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Action 24. Cessation of Turf Cutting in Raised Bogs - IPCC Submission to the Inter-departmental Cessation of Turf Cutting Working Group

IPCC's Submission on the Cessation of Turf Cutting Working Scheme

The Secretary
The Cessation of Turf Cutting Working Group
National Parks and Wildlife Service
7 Ely Place
Dublin 2

1st July 2009


Re: IPCC's Submission on the Cessation of Turf Cutting Scheme

Dear Sir/Madam,

The Irish Peatland Conservation Council (IPCC) welcome this opportunity to make our submission to the Cessation of Turf Cutting Working Group as advertised on the Irish Environmental Network website. IPCC have been very proactive in seeking a solution to the issue of turf cutting on SACs and NHAs since our foundation but in particular since April 2008. We have issued numerous letters to the Minister for the Environment and minutes of meetings along the way (see Appendix I). In addition we have undertaken a public awareness campaign by issuing press releases to the media and uploading information to our website at www.ipcc.ie and our bi-annual magazine Peatland News (see Appendix II).

IPCC are extremely disappointed that the Cessation of Turf Cutting Scheme was not implemented in February 2009, considering the loss of active raised bog habitat due directly to the continuation of private turf cutting on raised bog sites designated for conservation as proven by NPWS research published in the Fernandez 2005 report. The Cessation of Turf Cutting Scheme must be implemented before the 2010 turf cutting season begins if the government wish to retain any credibility in relation to their commitments to nature conservation in Ireland. The political will and finance needs to be in place if the implementation of the cessation of turf cutting is to be successful and if Ireland is to meet its EU obligation to protect endangered peatlands.

IPCC have met with Bord na Móna, IFA and NPWS specifically to discuss the Cessation of Turf Cutting Scheme and to find positive solutions to the obstacles to implementing the scheme. Outlined below are some elements that IPCC suggest might be part of a solution to implementing the Cessation of Turf Cutting Scheme. These suggestions are fully documented in Ireland's Peatland Conservation Plan 2020 - Halting the loss of peatland biodiversity (2009), published by IPCC.

Green Energy not Turf
The Green Party Ministers for Energy and for the Environment should provide grants to people in the areas affected by the cessation of turf cutting to convert their home heating systems to sustainable energy systems, such as biomass/biofuel pellets, solar power and/or thermal heating, thereby reducing the demand for turf. This could also be linked in with the energy saving schemes promoted by the government such as the home insulation grants scheme.

Relocation of Turf Cutters
Relocation of turf cutters to nearby non-designated sites is a viable option for the turbary rights holders and was not properly implemented by NPWS in the past. Turbary rights holders should be offered an attractive plot on a non-designated site with an incentive package for relocation.

A System of Arbitration
A system of arbitration should be put in place to find an acceptable price for the life supply of the turf in a plot to the turbary rights holder. This should be based on the volume of turf in the plot and not on its acreage.

A Substantial Front-loaded Package for the Cessation of Turf Cutting
Turf cutting, as a cheap form of fuel, is an important element to many households. The 2003 financial compensation package is out of date. A substantial funding package for the cessation of turf cutting should be put in place following the results of the arbitration process (see above). Because the majority of turf plot holdings of active turbary rights holders are small an attractive front-loaded financial package needs to be provided.

Compulsory Purchase
Where voluntary compliance with the Cessation of Turf Cutting Scheme does not happen compulsory purchase of the land holdings within the SAC and NHA should be carried out by NPWS or another relevant body within the time scale of the Cessation of Turf Cutting Scheme.

Cessation Agreement Body
An independent body should be contracted to arrange cessation agreements with turbary rights owners.

Land Registry
The land registry must accommodate people who have sold turbary rights to NPWS but do not have up-to-date titles of the land. This will allow people with out of date land titles to participate in the cessation scheme and get paid more rapidly.

Turf Cutting Methods
Within SACs and NHAs where turf cutting is active, it is imperative that banned machines such as "sausage machines" are not used. For example, IPCC have photographic evidence of sausage peat contractors cutting turf in the Connemara Bog Complex SAC in 2009.

Licensing
Under the 1999 Farm Agreement all turf cutters on affected sites who chose to continue cutting turf were expected to do so by acquiring a permit from the NPWS, which specified the way that turf was to be cut annually until 2008. Permit's were to be given for turf cutting on raised bog SACs and NHAs where it is deemed that turf cutting was not having a significant impact on the conservation status of the site. However, this control system was never implemented throughout the country. All existing turf cutters should be licensed, just like any other mining activity. The licensing process should insure that the volume of turf cut should be solely for the use of a single household.

Turbary in the Wider Countryside
The practice of turbary in the wider countryside should be regulated through the planning system.

