Monday, August 31, 2020

Keep Bearing In Mind The Economic Value of Biological Resources

80% of all economic activity and actually all life depends on biodiversity and yet Dr Liam Lysaght of our NBDC says conservation remains chronically underfunded by Ireland's government and species are more threatened than ever. 

I have set up this consultancy to re-direct public contracts to conservation and to meeting sustainable development objectives.   

Green Business Consultancy

In July and August, Frances Micklem at Green Business Consultancy (that is me) helped with 10 and entered 5 tenders, paving the way to redirect public contracts to operators with an environmental focus. The first conclusion that partners Richard C Cooke, Diarmaid Mulcahy and I came to was that Ireland (and eventually the EU) need a new information management system that can gather biodiversity data - (what is biodiversity data? It is information on the quantities and quality of life ecological conditions in marine and fresh water habitats as well as for wildlife and insects on land. Fertility of the soil and potential for food security, through the agricultural green transition) It is one thing to say 'information is to be made freely available' but actually there has to be a way to analyse the data against the 17 sustainable development goals and in reference to the Local Government Climate Change charter and the EU directives. What we are developing are grounds to attract funding and grounds to refuse harmful developments and training on all matters relating to sustainability, from economics to organic growing.


Analysis of biodiversity data for planning applications and permissions.

At the moment, if anyone asks the question: what is the impact of, for example, a new supermarket on a town periphery? We are not yet ready to quickly answer about the species on the green field site or statistics of smaller shops going bankrupt in the wake of the development. We cannot yet demonstrate what impact the compulsory purchase of greenways through farmers' lands will have and how does it compare to, instead, a voluntary uptake by farmers, of expert guidance (of which we have many in Ireland, only waiting to be asked) and committing the same land to organic or regenerative agriculture. Or to horticulture. Or to orchards, or to 'set aside' or agro forestry, or whatever other productive but experimental best practice methods farmers know about, are interested in, or would like to try. 

Species Loss - Extinctions past, present and threatened

"The expansion of the human niche by various forms of conversion is geometrically related to extinctions" I work with the Footprints in Coal Museum in Co. Kilkenny, in Geology history, Ecology Field Studies and as a training venue. 

Leveraging the Environmental Science expertise - 2% of Ireland's farms are already farmed organically.

Most importantly we need before and after data, so we can monitor if changes to our planning and building are working. Seems obvious but biodiversity data could easily be compared already, at organic and non organic farms, production plants and businesses. 

Measuring Community Biodiversity Action 

We need to be able to measure the success of climate action. Biological diversity can be understood as Ecosystem Diversity, Species Diversity and Genetic Diversity -

You will be glad to hear that we don't need more technology, we need more people monitoring the natural world and recording sightings. In fact, I am pleased to announce that I have taken on the role of actually being that new IMS!  The analysis turned out to be beyond the scope of technology. As everyone knows deep down, software can be clever but it can be no more than conscience-free number crunching at best. What we need now are contracts to go to operators who are both competent but also determined to preserve the environment (who has not noticed the instability and extremes of our weather now?) . 

Climate Action Training Ireland

To this end, I have revisioned 8 tenders and submitted 5. There is no end to what we can do with the skills we already have. So please get in touch and I'll align your business to a green funding opportunity - even if the contract looks at first to be only open to big businesses, with apparently challengingly big technical and financial capacity. 

There are no problems only solutions!

Greening E-tenders

Your response for 173044:1 Biodiversity Training for Communities in Co. Longford submitted

Your response for 171229:1 Small Business Innovation Research (SBIR) IRELAND submitted

Your response for 173532:1 Provision of Music Advisory Services submitted

Your response for 173358:1 Design, development and delivery of a Climate Action Training Programme for Local Authorities submitted

Your response for 173111:1 Multi Supplier Framework for a Coaching Service for School Leaders and Leadership teams in Department of Education Recognised Primary and Post Primary Schools submitted 

Your response for 170401: Appointment of an Operator for the National Biodiversity Data Centre. 

Your response for 170783: Provision of Procurement Advice and Training to Local Authorities.

Your response for 171460: Development of Social Housing Schemes - Wexford, Waterford, Kilkenny and Laois

Dealing with pests!


Sunday, August 16, 2020

Planning Objections using Sustainable Development Goals

Dear Offaly Planning Office, 

I have been teaching the 17 Sustainable Development Goals for 8 years, as a way to guide thinking and decision-making, in relation to climate action Directives. I have applied them to the application to use 50 acres of land to build a slaughter house and processing plant by Banagher Chilling Limited and find definitively that it goes against every one of the EU’s 17 Sustainability Goals, as follows. It also goes against every aspect of the Programme for Government for planning, as follows. It goes against public will, as you have seen by other objections. It will not even achieve the one thing it is suggested that it might: ‘A new player’ to help level the beef producing playing field in Ireland; China is not a new player, this plan has been hatched with Larry Goodman, Quealy’s and Simon Coveney no doubt as ambassadors and trade negotiators. Also, this is an extension to an existing factory so they are already partnering with our meat industry, especially with an investment that big. 

