FSC IN BRITISH COLUMBIA: RESPONSE TO PATRICK MOORE Patrick Moore, a spokesman for the industry-funded lobby group the Forest Alliance of British Columbia, has recently written to many e-mail lists, criticizing members of the Forest Stewardship Council in British Columbia, Canada, for a) encouraging individuals and organizations to become involved in the local FSC process and b) responding to misleading public relations and marketing claims made by a B.C. logging company, Western Forest Products, which is undergoing a FSC accredited certification assessment of its operations. Readers should realize that Western Forest Products is one of the leading forest industry members and funders of the Forest Alliance of BC, for which Patrick Moore is a spokesperson. Greenpeace Canada recently released a 40-page report on Western Forest Products operations in British Columbia, "Western Forest Products Logging Practices and the Forest Stewardship Council's Principles and Criteria: An Indicative Assessment", which Patrick Moore alludes to in his e-mail (<www.greenpeacecanada.org>). As a prelude, it should be noted that Western Forest Products has become one of the international poster children for destructive forestry, not an easy accomplishment given the competition. Losing business in international markets, Western Forest Products switched tack and signed a contract to undergo a FSC-accredited certification assessment, and has been widely promoting this as a marketing tool to boost its sales. Most surprising, Western Forest Products also claims in its public relations and marketing materials that they see no need to significantly change the forestry operations which earned them "poster child" status in the first place, and that they believe their current operations are FSC certifiable.. The Greenpeace report was designed to provide an alternative, independent perspective on the credibility of Western Forest Product's claims on that issue. Do Western Forest Product's forestry operations appear to be in conformance with the FSC's Principles and Criteria, or do significant changes to their operations appear to be warranted? The report does not set out to predict the outcomes of WFP's FSC certification assessment, which will not be completed by SGS-Qualifor until at least the summer of 1999, but rather to help inform the wider discussion on the issues that this certification assessment raises. FSC and Marketing: The Forest Stewardship Council is a market-driven forest policy instrument. The FSC was established to provide consumers of wood products with verifiable guarantees that the products they purchase come from ecologically sustainable, socially responsible and economically viable logging operations. An FSC stamp of approval is intended to give a market advantage and market incentive to logging companies which meet the criteria of the FSC and have passed a FSC endorsed certification assessment. The statistics so far from FSC accredited certifiers is that about half of the forestry companies which start the FSC-endorsed certification process actually obtain FSC-endorsed certification. Some companies apply to be certified and then either realize that the FSC is not for them or that the FSC standards are higher than they thought and would require significant changes to their operations to be certifiable. Some companies simply fail the certification assessment. In short, there is no guarantee whatsoever that a logging company that starts a FSC endorsed certification assessment, in fact, receive the FSC stamp of approval. An FSC stamp of approval is intended to give a market advantage to logging companies which demonstrably meet the criteria of the FSC. It is not intended to give market advantage to those companies which have not yet demonstrated that they are in compliance with the Principles and Criteria of the Forest Stewardship Council. Nonetheless, WFP seeks to gain marketing benefits simply through having contracted an FSC-accredited certifier to start the assessment process of their operations. Contrary to normal practice where companies wait to find out if they have passed the FSC certification assessment first before seeking FSC associated marketing benefits, Western Forest Products announced quite widely, to the press in BC as well as internationally, that they are pursuing FSC and believe their current practices are certifiable. For example, in speaking to the Vancouver Sun, WFP's chief forester Bill Dumont stated that we "do not believe we will have to change our practices in any significant way" in order to be certified. In speaking with the Canadian Broadcasting Corporation, Mr. Dumont stated that "we think our operations... are going to be recognized and we'll get our (FSC) certification." Greenpeace staff have spoken directly to customers of WFP who similarly state that WFP is portraying their pursuit of certification as virtually a done deal. Nonetheless, the fact is that Western Forest Products is in the very earliest stages of an FSC audit and that, to date, none of WFP's operations have been assessed for compliance with the FSC. In short, it is far too early to suggest that Western Forest Products will not have to change, or that they are