Category Archives: Forest Stewardship Council (FSC)

FSC Standard – Economically Viable

I just thought I’d rave a bit more about the ridiculous FSC Standard for Economically Viable.

Clearly the FSC is completely confused and conflicted about whether forestry is welfare or commerce, or is it money laundering?

So far I have found two different definitions of what the FSC means by Economically Viable. The first example comes from FSC UK:

Economically Viable

Economically viable forest management means that forest operations are structured and managed so as to be sufficiently profitable, without generating financial profit at the expense of the forest resource, the ecosystem, or affected communities. The tension between the need to generate adequate financial returns and the principles of responsible forest operations can be reduced through efforts to market the full range of forest products and services for their best value.

https://www.fsc-uk.org/en-uk/about-fsc/what-is-fsc/our-mission-and-vision

The second example comes from FSC Australia:

Economically Viable

The FSC certification standard requires that a forest management entity have sufficient financial resources to manage the defined forest area in conformance with the full scope of the standard.  The standard does not require that the certified forest is managed at a profit provided that other sources of working capital are available and sufficient to enable management in conformance with the standard.

https://www.scsglobalservices.com/news/scs-responds-to-questions-about-the-forestry-tasmania-fsc-forest-management-assessment

Both these examples demonstrate that no one at the FSC has ever studied Economics 101 – basic economic theory and principles.

So let’s discuss the FSC UK definition first:

Of the two definitions it’s the one I like the most; not perfect but at least heading in the right direction. Clearly the UK believes that forestry (growing trees for wood production) is a business, not welfare or money laundering. But the wording could be improved and simplified.

So here is my edit of the UK definition:

Economically viable forest management means that forest operations are structured and managed so as to be profitable. Any subsidies to the forest grower must be available equally to all forest growers within the same jurisdiction.

The rest of the words are pointless. If the forest management is Environmentally Appropriate, Socially Beneficial but it is not profitable then presumably the forest owner would not harvest any trees, ie. No need to seek FSC certification.

If the forest management meets all three Standards, then there is no need to reiterate the environmental and social standards within the economic standard as the UK definition has done. It is superfluous text!

Meet all three Standards = Achieve FSC Certification!

What is “sufficiently” profitable is a decision for the forest owner to make, based on available markets, etc..

If the forest owner is subsidised to manage the forest for wood production (which may be the case in some countries), then the FSC must ensure that all forest owners within that same jurisdiction have equal access to the same subsidies, ie. The FSC has a duty to uphold the principles of competitive neutrality within the forest industry, and not advantage one forest grower over another.

https://blackwoodgrowers.com.au/2016/10/17/competitive-neutrality-in-forestry/

Which leads me nicely to the Australian definition of Economically Viable.

The Australian definition of Economically Viable could be taken to be supportive of money laundering in the forest industry.

Within the Australian definition no profitability is required.

Any amount of money from any source (eg. Criminal activity) can be used to subsidise forest management, achieve economic viability and hence achieve FSC Certification.

In Tasmania that equates to robbing taxpayers to pay sawmillers.

If that definition does not open the gates to corruption and criminal activity I don’t know what would!

I would love to meet the economist that signed off on that definition of “economically viable”! A very “creative” economist indeed!!

Never mind the fact that the FSC supports both of the above contradictory Standards!!

If I was a farmer wanting to diversify my income and plant trees for wood production what would I think of the above Standards?

Would I be supportive of the FSC?

If I was a Tasmanian concerned about the continuing plunder of our public native forests, what would I think of the FSC? Would I have any confidence in Third Party Forest Certification?

I think the FSC has a long way to go to achieve any credibility.

An invitation to join the Forest Stewardship Council (FSC)

HI Gordon,

I’ve been reading your newsletter. Have you thought about joining your group up to FSC?

I’m in the environment chamber and on the board. Happy to talk about it if you are interested.

Cheers

I recently received this invitation to join the Australian branch of the FSC.

I’m making my reply to this invitation public because I believe the public and the marketplace need to better understand what is happening within the forest industry.

Hi XXXX

Thanks for the invitation for the Tasmanian Blackwood Growers Cooperative to join the FSC.

Twenty years ago I had hopes that the advent of the FSC would see major reform within the Australian forest industry.

Today I have no such illusions!

