The following is a lettter of complaint sent to the Irish Forest Service on 12th February 2017 sent by the South Galway Flood Relief Committee . The PDF can be found here:
A subsequent meeting was arrange with Minister Doyle that will be outlined in detail shortly.
South Galway over the past 30 years has suffered a number of severe flooding events that have brought many communities into severe crisis. The area of South Galway has unique hydrological characteristics in that waters draining from the Slieve Aughty Mountains must travel several times underground on the journey to the sea. These underground channels are fixed capacity so any changes to natural hydrology can promote severe flooding.
Irish Forestry guidelines for Forest management, which recommends during deforestation and site preparation getting water off the mountain as rapidly as possible and in the maximum direction of the slope is causing a change in mountain hydrology. This is also being reflected by local knowledge of water coming off the mountain much quicker than ever before.
South Galway with its unique geology and drainage has many Special Areas of Conservation (SACs) and Specially Protected Areas (SPAs) that are protected by the EU Habitats directive. There are also Water Framework Directives and EU Flood Directives which aim to ensure that Water quality and quantity is managed and controlled through River Basin Management.
It is our understanding that there are significant planning application gaps, such as Environmental Impact Assessments mandatory for forestry practice, incomplete for the Slieve Aughty Mountain plantation process as current operations on this site change the hydrology dynamic and causes uncontrollable flooding within the river basin. We believe that EIAs that have been completed over the number of years have neglected to consider the impact on the downstream catchment areas that include some 21 SACs and this runs contrary to EU and Irish National legalisation.
We therefore demand that all forestry practice that affects the hydrology dynamic of the Slieve Aughty catchment area ceases until proper hydrological studies have been done, mitigation measures have been put in place and there is full monitoring of this via more comprehensive EIAs (or other)
South Galway Profile
From a South Galway perspective, the Slieve Aughty Mountains are the source of 3 primary rivers that flow westwards toward the sea at Kinvara. These are the Ownshree, Boleyneendorish and the Owendalulleegh rivers as shown in the diagram.
The most unique feature of this landscape is that the rock changes from sandstone to limestone and many of the rivers flow underground (highlighted in dotted green here) . Many of these areas have Turloughs (Most are SACs) that can swell in normal winters. The following diagram describes the profile of the Owenshree River to the sea – which may go underground 6 times during its course to the sea.
There is one simple fact for the underground river channels – They have a limited capacity for water drainage. Some swallow holes (where water sinks) in the Grannagh are only 1 ft square and this can only sink at a certain rate. Water flow rates also depend on Turlough levels as water pressures rises and drops across the underground network.
This makes the whole South Galway area extremely sensitive to change in hydrological dynamics (Hydromorphological changes) of the Slieve Aughty Mountains.
There are many potential impacts:
- Increased rate of water of water coming off the mountains will causing flash flooding in areas around the immediate vicinity such as Castledaly, BlackRock, Skehana, Ballylee, Castletown and Beagh. The swallow-holes simply cannot manage large peak flows efficiently
- Any overall increase in volume of water descending the mountain due to changes in water storage capability in the Slieve Aughty Mountains –
Also, the impact of effects of climate change (e.g. increased rainfall) may be exacerbated by Hydromorphological changes from forestry best practice.
While these impacts are felt keenly by the local communities being subject to severe flooding, the impacts will also threaten the Conservation Objectives of a large number of SACs which are protected under the EU ‘Habitats’ directive.
Water Directive Framework/Irish Forestry Code of Best Practice
The Irish ‘Water Framework Directive, Western River Basin District, Programme of Measures and Standards For Forest and Water’ gives an overview of potential pressures on water from forests and forest activities together with the pathways and possible receptors involved. It highlights that forests may give rise to negative pressure on aquatic ecosystems but that proper forestry management can deliver programmes of measures with positive benefits. Section 4.7 introduces potential pressures from Hydromorphological Change. It states that;
Where forests are established in the catchment area of water abstractions or water dependent habitats and species potential impacts on the water resource may occur both with reduced flow levels and reduced water table and also through washout with increased and more rapid flood peak height.
