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Climate & Energy
Certification and the National Forests
Will Price

For 20 years the US Forest Service has watched a revolution in forest management from the sidelines. “Independent third-party certification” originated in the private sector to assure the public that the wide range of forest products they are buying come from responsibly managed forests, whether it is paper from Staples, tissues from Target, or lumber from Home Depot. Since the emergence of forest certification the construction industry has undergone a similar revolution, as green-building standards have been adopted in urban revitalization projects. Public investment has brought increased attention to environmental impacts, energy efficiency, and the materials that are used. Leadership in Energy & Environmental design, or LEED, the green-building standard that is best known and most widely-supported by the environmental community, favors the use of certified wood. Points are awarded for projects that use wood certified to standards set by the Forest Stewardship Council (FSC).

Certification is widely considered the best proof that forest products are from sustainably managed forest lands. Without certification landowners must convince their neighbors, buyers, shareholders, investors, and/or constituents by themselves, on the strength of their own word. Companies and public land management agencies that have achieved certification can point to their certification label when their practices are challenged. For example, Asia Pulp and Paper, one of the largest and most maligned companies logging in the tropics, has sought FSC certification as a way of countering persistent criticism from environmental and social activists.

Restoring public trust is perhaps one of the Forest Service’s most enduring challenges of the last half century. The agency’s management of the National Forests was criticized by the environmental community in the 70’s, by industry in the 90’s, and by local communities all along the way. As a result, Forest Service leaders have been challenged in Congressional hearings, community meetings, and courtrooms over the years. So the potential for rebuilding trust is at least one benefit of certification for the Forest Service. Perhaps now, when the agency is even more pressed to restore vast expanses of forest to avert catastrophic fires, greater trust and acceptance may prove critical. Whether certification can cultivate trust in the agency while improving National Forest management, and doing so without overburdening forest planners and accountants remains to be seen. The question remains, should the National Forests get certified?
Backpacking on the Allegheny National Forest. Credit Joe Philipson CC BY-NC-SA 2.0

Two Decades of Certification
Certification has had an interesting history in the US. FSC was launched by environmental groups in 1994 following the failure to address deforestation at the 1992 Earth Summit in Rio de Janeiro. It quickly gathered steam as progressive companies saw a way to prove that their products complied with a set of standards supported by environmental groups. In 1998, with FSC growing, and certification labels becoming important in the marketplace, the American Forest and Paper Association began to transition its Sustainable Forestry Program into a an independent organization, the Sustainable Forestry Initiative (SFI). Both FSC and SFI have evolved over the years. As the FSC-US office grew from its home in Vermont, to Washington, DC and then its present Minneapolis headquarters, their certificates proliferated. FSC’s label is now on everything from Kleenex to plywood. SFI has also grown rapidly, bringing along most of the acreage from an association representing much of the US forest products industry, and its standards becoming recognized by the Programme for the Endorsement of Forest Certification (PEFC), a global certification system based in Europe.

As of this year there will be almost a billion acres of forestland certified by PEFC and FSC worldwide. For both FSC and SFI, about two-thirds of the land in North America certified under each program is in Canada, much of it federal or “Crown Lands.” In fact, more than two-thirds of the FSC certified acreage globally (~450 million acres) is public, government-managed, or equivalent.1 So how is it that the US Forest Service—considered by many to be the leading forestry organization in the world—counts not a single certified acre amongst its 193 million acres of National Forest land? Until recently, the Forest Service and FSC were mutually disinclined to seek certification for National Forests. Several environmental groups supporting FSC felt that US National Forests should be an exception.To put it differently, they did not want FSC to sanction the timber harvesting program in the National Forest System.

Are National Forests an Exception?
The National Forests have always been on the frontlines of the conservation movement. First established to protect forest from over-exploitation, then tapped to fuel the war effort and economic growth, and more recently serving as the crucible for ecosystem management, the National Forests have always been surrounded by controversy. The American public has continually debated the balance of uses of National Forests, and laws like the National Forest Management Act have made public consultation a formal part of the decision process.This debate has sometimes simmered in communities near National Forests, dividing them on questions of existence and identity— e.g. are we loggers or birders, or both? At other times it has reached Washington, DC, involving the White House, Congress, and organized national interests. Right now the debate is again edging onto the national stage. With another record-breaking wildfire season upon us and mounting documentation of shifting habitats, how will the Forest Service again rebalance forest management to better address climate change mitigation and adaptation?How can certification help the Forest Service deal with these challenges?

