LOCATION: Bord Na Mona conference room*
DATE: Early 2016.
TOPIC: Ad planning meeting (*fictional)
BnaM Marketing Exec: ‘I’ll cut to the chase. Here’s the challenge: we’re a company that, pound for pound, is the biggest polluter in Ireland. We’ve wrecked nearly 80,000 hectares of boglands right across the country, increased flooding in the Shannon basin and polluted a lot of the waterways. Oh, and we get bunged well over a hundred million quid a year to keep three hopelessly inefficient peat-burning stations open; the dogs in the street know it’s the most expensive JobBridge scheme in the country. People are starting to wise up to climate change as well, and, to be honest, we’re a disaster area on that front too. Jesus, even some of the politicians have noticed. It turns out that simply draining bogs turns them from carbon sinks into carbon pumps. And as for the biodiversity, well, let’s just say, once our machines have ripped up a bog, it looks like a scene from Apocalypse Now. Total dead zone, nothing much bigger than an ant survives peat harvesting. Nada. Zip’.
Agency Suit: ‘Guys, guys, guys. Take it easy! For starters, how many people have ever been out on a Bord Na Mona bog – or a living bog, for that matter? Not many, right? So, they haven’t a clue what happens out here. How many know or care about carbon sinks and climate whatsit? Right again. Ladies and gents, welcome to 2016. The truth, or the post-truth, if you prefer, is precisely what we tell them. And as for the media, no problemo. We’ll organise to bus a few of them down from RTE, the Times, Indo etc. and give them the ‘conservation tour’, you know the one, where we do the touchy-feely talk about hares and sphagnum moss and restoration, the standard PR drill. We can bring in some friendly conservation types to give the gig a bit of cred, then just sit back and wait for the positive coverage. No problemo. Fish in a barrel’.
BnaM Marketing Exec: ‘That all sounds good in theory, but do you really think the media are that gullible? Surely if we focus on the handful of ruined bogs we’re restoring, it’s going to draw attention to the godawful mess we’ve made elsewhere? What if these journalists start digging for the real story; what if we start making a play of giving a shit about nature and the public smells a rat? This could turn into a PR disaster…’
Agency Suit: ‘Please, try to keep up. First of all, there’s nobody left in any of the papers that would know a live bog from a bale of briquettes. Second, even if they did, they’re all on deadlines, they’ll take the tour and the handouts, write it up in the morning and by the afternoon they’ll be off reporting on how much dogshit there is on Dollymount strand. Now, if I can have everyone’s attention, I’d like to unveil the title of the new campaign: ladies and gentlemen, I present ‘Bord Na Mona – Naturally Driven’
(Ripples of laughter around the boardroom table, followed by sustained applause as the video clip comes to an end).
Agency Suit: ‘As I said earlier, it’s 2016, people. Reality is exactly what we say it is, and remember, we get to put this message up on billboards, in newspapers and on the radio, TV, Facebook, Twitter, morning, noon and night, until, well, that’s what you are, Bord Na Mona, the newly minted Naturally Driven, ecologically friendly and progressive organisation – smelling of roses, you might say. The real genius, if I may be so bold, is that you get all that without having to change a single thing about what it is that you actually do. So, business-as-usual. Perception, people, is the new reality. Say it often enough and it becomes a fact. Reputation by repetition.’
BnaM Marketing Exec: ‘OK, I’ll accept what you’re proposing is a bold, ballsy play. Saying we are the exact opposite of what we actually are. And I’ll grant you that the media will probably play along – especially when we grease them up with some advertising spend – but there’s a fly in the ointment: what about the Advertising Standards Authority? There’s no way they are going to fall for this bullshit, no matter how you dress it up. Getting an ASAI ruling that our whole campaign is a pack of lies would be a disaster. Look at their Code of Standards. Up-front it says the following: ‘All marketing communications should be legal, decent, honest and truthful and should not mislead the consumer. All marketing communications should be prepared with a sense of responsibility both to the consumer and to society’. There is not a chance that this will be seen as honest and truthful, never mind the stuff about ‘not misleading the consumer’. And as for wider responsibility to society, don’t even go there. They’ll skin us alive, and then the media won’t be as docile as you seem to assume. This thing could still turn really ugly for the whole company…’
Agency Suit: ‘Oh ye of little faith! This is Ireland, boys and girls. Nobody takes any of this eco stuff too seriously. And besides, who do you think will be adjudicating on the ASAI panel? A bunch of agency types like me! And what do you think they know or care about bogs and carbon and yada yada? As far as most of them are concerned, Pete Briquette is that bloke from the Boomtown Rats! Oh, and did I mention, the ASAI is fully funded by the advertising industry? Or as we like to call it, regulation, Irish-style! Just like I said, no problemo. Honestly, you people worry far too much’.
