SOME INFORMATION ON THE
FOREST STEWARDSHIP COUNCIL (FSC)
Plantations already certified by FSC
The following is a selection of plantations already certified by the FSC. We have excluded the smaller plantations (less than 10,000 hectares), as well as those described as "plantation/semi-natural", "plantation/natural" and similar mixes, so as to highlight only those which can be characterized as typical industrial tree plantations (figures are in hectares). Shell's plantations are not included because they were certified after the last update in the FSC's web page.
BRAZIL V&M Florestal Ltda.: 235,886 Klabin Fabricadora de Papel e Celulose SA: 218,545 Eucatex SA - Salto & Botucatu and Buri: 48,962 Duratex SA - Botucatu, Lencois Paulistas, & Agudos Districts: 47,904 Plantar SA: 13,414
INDONESIA Perum Perhutani: Districts of Cepu, Kebonharjo, Mantingan, Kendal Lawu and Madiun: 62,278
NEW ZEALAND Fletcher Challenge Forests Ltd: 360,000
SOUTH AFRICA Mondi Forests - Lowveld, Komati, Piet Retief, Natal and Zululand: 431,301 SAPPI Forest Products: 48,507 South African Forestry Company Ltd. - Eastern Cape Region: 42,714 South African Forestry Company Ltd. - KwaZulu-Natal Region: 51,922 South African Forestry Company Ltd. - Mpumalanga North Region: 64,378 South African Forestry Company Ltd. - Mpumalanga South Region: 58,818 South African Forestry Company Ltd. - Western Cape Region: 53,530
UNITED KINGDOM Northern Ireland Forest Service: 75,500
ZIMBABWE Border Timbers Ltd.: 47,654 Forestry Commission: 19,085
Source: FSC web page (Information accurate as of December 31, 2000 )
South Africa: Something appears to be wrong
South Africa is perhaps the country when the contradictions about FSC-certified plantations stand out most clearly. Of the three major plantation companies, two of them have large areas of certified plantations: Mondi has 431,301 hectares and SAFCOL 271,362. The third company (SAPPI) is following the same policy and has begun the certification process with an initial 48,507 hectares certified. In total, 828,128 hectares of plantations have until now received the FSC stamp of approval --all certified by the UK-based SGS Qualifor-- and more will follow.
However, those same plantations are being opposed by a broad number of individuals and organizations in South Africa because of their environmental and social impacts. Many people were driven off the land --particularly during the Apartheid period-- to make way for those plantations and received no benefits from them. Plantation species have not only occupied 2 million hectares of fertile lands, but have also invaded another 2 million hectares through spontaneous seed dispersion. Both plantations and invaded areas have resulted in strong negative impacts on supplies of water --a scarce resource in South Africa-- and therfore on people and biodiversity.
South Africa is a megabiodiverse country and most of the flora and fauna is not located in forests but in grasslands and wetlands. The country has always had a relatively small area of forests. None of the plantation companies can therefore be accused of having caused deforestation. However, they can certainly be accused of having degraded enormous areas of the country's dominant ecosystem --grasslands-- which constitutes the support for its very diverse and unique wildlife and flora.
The contradiction is therefore clear. On the one hand, a certification firm --accredited to the FSC-- is telling the public that these plantations are sustainable. On the other hand, local networks such as Timberwatch have been created to oppose those same plantations because of their basic unsustainability. Something appears to be wrong and the FSC should look more closely into this matter.
Aotearoa/New Zealand: A challenging certification
In October 2000, all of Fletcher Challenge Forests' New Zealand plantations received Forest Stewardship Council certification, after an evaluation carried out on behalf of Scientific Certification Systems (SCS). Included in the certification is the world's largest continuous radiata pine plantation.
Ian Boyd, Fletcher Challenge Forests' then-Acting Chief Executive, said, "Forest Stewardship Council Certification will provide Fletcher Challenge Forests with a significant marketing opportunity in those markets which demand environmental responsibility."
However, the certification of Fletcher Challenge Forests' operations raises serious questions about SCS' assessment process, as well as about Fletcher Challenge Forests' plantation management itself.
