hfhc controlled wood risk assessment · 2014-07-10 · sustainable northwest, sa-coc-002372...

Forest Stewardship Council Controlled Wood Risk Assessment

Sustainable Northwest SA-COC-002372

February 15, 2013

Per acceptance of this document by Woodmark, this document serves as the official Controlled Wood Policy for the group certificate. This document and policy is

endorsed by Paul Vanderford, Group Manager.

Sustainable Northwest, SA-COC-002372 Controlled Wood Risk Assessment

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Background Sustainable Northwest is a not-for-profit organization located in Portland, Oregon. We hold a FSC group Chain of Custody certificate; the findings in this document apply for all members of a group certificate under the number SA-COC-002372. The FSC Controlled Wood standard was written to ensure that wood coming from poor forestry practices is not mixed with FSC-certified wood and included in wood products that carry the claim of “FSC Mixed Sources.” Group members will strive to not include any sources in FSC Mixed Sources products from any of the five following categories:

1) Illegally harvested wood; 2) Wood harvested in violation of traditional or civil rights; 3) Wood harvested in forests where high conservation values are threatened by

management activities; 4) Wood harvested in forests being converted to plantations or non-forest use; and 5) Wood harvested from forests where genetically modified trees are planted.

FSC-STD-40-005 requires a risk-based assessment, where forest products coming from areas where there is low risk to the five categories above could be considered “controlled” and usable in FSC Mixed Sources products. This document is the result of conducting a risk assessment for the district of origin for the members of our group certificate. The risk assessment was conducted by referencing existing reports and assessments of the study area conducted by other certified companies. Determinations of risk were then made based on the research. Summary of Findings The relevant district of origin for this analysis includes portions or entireties of California, Oregon, Washington, Idaho, Montana and parts of British Columbia. Our analysis indicates that across this broad geography, group members are at LOW RISK of sourcing material from the five categories above. These findings will be made publically available by Woodmark on the FSC website. District of origin The specific district of origin for this analysis is outlined on the map below. In addition, it is defined as follows: 1. Southwest Canada:

a. Coastal British Columbia – west of the Fraser River including Vancouver Island b. Interior British Columbia – defined as east of the Fraser River

2. Northwest United States: a. Washington – in entirety b. Oregon – in entirety c. Northern California; defined as north of I-80 d. Idaho west of I-15, north of I-84 to Idaho Falls and directly south from there e. Western Montana; defined as west of I-15


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Figure 1. The area outlined in red is the district of origin boundary for this assessment. Risk Assessment

A. Illegally Harvested Wood

Summary of Findings

Based on the criteria 1.1 – 1.4 on illegally harvested wood in the Controlled Wood Standard, wood within the district of origin can be described as LOW RISK. This determination is based on the following:

1. Group members source wood from credible businesses that follow state, provincial, national and international laws.

2. There are strong laws against illegal logging and very little evidence that it occurs.

3. Canada and the United States are countries recognized for having low corruption in public officials and politicians.

Assessment

All members purchase wood from credible businesses that follow state/provincial, national and international laws. In the United States and Canada, there is no evidence suggesting that illegal


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logging is a wide scale problem1, and is only documented as a rare occurrence in comparison to world data. Within the district of origin, logging laws are enforced with oversight from state, provincial and/or federal governments and judicial systems allow a process for prosecution of such offences. There is little evidence of corruption in the U.S. and Canadian governments. Transparency International’s Corruption Perceptions Index (CPI) is used to determine levels of corruption in worldwide governments. Although the CPI is related to overall corruption in the public sector, it is assumed that any low levels of corruption can be reflected to show good enforcement of forest practices laws.2 According to the FSC guidance document on implementing controlled wood requirements, “companies shall consider a threshold of 5 to determine unspecified/low risk3 The 2009 CPI rating for Canada is 8.7 and the U.S. received a rating of 7.5. In addition, The World Bank has developed a governance indicator for “Control of Corruption”4; both the U.S. and Canada are recognized for having high control over corruption.

B. Wood Harvested in violation of traditional and civil rights

Summary of Findings:

One can conclude that wood within the district of origin at LOW RISK in relation to the threat of violation of traditional and civil rights through compliance with criteria 2.1-2.5. This determination is based on the following:

1. Within the district of origin, there is no UN Security Council ban on timber exports.

2. The area is not designated as a source of conflict timber.

3. Child labor does not occur systematically and ILO Fundamental Principals and rights are respected.

4. The U.S. and Canada have recognized equitable processes in place to resolve conflicts of substantial magnitude pertaining to traditional rights including use rights, cultural interests or traditional cultural identity.


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5. There is no evidence of violation of the ILO Convention 169 on Indigenous and Tribal Peoples taking place in the forest areas in the district concerned.

Assessment

Within the district of origin there is no UN Security Council ban on timber exports5, the areas are not designated as a source of conflict timber6, child labor does not occur systematically7, and ILO Fundamental Principles and rights at work are respected8. The U.S. is recognized as having equitable processes in place to resolve conflicts pertaining to the rights of cultural interests, traditional and identity. Both the U.S. and Canada are recognized by the World Bank for providing voice and accountability to all citizens including indigenous people and following the rule of law as seen below. In addition, according to NEPCon, the U.S. and Canada are in low risk of a threat of violation of traditional and civil rights.

C. High Conservation Value Forest

For High Conservation Value Forests (HCVF), determination of “low risk” can be made if either Criterion 3.1 is met or Criterion 3.2 eliminates or greatly mitigates the threat to HCVs posed by non-compliance of Criterion 3.1: Criterion 3.1 Forest management activities in the relevant level (eco-region, sub-eco-region, local) do not threaten ecoregionally significant high conservation values. Criterion 3.2 A strong system of protection (effective protected areas and legislation) is in place that ensures survival of HCVs in the ecoregion.

C.1 Summary of Findings

We come to the conclusion that wood in the district of origin can be described as LOW RISK in relation to threat to High Conservation Values through compliance with Criterion 3.1, and partial assessment of Criterion 3.2. Our determination is based on the following:


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1. Although there are a few designations worth noting in the WWF Global 200, investigation indicates that biodiversity-based HCVs are adequately protected by the extensive protected area system represented in the ecoregions. All ecoregions have low or very low (less than “vulnerable”) conversion/protection ratios indicating that the protection is relatively secure.

