SFI “Greenwashing” Complaint Filed with Federal Trade Commission

Last month this blog explored some of the differences and validity of the two main “green” wood certification programs in the U.S. – the Forest Stewardship Council (FSC) and the Sustainable Forestry Initiative (SFI).

The FSC bills itself as “an independent, non-governmental, not for profit organization established to promote the responsible management of the world’s forests” while the Sustainable Forestry Initiative (SFI) (which the U.S. timber industry established in 1994) bills itself as “an independent, non-profit organization responsible for maintaining, overseeing and improving a sustainable forestry certification program.”

SFIYesterday, ForestEthics and Greenpeace filed a complaint with the Federal Trade Commission (FTC) asking the agency to investigate the Sustainable Forestry Initiative (SFI)’s claim to be a ‘green’ certifier of forest products. The complaint argues that SFI’s claim that it is an independent, non-profit public charity is deceptive and misleading because SFI is substantially governed and financed by the timber industry and because its vague and ambiguous forestry standards are developed and approved by timber industry personnel in a closed process.

The complaint is based on the FTC’s recently revised “Green Guides” and is joined by more than 2,800 individual consumers filing their own complaints, and supported by over 8,000 who signed a petition demanding that the FTC take action. This is the largest number of Green Guides complaints concerning a single scheme that the FTC has ever received.

Here is the opening portion of the complaint filed with the FTC:

On behalf of ForestEthics and Greenpeace, the Washington Forest Law Center (“WFLC”) submits this Complaint because consumers are being deceived by the Sustainable Forestry Initiative (“SFI”), a timber industry-funded forest certification system developed for the deceptive “green” marketing of lumber and paper products.

This Complaint provides detailed evidence that SFI is materially not in compliance with the Federal Trade Commission’s (“FTC”) revised “Green Guides,” which were formally re-promulgated on October 11, 2012. As set forth below, ForestEthics, Greenpeace, and allies believe that SFI engages in several unfair and deceptive acts and practices, which detrimentally mislead corporate and individual lumber and paper consumers who rely on certification in making purchasing decisions. Hundreds of millions of dollars in “green” spending are at issue.

We ask the FTC to investigate this Complaint and to take enforcement action requiring SFI to either cease its deceptive marketing practices or to make the necessary disclosures so as to comply with the revised Green Guides.

News of this FTC complaint follows closely on the heels of four more major US companies, Hewlett Packard, Office Depot, Southwest, and Cricket, announcing plans to move away from the SFI.

ForestEthics began its campaign against SFI’s greenwashing of forest destruction by filing complaints with the IRS and FTC in 2009. Since then, 24 companies have moved away from the SFI.

In April, the SFI sent a ‘cease and desist’ letter – a threat to sue – to ForestEthics. But, if sued, ForestEthics intends to vigorously stand by its First Amendment right to challenge SFI with truthful facts and opinion and to report SFI to consumer protection government agencies.

“The Sustainable Forestry Initiative label is the timber industry’s cynical effort to get a piece of the highly valuable green marketplace in the US, which is currently valued at $500 billion dollars annually.  We have demonstrable proof that in many regions of the U.S. and Canada, SFI offers virtually no environmental protection beyond that already required by state and federal laws and worse, it offers cover and false marketing for companies trying to take advantage of consumers’ best intentions,” said Aaron Sanger of ForestEthics. “It’s no surprise that the SFI is trying to intimidate ForestEthics with threats of a lawsuit – the green marketplace is growing more valuable by the day. Our Federal Trade Commission complaint today is proof positive that we will not be bullied.”

The complaint submitted by ForestEthics and Greenpeace yesterday centers around the following: The FTC’s Green Guides forbids deceptive claims of independence. The SFI claims that it is independent, but it has direct material connections to the forestry and paper products industry. In 2011, 93 percent of SFI’s funding came from SFI “program participants,” that includes a veritable “who’s who” of the timber and paper industry such as logging giants Weyerhaeuser, Plum Creek, and Rayonier.

The FTC works on behalf of consumers to prevent fraudulent, deceptive, and unfair business practices and to provide information to help spot, stop, and avoid them. The FTC’s Green Guides were introduced in 1992 to provide guidance to companies that want to call their products “green” or “eco-friendly” and help marketers ensure that claims they make about environmental attributes of their products are truthful and non-deceptive. The Green Guides were last revised in 1998 although the FTC began a comprehensive review of the Green Guides in 2007, which resulted in the 2012 revisions.

ForestEthics’ ongoing campaign to expose the SFI’s certification program in the U.S. marketplace began in 2009. ForestEthics’ work has revealed that the widely-used forest certification program is financed and governed by the timber industry. The SFI misleads well-intentioned companies and consumers into thinking they are making environmentally sound choices, when in reality the program “certifies” forestry practices that wreak environmental harm, including logging that create massive landslides, destroys rare wildlife and fish habitat, pollutes streams and rivers, and contaminates communities with toxic herbicides and fertilizers. By engaging with supporters and allies, ForestEthics is exposing the truth behind the SFI label while persuading regulators like the Federal Trade Commission and market leaders like Fortune 500 brands to take a stand against SFI “greenwashing”.

ForestEthics is represented by the Seattle-based Washington Forest Law Center, which played a key role in preparing ForestEthics’ FTC complaint.

69 Comments

  1. So, if it follows all laws, green or otherwise, it isn’t “green”??? “Adaptive slanderment”?? Sounds like they have a set of goalposts on wheels! *smirk*

    Edit: Yes, I like “greener” forestry practices but, this sounds more like their previous tactics weren’t working against SFI. The advertising world is full of similar situations. For example, “fat-free” foods claim to be healthy. I’d say let the market decide, and make SFI products a mid-level buying decision, with the superior FSC having worthwhile added value.

  2. This is great news. Thanks, Matthew. And the year 2009 is intriguing, because that’s also when ArchitectureWeek published some special coverage on forest certification issues.

    The concerted efforts by SFI to get recognized by the USGBC as a legitimate green labeling for LEED green building certification is another front in the political struggle around consumer information.

    These might provide some historical context for the long-running efforts behind these current events:

    FSC Versus SFI, by Christine MacDonald. ArchitectureWeek No. 439
    http://www.architectureweek.com/2009/0812/environment_1-1.html

    High Tension over Big Timber, by Christine MacDonald. ArchitectureWeek No. 449
    http://www.architectureweek.com/2009/1021/news_2-1.html

    It is great to see non-profit watchdog groups continuing the quest for fairness and accuracy in forest products labeling, creatively and effectively.

    • Steve, I’m honestly not sure how “third-party” the analysis of FSC and SFI done by Dovetail Partners, Inc really is.

      After all, sitting right on Dovetail Partner’s Board of Advisors is William Banzhaf, Former President, Sustainable Forestry Board. From Mr. Benzhaf’s bio listed on the Dovetail website.

      “William Banzhaf served as the President of the Sustainable Forestry Board….The 15-member body oversees the Sustainable Forestry Initiative®.”

      For that matter, you’ll notice that another person on Dovetail Parnter’s Board of Advisors (R. Philip Guillery) is the current “Systems Integrity Director of the FSC” and his bio reads, in part:

      Mr. Guillery has been involved with FSC since 1997. He participated in the development of the FSC national standards and numerous FSC policies, managed an FSC Group certificate, lead forests and CoC audits, and served on the FSC-US Board for seven years.

      So please explain, Steve, just how “3rd party” or “independent” Dovetail Parnter’s analysis of SFI or FSC really can be?

