31/03: WLL Newsletter #36 - 31st March 2006
CONTENTS
1. Extract: Water Governance in Ireland - Part III: Public Participation
2. Letters
Inductrial timber plantations impact negatively on biodiversity (Philip Owen)
Update from Rossport Solidarity Camp
3. Upcoming Events
4. In the news
(a) National:
Coillte to spend €60m buying Clonmel plant (Irish Independent)
5. Contact the Woodland League
1. EXTRACT: WATER GOVERNANCE IN IRELAND - PART III: PUBLIC PARTICIPATION
- Michael Ewing, MSc
In the last two issues, we have published sections from Michael Ewing's report, "Water Governance in Ireland". In this issue, we publish the fourth section in the report, "Public Participation".
4. PUBLIC PARTICIPATION
4.1. Description of the case
Mohercregg Group Water Scheme
The case selected is of a small private group water scheme (GWS), which provides drinking water for the community that owns it. The water supply comes from mountain-fed springs and is generally of very good quality. The 201 users of the suppply use an average of 39m³/day. However there is a problem with periodic pollution by Escherichia coli (E.coli), which indicates faecal contamination.
This case was chosen as typical of the situation faced by the 778 private GWS that deliver drinking water to 6% of the population, mostly in rural situations.
The decision-making process dicussed here relates to the requirement under the 2003 Drinking Water Regulations that all drinking water supplies must be free from E.coli contamination. To achiece this requirement the GWS must put in a treatment process. The GWS wishes to avoid the use of chlorine due to recognised potential health effects of Trihalomethanes (THMs), and has proposed instead the use of copper-silver ionisation as a proven alternative. The Authority initially said this was not appropriate and was unsure in the face of conflicting evidence as to the effectiveness and safety of this system.
The GWS can instal any treatment system it wishes, but is reliant on the approval of the Authority in order to avail of grants provided by the DOEHLG for 20 year design, build and operate (DBO) contracts. The Authority maintains that it has to follow procurement rules in offering the contracts for tender and cannot specify the treatment method to be used. Added to this is the requirement that the Mohercregg Group Water Scheme be bundled in with two other GWSs in order to make the contract a commercial proposition.
Community control of water supplies in some of the GWSs is being willingly relinquished into the care of the Sanitary Authorities; however there are many that want to maintain their autonomy.
Note: the Sanitary Authority in this case is Leitrin County Council, also referred to as the Authority.
4.2. Analysis of specific law
Quality and scope of specific legal framework
Whilst there is no specific legal requirement to provide information to the GWS regarding this process, the Authority is required under the 2003 Drinking Water Regulations to bring all the drinking water supplies up to certain standards. Its own activities in this regard are being monitored by the Office of Environmental Enforcement, and it could be subject to sanctions should it fail to reach the standards within its catchment.
At the same time, the Local Government Act, 2001 provides in Article 127 that
(1) A local authority may take such steps as it considers appropriate to consult with and promote effective participation by the local community in local government.
(2) Without prejudice to the generality of subsection (1) a local authority may—
(c) consult with local sectoral, community or other groups,
(e) consult with a recognised association under section 128,
However the GWS is a private body with whom the Authority deals with on same legal level as with any other private service provider. This means that the Sanitary Authority interacts with the Scheme as it would with any other body, informing it and enabling it to inform its members.
In practice then the Authority, in order to achieve its legal requirements, needs to provide information to the GWS.
Quality and scope of specific legal limits on access
Due to the fact that the GWS is a private body, the Authority refused access to the relevant files without the permission of the Secretary and Trustees of the GWS, which is only proper. The researcher however was also required to produce proof of his research bona fides, which implied a lack of trust, and a selective process, regardless of the wishes of the GWS committee. Had this been a public water supply or scheme then the information would have been available under S.I. 125 of 1998, the Access to Information on the Environment Regulations.
Quality and scope of legal requirements to build capacity of government agencies
There is no requirement in the Drinking Water Regulations or the concomitant guidelines requiring Sanitary Authorities to build their capacity to provide effective public participation.
The LOCAL GOVERNMENT ACT, 2001 in Section 71 requires that
(2) The relevant local authorities shall take such steps as may be practicable—
(b) to improve customer service to the public generally.
This is a broad requirement, and does not refer to participation by the public, but should be taken in conjunction with Section 127,which states:
(1) A local authority may take such steps as it considers appropriate to consult with and promote effective participation by the local community in local government.
Clearly in the light of the balancing of resources required in Section 69, in favour of those activities the Authority is compelled to carry out, then capacity building may not be a first priority.
Quality and scope of the legal requirements to build capacity of the public
There is no specific requirement contained within the Drinking Water Regulations for a Sanitary Authority to provide technical assistance to the public regarding the decision-making process concerned. However the Local Government Act, 2001 made general provisions for greater public involvement by Local Authorities viz: Article 64 which implies the need to provide such assistance as is needed states that
…..a local authority may........(c) facilitate and promote interest and involvement in local government affairs generally,
Again in Article 127.—(1) A local authority may take such steps as it considers appropriate to consult with and promote effective participation by the local community in local government
And also in Article 127 (3) (a) ………., the local authority may take such additional steps as it may consider appropriate to publicise, facilitate or promote the consultation process ……
These laudable provisions do however not compel but only allow the Authority to carry them out.
There is also no requirement under law for the Government to build capacity of the Sanitary Authority with regard to participation.
4.3. Analysis of the case
EFFORT
Scope and quality of effort
The underlying factor in making the decisions regarding the management of the GWS is the requirement to bring the quality of the drinking water up to the standards laid down. The method for reaching these standards is up to the members of the GWS. The council is required to enforce the standards as laid down, and when the Water Services Bill becomes Law to control the issuing of licences to operate.
So whilst the law is silent on a timeframe, the implications of the legislation do create a schedule of necessary decisions, and as this is a community-run GWS, then that is what underlies their timetable for participation.
A review of the correspondence between the two parties would indicate that communication did take place regarding the process. However when interviewing the members of the GWS committee it was clear that they were less than happy with the way in which certain parts of the process had been conducted. In particular the appointment of a consultant to act as the ‘Clients Representative’ was seen as a decision in which they had no part, and yet this person was to make recommendations to the council regarding how water treatment should be conducted in the future.
In order to make decisions regarding the future management of the GWS, its members needed to know:
1) What were the health issues relating to compliance?
2) What were the disinfection treatments available to them?
3) What were the financial consequences of the different choices?