2. Overlap with Conservation International Biodiversity Hotspots is limited to the CA Floristic Province (including the Klamath-Siskiyou Coniferous Forests and the Northern California Coastal Forests). This prioritization is complementary to the WWF prioritization and protection is determined to be adequate as described above.

3. Overlap with Smithsonian/IUCN designated Centers of Plant Diversity is primarily in already designated areas (e.g. Klamath-Siskiyou Coniferous Forests) but also includes the Willamette Valley forests ecoregion. The identified HCVs associated with this ecoregion are grasslands, oak savannas, and serpentine flora. It is unlikely that any forestry activities in the ecoregion are leading to further disruption of the noted ecoregional HCVs.

4. None of the district of origin is included in assessments of large landscape-level forests by WRI/Global Forest Watch Frontier Forests.

5. Intact Forest Landscapes identified by Greenpeace are sufficiently protected in British Columbia and exceptionally well-protected in the U.S.

C.2 Interpretation of the Standard

Criterion 3.1 Interpretation

Timber extraction in areas that have higher densities of High Conservation Values (HCVs) will have a higher risk associated with threat to those HCVs. Following that logic, presumed risk is elevated in areas identified by conservation organizations as priority due to significant accumulations of HCVs. These include high measures of biodiversity, high measures of endemism, unique assemblages of species, habitat for concentrations of endangered species, or the quality of the landscape as a large and intact landscape-level forest. The intent of Criterion 3.1 is to ensure that large-scale logging does not pose risk to forest areas that are a global, regional, or national high conservation priority. The intent, however, is not necessarily to eliminate logging from these areas. For example, well-managed forests can provide both habitat security and a proactive conservation effort for these areas. Another intent of Criterion 3.1 is to ensure that large-scale logging does not pose a risk to the cohesion of the large, landscape-level forests that represent or are part of native, large-scale ecosystems with limited direct human impact. These forests represent habitat for native species in historically natural or nearly natural patterns of distribution and abundance. This includes habitat for both species populations that require large land tracts and for those that are sensitive to human activities and human-caused forest fragmentation. Logging in these areas must be determined to be of no reasonable threat to the qualities stated above that define these forests. The term “large, landscape-level forests” is defined in the glossary of the standard. Criterion 3.2 Interpretation

Criterion 3.2 is included in the controlled wood standard to recognize that in many regions of the world strong systems are in place to protect global environmental conservation priorities. If


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Criteria 3.1 cannot be met, or it is determined that it is more difficult for a certificate-holder to measure compliance with Criterion 3.1, compliance with Criterion 3.2 can demonstrate that a district or region may be considered LOW RISK for HCVF. The intent of Criterion 3.2 is to ensure that comprehensive legal systems and effective enforcement are both present to regulate the “survival of the globally significant concentrations of biodiversity values, ecosystems, and/or services of nature present.” However, in the context of the US, a “strong protected areas system,” as stated in Criterion 3.3 of the Controlled Wood standard, is not representative of the entirety and efficacy of the legal system. A system of other environmental laws may actually lead to the meeting the intent of the Criterion. This includes legislation such as the Endangered Species Act and environmental protection measures such as the Clean Air Act and the Clean Water Act. These laws may provide sufficient biodiversity value protection within the preserves, parks, wilderness areas, and conservation easements to provide long-term protection of the values of concern. A strong protected areas system is one in which a high proportion of the landscape, the biological diversity, and ecosystems are protected physically or through legal mandates from conversion. A key component of the protected areas central management objectives is the maintenance of a natural state and processes (e.g. National Park, Wilderness Area, Preserves). The management and safeguard of these protected areas is such that illegal usage, habitat loss, and natural resources extraction (hunting, mining, oil, and natural gas drilling) do not occur at such a level that they threaten the integrity of the biological diversity and natural processes. The proportion protected in full protection schemes can be augmented by less-stringent protection that may allow multiple uses but explicitly does not allow the extraction or conversion that affects key species or ecosystems (e.g. State Parks, National Wildlife Refuges, and National Recreation Areas, forests enrolled in land trusts). C.3 Assessment of Criterion 3.1

Ecoregional Identification

There are 19 ecoregions in the district of origin, as shown below (see Figures 1 and 2)9,10.


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Figure 2. WWF ecoregions in the district of origin. Each ecoregion is distinguished by a color. The district of origin is the red-outlined area. Ecoregions include: Willamette Valley forests (NA0417); Blue Mountains forests (NA0505); British Columbia mainland coastal forests (NA0506); Cascade Mountains leeward forests (NA0507); Central and Southern Cascades forests (NA0508); Central Pacific coastal forests (NA0510); Eastern Cascades forests (NA0512); Klamath-Siskiyou forests (NA0516); North Central Rockies forests (NA0518); Northern California coastal forests (NA0519); Northern Pacific Coastal forests (NA0520); Okanagan dry forests (NA0522); Puget lowland forests (NA0524); Queen Charlotte Islands (NA0525); South Central Rockies forests (NA0528); Palouse grasslands (NA0813); Pacific Coastal Mountain icefields and tundra (NA1117 – not included in assessment); Montana Valley and Foothill grasslands (NA0808), Fraser Plateau and Basin complex (NA0514), and the Snake-Columbia shrub steppe (NA1309).

C.4 Overview of External Conservation Assessments

World Wildlife Fund: Global 200

The WWF Global 200 is a designation of exceptional regional biodiversity and exceptional representation of a fundamental habitat type. Unlike the Biodiversity Hotspot, the Global 200 ecoregions are selected exclusively on ecological criteria. These criteria may be influenced by human-caused actions leading to global rarity of a habitat, but they are not defined by destruction. The criteria used include: species richness, endemism, higher taxonomic uniqueness, extraordinary ecological or evolutionary phenomena, and global rarity of the major habitat type13,14. There are no global thresholds for inclusion due to the fact that ecoregions were not compared across habitat types (i.e. diversity values were not compared between deserts and rainforests). The World Wildlife Fund Global 200 Ecoregions designation may also include communities and ecosystems that are apparently globally secure; however, these communities are intended and essential as part of the conservation designation.


