APPENDIX 14
Memorandum from T Brewer & Co.
We are writing in connection with this enquiry
as a privately owned timber importing, machining and merchanting
business, operating within London. Formed originally in 1888 and
owned by the current shareholders since 1992, T Brewer & Co
(Brewer's) has a real interest in this issue and hopefully is
also able to contribute points from this perspective that will
be of use to the Committee.
As active members of the Timber Trade Federation,
Brewer's has signed up to the Responsible Purchasing Policy (RPP)
and has Chain of Custody (CoC) Certification for CSA, FSC, MTCC,
PEFC & SFI schemes either directly or through the auspices
of BM TRADA.
Brewer's day to day trading business involves
the sales of sawn, machined and a variety of timber based panel
products, to all manner of customers, from small individuals to
major PLC's, working on every conceivable level of construction
based projects, mainly in London.
Over many years Brewer's has taken a great deal
of interest in the issues surrounding sustainability and the environmental
impact of timber and therefore, whilst time is inevitably a limited
commodity, particularly for small businesses, we feel that it
is extremely important for the Committee to receive feedback from
companies such as ourselves, to hopefully help balance out the
high level of interaction, particularly from NGO's, who see lobbying
as a mainstream activity.
It is also probably worth pointing out that
the PEFC are the body that appear to have put the most effort
into suggesting that companies submit information to the Committee,
which would seem to suggest that they are very comfortable with
this situation, whereas the other large scheme with a high profile
in the UK, which seems to usually have a great deal of comment
available across a wide range of issues, has not made any effort
to highlight the work being undertaken by the Committee.
We have endeavoured to answer your questions
as fully and factually as possible, but inevitably those issues
closest to our business activities will have a more relevant content.
1. How useful has the work of the CPET proved?
How should its role develop to ensure further progress on the
issue of sustainable timber procurement?
CPET has provided a framework from which to
move forwards and what is needed now is a time of stability, so
that businesses can tackle this issue, instead of reacting to
even more change! To this should be added the large cost burden
that has already been borne by companies to ensure high levels
of CoC administration, which needs to be seen as a commercially
viable system to give it credibility—constant change will
devalue this process because other parties will not understand
what is already an extremely complex area, thereby allowing the
purchasers of timber products to be confused or possibly deceived.
The European aspects also need to be borne in
mind, so that a harmonized effort is available across the EU,
to increase the understanding of this complex issue and also to
allow larger companies to promote sustainability against a known
set of rules.
2. How reliable are the certification schemes
for timber endorsed by CPET? Are there concerns regarding either
the legality or sustainability of any of them?
We are probably not in a strong position to
comment on this, but we have seen a great deal of "squabbling"
between schemes, creating a "turf war" that has actually
made it difficult for us to promote sustainable timber at times.
Thankfully the latest announcement by DEFRA on schemes, whereby
the PEFC & SFI have been included has levelled a large amount
of anomalies which can only be helpful to responsible companies,
promoting sustainable timber. After all, while this "squabbling"
was going on, it effectively devalued the whole issue and allowed
timber with far lower credentials to pass through the system—this
is a moving target that needs addressing, not some new product
to be released at a later date; therefore the controls embraced
under CPET have at least raised the threshold significantly and
that must be a very good thing for sustainable timber.
3. Is there sufficient data to determine
where and how timber purchased by government is sourced?
No. Whilst some schemes, one in particular,
appears to make great claims about volumes and values of government
procurement of sustainable timber, on the ground there does not
appear to be any known way of evaluating it.
One of the key problems is that these schemes
are designed to promote how much certified timber has gone through
the system, so that the schemes can then "fanfare" their
amazing achievements!
In other words, companies bring in certified
products and submit returns based on that—what no one ever
asks or records is how much of this volume is actually requested
by the end user!
Whilst demand is growing, it is still a small
fraction of the overall volume/value sold. As far as government
contracts are concerned, the chain is lengthy and "broken"
by lack of understanding by the construction companies, their
sub-contractors and other interested parties.
This is where many companies are currently acting
in good faith, waiting for CPET and other government initiatives
to pull through an improved level of understanding, both from
their own people as they specify materials, and by the various
parties in the chain beneath them.
During question 1 we mentioned the importance
of consistency and stability—there have been so many changes
to date and what is required now is a period where each member
of the chain can actually concentrate on conformance.
4. Is the use of certification schemes enough
to ensure that the timber requirements of the UK and EU countries
do not have detrimental effects effects on forests and biodiversity
in developing countries? What other approaches should be used?
Yes. Timber in itself is as far as we understand
the ONLY renewable building material that is available. The vast
majority of all timber used is in construction and within that
the main timber supplied is softwood (pine and spruce). Whilst
there will be issues around the finer points of sustainability,
most softwoods are extremely sound on all measures of sustainability.
Indeed a huge percentage of the softwoods used come from countries
within the EU!
The shame of all this is the amount of time,
cost and effort put into researching these issues, whilst other
materials (plastics, steel, aggregates etc) seem to almost be
considered "eco-friendly". This often leads decision
makers to opt for far less environmentally friendly products,
in the misguided opinion that using timber products is "bad".
There are, in volume terms, relatively small
quantities of less sustainable timbers brought into the UK and
other EU countries and it is accepted that there are a wide range
of issues surrounding the legality of them. The main effort on
these materials needs to come through interaction with the governments
of those countries, across a wide range of issues, including poverty
and corruption. The EU FLEGT effort appears to be the current
route for assistance in these matters and those efforts should
continue.
As commented on in question 3, a concentrated
effort using the systems that are already in place through CPET
will control these issues to a very high level.
5. How satisfactory are the EU proposals
for FLEGT? Will they be stringent enough to have a significant
impact?
This is a subject area that our business does
not have much mainstrean knowledge on, but from the limited amount
of information that we have gathered to date, the EU FLEGT system
seems to be a worthy cause, that appears to be extremely slow,
procedural and time consuming. There seem to be a very limited
number of EU sponsor countries and this probably means that the
overall interest from member states is low.
If the progress to date is added to this, during
some 3 years of effort to date, then it strikes us that the whole
FLEGT system is just too cumbersome to actually achieve anything
of real worth.
6. Should the social impacts of forestry
be taken into account within certification schemes? Would it be
legal to do so?
As in 5, our knowledge on this is limited, but
it would seem from the information supplied to us from various
parties that the social issues surrounding timber sourcing are
already embodied within the main certification schemes. There
is a balance to be struck and care needs to be taken to ensure
that the social impact does not become too large a part of the
entire process.
7. 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?
As mentioned in 5, the EU FLEGT approach is
having some limited impact and the UK is one example of where
real effort is being made, through its links to West Africa. The
Timber Trade Federation, which in itself is a relatively small
organization with extremely limited resources, has been a major
participant in this united effort and the links being forged in
a region where communication and other issues make progress very
hard, are definitely showing results.
Indonesia is not an area that we really have
much information on.
8. Does the inclusion of forestry projects
in the clean development mechanism within the Kyoto protocol have
any implication for certification schemes?
Again, our knowledge on these issues is limited
and we cannot really add comments on this question.
October 2005
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