According to FSC principle 6, all World Health Organisation type 1A and 1B pesticides "shall be prohibited". Fletcher Challenge Forestry uses sodium fluoroacetate. Commonly known as 1080, it is a poison used to kill wildlife such as possums, which can damage plantation trees. In SCS' public summary of the assessment of Fletcher Challenge Forests' operations, the assessors acknowledge that 1080 is "a compound appearing on WHO Table 1". Yet, rather than refusing to award the certificate, SCS applied a condition which is so loose it is almost meaningless: "Within 12 months of award of certification, Fletcher Challenge Forests should be able to demonstrate that they are actively seeking alternatives to 1080, e.g. by supporting research into alternatives."
In other words, Fletcher Challenge Forests can continue to use 1080 without risking their FSC certificate, as long as they support research into alternatives. SCS does not mention what form such support should take, or even if it matters whether the research yields any results or not.
FSC principle 2 states that disputes over land rights "of a substantial magnitude . . . will normally disqualify an operation from being certified." To the Maori, land is sacred and they have several outstanding land claims on Fletcher Challenge Forests' plantation land under the 1840 Treaty of Waitangi. In their assessment, SCS' assessors describe the "uncertainty over ownership of a significant proportion of [Fletcher Challenge's] forest lands" as a "significant" issue. Once again however, this does not prevent SCS from awarding the certificate.
According to FSC Principle 6, "Use of genetically modified organisms shall be prohibited". Since 1995, Fletcher Challenge Forests has worked with Genesis Research and Development Corporation, New Zealand's biggest biotechnology company, on research into genetic modification of trees. SCS' assessors acknowledge that Fletcher Challenge Forests is involved in research on genetically modified plant tissues. Although Fletcher Challenge Forests does not currently use genetically modified trees in its plantations, rather than discussing whether Fletcher Challenge Forests' research conflicts with the spirit of FSC principles, the public summary of the assessment simply states: "All materials are classed as low risk and the laboratory is fully compliant with regulatory requirements."
In 1999 Fletcher Challenge Forests, Genesis, Monsanto, International Paper and Westvaco announced a US$60 million joint venture. The joint venture company, called ArborGen, will produce and market genetically modified tree seedlings, focussing on radiata pine and eucalyptus trees in New Zealand. Monsanto has since withdrawn from active partnership.
Whether Fletcher Challenge Forests use the genetically modified seedlings in its own plantations or, as part of the ArborGen joint venture, sells them to other forestry operations, Fletcher Challenge Forests is effectively using genetically modified organisms, and promoting their use in forestry operations. Whether Fletcher Challenge Forests is therefore in breach of FSC's principles should surely be a matter for the assessors to discuss in the public summary of the assessment. Yet, in describing Fletcher Challenge Forests' research and development activities, the assessors conclude: "The company has a clear commitment to the FSC principles".
Three of the four assessors hired by SCS to carry out the assessment of Fletcher Challenge Forests' operations work for the New Zealand company Forest Research. In 1982, Forest Research hosted an international meeting on genetic research with radiata pine. By September 1995, the institute's greenhouses in Rotorua were stuffed full of genetically modified radiata pine. Forest Research also runs projects funded by Fletcher Challenge Forests. Could this perhaps explain the assessors' unquestioning acceptance of Fletcher Challenge research into genetically modified trees?
By: Chris Lang; e-mail: firstname.lastname@example.org
Comments on the FSC's Principle on Plantations
It is important to begin by highlighting the fact that to receive FSC certification, a plantation company needs to comply with all FSC's principles and not only with the principle concerning plantations specifically-- principle 10.
Having said that, we shall focus on principle 10, which, as it currently stands, appears to allow unsustainable industrial tree plantations --particularly in the South-- to receive certification in spite of their negative social and environmental impacts. What follow are comments on the different criteria included under principle 10.
"Plantations shall be planned and managed in accordance with Principles and Criteria 1 - 9, and Principle 10 and its Criteria. While plantations can provide an array of social and economic benefits, and can contribute to satisfying the world's needs for forest products, they should complement the management of, reduce pressures on, and promote the restoration and conservation of natural forests."
