New FSC rules for forest groups: a helping hand for family forests

Size matters

The revised rules take the question of size properly into account – both in terms of the size of individual operations as well as the number of group members. 

Several points serve to facilitate certification of small operations. 

These include reduced requirements for field visiting to each individual operation, in particular when small operations can be grouped into one group with certain shared characteristics (‘sets’). 

Furthermore, mixed groups of SLIMF and non-SLIMF operations have been allowed to follow the streamlined SLIMF procedures for sub-groups of SLIMF operations.

There is no limit on the number of group members or the size of individual operations – this is beneficial for small operations as inclusion into large groups or groups that cover larger operations typically reduces their cost of certification. On the other hand, FSC puts more control in place as the size of the group and/or the size of individual operations increases. FSC has even introduced a special risk approach to mega-groups consisting of over 5,000 members.

Landscape level approach

Another change is the introduction of the option to evaluate compliance at landscape level rather than for each individual group member. 

This can presumably sometimes be a help for the smallest operations in a group for which some requirements may seem out of proportion. For example, it may sometimes make more sense to apply requirements for a certain percentage of set-aside areas to the overall group, if some of the larger group members for some reason set aside more than 'their' share of forest.

The general approach of FSC towards the issue of size and the option to use a landscape level approach seem clever and appropriate; they help to facilitate certification of small family forests while maintaining the credibility of the FSC system.

Sampling frequency: Math matters, too

However, when it comes to the more specific part of the rules – the required frequency of on-site visits and checks of individual operations in the group - something appears to have gone wrong. 

The idea of group certification is that the group manager takes a key role in ensuring the group’s compliance with the certification requirements. As part of this task, the group manager will pay regular on-site visits to forests covered by the group certificate. During the annual audits, the certification body will focus on the group managers’ ability to manage the group and also carry out field visits - but typically to a smaller number of operations. 

This approach to on-site surveying reflects that the group manager has a continuous commitment towards the group throughout the year, while the certification body is normally only involved once annually. It also ensures that group certification is a viable and cost-effective alternative to individual certification.

However, except for the smallest operations, the new rules turn the approach to on-site sampling upside-down. For example, in the case of a group of 100 operations with sizes between 1,000 and 10,000 ha, the group manager is required to pay on-site visits to 10 operations per year, while the certification body must visit at least 20 forest management units during the annual on-site audits. If the size of the individual operations is above 10,000 ha, the group manager can still settle for only 10 on-site visits, while the certification body now needs to carry out 80 field visits per year.

This new approach seems rather absurd. It is the result of the use of a linear equation for the sampling frequency for certification bodies (in the accreditation standard), while the sampling requirements for group managers are based on the square root of the number of group members (in the standard for forest groups).  

Dividing the group members into sets of similar forest management units, as required by the new rules, also has some strange implications for the field sampling requirements. If you have a group of e.g. 10 members in the size class 1,000 -10,000 ha, then the certification body is required to visit 2 group members (20 pct) during each annual audit. However, if the group is divided into two “sets” of 5 members each, the CB is only required to visit one member, because of a rule saying that only 50 pct of the “sets” shall be visited. In other words, FSC requires increased sampling if the group members are homogeneous. We would have expected the opposite.

In short: The new requirements on sampling frequency do not seem very logical. And they are sure to increase the cost of certification for all but the smallest groups and operations due to the increased requirements for field visits carried out by the certification body.

The way forward

Despite the apparent inconsistencies seen in the rules for on-site sampling, we do welcome the new rules for group certification as they facilitate the certification of small family forests – a key priority for FSC. And they do so in ways that manage to protect the credibility of the certification process. 

As the next step, we recommend using ongoing initiatives to develop contractor certification as inputs to develop an FSC standard for contractor certification, as this may be a key tool in smallholder certification. 

We also recommend looking into the reporting requirements related to certification of small forests. But even here, some progress has actually taken place: As from the 1st of January 2010, there is no longer any requirement to translate public summaries of audit reports for SLIMF forests from local languages into Spanish or English.

Deadlines for compliance

Both of the new standards will come into force on the 1st of January 2010. Forest management groups already holding an FSC group certificate need to comply with the new rules by 1st of January 2011. They have the option to undergo evaluation according to the new rules already during their 2010 audit.