Specific Details
The Threat Response Plan for the Hen Harrier 2024 – 2028
Intended results
To emphasise the importance of acknowledging the role farmers play in safeguarding the Hen Harrier through their dedication to nurturing suitable habitats on their lands. Farmers are central figures in Hen Harrier conservation endeavours and must be placed at the forefront of all decision-making processes.
That genuine and inclusive engagement with all stakeholders is essential for achieving true conservation success, fostering commitment and collaboration across the board. Furthermore, effective conservation strategies must be pragmatic, informed, and balanced.
To Outline a number of issues for consideration
Action 8-8a
There are currently 6 Special Protection Areas (SPA's) for Hen Harrier breeding habitat. Two further SPAs have been designated for the wintering population. There is a fear amongst farmers that examination of areas outside of the SPA's which Hen Harriers habitat will result in more designations.
While farmers acknowledge the key role that designation plays in the protection of species and habitat loss, the endeavour and efforts of farm families must be recognised too, who manage and upkeep these important areas. Considerable effort is required to innovate, streamline and improve existing notification processes, which currently are not fit-for purpose, creating significant stress and frustration for farm families seeking to improve and advance on-farm operations.
Ultimately, the economic viability and value of farms on designated lands must be protected.
Proper engagement and appropriate support must be given to farmers whose income and property values are diminished because of designations. The economic interests and security of farmers on designated land throughout the country are currently being undermined due to the severe restrictions imposed on them, compounded by less than adequate administrative and governance systems. This is simply unacceptable. Farmers cannot be left in limbo and should not have to suffer economic disadvantage.
To oppose any further designations of farm land and/or further restrictions on existing designated lands, until current designations have been adequately compensated for and existing system inefficiencies adressed. Proactive engagement must take place with impacted landowners with right of appeal provided.
Action 9
Alongside the efforts within the agricultural sector, it is crucial to acknowledge and address external factors that pose significant threats to the survival of the Hen Harrier.
The risk posed by predators, notably pine martens and ravens, presents a significant concern. For example, a recent study in Scotland1 found that all the hen harrier nest failures were due to natural factors or predation by foxes and other birds. Despite being categorised as a 'medium' level threat in the plan, there is a notable absence of direct action outlined to effectively address this issue.
It is crucial to recognize the potential impact of these predators on the Hen Harrier population and its habitat. Implementing targeted strategies aimed at mitigating the predation risk is essential for the successful conservation of the species. Collaborative efforts, informed by scientific research and stakeholder engagement, are needed to develop proactive measures that strike a balance between predator management and ecosystem preservation within the framework of the plan.
In addition, since the onset of the Covid-19 pandemic in 2020, there has been a remarkable surge in interest and demand for outdoor recreational activities. While the benefits of such activities are widely acknowledged, their burgeoning popularity poses a risk to the Hen Harrier and other ground nesting birds, especially during critical breeding periods when species are most vulnerable
Additionally, the presence of dogs exacerbates this threat, necessitating stringent measures to safeguard wildlife habitats. The unequivocal policy of 'No Dogs Allowed' must be upheld on farmland without exception. Although recreational activity is currently categorised as a 'low threat' in this plan, it is imperative to recognise the escalating trend and implement enhanced precautions to minimise disturbance to wildlife and their habitats.
To highlight that addressing threats from predators and increased recreational activity requires a targeted and comprehensive approach within the plan.
Action 12
Changes to land eligibility requirements under the Common Agricultural Policy (CAP) 2023-2027 have taken positive steps toward incentivising the protection of habitats crucial for Hen Harrier survival. These adjustments signal a proactive approach to conservation within agricultural policy. However, there are lingering concerns regarding forthcoming changes, such as the introduction of Good Agricultural & Environmental Conditions (GAEC) 2 under the Common Agricultural Policy (CAP).
While the full implications of Good Agricultural & Environmental Conditions (GAEC) 2 remain to be seen, there is apprehension that it may introduce additional challenges or unintended consequences for habitat preservation efforts.
It is imperative that the /department of Agriculture, Food, and the Marine (DAFM) ensure not only that maximum flexibilities apply at a local level in designing Good Agricultural & Environmental Conditions (GAEC) 2 standards to minimise its impact on the operations and economic viability of farms, but also that proper engagement with farm organisations and impacted farmers is facilitated prior to its implementation.
To propose that a full socio-economic assessment of Good Agricultural & Environmental Conditions (GAEC) 2 restrictions required prior to any implementation of measures which should be applied on a voluntarily basis only.
Action 13
Emphasis on collaboration and maintaining continuous communication with farmers is essential. The effectiveness of this collaborative model has been demonstrated successfully in previous schemes, particularly when combined with both advisory and financial support. Proper engagement stands as a cornerstone for the success of the plan, underlining the critical importance of ensuring farmers are actively involved and informed throughout the process.