The information on the health issues was provided to the committee, though mostly in relation to ‘Boil Notices’. However, it was only through the insistence of the GWS committee that the Copper Silver Ionisation treatment was taken as a valid option. The Sanitary Authority will not commit to providing this system of disinfection as it is their position that to specify a particular treatment process would be contrary to the procurement rules under which they operate. They also have concerns about the effectiveness of this alternative treatment, the potential health consequences for the consumers and the legal liability that they would be open to if they were seen to allow what they see as an unproven technology.
Incorrect information appears to have been provided to the GWS regarding the grants available to them, in a letter from the Authority on 13/6/2003. The letter seemed to imply that either the GWS went down the prescribed route or there were no grants available. After political intervention it became clear that this was not so.
Meetings between the relevant officials of the Water Services Section and the GWS members took place on an ad hoc basis sometimes at the request of the GWS. However, the members of the GWS interviewed felt that the meetings were used by the Authority personnel as information giving sessions rather than occasions for discussion and joint decision-making.
Cost and affordability
In order to promote greater attendance at meetings between the Authority and the GWS members and to reduce costs for the GWS scheme and members, meetings were held in a location central to the community. Meetings were also held out of office hours to facilitate working members.
Fairness and equitability
The issue of inclusiveness did not occur in that the Authority and the GWS were equal partners in the process, though as can be seen from the above the meetings were held in such a way as to be as inclusive as possible.
Timeliness
The timing of the process is led by two factors. Firstly the requirement to be compliant with the Regulations and before licencing is introduced and secondly by the commercial realities of the bundling and DBO processes. However, the GWS is in charge of the water supply and can make whatever decisions it wishes in its own time, provided it is compliant with the law.
Channels of access
Whilst the files regarding the GWS, being private correspondence, are only open to the members of same, these files were far from complete, with no record of many of the letters sent out by the Sanitary Authority. Only some water quality records were present, so that it would require further searches to find out the history and indeed present status of the drinking water on the GWS. The correspondence was compared with that contained in the GWS secretary’s file.
With regard to drinking water quality, Section 67 of the EPA Act, 1992 prescribes that—The Agency shall keep and maintain, or cause to be kept and maintained, such records, including such summary records, of the results of any monitoring carried out, caused to be carried out, or arranged by it under this Act as it considers necessary for the purposes of any of its functions and shall, subject to section 39, make such records available, or cause such records to be made available, for inspection by the public at all reasonable times, and, as the Agency considers appropriate, publish, or cause to be published, such records.
So the information regarding drinking water quality could be available in a public register, but isn’t. So for example, a person thinking of joining a GWS cannot access a public register to see what the track record, of the water supply provided, is. The EPA reports that the GWS had 3 excedences of E. coli and 4 for total coliform bacteria in 2004. This important information is not on the GWS file.
Efforts to build capacity of government agencies
There have been no guidelines or training on public participation offered over the last 3 years to officials in the Water Services Section of the Authority. Whilst there is no earmarked budget for public participation activities, costs incurred are charged against the Section budget, which is estimated to be about 65-70% of what is required to carry out its statutory functions properly.
Efforts to build capacity of the public
The guidelines regarding the DBO process and the grant aided improvement of GWS infrastructure were clear to the authority personnel, but not to the members of the GWS committee. There would appear to be a problem of communication when the Authority says that at meetings with the GWS membership it has made it clear what would be the sequence of the decision-making process, and yet the committee says the opposite, that it was never made clear to them. This is despite what appeared to the researcher to be the best of intentions by both parties.
EFFECTIVENESS
Impact of access
Whilst the files kept by the Authority and relating to the process are available to members of the committee of the GWS, they are poorly kept and would not inform anyone who didn’t already have a good grasp of the situation.
Although most of the requests for information made by the GWS were responded to within a month, not all were. The most recent being a verbal request made at a meeting between the GWS and the Sanitary Authority in September 2005, which had still not received a response on 5th February 2006.
Outcomes of access
In essence the decision here always belonged to the GWS membership. However the consequences of their decision options made it difficult to make the decision that they wanted to regarding the choice of sterilization process. If they followed their own choice then there were potentially serious financial consequences. At one stage they appear to have been informed incorrectly that they would receive no grant aid if they insisted on this form of treatment.
Effectiveness of capacity building for government agencies
It was the experience of the stakeholders that some of the officials talked down to them and even misinformed them about their decision options and their consequences, whilst others were very helpful. This did not create a trusting environment for the decision-making process.
4.4. Findings
The presentation of values in the findings charts uses colour coding to show the values given in response to each indicator as following:
very good
good
intermediate
poor
very bad
not applicable
LAW
Quality and scope of specific legal framework
50 To what extent does the law require a government agency to provide relevant information to the public about the intention to start the selected decision-making process? - very bad
51 To what extent does the law require the government to provide opportunities for public involvement in the selected decision-makin process? - intermediate
Quality of specific legal limits on access
52 How clear and narrow are the limits on claims of confidentiality of relevant information about the selected decision-making process? - good
Quality and scope of legal requirements to build capacity of government agencies
53 To what extent does the law require the agency responsible for the selected decision-making process to build the capacity of its staff with regard to public participation? - intermediate
Quality and scope of the legal requirements to build capacity of the public
56 To what extent does the law require the government to offer the public technical assistance, guidance or training on participation in the selected decision-making process? - intermediate
58 To what extent does the law require the government to build the capacity of sub-national governments with regard to participation in the selected decision-making process? - very bad
Legal requirement for timeliness
59 How clearly does the law establish a reasonable timeframe for participation in the selected decision-making process? - very good
EFFORT
Scope and quality of effort
60s To what extent does the responsible agency make available to the public a clear description of its decision-making processes, including opportunities for participation? - good
62 To what extent did the responsible agency provide relevant information to the public about decision options and their environmental and health impacts in the selected case? - good
63 To what extent did the responsible agency hold public participation sessions at all stages of the decision-making process in the selected case? - good
Cost and affordability
65 To what extent did the responsible agency keep costs of participation low for participants in the selected case? - good
Fairness and equitability
67 How well did the responsible agency make a planned and systematic effort to involve [pull-down list including women, poor, minorities, etc] in decision-making in the selected case? - not applicable
Timeliness
68 Did notification of the start of each stage in decision-making process in the selected case provide reasonable lead time for effective public participation? - not applicable
Channels of access
70 How well does the responsible agency maintain a publicly accessible registry of past and pending decisions? - poor
73 To what extent was relevant supporting documentation available through public registries for the selected decision-making process? - poor
Efforts to build capacity of government agencies
75s To what extent were guidelines or training on public participation offered regularly over the last 3 years to officials in the agency that leads the selected decision-making process? - very bad
77s How adequate is the government budget allocation for effectively facilitating public participation in the selected decision-making process? - intermediate
Effort to build the capacity of the public
79s How clear and easily accessible are the public guidelines on how to participate in the selected decision-making process? - intermediate
EFFECTIVENESS
Impacts of access
81 To what extent was a public record kept in a reasonably accessible format detailing comments made, comments incorporated in the selected decision, and reasons for any rejection of comments? - not applocable
82 How promptly did the public receive information about the dispensation of comments in the selected case? - good
Outcomes of access
84 To what extent did public participation influence the final decision in the selected case? - good
Effectiveness of capacity building for government agencies
86 How well did staff/officials execute their participation responsibilities in the selected case? - intermediate
4.5. Conclusions regarding Public Participation
The decisions to be made here centred on the requirement to be compliant with the Drinking Water Regulations, and in particular with the requirement to have drinking water that is free of E.coli. The fact that the GWS is a private community based group meant that it was in effect responsible for informing its own public i.e. the members. There was then no legal requirement on the Authority to provide information directly to the public regarding the decision-making process.
