CONTENTS:
1. Coillte pesticide derogation application - Cypermethrin
(a) Original application
(b) Questionnaire to be completed for submission on the derogation
(c) People Against Pesticide’s Submissions
(d) Other submissions
2. Letter for the decertification of Coillte
3. Organisations from 8 countries demand the FSC to withdraw certificates
4. The resistance continues out west; A round up of news from Rossport Solidarity Camp
5. In the news:
(a) Local:
‘Comer Demesne plans scuppered after mast gets green light (Kilkenny Advertiser)
(b) National:
Weyerhaeuser plant for Coillte (Irish Times)
Mussel power leaves the trees standing (Sunday Times)
(c) UK:
The Rise and Fall of Britain’s Industrial Forest (The Independent)
6. Contact the Woodland League

1. COILLTE’S PESTICIDE DEROGATION APPLICATION - CYPERMETHRIN

On the 6th September, the Woodland League, and many others, received an e-mail from Gus Hellier of Soil Association/Woodmark asking for submissions on a derogation application to allow Cypermethrin to be used in FSC certified forestry in Ireland. From January 2006, Cypermethrin has been classed by FSC as a highly hazardous chemical, and as such is banned in FSC certified forests. However, a region can obtain derogation from this banning if a reasonable argument can be made that the pesticide is necessary. The argument was made in the application (see below). We were all asked to make a submission on this.

For the derogation request to be successful (i.e. for Cypermethrin to be allowed in Ireland), there are four requirements. Firstly, that there is a demonstrated need for the pesticide, secondly that there are specified controls in place for the pesticide use, thirdly that there are programmes to identify alternatives, and finally and most importantly that there is general social and environmental support for the pesticide to be used. For the last one, a letter of support from the National Initiative (in Ireland’s case, the National Initiative is IFCI) is generally considered enough evidence that there is general social and environmental support for the pesticide to be used.

However, according to Gus Hellier, IFCI gave Soil Association/Woodmark the responsibility of carrying out the consultation in Ireland on the derogation application. Thus, we received this e-mail from Gus Hellier, with an attached questionnaire (see below).

Initially, it wasn’t clear as to whether the application for the use of Cypermethrin was made by Coillte, or one of the other two FSC certified forestry operations in Ireland. However, in an e-mail on the 11th September, Gus Hellier confirmed that it was Coillte that had made the application.

The Woodland League have also noted that there are several inaccuracies and incomplete comments in the application. In the application it is stated that there is “an accredited or preliminarily accredited FSC Forest Stewardship Standard applicable to the territory concerned”. However, this is not the case. The current FSC standard for Ireland is the second draft standard – and for many reasons this is neither accredited not preliminarily accredited by FSC International.

It is also required that in the application, programmes to identify alternatives to pesticide use have to be described. This application fails to do that – it states some organisations that are carrying out research, but does not describe what this research is or any outcomes of the research.

It is our hope that everybody reading this will respond in the negative to the derogation application – i.e. that everybody will refuse to allow Cypermethrin to be used in Irish forestry. Below is a submission on the derogation written on behalf of People Against Pesticides. People Against Pesticides have given permission for people to use any/all information contained in their submission. Also included below are several other submissions that have been made by organisations and individuals.

It is our understanding that the closing date for submissions is the 6th of October, though we are awaiting confirmation on this.

The person in FSC International that will be reviewing the derogation is Frank Katto. We suggest that in making a submission to Gus Hellier (ghellier@aoilassociation.org), you also copy Frank Katto (f.katto@fsc.org) in on the submission. A questionnaire that was sent by Gus Hellier is included below.

Please respond and stop this chemical from being used in Irish forestry.


==========================================================

1(a). DEROGATION APPLICATION BY COILLTE

Below is the application for derogation to use Cypermethrin, requested by Coillte and made by Soil Association/Woodmark. This is due to be sent to FSC international along with the submissions that are made. It is therefore very important that we get as many submissions made as possible.

Formatting has been altered to suit the newsletter.

FSC-TPL-01-002 Application for a derogation to use a highly hazardous pesticide

Name and contact details of certification body requesting derogation:
Woodmark
Soil Association
Bristol House, 40-56 Victoria St
Bristol BS1 6BY, UK
T: 00 44 (0) 117 914 2435
F: 00 44 (0) 117 314 5001
W: www.soilassociation.org/forestry

Active ingredient for which derogation requested:
Cypermethrin

Geographical scope of requested derogation:
Republic of Ireland

Is there an accredited or preliminarily accredited FSC Forest Stewardship Standard applicable to the territory concerned?
Yes

Requested time period for derogation:
(nb Derogations shall normally be issued for a five-year period. There will be a presumption against renewal of a derogation after the expiry of the five-year period).
5 years

