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Comments on the article by Freris/Laschefsky on Precious Woods and the FSC, by Imme Scholz,
Including the response by Freris/Laschefski (italic)

The main idea of the article is that there is no sustainable way of using Amazon timber, therefore, certification is no "green" alternative for local economic development in the Amazon region. The real alternative would be to promote non-timber forest products harvested and processed by local communities. In order to make their point, the authors enumerate a list of problems which FSC is facing, but they fail to realise that FSC can be held responsible only for some of these problems.
Response Freris/Laschefski: The main idea of the article is to dismantle some of the myths used in the marketing of FSC certified timber. This process results in an analysis of the real impacts of certification on logging of primary forests. At no point in the article do we state that there is no sustainable way of using Amazon timber, but we do question the role of certification of tropical timber in the preservation of the worlds remaining tropical rainforests. Whether or not FSC is "responsible' or not for its negative impacts is of little interest. Good intentions are not enough. Initiatives such as tropical timber certification do not occur in a vacuum. Given the context, maybe this really is NOT the most appropriate means of forest preservation. With the growing controversy surrounding FSC, individuals and organisations who have been involved in its support should have the courage to re-evaluate its REAL objective. If this is to simply open new markets for tropical timber, then the marketing currently used is extremely deceptive. If however the objective is to contribute to the conservation of tropical rainforests, we argue that FSC is failing on various fronts.

In addition to that, the authors fail to recognise that the use of non-timber forest products (known as "extractivism" in the Amazon) has a long tradition in the region and often contributed to a drastic reduction of the regeneration capacity of the species involved, and, as a consequence, to a boom and bust cycle, e.g. in the case of rosewood - pau-rosa or macaranduba (see Homma 1992 for an analysis of the economics of extractivism).
Response Freris/Laschefski: We have deliberately avoided the use of the term Extractivism. It is a diffuse and somewhat meaningless term. The intensive exploitation of non timber forest products can clearly have a devastating impact on the environment. The use of forest resources needs to approached in more holistic and less linear manner in order to avoid damaging sequels. Without defining one particular category of forest product, we support the diversification of land use systems, based on the traditional knowledge of local peoples who should be the main beneficiaries of any economic intervention. Here a quote from the article: "Traditional people value most highly, intact forest which needs to be preserved in its entirety to continue to yield the enormous diversity of products. This land use represents an efficiency and sustainability that industrial forestry will never be able to attain."

The other "misunderstanding" is that certification is meant to constitute an alternative development model for the region in itself.This has never been the case, certification is merely intended to be an instrument for the conversion of timber harvesting to more sustainable patterns. However, the authors are right to question whether large-scale timber harvesting and processing really is a sustainable option for the economic use of tropical forests.
Response Freris/Laschefski: This is not our misunderstanding. FSC is being sold by its supporters as an appropriate development model for the region - see Myth 4. It is however interesting to see that we agree on one essential issue: Large scale timber harvesting and processing is highly questionable as a sustainable economic use of tropical forests. We argue that FSC is supporting an industrial scale logging economy both directly, through certification of large foreign logging companies and indirectly, through the marketing, research, training which reinforce a regional economic culture of logging.

But they fail to mention the economic reasons, mainly technological progress which favours the production of technology-intensive panels on the basis of homogeneous wood fibres from monocultures (pine and eucalyptus plantations).
Response Freris/Laschefski: FSC has developed specific principles and criteria for plantations which thus need to be discussed in an separate context. The focus of this article is certified logging of primary forests. The main demand for timber from primary forests is the plywood and Verneer industry. The demand stimulating plantations is pulp and paper industry, palmoil and charcoal production for the steel industry. This are quite different market segments. So what is the point?.

Certification has been successful so far with big firms, which are able to invest large sums in the acquisition of learning, machines, sophisticated inventory systems, electronic equipment and forest areas. In the Amazon, these firms are the exception in the timber sector. Certification still is not a real alternative for the majority of timber processing enterprises in the region, because the necessary investment is too high and prices still do not compensate the effort. But these arguments are not taken into account by the authors.
Response Freris/Laschefski: This question is considered when we make the point that the cheapest way of timber production is still illegal logging. We suggest that instead of focusing efforts on improving management practices of the cream of the timber industry, efforts to contain the devastation of logging might better be spent on addressing the real political and dynamic of timber exploitation. In continuation of your point, we argue that voluntary market solutions are very limited and should not play such a dominant role in international forest policy: Certified tropical timber sold to an ecologically conscious elite of the first world has little influence on the global dynamics of the timber business. Within Brasil, 85% of timber from the Amazon is consumed in internal markets 23 . It is these markets that help sustain illegal logging in the region, currently estimated at 80%.