Due to the fact that the GWS is a private body, the Authority refused the researcher access to the relevant files without the permission of the Secretary and Trustees of the GWS, which is only proper. The researcher however was also required to produce proof of his research bona fides, which implied a lack of trust, and a selective process, regardless of the wishes of the GWS committee.
There are no legal requirements in the Drinking Water Regulations for capacity building regarding public participation, though the Local Government Act provides the scope to do so. The same situation applies to building the capacity of the public in this regard.
Whilst the law is silent on a timeframe, the implications of the legislation do create a schedule of necessary decisions, and as this is a community-run GWS, then that is their timetable for participation.
When interviewing the members of the GWS committee it was clear that they were less than happy with the way in which certain parts of the process had been conducted by the Authority. In particular the appointment of a consultant to act as the ‘Clients Representative’ was seen as a decision in which they had no part.
In order to make decisions regarding the future management of the GWS, its members needed to know: What were the health issues relating to compliance? What were the disinfection treatments available to them? And what were the financial consequences of the different choices? It seems that in the case of the last two questions in particular it was, according to the committee members interviewed, difficult to get definitive answers from the Authority.
Meetings between the two parties were held in the heart of the GWS area and organised to be at times designed to make it easy to attend, but despite what appears to be good intent on both sides, the GWS committee felt that often the meetings were not about partnership, but about the Authority personnel using the occasion just to give information.
No registers of information regarding drinking waters which are accessible and open to the public are kept, and the correspondence files relating to this process were poorly kept. This makes it difficult to track the decision-making and creates problems of continuity.
There have been no guidelines or training on public participation offered over the last 3 years to officials in the Water Services Section of the Authority, and whilst there is no earmarked budget for public participation activities, costs incurred are charged against the Section budget, which is estimated to be about 65-70% of what it requires to carry out its statutory functions properly.
There would appear to be a communication problem between the parties involved which is hampering the decision-making process. That said written communications seem to be generally effective, with responses to GWS requests being reasonably timely. A recent verbal request made at a meeting was however unanswered some 4 months later.
It was the experience of the stakeholders that some of the officials talked down to them and even misinformed them about their decision options and their consequences, whilst others were very helpful. This did not create a trusting environment for the decision-making process.
- Michael Ewing, MSc
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2. LETTERS
INDUSTRIAL TIMBER PLANTATIONS IMPACT NEGATIVLY ON BIODIVERSITY
Philip Owen, Geasphere
www.geasphere.co.za
The following extracts from scientific review papers apply to industrial timber plantations composed primarily of eucalyptus and pine monocultures.
Policy makers globally must recognize the negative impact of industrial timber monocultures and take steps to limit the expansion and entrenchment of this destructive model. Philip Owen Geasphere “Plantation Forestry in South Africa and its Impact on Biodiversity”
Review paper by: A.G. Armstrong, G. Benn, A.E. Bowland, P.S. Goodman, D.N. Johnson, A.H. Maddock and C.R. Scott-Shaw Commercial Aforestation has a major impact on biodiversity in some regions of South Africa, as demonstrated by empirical studies. This is no emotional perception. There is a urgent need for research to address many issues relating to the conservation of biodiversity in timber growing and agricultural regions. There is also an urgent requirement for the implementation of recommendations arising from this research. The impacts of land transformation are cumulative because more of the South African landscapes are being transformed yearly. Ecosystems are being subjected to changes on a unprecedented scale, and the risk of extinction and irreversible degradation is greater. Without proactive and timeous conservation action, more species and other components of biodiversity will pass over the brink to extinction, ecosystems will be affected, and we will be the poorer for it.
The Impact of Commercial Afforestation on Bird Populations in Mpumalanga Province, South Africa – Insights from Bird - Atlas data. By: David G. Allan, James A. Harrison, Rene A. Navarro, Brian W. van
Wilgen and Mark W. Thompson
Extract:
“South Africa’s endemic grasslands, and the unique biodiversity supported by them HAVE been neglected and impinged upon by forestry (Industrial Timber Plantations) in the past. Positive contribution from forestry is needed if biodiversity in the grassland biome is to be viable in the long term. This unavoidably means that large tracts of land suitable for afforestation must be sacrificed by the industry and be devoted instead to alternative forms of land use which has fewer negative impacts on the grassland biota, for example pastoral farming and ecotourism. Identifying such alternatives and assessing their economic value relative to forestry is an immediate research priority.”
Source:
1.“Plantation Forestry in South Africa and its Impact on Biodiversity”
For a copy of this document contact: KwaZulu-Natal Conservation Service,
P.O.Box 662, Pietermaritzburg, 3200, South Africa.
2. The Impact of commercial afforestation on Bird Populations in
Mpumalanga Province, South Africa – Insights from Bird-atlas data.
For a Copy of this document contact:
Avian Demography Unit, Department of Statistical Sciences, UCT,
Rondebosch, 7700, South Africa
Devision of Environmental Technology, CSIR, Private Bag X50011,
Stellenbosch, 7599, South Africa.
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UPDATE FROM ROSSPORT SOLIDARITY CAMP
Hey folks,
Just a quick update on the camp.
