WRM comments on FSC's principle 10 on plantations

It is important to begin by highlighting the fact that to receive FSC certification, a plantation company needs to comply with all FSC's principles and not only with the principle concerning plantations specifically-- principle 10.

Having said that, we shall focus on principle 10, which, as it currently stands, appears to allow unsustainable industrial tree plantations --particularly in the South-- to receive certification in spite of their negative social and environmental impacts. What follow are comments on the different criteria included under principle 10.

"Plantations shall be planned and managed in accordance with Principles and Criteria 1 - 9, and Principle 10 and its Criteria. While plantations can provide an array of social and economic benefits, and can contribute to satisfying the world’s needs for forest products, they should complement the management of, reduce pressures on, and promote the restoration and conservation of natural forests."

In the South, all of these claims have already been proven unachievable in practice:

- Large-scale industrial monocrops have provided "an array of social and economic benefits" only to the rich.

- What does "can contribute to satisfying the world’s needs for forest products" mean in a Southern context? Plantations produce only two forest products: timber and pulpwood. These two --and especially the latter-- are aimed at endless over-consumption by Northern countries and Southern elites. The beneficiary is therefore not "the world" but the rich world. All the other products which are produced by real forests (food, fodder, water, medicine, shelter, fuelwood, etc.), which satisfy the needs of local communities, are almost totally absent from plantations and the local world therefore does not benefit from plantations.

- In most cases, plantations have resulted in the destruction of native forests or other native ecosystems such as grasslands and have not contributed to "complement the management of, reduce pressures on, and promote the restoration and conservation of natural forests". The fact that, despite this, the principle states only that plantations “should” promote conservation, not that they “must”, signals its detachment from the real world.

"Principle 10.1. The management objectives of the plantation, including natural forest conservation and restoration objectives, shall be explicitly stated in the management plan, and clearly demonstrated in the implementation of the plan."

- The management objectives of industrial plantations are always explicitly stated: the production of large quantities of timber in the shortest time possible. Large plantation companies often write natural forest conservation and restoration objectives into their plans, but more as a public relations exercise than as a genuine management objective.

"10.2 The design and layout of plantations should promote the protection, restoration and conservation of natural forests, and not increase pressures on natural forests. Wildlife corridors, streamline zones and a mosaic of stands of different ages and rotation periods, shall be used in the layout of the plantation, consistent with the scale of the operation. The scale and layout of plantation blocks shall be consistent with the patterns of forest stands found within the natural landscape."

- There is no positive relationship between industrial plantations and forest conservation. Wood produced in industrial plantations does not, as a rule, substitute for wood extracted from natural stands: the former is mostly aimed at the production of pulp and paper, while the latter is aimed at the timber industry, which requires high-quality wood.

- There are a number of negative relationships, through which large-scale plantations actually promote deforestation. In the first place, most plantations in the tropics substitute for primary or secondary forest, which are clearcut and/or set on fire prior to planting. Secondly, people displaced from their land by plantations have to clear new forest areas in order to survive. Thirdly, it is not unusual for the news that plantations are going to be established in a certain area to result in its deforestation by local speculators in order to be able to sell the land to the plantation companies. Additionally, roads leading to plantations upend up new forest areas to encroachment. Fires originating in plantations, in addition, can extend to nearby forests. In consequence, large-scale plantations are usually both direct and indirect causes of deforestation.

- Most plantation companies are able, if pressed, to make at least a token attempt to set up "wildlife corridors, streamline zones and a mosaic of stands of different ages and rotation periods." However, this does not mean that local ecosystems (forests, grasslands, wetlands and so forth) will not suffer, because there will usually be a number of companies occupying a given area. Wildlife corridors isolated within a sea of eucalyptus or pines are not of much significance for the conservation of wildlife. The same is applicable to the preservation of streamline zones. The impact of these plantations on water must be dealt with at a basin level and not at plantation level. The impact of large masses of fast-growing trees in a given area have already resulted in the disappearance of water courses and profound changes in the water cycle. Finally, almost all companies plant what could be loosely interpreted as “mosaics” of stands of different ages and rotation periods. By itself, however, this implies nothing about the impacts on water, soils, flora and fauna. The size of each “tile” in these so-called “mosaics” is likely to be far larger than in a forest because it is determined by the commercial need to be able to have something to harvest every year, not by ecological criteria.

