Recommendations on the implementation and review of the National Biodiversity Plan

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Recommendations on the

Implementation and Review of the

National Biodiversity Plan

C O M H A R

THE NATIONAL S U S TA I N A B L E DEVELOPMENT PA RT N E R S H I P

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“At the most popular level, there is the instinctive pleasure in nature’s variety, at least in its familiar and colourful forms. The notion that this should be handed on intact ‘to our grand-children’ is now a moral imperative for many people. Quite as appealing to utilitarian minds is the wisdom of keeping the maximum number of species up humanity’s sleeve for potential future use: a pool of genes for new crop species; a cure for cancer in the rainforest.”

M I C H A E L V I N E Y

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Members of the Biodiversity Working Group:

  Birdwatch Ireland

  An Taisce

  Irish Farmers’ Association

  Coastwatch

  Environmental Protection Agency

  Heritage Council

  Sunflower Recycling.

Supported by:

  Chairman of the WG, Comhar secretariat

  Comhar secretariat

 c

  Department of Environment, Heritage and Local

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Mid-term review of the

National Biodiversity Plan

Executive Summary

Background

One of the most significant resources of our planet is Earth’s great diversity of species, interacting within a vast range of intricate ecosystems. This richness of life has already been damaged by our ancestors and is under severe threat currently due to the huge expansion of human population numbers and explosion of economic activity. To coun-teract this threat, a global Convention on Biodiverstiy was drawn up in  by the United Nations. Ireland ratified this convention in .

Ireland’s National Biodiversity Plan (NBP) was prepared in response to this and it was published in . The Plan sets out ninety-one actions aimed at conserving biological diversity in Ireland over the five years from to . This report presents a mid-term review of progress on the implementation of the Plan. The review was prepared, at the request of the Department of Environment, Heritage and Local Government (DoEHLG), by a working group of Comhar. The group was assisted in its work by the National Parks and Wildlife Service of the DoEHLG and the Comhar secretariat.

Status of implementation

Progress on most of the actions in the Plan has been slow or minimal. It is difficult to audit the Plan due to a lack of prioritised targets within specified timescales. Where progress has been made in the implementation of some of the actions contained in the NBP, it is largely in areas where the European Commission has exerted pressures on the Irish authorities to deliver on commitments made.

Recommendations

. Establish a Biodiversity Fund (€million per annum) to support local site conser-vation and management, and for the production of biodiversity awareness and edu-cational material.

. Set up the Biodiversity Forum for all relevant stakeholders.

. Carry out biodiversity awareness and training in all relevant government depart-ments and in local authorities.

. Generate public awareness of the importance and relevance of biodiversity protec-tion to the people of Ireland.

. Establish prioritised targets and timescales for species and habitat protection and conservation.

. Develop indicators to measure progress of conservation measures.

. Update present information systems to improve access to information on all aspects of biodiversity conservation in Ireland.

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Introduction

T

he Convention on Biological Diversity is the first global agreement on the con-servation and sustainable use of biological diversity, with countries having rat-ified the agreement. Ireland signed the Convention on Biological Diversity in

 and ratified it in . The National Biodiversity Plan was published by the Government in April , as Ireland’s response to the requirements outlined under Article of the Convention on Biological Diversity. The EU target is to halt the loss of biodiversity by .

The National Biodiversity Plan (NBP) sets out a list of ninety-one actions which are aimed at halting biodiversity loss in Ireland. The plan is divided into three sections, deal-ing with the overall context for the plan, the specific actions or commitments given by government for addressing biodiversity conservation, and outlines issues dealing with implementation, monitoring and future plans.

The specific actions identified for dealing with biodiversity conservation are presented under the following sub-headings:

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Integration of biodiversity into sectors, ( actions)

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Legislation, (actions)

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Protected areas, (actions)

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Species conservation, (actions)

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Habitat and ecosystem conservation, (action)

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Countrywide conservation, (actions)

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Conservation and sustainable use of genetic diversity, (actions)

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Biosafety – genetically modified organisms (GMOs), (actions)

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Knowledge: identification, monitoring and research, (actions)

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Public awareness and education, (actions)

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EU, regional and international, ( actions)

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Terrestrial ecosystems: agriculture, (actions)

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Terrestrial ecosystems: forests, (actions)

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Inland waters and wetlands, (actions)

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Marine and coastal. (actions)

The NBP covers the five-year period -, and is the first step in establishing a permanent process of committed action to promote conservation and sustainable use of biological diversity. Subsequent plans will be produced on a five-yearly cycle.

The Department of the Environment, Heritage and Local Government has requested Comhar, with the assistance of the Heritage Council, to establish a Biodiversity Working Group that would make recommendations on the mid-term review of the NBP. This document sets out the views of the Biodiversity Working Group on the content and progress with implementation of the NBP. It also makes recommendations that it hopes will be of use in drafting subsequent five-year plans.

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Biological Diversity

B

iological diversity, or biodiversity, is the term given to the variety of life on Earth and the natural patterns it forms. The biodiversity we see today is the result of billions of years of evolution, shaped by natural processes and, increasingly, by the influence of humans. It forms the web of life of which we are an integral part and upon which we so fully depend. It is the combination of life forms and their interactions with each other and with the rest of the environment that has made Earth a uniquely habit-able place for humans.

Biodiversity is beneficial to us. Ecosystems provide a variety of functions including the regulation of climatic processes, breakdown of wastes and recycling of nutrients, filter-ing of water, buffer against floodfilter-ing, maintenance of soil fertility and the provision of natural resources. Biodiversity indicators can be used to monitor environmental quali-ty, such as invertebrates for water and lichens for air. Aside from all these benefits to man, biodiversity has an intrinsic value and it is our ethical responsibility to ensure it is passed on to the next generation.

Species, habitats and ecosystems, the planet’s whole natural heritage, is under an ever-increasing threat. Many species and habitats are in decline and in some cases their future is endangered. Irreversible losses have already occurred, with many species having already become extinct, and the rate of extinction is increasing. The extinction of one species results in the irreversible loss of a unique suite of genetic adaptations that have been acquired typically over very long time scales of hundreds of thousands of years.

Undoubtedly human behaviour now causes, directly and indirectly, considerable loss of biological diversity. Globally, the degradation of biological diversity is principally due to habitat destruction, human population growth, development pressure, poverty, the intro-duction of non-native species, climate change and over-exploitation. The relative effects of these factors vary in time and location. In Ireland today, habitat degradation and loss is the main factor eroding biodiversity, including through changes in agricultural prac-tices, poorly managed afforestation, drainage, urban development pressures, pollution and the impacts of invasive species. The influence of climatic change is becoming increas-ingly important.