A manufacturing plant for Asia will take none of the small farmers' sucklers because the dairy 'waste' calves (decide if you agree with that concept too) will be too cheap to refuse. The Irish meat bosses will still not pay for higher welfare/quality animals – what the small farmers produce and please confirm if there is anything in this application that commits Banagher Chilling to paying a higher rate and for a particular quality or weight. Chinese agriculture standards are not known to be higher than ours. It is generally thought that the Covid 19 started in a Chinese Wet Market. That is an open-air slaughter house and representative of the food safety standards that they will replicate here. There will be no benefit to your county’s employment, your farmers’ industry, your constituents’ health or your reputation as the 2ndtier of government, as we face into the most important decade of climate action we have. We have no reason to believe that their agency staff will be treated differently to ours in terms of exposure to abuse and illness, even in regard to protections that are in place for the rest of Ireland’s workforce. 


Please visit, unannounced, the existing factory before making a decision. One friend, an engineer, was seconded to a factory to mend a machine on the line. He was horrified by the blood bath that he faced. The staff had reached a level of complete indifference to the animals or themselves. Absolute filth and entrails covered faces and clothes, no longer even wiped off and the processing of animals starting before they lost consciousness. Therefore, I  encourage every person in a decision-making capacity to visit a slaughterhouse and only then decide if they are comfortable being complicit in a development like this; on grounds of the social, work, accommodation and natural environment crises; the inability to protect all 140 bullocks from witnessing the slaughter of the other ones, every day; the pay and PPE conditions for existing workers, the water footprint of the animals and facility, the carbon emissions from the processing and animals and the revised industrial land use. Invite other possibilities for that large tract of land that could do a lot of good, if used properly.


Please see this as your first chance to really weigh up environmental, social and financial indicators and impacts and use the backing of EU commitments and the programme for government to say no to damaging developments. 



I propose that the Sustainable Development Goals outline a simple and crucial way to reach good planning decisions.  I have answered in terms of the Main Goals 7 & 13, then the Goals that directly contribute to the main goals and then those that indirectly contribute to the main goals.


Main Goals:

7. Sustainable and Clean Energy: 

Does the planning application suggest that the developers intend to use renewable energy sources? Are there any commitments to SSE Airtricity – fully renewable electricity or independent, renewable energy such as solar panels or wind turbines on the large site? Or a bio-digester. The latter would be feasible if the cow dung, as they crap themselves, in the face of death (as anyone would) was harvested and used to generate energy.


 13. Climate Action:

There is no shortage of studies showing that beef production is the most resource-intensive kind of meat production. A 2014 study from Proceedings of the National Academy of Sciences, for instance, revealed that producing beef requires 28 times more land and 11 times more irrigation water to produce than the average of pork, poultry or other types of livestock.


Beef also comes with a major climate impact. Beef production releases five times more greenhouse gases than the average of other livestock categories. It also produces six times more reactive nitrogen, which is known to cause air and water pollution. And compared to foods like potatoes, wheat, and rice, beef production requires a whopping 160 times more land and produces 11 times more greenhouse gases Climate Impact of Beef.


Climate action commitments include a move away from animal agriculture towards diverse vegetable and grain crops and fruit orchards, when this expansion project is attached to contrary increases in the national herd. Climate action includes a push to organic practices and away from the chemical degradation of food, land and water. Does the application include reference to, or commitment to minimising, nitrates and other flavour enhancers, preservatives and pumping-up methods, in meat processing? Does the application involve a commitment to avoiding one-use plastics in packaging? What stages of the circular economy will be in place: 1) Ecodesign? 2) Production/Reprocessing- avoidance of waste? 3) Distribution - transport methods and footprint to Asia and contamination risk? 4) Consumption – will the factory planned encourage consumers to buy less but high welfare/ high quality beef - In line with a changing national diet to less meat. Repair/Reuse – This is an extension to an existing factory. Does the application describe how the old machinery will be re-purposed or disposed of? Will there be a discount or sweeteners to neighbours to help them tolerate the development? Any other environmentally sound practices included in the design?


Is the council somehow financially obliged to the company/developer and do you need help from Super Junior Minister, Pippa Hackett or Eamon Ryan on Climate, or perhaps Grace O’Sullivan MEP? Is there a way to leverage support for better regional decisions?


Direct Contribution:

6. Clean Water and Sanitation: 

Water footprint: 1kg of Beef requires 15,000 kg of water. 1litre of milk requires over a 1000litres of water. Please refuse permission on grounds of fresh water usage. How much water will they use per day to wash down the new expanded slaughter house and processing lines? Will there be any use of chemical cleaners? Is there a risk of sanitary conditions killing biodiversity in nearby ground water and streams? Where will their water come from? Is it a well? Is there an aquifer? How will it be managed? Is it a share well with the residential people’s home nextdoor?


9. Industry, Innovation and Infrastructure

Will they pay rates? Would they be tax exempt as a foreign investment? Animal agriculture is an industry that Ireland is committed to reducing. There is an agreement that blind growth  is unsustainable. This is part of a blind growth experiment, where dairy was increased to huge herds, with the inevitable necessity of producing an unwanted calf each year, to keep the mother producing milk for the industry.


An innovation would include things like using the manure from farm animals to build soil fertility. 


