For the attention of:
Oireachtas Joint Committee on Public Petitions
Topic: Integrated Invasive Species Policy Proposal
Result: Innovative approach to invasive species management which prohibits the sale of invasive species, prioritises their removal at the community level, and utilises their biomass as a solid fuel.
– Introduction –
Cherry Laurel is a pervasive, non-native plant that was introduced to Ireland in 1690. It is evergreen with toxic leaves and so is avoided by herbivory animals. It thrives in our rich woodland soils and subsequently dominates this habitat by casting other plants in permanent shadow.
This has decimated biodiversity in Ireland’s small and isolated woodlands: Cherry Laurel is considered by the NPWS to be one of the “greatest threats to our remaining native woodlands”.
Cherry Laurel, however, hasn’t been allocated as an invasive species on the Third Schedule of the Bird and Habitat Directive (2011): Ireland’s Register of Invasive Species. According to the National Biodiversity Data Centre, this is due to the lack of funding available for the ‘necessary’ risk assessment.
Subsequently, considerable funds are allocated to remove this invasive species every year whilst it is simultaneously being encouraged as an ornamental plant in garden centres. This inconsistency has created confusion as to the nature of Cherry Laurel; many people, including government departments, are unaware that this plant is an invasive species. It is therefore planted in estates and parks, the seeds infecting nearby parkland or woodland habitat.
The Gaelic Woodland Project has been communicating with multi-disciplinary stakeholders to explore an alternative, integrated approach to Invasive Species Management which we’d like to present to the Committee for serious consideration.
Our strategy is a paradigm shift to reimagine our relationship with Cherry Laurel so that we may turn this ecological crisis into an energy opportunity. We beseech the Oireachtas to be brave enough to work outside convention to remediate this perpetuating ecological crisis.
We present below a step-by-step process to enact the necessary change.
Step 1: Prohibit the Sale of Invasive Species:
- Include Cherry Laurel in the Third Schedule of invasive species in the Birds and Habitat Directive (2011). The National Biodiversity Data Centre conducted the risk assessments for the thirty-five non-native plants within this Schedule. According to the NBDC, funding was not available to conduct further assessments to include Cherry Laurel within the Schedule, they do, however, consider Cherry Laurel as an invasive species, and one of serious concern.
- We advise that Cherry Laurel be included in the Third Schedule by merit of consultation with expert judgement and that the ‘required’ risk assessment be conducted post factum whenever funding becomes available.
- Activate Regulation 50 in the Birds and Habitat Directive (2011):
“50. (1) Save in accordance with a licence granted under paragraph (7), and subject to Regulation 74, a person shall be guilty of an offence if he or she has in his or her possession for sale, or for the purposes of breeding, reproduction or propagation, or offers or exposes for sale, transportation, distribution, introduction or release—” of species within the Third Schedule.
The activation of Regulation 50 was postponed due to the (EU) 2015/1535 procedure, also known as TRIS, which aims to “prevent creating barriers in the internal market before they materialize”. Prohibiting the sale of these invasive species would impact the single market so a consultation period was granted between EU Council and the Member States.
Accordingly to the Bird and Habitat Directive: “74. (1) Regulation 50 shall come into effect on the date on which the Minister gives public notice of its coming into effect.” European Member States have had 11-years to communicate their position on our invasive species management policy and it is overdue that the Minister enacts this necessary regulation.
Step 2: Felling License Exception
Ireland’s Forestry Programme 2012-2020 acknowledges that “There is a growing recognition that existing controls are insufficient to respond to the ecological, economic and cultural threats posed by invasive alien species”.
The Native Woodland Conservation Scheme supports the clearance of invasive species such as laurel and rhododendron, however, this support requires a Native Woodland Plan by an NWS Participating Ecologist and Forester; Landowners must also acquire a Felling License.
The “existing controls are insufficient” because we limit our actions against invasive species. We want the Oireachtas Joint Committee to prioritise the removal of Cherry Laurel by granting a special exemption from felling licenses. The Forestry Service is already inundated with a backlog of felling applications; the inclusion of invasive species in felling licenses burdens an already strained system and inhibits removal.
We recommend that this exemption be granted during the winter months to limit Cherry Laurel seed dispersal and to protect adjacent pollinators during the Spring and Summer. Removing these hurdles will encourage community action against invasive species.
Step 3: Invasive Species as a Biofuel
Today around 20 to 25% of private households use turf or peat briquettes for home heating. Since the end of commercial peat cutting in 2020, Ireland has imported >42,800 tonnes of peat; we also import considerable firewood from Germany, Sweden, and China.
After consultation with the Irish Bioenergy Association, we believe that Cherry Laurel could be a viable alternative to solid fuel imports with its high calorific content. Due to extensive island-wide infestation, this biofuel can be sourced locally and used to mitigate the increasing costs of solid fuel during this Energy Crisis.
This will only be a temporary reprieve from increasing energy costs as, eventually, we will run out of Cherry Laurel to cut, but that is the goal.
The leaves must be removed and the woodcut, stacked and dried, very much like peat. However, unlike peat, by utilising this solid fuel we’re protecting habitat and restoring biodiversity. This market development requires consultation and authority that is outside the scope of our charity, which is run by volunteers. We implore the Oireachtas to facilitate the utilisation of Cherry Laurel as a biofuel.
We’re happy to facilitate engagement with stakeholders to achieve this outcome.
Hurdles and Solutions to Implementation: Compensation
“(10) The Minister may provide compensation where a person can establish that he or she suffered a financial loss as a consequence of being prevented by Regulation 50 from selling any of the items that were in his or her possession on the date on which public notice was given, and may reimburse vouched expenses incurred by a person in the disposal of such items in accordance with the requirements of a transitional licence or of a direction under paragraph (8).”
Garden Centres may request compensation for loss of earnings in prohibited stock. This hurdle mustn’t be seen as an excuse for inaction; the self-inflicted economic and environmental burden of selling, and removing, invasive species is absurd. We present a solution so that financial losses, and thus compensation, can be mitigated by stimulating new markets.
Cherry Laurel is primarily purchased for hedging. An awareness campaign must be initiated to inform the public that Cherry Laurel is a serious threat to our woodlands and shouldn’t be planted. Homeowners, in this knowledge, may subsequently decide to replace their laurel hedging with more traditional Irish hedging (hawthorn, blackthorn, holly etc), if that option is presented.
Although garden centres may lose sales on new laurel hedging, they could gain considerable business in REPLACEMENT hedging. This will alleviate the financial loss to Garden Centres and, if correctly cultivated, the profits in replacement hedging could surpass losses in Cherry Laurel sales.
– Conclusion –
The cumulation of these recommended steps creates a pathway to an improved policy that utilises the Waste Management Hierarchy and the principles of integrated environmental management planning to harness the synergies and provide a new solid fuel for rural Ireland whilst simultaneously tackling the greatest threat to our native woodlands.
The Gaelic Woodland Project is a registered charity; we’re experimenting with a non-mechanised methodology for community action against invasive species in October 2022. Our results will be published and sent to community groups around the country in 2023.
If the Oireachtas takes prompt action on this issue, then by next year, guided by our non-mechanised methodology, we can empower community groups and decentralise the fight against Cherry Laurel. Furthermore, we can slightly reduce our reliance on fuel imports and provide resources for new enterprises.
Adopting this approach could change the trajectory of this ecological crisis and provide temporary relief during this Energy Crisis. I implore you to support this action.
PgD Env.Protection. CAPM
Gaelic Woodland project- Founder
An Taisce- Climate Ambassador