BirdWatch Ireland submission to Department of Agriculture Food and the Marine request for submissions on the Discussion Document on the potential ...
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BirdWatch Ireland submission to Department of Agriculture Food and the Marine
request for submissions on the Discussion Document on the potential for GHG
mitigation within the Agriculture and Forest sector.
BirdWatch Ireland
BirdWatch Ireland is Ireland’s largest environmental NGO and is a science based conservation charity
with 15,000 members, a team of professional staff and 2,000 active volunteers. BirdWatch Ireland
has been actively engaging in the issue of Climate change for more than 10 years, seeking action on
climate change mitigation and adaptation from all relevant sectors of society.
Introduction
Irish agriculture is a very important indigenous sector in Ireland providing a substantial number of
jobs and supporting rural families. Agriculture is also important for biodiversity as our species have
evolved over the millennia in tune with this land use. We acknowledge that significant research and
work has been conducted by Teagasc, the Department of Agriculture, Food and the Marine, and
others to assess and determine the carbon footprint of Irish agriculture and opportunities to
mitigate against this. Emissions from agriculture are projected to continue to increase into the
future with the expansion plans of Food Harvest 2020, when emissions should actually be decreasing
in order to prevent the worst effects of climate change.
While it is laudable that the DAFF is seeking views on the potential for GHG mitigation within
agriculture with the view to developing a sectoral mitigation plan, this is in the context where the
legal mechanism for it, the 2015 Climate Change Bill, has not yet been agreed by Government and
the discussion is proposed in the absence of guidance and objectives of a National Mitigation Plan.
However, BirdWatch Ireland welcomes the opportunity to comment on this Discussion Document.
1The projected impacts of climate change on our planet and people, especially the most vulnerable
people in developing countries, are potentially devastating. Climate change will also impact
biodiversity including birds and their habitats. We must do everything we can to reduce greenhouse
gases and reduce these impacts. The intensification of agriculture under Food Harvest 2020 with
resulting greenhouse gas increases coupled with the proposed significant afforestation in the
Forestry Programme2014-2020 to mitigate against this could result in substantial changes to land
use in Ireland with implications for birds and their habitats.
Climate Change Impacts on Biodiversity
Climate change is anticipated to affect all the levels of biodiversity, from organism to biome levels
(Bellard et al 20131, Mokany et al 20132, Pereira et al 20103). Changing temperature and
precipitation (IPCC, 20074) are expected to interact with other pressures (e.g. habitat fragmentation
and loss) to influence biodiversity negative and in some cases, positive ways (Hagerman et al 20105).
Species with reduced climatic ranges, specialist habitat requirements and small populations are
potentially the most vulnerable to extinction and includes especially mountain species and biota
restricted to islands (IPPC 2007; Adam 20096, Loarie et al 20097, Thuiller et al 20058, Walther et al
20059). The habitats of many species will move poleward or upward from their current locations
(IPCC 2007, Hickling et al 200610, Tamis et al 200511). Although there is relatively limited evidence of
current extinctions caused by climate change, there are many examples of observed impacts on
biodiversity including changes in phenology (Donnelly et al 201112), alpine plant species in
Switzerland moving up hillsides (Walther et al 2005) and birds migrating further north (Lehikoinen
1
Bellard, C. et al., 2012. Impacts of climate change on the future of biodiversity. Ecology letters, pp.365–377
2
Mokany, K., Harwood, T.D. & Ferrier, S., 2013. Comparing habitat configuration strategies for retaining biodiversity under climate change
V. Devictor, ed. Journal of Applied Ecology, 50(2), pp.519–527.
3
Pereira, H.M., Leadley, P.W., Proenca, V., Alkemade, R., Scharlemann, J.P.W., Fernandez-Manjarres, J.F. et al. (2010). Scenarios for global
biodiversity in the 21st century. Science, 330, 1496–1501
4
IPCC, 2007c. Summary for Policymakers Climate change 2007: the physical science basis. In: Solomon, S.D., Qin, M., Manning, Z., Chen,
M., Marquis, K.B., Averyt, M.T., Miller, H.L. (Eds.), Contribution of Working Group I to the Fourth Assessment Report of the
Intergovernmental Panel on Climate Change, Cambridge University Press, Cambridge, UK, p. 18.
