An independent observer of the Forest Stewartship Council

Certification of monoculture tree plantations - open letter to FSC membersTags: Plantations

"Plantations are monocultures, created from seemingly endless rows of identical trees. They suck the water out of nearby streams and ponds and lower the water table, leaving little or no water for people living near the plantations. They deplete soils, pollute the environment with agrotoxics and eradicate biodiverse local ecosystems. Activists in Brazil call them the green desert because of the way they destroy local people's livelihoods and environments. But what's almost as bad as the plantations themselves is that this sort of plantation is given a green seal of approval by the Forest Stewardship Council."

This comes from a new World Rainforest Movement briefing titled "FSC certification of tree plantations needs to be stopped". The briefing is timed to coincide with the FSC's General Assembly, which will take place from 3-7 November 2008 in South Africa.

download the pdf file

Despite the fact that FSC has been carrying out a "Plantations Review" for the past four years, FSC continues to certify some of the most destructive plantation operations in the world. In an attempt to change this, a number of organizations from countries impacted by FSC-certified plantations have written an open letter to FSC members. If you wish to support local communities struggling against tree plantations, please sign on to the letter by filling out the form on WRM's website or by sending an email to .org.uy, before 31 October 2008.


The undersigned wish to urge members of the Forest Stewardship Council (FSC) to urgently resolve the serious problem of FSC certification of monoculture tree plantations, at the FSC general assembly to be held in Cape Town, South Africa.

One of the topics for discussion at the general assembly is a Review of FSC Principles and Criteria, and there is therefore an opportunity for changing those principles in such a way as to exclude the certification of monoculture tree plantations by FSC.

FSC members -particularly from the environmental and social chambers- must be made aware that certification of that type of plantation is not only eroding the FSC's credibility but -more importantly- that it is undermining local people's struggles against plantations.

Those peoples are struggling to protect the same things that FSC members from environmental and social organizations agreed needed to be protected when they joined the FSC: indigenous, traditional and peasant communities' rights and livelihoods; forests, grasslands and wetlands; water, soils and biodiversity.

All large scale tree plantations impact heavily on most -and usually all- of the above. There is now more than sufficient documented evidence of those impacts in a large number of countries, ranging from South Africa and Swaziland to Brazil, Colombia, Chile, Ecuador, Uruguay, Spain, Ireland and others.

The obvious conclusion must be that large scale tree monocultures are uncertifiable.

In spite of that, time and time again FSC-accredited certifiers have awarded the FSC seal to them. Little has mattered that those plantations were being opposed by local communities and that the FSC label would result in further strengthening already very powerful companies whose activities are destroying Nature and peoples' livelihoods.

Four years after having launched the FSC Plantations Review, nothing has changed. In spite of abundant documentation demonstrating the negative social and environmental impacts of plantations, there are currently at least 8.5 million hectares of plantations already certified, as well as an unknown area within the 37.7 million hectares grouped under the category "semi-natural and mixed plantation and natural forest", which hides a large number of plantations.

The time has now arrived for FSC members -particularly from the social and environmental chambers- to take sides: to continue to allow business as usual, or to fight for change; to protect the interests of large pulp and timber corporations or the rights of local peoples and Nature; to carry on accepting that plantations are a "type of forest" or to agree that they have nothing in common with them; to greenwash a most harmful land-use, or to oppose social and environmental destruction.

We therefore call on those FSC members who share with us the desire to protect local peoples and Nature from the damage caused by the expansion of tree plantations to raise their voices at the upcoming general assembly and to help bring about the change that is needed.

Centro de Estudos e Pesquisas para o Desenvolvimento - CEPEDES Brazil

Federação de Órgãos para Assistência Social e Educacional - FASE Brazil

CENSAT-Friends of the Earth Colombia

COECOCEIBA Friends of the Earth Costa Rica

Observatorio Latinoamericano de Conflictos Ambientales - OLCA Chile

Acción Ecológica Ecuador

Asociación pola Defensa da Ria - APDR Spain

Asociación para a Defensa Ecolóxica de Galicia -ADEGA Spain

Federación Ecoloxista Galega - FEG Spain

Grupo Guayubira Uruguay

Pesticides Action Network PAN Uruguay

REDES - Friends of the Earth Uruguay

Timberwatch Coalition South Africa

World Rainforest Movement

Further information on the destructive nature of industrial tree plantations is available on WRM's website.