Regarding the myths the authors try to deconstruct, it is sad to see that the arguments they use often do not hit the target:
Myth 1: First, it is true that the real impact low-impact logging will have on the forest ecosystem is still unknown. There is urgent need for long-term accompanying research in order to know and measure these impacts. But certification has never pretended to leave the forest untouched; it is an explicit aim of silvicultural practices to change the ecosystem and make it more productive in terms of marketable timber volumes. Protection of the forest ecosystem and its original biodiversity is nothing you may expect from certified logging, this is an aim pursued by the demarcation of protected areas. The idea of certified logging is to maintain forest cover and its basic ecological services (protection against erosion, protection of the water cycle, etc.).
Response Freris/Laschefski: The myth states that - Certified logging of primary tropical forests has minimal impact on the forest ecosystem. The marketing of FSC is based on the claim that certification somehow contributes to the preservation of tropical forests. The consumer might thus be mislead into thinking that there will be minimal intereference in an area of certified forest which, through logging will somehow be protected from worse fates. However, even the vehement supports of FSC admit, as you do that certified logging does have a profound effect on forest, turning these complex, biodiverse ecosystems into marketable timber stands. This fact contravenes a basic principle of FSC - "certified" intervention must not downgrade ecosystems. FSC is rightly cautious about their claims of protecting ecosystems and tend not use the term sustainability in their documents. Instead they speak about well or responsibly managed forests, which seems to transcribe in reality to merely having more sophisticated information about the damage being caused. The problem is, that the public discussion and marketing of FSC creates the impression that through certified logging, forest ecosystems will be protected. "Help conserve the world's forest. Look for and purchase products carrying the FSC". How this will be interpreted by the consumers? It is certain that they will not understand that through certification, primary forests will be excluded more comprehensive protection and transformed in timber production sites.

Second, the opening up of undisturbed forest areas for logging is not a problem of certified logging but of logging in general. The difference is that certification aims at fixing the logging firm on one area and thus interrupt the traditional pattern of migrant logging.
Response Freris/Laschefski: Within the Amazon state, the traditional timber extraction focused on exploiting species of the flood plains accessible by water during the wet season. Logging of the highlands (Terra Firme) occurred when access was gained through roads for example the Transamazon. Although we certainly not defend the chaos, illegality, social and environmental abuses that traditional system engenders, it is limited both geographically to the floodplains and in time by the seasons. In contrast certified logging of PWA and now Gethal is carried out in the highlands, creating a new logging frontier no longer contained by these natural factors. In addition, in order to carry out planned and rational management, a well maintained infrastructure of roads is required specifically laid down for logging. This is clearly demonstrated on the satellite image of the PWA management area. The most effective means of introducing serious deforestation into the heart of the forest is to lay down a road.

It would in fact be interesting to have a detailed comparison of the impact of the traditional system and the innovations of certified logging. We assume one is less damaging than the other - but do we really know?
Myth 2: Of course certification alone does not represent a fundamental change of the incentives that influence land-use patterns. But certification as a voluntary market instrument cannot be blamed for this. Certification tries to show that forest use may be an economically interesting alternative if pursued on a long-term basis (long-term commitment of the forest area under a management plan is binding, both under FSC rules as under Brazilian law).
Response Freris/Laschefski: Again WE are not suggesting that Certification schemes should or do meaningfully change incentives land use patterns. However, this claim is included as a myth as defenders of FSC often assert that certification discourages more damaging less lucrative (in the long term) uses of forests. So you agree with us that this claim is unsubstantiated.

