Memorandum from FERN
How useful has the work of the CPET proved? How
should its role develop to ensure future progress on the issue
of sustainable timber procurement?
USEFULNESS OF
CPET WORK
The CPET (Central Point of Expertise) process
has been instrumental in developing criteria for the endorsement
of forest certification schemes that are acceptable to all stakeholders,
including the timber industry and environmental NGOs. The process
to develop these criteria has been transparent and inclusive,
which should be commended.
PROBLEMS WITH
THE WORK
OF CPET
However, the second step of the process has
been questionable, to say the least. This stepthe scoring
of certification schemes on the basis of CPET criteriahas
been criticised by FERN and other environmental NGOs as being
unscientific, not sufficiently inclusive, and open to challenge.
In this submission, we focus on how CPET should improve significantly
its assessment and scoring of existing certification schemes,
as we believe that this is the key element to ensure progress
on sustainable timber procurement.
FERN, jointly with Greenpeace, FoE and WWF,
has assessed the SFI (Sustainable Forestry Initiative) and the
PEFC (Programme for the Endorsement of Forest Certification),
using the CPET criteria. This consortium disagreed with DEFRA
(or rather ProForestthe consultancy appointed by DEFRA)
on the scoring of more than half of the criteria. In our assessment,
neither scheme would have been endorsed. Therefore, it is our
conclusion that the current CPET scoring system cannot be supported
and needs to change.
Furthermore, there is growing well-documented
evidence that forest certification schemes do not always implement
their own policies. We are particularly concerned with the CSA
(Canadian Standards Association) scheme, as most of the CSA's
certificates have now been formally challenged by the Sierra Legal
Defence Fund, on behalf of environmental NGOs (Sierra Club) and
indigenous peoples' organisations (National Aboriginal Forestry
Organisation). The appeal states that in 11 of the 12 companies
investigated, there were no reasonable grounds to conclude that
the CSA's requirements had been met. [2]
The CPET assessment, being a desk assessment
only, will not always be able to identify non-compliance. This
leaves it vulnerable to endorsing schemes that do not deliver
sustainable forest management on the ground. One solution to this
problem would be field audits, although this would be a costly
solution. Another option would be to re-examine the CPET criteria
if, after further scrutiny, it is revealed that timber from badly
managed forests was being accepted.
It is imperative that CPET ensures that all
endorsed certification schemes continue to deliver timber sourced
from well-managed forests. Failure to do so would undermine the
stated aims of CPET and with them, the UK Procurement Policy.
WAYS FORWARD
To address these concerns, we would suggest
the following changes to the CPET process:
CPET, on behalf of DEFRA, would need
to carry out an urgent revision of the existing accepted forest
certification schemes, taking into account the full FERN, Greenpeace,
FoE and WWF analysis.
A new procedure would need to be
developed for the revision of accepted schemes. We propose a procedure
that would allow for annual revisions, and would take into account
comments received by interested parties, such as NGOs and the
timber industry.
CPET would have to undertake a fully
inclusive process of reviewing its criteria and developing guidelines
on how to implement these criteria, to prevent certification schemes
that permit bad forest management practices slipping through the
net and being accepted under the CPET assessment procedure.
CPET would have to consult all stakeholders
on the guidelines to be prepared for the scoring of schemes based
on the above.
How reliable are the certification schemes for
timber endorsed by CPET? Are there concerns regarding either the
sustainability or legality of any of them?
There are serious concerns with regard to the
sustainability of three of the four approved schemes and with
regard to the legality of all endorsed schemes.
With regard to sustainability: As stated above,
FERN, together with WWF, FoE and Greenpeace, has carried out an
assessment of two of the four endorsed schemes, namely the PEFC
and the SFI. We dispute 13 of the 26 criteria for the PEFC, and
18 of the 26 criteria for the SFI. In our opinion, the SFI and
PEFC schemes clearly do not meet the threshold for endorsement,
as developed by CPET, and therefore should not have been endorsed.