assured FSC certification in any way. FSC Certification Assessments in BC. The FSC generic Principles and Criteria are further elaborated to fit the different regional conditions and forest types. The FSC system allows for this development in a two-track process. Where FSC-approved regional standards process has completed its work and the standards have been approved by the FSC, they are used as the basis for FSC endorsed certifications. This process is not completed yet in British Columbia. In the absence of FSC-approved regional standards, FSC accredited certifiers take into account relevant regional standards as part of their local standards development procedures. In the coastal temperate rainforest regions of British Columbia, one of the most significant and relevant standards is that developed by the Clayoquot Sound Science Panel. The Panel was an independent blue-ribbon group of forestry scientists and First Nations' people which was put in place by the BC Provincial government to develop "world class logging standards" for Clayoquot Sound in 1993, fol lowing a summer of public protest and civil disobedience over MacMillan Bloedel's planned logging in the area. Combining the latest in foestry science with the accumulated local knowledge of the Nuu-cha-nulth First Nation, the forestry recommendations of the Panel set a number of important precedents and benchmarks for BC. One of the most important benchmarks is the widespread consensus and support that their recommendations received from the BC Provincial government, industry, environmentalists, local communities, scientists and the Nuu-cha-nulth. This consensus makes the Clayoquot Sound Science Panel forestry recommendations truly unique in BC, and a particularly useful benchmark for the FSC. The BC FSC Steering Committee has endorsed the CSSP standards as a benchmark for the development of FSC standards in BC. The Clayoquot Soud Science Panel recommendations provide both a conceptual framework for forestry management and more specific recommendations relevant to coastal temperate rainforests. (As Western Forest Products operates only in coastal temperate rainforests, the overall findings are particularly applicable to their operations.) Conceptually, the Panel calls for ecosystem-based planning, adaptive management, application of the precautionary approach, and respect for and incorporation into the planning process of the cultural rights, traditions, knowledge and needs of the indigenous people in whose territory Clayoquot Sound falls. (Note: BC has yet to settle outstanding land questions with the indigenous peoples, or First Nations, who reside in the coastal temperate rainforest regions of the province. Western Forest Products operates in un-ceded territories of 27 different First Nation communities More specifically for the coastal rainforest, the Panel recommended an end to clearcutting, full biological and cultural studies be completed for remaining pristine watersheds before determining whether logging should occur in these areas, and a reduced rate of cut that can be ecologically sustained. The Greenpeace report draws on the CSSP recommendations as one important benchmark in its indicative assessment of Western Forest Products. [For more discussion of the Clayoquot Sound Science Panel recommendations and its implementation, there is an excellent report available on the Friends of Clayoquot Sound web-site at www.island.net/~focs] Clearcutting. While the FSC has not explicitly taken any position on clearcutting at the global level, a growing body of science finds that this harvesting technique has many long-lasting impacts on forest ecosystems such as coastal temperate rainforests and should be avoided. Clearcutting is used to convert multi-aged, multi-storied primary (old-growth) coastal temperate rainforests in BC to even-aged short-rotation tree-farms, and does not correspond to historic natural disturbance patterns for these forests according to the Clayoquot Sound Science Panel Out of the 10-million hectares of forest land certified under the FSC system, there is no case of an FSC-endorsed certification involving the clearcutting of old-growth, or primary, forest. Indicative Assessment Report on Western Forest Products. Besides utilizing the work of the Science Panel, Greenpeace reviewed a sample of Western Forest Product 5-year Forest Development Plans and Silviculture Prescriptions from regions where Western Forest Products is currently logging or plan to log. An additional 80 referenced documents were used in considering WFP's current activities. Potential conformance or non-conformance with each of the relevant FSC Principles and Criteria was assessed based on the above evidence. The results of this study can be found in a 40-page report, "Western Forest Products Logging Practices and the Forest wardship Council's Principles and Criteria: An Indicative Assessment". Findings include: * 98 per cent of 428 cutblocks reviewed are scheduled to be logged using clearcutting or clearcuts with reserves, in non-conformance with the objectives of critieria under FSC Principle 6 * There are a number of circumstances in which First Nations whose traditional territories are