5
IPCC, 2007c. Summary for Policymakers Climate change 2007: the physical science basis. In: Solomon, S.D., Qin, M., Manning, Z., Chen,
M., Marquis, K.B., Averyt, M.T., Miller, H.L. (Eds.), Contribution of Working Group I to the Fourth Assessment Report of the
Intergovernmental Panel on Climate Change, Cambridge University Press, Cambridge, UK, p. 18.
6
Adam, P., 2009. Going with the flow? Threatened species management and legislation in the face of climate change. Ecological
Management & Restoration, 10(May), pp.S44–S52.
7
Loarie, S.R. et al., 2009. The velocity of climate change. Nature, 462(7276), pp.1052–5.
8
Thuiller W, Lavorel S, Araujo MB, Sykes MT, Prentice IC (2005) Climate change threats to plant diversity in Europe. Proceedings of the
National Academy of Sciences of the United States of America, 102, 8245–8250.
9
Walther GR, Beissner S, Burga CA. 2005. Trends in upward shift of alpine plants. Journal of Vegetation Science 16: 541– 548.
10
Hickling, R. et al., 2006. The distributions of a wide range of taxonomic groups are expanding polewards. Global Change Biology, 12(3),
pp.450–455.
11
Tamis, W., Van’t Zelfde, M., Meijden, R. & Haes, H. (2005) Changes in vascular plant biodiversity in the Netherlands in the 20th century
explained by their climatic and other environmental characteristics. Climatic Change, 72, 37–56
12
Donnelly, A., Caffarra, A. & O’Neill, B.F., 2011. A review of climate-driven mismatches between interdependent phenophases in
terrestrial and aquatic ecosystems. International journal of biometeorology, 55(6), pp.805–17
2and Sparks 201013). It has been suggested that climate change could surpass habitat destruction as
the greatest global threat to biodiversity over the next few decades (Bellard et al 201314, Leadley et
al. 201015, Rose et al 200916, Opdam & Wascher 200417). Climate change will cause further losses of
habitats and species that are already experiencing severe declines from habitat loss, degradation,
and fragmentation and disturbance. Protected areas must be afforded greater protection,
management and connected to provide a “backbone for biodiversity” and to accommodate the
expected changes in species distribution. In addition, the landscape outside these areas must
become more ‘permeable’ to species’ movements by providing stepping stones of high quality
habitat and by more sustainable land-use policies.
Farmland Birds and Agriculture in Ireland
Ireland’s biodiversity is facing very severe threats, as evidenced by declining populations of many
farmland birds and the loss in extent and quality of many semi-natural habitats in the mosaic of
Ireland’s farmed landscapes. Farmland birds across Europe have declined by over 40% in the past 30
years. In Ireland, many previously common farmland birds have suffered major population and range
declines since the 1970’s18. While Ireland has been farmed for millennia, farming practices existed
alongside healthy ecosystems. In recent decades we have drastically changed the way we farm and
used farmland. Declining bird populations often indicate declining health of the natural
environment. They reflect losses in habitat extent and quality and often equate to losses in
ecosystems services which are a valuable asset to Ireland.
Target 3(A) of the EU Biodiversity Action Plan states “By 2020, maximise areas under agriculture
across grasslands, arable land and permanent crops that are covered by biodiversity-related
measures under the CAP so as to ensure the conservation of biodiversity and to bring about a
measurable improvement in the conservation status of species and habitats that depend on or are
affected by agriculture and in the provision of ecosystem services as compared to the EU2010
13
Lehikoinen E, Sparks TH (2010) Changes in migration. In: Møller AP, Fiedler W, Berthold P (eds) Effects of climate change on birds.
Oxford University Press, Oxford, pp 89–112
14
Bellard, C. et al., 2012. Impacts of climate change on the future of biodiversity. Ecology letters, pp.365–377.
15
Leadley, P., Pereira, H.M., Alkemade, R., Fernandez-Manjarres, J.F., Proenca, V., Scharlemann, J.P.W. et al. (2010). Biodiversity scenarios:
projections of 21st century change in biodiversity and associated ecosystem services. In: Secretariat of the Convention on Biological
Diversity (ed. Diversity SotCoB). Published by the Secretariat of the Convention on Biological Diversity, Montreal, p. 1–132. Technical
Series no. 50.