Enforcement
Annual fly overs by Enforcement Officers should take place on all sites where turf cutting has ceased to ensure no illegal turf cutting activity occurs.

Fines
A legal structure needs to be put in place with severe penalties for those who willfully continue turf cutting on SACs and NHAs. Penalties could be linked to Government subsidies such as the Single Farm Payment should the individual be a farmer or to tax benefits should they be a PAYE worker.

Turf Cutting Festivals
Turf cutting festivals (the former turf cutting competitions) should be re-instigated in the affected counties so that traditions that people hold in high regard are retained and celebrated.

Peatland Cultural Education
Communities should be invited to participate in cultural programmes focusing on bogs, organised by various groups such as NPWS at National Parks and designated sites, by Bord na Móna at the Lough Boora Parklands, during Heritage Week and International Bog Day and at the Lough Ree Wetlands Park when it is established.

Small Scale Restoration
Turf cutters from affected SAC and NHA sites and local communities should be trained so that they can participate in the restoration of sites affected by turf cutting. Small scale restoration will allow turf cutters to continue to work with the peatlands their ancestors worked on. This would be in the new role of conservation volunteers and they would work on site restoration projects and drain blocking on the SACs and NHAs affected by the Cessation of Turf Cutting Scheme.

Large Scale Restoration
Large scale restoration measures on a landscape scale are required within the hydrological units of the raised bog SACs and NHAs. These restoration works need to be adequately funded by the government and other relevant authorities and could provide a potential source of employment within rural areas most affected by the cessation of turf cutting. The aim of the Cessation of Turf Cutting Scheme ultimately is to gain control of the hydrological unit of the SAC and NHA sites. For the scheme to be successful it must be followed by large scale restoration.

Signage
Erect SAC and NHA signs on all sites affected by the Cessation of Turf Cutting Scheme. This needs to include relevant information about the scheme, the acceptable methods of extracting turf and contact details for NPWS.

Consultation Board
A consultation board and consultation process needs to be put in place between conservation agencies and all affected landowners in relation to the cessation of turf cutting on designated raised bogs.

Publicity
The Cessation of Turf Cutting Working Group, NPWS and other relevant agencies and departments must actively publicise the facts about the cessation of turf cutting. Turf cutters do not see how their activities are causing the destruction of raised bogs. It needs to be communicated why Irish raised bogs are so important on a national, European and global scale and why it is so urgent that all turf cutting ceases on designated sites. Most people don't know which bogs in their locality, if any, are being affected by the cessation of turf cutting. Also many people are under the perception that the cessation of turf cutting applies to all bogs. The Local NPWS Wildlife Rangers, Heritage Officers, NGOs and other relevant parties should publicise through local radio, press and television which raised bogs in their area are affected by the cessation of turf cutting and the time scale for each site. This is so important that ideally it should be contracted out to a professional agency.

Sources of Funding
Possible sources of funding for the compensation measures, the Consultation Board and publicity might include the plastic bag tax, the Lottery, a cessation of turf cutting licensing fee for all active turf cutters on SACs and NHAs and co-funding with a special EU grant package. The EU were generous in the past when NPWS were purchasing intact raised bogs from Bord na Móna.

Sale of "Certified" Turf from Non-designated Sites
All turf cutting contractors should register with and be vetted by local authorities or another appropriate body so that the turf they supply to householders can be proven not to come from an SAC or NHA.

Research
Undertake research into the extent and effects of turf cutting on blanket bogs to determine blanket bog habitats sensitive to turf cutting.

I hope this submission will be helpful to you in successfully implementing the Cessation of Turf Cutting Scheme.

Please acknowledge receipt of this submission.

Yours sincerely

Sarah Malone

_____________________________
Sarah Malone B.A. Her. Stud.
Conservation Officer, IPCC.

ENC:
Appendix I: Letters written by IPCC to the Minister of the Environment regarding the Cessation of Turf Cutting Scheme and minutes from meetings IPCC have had with NPWS and the IFA regarding the Cessation of Turf Cutting Scheme.

Appendix II: Press releases and publicity issued by IPCC regarding the Cessation of Turf Cutting Scheme.

cc: Jim Ryan, National Parks and Wildlife Service, 7 Ely Place, Dublin 2
cc: Dr Michael O'Brien, European Commission, Environment DG XI, BU-9 3-184, B-1049 Brussels, Belgium
cc: Gerry Gunning, Irish Farmer's Association, Irish Farm Centre, Bluebell, Dublin 12
cc: Minister John Gormley, Minister for Environment, Heritage and Local Government, Department of Environment, Heritage and Local Government, Custom House, Dublin 1
cc: Gerry Ryan, Director of Land and Property, Bord na Móna, Main Street, Newbridge, Co. Kildare

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