The draft of Ireland’s plant to enhance biodiversity loss is currently open for public submissions but the critical question is: can such a document halt the dramatic decline in species and habitats in Ireland?
Ireland is one of the few countries in the world at the stage of developing its fourth national biodiversity action plan (NBAP), Elizabeth Mrema, the executive secretary of the United Nations Convention on Biological Diversity (biodiversity) told delegates at the 2022 national biodiversity conference in Dublin Castle in June this year.
It will set the biodiversity agenda from 2023-2027 and will be Ireland’s main mechanism for engaging with national and international policy developments such as the new Global Biodiversity Framework, the EU Biodiversity Strategy and its forthcoming Nature Restoration Law.
It is open for public consultation until November 9th. During this time members of the public or community groups can submit suggestions to what Minister for Heritage Malcolm Noonan wants to be “a living document”.
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Too many open-ended actions with legislative loopholes and lack of powers of enforcement were strong criticisms of previous national biodiversity action plans
Environmental non-governmental organisations and Government agencies have already given some feedback on the draft document. But in spite of vastly increased funding to bodies such as the National Parks & Wildlife Service and funds for new biodiversity officers in local authorities, many environmental campaigners remain disillusioned by the prospect of yet another NBAP, when previous ones lacked the teeth to halt the catastrophic decline in species and habitats in the past few decades.
Almost half of the EU protected habitats and species in Ireland are in decline and over 60 per cent of Ireland’s common birds are on either red or amber lists. One third of wild bee species are becoming extinct and the number of pristine rivers has dropped from 500 to 20 over the past 40 years. Noonan has himself admitted “we are living in an age of extinction”.
So, how can yet another corporate-led initiative to reframe Ireland’s attempt to value, conserve, restore and sustainably manage nature really make a difference?
How can a written document ensure the enforcement of national and international legislation to protect habitats, species, landscapes and the marine environment that previous documents have failed to do?
And what value really is there in shifting unachieved actions from previous national biodiversity action plans to the new one? Too many open-ended actions with legislative loopholes and lack of powers of enforcement were strong criticisms of previous national biodiversity action plans so how will this new one be any different?
There are broad general restoration targets but there are no listings of species of conservation concern and a commitment to restoring habitats and populations or who will do that
Yvonne Buckley, professor of zoology at Trinity College Dublin says the biggest problem is lack of accountability if actions and objectives of the NBAP are not fulfilled. “You can review and evaluate actions that aren’t implemented but it’s unclear what failure means. There are consequences [of biodiversity loss] for every member of society who gets so much benefit from ecosystem services in terms of their health, cultural and recreational values but the NBAP would have to be on a statutory footing so that there are consequences [for those who flout the law].”
Oonagh Duggan is head of policy and advocacy at Birdwatch Ireland and a member of the Independent expert group, the National Biodiversity Forum, which highlighted the failures of the current biodiversity action plan. She agrees the new NBAP needs to underpinned by law but argues that what the plan contains is just as critical.
“Some actions in the plan are already legally binding, for example the ones relating to the [new] Common Agriculture Policy regulation under the remit of the Department of Agriculture,” she says.
Duggan contends the Irish state is the biggest transgressor of EU Environmental Law in Ireland. “The question is who is holding these state bodies to account in this country? The new NBAP needs to have mechanisms which allow the National Parks & Wildlife Service to compel Government departments to adhere to legislation. And NPWS needs to defend habitats and species in Government policy and planning. Even our own Irish Wildlife Act is in breach of EU law,” she says.
Fintan Kelly of the Irish Environmental Network is concerned greater commitment to enforcement with the Wildlife Crimes Unit at the NPWS will be weakened if larger Government departments still dictate actions. “Even with the NPWs being better resourced, the hard decisions won’t be made if other more senior departments don’t come on board,” says Kelly. By way of example, he cites the six special protection areas (SPAs) for hen harriers which should legally and scientifically have less forestry. “Yet, more than half of these SPAs are planted with commercial forestry,” he says.
Shane McGuinness, research fellow at the School of Architecture, Planning and Environmental Policy at University College Dublin says some targets in the draft NBAP — such as the Land Use Review completion date of 2023 — aren’t realistic.
Climate change and biodiversity are interlinked and we need to set more immediate goals to monitor and enhance biodiversity
“Also, agriculture has enabled itself to be pushed down the road for monitoring of habitats on farms to 2027 which isn’t good given the impact and size of the sector. By 2050, we should be aiming to have biodiversity protected and respected everywhere without having to draw a red line on a map which leads to as much push back as support,” he says.
Although Duggan feels there is more political and societal will behind the protection of nature now, she is concerned the language used in the draft NBAP is not strong enough or specific enough.
“There are broad general restoration targets but there are no listings of species of conservation concern and a commitment to restoring habitats and populations or who will do that. The objectives in the plan are good but the actions to get there need significant strengthening.
“For example one of the actions of the Department of Agriculture to address the root causes of biodiversity loss focuses on monitoring agricultural schemes but what’s the good of monitoring something if an adverse effect has already happened especially for a sector that we know is the most significant driver of biodiversity loss. This monitoring is already legally binding under the CAP Strategic Plan anyway,” she says.
Anabel O’Hora is the youth adviser for the Children’s and Young People’s Assembly on biodiversity loss which will met in Glencree, Co Wicklow in early October and will also convene in Killarney National Park from October 21st-23rd. She is pleased with the “whole of Government, whole of society” approach within the plan. “We haven’t seen that in any action plan before and this will mean that local communities will know what’s happening and be able to take individual actions to protect biodiversity. There is a lack of education on what to do at the moment,” she believes.
O’Hora is also happy with the objective to embed biodiversity into climate action. “Climate change and biodiversity are interlinked and we need to set more immediate goals to monitor and enhance biodiversity,” says O’Hora. The Young People’s Assembly on Biodiversity intends to make a submission to the draft NBAP before the deadline. The Citizens’ Assembly on Biodiversity Loss will also make a submission before the final version of the plan is published in early 2023.
Summary of six objectives of draft national biodiversity action plan 2023-2027
1) To adopt a whole of Government and whole of society approach to biodiversity. This will require all Government departments, State agencies, community groups, farmers, fishers, foresters, business people, educators and young people to be involved.
2) To strengthen protection of existing designated areas and species and enhance their protection and restoration as well as spreading the protection of biodiversity and ecosystem services to the wider countryside and marine environments. To this end, a national restoration plan to meet EU biodiversity strategy 2030 nature restoration targets is proposed.
3) To promote the value of nature for wellbeing, enterprise and employment.
4) To embed biodiversity into climate action with use of nature-based solutions where appropriate for climate change adaptation and mitigation measures.
5) To provide more research on biodiversity and ecosystems and to monitor habitats and species and their conservation needs.
6) To strengthen Ireland’s contribution to international biodiversity initiatives.
There have been more than 60 submissions already made on the draft NBAP. The public can submit your views by filling in an online survey, by email or by post. See gov.ie/biodiversityplan for details