16
Rose, N.-A. & Burton, P.J., 2009. Using bioclimatic envelopes to identify temporal corridors in support of conservation planning in a
changing climate. Forest Ecology and Management, 258, pp.S64–S74.
17
Opdam, P. & Wascher, D., 2004. Climate change meets habitat fragmentation: linking landscape and biogeographical scale levels in
research and conservation. Biological Conservation, 117(3), pp.285–297.
18
Lynas, P., Newton, S.F. & Robinson, J.A. 2007. The status of birds in Ireland: an analysis of conservation concern 2008 – 2013. Irish Birds
8: 149-166.
3Baseline, thus contributing to enhance sustainable management19”. The Overall Target of Ireland’s
National Biodiversity Plan is “that biodiversity loss and degradation of ecosystems are reduced by
2016 and progress is made towards substantial recovery by 202020”. Ireland’s Biodiversity Action
Plan also has a specific target for biodiversity in the wider countryside to “optimise use of
opportunities under agricultural, rural development and forest policy to benefit biodiversity.”
Internationally, Ireland has obligations for biodiversity conservation at a European level (preventing
biodiversity loss is a priority for the Europe 2020 strategy)21 as well as globally22.
In addition to the delivery of national and international commitments on biodiversity conservation,
and the recognised need to integrate actions toward this end into agriculture and other sectors,
sustaining biodiversity also has many positive benefits for farming in itself. These are services
provided by biodiversity which we would otherwise have to pay for ourselves. They are often under-
estimated and under-valued even by the agri-food sector, and include pollination, predator control,
maintenance of soil fertility and structure and water management services23. According to Bord Bia
and others in the agri-food sector, the perceived green image of Ireland gives us a significant
competitive advantage when marketing our products abroad. If we are to maintain this image, we
need to move urgently to proactively support biodiversity and ecosystem services in the farmed
landscape and implement measures where species and habitat losses are most pressing. It is well-
documented that many modern, intensive farming practices leave little space for birds or
biodiversity24. Many birds that use farmland habitats that were previously common have suffered
major population declines since the 1970’s. In Ireland, these include Kestrel, Skylark and
19
Communication from the Commission to the European Parliament, the Council, the Economic and Social Committee and the Committee
of the Regions: Our life insurance, our natural capital: an EU biodiversity strategy to 2020. July 2011.
20
Department of Arts, Heritage and the Gaeltacht, 2011. Actions for Biodiversity 2011-2016: Ireland’s National Biodiversity Plan.
Department of Arts, Heritage and the Gaeltacht, Dublin.
21
European Commission. 2010. Europe 2020: A strategy for smart, sustainable and inclusive growth. Communication COM(2010) 2020
final, European Commission, Brussels. http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2010:2020:FIN:EN:PDF (accessed
January 2013)
22
Convention on Biological Diversity. 2010. Strategic Plan for Biodiversity 2011-2020. http://www.cbd.int/decision/cop/?id=12268
(accessed August 2012).
23
National Rural Network. 2011. Biodiversity as a Resource in Agriculture and Rural Development.
http://www.nrn.ie/wpcontent/uploads/2011/08/swig2_biodiversity_as_a_resource_in_agriculture.pdf (accessed August 2012)
24
Newton, I. 2004. The recent declines of farmland bird populations in Britain: an appraisal of causal factors and conservation actions. Ibis
146: 579-600.
4Yellowhammer, with Corn Bunting (a tillage-specialist) becoming extinct as a breeding bird in
Ireland, with the last confirmed breeding in the 1990s25.
Birds are indicators of the health of the countryside. Like the “canary in the coalmine”, birds can
provide early warning systems for the degradation or loss of ecosystems, and the services such
ecosystems provide. Birds satisfy many of the criteria of effective indicators, are often used as an
early-warning system to detect emergence of environmental problems, and have been widely used
to inform decision making and land use management policy including within agricultural
ecosystems26. The decline in farmland bird populations is telling us that we need to do more to
maintain a healthy balance of nature across Irish farmland. Any proposals in a future Mitigation
Plan which demonstrates the sources, sinks and stores of carbon relating to agriculture must ensure
that biodiversity and especially birds and their habitats do not lose out.