- What is the meaning of "The scale and layout of plantation blocks shall be consistent with the patterns of forest stands found within the natural landscape"? What happens in cases such as Uruguay, Argentina and South Africa, where plantations are established on grasslands? Such plantations have already been certified in those three countries. Can this be interpreted as meaning that grassland ecosystems are unimportant to the FSC? And in all cases, how can a eucalyptus or pine plantation "be consistent with the patterns of forest stands found within the natural landscape"?

"10.3. Diversity in the composition of plantations is preferred, so as to enhance economic, ecological and social stability. Such diversity may include the size and spatial distribution of management units within the landscape, number and genetic composition of species, age classes and structures."

- This clause is so vague that it could be satisfied merely by planting two species of eucalyptus in a huge industrial plantation rather than just one, and planting two different areas a couple of years apart rather than planting all the trees at once. In fact, most large industrial plantations already comply with the letter of this principle simply because to do so enhances economic stability (more protection against specific predators). However, such inadequate measures cannot appreciably enhance either ecological or social stability (although the protection against pests provided by some diversity could protect the jobs of plantation workers who might otherwise lose their jobs if the plantation were to be decimated by insects or fungi). And even this call for minimum diversity is not mandatory but merely "preferred".

"10.4. The selection of species for planting shall be based on their overall suitability for the site and their appropriateness to the management objectives. In order to enhance the conservation of biological diversity, native species are preferred over exotic species in the establishment of plantations and the restoration of degraded ecosystems. Exotic species, which shall be used only when their performance is greater than that of native species, shall be carefully monitored to detect unusual mortality, disease or insect outbreaks and adverse ecological impacts."

- This criterion leaves the door wide open to fast-growth exotic tree plantations, which "are based on their overall suitability for the site and their appropriateness to the management objectives" (the production of large volumes of homogeneous raw material for industry). Native species are again only "preferred", not “required”, and if “performance” is measured only by how much industrial wood a species produces, then all industrial plantations will comply with this criterion automatically. There is therefore a need to define “performance” clearly, because most native species' “performance” in the production of water, soil, food, medicine, fodder, etc. is usually far better than that of alien species which produce little --or none-- of these goods. The last sentence ("Exotic species . . . shall be carefully monitored to detect unusual mortality, disease or insect outbreaks and adverse ecological impacts") is very confusing. Are the adverse ecological impacts referred to impacts on the plantation or of the plantation on neighbouring ecosystems and local production?

"10.5. A proportion of the overall forest management area, appropriate to the scale of the plantation and to be determined in regional standards, shall be managed so as to restore the site to a natural forest cover."

- Here again appears the confusion between forest and plantation. (the “overall forest management area” includes industrial plantations, which are not forests.) In addition, what “proportion” of the plantation is to be returned to “natural forest cover”? One per cent? 10 per cent? 50 per cent? Who will determine the regional standards? What if the area never had forest cover (e.g. Uruguay, Argentina, South Africa)? Are plantation owners then exempted from restoring part of their operations to non-plantation vegetation?

"10.6. Measures shall be taken to maintain or improve soil structure, fertility, and biological activity. The techniques and rate of harvesting, road and trail construction and maintenance, and the choice of species shall not result in long term soil degradation or adverse impacts on water quality, quantity or substantial deviation from stream course drainage patterns."

- If this criterion were to be applied consistently, then no large-scale, fast growth, exotic tree plantation could be certified. Yet if applied carelessly, the criterion would allow a great deal of environmentally damaging practice. Who will decide whether this clause has been met or not? Most large plantation companies include (at least on paper) measures and techniques for environmental conservation. However, all their activities will necessarily have impacts --almost always deleterious-- on soil structure, fertility, biological activities and water. From our perspective, there is already enough evidence that, other things being equal, the species, harvesting methods, and maintenance techniques chosen for industrial monoculture plantations will result, as a rule, "in long term soil degradation or adverse impacts on water quality, quantity or substantial deviation from stream course drainage patterns." Yet of course theoretical studies can be found that claim that this need not be the case, and company studies that claim that fertility and hydrology have not been affected. Who will decide which experiences or set of studies are to be taken seriously? The FSC criterion is mysteriously silent about this key question.