An innovation would be a slaughterhouse designed to facilitate Ireland’s reduced meat production and consumption; committed to only kill cattle at four, five, six, seven and 8 years old, to facilitate the stopping of breeding of more. As well, the storing and distribution of the last generation of cattle, for food, could be managed over ten years. They could repurpose the Chillers – cold stores of the existing operation, to hold the nation’s beef. That would genuinely raise the value of meat and consumers would be allowed a quota, for example monthly or at Christmas. 


Another innovation would be planting a mixture of hazel and cob trees on the 50 acres to yield a plant-based milk; a small, high value crop, a carbon absorbing woodland, a community amenity, any number of artisan local products from oils to desserts to protein-rich savoury meals. 


An innovation would be the same land-owner being supported in creating a biodynamic 50 acres, pooling all the expertise in regenerative, best practice farming production and creating a ‘smart’ social farm showcasing social housing to passive energy standards, sheltered growing spaces for growing, fibre-optic technology to protect human and wildlife from wireless technology. 


Draw down Green Deal money for all and any of these things, so everyone feels supported in doing something positive rather than selling their soul for some intensive slaughtering. No one really wants to do that, deep down, only the very top tier of businessmen, completely removed from the actual logistics of the operation, who are profiting.       


15. Life on Land

Notice and point out how symbolic it is that the factory and old people’s home are far away from other communities. These are both disconnections that need to be addressed to support life on land. The disconnection from food means that many people do not know where food comes from let alone what happens to young unwanted animals in intensive agriculture; calves, piglets, lambs, layers’ male chicks and ducks. 


Human life is affected by the genetically modified feeds, glyphosate-drenched grazing and grains that accumulate in animals and therefore the food chain, affecting human health. Does the planning application include a detailed list of additives that will be used in the processing of meat? Does that list include any of the list, shared by WHO as potentially carcinogenic? Was there a break down of how much of the carcass will go for human consumption and how and where the entrails will go for pet food processing. Peer reviewed reports show that 40% of all emissions come from the pet food industry and so regulation for that is going to be important too as it would increase, in line with the increased kill-rate. 

Calves reared for meat from the dairy industry are separated from their mothers before they get the cholostrum they need to build their immune systems so that multiple doses of anti-biotics are needed to manage pneumonia in their first months. In the planning application, are there any labelling or record of the amounts of pharmaceutical product traces, to be applied or kept, for the new factory? Could these be asked for? Should these be asked for? Do the managers show that they are conscious of minimizing antibiotics in the food chain, as they are rendering crucial antibiotics ineffective, through over use?


Other unsustainable, on-land issues include run-off, chemical and animal waste. The building application goes against the commitment to move away from concrete as a basic material. There are many better materials such as these. There is a new recycling plant ,Trifol, who make recycled plastic blocks, in Laois. But insist Trifol do not continue to put melted wax into the human food chain through fruit coatings. Tidy up the supply chain as you go and write stipulations into each permission (like the old requirement to put in a native hedge, but stricter).


What is the provision for the new meat factory workers going to be? Will they share appartments on site? Will they be all foreign nationals? Will they be paid the minimum wage? Will the factory provide accommodation and minibuses for agency workers off-site? Is there a risk of workers being obliged to work in sub-standard conditions for excessive hours, if the bosses plan to include board and lodgings for staff to their contracts. Will they have contracts?


Noise pollution: In order to kill and process a hundred and forty bulls every day, there is going to be constant balling. Is there sound proofing built into the design? Are there parameters for the hours the slaughter line can operate? Did the applicants consult the residents of the care home to listen to any anticipated concerns or to put their minds at rest that for example, the slaughter stops at 5pm for definite.  If not, why not?



17. Partnerships for the Goals.

Are there any obvious partnerships towards sustainability, within the application? Have the operators approached farmers and guaranteed a better price than the other few operators of the other many factories? I know that many Kilkenny farmers for example, will take their cattle to Donegal as they are more likely to get a fair price there than down the country. What agreements have been made? Has there been payments made or promised to the council indirectly for other work, or directly for the development? Will a local transport company get the contract to carry the beef to the airports? Or ports? Will there be any local distribution of meat? Would there be any partnership with local biodiversity groups or EPA in monitoring the site, through the build and on-going operations. If you give permission for a multi-million project, you will not be able to retract it, as the investment is too high. You can refuse it now on every ground and invite and incentivize better proposals.

Indirect contribution to the main goals: 

1.    No Poverty.

Every small farmer is living in poverty. The majority still owe for feed from last winter and some still from the previous winter. The week their EU payment comes in, it goes out to pay for agri-chemicals and veterinary jabs under the heading ‘health programmes’. None of it goes to the farmer to put back into the farm, for basic maintenance, let alone towards taking a risk on a greening experiment, like investing in a mixed meadow seed rather than a monocrop, rich rye – no use to biodiversity. Species rich farmland produces heavier, healthier livestock and produce more milk - Older farming generations describe them as ‘well ground’, ‘cae ysbyty’ (field hospital) in Wales, and ‘the shore land’ used to describe the partial fields beyond the grass leys along the coast in Scotland. Species-rich grasslands for unwell livestock could be explored and savings made on veterinary interventions. Information on plants for use as medicinal remedies include ethnoveterinary and traditional medicine and zoopharmacognosy, which is the study of self-treatment.


