Forestry

FIE publishes today a leaked copy of the EU Auditor's Report on Irish forestry. Together with the EU wide Auditor's Report
published on the Commission's website they show that 4.7 billion euros in funding allocated for forestry from 2000 - 2006 is doing virtually nothing to remove land from agricultural production while planting Ireland's valuable uplands and peatlands with poor quality conifers. Inflated claims for grants, bogus claims to qualify as farmers, and failures of assessment are documented in these pages. In 5 of the 7 projects visited in Ireland, the Auditors determined that the aid 'was called into question'. Coming at a time when Ireland is fighting cuts proposed to curb the abuses, the Audit Reports have been ignored by the Irish authorities.

Read our Press Release and our coverage in the Forest Network Newsletter 157, including follow up Parliamentary Questions. And see the Sunday Times, the only paper to cover the scandal in the English language to date.
FIE publishes today a leaked copy of the EU Auditor's Report on Irish forestry. Together with the EU wide Auditor's Report
published on the Commission's website they show that 4.7 billion euros in funding allocated for forestry from 2000 - 2006 is doing virtually nothing to remove land from agricultural production while planting Ireland's valuable uplands and peatlands with poor quality conifers. Inflated claims for grants, bogus claims to qualify as farmers, and failures of assessment are documented in these pages. In 5 of the 7 projects visited in Ireland, the Auditors determined that the aid 'was called into question'. Coming at a time when Ireland is fighting cuts proposed to curb the abuses, the Audit Reports have been ignored by the Irish authorities.

Read our Press Release and our coverage in the Forest Network Newsletter 157, including follow up Parliamentary Questions. And see the Sunday Times, the only paper to cover the scandal in the English language to date.
The Minister for Agriculture
Mary Coughlin, TD,
Kildare Street,
Dublin 2
29 November 2004

By fax only: 01 -6611013

RE: Planting on peatlands comprising up to 84% of Irish afforestation in the period 1990, 2000.

Dear Minister;

We attach a copy of European Environmental Agency's Spatial Analysis Group 'Revision of the assessment of forest creation and afforestation in Ireland'.

This revision, which was in part prompted by our organisation's questioning of the Agency's original figures produced in May of this year, suggests that planting on peatlands comprises up to 84% of Irish afforestation in the period 1990, 2000.

These figures are not in accord with the written Parliamentary Reply provided by your predecessor on 27 April 2004 when he stated that 'the information was not readily available'. He then suggested that 'peat and mineral soils have comprised 30% and 70%, respectively, of the area afforested since 1990'. We note in today's Irish Times that this figures is based on 'site visits' and that in fact your officials are expressing some surprise that satellite mapping can distinguish between peat and mineral soils.

It appears that your Department has not, in fact, compiled the simple information provided on page 5 of the grant application form distinguishing between peat and mineral soils. Would you therefore instruct your Forest Service to compile these figures and, in the interim, refuse grant applications for afforestation on peatbogs, given that this new information indicates that 98,519 hectares have been planted on peatlands between 1990 and 2000?

You will understand that our organisation and Irish conservationists in general take the gravest view of this situation. It appears that EU funding which was intended to take agricultural land out of production and increase our forest cover was instead used to plant some of our most valuable habitats with a monoculture of alien conifers producing the poorest grade of timber.

Aside from the lose of biodiversy represented by these plantings, claims of the sequestration benefits of Irish forestry are severely undermined by afforestation on our bogs, which are themselves already significant carbon sinks.

We look to you to you to take decisive and clear action to ensure the protection of Ireland's biodiversity against what, if it is true, must be a major abuse of European funding.

Sincerely yours,



Tony Lowes,
Director, Friends of the Irish Environment



Attached: Land Cover Accounts based on CLC1990-2000
Revision of the assessment of forest creation and afforestation in Ireland

Spatial Analysis Group Note
20 July 2004

Land Cover Accounts based on CLC1990-2000
Revision of the assessment of forest creation and afforestation in Ireland

Provisional results on Corine Land Cover change 1990-2000 were presented publicly during the Bridging the Gap Conference in Dublin, 28-30 April 2004. One of the most striking findings was the conversion of coniferous to peatbogs during the period. An ancillary comment was that during the same period, land cover accounts show a slight decrease in forests areas, described in CLC as 311 Deciduous forests, 312 Coniferous forests and 313 Mixed forests, that have been interpreted as a loss of forest area.