All very well - but isn't this is bit naive? What exactly does anyone think FSC is going to certify when its Chairman works for one of the biggest plantation companies in Brazil??

The Chairman of the International Board of FSC, Roberto Waack - works for the Orsa Group in Brazil which owns big eucalyptus plantations.

See http://www.fsc.org/bod.html
and http://www.orsaflorestal.com.br/

thanks, this will help me in my< work a lot....! No wonder
Dont worry about FSC, all seems to be normal! Grrrrrrh.

Another question: Did anybody know something about Andre de Freitas, the chairmann of the FSC gGmbH in Bonn/Germany?
Thanks for informations.

I think the author did not give us a critical details on how FSC certification is a problems. Did the author outline the bases that before FSC certification what was status on environmental, social and economic of the communities, which resulted in decline or deterioration of the above aspects. Even though they will be no certification, forest plantation will not stop hence poor communities will not benefit from the forest plantation.

Clowns to the left of me, Jokers to the right ------

What follows is relevant to the call of various correspondents on this site for the FSC to cease its involvement in certifying forestry plantations, tree farms if you prefer. It is not written from the same perspective as others on this site, and it does not relate to plantations in developing or third world countries; rather it has to do with the FSC’s derogations for chemical use in New Zealand, an advanced, wealthy country, and the conditions surrounding those derogations. Most of what transpired took place earlier this year, but seems to have been overlooked or, more likely, kept relatively quiet outside the FSC and NZ organizations concerned.

It is a story of ineptitude and un-professionalism, and is a salutary lesson about the stupidity of centralising opinion and attempted regulation in Bonn and Europe, on the opposite side of the world.

NZ forestry organizations submitted requests for derogations for the use of a number of chemicals in their plantations. These were for chemicals used for a long time in the establishment and maintenance of plantations in NZ, and included herbicides such as terbuthylazine, hexazinone and metsulfuron methyl, as examples, and 1080 poison. The derogations were generally granted, though with variable and sometimes contradictory conditions.

The Advisory Team and Pesticides Committee responsible for considering these derogations included Messrs Isenring, Neumeister and Verdoorn, and further detail about this process can be found on the FSC web-site. Isenring is from PAN UK, Neumeister from PAN Germany and Verdoorn from Birdlife South Africa. They all have, apparently, high academic qualifications to Ph D level.

I shall instance some of the absurdities arising from these deliberations.

Instead of using metsulfuron methyl, a broadleaf and woody weed herbicide usually used in combination with glyphosate, both as foliar knockdowns as a pre-planting cleanup procedure, and sometimes also combined with a residual herbicide such as terbuthylazine, this panel suggested to NZ that they should use picloram instead. This demonstrated the ignorance of the FSC so-called experts. Not only is picloram used at higher rates, it has a far higher toxicity rating, is also very residual in soil, is extremely mobile and kills trees. Its use would mean a prolonged period of at least a year, maybe longer, before the plantation could be established. Metsulfuron methyl has low toxicity, much less residual effect and very little if applied to kill existing weed, and is used at lower rates. Given some of the slopes in NZ, the use of picloram, apart from the fact that it would kill the plantation trees, would be disastrous in terms of potential downslope movement.