        • *Smirk* all you want Larry….My question to Steve RE: a supposed “3rd party” analysis done by an organization (Dovetail Parnters, Inc) with clear ties to SFI and FSC are 100% legit. I have no problem with with Dovetail Partners doing an analysis, I look forward to reading it, I’m just not sure it can be considered “3rd party” or even that far removed from these certification programs. Personally I think Felice brought up some good points about FSC is general too.

  3. Dovetail Partners, Inc. appears to have gone to great lengths to avoid disclosing their funding sources. Or maybe no one has ever written about them.

    But this poster, from one of the “forest nformation” sites they manage, suggests some lineage:
    http://forestinfo.org/sites/default/files/pdfReports/TheRightChoicePoster.pdf

    At the same time, one of top report summaries at the link Steve shared says, “A strong case can be made that the differences between the programs’ standards are significant.”

    If they are an important reverence, I’d be interested in concrete information about who they are.

  4. My experience, as a log buyer and lumber manufacturer, is that a FSC clear cuts don’t look any different than a non certified clear cut. Lately FSC has so watered down there requirements by letting a mill blend their log sources through buyer credits, that you can be buying FSC certified lumber that does not come form a FSC certified source. I see FSC as a for profit organization that has figured out a way, through excellent marketing, to tax timber producers.
    In the woods and in the mills FSC doesn’t really mean a thing, just more paperwork and money, and oh yes, you get an FSC certified number, if you pay them regularly,

    • Steve, Did you read the entire FTC complaint? What did you think about their analyses and conclusions?

      I also think Kevin brought up a completely relevant point about Dovetail Partners, Inc and their funding sources. After all, if Sharon wants to bring up funding sources for a group filing a lawsuit, seems who funds (and is a part of) Dovetail Partners is completely germane.

  5. What is interesting about this discussion to me is that the argument seems to be that you can’t trust the funders of SFI.

    I would like to hear what practices in what version of FSC people prefer to SFI, that might be a more substantive discussion.

    Also, the people who know the most are the certifiers on the ground who generally certify to both. Many of these folks are out there to be asked. I will try to find one to post here.

    And what about PEFC? This came out yesterday…

    • Sharon: As I mentioned above, you seem to bring up all kinds of info about funding of enviro groups, so it’s strange to me that, apparently, you see no problem what-so-ever with the logging industry (or was that “timber industry”?) funding a logging certification program. How in the world can funding of SFI, or FSC for that matter, not be part of the consideration as we look at the validity of each program?

    • It’s untrue that certifiers generally certify to both FSC and SFI. In fact, there is little overlap. For the FSC perspective, try Robert Hrubes at SCS or Dave Bubser of Rainforest Alliance/SmartWood.

      PEFC started in northern Europe but has evolved to become a global umbrella for all of the industry-based forest certification systems that exist to provide an alternative to FSC. SFI is affiliated with PEFC (SFI-certified products can bear the PEFC label, and vice versa).

      IMHO, there is no such thing as a truly independent analysis of FSC and SFI — you won’t find it from Dovetail or anywhere else.

      FSC has lots of flaws, but it still sets the bar higher than SFI — which is greenwashing, pure and simple.

      • Jason, I should have said that I know people who have audited both systems.
        I have no idea of the percentage of those people there are out there.

        But if you say MOST auditors are one or the other, then that would mean you couldn’t trust them not to have self-interest at the forefront. I’m not really interested in whose self-interest is stronger…I would be interested in discussions of specific forest practices that are different between them and we could discuss the pros and cons here.

        • There are a number of forests — mostly state forests — that are dual-certified under both FSC and SFI, primarily for political reasons. You won’t learn too much from these cases about the differences between the systems, because obviously they are the same forests, managed the same way — and if it’s true that FSC is a higher bar than SFI, then obviously forests that can be certified to the standards of the former meet the requirements of the latter.

          If you want to get into the specifics of how the two standards differ at the forest level, then you have to answer the question “where” since both standards vary by state, region and/or country. It gets crazily complex.

          Robert Hrubes of SCS is a PhD forester who has been certifying under FSC since the mid 90s. Obviously, he is pro-FSC — again, I don’t think you will find any individual or organization that doesn’t have a point of view and a bias in this debate. Robert has participated in several of the dual FSC-SFI certifications referenced above. He is familiar with state forestry regs and BMPs in many states, and since SFI basically defaults to state regs/BMPs at its lowest common denominator, he could also tell you how FSC standards differ from SFI from one state to the next. Maybe we could suck him into this discussion, but my guess is he is probably too busy.

  6. I’m with you, Sharon. An essay from the July 2011 Forestry Source is here:

    http://www.nxtbook.com/nxtbooks/saf/forestrysource_201107/index.php#/7

    SFI vs. FSC: Are We Asking the Wrong Question?
    By Daniel J. Simonds

    Simonds opens by writing:

    “As a consultant and insider in the business of “green” certification for paper and wood products, I’m getting a little tired of the seemingly never-ending debate between our two principle sustainable forest-management certification programs. Both the Sustainable Forestry Initiative (SFI) and Forest Stewardship Council (FSC) programs have established themselves as important players in defining standards of responsible practice and sustainable sourcing. Those little graphical icons that we now find everywhere, on magazines, lumber, coffee cups, and pencils, are here to stay. So why are we still arguing over which program is better? I think it’s time to move on. Let’s ask some questions that matter and try to make these important programs better.”

    His bio: Dan Simonds, CF, FCA, is a forester and management system consultant who has been an SAF member for 28 years. He has 20+ years of land management experience in Northern New England, and for 4 years has managed forestry certification programs for a large, third-party certification firm. He is the principal of MixedWood (www.mxwood.com), a consulting firm specializing in environmental certification systems for paper and wood products.

    • Seems to me, Steve, that the FTC complaint filed by ForestEthics and Greenpeace, does, in fact, “Ask some questions that matter” in an attempt to “try to make these important programs better.”

      You might not like the questions, or issues the FTC complaint raises, or how these groups want to try and makes these certification programs better, but that really doesn’t matter.

  7. I consider FSC “greenwashing light”. Created by foresters, from the beginning FSC paid insufficient attention to impacts of forestry practices on water quality and hydrology. Landsliding is also not sufficiently addressed. For example, do you want to build a road over steep, landslide prone slopes? No problem for FSC certifiers.

    Early on I was one among many pointing out these problems with FSC certification; forester dominated FSC did not listen then and they are not listening now. I wish Forest Ethics would not stop with SFI but will subsequently go after FSC as well.

    • So are forest certification systems designed by foresters bad? That seems like it would be a problem, as would cop accountability systems designed by cops, medical accountability systems designed by doctors… etc.

      Who else would design a sustainable forest certification system?

  8. Any program that mandates uneven-aged management, and other “dealbreakers”, will find itself without clients. The trick is in getting private landowners to change their practices. It simply is a compromise but, some people just don’t like that “C-word”, at all. Almanor Forest Products, near Mount Lassen, has been successful with their profitable uneven-aged management. The “leave trees” on their lands are valuable, being relatively large superior trees but, they are even more valuable as seed sources for the next generation. Their economic strategy works for them, at their location. Other locations may not be suitable or profitable.

  9. My sense of the current situation, boiled down to an extract, is that, to achieve facts on the ground of ecologically-sustained forests that also produce significant woods products, FSC is better than nothing, though it badly needs some more stringent competition to help it be honest and improving, while SFI is actually worse than nothing, because the impression it seeks to project is not backed up by any significant ecological substance, and because SFI exists mainly to undercut and worsen FSC.

    Just sayin.

  10. Lying to consumers is never okay in any situation! This is a great step forward in trying to create transparency and honesty in all our markets, not just the timber industry.