1. Demonstrated need
Need may be demonstrated where:
- The pesticide is used for protecting native species and forests against damage caused by introduced species or for protecting human health against dangerous diseases, OR
- Use of the pesticide is obligatory under national laws or regulations, OR
- Use of the pesticide is the only economically, environmentally, socially and technically feasible way of controlling specific organisms which are causing severe damage in natural forests or plantations in the specified country (as indicated by consideration, assessments and preferably field-trials of alternative non-chemical or less toxic pest-management methods)

Explain how the proposed use complies with the specified criteria for need, including the consideration of alternatives which do not require the use of pesticides on the FSC list of ‘highly hazardous pesticides’:
The large pine weevil can be expected to infest most, if not all, conifer restocking sites. Delaying restocking until the insect population has subsided leads to excessive competing vegetation cover.
While research is in progress both here (Maynooth College, NUI) and in co-operation with the Forestry Commission in the UK through an Interreg Wales project on natural enemies, no such pest management option has yet emerged for operational use.
The identification of candidate insecticides, their authorisation by the Regulatory Authority and their subsequent development into operational use are long and arduous processes. Once an insecticide is adopted, stability in its use is essential to ensuring safe use and confidence in the product.

2. Specified controls to mitigate the hazard
The derogation shall specify the controls that will be implemented to mitigate the hazard associated with the use of the pesticide, for example restrictions related to weather conditions, soil types, application method, water courses, etc..
If the specified formulation is considered to reduce the level of hazard then the information on which this claim is based shall be presented, and the applicant shall provide credible independent, third party support for the claimed reduction of hazard.

Specify the controls that will be implemented to mitigate the hazard:
First here are the controls placed by the Regulatory Authority to ensure operator and environmental safety. Secondly, hazard is reduced through the use of dipping; spray application through mechanical planters at time of planting; and, standard operating procedures for directed manual spraying. In addition, protocols are in place for the protection of the public.

3. Programme to identify alternatives
The application shall describe the programme(s) which are in place in the territory concerned or which will be put in place during the period over which the derogation will be applicable, designed to identify alternative pest control methods which do not use highly hazardous pesticides.

Describe the programme(s) that are in place to identify alternatives:
Research is in progress both here (Maynooth College, NUI) and in co-operation with the Forestry Commission in the UK through an Interreg Wales project on natural enemies.

4. Stakeholder support
All applications for derogations shall include evidence that the application is supported by social, environmental and economic stakeholders in the best interests of promoting FSC’s goals in the territory concerned. It is the responsibility of the applicant to present this evidence in support of their application (see summary of procedures in Section 8, below).
The level of stakeholder support required will be evaluated taking account of the geographical scope of the derogation, the justification of need, and other factors include in the application such as the strength of the programme to identify alternatives, and the level of controls to mitigate the identified hazards.
A written letter of support by the Board of Directors of the FSC National Initiative for the territory concerned shall normally be considered sufficient evidence of national stakeholder support for the application.

Describe the consultation that has taken place and summarise the results:
[WLL note: consultation is ongoing]

Contingency plan to eliminate use of the pesticide during the derogation period
Derogations shall normally be issued for a five-year period. There is a presumption against renewal at the end of this five-year period unless it can be clearly demonstrated that the programme to identify alternatives has been fully implemented but has failed to identify an acceptable alternative in the available time.
Forest managers seeking certification under an approved derogation should therefore ensure that they have a contingency plan in place to eliminate use of the pesticide prior to the end of the derogation period. If a derogation is not renewed, the continued use of a highly hazardous pesticide after the expiry of the derogation would be considered a major non-compliance and would lead to the withdrawal of the certificate.
As a condition of use of a derogated pesticide, forest managers shall record quantitative and qualitative information about their use of such a pesticide, and this information shall be included in the certification body’s evaluation reports and in all subsequent surveillance reports.
Compliance with these requirements would need to be demonstrated by an applicant for certification at the Forest Management Unit (FMU) level and be verified by the certification body prior to the issue of a certificate. However, this evaluation is independent of the decision to issue a derogation for use of a pesticide over a geographical area.


==========================================================

1(b). QUESTIONNAIRE TO BE COMPLETED FOR SUBMISSION ON THE DEROGATION

CHEMICAL DEROGATION APPLICATION CONSULTATION RESPONSE FORM

PLEASE COMPLETE ALL SECTIONS AND USE ADDITIONAL SHEETS IF NEEDED

Chemical derogation application consultation response form for:
Republic of Ireland , 2006

Please return this form to Gus Hellier at:
Soil Association Woodmark, Bristol House, 40-56 Victoria Street, Bristol BS1 6BY. UK
Email:ghellier@soilassociation.org Fax: 0044 117 925 2504

Your Name:
Organisation/Affiliation:
Contact Details:

Chemical Name: Cypermethrin
Do you agree with the derogation: Yes/No
If no please explain why:


==========================================================

1(c). PEOPLE AGAINST PESTICIDE SUBMISSION

Your Name: Mr. Ciarán Hughes
Organisation/ Affliation: People Against Pesticides
Contact details: Caherawoneen, Kinvara, Co. Galway, IRELAND ciaran_hughes@yahoo.co.uk

Chemical Name: Cypermethrin
Do you agree with the derogation application?No
If no please explain why: Please see enclosed information

Gus Hellier, A Chara,

I am responding on behalf of People against Pesticides, and Irish NGO and the only pesticide action group in Ireland. PaP has been involved in the FSC process in Ireland since its inception.

