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To the Taiga Rescue Network --

I beg to differ with the conclusion that this piece by Glen Barry raises 'serious concerns' regarding the FSC system. The article raises a number of vague, unsubstantiated allegations, and does not conceptually verify most of them. The article is littered with spurious allegations that would be ignored by any rigorous logical or factual analysis. For example, the conjecture that "dissent is not welcome and is rarely heard" is preposterous. The FSC system is based on convening stakeholders who are traditionally archrivals in forest policy matters to develop best available compromises. If the author thinks that dissent is rare, he has not attended any regional or national WG meetings in the U.S. (and, in fact, I think he has not, although he lives here). As another example, I didn't know much about the facts of the Brazilian certificate that Mr. Barry so disdains, and I know nothing more about the facts after reading his diatribe against it. I hope his impression is wrong, but we should learn and discuss more of the facts about that certificate before we determine that it is or is not a serious concern.

Ad hominem attacks on industrial and government forest managers do not stand up under logical scrutiny. Without good stewardship on industrial and public lands, conservation and protection goals will be impossible to meet in many parts of the world, including the U.S. I'd much prefer FSC management to unregulated or government-only regulated management on most of the public forests that I've seen.

Does the FSC system have room for significant improvements? Absolutely. We are working, and should work harder to make the program accessible and viable for small and private forest owners. Resource manager and coop certification programs are working to resolve that limitation. We should be open to suggestions on how to improve those programs. As FSC stakeholders know, we also have much work left to do on plantation management, partial estate certification, high conservation value forests, and percentage-based labeling claims.

The old-growth issue that Mr. Barry raises is a legitimate one. It is also one that working groups struggle with, to balance provisions in consideration of the ecological costs and benefits of protection and the social costs and benefits to indigenous and other local communities. There seem to be few win-win resolutions in some regions, but I challenge any assumption that FSC working groups do not try earnestly to balance these values for optimal results. In particular, the provisions of the draft Pacific Coast Working Group (U.S.) standards has strict limitations on the management and harvest of old growth forests. Areas with indigenous groups and working groups in developing nations will take varying perspectives on how to handle old-growth forests in their regions, and it is unseemly for North Americans to judge whether those regions have made good compromises for their forest uses or not.

Are environmental/economic trade-offs sometimes struck that are unsavory to the environmental chamber? Yes, but the economic chamber thinks some pretty unacceptable compromises are made, too.

Unsubstantiated, derogatory accusations about the motives of Greenpeace and WWF are scandalous. I do not know the motives of the author, but thorough analysis, intellectual rigor, and fairness do not seem to be among them.

Nicholas R. Brown, PhD
Manager for U.S. Forest Conservation
World Wildlife Fund - US
1250 24th St. NW
Washington, DC 20037