When one has to consume tree flesh, more commonly known as wood, it’s best to use wood certified as coming from a responsibly managed forest. However, one person’s definition of responsible is another person’s nightmare. Whether forest management is a nightmare or a dream depends on both the reference point one starts with and who owns the land.
If the reference point is an often-clear-cut, short-rotation, chemical-soaked industrial plantation where profit is to be maximized up to the point of just barely avoiding jail or fines high enough to erode net present value, any forest management technique or restraint on fiber exploitation is viewed as positive. If the reference point is a pristine, rare, biologically diverse, carbon-concentrating, magnificent ancient forest, any forest management technique that allows fiber exploitation is viewed as negative. Regarding who owns the land, public forestland managers are held to a higher standard than private forestland owners.
An effort is presently afoot in one forest certification organization (and it will be followed by others) to certify federal public forestlands within the National Forest System. To date, forest certification has centered on privately owned lands or some state-owned “public” lands. Certifying federal public forestlands is a foolish idea that should be abandoned at once.
The Theory of Certification
As a whole, forests of the world are horribly managed. Usually the only way to profit from owning forests is either to mine them once of their wood and walk away or to convert them from real forests to tree farms—always to the detriment of biological diversity, watershed integrity, aesthetic appreciation, and social good.
By certifying forestlands as responsibly managed and recognizing measures taken to dial back wood exploitation so as to at least conserve a modicum of other forest products (air, soil, water, carbon storage, wildlife, fish, et al.), certification organizations make it possible for wood products to be marketed as “good wood,” “green,” “sustainable,” or the like. Consumers are willing to pay a premium for such wood or at least prefer it when purchasing comparable products.
Forest certification hasn’t worked out as well as hoped, but hope springs eternal (even in me) and certification is a worthy social and environmental endeavor.
Three Certification Organizations, One of Which Doesn’t Totally Suck
Formed in 1993, the Forest Stewardship Council (FSC) is—in relative terms—the gold standard of forest certification around the world. Although in absolute terms the FSC could be a lot better, in relative terms it leaves the others in the dust. An order of magnitude below the FSC is the Sustainable Forestry Initiative (SFI), an industry-controlled greenwashing machine. Another order of magnitude below the SFI is the American Tree Farm System (ATFS).
FSC certification means something. Compared to the reference point of an industrial plantation, a forest managed to FSC standards shows either significant improvement (says me the optimist) or significantly less damage (says me the pessimist). Forestland owners who become FSC certified are atypical forestland owners in that they willingly and voluntarily eschew profit maximization because they value stewardship and forest products other than just wood.
I specified as much FSC wood as I could get for building my home in southern Oregon. Rather than being framed with Douglas-fir, the house was framed with white fir from Collins Pine (arguably the most responsible large private timberland owner in the United States), taken both for profit but also to give room to late-successional ponderosa pine that originally dominated the site. The cabinets are made of formaldehyde-free FSC-certified plywood. The interior doors are 85 percent wheat hulls covered with a thin veneer of real wood.
SFI and ATFS certification are both greenwashing. The standards to be so certified are far less rigorous than for FSC certification and often approach “business as usual” practices so that profits are not materially affected.
The ATFS started in 1941. I remember as a kid seeing its distinctive signs adorning small private timberlands in the upper Willamette Valley. To maintain relevance the ATFS has gotten into the forest certification game.
The SFI arose because the mainstream timber industry considered FSC-certified wood a threat to its business model. After concluding it was better to join the sustainability bandwagon as one could not beat the legitimate public demand for more responsibly sourced wood products, the timber industry created the SFI. The SFI is far better funded and—as it has far lower certification standards—has more forest acres under certification than does the FSC.
It’s All About Market Share
One factor driving the FSC desire to certify national forest lands is trying to increase its market share. If not a measure of success, market share is a major aspect of survival.
