Internationella FSC i Bonn gav i höstas, via Svenska FSC kansliet, uppsalabaserade företaget Greensway i uppdrag att ta fram en ny metod för den riskbedömning en FSC-certifierad virkesköpare måste förhålla sig till då denne köper virkesråvara från en icke certifierad skogsägare. Tidigare har dessa virkesköpare använt FSC:s kreditsystem/spårbarhetssystem för virkesköp hos ickecertifierade skogsägare och detta innebär att all råvara som blandas in är minst i nivå med FSC:s Controlled Wood.
FSC-kontrollerat virke gör det således möjligt att blanda FSC-certifierat material med icke certifierat material. En produkt med FSC Mix-märkning innebär att företaget som tillverkat produkten är certifierad enligt FSC:s spårbarhetsstandarder och råvaran de köpt in kommer inte bara från FSC-certifierat skogsbruk, utan också från skogsbruk som inte är FSC-certifierat.
Det är just förutsättningarna för detta system som skall ändras genom en ny CNRA. Förbundets syn på de förslag som presenterats är mycket kritiskt då det inte tar hänsyn till det lågintensiva överhållningsskogsbruk som många av våra medlemmar ägnat sig i omkring 150 år, utan stipulerar istället 26 icke försumbara risker (non-negligible risks) med tillhörande kontrollåtgärder som måste beaktas och hanteras vid virkesaffärer. Resultatet blir ett byråkratiskt kontrollsystem som indirekt tvingar icke certifierade skogsägare att anamma FSC-regler utan att de facto vara certifierade.
Våra synpunkter redovisas nedan och är skrivna på engelska då de redovisas inför FSC International.
Statements concerning the document FSC-RA-SE_V2-0_FSC_Risk_Assessment_for_Sweden_D1-0_for-consultation_4449
Sveriges Allmänningsskogars Förbund is an association constituted of 21 different commonly owned forests in the counties of Dalarna, Gävleborg and Norrbotten. The twenty-one members own a total of more than 670 000 hectares of land where we primarily conduct low-intensity forestry, combined with hunting, fishing, tourism and electricity production (hydropower, windmills, and solar power). The forestry practice differs significantly from the average Swedish forestry practice and is considered the primary business and conducted at a low-intensity level through retention of forests that are logged at an average stand age of 130 years (the national average in Sweden is about 100 years). This practice leads to higher abundance of rare species and older forests stands than neighboring forests and therefore these areas may constitute a refuge for species dependent upon older forests and their structures on a landscape level. These forests are owned by a total of about 35 000 joint-owners (reindeer herders as well as non-reindeer herders) that are dependent upon their financial yield to support their own agricultural and forestry enterprises in the local areas adjacent to each forest. Most of these owners live in the sparsely populated countryside and their livelihoods are often associated with or dependent upon agriculture and forestry. The logged timber from these forests consists primarily of premium sawtimber suitable for renovations of historic buildings and other areas of use where construction quality is of high importance and the standard retail lumber is not sufficient due to the modern forestry practices of fast-growing trees with wider annual rings, etc.
This practice of low-intensity forestry and retention, managed like modern “ecological landscapes,” is more than 150 years old. We are concerned that demands, configured for modern high intensity forestry, from FSC-certificate holders, will force our members into a more intense and modern forestry practice where we no longer can manage the forests with our preferred low-intensity forestry practices. The reason for our concerns is obvious: If we are forced into a situation where our conditions are not acknowledged and we then are forced to comply with a set of regulations derived from the FSC-certification, our old forest practices are unwillingly exchanged for more modern practices, along with short rotations of our forest stands. Consequently, our species refuges and old “ecological landscapes” will change into the type of forests that our FSC-certified neighbors manage, with less species-richness and less older stands. Also, the function of CO2-binding that our 670 000 hectares of forests constitute is no laughing matter.
This consequence benefits no one.
Therefore, we suggest that low-intensity forestry based on retention and longer rotation cycles of forest stands (like the commonly owned forests of Dalarna, Gävleborg and Norrbotten counties) is subjected to exceptions in the risk assessment so trade is possible with the FSC-certified enterprises that source wood. Wood sourced from forest stands that are allowed to grow for several decades longer than FSC-certified neighbors do not constitute the risk that this work set off to identify and mitigate. This is crucial to allow us to continue playing a significant role in sustaining the agricultural producers and the local residents in the sparsely populated areas where our member forests are situated.
General statements
Sweden has an intricate system of laws and regulations that controls the forestry sector. Breaking these laws is a punishable offence that leads to legal penalties. For instance, the Swedish Environmental Code (Miljöbalken) and the Forestry Act (Skogsvårdslagen) are two sets of law that continuously regulates most of the non-negligible risks that are evaluated in the risk assessment. With a functional legal system already in place, a 26-point intricate non-negligible risk assessment system for Controlled Wood is made redundant, especially when other countries are operating the same FSC-risk assessment system with only 1(!) non-negligible risk identified (i.e. Germany). As a result, this considerable inequality between countries within the EU will create further discrepancies within the forestry sector and distort the market.