being logged by WFP feel that their concerns over the impacts of logging are being ignored by WFP, in non-conformance with FSC Principle 3 and related criteria; * Over 90 per cent of the logging conducted by WFP is in old-growth, or primary, rainforest, including logging planned in numerous pristine watersheds with regionally and globally significant conservation values, raising non-conformance issues under Principle 6, Principle 9, and potentially Principal 10. * Freedom of Information searches revealed that Western Forest Products has been penalized for 11 Forest Act infractions, 12 Forest Practices Code infractions, 3 Litter Act infractions and jas been in "non-mpliance" with the BC Forest Practices Code an additional 121 occasions, demonstrating a pattern of WFP non-conformance with criteria under FSC Principle 1 * The rate of harvest by Western Forest Products is well above the long-term sustained yield, in some cases almost double what can be permanently sustained, in non-conformance with criteria under FSC Principle 5. Of the 32 FSC criteria for which we found sufficient information to make an indicative assessment, Western Forest Products was judged to be in conformance with 6 per cent of the criteria. For the remaining criteria we considered, Western Forest Products was either in non-conformance (25%) or serious non-conformance (69%), yielding an overall failure rate or non-conformance score of 94%. When assessing the logging practices and plans of Western Forest Products, in numerous circumstances we attempted to give WFP the benefit of the doubt. For example, in examining Principle 10, which applies to the management of plantations, we classified each criteria as having insufficient information to be assessed and set it aside from the analysis. However, numerous foresters with whom w spoke consider Western Forest Products to be converting primary forests to tree plantations. While Greenpeace agrees with this we determined this to be open to significant debate and assessment, we therefore gave the benefit of the doubt to WFP for all 8 criteria cited under Principle 10. If the FSC endorsed certification assessment were to find that WFP is converting primary forests to tree plantations, WFP would of course be completely ineligible from FSC certification. This assessment is only indicative, not definitive. Greenpeace cannot in any way predict the outcome of the FSC endorsed SGS-Qualifor certification assessment now under way of WFP's operations, nor would we wish to. At the same time, Western Forest Products also cannot predict the outcome of the FSC certification assessment, much as they would like to. Nonetheless, Western Forest Products has publicly communicated and strongly implied to their customers that their operations are FSC certifiable without significant changes. WFP has done this at the earliest stages of the process, well before the FSC certification assessment has even begun proper consultation, much less close to completed. What the Greenpeace report does is provide an alternative, independent perspective on the viaibility of Western Forest Products claims on this issue, and a contribution to the dialogue and development of the FSC process in British Columbia. Of course, the FSC certification assessment of Western Forest Products should also continue. Patrick Moore Claims and Red Herrings. Because the FSC has certified some logging operations in old-growth, and because some openings in second-growth that have been certified would be classified as a clearcut, Mr Moore has attempted to characterize this as though the FSC has approved the clearcutting of old-growth. The case of Big Creek Timber, cited by Patrick Moore, is particularly interesting. This operation, located in the redwood zone of California, does harvest some residual individual old-growth trees in its operations. But all intact stands of old-growth redwoods in its ownership are set aside from harvest, the company uses no clearcutting, its rotation ages are nearly twice the average of industrial redwood forestry companies in the state, and it both retains, recruits and regenerates forests with numerous old-growth attributes. In fact, Big Creek is highly unusual among redwood producers in growing the highest premium grades of clear redwood timbers from its managed secondary forests, grades which are normally only associated with primary forests and rarely regenerated by industrial forestry operations. Big Creek Timber's forestry operations (which interestingly are located in the southern extent of the coastal temperate rainforest zone of North America) stand in stark contrast to those of Western Forest Products. This is one example of statements made by Mr Moore which are disingenuous at best, if not intentionally misleading. Other examples: 1) Greenpeace sent this report to Western Forest Products on the day it was released, as well as to numerous FSC bodies including the certification agency WFP has contracted to conduct the FSC audit. I am therefore surprised that Mr Moore had "tried to find the Greenpeace document" but was unable to. Surely he has heard of the telephone, e-mail or perhaps the fax machine. Numerous other logging companies and officials were able to figure it out and have received a copy of the report to review. We are happy to send out copies of the report to whomever requests it. Hard copies of the report are available either by contacting the Greenpeace office in Vancouver or by accessing the Greenpeace Canada website at <www.greenpeacecanada.org>. 