Whit,
You make an
excellent point about my use of FSC green certification corrective action
requests. I think your question is very legitimate, and not at all
unfounded. I would like to explain.
In all of my
opinions about FSC certification, I have stated that I do not think it is
appropriate for multiple purpose public lands because it was intended to guide
forestry on lands where that is the main purpose of the lands...where harvesting
is the focus. In the process of seeing that its clients lands
are "productive", that forestry is economically viable, that forestry is
performed efficiently so that expenses are held down, they focus on those
goals. I grant that they do offer in the New England Standard certain
principles that are meant to protect the other ecological values of those
properties. Within that standard are some valuable concepts for such
protections. I do not see much in that standard to protect
social values and as a matter of fact, Corey Brinkema, President of FSC US has
said that later planned versions of the New England Standard will be focused on
improving attention to social issues. As I see it, it is a
question of focus: I personally believe that on multiple purpose
state owned lands, held in trust for the public who ownes them, making money on
the harvesting of the trees should be a MINOR ecosystem service, not the focus
of land stewardship. Instead of determining that we will harvest first,
and "watch out for other resources" while we do it, I think we should
be relishing the ecological and social values these lands offer, and using a
very small portion of these lands (if indeed any) for commercial resource
extraction. It is a question of focus.
The second
major point I have made is associated with focus: It has to do with
money. In its quest to get certified,and then maintain
certification, EOEEA has used that goal to obtain funds that facilitate logging,
possibly to the detriment of other ways precious funds could be spent on proper
stewardship of our lands. Emphasis on woodland roads, new vehicles for
forestry staff, expanded forestry staff, mapping and other efforts to identify
tree species and allowable cut figures... etc. etc. have been
expensive. At the same time we closed DCR pools in the heat of the
summer. There are expenses for conducting a top notch forestry
program, and in fact one of the main corrective action requests of the current
FSC/SCS report is for the state to identify access to the necessary funds to
keep their forestry program going to the green certification standards. At
the same time I see funding for Natural Heritage at a very low point. I
have to question whether green certification is driving the allocation of
funds and causing real problems for other budget priorities such as more
park rangers, park watch staff, programs to promote our recreational lands to
the public, maintenance of facilities... all of the other aspects of the
DCR mandate to be good stewards of these lands for the people who own
them..
The third major point I have made is that FSC/SCS certification has not
been effective as an oversight mechanism for forestry on public
lands. There is a distinction between the oversight (unacceptable)
during the first five year period and the oversight that took place at the
time of the recertification audit.
I have
observed what I call A perfect "storm" of events that all seemed to occur
at about the same time when citizens noticed a sudden increase in
harvesting on our public lands. We saw clearcutting of the red
pine and Norway Spruce plantations, more aggressive cuts in areas that were not
non native plantations, new energy in the Bureau of forestry planning that
included proposals for harvests in our state parks and in beautiful
sections of our state forests such as October Mountain. These events
included: The first FSC certification period (May 2004), the
reorganization of the divisions of EOEEA, the hiring of Jim DiMaio as the Chief
Forester, the creation of the DCR Stewardship Council, and the writing of
the Chapter 21, section 2F law requiring resource management plans.
It is impossible to know exactly which of those events (or whether there were
others) were responsible for what citizens saw as a major shift in forestry
policy on publicly owned lands.
But: during that five year period of time since May, 2004, we saw
the very things that are now cited as corrective action requests in the 2009
FSC/SCS report. We knew they were cutting and proposing
harvests in areas without management plans, per Principle 7 of the New England
Standard. We knew they didn't have the funding or resources to do
the site specific planning that was a "condition" of the first
certification. We knew they were not monitoring the cutting and
providing the results to the public per Principle 8. We saw evidence
of environmental damage that should not have occurred under Principle
6. We saw what the law seemed to say were illegal clearcuts on DFW
property per Chapter 131, section 4,part 16 (as a matter of fact,
the SCS reports of 2002-2004 directly said that clearcuts on DFW lands were
illegal in Massachusetts). We saw clearcuts that were called
shelterwood cuts and thought that BOF was violating laws that place
restricitions on cuts of 5 or 10 acres or more. These were violations
of Principle 1 which requires compliance with our own laws and
regulations. We saw lack of protection of seeps and streams
and vernal pools, inadequate filter strips or buffer areas, failures
to protect natural and cultural resources because of insufficient
inventories or inadequate data bases. There was much
more. In spite of all of this, FSC certification continued,
and praise was offered to the state for "progress, promises and good
intentions". Conditions were changed, time deadlines were extended and
each annual audit ended with the words: "the state is in overall
compliance with the New England Standard and deserves to continue to be
certified". Complaints to individuals in the agencies were met
with broad assurances that we should not worry, "we are green
certified".
Many citizens
became concerned that FSC/SCS was glossing over unacceptable forestry practices
and was not guaranteeing the citizens of Massachusetts that "our forests are
well managed". We saw FSC/SCS as Cheerleaders, rather than judges of a
performance based system of evaluation. A large number of
stakeholders communicated directly with leaders of Scientific Certification
Systems and with their auditors. We asked "how can this
be?" We offered specific examples. We even reached the
point of suggesting to SCS that if they did not stand in judgment of what we
knew to be unacceptable forestry by their own standards, and lack of compliance
with their own principles, that their credibility as an auditor for FSC would be
on the line.
And so:
Massachusetts did not keep its certification in April, 2009. How can any
of us know exactly why the SCS report suddenly came up with corrective
action requests that validated many of our concerns? We are glad they
did. But, is this what makes good oversight? We
are very concerned about having an "outside entity" be in charge of
enforcement of our forestry practices if it requires a "watchdog" citizenry to
make them do their job. There is also a fundamental problem with
the fact that FSC/SCS has established major and minor corrective action requests
for this (and past) audits. The Major ones are in large
part administrative: the state is to officially designate and provide good
reasons for the lands that will be in the scope of FSC certification. Also
it must demonstrate that it has done monitoring and made the reports available
to the public. Once those two corrective action requests are
satisfied, FSC will grant certification to the state, IN SPITE OF ALL OF THE
OTHER CORRECTIVE ACTION REQUESTS THAT ARE STILL OUTSTANDING.
.
I
do not consider the remaining outstanding corrective action requests to be
Minor, as they do. I do not believe that a certification system that
allows its logo to go on wood from Massachusetts and declares the client to
have 'well managed forests" should grant such a "title" until it is
sure that all of the corrective action requests are complied with.
We should comply first, and then earn the certification.
I agree that there
is some irony in the fact that I now hold up those corrective action
requests to the state. If it turns out that I am in
a minority of people who believe that FSC/SCS certification focus is wrong
for public lands, that being certified has sucked up too much of our money
that should have been used elsewhere, and that they have not and do
not make sufficient demands for compliance with their principles, then
I will have to accept being in that minority and then see how I can best
use FSC certification. I will look to the corrective action requests
that have been made, and ask why the state is not yet in compliance with
them. I have already asked what we can do about the fact that the
state is actually violating some of the corrective action requests during
this non certified period of time. I will ask, "if we want
guidance from FSC/SCS for our forestry, why do we appeal their observations and
requests?" I will use the fact that SCS has provided validation
of stakeholder concerns to see if both parties to the
relationship, FSC/SCS and the state, are fulfilling their
obligations as we expect them to do and as we are paying them to
do. Claudia
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