Current societal values in Ireland do not place emphasis on the importance of natural resources including biodiversity. This may be due to a lack of awareness of the attrib-utes of the natural world and the fact that economic models have great difficulty in put-ting values on natural attributes and capital. Common good assets tend to be used by all and paid for by no one.

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Observations on the Plan

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It provides a comprehensive list of actions addressing a wide range of govern-ment departgovern-ments, agencies, non-governgovern-ment bodies and other stakeholders.

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It is a welcome first step on the road towards engaging all parts of Government

in protecting and enhancing biodiversity.

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The Plan represents a major opportunity for Ireland to capitalise on and enhance its clean green image by taking action to conserve species and habitats which could become a symbol of a high quality environment.

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A significant body of biodiversity skills and expertise has been built up in recent years due to government investment in research programmes.

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Economic growth and enhanced public awareness has improved the opportu-nity and demand for better knowledge generation, conservation and enhance-ment.

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Reform of the Common Agricultural Policy is a major opportunity for refo-cusing agricultural policy as a positive force in favour of biodiversity. Cross compliance requirements will bring about major changes for biodiversity.

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Biodiversity loss is occurring at an increasingly rapid rate and therefore

demands effective and timely action.

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Pressures on biodiversity are increasing with growth in population, use of resources and change in land use, urbanisation, road building and infrastructure development.

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Climate change is bringing about movement of species from one geographical region to another. This is adding to the complexity of biodiversity manage-ment.

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The impact of Genetically Modified Organisms (GMOs) and threat of invasive species to Irish flora and fauna needs to be examined.

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Main Issues in the Plan

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he Biodiversity Working Group has identified a number of key issues which it feels are central to the successful implementation of an effective NBP, and which underpin much of the efforts to ensure that the conservation of biological diver-sity receives the importance it deserves.

The main issues are:

The Process

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The 'top-down' approach is a major weakness as it fails to avail of the opportu-nities provided to draw on the expertise, support and enthusiasm of the stakehold-ers. Successful and complete implementation of the NBP is not possible without the active involvement of stakeholders.

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It is regrettable that little effort has been made to establish a meaningful

participa-tory processto complement the development and implementation of the current

and subsequent plans. The process of developing national plans is just as important as their implementation as it can become a way of building the political and social consensus needed to make the changes necessary in society and national life.

Implementation

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The lack of a dedicated and adequately resourced Biodiversity Unit to oversee implementation of the NBP is a serious weakness in the Plan’s implementation. The successful implementation of the NBP is dependent on the professionalism and energy of dedicated staff to promote and support the identified actions.

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The absence of adequate and dedicated financial support to assist the imple-mentation of the Plan is a serious impediment to the impleimple-mentation of the iden-tified actions.

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The overall value of the Plan is diminished by failure to prioritise actions, and by not including specific targets and timescales. The absence of targets makes it diffi-cult to assess progress with implementation of the Plan. The lack of a clear struc-ture makes it difficult to communicate objectives and engage key players.

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The Plan provides no incentives or guidance for those “asked” to carry out actions.

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The failure to recognise the important contribution that the private sector can make to achieving the objectives of the Convention on Biological Diversity is a weakness of the Plan. The Plan would benefit greatly from identifying some

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egy or process by which the private sector could engage with public bodies to ben-efit the conservation of biological diversity.

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Delay in publishing the plan and the lack of a public launch meant that the Plan was not the call to action, or promoted actively, so there was little response in terms of implementation.

Education/Awareness

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Status of Implementation

of the Plan

General

P

rogress with implementation of the NBP has been very slow. The absence of spe-cific targets and timescales for the different actions identified in the Plan makes it difficult to assess progress with its implementation. The absence of a clear struc-ture and order of priorities of the actions is a weakness in its implementation. Many actions outlined in the Plan are too general and lack specificity. The Plan does not have political and public support and generally has not achieved its objective.

Progress has been made in the implementation of some of the actions contained in the NBP largely in areas where the European Commission has exerted pressures on the Irish authorities to deliver on commitments made.

The Biodiversity Working Group reviewed and discussed all ninety-one actions con-tained in the Plan and commented on progress, based on the knowledge available to the members of the group. A detailed commentary on each action is given in Appendix  to this report. The following is the summary view of the Working Group presented under each of the main subsections of the report.

Summary review of actions listed under 15 sub-headings of the Plan

(a) Integrating Biodiversity into Sectors (actions 1 to 11)

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Some limited progress has been made in this area, but the failure to establish a Biodiversity Unit to promote and assist the implementation of the NBP is a serious weakness. It suggests that the conservation of biological diversity is a low priority. The absence of dedicated funding to promote biodiversity actions is similarly disap-pointing and reflects poorly on the commitment to the conservation of biological diversity at government level.

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A key mechanism to achieve the conservation of biodiversity is by ensuring that all relevant plans, programmes and legislation incorporate specific provisions for biodi-versity. There is little evidence that comprehensive progress has been made in this area. This has resulted in policy conflicts in a number of areas e.g. hen harrier pro-tection and wind farms.

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Some progress has been made on the delivery of Local Biodiversity Action Plans. Structures now exist at the local level to facilitate stakeholder input and involve-ment. Six local authorities have commenced the process of producing Local Biodiversity Action Plans. The Heritage Officer posts, Heritage Forums and the County Development Boards provide appropriate structures at the local level for addressing conservation of biological diversity issues. However the Department of

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Environment, Heritage and Local Government needs to capitalise on this and take a much more proactive role in availing of these opportunities for promoting biodi-versity.

(b) Legislation (actions 12 to 14)

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The legislative basis for protecting and enhancing biodiversity needs to be strength-ened along the lines of the Water Framework Directive. It is essential to have strong legislation based on ecological principles to ensure that the conservation of biolog-ical diversity receives the attention it deserves.

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There is a need for more comprehensive geographic information on biodiversity to be readily accessible to planning authorities in the discharge of their statutory func-tions.

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The Department of Communications, Marine and Natural Resources needs to progress its commitment to introduce new legislation on integrated coastal zone management.

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There is a need for guidance and training for planners to facilitate the adequate assessment of biodiversity aspects of proposals.