Sunrise in a longleaf pine forest. Credit Flickr user UGArdener CC BY-NC 2.0 FSC and SFI have differed on whether National Forests should be considered an exception for certification. From the time the question first arose, SFI has been willing to consider certifying National Forests. For FSC, National Forest certification could cause an internal conflict that would be difficult and expensive to navigate, so for many years they upheld a policy essentially prohibiting FSC certification of National Forests. In the meantime other federal forest lands have been certified by FSC, including forests managed by the military and the National Park Service.2 The exception has at times been glaring for the Forest Service, whose representatives at international meetings were often questioned why National Forests were not allowed to be FSC certified. So the discussion on whether certification is appropriate for a National Forest is really a debate about FSC certification in particular, and how some FSC supporters regard the Forest Service.

One of the reasons proponents would like to see National Forests certified—expanding the supply of certified wood from well-managed forests—is a Gordian Knot for some environmental groups that have been FSC’s key supporters.To them supporting an increase in the supply of certified wood by encompassing the National Forests perches them on a slippery slope. They have fought for years to shrink the timber program; would certification significantly expand timber harvesting? Meanwhile, there are FSC-certified wood products companies that are disadvantaged because they are surrounded by National Forests whose wood supply cannot be certified.

In some ways this is the same problem some in the environmental community had to navigate when helping to launch FSC: they were cautious about endorsing logging operations, but recognized that wood could come from well-managed forests. It is the same problem now bedeviling both certification systems as they wrestle with, and defend, their standards on allowing some percentage of wood from lands that are not certified— i.e. what should be included in their “chain of custody,” and how much risk is too much to bear?3 A portion of wood products sold with certification labels is not actually from certified forests; some of it may even be coming from US National Forests.4

The Forest Service also recognizes that it is an exception, having been repeatedly tested in the battle between sustainable use and chronic abuse of natural resources, and is wary of inviting still another kind of scrutiny or conflict. The growth of certification systems in the US and around the world has been associated with acrimonious competition in the marketplace. FSC, SFI, and many proponents of each standard have a history of fierce debate, a dynamic the already embattled Forest Service has not wanted to further inflame.

Zack Frank/Shutterstock.comA simple solution, at least to the competition between the two certification systems, was pioneered with several state forestry agencies that sought certification from both FSC and SFI. From 1997 until 2003, with support from the US Forest Service and private foundations, the Pinchot Institute worked with a number of states and Indian tribes to see whether certification was achievable and served their needs. Many became FSC and SFI certified as a result. They cited many reasons for choosing to certify their forests. For example, representatives of the Pennsylvania Department of Conservation and Natural Resources said that despite some additional work and the cost, the holistic review and constituency support certification engendered reduced the staff time devoted to resolving public conflicts. All the agencies had to make adjustments. Often they already knew certain shortcomings existed but certification audits served to draw attention to these issues and secure new resources to address them.

Soon after the pilot certification studies with state agencies and Indian tribes, which brought certification to more than 6 million acres of forest land in the US, the Institute began working with the US Forest Service to consider “test audits” on a few case study National Forests. In 1998, the Forest Service had considered the possibility of certifying the Lakeview Federal Stewardship Unit in Oregon (or at that time the “Sustained Yield Unit”). The Forest Service, FSC, and stakeholders concluded that certification would be premature. This experience gave rise to the FSC Federal Lands Policy mentioned above. It was really a National Forest System policy, and it established three somewhat circular and vaguely defined conditions: a willing landowner, stakeholder consensus about management of the National Forest, and a set of considerations additional to the FSC Standard.
National Forests Audited in the 2007 Certification Study

To better understand how certification could affect a National Forest— and whether there were insurmountable obstacles (e.g. some conflict between certification standards and federal policy)—the Institute and the Forest Service compared the management of seven National Forests against FSC and SFI standards. A “paper study” analyzed thousands of pages of planning documents, directives, and guidance. With no insurmountable policy barriers evident, the Institute and the Forest Service then organized the “test audits” on the seven National Forests. Nevertheless, while the study involved all the steps in an actual certification audit, the FSC Federal Lands Policy meant that the study could not lead to actual certification. It even included a mock set of what were called additional considerations that laid out potential new standards unique to the mission and management of National Forests. Developed through broad stakeholder consultation, these considerations were wide-ranging and forward- looking: for example, testing a National Forest on how it is addressing climate change on the forest and the surrounding landscape.

