A 50-page submission to the European Commission by the Irish Peatland Conservation Council (IPCC) argues that large tracts of midlands and western bogs should be declared Special Areas of Conservation (SAC), thousands of acres more than the Government suggests.
The council submission, entitled Irish Raised Bogs, Special Areas of Conservation, has been given to the EU Commissioner for Environment and Nuclear Safety, Mrs Ritt Bjerregaard.
The report points out that the Government has not yet submitted a formal list of SACs to the commission although under the EU Habitats Directive the deadline for submission of a full list was June 1985.
As a result of the delay, the Government faces legal action by the EU, and the council has expressed concern that, while the Government delays, many raised bogs are being damaged by development.
The council has put forward arguments to the EU that a further 4,993 hectares of raised bog be designated active raised bog and 9,683 hectares as "degraded" SACs, adding 113 new sites to the list of 35 the Government has suggested should be SACs.
The additional sites proposed by the IPCC for designation occur in three cluster concentrations and in a belt transect running across the country from Kildare to Galway.
The areas were identified as the Upper Shannon/Lough Ree cluster, Lower Shannon/Little Brosna cluster, the Bog of Allen Transect from Kildare to Galway and the Mayo/Roscommon cluster.
Three of the concentrations of raised bogs occur in areas that have been subject to intensive industrial peat extraction, while in the fourth, Mayo/Roscommon, there have been centuries of peat cutting by hand.
A copy of the submission has also been sent to the Minister for Arts, Heritage, Gaeltacht and the Islands, Ms de Valera.
Meanwhile, a submission to Government from the Midland Regional Authority deals with the subject of the development of the bogs in the midlands for the production of electricity in peat generating stations.
An extensive plan has been put forward by Bord na Mona for the reuse of cutaway bog at Mountlucas, Tullamore, where it envisages the development of a new urban/industrial park of 2,400 acres.
The submission also said that 4,000 acres of cutaway bog near Rochfort Bridge has considerable potential as an industrial zone, a residential town or an international airport.
Such a development could cost between £50 million and £100 million, it says.