Today we had a visit from The National Parks and Wildlife Service www.npws.ie/ . They dropped by the camp to see what impact we're havin on the local environment. They did not stay very long but said they we're satisfied with what they saw and said they had to write up a report for their superiors. Shortly after they left our friendly neighbourhood Gardai dropped by for light refreshments and conversation. Finding nothing to fault on site they left, but not before requesting the drivers license and insurance of someone on site.
Although we are doing our utmost not to have a lasting effect on the area we are camped in ( see http://www.indymedia.ie/article/74884)
it is a Special Area of Conservation (
http://www.teagasc.ie/publications/2003/20031104/paper4.htm ), and the relevant bodies it seems see us as a bigger threat to the area than a pipeline and refinery that stands to pollute the entire Broadhaven Bay not to mention other S.A.C.'s i.e. Carrowmore lake (
http://www.indymedia.ie/article/74919 ) .
Really, this email is a heads up to all you good folk out there; they are being all civil with us now, but the time may/will come when they look to remove the camp. We will need more bodies on site if it comes to that. We'll keep ye posted on any further developments.
Solidarity
Michael and all here at the Rossport Solidarity Camp
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3. UPCOMING EVENTS
April 2nd 06: Living Willow Sculpture
with Katrin Schwart, ftraditional and contemporary basket-maker. Learn the techniques of this popular craft through planting and weaving beautiful outside seats and play structures. Katrin will also provide tools, materials and advice on suitable varieties for home projects. Sun 2nd Apr 10am-5pm. Cost €75 – includes lunch. Contact 091 550905 or email info@galwaygarden.com www.galwaygarden.com. Galway.
April-May 2006: Seminars in Environmental Law at UL
The International Commercial and Economic Law Research Group at the University of Limerick will run a series of seminars on environmental law in the Spring 2006 semester. These seminars will deal with issues such as climate change, environmental enforcement in Ireland, fisheries in the national and international contexts and recent developments in domestic environmental law.
TIMETABLE OF EVENTS:
* Fisheries In Ireland: Lessons From North America, Date: Thursday 27 April 2006, Speaker: Professor Katrina Wyman, School of Law, New York University
* Environmental Impact Assessments, Date: May 2006, Speaker : Garrett Simons, BL,
(All events are subject to change.)
Further details of the Seminars are available at http://www.ul.ie/envirocom/worddocs/EnvironmentalLaw.doc or from the Project Leader: Rónán Kennedy, ICELRG, School of Law, University of Limerick. Email: ronan.kennedy@ul.ie
Further information on the International Commercial and Economic Law Research Group is available by contacting Raymond J Friel, Director, ICELRG, School of Law, University of Limerick. Email: raymond.friel@ul.ie . Limerick.
Friday 28th April -Monday 1st May 06 ''Health, Medicine & The Law'' - A Contemporary and Brehon Perspective
See http://www.burrenlawschool.org/programme.html for programme.
Burren Law School 2006, Burren College of Art, Ballyvaughan, Co. Clare
6th / 7th May 06: Weekend in the Woods – CELT
Another big weekend of traditional and ecological skills training at all levels for adults (age 14+) Courses will include Wood Carving, Dry-stone and Lime-mortar Walling, Basket Weaving, Blacksmithing, Greenwood Furniture making, Natural Building, Coppersmithing, Silversmithing, Herb Lore, Bushcraft, Natural Building, Sugan Chair making and more. For details see http://www.celtnet.org/events-page14233.html. Clare.
22 / 23 / 24 July 06: Summer in the Woods - CELT
Bealkelly Wood, Tuamgraney - 12 courses including Boat-building - see http://www.celtnet.org for more info. Clare.
7th / 8th October 06: Weekend in the Woods – CELT
Bealkelly Wood, Tuamgraney - see http://www.celtnet.org for more info. Clare.
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4(a). IN THE NEWS - National
COILLTE TO SPEND €60m BUYING CLONMEL PLANT
COILLTE, the semi-state forestry company, looks poised to pay an estimated €60m for a timber board manufacturing plant in Clonmel in Co Tipperary.
The plant represents the Irish interests of Weyerhaeuser, an American timber products giant which had sales last year of $22.6bn.
Coillte is expected to merge the Clonmel company with its existing Smartply facility in Waterford, which it acquired from American company Louisiana Pacific in 2002. Smartply makes a type of timber board called OSB, while the Clonmel facility makes a MDF board.
The sale of its Clonmel plant, which employs 170 people, is part of an international restructuring by the American company, which is moving out of forestry and timber products to focus on its real-estate operations.
Last month, Weyerhaeuser posted a Q4 loss of $211m, compared to a profit of $199m in the previous year. The losses were largely due to restructuring charges.
Although the purchase of the Clonmel timber plant is not yet complete, it is understood that Coillte has outbid Cavan-based Green Belt, which is a biggest privately-owned forestry company in the State.
Expansion
Coillte has been keen to expand its timber board operation for more than 12 months, even considering setting up a manufacturing facility in another European country. Coillte made pre-tax profits in 2004 of €37.7m, up 35pc on the previous year.
Timber board accounted for much of the growth in profits, with the Waterford plant operating 24 hours a day, 365 days a year.
The semi-state company has invested approximately €10m in the Smartply facility over the past 12 months to increase capacity by about 12pc.
Aside from the booming Irish market, the European market for timber boards is growing by about 20pc per year.
Coillte manages 1.1m acres of forest on land which makes up 6.3pc of the area of the country, equivalent to the size of two average counties.
Coillte's core product is the production of logs, but although it produced 2.66m cubic metres of log in 2004, the last year for which figures are available, pricing pressure has reduced the margins in this business.
(c) The Irish Independent, March 28 '06
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5. WOODLAND LEAGUE CONTACT DETAILS
www.woodlandleague.org
Andrew St. Ledger, PRO,
+353-(0)87-9933157
Brendan Kelly, Liaison Officer,
+353-(0)91-687778 (evenings)
+353-(0)86-1529176 (mobile)
brendankellywoodlawn@yahoo.ie
Ciarán Hughes, Secretary,
The Woodland League,
c/o Caherawoneen, Kinvara, Co. Galway, Ireland.