The intensification of the dairy sector under FH2020 requires that the vast majority of good
agricultural land be utilised in intensive pastoral faming systems. This is driving the forestry sector to
target marginal land for afforestation with conifers. At both a regional and national scale this
marginal land is all too often the land that has seen the least intensification. These low input areas
are often the last refuges for many species which have been marginalised by the intensification of
agriculture. In this way afforestation is resulting in the direct loss of endangered habitats and
species. High Nature Value farmland including Ireland’s designated SACs and SPAs are being
afforested. This deleterious trend is most obvious in our uplands and riparian SACs. It is noted that
unenclosed or marginal land is targeted by the Forestry Programme and this will reduce further the
habitats available for our native birds.
BirdWatch Ireland has already raised concerns related to the likely environmental impacts of Food
Harvest 2020 (FH2020) and the role of Ireland's Rural Development Programme. The Environmental
Analysis Report (EAR) of FH2020 identified that FH2020 actions would have a negative impact on the
environment, including biodiversity. Although the level of this negative impact is debatable, it is
agreed that FH2020 actions will damage Ireland's environment. However, the EAR suggests that
these negative impacts could be mitigated through actions within the RDP. FH2020 has been
proposed as a vision led by the Irish agri-food industry, and is not government policy. As a result, the
25
Lynas, P., Newton, S.F. & Robinson, J.A. 2007. The status of birds in Ireland: an analysis of conservation concern 2008 – 2013. Irish Birds
8: 149-166.,
26
Gregory, R. D., A. van Strien, P. Vorisek, A. W. Gmelig Meyling, D. G. Noble, R. P. B. Foppen and D. W. Gibbons. 2005. Developing
indicators for European birds. Philos. T. R. Soc. B 360: 269-288.
5polluter-pays principle states that it should be the Irish agri-food sector that is responsible for
addressing negative environmental impacts arising from FH2020 actions rather than European
taxpayers (through the RDP).
Discussion Document Points
Greening in Pillar One-Hedgerows:
In the Discussion document there is a description of the Greening measures Irish farmers need to
comply with in order to receive their Basic Payment. The Ecological Focus Areas are a requirement
for a relatively small number of arable farmers in Ireland. The Hedgerow greening measure for these
farmers allows a farmer to receive 100% payment for a 100m hedgerow which only contains 20%
vegetative material dispersed over the 100m (i.e. gappy hedges) and which can include briars. How
does this qualify as a hedgerow? Our hedgerow network sequesters carbon (estimates suggest that
hedgerow and nonforest woodlands could potentially sequester 0.66–3.3 t CO2/ha/year27). This
current greening measure under Pillar 1 in the CAP (2014-2020) does not adequately contribute to
achieving environmental targets. Farmers should be required to plant up gappy hedgerows with
tree/shrub stock of native Irish provenance in order to receive their payment to ensure that the full
payment means that a full 100m of hedgerow exists and to further contribute to carbon
sequestration.
Knowledge Transfer:
BirdWatch Ireland fully agrees that one of the most appropriate ways to achieve the FH2020 targets
is through an improved training and advisory programme. Such a programme would not only
enhance the benefit of actions under FH2020, but also help deal with environmental risks from the
FH2020 actions. Once risks are identified, appropriate measures can be taken to either avoid
potentially damaging actions, or better deliver mitigation measures to avoid them. Such a training
and advisory programme must include environmental expertise to ensure damage is minimised and
positive benefits for the environment, and the associated benefits this has for the agri-food sector,
can be maximised.
An assessment of the levels of environmental education within Teagasc, Agricultural Education
Courses in Kildalton College was presented at the Teagasc Agri-Environment Conference in
Tullamore in November 2014. When students were asked how significant is the role of agriculture in
27
Black, K., Green,S., Mullooley, G., & Poveda, A., (2014) Carbon Sequestration by Hedgerows in the Irish Landscape, Ireland;
Environmental Protection Agency.
