For any mid- to large-scale, and even for small-scale, forest certification projects, it is quite common for there to be many strongly-held points of view among interested stakeholders
SCS Global Services Correction to its rebuttal of misleading and inaccurate statements in Ecologist article
20th September, 2016
In response to a recent article published in the Ecologist, "Are the UK 'biomass sustainability standards' legitimising forest destruction?", SCS has prepared this point-by-point rebuttal to several misleading and inaccurate statements, and invites readers with additional questions to contact us directly.
All Certification Bodies working in the environmental field must necessarily tackle controversial issues on a regular basis.
SCS Global Services (SCS) is a widely respected independent third-party auditor and certification body that has operated since the mid-1980s. SCS is recognized by government agencies, international NGOs (e.g., World Wildlife Fund, Nature Conservancy), leading environmental certification schemes, companies and stakeholders worldwide for excellence, professionalism, and neutrality.
This is an amended/corrected version of the original rebuttal published on 5th September. Misleading Statement #4.4 has been amended (see below). The Ecologist has kept the original rebuttal statement here for reference purposes only.
Misleading Statement #1. "Drax's SBP auditors: Consultants with a track-record of granting controversial certificates
The certification company chosen by Drax is SCS Global Services ('SCS'), and it is no stranger to controversy."
1. The term "consultant" can confuse readers internationally and it simply does not accurately characterize SCS' role. SCS acts as a Certification Body (CB), providing independent, unbiased assessment of conformity with a set of standards. SCS does not act (and is not permitted to act) as a consultant - i.e., an entity that provides advice, tools and guidance to help a client succeed - for any company for which SCS is providing conformity assessment services.
2. All CBs working in the environmental field must necessarily tackle controversial issues on a regular basis. For any mid- to large-scale, and even for small-scale, forest certification projects, it is quite common for there to be many strongly-held points of view among interested stakeholders.
The CB's responsibilities include delving into the complex details of a company's operations, providing an avenue for employees to air any concerns without reprisal, and reviewing and considering all stakeholder concerns. Indeed, as a CB we are regularly evaluated by the accrediting body for our compliance with the Forest Stewardship Council (FSC) standard on stakeholder consultation.
The conformity assessment audit and reporting process provides extensive transparency (e.g., 50+ page public summary reports) into these issues, and includes corrective action requests as needed. To state that SCS is "no stranger to controversy" suggests that SCS is somehow unusual in this respect, and presented out of context, carries a very negative connotation. Every FSC CB, indeed every CB for any of the growing array of environmental certification programs operating around the world, is no stranger to controversy.
3. SCS is deeply knowledgeable about forestry standards and certification programmes. SCS representatives participated on the founding FSC board of directors, and SCS was among the first CBs to be accredited to issue FSC-endorsed certificates in the early 1990's.
Having conducted hundreds of FSC certification audits over 25 years, SCS has built and maintained a strong reputation as a technically competent auditing body with a deep and abiding commitment to the values, policies and procedures of the FSC. SCS has undergone numerous oversight (accreditation) audits throughout its 25-year affiliation with the FSC, and has maintained without interruption its status as a duly-accredited FSC certification body.
Misleading Statement #2. "Forest Stewardship Council (FSC) certificates awarded as a result of SCS assessments include:
- Certification of the Jari forestry project in Brazil from 2004. In 2015, the certificate was suspended after government authorities raided the company's offices on suspicion of massive fraud and illegal timber laundering. SCS had noted problems with the company's documentation but had chosen to certify them regardless;
- Certification of Green Diamond Resource Company in California, despite what the Environmental Protection Information Center described as ‘Green Diamond's aggressive clearcut logging, their legacy of toxic pollution, their decades long history of antagonistic relationships with local communities and civil society organizations, and their corporate culture of greenwash, impunity, and lack of accountability'."
1. SCS has conducted hundreds of FSC certification audits over 25 years. It is notable that the two examples highlighted by the author were pulled from the FSC Watch website, a small organization whose raison d'etre is to attack and seek to damage the reputation of the FSC, dating back to the 1993 FSC founding assembly, when FSC Watch's leader, Simon Counsel, declared open opposition to the FSC on the basis of key policies decisions with which he disagreed. Notably, FSC Watch posts anti-FSC stories on its website without any effort at corroboration, fact-checking or any other form of vetting. Does the editorial staff of The Ecologist really believe that such a website constitutes a fact-checked source confirming/validating the content of articles it publishes?
2. SCS does not, indeed cannot, make certification decisions on the basis of opinion or discretionary choice. Rather, as a CB, we are obligated to make certification decisions strictly on the basis of conformity to the applicable FSC certification standard(s). We have done so for 25 years in a manner that has withstood ongoing oversight by FSC throughout those years.