In the current factory culture, factories will not take a small herd when they are ready. They will often agree to take one animal at a time and are allowed to refuse and/or deduct value on grounds of the animal being too heavy. Rather than a greater income for a heavier animal as in the past, farmers are now actually penalized for bringing an animal that is heavier to process. In addition, a recent DAFM audit of factory weighing equipment suggested that over 80% of them were outside accuracy to the extent of being non-compliant. Therefore, the factories are fixing their machines to further devalue animals. There are also the legendary Friday meetings between the Irish meat bosses to set prices. Does the planning application outline how new operators are going to avoid collusion with these systems and the perpetuation of poverty for farmers. 


2.    Zero Hunger

This application has impacts on the food industry in Ireland and the food industry in Asia. Ireland is already in trouble with Europe for our ‘race to the bottom’ in terms of no animal welfare. Europe is already in trouble for it’s international trade in grain. In both cases, at the destination, the produce is flooding a market with cheap produce and undervaluing local or better-produced food and causing poverty. 

3.    Good Health and Well being

Health in terms of great physical health requires that we eat fresh, raw foods with an intact vitamin and mineral profile. The nutritional quality of food is lowered a bit by cooking but preserved by fermenting, dehydrating and cooking at low temperatures. Organic food may not look different or taste different or better. In fact it may look lack-lustre or even stunted or otherwise flawed but it is the key to health as it is the only food that has not been grown, using chemical fertilisers, pesticides, herbicides, fungicides or preserved with sulphites, nitrates and other e-numbers. These chemicals accumulate in the body: We cannot naturally eliminate them. We cannot actively detox from them. They disrupt our enzymes and other digestive processes and are linked to various serious illnesses. In a study of MEPs, 100% of them had Round Up in their urinary samples, suggesting four times the safe amount in their bodies. Only 2% of Irish farms run on organic principles, without the use of chemicals, therefore nearly every meat product that comes out of the new factory would come from an animal fed imported finishers and other feeds with un-regulated gmo, treated seeds and chemical fertilizers etc in them. There is a movement to make small farmers organic to meet the EU directive but leave the intensive producers and feedlot owners to continue without a limit on their herd numbers or limit to their chemical use.


Meat is also hard for the human body to digest. It might be traditional to eat lots of meat but animal proteins of any sort are the first thing a nutritionist would tell any patient to give up to allow their natural systems to recover. In China, it self, the government issued a directive in 2016 for consumers to cut their meat intake by 50%, on environmental grounds. This application to process beef for China goes directly against their efforts to reduce meat intake China and Asia's Beef Market



Recent months have shown, without doubt, that working in a meat factory is a degrading and dangerous occupation. No one is advocating for them. There is no regard for life. There is no PPE or other Health and Safety oversight. The environment is completely profit-driven, with employee retention, satisfaction, continue professional development, pay and accommodation not even being a factor in the business plan. Just because the planning application was probably in before the pandemic broke in Ireland, planning offices must incorporate the new ways of working and guidelines and not facilitate another major development.

There are several studies that connect working in slaughter houses with domestic abuse. There are several Irish factories where suicide is a recurring problem.   

4,Quality Education

There are Horticulture Fetac level 5 and Agriculture Fetac Level 5 with a major uptake in some counties of 500 new pig farm managers in training, while horticulture (fruit and vegetables, heritage seed and organic varieties seed saving, plant science, soil science are taught and sustainable designs  developed. In this beef processing plant, vets who have studied for upwards of seven years will be expected to oversee the slaughter and food scientists will spend their working life testing levels of salmonella, bochilism, ecoli and other microbial problems. The production line workers will be asked in stifling heat with extractor fans that may have to be reversed to stop the stench reaching the residential home, as happened in Quealy’s QK Meats. These workers will not be given opportunity to progress professionally, just fulfil their conveyor belt role with body parts, burgers or machinery maintenance or cleaning. It would provide the epitome of unmeaningful employment to educated and uneducated alike.     

4.    Gender Equality

It has come to light during the pandemic that there are a few women who work in meat processing plants and maybe some more again in quality control and testing. When considering this planning application, what is more important than equal employment opportunities is the whole supply chain. If local councils could take the lead in linking breeding and milking practices with exploitation, mothering and milk for the species’ own young, it would really help consumers turn away from meat and dairy. A planning refusal that stated that Offaly was not open to intensive farming operations or related services would help constituents differentiate between small farm produce as good and supermarket mass produced produce as not good. This is the sort of education that is mentioned in the programme for government, leading by example. Ie. The planning office can say this application has brought to light the many inconsistencies in our climate action and biodiversity loss response. We will have to refuse the application but also ensure that from now on, only organic milk, fairtrade coffee and free range organic beef and vegetables from local farms that are in transition – therefore not using agricultural fertilizers and chemical sprays but have not yet completed their 6 years for certification - are served in public buildings.