In the South, all of these claims have already been proven unachievable in practice:
Large-scale industrial monocrops have provided "an array of social and economic benefits" only to the rich.
What does "can contribute to satisfying the world's needs for forest products" mean in a Southern context? Plantations produce only two forest products: timber and pulpwood. These two --and especially the latter-- are aimed at endless over-consumption by Northern countries and Southern elites. The beneficiary is therefore not "the world" but the rich world. All the other products which are produced by real forests (food, fodder, water, medicine, shelter, fuelwood, etc.), which satisfy the needs of local communities, are almost totally absent from plantations and the local world therefore does not benefit from plantations.
In most cases, plantations have resulted in the destruction of native forests or other native ecosystems such as grasslands and have not contributed to "complement the management of, reduce pressures on, and promote the restoration and conservation of natural forests". The fact that, despite this, the principle states only that plantations "should" promote conservation, not that they "must", signals its detachment from the real world.
"Principle 10.1. The management objectives of the plantation, including natural forest conservation and restoration objectives, shall be explicitly stated in the management plan, and clearly demonstrated in the implementation of the plan."
The management objectives of industrial plantations are always explicitly stated: the production of large quantities of timber in the shortest time possible. Large plantation companies often write natural forest conservation and restoration objectives into their plans, but more as a public relations exercise than as a genuine management objective.
"10.2 The design and layout of plantations should promote the protection, restoration and conservation of natural forests, and not increase pressures on natural forests. Wildlife corridors, streamline zones and a mosaic of stands of different ages and rotation periods, shall be used in the layout of the plantation, consistent with the scale of the operation. The scale and layout of plantation blocks shall be consistent with the patterns of forest stands found within the natural landscape."
There is no positive relationship between industrial plantations and forest conservation. Wood produced in industrial plantations does not, as a rule, substitute for wood extracted from natural stands: the former is mostly aimed at the production of pulp and paper, while the latter is aimed at the timber industry, which requires high-quality wood.
There are a number of negative relationships, through which large-scale plantations actually promote deforestation. In the first place, most plantations in the tropics substitute for primary or secondary forest, which are clearcut and/or set on fire prior to planting. Secondly, people displaced from their land by plantations have to clear new forest areas in order to survive. Thirdly, it is not unusual for the news that plantations are going to be established in a certain area to result in its deforestation by local speculators in order to be able to sell the land to the plantation companies. Additionally, roads leading to plantations upen up new forest areas to encroachment. Fires originating in plantations, in addition, can extend to nearby forests. In consequence, large-scale plantations are usually both direct and indirect causes of deforestation.
Most plantation companies are able, if pressed, to make at least a token attempt to set up "wildlife corridors, streamline zones and a mosaic of stands of different ages and rotation periods." However, this does not mean that local ecosystems (forests, grasslands, wetlands and so forth) will not suffer, because there will usually be a number of companies occupying a given area. Wildlife corridors isolated within a sea of eucalyptus or pines are not of much significance for the conservation of wildlife. The same is applicable to the preservation of streamline zones. The impact of these plantations on water must be dealt with at a basin level and not at plantation level. The impact of large masses of fast-growing trees in a given area have already resulted in the disappearance of water courses and profound changes in the water cycle. Finally, almost all companies plant what could be loosely interpreted as "mosaics" of stands of different ages and rotation periods. By itself, however, this implies nothing about the impacts on water, soils, flora and fauna. The size of each "tile" in these so-called "mosaics" is likely to be far larger than in a forest because it is determined by the commercial need to be able to have something to harvest every year, not by ecological criteria.
What is the meaning of "The scale and layout of plantation blocks shall be consistent with the patterns of forest stands found within the natural landscape"? What happens in cases such as Uruguay, Argentina and South Africa, where plantations are established on grasslands? Such plantations have already been certified in those three countries. Can this be interpreted as meaning that grassland ecosystems are unimportant to the FSC? And in all cases, how can a eucalyptus or pine plantation "be consistent with the patterns of forest stands found within the natural landscape"?
"10.3. Diversity in the composition of plantations is preferred, so as to enhance economic, ecological and social stability. Such diversity may include the size and spatial distribution of management units within the landscape, number and genetic composition of species, age classes and structures."