+353-(0)87-9652992
woodlandleague@yahoo.ie
Yahoo! Discussion Group:
http://www.yahoogroups.com/groups/woodland-league
woodland-league-subscribe@yahoogroups.com
Petition:
http://www.petitiononline.com/rfpii
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1. Extract: Water Governance in Ireland - Part III: Public Participation
2. Letters
Inductrial timber plantations impact negatively on biodiversity (Philip Owen)
Update from Rossport Solidarity Camp
3. Upcoming Events
4. In the news
(a) National:
Coillte to spend €60m buying Clonmel plant (Irish Independent)
5. Contact the Woodland League
1. EXTRACT: WATER GOVERNANCE IN IRELAND - PART III: PUBLIC PARTICIPATION
- Michael Ewing, MSc
In the last two issues, we have published sections from Michael Ewing's report, "Water Governance in Ireland". In this issue, we publish the fourth section in the report, "Public Participation".
4. PUBLIC PARTICIPATION
4.1. Description of the case
Mohercregg Group Water Scheme
The case selected is of a small private group water scheme (GWS), which provides drinking water for the community that owns it. The water supply comes from mountain-fed springs and is generally of very good quality. The 201 users of the suppply use an average of 39m³/day. However there is a problem with periodic pollution by Escherichia coli (E.coli), which indicates faecal contamination.
This case was chosen as typical of the situation faced by the 778 private GWS that deliver drinking water to 6% of the population, mostly in rural situations.
The decision-making process dicussed here relates to the requirement under the 2003 Drinking Water Regulations that all drinking water supplies must be free from E.coli contamination. To achiece this requirement the GWS must put in a treatment process. The GWS wishes to avoid the use of chlorine due to recognised potential health effects of Trihalomethanes (THMs), and has proposed instead the use of copper-silver ionisation as a proven alternative. The Authority initially said this was not appropriate and was unsure in the face of conflicting evidence as to the effectiveness and safety of this system.
The GWS can instal any treatment system it wishes, but is reliant on the approval of the Authority in order to avail of grants provided by the DOEHLG for 20 year design, build and operate (DBO) contracts. The Authority maintains that it has to follow procurement rules in offering the contracts for tender and cannot specify the treatment method to be used. Added to this is the requirement that the Mohercregg Group Water Scheme be bundled in with two other GWSs in order to make the contract a commercial proposition.
Community control of water supplies in some of the GWSs is being willingly relinquished into the care of the Sanitary Authorities; however there are many that want to maintain their autonomy.
Note: the Sanitary Authority in this case is Leitrin County Council, also referred to as the Authority.
4.2. Analysis of specific law
Quality and scope of specific legal framework
Whilst there is no specific legal requirement to provide information to the GWS regarding this process, the Authority is required under the 2003 Drinking Water Regulations to bring all the drinking water supplies up to certain standards. Its own activities in this regard are being monitored by the Office of Environmental Enforcement, and it could be subject to sanctions should it fail to reach the standards within its catchment.
At the same time, the Local Government Act, 2001 provides in Article 127 that
(1) A local authority may take such steps as it considers appropriate to consult with and promote effective participation by the local community in local government.
(2) Without prejudice to the generality of subsection (1) a local authority may—
(c) consult with local sectoral, community or other groups,
(e) consult with a recognised association under section 128,
However the GWS is a private body with whom the Authority deals with on same legal level as with any other private service provider. This means that the Sanitary Authority interacts with the Scheme as it would with any other body, informing it and enabling it to inform its members.
In practice then the Authority, in order to achieve its legal requirements, needs to provide information to the GWS.
Quality and scope of specific legal limits on access
Due to the fact that the GWS is a private body, the Authority refused access to the relevant files without the permission of the Secretary and Trustees of the GWS, which is only proper. The researcher however was also required to produce proof of his research bona fides, which implied a lack of trust, and a selective process, regardless of the wishes of the GWS committee. Had this been a public water supply or scheme then the information would have been available under S.I. 125 of 1998, the Access to Information on the Environment Regulations.
Quality and scope of legal requirements to build capacity of government agencies
There is no requirement in the Drinking Water Regulations or the concomitant guidelines requiring Sanitary Authorities to build their capacity to provide effective public participation.
The LOCAL GOVERNMENT ACT, 2001 in Section 71 requires that
(2) The relevant local authorities shall take such steps as may be practicable—
(b) to improve customer service to the public generally.
This is a broad requirement, and does not refer to participation by the public, but should be taken in conjunction with Section 127,which states:
(1) A local authority may take such steps as it considers appropriate to consult with and promote effective participation by the local community in local government.
Clearly in the light of the balancing of resources required in Section 69, in favour of those activities the Authority is compelled to carry out, then capacity building may not be a first priority.
Quality and scope of the legal requirements to build capacity of the public
There is no specific requirement contained within the Drinking Water Regulations for a Sanitary Authority to provide technical assistance to the public regarding the decision-making process concerned. However the Local Government Act, 2001 made general provisions for greater public involvement by Local Authorities viz: Article 64 which implies the need to provide such assistance as is needed states that
…..a local authority may........(c) facilitate and promote interest and involvement in local government affairs generally,
Again in Article 127.—(1) A local authority may take such steps as it considers appropriate to consult with and promote effective participation by the local community in local government
And also in Article 127 (3) (a) ………., the local authority may take such additional steps as it may consider appropriate to publicise, facilitate or promote the consultation process ……
These laudable provisions do however not compel but only allow the Authority to carry them out.
There is also no requirement under law for the Government to build capacity of the Sanitary Authority with regard to participation.
4.3. Analysis of the case
EFFORT
Scope and quality of effort
The underlying factor in making the decisions regarding the management of the GWS is the requirement to bring the quality of the drinking water up to the standards laid down. The method for reaching these standards is up to the members of the GWS. The council is required to enforce the standards as laid down, and when the Water Services Bill becomes Law to control the issuing of licences to operate.
So whilst the law is silent on a timeframe, the implications of the legislation do create a schedule of necessary decisions, and as this is a community-run GWS, then that is what underlies their timetable for participation.
A review of the correspondence between the two parties would indicate that communication did take place regarding the process. However when interviewing the members of the GWS committee it was clear that they were less than happy with the way in which certain parts of the process had been conducted. In particular the appointment of a consultant to act as the ‘Clients Representative’ was seen as a decision in which they had no part, and yet this person was to make recommendations to the council regarding how water treatment should be conducted in the future.
In order to make decisions regarding the future management of the GWS, its members needed to know:
1) What were the health issues relating to compliance?
2) What were the disinfection treatments available to them?
3) What were the financial consequences of the different choices?