In the NZ response dated 30 May 2008, I quote the opening statement: ‘The members of the New Zealand (NZ) FSC Certified Forest Managers Cluster (Primary Appellants) and NZ pest management authorities (Secondary Appellants) wish to appeal the conditions of all recently approved pesticide derogations for NZ’.
With regard to picloram and other chemicals, again I quote from the response:
• ‘Recommending Hazardous Alternatives: The Advisory Team have also recommended pesticides that are environmentally inappropriate. For example, in terms of alternatives for Terbuthylazine and Hexazinone, the chemical Picloram that is suggested as a partial replacement is rated as more highly toxic than Terbuthylazine and Hexazinone by the WHO and NZ certificate holders will not consider using it. Terbuthylazine and Hexazinone are used for releasing young seedlings from competing weed growth. Picloram will kill the plantation crop and is therefore not an alternative. Additionally Picloram is quite residual and can last as long, if not longer, than Hexazinone and is at least as mobile in soil.
• Recommending Inappropriate Alternatives: Furthermore, many of the other recommended alternatives to Terbuthylazine and Hexazinone are broad spectrum and if used would kill the very plantation tree species they are being used to release.’

NZ has an extremely severe possum problem; this introduced Australian animal has caused massive defoliation of native forests and plantations. It has been estimated that there are some 70 million of these feral pests in NZ. Control of this pest has been with the use of 1080 (monofluoroacetate), which can be safely used as a broadcast bait because there are no native NZ species which will pick up the baits. However, of course, the FSC and its ‘expert’ anti-chemical panels believed that there should be a better way, and they came up with a doozy!

They recommended that NZ begin to train a particular falcon species to kill possums. These ‘experts’ (ornithologically so now apparently) overlooked a couple of rather salient points. Firstly, the possums are nocturnal, whereas the falcon is diurnal. Secondly, the possums are far bigger than the suggested bird. Thirdly, the falcon does not feed on possums!

The NZ members addressed the possum suggestion thus: ‘Threat to FSC Credibility: Many of the Advisory Team comments in both the Advisory Team’s recommendations–and the derogations themselves demonstrate their unfamiliarity with local NZ conditions. For example, to have publically documented the suggestion that NZ falcons be used as an alternative method of possum control must pose a severe threat to the credibility of FSC and its processes. Falcon do not prey on possum. Falcon are diurnal whereas possum are nocturnal and largely arboreal.’

In the 10-page response, the NZ members addressed failure after failure of the Advisory Team and Pesticides Committee under headings including the following basis for the appeal:
The Appellants find that the conditions of the derogations are impractical, inconsistent, based on erroneous assumptions, and technically poorly justified. The Appellants also consider the conditions to be outside the spirit of the pesticide policy and contradict the process contained in the Derogation Application Guidelines. What is evident is that the Advisory Team who provided advice to the Pesticides Committee had little or no familiarity with local NZ conditions and as a result the derogations appear to have been based on erroneous assumptions to the extent that many conditions around use, where permitted, are neither sensible nor logical.’

Other headings included:

Under General

Too Prescriptive
Inconsistent Outcome
Misinterpretation of Evidence
Balancing Stakeholder Responses
Ignoring Existing and Past Alternatives Trials
Unrealistic and Unfair Timeframe
Ignoring Information in the Applications
Communications and Drafts for Comment

Under Herbicides, in addition to the two paragraphs above:

Unrealistic and Unfair Timeframes

Under 1080:

Subject to Substantial Review: The derogation decision on 1080 ignores the most recent review of the use of 1080 in NZ by the Government body, the Environmental Risk Management Agency (ERMA).
Compromises Biosecurity and Safety: The decision also ignores the fact that the greatest use of 1080 within forests are by contractors required to carry out poisoning operations due to biosecurity threat to prevent the spread of bovine tuberculosis.
Misapplied Conclusions
Plantation Accessibility
Contrary to Protection of Endangered Species

There is much else in the document. I do not know if it has been posted on any web-site. There was also a response from Peter Thomson, Post Border MAF Biosecurity New Zealand, Ministry of Agriculture and Forestry, dated 30 May, to Frank Katto, Policy Officer FSC, Bonn, supporting the submission from the Certified Managers Cluster.

The FSC Advisory Team and Pesticides Committee, who came up with all the nonsense, have demonstrated a complete lack, not only of knowledge of NZ conditions, but of the responsibility to carefully consider facts. Instead it seems clear that they have quite deliberately allowed their belief system to over-ride appropriate use of any scientific training. There is no place for deliberations based on belief.

