Richard Z. Donovan, September 2024

In November of 2023 I offered some perspectives on the continuing evolution of the FSC system to FSC colleagues around the world – particularly founding and current members of FSC and other forest experts or aficionados. Following is an update on those previous thoughts, plus a couple additional items, as the FSC enters a year of planning and discussion in preparation for the upcoming FSC USA and Canada meetings in Nashville, Tennessee in October 2024, and looking towards the October 2025 FSC General Assembly in Panama.

Contrary to my original email, which went only to FSC members or advisors, I have decided to make these comments public for two major reasons. First, we are getting new leadership for FSC at the international level and for FSC Canada, we already have new leadership in the USA, and I am sure there are other leadership changes elsewhere in the FSC system. Second, I think the public wants FSC to respond, particularly due to the impact of climate, the role of forests, the role of forest-based products, and all the values in play.

Quick Introduction and Personal Background

As some of you know, I have been associated with the FSC since before its inception, starting with the November 1990 Woodworker’s Alliance for Rainforest Protection (WARP)-organized meeting in Northampton, Massachusetts, which set in motion a series of meetings and actions that would lead to the founding of the FSC in Toronto in October 1993. I have participated in all FSC General Assemblies and some regionally organized meetings in the Americas and Europe and have had the privilege of working with many FSC national representatives or initiatives over the years on all continents. I have been a part of numerous Working and Advisory Groups, led several FSC national or regional standards tests, and for many years was the Director of FSC-accredited certification program at the Rainforest Alliance (where I worked for 27 years – 1992-2019). Indeed, it was through FSC’s early design meetings that I met Ivan Ussach and Dan Katz of Rainforest Alliance and thanks to FSC’s early origin process, it was why I ended up at the Alliance. As of July 1, 2019, I “semi-retired”, now spending 50% paid time on numerous small contracts. I am a very independent forest advisor – something I truly enjoy, and hope provides value to forests and the communities that depend on them. I have the luxury of writing these observations without reporting to anyone. They are meant to be constructive thoughts for the betterment of FSC and fulfillment of its mission. 

The FSC is quite different in many ways (and now bigger!) from what I managed at Rainforest Alliance (with help from a lot of folks). But there are similarities. When I was at RA we took on the challenge of an international global scope program and decided to put in place a centrally located leadership and technical, quality control team, complemented by 12 different regional managers. We came to this structure after years of experimentation, first working with committed national and regional NGOs. On a day-to-day management level, approximately 80-90% of decisions were made in the regions, though we also held those regional offices accountable by providing policy and budget guidance on an ongoing basis, formally and regularly auditing technical, management and financial performance, and constantly trying to be as responsive and supportive as possible to the regions. Regional offices DID report to the global leadership, and senior staffing and budget decisions were made and monitored by the global HQ. NO system is perfect, and we faced many challenges. Central office staff traveled a lot (yours truly approximately 40% throughout), but this travel was to provide leadership and support, and troubleshoot challenging certification situations. I felt the system was effective. 

Opportunities for Positive Change in FSC’s Management

During the creation of the FSC (1990-1993), I was lucky to work with Francis Sullivan, Jamison Ervin, Tim Synnott, Charlie Walkinshaw, Robert Simeone, Yati Bun, Virgilio Viana, Marcus Colchester, Martha Nuñez and many others to explore the idea of FSC through multi stakeholder dialogues around the globe and funded by the McArthur Foundation and others. FSC creators were many – a core group of 30-50 people who were generally close to forests, close to communities – indigenous or otherwise – or close to the forestry and forest products business, including NGOs, forestry experts, companies, even sometimes behind the scenes government staff. The FSC that we see today, in my mind, is still a youthful organization, but now mature enough to listen and channel constructive criticism, and use it to improve. 

On structure and management, my observation is that FSC – with its many tentacles around the world – is too centralized in its management, doesn’t build enough on its regional and national capacities, and far too much of its decision-making is determined by centralized structures that obstruct the FSC’s success. This is manifest in a large number of FSC staff based in Germany, and a global Policy and Standards Committee (PSC) that often makes decisions (or recommendations) the PSC is ill-suited and informed about, and without strong regional staff who are inconsistently supported. The regional actors in the FSC Network are people who I see as highly competent. They are also desiring of more ability to make FSC better tuned to regional dynamics, and the dynamics of the nations, communities, and forests in them. 

Unfortunately, there is also a “Balkanization” within FSC, wherein we see countries, regions, even international offices fighting over resources in a way that undermines FSC’s success. This situation is NOT simply a decentralization versus centralization issue. It is how to create a more responsive, dynamic, and accountable management structure and system that fosters innovation, consistent global rigor, and is realistic and impactful regionally.

Proposed Solutions

On the management side, FSC should reduce staff presence in Europe, particularly Bonn, and redirect investment toward creating stronger regional hubs – with highly competent regional leaders and staff. 

For initial thinking I would suggest consideration of the following as just a start on the idea of regional hubs, the beginnings of which already exist. Exact regions will probably take further thinking, but I would suggest: 1) Africa, 2) Central and South America, the Caribbean and Mexico, 3) Canada and USA, 4) Europe (including Russia) and the Middle East, 5) Asia (including China, India, Laos, Myanmar, Nepal, Thailand, Vietnam, etc.), and 6) Oceania (including Australia, Indonesia, New Zealand, Philippines, etc.). 