The information on the health issues was provided to the committee, though mostly in relation to ‘Boil Notices’. However, it was only through the insistence of the GWS committee that the Copper Silver Ionisation treatment was taken as a valid option. The Sanitary Authority will not commit to providing this system of disinfection as it is their position that to specify a particular treatment process would be contrary to the procurement rules under which they operate. They also have concerns about the effectiveness of this alternative treatment, the potential health consequences for the consumers and the legal liability that they would be open to if they were seen to allow what they see as an unproven technology.
Incorrect information appears to have been provided to the GWS regarding the grants available to them, in a letter from the Authority on 13/6/2003. The letter seemed to imply that either the GWS went down the prescribed route or there were no grants available. After political intervention it became clear that this was not so.
Meetings between the relevant officials of the Water Services Section and the GWS members took place on an ad hoc basis sometimes at the request of the GWS. However, the members of the GWS interviewed felt that the meetings were used by the Authority personnel as information giving sessions rather than occasions for discussion and joint decision-making.
Cost and affordability
In order to promote greater attendance at meetings between the Authority and the GWS members and to reduce costs for the GWS scheme and members, meetings were held in a location central to the community. Meetings were also held out of office hours to facilitate working members.
Fairness and equitability
The issue of inclusiveness did not occur in that the Authority and the GWS were equal partners in the process, though as can be seen from the above the meetings were held in such a way as to be as inclusive as possible.
Timeliness
The timing of the process is led by two factors. Firstly the requirement to be compliant with the Regulations and before licencing is introduced and secondly by the commercial realities of the bundling and DBO processes. However, the GWS is in charge of the water supply and can make whatever decisions it wishes in its own time, provided it is compliant with the law.
Channels of access
Whilst the files regarding the GWS, being private correspondence, are only open to the members of same, these files were far from complete, with no record of many of the letters sent out by the Sanitary Authority. Only some water quality records were present, so that it would require further searches to find out the history and indeed present status of the drinking water on the GWS. The correspondence was compared with that contained in the GWS secretary’s file.
With regard to drinking water quality, Section 67 of the EPA Act, 1992 prescribes that—The Agency shall keep and maintain, or cause to be kept and maintained, such records, including such summary records, of the results of any monitoring carried out, caused to be carried out, or arranged by it under this Act as it considers necessary for the purposes of any of its functions and shall, subject to section 39, make such records available, or cause such records to be made available, for inspection by the public at all reasonable times, and, as the Agency considers appropriate, publish, or cause to be published, such records.
So the information regarding drinking water quality could be available in a public register, but isn’t. So for example, a person thinking of joining a GWS cannot access a public register to see what the track record, of the water supply provided, is. The EPA reports that the GWS had 3 excedences of E. coli and 4 for total coliform bacteria in 2004. This important information is not on the GWS file.
Efforts to build capacity of government agencies
There have been no guidelines or training on public participation offered over the last 3 years to officials in the Water Services Section of the Authority. Whilst there is no earmarked budget for public participation activities, costs incurred are charged against the Section budget, which is estimated to be about 65-70% of what is required to carry out its statutory functions properly.
Efforts to build capacity of the public
The guidelines regarding the DBO process and the grant aided improvement of GWS infrastructure were clear to the authority personnel, but not to the members of the GWS committee. There would appear to be a problem of communication when the Authority says that at meetings with the GWS membership it has made it clear what would be the sequence of the decision-making process, and yet the committee says the opposite, that it was never made clear to them. This is despite what appeared to the researcher to be the best of intentions by both parties.
EFFECTIVENESS
Impact of access
Whilst the files kept by the Authority and relating to the process are available to members of the committee of the GWS, they are poorly kept and would not inform anyone who didn’t already have a good grasp of the situation.
Although most of the requests for information made by the GWS were responded to within a month, not all were. The most recent being a verbal request made at a meeting between the GWS and the Sanitary Authority in September 2005, which had still not received a response on 5th February 2006.
Outcomes of access
In essence the decision here always belonged to the GWS membership. However the consequences of their decision options made it difficult to make the decision that they wanted to regarding the choice of sterilization process. If they followed their own choice then there were potentially serious financial consequences. At one stage they appear to have been informed incorrectly that they would receive no grant aid if they insisted on this form of treatment.
Effectiveness of capacity building for government agencies
It was the experience of the stakeholders that some of the officials talked down to them and even misinformed them about their decision options and their consequences, whilst others were very helpful. This did not create a trusting environment for the decision-making process.
4.4. Findings
The presentation of values in the findings charts uses colour coding to show the values given in response to each indicator as following:
very good
good
intermediate
poor
very bad
not applicable
LAW
Quality and scope of specific legal framework
50 To what extent does the law require a government agency to provide relevant information to the public about the intention to start the selected decision-making process? - very bad
51 To what extent does the law require the government to provide opportunities for public involvement in the selected decision-makin process? - intermediate
Quality of specific legal limits on access
52 How clear and narrow are the limits on claims of confidentiality of relevant information about the selected decision-making process? - good
Quality and scope of legal requirements to build capacity of government agencies
53 To what extent does the law require the agency responsible for the selected decision-making process to build the capacity of its staff with regard to public participation? - intermediate
Quality and scope of the legal requirements to build capacity of the public
56 To what extent does the law require the government to offer the public technical assistance, guidance or training on participation in the selected decision-making process? - intermediate
58 To what extent does the law require the government to build the capacity of sub-national governments with regard to participation in the selected decision-making process? - very bad
Legal requirement for timeliness
59 How clearly does the law establish a reasonable timeframe for participation in the selected decision-making process? - very good
EFFORT
Scope and quality of effort
60s To what extent does the responsible agency make available to the public a clear description of its decision-making processes, including opportunities for participation? - good
62 To what extent did the responsible agency provide relevant information to the public about decision options and their environmental and health impacts in the selected case? - good
63 To what extent did the responsible agency hold public participation sessions at all stages of the decision-making process in the selected case? - good
Cost and affordability
65 To what extent did the responsible agency keep costs of participation low for participants in the selected case? - good
Fairness and equitability
67 How well did the responsible agency make a planned and systematic effort to involve [pull-down list including women, poor, minorities, etc] in decision-making in the selected case? - not applicable
Timeliness
68 Did notification of the start of each stage in decision-making process in the selected case provide reasonable lead time for effective public participation? - not applicable
Channels of access
70 How well does the responsible agency maintain a publicly accessible registry of past and pending decisions? - poor
73 To what extent was relevant supporting documentation available through public registries for the selected decision-making process? - poor
Efforts to build capacity of government agencies
75s To what extent were guidelines or training on public participation offered regularly over the last 3 years to officials in the agency that leads the selected decision-making process? - very bad
77s How adequate is the government budget allocation for effectively facilitating public participation in the selected decision-making process? - intermediate
Effort to build the capacity of the public
79s How clear and easily accessible are the public guidelines on how to participate in the selected decision-making process? - intermediate
EFFECTIVENESS
Impacts of access
81 To what extent was a public record kept in a reasonably accessible format detailing comments made, comments incorporated in the selected decision, and reasons for any rejection of comments? - not applocable
82 How promptly did the public receive information about the dispensation of comments in the selected case? - good
Outcomes of access
84 To what extent did public participation influence the final decision in the selected case? - good
Effectiveness of capacity building for government agencies
86 How well did staff/officials execute their participation responsibilities in the selected case? - intermediate
4.5. Conclusions regarding Public Participation
The decisions to be made here centred on the requirement to be compliant with the Drinking Water Regulations, and in particular with the requirement to have drinking water that is free of E.coli. The fact that the GWS is a private community based group meant that it was in effect responsible for informing its own public i.e. the members. There was then no legal requirement on the Authority to provide information directly to the public regarding the decision-making process.