The SFI poses an existential threat to the FSC. One example of how it does this involves the US Green Building Council (USGBC), which offers the widely used green building rating system known as LEED (Leadership in Energy and Design). The USGBC says that the “use of third-party–certified wood promotes good stewardship of forests and related ecosystems.” LEED certification is based on using certain kinds of materials, design, and construction when building buildings. Points are given for each green thing done, including using certified wood. If enough points are accrued, the building is certified. Initially the USGBC favored FSC-certified wood in its standards, because FSC-certified wood was most responsibly sourced and builders could find the FSC label.
Then the SFI, through old-fashioned lobbying and arm twisting, legal intimidation, and otherwise making life difficult, forced the USGBC to embrace any and all certification, thereby extending a false equivalency to all forest certification programs. Thus FSC-certified wood is no longer favored in the LEED standards and no longer enjoys that advantage to its market share.
The FSC’s Ploy to Certify National Forest System Lands
The FSC-US has recently issued FSC-US Forest Management Standard (V1.1): Complete with: Family Forest Indicators and Guidance and Supplementary Requirements for Lands Managed by the USDA Forest Service. The US standards apply only to the contiguous forty-eight states and not the territories.
“Family Forest Indicators and Guidance” is code for holding small forestland owners less accountable than large forestland owners. In the inevitable tension between high standards of certification and high penetration into the forestland certification marketplace, the latter is prevailing. “Supplementary Requirements for Lands Managed by the USDA Forest Service” means certification of units of the National Forest System.
The 124-page document goes deeply into the weeds of forest management and is not for reading by the faint of heart. Its language is bureaucratic, as the FSC is essentially a bureaucracy that must go into some detail so as to appear objective in the pursuit of awarding forestland certification, which is otherwise inherently a subjective process. (I offer the preceding as critique more than criticism, as I know of no other way to do it.)
The FSC-US standards are hierarchical, with nesting “principles, criteria, indicators, applicability, intent, and guidance.” While inherently logical in its structure, it not easy to understand. When a forestland owner requests certification, an “independent” (not FSC, but FSC-certified) entity conducts the evaluation. Fittingly, lots of paperwork must be done.
The FSC-US standards are fundamentally written with private forestland owners in mind, with an understanding that private profit is necessary and that standards too onerous will result in fewer forestland acres being FSC certified. The last nine pages are an appendix that attempts modifications, amplifications, and clarifications of the general FSC-US standards to accommodate circumstances unique to units of the National Forest System.
National Forests ≠ Private Timberlands
The ownership, needs, outputs, and legal requirements of private timberlands and federal public forestlands are fundamentally different (Table 1).
National forests are not private tree farms. National forests don’t need to make a profit, because their owners don’t require such and also appreciate that most forest products, while invaluable to society, are valueless in the marketplace. Being public lands, national forests provide nonmarket goods and ecosystem services that the private sector is unable or unwilling to provide. The ownership of private timberlands changes, while the ownership of the national forests never changes.
This disconnect is evident in the fact that the standards for national forest management imposed on the Forest Service by Congress are orders of magnitude higher than FSC standards. The theory of forest certification is to encourage a forestland owner to elevate forestland management above and beyond business as usual. For all of its faults, and they are multiple and varied, national forest management on a bad day exceeds FSC-certified management on a good day. The new FSC standard will generally not demand any more of the Forest Service than Congress demands now. Certification will not leverage better national forest management.
Besides that, FSC certification of units of the national forest will tend to give cover to bad Forest Service logging projects and reinforce the archaic notion that timber production on the national forests is essential, desirable, or beneficial.
As an example, take the matter of logging old-growth forests on the National Forest System. While clearcutting old-growth forest is illegal in many cases, such as when it affects a species protected under the Endangered Species Act, alas, as a matter of law, the clearcutting of old-growth forests on the National Forest System is not illegal per se. The FSC standard allows under certain circumstances the clear-cutting of old-growth forests on public lands, which is unacceptable under any circumstances.