The fact that Bunnings/Officeworks will help shut down public native welfare forestry next year is indirectly due to the FSC, but otherwise the industry and the wood marketplace are utterly moribund.

Harsh words I know, but after a 40 year career that is the only conclusion I can come too.

The FSCs standards for “economically viable” are a joke. No they are worse than a joke! They are completely offensive and destructive to the future of the industry:.  

https://blackwoodgrowers.com.au/2019/05/13/fsc-supports-illegal-forestry-in-australia/

https://blackwoodgrowers.com.au/2016/10/17/competitive-neutrality-in-forestry/

Because of this “Standard”, private forest growers have no hope. Because of this “Standard” my Group has no future. How can it when annual taxpayer subsidies to public native welfare forestry are fully supported by the FSC and PEFC? Private growers don’t get FSC/PEFC approved annual taxpayer subsidies!!

Growing trees for wood production is a commercial activity. It is not welfare!

Should I join the FSC to help drive change within the FSC?

If Greenpeace resigned because it could not achieve meaningful change within the FSC what chance would I have of doing so?

https://blackwoodgrowers.com.au/2018/03/30/greenpeace-leaves-the-forest-stewardship-council-fsc/

Greenpeace is right! Third party certification without transparency is a waste of time. It becomes a form-filling, label-sticking exercise of little value.

So why would I join an organisation like the FSC that deliberately seeks to undermine private forest growers?

Taxpayer subsidised welfare forestry and profit-driven commercial forestry cannot coexist in the same marketplace.

It’s that simple!

The FSC supports welfare forestry and therefore undermines commercial forestry.

It’s that simple!

If the FSC wants to support and encourage farm forestry in Australia then it needs to change its assessment standards.

It’s that simple!

Yours sincerely,

Gordon Bradbury

Sustainable Timbers Tasmania fails FSC audit again!

logging2

After being audited in May 2019, and the audit report being finalised in February this year, Sustainable Timbers Tasmania (STT) this week were finally courageous enough to publically announce that it had once again failed FSC certification.

https://www.sttas.com.au/

https://www.abc.net.au/radio/northtas/programs/drive/sustainable-timber-tasmania-fsc-certification/12567014

No one seems at all surprised!

It has been more than 10 years since STT promised to gain FSC certification.

That’s 10 years of failure!

With Bunnings Hardware promising to only sell FSC certified products after 31st December 2020, the future for STT is not looking good. Bunnings is the largest retailer of Tasmanian oak products from Tasmania’s public native forests.

On 1st July this year Bunnings announced they would no longer sell public native forest products from Vicforests.

https://blackwoodgrowers.com.au/2020/07/01/bunnings-stops-selling-timber-logged-by-vicforests-after-court-ruling/

The long, slow, bitter, costly road to oblivion for public native welfare forestry in Australia is entering its final phase.

Meanwhile instead of questioning its own failings, or plotting a new course for the future, the forest industry is now waging an all out publicity war on anyone it regards as an enemy, including the FSC and Bunnings.

The culture within the forest industry has become neurotic and hostile.

How the forest industry responds and behaves in this final closing down of public native forestry in Australia will impact the greater industry for decades to come.

If the industry continues its current hostile virulent campaign then the brand/industry damage will be severe indeed.

The private forestry sector in Australia is already starved of oxygen in attempting to generate a positive image and message to the marketplace and the community.

A few more years of negative hostile publicity will alienate more of the marketplace and the community, and further isolate the forest industry.

The Australian forest industry desperately needs to improve its support within the broader community. Right now the opposite is happening.

Will the private forestry sector remain silent as its future is destroyed in this battle?

  1. By the way this article had no impact whatsoever on the FSC audit:

https://www.theguardian.com/environment/2018/mar/29/tasmanian-forest-agreement-delivers-13bn-losses-in-giant-on-taxpayers

Apparently the FSC is perfectly happy supporting fraudulent behaviour in the forest industry.

FSC supports illegal forestry in Australia

The following constitutes my submission to SCS Global Services as part of its assessment of Sustainable Timber Tasmania for FSC Certification.

https://blackwoodgrowers.com.au/2019/04/10/public-notification/

FSC2

https://au.fsc.org/en-au

https://www.sttas.com.au/

http://www.scsglobalservices.com/

The idea that public native forestry in Tasmania is “environmentally appropriate, socially beneficial and economically viable” (FSC’s very own criteria!) is complete and utter fantasy.