(c) Protected Areas (actions 15 to 24)

Public Awareness, Consultation and Support

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One of the unfortunate consequences of the manner in which the designation of Natura sites has been tackled in Ireland, is the resultant negative perception of nature conservation amongst the general public. It is regrettable that a more proac-tive programme of promotion of the benefits of nature conservation has not been initiated to counteract this negative perception of the designation process. Such programmes have been implemented to great effect in other EU States.

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Gaining the support of the general public for the objectives of Natura will only occur if a far greater effort is made to promote the importance of the designated sites for both nature conservation and for local communities. To this end, efforts should be made to inform local communities of the location and nature conserva-tion significance of sites in their locality, and of the potential socio-economic ben-efits of Natura .

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Involvement of all relevant stakeholders in the designation and management process needs to be strengthened. For example, the formal appeals process should be mod-ified to allow NGOs and other state agencies access to the process. In addition, the current liaison committee system should be extended to include all relevant stake-holders.

Designation

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open and transparent manner (and be equally accessible to NGOS and scientists). The current ad hoc system of boundary review has resulted in much confusion and also damage to important habitats.

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It must be emphasised however, that designation, though crucial, is only a means to an end. Despite the designation of sites, habitat loss is still continuing within SACs and SPAs. There needs to be far greater enforcement of legislation. It is also wor-rying that recent guidelines issued by the Department of the Environment, Heritage and Local Government appear to downgrade the strict protection afforded to SACs in order to facilitate development.

Production & Implementation of Management Plans

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While progress has been made in the formal designation of Natura  sites, it is regrettable that there has been such delay in the production and implementation of management plans for the sites. This delay is causing uncertainty as to the exact con-sequences of designation, and is not assisting the attainment of favourable conserva-tion status on the sites. Despite funding from the EU, the process of management plan preparation for Natura sites has been inadequate. Particular issues of con-cern are:

- Lack of public participation in the process of devising plans

- Delay in publication of draft plans and restricted availability of plans

- Lack of practicable actions, targets and review dates in plans published to date

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Once plans have been agreed, it will be essential that adequate resources are made available to ensure that they are implemented, that the results are monitored and that the plans are periodically reviewed and revised as necessary.

Monitoring and Review

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A systematic programme of monitoring and review, with publication of data and results, is necessary, to assess the impacts of positive management on the species and habitats for which sites have been designated and to ensure that damage to sites is recorded and addressed.

Nature Reserves

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The mechanism for designation of privately owned nature reserves should be pub-lished and promoted. There is considerable local interest and goodwill towards the idea of local nature reserves. To harness and encourage this, a community partner-ship approach should be encouraged and public participation should be facilitated.

(d) Species Conservation (actions 25 to 30)

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Successful action to safeguard Ireland’s biological diversity is dependent on putting in place a system of tracking and identifying species of conservation concern, and producing and implementing Action Plans for threatened species.

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(e) Habitat and Ecosystem Conservation (action 31)

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There is a need to develop a systemic and comprehensive approach for identifying habitats of nature conservation interest, and the development and implementation of Habitat Action Plans. Habitats considered to be of conservation importance should also include those of local conservation importance.

(f) Countrywide Conservation (actions 32 to 34)

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The conservation of biological diversity in the wider countryside, outside specially designated sites, is one of the central planks of the biodiversity approach. With the exception of improvements made to the Rural Environment Protection Scheme, (see sub-paragraph m below) efforts to address the conservation of biological diver-sity in the wider countryside have been very poor. This is a significant weakness of the NBP.

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A particular weakness of the NBP is that hedgerows are the only habitat identified for special consideration in the countryside, yet other habitat features such as ponds and watercourses, semi-natural grasslands, scrub, etc, are equally important for the conservation of biological diversity. No actions have been identified for the con-servation of these elements.

(g) Conservation and Sustainable Use of Genetic Diversity (actions 35 to 37)

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While efforts have been made to conserve the genetic variety of domesticated plants and animals, little effort has been made to ensure genetic diversity of wild species. The Department of the Environment, Heritage and Local Government is the appro-priate body to take the initiative in this area.

(h) Biosafety – Genetically Modified Organisms (GMOs) (actions 38 & 39)

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The Cartagena Protocol on Biosafety, part of the Convention on Biological Diversity, has been ratified. This recognises the right of any country to say no to the import of GMOs, even in the absence of scientific information, on the basis of the precautionary principle due to “the extent of the potential adverse effects of a living

mod-ified organism on the conservation and sustainable use of biological diversity”.

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This protocol will, no doubt, be instrumental in the future decisions about growing GM crops in Ireland. Ireland has yet to develop co-existence legislation, which would lay down the way in which GM crops would be regulated in order to pre-vent contamination (above a certain threshold) of non-GM crops and seeds. It may make more economic sense to adopt a GM-free approach, which would make label-ing of Irish produce simpler and give the brand an extra boost.

(i) Biodiversity and Sustainability

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great and it will negatively affect the capacity of ecosystems to respond to further changes.

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There is an ongoing problem with the concept of ‘sustainable development’ which needs to be addressed. It is used more often to describe whether a given activity can be/is economically viable than in the full Bruntland and Rio - environmental, social and economic - sense. Correct and clear use of the term and consequently scruti-ny tests are essential in order to measure ‘real’ sustainability.

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Respect for ecological integrity and biodiversity is one of the key themes of Comhar’s Principles for Sustainable Development. The Principles recognise that sustainable development is above all about integration and that environment must be treated as an integral part of economic development and part of the socio-cul-tural sphere.

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It is welcome that EU grants and supports have become much better orientated towards sustainable use of resources and increasingly take biodiversity into due account. But unless those who apply the new rules and make project decisions are conversant with sustainability, and have some knowledge of the complexity of bio-diversity, supports like Leader, CAP and Common Fisheries Policy (CFP) can still be misapplied and damage biodiversity inadvertently.

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EU legislation on Nature provides for situations where biodiversity loss in a pro-tected area is unavoidable or of overriding public importance. For such cases, mit-igation and compensation regimes are set out. It is of great concern that in practise such losses are generally not compensated in Ireland. This area requires special atten-tion over a whole project life cycle – from original concept and scrutiny of whether it really is unavoidable to build or take a certain route, over decisions on compensa-tion, to implementacompensa-tion, monitoring and fine tuning. Such life cycle analyses on sustainability should yield badly needed data to use in future cases.