  11. Unfortunately, misleading consumers is common practice in a capitalist economy. However, flat out lying to consumers is illegal and unconstitutional, as decided in the 4th Circuit Court of Appeals case Tradebrands v. FTC (2006). The FTC realized that Tradebrands’ health and fitness products actually did nothing to benefit the health of their consumers, and forced the company to cease production of all these products ( and pay over $7 million back to their customers).

    The SFI certification is far worse because its false claims don’t just affect the consumer, they affect the entire global population. It would be a shame for the FTC to recognize the dangers of false fitness advertizing and then grossly overlook false environmental advertizing just seven years later.

    Furthermore, the issue of environmental degradation is not something that should come down to a compromise or that “c-word” as Larry so eloquently put it. I doubt anyone would willingly give up the health of their families, taking comfort in the fact that a Fortune 500 company’s profits are growing. Yet, that is the “compromise” we are accepting with SFI.

    Thank you, ForestEthics, for bringing SFI’s gross malpractice to the attention of the FTC. It is my hope that they will act with the same swiftness and diligence they did back in 2006 with Tradebrands, Inc.

      • It is a simple matter of misusing and overusing our natural resources. SFI approves several practices that have a disastrous impact on the environment, such as removing irreplaceable old growth and endangered forests and replacing them with genetically modified trees (not to mention all of the pollution caused by clear cutting). Just because these practices are approved in the US doesn’t mean that they only affect the US. The environment is completely interconnected, and the damage SFI is causing isn’t isolating the issue to North America, but rather adding to global environmental degradation. Allowing these practices to continue in the US will only serve as an example for other nations to follow. I hate to bring up the slippery slope idea, but that is unfortunately how things seem to work in terms of politics and profits.

          • Planting of genetically engineered trees is just one of the several destructive practices approved under SFI certification. And there are actually several areas in both the United States and Canada growing genetically engineered trees: Georgia, New York, Virginia, Oregon, Alberta, Quebec, etc. They may be trials, but they trees are still growing.

            • So what tees are they growing in New York, GA, Oregon etc.? I would bet researchers are growing them and not timber companies. GE trees have long been a solution in search of a problem (IMHO).

              We should know because they are regulated by APHIS and I believe they have a database we can access to see who is doing it. Companies are unlikely to plant GE trees because it’s too long to wait to see if they work and too big a risk to put extra bucks in the ground.

  12. The reason SFI exists is because the timber industry could not tolerate the prospect of accountability via independent certification so they started their own competing program.

    SFI should be looked at through the lens of economic monopoly. They will likely improve standards (and create an appearance of independence) to compete with FSC until SFI is able to destroy and replace FSC, at which time they will relax standards and enjoy monopoly profits from certiified wood that can be produced cheaply under weak standards.

  13. I’ve heard it said that one of FSC’s greatest accomplishments has been pushing SFI to become a more rigorous certification system. I’m not sure I buy that. As a conservationist and a forester that has been exposed to both systems, there is no question in my mind that FSC’s standards are more rigorous. Not sure where Felice is getting information, but clearly is unfamiliar with FSC’s three chambered structure and history (created by foresters? Even if that were a “bad” thing, it’s inaccurate…).

    But really, for anyone wanting to compare the two systems, get with a knowledgeable forester and/or ecologist and spend some time in forests certified by each system. It becomes quite clear that there is a difference. TIMO/REIT managed lands across much of the West really challenge the idea of “sustainable forestry” (cut all merch in 10 years or less, carve off some HBU tracts, and sell!), yet most are SFI certified. If only consumers would take interest, educate themselves, and track the forests they know locally…Unfortunately, quality of forest management is not high enough of a priority for most.

      • Jay, in my area of the west there are few mills and no TIMO or REIT timberlands. Could you be more specific as to the lands, and the landowner (s) you are talking about (“cut all merch in 10 years or less?”)

        • Sharon, I wish I could be more specific, but it has cost me in the past when I’ve been associated with media raising concerns about the rise of timberland investment entities and ensuing impacts on forests and communities. Besides, I/we have had more success trying to partner with them in an effort to find more positive outcomes, than alienating them. That said, there are a few big ones – one described by Matthew (thanks!) – that are almost easy to track (you just cannot figure out where there $ is coming from usually, as they do a good job of protecting the anonymity of their investors, often endowments,pension funds, large financial institutions, etc.).

          Interestingly, a quick google for a speech given by Clark Binkley for the Pinchot Institute on “the rise and fall of the timberland investment management organization” gives some interesting background on why/how TIMOs/REIT’s came to be (though outside of the scope of this conversation). What I found interesting was that at least according to Al Sample, there was thought (optimism?) in the environmental community when TIMO’s came on the scene, breaking up vertically integrated timber companies. That blows me away, as at least vertically integrated timber companies needed to have sustainable production from their fee lands as feedstock for their mills. At least one (economic), maybe even two (social? at least for our rural communities), of our three pillars of sustainability were close to being satisfied under that regime. We’ve mostly lost that now.

          • I remember when they came on board in the east.. and there were worries about the possible loss of relations and jobs with local communities, with the companies investing in research, and the folks out there working who could also fight fires. But I think that the idea was that they wouldn’t manage as intensively so there would be fewer environmental impacts.

            Graduate students.. it would be interesting to compare what people thought at the time about REITS and TIMOs, with what actually happened.

            Also, the folks I know are hesitant to criticize FSC publicly because they get family-feeding bucks from auditing.

            Stepping back from all this, I can see why journalists have a problem figuring out what’s really going on as it seems like those who really know have complex relationships that make it difficult to talk publicly.

            • Very true. Yet these are also often complex issues that many journalists want to cram into a good vs evil kind of story. I know some good foresters that spent careers “building inventory” on industry timberland, that secretly lament the pace at which it is being harvested by their new (investor) employers. Definitely makes for some mixed emotions and interesting relationships on the front lines.

    • RE: Jay’s point and Sharon’s question:

      “TIMO/REIT managed lands across much of the West really challenge the idea of “sustainable forestry” (cut all merch in 10 years or less, carve off some HBU tracts, and sell!), yet most are SFI certified.”

      In Montana, Plum Creek Timber Company, a SFI certified company, is a huge TIMO/REIT and has been in the process of doing exactly what Jay describes, for years and years.

      For an excellent look at Plum Creek Timber Company and their TIMO/REIT in Montana I highly suggest this article from Dave Skinner of the Hydra Project in Whitefish, MT. It literally would be tough to find a more vocal supporter of logging in Montana, especially on public lands, than Dave Skinner, so it’s important to keep that in mind when reading his perspective.

      What is Plum Creek’s End Game?
      Montanans and Wall Street surely want to know
      By Dave Skinner

      http://www.flatheadbeacon.com/articles/article/what_is_plum_creeks_end_game/11885

      In 1989, a limited public partnership called Plum Creek Timber (PCL) was formed for the purpose of buying 1.4 million acres of timberland and associated sawmills from Burlington Resources. In the 1990s, PCL bought more land, in Montana, the Southeast and Maine, accumulating about 3.8 million total acres of timberland by 1999.

      Also in 1999, Plum Creek pulled off one of the greatest business coups in history. PCL was the first major integrated wood products company to re-incorporate as a Real Estate Investment Trust, or REIT. Why? Taxes. For shareholders of REITs and their land-only Timberland Investment Management Organization (TIMO) counterparts, the federal tax hit is only 15 percent on profits versus 40 percent for other corporate entities.

      PCL’s directors also cleverly protected themselves and their new business toy with anti-takeover provisions in a new REIT corporate charter. PCL’s enemies were thereby blocked from using a hostile merger to co-opt Plum Creek’s tax advantages.