I am going to divide my response into two sections, the first dealing with Cypermethrin as a chemical, the second dealing with the application for derogation.

Coillte Teoranta own over 99% of the certified forests in Ireland. It is therefore reasonable to assume that the derogation will benefit Coillte more than any other forestry company based in Ireland. However, the points made below, while they may directly refer to Coillte, also apply to all other certified forests in Ireland.

1. PaP wishes to make the following observations on the pesticide Cypermethrin:
1. Cypermethrin is highly toxic to fish and water insects ciaran_hughes@yahoo.co.uk. Ireland is already in court over water pollution relating to forestry, most notably in relation to the Freshwater Pearl Mussel [2-5]. There is a partial moratorium on Coillte’s felling policies in place in Counties Donegal, Galway and Mayo because of this. Allowing the use of further chemicals that damage aquatic life will exacerbate the problems that already exist with forestry operations damaging waterways.
2. The median lethal concentration of Cypermethrin for most fish is less than 5 parts-per-billion, and can have serious sub-lethal effects on fish at just 0.5 parts-per-billion 2006-03-03 08:33:34 (i.e. the LC50 of Cypermethrin is 8.3 μg/l. Water insects are affected/killed at similar concentrations. Thus, by FSC standards (FSC-GUI-30-001), Cypermethrin has “Acute toxicity to aquatic organisms”.
3. Cypermethrin is a broad-spectrum insecticide. Use of Cypermethrin will cause damage to insect life outside its intended target, which alone is the large pine weevil.
4. The fact that Cypermethrin is highly toxic to fish and other aquatic organisms, and that a large percentage of Coillte Teoranta’s forest estate is on wetlands which drain into streams, rivers and lakes, means that the effects of the pesticide application will be apparent beyond its intended use.
5. Cypermethrin is also highly toxic to bees ciaran_hughes@yahoo.co.uk. The bee population in Ireland is already in serious decline, as reported in 7d848c380f082c9fec60aedb3f17829e. By granting permission to use Cypermethrin, the bee population will be further threatened, and, again, the effects of the pesticide application will be apparent beyond its intended use.
6. Cypermethrin is highly toxic to the earth worm, an essential creature for the stabilisation of soil quality 1, and, again, the effects of the pesticide application will be apparent beyond its intended use.
7. Cypermethrin also has negative impacts on plant life [11-15], which is surprising and a severe negative impact considering that it is an insecticide, thus further demonstrating that the use of Cypermethrin will have effects beyond its intended use, which is for the control of the large pine weevil.
8. Tests have shown that Cypermethrin damages genetic material in Rats [9, 10].
9. The US Environmental Protection Agency classifies Cypermethrin as a possible human carcinogen. Thus, by FSC standards (FSC-GUI-30-001), Cypermethrin has some carcinogenicity.
10. Resistance develops quickly in insects that are exposed to Cypermethrin [16-18]. It is intuitive that if the large pine weevil is exposed regularly to Cypermethrin, it will become immune.
11. The majority of pesticides that contain Cypermethrin also contain other substances that are often classed as “inert”, such as
o Crystalline silica (The International Agency for Research on Cancer has classified evidence about its ability to cause cancer as sufficient in animals and limited in humans.) [19]
o Ethylbenzene (causes throat irritation, eye irritation, damage to liver and kidneys, dizziness, and incoordination. In laboratory tests, exposure to ethylbenzene has caused foetal resorption, retardation of foetal skeletal development, and extra ribs in foetuses.) [20]
o Xylenes (solvent that cause nose, throat, and eye irritation, labored breathing, lung inflammation, nausea, vomiting, mild liver toxicity, impaired short-term memory, and hearing loss in exposed humans and/or laboratory animals. In laboratory tests, xylene exposure has also caused reduced fertility, increased number of fetal resorptions, increased incidence of cleft palate, and decreased fetal weight. Xylene inhalation has been associated with an increased frequency of leukemia in solvent-exposed workers. It may be a cocarcinogen; exposure to xylenes enhanced the number of skin cancers caused by other carcinogens. It has the potential for bioaccumulation in human fat tissue.) [21]
o Trimethylbenzenes (highly volatile solvents that cause skin and eye irritation, nervousness, tension, bronchitis, disruptions of blood clotting, headaches, fatigue, dizziness, and loss of consciousness.) [22]