Just the history of the industry over the last 5 years demonstrates the hypocrisy of this idea, never mind the forestry wars of the last 40+ years!!

The above image is taken from the Forest Stewardship Council (FSC) website. Unfortunately none of these three titles on the FSC website are live/linked. You can’t click to find out what the FSC means by “Environmentally Appropriate” or “Economically Viable”. So I typed “Economically Viable” into their search box and I got this result:

EcoVia

FSC “could not find any results”!!

I think the FSC has got some issues to resolve.

Luckily I have a clue as to what the FSC means by “economically viable” from the last time Forestry Tasmania attempted to gain FSC certification. The following quote comes from SCS Global Services website:

Can a company that operates at a loss achieve certification?

The FSC certification standard requires that a forest management entity have sufficient financial resources [taxpayer subsidies] to manage the defined forest area in conformance with the full scope of the standard.  The standard does not require that the certified forest is managed at a profit provided that other sources of working capital [taxpayer subsidies] are available and sufficient [$ billions] to enable management in conformance with the standard.

https://www.scsglobalservices.com/news/scs-responds-to-questions-about-the-forestry-tasmania-fsc-forest-management-assessment

So the FSC defines “economically viable” as pretty much anything, including major loss-making public native forestry.

The problem is, under Australian law that is ILLEGAL!!!!!!!

It’s called Competitive Neutrality, and I wrote a blog about it back in 2016:

https://blackwoodgrowers.com.au/2016/10/17/competitive-neutrality-in-forestry/

It is Tasmania’s view that all the State’s PTEs and PFEs, together with its GBEs, are significant Government businesses for the purposes of the CPA. Accordingly, in applying the competitive neutrality principles, significant Government business enterprises are defined as those enterprises which are classified as PTEs, PFEs and/or GBEs.

https://www.economicregulator.tas.gov.au/Documents/Competitive%20Neutrality%20Principles%20Guidelines%20June%201996.pdf

This includes FT/STT.

In 1995 Australia’s governments agreed to the National Competition Policy (NCP) and Related Reforms.

http://ncp.ncc.gov.au/pages/home

The problem is many of those reforms have never been implemented, or have since been watered down.

FT/STT is a classic example!

It was corporatized according to NCP policy, but it has never been run as a commercial business. And yet it competes in the marketplace against private tree growers.

FT/STT has never publically acknowledged that it is a Government business competing in the marketplace against private forest growers both here in Tasmania and on the mainland

FT/STT has never publically acknowledged the need for it to behave in a competitively neutral manner.

FT/STT has never had any Competitive Neutrality Policies and objectives…..ever!

And every week that FT/STT gets another taxpayer handout is another breach of Australia’s Trade Practices Laws.

The fact that FT/STT has never been prosecuted illustrates the broken nature of Australia’s political system, and a conflicted forest industry.

The NCP does not discuss what should be done with Government businesses that cannot survive in a commercial world, businesses like FT/STT.

The FSC does not say where these “other sources” of money may come from or place any limits on the extent of subsidisation.

I wonder what economists think of this idea?

I wonder what private forest owners who compete in the marketplace against loss-making, forest squandering Sustainable Timber Tasmania think of this idea?

So Sustainable Timber Tasmania passes the FSC “economically viable” criteria with flying colors! What a joke!!

Never mind the long suffering Tasmanian taxpayer, or the lowly paid Tasmanian public servant!

The last 20 years

Last year this article appeared in a major Australian news media site detailing the extent of commercial losses from public native forestry in Tasmania:

JL

https://www.theguardian.com/environment/2018/mar/29/tasmanian-forest-agreement-delivers-13bn-losses-in-giant-on-taxpayers

And that analysis was using FT’s own accounting methods!

If FT had to do its accounting like a private forest grower (ie. Competitive neutrality) the losses would be far greater. What private forest grower can value its entire land estate at $0.00??

No doubt the FSC would see this article as glowing praise for world class forest management!!

Greenpeace

The environmental organisation Greenpeace was one of the founding partners of the FSC. In March last year Greenpeace resigned from the FSC citing ongoing and significant issues with the way the FSC was being managed:

https://blackwoodgrowers.com.au/2018/03/30/greenpeace-leaves-the-forest-stewardship-council-fsc/

With Greenpeace gone it now seems that the FSC is moving towards becoming another forest industry rubber stamping organisation like the PEFC.

