A Critique of the Tembec Certifications, FSC’s largest certified company

This article was supplied by Mary Bull, of the Greenwood Earth Alliance:

The Forest Stewardship Council certifications of Tembec Industries Inc on vast areas of Canadian forest land have involved many of the typical flaws and failures of FSC certification documented throughout this web site. These certifications cover large industrial-scale operations involving massive clearcutting and even-aged management, with the certification awarded on the basis of future reforms, and in some cases, future standards. Certifiers, such as Smartwood, are paid directly by the logging company to do the certification, and the FSC has failed to provide adequate oversight of compliance. These large operations have catastrophic impacts on wildlife, water, climate, and other natural resources. The concerns and rights of the local communities, such as those of First Nations, are marginalized by the timber company and the certifiers.According to their web site, Tembec Industries Inc is a Canadian integrated forest products company, with operations in North America and France, about $3.8 billion in sales, and 10,000 employees. They operate 50 pulp, paper, and wood product manufacturing units, produce chemicals from by-products, and market their products worldwide. They also manage 40 million acres of forest land. Most of this is public land that spans First Nations territories and includes boreal forest.Tembec’s August 24, 2006 press release states that the Smartwood certification of over 1,000,000 hectares in the Temiscamingue region of Quebec (Forest Management Units 81-21 and 81-22) brought Tembec’s total number of FSC-certified hectares to 7.4 million (18.3 million acres), making it the company with the largest area of FSC-certifed forest.In the case of Tembec, one needn’t look further than the certifier’s public summaries to become alarmed and disillusioned by the vast discrepancy between the FSC green label and PR -the “promise” of FSC certification and its guarantee to consumers – and the sad reality in the woods, as described in the summaries by the logging company, their certifiers, and concerned stakeholders.The public summaries are long documents (in this case, up to 50 pages) that often use highly convoluted language – for instance, “alternative scenarios that imitate a greater intensity of disturbance” means “clearcut”. These public summaries sometimes seem purposely opaque – for instance, the silviculture methods that Tembec actually use on the 2.5 million acres they manage in the Temiscamingue region of Quebec are not stated explicitly until page 43 of the 44-page document, tucked away in a table: 67% in even-aged management with 47% of this clearcut. As a consequence, the public summaries are highly ‘opaque’. Just getting beyond the list of abbreviations at the beginning can be a feat for some concerned lay-people.For this reason, this critique will simply list selected highlights from two of the certifications, with some explanations. You are encouraged to read the entire documents for the full impact.”La Saare Forest” (FMUs 85-51 and 85-62) in the Abitibi region, NW Quebec. 1,179,022 hectares, all boreal forest. FSC-certified July 2005 by Smartwood.Pg 6. states that Tembec’s silviculture method is clear-cutting and that the company has no plans to use any other method, because clear-cutting provides “the light and heat requirement for seedling establishment…”Pg 6. “Tembec is examining the possibility of using other alternative methods that put into place a more ecosystem-based approach” that relies on “the imitation of natural disturbances specific to the region.” This comes up in several of Tembec’s certification summaries. For instance, in the Gordon Cosens certification two years prior to this one, the Smartwood certifiers describe the evolution of Tembec’s management practices culminating in what they call “a more ecological approach…Harvest patterns were to emulate fire disturbance, resulting in large areas of unharvested and large areas with concentrated harvest [ed: clearcuts] and the retention of stands to enhance biodiversity.” These areas of concentrated harvest included 25,000-acre cutblocks with 10% retention, that is, 90% clearcuts…As if industrial logging could in any way meaningfully imitate the effects of a wild fire, a force of nature with a complex symbiotic relationship with the forest that has evolved over millennia.It only gets worse from there, with inadequate input from First Nations; nothing officially protected, though it says at the top of page 11, “expected protected areas would cover 104,035 ha,” (out of 1,179,022), or officially designated High Conservation Value Forest (though the certifiers are enthusiastic over Tembec’s unimplemented plans in this regard).Pg 25-28. Here is a sampling from the Weaknesses section, which includes a list of 12 inconsistencies with Principle 6 (Environmental