Having been alerted by experts very soon after Dublin to the gap between our assessment and the national forest statistics of Ireland, we analysed our database further and came to the conclusion that our first interpretation was not correct, essentially because of insufficient attention to the CLC324 Transitional woodland shrubs. They are currently separated from the forests (trees being seen by the photo-interpreters when they are aged circa 10 years, with some variations according to species and conditions) although they are made essentially, in the case of Ireland, of recent fellings and new plantations. By adding CLC324 to the forest classes, we arrive at numbers quite close to what is considered by the foresters as the forest territory, which includes rotations and recent afforestation, as well as to their measurement of afforestation itself.

Therefore, we have modified the methodology of land accounts by including in "Forest creation and afforestation" (now coded LCF72) and "Withdrawal of farming with woodland creation" (now coded LCF61) the respective conversions of land to transitional woodland.

At the same time, we have revised the aggregated grouping of CLC and introduced a new class, so-called 3A Forests & transitional woodland. This solution will reconcile to some extent CLC and conventional forest statistics. It should be noted that this is still provisional, some adjustments being necessary after examining the situation in other regions (such as the Mediterranean or new Member States) where natural colonisation (out of the farmland abandonment context, explicitly described in LCF61) may happen. A decision may be taken if justified by the magnitude of the phenomenon.

Note also that this change in interpretation does not modify at all the finding that the area of 1990 coniferous forest felled during the period is slightly larger that the new areas identified as coniferous (more than around 10 years old). This means that fellings of coniferous trees have been greater than the "recruitment" of observable trees.

Far more importantly, it should also be noted that the "new" (and correct) definition of afforestation (which is not simply made up of trees more than 10 years but now also includes young shrubs) leads to a dramatic revision of the assessment of the peatbogs issue. The amount shifts from 30000 ha ("old coniferous only) to 98000 ha (total afforestation of peatbogs). Of course this issue has to be understood in an historical perspective, taking into account the extensive deforestation of Ireland in the 18th century and the potential of the overall landscape. However, as stated by the Forest Ecosystem Research Group of the University College of Dublin (http://www.ucd.ie/ferg/Research/Topics/Peatland_forests.html ) "Currently, about half the area of plantation forest in Ireland is on peatlands. Historically, these ecosystems were treeless, so afforestation, with drainage and fertilisation, represents a major change for these landscapes."

It may have consequences for fauna, flora and water, both directly and as a consequence of change in landscape patterns and diversity. In particular, afforestation of peatland happens often not only in broad peat lands but also in areas where peatbogs represent only small inclusions. As for the amount, the land cover accounts show that forest creation and afforestation on peatbogs ranges up to 84% of the total afforestation during the 1990-2000 period.

ENDS

We submit that the subject application requires a Waste Licence, a license to extract water and an Environmental Impact Assessment. If our grounds are accepted by your authority, a further planning application and public advertisements would be necessary.

The information provided is insufficient for the planning authority to make a land use decision on the contaminated soil that exists on this site or the potential of the proposed alternative treatment to cause pollution and/or a danger to public health.
The Secretary,
The Planning Authority
Offaly County Council,
County Offaly
13 February, 2004


Re:
Offaly County Council 04/60
Retention of Sawmill and ancillary activities, expansion of existing buildings and activities.
Leap townland, Roscrea, County Offaly.


Dear Secretary,

We submit that the subject application requires a Waste Licence, a license to extract water and an Environmental Impact Assessment. If our grounds are accepted by your authority, a further planning application and public advertisements would be necessary.

The information provided is insufficient for the planning authority to make a land use decision on the contaminated soil that exists on this site or the potential of the proposed alternative treatment to cause pollution and/or a danger to public health.

The application includes the retention of contaminated land which the applicant proposes to cap. Contaminated soil is waste as defined under European law.

The application indicates that there are '13 metres' of contaminated soil and the developer intents to 'cap' this with concrete. This figure is meaningless as no volume of contaminated soil is given. On the information available, we would suggest that the quantity of waste to be retained exceed relevant thresholds in the EIA Directive and Regulations.

Therefore an application for retention of severely contaminated soil on site which may be a source of continuing pollution of groundwater should be subject to EIA as a sub-threshold development.

