Summary
Ireland’s Afforestation Scheme offers generous grants to landowners to plant trees. However, to date, uptake of the scheme by landowners is well below national targets. One potential barrier to uptake is the administrative friction within the scheme, which can make landowners’ experiences of policy implementation more onerous and result in lower participation. The purpose of this policy brief is to catalogue the costs of administrative frictions in Ireland’s Afforestation Scheme and provide recommendations to reduce those costs. Through an audit of Ireland’s afforestation scheme, a journey map was developed to illustrate the typical steps undertaken by a landowner engaging with the scheme. The level and type of administrative friction in each step in this journey was then evaluated and confirmed via qualitative analysis of interviews with relevant stakeholders. The audit reveals that unpredictable timelines in the application process serve as a significant barrier to afforestation efforts. In addition, the high level of uncertainty surrounding grant application outcomes complicates the decision-making process for landowners. To address these challenges, this brief recommends streamlining information requirements, establishing clear timelines, and enhancing communication to reduce friction and facilitate afforestation. This is the first audit conducted to identify administrative barriers to climate action, demonstrating the potential of this methodology to assess other schemes within national climate action plans.
Context
Since 2007, Ireland has launched three afforestation schemes to reach a national target of 18% tree cover by 2050, providing annual premiums to landowners who plant forests[i]. As of 2024, 11.6% of national land cover consisted of forestry, and Ireland is far short of its afforestation target of 8,000 ha per annum with just 1,651 ha of trees planted in 2023[ii]. While many barriers have been identified which impede delivery of afforestation schemes, such as concerns about profitability[iii]; farming values and traditions; irreversibility; and succession implications[iv], the onerous experiences a landowner may face when applying for a scheme, known as “administrative burdens”, have received limited attention despite the likelihood that such burdens or frictions lead to lower policy adoption rates and participation in programmes[v].
Administrative frictions can make it harder to find the relevant information (leading to search costs); make it more difficult to assess the benefits and costs of a decision (evaluation costs); create frustration, stress, embarrassment, and other negative emotions (psychological costs); and create waiting times and other delays (time costs)[vi]. Interest in administrative friction is growing worldwide, as governments and organisations strive to understand how friction reduction initiatives can improve processes[vii]. “Sludge Audits”, such as the one undertaken for this brief, can help to catalogue the costs of administrative frictions, or “sludge”, and determine how to reduce those frictions[viii].
Methodology
We conducted a three phase sludge audit of administrative frictions. In phase one, a behavioural journey map was developed to illustrate the typical steps a landowner undertakes as part of Ireland’s Afforestation Scheme. In the second phase, an evaluation of the extent of administrative frictions in each step of the journey was conducted, obtaining a fine-grained assessment of administrative frictions in the process following the assessment criteria developed by the New South Wales Behavioural Insights Unit[ix]. The third phase provided a holistic assessment of the process obtained through qualitative analysis. All three phases were informed by semi-structured interviews with 12 stakeholders, following a semi-systematic interview guide[x].
Analysis
The research identified six stages in a landowner’s journey through the afforestation scheme, each consisting of between two to nine steps, which were given a “sludge score” to quantify the extent of administrative frictions. Overall, twelve steps in the application process demonstrated minimal administrative friction, receiving a “sludge score” of 1 or less (very easy). For example, search costs did not emerge as a major barrier in the audit, contrasting with findings from previous studies on afforestation schemes in Ireland and elsewhere[xi]. This audit suggests that Ireland’s current Afforestation Scheme has been sufficiently advertised and communicated, minimising search costs as a barrier.
In contrast, eight steps within the journey contained actions or costs that made it harder for landowners to obtain grants and plant trees through the scheme, earning a sludge score between 3 to 5 (very difficult). Figure 1 presents stages two (Figure 1a. technical approval) and three (Figure 1b. ecological assessments) in the journey map, which involves steps with relatively high sludge scores. Stages one (preparation), four (financial approval), five (planting) and six (payment) of the journey map all involved steps with sludge scores of 3 or less and are thus not presented here. A full assessment is presented in the working paper available here: https://osf.io/mf37p/.