Brasilian law and Certification rules should not be confused. Certification is voluntary and market driven, meaning that if the benefit does not outweigh the cost, companies can easily opt for weaker standards. Binding state laws are quite different - if the company fails comply, it is acting illegally. We suggest the investment in the regulations of FSC schemes, might be thus better spent- "Invest in improving control by governmental agencies of illegal logging and gradual tightening of state regulations for legal logging." This is a weak argument in an economic setting characterised by short-termism. FSC defenders hope that the success of the instrument (growing voluntary adherence) may strengthen those forces within government who advocate a more radical change of incentives influencing land-use patterns. Voluntary market-based instruments for environment and resource protection always need strong environmental control as a basis; certification was never meant to substitute this but to show that certain protection rules converge with the interests of the forest user. Again, certification means a fundamental change in forest use (mainly diversification of marketable species) in order to fix firms on the same area. This is the contrary of the traditional pattern, which consisted in constant migration to remote areas. However, the authors may not be solely blamed for not acknowledging this fact - industry itself hesitates to acknowledge it because it means a major change of its routines.
Response Freris/Laschefski: You admitted above that the silviculture practices of certification schemes transform the forest ecosystem into stands of marketable timber - protecting at least the area from land erosion and maintaining the hydrological functions. Given this radical transformation of a previously extremely complex biodiverse forest ecosystem, it seems of little importance if the tree stands include 20 or 60 marketable species. It must also be remembered that opening new markets for previously unexplored species will stimulate their extraction beyond the bounds of certified management area. This undesirable side effect is clearly demonstrated in the article with reference to the exploration of Acuariquara.

Myth 3: The "timber bias" criticised by the authors certainly exists in Brazilian institutions, especially in the forest lobby. To see the forest as a multiple resource is still new in Brazil. However, the MMA (Federal Ministry of the Environment) has invested a lot in promoting the use of non-timber forest products, much of it with support of the PPG7. It is not fair to describe the Promanejo project as focussing only on timber production. Project design and activities include support to the traditional population of the Flona Tapajós and the processing and marketing of non-timber forest products. The results of these measures should be replicated in other areas later on.
Response Freris/Laschefski: Promanejo in the Amazonas state focuses on timber production and has a strong influence on the states institutions responsible for forest policy. This does not mean that there are no examples of some support of non timber forest products in other regions, - but the bias is there, replicated throughout the institutions deliberating on forest issues. The impact of this vision cannot be underestimated. It is manifest in the training schemes for local people in timber extraction, the timber bias in the state and academic institutions and the higher echelons of international bodies that deliberate on forest policy.

The main argument against the "timber vocation" of the Amazon is the lack of competitiveness of tropical timber as an input for industrialised mass production in comparison to homogeneous wood fibre from plantations, due to the species diversity of these rain forests (unfortunately, in Indonesia, with forests dominated by dipterocarpacea, this has been different).
Response Freris/Laschefski: Our argument against "timber vocation" is that it is simply not a desirable future for tropical forest ecosystems or for local peoples. However what you are stating tends to agree with the argument in Myth 6 - markets for certified tropical timber are seriously limited. To respond to market demands, we suggest the use of replanted timber from former degraded areas. With respect plantation timber, as already noted above the dynamic and economy is quite separate from the question of timber from primary forests and has more in common with industrial agriculture than forestry.

Myth 4: The authors are right to state that certification in itself cannot provide for a new basis of local economic development. But there are many municipalities in the Amazon, especially in the poor rural areas of Pará, where non-agricultural labour revenue depends to 80 - 90% on timber industry. This dependence is worsened by the traditional migration of sawmills to new agrarian frontiers when timber resources are exhausted. This pattern can be changed by certification. The fact that Precious Woods is now acquiring a forest area in Pará is a reflection of many errors of evaluation they made when deciding that Itacoatiara would be the ideal location for them, it is not part of a traditional migration process.
Response Freris/Laschefski: Firstly, the reason that PWA is moving to Para has nothing to do with traditional migration patterns or questions of labour. The management area in Itacoatiara is poor in marketable tree species, such that to respond to demands PWA are logging two compartments a year instead of one. This means that they will finish the first round of logging of the whole area, well before the 25 year cycle is complete. This in turn, means they will have several years fallow, unable to log their area - so they had to find a new patch of forest. It is likely that this area is Para is the intact native forest required to render the tree species. This we considered a new logging frontier, created through the process of certification of tropical timber.

