The following has been submitted by the Irish Environmental and Social Stakeholders.
THE BEGINNINGS OF PLANTATION FORESTRY IN IRELAND
In the 1930s the now famous Irish plant collector Augustine Henry brought the Sitka Spruce to Ireland and over time it became the basis of a virtual 100% blanket monoculture in the Irish landscape – totally alien to the natural habitats of Oak, Ash, Rowan, Willow, etc. Being an alien species, plucked from its North American environment, planted in vast areas and susceptible to attack from the pine weevil, vast quantities of pesticides were used and are still used. Lindane, Permasect and Cypermethrin, all carcinogenic, persistent immune-damaging were used, and some are still used, seriously polluting water systems, and damaging fish spawning grounds.
In addition, as these trees were planted in the main in uplands areas huge amounts of fertilisers were also used, and which flowed into river systems over-nutrifying the water. The pesticides and fertilisers used have had a serious effect on all the ecosystems throughout the country.
FSC/IFCI IRELAND – THE BACKGROUND
The development of an FSC National Standard for Ireland is now in its tenth year. Curiously, the ‘first’ draft standard was never seen (when we have asked about this in the past, we have been offered the unacceptable excuse that this first draft was written ‘in house’). What was presented for public consultation in 1999 was a second draft written by an ex-employee of the state forestry company Coillte, which at the time was considering assessment for certification.
The ‘fourth’ draft that is now being presented is based on a third draft and will be considered as a final standard, which we believe is totally unacceptable. This draft forest standard has been created under the illusion of public participation and with the participation of An Taisce, Voice and Birdwatch Ireland, who were apparently invited participants to the process. None of their remits are primarily concerned with forestry, whereas, the Woodland League, CELT, Forest Friends, The Native Woodland Trust and Muintir na Coille are – but have not been involved in the development of the standard.
The creation of a National Forest standard is too important to be allowed to continue until the many questions surrounding our Forests have been resolved. The IEN, (The Irish Environmental Network), as the body which services National Environment groups in Ireland and which espouses the principles of biodiversity in every other sphere of its activities, should call for the suspension of the current FSC process with immediate effect.
The shambolic development of Ireland’s national FSC standard has been led by the Irish Forest Certifcation Initiative, which was set up, without adequate consultation, in 1999; trying to bury the IFCI’s miserable record, ‘FSC Ireland’ was recently established, but in reality it is merely the continuation of IFCI under new name. Did IFCI/FSC Ireland go through proper procedures to change the name?
Serious questions need to be addressed at this point, including the following:
- What has become of the IFCI company, which was set up and funded to produce a Forest standard for Ireland in 1999?
- Who mandated the present FSC Ireland to be formed and were the public notified and involved in its creation? As we understand it, FSC certification standard-making should involve all stakeholders in a transparent process, with adequate publicity etc, (for example, refer to the handbook by Hannah Scrase for FSC processes on the FSC website, ‘A beginners guide to FSC certification’).
- Who chose the participants for the three chambers and why are none of the forestry-related NGOs, specialising in this area involved – like Forest Friends (John Haughton), Muintir na Coille (Joe Gowran), Hedgelayers Association, the Native Woodland Trust, CELT and The Woodland League?
- Who is now funding the Irish Forest certification standard process? If it is the case that FSC is funding the Irish process then it is yet another blatant example of conflict of interest, which this process has been plagued by since its inception. If so, is the FSC now defending its reputation in Ireland by direct intervention in a process it will benefit from? Even if FSC is not funding the process they are allowing IFCI to use their logo, which represents a direct endorsement.
There have been and still are serious conflicts of interest within the IFCI/FSC Ireland processes. This involved a director changing his spots and becoming a consultant for the group, and individuals representing ‘GONGOS;, i.e. ‘Government Organised Non-Governmental Organisations’. It involved people purporting to represent NGOs who were clearly not So, and others supposedly representing groups which they did not have the capacity to do. Also previous employees of State bodies were clearly promoting their vested interests, continuing to promote the status quo in Irish Forestry, with no serious efforts to engage in any kind of genuine objective or fair analysis, empathy or primary care for the environment or biodiversity. Some submissions on the draft national standard made by NGOs were excluded by their being, ‘mislaid’, omitted or lost.