I understand that at the FSC General Assembly in South Africa, a large number of organizations have grave concerns about the viability of the FSC’s chemicals policy and criteria, and will be seeking to make it more pragmatic. The FSC does not recognise the national regulatory authorities in NZ or Australia, even thought these have been in existence in one form or another far longer than the FSC. Recognition by the FSC of such legislated bodies would seem to be a logical step.

I and many others have conducted exactly what we believe is the appropriate approach to the use of chemicals in plantations - continuous improvement research, which does not get recognition by the FSC, although they espouse it. Where trialing of new chemicals is concerned, there is no guarantee that any new chemicals will be acceptable to the FSC's criteria, and the fact is that some of the potential alternatives already developed are 'prohibited' by the FSC on specious, unscientific grounds.

There is a strong case for the FSC to accept that it lacks the necessary expertise to have any role in the regulation of the use of chemicals in plantations. Others, of course, suggest a complete divestment of FSC involvement in plantation certification.

Dr Barry Tomkins,
Victoria, Australia

Dear FSC Watch, dear Chris Lang
when you published the letter and call to FSC with all the signatures, it seems that you forgot to mention how WRM send a similar call to the last FSC General Assembly in 2005, and how it falsified the majority of the signatures, and how FSC received many angry letters and calls from stakholders distancing themselves from the content of the letter and call. It seemed then that falsifying the signatures did not happen by accident, and that WRM and the usual key players were well aware of it and may even have been involved in it and backing it. In case you still don't remember ask the attendants at the General Assembly and FSC about the case. I am sure they will remember!

If you claim to be transparent and credible - why don't you start doing yourself what expect from others.

Very best regards

Dear FSC Watch,

This is a response to Roger Miller’s post which says that “WRM send a similar call to the last FSC General Assembly in 2005” and that “it falsified the majority of the signatures”, which ends with an accusation to FSC Watch and Chris Lang saying that “If you claim to be transparent and credible - why don't you start doing yourself what expect from others.”

What follows is proof that all of Roger’s assumptions and accusations are wrong and particularly this one: “It seemed then that falsifying the signatures did not happen by accident, and that WRM and the usual key players were well aware of it and may even have been involved in it and backing it.”

Regarding what happened in 2005, it was a mistake from one of our staff which resulted in the wrong inclusion of three signatories (not “the majority” as Roger says). Those people, together with the others that signed on to the letter, had been participating in the elaboration of the open letter. Given that they didn’t express opposition to the final text when asked to, the WRM staff assumed –wrongly- that they endorsed it and therefore included their signatures. The procedure was obviously incorrect and we saw this as a very serious mistake. We therefore quickly reacted by sending the message below to both the FSC and to those whose signatures had appeared in the initial letter.

I hope the above clarifies the issue.

Best regards,
Ricardo Carrere
International Coordinator
World Rainforest Movement

From: Ana Filippini <anafili@wrm.org.uy>
To: director.office@fsc.org, accreditation@fsc.org,
director.office@fsc.org, accreditation@fsc.org,
finance.fundraising@fsc.org, human.resources@fsc.org

Subject: Open letter asking moratorium on certification to FSC

Copies to: <urgewald@urgewald.de>, "'Wally Menne'"
<chrislang@t-online.de>, "'Lydia Bartz'" <lydia@urgewald.de>,
<wac@geasphere.co.za>, <rcarrere@wrm.org.uy>,
<licania@racsa.co.cr>, "'Jutta Kill'" <jutta@fern.org>,
<saskia@gn.apc.org>, "'Maria Rydlund'" <Maria.Rydlund@snf.se>,
Godfrey Silaule <gsilaule@soft.co.za>, <lovera1@conexion.com.py>,
"Phillip Owen" <owen@soft.co.za>, "peter gerhardt, robin wood",
<tropenwald@robinwood.de>, L.vanderMaesen@geog.uu.nl

Send reply to: anafili@wrm.org.uy
Date sent: Fri, 21 Oct 2005 12:14:51 -0300
21 Oct 2005 12:14:51 -0300

Dear Sirs and Madams,

On October 4, I sent you a letter on behalf of several organizations. After the letter had been sent, some of the signatories let us know that there had been a misunderstanding and that their signatures should not have been included in the letter.