FSC must have strong central leadership, business management and accountability that conducts constant monitoring of the performance of each Regional Hub, including periodic (at least every 2 years) technical and financial audits of each regional center (producing management reports that identify where management needs improvement). At the global level, several functions should remain global – accreditation, global communications, global marketing, and global innovation and research. FSC should have a Global Ombudsperson who leads in terms of creating a responsive system for managing stakeholder engagement in all respects, and that person should have a counterpart in each region (i.e., a Regional Ombudsperson). In addition to a Regional Director, each Regional Hub should have a Regional Accreditation System Officer to assist in managing the credibility of the FSC Accreditation/Certification Program (in cooperation with others in FSC IC and, separately Assurance Services International (ASI), a Regional Marketing Officer, a Regional Communications Officer, and a Regional Certified Operations Liaison Officer (per what I think has been the ongoing positive experience of FSC USA). The latter’s job is to connect with certified FM operations, listen to their concerns, and be their advocate at the regional level in terms of external marketing and communications connections (and perhaps other things I am not aware of) and all things FSC.  

Regional Directors and the FSC International Director should form a relatively streamlined Global Management Council, that reports to the FSC IC Board of Directors, and indirectly to Regional Advisory Councils made up on FSC members and certified operations, plus of course all FSC members. All FSC members and certified operations should have voice through Regional Advisory Councils. 

I would also suggest that the FSC General Assembly dynamic continue, but moving to a once every 4 years meeting. Between the GA’s, each Region should have a regional meeting at the 2 year mark, to better manage the system and consider new ideas. The GA itself is a unique event , including the motions process that provides core value for FSC members to weigh in on what is important to them. Also, though virtual participation should always be an option, physical presence of FSC board, staff, and members, plus observers, is a unique, unifying space in the FSC world – the type of meeting that I have never seen in forestry or any other sector. The FSC should do everything in its power to encourage face-to-face participation.

Technical Improvements After Taking Stock of 30 years of FSC

Three potential arenas for improvement stand out right now to me – improving management of High Conservation Values (HCVs), sustainable silviculture for natural forests, and restoration.

As for HCVs, experience in all three biomes (tropical, temperate and boreal) leads me to three positive options for change. Neither the International Generic Indicators (IGIs) or FSC national standards, with the sole exception of Canada, require that HCV assessments themselves, who they were developed by, or how local expert review was done, are made public. In my experience all too often we see HCV assessments in the same jurisdiction or ecosystem coming to different and disparate results. This reduces FSC’s potential for positive impact. Building on the HCV frameworks ideas per Version 5 of the P&C, imagine if we went a step forther and developed “FSC-endorsed” HCV assessments for key jurisdictions and ecosystems such that FM managers at all scales (including smallholders) had consistent publicly available expert guidance on what the HCVs are and how FM managers could better deliver on HCV protection, enhancement or restoration. At the same time perhaps we consider incentivizing the conservation and restoration of HCVs and HCV areas (HCVAs). What if we reduced the annual administration fee (AAF) for FMs that create bigger and better HCVAs? What other incentive options are out there?

As to sustainable silviculture, FSC has deep experience on many levels that should allow us to be far more rigorous and specific about how, in particular, natural forests could be better managed for all values. With climate change, and the diminishing presence of late successional, old growth (even primary) forest, it is urgent FSC re-examine what it has learned about silviculture and make improvements in its requirements. Through reduced impact logging (RIL), climate-smart practices, and capitalizing on thousands of years of traditional ecological knowledge (TEK), ecological silviculture has arrived. FSC had already contributed to that in some countries by emphasizing these things but the opportunities for improvements are numerous. I am urging FSC to include a global review of sustainable silviculture as it embarks on a review and potential revision of the P&C and IGIs, which I think is scheduled to start in 2025.

Lastly, though the FSC has created an ecosystem services approach that in theory could have high value, this has not yet resulted in fostering enough restoration action. Though there are some FSC-certified operations implementing restoration, FSC’s impact in the restoration sector is still not what it could be. FSC does not yet trumpet “FSC-certified restoration”. Not every restoration initiative needs FSC certification. but why not ratchet up the FSC option for restoration, fostering better performance and accountability?

Conclusion – Despite my “lucky late-in-life state of independence”, I do not take any of the observations I make lightly. I know there are many nuances to the FSC world and complex dynamics. 

Thankfully, more than ever, the world is paying attention to forests and climate, whether it is the conservation of “old growth”, restoration of forest ecosystems, managing fires, maintaining or enhancing HCVs, or better managing forest values with indigenous or traditional communities. Global, national, and local marketplaces are also yearning for more sustainable, renewable, circular, and climate-positive products.

If you have a disruptive idea on how to better conserve forest ecosystems and values, or meet ever-growing human and market demands, have at it. Now is as good a time as any to put such ideas forward. The FSC system is ripe for positive, even disruptive, change. As many people have said – it needs to be more “fit for purpose” realizing it is not just a certification system, but a global leader on forests and forestry, forest values and forest peoples. “Here and now” is a time for positive change. We should be impatient.  We need action.