FSC (Forest Stewardship Council) is a non-governmental non-commercial member organization, founded in 1993 by a group of nature conservation organizations, forestry enterprises, traders and forestry trade unions. The primary goal was to protect tropical forests from intensive logging. Nowadays FSC Forest Management Standard is widely spread among the world. Obtaining FSC Certificate enables enterprises to sell timber and wood-based products on European and American markets.
As SFRA (State Forest Resources Agency of Ukraine) states, 3,92 million ha of forests are now certified in Ukraine. The temp of certified forests increase is one of the highest in Europe. Nevertheless, as the analysis by EPL demonstrates, quantity does not mean quality. Even State Forest Enterprises (SFEs), which obtained the Certificate years ago, do not always comply with the Standard.
Forest Management Standard
The Certificate of compliance of forest management with FSC Standard is issued by specialized audit firms, which have relevant licenses. There are three of them in Ukraine – NEPCon, SGS Qualifor and “Forest Certifiation” (aka Legallis). Also there is an FSC National Office in Ukraine, which conducts overall coordination, support, promotes forest certification, but does not conduct audit control.
By now, National Forest Management Standard awaits for acceptance, so when conducting audits audit firms use their own Standards. For example, here is the NEPCon Standard: https://www.nepcon.org/library/standard/fsc-forest-management/nepcon-interim-standard-ukraine-UKR.
Differences between Standards, from an average activist’s point of view, are nonsignificant, as all Standards are based on the next FSC Principles:
Principle 1: Compliance with Laws. The Organization shall comply with all applicable laws, regulations and nationally- ratified international treaties, conventions and agreements;
Principle 2: Workers Rights and Employment Conditions. The Organization shall maintain or enhance the social and economic wellbeing of workers;
Principle 3: Indigenous Peoples’ Rights. The Organization shall identify and uphold Indigenous Peoples’ legal and customary rights of ownership, use and management of land, territories and resources affected by management activities;
Principle 4: Community Relations. The Organization shall contribute to maintaining or enhancing the social and economic wellbeing of local communities;
Principle 5: Benefits from the Forest. The Organization shall efficiently manage the range of multiple products and services of the Management Unit to maintain or enhance long term economic viability and the range of environmental and social benefits;
Principle 6: Environmental Values and Impacts . The Organization shall maintain, conserve and/or restore ecosystem services and environmental values of the Management Unit, and shall avoid, repair or mitigate negative environmental impacts;
Principle 7: Management Planning. The Organization shall have a management plan consistent with its policies and objectives and proportionate to scale, intensity and risks of its management activities. The management plan shall be implemented and kept up to date based on monitoring information in order to promote adaptive management. The associated planning and procedural documentation shall be sufficient to guide staff, inform affected stakeholders and interested stakeholders and to justify management decisions;
Principle 8: Monitoring and Assessment. The Organization shall demonstrate that, progress towards achieving the management objectives, the impacts of management activities and the condition of the Management Unit, are monitored and evaluated proportionate to the scale, intensity and risk of management activities, in order to implement adaptive management;
Principle 9: High Conservation Values. The Organization shall maintain and/or enhance the High Conservation Values in the Management Unit through applying the precautionary approach;
Principle 10: Implementation of Management Activities. Management activities conducted by or for The Organization for the Management Unit shall be selected and implemented consistent with The Organization’s economic, environmental and social policies and objectives and in compliance with the Principles and Criteria collectively.
In theory, Certified SFEs must comply with the strict Standard requirements: protect rare species; detach high conservation value forests with the special management regime; mark 5% of the forests as representative and conduct no logging there; after logging leave a certain number of trees on a plot as seed trees and biodiversity hotbeds; build bridges across water bodies for timber transportation and never transport timber down the rivers.
Among the other requirements, there are: properly prepared land documentation; compliance with the national legislation; annual preparation of the Environmental Impact Statement; openness for public representatives etc. There is even a requirement to control that a logging crew wears helmets and waistcoats and does not leave any waste in a forest.
Unfortunately, in reality we often observe different. There are SFEs, which diligently comply with most requirements of the Standard. However, as EPL analysis shows, there are other examples of formal, nominal compliance with the Standard, when auditors disregard obvious nonconformities.
The typical nonconformities of FSC Standard requirements in Ukraine, according to EPL, are:
Violations of the national legislation:
most certified SFEs disregard letters of request and appeal, which are sent by average citizens via e-mail, despite the fact that the national legislation allows this mailing method;
despite the Forestry Codex requirements, SFEs do not approve forest inventory documents with the Ministry of Ecology;
disregarding requirements of the Law “On fauna protection”, SFEs conduct sanitary logging during the “silence season”;
conduct logging without necessary documents (limits) and within the plots, where such logging is forbidden;
Not involving true stakeholders to the certification process. Usually auditors limit themselves by sending news concerning audits to main NGOs and publishing such information on FSC website. Local stakeholders – regional ecological departments, local high schools, protected areas – are rarely being informed. Therefore, such stakeholders have no idea about the certification process. As a result, representative and high conservation value (HCV) forests are poorly identified and rare species are identified deficiently.