"10.7. Measures shall be taken to prevent and minimize outbreaks of pests, diseases, fire and invasive plant introductions. Integrated pest management shall form an essential part of the management plan, with primary reliance on prevention and biological control methods rather than chemical pesticides and fertilizers. Plantation management should make every effort to move away from chemical pesticides and fertilizers, including their use in nurseries. The use of chemicals is also covered in Criteria 6.6 and 6.7."

- This clause relies so heavily on vague wording such as "minimize", "primary reliance", and "every effort" that it becomes worthless in practice.

- What are referred to as “pests” and “diseases” are frequently those native species which happen to be able to find food within the plantation (a food desert for most native fauna). Eradicating them is in fact a blow to local biodiversity. “Integrated pest management” is hardly great boon in itself if it implies nothing more than the protection of the exotic species against its few local (or exotic) predators. In addition, companies can easily claim that they are "making every effort" to move away from chemical pesticides and fertilizers without actually doing anything to lower their chemical use. In accordance with clause 10.6 (soil fertility), they will argue that there is no available substitute (given the scale of their plantations) to chemical fertilizers. They are already trying, they will say, to replace pesticides with silvicultural methods (thinning, prunning, spacing, etc.) for economic reasons, but, sadly, must still rely on chemical pesticides to a high degree. It is revealing, moreover, that criterion 10.7 says nothing about “moving away” from using herbicides, which are also harmful chemicals.

- In many countries, plantation trees themselves easily become “invasive plant introductions”. What "measures shall be taken to prevent and minimize” such introductions in South Africa, for instance, where it is the introduced eucalyptus, wattles and pines which have turned into “invasive species” in the native ecosystems?

"10.8. Appropriate to the scale and diversity of the operation, monitoring of plantations shall include regular assessment of potential on-site and off-site ecological and social impacts (e.g. natural regeneration, effects on water resources and soil fertility, and impacts on local welfare and well-being), in addition to those elements addressed in principles 8, 6 and 4. No species should be planted on a large scale until local trials and/or experience have shown that they are ecologically well-adapted to the site, are not invasive, and do not have significant negative ecological impacts on other ecosystems. Special attention will be paid to social issues of land acquisition for plantations, especially the protection of local rights of ownership, use or access."

- This is perhaps the best-written criterion. However, its presupposition that “local trials” --which are always small-scale-- can prove the appropriateness of a large-scale industrial planting of a species to an ecosystem in general is mistaken. Small local trials can determine, up to a point, likely rates of growth of an industrial species on a site. They can also determine, to a certain extent, whether the species is likely to be invasive (although if it is in fact invasive, the trial itself will probably result in an invasion). But the only effective test of the social and environmental effects of large-scale plantations are large-scale plantations themselves. The criterion should therefore be revised to specify that no plantations will be certified in areas where there is enough evidence of substantial negative impacts (social, environmental or both) caused by existing large-scale plantations.

- The last sentence ("Special attention will be paid to social issues of land acquisition for plantations, especially the protection of local rights of ownership, use or access") points in the right direction, but what does "special attention will be paid" actually mean? Does it mean that no certification will take place if any local right has been violated? What if the violation occurred at the hands of speculators or the government before the company bought or rented the land? And again, who decides whether enough “attention” has been paid to land rights issues? The clause is tellingly silent on this question.

"10.9: Plantations established in areas converted from natural forests after November 1994 normally shall not qualify for certification. Certification may be allowed in circumstances where sufficient evidence is submitted to the certification body that the manager/owner is not responsible directly or indirectly of such conversion."

This raises a series of questions --why November 1994? Why "normally" shall not qualify for certification --who decides what is "normal"? Who judges the evidence presented and on what criteria? Would a signed slip of paper saying "I wasn't there when it happened and I didn't do it" suffice? If a second company buys up the plantation from the company responsible for clearing the forest, can the second company then be certified? Presumably the second company wasn't directly or indirectly responsible for the "conversion".

In sum, Principle 10 does not seem to offer nearly enough guarantees to end-consumers that wood from industrial plantations is produced in a socially equitable and environmentally-friendly manner. Neither is the principle very useful for people struggling against plantations at the local or national levels. The main issue (large-scale monocrops) is not taken into account. The problem is not the tree species (eucalyptus, pines, acacias, etc.) but the overall plantation model, which the FSC unjustifiably accepts without discussion. We believe that this principle is clearly insufficient and needs to be substantially modified before it can be said to be appropriate to the reality of large scale industrial tree monocrops.