This retention of contaminated soil on site must be fully considered. We note that retention applications are outside the definition of licensable activities for which IPC licences are available and even if such licenses were available we refer you to the Inspector's Report in the Boards previous refusal for retention at this location:

Under the 2000 Planning Act, the Inspector noted that it is not sufficient for the first party to rely on the existence of an IPC licence in relation to environmental matters. The Board must make a land use decision based on all relevant factors, including environmental factors. [Inspector's Report, 13.8.6, PL 201394.]

In this regard, we would respectfully draw the planning authorities attention to the explanation of the applicant that for the failure to provide evidence of the levels of contamination in water in boreholes. The applicant states that that the percentage compliance of the results recorded could not be calculated due to the fact that no emission limit values has been set for surface water or groundwater emissions from the site in the IPC licence.

Further, the application contains no or insufficient information on the impact of copper and other process effluents on the proposed reedbed. Pesticides in Tanalith E, which is now being used as an alternative to Tanalith CCA includes Copper and boric acid (LC 50 100mg/l). Both of these are phytotoxic. [Tebuconazole and propiconazole (LD 50 1700 - 4000 mg/kg) are also constituents.]

Yet Appendix 6 states 'none of the constituents of Tanalith E are considered toxic or potentially harmful at levels present in the treated timber'. The question is not the levels of phytotoxic or other chemicals in the treated timber, but the potential of the process effluents to pollute the environment and the appropriateness of the mitigation measures proposed.

We attach the Material Safety Data Sheet. It states clearly that 'Tanelith E is toxic to fish and wildlife. Do not contaminate drains, sewers, or other waterbodies with the product or used containers.' It also stated that it 'may be absorbed through skin and cause damage to internal organs.'

Our Inspector was unable to locate on the files available from the Local Authority any details as to the size and location of the proposed reedbed(s). The flow rate of effluent to the proposed reed bed does not appear to be given. Without this information the suitability and effectiveness of this type of water treatment cannot be ascertained.

Appendix 6 also states: 'It is not considered necessary to monitor for the pesticides or herbicides [contained in Tanalith E ] at any of the monitoring points.' We suggest that independent monitoring must be carried out to ensure that if contamination of the groundwater occurs then mitigating measures can be implemented.

It is proposed that the contaminated groundwater is pumped out and filtered to remove the Chromium IV, and the 'cleaned' water could then be used in preservative preparation or discharged into D1, D2 or D3. We understand that a licence is required for the extraction of water from any water body including an aquifer. Our Inspector found no evidence in the planning application that such a license has been obtained.

For all of these reasons, we would urge the local authority to require both a Waste License and license for the extraction of water. Given the sensitivity of the site and the scale, nature, and planning history of the development, a full Environmental Impact Assessment should be prepared by the developer and submitted to the planning authority with the required public notifiaction.



Caroline Lewis


Attached: 'EU Court advisor says contaminated land is waste',
© Environmental News Daily

Material Safety Data Sheet, Tanaleth E





EU Court advisor says contaminated land is waste
Date: Friday, January 30 @ 08:03:05 CST
Topic: Papers Today


Contaminated land should be subject to EU waste rules once it is unfit for use and its owner is legally required to remove it, according to an advisor at the European court of justice. The opinion could have big implications for European contaminated land management practices if endorsed by the full court.

The court has been asked to rule in a case involving pollution of surrounding land by leaking underground petrol tanks at a Texaco filling station in Brussels. The Belgian capital's authorities say Texaco is responsible for disposing of the contaminated earth in accordance with the EU's strict waste disposal rules. Texaco argues that the land is not waste.

In her opinion for the court, delivered on Thursday, advocate general Juliane Kokott says the contaminated land is "presumed to be waste" once it "can no longer be used for the purpose it was intended". And it "must be considered as waste" once the owner is legally obliged to remove the land.

Ms Kokott says the land should be defined as waste even before it has been dug up - a potentially explosive interpretation that could mean large tracts of contaminated land technically become landfills. The logical legal extension is that they would require operating permits and would almost certainly breach the EU's landfill directive.

In a second part of the opinion the advocate general says it is up to Belgian courts to decide whether the station's owner or Texaco as the fuel supplier is responsible for the waste. But she drops heavy hints that the oil firm should be held responsible - because of its "economic power" over the station owner, because the owner was not allowed to modify the tanks without Texaco's permission, and because the leaks were apparently exacerbated by Texaco's failure to fill the tanks properly.