In FERN's analysis[3]
neither the CSA, the PEFC, the MTCC (Malaysian Timber Certification
Council) or the SFI meet the minimum requirements for a credible
certification process described by governments, NGOs and the timber
industry. All these actors have described what minimum requirements
for credible certification schemes should be [see box 1]. These
include: minimum performance-based standards, transparency, and
independence of vested interests. A close look at all four schemes
shows that, with the exception of the FSC, not one meets all of
these minimum standards. The MTCC, CSA, SFI and PEFC all lack
clear minimum thresholds before issuing a label; and the PEFC
and SFI schemes lack transparency because crucial documents, such
as certification reports and documents relating to certification
procedures, are not made available to the public. Also, the PEFC,
CSA, SFI and MTCC are not independent of vested interests as in
all cases "economic" interests (the timber industry
or forest owners) have a larger say over the development of standards
than social or environmental interest groups.
BOX 1
AGREED MINIMUM CRITERIA FOR FOREST CERTIFICATION SCHEMES
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Governments, industry and NGOs appear to agree to some extent
on the key components of a credible certification scheme, including:
the assessment of performance on the ground (not just on paper);
transparency; and independence of vested interests.
1. Performance on the ground
The first intergovernmental agreement on forest certification
was reached within the Intergovernmental Panel on Forests (IPF)
under the auspices of the United Nations Commission on Sustainable
Development. In 1997, the IPF adopted a number of Proposals for
Action relating to certification. The panel emphasised "that
the development of criteria and indicators [through governmental
processes such as the Helsinki and Montreal processes] is primarily
intended for promoting and monitoring sustainable forest management,
and not for imposing certification schemes for forest products.
[These] criteria and indicators are not performance standards
for certifying management at any level." [4]
The message that certification schemes need to be based on
performance requirements has since been repeated in different
forums, such as the FAO (UN Food and Agricultural Organisation)
and the European Union: "it is important to recognise the
differences between indicators for sustainable forest management
and certification standards. While indicators are used to show
the state of the art and to monitor changes with regard to relevant
aspects of sustainable forest management (as defined by criteria),
certification standards lay down a certain quality level or performance
standards that has to be achieved." [5]
2. Transparency, participation and independence
The IPF Proposals for Action, agreed by all governments,
state: "Governments have a role in encouraging transparency,
the full participation of interested parties, non-discrimination
and open access to voluntary certification schemes." [6]Proposal
For Action 133, relating to certification and labelling, reads:
"[the panel] urged countries to support the application to
certification schemes of such concepts as: open access and non-discrimination
in respect of all types of forests, forest owners, mangers and
operators; credibility; [7]non-deceptiveness;
cost-effectiveness; participation that seeks to involve all interested
parties including local communities; sustainable forest management
and transparency."
The Forestry Industry (in the International Forestry Industry
Roundtable (IFIR)) supports this approach in its report, Proposing
an international mutual recognition framework. [8]It
lists the following criteria for credible certification schemes:
conformity with sustainable forest management standards and legislation;
"the influence of all stakeholders shall be balanced and
consensus outcomes shall be sought"; scientifically supported;
continual improvement; non-discriminatory "accommodating
all forest types, sizes and ownership structures"; repeatability,
reliability and consistency; independence and competence; transparency;
SFM claims; chain of custody.
Finally, the World Bank, when adopting its new Forest Policy in
November 2002, states that: [9]
"To be acceptable to the Bank, a forest certification
system must require:
(a) compliance with relevant laws;
(b) recognition of and respect for any legally documented
or customary land tenure and use rights as well as the rights
of indigenous peoples and workers;
(c) measures to maintain or enhance sound and effective
community relations;
(d) conservation of biological diversity and ecological
functions;
(e) measures to maintain or enhance environmentally sound
multiple benefits accruing from the forest;
(f) prevention or minimisation of the adverse environmental
impacts from forest use;
(g) effective forest management planning;
(h) active monitoring and assessment of relevant forest
management areas;
(i) the maintenance of critical forest areas and other
critical natural habitats affected by the operation.
