Why Five Out of Five Friends Network Facilitators Say "NO" to FSC Certification
Massachusetts wants to use certain forests for revenue generation and as fuel for biomass plants. FSC re-certification will allow this to happen.
Currently there are 5 large-scale biomass power plants slated to be built. These biomass plants will increase logging in public forests to 10 times greater than historical levels and consume 532,000 green tons of wood annually, requiring clear-cutting 6,200 acres, or partially cutting between 11,000 and 31,000 acres each year. Historical 1980- 2006 public land logging averaged 1,250 acres partially cut. (See: http://www.maforests.org.) Is this really "sustainable" and "renewable"?
MA lost FSC "Green" certification in 2009. Why?
Public outcry due to widespread evidence of FSC violations and aggressive logging practices, including thousands of acres clear-cut, and other forms of commercial grade logging in State Parks and State Forests---practices which were sanctioned by FSC over the past 5 years, caused the Commonwealth of MA to loose FSC certification. View the 2009 recertification evaluation audit report.
Now MA wants to recertify public lands. How does re-certification relate to the Forest Futures Visioning Process?
DCR has already decided that some properties are elgible for green certification and will be eligible for certification in the future. Does this mean that the Forest Future Visioning Process will not determine whether public lands should be certified? Will DCR and not the Forest Vision Process decide which lands are eligible for green certification, which implies timber harvesting?
March 18, 2010 Public Comment Summary and DCR Response to FSC Recertification
Read what people in other states and countries are saying about FSC Certification: FSC-Watch.
Read what the Forest Futures Advisory Group of Stakeholders have to say about FSC violations here.
Which forests slated be used for timber? Is your favorite on the list?
View state forests lists with reviewed management plans.
View state forests without reviewed management plans.
To view the state wildlife lands list.
Is FSC Certification is appropriate for Massachusetts public lands?
Re-certification Comments by Mass Audubon
1. FSC standards are designed to promote sustainable commercial timber extraction from industrial-based lands and are not suitable for tracts of public lands held predominantly for preservation, ecological restoration and recreational services. The purposes for management of public lands are supposed to be to support ecosystem functions, not to be in the timber business. A market driven system has no place overseeing management of public lands.
2. FSC Certification, as a market-based management tool, undermines conservation efforts in Massachusetts’ public forests where no such commercial imperative exists, and has hindered efforts to give greater preference to biological diversity, ecological restoration, and recreation. On behalf of FSC, Scientific Certification Systems assessments have criticized the Commonwealth for not producing greater amounts of board feet from public forest lands, placing production before conservation, encouraging the state to “capture market value” of growing trees, rather than allowing them to proceed to late successional or old growth status.
3. FSC is a private organization in competition with other certification systems with a vested interest in increasing and keeping lands under their certification.
4. The FSC auditing company, Scientific Certification Systems, benefits financially from keeping FSC ‘in business’ and keeping clients certified. SCS has displayed a lack of understanding of the significant nature of the controversies related to the forestry policies on DCR lands which led to the defacto logging moratorium put in place by the Commissioner of DCR and the DCR Stewardship Council. For details see SCS desire to control any and all future moratoriums: CAR 2009.1 and accompanying discussion (beginning on page 55 ) SCS report: http://www.mass.gov/Eoeea/docs/eea/lf/green_certification_report_2009.pdf
5. The auditors of Scientific Certification Systems do not respect or understand the intent of MGL c. 21 s. 2F which requires full value Resource Management Plans for each DCR park, reservation and forest. Although the Northeast Standard requires that a client complies with all state laws, they conveniently deem compliance with this law as unnecessary to meet FSC requirements. MGL c. 21 s. 2F was intended to find balance among competing values on Massachusetts’ public lands. This balance is being ignored by SCS. See discussion of Criterion 7.1 (beginning on page 95) of the SCS report.
6. SCS revised its requirement for site specific forest management plans when the state did not comply. SCS is not concerned that the district forest management plans have made no effort to set aside any areas as parklands or recreational assets where commercial timber harvesting will be prohibited to allow for dispersed and accessible recreation.
7. FSC certification also makes no mention of the other economic values state public forests provide, such as preserving aesthetic and scenic areas for the tourism values they provide. Economic value to certification is simply timber value.
8. SCS has not questioned why there are so many FOIA requests from citizens with respect to 2 forestry issues. Instead of investigating reasons for these public requests, SCS bemoans the fact that valuable time is wasted in responding to public complaints by the agencies, and implies that it might be advantageous for the state to charge citizens more money for responses to the requests. See Recommendation 2009.1 and discussion (beginning on page 63) SCS report.
9. Climate change is upon us but not covered by FSC certification. Our state forests play a significant role in mitigating the effects of climate change. FSC certification does not take climate change into consideration in any of its forestry guidelines. See: ( page 44) SCS report: public input comment suggests “all ecosystems are at risk; the agencies don't know how to address this and current policies are archaic in the face of the climate change situation.” SCS response: “not specifically addressed in the FSC standard.”
10. FSC Certification has been used to leverage funding from the legislature to facilitate commercial logging on public lands. Scarce funds have been diverted from Massachusetts public land ecological and recreational stewardship goals as a result, for the purposes of constructing logging roads, mapping public forest land for timber production and other expenses to prepare the lands for logging. FSC is a net money loser for Commonwealth taxpayers, costing far more than any financial benefits, and represents a subsidy for the wood
products sector.
11. FSC Certification has not provided the oversight and enforcement needed on MA forestry operations. Despite claims to be a performance based system, in practice it relaxes standards, adjusts deadlines and lavishes praise upon promises, progress and good intentions. Audits often rely on documentation from the members of the forestry staff themselves and thus do not attempt to maintain the claimed “independent” nature of the assessment.
12. FSC Certification is an unnecessary expense, an extra bureaucratic layer, and is not codified in state law, when what we need is stronger state laws and enforcement mechanisms defining a smaller percentage of state lands where exemplary forestry will set an example of performance to the highest standards.
Massachusetts Forest and Park Friends Network
www.networkingfriends.net