Buying FSC certified wood products does not save the world’s forests.

New Zealand

Imagine if this response on economic viability was given within a New Zealand context, where the forest industry is fully commercial and profitable?

“Yeah we just waste taxpayers money to grow trees and give them away! Who cares about farmers?”

New Zealand farmers would be marching on their Parliament House to bring down the Government!

Here in Tasmania? Not a whisper of protest!

Bunnings

Bunnings, Australia’s largest timber retailer, is threatening to stop selling public native forest products next year (2020) unless the products achieve FSC certification.

https://blackwoodgrowers.com.au/2018/08/04/bunnings-finally-takes-a-stand/

The marketplace is finally saying “enough is enough”!

For both Vicforests and STT this is crunch time!

Wind up

Four years ago former State politician Sue Smith called for the winding up of FT/STT. How she described the forest industry then is still the same today, but worse.

https://www.themercury.com.au/news/politics/former-mlc-sue-smith-urges-forestry-tasmania-windup/news-story/50272c2ae1798a9358999278b5563073?fbclid=IwAR2YxZMeGSksYF7eI5NxmEmnPxYe2BQ3a8vUdCmr38t1hclWC7tS3JqC-xc

How in anyone’s imagination can this agency achieve FSC certification?

Blackwood

Who is going to grow commercial blackwood when the Tasmania State government and STT waste taxpayers money giving away public native forest blackwood, supported by taxpayer subsidies and the Forest Stewardship Council?

Nothing has changed

Sustainable Timbers Tasmania does not have a business plan, nor does it have commercial objectives.

Neither does it apologise every year for its continuing waste of Tasmanian taxpayers money.

“This is the number of teachers and nurses you missed out on this year thanks to our activities. But don’t worry! We are sustainable!!”

Nothing has changed.

But from my perspective it is the failed economics of public native forestry that is the primary reason that Tasmania will never have a Tasmanian Blackwood Growers Cooperative.

If the FSC “Economic Viability” criteria are so easy to achieve, one must assume the other two criteria – “Environmentally Appropriate” and “Socially Beneficial” – are just a walk in the park!

As a forester I believe this is about the worst possible outcome for the forest industry. It is certainly the worst possible outcome for the Tasmanian community.

  1. And finally, who gets to pay for STT’s FSC assessment? That’s right! The long suffering Tasmanian taxpayer. Show me a private forest grower who has their FSC assessment paid for by the taxpayer. Answer! NONE!!

PPS. STT is just the forest manager. The State Government owns the forests! The same State Government that wants to log the Tasmanian Wilderness World Heritage Area. The same State Government that IS logging ancient rainforests in Conservation Reserves. For the FSC to certify STT would be an even bigger act of hypocrisy than that of the Tasmanian State Government. The Tasmanian Government determines Forest Policy NOT Sustainable Timbers Tasmania!!

When will Tasmania get a real forest industry based on profitable private tree growers?

Greenpeace leaves the Forest Stewardship Council (FSC)

rainforest3

It’s a grim day for the world’s forests.

On Monday 26th March Greenpeace International announced it was leaving the FSC.

Greenpeace said that the FSC has become a “tool for forestry and timber extraction” and it wouldn’t renew its membership.

Greenpeace International to not renew FSC membership

Here’s how the Washington Post reported the story:

https://www.washingtonpost.com/world/asia_pacific/greenpeace-leaves-sustainable-wood-certification-group/2018/03/27/aa6c0a4e-3184-11e8-b6bd-0084a1666987_story.html?utm_term=.1993de3f7510

The FSC’s response to the Greenpeace announcement clearly shows no interest in rebuilding the relationship. Is this an indication that vested interests have indeed successfully taken control of the FSC?

FSC Statement about Greenpeace International

Is this the end of third party forest certification?

FSC Certification Evaluation of Forestry Tasmania

seeking_your_input_blog_banner_2014

SCS Global Services,

2000 Powell Street, Ste. 600

Emeryville,

CA 94608 USA

 

Dear Dr. Hrubes,

RE: FSC Certification Evaluation of Forestry Tasmania

Thankyou for the opportunity to participate in the stakeholder consultation process.

As a forester and forest industry representative my submission to the Forestry Tasmania FSC Certification Evaluation focuses on just two issues.

