% forest cover target is to be achieved.

The current Climate Action Plan has a less ambitious 2030 target as it proposes to “incentivise an increase to the area of afforestation by 68,000ha”, which still amounts to over 200m plants.

The enormity of this social, environmental and economic challenge, instead of being discussed by the Commission throughout the CAP negotiation with all relevant DGs, was only foisted on DG Environment as late as last November. As a result, the programme has not been considered on its overall merits in achieving net zero.

By being outside the CAP, the forestry programme fails to connect with the EU Forest Strategy, which according to the Commission “is one of the flagship initiatives of the European Green Deal”.

The Green Deal, which has influenced the CAP, places strong emphasis on carbon removal as evidenced in the Commission’s statement of support on 16 December 2021.

This has relevance to Ireland because – inside or outside CAP – the Green Deal sees carbon farming as a significant incentive but this has yet to register in Ireland.

We are well behind member states in this respect and over 10 years behind the UK in developing a Forest Carbon Code (FCC).

FCC development

The Society of Irish Foresters (SIF) and the Irish Timber Growers Association (ITGA) have proposed the development of a FCC for Ireland.

This would include “An afforestation scheme that will leverage the carbon value sequestered by forests and use this to reward and incentivise farmers and landowners who plant” as proposed by the society.

The Department claims that issues such as forestry licence approvals, time responding to DG Environment and developing a new forestry strategy have stalled the establishment of a carbon code.

As the expected dramatic increase of afforestation licence applications cannot now materialise, there is an opportunity to free up staff to research and establish a FCC along with the relevant stakeholders.

As no new licence applications can be accepted for afforestation and roading until State aid approval is granted, Department inspectors and other staff who previously approved 400 of these licences each month could now turn to other projects including fast tracking a FCC for Ireland.

This should, as the IFA and SIF propose, focus on carbon farming, especially as farmers’ engagement with forestry has fallen dramatically.

The development of an Irish FCC would provide forest owners with revenue for the carbon they store long after premium payments cease.

While there may be up to 1,000ha of afforestation licences available for planting under de minimis aid during the spring planting programme, a small number of applicants have stated that they will not proceed as their projects exceed €200,000 funding under this interim arrangement.

The relevant European Commission regulation maintains a ceiling of €200,000 on “a single undertaking over three years”.

This would preclude a licence for approximately 20ha and over with native species.

A solution to this would be to divide the lot – say, into 15ha this year and the balance next year. Because nursery supplies of native species are limited right now, this could be an interim solution to a problem not in the landowner’s making.