In addition to the requirements above, a forest certification
system must be independent, cost-effective, and based on objective
and measurable performance standards that are defined at the national
level and are compatible with internationally accepted principles
and criteria of sustainable forest management. The system must
require independent, third-party assessment of forest management
performance. In addition, the system's standards must be developed
with the meaningful participation of local people and communities;
indigenous peoples; non-governmental organisations representing
consumer, producer, and conservation interests; and other members
of civil society, including the private sector. The decision-making
procedures of the certification system must be fair, transparent,
independent, and designed to avoid conflicts of interest."
CONCLUSION
In short, the World Bank, governments and the forestry industry
all seem to agree on most of the conditions for credible certification
schemes such as balanced participation, transparency, consistency
and replicability, and measurable, minimum performance-based standards.
Nonetheless, most of the certification schemes researched here
do not meet these demands. No scheme, with the exception of the
FSC, requires balanced participation of all stakeholders and no
scheme, with the exception of the FSC, is based on clear and meaningful
minimum performance standards. The SFI and CSA allow individual
forestry companies to customise the standards against which they
will be measured and certified. This means that the standards
of these programmes vary on a case-by-case basis. Transparency
is a serious problem in most schemes. Finally, the World Bank
clearly states that certification schemes must be designed to
avoid conflict of interests; this demand is violated by the CSA,
PEFC, and SFI, as the decision-making structure is clearly dominated
by the forestry sector.
Furthermore, the SFI, CSA, PEFC and MTCC all allow for forest
management practices, widely seen by the environmental and social
NGO community as being non-conducive to sustainable forest management.
These include large-scale clear-cuts, the use of genetically modified
trees, and the conversion of (old growth) forests to tree plantations
or other land uses. The PEFC scheme is known to have certified
the logging of the last few stands of old growth forests in Scandinavia
and violated customary rights of Sami people in Lapland; the SFI
has certified forestry practices which are seen as the most destructive
in the US, and the MTCC has certified logging operations in forests
without the authorisation of indigenous groups living in these
areas.
Attached (Annex 1) is a short analysis of why FERN believes
that these schemes do not yet meet minimum requirements for a
credible consumer label. By endorsing these schemes as providing
"sustainably produced" timber, the CPET process has
seriously undermined progress towards true sustainable forest
management.
With regard to legality: Verifying legality is often seen
as a first step towards certifying sustainability, including in
the approach chosen by the UK Government. However, several studies
have pointed out problems with this approach. A recent final draft
of a report by SGS Global Trade Solutions, written for the World
Bank/WWF Alliance, states:
"Certification schemes such as FSC, PEFC or ISO 14000
. . . may not be the most appropriate and comprehensive solutions
to the illegal logging problem . . . These "quality assurance"
systems have not been designed as tools to enforce the law and
to be made compulsory. They are not based on regular and unannounced
audits and on continuous sampling and they rely on paper-based
chain-of-custody systems that are possible to forge. Given this,
certification schemes do not provide the level of confidence that
is likely to be required to demonstrate legal origin." [10]
The same report points out that improving the "current
rules and regulations" may not be adequate to detect illegal
logging and to prevent fraud. Concerning certification in Africa,
the report states:
"By design, certification cannot be used as a detection
tool: although `respect of all national and local laws and administrative
requirements . . . and of all the provisions of binding international
agreements . . .' is part of FSC principles 1.1 to 1.5, certification
audits do not involve probing, in-depth investigation for fraud.
Legality is not the primary concern: assessors are not policemen.
Certification is a quality assurance approach and demands trust
and goodwill. Initial assessments and surveillance visits are
limited in time, frequency and area. Current chain-of-custody
requirements and audit systems are therefore vulnerable to abuse."
[11]
Another World Bank report, [12]clearly
states the need for physical segregation of certified products
from non-certified products throughout the chain from forest to
retailer, as well as the need for independent monitoring of the
chain of custody to detect illegal practices. If a label endorsing
a forest product as being from well-managed forest is to be used
as independent validation that the wood is legally sourced, three
conditions have to be fulfilled:
(i) the forest certification standard needs a clear requirement
that national laws have to be abided by;
(ii) the standard needs to be implemented effectively;
and
(iii) there needs to be effective chain of custody control
from the forest to the point at which the product is labelled.