To emphasise that maintaining open and transparent communication with farmers throughout every stage of the plan's implementation is paramount to its success.
Action 14-15
Farmer participation in agri-environmental schemes not only fosters environmental stewardship but also supports farm incomes. With the introduction of the new Common Agricultural Policy (CAP) for 2023-2027, there's a heightened focus on climate and environmental objectives. Under the previous Common Agricultural Policy (CAP), European Innovation Projects (EIPs) played a pivotal role, with notable initiatives like the Hen Harrier and Pearl Mussel Projects among the 55 projects established.
The Hen Harrier Project, spanning six Special Protection Areas (SPAs) crucial for the species' breeding habitat, engaged approximately 1,600 farmers with a total budget of €25 million. The project ran from 2017-2022.
During its tenure, the Hen Harrier Project provided additional compensation to farmers, supplementing their Green Low Carbon Agri-Environment Scheme (GLAS) payments for implementing targeted actions and measures aimed at safeguarding the hen harrier habitat.
With the conclusion of the scheme, farmers have transitioned into the Agri Climate Rural Environmental Scheme (ACRES). Launched in 2023, this flagship agri-environmental initiative, with a substantial budget of €1.5 billion, is structured around two key approaches
1. Co-operation Project option available to farmers in defined high priority geographical areas. This is broken into results-based and general measures, and additional non-productive investments and landscape actions, which will be designed by local project teams for your land-type and region. Maximum payment is €10,500.
2. General option available nationally (outside of the Co-operation Area), which offers a range of measures (both results-based and general). Average payments are expected to be in the region of €5,000 per annum over the five-year period of the scheme with the potential to reach a maximum of €7,300.
The majority of Hen Harrier areas are encompassed within the Co-Operation approach under the Agri-Climate Rural Environmental Scheme (ACRES). While also results-based, actions within the Agri-Climate Rural Environmental Scheme (ACRES) Co-Operation are broader and more habitat-focused, with less specificity towards any individual species. Consequently, farmers are tasked with maintaining a higher standard of farming practices for relatively less compensation compared to previous schemes.
This has raised concerns that without additional incentives, there's a risk of habitat degradation and a potential regression to its original conditions. A separate dedicated payment programme should be established for the Hen Harrier, providing financial support to farmers for work carried out on their land to protect the Hen Harrier, as well as compensatory payments for being constrained from conducting conventional agricultural activity.
Such payments should remain in place for such time as the designation remains. Removal of payment automatically incurs the removal of designation also
To emphasise that initiatives like Agri-Climate Rural Environmental Scheme (ACRES) require time to mature and demonstrate tangible outcomes. Assessing the full impact of such actions within a mere five-year timeframe is insufficient. Therefore, it's imperative to allow these initiatives adequate time to evolve and yield meaningful results.
Moreover, ensuring the continuity of support and incentives for farmers is essential to sustain the achieved standards and prevent habitat deterioration in the long term.
The reintroduction of the National Parks & Wildlife Services (NPWS) Farm Plan Scheme has been a positive development, however, greater funding is needed to increase awareness and expand the number of farm plans on the scheme, with increased payment rates to reflect the additional costs and burden on farmers whose land is designated.
An Enhanced Farm Plan Scheme must be funded through the National Exchequer and all farmers with designations who apply for the scheme must be catered for. In addition, increased resources should be allocated to ensure the smooth and efficient delivery of payments to farmers on time.
To propose a separate stand-alone Early Intervention Plan (EIP) be established that is locally led, and designed by farmers for farmers. This scheme must not be confined to budgetary/Common Agricultural Policy (CAP) cycles. Instead, it needs time to be able to develop to create tangible results.
Action 18-21; 26
A holistic perspective must be undertaken with regard the efficacy or otherwise of the Hen Harrier Programme. The input and endeavour of participating farmers cannot be questioned. Consideration also should be afforded to broader policy change; weather events and other measures which were not included within the scope of the Hen Harrier Programme, for example predation, which could have impacted derived outcomes in either a positive/negative manner.
With regard Action 26 specifically, careful consideration needs to be afforded to definitions provided for ‘intensification of farming'.
While increased surveys and research on the Hen Harrier is to be acknowledged, given likely sample size, careful consideration needs to be afforded to the representation or otherwise of inferences or recommendations derived. As noted multiple times above, regular and meaningful engagement with landowners is essential throughout.
Forestry
In order to start to address the conservation conflict between hen harrier conservation and forestry there needs to be substantive change in policy; (i) there needs to be acceptance that forest management practices including afforestation are wholly compatible with hen harrier conservation, (ii) the restrictions on planting and forest management activity within Special Protection Area's (SPAs) and non-designated important areas need to be relaxed,
(iii) if a farmer is financially impacted as a result of restrictions to protect the hen harrier they must be compensated for the conservation service they are providing and (iv) there needs to be greater stakeholder engagement and communication with farmers that are within Special Protection Area's (SPAs) to rebuild trust.