It indicates that there may be hydrological changes due to site preparation, clear-felling. In particular to clear-felling it states that there can be substantial increases in hydraulic flow (e.g. 15%) which can give rise to can give rise to “stream surge resulting in physical (hydro-morphological) impacts in receiving streams leading to bank erosion and stream widening. The pressure potential may be more pronounced for older forest stands which are clear-felled due to the absence of buffer zones and drainage networks extending into the aquatic zone.”
Another area of concern is restocking (replanting) of felled sites, which is a legal requirement under Irish Forestry act. This is described as:
“Restocking generally requires some initial site preparation. This may involve windrowing of brash, upgrading of former drainage systems to comply with current guidelines and appropriate cultivation of the sites where necessary. … Scrap mounding between windrows is sometimes practised to provide a planting medium. Restocking is carried out in accordance with the principles set out in the Forest Service suite of Guidelines, the Code of Best Forest Practice and the Forestry Schemes Manual.
In the Code of Best Forest Practice – Ireland, Forest Service 2000, Section 5.7, under ‘Site Preparation’ it states
The objective of forest drainage is to prevent the soil water rising into and saturating the root zone and waterlogging the soil. By maintaining the water table below the root zone, drainage promotes deep rooting, improves tree anchorage and strengthens the soil. It may also prevent the build-up of soil pore water pressure, which can occur during windy conditions, resulting in hydraulic fracture of the soil and wind-throw. To be successful, forest drainage must remove surplus water rapidly and must be designed against the cause of saturation and waterlogging.
It describes the different methods of drainage e.g. mounding, tunnelling with the most common method being ‘mounding’ and it states: “Drains should run in the direction of maximum slope and feed into collector drains spaced approximately 80 m apart.”
It is therefore very clear that there will be a significant hydromorphological change (this is even highlighted within the forestry code of best practice guidelines i.e. “remove surplus water rapidly”).
The impact that this has on an area with unique karst geology with multiple underground rivers has never been researched or studied and therefore it is impossible to state that there is no impact of these hydromorphological changes.
South Galway Situation
South Galway over the past 30 years has suffered a number of severe flooding events that have brought many communities into severe crisis. In winter 2015, over 35 homes were flooded, over 25 farm buildings flooded, over 200 farms were flooded and over 22 roads closed for a combined total of 1733 days. The area has been having substantial flooding since 1990 with 5-6 several flood events. Over 15 homes have been flooded and permanently closed since 1990 and that number continues to increase.
There is no doubt that there is a serious increase in how fast and how much water is coming off the mountain during heavy rainfall. There is measureable correlation between heavy rainfall and an immediate increase in river water levels.
- Within 4 hours, some of the Slieve Aughty Rivers can rise over 1 metre.
- With 36 hours, Blackrock Turlough can rise over 10 metres and extend over 2km.
This rapid run-off has an immediate impact on the area around Castledaly, Grannagh, Peterswell, Skehana, Blackrock, Ballylee, Deerpark, Rinrush, Castletown and then continues into the Gort lowlands of Kiltartan, Coole, Tieneevin, Caherglassaun, Killomoran, Cahermore and Kinvara.
Snapshot of flooding (Courtesy of Sean Brady Aerial Photography)
The flooding of these communities also has a direct impact on the many SACs, habitats and protected species e.g. In the picture here we see Coole Lake, within an SAC overflowing into a farmyard in Tierneevin and becoming polluted – this situation breaks the Coole-Garryland SAC’s Conservation Objective and this is just one SAC of 21 in the area.
The South Galway Flood Relief Committee, on behalf of the many communities between Slieve Aughty and the Sea, demand the following clarifications and actions from the Forest Service.