In order to effectively exclude non-certified content, a
credible chain of custody should include three main elements:
identification, segregation and documentation. Segregation requires
clients to physically keep certified wood separate from uncertified
wood at all phases of transportation, production, distribution,
sale and export. Accurate records need to be maintained for the
production of certified products.
In conclusion, FERN believes that forest certification schemes
are not ideal tools to address illegal logging practices, although
some schemes are notably better at identifying illegal practices
than others, depending on the standard requirements and implementation
processes and the rigour of the chain of custody. Currently, only
the Canadian Standards Association's scheme (CSA) and the Forest
Stewardship Council (FSC) have a chain of custody that requires
segregation for solid wood products and demand legality in their
standards and could therefore qualify as a first step in verification
of legality. However, these schemes are not (yet) based on unannounced
audits, continuous sampling and independent monitoring of the
chain of custody, which is seen as essential for verification
of legality.
Is the use of certification schemes enough to ensure that the
timber requirements of the UK and EU countries does not have detrimental
impacts on forests and biodiversity in developing countries? What
other approaches should be used?
The following facts are important:
According to the World Resources Institute, at
most 20% of the wood produced in the tropics is exported; whereas
at least 80% is typically consumed in the local markets. In Brazil,
86.6% of all the wood produced in the Amazon region is sold on
the domestic market. Certification requirements in Europe will
only directly impact on those forests that export timber and wood
products to the European market.
More 90% certified forests lie in the North. Only
an estimated per cent of certified forests are situated in the
tropics. Hence, certification as a tool will have a larger impact
on forest biodiversity in the North than in the tropics.
Of the four major certification schemes (SFI,
CSA, PEFC and FSC), only the FSC has a large number of certifications
in the South. Forest certification in the tropics is not simple
or straightforward. It is still relatively new concept and only
a few certifications are applicable on a commercial scale. If
we consider just the Amazon region, there are more than 3,000
lumber mills; only a handful has been granted (FSC) certification.
As of October 2000, only five forest areas in Brazil have been
certified (a total of 21.440 ha).
The tropical certification schemes which have
been created in recent years, are the MTCC (Malaysia), Cerflor
(Brazil), and Certfor (Chile) and their focus is primarily on
certification of plantations rather than forests. All have been
highly criticised by local and national NGOs in their respective
countries as certifying "business-as-usual practices"
and for failing to contribute to improved forest management.
In short, forest certification will only address a certain
percentage of timber imports. Forest certification is not a panacea
to solve the forest crisis, other measures are needed. Clearly
more is needed to ensure that the timber requirements of the UK
and EU countries do not, in so far as possible, cause negative
impacts on forests and biodiversity in the tropics. This varies
from aid and trade measures to re-adjusting financial flows, notably
investment flows, to timber procurement measures. For aid, trade
and financial measures I would like to refer to FERN reports which
address these issues. [13]
In terms of timber procurement it would be advisable to:
Develop and implement strategies to reduce timber
and pulp and paper consumption and increase recycling and re-use
of timber, pulp and paper;
Use, wherever possible, timber and timber products
(including paper) originating in Europe. This is important to
lessen the demands on forests in developing countriesspecifically
with growing demand in India and Chinaas well as to ensure
a healthy European forestry industry which cannot easily compete
with cheap imports of paper and pulp from the South.
Buy FSC certified timber, when purchasing timber
from the tropics cannot be avoided. Currently, the FSC is by far
the least disputed certification scheme;
How satisfactory are the EU proposals for FLEGT? Will they
be stringent enough to have a significant impact?
This is as yet unclear. The central activity of the Action
Plan is to develop voluntary bilateral or regional partnership
agreements, with the aim of creating a caucus of the main wood-producing
and importing countries. Timber exporting partner countries would
then "license" as "legal" all timber exports
to the EU (or other importing countries joining the caucus). The
licensing scheme would initially cover a limited range of products
(logs, sawn timber and plywood) and eventually be extended to
other categories. In order to implement these voluntary partnership
agreements the Commission must draft a regulation that will form
the legal basis for a licensing scheme and would allow customs
to seize non-licensed timber products. Obviously this "licensing
scheme" begs a lot of questions such as: "who decides
what is legal"; "who decides which timber will be licensed
as legal or illegal"; "who decides when and how to award
a licence for legality"; "what control mechanisms need
to be in place?"; "who will benefit from such a scheme?"
etc.
