Submission on Draft Tree Management Policy 2021-2026

The South Dublin Conservation Society would like to make the following observations in relation to the consultation process concerning the new proposed Tree Management Policy for the South Dublin County administrative area. We hope that South Dublin County Council will take on board the various observations raised and in doing so incorporate these into the final management plan arising from the consultation process.

1. Our Society welcomes the ‘Living with Trees’, South Dublin County Council’s Tree Management Policy for the period 2021 to 2026 and the continued commitment by South Dublin County Council in the provision and maintenance of publicly owned tree stock. However, we note that this policy document reflects general operational matters, such as tree pruning, tree planting, etc., but lacks forward vision when it comes to goals, objectives, and specific actions for the defined period. There is no specific mission statement relating to trees into the future outlined. This policy document lacks the vision to be a strategy document which informs and educates the public about the importance of trees, from both a carbon sequestering and biodiversity focus, nor does it provide guidance to each citizen of South Dublin County when it comes to the planting, maintaining, and preserving the County’s tree stock. It is our Society’s belief that South Dublin County Council should consider revising this policy document and in doing so turning into a focussed strategy document or some form of action plan with real and tangible goals and objectives.
2. It is important that the senior management of South Dublin County Council provide the necessary personnel and financial resources to assist the various measures being outlined in the new proposed tree management policy document. The appointment of a ‘Tree/Arboricultural Officer’ would be a step in the right direction in assisting South Dublin County Council in adhering to international, EU and national legalisation and policy frameworks. A Tree/Arboricultural Officer “speaks for the trees” and is a position that collaborates between residents, community groups, developers, and elected representatives in assisting and deepening engagement between the local authority and all its shareholders when it comes to tree/woodland management.
3. There are very few trees in the South Dublin County administrative area that are legally protected with a TPO designation. The public should be requested, through an awareness campaign by the Council, to submit their favourite tree, or groups of trees, and their locations for consideration and eventual inclusion on a TPO database by South Dublin County Council for legal protection purposes.
4. South Dublin County Council should consider and promote the concept of ‘pocket forests’ to enhance tree canopy in an urban setting. The Council should also consider and support local communities who wish to establish community tree nurseries/orchards with a focus on native tree species. One ideal location is Friarstown, near to the where the Council allotments are currently situated, and which could provide the basis for a publicly funded and supported community tree nursery. It is important to create a sense of ownership amongst the public and all other relevant stakeholders when it comes to trees and tree plantings. South Dublin County Council should have an objective in any eventual policy document to provide support for the planting of trees on private property/land with the view to encourage public/private collective action in the increasing of tree canopy cover across the South Dublin County administrative area. Householders should be encouraged to assist in the planting of appropriate (species/size) trees in their own front and rear gardens.
5. Hedgerow management should also be a key focus within any eventual policy document. Hedgerows play an important ecological role and need to be managed in a sensitive way as linear woodlands. Rewilding should be very much considered in the policy document as an appropriate approach to generate additional tree canopy cover in public open spaces. It is a low cost/high reward measure with the potential to increase the number of trees while addressing the biodiversity needs of the County.
6. South Dublin County Council need to identify and acquire parcels of land across its administrative area to be developed for urban forest projects. Such urban forests could play an important recreational role as the trees mature in the long term but in the short term would provide a role in carbon sequestration, biodiversity habitats while offsetting air and noise pollution arising from the road network across the County. While several Council owned public parks are very limited in the expansion of further tree canopy cover, due to sport recreational needs, having additional parcels of land as urban forested areas would very much compliment and support the existing local and regional network of parks across the Council’s administrative area.
7. The retention of Rathcoole Woodlands should be a key priority of the Council and that it be given immediate protection through a TPO designation process. These woodlands are a great example of rewilding in action and are important recreational amenity for the citizens of Saggart and Rathcoole.
8. Public open spaces or designation spaces in existing parkland locations should be utilised for both the promotion of ‘pocket forests’ and community tree nurseries/orchards.
9. South Dublin County Council should encourage the planting of trees on open spaces by working closely with community organisations, residents’ associations’, school bodies, etc. The Council should proactively approach such organisations offering practical and financial help for such planting, including ‘pocket forests’ and community tree nurseries/orchards. It is important that South Dublin County Council develop some form of a process or policy to encourage and support community based initiatives in the planting of trees and how the community can become stewards of the existing trees for future generations to admire and appreciate.
10. South Dublin County Council needs to carry out a survey of all existing tree cover, both public and private, across its administrative area to assess the scale, density and variety/species of trees growing. It should be a priority that all areas of tree canopy cover deemed as woodland and over 2.5 hectares in size should be mapped and included in the map appendices of the County Development Plan. Hedgerows should be counted as linear woodlands. Parcels of land under tree cover should be given legal protection and be preserved under the same County Development Plan process.
11. South Dublin County Council should consider planting tree species for their longevity and heritage value incorporating Irish native broadleaf species at the centre of its tree planting programme.
12. South Dublin County Council should consider planting large canopy trees to achieve the maximum benefit that trees provide. Obviously planting the right tree in the right location should be at the forefront of such plantings. These large trees would create new skyline features and offer the maximum impact when mature from a biodiversity and carbon sequestration perspective.