6Irelands greenhouse gas emissions, 51% stated that it had some significance, 38% stated that it was
very significant with 11% stating that it had little or no significance. When students were asked how
important is the area of biodiversity to Irish agriculture 71% said it was slightly important with 13%
saying it was extremely important and 16% saying it was not important. These results would imply
that there is a lot more work to be done to educate young farmers on the importance of climate
change and of reducing emissions in agriculture as well as the importance of biodiversity which
underpins agriculture. The presentation on the research is available here:
http://www.teagasc.ie/publications/2014/3366/Environmental-Conference-Gerard-Griffin-PP.pdf.
Bionergy: Targeted Agricultural Modernisation Schemes II (TAMS II)
Under the section on bioenergy it is stated that there are “Potentially positive impacts on
biodiversity, most notably invertebrates and birds, through the provision of additional types of
habitats”. This statement needs to be backed up by research on the impacts on biodiversity and
birds. Currently, there is no known research in Ireland on the impacts, positive or negative, of Short
Rotation Coppice on birds.
Forestry and Bioenergy as Mitigation for Agricultural Emissions
In the European Council Conclusions of October 2014 ‘the Commission is to examine the best means
of encouraging the sustainable intensification of food production, while optimising the sector's
contribution to greenhouse gas mitigation and sequestration, including through afforestation. Policy
on how to include Land Use, Land Use Change and Forestry into the 2030 greenhouse gas mitigation
framework will be established as soon as technical conditions allow and in any case before 2020’.
From the Discussion document, it is clear that forestry and bioenergy are suggested as the offsets for
agriculture-related greenhouse gases. The consultation process accompanying the proposed
National Mitigation Plan should be the mechanism whereby the public is given a voice on how we
should decide on national mitigation for greenhouse gases using the available reservoirs and sinks of
carbon. Some other questions which may need to be addressed and clarified in the mitigation plan
relates to ownership of the store of forest carbon and to which sector will the benefits of the store
be attributed for mitigation? If the government provides grants to landowners for forestry
plantation does the government own all or part of the sink/reservoir of carbon? Is it possible that
the non-grant aided amount of forestry could be used to offset emissions from other sectors
including possibly the private sector?
7The permanence of the forestry stock taking in to account the risks associated with wind blow,
disease, fire etc along with the potential for Double Counting needs to be taken into account in the
carbon budget and to verify the carbon sequestration potential as proposed in the Discussion
document. It will be essential that forest stocks are chosen that can adapt to a changing climate. Due
to a warming climate, there is a need to select and use species that are more suited to the potential
future changes in climate. Native Irish species of Irish provenance should be researched for their
potential adaptability to climate change and the appropriate stock chosen. “In general most
broadleaved species have a higher carbon content than conifers but this is offset by their lower rate
of growth, although in species with very long rotations (i.e. >100 years) such as oak, the carbon
stocks averaged over time can be higher than in faster growing conifer stands.28”
All of the potential impacts of forestry expansion including road construction will need to be taken
into account in the greenhouse gas emissions sinks and sources and their mitigation. “The
construction of forest roads and subsequent increase in traffic and felling and thinning activities is
likely to increase CO2 emissions”29.
Forestry expansion & main potential impacts on birds
The proposed expansion of forestry under the Forestry Programme 2014-2020, if implemented, will
lead to substantial change to the Irish landscape with potentially significant impacts to birds and
biodiversity. Research has shown that ‘forest management for the benefit of birds should focus on
increasing the structural diversity of forests’30. Considerations of impacts of our existing forest cover
and planned expansion on our native bird communities, particularly those of grassland, upland
moorland, riparian and lake & fen habitats include;
Changes in water quality and water retention: Potential impacts through the acidification of
watercourses, particularly those with low-buffering capacity and knock-on negative impacts
on prey abundance (invertebrate/fish spp.) and for birds associated with riverine, lake & fen
habitats (e.g. Dipper, Grey Wagtail, Kingfisher, Common Scoter, Tufted Duck, Great-crested
Grebe) and breeding productivity (e.g. Dipper31)
Displacement disturbance: For example - Loss of open upland heath/bog habitat to new
plantations has direct impacts on upland breeding birds through displacement. Those which
prefer open landscapes include breeding waders (Golden Plover, Curlew, Dunlin), Raptors
28
Forestry Commission, Woodland Carbon Code (2014) Woodland Carbon Code [online], available:
http://www.forestry.gov.uk/forestry/infd-883l84#5, [accessed 20/3/2015]
29
Department of Agriculture, Food and Marine (2014) Environmental Report of the Forestry Programme 2014-2020.