Furthermore, there is a clear danger that the EU's efforts
to curb illegal logging with such a licensing scheme will unwittingly
encourage national governments to water-down their existing environmental
laws rather than strengthen them. This could lead to weakening
existing forest laws, or even to legalising current illegal practices,
in order to satisfy the EU and other international markets. All
this would certainly undermine local struggles for forest law
reform and would have a significantbut negativeimpact.
Nevertheless, FERN has been cautiously positive about the
FLEGT Action Planwhy?
Firstly, the Action Plan highlights clearly some of the underlying
causes of forest loss by mentioning the challenge to "ensure
that actions to address illegal logging, particularly enhanced
law enforcement, do not target weak groups, while leaving powerful
players unscathed. This requires careful considerations in countries
where corrupt elements within the police and judicial services
operate in complicity with large-scale illegal business activities."
This is the first EU document that actively promotes policy reform.
Also, in terms of highlighting the underlying causes of illegal
and unsustainable logging practices and hinting towards possible
solutions, this Action Plan is the most progressive EU document
on forests to date, thereby opening a door to discuss issues such
as forest law reform, tenure rights and corruption.
Secondly, the Council of the European Union, in its adoption
of the Action Plan, showed that it is fully aware of the political
nature of the issue, as it called on the European Community and
its member states in implementing the Action Plan to: [14]
strengthen land tenure and access rights especially
for marginalised, rural communities and indigenous peoples;
strengthen effective participation by all stakeholders,
notably of non-state actors and indigenous peoples, in policy-making
and implementation;
increase transparency in association with forest
exploitation operations, including the introduction of independent
monitoring;
reduce corruption in association with the award
of forest concessions and the harvesting and trade of timber.
Thereby the Council has paved the way for the implementation
of the Action Plan, which could address the underlying causes
leading to forest loss such as unclear and unjust tenure rights,
corruption, lack of transparency and lack of participation in
policy making.
Thirdly, the FLEGT process has, to date, created some political
space for NGOs from the Southnotably Indonesia, Ghana,
and Brazilto push for their own agenda, including most
of the issues listed above.
Fourthly, the Action Plan goes beyond just the FLEGT licensing
scheme and also calls for long overdue diligence procedures for
financial institutions, such as export credit agencies and private
banks, as well as asking member states to look into implementing
other measures such as money laundering legislation and stolen
goods legislation. By doing so, the Action Plan has opened a debate
for reform of financial institutions and forced member states
to look at their own legislation.
So, on the one hand, the FLEGT Action Plan, including the
FLEGT licensing scheme, has the potential to create opportunities
for civil society to push for solutions to highly political issues,
such as land rights and tenure rights, transparency, corruption
and often much needed forest law reform. Yet conversely, the FLEGT
Action Plan, and particularly the FLEGT licensing scheme, has
the potential to undermine national and local campaigns. It all
depends on what the final texts look like and how the FLEGT licensing
scheme will be implemented. At this stage, it is too early to
say whether the FLEGT Action Plan will have a positive or a negative
impact.
However, even in the best-case scenario, the FLEGT licensing
scheme will only address a small part of the illegal timber trade,
namely only the trade with producer countries who choose to start
a FLEGT partnership agreement with the EU. As a result, FERN,
jointly with Greenpeace and WWF, has argued that the FLEGT licensing
scheme should be embedded in broader legislation allowing customs
to seize all illegally-sourced timber and supporting partner countries
to improve forest management practices. The three organisations
have hired a law firm that has developed an EU Regulation which
would do exactly that. [15]However,
it is unclear if and how this legal proposal would be politically
feasible at EU level.
Should the social impacts of forestry be taken into account
within certification schemes? Would it be legal to do so?