Opportunities for new planting need to be identified.
The ban imposed on afforestation within the six Hen Harrier Special Protection Area's (SPAs) when the Forest Management Protocol for Hen Harrier Special Protection Area's (SPAs) was withdrawn in 2010 was implemented without any notification or consultation.
This decision sterilised and devalued farmer's land and created an unnecessarily an adversarial situation and damaged the perception of conservation among farmers. Farmers are no longer willing the bear the brunt of the States obligation to conserve and protect the hen harrier.
The ban on planting within the Special Protection Area's (SPA's) and non-designated breeding areas needs to be removed. The existing appropriate assessment screening process is sufficient to determine whether the afforestation plan will adversely affect the integrity of the land.
Opportunities for new afforestation within the Special Protected Area's (SPA) and non-designated breeding areas should be considered as part of the long-term management strategy. No forestry thresholds should apply.
Action 30 - 42
According to the National Forest Inventory 2022 the private forest estate accounts for over 50% of the national forest estate. As a key stakeholder that will be directly impacted by the long-term management strategy for the hen harrier Special Protection Area's (SPA's). It is vital that farmers are identified as key stakeholders so they have an opportunity to input in the development of long-term management strategy. This will be vital to get buy in for the recommended management strategy.
Farmers within Special Protection Area's (SPA's) network and non-designated important breeding areas will be impacted by management actions, felling license assessments or future amendments proposed under Action 32, 34 and 35, and need to be consulted and involved in the decision-making process.
The financial implication of any proposed measures including setbacks, premature felling, delayed replanting or targeted removal, need to be fully recovered by farmers through a Hen Harrier Forest Conservation Scheme.
To propose that a Hen Harrier Forestry Implementation Group is established to ensure that forest owners, not just Coillte are consulted in relation to all conservation measures to improve breeding hen harrier habitats.
Action 36
The review of the management prescriptions for felling including the introduction of setbacks and open spaces for biodiversity must consider the additional management costs, the loss of productive area and the financial implications to the forest owner.
To propose that a Hen Harrier Forest Conservation Scheme is developed to support forest owners to manage their forest for the protection and conservation of hen harriers.
Action 38
The programme for targeted forest removal could have significant implications for forest owners that have made the decision to permanently convert their land to forestry. The programme to remove forest must be done in consultation and with the full agreement of a forest owner. Farmers must not be obligated to remove a forest.
To propose that the targeted forest removal only takes place at clear-fell stage in the private forest estate, in order for farmers to realise their return on investment and that conversion of forests back to agricultural land must be financially supported via the Hen Harrier Forest Conservation Scheme.
Action 40
There needs to be a full review of the appropriateness and practicality of some of the procedures including the use of red zones, restrictions on forest operations, slippage of restrictions beyond the breeding season etc. The restrictions are forcing forest operations to take place during the wrong season, which is having an impact on soils, water quality and increasing the risk of windthrow post thinning operations.
To minimise restrictions and costs to farmers, as well as improve the protection of hen harrier, an annual national survey is undertaken, rather than the current five-year national survey. This would deliver more accurate conservation information on the bird. Protection measures and agreed buffer zones could be applied to actual nest sites, thus affording protection precisely where it is required and allowing forest operations to proceed safely in other areas known to be absent of hen harriers.
To propose that national hen harrier annual surveys is undertaken to deliver more accurate conservation information to minimise disturbance by forest operations and reduce costs for forest owners.
Action 46 & 47
Farmers as custodians of their environment believe the current research over emphasizes the pressure of forests on hen harrier conservation. That the pressures can be managed at landscape level by creating a mosaic of forest ages to provide areas of preferred habitat for hen harriers i.e. pre-thicket forests.
That until conservation policy properly considers the many factors that impact upon hen harrier conservation in Ireland, including prey availability for adult birds to predation, as well as as well as the impact of adverse summer weather affects juvenile birds and nest productivity, the decline in breeding pairs will continue.
More research is needed to understand the impact of predation on nest success and viability. In Scotland, the Heads Up for Harriers partnership project found that the low survival rate for young birds was that all the nest failures were due to natural factors or predation by foxes and other birds.
To emphasise that the scope of the research proposed needs to be extended in order to get a complete picture of hen harriers' behavior and the factors impacting their survival in order to support farmers to better cater for nesting hen harriers.
Charlie McConalogue
Minister (Department of Agriculture, Food and the Marine)
Malcolm Noonan
Minister of State (Department of Housing, Local Government and Heritage)
Niall Ó'Donnchú
Assistant Secretary (Department of Housing, Local Government and Heritage)
Amii McKeever
Adviser to Minister (Department of Agriculture, Food and the Marine)
Hannah Hamilton
Special Adviser (Department of Housing, Local Government and Heritage)