30
Sweeney, O., Wilson, M.W., Irwin,S., Kelly, TC., Gittings, T., and O’Halloran T (2011) Breeding birds of native woodlands and
plantation forests in Ireland. Irish Birds, 9: 181-196.
31
Ormerod, SJ, O’Halloran, Gribbin, SD & Tyler, SJ 1991. The ecology of Dippers Cinclus cinclus in relation to stream acidity in upland
Wales; Breeding performance, Calcium physiology and nestling growth. J. Appl. Ecology, 28:419-433.
8(Hen Harrier, Merlin, Peregrine), Raven, Red Grouse etc. Also, the effect of habitat
fragmentation and/or edge effects of forestry on the distribution and ecology of key species
require consideration.
Loss of feeding areas: Particularly important for raptor species. For example, open country
species abandon afforested areas once trees get above a certain height. The distinction
between pre-thicket and closed-canopy stages is important in this instance.
Changes to predatory regime: Studies have shown that increased forest cover can raise
numbers of predators in an area (e.g. observed impact on upland breeding birds32).
Physical impacts of forestry activities: Studies have shown impacts on watercourses,
(changes in pH and heavy metal concentrations) catchment soils, geology and erosion rates.
Habitat change: Impacts of drainage on underlying habitat and habitat quality knock-on
impacts on food availability for bird species (e.g abundance of invertebrates and preferred
prey items).
Chemical spraying: Use of pesticides and herbicides on invertebrate composition and
abundance is well documented, while fertiliser use can cause increases in vigorous grasses
such as Molinia in areas adjacent to forest stands, which reduces plant species diversity and
the suitability of sites for breeding waders.
Conclusion
Agriculture is in the process of intensification in Ireland with projected increases in greenhouse
gases. This intensification will cause impacts to birds and their habitats. Sustained and increased
afforestation is being proposed as the main ‘offset’ for the emissions from agriculture and this land
use change will impact on birds and their habitats. The proposed changes to land use in Ireland
could be a triple whammy for birds in Ireland. They need to be further investigated to ensure that
birds, their habitats and biodiversity in general is not only not impacted further and that any
impacts are mitigated against but that habitat structure and function is restored and species
populations are increased thereby improving resilience to climate change. We also need a debate
on land use policy in Ireland and how we envision our country in 50 to 100 years time.
A report by the German Federal Agency for Nature Conservation states “As has been pointed out by
the Millennium Ecosystem Assessment the components of biodiversity (at the levels of genes,
species and ecosystems) form the basis for the provision of ecosystem services, many of which are
32
Avery, M.I. & Leslie, R. 1990. Birds and Forestry. T. & A.D. Poyser,
London. Thompson, D.B.A., MacDonald, A.J., Marsden, J.H. & Galbraith, C.A. 1995. Upland heather moorland in Great Britain: a review of
international importance, vegetation change and some objectives for nature conservation. Biol. Conserv. 71: 163–178.
9central to human well-being. However, we cannot determine with certainty which specific genes,
species, communities or ecosystems are critical for specific ecosystem services in a given situation.
Added to this, changing climate conditions will undoubtedly change these relationships, and so
losing any element of biodiversity is likely to reduce the potential for continued provision of
ecosystem services. Thus, any climate change-related measure or policy – and indeed any other
policy - that has negative impacts on biodiversity risks being counter-productive. All such policies
and activities should therefore be carefully designed to minimize negative impacts on biodiversity”33.
END
33
Cowan, C., Epple, C., Korn, H., Schliep, R., and Stadler, J., (eds) (2010) Working with Nature to Tackle Climate Change- Report of the
ENCA / BfN Workshop on “Developing ecosystem-based approaches to climate change – why, what and how” Bonn: Bundesamt für
Naturschutz (BfN)
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