Complaint to appeal the decision of the Re-Certification of Green Diamond Resource Company as in conformance with the standards and criteria of the Forest Stewardship Council (FSC) on December 24, 2018.
The Complaint and Appeal were presented to the independent certification company, Scientific Certification Systems (SCS), based in Emeryville, CA. SCS initially certified Green Diamond in 2012 amidst great local opposition and controversy, and then re-certified Green Diamond in early 2018.
FSC certification, monitoring, and issuance of additional specific criteria to maintain FSC conformance and certification, known as “Corrective Action Reports” are all conducted and administered by independent third-party certification companies, like SCS. SCS is also the certification company responsible for Humboldt Redwood Company’s FSC certification.
EPIC’s Complaint to SCS comes out of an investigation into Green Diamond’s re-certification under FSC for forest management and the legitimacy of Green Diamond’s network of “High Conservation Value Forest” (HCVF). FSC standards require certified companies like Green Diamond to establish and maintain an HCVF network of lands classified as “core-interior habitats,” and to voluntary conserve, enhance, and maintain all lands designated as HCVF.
EPIC found that Green Diamond is not including lands in its HCVF network that do not meet the definition of a “core interior habitat,” such as the Riparian Management Zones (RMZs) established along Class I and Class II watercourses on Green Diamond lands. These RMZs are thin strips of forested lands left behind after Green Diamond clearcuts. Even if Green Diamond’s RMZs are appropriate to include in its HCVF network, evidence found in SCS’s own audit and certification and re-certification reports indicates that the total acreage of RMZ accounted by the company as HCVF has steadily declined since 2012, and that thousands of acres once accounted as RMZ HCVF have not been maintained as HCVF and instead have been subject to active commercial timber management.
EPIC further found that Green Diamond was accounting something it calls, “NSO Core-Areas,” as HCVF. Aside from the fact that no clear definition of “NSO Core-Areas” seems to exist, there is also no indication of where these areas are located on the Green Diamond commercial timber landscape, or if they exist at all. And, if all that’s not suspicious enough, SCS’s own audit and certification reports show a steady decline in the acres accounted by Green Diamond as “NSO Core Areas” in its HCVF network since 2012. It appears that thousands of acres of “NSO Core Areas” once accounted by Green Diamond as part of its HCVF network have since been lost to active commercial timber management, which is expressly antithetical to the requirements to protect, enhance, and maintain lands designated as HCVF and to preclude active commercial timber management in such areas.
EPIC also Appealed Green Diamond’s re-certification by SCS under FSC standards on the basis that the company has not lived up to FSC standards or genuinely addressed Corrective Acton Reports calling on the company to create a program to solicit, intake, and integrate input into its management practices from a broad spectrum of public and community stakeholders. Green Diamond claims that the funding of local civic clubs and recreational community sports teams are sufficient to meet the letter and intent of FSC’s standards for intaking and integrating public stakeholder input. Suffice to say, EPIC disagrees.
SCS has initiated its process to formally investigate and respond to EPIC’s Complaint and Appeal of Green Diamond’s 2017-2018 re-certification under FSC’s standards and has promised to provide a full written response from its investigation within 90-days of the filing date.
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