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Figure 3. Overlap of the district of origin and the WWF Global 200 Ecoregions. The district of origin is outlined in red and overlaps with the Pacific Temperate Rainforests and the Klamath-Siskiyou Coniferous Forests G200 ecoregions13,14.

Conservation International: Global Biodiversity Hotspots

The Hotspots designation is one of both biodiversity value and also one of conservation value. To qualify as a hotspot, a region must meet two criteria: it must contain at least 1,500 species of vascular plants (> 0.5 percent of the world’s total) as endemics, and it has to have lost at least 70 percent of its original habitat (online reference at www.biodiversityhotspots.org). Thus, only those areas that have been severely degraded are considered Hotspots. Hotspots are of larger scale and comprise multiple landscapes and ecosystems, some of which are not of particular conservation priority, it may be necessary to further breakdown these designations to the particular areas within the Hotspot that represent the values that are significant for conservation12. For example, one of the Conservation International Biodiversity Hotspots is the California Floristic Province. It encompasses all of California and parts of Southern Oregon. Included in this region are extensive Lodgepole Pine (Pinus contorta) forests that are apparently secure and not of high conservation priority. Also included in the region is the city of San Francisco - which is not recognized as a conservation priority. However, in the Conservation International justification of designation of the California Floristic Province as a Biodiversity Hotspot, there is description of the regions and ecosystems contained within the Biodiversity Hotspot that are of conservation priority42. These include regions or distinctions that have been explicitly recognized to contain exceptionally high plant diversity:

• the Sierra Nevada • the Transverse Ranges in southern California - a narrow strip that runs east to west in

southern California, separating the Coast Ranges to the north from the Peninsular Ranges to the south

• the Klamath-Siskiyou region in the coastal mountain ranges of California and Oregon • the Coast Ranges • Serpentine soil habitats occurring along fault zones in the Central and North Coast and

Cascade ranges

IUCN – Smithsonian Centres of Plant Diversity

The IUCN/Smithsonian Centres of Plant Diversity designation is also regional, primarily based on species richness and endemism but also including factors such genepools of plants utile for


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humans (e.g. crop plant heritage), adaptations to special soils or conditions (e.g. serpentine soils), and under imminent threat of destruction11,12. Globally, 234 sites were selected as Centres of Plant Diversity, but within those designations are more specific areas that may be treated independently in the assessments and designation. For example, both the Klamath-Siskiyou Region and the California Floristic Province are designated Centres of Plant Diversity despite the fact the Klamath-Siskiyou Region lies within the California Floristic Province.

Figure 4. Smithsonian Institution / IUCN Centers of Plant Diversity for North America. Overlap occurs in the northern section of the California Floristic Province and the North American Serpentine Flora Centers of Plant Diversity.11,12

Conservation International High-Biodiversity Wilderness Area

Conservation International identifies five high-biodiversity wilderness areas: vast regions of relatively pristine habitat that sustain large numbers of plant and animal species found nowhere else. The designation of a High Biodiversity Wilderness Area indicates that a terrestrial ecoregion is at least 10,000 km2 in size that has a human population density of less than five people per km2 (not including urban areas). Further, the region must have at least 70% of its historical habitat extent and must contain at least 1,500 endemic vascular plant species. Twenty-four wilderness areas were identified in the process of which five were found to contain 1500 vascular plant species and thus designated high biodiversity17. The impact of including both this designation and that of the low-access forests of Global Forest Watch will likely not come into play in most wilderness areas. However, the single High Biodiversity Wilderness Area in the US is the North American Deserts. This area comprises forest ecosystems in the Southern Rocky Mountains and Southeastern Sierra Nevada.


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Figure 5. High Biodiversity Wilderness Areas identified by Conservation International. The five areas outlined in red have been identified to be global conservation priorities due to their qualities of being large and generally intact habitat areas that support high levels of biodiversity17. WRI/Global Forest Watch Frontier Forest

Frontier Forests, as defined by Global Forest Watch, an initiative of WRI, are large and intact natural forests. They are less influenced by direct human activities and maintain viable populations of most if not all species that historically lived in the region. WRI has established seven criteria in its definition18:

1. It is primarily forested 2. It is big enough to support viable populations of all indigenous species associated with

that forest type -- measured by the forest's ability to support wide-ranging animal species (such as elephants, harpy eagles, or brown bears).

3. It is large enough to keep these species' populations viable even in the face of the natural disasters -- such as hurricanes, fires, and pest or disease outbreaks -- that might occur there in a century.

4. Its structure and composition are determined mainly by natural events, though limited human disturbance by traditional activities of the sort that have shaped forests for thousands of years -- such as low-density shifting cultivation -- is acceptable. As such, it remains relatively unmanaged by humans, and natural disturbances (such as fire) are permitted to shape much of the forest.

5. In forests where patches of trees of different ages would naturally occur, the landscape exhibits this type of heterogeneity.

6. It is dominated by indigenous tree species. 7. It is home to most, if not all, of the other plant and animal species that typically live in

this type of forest.


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Figure 6. Global Forest Watch Frontier Forests in North America. The areas in green are designated as low/no risk by Global Forest Watch. The areas in orange are designated as high risk19. Greenpeace Intact Forests

Greenpeace defines an intact forest landscape to be a minimally disturbed forested area of at least 500 km2, which also has a minimal width of 10 km. The delineations were based on 2000-2002 Landsat images The Intact Forests do not include the following20,21:

1. Settlements (with 1 km buffer zone) 2. 1 km buffer zones around infrastructure used for communication between settlements

and industrial sites; or for industrial exploitation of natural resources (including motor roads, railways, navigable waterways, pipelines, trunk power transmission lines and other linear objects)

3. Agricultural lands, except small scale which are used by local communities for their needs and are not connected with the rest of the world by infrastructure

4. Territories disturbed by economic activities during the last 30-70 years (logging, mining operation sites, abandoned agricultural lands, etc.)

5. Artificially restored forests, tree plantations 6. Burnt lands and young tree sites adjacent to infrastructure objects (buffer zones of 1 km)

C.5 Assessment of Criterion 3.2

During the assessment on Criterion 3.1, the following ecoregions were flagged for assessment of protection levels for biodiversity-based HCVF (Criterion 3.2).