This clause is so vague that it could be satisfied merely by planting two species of eucalyptus in a huge industrial plantation rather than just one, and planting two different areas a couple of years apart rather than planting all the trees at once. In fact, most large industrial plantations already comply with the letter of this principle simply because to do so enhances economic stability (more protection against specific predators). However, such inadequate measures cannot appreciably enhance either ecological or social stability (although the protection against pests provided by some diversity could protect the jobs of plantation workers who might otherwise lose their jobs if the plantation were to be decimated by insects or fungi). And even this call for minimum diversity is not mandatory but merely "preferred".
"10.4. The selection of species for planting shall be based on their overall suitability for the site and their appropriateness to the management objectives. In order to enhance the conservation of biological diversity, native species are preferred over exotic species in the establishment of plantations and the restoration of degraded ecosystems. Exotic species, which shall be used only when their performance is greater than that of native species, shall be carefully monitored to detect unusual mortality, disease or insect outbreaks and adverse ecological impacts."
This criterion leaves the door wide open to fast-growth exotic tree plantations, which "are based on their overall suitability for the site and their appropriateness to the management objectives" (the production of large volumes of homogeneous raw material for industry). Native species are again only "preferred", not "required", and if "performance" is measured only by how much industrial wood a species produces, then all industrial plantations will comply with this criterion automatically. There is therefore a need to define "performance" clearly, because most native species' "performance" in the production of water, soil, food, medicine, fodder, etc. is usually far better than that of alien species which produce little --or none-- of these goods. The last sentence ("Exotic species . . . shall be carefully monitored to detect unusual mortality, disease or insect outbreaks and adverse ecological impacts") is very confusing. Are the adverse ecological impacts referred to impacts on the plantation or of the plantation on neighbouring ecosystems and local production?
"10.5. A proportion of the overall forest management area, appropriate to the scale of the plantation and to be determined in regional standards, shall be managed so as to restore the site to a natural forest cover."
Here again appears the confusion between forest and plantation. (the "overall forest management area" includes industrial plantations, which are not forests.) In addition, what "proportion" of the plantation is to be returned to "natural forest cover"? One per cent? 10 per cent? 50 per cent? Who will determine the regional standards? What if the area never had forest cover (e.g. Uruguay, Argentina, South Africa)? Are plantation owners then exempted from restoring part of their operations to non-plantation vegetation?
"10.6. Measures shall be taken to maintain or improve soil structure, fertility, and biological activity. The techniques and rate of harvesting, road and trail construction and maintenance, and the choice of species shall not result in long term soil degradation or adverse impacts on water quality, quantity or substantial deviation from stream course drainage patterns."
If this criterion were to be applied consistently, then no large-scale, fast growth, exotic tree plantation could be certified. Yet if applied carelessly, the criterion would allow a great deal of environmentally damaging practice. Who will decide whether this clause has been met or not? Most large plantation companies include (at least on paper) measures and techniques for environmental conservation. However, all their activities will necessarily have impacts --almost always deleterious-- on soil structure, fertility, biological activities and water. From our perspective, there is already enough evidence that, other things being equal, the species, harvesting methods, and maintenance techniques chosen for industrial monoculture plantations will result, as a rule, "in long term soil degradation or adverse impacts on water quality, quantity or substantial deviation from stream course drainage patterns." Yet of course theoretical studies can be found that claim that this need not be the case, and company studies that claim that fertility and hydrology have not been affected. Who will decide which experiences or set of studies are to be taken seriously? The FSC criterion is mysteriously silent about this key question.
"10.7. Measures shall be taken to prevent and minimize outbreaks of pests, diseases, fire and invasive plant introductions. Integrated pest management shall form an essential part of the management plan, with primary reliance on prevention and biological control methods rather than chemical pesticides and fertilizers. Plantation management should make every effort to move away from chemical pesticides and fertilizers, including their use in nurseries. The use of chemicals is also covered in Criteria 6.6 and 6.7."
This clause relies so heavily on vague wording such as "minimize", "primary reliance", and "every effort" that it becomes worthless in practice.