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Indicator data gathering from large numbers of small points and efficient feedback in an understandable manner is essential. It is welcome that policy and research are now going in this direction. The full application of the Water Framework Directive should allow significant progress. This approach would serve as a model for other areas.

(j) Knowledge: Identification, Monitoring and Research (actions 40 to 44)

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The Convention on Biological Diversity and the NBP are essentially knowledge-based initiatives. Therefore, the importance of having detailed high quality infor-mation available to assist the process cannot be overemphasised. In this regard, the announcement by the Minister of his intention to establish a National Biological Records Centre is very welcome.

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The development of a research agenda with the academic community and policy makers is also a good example of the kind of partnerships that should be developed for implementation of the NBP. It is strongly recommended that the Platform con-tinues beyond the life-time of this five-year Plan.

(k) Public Awareness and Education (actions 46 & 46)

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A significant impediment to the successful implementation of the NBP is the lack of political support, and generally a poor appreciation or understanding of the need for the conservation of biological diversity amongst the general public. Far greater effort should be made to build on existing education and awareness initiatives and to progress the development of the targeted education and awareness strategy as pro-posed in the Plan.

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A campaign to heighten awareness of the importance of biodiversity, similar to the Euro-Changeover Campaign, should be undertaken.

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To date those who have been most active in biodiversity education awareness rais-ing are the environmental non-governmental organisations. These groups should be supported with financial assistance from the Department of the Environment, Heritage and Local Government.

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Those in charge of implementing the Plan should consider working with national competitions, e.g., the Tidy Towns Competition, with the objective of adding a bio-diversity conservation award to the prize list.

(l) EU, Regional and International (actions 47 to 56)

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The Irish authorities are obliged to support and to implement international and regional agreements and conventions that seek the conservation of nature and bio-logical diversity. The Department of the Environment, Heritage and Local Government should actively engage with the Department of Foreign Affairs to ensure that their Overseas Development Aid programme supports the principles of the Convention on Biological Diversity.

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There are major opportunities to leverage biodiversity conservation through the very significant aid programme the Irish government provides to African countries in particular.

(m) Terrestrial Ecosystems: Agriculture (actions 57 to 64)

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The Biodiversity Working Group is supportive of the principle that farmers who undertake positive actions for the benefit of our biological diversity, should be rewarded financially for this positive management. Against this however, it is regret-table that agricultural activity is considered largely exempted development in cer-tain areas of legislation that impact greatly on nature conservation, such as the Wildlife Acts,Waste Permits and Land Reclaimation.

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The Mid-Term Review of the Common Agriculture Policy has introduced funda-mental changes to the CAP by decoupling farm supports from production. With effect from January,, the system of production-linked supports to farmers has been replaced with a fully decoupled Single Farm Payment. This payment will be conditional on cross-compliance with EU Directives including biodiversity con-siderations, adherence to the Code of Good Agricultural Practice and subject to inspections.

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While the consequences of this for biological diversity are still unclear, the Government should avail of all opportunities that this policy change provides for the enhancement of biological diversity. To achieve this, it is vital that the influence of policy reform is monitored for the influence it has on biological diversity.

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The introduction of REPS , with its range of optional enhancement measures, is a very welcome development in integrating biodiversity concerns into this sector. The consultation exercise undertaken by the Department of Agriculture and Food in the development of REPS is to be welcomed. Additional initiatives should be taken to further assist this integration. These include the introduction of monitoring of the ecological aspects of REPS and of Commonage Framework plans. A first step is the introduction of a wildlife audit or survey when farmers are entering REPS . Another positive contribution would be the formal involvement of National Parks and Wildlife in the approval of farm plans for all farms within designated sites.

(n) Terrestrial Ecosystems: Forests (actions 65 to 78)

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As the largest land-use change in Ireland, afforestation has significant potential to impact negatively on the conservation of biological diversity in Ireland. The impact of this land-use change on biodiversity in the wider countryside has not been ade-quately assessed. Current forestry policy should be reviewed in the context of the Convention on Biological Diversity and the National Biodiversity Plan, to ensure a full assessment of its impacts and the incorporation of biodiversity conservation pro-visions.

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The development of Guidelines on Biodiversity by the Forest Service and the devel-opment of biodiversity plans for the Forest Management Units of Coillte are both significant measures aimed at benefiting biological diversity as part of the afforesta-tion programme. It is crucial that the Biodiversity Guidelines are extended to include sites below ten hectares. The Native Woodland Scheme and the Inventory of Native Woodlands are also very important initiatives for the conservation of native woodlands.

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Despite these developments, the aspects of forestry where biodiversity is the primary objective are starved of funding during times of financial constraint. This appears to indicate that nature conservation is still a low priority for the forestry sector and the Forest Service in particular.

(o) Inland Waters and Wetlands (actions 79 to 84)

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Wetlands are particularly valuable for biological diversity, and Ireland is fortunate to have an extensive wetland resource of high biodiversity value. The implementation of the Water Framework Directive (WFD) is a very positive development, and should greatly enhance the protection of Ireland’s main rivers and water bodies. The scientific approach to water conservation and the River Basin management approach adopted in the WFD is an excellent example of the kind of systematic approach needed to deal with such an important and complex issue.

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Despite progress with the WFD, there are many outstanding issues surrounding the protection of wetlands that need to be addressed, in particular reducing the negative impacts of arterial and field drainage and halting wetland loss through infilling and reclamation. The absence of a national wetland inventory, as required under the Ramsar Convention, is a serious weakness, as it makes it impossible to identify the extent to which wetlands in Ireland are being destroyed. It is regrettable that the range of actions outlined in the Plan is not adequate to protect and enhance small wetland features such as streams, ponds, marshes and wet grasslands.

(p) Marine and Coastal (Actions 85 to 91)

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Ireland has an extremely diverse marine environment, containing a diversity far exceeding that of the terrestrial environment. Because of the unique importance of Ireland’s marine environment for maintaining biological diversity, there is a pressing need for the marine sector and its range of activities to adopt a comprehensive pro-gramme of biodiversity and nature conservation measures. In this regard, recent expansion of research in the marine environment is welcome.

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Aquaculture is an expanding industry in Ireland, and considerable investment was put in place for its expansion in the National Development Plan  – , in order to double output by . However, this growth is being undertaken with-out any carrying capacity studies of the bays or estuaries involved.