Ecoregion Name WWF G200 CI Hotspot SI/IUCN CPD WWF Assessment

Flagged to assess at Criterion 3.2

Klamath-Siskiyou Coniferous Forests

Klamath-Siskiyou Conifer Forests

California Floristic Province

California Floristic Province; NA Serpentine Flora

Critical/ endangered

Yes

Central Pacific Coastal Forests

Pacific Temperate Rainforests

None None Critical/ endangered

Yes

British Columbia Mainland Coastal Forests


None NA Serpentine Flora Critical/ endangered

Yes

Northern California Coastal Forests


None None Critical/ endangered

Yes

Willamette Valley Forests

None None NA Serpentine Flora Critical/ endangered

Yes


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The Klamath-Siskiyou Coniferous Forests Ecoregion - Protection

The Klamath-Siskiyou Forests ecoregion covers 50,299 square kilometers, approximately 63% of which are publicly owned (see Figure 7). Complete and near-complete protection afforded through designations such as wilderness and national park service covers 12.44% of the ecoregion, and an additional 44.8% of the ecoregion is offered permanent protection from conversion16. Current harvest practices by the Forest Service (the largest land manager in the region) favor protection of HCVs on public land. Private land owners in the region have some responsibility for protection of HCVs (private land accounts for 37% of the ecoregion), but strict Forest Practice Rules have been passed in both Oregon and California that mandate protection of forest resources and ecosystem values. The Forest Practice Rules also limit opening sizes. Although there are mixed reports regarding the level of policy to protect HCVs, the area has to be considered relatively well protected16. There is additional supportive scientific evidence that the ecoregion is relatively well-protected. An assessment of the ratio of converted lands to protected lands states that only 4.6% of the ecoregion has been converted and 58.6% of the land is protected. The converted/protected ratio of 0.08 is very low (note: the published assessment was done on the analogous TNC/USFS ecoregional delineation – the Klamath Mountains Ecoregion)23.

Figure 7. Federal land ownership in the Klamath-Siskiyou Forests ecoregion. The ecoregion is outlined in red, fully protected designation (national park, wilderness, etc) is dark-green shaded, national forest is light-green, national recreation area is cream-shaded, and BLM is yellow-shaded.

Central Pacific Coastal Forests – Protection

Just more than half of the Central Pacific Coastal forests (55%) is located in the US and the rest is Vancouver Island, in British Columbia, Canada. The US section is mostly privately held (55%) (see Figure 8). Federal lands make up 31% and state and county lands make up 12% of the ecoregion. The Canadian portion is 75% Crown Land. The primary threats to the ecoregion at one time were logging, but now are more associated with pollution, grazing, introduced species, road building, and recreational impacts. The ecoregion is relatively well-protected. Top level protection as park or wilderness covers 9.4% percent of the ecoregion (note: this does not include the core portion of Olympic National Park, which falls in a different ecoregion). An additional 15% is granted moderate protection, and an additional 76% is granted protection from issues such as conversion and division. Given the legal


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ownership in the ecoregion and the current forest practices of both Crown Lands in BC and US Forest Service in the US, it is very unlikely that forest practices currently contribute great threat to ecoregional HCVs. In addition, an assessment of the ratio of converted lands to protected lands states that 2.1% of the ecoregion has been converted. The converted/protected ratio of less than 0.1 is very low. (note: the published assessment was done on the analogous TNC/USFS ecoregional delineation – the Pacific Northwest Coast)23.

Figure 8. Protected areas in the Central Pacific Coastal Forests ecoregion. The ecoregion is outlined in red, fully protected designation (national park, wilderness, etc) is dark-green shaded; moderate protection (e.g. national forest) is light-green. Note the white space on the northern tip of the Olympic Peninsula is not part of this ecoregion and is covered below. British Columbia Mainland Coastal Forests Ecoregion - Protection

In total, 22.5% of the ecoregion is enrolled in protection (see Figure 12)23 and about 13% of the entire ecoregion is enrolled in the highest level protection. Only about 10% of the ecoregion is located in the US and about 90% in Canada. About 40% of the US portion of the ecoregion is fully protected as wilderness or park – most notably the North Cascades and Olympic National Parks29. Given the legal ownership and protection levels of the ecoregion in the US, it is very unlikely that forest practices currently contribute great threat to ecoregional HCVs. In addition, an assessment of the ratio of converted lands to protected lands states that 0.5% of the ecoregion has been converted and 22.5% of the land is protected. The converted/protected ratio of 0.02 is very low (note: the published assessment was done on the analogous TNC/USFS ecoregional delineation – the North Cascades)19.


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Figure 9. Protected areas in the British Columbia Mainland Coastal Forests ecoregion. The ecoregion is outlined in red, fully protected designation (national park, wilderness, etc) is dark-green shaded; US national forest is light-green. Northern California Coastal Forests Ecoregion - Protection

Only about 14% of the ecoregion is publicly owned (this is low for western ecoregions); however, approximately 19% of the ecoregion is protected49 and 10% is under high level protection as park or wilderness16 (see Figure 10). The protection index of Hoekstra indicates that the level of protection is good – the index value of 0.25 is less than the “vulnerable” classification. The California Forest Practice Act (initially passed in 1973) regulates forestry on private lands and is recognized as the most stringent set of regulations for private land forestry in the country. The regulations apply to all timber sales on all lands – industrial and small, family forests – although the requirements differ. The forest practice rules limit clearcut opening sizes, require retention, have strict buffer zones around water courses and provide for threatened species.

Figure 10. Protected areas in the Northern California Coastal Forests ecoregion. The ecoregion is outlined in red, fully protected designation (national park, wilderness, etc) is dark-green shaded; lower category protected areas (e.g. US national forest) is light-green. Willamette Valley Forests - Protection The ecoregion is woepoor in terms of protected areas, with less than 2% of the ecoregion enrolled in a protection scheme23 and less than 1% is in high-level protection15 (see Figure 11). Additionally, the levels of protection are at the “critical” classification according to the conversion/protection metric23; 64% of the ecoregion has been converted. However, the primary


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threat to the ecoregion is urban/suburban development and fire suppression – logging is not noted as a concern. Only 0.1% of the grasslands and oak savannas of the area remain and because of fire suppression, the undeveloped sections of the savanna are converting to forest. Serpentine savannas in the area are the reason this ecoregion is noted as primary importance for conservation and maintenance of these areas is contingent on proper management. Many silvicultural efforts are underway to restore both native oak savannah and oak woodland habitat; these treatements generally focus removals on Douglas-fir that has invaded stands maintained by fire. It does not seem that wood harveste in the ecoregion is not responsible for threats to HCVs.