- Provide clarification and statistics relating to past, present and future forestry operations on Slieve Aughty:
- What is the history of planting in Slieve Aughty? Year by year/by catchment
- What is the history of felling in Slieve Aughty? Year by year/by catchment
- Can you provide yearly graph of % forest age in 5 year increments (0-5,5-10,…)
- What the expected lifetime of a forest – planting to felling? Has this changed in the past 30 years?
Forestry Code of Best Practice
- When did the code of best practice last get updated? When is it due for an update?
- How many inspections/audits have been carried on forestry operations to see if licensees adhere to code of best practice (year by year)
- Has this code ever been enforced?
- What is predominant form of drainage when preparing or replanting?
- What is the recommended depth of a drain (when mounding?)
Environment Impact Assessments
- Have any mandatory assessment been carried out regarding the impact of hydromorphological changes of the Slieve Aughty mountains due to forestry management (planting, felling, replanting) on the downstream hydrological dynamics of a karst area
- If so, have any assessments highlighted the impact of the 21 SACs that are in the Slieve Aughty catchment?
- Please provide us with the last 10 EIAs on Slieve Aughty
- Have the NPWS ever provided recommendations/advice on an EIA relating to forestry operations on Slieve Aughty? Has Forest service heeded recommendations?
- Have the NPWS ever queried an EIA on impact of hydromorphological changes on Slieve Aughty?
Water Framework Directive
- Have Forest Service implemented WFD Management action FM7 – “Comprehensive review of all Codes of Practice, Guidance Documents and Forestry Schemes Manual to ensure cross referencing, reflection of developments in legislation, policy, environmental objectives and environmental findings as appropriate?
- In relation to Slieve Aughty forests, have Forest Service implemented Management action WFD FM 8– “Establish a scheduled review process with predetermined time intervals (annually, biannually etc) to maintain this suite of documents in an up to date state.”
- In relation to Slieve Aughty forests, have Forest Service implemented Measures WFD FH 1– “Audit existing drainage network before harvesting (part of existing application)”
- In relation to Slieve Aughty forests, have Forest Service implemented Measures WFD FH 3– “Redesign of drainage network on sites for restocking)” to minimise contribution to peak flow and increase time period to peak flow. Reduce risk of washout.?
- In relation to Slieve Aughty forests, have Forest Service implemented Measures WFD FH 4 – “Research control of flow regime changes from forest cover for sensitive receptors to limit impact on water balance which could affect habitats, species or uses associated with protected areas?
- What are the objectives of the Irish Forest Service in terms of clarification on impacts of Hydromorphological changes on the Slieve Aughty due to forestry management?
- What are the objectives of the Irish Forest Service in terms of clarification on mitigation measures for Hydromorphological changes on the Slieve Aughty?
- What are the objectives of the Irish Forest Service in terms of updating guidelines on Forestry best practice?
- What are the objectives of the Irish Forest Service in terms of monitoring and enforcement of these guidelines?
- What are the timeframes for availability and implementation of these objectives?
The SGFRC support forestry operations in Ireland. We support Irish Forestry code of best practice for forestry as a resource. However, if Irish Forest Service code of best practice involves ‘getting water off the mountains as rapidly as possible’ then either the Irish Forest Service invest in solutions that will transport this water safely to the sea or Irish Forest Service incorporates mitigation measure to attenuate water.
Mitigation measures have been proven and seen very good success in areas like Pickering, UK which planned and successfully implemented a ‘Slow-the-flow’ project:
It is our understanding that mandatory guidelines on both EIAs and WFD will be fully implemented by Irish Forest Services and licensees. However, if any aspect of relevant EIAs, or the WFD have not been dealt with sufficiently by the Forest Service or licensees, then we demand that forestry practices that have a hydromorphological impact cease until proper hydrological studies, informed Environmental Impact Assessments and WFD measures can be completed and fully implemented.
The SGFRC would like to meet up with the Irish Forest Service as soon as possible to discuss these topics.
Chair, South Galway Flood Relief Committee, 086-8097223