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A high proportion of the aquaculture licences granted by the Department of Communications, Marine and Natural Resources are within Natura sites. No Environmental Impact Assessment for shellfish applications within these sites is required by the Department of Communications, Marine and Natural Resources (DCMNR) as part of the application process, despite the requirement for ‘appro-priate assessment’ in the Habitats Directive. In addition, conservation management plans have not been published for these coastal SACs and SPAs. Aquaculture poli-cy needs to incorporate biodiversity considerations by addressing these deficiencies. A National Integrated Coastal Zone Management Strategy is urgently required.

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It is regrettable that such little progress has been made in the development of the Coastal Zone Management Strategy, as outlined in Action  of the National Biodiversity Plan. The Department of the Environment, Heritage and Local Government should play a lead role in the development of this strategy.

(q) Implementation, monitoring and future plans (Chapter 3 of NBP).

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The working group agrees with the section of the Plan dealing with implementa-tion. It sets out the importance of having concerted and systematic action to address conservation of biological diversity in Ireland. It is regrettable that so little progress has been made of the kind needed to give the conservation of biological diversity the high profile it needs if the Plan is to be implemented successfully.

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One of the key elements of the National Biodiversity Plan is the commitment to establish a Biodiversity Forum. The establishment of the Biodiversity Forum is essential to assist in the development, implementation and promotion of all actions striving to conserve Ireland’s biological diversity. That this Forum has not been established is a major weakness with implementation of the Plan.

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6. Recommendations

A. General Recommendations

These recommendations reflect the discussions of the Working Group in relation to the overall approach and broad issues of the NBP. Specific recommendations in relation to technical issues are included in the detailed response to the actions of the NBP.

1. Resources

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The implementation of the NBP must be adequately resourced (financial and human). To date, few if any of the responsible departments have staff dedicated pure-ly to implementation of the Plan. Given this lack of priority, it is hardpure-ly surprising that progress in implementing the Plan has been slow.

•

A Biodiversity Fund of the order of €m per annum should be established. The objectives of the fund should be twofold: first to facilitate the conservation and man-agement of local sites specifically for biodiversity objectives; and second, to encour-age the production of educational and other information to increase understanding of the needs for the conservation of biological diversity at the local level. The resources could be allocated from the Environment Fund or a percentage of prop-erty taxes.

2. Involvement of Stakeholders in Implementation

•

The Biodiversity Forum proposed in Action  of the NBP should be established without delay. This Forum should be representative of all relevant stakeholders, and every effort should be made to include representatives from sectors (including the private sector) where the full impact and importance of the NBP may not yet be fully realised. Properly constituted, such a Forum can act in a proactive way, to assist in the implementation of the NBP, thus providing a valuable resource to Government in the implementation and review of the current plan and in writing future plans.

•

One of the major aims of such a Forum would be to promote the objectives of the Plan amongst its partners/members, and to provide the momentum for ensuring that the priority actions of the Plan are implemented. In addition, the Forum could take on the responsibility of promoting a biodiversity education and awareness strat-egy as identified in the NBP. (See Annex for draft terms of reference).

3. Training/Familiarisation

•

Training and familiarisation on the relevance of biodiversity and the relevance of the NBP should be held within all government departments. The operation of all departments has an impact on biodiversity in some way, and this may easily be over-looked if it is not highlighted. In addition, specific targeted training should be pro-vided for staff within the departments with most responsibility for implementation

(22)

of actions in the NBP, e.g., Environment, Heritage & Local Government, Agriculture & Food, Communications, Marine and Natural Resources, Community, Rural & Gaeltacht Affairs, and Transport.

4. Education and Public awareness

•

It is essential to develop public awareness of the importance of biodiversity and the relevance of all the aspects of the NBP. For example, much international research has been carried out on the socio-economic benefits of the Natura Network. This work is easily transferable to the Irish situation and could be supplemented with locally based studies.

•

This education and awareness role could form part of the remit of the Biodiversity Forum, which could aim to promote the objectives of the Convention on Biological Diversity in general, and the NBP in particular.

•

Specific actions to increase awareness could include:

- mobilise public opinion/inform/interest/educate on the benefits of biodiversi-ty protection and enhancement;

- organise a major event/conference/exhibition on Irish biodiversity (heritage); - fund a number of pilot projects demonstrating best practice in biodiversity.

5. Information

•

The existing situation regarding access to Ordnance Survey maps (cost, licensing and copyright) mitigates against access to spatial information. The Department should explore with Ordnance Survey the possibility of granting concession rates to those agencies (e.g. local authorities, ENFO, etc.) who need to provide information on biodiversity to the public.

•

Develop a web-based information system to deliver facts on biodiversity to the pub-lic and the popub-licy makers and which is easy to access and to understand. Most of the actions of the NBP depend on the availability of adequate information, such as baseline population data, information on the extent, location and rate of loss of cer-tain habitats, specific information on threats and constraints faced by sites, species and assemblages. Much of this data is still not being collected. Positive moves such as the formation of the National Biodiversity Research Platform and the proposed National Biological Records Centre are to be welcomed, but a systematic approach to the collection, storage and delivery biological data is still needed.

6. Monitoring and evaluation

(23)

B. Recommendations for the development of the next National

Biodiversity Plan

The current NBP covers the period – . Preparations for the development of the next plan should begin soon. In order to build upon the positive aspects of the cur-rent plan and avoid the problems which it has faced, the following recommendations are made for the development of the next NBP.

Consultation and Participation

•

The single most important issue in the current NBP is the lack of adequate consul-tation with a range of sectors in the development of the plan. It is essential that this is addressed in the development of the next plan, to ensure that participation by all stakeholders is facilitated. Consultation should begin before the formulation of the plan has started, with a wide-ranging information and education campaign, to ensure that the general public and interested groups are aware of the issues, and to facilitate their informed participation.

•

The formation of the Biodiversity Forum will be an important step in this process, and will help to ensure that the consultation and participation process is adequate. Consultation should take place within Government as well, as many of those involved in government departments and agencies outside the DoEHLG will have much to offer the process of development of the next NBP. Their involvement at an early stage will also help to ensure “buy-in” to the process of implementation of the plan.

Actions & Targets

•

The next NBP should contain specific, detailed actions, with targets laid out wher-ever possible, details given of which department or agency is responsible, and by when certain results must be achieved.

Priorities

•

It is difficult for any plan to predict what resources are likely to be made available for its implementation in the future. It is necessary then for actions to be priori-tised, to ensure that the most important actions are tackled first and to ensure that implementation of the actions is tailored in accordance with resources made avail-able by government.