Impact), such as”current harvest type strongly favours conversion of uneven-aged stands to even aged stands”an annual allowable cut calculation that is “deficient” and in need of “an in-depth reassessment of the model;””the reliability of the data used by the model is questionable;””growth and yield calculations in mixed stands are inadequate;””no consideration for risks or errors in AAC calculation””non-timber resource protection measures remain to be developed;””no monitoring of succession or natural dynamics in some instances;””no environmental impact mitigation measures for different types of forest operations”And so on. (Note that many of these critical shortcomings are cited a year later in the certification summary addressed in more detail below.) Yet, there are no pre-conditions, and the conditions, mostly two years down the road, require little or no actual change in logging practices.FMUs 81-21 and 81-22, Temiscamingue region, Quebec. 1,000,000+ hectares. FSC-certified June 2006 by Smartwood.Pg 10. Stakeholder comments P1 (Legal). “Class action procedures were initiated against industry regarding hours worked by silviculture workers.”Pg10-14 Stakeholder comments P3 (Indigenous Rights). About 25 collective and individual comments by First Nations respondents to the effect that they are marginalized in the forest management process, citing:lack of human and financial resources to effectively participate in planning;marginalization of their input when they participate in the annual plan consultation, e.g., with regard to protective measures and silviculture methods (too much clearcutting is taking place with impacts on wildlife, and multi-aged stands are being converted to even-aged stands);agreements that are subsequently ignored or modified without further consultation;being pressured into consenting to plans;exclusion from participation in strategic planning (general forest management plan);exclusion from participation in the definition of high conservation value forest;requests for data ignored;inadequate maps – a history of the logging is required;inadequate tools for judging the state of the resource;employment opportunities are lacking.In addition, two First Nations have withheld their consent for Tembec to engage in any forest planning or operations, have attempted to disrupt forest operations, and have expressed the need for better First Nation participation in forest management.Pg 17–18. Strengths and Weaknesses P4 (Community Relations and Workers Rights). No established process for public participation. Working conditions an issue. Health insurance not offered to all workers.Pg 19. Strengths and Weaknesses P5 (Forest Benefits). Quality wood is left in the forest; The precautionary principle should be used when calculating the allowable cut.Pg 19.. Strengths and Weaknesses P6 (Environmental Impact).Tembec does not have the software tools to do adequate large scale spatial evaluations of its forestry practices.Tembec’s current forest management approach does not conserve the structure or function of the pre-industrial forest. There is likely still too much clearcutting compared with partial cutting.Tembec does not yet possess an explicit strategy for retention of live trees in its cut-blocks (Note that the FSC/national boreal standard adopted two years prior, with which Tembec agreed to comply in April 2003, specifies retaining 25% in each cutblock).Tembec proposed an alternative to selection cutting that takes more wood, without analyzing how this will work within the ecosystem management strategy.Pg 20. Strengths and Weaknesses P8 (Monitoring and Assessment). Tembec does no environmental studies, and has no environmental impact evaluation or monitoring method usable in an adaptive management system at the stand or landscape levels.Corrective Action Requests. Following are highlights from a long list of CARs.Pg 24. Coulombe Commission reported that the model and method used to calculate the Allowable Annual Cut were thoroughly assessed and found to be significantly deficient. [ed: The implication is that too much forest is being cut to be sustainable.]Pg.26. In general, Tembec leaves very few wildlife trees behind in its clearcut blocs.Pg 27. Tembec uses proposed protected areas as part of its land base when calculating Allowable Annual Cut [Note that the certifiers flagged this same transgression two years earlier in the April 2003 certification of the Gordon Cosens Forest]. Tembec has no landscape plan for moving toward pre-industrial forest conditions.Pg 28. Tembec has no standard operating procedures to avoid soil compaction, nutrient exhaustion, hydrological damage to sensitive areas. Tembec has no road/access management and maintenance plan. Waterways are not classified according to sensitivity.Pg. 29. Tembec has no procedures for restoring areas damaged from non-compliance. Tembec uses exotic species in bank stabilization and hybrid plantations, but has not