Please find below -and also attached- the letter again with the appropriate endorsements.

I'm very sorry for this misunderstanding.
Sincerely yours,
Ana Filippini

October 20, 2005

Open letter asking moratorium on certification to FSC

We, the undersigned environmental and social justice organizations,
call on the FSC to immediately institute a moratorium on the
certification and re-certification of industrial timber plantations,
until the findings and recommendations of the present "Plantations
Review" have been incorporated into the FSC certification system and
are being properly implemented.

Industrial timber plantations established as large scale chemical and
mechanical intensively managed monocultures, have a wide range of negative
environmental and social impacts that have not yet been adequately
assessed and comprehensively quantified, and that cannot therefore be
meaningfully mitigated against.

The problems caused by industrial timber plantations are often more
acute in the south, where trees grow fast and high yielding alien
plantations have rotation cycles as short as seven years. These short
rotations result in abnormally high depletion of soil nutrients, leading
to long term soil impoverishment, together with accelerated top-soil

In South Africa, more than 1 million hectares of industrial timber
plantations have been certified by the FSC and timber companies use
the FSC label to promote their products as "environmentally friendly". Yet
these plantations have been responsible for major impacts on the scarce
local water resource, lowering the groundwater table and drying out
countless wetlands, fountains and streams - which severely limit land use
options and thereby jeopardize rural people's livelihoods. All industrial
timber plantations in South Africa have been established in areas with the
highest rainfall and deepest soils, replacing valuable grasslands, and
disrupting or displacing the traditional communities that occupied those

Such problems are not confined to the south. In Ireland, the FSC has
certified extensive plantations comprising 90% exotic species, mainly
Sitka Spruce from North America - with apparent disregard for ecological
impacts and nature conservation principles.

The negative impacts associated with timber plantations (and FSC
certification thereof) have come increasingly under the spotlight
during the past decade. As early as 2001 the FSC position on
plantations was listed as an issue which needed clarification. In May,
2002 Tim Synott produced an FSC Plantation Policy Draft, which
acknowledged that "Disputes have arisen around plantation certification,
and some of the disagreements and confusion has been caused by different
interpretations of the FSC Principles and Criteria and other policies." At
the FSC general assembly in November, 2002, FSC members passed a motion
which stated that "The current version of the FSC Plantation Policy Draft
(30 May 2002) is not clear enough and needs improvement." The motion
continued to state that FSC should produce a revised plantation policy
"after a broad consultation with the membership" to give "concrete
guidance on the interpretation of P10 [principle 10]". This was to have
taken place within 18 months, i.e. by May 2004. In September 2004 the FSC
launched the present plantations review in Bonn.

Please provide full details of the area of Industrial plantations that has
been certified since November 2002 when the organization's membership
passed a motion which clearly stated that the FSC policy on plantations
needed improvement.

There is growing and justified opposition to the spread of industrial
timber plantations world-wide, and we cannot endorse continued FSC
certification of industrial timber plantations using the current flawed
principles and criteria. Therefore, the FSC board of directors must
suspend certification of industrial timber plantations until the review
process has been finalized and the broadly approved findings and
recommendations incorporated. It is essential that the social and
environmental concerns of the non-industry stakeholders are fully
addressed in this process. Continuing to certify industrial timber
plantations while the Review is in progress undermines the legitimacy of
the review and the reputation of the FSC.


Lydia Bartz
Urgewald, Germany

Peter Gerhardt
Robin Wood, Germany

Chris Lang
WRM Plantations Campaign, Germany

Philip Owen
Geasphere, South Africa

Godfrey Silaule,
Geasphere, South Africa

Wally Menne
Timberwatch Coalition, South Africa

Ricardo Carrere
World Rainforest Movement, Uruguay

please add me to your mailing list cheers .jon porter

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I am very happy that not everything online is garbage and junk. Thanks for the post.

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