Structure

(24)

Rele

vant Go

ve

rn

ment Depar

tments and State agencies to pr

epar e, with stak eholder s, their o wn Biodi ve rsity

Action Plans in line w

ith ag

reed

guidelines to ensur

e and pr

omote the conser

vation and sustainab

le use of biodi

ve rsity . All Depar tments; Rele vant Agencies Impr o ve

generation and management of infor

mation on biodi

ve

rsity within Go

ve

rn

ment Depar

tments and agencies.

DOEHLG Cr

eate biodi

ve

rsity units or posts within r

ele

vant Go

ve

rn

ment Depar

tments and State agencies whose functions will include the p

reparation of biodi

ve

rsity

action plans within the frame

w

ork of the National Biodi

ve rsity Plan. Wher e r ele vant

Draft Guidelines ha

ve

been pr

epar

ed for Local

Author ities, Go ve rn ment Depar tments and State Agencies b ut ha ve not y et issued. The Inter-Depar tmental Steer ing Gr

oup has an

impor

tant r

ole to pla

y in r

elation to this action.

No for

mal infor

mation management system y

et

exists. One biodi

ve

rsity unit with 2 staff estab

lished in the Depar tment of Ag ricultur e. Pr

ocess has commenced

b

ut disappointed at the _{lack of pr}

o

g

ress

Complexity of task not fully under

stood.

Needs to be under

tak

en

in tandem with

Action 1.

Disappointing that r

ele

vant

Go

ve

rn

ment Dept & State

Agencies ha

ve

not

estab

lished mor

e units &

posts. Link ed dir ectly to Action 1 Identify r ele vant Go ve rn ment Depts.

Issue Guidelines to Rele

vant

Go

ve

rn

ment Depts as soon as possib

le

.

Seminar for Go

ve

rn

ment

Depts.

Commence implementation of all rele

vant Plans in 2005.

DOEHLG to ar

range a random sample

of Go

ve

rn

ment Depts to estab

lish if an

y

system in place

.

De

vise a frame

w

ork for Go

ve

rn

ment

Depts on manag

ing infor mation on biodi ve rsity . All r ele vant Go ve rn ment Depts. to estab lish biodi ve

rsity posts & units b

y

the end of 2005. Appr

opr

iate training pr

o

vided to be

pr o vided b y DOEHLG .

ACTION AGENCY RESPONIBLE ST

A

TUS COM

MENT RECOMMENDA

TIONS

Integrating B

iodiversity into Sectors

Annex 1

–

Comments and Recommendations on Actions in the National Biodiversity Action Plan

(25)

Ensur

e all r

ele

vant plans and pr

o

g

rammes and all ne

w leg

islation,

and k

ey existing leg

islation, incor porates pr o visions r equir

ing the conser

vation of biolo g ical di ve rsity . All Depar tments Ensur e biodi ve rsity contin

ues to be fully addr

essed in the implementation of the operational pr

o

g

rammes of the National De

velop

ment Plan,

and in

the pr

eparation of futur

e National Plans (e

.g.

National De

velopment Plan,

National Sustainab

le De

velopment Strategy) ensur

e the

integ

ration and

enhancement of biodi

ve

rsity will be a k

ey consideration.

Depar

tment of

Finance as lead organisation

A

TUS COM

MENT RECOMMENDA

TIONS 4 5 DOEHLG cur rently pr o vides obser

vations on all

rele vant ne w leg islation, pr o g

rammes and plans in

relation to biodi

ve rsity conser vation. En vir onment Appraisals w er e car

ried out on all

Operational Pr

o

g

rammes in NDP

. Midter

m r

evie

w

has been completed in r

egar

d to NDP

.

Good pr

o

g

ress has been

made in r

egar

d to the

intr

oduction of natur

e

conser

vation leg

islation

b

ut little integ

ration of

biodi

ve

rsity considerations

into wider leg

islation.

The SEA Dir

ecti

ve

will

g

iv

e a frame

w

ork for the

assessment of futur

e plans and pr o g rammes. Ther e ar e concer ns that

appraisals do not addr

ess biodi ve rsity issues adequately .

•

Addr ess kno

wn conflicts in existing

leg

islation (e

.g.

drainage of w

etlands, in cer tain cir cumstances, being ex empted de

velopment under planning leg

islation).

•

Under tak e r evie

w of existing r

ele

vant

plans & pr

o

g

ramme to deter

mine the

extent to which pr

o

vision has been

made for the conser

vation of

biodi

ve

rsity and to identify and addr

ess

conflicts.

•

Methodolo

gy to be de

vised under the

SEA Dir

ecti

ve

could be used for this

pur

pose

.

Also impor

tant that this

Action is link ed to Action 3.

•

Ensur

e training is pr

o

vided to those

in

volv

ed in dra

wing up and

implementing biodi

ve

rsity action plans

for SEA Dir

ecti

ve

.

DOEHLG to pr

omote under

standing of

biodi

ve

rsity at operational pr

o g ramme le vel. Ensur

e the integ

ration and enhancement

of biodi

ve

rsity using existing and emerg

ing methodolo g ies (e .g. sustainability impact

assessment and her

(26)

Consider the de

velopment of financial instr

uments/incenti

ves to pr

omote the conser

vation of biodi

ve

rsity

.

DOEHLG & Dept. of Finance Estab

lish a Biodi

ve

rsity Unit within the Depar

tment of

Ar

ts,

Her

itage

, Gaeltacht and the Islands to

•

co-or

dinate and suppor

t the deli

ve

ry

of the National Biodi

ve

rsity Plan and the contin

uing r

esponse to the CBD;

•

suppor

t the pr

eparation of the sectoral biodi

ve

rsity plans;

and

•

assist the w

ork of the Biodi

ve rsity F o ru m. DOEHLG Contin

ue the r

ole of the Inter-Depar

tmental Biodi

ve

rsity Steer

ing Gr

oup and expand to o

ve

rsee ongoing exchange of infor

mation,

co-or

dination and

collaboration in r

espect of biodi

ve

rsity in the context of the implementation of the National Biodi

ve

rsity Plan and fur

therance

of the objecti

ves of the CBD

.

All Depts.

/

Agencies

& DOEHLG

A

TUS COM

MENT RECOMMENDA

TIONS

6 7 8

A small n

u

mber of instr

uments existing pr

ior to

the NBP such as Cor

ncrak

e Scheme and Lobster

tagg

ing scheme ha

ve

made a positi

ve

contr

ib

ution.