      As for “friendly” mergers, in the fall of 2001, Plum Creek merged with The Timber Company (TGP), the land-management arm of Georgia-Pacific Corporation. The deal involved 5 million acres of Georgia-Pacific’s commercial timberland, placing PCL second behind International Paper in total United States land ownership.

      Pioneering the REIT game was magic for Plum Creek, which became a Wall Street money magnet. According to the Wall Street Journal, from 1999 to 2004, PCL “net income more than quadrupled to $362 million.”

      This success triggered a wild copycat frenzy by America’s timber industry to disintegrate itself into REITs and TIMOs, with at least 20 million acres changing hands in huge chunks – and the scramble isn’t over.

      So “where” is Plum Creek today? With 85 percent of its land in 17 other states around the U.S., PCL’s investments, and interests, are obviously no longer centered on Montana “home ground.”

      Equally important: Precisely what is PCL today? Consider that PCL bought millions of acres, but has no sawmills outside Montana. Why not? Under REIT law, no more than 20 percent of assets can be manufacturing assets. Furthermore, REITs that generate more than 10 percent of their income (profit) from manufacturing lose the REIT tax benefits.

      In short, federal law prohibits REITs from manufacturing as a main source of income. REITs and TIMOs focus instead on generating capital-gains income either by selling trees, or selling dirt. Ergo, real estate.

      Why is the law that way? Congress wanted to prevent industrial firms from using REIT incorporation as a tax dodge.

      Nonetheless, Plum Creek retained its sawmills for a very good reason – to mill liquid cash out of solid Montana trees. Monetizing Montana wood with infrastructure it controls is, or was, the most cost-effective way Plum Creek could generate the cash the company needed to assemble its real-estate empire.

      And what an empire! In less than 15 years, Plum Creek leapt from being a bit player in the Northwest, to top star on the national stage, a spectacular achievement by any standard.

      What can Plum Creek possibly do to top that? Or are events now in the end game? Wall Streeters are surely asking … and so must Montanans.

        • Sharon, I’m not surprised by TIMO/REITs, but it seemed that you were since you asked for additional information, which I think the Skinner column provides nicely. If, after reading Skinner’s column, you can’t figure out what bothers people about TIMO/REITs, I’m not sure I can help.

          • I think my point was that my observation is that there was not such concern about TIMOs and REITs in the east… I wonder why the concerns would be different?

            My memory was like Jason’s a bit.. not a great deal of concern when they came to the East. But my memory is often wrong…

  14. Hopefully FSC has improved since I reviewed their reforestation requirements in the US in a Journal of Forestry article some years back. At the time they were all over the map based on (I guess) deals struck by various folks across the different regions. I had heard that they were going to harmonize across the regions, but don’t know if that ever happened.

    Let’s step back from the discussion a bit and look at the way it’s framed.

    Let’s say that FSC is more restrictive. I mostly remember that the FS couldn’t meet some of the social requirements. However, less restrictive does not mean “not sustainable”. I guess that’s where I’m having the logic breakdown,

    For example, our northern neighbors in Canada took the Montreal criteria and indicators, developed their own and certify to those. They think they’re sustainable. Who is to say that they are not? On what basis?

    “Greenwashing” suggests that bad things happen under these other systems that don’t happen with FSC. We also know that bad things happen under FSC.

    It seems to me that a profitable discussion for our mutual learning (and possibly letting the boards of both organizations know what we have learned) would be “what bad things have you seen occur under SFI and FSC that you consider not to be sustainable?” And let’s look at the evidence and openly discuss why we do or do not consider it to be sustainable.

    Recently I had a conversation with individuals within State X who are thinking of developing their own system (the State). Is this because they want to be “unsustainable” or because FSC doesn’t work for them? Or they disagree with whatever standards are in that region? Or because it costs too much for small landowners?

    • I find these comments thoughtful. I agree that ‘bad’ things happen under FSC – I’ve seen it myself – and agree that in these cases, FSC is guilty of greenwashing.

      But as Jay points out above, SFI routinely certifies status quo industrial forestry, and for all its problems and weaknesses, FSC does not. Green Diamond Resources, the second largest redwood producer in California, recently switched from SFI to FSC, and in doing so, they have had to change their forest practices in numerous substantive ways that make them less environmentally harmful — substantially increasing retention (the percentage of trees that are left behind in an even-age management regime), eliminating legal but harmful chemicals like atrazine, increasing conservation set-asides, etc. Many environmentalists are unhappy with Green Diamond’s FSC certification, arguing that FSC requirements don’t go far enough — that, for example, even-age management (clearcutting and replanting) and herbicide use should not be allowed at all under FSC standards in the redwood region. Other people point to the fact that hundreds of thousands of acres of California forest are now being managed more responsibly than they would have been otherwise as a substantial win for the environment.

      It is no small undertaking to create a forest certification system. Rather than try to develop a new system from scratch, I think the sensible route is to get involved in the existing systems and seek to improve them from within. SFI has improved over the years, and since in many respects it represents the “sea that lifts all ships” for North America’s working forests, any improvements it does make have a significant impact. I question, though, if SFI will continue to improve if FSC fails or if watchdogs like ForestEthics lay off of them.

      FSC truly is an open stakeholder process, both in terms of standards development and governance. It is a human institution and flawed as such, but if you are willing and able to wade into the process and you are effective at building coalitions, it is possible to improve it from within.

      • Thanks Jason! This is helpful to get a mental image.. do you know the proportion of retention changed and the difference in proportion of conservation areas? I think atrazine is a good example of the personal preference aspect..did I read that sometimes fsc thinks herbicides are ok (in some countries?)

        • The information I have ready to hand is from the FSC/SCS press release on the Green Diamond cert, so you can take it with however big a grain of salt you like. With this disclaimer, here’s what the release says:

          “To achieve FSC certification, Green Diamond implemented a number of improvements in forest management policies and practices that were required by the FSC US Forest Management Standard and the SCS audit team, including:

          – Increased levels of green tree retention within even-aged harvest units and reduced use of clear cutting. Tree retention within harvest units will include a variety of sizes and ages of trees and will approach 30% of pre-harvest basal area, on average, and no less than 10% in any one harvest unit.

          – Completion of an eco-regional gap analysis of protected areas and establishment of four new representative sample areas, reserving the following habitat types: Douglas-fir/western hemlock, un-entered old growth redwood stands, prairie in the Bald Hills, and the serpentine chaparral area on Rattlesnake Ridge.

          – Completion of an analysis for the presence of areas with high conservation values (HCV) on the property, utilizing input from external experts and stakeholders and a commitment to conserve these areas.

          – Enhanced stakeholder input and consultation procedures.

          – Completion of a comprehensive Forest Management Plan addressing all subject areas required by FSC. Green Diamond has exceeded FSC’s transparency requirements by publically posting the entire plan on their website.

          – More comprehensive and regular public summaries of monitoring activities and results.

          Additional changes will be incorporated into Green Diamond’s management system throughout 2013. These changes include:

          – Enhancing the extent and ecological condition of oak-woodlands on the certified forest.

          – Completing an assessment for the presence of rare ecological communities, including those containing threatened and vulnerable species.

          – Implementing improved methods for periodically assessing social impacts of management activities.

          – Enhancing the site-based ecological appropriateness of redwood planting decisions.

          – Implementing procedures to control exotic plant species.

          – Implementing enhanced adaptive feedback mechanisms for monitoring attainment of management plan objectives.

          – Fully aligning Green Diamond’s chemical use practices with FSC requirements, including eliminating use of prohibited pesticides such as Atrazine.

          A public summary of the certification report, detailing the audit findings, is available at http://www.info.fsc.org.”