Due to the fact that the GWS is a private body, the Authority refused the researcher access to the relevant files without the permission of the Secretary and Trustees of the GWS, which is only proper. The researcher however was also required to produce proof of his research bona fides, which implied a lack of trust, and a selective process, regardless of the wishes of the GWS committee.
There are no legal requirements in the Drinking Water Regulations for capacity building regarding public participation, though the Local Government Act provides the scope to do so. The same situation applies to building the capacity of the public in this regard.
Whilst the law is silent on a timeframe, the implications of the legislation do create a schedule of necessary decisions, and as this is a community-run GWS, then that is their timetable for participation.
When interviewing the members of the GWS committee it was clear that they were less than happy with the way in which certain parts of the process had been conducted by the Authority. In particular the appointment of a consultant to act as the ‘Clients Representative’ was seen as a decision in which they had no part.
In order to make decisions regarding the future management of the GWS, its members needed to know: What were the health issues relating to compliance? What were the disinfection treatments available to them? And what were the financial consequences of the different choices? It seems that in the case of the last two questions in particular it was, according to the committee members interviewed, difficult to get definitive answers from the Authority.
Meetings between the two parties were held in the heart of the GWS area and organised to be at times designed to make it easy to attend, but despite what appears to be good intent on both sides, the GWS committee felt that often the meetings were not about partnership, but about the Authority personnel using the occasion just to give information.
No registers of information regarding drinking waters which are accessible and open to the public are kept, and the correspondence files relating to this process were poorly kept. This makes it difficult to track the decision-making and creates problems of continuity.
There have been no guidelines or training on public participation offered over the last 3 years to officials in the Water Services Section of the Authority, and whilst there is no earmarked budget for public participation activities, costs incurred are charged against the Section budget, which is estimated to be about 65-70% of what it requires to carry out its statutory functions properly.
There would appear to be a communication problem between the parties involved which is hampering the decision-making process. That said written communications seem to be generally effective, with responses to GWS requests being reasonably timely. A recent verbal request made at a meeting was however unanswered some 4 months later.
It was the experience of the stakeholders that some of the officials talked down to them and even misinformed them about their decision options and their consequences, whilst others were very helpful. This did not create a trusting environment for the decision-making process.
- Michael Ewing, MSc
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2. LETTERS
INDUSTRIAL TIMBER PLANTATIONS IMPACT NEGATIVLY ON BIODIVERSITY
Philip Owen, Geasphere
www.geasphere.co.za
The following extracts from scientific review papers apply to industrial timber plantations composed primarily of eucalyptus and pine monocultures.
Policy makers globally must recognize the negative impact of industrial timber monocultures and take steps to limit the expansion and entrenchment of this destructive model. Philip Owen Geasphere “Plantation Forestry in South Africa and its Impact on Biodiversity”
Review paper by: A.G. Armstrong, G. Benn, A.E. Bowland, P.S. Goodman, D.N. Johnson, A.H. Maddock and C.R. Scott-Shaw Commercial Aforestation has a major impact on biodiversity in some regions of South Africa, as demonstrated by empirical studies. This is no emotional perception. There is a urgent need for research to address many issues relating to the conservation of biodiversity in timber growing and agricultural regions. There is also an urgent requirement for the implementation of recommendations arising from this research. The impacts of land transformation are cumulative because more of the South African landscapes are being transformed yearly. Ecosystems are being subjected to changes on a unprecedented scale, and the risk of extinction and irreversible degradation is greater. Without proactive and timeous conservation action, more species and other components of biodiversity will pass over the brink to extinction, ecosystems will be affected, and we will be the poorer for it.
The Impact of Commercial Afforestation on Bird Populations in Mpumalanga Province, South Africa – Insights from Bird - Atlas data. By: David G. Allan, James A. Harrison, Rene A. Navarro, Brian W. van
Wilgen and Mark W. Thompson
Extract:
“South Africa’s endemic grasslands, and the unique biodiversity supported by them HAVE been neglected and impinged upon by forestry (Industrial Timber Plantations) in the past. Positive contribution from forestry is needed if biodiversity in the grassland biome is to be viable in the long term. This unavoidably means that large tracts of land suitable for afforestation must be sacrificed by the industry and be devoted instead to alternative forms of land use which has fewer negative impacts on the grassland biota, for example pastoral farming and ecotourism. Identifying such alternatives and assessing their economic value relative to forestry is an immediate research priority.”
Source:
1.“Plantation Forestry in South Africa and its Impact on Biodiversity”
For a copy of this document contact: KwaZulu-Natal Conservation Service,
P.O.Box 662, Pietermaritzburg, 3200, South Africa.
2. The Impact of commercial afforestation on Bird Populations in
Mpumalanga Province, South Africa – Insights from Bird-atlas data.
For a Copy of this document contact:
Avian Demography Unit, Department of Statistical Sciences, UCT,
Rondebosch, 7700, South Africa
Devision of Environmental Technology, CSIR, Private Bag X50011,
Stellenbosch, 7599, South Africa.
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UPDATE FROM ROSSPORT SOLIDARITY CAMP
Hey folks,
Just a quick update on the camp.