2. PaP wishes to make the following observation on the application to use the pesticide:
1. It is claimed that there is an “accredited or preliminarily accredited FSC Forest Stewardship Standard applicable to the territory concerned”. This is not the case. The current draft in Ireland is IFCI Draft Number 2, and this is not accredited by FSC International. Therefore the application should be invalid.
2. The protocols for the protection of the public are not outlined in the application. Therefore the application should be invalid.
3. A description of the programmes in place for researching alternatives is required. However, the application states that “‘Research is in progress both here (Maynooth College, NUI) and in co-operation with the Forestry Commission in the UK through an Interreg Wales project on natural enemies”. This does not describe what the research is. Therefore the application should be invalid.
4. The use of pesticide in Coillte’s monocultures can not be considered last resort. The use of monoculture conifer plantations leaves the trees prone to infection by disease and pest by accelerating the spread of the disease/pest. If Coillte increased their native mixed planting, it would reduce the risk from infection by disease/pest, and thus reduce the need for pesticide application.
5. It is stated that “hazard is reduced through the use of dipping”. However, the dipping method has caused controversy and conflicts with the Services, Industrial, Professional and Technical Union (SIPTU) who represented over 450 Coillte workers. SIPTU claimed that this form of treatment poses significant health and safety concerns [24, 25].
6. The application states that the need for pesticide usage is demonstrated where “Use of the pesticide is the only economically, environmentally, socially and technically feasible way of controlling specific organisms which are causing severe damage in natural forests or plantations in the specified country (as indicated by consideration, assessments and preferably field-trials of alternative non-chemical or less toxic pest-management methods)”. The applicant states that “The large pine weevil can be expected to infest most, if not all, conifer restocking sites. Delaying restocking until the insect population has subsided leads to excessive competing vegetation cover”. The logic that pesticide application is the only option is not sound. The clearing of the site from vegetation prior to planting is an alternative, and the use of native trees on the right sites would be considered an alternative.

Therefore, it should be obvious to the Soil Association and FSC that
1. The demonstrated need for the use of Cypermethrin is based on the massive overuse of foreign exotic conifer plantations in Ireland. Additionally, the demonstrated need states that competing vegetation is a problem – we have given one alternative. It also fails to demonstrate the need for the use of the ‘highly toxic’ pesticide Cypermethrin specifically.
2. The specified controls for the pesticide application are in question, and have led to a dispute between the trade union SIPTU and Coillte Teoranta. The application does not identify controls that are in place to mitigate the environmental and health hazard associated with the chemical pesticide usage.
3. The application states that there are programmes in place to identify alternatives. However, the very practical alternatives such as manual/mechanical clearing and increasing the native planting rate have apparently been ignored.
4. It has to be noted that “A written letter of support by the Board of Directors of the FSC National Initiative for the territory concerned will normally be considered sufficient evidence of national stakeholder support for the application” will not be sufficient in the case of Ireland. There are only three directors representing a two environmental NGOs, An Taisce and Friends of the irish Environment, a single self-title “State Environmental NGO” on the Social Chamber, the Woodlands of Ireland, and Coillte Teoranta on the Economic Chamber. A letter from these directors should not be considered “sufficient evidence of national stakeholder support for the application”. Additionally, a letter from the whole steering committee should also not be considered “sufficient evidence of national stakeholder support for the application”. On the Steering Committee, only three NGOs are represented on the Environmental Chamber – An Taisce, VOICE and FIE. Only one is represented on the Social Chamber – Woodlands of Ireland.

Considering the above 21 points, People against Pesticides vehemently oppose the derogation to allow the use of Cypermethrin in certified Irish Forestry.

Is mise le meas

Ciarán Hughes
People against Pesticides

References:

1. United States Environmental Protection Agency, Cypermethrin Fact Sheet, 1989.
2. Case C-392/96, Commission of the European Communities v. Ireland (1999)
http://curia.europa.eu/jurisp/cgi-bin/form.pl?lang=en&Submit=Submit&alldocs=alldocs&docj=docj&docop=docop&docor=docor&docjo=docjo&numaff=C-392%2F96&datefs=&datefe=&nomusuel=&domaine=&mots=&resmax=100
3. Case C-418/04, Commission of the European Communities v. Ireland (Pending)
http://curia.europa.eu/jurisp/cgi-bin/form.pl?lang=en&Submit=Submit&alldocs=alldocs&docj=docj&docop=docop&docor=docor&docjo=docjo&numaff=C-418%2F04&datefs=&datefe=&nomusuel=&domaine=&mots=&resmax=100
4. Case C-282/02, Commission of the European Communities v. Ireland (2005)
http://curia.europa.eu/jurisp/cgi-bin/form.pl?lang=en&Submit=Submit&alldocs=alldocs&docj=docj&docop=docop&docor=docor&docjo=docjo&numaff=C-282%2F02&datefs=&datefe=&nomusuel=&domaine=&mots=&resmax=100
5. Communication to author from Liam Cashman, European Commissioner, July 20 ‘06
6. World Health Organization (WHO). 1989. Cypermethrin. Environmental Health Criteria 82. Geneva, Switzerland: United Nations Environment Programme, International Labor Organization, and WHO.
7. The Irish Examiner, August 16 ’06, Declining bee population will mean changes to countryside
8. Roberts, B.L. and H.W. Dorough. 1984. Relative toxicities of chemicals to the earthworm Eisenia foetida. Environ. Toxicol. Chem. 3:67-78.
9. Amer, S.M., et al. 1993. Induction of chromosomal aberrations and sister chromatid exchange in vivo and in vitro by the insecticide cypermethrin. J. Appl. Toxicol. 13:341-345.
10. Bhunya, S.P. and Pati, P.C. 1988. Genotoxic effects of a synthetic pyrethroid Insecticide, Cypermethrin, in mice in vivo. Toxicol. Lett. 41:223-230.
11. Megharaj, M., et al. 1987. Influence of cypermethrin and fenvalerate on a green algae and three cyanobacteria isolated from soil. Ecotoxicol. Environ. Safety 14:142-146.
12. Tu, C.M. 1983. Effects of pyrethroid insecticide seed treatments on Rhizobium japonicum and its symbiotic relationship with, and growth of soybean. J. Environ. Sci. Health B18:369-378.
13. Tu, C.M. 1991. Effect of some technical and formulated insecticides on microbial activities in soil. J. Environ. Sci. Health B26:557-573.
14. Kara, M., et al. 1994. Cytogenetic effects of the insecticide cypermethrin on the root meristems of Allium cepa L. Turk. J. Biol. 18:323-331.
15. Atale, A.S., et al. 1993. Mitodepressive and chromotoxic effects of some agrochemicals on chili. J. Maharashtra Agric. Univ. 18:30-31.
16. Yu, S.J. 1991. Insecticide resistance in the fall armyworm, Spodoptera frugiperda (J.E. Smith). Pest. Biochem. Physiol. 39:84-91.
17. Kerns, D.L. and M.J. Gaylor. 1992. Insecticide resistance in field populations of the cotton aphid (Homoptera: Aphididae). J. Econ. Entomol. 85:1- 8.
18. Martinez-Cabrillo, J.L., et al. 1991. Responses of populations of the tobacco budworm (Lepidopterea: Noctuidae) from northwest Mexico to pyrethroids. J. Econ. Entomol. 84:363-366.
19. U.S. Dept. of Health and Human Services. Public Health Service. 1991. Sixth annual report on carcinogens. Summary. Research Triangle Park: National Institute of Environmental Health Sciences.
20. U.S. Dept. of Health and Human Services. Public Health Service. Agency for Toxic Substances and Disease Registry. 1990. Toxicological profile for ethylbenzene. (November.)
21. U.S. Dept. of Health and Human Services. Public Health Service. Agency for Toxic Substances and Disease Registry. 1993. Toxicological profile for xylenes. (October.)
22. Sittig, M. 1991. Handbook of toxic and hazardous chemicals and carcinogens. 3rd edition. Vol. 2. Park Ridge, NJ: Noyes Publications. Pp. 1161-1162.
23. Coillte Social and Environmental Report, 2003. www.coillte.ie
24. Irish Times, April 13 ’06 – “Concerns over tree treatment”
http://www.ireland.com/newspaper/ireland/2006/0413/3231942574HM2BOLDS.html
25. Irish Independent, April 13 ’06 – “Workers bugged by insect strategy”
http://www.unison.ie/irish_independent/stories.php3?ca=9&si=1596854&issue_id=13913


==========================================================

1(d). OTHER SUBMISSIONS ALREADY MADE

SUBMISSION BY STEVEN HARRINGTON

Your Name: Steven Harrington
Organisation/Affliation: Private citizen; former member, FSC-US Board of Directors; Former member, FSC-US Technical Standards Committee; Coordinator, FSC-US Southwest Regional Standards Working Group
Contact details: Black Ball View, Knockroe East, Allihies, Beara, West Cork, Ireland 011-353-27-73136scribes1963@eircom.net

Chemical Name: cypermethrin
Do you agree with the derogation application? NO
If no please explain why:
A dominant system of even-aged exotic monoculture flies in the FSC of everything for which FSC has stood. The plantation system in Ireland is the worst choice for forestry from a long-term standpoint – the average person on the street despises the spruce plantations; environmentalists deplore their impact; and they are an insult to the art and science of forestry. The derogation is being requested in order to stuff the square peg of exotic even-aged monoculture into the round peg of FSC certification. The chemical is on the violations list for a reason – if the forestry system requires it to work, how can the system be said to be providing a benefit? It is providing harm in this case. The fact that the derogation is being requested 5 years on into Coillte’s certificate is simply unacceptable.



SUBMISSION BY CAVAN LEITRIM ENVIRONMENTAL AWARENESS NETWORK (CLEAN)

Your Name: Christine Raab-Heine
Organisation/ Affliation: CLEAN (Cavan Leitrim Environmental Awareness Network) Ltd
Contact details: Greagh House, Kilmore, Dowra, Co. Leitrim. chheine@iolfree.ie

Chemical Name: cypermethrin
Do you agree with the derogation application? No
If no please explain why:

Dear Gus,

We are an environmental group operating mainly, but not only in the North West of Ireland. On behalf of CLEAN I wish to forward you our response to this application.