Reps 3 contains enhanced options for biodi

ve rsity conser vation. The Natur e W

oodland Scheme and the

Affor

estation Grant

Aid Pr

emium Scheme include

significant biodi ve rsity components. No pr o g ress. The w

ork of the Inter-Depar

tmental Committee

in Biodi

ve

rsity is ongoing.

T oo fe w positi ve de velopments –

disappointing range of effecti

ve

incenti

ves for the

conser

vation of

biodi

ve

rsity

. Financial

incenti ves under mining conser vation of biodi ve rsity ha ve outw eighed positi ve de velopments. The f ailur

e to estab

lish a

biodi

ve

rsity unit is a major

w

eakness in the deli

ve

ry

of the plan. The

W orking Gr oup is una w ar

e of the w

ork of the

inter depar tmental g roup . Intr

oduce wider range of financial

incenti

ves to pr

omote the conser

vation of

biodi

ve

rsity in the next financial y

ear

.

These could include;

•

T

ax incenti

ve

schemes for lando

wner s and fisher men.

•

Ensur

e the use of Modulation P

ay ment for biodi ve rsity .

•

T ax Cr edit/W ai

ver for Stamp Duty for

transfer of lands for natur

e conser

vation

•

En

vir

onment Fund -ensur

e specific

funding is pr

o

vided for biodi

ve

rsity

.

This unit should be estab

lished

immediately and adequately resour

ced.

Recommendation for this action can only be made after w

orking g

roup is br

iefed on

the w

ork of the Inter

(27)

Estab

lish a specific Biodi

ve rsity F o rum, r epr esentati ve

of all stak

eholder

s, to pr

o

vide a mechanism for consultation with,

and input fr om, all inter ested par ties.

DOEHLG Each Local

Author

ity to pr

epar

e a Local Biodi

ve

rsity Plan in consultation with r

ele vant stak eholder s. Each Local Author

ity to designate a contact officer for natural her

itage conser

vation matter

s in its ar

ea.

DOEHLG & all Local Author

ities Legislation T o r evie w contin

uously the adequacy of wildlife leg

islation in fur

ther

ing the objecti

ves of strateg

ies for biodi

ve

rsity

.

DOEHLG (National Parks &

W

ildlife)

Intr

oduce leg

islation to pr

o

vide a legal basis for National P

arks (and other her

itage pr oper ties) and, if necessar y, intr oduce

a National P

arks and Her

itage

Pr

oper

ties Bill.

W

ildlife)

A

TUS COM

MENT RECOMMENDA

TIONS

9 10 11 12 13

The Depar

tment has ag

reed that Comhar should

tak

e on the r

ole of the Biodi

ve

rsity F

o

rum.

Guidelines for local biodi

ve

rsity plans drafted b

ut not y et issued. 6 Local Author ities ha ve commenced the pr

eparation of Local Biodi

ve

rsity Plans and 25

local author ities ha ve appointed Her itage Officer s

It is a featur

e of the w

ork of the Biodi

ve

rsity and

P

olicy Unit to k

eep the adequacy of

W

ildlife

leg

islation under r

evie

w

. W

ork on the Re

vie

w of the

Habitats Regulations ongoing and measur

es to affor

d

impr

o

ved pr

otection to Natura 2000 sites ar

e being consider ed. No pr o g ress W e w

elcome the r

ole of

Comhar and the

W

orking

Gr

oup on Biodi

ve

rsity in

the r

evie

w of the

National Biodi

ve

rsity

Plan b

ut it ma

y ha ve been mor e appr opr iate

to engage with a wider range of stak

eholder

s.

In some cases Local Author

ities lack r

esour

ces

to car

ry

out this task.

Ther

e is a lack of data in

most counties for the preparation of Local Biodi

ve

rsity Plans

W

elcome the intention to

pr

oduce the leg

islation

which enhances the protection of Natura 2000 sites.

W

e r

ecommend that the F

o

rum be

estab

lished compr

ising a br

oad range of

repr esentati ves, which effecti vely r eflect the

scope of the plan. The

W

orking Gr

oup has de

vised a draft

frame

w

ork for such a F

o

rum (see annex 2).

Resour

ces should be made a

vailab

le for the

collection of data (county b

y

county

sur

ve

ys) and emplo

yment of Biodi

ve

rsity

Officer

s.

Implementation of the Biodi

ve

rsity

Action

Plan should for

m par

t of the County

De

velopment Plan Pr

ocess.

Incor

porate transpar

ency and pub

lic

par

ticipation in the r

evie

w pr

ocess.

Intr

oduce a ne

w Bill to put National P

arks

on a statutor

(28)

Re

vie

w the need for leg

islation to pr

o

vide additional conser

vation measur

es for a limited n

umber of species which ar

e of par

tic

ularly ser

ious conser

vation concer

n.

W ildlife) Protected Areas Re vie w pr eviously pr

oposed Natural Her

itage

Ar

eas and designate as appr

opr

iate under the

W

ildlife (Amendment)

Act,

2000.

W

ildlife)

Elaborate and pub

lish a frame

w

ork for the selection and designation of futur

e Natural Her

itage

Ar

eas,

including sites of geolo

g

ical and geomor

pholo

g

ical

impor

tance

, taking into account the vie

ws of inter

ested par

ties.

W

ildlife)

Complete identification and notification of SA

Cs and SP

As,

their submission to the Eur

opean Commission and for

mal designation.

W

ildlife)

A

TUS COM

MENT RECOMMENDA

TIONS

14 15 16 17

No r evie w under tak en. Resour ces ha ve been

utilised on r

esear ch-led ag ri-en vir onment policy adv

ances for species such as the cor

ncrak

e;

r

esear

ch

and site designation for species such as mar

sh

saxifrage;

and r

esear

ch and sur

ve

y on g

roups for

which ther

e is still little data,

such as br

yoph

ytes.

In the latter case this will culminate in a Red Data Book,

and the subsequent addition to and r

emo

val

of species in the Flora Pr

otection Or

der

.

Re

vie

w has not tak

en place

–

58 NHAs ha

ve been for mally designated. Not pub lished. 129 SP As designated Cur

rently 420 candidate SA

C sites transmitted

to Eur

opean Commission under the Habitats

Dir

ecti

ve

.

Open Season Or

der s ha ve been r evie w

ed for Basking

Sharks. Leg

islation is w

eak and

implementation is ineffecti

ve

.