      • I live on the Yurok Reservation which is about 50% owned by Greeen Diamond Resources (formerly Simpson Timber). The company has come a long way from the days when it destroyed a Sustained Yield Unit up on the Olympic Peninsula.

        What GDR is not doing, however, is protecting landslide prone slopes from the roads and clearcuts which generate landslides and road failures during big storms deelivering massive amounts of sediment to streams and, for example, turning the ocean at False Klamath Cove muddy during major storms. Neither FSC nor the State of California requires protection of landslide prone slopes and neither prohibits road building on landslide terraine. That is part of why I say FSC is not good when it comes to protecting water qulaity.

        If the FSC folks want to fix this, there are many of us out here ready to help them.

      • Thanks Jason! I’ve had a frustrating day at different airports (once again with poor free internet) but have looked up a couple of things.

        First let me say I take everything with a grain of salt.. so first I found this critiquing FSC (on the FSC critique website) use of herbicides
        http://www.fsc-watch.org/archives/2006/11/08/A_Million_Acres_of_Clearcuts_and_Pesticide_Use__Certified__in_Canada_and_Maine

        In this article, the author, says that the Sierra Club says, (yes, I know it’s double hearsay) that the company was using Garlon and that that is “clearly prohibited by FSC.”

        Now on this piece I found from Britain, it says that Garlon is OK by FSC as it is not “highly hazardous”.http://www.forestry.gov.uk/pdf/FR_update_Nov09_Herbicides.pdf/$file/FR_update_Nov09_Herbicides.pdf, slide 8.

        This raises the question … are the standards completely clear?
        Are they different in Maine and Britain?

        Also now that I looked SFI also has a public process with an external expert panel described here
        http://www.sfiprogram.org/standards-and-certifications/introduction-to-the-standard/standard-development-process1/

        Here’s the external review panel http://www.sampsongroup.com/sfi/panel.htm

        and here’s the Board of Directors.
        http://www.sfiprogram.org/who-is-sfi/sfi-governance/sfi-board-members/

        Here are the board members of FSC https://us.fsc.org/board-of-directors.183.htm

        • The FSC Watch article is over ten years old, and of course there has been evolution of FSC standards re: forest chemicals, but I am not sufficiently familiar with FSC forest management standards to be able tell you what is different today from a decade ago. My personal expertise lies in chain-of-custofy certification, not forest certification.

          As a member of Sierra Club’s forest certification team for the last 6 years, I have been party to Sierra Club appeals of both FSC certifications (in Michigan) and SFI certifications (in Washington state). I can tell you that where something is clearly prohibited in FSC’s standards, an FSC-accredited certifier is unlikely to overlook it, as it places their accreditation at risk.

          You ask: “Are the standards completely clear? Are they different in Maine and Britain?”

          In my opinion and experience, there are cases where FSC standards are not completely clear, which is a problem.

          And, as I noted earlier, FSC standards vary by country and, in some cases, region. FSC FM standards have a hierarchical structure, with 10 broad Principles at the highest level, numerous Criteria at the intermediary level (I believe there are 56), and then lots of Indicators at the lowest level.The P&C are universal. It is the Indicators that vary from one place to the next.

          SFI’s standards also vary because state regs and BMPs vary. Furthermore, SFI’s standards are worded in ways that allow companies great latitude in satisfying them. In general, “plans” and “programs” take precedence over prescriptive performance requirements.

          PEFC has even more variation, since it is a patchwork quilt of national forest certification systems spawned by forest industries in countries around the world to provide an alternative to — and compete with — FSC.

          So if variation is a problem for you, then there is no forest certification system you can turn to.

          Sierra Club supports FSC, for all its flaws, because the application of its FM standards generally result in significant improvements over legal requirements, both WRT environmental and social issues. The certification process, appeals mechanisms and standards development process, while cumbersome and often frustrating, nevertheless give environmental groups, local communities, and other stakeholders outside the forest industry more leverage in improving forest practices than we would have if the FSC didn’t exist.

          The Club opposes SFI because, on the balance, its standards represent insignificant improvement over legal requirements, and yet — in its public relations and lobbying — it seeks equal status with FSC. SFI confuses the public. Its backers and supporters use their lobbying power to attempt to force market acceptance — look what it happening right now in their attempts to ban LEED for use by states and federal agencies because of LEED rewards the use of FSC-certified wood but does not credit SFI (never mind the fact that regionally-harvested wood, whether certified or not, is rewarded under LEED).

          Environmental Building News, May 22nd: “Energy Reforms Threatened by Two Poison Pills”

          http://buildinggreen.com/auth/article.cfm/2013/5/22/Energy-Reforms-Threatened-by-Two-Poison-Pills/?utm_source=BuildingGreen.com+Mailing+List&utm_campaign=4a40ab69dd-BGB_2013_05_285_28_2013&utm_medium=email&utm_term=0_d558b0594a-4a40ab69dd-157074845&mc_cid=4a40ab69dd&mc_eid=37d3ecedae

          Real Estate Law & Industry Report, May 28th, “North Carolina May Ban LEED Construction”

          http://www.jasongrantconsulting.com/wp-content/uploads/2013/05/NC-may-ban-LEED.pdf

          Treehugger, Feb. 24th, “SFI Couldn’t Join LEED, So Now it is Out to Destroy It”

          http://www.treehugger.com/green-architecture/leed-bashing-how-wood-wars-are-hurting-leed-and-all-green-building.html

          The Club’s appeal of Weyerhaeuser’s SFI certification in the wake of the Stillman Creek landslides and all of the steep-slope clearcutting that exacerbated those landslides was, quite naturally, stonewalled. As far as I can tell, the forest industry holds the trump cards when it comes to SFI’s certification process, its standard development, and its appeals/complaints mechanism.

          • Jason, about LEED, I found this …
            http://www2.buildinggreen.com/blogs/fsc-and-beyond-leed-2012-buries-wood-wars-hatchet

            Responsible extraction of raw materials (1–2 points)

            All new wood products used to achieve this credit must be FSC-certified “or better.” The only exception to this is wood harvested and milled within 50 miles of the building site–a significant change from prior versions of LEED, which gave credit for “locally” sourced wood and other materials within 500 miles of the site.

            The whole subsection on extraction of raw materials also has local-sourcing tiers for calculating credit, which is based on percentage by cost. Domestic products have their cost value multiplied by 1.5; in-state or in-province products have their cost value doubled; and products from within 50 miles/80 km have their cost value tripled. It’s a major incentive for using locally and regionally sourced materials, which fosters local economies and could potentially quell arguments against using LEED for government projects–despite LEED 2012’s renewed commitment to FSC for wood sourcing.

            It seems like LEED went from 500 (sensible) to 50. Now I couldn’t get credit for using bug killed lodgepole from Colorado, because it’s not certified. Conceivably, it is therefore “greener” to import from another state (with FSC certified trees) than my own, simply because our mountains do not have good growing conditions for trees?

            Again, I think it is hype for anyone to say SFI is out to “destroy” FSC. They want to be treated similarly by the ever-untransparent LEED folks.

            My pet peeve about LEED and public agencies is that I think we should put the bucks into energy and water efficiency improvements that save taxpayer bucks and not into paying for certification. We had very smart and dedicated engineers in the FS, and the taxpayer would get the biggest bang for the buck by going by their ideas.

            • Sharon,

              The article you found is dated. Here is where LEED v4 wound up on this:

              “Use products that meet at least one of the responsible extraction criteria below for at least 25%, by cost, of the total value of permanently installed building products in the project.