What are referred to as "pests" and "diseases" are frequently those native species which happen to be able to find food within the plantation (a food desert for most native fauna). Eradicating them is in fact a blow to local biodiversity. "Integrated pest management" is hardly great boon in itself if it implies nothing more than the protection of the exotic species against its few local (or exotic) predators. In addition, companies can easily claim that they are "making every effort" to move away from chemical pesticides and fertilizers without actually doing anything to lower their chemical use. In accordance with clause 10.6 (soil fertility), they will argue that there is no available substitute (given the scale of their plantations) to chemical fertilizers. They are already trying, they will say, to replace pesticides with silvicultural methods (thinning, prunning, spacing, etc.) for economic reasons, but, sadly, must still rely on chemical pesticides to a high degree. It is revealing, moreover, that criterion 10.7 says nothing about "moving away" from using herbicides, which are also harmful chemicals.
In many countries, plantation trees themselves easily become "invasive plant introductions". What "measures shall be taken to prevent and minimize" such introductions in South Africa, for instance, where it is the introduced eucalyptus, wattles and pines which have turned into "invasive species" in the native ecosystems?
"10.8. Appropriate to the scale and diversity of the operation, monitoring of plantations shall include regular assessment of potential on-site and off-site ecological and social impacts (e.g. natural regeneration, effects on water resources and soil fertility, and impacts on local welfare and well-being), in addition to those elements addressed in principles 8, 6 and 4. No species should be planted on a large scale until local trials and/or experience have shown that they are ecologically well-adapted to the site, are not invasive, and do not have significant negative ecological impacts on other ecosystems. Special attention will be paid to social issues of land acquisition for plantations, especially the protection of local rights of ownership, use or access."
This is perhaps the best-written criterion. However, its presupposition that "local trials" --which are always small-scale-- can prove the appropriateness of a large-scale industrial planting of a species to an ecosystem in general is mistaken. Small local trials can determine, up to a point, likely rates of growth of an industrial species on a site. They can also determine, to a certain extent, whether the species is likely to be invasive (although if it is in fact invasive, the trial itself will probably result in an invasion). But the only effective test of the social and environmental effects of large-scale plantations are large-scale plantations themselves. The criterion should therefore be revised to specify that no plantations will be certified in areas where there is enough evidence of substantial negative impacts (social, environmental or both) caused by existing large-scale plantations.
The last sentence ("Special attention will be paid to social issues of land acquisition for plantations, especially the protection of local rights of ownership, use or access") points in the right direction, but what does "special attention will be paid" actually mean? Does it mean that no certification will take place if any local right has been violated? What if the violation occurred at the hands of speculators or the government before the company bought or rented the land? And again, who decides whether enough "attention" has been paid to land rights issues? The clause is tellingly silent on this question.
"10.9: Plantations established in areas converted from natural forests after November 1994 normally shall not qualify for certification. Certification may be allowed in circumstances where sufficient evidence is submitted to the certification body that the manager/owner is not responsible directly or indirectly of such conversion."
This raises a series of questions --why November 1994? Why "normally" shall not qualify for certification --who decides what is "normal"? Who judges the evidence presented and on what criteria? Would a signed slip of paper saying "I wasn't there when it happened and I didn't do it" suffice? If a second company buys up the plantation from the company responsible for clearing the forest, can the second company then be certified? Presumably the second company wasn't directly or indirectly responsible for the "conversion".
In sum, Principle 10 does not seem to offer nearly enough guarantees to end-consumers that wood from industrial plantations is produced in a socially equitable and environmentally-friendly manner. Neither is the principle very useful for people struggling against plantations at the local or national levels. The main issue (large-scale monocrops) is not taken into account. The problem is not the tree species (eucalyptus, pines, acacias, etc.) but the overall plantation model, which the FSC unjustifiably accepts without discussion. We believe that this principle is clearly insufficient and needs to be substantially modified before it can be said to be appropriate to the reality of large scale industrial tree monocrops.
The FSC should review plantation certification
A troubling fact has come to our attention: an increasing number of large-scale tree monocrops are receiving Forest Stewardship Council (FSC) certification throughout the world.