Today we had a visit from The National Parks and Wildlife Service www.npws.ie/ . They dropped by the camp to see what impact we're havin on the local environment. They did not stay very long but said they we're satisfied with what they saw and said they had to write up a report for their superiors. Shortly after they left our friendly neighbourhood Gardai dropped by for light refreshments and conversation. Finding nothing to fault on site they left, but not before requesting the drivers license and insurance of someone on site.
Although we are doing our utmost not to have a lasting effect on the area we are camped in ( see http://www.indymedia.ie/article/74884)
it is a Special Area of Conservation (
http://www.teagasc.ie/publications/2003/20031104/paper4.htm ), and the relevant bodies it seems see us as a bigger threat to the area than a pipeline and refinery that stands to pollute the entire Broadhaven Bay not to mention other S.A.C.'s i.e. Carrowmore lake (
http://www.indymedia.ie/article/74919 ) .
Really, this email is a heads up to all you good folk out there; they are being all civil with us now, but the time may/will come when they look to remove the camp. We will need more bodies on site if it comes to that. We'll keep ye posted on any further developments.
Solidarity
Michael and all here at the Rossport Solidarity Camp
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3. UPCOMING EVENTS
April 2nd 06: Living Willow Sculpture
with Katrin Schwart, ftraditional and contemporary basket-maker. Learn the techniques of this popular craft through planting and weaving beautiful outside seats and play structures. Katrin will also provide tools, materials and advice on suitable varieties for home projects. Sun 2nd Apr 10am-5pm. Cost €75 – includes lunch. Contact 091 550905 or email info@galwaygarden.com www.galwaygarden.com. Galway.
April-May 2006: Seminars in Environmental Law at UL
The International Commercial and Economic Law Research Group at the University of Limerick will run a series of seminars on environmental law in the Spring 2006 semester. These seminars will deal with issues such as climate change, environmental enforcement in Ireland, fisheries in the national and international contexts and recent developments in domestic environmental law.
TIMETABLE OF EVENTS:
* Fisheries In Ireland: Lessons From North America, Date: Thursday 27 April 2006, Speaker: Professor Katrina Wyman, School of Law, New York University
* Environmental Impact Assessments, Date: May 2006, Speaker : Garrett Simons, BL,
(All events are subject to change.)
Further details of the Seminars are available at http://www.ul.ie/envirocom/worddocs/EnvironmentalLaw.doc or from the Project Leader: Rónán Kennedy, ICELRG, School of Law, University of Limerick. Email: ronan.kennedy@ul.ie
Further information on the International Commercial and Economic Law Research Group is available by contacting Raymond J Friel, Director, ICELRG, School of Law, University of Limerick. Email: raymond.friel@ul.ie . Limerick.
Friday 28th April -Monday 1st May 06 ''Health, Medicine & The Law'' - A Contemporary and Brehon Perspective
See http://www.burrenlawschool.org/programme.html for programme.
Burren Law School 2006, Burren College of Art, Ballyvaughan, Co. Clare
6th / 7th May 06: Weekend in the Woods – CELT
Another big weekend of traditional and ecological skills training at all levels for adults (age 14+) Courses will include Wood Carving, Dry-stone and Lime-mortar Walling, Basket Weaving, Blacksmithing, Greenwood Furniture making, Natural Building, Coppersmithing, Silversmithing, Herb Lore, Bushcraft, Natural Building, Sugan Chair making and more. For details see http://www.celtnet.org/events-page14233.html. Clare.
22 / 23 / 24 July 06: Summer in the Woods - CELT
Bealkelly Wood, Tuamgraney - 12 courses including Boat-building - see http://www.celtnet.org for more info. Clare.
7th / 8th October 06: Weekend in the Woods – CELT
Bealkelly Wood, Tuamgraney - see http://www.celtnet.org for more info. Clare.
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4(a). IN THE NEWS - National
COILLTE TO SPEND €60m BUYING CLONMEL PLANT
COILLTE, the semi-state forestry company, looks poised to pay an estimated €60m for a timber board manufacturing plant in Clonmel in Co Tipperary.
The plant represents the Irish interests of Weyerhaeuser, an American timber products giant which had sales last year of $22.6bn.
Coillte is expected to merge the Clonmel company with its existing Smartply facility in Waterford, which it acquired from American company Louisiana Pacific in 2002. Smartply makes a type of timber board called OSB, while the Clonmel facility makes a MDF board.
The sale of its Clonmel plant, which employs 170 people, is part of an international restructuring by the American company, which is moving out of forestry and timber products to focus on its real-estate operations.
Last month, Weyerhaeuser posted a Q4 loss of $211m, compared to a profit of $199m in the previous year. The losses were largely due to restructuring charges.
Although the purchase of the Clonmel timber plant is not yet complete, it is understood that Coillte has outbid Cavan-based Green Belt, which is a biggest privately-owned forestry company in the State.
Expansion
Coillte has been keen to expand its timber board operation for more than 12 months, even considering setting up a manufacturing facility in another European country. Coillte made pre-tax profits in 2004 of €37.7m, up 35pc on the previous year.
Timber board accounted for much of the growth in profits, with the Waterford plant operating 24 hours a day, 365 days a year.
The semi-state company has invested approximately €10m in the Smartply facility over the past 12 months to increase capacity by about 12pc.
Aside from the booming Irish market, the European market for timber boards is growing by about 20pc per year.
Coillte manages 1.1m acres of forest on land which makes up 6.3pc of the area of the country, equivalent to the size of two average counties.
Coillte's core product is the production of logs, but although it produced 2.66m cubic metres of log in 2004, the last year for which figures are available, pricing pressure has reduced the margins in this business.
(c) The Irish Independent, March 28 '06
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5. WOODLAND LEAGUE CONTACT DETAILS
www.woodlandleague.org
Andrew St. Ledger, PRO,
+353-(0)87-9933157
Brendan Kelly, Liaison Officer,
+353-(0)91-687778 (evenings)
+353-(0)86-1529176 (mobile)
brendankellywoodlawn@yahoo.ie
Ciarán Hughes, Secretary,
The Woodland League,
c/o Caherawoneen, Kinvara, Co. Galway, Ireland.
+353-(0)87-9652992
woodlandleague@yahoo.ie
Yahoo! Discussion Group:
http://www.yahoogroups.com/groups/woodland-league
woodland-league-subscribe@yahoogroups.com
Petition:
http://www.petitiononline.com/rfpii
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