Figure 11. Protected areas in the Willamette Valley Forests ecoregion. The ecoregion is outlined in red, fully protected designation (national park, wilderness, etc) is dark-green shaded and less stringent protection is noted in light-green. The following states/provinces were flagged for assessment of protection levels for intact forest-based HCVF (Criterion 3.2). Idaho, Washington, Oregon, California and British Columbia have been flagged for protection of Intact Forests. As depicted in the figures below (Figures 12-17), nearly all of the identified Intact Forests20-,21,22,23 in these states are within highest level protection as wilderness or national park.

Figure 12. Greenpeace identified Intact Forest Landscapes in Northern California. The Intact Forests is the red area. Forest Service Wilderness Areas lands are green-shaded. The intact forests identified in Northern California are all under federal ownership and in a high level of protection as wilderness.


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Figure 13. Greenpeace identified Intact Forest Landscapes in Oregon. The Intact Forests is the red area. Forest Service Wilderness Areas lands are green-shaded. The intact forests identified in Oregon are all under federal ownership and in a high level of protection as wilderness.

Figure 14. Greenpeace identified Intact Forest Landscapes in Washington. The Intact Forests is the red area. Forest Service and Park Service Wilderness Areas lands are green-shaded. The intact forests identified in Washington are nearly all under federal ownership and in a high level of protection as wilderness. The area labeled as Olympic Wilderness is primarily under Park Service management, but the area includes Forest Service Wilderness areas that are unlabeled (Mount Skokomish Wilderness, The Brothers Wilderness, Colonel Bob Wilderness, and Buckhorn Wilderness). The area labeled as Mount Baker Wilderness (NPS) is adjacent to the unlabeled Noisy-Diosbud Wilderness (USFS). Nearly all of the small portions of the Intact Forest that are not designated wilderness pertain to National Forests (Okanogan NF, Mount Baker NF, Snoqualmie NF, and Wenatchee NF).

Figure 15. Greenpeace identified Intact Forest Landscapes in Idaho. The Intact Forests are the red areas. Wilderness designations from US Forest Service and Park Service lands are green-shaded. The intact


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forests identified in Idaho are nearly all under federal ownership and are generally well-protected. Almost all of the areas of intact forest that are not in wilderness designation are in federal ownership.

Figure 16. Greenpeace identified Intact Forest Landscapes in SE Alaska. The Intact Forests are the red areas. Wilderness designations from US Forest Service and Park Service lands are green-shaded. All of the intact forests in the procurement area are under federal ownership and the majority of intact forests identified in SE Alaska are strictly protected.

Figure 17. Greenpeace identified Intact Forest Landscapes in the British Columbia Mainland Coastal forests, Central Pacific Coastal Forests, and Cascade Mountains Leeward Forests ecoregions with focus on British Columbia. The Intact Forests are the red areas. Top level protection as wilderness or park is shaded in green. There are significant amounts of intact forests identified in BC that are included in forest tenures and that are not protected. See discussion below. Although it is difficult to discern in Figure 17 above, the representation of Intact Forests in the Cascade Mountains Leeward Forests and the Central Pacific Coastal forests ecoregions is excellent. The larger sections of Intact Forest that are depicted as unprotected above are in the British Columbian Mainland Coastal Forests ecoregion. FSC-Canada has communicated that the Pacific Coast Rainforest ecoregion (WWF Global 200 – comprising the British Columbia Mainland Coastal forests and Central Pacific Coastal Forests ecoregions) can be considered LOW RISK due to the recent conservation agreements of the Great Bear Rainforest. This agreement between environmental groups (ForestEthics, Greenpeace, Sierra Club of Canada, The Nature Conservancy, and others), the forest industry, and provincial and national government led to the groundbreaking conservation plan. The plan includes new legislation designed to protect the HCVs (intactness, rare species, old growth, roadless areas, etc.)


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in the region. The results of this agreement are not captured in the figures above due to the timeliness of the agreement.

C.6 Determination of Criteria 3.1 and 3.2

We conclude that the district of origin is at LOW RISK in relation to threat to High Conservation Values due to compliance with a combination of Criterion 3.1 and 3.2. Our determination is based on the following conclusions:

1. Fourteen ecoregions (Blue Mountains forests; Cascade Mountains leeward forests; Central and Southern Cascades forests; Eastern Cascades forests; North Central Rockies forests; Okanagan dry forests; Puget lowland forests; Queen Charlotte Islands; South Central Rockies forests; Palouse grasslands; Pacific Coastal Mountain icefields and tundra; Montana Valley and Foothill grasslands; Fraser Plateau and Basin complex; and the Snake-Columbia shrub steppe) were NOT identified to be part of any areas designated for measurements of high biodiversity, endemism, or accumulations of rare or endangered species. Wood harvested in these ecoregions can be considered LOW RISK following guidance from Annex 2.

2. Six ecoregions (Klamath-Siskiyou Coniferous Forests; Central Pacific Coastal Forests; North Pacific Coastal Forests; British Columbia Mainland Coastal Forests; Northern California Coastal Forests; and Willamette Valley Forests) were included in prioritization schemes due to high levels of species diversity and endemism. Five of these were flagged for further assessment at their levels of protection and Criterion 3.2. The North Pacific Coastal Forests was assessed to be in relatively stable/intact status and, thus, in reference to the Controlled Wood standard, was considered to exhibit LOW RISK.