8.Decent work and economic growth

Many would argue that killing animals using the Halal method does not constitute decent work. Does the application state what killing method will be used? Halal is supposed to include two factors: a) the animal should be fully conscious when his/her throat is cut (no stunning or gassing prior to slaughter) b) the person who slits the throat should say ‘Allah’. You will understand that there will be a big uptake on the first part of this ‘sacred’ process as it saves money and time not to have to render animals unconscious before killing. The carbonated gas was also in short supply last year and probably has environmental implications. It is unlikely that the second part is adhered to at all. This Halal slaughter method is contrary to Irish Animal Welfare laws as it is extremely cruel and leads to chaos amongst animals partially bled out and some going in and being hung up for their throats to be cut and then others starting to be ‘processed’, made into cuts of meat, when the animal is still moving and hoping to live.


My anxiety that this will be an exclusively Halal operation is that only cows are mentioned. The Muslim market considers pigs dirty and so that could be why they are leaving them out. The planning office must have a commitment that animals will be stunned before slaughter or there will be both National and EU repercussions.   


Economic growth is not to be attached to animal agriculture as it is associated with having a negative impact with high nitrogen and phosphorous loading and emissions. Consider the climate instability already in Ireland. During the drought in 2018, there was also a storm and electricity supply was lost. This meant there were thousands of dairy cows contrived to produce 70litres a day each, when only 10 litres a day is normal. Think of the water they needed. Then think of the horrendous mastitis, pain and life-threatening situations for herds when automatic milking operations came to a standstill. 


The economic growth county councils need to be facilitating is a subsistence plus lifestyle, where each household has a manageable quota and competence in caring for land, vegetables, animals, other people and services related to those things. All planning permissions and spending should be connected to conservation. This is justified as 80% of all industries and economies, globally, depend on a natural source. Biodiversity is the foundation of all growth and sustainability. Protection of water, soil and biodiverse insects and plants, is the protection of the global economy. 


10, Reduced inequalities

This project would increase inequalities many times over as the meat industry will justify lower rates for carcasses, no further standards are being required. 


Old people (who are probably paying over €1000.00 a week for care and accommodation) will be subjected to the sounds of the death throes of over a hundred cattle a day, the grind of the machinery, the arrival and departure of lorries. Many of those elderly people know that the climate science is at the front of politics now. They will have tried to stop DDT and other chemical weapons that have since become metamorphosed into agricultural chemicals. If you give permission they will feel even more disempowered, knowing that a development so blatantly archaic and destructive has been allowed. It will prove to them that Ireland can’t look after the people, only the corporations. 


Do you expect pay inequalities to be addressed at all in this operation? We do know that there is an annexed community in China, working as slaves in industry. What integration does the planning application propose for staff and payment and holidays, sick pay and other statutory rights?


11. Sustainable cities and communities

Has the planning office communicated with the Elected Councillors on this? Talked to the Biodiversity officers? Looked at the EPA impact and considered the wider implications for the concerted effort towards joined up thinking and think global, act local – not in a trading way but in a way that acknowledges that China can’t produce its own cows as the air pollution is so bad, 

Digital connectivity, biodiversity, clean water, transport - regular


12, Responsible Consumption and Production. 

Having researched the Chinese and Asian meat industry further, you will notice that they talk of beef and veal in the same breath. Veal is not reared in Ireland, due to welfare issues with raising calves in isolation, in darkness and tied, in order to make their flesh white and non-muscled and sinewy. We do however live export calves as young as 31 days to the UK, France and Holland to raise for veal. You need to make sure that this project is not going to facilitate a new veal market in Ireland where farmers keep their originally discarded calves of dairy cows but in non-compliant environments to bring to this new Asian trade avenue.


14. Life below water

Animal agriculture run off is a killer in waterways, drifting along streams and coastlines, using up oxygen and suffocating and sickening a myriad of aquatic life. “Dead zones” are the unintended consequences of our agricultural system trying to generate as much profit out of the land as possible. An island producing beef for a country like China (that is 137 times its size) would surely count as a plan to 'generate as much profit out of the land as possible'. China, let alone the rest of Asia - the proposed market, has one billion more people than the United States who have 340 million and Ireland has four and three quarter million. Trading with a country like that should be seen as not in line National, EU or Chinese climate action Directives.

Dead zones describe areas where hypoxia is taking place – basically an area of water with decreased levels of oxygen. Dead zones fluctuate in size with the seasons and move with the tides, but their presence is essentially guaranteed in areas where excess nutrients from conventional agricultural operations enter waterways.

16. Peace justice and strong institutions.

 I'd like to say that I don't expect An Bord Pleanala or county council planning offices to work through decisions like this, goal by goal, priority weighting them and accordingly....but I do. If people don't know how to reason, prioritise or know enough about different sectors or financial, environmental or social impacts, then involve another department, phone a friend or phone me. I live and breath just and systematic reasoning. County councils can only be strong enough institutions to protect from corporations, if they require comprehensive planning applications, addressing each one of the sustainable development goals and if they don't, councils can invoke EU law and support via the above sort of considered and systematic reporting to accompany your letters refusing permission.  


Thank you, 

Best regards, Frances


Wednesday, August 12, 2020

Public Banking Queen - for Europe

An Epithet For Frances Micklem

 Like in the Trojan Wars, it looks like I am going to be given an epithet! Odysseus was referred to as 'Fleet of Foot'. Just this week I have been called 'Public Banking Queen', the 'Florence Nightingale of Etenders' and someone else said a 'Modern Day Robin Hood'. All of them pretty cool, I think and totally spot on. 