We are first of all puzzled that this derogation is sought for the whole of Ireland just because Woodmark was asked by an undisclosed party that such derogation should be applied for.

We have a serious problem with this application. To our knowledge Cypermethrin is an insecticide that is highly toxic to fish, bees, earthworms and even plants, and was, as far as we are aware, therefore banned by the Irish department of Communications, Marine and Natural Resources, from use in fish farming. The fact that the chemical is on the FSC list for highly toxic chemicals would underline its potential dangerous effects. We also learned from our search that Cypermethrin has carcinogenic effects, and that Cypermethrin products generally contain further additives that are of concern themselves, as they can cause cancer, damages to foetuses and various diseases to humans on exposure to the chemical.

We do not consider that the application sufficiently proves that the chemical needs to be used in forestry operations in the Republic of Ireland. We are afraid that the chemical will easily reach and pollute watercourses, as Irish plantations are frequently and in an unsystematic and unwatched manner planted in wetland areas and are prone to pollute water courses. It has quite often happened for example that public or group water supplies were polluted after clear felling of plantations. The same effect can easily happen from dipping and planting trees with Cypermethrin, or from spraying existing trees. We do not know of any case where active warning has been given to the public or to local authorities, before such spraying was undertaken. Currently, some forestry operations posts a notice on the site where they intend to spray. However, waterways can often carry the chemicals far into people water supplies.

The fresh water pearl mussel, a rare and protected species in Ireland, is already endangered by forestry practices such as clear felling. It is this practice that is the reason behind this application, as the larvae of the pine weevil tends to develop especially on clear felled conifer sites. A reduction in exotic conifer plantation, as well as a reduction in clear felling of large blocks of stands with following quick reforestation of the same exotic species on unsuitable land, that is difficult to access, could decrease the occurrence of the pest. The fact that exotic conifers were planted en masse on unsuitable wetland sites certainly has contributed to the spread of the pine weevil.

A different approach to forestry in Ireland would to our understanding diminish the problem, i.e. planting of native and mixed forests, as well as a widespread adoption of silvicultural regimes other than exotic plantations and clear felling. We are commonly told that this cannot be achieved in the short term. However, from the draft IFCI standard in its present form we have to conclude that it is also no long-term goal. One could indeed start to ask whether the pine weevil is not in fact doing a good job.

Apart from this there are other possible approaches to fight the pine weevil, such as for example trapping, which were not mentioned in the application.

In conclusion, we are of the opinion that Irish forestry at the moment does not deserve FSC certification anyhow. To accept this derogation application to allow Cypermethrin would make it an even greater farce. We request that this application is refused.

Sincerely

Christine Raab-Heine
Director

P.S. Why is an explanation not also asked where the response is YES?


==========================================================

2. LETTER FOR THE DE-CERTIFICATION OF COILLTE

We the undersigned wish to register our concern over the certification of tree plantations in our country by the FSC, which has granted a green label to monoculture plantations that have proven to be socially and environmentally destructive.

We are aware that the FSC is carrying out a review of its plantation certification policy, and it is our hope that the result of this process will be an end to the certification of these types of plantations by the FSC in the future.

Nevertheless, the fact remains that the FSC has already certified large areas of monoculture tree plantations in our country, and we believe that their certification should be re-assessed as part of the current review process in order to determine whether they deserve to keep the FSC label.

There are well-documented cases of plantations in our country that never should have received this label and clearly merit de-certification.

As proof that the current review process is genuinely aimed at a profound change in plantation policy, we are calling for the immediate de-certification of the plantations that most blatantly violate the FSC's mission and the re-evaluation of all other certified plantations in the country.

We therefore demand the immediate de-certification of the plantations owned by Coillte.

Sincerely,

Cavan-Leitrim Environmental Awareness Network, Ireland
Doolough Protection Group, Ireland
People Against Pesticides, Ireland
Friends of the Irish Environment, Ireland
GM-Free Ireland Network, Ireland
People Before Profit, Ireland
Save Saleen Wood Campaign, Ireland
Shell to Sea, Ireland
The Davitt League, Ireland
Woodland League, Ireland


==========================================================

3. ORGANISATIONS FROM 8 COUNTRIES DEMAND THE FSC TO WITHDRAW CERTIFICATES

PRESS RELEASE

September 1, 2006

Subject: Organizations from 8 countries demand the FSC to withdraw certificates

Organizations from eight countries demand the FSC to withdraw its “green label” to several plantation companies

Organizations from eight different countries are requesting the Forest Stewardship Council –a labelling scheme that certifies good forest management practices- to withdraw the FSC certificate awarded to a number of companies in Brazil, Colombia, Chile, Ecuador, Ireland, South Africa, Spain and Uruguay. The challenged certifications in all cases involve large-scale tree plantations which the organizations point out violate the FSC’s mandate of promoting “environmentally appropriate, socially beneficial, and economically viable management of the world's forests.”