A Split in the Conservation Community on National Forest Certification
Some conservation organizations either support or don’t mind the certification of national forest lands. Others are quite opposed, while still others aren’t aware of the threat.
I think that the conservation organizations that support certification of national forest lands sincerely believe that wood is generally good (it is, compared to concrete or steel or plastic, but not compared to alternative fibers), that wood from the national forests makes up a significant portion of the nation’s timber supply (it does not), and that showcasing certified forest management on public forestlands can have a salutary effect on private timberland management (it won’t, as the former doesn’t require profit while the latter does).
Those opposing national forest certification include but are not limited to the Dogwood Alliance, the Center for Biological Diversity, the Geos Institute, Greenpeace, KS Wild, the Natural Resources Defense Council, Oregon Wild, the Rainforest Action Network, the Sierra Club, the Western Environmental Law Center, and WildEarth Guardians. For fighting the good fight and often winning those fights for federal public lands, these are generally my go-to conservation organizations. (To this list I would add Earthjustice, Advocates for the West, and some others.)
FSC: Please Step Back and Stand Down
The remainder of this post is for just the FSC leadership. The rest of you should stop reading.
Let’s start with affirming that I believe in FSC goals, standards, and processes as they apply to private lands. Here’s why the FSC should abandon its effort to certify national forest lands:
Brand damage. It’s not going to help the FSC brand. Right now, I can unequivocally endorse the FSC and its certified wood. If the FSC label is applied to wood that comes from the national forests, I won’t be able to.
Lack of interest. It is unlikely that the Forest Service, even with a less evil administration than we presently have, will have any interest in national forest certification. Think like a bureaucrat for a minute. You are already ass-deep in federal requirements that limit your discretion to manage (actually the abuse of such discretion). The public is looking over your shoulder and/or is in your face for just about anything you try to do. Why would you voluntarily subject yourself to certification evaluation and oversight? FSC certification might be of interest to some of the mills that might buy the logs, but life is too short to add another bureaucratic quagmire to the one you already inhabit.
Annoying conservation organizations. Those conservation organizations fighting bad Forest Service logging projects will see FSC certification as a problem, not an opportunity. Hell hath no fury like a local conservation organization facing an existential threat to the public lands in its backyard.
Dissension in the conservation and sustainability communities. We should be fighting the real foes of responsibly managed forests, not arguing with each other as to whether commercial timber extraction is a legitimate goal of the National Forest System.
Opposition from the conservation community. We should continue to fight our common foes of the SFI and the ATFS, not each other. I warn you not to interpret the genteel concerns the conservation community has expressed to date as something that can be dismissed in your drive for market share. Public lands conservationists, especially with (but not limited to) the present administration, face a myriad of acute threats. Since near the beginning of the FSC, national forest certification has been a chronic threat that because of conservation community opposition has not advanced. As soon as one unit of the National Forest System tries to get FSC certified, all hell will break loose and fury will rain down upon not only the Forest Service but also the Forest Stewardship Council.
Consumption of your bureaucracy. Assuming that a unit of the National Forest System is FSC certified (see “lack of interest” above), most of the FSC’s resources will soon be consumed addressing the complaints you will receive (and that you invite under your process) alleging violations of the FSC standards. The complaints will be not only numerous but also substantive. One of FSC’s central principles is that certified forestland owners must comply with law. The Forest Service has a long and infamous record of violating federal law. As for numerous, conservationists now will be able to not only take the agency to federal court but also bring it up on charges under the FSC process. As for substantive, the complaints will be because the Freedom of Information Act results in a required level of transparency for public forestland managers that is not the case with private forestland owners.
She’s gone. You all know who I mean. The driving force that was a particular board member so focused on FSC certification for national forests is no longer on your board. Now she can neither hurt nor haunt you.
Forest Stewardship Council, the path you are on will not end in a good place. Continuing on such a path because no better path is presently available is foolish. Stop and find yourself a new path.