13. South Dublin County Council should consider drawing up a guidance document to address the issue of damage to trees because of using salt (sodium chloride) on paved surfaces and alongside road surfaces resulting from its winter maintenance programme. Potential damage may occur when a high concentration of salt is present in the surface water runoff entering a nearby tree-rooting environment. It is a known fact that damage also occurs when tree branches are exposed to melted salt water blown into the air by vehicle traffic. Indirect damage may occur when physical and chemical soil properties are adversely affected by the salt. The presence of sodium can lead to the disintegration of the soil particles and the production of fines which enter and clog soil pores. This reduces aeration and promotes soil compaction. Salt also alters the osmotic potential of the soil solution. The tree therefore must use more energy to absorb water from the soil. South Dublin County Council should consider carrying out a study to assess the health status of roadside vegetation across its administrative area and whether the impact of using salt is adversely impacting of the health of roadside trees, resulting in such trees dying/decaying, and become a liability when brought down by winds/rains during stormy conditions onto road surfaces.
14. South Dublin County Council receives requests from time to time from members of the public to have trees removed due to perceived nuisance created by trees in an urban setting. Often leaf litter is the issue at hand and the reason that trees are being sought to be removed. This is not a sufficient reason for the removal of any tree in an urban setting. As it is existing Council policy that, as far as practicably possible, acceptable arboricultural pruning work is carried out to mitigate the loss of views, shade, and leaf litter experienced by adjoining property owners, provided that the health and value of the tree is not compromised. The financial cost of this arboricultural pruning work, if originally requested by a member of the public and carried out by the Council, should be borne by the requester. These financial costs should include stump and tree debris removal. Such an approach taken by South Dublin County Council would deter members of the public making frivolous requests for the removal of urban trees just for the sake of it. South Dublin County Council should consider establishing a tree ‘reserve fund’ with monies received for tree losses and/or damage to publicly owned trees to be used for the procurement and planting of replacement trees.
15. South Dublin County Council should establish ‘Tree By-laws’ to ensure that all publicly own trees are adequately protected from unnecessary destruction, loss or damage caused by any person, and include measures to address compensation and/or replacement. These ‘Tree By-Laws’ should accompany and support existing Council ‘Park By-Laws’.
16. South Dublin County Council should provide designated facilities for members of the public where the public can dispose of leaf and waste vegetation matter in a safe and controlled manner. Currently the Civic Waste Facility at Ballymount is the only designated location in the County where the public can bring such material under certain vehicle criteria. A lot of this waste material is taken away by private waste contractors, landscapers, etc., but a lot is dumped on publicly owned open spaces, parkland and alongside road verges. It is a wasted resource which could be utilised in a more cost and biological effective way.
17. Tree sculpture should be explored, where appropriate, by South Dublin County Council to engage the public and allow trees to continue to contribute as public amenity features after they have reached the end of their safe useful life span. While examples of tree sculptures can be seen in many of South Dublin’s parkland settings, there is potential to expand the potential of tree sculpturing in urban settings such as roundabouts, meeting squares, etc.
18. From a planning perspective, South Dublin County Council should make it compulsory that all new planning developments within its administrative area incorporate widened grass verges to create more allocated space for tree plantings and allow trees to grow with proper root structures and be safely distanced from nearby properties where often new builds do not have sufficient allocated front garden area space.
19. It is a known fact that tree planting on floodplains upstream of urban areas can significantly reduce potential flood risk downstream. South Dublin County Council should investigate time and resources in such a measure and design a tree planting programme in cooperation with interested stakeholders, whether private or public, in rolling out a plan to tackle climate change and flooding risk potential.
20. The importance of trees as part of Sustainable Drainage Systems (SUDS) is becoming more widely accepted and there are numerous examples of projects both nationally and internationally where trees play a pivotal role in addressing and easing surface rain runoff and flooding risk while improving water quality, air quality, enhancement of the urban landscape and improving biodiversity. South Dublin County Council needs to address and reflect the potential of trees and SUDS in the eventual policy document that is drawn up.
21. There needs to be a policy and a publicly available recording system to ensure that the volume of stored carbon which is planted in the form of trees is always substantially greater than that which is felled or pruned. Otherwise, the tree management is actively contributing to climate change. We note that in the period 2015 - 2020 the number of trees planted was 6,014 and the number felled was 5,319 and stumps removed 2,604 (plus the number pruned was 13,705 some branches of which would be the same size as a new tree) but the new trees are usually 1.2 - 1.6cm in diameter and the felled trees can vary greatly and include many trees which are ten times or more the diameter of those planted. There are ways of minimising carbon loss, such as leaving trees and branches were felled to break down naturally over a long period of time, using suitable timber for construction, furniture making, woodturning, etc., but all these methods need to be specified, measured, and recorded for the quantities of carbon which is being stored or not. This then needs to be compared with the quantity of stored carbon being planted in new trees at the same time, say each year. It is not good enough at this stage of our climate crisis to say that the new trees will catch up with the felled trees in 10 - 15 years’ time. We now don't have that time to wait, we must be increasing carbon storage by a significant amount each year to prevent the climate crisis going beyond the irreversible tipping point. Essentially this means that if a 30cm tree is being felled and the timber is not being used in a way that prevents carbon loss, then 15 x 2cm trees (as a rough illustration) would need to be planted purely to replace the lost carbon and 20 or more would need to be planted if a significant contribution to increasing carbon storage is to be made and to allow for some trees failing.