NF Certification Study The report focused on five National Forests: two in the Pacific Northwest, one in the Lake States, one in Pennsylvania, and one in Florida. The study yielded important findings, including a demonstration of what would comprise an audit for a National Forest. Auditors both marveled at and complained about the comprehensiveness of the documentation used by the Forest Service—“more forestry paperwork than any other forest in the world.” This flood of paperwork contributes to what critics, and the Forest Service itself, have called “analysis paralysis.” The supposed benefits of the documentation is that the agency is prepared for any contingency, management activity, or policy change.The study found instances in which National Forests fell short in implementing their own plans and priorities or encountered internal resistance when attempting to do so.

Certification is unlikely to significantly affect the planning process defined by the rules and regulations governing the National Forest System. That certification could reduce these requirements is a concern expressed by some environmental groups. The Forest Service would still have to fulfill the requirements of NEPA, ESA, NFMA, and all other applicable laws. Forest Supervisors would still need to assess the impacts of proposed projects, consult the public, and weigh alternatives. They will still need to monitor the status of rare plants and animals and understand how their management decisions affect these resources. And they would still need to seek biological opinions in response to concerns raised by the public. Certification in fact adds independent oversight on whether and how the Forest Service is meeting its own requirements.

Teaching to the Test or Real Improvement?
So what can certification add? Perhaps the best way to evaluate whether certification can serve the public interest is to look at the major problems the Forest Service faces, and consider what certification could do to help. Could FSC and SFI help the Forest Service materially improve its management of a National Forest? Or would certification be akin to an overly burdensome testing mandate, adding to the already heavy workload of National Forest managers without significantly improving the health and management of our forests?
View of Mt. Hood from Trilium Lake, Mt. Hood National Forest. Credit C.B. Aberlé CC BY-NC-SA 2.0

The findings of the study suggest there are two major ways in which certification could be helpful.One is at the field level, where it showed that a holistic review helped draw attention to chronic and systemic problems and secure additional resources to resolve them. A second way addresses trust and relationships with stakeholders. As in the certification pilots with state agencies, the audit findings on National Forests identified barriers to reaching stated goals. This was especially true on the Lakeview F
ederal Stewardship Unit, where in the 1990’s the Forest Service experimented with a new approach to National Forest management. In reviewing this Unit as part of the study, Scientific Certification Systems found that the Forest Service had either set unrealistic goals or needed to find more money and/or a new a way to get work done. For example, the Forest Service consistently fell short of its stated goals for forest restoration and road decommissioning. Based on the results of the test audits on five National Forests in the study, a common element was the inconsistency between what is planned and what is accomplished.

A comprehensive independent review can be an opportunity for adjustment occurring more frequently and with harder deadlines than decadal forest plan revisions.The Forest Service has long done periodic internal reviews usually conducted by the regional line officer and staff, with participation from the Washington office as well. These reviews provide important overall evaluation and guidance but they are by nature internally focused and largely closed to the public. Reviews by a third party that has seen the books, reviewed projects in the field, and interviewed a diversity of external stakeholders can offer important new insights and provide the public transparency that is essential for rebuilding trust.

So perhaps the most important potential benefit of certification is the way in which it engages external stakeholders and speaks directly to the public. To this end, certification may be more beneficial on some National Forests than others. Some forests may not be interested or ready, while others may be eager or looking for new ways to accomplish their mission. Certification could help reset the relationship between the Forest Service and its critics. Like an independent financial audit, certification is intended to evaluate any organization’s performance relative to its stated policies and objectives, in the broader context of widely accepted standards of practice. Certification does not establish goals— which are a matter for the public to decide through existing policymaking and planning processes—but it can help promote the understanding and public trust necessary to achieve them.

Will Price is Director of Conservation Programs at the Pinchot Institute in Princeton, New Jersey.

1 https://ic.fsc.org/preview.facts-andfigures- november-2014.a-3810.pdf
2 Marsh-Billings Rockefeller National Historic Site is a demonstration and teaching forest in Vermont encompassing about 500 acres, and was certified through a pilot project coordinated by the Pinchot Institute.
3 This is another discussion altogether, along with the related question of how much wood from National Forests is already sourced for use under FSC and SFI labels.
4 The SFI Fiber Sourcing label most prevalent in the marketplace can contain more material from forests that have not been certified (100% is allowable). FSC’s “Mixed Sources” label requires an average of at least 70% from certified forests.
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