3. The FSC certification process involves extensive auditing, with a major, extremely detailed audit every five years and annual surveillance audits, all of which include documentation reviews and onsite inspections. That said, no certification system is perfect, which is why it is important for certification scheme owners and CBs to keep our ears to the ground for signs of trouble. When the allegations against Jari arose, even though these allegations did not directly pertain to lands under the scope of the FSC certificate, SCS took proactive measures by undertaking a special audit above and beyond the normally scheduled annual audit. On the basis of the special audit, SCS suspended 8 of the 10 FSC forest management and chain-of-custody certificates held by Jari. These certificates remain suspended, and can be lifted only if and when Jari provides verifiable evidence that it has corrected the issues that led to the certificate suspensions, and after SCS conducts another special audit to confirm these corrections.
4. The Green Diamond "controversy" described by the author reflects another uncorroborated and factually inaccurate screed posted on the FSC Watch web site, now over three years ago. While it still remains on the FSC Watch web site, nowhere on Environmental Protection and Information Center's (EPIC) web site is there any longer a single adverse mentioning of Green Diamond Resource Company. Indeed, both the EPIC Director and another staffer responsible for the irresponsible editorial, which was posted by FSC Watch uncritically and without corroboration on its website, have been severed from association with EPIC, in part over this very issue.
In stark contrast to the overblown, inaccurate and now very dated hit piece that the author cited in the Ecologist, EPIC and the larger community of Humboldt County, California now have a very much more collaborative and cooperative working relationship with Green Diamond though, as is intrinsically the case for most large-scale forest operations, there remain points of discussion and deliberation between Green Diamond and its stakeholders. Does The Ecologist's editorial staff believe it appropriate for its authors to rely on dated and, in this case, inaccurate materials that were never even casually vetted for factual accuracy?
Misleading Statement #3. "SCS spent a total of just seven hours inspecting logging operations across two overlapping areas from which Drax's pellet mills source wood, each with 3.9 million hectares of forest. The SCS reports largely summarise 'supply base' reports written by a Drax director."
1. The seven hours cited by the author are substantially out of context, and wildly understated relative to the time actually expended by SCS auditors on this multi-scheme project. As described in SCS' two Public Summary reports, our audit team spent 66 hours (8.25 days) auditing Drax's facilities against the SBP certification requirements.
This time count includes a thorough pre-assessment, full review of procedures and documents, and on-site/field portions (including interviews and physical inspections). The on-site/in-field portions alone comprised 45 hours (more than 5.5 days). This is time spent in addition to the time devoted to evaluating Drax against the requirements of FSC, SFI, and PEFC Chain of Custody (CoC) requirements. (It should be fully recognized that SBP certification can be achieved only when the organization/certificate holder also maintains certification to at least one of these three CoC standards: SBP is built upon the foundations of these other recognized certifications.)
2. The Supply Base Evaluation (SBE) conducted by Drax was not a requirement for its SBP certification, since all of their material inputs can be sourced with either an SBP-compliant or SBP-controlled claim. Drax voluntarily implemented this SBE program even though that measure exceeded the certification requirements. As a result, SCS was obligated to conduct our own field verification of their SBE; hence the seven hours spent at the forest level were entirely appropriate given this context. It is also worth noting that it is simply not feasible to inspect the entire acreage land area of any forest management operation. Field audits are always conducted on a sample-basis, with sampling and site selection processes taking into account variability in forest conditions across an ownership as well as risk factors in order to maximize the representativeness of the selected sample.
Misleading Statement #4. "A simple web search casts doubt on some of the claims accepted by SCS: For example, the certification report states that there are no IUCN Red List species (i.e. endangered or threatened species) in the wider sourcing region. In fact, there are 10 Red Listed species in Louisiana alone, including the Louisiana Pine Snake, which depends on Longleaf pine forests. Drax's own report shows that Longleaf pine forms part of the wood mix used by both pellet mills. According to IUCN, 'intensive pine silviculture', i.e. pine plantations, are one of two key threats to the species."
1. Here is another factual error. The Public Summary Report ["certification report"] does not state that "there are no IUCN Red List species (i.e. endangered or threatened species) in the wider sourcing region," as the author claims. Rather, SCS' public summary reports clearly state: "There is one International Union for Conservation of Nature (‘IUCN') Red List of Threatened Species that is worthy of note in Drax' supply region - Longleaf pine (pinus palustris). (emphasis added).
2. The important questions to ask are 1) whether or not any listed species are present in the sourcing area (not the whole state), and 2) if so, are they affected by the forest management activities?
There is no evidence that use of Longleaf pine, which constitutes only a tiny fraction of Drax' supply source, is negatively impacting Louisiana Pine Snake habitat. The de minimus volumes of Longleaf pine in Drax' supply base are more likely due to the efforts of forest managers reintroducing Longleaf pine into managed forests as a way to promote its restoration, since large stands of Longleaf pine have all but disappeared due to centuries of human activity in the region.