determined their invasiveness.Pg 29. Tembec’s management plan does not address non-timber forest resources, such as wildlife, fish, habitat, recreational, cultural, visual, etc. and the management plan is neither adaptive nor is it designed to test hypotheses regarding its affect on other variables besides wood production.Pg 30. High Conservation Value Forest identification is incomplete, the consultation process is ad hoc.The certifiers deemed all of the issues addressed in the Corrective Action Requests as minor, which means the certification can proceed, based on promises that these minor problems will be resolved by the time the first audit rolls around in a year (or in some cases, two years down the road). Of course, as any observer has witnessed, the problems most likely will not be resolved, may never be resolved, and indeed may worsen with no effect on the certification whatsoever.The certifiers deemed most of the First Nations issues as not significant enough to warrant a Corrective Action Request; instead they addressed them as “Observations,” which are recommended voluntary actions that Tembec can implement or not, with no affect on certification status.Appendix II provides the public summary of the management plan: a two-page table. This slim volume reveals that 67% of the forest is in even-aged management with 47% of that designated clearcut in 1-150 ha blocks, and 35% in uneven-aged management with 48% of that in Group Selection cuts.Though protected areas were mentioned in the context of being wrongly used in the Allowable Annual Cut calculation, the number, size, and location of these areas were not given in the summary. The management plan shows all acreage (and then some – 102%) being subject to cut.ConclusionThese summaries reveal that Tembec engage in clearcutting, high-grading, even-aged management, overlogging, and very large scale destruction of habitat through industrial logging. Sustainable forestry simply does not include these practices – they are the antithesis of sustainable forestry – they severely damage the forest ecosystem.Further, Tembec address no environmental values in their management plan…and they are being certified for environmentally friendly logging.Do you think the FSC’s Public Relations out-purings accurately reflects what is happening in Tembec’s forests, or do you think the consumer would be surprised and shocked at the massive clearcutting, high-grading, and even-aged management that is being touted as earth-friendly, sustainable forestry?In addition to this article, you are encouraged to read two short articles that are supplemental to this critique: “Great Bear hug: Environmentalists are cheering, but they are the losers in an agreement reached over B.C.’s last rain forest area” (Lawrence Solomon, Financial Post, February 10, 2006), and “Forests worth far more alive than dead” (Stephen Leahy, Inter Press Service, September 28, 2006).The “Great Bear hug” article shows how compromised environmental groups can become when they sit down at the table with industrial resource-extractors and big, industry-friendly foundations. Though the Great Bear situation is not FSC related, the same groups from whom the FSC draws its credibility – Greenpeace, Forest Ethics, and Rainforest Action Network – were the duped players in this travesty, which was funded by US foundations to the tune of $60 million. The Stephen Leahy article covers Canada’s 10th National Forest Congress in September 2006. It focuses on a presentation by an environmental ecologist that puts a dollar value just on the ecosystem functions of the Canadian boreal forest – a conservative $250 billion per year, which amounts to about 9% of the Gross Domestic Product (while mining accounts for 4% and energy for 6.5%). The article goes on to show how critical the boreal forest is to the health of the planet, and how the latest satellite photos reveal massive clear-cutting in Ontario’s boreal forest, where Tembec manages five million acres, clearcutting blocks of up to 10,000 hectares (~25,000 acres).Finally, the Canadian environmental group, Yukon Conservation Society (YCS), who were active in the development of the Canada/FSC national boreal standard, will be contributing an article to this web site on the FSC certification of Tembec’s Gordon Cosens Forest in Ontario (April 2003). At two million hectares, Gordon Cosens was one of the largest certifications in the world and the first certification of boreal forest in North America. In the article “A Fine Balance” in the Summer 2003 issue of the YCS newsletter Walk Softly, YCS seriously questioned the certification of an industrial logging company known to clearcut boreal forest in harvest blocks as large as 10,000 hectares, and the awarding of a certification based on promises to conform to a future standard, which would not be finalized until August 2004, well over a year after the fact.


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