3. Further investigation of the Klamath-Siskiyou Coniferous, Central Pacific Coastal forests, British Columbia Mainland Coastal forests, and Northern California Coastal forests indicates that biodiversity-based HCVs are adequately protected by the extensive protected area system represented in the ecoregions. In all four ecoregions there is sound representation in highest level protection schemes and additional strong representation in moderate protection schemes. All ecoregions have low (less than “vulnerable”) conversion/protection ratios indicating that the protection is relatively secure. Additionally, given the current climate of public land use and the regulations addressing forestry on private lands in Washington, Oregon, and California, the wood procured from these ecoregions can be considered LOW RISK.

4. The Willamette Valley forests ecoregion presents a different case. There is very poor representation of the ecoregion in protection (less than 1% in high level protection) and the area has experienced tremendous conversion historically (approximately 64%). The ratio of conversion to protection led to classification of the ecoregion as “critical.” However, the identified HCVs associated with this ecoregion surround grasslands, oak savannas, and serpentine flora. The oak savanna is disappearing from the ecoregion due to urban/suburban development along with repression of fire which leads to encroachment from conifers. It is highly unlikely that any forestry activities in the ecoregion are leading to further disruption of the noted ecoregional HCVs, and, thus wood coming from the area should be considered LOW RISK.

5. There are no WRI/Global Forest Watch defined Frontier Forests in the procurement area.


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6. The Greenpeace defined Intact Forests in the procurement area in the United States are nearly all entirely protected in highest level protection schemes as wilderness and national parks. The Central Pacific Coastal forests and Cascade Mountains Leeward forests ecoregions both have Intact Forests identified in their Canadian portions, but these areas are well-protected and well-represented in high level conservation schemes.

7. The British Columbia Mainland Coastal Forests ecoregion has extensive areas of Intact Forests that until recently were unprotected and at risk from forest operations. In 2006, a collaborative agreement was announced to protect the Great Bear Rainforest area. This agreement has resulted in altered forest practices and increased protected areas. In light of this agreement, FSC Canada has communicated that they believe wood coming from this ecoregion can be considered LOW RISK.

C.5 Preliminary Determination of Criterion 3.1 and 3.2

One can conclude that wood in the district of origin is at LOW RISK in relation to threat to High Conservation Values due to compliance with a combination of Criterion 3.1 and 3.2. This determination is based on the following conclusion:

Although five ecoregions were included in WWF G200, CI Hotspots, and/or IUCN Centre of Plant Diversity prioritization due to high levels of species diversity and endemism, there currently is LOW RISK to further impact on the High Conservation Values of these ecoregions. Due to changes in legislation and priorities for conservation on public land within the region, there has been virtually no logging on public lands24.

D) Wood harvested in forests being converted to plantations or non-forest use

Summary of Findings

We conclude that within the district of origin, there is LOW RISK in regards to forest conversion. We note some concern in the Puget Trough ecoregion (in Washington) and will continue to monitor any available data.

Assessment

The process of determination of risk in the category of conversion is through analysis of data assessing forest cover over time. Identifying a state or a county as having rates of conversion above 0.5% per year does not necessarily define a region as high risk. The Controlled Wood risk criteria identify an area as high risk if the rate of loss of forests exceeded this rate in the ecoregion. Data for these best estimates of conversion rates were provided by the US Forest Service for the United States and by FSC-Canada for British Columbia. The standard defines ecoregion as:

“A large area of land or water that contains a geographically distinct assemblage of natural communities that:

1. Share a large majority of their species and ecological dynamics; 2. Share similar environmental conditions, and; 3. Interact ecologically in ways that are critical for their long-term persistence.”

U.S. Forest Service ecosystem districts or provinces meet the elements of this definition and were therefore used in this analysis due to the availability of data on forest cover change over


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time52. A risk assessment at the district level would be valid to assess the criterion for conversion; however, for this risk assessment, the analysis was performed at a finer scale.

Figure 18. Ecosystem provinces of the United States as defined by the U.S. Forest Service25.

One particular note pertaining to using the USFS data should be discussed. There is some disparity between the FSC definitions for natural and plantation forests and the definitions used by the USFS in categorizing forestland. In the US West, virtually all tree plantings are for general forestry rather than the purpose of single-species high-yield fiber farming. There is a single exceptions east of the Cascades where a large block of hybrid poplars have been planted; this plantation is FSC-certified. Oregon The following is used as a best estimate of forest trends in Western Oregon26 and includes provinces 242, M242, and M261.

Year 242 ac. M242 ac. M261 ac. Percent Change

1973 819,468 5,948,505 2,151,351

1982 794,439 5,902,135 2,108,707 -2%

1994 787,487 5,878,947 2,090,629 -1%

2006 785,633 5,873,378 2,088,772 0%

2005 781,461 5,869,670 2,084,601 0% (table excerpted from Gary Dodge’s communications with D. Azuma26). The ecoregions underwent significant loss of wildland forest in the late 1970s and early 1980s., lessening in the 1990s. Since 1994, there has been negligible loss of forest cover. It should be noted this assessment excludes forests owned by the federal government. The assessment was conducted under the recognition that conversion from natural forests on federal lands in the ecoregion does not occur. Since there are large sections of National Forest in the provinces, these estimates should be viewed as overestimates of land-cover change. Eastern Oregon Wildland Forests

The USFS data is not available for Eastern Oregon provinces 342 and M332. However, the Oregon Department of Forestry, jointly with the US Forest Service, published an assessment of land use in Eastern Oregon spanning from 1975 to 200127. This report indicates that, excluding


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federal lands, wildland forest coverage in Eastern Oregon is well-below the FSC controlled wood threshold of -0.5% annual change in forest cover.

Year acres Change Annual percent change

1975 3,349,000 1986 3,329,000 1975-1986 -0.06%2001 3,307,000 1986-2001 -0.04%

(table excerpted from Lettman, et al. 200455). Washington

The following data, which encompass the state of Washington, provide evidence for forest cover changes. Baseline data was collected between 1988-1990 and then again in 2001. To ensure a conservative risk assessment we used an estimate of annual forest cover loss, based on a ten-year data period.

Estimated loss of forest land (timberland, non-productive forest, and reserved forest) to non-forest land use for all owner classes, Washington, 1988-90 to 2001.