Again, as stated in SCS' public summary report: "This species [Longleaf pine] is far less common than it once was, and efforts are underway to promote longleaf pine coverage in the region.
The intent of listing species to the Red List is not to promote prohibition of their use but rather to heighten priority setting for conservation of the species (IUCN 2014). Critical to the recovery of the species is continued access to markets for longleaf pine. If landowners do not expect to be able to sell this wood, then they will not plant the tree in the first place. This position is captured in a statement from a USDA researcher and supported by the conservation group, the Longleaf Alliance:
"Strong markets for forest products provide incentives for private landowners to keep their lands in forest cover (Wear 2013). This is particularly important across the longleaf range where recent forecasts of human population and income growth point toward increasing pressure in some locations to convert forest land to other uses (Wear 2013). Strong markets also enable landowners to invest in the management practices required to establish longleaf pine forests and implement practices such as prescribed fire and thinning which are crucial restoration activities."
3. It is also misleading to suggest that SCS and Drax failed to conduct such a "simple web search." IUCN is identified by SBP in "Standard 1 - Feedstock compliance standard" as a resource for use in demonstrating conformance with several indicators in criterion 2.1 and 2.2 of the standard. Those criteria specifically focus on: identification and protection of species of outstanding or exceptional value; assessment and maintenance of high-conservation value forests, key ecosystems or habitats, and; protection of bio-diversity.
4. In addition to using IUCN's red list (as well as the High Conservation Value Network, Global Forest Risk Registry and CITES), as sources of information to determine risk, SBP requires that the certification body conduct a stakeholder consultation process. As part of SCS' stakeholder consultation process, several environmental organizations -including the Dogwood Alliance, Longleaf Alliance, Natural Resources Defense council, and the Sierra Club (Delta Chapter) -were contacted and given the opportunity to provide comments, feedback, and criticisms.
CORRECTION. In follow up to our recent posting, item #4.4, it was recently brought to our attention that our request for stakeholder feedback directed to the NRDC during the Main Evaluation Audit in 2015 did not get forwarded to the appropriate NRDC staff; hence, we did not receive comments from NRDC at that time. However, SBP does not limit stakeholder consultation to just the Main Evaluation and Re-Evaluation Audits. According to SBP Framework Standard 3: “Certification Systems Requirements for Certification Bodies,” clause 9.7, any comments we receive from stakeholders at any time regarding compliance with SBP requirements must be recorded and evaluated during or prior to the next audit, as appropriate. Since NRDC has recently informed us that they do have some concerns, SCS looks forward to receiving their stakeholder comments as part of the 2016 SBP 1st Annual Surveillance audits of Drax
5. Based on the species population data available on the IUCN website, the one species cited in the article (the Louisana Pine Snake) does not have extant populations within Drax's current supply area. Current populations of the species are located farther away than the 70-mile sourcing radius of Drax's facilities.
Misleading Statement #5. "Companies applying for a certificate choose their own auditor amongst the list of SBP-approved consultancies and pay them for their services. This creates a strong incentive for certifying consultancies to provide the desired service to their 'customers', and to be biased in favour of granting certificates. This is a generic problem of voluntary certification schemes.
The best 'sustainability' certificates money can buy
... Standards themselves are of little importance as long as companies can so easily pay another company for providing them with certificates to 'prove' compliance with those standards."
1. The implication of these statements, and the author's clear bias, is that certificates are "for sale." This ad hominem is patently untrue, and a clear attack on SCS' professionalism. Certification bodies such as SCS must comply with internationally accepted guidance to prevent conflicts of interest (ISO 17065), and must be accredited to FSC and PEFC. In SCS' case, our Assessment Services Agreement and all other relevant program documents explicitly clarify that the certification applicant can expect to receive a full and fair audit, but that there is no guarantee that the result of that audit will be a certification.
2. SCS performs services on a strict time-and-materials basis, and levies no "marketing" fees in association with the license of certification marks (as is the case with some bodies).
3. The ability of an applicant to choose a certification body from a list of SBP-approved CBs helps to assure that audits can be scheduled in a timely manner, and helps prevents monopolization and price gauging. It is quite common in voluntary certification programs around the world, for everything from organic agriculture to MSC certified fish.
4. In this instance, the SCS audit of Drax was also witnessed by third parties responsible for assuring that our audit was in full compliance with SBP principles and criteria.
For more information visit scsglobalservices.com
 IUCN Standards and Petitions Subcommittee. 2014. Guidelines for Using the IUCN Red List Categories and Criteria. Version 11. Prepared by the Standards and Petitions Subcommittee. Downloadable from http://www.iucnredlist.org/documents/RedListGuidelines.pdf.
 Wear, D. N. 2013. "Forecasts of Land Uses." Chapter 4 in Southern Forest Futures Project Technical Report.
 Longleaf Alliance and NCASI. 2014 "Longleaf Pine: Sustainable Forest Management and the Restoration of a Species" brochure.
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