The primary administrative obstacle identified in this audit occurs when the Department of Agriculture, Food and the Marine issues a “Further Information Required” letter during technical approval checks. This letter requests applicants to submit detailed information about their property within an eight-week period, and additional surveys, remedial actions, and environmental assessments may be required. The timing and specific demands of this letter are hard to predict, introducing uncertainty that may lead to stress and anxiety for landowners. Partly due to the possibility of further requests down the line, many applicants withdraw their applications after receiving this letter.
The audit also highlighted the unpredictability of timelines in the application process as a significant barrier to successful afforestation efforts. Unpredictability and inconsistent decision-making across the regional forestry inspectorate were emphasised by stakeholders as primary reasons for abandoned applications and foresters opting not to take on afforestation applications.
Figure 1: Fine-grained sludge assessment of stage 2 (a. Technical approval) and stage 3 (b. Ecological assessments) from 1 (=very easy) to 5 (= very difficult) of Ireland’s Afforestation Scheme as of April 2024. For a complete assessment of all stages, see the working paper available at: https://osf.io/mf37p/
Policy Recommendations
Re-evaluate the process around “Further Information Required” letters
The requirement for landowners to provide information as requested in a “Further Information Required” letter is an important part of the planning process that helps mitigate against potential negative environmental impacts of an afforestation application. However, this audit identified that the letter and associated information requirements are the main barrier to uptake of the scheme, causing time costs, evaluation costs, and psychological costs to landowners and foresters. Thus, a re-evaluation of the process around the “Further Information Required” letter is recommended, such as providing earlier, more proactive communication regarding the kind of information that may be required and loosening the eight week deadline in which landowners have to provide this information, particularly in cases where the additional information is onerous and may require external assistance.
Establish clear timelines for landowners
It becomes more challenging for a landowner to decide whether to plant trees through the Afforestation Scheme when the estimated timelines for various approval decisions, payment, and overall programme completion are unknown. Agreeing and communicating an appropriate time for an application to be considered by a particular section in the Department would reduce the perceived burden of the applicants. It would also be helpful to communicate with the applicants when the application moves from one section within the Department to another to reassure the applicants of progress. Following this audit, the Department agreed to a Farmers’ Charter of Rights in July 2024, establishing a maximum of 6-9 month licence decision target, which may in part address this recommendation. However, the new Forestry Programme also provides additional environmental requirements, including for new surveys (e.g. Habitat Maps, High Nature Value surveys, peat surveys, and threatened species considerations, depending on the site), all of which could create additional administrative barriers. Further investigation into barriers at the point of submission of the applications might thus be warranted.
Improve communication between the Department and registered foresters
Registered foresters cannot keep landowners informed about the licence application status when the registered foresters struggle to stay informed themselves. Improved communication, for example through the existing Integrated Forestry Information System (iFORIS iNET), could include specific details for delayed applications, explaining why applications may remain in certain departments. The iFORIS iNET system should also email notifications to the forester when the application moves internally, depending on referrals to other departments.
Address administrative frictions in other licencing programmes
While not directly linked to the grant application process through Ireland’s Afforestation Scheme, the audit identified frictions within other forestry-related licencing requirements in Ireland, such as those for planting, felling, and harvesting. Each application process could lead to financial burdens, time costs, implementation costs, and psychological impacts. Conducting further audits to examine these licencing processes could reveal opportunities for improvement, ultimately making forest management in Ireland more accessible and encouraging greater landowner participation in afforestation efforts.
Conclusion
This brief presents one of the first “sludge” audits aimed at identifying administrative frictions as a barrier to achieving climate action targets. Given that almost no process is frictionless, any audit will uncover some friction and this audit is no exception. While the focus of this policy brief is on identifying administrative frictions, it is important to highlight that many steps in the application process are designed efficiently with minimal friction (e.g. learning about the scheme and receiving financial approval once technical and ecological assessments are complete). However, the approach taken in this study can, and should, be applied to other climate and afforestation schemes to identify process improvements that ease participation and enhance the likelihood of meeting climate goals.