We understand the difficulties in Para where in many places the local economy is totally bound with the logging industry. In this context, certification schemes could help promote use of timber from replanted forests and then yes, encourage diversification of tree species - upgrade not downgrade. However, Certification should not be used to encourage logging the diminishing islands of native forests simply because of the momentum a logging economy fixed on short term gain - after all, no forest, no logging, no jobs. Regarding labour it is clear that forest operations are not as labour intensive as family agriculture production systems. The traditional argument in favour of forestry instead of agriculture on a specific area mainly refers to ecological conditions, which determine a higher sustainability for forestry also in economic and social terms in comparison to other forms of land use. In this context, the calculation that the 2.700 ha used for transport infrastructure by Precious Woods would give sustenance to 540 families shows a poor understanding of family agriculture in the Amazon: a traditional family needs at least 24 ha for its rotation system (3 hectares are used per year and then left fallow in order to recuperate soil fertility; with a fallow period of 8 years, a family needs a total of 24 hectares), therefore the 2700 ha would just be enough for 112,5 families.
Response Freris/Laschefski: Indeed, we could dispute these figures given the enormous diversity of Amazonian ecosystems. Traditional land use systems depend on their location (floodland or terra firme), soil fertility, and a series of social and cultural issues. The numbers presented in the article are based on interviews of local organisations and institutions with respect on ribeirinhos in the region of Itacoatiara. However there has been some innovative work on alternative agricultural practices for the region based on Permaculture. These demonstrate that a 3 hectare highland area can be farmed permanently, removing the need for slash and burn. The diversity and quantity of production is in excess of the subsistence needs of a typical Amazonian family. It is these experiences that need the support of individuals and institutions interested in changing the pattern of social abuse and environmental degradation that characterise the region.

The other case put forward by the authors, traditional families expelled from the area to be managed by Gethal, refers to the larger problem of land titles and agrarian reform which cannot be solved by certification, but for which certification cannot be blamed either.
Response Freris/Laschefski: Clearly, Gethal is not responsible for agrarian reform in Brasil. However it could be considered a beneficiary of unjust system of land ownership and thus certainly has become part of the problem. Approval of Certification demands that these social issues are considered and effectively addressed. In the case of Gethal this question seems to have been inadequately dealt with.

Myth 5: Lack of transparency - here the authors name a real problem the FSC is facing, and which could compromise its credibility in the near future. This would favour those who say that there is no possibility of co-operative As there is until now no model for smaller operaters or even local people the effect is an acceleration of land concentration.learning in tropical timber industry, and strengthen calls for boycott, which, in turn, would again increase illegality in the timber sector (and failing to reduce logging). The authors are completely right to say that it is wrong to hide the systematic breaking of FSC rules by certified enterprises. Under these circumstances, enterprises learn that the political agreement between industry, NGOs and environmental authorities is more important than rule compliance, and this undermines the authority of NGOs, which have to rely on transparency and information of the public.
Myth 6: This is a call for a CO2 balance along the production chain of timber industry!
Response Freris/Laschefski: No this is a clarification of the simplistic argumentation used by supporters of sustainable forest management. The climax situation of primary forests is a system of equilibrium of mass flows. Therefore, serious foresters should consider the whole system of mass flows in forest management including timber consumption.

Myth 7: It is true that the "green bonus" for certified timber on international markets is not very high. This is one of the factors that have to be taken into account when calculating the economic feasibility of sustainable large operations in tropical forests (see above). Regarding the case presented by the authors, it is sad that they omit the Brazilian buyers' group which has been created by Friends of the Earth because the domestic market is much more important than external markets for Amazon timber. Already now, however, external and internal demand for certified timber is larger than the offer. Which means, that Brazilian industries committed to process certified timber buy timber from certified plantations in the South of the country.
Response Freris/Laschefski: We feel, as mentioned in our article, that buyer`s groups create an illusion of a huge demand. It is easy for companies to make public declarations about their commitment to buy FSC-timber meanwhile selling the non certified variety. Certified timber will remain in its little ecological niche as the vast majority of products are made from regular timber. Stocks depend on consumer demand, but research shows, there is a very limited elite in Brazil which is able to pay higher prices for certified products and there is a little awareness for ecological and social sound products. Limiting the market of non certified tropical timber would certainly have a more effective impact on the logging industry.
A good example of the success of such a strategy was the timber boycott, which involved the main Do-it-yourself market chains in Europe. Ironically this boycott was the driving force to create the FSC.