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Dear Glenn,

I am writing in response to your "Overview and Commentary" dated 30 July 2001, in the hope that your subscribers will have the opportunity of reading the views of those you accuse of "bastardizing" forest certification.

You say the FSC principles and criteria fail to define the circumstances in which logging of "old growth forest wildlands" is acceptable. The FSC principles are, of course, deliberately broad to avoid top-down "one-size-fits-all" prescriptions and to permit development of more precise standards by certifiers and regional stakeholders. Principle 6.2 requires safeguards to protect rare, threatened and endangered species and their habitats as well as the creation of appropriate conservation zones and protected areas. Principle 9 requires forest managers to identify high conservation value forests (HCVF) and conserve the relevant values. HCVF is a new and inclusive concept for defining which forests deserve highest conservation priority – taking into account biological factors, environmental services, and social values. While "old growth" is clearly a conservation priority in countries that have lost most of their natural forest, it translates less well as a prioritizing concept to countries rich in natural forest, or inhabited forests where the line between new and old growth is difficult to draw. Also many forests that have high biodiversity or important social values would not qualify as old growth (e.g. the tembawang forest gardens of Kalimantan). You should also be aware that the concept of "wildlands" or "wilderness" is offensive to many forest dwelling communities when used by others to describe their ancestral domains.

You call for a return to the 1980's neocolonialism of boycotts on tropical timber, even though the rich world shows no willingness to pay for the conservation it desires in poorer tropical countries. A well-subscribed boycott discriminates against all tropical producers and offers no incentive for improvement. Certification, imperfect as it is, defines a path for tropical forest managers to follow. Certified forestry may offer less protection to biodiversity than the utopia of vast tracts of strictly protected forest, but is vastly preferable to the reality in many parts of the tropics of repeated cycles of reckless logging or straight out forest clearance.

You are quick to condemn the FSC over the grant of a single certificate in Sumatra. Two major strengths of the FSC are that certification assessments are public documents and that aggrieved parties may lodge complaints. The FSC's elaborate and transparent grievance procedures are designed to take into account the many different stakeholders in forestry and the inevitability of differences in opinion. In the Sumatran case, complaints have been lodged and the jury is still out. Commentary prejudging the outcome from afar, or deriding the ability of the FSC system to deal with those complaints, is surely unhelpful. You chastise WWF for working with unnamed logging companies. Without knowing the specifics of your concerns, WWF remains open to providing advice to any company that genuinely wants to improve its logging practices, on the premise that conflicts are rarely resolved without dialogue. We would certainly see it as a positive result if a migratory logging company changed its spots and achieved certification.

The Papua New Guinea Forest Industry Association would no doubt be as confounded as I was by your allegation that WWF is "the driving force" behind logging in PNG. If this refers to WWF technical assistance to local communities in Gulf Province who are conserving their forests by effectively managing them, then you should be aware that timber production from these communities amounts to less than 0.0x% of PNG's industrial timber production.

Finally, I would urge forests.org to devote less bytes to attacks on the FSC system and its supporters, and more to constructive suggestions on how the system can be strengthened. If not, perhaps forest.org risks will inadvertently support the cause of "meaningless industry sponsored alternatives" .

Rod Taylor
Asia Pacific Forest Coordinator
WWF International