“None of the South African plantations should have been certified by the FSC, firstly because plantations are not forests and secondly because of the serious negative social and environmental impacts they produce,” says Wally Menne, a member of the Timberwatch Coalition. Philip Owen, from GeaSphere adds that “In South Africa, Industrial Timber Plantations impact most severely on the grassland biome, which is the most threatened vegetation type locally. Surely –he adds- the FSC should not be sanctioning this destruction of the natural environment.”

In the case of Ecuador Nathalia Bonilla –in charge of the certification issue at the local NGO Acción Ecológica- is demanding the de-certification of some 20,000 hectares of pine and eucalyptus plantations established in the Andes by the Dutch FACE Foundation, as well as over 8,000 hectares belonging to Ecuadorian company ENDESA/BOTROSA, which has a long history of social and environmental crimes. “We have documented in detail the negative impacts of these plantations on the livelihoods of the affected indigenous communities and on their environment; now the obvious step is for the FSC to withdraw the certificate to these plantations.”

Marcelo Calazans, a member of the Brazilian Alert Against the Green Desert Movement, which campaigns against tree monocultures described as “green deserts”, states that “although we oppose the certification of all large-scale tree monocultures, we are demanding the de-certification of only three companies: Suzano-Bahia Sul,Vallourec & Mannesmann and Plantar. The reason for this is that the social and environmental impacts of these three companies are so well documented that it is obvious that the FSC must immediately withdraw its certificate.”

The transnational Smurfit Kappa has a long history of conflicts with local communities in the Colombian region where it operates. “We cannot understand how this company can sell its products under the FSC logo”, says Diego Alejandro Cardona from CENSAT-Friends of the Earth Colombia. “The company’s operations are probably economically viable”, states Cardona, “but it no way can they be described as being environmentally appropriate or socially beneficial. We therefore demand the FSC to cease providing it credibility through the use of its label.”

In the case of Spain, local organizations have been demanding for over a year the cancellation of the FSC certification to plantations company NORFOR. Antón Masa, from the Association for the Defence of the Ria of Pontevedra explains that the reason for the urgent cancellation of the NORFOR certification “lies in the serious deficiencies found in the certification report and the clear inadequacy of NORFOR’s management system with respect to FSC principles and criteria.”

Several organizations in Ireland are demanding the withdrawal of the FSC certificate awarded to Coillte’s 438,000 hectares of plantations. Ciaran Hughes, from the Woodland League says: “NGOs in Ireland that have campaigned for the decertification of Coillte have been dealt a serious blow with Coillte’s recertification earlier this year. Coillte practices have always fallen far too short of the FSC principles and criteria.”

“In Chile there are serious cases of companies that should have never received the FSC logo and that deserve to be de-certified. Such are the cases of Forestal Monte Aguila, belonging to CMPC (Mininco) and Forestal Bio (Forestal Arauco), that are severely questioned and whose certification does not take into account their environmental impacts and the territorial conflicts with indigenous Mapuche communities”, states Alfredo Seguel, from the Agrupación Konapewman and member of the working groups of the Coordination of Mapuche Territorial Identities (CITEM).

As respects to Uruguay, local organizations are demanding the de-certification of two national (COFUSA and FYMNSA) and two foreign (Finnish COFOSA and Spanish EUFORES) plantation companies. Ricardo Carrere, the author of the report “Greenwash: Critical analysis of FSC certification of industrial tree monocultures in Uruguay”, stresses that “none of those plantations should have been certified” and that “by certifying large-scale tree monocultures such as these, the FSC is weakening local struggles against them.”

The organizations involved in this activity have sent letters to the FSC Board and to the members of the Plantations Review Working Group demanding the withdrawal of the FSC certificate to all the above mentioned companies, on the basis that none of them comply with the FSC mandate.

For interviews:

In Brazil:
Marcelo Calazans
Brazilian Alert Against the Green Desert Movement
marcelo.fase@terra.com.br
+55 273 223 7436

In Colombia
Diego Alejandro Cardona Calle
CENSAT Agua Viva
bosques@censat.org
+57 1 3377709

In Chile
Alfredo Seguel
Coordination of Mapuche Territorial Identities
alfredoseguel@gmail.com
+5645 213313

In Ecuador
Nathalia Bonilla
Acción Ecológica
cbosques@accionecologica.org
+593-22-547-516

In Ireland:
Ciaran Hughes
Woodland League
ciaran_hughes@yahoo.co.uk
+353-87-9652992

In South Africa:
Philip Owen
GeaSphere
owen@soft.co.za
Mobile: 0730980867

In Spain:
Benito Andrade
Asociación pola defensa da Ría
bandrade@mundo-r.com
+34 636281252

In Uruguay
Ricardo Carrere
World Rainforest Movement
wrm@wrm.org.uy
+5982 4132989


==========================================================

4. THE RESISTANCE CONTINUES OUT WEST; A ROUND UP OF NEWS FROM ROSSPORT SOLIDARITY CAMP

A round up of news from Rossport Solidarity Camp and the Shell to Sea campaign; re-routed pipelines, plans by Shell to restart work, a meaningless recommendations from a government appointed mediator, thirteen months of blocking Shell and counting, a gathering at the camp and a wee walk to Dublin...