              Bio-based materials. Bio-based products must meet the Sustainable Agriculture Network’s Sustainable Agriculture Standard. Bio-based raw materials must be tested using ASTM Test Method D6866 and be legally harvested, as defined by the exporting and receiving country. Exclude hide products, such as leather and other animal skin material.

              New wood products. Wood products must be certified by the Forest Stewardship Council or USGBC-approved equivalent.

              Materials reuse. Reuse includes salvaged, refurbished, or reused products.

              Recycled content. Recycled content is the sum of postconsumer recycled content plus one-half the preconsumer recycled content, based on cost.

              USGBC approved program. Other programs for other material types meeting leadership extraction criteria that become available will be evaluated and added as appropriate.

              Products that meet the above criteria are valued according to source location (extraction, manufacture, and purchase point must be within the distances noted below): Products sourced within 100 miles of the project site are valued at 200% of their cost Products sourced domestically within 500 miles of the project site are valued at 150% of their cost.”

              You are right that the bug-killed lodgepole pine will not get credited under this language — unless in the forthcoming LEED v4 reference guide or future addenda, someone decides that such wood qualifies as a “salvaged” product under materials reuse. There are provisions, however, for crediting wood salvaged from orchards and waterways.

              In LEED v4, there are credits other than the one whose language is quoted above where pretty much any wood can earn points. For instance, there is a credit that awards points for use of products covered by Environmental Product Declarations (EPDs), which simply requires a generic LCA for the product or material in question. American Wood Council has already produced EPDs for domestic softwood lumber, softwood plywood and OSB, so all of these products will qualify under LEED v4 whether or not they are certified.

              LEED has multiple credits, and the credits have different intents and objectives — so there are lots of ways that different products can contribute to earning points, depending on which credit a project team is pursuing. LEED 2009 (the version of LEED now in use, which will give way to LEED v4 in the coming years) has separate credits for FSC-certified wood — no matter where it comes from — and for regionally-sourced materials — irregardless of their environmental pedigree and footprint. I’m not defending the logic of this, by the way — but SFI and its supporters lie when they contend that LEED discriminates against domestically-produced forest products.

              And I’ve never hear anyone argue that it is “greener” to import FSC-certified wood from Brazil than it is to use salvage wood from nearby.

              You say you think it’s hype for anyone to say SFI is out to “kill” FSC — but you don’t say why.

              In 1997, the American Forest & Paper Association, which created SFI, released a white paper that is worth reading:

              http://www.jasongrantconsulting.com/wp-content/uploads/2011/10/AFPA-AntiFSC-Letter-1997.pdf

              I don’t know if you have seen this white paper before, but after you have read it, please tell me if you still think that AF&PA and its most powerful members — Weyerhaeuser, Plum Creek, Sierra Pacific, International Paper and the rest — wouldn’t have killed FSC in the cradle if they had been able to — or wouldn’t kill it today if they knew how.

              Yes, SFI wants to be treated equally to FSC by LEED. But they are NOT equal, and as long as they try to pass off wood from status quo industrial forestry as green, they are not going to get rewarded by any true leadership green building standard. Instead, they are going have to keep pushing Green Globes, the SFI of green building, popular now with both the timber lobby and the chemical and plastics industries because it makes so-called “green” building safe for industrial forestry and vinyl.

              • Jason, sorry I didn’t reply sooner but have been in airports with ??##!! free wifi.

                1) this is all incredibly complicated, but it sounds like they have to be certified (one of the criteria for new) AND get extra points depending on their distance. Is that the way you read it? See my italics. (note to others : if this is what LEEDS wood requirements are…my impression is that we can all make more sensible decisions on our buildings about green investments ourselves.. and use the bucks we save on not certifying to LEED to make more green investments.)

                Products that meet the above criteria are valued according to source location (extraction, manufacture, and purchase point must be within the distances noted below): Products sourced within 100 miles of the project site are valued at 200% of their cost Products sourced domestically within 500 miles of the project site are valued at 150% of their cost.”

                2) You said “don’t know if you have seen this white paper before, but after you have read it, please tell me if you still think that AF&PA and its most powerful members — Weyerhaeuser, Plum Creek, Sierra Pacific, International Paper and the rest — wouldn’t have killed FSC in the cradle if they had been able to — or wouldn’t kill it today if they knew how.”
                I’m not sure that this is relevant, and here’s why…
                FSC is trying to make money (in a green way) and their competitors are SFI PEFC CSA and possibly others.
                In this competition, FSC and allies do a variety of things.. to dismiss SFI (usually not an argument based on their standards, usually base on its original/current relationship with timber industry.) It seems to me that SFI has done quite a bit since its initiation to become more independent.
                But you say that timber industry (or we could call this subset of “timber industry” BTIWL) or (big timber industry with land) would “kill” FSC. Would McDonalds want to “kill” Burger King “in the cradle”? It makes the timber industry somehow more malevolent than other companies/organizations who compete with each other.

                Stephen Covey once quoted someone who said “your behavior is speaking so loudly I can’t hear what you’re saying.” What we see from FSC is putting SFI down in a variety of ways.. what we see from SFI is trying to get acknowledged as being in the business. Who is trying to “kill” whom?

                You also stated “But they are NOT equal, and as long as they try to pass off wood from status quo industrial forestry as green,”. No they are not equal, for sure. But that’s not the question. The question is whether they are both “sustainable”. Or “adequately” green.

                When you say “status quo industrial forestry”, I’m thinking that this is an overstatement. Now, I am very careful about what people say in general, and others on the blog know this, so I’m not picking on you.

                In my opinion, SFi – just the third party audits and the continuous improvement- has to make a difference. I know that because we attempted to do some of that in the Forest Service and found out many interesting things that could be improved… just in terms of actually implementing what the FS it was implementing. In other words, just some mildly external audits would have made a big difference in the Forest Service in some areas.

                FS partners reading this, if any, may note that what you have observed about working with the FS on a project, and then the project not being carried out the way it was intended, was also observed during the trial period of the FS experimenting with mildly external audits of forest practices.

                So when you say SFI certification is “business as usual,” you could mean:
                1) The use of SFI improved, from an environmental perspective, no standards from any industrial landowner’s prior practices
                AND
                2) SFI external auditing and continuous improvement requirements did not improve the translation from desired behavior to actual behavior, presumably because industry was doing so well on this before, unlike the Forest Service.
                I find both 1 and 2 fairly hard to believe. The reason being that most organizations are all over the map unless required not to be (and sometimes still, even then). It just seems hard to believe that all companies currently certified to SFI were performing so well beforehand.

                3) Critiques of SFI tend to focus on a) structural ties to the timber industry OR b) specific differences in the standards (less of this).

                So my question to all SFI critics, is
                What would SFI have to change in its structures and standards for you to judge them, not equal to FSC, but simply “sustainable”?
                And, do you consider CSA “sustainable”? Why or why not?

                The US imports most wood from Canada. Most of that is (that is certified) is certified to SFI and CSA. So this seems like an important question for LEED, which is a US outfit.

                • Hi Sharon,

                  Its an interesting question you raise pertaining to the influence of money in politics. For me, the distinction can be made between money that is clearly supporting private interests versus money that is support public interests. After your very own professional alma mater exists because of the belief that we can put money to use for the public good. Yes, there is always the question of whether private foundations dollars are or are not being used in the public’s interest, but this is usually because we have disagreements about what constitutes the public’s interest. For me, the old cliche of doing the “greatest good for the greatest number over the long run” typically helps to understand whether something is in the public’s interest or not. Regardless of this debate, however, it doesn’t seem like a stretch to suggest that we ought of to have a bit more of an “arms length” between certification programs and those who stand to benefit most from them. As a former public servant yourself, I am sure you know far more about “conflict of interest” questions than most of the “civilian” population. Is there some reason why SFI should be exempt form this basic idea? I guess I do think the source of the money makes a difference…

                  Cheers,
                  Mike

                  • Yes, but Mike, . NRA would say that they are in the “public interest”. It’s not my “public interest” .