The following proposal that I sent to the EU Reform and Cohesion Commission, a fortnight ago, will explain why. If you're closer to home, already an expert in your field and you need someone to find and complete funding applications for your project, give me a shout. Frances Micklem, 083 144 3968. Green Business Consultancy. 

There's the LEAN business continuity grants going at the moment, from the Enterprise Board that I'll help you with if your company is bigger than 9 staff but I prefer to watch the public tenders. They are bigger money and it's where Ireland really needs leadership. We have a green transition on our hands and I intend to match the knowhow to the funding. Let the organic farmers train the farmers who must otherwise transition blindly. Let's fund the communities that love their locality and are motivated with ideas to clean it up and preserve it. 

I am providing a platform that sits over the etenders website. Whereas most people cannot face into the procurement process as there's so much writing, I absolutely love it. Between us, we can generate a proposal that ticks all the social, environmental, community engagement, job creation and energy saving and amounts to an irresistible and thoughtful strategy, buyers would be mad to pass up. 

Letter to the EU Commission For Cohesion and Reform

This is a request for Ireland to be the sixth pilot project for the Cohesion & Reform Commission. We are proposing a new Information Management System for the Global Biodiversity Information Facility, starting with Ireland’s National Biodiversity Data Centre. We will coordinate data analysis best practice from all the nodes and when it is fit for purpose, we will make it available for Europe-wide use as a (Green/Sustainability/Non-profit/Community) Public Bank Charter. It will address various economic, climate and social problems.

As the OECD Panel proposed, when the GBIF Biodiversity Data Centres were first started in 2001, they were to 

"enable users to navigate and put to use vast quantities of biodiversity information, advancing scientific research ... serving the economic and quality-of-life interests of society, and providing a basis from which our knowledge of the natural world can grow rapidly and in a manner that avoids duplication of effort and expenditure."

And the GBIF Secretariat then formed in 2001 have consisted in these four departments:

  • Participation and Engagement is responsible for operating the network of Participants and publishers, recruiting new members and enhancing the capacity of current ones.
  • Data Products is responsible for the quality and scientific value of the integrated data products produced by the GBIF network.
  • Informatics is responsible for data management, software development and the overall operation of the GBIF infrastructure.
  • Administration is responsible for maintaining both the network and the Secretariat's underlying operations and processes.


There needs to be a fifth department to interrogate the data to fulfill the following purposes, in its legislative context. 

1. The new IMS will allow all proposed developments to be analyzed for their impact on Biodiversity, water footprint etc.

2. Public spending/ EU funding can be justified by meeting a criterion, including equally-weighted financial, social and environmental benefits.

3. Biodiversity Data can measure a country’s performance in line with Climate Action and Habitat Protection performance.

(So far, as you will know, Ireland has failed to implement EU directives from 1992 and even now public money is being directed to Intensive Farming - weaning crates to be specific (Teagasc is the Authority and DAFM the Government Department issuing Covid-recovery money to Feed-lot owners rather than small farmers): Sub-standard, no BER rating, no infrastructure, and certainly not passive, Social Housing Schemes (4 County Councils, so over a 1000 houses): ‘Multiples’ Supermarkets are being awarded large contracts to pay for marketing of their own low-welfare, meat, ready-meals to the UK and low welfare-dairy to Japan (Bord Bia are the Authority issuing those two funds). 

4. The IMS would be the foundation of a free, environmental ‘Citizens Advice Bureau’ or ‘Legal Aid Board’ that communities could use to get an evidence-based report to protect a local area, object to a planning application or support a funding application. The NBDC in Ireland is supposed to provide this but cannot. The pilot, phase one, would be for researchers in several disciplines (Law, Economics, Environmental Science, Social Economy, Planning, History, Geology) to do thorough interrogations of data to respond to various stakeholder’s/users requests. So, they would analyze biodiversity data in relation to existing Environmental Laws and EU Directives and then synthesize their findings, through forum discussions, into reports. This work would produce two things: A reference library of data analysis reports and also analysis tools for future use, by public users. It would make the GBIF network able to address the climate, economic and social problems, OECD anticipated. In the same way as lawyers can go to the Law Library to find precedents on which to base their case, they need to be able to access biodiversity data, trends and particular events, to name as precedents to prevent further or repeated species loss and damaging developments.    

5. The proposed Biodiversity IMS as funding/lending criteria. We believe that the Cohesion Commission is focusing on making the New Green Deal a just transition for citizens. This is the longer vision for the development of the GBIF Information Management System. If Green Deal funding can be awarded on the strength of evidence and reports from the Biodiversity Data Centres, therefore pertaining to protections or benefits that the initiatives will achieve, this could become the basis for a European Public Bank. Our group, which includes the Green Party, who are in a coalition government at the moment, the Sparkassen Bank International Co-operative Arm and the other business, political and economic leaders outlined below, are all committed to implementing a banking system that builds a sustainable monetary system, independent of private banks, over time. If we do not find a way to integrate environmental protection into our financial structures, we in Ireland are definitely doomed: 

You will be aware that Ireland’s Minister for Finance has stayed the same even since the new government and has now been given the lead of a major Euro Zone group. The focus he brings is on major tax breaks for damaging industries and austerity for people. Therefore, we really need criteria that monetize conservation. 