Bord Na Mona’s 2016 ‘Naturally Driven’ campaign is arguably one of the most dishonest, cynical and misleading campaigns ever to air in the Irish media. And that is saying something. Quite how board chairman John Horgan (formerly chair of the Labour Court) and CEO Mike Quinn ever signed off on this remains a mystery. You can view the entire current board of the organisation here. For a ‘Naturally Driven’ organisation it is remarkable that not a single person at board level has any background, qualifications or expertise in the ecological or environmental areas (one board member, an educationalist, is listed as having presented a programme on environmental issues on local radio, and that’s about it).
I’ve written in detail earlier this year about the campaign, and why I believed it was so objectionable. I also helped draw up a press release on behalf of An Taisce some months back, setting out our strong objections to the ‘cynical’ campaign, and this got some limited media pick-up.
The next obvious step was to write directly to the ASAI with a formal complaint, which I did in September last. The wording of my complaint is set out below. Rather than being too general, I tried to address specific parts of the ASAI Code of Standards I believed the ad campaign breached:
In its current radio advert, Bord Na Mona describes itself as “a company born of the land, that rehabilitates and preserves that land”. The advert continues: “To ensure a sustainable future is not just an ideal, but a reality – Bord Na Mona: Naturally Driven’.
This advert also points out that Bord Na Mona “already powers over 100,000 homes with green energy, that turns organic materials into renewable fuel, even converts household rubbish into electricity…”.
Based on the above statements, any reasonable member of the public would be led to believe that Bord Na Mona is primarily a renewable energy company, which is a gross misrepresentation of reality. Bord Na Mona’s core business is in fact the strip mining of millions of tons of peat from some 80,000 hectares of bogs. This business is extractive, massively ecologically damaging and adds hugely to carbon pollution as a result of the draining and destruction of tens of thousands of hectares of boglands.
The ‘rehabilitation’ that Bord Na Mona refers to in its radio ad amounts to around 1,000 hectares (or 1/80th of its total land bank) on which it has carried out remediation work to recover it from the damage inflicted on said bogs by Bord Na Mona itself.
This radio advert focuses on minor, non-core areas of its business to deliberately present a false and misleading public view of Bord Na Mona as an environmentally driven, ecologically responsible company. Their track record shows this to be nothing more than window dressing. The ASAI code states, inter alia, that adverts “should be legal, decent, honest and truthful” and “should be prepared with a sense of responsibility to consumers and society”.
I believe the Bord Na Mona advert is in clear breach of Section 15 (‘Environmental Claims’) of the ASAI code. Section 15.2 states: “Environmental claims should not be used without qualification unless advertisers can provide substantiation that their product will cause no environmental damage. Absolute claims should be supported by a high level of substantiation”.
Bord Na Mona makes extravagant claims about the environmental benefits of some of its practices, while deliberately evading the fact that their core business is carbon-intensive, ecologically damaging, completely non-renewable and is a major contributor to climate change.
Section 15.5 states the following: “The basis of any claim should be explained clearly and should be qualified where necessary. Unqualified claims may mislead if they omit significant information.” I contend that Bord Na Mona’s advert is, under Section 15.5, misleading as it manifestly misleads by “omitting significant information”.