Description of change Other public

Forest industry

Other private

Annual change

(area reported in thousands of acres) All Washington Net loss of forest area: 0 65 242 Forest area in 2001 12,414 4,530 4,833 Percent loss of forestland: 0.0 1.4 4.8 -0.14% Blue Mountains (M332g) Net loss of forest area: 0 0 0 Forest area in 2001 256 14 46 Percent loss of forestland: 0.0 0.0 0.0 0% Columbia Basin (342i) Net loss of forest area: 0 0 0 Forest area in 2001 83 9 293 Percent loss of forestland: 0.0 0.0 0.0 0% Eastern Cascades (M242c) Net loss of forest area: 0 0 12 Forest area in 2001 782 299 652 Percent loss of forestland: 0.0 0.0 1.8 -0.07% Northern Cascades (M242b) Net loss of forest area: 0 8 0 Forest area in 2001 4,852 542 272 Percent loss of forestland: 0.0 1.5 0.0 -0.01%


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Okanogan Highland (M333a) Net loss of forest area: 0 0 22 Forest area in 2001 1,917 455 1,752 Percent loss of forestland: 0.0 0.0 1.2 -0.05% Washington Coast Range (M242a) Net loss of forest area: 0 11 11 Forest area in 2001 1,907 1,625 583 Percent loss of forestland: 0.0 0.7 1.9 -0.06% Palouse Prairie (331a) Net loss of forest area: 0 0 0 Forest area in 2001 7 0 26 Percent loss of forestland: 0.0 0.0 0.0 0% Puget Trough (242a) Net loss of forest area: 0 31 186 Forest area in 2001 449 593 1,012 Percent loss of forestland: 0.0 5.0 15.5 -0.96% Western Cascades (M242b) Net loss of forest area: 0 14 10 Forest area in 2001 2,159 993 172 Percent loss of forestland: 0.0 1.4 5.6 -0.07% Willamette Valley (242a) Net loss of forest area: 0 0 0 Forest area in 2001 4 0 25 Percent loss of forestland: 0.0 0.0 0.0 0%

(table excerpted from Gary Dodge’s communications with Andrew Gray, USFS28). The single ecoregion that returned a risk value of higher than the FSC controlled wood threshold was the Puget Trough ecoregion. This area experienced a 0.96 % per annual loss of forest in the study period. However, according to a report issued by the American Hardwood Export Council (AHEC):

“Given the evidence that this is higher than the low risk threshold set by FSC, there are risk mitigation considerations that could accompany a risk assessment for hardwood purchases from within the Puget Trough ecosection. The most significant hardwood species exported from the Puget Trough is red alder. While the range of red alder overlaps broadly with the Puget Trough, as well as the Pacific Lowland Mixed Forests province and the adjacent province (M242), most is grown and harvested in managed timber stands. The most recent published studies of timber resource statistics grouped for all counties in the eastern and western portions of Washington show only minor reductions in forest (or timberland) area between the late 1980s and the early part of the current decade. In addition, approximately


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20% of the red alder in western Washington is produced from state lands, not at risk of forest conversion.”

In the CWRA for Cascade Hardwoods (SW-CW-2425), it is stated that:

“While the gross acreage of non-industrial (NIPF) forests remained stable, it appears that ownership patterns are shifting as some lands are purchased from industry while other lands, especially those areas close to the urban interface and transportation corridors, are being sold for non-timber uses. Non-industrial private net conversion remained small changing from -0.08%/yr average in the 1980s to -0.06% in the 1990s.”

Additionally, the CWRA for Columbia Vista Corporation (SW-CW-002444) concludes that the Puget Lowland Forests ecoregion should be considered low risk in regards to conversion. We recognize the need to track the usage of non-FSC wood sourced from the Puget Trough. We will continue to monitor conversion data for this ecoregion. California and Alaska

FIA data for California addressing conversion rates are not yet available as they are for Oregon and Washington. However, due to the rigorous California laws addressing forest practices on private lands (California Forest Practice Rules) and the preponderance of public lands in the ecoregions included in the procurement area, we come to the conclusion that the risk to conversion from California and Alaska is low. The California forest practice rules do not allow conversion from forest to non-forest to take place without special applications. These applications are thoroughly checked and verified by the California Department of Forestry. Thus, there can be small instances of conversion for development purposes, but the procurement area encompasses none of the major metropolitan areas in California. Additionally, the very high percentage of public lands in the USFS province (M261) (see above notes in HCVF section) further lowers the risk of high levels of conversion in the region. British Columbia, Nova Scotia and New Brunswick

The following guidance is provided by FSC-Canada addressing conversion of Canadian forestland29:

“Total annual deforestation in Canada is estimated as ranging between 54,600 and 80,500 hectares annually. Based on a total national forest area of 418 million hectares, this amounts to an annual deforestation rate as high as 0.019%, or 1/25th of the international threshold. Deforestation rates in Canada are not broken down by ecoregion. It is not known if the deforestation rates in any ecoregion might potentially be more than 25 times higher than the average national rate; if so it would be restricted to ecoregions in highly urbanized areas.”

As far as FSC-Canada has stated, the best available data for this factor is at the country level. There is a single major urban area (Vancouver, BC) in the assessment area, and the metropolitan area falls within the Puget Lowland Forests ecoregion (analogous to the Puget Trough region noted for Washington State). The US portion of the ecoregion is flagged to be not low risk. Although excellent data are not available for claims of low risk in the Georgia Basin area (the


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Canadian portion of the ecoregion), the guidance provided by FSC-Canada leads to low risk. We address the ecoregion in its entirety (with focus in the US) in the Washington section.