1. Commercial Management

 

The forest industry in Tasmania is currently home to two mutually incompatible business models competing in the same marketplace.

The historical, traditional and still dominant business model is the taxpayer-subsidised, community service business model that frames current Tasmanian forest policy, and public forest management by Forestry Tasmania.

The fundamental basis of this model is that public forests managed for wood production are there to serve the community largely through providing regional employment. Good business, commercial management and profit play no part in this business model.

The second business model has always been present in Tasmania but has recently become more significant with the expansion of private plantations and the sale of public plantations to the private sector. This business model is used by private plantation and forest owners; it is the fully commercial, market-focused, profit-driven business model.

It is the same business model that will help drive my goal of establishing a Tasmanian Blackwood Growers Cooperative.

These two business models cannot succeed in the same marketplace. This situation is unstable and ultimately destructive to the entire forest industry. It is also a missed opportunity to realise and develop Tasmania’s significant commercial forest potential.

The traditional business model represents nothing more than a destructive antitrust, anti-competitive business model. It undermines the ability of the marketplace to function properly and put a proper price on forest products. It destroys the value of private forest assets and investment.

At the moment logs from public native forest are being transported to market at taxpayers’ expense, whilst private tree growers do not have access to any taxpayer subsidy. This is blatant antitrust behaviour.

Also please read this brief analysis of the deliberate decline in commercial focus at Forestry Tasmania over the past 20 years. Forestry Tasmania is a storm-tossed, rudderless ship:

http://tasmaniantimes.com/index.php?/article/forestry-tas-devoid-of-commercial-purpose/

The Forest Stewardship Council (FSC) must not give its support to this antitrust behaviour. Forestry Tasmania must not be given FSC Certification until it is restructured and managed on a fully commercial profitable basis.

 

2. Public blackwood forest resource mismanagement

 

For the last 25 years Forestry Tasmania have been overcutting the public native blackwood resource that currently forms the basis for Tasmania’s iconic blackwood industry. Using Forestry Tasmania’s own data I have summarised this sad sorry episode.

Incomplete history 2

https://blackwoodgrowers.com.au/2014/08/14/the-incomplete-history-and-current-practice-of-unsustainable-blackwood-mismanagement/

https://blackwoodgrowers.com.au/2014/06/23/the-incomplete-history-of-unsustainable-blackwood-mismanagement/

Forestry Tasmania perpetuates the message that the public blackwood forest resource is being responsibly and sustainably managed, when their own data (as shown in the above chart) clearly shows this is not the case!

The recently released Review of the Sustainable Sawlog Supply from the Blackwood Management Zone is a grossly misleading and inadequate document.

http://www.forestrytas.com.au/sfm/review-of-the-sustainable-sawlog-supply-from-the-blackwood-management-zone

The fact that in 2010 Forestry Tasmania announced that henceforth blackwood and all other special timber species were to be managed on a “non-commercial non-profit” basis was a severe blow to the Tasmanian farmers and the blackwood industry.

Blackwood (Acacia melanoxylon) is Australia’s premier appearance-grade timber species. It is a common tree on farmland across northern Tasmania, most of which is unmanaged and until recently had little commercial value. But this is now changing.

The only way to build and grow Tasmania’s blackwood industry is by encouraging Tasmanian farmers to grow it, just as New Zealand farmers have been for the past 30 years. But Tasmania’s blackwood industry will be gone in 5-10 years due to the mismanagement and overcutting of the public resource by Forestry Tasmania. The local blackwood markets and industries will be gone before Tasmanian farmers have a chance to contribute. Tasmanian farmers will have to start the whole industry from scratch with no market price or demand signals.

The Forest Stewardship Council (FSC) must not give its support to this blatant mismanagement of Tasmania’s public forest resource. Forestry Tasmania must not be given FSC Certification until it provides a full and correct report on the nature of the blackwood resource, and manages that resource on a fully commercial, profitable and sustainable basis.

From my perspective as a forest industry representative and stakeholder there is very little positive that can be said about the current state of forest industry policy and practice in Tasmania. The industry is continuing to go backwards year after year. This comes as no surprise to me at all.

Major review and reform is desperately needed.

The Forest Stewardship Council (FSC) should not add its support to this mess by granting FSC Certification to Forestry Tasmania; not until major reforms are implemented.

 

Yours Sincerely,

 

 

Dr. Gordon Bradbury

14th October 2014