Inter

ested par

ties should

include all stak

eholder

s.

Pr

oposals for changes to

boundar

ies should be done

in a open and transpar

ent

manner (and be equally accessib

le to NGOS and

scientists). Slo w pr ocess dr iv en b y EU enfor cement. Car ry out r evie

w (in conjunction with

commitment under action 12) with par

ticular emphasis on implementation and

pub lish r esults b y 2005 Re vie w pr

eviously designated ar

eas and sim ultaneously str engthen leg islati ve basis to pr o

vide for effecti

ve

pr

otection and

management and complete designation of NHAs;

mak

e this infor

mation mor

e accessib

le

.

Pub

lish the drafts on the inter

net,

when

av

ailab

le

, for comment and adoption

befor

e end of 2004.

Finish designation (par

ticularly SP

As) as a

matter of pr

ior

(29)

Pr

o

vide advice and pr

epar

e and issue Guidelines on the Conser

vation of SA

Cs,

SP

As,

NHAs and other pr

otected ar

eas to local auth

or

ities and other author

ities.

W

ildlife)

Contin

ue the pr

o

g

ramme of acquisition,

ag

reement to

, and designation of a r

epr

esentati

ve

ser

ies of Natur

e Reser

ves.

W

ildlife)

Pr

epar

e and implement site specific conser

vation plans and other plans (e

.g.

Commonage Frame

w

ork Plans) with par

ticular r

efer

en

ce to Natura 2000 sites,

NHAs,

Natur

e Reser

ves and National P

arks in consultation with affected lando

wner

s and the pub

lic

.

W

ildlife)

A

TUS COM

MENT RECOMMENDA

TIONS

18 19 20

Ad-hoc advice a

vailab

le fr

om Dept.

No for

mal

guidelines issued. 78 Natur

e Reser

ves ha

ve

been designated,

67 of

these ar

e in State Owner

ship and 11 in Pr

iv

ate

Owner

ship

.

Draft Management Plans for Killar

ne

y and

W

icklo

w

pub

lished.

3,997 Commonage Frame

w

ork Plans ha

ve

been

pr

epar

ed co

ve

ring 435,527 ha and 25 ar

e under

appeal.

K

ey action r

equir

ing

attention - pr

ob

lems

associated with v

ar

ious

steps in the pr

ocess,

e

.g.,

comm

unication,

ad-hoc

advice

.

Land acquisition not alw

ays necessar

y.

Inadequate pr

ocess of plan

pr

eparation despite

av

ailab

le funding,

par

ticular

issues of concer

n ar

e

•

No pub

lic

par

ticipation,

and

•

Dela

y in pub

lication

of draft plans

Pub

lished plans ar

e w

eak

and contain no practicab

le

actions.

Mechanism for designation of pr

iv

ately o

wned

natur

e r

eser

ves should be pub

lished.

Comm

unity par

tner

ship appr

oach should be

encouraged and pub

lic par

ticipation should be

facilitated. Pub

lish all existing draft management plans for

comment as soon as possib

le and pr

o

vide for

longer per

iod of consultation (3 months)

Implement plans and put in place ann

ual

repor

ting mechanism for all sites.

Change liaison committee system to include all r

ele

vant stak

eholder

s.

Futur

e plans should include practical actions

targets and r

evie

(30)

Contin

ue to pr

o

vide compensation for f

ar

m

er

s and other lando

wner

s for losses incur

red in manag

ing their lands in a manner which

is compatib

le with the

conser

v

ation r

equir

ements of designated sites.

W

ildlife)

Contin

ue or put in place fur

ther measur

es,

including appeals pr

ocedur

es,

to pr

o

vide for consultation with,

and the par

ticipatio

n of

, those affected b

y

existing and futur

e pr

otected ar

eas.

W

ildlife)

Estab

lish a compr

ehensi

ve

pr

o

g

ramme to monitor the condition of pr

otected ar

eas.

W

ildlife)

A

TUS COM

MENT RECOMMENDA

TIONS

21 22 23

D

AF operates REPS wher

eb

y a f

acility is in place

to compensate f

ar

mer

s in designated ar

eas.

€

4.5m paid in 2002 and 2003 in r

egar

d to sheep

destocking and a similar figur

e is lik

ely to be

expended in 2004. Le

vels of pa

yment ha

ve

been incr

eased for bo

g acquisition. Natur e Conser v ation Designation Appeals Boar d estab lished for merly kno

wn as the SA

C

Appeals

Advisor

y Boar

d.

175 appeals sent to Boar

d

121 appeals dealt with 54 appeals outstanding. (SA

C

Appeals Boar

d compr

ises an independent

chair per son, with tw o r epr esenting lando wner inter

ests and tw

o r epr esenting non-Go ve rnmental en vir onmental organizations.)

A Site Inspection Repor

ting (SIR) pr

o

g

ramme has

been set up to r

epor

t on impacts that ma

y potentially

affect (both positi

vely and negati

vely) the integ

rity

of the designated sites.

The ar

ea affected is

calculated and the impacts listed.

The r

epor

ting

cycle is e

ver

y thr

ee y

ear

s and is car

ried out b

y the National P arks and W ildlife Ser vice Conser v ation Ranger s. W

elcome the positi

ve

mo

ves on sheep destocking

b

ut disappointed that little _prog

ress has been made

on pr

ior

ity species

(geese & sheep). Fo

rmal Appeals Pr ocess w orks w ell ho w ev er the infor

mal appeals pr

ocess is

not satisf

actor

y.

Need to differ betw

een

(a)

compensation for damage caused b

y

wildlife (geese & s

w

ans)

(b)

compensation for changes in f

ar

m

practice to pr

otect wildlife & habitats

(cor

ncrak

e)

Separate compensations schemes need to be designed for (a) & (b). Fo

rmal appeals pr

ocess should allo

w NGOs

and other State

Agencies to appeal within

the for

mal appeals pr

Recommendations on the implementation and review of the National Biodiversity Plan

Recommendations on the

Implementation and Review of the

National Biodiversity Plan

C O M H A R

Contents

Members of the Biodiversity Working Group:

Mid-term review of the

National Biodiversity Plan

Executive Summary

Background

Status of implementation

Recommendations

Introduction

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Biological Diversity

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Observations on the Plan

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Main Issues in the Plan

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The Process

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Implementation

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Education/Awareness

Status of Implementation

of the Plan

General

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Summary review of actions listed under 15 sub-headings of the Plan

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