Not involving biologists to the certification process. As a result – foresters themselves develop an environmental impact statement (EIS) and a rare species list. This means that no identification of protected species localization is being held – it is impossible to talk about “sustainable” or “responsible” management without this. EIS are developed only nominally, they include dozens of mistakes and inaccuracies, and no actual impact assessment is made. For example, several certified SFEs protect beavers, badgers, may-lilies and even Weymouth pines as “protected species” (obviously they are not protected, moreover, the Weymouth pine does not even naturally occur in Ukraine). Sometimes mythical creatures are listed in the EIS (“grey crane”), and among the key biotopes there are “plots with vegetation communities” and “plots, which differ by moisture regime”, which is nonsense from the biological point of view.
Dragging (skidding) logs through waterbodies and conducting logging within the overwet (overmoisturized) plot during the “wet” season.
Protected species are usually being identified only within non-commercial forests, so that no new protected zones appear and, therefore, logging amounts do not decrease.
Representative plots mostly consist of existing protected areas, and not of the plots, which should be representative according to the Standard. Moreover, such representative plots undergo intensive sanitary logging (even within the broad-leaved forests), which results in destroying natural processes in the forest and thus discrediting the idea of representative plots establishment.
Seed trees, as biodiversity hotbeds, are not always retained after a clear cutting. Sometimes such trees are retained only nominally – SFEs retain only trees of no commercial interest.
Include alien species. For example, certified SFEs of Cherkasy region plant eastern black walnut (Juglans nigra) instead of logged native forests of oak and ash.
No control of invasive species (Acer negundo, Quercus rubra) is being implemented.
Not implementing novel logging techniques. For example, p. 5.3 of NEPCon Temporary Standards states “logging techniques being used must avoid damage of retained trees and trees being harvested”. In reality, cable cranes are extremely rare, old vehicles are still being used for logging, which is much cheaper. As a result – severe damage to the soil layer and retained trees.
And logging crews wearing helmets and leaving no waste in a forest after logging raises a smile among anyone, who regularly visits forests. It is a big luck – to see a logger wearing a helmet, and there are usually bottles and tare from fuels left in the forest after logging.
Most of such nonconformities are obvious, but audit firms, which issue Certificates, usually disregard them. A reason for this may lie in a competitive situation, which appears in Ukraine. Outdated forest management practices of most SFEs do not comply with the FSC Standard, changing such practices requires much efforts and resources. Herewith, the Certification process is also not free – audit firm receives a lot of money for audits.
Therefore, we observe a situation, where one of the audit firms, not willing to lose clients, conducts “dumping” and ignores nonconformities – and other audit firms are forced to be more ignorant and disregard violations. Otherwise, not a single SFE will turn to such “strict” audit firm – the Certification process is voluntarily and a SFE can choose an audit firm by themselves.
Logging within the “Tsuman Puscha” Nature Reserve, representative plots
According to auditors, this is a normal situation
It is expected, that such problems are solved by ASI (Accreditation Services International) – an independent body, which can suspend audit firm accreditation in case of revealing any nonconformities in their work.
In reality, inert role of civil society and complex bureaucratic procedures of complaint revision make this mechanism almost useless. For example, EPL submitted a complaint concerning Volyn Regional Forestry and Hunting Economy nonconformities to NEPCon in Ukraine. It was revised for 3 months and now, according to the procedure, it is revised by NEPCon Central office in Estonia. Only after such revision, the complaint can be submitted to ASI.
One must admit, that NEPCon does not consider as major nonconformities violations of the national legislation (logging within the Nature reserve, which is now being investigated by the police; SFE authorities received a suspicion of violating of p. 246 of Criminal Codex) and logging within the representative plots.
EPL complaint and NEPCon response can be viewed here.
Moreover, most auditors – the ones, who actually assess SFE compliance with the Standard – are usually the representatives of the forestry sector. Most of them are lecturers of the Forestry High Schools. Audit firms only sometimes involve biologists of ecologists, who can provide an opinion concerning nature conservation aspects of the certification without bias. Therefore, audits are conducted biased; auditors are in league with the foresters when facing controversial questions.
Nevertheless, there are some positive examples. For example, “Legallis” audit firm always posts announcements of future audits on FB and personally contacts nature conservation NGOs representatives. Also while conducting certification of Seredyna-Buda SFE, the SFE hired a professional biologist for rare plants identification.
Civil society role
One of the reasons of low certification quality in Ukraine is the inert civil society and stakeholders. For submitting adequate remarks and proposals, one must study the Standard and know, what really happens within a SFE. Most civil activists are not competent or have no time for this. It is much easier to make wrathful posts on social or mass media, than to conduct an official mailing.
Instead of conclusions
FSC is a good market mechanism of making forestry more “sustainable”, but in Ukraine it works only nominally, does not play its role. The reasons of this are low-quality work of several audit firms and passive role of civil society.
For now EPL gathers a base of representative plot of all certified SFEs and conducts an educational work concerning participation of civil society representatives and scientists in the certification process.
For more detailed information contact:
Petro Testov, EPL analyst
Tel: +38(032) 225 – 76 -82; +38(068) 934 – 95 – 74