6. Education and health. This flagship pilot project would put Ireland on the map because, as well as a technical and legal/political/environmental/economic and social research project, it would engage all of Ireland and its farmers in Biodiversity Data Collection and Protection. This is because our consortium has a nationwide training component. As Environmental Protection regulations are amended, we would put them into tailored courses for local authority use, in planning departments, services and every sector, focusing on use and preservation of marine and fresh water and land life. This is going to be even more important now with all the ‘control of diseases’ actions, which are leading to wider use of chemicals, water use and other environmental controls. There will need to be a wide Public Health education about the distinctions between healthy microflora, microbial activity, beneficial insects and pollinators and harmful ones. 

7. Humane animal industries. One of our more ambitious plans involves re-commissioning all the fishing boats from the dead-zones and no-take zones on Ireland's coast to clean up the ocean of plastic and nets. They can be paid for what they 'harvest' and we have a new plastic recycling centre Trifol, in County Laois of sufficient scale to recycle as much waste as is found and they do not need it to be clean. Unfortunately, at the moment Trifol are being allowed to sell their melted plastic wax into the food chain as coating for apples, in Ireland and abroad. We are really hoping that Commissioner Kyriakides can stop them on Food Safety grounds.


The second trial will be to stop pig, chicken, sheep and cow breeding altogether and repurpose the animals we have. Pigs would be transported from intensive facilities (99% of Ireland's pigs never see daylight, without room to turn around) to fields to graze off, root and aerate the soil for land-use change from grazing to horticulture. Cattle to become only pasture-fed (already being successfully piloted via natural agriculture in Limerick and to pay their way by producing manure to both feed biodigesters and also to fertilise the soil. 


The third is to bring back traveling / on site slaughter skills and facilities. A part of Ireland's 'race to the bottom' with animal welfare has been the introduction of Halal methods to serve Egyptian and other markets. As you will know, this involves killing without anaesthetic or stunning first. This, of course, saves the meat factories money and time but is a conscious and painful horror story for farm animals, like live export but worse.  One can see how this would encourage consumers to shop local, give a fair price to farmers for meat, be in line with Farm to Fork objectives as well as possibly change diets and incentivise communities to help farmers with managing weeds and pests and decrease their reliance on agri-chemicals. 


As well as funding positive initiatives, Ireland is going to need Europe to come down heavily on the meat, dairy, pharmaceutical and chemical giants. They fix the price of animals, they fix the weighing machines, they necessitate the live export, they avail of all the EU farm payments are also heavily subsidised by public money. Major Food Safety non-compliance is completely overlooked by government and the courts. The same with the pharmaceutical companies which somehow have been equated with 'animal health' programmes, where everyone knows that vaccinations and antibiotics would be less essential if animals were afforded a natural life with any of the 5 freedoms, colostrum from their mothers and fresh air as other valid chances to build their immune systems.


This relates to why I am also cc’ing Commissioner Kyriakides who has rightly threatened to take decisive legal action against Ireland unless our systemic non-compliance is addressed. This was most recently in regard to animal welfare. We have been working on getting an Animal Referendum held here, where 36 exploitative and non-compliant animal industries/practices were identified. We wanted to gauge public support, for change in licensing, diet and lifestyle choices. 


Like biodiversity, with animals, there is a focus on ‘control of’ rather than ‘protections for’. There are also the comparable conflicts of interests in committing to protect anything that we have the intention of exploiting – which is (in Ireland) every part of the eco-system including land, soil, minerals, animals, fish, water and people. This ‘conflict of interests’ is exemplified by the (Department of Agriculture, Food and Marine) DAFM, also managing ‘Animal Welfare’. 


8. The ‘problem’ we will solve is that we cannot protect animal or plant life without this data analysis, in line with EU law. The problem is exemplified by the Green Minister, over the National Biodiversity Data Centre, who is being required to grant a license for capturing hares for ‘sport’. This capturing starts four months in advance of the hare coursing events, when they are released from their boxes and chased on a race track by two greyhounds. Even though the Green Party and the minister in particular are completely against the main parties' subsidies and support of the greyhound industry, the Green Minister has no recourse to definitive biodiversity data on the endangered nature of the hare, its decline due to a spreading virus and through coursing, or of its importance/role in the eco-system. 


The way the problem has translated into public spending has been that the county dog and horse pounds each get half a million a year plus a thousand per horse seized. Meanwhile the shelters receive between 2 and 20,000 euro a year. Even though the latter treat injured animals, keep them for at least six weeks for care, chip, spay, neuter, vaccination and re-homing and incur all the costs themselves. The former put animals down after 5 days and are further incentivised by carcass collection payments as well. 


Accountability goes back to the government. For example Shell were given a license to drill and contaminate the water sources of the West coast. The government also gave AXA insurance, an Irish company 50 million to insure Shell. So that when they create natural disasters the compensation and clean up must be paid by Ireland.