Photos available athttp://www.indymedia.org.uk/en/2006/08/348790.html

Shell intend to start work in September
Shell has announced that it intends to recommence works at the site of its proposed refinery at Bellanaboy, Erris Co Mayo this September. Work is scheduled to begin with the installation of Axonics water treatment systems. The proposed refinery site at Bellanaboy has been picketed for over thirteen months by local campaigners who have succeeded in stopping all work at the site since the Rossport five were imprisoned at the end of June 2005. Shell’s subcontractors have so far only succeeded in limited preparatory peat removal from the site, which is located on ex-Coillte (state forestry) land consisting of blanket bog. If built the proposed refinery would have a detrimental effect on the local environment and the community it sustains resulting in pollution of the currently clean air and water, negatively affecting health, livelihoods and wildlife. Local Shell to Sea campaigners and members of the solidarity camp vow to maintain the picket and to prevent any attempted work; there will never be a refinery at Bellanaboy!

Peter Cassell’s Report: avoiding the issues
Shell’s announcement came in the wake of the release of a report by Peter Cassell’s who was appointed by Minister Noel Dempsey to mediate between Shell and the Rossport five shortly after their release from prison last October. The report compiled at the request of Minister Dempsey after the collapse of mediation has been widely criticized as failing to address the key issues involved in the Corrib project and raised by Shell to Sea. It offered token recommendations, which served more to cloud the real issues than to deal with the glaring problems.

Re-routing the pipe?
The report’s main recommendation was the re-routing of the upstream pipeline to address the issues of proximity to housing. In a contrived attempt at reasonableness Shell announced that it now intends to re-route the contentious pipeline. The word ‘reroute’ however remains ambiguous. When pushed on Mid west radio station Shell deputy managing director Terry Nolan conceded that the upstream pipe might still could go through Rossport. Rerouting of the pipeline not only potentially moves the problem to another community but also fails to address the core demand of the campaign that is named Shell to Sea; namely that Shell processes the gas at sea.

Local development fund;
Among Cassell’s other recommendations was the establishment of a local development fund, the employment of people and purchase of services locally, local infrastructural enhancements, notably on roads. The suggestion of a ‘local development’ fund has been met with general contempt from local and national Shell to Sea organisers as representing little more than Shell throwing a few crumbs from the table. Shell and its consortium partners own 100% of our gas, they pay no royalties and the little tax (25%) can be written off against costs. One of the core demands of the campaign is the renegotiation of the ‘deal’ so that the gas benefits us instead of lining the pockets of a huge multinational corporation.

One of the most insulting and blatantly wrong parts of the report is the section where Cassells categorises the type of people in the local community. He asserts that he encountered three types of people in the area (i) those who support the project and have always done so, (ii) those who support the project but have genuine concerns, and finally (iii) those who are opposed to all development. The clear attempt to paint those who are fighting for the survival of their community as being opposed to development or as having concerns that are not genuine is contemptible. The portrayal of opponents of the current project as a vocal minority is also unfounded. Erris Shell to Sea recently conducted a door-to-door ‘canvas’ of over 2,500 homes in Erris handing out information on the project and its effects. The overwhelming response was one of support. Out of 2,500 homes approximately fifteen did not support the campaign. A poll conduced by a local newspaper last year found that 80% of those polled supported the demand of Shell to sea.

The Long Walk;
Local Shell to Sea campaigners, members of Rossport Solidarity Camp and supporters recently undertook an epic cross-country walk from outside Shell’s semi derelict compound in Rossport to Dublin city. Almost three hundred people took part in the walk along the way with eight people walking the whole way. The walk, which took just under two weeks saw campaigners walk over 300km stopping in towns along the way holding public information meetings, talking to people and handing out information about how Corrib affects us all. The walk ended in Dublin on Saturday 12th of August at the G.P.O. on O’Connell street. The overwhelming response encountered by walkers was one of support and solidarity.

Rossport Solidarity Camp August Bank Holiday Organising Weekend;
While some of us were tramping the roads to Dublin the Rossport Solidarity Camp hosted a weekend of organising on the August bank holiday weekend. The gathering followed on from our very successful one-year anniversary gathering on the June bank holiday. The gathering saw those interested in organising around social justice and environmental issues gather at the camp to help out with preparing the camp for winter and meetings about how to further the aims of the campaign, specifically raising the issue of the ownership and control of our natural resources. We are holding a building week from 18th –22nd of September. If you are interested in helping please get in touch. (rossportsolidaritycamp@gmail.com)

For more info see
www.shelltosea.com
www.indymedia.ie/mayo
www.struggle.ws/rsc


==========================================================

Continued athttp://www.woodlandleague.org/newsletter/index.php?itemid=57