Among the plantations recently given a "green" stamp of approval are Shell's plantations in Argentina, Chile, Paraguay and Uruguay; SAPPI's, MONDI's and SAFCOL's in South Africa; Klabin's and V&M Florestal's in Brazil; Perum Perhutani's in Indonesia; Fletcher Challenge's in New Zealand/Aotearoa and many others (see details below). If this trend continues, many more tree monocultures will also be guaranteed "sustainable" by the FSC, an organization which enjoys great credibility among the public.
The FSC was created as a result of increased awareness by consumers about their role in forest destruction, resulting from successful NGO campaigns, particularly regarding unsustainable logging practices in the tropics. When consumers began to ask their suppliers for certified wood, a number of NGOs decided to promote a process which could give them the choice of a "green" product. The NGOs came up with a number of principles and criteria that they insisted should be met before an FSC certificate was granted.
Nine of those principles are focused on forests and one on plantations (number 10). We believe that it is this decision --to allow large-scale monoculture plantations to be certified along with other forestry operations-- which lies at the root of the current disturbing trend. People throughout the world are increasingly aware that plantations are not forests. Numerous local communities and organizations have documented the impacts of large-scale plantations and opposed them because of their social and environmental impacts. The plantations in question have resulted either in deforestation or in the degradation of other ecosystems, particularly grasslands and wetlands. On the ground reality is showing that large-scale tree monocultures --no matter how many mitigation measures are implemented-- inevitably result in large-scale impacts on water, soils, flora, fauna and people because of their sheer scale.
Even if one accepts --which we don't-- that plantations are forests, the fact is that Principle 10 is so weak that most plantations --with the exception of those in areas marked by land conflict-- can be declared "sustainable" and given FSC certification (see article below).
We do not pretend to challenge the FSC and even less to question our NGO friends involved in it. What we do request is for them to revisit the whole issue of plantation certification, to take into account the plentiful existing documentation regarding the basic unsustainability of the plantation forestry model and either to exclude plantations from FSC certification altogether or to modify substantially Principle 10.
The FSC's main strength is its public credibility. Certification of unsustainable forestry operations --such as large-scale tree monocultures-- can erode this credibility. A critical review of its own principles by the FSC can only increase it. We sincerely hope that the FSC will be able to accomplish the latter.
RE-THINKING PLANTATION CERTIFICATION
Plantations are not forests
One of the main problems for those struggling against large-scale industrial tree plantations is the existing confusion (generated by the UN Food and Agriculture Organization) between forests and plantations (i.e. "natural" forests and" planted" forests.) The FSC's definition contributes to support such confusion by stating that plantations are forests: "Plantation: Forest areas lacking most of the principal characteristics and key elements of native ecosystems as defined by FSC-approved national and regional standards of forest stewardship, which result from the human activities of either planting, sowing or intensive silviculture treatments." That definition enables the FSC to include plantations in its list of "certified forests".
The FSC's definition might be a useful way of defining Northern managed forests, where the original forest has been so simplified that it has become more akin to a plantation than to a forest. But it is not useful at all for people struggling in Brazil, Indonesia, South Africa, Thailand and many other countries against large-scale monocultures of exotic species such as eucalyptus or pines. Such plantations are not forests: they are tree crops.
In spite of the propaganda about "plantations helping to alleviate pressures on forests", experience has proven that not only do plantations not alleviate pressures on forests but, on the contrary, that they are a major direct and indirect cause of deforestation. At the same time, they result in widespread environmental and social problems
(see http://www.wrm.org.uy/plantations/index.html )
What foresters call "afforestation" --creating so-called "forests" where they didn't exist before-- usually results in environmental destruction insofar as diverse local ecosystems are replaced by uniform tree monocultures. Despite the FSC's focus on the protection of forests, this type of environmental degradation was not sufficiently taken on board when the organization elaborated its principles and criteria. That perhaps helps explain the contradictions of certification in countries such as South Africa, with its predominant grassland ecosystem (see article below).
The FSC was created to protect the world's forests and forest peoples against destructive logging practices, by promoting the sustainable use of forests. Large-scale monoculture tree plantations have little in common with forests and result in serious environmental and social problems. We therefore strongly urge the FSC to exclude such type of plantations from its mandate.