                    I guess I have found that industry has an agenda (pretty predictable and open) and ideologues also have an agenda (not always so clear). If you happen not to agree with their ideology, then you might think that they should not have undue influence either.

                    That’s where I am. FSC wants power to promote a certain view of sustainable forestry and to make money. SFI wants power to promote another view and to make money.

                    I actually prefer when government more transparently does this. Like USDA Organic. The fights about practices still go on, but they seem to be more out in the open and also less vitriolic.

                    Or maybe the way Canadians did it.

                    • Good points Sharon, and I do very much agree with transparency (truth in advertising). It seems as though we already have a pretty good idea of the businesses that support SFI. Do you know what corporate interests are involved with FSC off hand? Are there large scale commodity driven interests that support FSC? Understanding this better might provide for a good, transparent conversation. Just to be clear, if FSC has the same potential for conflict of interest that it appears exists within SFI, I would certainly be in favor of the same kind of ForestEthics action to be taken against FSC.

                      Following in the theme of transparency, I’ll pose the same question here that I posed elsewhere and ask: Why was SFI created in the first place? What interests supported the creation of SFI versus those that created and support FSC, and which do you believe have a greater societal interest in mind (i.e. the greatest good for the greatest number over the long run)? I ask these question baring in mind that the public estate was created as a means of protecting public interests from the power of the private sector to overwhelm natural systems. If large scale private interests are now truly benign, then perhaps we need to discuss the purposes of the public estate as a whole…:)

                    • Some of the larger North American commercial interests currently in the FSC camp:

                      Potlatch
                      Mendocino Redwood Co/Humboldt Redwood Co
                      Green Diamond
                      Domtar
                      Tembec
                      Columbia Forest Products
                      The Collins Companies
                      Kimberly Clark
                      The Home Depot

                      All are in the FSC’s economic chamber, whose members get 1/3rd of the BoD seats and 1/3rd of the vote on major policy issues, standards approvals, etc. that are put to the membership.

                      Sierra Club, WWF, NRDC, NWF, Greenpeace, and most other well-known environmental groups are in FSC’s environmental chamber, with the same governance and voting rights as the commercial interests. Practically, members of both chambers have to find compromises in order for anything to get done. The social chamber is rarely as polarized as the other two.

                      SFI creates a facade of a stakeholder-balanced governance system and standards development process, but as noted earlier, in fact the big timber companies provide almost all of the funding and hold the trump cards. This is why so few environmental groups are at the table.

                      I believe that FSC these days is funded through a combination of fees levied on top of each FM and CoC certificate (there are nearly 30,000 of the latter) and grants from charitable foundations and the EU. SFI has far fewer certificates (but more certified forest land in NA) — if they had the same funding mechanism as FSC, SFI would be broke!

                    • (I could not see hot to reply to Jason directly, so I’m replaying to Sharon). Thanks to Jason for detailing the private interests involved with FSC. I appreciate the education. I’ve since gone to the FSC site myself and could see the three-pronged BoD. Seems like a good way to balance out the voting and influence…This issue is really intriguing. How different is FSC’s approach, from a structural standpoint, to the SAF BoD. (Jason I know you’ve already said that large timber companies primarily fund SFI, and I can see how this would create a difference between SFI and FSC), but what about the structural aspect of the organization itself. Is SFI’s BoD divided into three chambers? Or is it all in one group? Thanks in advance for any responses. I know I’m asking others to do my homework…:)

                    • Superficially, SFI’s board mimics FSC’s 3 chamber system. From the SFI website:

                      “SFI Inc.’s 18-member multi-stakeholder Board of Directors comprises three chambers, representing environmental, economic and social interests equally… Board members include representatives of environmental, conservation, professional and academic groups, independent professional loggers, family forest owners, public officials, labor and the forest products industry”

                      http://www.sfiprogram.org/about-us/sfi-governance/sfi-board-members/

                      But look who is on their BoD in the environmental sector: The Conservation Fund, Bird Studies Canada, Manomet Center for Conservation Sciences, Ducks Unlimited Canada…not exactly a who’s who of the environmental community.

                      The social sector has two forestry academics, a state forester, a family forest owner and a guy from Habitat for Humanity Canada. Nothing wrong with that, but not notable for diversity or independence from the forest industry.

                      SFI appoints its directors from within. FSC’s BoD is elected in open elections by its membership — and membership in FSC is open to all. SFI has no membership.

                      Now to be fair, the conservation community has, by and large, spurned SFI, although there was a time when SFI tried reaching out to the major environmental groups to try to get them involved. Also, there was a period in the aughts when representatives from The Nature Conservancy and Conservation International served on the SFI BoD, which at that time was called the Sustainable Forestry Board or SFB. In the end, however, they left. I remember a key staffer from TNC saying that for a while they thought they could improve SFI from within sufficiently to justify their involvement, but that hope faded with time.

                      I think most of us hope that the forest certification wars won’t continue forever, and that at some point there will be some sort of rapprochement if not a merger. At the moment, though, that day seems a long way off.

                • Hi Sharon, from what I see, if ForestEthics prevails in their complaint with the FTC, and SFI complies with the order, this would be good start. I’m in no way qualified to answer the more substantive aspects of your question…

                • Sharon,

                  Regarding your LEED v4 question, yes, a wood product would need to be FSC-certified (or recycled-content, or reclaimed) in order for its dollar value to contribute to earning one (and only one) of the points available under this particular credit, and then regional sourcing is a multiplier on top of that. Since the threshold for earning this single point is 25% of the total cost of building materials, and most commercial/institutional buildings (to which the LEED for Building Design & Construction rating system, from which this language comes, mainly applies) are built mostly from steel & concrete (wood, when it is used, is usually for interior finishes and is a small percentage of the materials budget), the main way that people will earn this point is by using other materials, e.g. high-recycled content steel or other materials. Relatively speaking, FSC-certified wood will be a drop in the bucket in most circumstances.

                  Also, it’s important to remember that this and most other LEED v4 credits are voluntary — people don’t have to go for this credit/point in order to get a building LEED certified. There are at least 99 other points to pursue. And, as I noted before, people can earn a point under a different credit using any old wood, certified or not, that bears an EPD.

                  Timber lobby propaganda notwithstanding, LEED does not and has never required the use of FSC-certified wood. It’s always been one voluntary point among many. And if you look at the relative weighting of credits/points across the rating system, most of the emphasis in LEED is on energy and water efficiency and other dimensions of green building — not on wood or any other building material.

                  As for the rest of your post, I’m not sure what to say. Quite clearly, you and I see the FSC/SFI conflict through very different lenses. I am not a forester or a forest scientist like you, but I have seen enough FSC-certified and SFI-certified forests and forestry over the last 20 years to know that there is an important difference between the two, and that it’s not just about “McDonald’s vs. Burger King”-style brand competition. I have lived in Northern California, Oregon or Washington for most of my adult life and have seen plenty of examples of how Sierra Pacific Industries, Pacific Lumber Company (under Maxxam’s ownership, prior to the bankruptcy), Weyerhaeuser, et al. approach logging and forest management. All are SFI-certified (or were, in the case of PalCo). All practice what I would consider “status quo industrial forestry” in their respective ownerships. If SFI has caused them to improve, that’s great, but it sure looks to me like the change is around the margins and does not get at the core of their practices.