Follow-up: European court of justice http://www.curia.eu.int/, tel: +352 43031,
and opinion in case C-1/03
http://www.curia.eu.int/jurisp/cgi-bin/form.pl?lang=en&Submit=Submit&docrequire=alldocs&numaff=c-1/03.
© Environment Daily


Page 1
Tan E
MATERIAL SAFETY DATA SHEET
Koppers Arch Wood Protection
Issued: May 2001
Page 1 of 3
STATEMENT OF
HAZARDOUS NATURE:
COMPANY DETAILS
Company:
Koppers Arch Wood Protection (NZ) Ltd
Address:
265 James Fletcher Drive
8 Penn Place
NZFRI Campus
PO Box 22-148,
PO Box 6124
PO Box 6123
Otahuhu, AUCKLAND
CHRISTCHURCH
ROTORUA
Telephone Number:
(09) 276 3646
(03) 348 5379
(07) 350 1680
Emergency Phone No. 0800-623-000
IDENTIFICATION
Product Name:
TANALITH® E
Other Names:
Copper Azole, CuAz
Manufacturer's Product Code:
3485
Uses:
For use as a timber preservative for industrial vacuum pressure plants for
protection of timber against fungi, insects and termite damage.
U.N. Number:
3010
Hazchem Code:
2X
Dangerous Goods Class:
6.1
Toxic Substances Schedule:
4
Packing Group:
III
Proper Shipping Name:
Copper based pesticide, liquid toxic
PHYSICAL DESCRIPTION/PROPERTIES
Appearance:
Blue liquid with faint odour
Viscosity:
355cPs 25?C
Boiling/Melting Point:
> 149?C
Flash Point:
Not applicable
Vapour Pressure:
Not determined
Flammability Limits:
Not Applicable
Specific Gravity:
1.3 g/ml @ 20?C
Solubility in Water:
Forms micro emulsion
on dilution in water
pH:
? 10.0 Concentrate
Dilute 9.2 (50g/l H
2
O)
Other Properties:
May generate ammonia and oxides of carbon in a fire situation.
INGREDIENTS
Chemical Entity
CAS No.
Proportion %m/m
Copper carbonate
12069-69-1
12.3 % as Cu
Boric acid
10043-35-3
4.9 %
Tebuconazole
107534-35-3
0.49%
Monoethanolamine
000141-43-5
46 %
Di-2-ethylhexyl phthalate
117-81-7
< 0.2 %
Surfactants and defoamers
--
8.0 %
Water
7732-18-5
15.7 %
- May cause irritation to skin, eyes, respiratory system
and digestive system-



Page 2
Tan E
MATERIAL SAFETY DATA SHEET
Koppers Arch Wood Protection
Issued: May 2001
Page 2 of 3
HEALTH HAZARD INFORMATION
Health Effects
Acute Swallowed:
Harmful if swallowed.
Eye:
Potentially corrosive and irritating to eyes.
Skin:
May be absorbed through skin and cause damage to internal organs.
Corrosive and irritating to skin.
Inhaled:
Harmful by inhalation.
Chronic
Non-mutagenic in Ames test and Micronucleus test.
First Aid
Swallowed:
DO NOT INDUCE vomiting; give ¬? litre of milk to drink followed by water
sipped slowly. Contact a doctor or National Poisons Centre immediately.
Eye:
Remove contact lenses if worn. Apply continuous irrigation with water for at
least 15 minutes holding eyelids apart. Seek medical attention.
Skin:
Wash skin with plenty of water after contaminated clothing removed. If
irritation persists seek medical attention.
Inhaled:
Move to fresh air and keep patient warm and still. Apply rescue breathing if
required, seek medical attention.
First Aid Facilities:
Emergency shower, eyewash, hand wash, soap.
Advice to Doctor:
Treat symptomatically
NATIONAL POISONS CENTRE (03) 474-7000
PRECAUTIONS FOR USE
Toxicology Data
Ingestion :
Acute oral LD
50
(rat) > 740 mg/kg
Skin :
Acute dermal LD
50
(rat) > 2010 mg/kg
Dermal irritation (rabbit) : Positive
Exposure Standards
OEL Copper (mists)
1.0 mg/m
3
long term
OEL ethanolamine
7.5 mg/m
3
long term
OEL di-2-ethyl hexyl phthalate
5.0 mg/m
3
long term
OEL boron
1.0 mg/m¬? long term
Engineering Controls:
Vacuum pressure timber impregnation plants should be operated to
minimise exposure of people to the product and treatment solution.
Mechanical ventilation is recommended if working in enclosed spaces.
Personal Protection:
Use good occupational work practices. Avoid skin contact when handling
solutions or freshly treated timber. Wear chemical resistant gloves and
apron, overalls, work boots plus eye/face protection. Note Tanalith® E can
penetrate leather shoes. Remove protective clothing and wash exposed
skin with soap and water prior to eating, drinking, smoking or using toilet
facilities.
Wash protective clothing separate from household laundry.
DO NOT EAT, DRINK OR SMOKE WHEN USING THIS PRODUCT
Flammability:
No applicable.