We strongly oppose the brief time given for consultation and we ask for another consultation since this risk assessment venture has been hastily put together and risk causing many problems for Swedish forestry and industry in general. For instance, the intricate system used for wood exchange among FSC-certified industries and loggers where transport of the timber is conducted along our railroads will likely be heavily affected by the suggestions at hand.
Maps that used to identify the reindeer herding villages included reindeer herding in areas outside Lappmarken. Through legal decisions around the 1930’s reindeer herding was allowed in some areas outside Lappmarken and these reindeers can be owned by anyone in the area, opposed to the areas in Lappmarken, where only the Sámi are allowed to own reindeers. The concession to own and herd reindeers in these areas is requested by an applicant and only stretches for a maximum period of 10 years (however, most permissions are given for periods of 5 years). According to the Swedish Reindeer Husbandry Act (Rennäringslagen 85§) this concession is only granted if “continuous reindeer husbandry is of considerable benefit for the locality”, which in turn is decided by the County Administrative Board (Länsstyrelsen). Within this area of concession, any landowner, or person that farms the land may own the reindeer that are herded by the concession permit holder for a financial compensation.
We therefore advise you to omit areas outside Lappmarken from your analysis.
Finally, we wish to express our confusion when FSC appoints a third-party consultant enterprise to manage such sensitive and precarious work. This update of the risk assessment in Sweden should have been agreed upon by FSC Sweden and their stakeholders since the implications for FSC-certified buyers of wood products, as well as for the non-certified landowners might be arbitrary and create severe consequences for the certified or non-certified performers. The third-party consultant has also been forced to work under extreme pressure during the consultation, which further disqualifies the risk assessment assignment. The summoned expert group does not involve a single person from the forestry sector(!). As a comparison half of the 12 experts come from the reindeer herding sector. This biased composition of experts and hurried carelessness is unacceptable and bound to lead to a one-sided result.
Statements on the suggested mitigation measures in document “FSC-RA-SE_V2-0_FSC_Risk_Assessment_for_Sweden_D1-0_for-consultation_4449”
Risk indicator 13: Please change the sentence “This is achieved by consultation of relevant databases of registered cultural monuments, and with landowners to identify any unregistered cultural monuments, within the area.” to “This is achieved by consultation of relevant databases of registered cultural monuments”. Consulting the landowner is reasonable, but holding the landowner accountable in knowing “all existing cultural monuments in the area” is not 100 % without fail. Therefore, we also ask you to change “All existing cultural monuments” to “all known cultural monuments” since unknown may exist, but are – unknown…
The level of satisfactory planning should also be defined to clarify the level needed to mitigate risks.
More on this topic: See our response to risk indicator 63.
Risk indicator 43: A level of ground lichen richness needs to be defined since ground lichens tend to be present within most of the forest lands in question. We suggest using the definition “lavtyp” used by the Swedish National Forest Board which means that more than 50 % of the forest floor is covered by ground lichens. If this definition is not used and consultations fail to meet an agreement for whatever reason, the result will lead to great difficulties in reforestation measures due to the absence of soil scarification.
Risk indicators 55 and 56: These indicators are written in a manner that might make them incompatible with the Nature Restoration Law passed by the European Commission since mentioned law dictates that Sweden needs to restore grasslands and similar biotopes. As a result, forested lands must be converted to grasslands. Also, the Regulation on Deforestation-free Products (also passed by the EU Commission and one reason for this consultation on FSC risk assessment for Sweden) bans the trade of wood harvested from forests transformed to grasslands. As a result, we might soon have two incompatible laws on collision courses applying to land conversion. Therefore, be mindful of how you stipulate these mitigation measures.
Risk indicator 57: This indicator threatens the whole concept of our members’ low-intensity forestry practice based on retention of forest stands that are logged at an average age of 130 years. This indicator needs to clarify that low-intensity forestry practice is approved of by the FSC Controlled Wood, otherwise we unwillingly must change forestry practice to more of a short-rotation practice, which benefits no one. Also, the stand age itself is not a guarantee of high conservation values in terms of rarer species and important structures even if these factors often correlate. Most of our forests are dominated by Scots pine (Pinus sylvestris) on relatively nutrient poor lichen-rich soil, thus gap harvesting and natural regeneration are not suitable methods.
Risk indicator 62: We strongly question the need to consult on a yearly basis. If an agreement is reached, there is no need for cycles of consultations. Furthermore, we suggest using the definition “lavtyp” used by the Swedish National Forest Board which means that more than 50 % of the forest floor is covered by ground lichens.
Risk indicator 63: This indicator is already covered by risk indicator 13. We strongly suggest that FSC does not group humans and their history according to their ethnic or cultural origin for obvious reasons.