Similarly when a pharmaceutical company's vaccine was proven in court to have caused a life-debilitating condition, it was the Health Service who had to pay compensation, not the drug developer/manufacturer.


9. An EU public bank rather than just Irish and reporting directly to the Cohesion and Reform Commission or OECD. In addition to industry being the main priority for the Ireland’s Department of Finance, the other problem is unwillingness to change. In past proposals, Ireland has sought to empower the regional local authorities to oversee a public or community banking system but actually the structure behind these (the County Executive Management Team) are non-elected, slow-moving beasts that have no interest in the public representatives on their council, no interest in government, no interest in the local economy, let alone public opinion/participation, the EU or the climate crisis. That is why we suggest that this project reports directly to the EU, via the Green Party but is coordinated and overseen by, and responds to, leaders from Non Government Organizations, who actually deal with the collateral damage of industry: A core group of environmental lawyers and social business leaders, empowering and financing citizens, entrepreneurs, cooperatives, conscious construction developers, animal rescues, progressive farmers, housing charities and social enterprise groups that know what needs to be done and can start to do it. 

Our group can utilize the perspectives, research, experience and skillsets of 400 Green Party policy group members. The project would be managed and steered by Diarmaid Mulcahy, International Business, Political & Community sectors Agriculture, Fisheries, Food and Health IRE. The Public Bank grounded on conservation of water and biodiversity is a plan developed by myself and Richard C Cook, Author of ‘Credit as A Public Utility’, National Treasury & Green Party US (Series attached); I was asked by Harald Felzen of the SBFIC and Eamon Ryan to be a government partner in its development. 

The economic policy of a vegan organic food system as 1% more profitable annually than current systems and other greater productivities come from research and policies shared by the Humane Party and work with Clifden Roberts & Robert Mason, Presidential Candidate & Economist, US (policies attached); Irish Green Party Leaders and Finance, Eamon Ryan, Catherine Martin, Neasa Hourigan and Mark Dearey, with Banking & Monetary, Environmental Law, Planning and Food Security groups. 

We propose a project in two phases. In the initial phase, a full assessment top to bottom of the entire system and processes associated with the NBDC service. Who does what and where data comes in. Also, within the first phase, would be a full engagement with all the stakeholders who require an output from the Data Centres; the analysis of the data and the interrogation of the data that is provided by participants. 

The engagement with stakeholders will throw up a range of required outputs. The engagement would be done via face-to-face, questionnaires and surveys, round tables, focus groups and with the general public through ‘conversation cafes’. The goal for the first phase would be to consolidate the existing service. Through website analysis, social media, all resourcing, sales of charts and swatches and other plant and insect ID and training literature will be cross-referenced and shared. There will be a publication need for print resources for all the professional user groups. 

There will be a full review of the National Biodiversity Data Centre (NBDC) training programmes – resources, who, when and why. Who avails of it and programmes and materials. We will want to make sure that Ireland’s Data Centre is to an international standard. Therefore, part of stage one will be to engage with other nodes within the GBIF to see what systems they are engaging. This will help share focus on the hierarchy of needs, starting with the needs of the planet and working down to the needs of the farmers and town businesses. From the planet’s perspective, we will be talking about Europe’s 17 Sustainability Goals. Then down to the local council, town and community biodiversity plans. 

We hoped to enter the public procurement competition to run Ireland’s NBDC and attach the Tender Response document, which confirms our financial and technical capacity and explains Phase One in detail. It shows how we would encourage a nationwide effort and training in monitoring and entering biodiversity data, via the Citizen Science (voluntary) programmes. We would put a special focus on, currently unmonitored, areas of Conservation importance that have been identified jointly with Europe. Stage 2 would be to continue with the research forum’s body of work; to apply the data in multiple contexts from multiple perspectives. Simultaneously, we will develop the bespoke Management Information tool, an example would be the Management Information System of the Central Statistics Office. We would build the system, trouble shoot it and test it for workability and usefulness, by the NBDC and stakeholders. Furthermore there will be training courses as there will be different outputs for all users, stakeholders and general public.

The likelihood is that the general maintenance of the Irish Data Centre’s work and database will be separate to this proposed programme of work, to develop a new Information Management System for biodiversity data across Europe. Therefore, I attach an organizational chart and pricing plan specific to this, amounting to €1,070,000 over two years. 

In previous work done by Ireland’s Green Party and Sparkassen Bank’s SBFIC, on actually putting the legislation in place for a Public Bank, there was a cost calculated of 170 million euro. If this could be provided, this would make an extraordinary saving for both citizens and environment. The bank would be a third stage of the pilot scheme with a lending criteria, based on the new biodiversity data IMS and fresh water as its Golden Peg. Such a bank would not, of course, lend money to start with, but all EU Green Deal funding could pass through the new bank to 1) ensure it is spent on projects, where there is evidence for their benefit. 2) Make interest-free money available for sustainable start-ups and community initiatives 3) Build up the bank’s reserves by money passing through it. 

I hope it is appropriate that we are bringing this ambitious plan directly to you for consideration. We have the vision and the vehicle to realize the full requirements of the GBIF databases in their legislative context and help Europe facilitate the Just Transition we are all banking on.


Many thanks, 

Frances Micklem