2) Mr Moore states that "there is general agreement that the 10 Principles (of the FSC) are quite good". This is a complete about-face for Mr Moore since recently he has been quoted in the press denigrating the FSC and proposing instead his own idea as to an acceptable certification standard. Moore's proposed certification system was that of the VQA - the Vintner's Quality Assocation. Beats me what wine growing has in common with the environmental, social and technical concerns of forestry, nor why Mr Moore would propose a certification system that has no recognition in the international marketplace for wood products. His ostensible support for the FSC's principles is spurious at best. 3) In the third paragraph Mr Moore says that "for some years now Greenpeace.. has been promoting a boycott of Canadian forest products". This is categorically not the case. Our work in the marketplace has taken two different approaches, the first being to encourage consumers to demand that the products they buy be certified by an independent, third-party certifier such as those accredited by the FSC. In addition, we have actively worked in the field to locate and promote sustainable logging operations, such as some of the logging conducted by the Small Business program in Vernon, B.C. The second approach for Greenpeace in Canada and internationally is to assess the health of ecosystems and the level of threat to a particularly vulnerable ecosystem and then encourage customers to not buy products from specific companies using the most egregious practices. This approach has been and is very company-specific. For example, throughout 1993 and 1994, Greenpeace encouraged customers to reject products from MacMillan Bloedel because of their clearcutting in Clayoquot Sound. The pressure lessened on MacMillan Bloedel in 1995-96, when MB ceased clearcutting in Clayoquot. More recently, Western Forest Products and International Forest Products have been targeted, due to their proposed and ongoing clearcutting of some of the few remaining intact, pristine large rainforest valleys left in coastal B.C. Out of 353 rainforest watersheds in BC, 80 per cent have been impacted by clearcut logging. Those that remain provide irreplaceable values for conservation and as scientific benchmarks. The environmental community in British Columbia has jointly recommended to government and industry that the remaining valleys be placed off-limits to industrial development. Last month, 50 Canadian and international scientists sent a letter to the governments of B.C. and Canada endorsing this position. Greenpeace and the FSC. Greenpeace has been and continues to be an active member in the Forest Stewardship Council, in B.C. and internationally, along with hundreds of other FSC members representing social, economic and environmental perspectives. We will continue to encourage individuals and companies which truly and demonstrably support the Principles and the Criteria of the FSC to become members and, in the case of logging operations, to become certified by the FSC. What we do not support are companies making misleading claims about their practices, or what kind of practices the FSC has supported or currently is supporting. The integrity of the FSC process and its recognition in the marketplace is critical and, ultimately, will rest on what consumers will and will not support. Certainly we, and even companies such as MacMillan Bloedel, are aware that customers internationally do not want to buy products made from the clearcutting of old-growth. Given all we know about its impacts, that's really not a surprise. One of the co-authors of the report is Bill Barclay, who has been Greenpeace's international representative to the Forest Stewardship Council for five years and has been intimately involved in the FSC processes and policy-making. Most recently, Mr Barclay served as one of twelve FSC membership-elected representatives to a FSC Working Group to further develop FSC's Principle 9, related to the maintenance of natural forests. The Working Group was comprised of a balanced set of elected representatives from each chamber of the FSC. The meeting, which was held in Mexico, was attended by two representatives from BC observing on behalf of the Canadian Pulp and Paper Association, Western Forest Products, Lignum Forest Products, Weyerhauser Canada and MacMillan Bloedel. Greenpeace is currently actively following FSC certification activities in Russia, Canada, Brazil, the South Pacific, New Zealand, Australia, Chile, and throughout Europe. Tamara Stark Greenpeace Canada Forests Campaigner 1726 Commercial Drive Vancouver BC V5N 4A3 e-mail tamara.stark@yvr.greenpeace.org Bill Barclay Forests Campaign Greenpeace 965 Mission St. Suite 450 San Francisco, CA 94103 Tel: 1-415-512-7136 Fax: 1-415-512-8699 e-mail: bbarclay@sfo.greenpeace.org
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