There is no such thing as sustainable forest management without
taking into account social issues including labour rights, tenure
rights, and health and safety. FERN has, jointly with FoE and
Greenpeace, presented a submission to the UK Environmental Audit
Committee[16] (22 February
2005) stating that the UK's current timber procurement position,
which excludes social criteria, is in contradiction to international
agreements of which the Government is a signatory and which the
Government cites in its advice to procurement authorities. Furthermore,
the submission clearly outlines that in our view, there is no
legal reasoning behind the UK's claim that social aspects of forest
management cannot be taken into consideration due to the EU Procurement
Directives. In our opinion, environmental matters related to the
way in which forests are managed have the same demonstrable bearing
on the quality of the finished product as social matters. It is
disingenuous to claim, for example, that protection of a rare
species is in some way more relevant to a contract to supply timber
than a similar criterion concerning prevention of harm to forest-dependent
people or protecting indigenous peoples' rights. Other EU governments,
such as Denmark's, have included social elements in their procurement
policies and the Dutch and German governments are considering
doing so also. Therefore, we are pleased that the UK Government
has stated that is revisiting this aspect of its policy, as stated
by UK Minister Elliot Morley in a meeting with UK NGOs, including
FERN. [17]
FERN's position was strengthened by a recent legal opinion,
commissioned by WWF, looking into the matter of the use of social
and other criteria in the public procurement process. This legal
opinion also concludes that ". . . [social] criteria can
be lawfully and properly be taken into account in a public procurement
exercise if they are objectively justifiable, proportionate and
non discriminatory, a fortiori where they reflect (1) generally
accepted international standards and legal norms; 2) a policy
stance taken in international instruments or agreements to which
the EU is a signatory or which the EU has in some other way adopted
or supports or (3) an objective of the EU Treaty." [18]In
short, there seems to be no legal basis to exclude social criteria,
such as land-rights and user rights, from timber procurement policies.
How successful has the bilateral agreement with Indonesia been
in reducing the imports of illegal timber into the UK? What progress
has there been on negotiating agreements with further countries?
It is too early to tell: the Tropical Forest Trust has carried
out research on behalf of the UK and Dutch Timber Trade Federations
showing that virtually no timber from Indonesia, entering into
the EU, is legally sourced. With illegally sourced timber in the
spotlight, many UK and Dutch companies are looking for other sources
of timber. Subsequently, (illegal) timber imports from Indonesia
to the UK have decreased drastically (by an estimated 30-50%).
As there is as yet no formal partnership agreement in place between
the EU and Indonesia, the impact of the bilateral agreement between
the UK and Indonesia (which can be seen as a potential predecessor
of an EU FLEGT partnership agreement) is difficult to measure.
Does the inclusion of forestry projects in the Clean Development
Mechanisms within the Kyoto Protocol have any implications for
certification schemes?
Yes, the inclusion of forestry projects in the Clean Development
Mechanism (CDM) within the Kyoto Protocol has implications for
certification schemes, and they are likely to be negative. None
of the existing certification schemes was developed with climate
change considerations in mind. As a consequence, none of these
schemes is set up to assess carbon fluxes in forest ecosystems.