Section 15.6 states, inter alia: “Advertisers should ensure claims that are based on only part of the advertised product’s lifecycle do not mislead consumers about the product’s total environmental impact”. I contend that Bord Na Mona’s advert is wholly misleading in that it omits critical information about the advertised product’s total environmental impact’. For a company to publicly claim to be “sustainable” because it repairs some of the damage it has inflicted on 1/80th of its land bank, while continuing to unsustainably exploit the remaining land is, in my opinion, a gross misrepresentation of reality and manifestly aimed to confuse and mislead the public as to the true nature of the company and its products.
So, and open-and-shut case, you might say? Not so fast. On December 16th, I received the ASAI’s ruling, which ran to six pages, almost all of which were copy-and-pasted from Bord Na Mona’s response to the five written complaints to the ASAI this campaign attracted. Rather than troubling itself to address any of the points I set out in my complaint, this was the self-regulation agency’s generic summing up, in full, to all five complaints:
All complainants considered the advertising to be misleading and disputed the fact that Bord Na Mona were an environmentally friendly company or ‘naturally driven’ as proclaimed in their advertising. All complainants posed the question how Bord Na Móna could substantiate the claim that they powered Irish homes with “green energy” when they were using turf and peat from Ireland’s rapidly diminishing bogs to fuel power plants, domestic fires and the horticultural market.
And the ASAI’s Jesuitical Conclusion, having no doubt carefully weighed up all complaints, was as follows:
The Complaints Committee considered the details of the complaint and the advertisers’ response. They noted that the advertisers had identified a lack of knowledge amongst consumers in relation to the various facets of their business, other than the peat/turf/briquettes area and that they wished to expand the understanding of the public in relation to these other elements of their business.
The Committee understood that part of the complainants’ concerns related to the absence of a reference in the advertising to the use of turf and peat in the advertisers’ energy generation. They noted that the advertisers had demonstrated that they were powering homes in Ireland through “green energy” but that the advertising had not claimed or suggested that they were powering all homes in this fashion; the advertising had clearly referred to the number of homes currently receiving this type of power and the number of homes which the advertisers hoped to expand to in the future. The Committee did not consider that the Code required advertising to reflect all aspects of an organisation’s business or products and that it was acceptable to focus on a selected element provided it did not mislead. In this case, the Committee did not consider the advertising to be misleading and did not uphold the complaints.
A red herring lobbed in by Bord Na Mona in its Response was to the effect that the problem with their business practices was not their actual practices but ‘a lack of knowledge amongst consumers in relation to the various facets of their business’ and this piece of glib nonsense was faithfully parroted in the ASAI’s Conclusion.
Quite apart from the staggering lack of critical thinking on display from the ASAI in its Conclusion, I was more than a little bothered by the fact that my specific complaints had not been addressed, and wrote to CEO Orla Twomey on December 19th to this effect. She replied two days later to explain that, by the time they had received my complaint, ‘we had in fact already started an investigation into the advertising arising out of four earlier complaints’. She went on to explain that: ‘Whilst your complaint contained much detail we considered that the core elements had been covered in our earlier complaints’.
It is, she added, ASAI practice ‘where complaints are received after a response has been received and where no new issues have been raised, not to include the latter complaints in the final formal case’. In other words, they never actually adjudicated on my complaint, nor did they in fact put my complaint to Bord Na Mona, who had already issued their stock responses.
And for a final kick in the teeth, I had asked Ms. Twomey as to what review or appeals process exists when a complaint is rejected. ‘An application for a review will only be accepted from the parties to the original complaint and as explained above your complaint does not fall into that category’.
This gloriously Orwellian ruling means that since they threw my original complaint into the bin and admitted to having failed to actually put it to Bord Na Mona, therefore I am not a ‘party to the original complaint’ and so an application for a review arising from my complaint is automatically rejected. You really have to stand right back and admire the rigours of the self-regulating, industry-funded ASAI.
Twomey signed off her letter as follows: ‘I hope that the above provides you with context and clarity on how the ASAI have thoroughly dealt with all complaints received’. To which my two-word answer is: absolutely not. Let’s recap briefly:
Section 15.2 states as follows: “Environmental claims should not be used without qualification unless advertisers can provide substantiation that their product will cause no environmental damage. Absolute claims should be supported by a high level of substantiation”. To have failed to rule against the blatant ‘environmental claims’ being made by Bord Na Mona on this one defies logic. How exactly did Bord Na Mona substantiate’ that their products ‘will cause no environmental damage?