                  You ask what SFI would have to change in its structure/standards for me to “judge them, not equal to FSC, but simply ‘sustainable'”.

                  It’s funny that you put it that way. For me, “sustainability” is the last thing that’s simple. For me, sustainability is aspirational — a goal toward which we ought to be collectively striving, but that doesn’t apply to nearly anything going on today. To me, truly sustainable forestry would mean that we could manage a forest exactly that way FOREVER, without any loss of biodiversity, degradation of soil or water quality, production of pollution, use of toxic chemicals, etc. etc. FSC doesn’t represent sustainable forestry for me or most other folks in FSC’s environmental chamber. In fact, I think this is why FSC eschews the “S” word and instead talks about “well-managed forests” or “environmentally and socially responsible forest management.”

                  So I don’t have a good answer to your question the way you’ve phrased it.

                  I’m glad that SFI is gradually improving – as I said before, I see this as the “sea that raises all ships.”

                  I could come around to supporting SFI or CSA if I didn’t see them as fronts for the big land-owning timber companies in the U.S. and Canada whose core purpose is not just to defend intensive industrial forestry, but to pass it off as somehow “green” and “sustainable.” What specific changes do they need to make for that to happen? I don’t have an off-the-cuff answer that would satisfy you or anyone else, but I do figure that we’re likely to recognize it when we see it.

                • Hi Sharon,

                  What if we turned the question around and asked, what would FSC have to change in terms of its structures and standards for SFI supporters to come on board with FSC? Why does SFI exist in the first place? What is it about FSC that was unacceptable to SFI supporters? Just a thought to continue the conversation…

                • Sharon, I’ll take a shot at your first question. For one, SFI needs more ecological rigor if a company or landowner should expect some certified recognition that what they do is “sustainable”. Perhaps the bigger question relates to what “sustainability” means in the world of forestry. We just have not seen any changes in on-the-ground forestry practices as a result of SFI certification with our industrial and TIMO/REIT owners in the Pacific NW. I invite anyone to show me something to the contrary. They already must manage according to state forest practices (which some states argue should be grounds for certification), but state forest practices that I know (WA, and OR, MT to a lesser extent) have few provisions for “sustainability”, whatever that does mean in a forestry context. In a state like WA or OR, you have to reforest after a regen harvest, but if you own 50,000+ acres and just cut 40% of your landbase over several years, how sustainable is that for local mills in the coming years (many now severed from a source of timber), ecological processes and organisms dependent on later seres or successional stages of forests? How is that sustainable for workers and communities when so many harvests were crammed into such a short period of time that labor/contractors had to be imported from outside of the community, only to leave when the cutting is done? These are the kinds of things that FSC certification at least tries to get at in the certification process. I have friends that have gone through the SFI process that suggest that certification is something that can be achieved simply by having your paperwork demonstrating compliance with various laws and accounting principles in place.

                  I think this whole discussion begs the question of what is the point of certification. We have state forest practices for private land, the bazillion regs that pertain to fed forest management for NFS, etc., lands…Once upon a time some of us hoped that certification would represent something that stood above all of that. Exemplary management. SFI hired the ad agency that did “Got Milk?” for the dairy industry, and some would argue that it’s been a race to the bottom ever since. I actually don’t agree with that. But SFI is not deserving of “green” or “sustainable” certification in my book right now. That does not make them and their subscribers bad. They serve their role. It’s a bit like my choice between Walmart of the farmers’ market. But that’s digressing even more…

    • I would buy local that has not been certified at all.. because locally we have lots of dead trees. Dead trees that are not managed (free range trees, no herbicides, no other management ) do not fit into certification schemes.

        • Miami- from N. Florida
          Peoria- from local woods or Lake States
          San Diego- Sierra Nevada
          Topeka – Colorado is closest 🙂 no certification because no forest management

          In all these if I were going for wood from managed forests I would pick whatever certification system was available.

          Try visiting your local HD or Lowe’s and see what if any local stuff is available. I would prefer to have piles of “Colorado grown” at the lumberyard, just like the grocery store.

  15. Another question I thought of. What if the haul to the nearest mill is very long? Does that make a difference in certification? There are trees cut in the LA Basin but, the nearest mill is six hours, each way. Can those logs ever be certified, by either or both entities? I even saw cull logs being trucked from SoCal to Central California SPI mills.

    Oh, and just yesterday, while on a photo expedition to Yosemite, I saw a log truck coming out of the National Park, with old growth logs! Could THOSE be certified? I’m guessing that logs are being sold that are cut under Obama’s “View Enhancement Program”, within National Parks.

    • Larry, the real important point about the LA Basin and the Park Service is that forest certification schemes have to do with the sustainable forest practices on land managed for timber production. Things like thinning, fertilization, herbicides, protecting wildlife, roads that are not dumping sediment into streams, etc. There is another part of certification that has to do with the chain of custody, but forest management practices is where it all starts.

      However, just taking trees from southern Cal forests or Parks is simply removal of extraneous “free range” or unmanaged trees. Since there is no “intentional forest management” there can be no “sustainable forest certification”.

      Now, you might also think “shoot, the FS doesn’t really do much thinning, herbicides or whatever anymore so they would do fine and could be certified, if they kind of pretended that they were in the biz of forest management and were certified.” So you can check out the Pinchot Institute study here http://www.pinchot.org/gp/National_Forest_Certification.

      I was working for the Forest Service when this was going on and there are a couple of good reasons not to certify…(because taxpayers’ money would go to possibly improving the marketability of certain sawmills’ products; and because the FS would be following standards not developed using NEPA and “the best science.”

      but the way I heard it, FSC was interested at one time (and may be again) but the Sierra Club doesn’t want to because they are against commercial logging sustainable (FSC) or not on public lands. Of course, this is all hearsay because any meetings would not be/have been public. Perhaps meeting notes could be FOIA’d? Or retirees who were at the meetings might contribute?

      Whoops, I got off the topic, onto NFS certification. Anyway, I may be reading the new LEED statements incorrectly but it looked to me as if wood had to be certified AND within the distances to get the credits. If it was OR, then you would just measure the distance from the location the logs originated to the mill to see if you could get some credits.

  16. Howdy,

    Its been a long time since I’ve had a chance to visit this site. This was a great discussion. Thanks to Mathew for opening up the conversation. I really appreciated Jason’s very informed comments and responses. A long time ago I worked briefly as an FSC auditor in Montana and I really appreciate all the good information that Jason presented.

    My two cents, at this relatively late date in the conversation, is that the ForestEthics complaint comes down to a “prima facia” conflict of interest case not unlike many other cases in which advocacy groups are too closely tied to those with a financial interest in their advocacy. Putting aside any of the substantive arguments on whether FSC is a better certification program than SFI, no one can argue that the ForestEthics case is grounded in fundamentally good policy (i.e. tax exempt status rules and regulations should be stringently adhered to). I think everyone would agree that “paid for” lobbyist are already far too cozy with politicians and that this has resulted in a degradation of our democracy. There is a real parallel here with purportedly non-profit organizations who are truly acting on behalf of commercial interests.

    For this reason alone, and without knowing anything more than what I’ve read here, I am strongly in favor of ForestEthics’ actions. It will be really interesting to see how the FTC responds! Mathew, I would personally appreciate your tracking on this and reporting the findings down the line.

    • I think I agree with you, Mike. My problem is that I am not sure that organizations based on ideological points of view and funded through membership or foundations should necessarily be cozy with politicians either.

      I guess we have to decide if the problem is politicians unduly influenced by money (regardless of source) or only money from commercial sources. Cause I’m not sure I can get behind the “companies bad, foundations/interest groups good” dichotomy.

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