Following numerous complaints, it was generally accepted that IFCI had failed and that a new process would have to be initiated. Unfortunately the supposedly new process has merely resurrected the old one, with many of the same tired old faces still involved. Now, some ten years later, we have the same people on IFCI now preferring to call themselves FSC Ireland and asking for submissions to a ‘Final Draft’ by 23rd October. This is not acceptable. IFCI was discredited through its lack of consultation and therefore it is perhaps incumbent on the Irish government to initiate foster or promote an entirely new process open to full and inclusive participation with a new Board of Directors and Steering Committee to be elected.
Much valuable work has gone into the existing ‘Second Draft’, which could conceivably be circulated widely and considered as a ‘First Draft’ open for public comment. The process could thereafter be completed within a reasonable timeframe.
THE ROLE OF NGOS IN THE FSC/IFCI PROCESS
What should have been a genuine multi-stakeholder level playing field proved to be one of exclusion of groups who did not subscribe to the status quo in Irish Forestry. This was done on spurious grounds, which went so far as what one could describe as ‘bullying’ individuals out of the process, or excluding them from normal entitlements such as what would be regarded as legitimate expenses.
Some ENGOs withdrew when they saw that the system was not credible. To their shame a few of the larger and more influential environmental NGOs (ENGOs) stayed in the system thereby affording it the credibility that the process did not deserve. These ENGOs on the one hand promote biodiversity as a rule but when it comes to Irish Forestry and the FSC/IFCI process, effectively by their actions remaining in the system are supporting alien tree monoculture in Irish Forestry.
Genuine efforts were made to try and put the process on a proper footing. For example, the Woodland league met IFCI through the intervention of FSC International in 2005, as well as at an FSC environment chamber meeting in Bonn in 2006. Terms of reference for re-engaging in 2005 were discussed, which highlighted the problems that the FSC process is littered with.
Documentation of these meetings, which gives detailed background to the FSC/IFCI Ireland debacle, is available. If one examines the Bonn meeting minutes one will see the way FSC conducts its business, which is seriously flawed and wide open to abuse. Without reforming the parent body, FSC International, it is not possible to reform the national processes of certification.
EXAMPLES OF BREACHES OF FSC PRINCIPLES
Ownership: Deeds and Titles
The first principle dealt with in the draft states that the company or entity applying for FSC certification (Coillte) should be clearly defined and its deeds and title to the forest estate clearly placed in the public domain. There are at least eleven different definitions for Coillte in the public domain that is known. Their title deeds, including a list of conveyances and trusts left to the Irish people by benevolent landowners etc are still not available in the public domain, nor on their website. The solicitors working for them hold the title deeds in what is known as bundles, which is dubious and unclear. However after they sell off land from the bundle, new titles can be created by compliant solicitors. No one is ever the wiser as to Coillte’s entitlement to sell off certain lands.
Coillte remains the largest land development company in Ireland. It is not really a forestry company. There are major issues to be unravelled regarding the Coillte/AIB/Irish Life pension fund company called Irish Forestry Unit Trust, which manages a large amount of the public ‘forest’ estate as a private landowner. This IFUT also stands to benefit from any weak National Forest Standard foisted onto an unsuspecting public by FSC Ireland a.k.a IFCI. This last point links the important National resource of public forests into the web of speculators, bankers and economists. The current Forestry plan is largely based on the recommendations of a pure economist, Peter Bacon who recommended the setting up of Nama, which is to deal with toxic loans at present in the hands of the banking system in Ireland. The sudden urgency to produce a standard now, at a time of serious economic depression may be to suit the Irish Forestry Investment Funds plantations and the potential purchaser(s) of the Coillte estate.
In summary, the FSC Ireland Draft forest standard 2009 is attempting to pass itself off as the fourth and final stage of an extremely flawed process. The intention is that it would become the National Forest Standard for Ireland. If it is not stopped in its tracks it will set Irish Forestry back by at least twenty years.
SUMMARY LIST OF QUESTIONS THAT NEED TO BE ADDRESSED
- What has become of the IFCI, set up and funded to produce a Forest standard for Ireland in 1999?
- Who mandated FSC Ireland to be formed?
- When and where were the public notified of, and involved in, FSC Ireland’s creation?
- Specifically, which NGO Groups were contacted and represented?
- How were the representatives for FSC Ireland selected?
- Who is funding FSC Ireland?
- Who is now representing the forestry groups Andrew St.Ledger was mandated to represent?
- Who are the representatives on the Social chamber?
- Who represents the ITGA, UFA, Organic Growers, Contractors, Retailers etc?
- Where can the First Draft of the national standard be found?
Signed by Brendan Kelly on behalf of IESS, The Irish Environmental and Social Stakeholders.