FSC has released a new draft of the FSC Principles and Criteria for public consultation and stakeholders are invited to provide comments until the 10th of May.
FSC expects that this is the final public consultation before a final draft will be submitted for membership approval by the end of the year. We encourage our readers to take this unique chance to help improve the system by providing feedback.
The 2009 August version of Certified Wood Update included a detailed review of draft 2 of the P&C. Draft 3 is better worded and has amore logical structure. As such the proposed standard is a clear improvement compared to the former version. In draft 2, FSC introduced normative guidance notes. These have been taken out in draft 3 and replaced by more detailed criteria and non-normative explanatory notes.Compared to the major changes in contents and structure introduced with draft 2, the changes from draft 2 to draft 3 seem to be minor.
FSC Legality standard?
Principle 1 covering legality issues has developed into a "monster principle" with 27 criteria compared to only 6 in the former version. The intention is that the principle can be used as a stand-alone standard for legality verification – e.g. in connection with companies following a stepwise approach towards FSC certification.
Doubtlessly a huge need for an internationally recognized standard for verification of legal compliance by forestry exists, and this part of the draft seems to be a great proposal for such a standard.
However, we question the feasibility of including this as a part of a standard for responsible forest management! There is major overlap between requirements in principle 1 and requirements in other parts of the standard; in case an area is not covered by legislation, it is anyway covered by another principle and shall be evaluated.
Whenever an issue is evaluated several times under different parts of the standard, this results in a more complex auditing process. We strongly recommend FSC to develop a separate legality standard including all relevant aspects, while keeping Principle 1 short and focused on those legal areas that are not covered by other parts of the standard.
Climate change adaptation needed - also of the FSC standard
Surprisingly, considerations to forests important role in the climate change is almost completely neglected in the new version of the standard, with exception of one criterion (10.13) focusing mainly on pollution.
The forests' role as one of the world's most important global carbon storage and potential sink is not covered by the standard at all. For example, there are no requirements to ensure that the long term forest carbon storage capacity is evaluated, maintained or increased in connection with management activities.
Furthermore, we would have expected requirements related to ensuring that species selection and silvicultural system consider future climate change. Despite some general referenes to adaptive management, the standard far from constitutes the updated document that seems needed in order to support forestry that is truly braced for imminent and drastic change in climatic conditions.
How will the forest be affected in case of climate change and what measures can be taken to avoid negative influence? The lack of focus on climate issues leaves an impression of an outdated standard even before it is approved.
What about the small scale forest operations?
While FSC has been very successful in certifying large operations, small operations seem to be FSC’s Achilles' heel. The organization still needs to show that the certification program is feasible for small private family owned forest in large scale.
Several motions passed at the FSC General Assemblies have required FSC to focus on this area, and we would have expected that FSC would use this opportunity to ensure that the certification requirements are adapted to all sizes of forests.
The new draft is both longer and more complex than the former and seems to take a big step in the wrong direction. Some of the criteria include “appropriate to scale”, but this seems far from consistently implemented. We strongly recommend that the standard is given a reality check for the feasibility for the smallest holdings before it is approved or considering having a simplified version.
When will the new standard come into force?
This is not clear yet, but a qualified guess would be "at the earliest in the beginning of 2012".
If the standard is completed according to FSC’s current plan, it might be approved by the members in the beginning of 2011. However, before the new standard can be used in the field, the national and regional standards shall be updated. The earliest we can expect using new locally adopted standards is in the beginning of 2012.
However, this assumes that the standard gets approved by the beginning of the new year, which can far from be considered granted given the FSC complex voting system and the many different interests involved.
Join the consultation
Don't miss the opportunity to let your voice be heard. FSC has made it easy fo those with limited time, while providing extensive explanations for those who wish to know the background, by publishing two different versions of the draft standard – a comprehensive 133-page version with a lot of background information and a shorter 33 page version.
Download both versions of the draft standard
The FSC 'fundamental law' out for review (26/8 2009)
First discussions on global framework for timber legality verification (15/2 2010)
Adaptive forestry: last minute for action (22/12 2009)
FSC adapts to climate change (22/12 2009)