Page 3
Tan E
MATERIAL SAFETY DATA SHEET
Koppers Arch Wood Protection
Issued: May 2001
Page 3 of 3
SAFE HANDLING INFORMATION
Storage and Transport
6.1, Harmful. Store under secure conditions; protect from acids.
KEEP OUT OF REACH OF CHILDREN
Spills and Disposal:
Dispose of surplus product and empty drums by method approved by local
Waste Disposal Authority. Use earth or sand to contain spillage. Collect in
steel/plastic container and remove to official disposal site.
Fire/Explosion Hazard:
The product is not flammable. Exposure to extreme heat may produce
fumes containing copper and mono-ethanolamine. Use dry chemicals, CO
2
or water spray. DO NOT use a water jet. Do not wash product into drains or
sewers.
OTHER INFORMATION:
Risk Phrases:
Harmful in inhalation.
Safety Phrases:
Harmful; Irritant. Irritating to eyes, respiratory system and skin.
Environmental Protection:
Tanalith® E formulated product is toxic to fish and wild life. Do not
contaminate drains, sewers or other water bodies with the product or used
containers.
Contact point:
0800-623-000
or - NATIONAL POISONS CENTRE (03) 474 7000
The information contained herein is given in good faith, but no warranty, expressed or implied is made.
Consult Koppers Arch Wood Protection (NZ) Limited for further information.


file http://www.lockwood.co.nz/pdfs/nz_tan_e.pdf.
http://www.google.com/search?q=cache:bCqPlPdd8nsJ:www.lockwood.co.nz/pdfs/nz_tan_e.pdf+tanalith+E+toxic&hl=en&ie=UTF-8
Accessed 13 February, 2004
The Forest Network Newsletter has published a reply from the European Environmental Agency to their challenge of the EEA's estimate that Irish forestry declined in area between 1990, 2000, just when Ireland was planting 15,000 hectares a year of tax free forestry with EU funding. The agency's corrected survey, they did not include forest under 10 years old - reveals a 'dramatic' correction of the amount of forestry on peatlands. The Corin maps show that 84% of forestry in this period was on Ireland's peatlands. This failed the purpose of the funding, to remove agricultural land from production and has irreparably damaged both habitats and carbon sinks.

Read FNN!

Read Our Letter to the Minister




The Forest Network Newsletter has published a reply from the European Environmental Agency to their challenge of the EEA's estimate that Irish forestry declined in area between 1990, 2000, just when Ireland was planting 15,000 hectares a year of tax free forestry with EU funding. The agency's corrected survey, they did not include forest under 10 years old - reveals a 'dramatic' correction of the amount of forestry on peatlands. The Corin maps show that 84% of forestry in this period was on Ireland's peatlands. This failed the purpose of the funding, to remove agricultural land from production and has irreparably damaged both habitats and carbon sinks.

Read FNN!

Read Our Letter to the Minister



At the Standish Sawmill in Leap, County Offaly, FIE has opposed the grant of a permission to retain and expand an operation that has a proven track record of polluting local groundwater through pressure treatment of timber with Chromium IV, arsenic, and copper [CCA]. Read our objection and commentary in this week's Forest Network Newsletter [FNN]. We also reprint in FNN Rachael's report on CCA. This is as blatant a case of planning abuse as FIE has encountered. See also Phoenix Magazine and our objection.
At the Standish Sawmill in Leap, County Offaly, FIE has opposed the grant of a permission to retain and expand an operation that has a proven track record of polluting local groundwater through pressure treatment of timber with Chromium IV, arsenic, and copper [CCA]. Read our objection and commentary in this week's Forest Network Newsletter [FNN]. We also reprint in FNN Rachael's report on CCA. This is as blatant a case of planning abuse as FIE has encountered. See also Phoenix Magazine and our objection.