E) Wood from forests in which genetically modified trees are planted Summary of Findings

One can come to the conclusion that wood in the district of origin is LOW RISK in relation to threat of GMO trees use through compliance with Criterion 5.a. This determination is based on the following:

1. No GMO species used in paper production has been approved for commercial use in U.S. 2. NEPCon’s Global Forest Registry Risk concludes that forests in the U.S. and Canada are at

low risk for genetically modified trees. Assessment

According to a report by the UN’s Forestry Department of Food and Agriculture Organization, there is no commercial genetically modified trees being used in the US or in Canada.30 While there have been experimental trails in the U.S. of GM trees, no species is used in production of wood products has been approved for commercial use. Therefore, it can then be concluded that the district of origin can be considered to be low risk in relationship to wood being sourced from forests in which genetically modified trees are planted. This issue can be monitored in the future for a change in the status of GM trees in the US and Canada. References: 1American Hardwood Export Council. 2008. Assessment of Lawful Harvesting & Sustainability of US Hardwood Exports. Accessed online: August 14, 2009. www.ahec.org/publications/AHEC%20publications/AHEC_RISK_ASSESSMENT.pdf 2Transparency International. 2008. Corruption Perceptions Index Regional Highlights: Americas. Berlin, Germany. 3Forest Stewardship Council. Implementation of FSC Controlled Wood requirements in FSC STD-40-005 V2-1 and FSC-STD-20-011 V1-1. Accessed online August 14, 2009. http://globalforestrisk.nepcon.net/files/FSC-ADV-40-016_V1-1_EN_Implementation_of_FSC%20ControlledWood.pdf. 4World Bank. Governance Matters 2009. Worldwide Governance Indicators, 1996-2008. Accessed online: August 14, 2009. http://info.worldbank.org/governance/wgi/index.asp. 5Global Witness. Accessed online August 14, 2009. www.globalwitness.org/pages/en/forests.html 6United States Agency for International Development. 2005. Conflict Timber: Dimensions of the Problem in Asia and Africa Volume I Synthesis Report. Accessed online: August 14, 2009. www.usaid.gov/our_work/cross-cutting_programs/transition_initiatives/pubs/vol1synth.pdf


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7International Labour Office. 2006. Global Child labor trends 2000 to 2004. Accessed online: August 14, 2009. www.ilo.org/ipecinfo/product/viewProduct.do;?productId=2299 8American Hardwood Export Council. 2008. Assessment of Lawful Harvesting & Sustainability of US Hardwood Exports. Accessed online: August 14, 2009. www.ahec.org/publications/AHEC%20publications/AHEC_RISK_ASSESSMENT.pdf 9World Wildlife Fund. 2006. Global ecoregions. Washington, DC. Accessed online: May 21, 2009. http://www.worldwildlife.org/science/ecoregions/item1847.html. 10Ricketts, T.H., et al., Terrestrial ecoregions of North America: A conservation assessment. 1999, Washington, DC: World Wildlife Fund, Island Press. 11IUCN - Smithsonian. 2001. Centres of Plant Diversity - North American Serpentine Flora. Washington, DC. Accessed online: May 21, 2009. http://www.nmnh.si.edu/botany/projects/cpd/na/na16e-25.htm. 12IUCN - Smithsonian. 2001. Centres of Plant Diversity - California Floristic Province. Washington, DC. Accessed online: May 21, 2009. http://www.nmnh.si.edu/botany/projects/cpd/na/na16.htm. 13Olson, D.M. and E. Dinerstein, The Global 200: Priority Ecoregions for Global Conservation. Annals of the Missouri Botanical Garden, 2002. 89. 14World Wildlife Fund. 2001. Global 200 Map. Washington, DC. Accessed online: May 21, 2009. http://www.worldwildlife.org/science/pubs/g200.pdf. 15World Wildlife Fund. 2001. Willamette Valley forests (NA0417). Washington, DC. Accessed online: May 11, 2009. http://www.worldwildlife.org/wildworld/profiles/terrestrial/na/na0417_full.html. 16World Wildlife Fund. 2001. Klamath-Siskiyou forests (NA0516). Washington, DC. Accessed online: May 11, 2009. http://www.worldwildlife.org/wildworld/profiles/terrestrial/na/na0516_full.html. 17Conservation International. 2007. High-biodiversity Wilderness Areas. Washington, DC. Accessed online: May 11, 2009. http://www.conservation.org/explore/priority_areas/wilderness/pages/default.aspx. 18World Resources Institute. Bryant, D., D. Nielson, and L. Tangley. 1997. Last frontier forests: Ecosystems and economies on the edge. Washington, DC. High-biodiversity Wilderness Areas. Accessed online: May 11, 2009. http://forests.wri.org/pubs_description.cfm?PubID=2619. 19Global Forest Watch. 1997. Frontier Forests - Interactive Map of North America. Washington, DC. Accessed online: May 11, 2009. http://www.globalforestwatch.org/english/interactive.maps/northamerica.htm. 20Greenpeace. 2006. The World's Last Intact Forest Landscapes - concepts and criteria. Washington, DC. Accessed online: May 11, 2009. http://www.intactforests.org/concept/concept.htm.


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21Greenpeace. 2006. Roadmap to recovery: The World's Last Intact Forest Landscapes. Washington, DC. Accessed online: May 11, 2009. http://www.intactforests.org/. 22Conservation Biology Institute. Heilman, G.E.J. and J.R. Strittholt. 2002. Klamath-Siskiyou Private Lands Conservation Assessment. Corvallis, OR. 23Hoekstra, J.M., et al., Confronting a biome crisis: global disparities of habitat loss and protection. Ecology Letters, 2005. 8. 24New Zealand Government. 2001. Indigenous West Coast forests transferred to DOC - Press Release. Accessed online: May 11, 2009. http://www.scoop.co.nz/stories/PA0105/S00649.htm. 25US Department of Agriculture, Forest Service, Ecosystem provinces of the United States as defined by the U.S. Forest Service. www.fs.fed.us/land/ecosysmgmt/colorimagemap/ecoreg1_provinces.html. 26Azuma, D., FIA Research Forester, USDA Forest Service. 2008: Portland, Oregon. 27US Department of Agriculture, Forest Service, Pacific Northwest Research Station and the Oregon Department of Forestry. Lettman, G.J., et al. 2004. Land use change on non-federal land in Eastern Oregon, 1975-2001. Salem, Oregon. 28Gray, A., FIA Research Forester, USDA Forest Service, PNW Research Station. 2008: Corvallis, Oregon. 29FSC-Canada. 2007. Controlled Wood Information Matrix – Rolling Draft 1.0 September 2007. Accessed online: May 11, 2009. www.fsccanada.org/ControlledWood.htm. 30FAO, 2004. Preliminary review of biotechnology in forestry, including genetic modification. Forest Genetic Resources Working Paper FGR/59E. Forest Resources Development Service, Forest Resources Division. Rome, Italy. (available at http://www.fao.org/docrep/008/ae574e/ae574e00.htm)

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