In addition, none of the existing schemes includes any provisions
to address carbon accounting. These provisions, however, should
be of utmost importance to ensure that carbon sequestration objectives
do not undermine the objectives of forest certification schemes,
which include biodiversity conservation. Experiences to date show
that carbon sequestration objectives to run counter to biodiversity
conservation objectives. [19]
FERN has always argued against the inclusion of forests (and
plantations) in the CDM. The CDM provides an incentive for monoculture,
fast-growing species that maximise carbon uptake. This incentive
for monoculture tree plantations with exotic speciesthat
typically grow faster than native species- runs counter to efforts
to increase the use of native tree species and restore single-age
tree stands into multiple-age, diversely structured forests. These
aspects are all the more problematic given the controversies as
to whether or not carbon fluxes in forest ecosystems can even
be measured with the accuracy needed for carbon accounting schemes
such as the CDM. FERN, jointly with the Cornerhouse, submitted
a detailed memorandum to the UK Parliamentary Environment Audit
Committee's Inquiry into the International Challenge of Climate
Change, which contains our position on forests and the CDM.[20]
September 2005
2
Sierra Legal Defence Fund, 11 complaints against CSA certified
companies (29 October 2004). Back
3
FERN, Footprints in the forest, current practise and future
challenge in forest certification (FERN, January 2004). Available
at www.fern.org Back
4
Report of the ad hoc intergovernmental panel on forests on
its fourth session, E/CN.17/1997/12 (20 March 1997). Back
5
EU statement regarding agenda item 6: criteria and indicators
of sustainable forest management of all types of forests and implications
for certification; 7 March 2001. Back
6
Report of the ad hoc intergovernmental panel on forests on
its fourth session, E/CN.17/1997/12 (20 March 1997). Back
7
The term credibility is a vague term. Bass and Simula (1999)
have interpreted this term as multi-stakeholder support, transparency,
reliability and accountability. Back
8
IFIR, Proposing an international mutual recognition framework:
Report of working group on mutual recognition between credible
sustainable management certification systems and standards
(February 2001). www.sfms.com/pdfs/ifirframework.pdf. Back
9
http://wbln0018.woeldbank.org/institutional/manual/Opmanual Back
10
SGS Global Trade Solutions (2003), "Legal Origin of Timber
as a Step Towards Sustainable Forest Management", Final Draft,
September 2002-June 2003, World Bank/WWF Alliance, p 2. Back
11
SGS Global Trade Solutions (2003), p 9. Back
12
Dennis P Dykstra et al, "Wood tracking: verification and
monitoring the chain of custody and legal compliance in the timber
industry", World Bank Discussion Paper (Date). Back
13
Specifically: FERN; Forests at the edge: A review of EC aid spending;
November 2002-FERN; Trade liberalisation and its impact on forests:
An overview of the most relevant issues; July 2000-ECA Watch coalition;
Race to the Bottom Take II: an assessment of sustainable development
achievements of ECA-supported projects; September 2003. All are
available at www.fern.org Back
14
Council of the European Union (2003) Communication from the
Commission to the Council and the European Parliament on Forest
Law Enforcement, Governance and Trade (FLEGT): Proposal for an
EU Action Plan-Council Conclusions, p 3. Back
15
Draft legislation is available at www.fern.org or at www.illegal-logging.info
and is available from info@fern.org Back
16
FERN, Greenpeace and Friends of the Earth submission to UK Environmental
Audit Committee on the need for inclusion of social criteria in
the UK Timber Procurement Policy (22 February 2005). Back
17
Letter from Elliot Morley to WWF, Greenpeace and FERN (11 August
2005) in response to a letter from these organisations to Elliot
Morley (20 July 2005). Back
18
"In the matter of the use of social and other criteria in
the public procurement process", Legal Opinion by Monckton
Chambers, 1&2 Raymond Buildings (12 July 2005). Back
19
Experience with certification of "carbon sinks" by
the Forests Stewardship Council confirms FERN's concerns that
the inclusion of forestry projects in the CDM may have a negative
impact on forest certifications schemes. At least four FSC certificates
have been issued to forestry projects linked to the CDM carbon
market. Three of these certificates are very controversial and
have been challenged by NGOs, including FERN. Although the certification
body did not directly assess the carbon measurements, in all three
cases the existence of carbon contracts appears to have added
pressure on the certification body to issue the FSC certificate.
Not doing so would have in at least two cases (Plantar and V7M
do Brasil certifications in Minas Gerais, Brasil) excluded the
companies seeking certification from the carbon market, because
the institution under whose auspices the carbon projects were
conceived, required FSC certification of all forestry projects
in its carbon finance portfolio. Back
20
For further detail on the controversy surrounding carbon measurements
in forest ecosystems see the Memorandum by CornerHouse, SinksWatch
and Carbon Trade Watch to the UK Parliamentary Environment Audit
Committee's Inquiry into the International Challenge of Climate
Change: UK Leadership in the G8 and EU, submitted by Larry Lohmann
on 29 October 2004. Back
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