Section 15.5 states that: “The basis of any claim should be explained clearly and should be qualified where necessary. Unqualified claims may mislead if they omit significant information.” Quite how Bord Na Mona got away with omitting the ‘significant information’ that 95%+ of their business is in pure ecological wreckage is something the suits on the ASAI might like to explain sometime, but don’t hold your breath.
Section 15.6 states: “Advertisers should ensure claims that are based on only part of the advertised product’s lifecycle do not mislead consumers about the product’s total environmental impact”. This is the killer section. Bord Na Mona focuses obsessively on its token remediation and minor renewables business while grossly misleading consumers about the product’s total environmental impact. And the ASAI, disgracefully, lets it away with this blatant sleight of hand.
Given the rigorous approach adopted here by the ASAI, now might be a very good time for the tobacco industry to apply to be allowed to start running ad campaigns again. They could after all focus on the fact that tobacco leaves are ‘100% natural’ – naturally driven, you might say, and then explain (truthfully) that cigarettes can helpful in losing weight and relieving stress. And as for the product’s ‘total environmental impact’, let’s not get hung up on such trivial detail. Besides, think of the jobs being created in tobacco growing, marketing and distribution.
Finally, buried deep in Bord Na Mona’s response is a telling statement: ‘In the past year they have sourced 320,000 energy tonnes of biomass and this is projected to grow to over 1m energy tonnes by 2020’. This is a critical part of the company’s ‘transitioning to 100% renewable energy’, according to its annual report.
Great news. So, what exactly is this ‘biomass’ and where does it come from? You may be a little taken aback to hear that some of it is a product called PKS, or palm kernel shells. These are a by-product of the mass rainforest clearances taking place in Indonesia and elsewhere, from where Bord Na Mona imports this product that helps make rainforest felling for palm oil plantations commercially viable.
The company acknowledges that it is buying them from unsustainable sources as follows: ‘An early output of the review (of future supply of biomass) will see the company cease to source, import and use PKS (Palm Kernel Shells) in 2017 once we have alternative sustainable supply chains in place’. CEO Mike Quinn confirmed to the Joint Oireachtas Committee on Jobs, Enterprise and Innovation last year that they buy these PKS from both Indonesia and Malaysia. Lord, let me be sustainable, but, to paraphrase St. Augustine, just not yet.
Today is the last day of the hottest year in Earth’s recorded history, unseating 2015 from its briefly held no. 1 position. Absolutely unprecedented Arctic ice melt and temperature spikes could, scientists warn, trigger ‘uncontrollable climate change at a global level’. In recent months, we have also learned that East Antarctica is far less stable than previously assumed.
Its massive Totten glacier holds in place an ice shelf larger than the state of California, and this is being undermined by vast currents of warmed ocean water. It is losing height at the rate of 10 metres a year. Were this land-based ice shelf to collapse entirely, global sea levels would rise by around four metres.
How long such a collapse would take to play out remains in question, but we can say with confidence that every tonne of peat harvested in Ireland and every tonne of ‘biomass’ we import from south east Asia moves the countdown clock towards global catastrophe forward another second or two.
As far as the rest of the natural world is concerned, the countdown to oblivion is already in full swing. WWF data this year confirmed that more than two thirds of all the world’s wildlife are on target to be gone by 2020. Since 1970, there has been a 58% overall decline in the numbers of fish, mammals, birds and reptiles worldwide, according to the WWF’s bi-annual Living Planet Index. Meteors notwithstanding, there hasn’t been a global mass extinction event on this scale for around a quarter of a billion years. You have to go back to the end-Permian period for any historical analogue.
That catastrophe almost extinguished all life on Earth, yet human activity over the last 200 years and projected over the next 50 will put as much heat-trapping gases into the atmosphere as the totality of emissions from the Siberian Traps over a period in excess of 100,000 years that precipitated what is known as The Great Dying.
2016 has seen our uncontrolled experiment with the foundations of life on Earth edging closer towards its logical, if tragic, conclusion. What will 2017 bring? We’ll know soon enough.