Forest Certification Considered for National Forests

For many years now, the timber industry has responded to the demand for a reliable sustainably harvested wood supply. Similar to the idea of an “organic” label, forest certification programs were established as a market-based incentive for the industry to provide consumers lumber and wood products that were logged in a way that met certain environmental standards. The prevailing certification labels are Sustainable Forest Initiative (SFI) and Forest Stewardship Council (FSC).

Meanwhile, national forests have become a decreasing source of timber and an increasing source for recreation, clean water and healthy wildlife. Our understanding of the importance for these resources has become a predominant public interest issue. Taking the protection of our remaining wild places out of the hands of the public and further into the financial market’s hands would pose significant threats to these interests. With over a third of all Oregonians’ drinking water originating on the slopes and in the forests of Mt. Hood National Forest, the health of our municipal watersheds should be a top priority in management decisions, not furthering the timber sale program.

In 2005, the Pinchot Institute for Conservation (http://www.pinchot.org) began a test study on sustainable certification of logging in our national forests. Mt. Hood National Forest was one of six forests in the test study. The results of the study were released in 2007. Despite the study finding wide-ranging fault with the concept and feasibility of certification, the Forest Service began a round of stakeholder meetings to test the waters with environmentalists and industry only a year later. Last week, before completing all the scheduled meetings, the Forest Service advanced the concept further by announcing a 60-day public commenting period. After reading information provided below, please consider writing comments before November 17th.

This concept brings up major points of concern for both Mt. Hood National Forest and the National Forest system as a whole:

OHVs
Currently only 4 law enforcement officers police Mt. Hood National Forest, including the enforcement of a growing presence and impact from Off-Highway Vehicles (OHVs). Mt. Hood National Forest has over 4,000 miles of roads and adequate monitoring of OHV usage cannot be implemented. Areas such as LaDee Flat in the Clackamas District have caused dramatic impact and conflict. Signage communicating rules will almost immediately be illegally removed by users once posted. The Pinchot Institute report addressed the same issue in its findings stating, “The FS [Forest Service] cannot control unauthorized OHV/ATV access as effectively as in the past due to budget limitations.” Additionally, the study stated, “FS no longer bothers posting signs, as they get shot up or torn down almost immediately by users” and this “Lack of posting, whether by inaction or action of OHV users, creates an impossible enforcement problem given the level of damaging use.”

ROAD SYSTEM
The analyses of the Pinchot Institute and Bark (through our own surveying of the road system) have both proven a serious lack of attention to the road systems by Mt. Hood National Forest. As stated in the Mt. Hood National Forest evaluation by the Pinchot Institute, “Presently, roughly 50% of the road network on MTHNF [Mt. Hood National Forest] is not needed to support management activities and public access needs on the Forest. Because of budget reductions that have, among other things, resulted in the elimination of the Forest road maintenance crew, the overall level of road maintenance effort is insufficient to keep the road network in good condition.” Later the report stated the continued inadequacy with, “There is, as yet, no completed road management plan for the Forest.”

RECREATION IS THE PUBLIC PRIORITY
A recent recreation study, The Cordell Outdoor Recreation Trends found that, “From 1999 to 2008, the total number of people who participated in one or more of 60 outdoor activities grew by 4.4 percent, from an estimated 208 million to 217 million (Cordell 2008). At the same time, the number of days of participation across all participants and activities increased from 67 billion to 84 billion, growth of approximately 25 percent.” The Pinchot Institute came to the same conclusions in consideration of the proximity of Mt. Hood National Forest to the Portland/Vancouver Metropolitan area and the resulting “heavy recreational use” when it referred to Mt. Hood National Forest as an “urban national forest” which requires a “unique management environment.” Ensuring the highest standard for recreation access and opportunity would not be a part of the certification standards and could have the effect of allocating even more funds away from important planning and maintenance needs for recreation.

NW FOREST PLAN ALREADY PROTECTS OUR OLD GROWTH TREES
According to the Pinchot Institute’s findings, the FSC guidelines are in direct contradiction to the Northwest Forest Plan. The Northwest Forest Plan was passed in order to control and mandate the commercial industry in the Pacific Northwest Region, with particular consideration to the importance of our ancient forests. The usurping of this law to a commercial entity is a direct negation of the purpose of such deep seated legal history. Moreover this conflict is in direct violation of Principle one of the FSC which states that “Forest management shall respect all applicable laws” and at the same time “comply with all FSC Principles and Criteria.”

MONITORING
FSC Guidelines are very specific and strict as to the necessary methods for harvesting, thinning, and reseeding. Though such guidelines may be written into timber contracts the monitoring of actual behavior is insufficient to be sure such guidelines are being followed. Even with current regulations timber harvests are regularly increased illegally by commercial logging in our national forests. As the budget of the Forest Service continues to be cut, a new level of even stricter monitoring is not feasible.

STRENGTHEN LAWS
If the conversion to FSC is designed to increase the stringency of the current standards, the standards can be amended through National Environmental Policy Act without the need for FSC certification. The areas of the FSC which are deemed to be of greater value can easily be implemented by the Forest Service. The analysis of the Pinchot Institute has provided many recommendations of places the Forest Service can improve the quality of the forests.

THE PUBLIC IS MORE THAN JUST A CONSUMER
In order to achieve certification, the Forest Service must adopt and memorialize a policy assuring that when conflicts arise between US law and FSC guidelines, such conflicts will be referred to the FSC for resolution. The National Forests are public lands and the property of the United States citizenship. By allowing a third party consumer entity, with an obvious bias, to resolve conflicts of public lands the rights of the land owners – the public – are being removed. NEPA was a revolutionary act because it allowed the public to sue their government over decisions that affect their tax-payer owned lands. By allowing FSC to be the fall back for conflicts, this policy removes this essential power of the citizenship to dispute how the lands their tax payer dollars fund are being managed.

CONSUMER LABELING OF PUBLIC SERVICES
In our current media-saturated society, National Forests are a lasting symbol that not everything can be bought. By branding our National Forests with logos, such as the FSC certification stamp, we are allowing one of the few standing corporate-free icons of our society to be auctioned off.

NATIVE RIGHTS
Many native groups use and occupy sections of the National Forests. Their rights to use these lands have been long-established and held together by informal memorandums of understanding. According to the second FSC Principle these rights would need to be “legally established.” Such legal processing could jeopardize trust in these long standing relationships. The Pinchot Institute seconds this concern in its assessment, “Huckleberry gathering is an important tribal use on the Forest, and MTHNF managers have pursued various strategies for providing for this customary use. However, there is acknowledged uncertainty as to whether tribal gathering can be assured through a formal designation/reservation.” Native Rights across the country need to be assessed in much greater detail in order to avoid disrupting the positive interactions which have been established.

If you have additional questions, please contact Bark volunteer, Brynn Dahlquist at brynniewynnie (at) hotmail (dot) com.

For more information, check out http://www.fs.fed.us/projects/forestcertification/index.shtml. Send your comments to:
Doug MacCleery
USDA Forest Service (FM)
201 14th St. SW., Mailstop: 1103
Washington, DC 20024
Comments may also be sent via e-mail to [email protected], or via facsimile to(202) 205–1045.
Please send a copy to amy (at) bark-out (dot) org, so that Bark may ensure that the agency responds to your comments.