Further information: For further information on the audit analysis, see the working paper Lentz, Augustenborg & Lades (2024) available here https://osf.io/mf37p/.
Acknowledgements:
This work is part of the research project assessing “Administrative Burdens as Barriers to Implementation of Ireland’s Climate Action Plan” (ABICAP), (EPA project 2022-CE-1149), funded through the EPA Research Programme 2021-2030.The EPA Research Programme is a Government of Ireland initiative funded by the Department of the Environment, Climate and Communications. It is administered by the Environmental Protection Agency, which has the statutory function of co-ordinating and promoting environmental research. The authors would like to acknowledge the members of the project steering committee, namely Desmond O’Mahoney; Michael O’Dwyer; Michelle Corrigan; Hannah Julieane; Sandy McPhee; Shane Timmons; and Martin Bækgaard, coordinated by Anne Mason. We are also grateful to the New South Wales Government Behavioural Insights Unit, who provided access to their Sludge Finder Tool; Dr Lucie Martin at Ireland’s Economic and Social Research Institute; and staff within the Department of Agriculture, Food and Marine for valuable feedback. Ethics approval for this research was confirmed by UCD’s Office of Research Ethics on September 7, 2023 (Reference: LS-LR-23-208-Lades)
Disclaimer:
Although every effort has been made to ensure the accuracy of the material contained in this publication, complete accuracy cannot be guaranteed. The Environmental Protection Agency, the authors and the steering committee members do not accept any responsibility whatsoever for loss or damage occasioned, or claimed to have been occasioned, in part or in full, as a consequence of any person acting, or refraining from acting, as a result of a matter contained in this publication. All or part of this publication may be reproduced without further permission, provided the source is acknowledged. This report is based on research carried out from January 2023 to June 2024. More recent data may have become available since the research was completed. The EPA Research Programme addresses the need for research in Ireland to inform policymakers and other stakeholders on a range of questions in relation to environmental protection. This policy brief is intended as a contribution to the necessary debate on the protection of the environment.
[i] Government of Ireland (2023) Ireland’s Forestry Strategy 2023-2030.
Department of Agriculture, Food and the Marine, Forestry Division (2024) Afforestation Scheme 2023-2027.
[ii] Department of Agriculture, Food and the Marine (2024) Annual Report 2023.
[iii] Irwin, R. et al. (2023) Increasing tree cover on Irish dairy and dry stock farms: The main attitudes, influential bodies and barriers that affect agroforestry uptake. Environmental Science & Policy, 146:76–89.
[iv] Lawrence, A. & N. Dandy (2014) Private landowners’ approaches to planting and managing forests in the UK: What’s the evidence? Land Use Policy, 36:351–360.
[v] Bearson, D. F., & C.R. Sunstein (2023) Take up. Behavioural Public Policy, 1–16.
[vi] Herd, P., & D.P. Moynihan (2019) Administrative burden: Policymaking by other means (1 edition). Russell Sage Foundation.
Moynihan, D. et al. (2015. Administrative burden: Learning, psychological, and compliance costs in citizen-state interactions. Journal of Public Administration Research and Theory, 25(1):43–69.
Shahab, S., & L.K. Lades (2024) Sludge and transaction costs. Behavioural Public Policy, 8(2):327-348.
[vii] OECD (2024) Fixing frictions: ‘Sludge audits’ around the world.
OIRA (2024) Tackling the Time Tax: Making Important Government Benefits and Programs Easier to Access.
[viii] Sunstein, C. R. (2022). Sludge audits. Behavioural Public Policy, 6(4), 654–673.
[ix] NSW Behavioural Insights Unit (2024) The NSW Government Sludge Audit Method Guide.
[x] Lades, L, & L. Martin (2024) Interview Guide: Identifying “Sludge” in Climate Action. Hosted on the Open Science Framework.
[xi] Duesberg, S. et al. (2014) Assessing policy tools for encouraging farm afforestation in Ireland. Land Use Policy, 38:194–203.
Lienhoop, N. & R. Brouwer (2015) Agri-environmental policy valuation: Farmers’ contract design preferences for afforestation schemes. Land Use Policy, 42:568–577.
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