Grade Inflation? SCS Certification of Irving’s Allagash Timberlands
A Report for Sierra Club in May, 2002

By Mitch Lansky


In this document, I start with some general concerns about the certification of Irving’s intensive practices as "natural forests," rather than plantations. To get a background about the degree to which these practices are used in the Allagash Timberlands, see Appendix I, where I make estimates, based on available data (which, I show, are unreliable) from SCS ‘s Public Certification Summary Document (PCS) and the Irving Management Plan Summary (IMPS). I then discuss the various means by which SCS inflated grades above levels justified by the evidence. Finally I do a criterion by criterion analysis of the SCS grading of the Allagash Timberlands. This analysis is based primarily on evidence from the PCS and SCS’s Forest Conservation Plan Operating Manual (OM). I bring in evidence from other documents at times, including other SCS certifications and literature written by SCS certifiers.

I. Plantation or natural forest?

Before proceeding with the certification, SCS has to determine which set of standards to use--natural forests or plantation forests. SCS admits (pg. 5 OM) that "there is not a clear demarcation between natural forests and plantations." The judgement of which type to choose is up to evaluator. If natural forests are cleared for plantations, however, "the plantation operation is not certifiable."

Plantations, according to Draft Interim Standards (DIS, pg. 29) lack "most of the principal characteristics and key elements of native ecosystems," and can result from "either planting, sowing or intensive silvicultural treatments." I understand this to mean that intensive practices, even to natural regeneration, could be construed as creating a plantation in some circumstances.

The word "most" becomes rather confusing, because a plantation obviously has trees and can support birds, insects, understory plants, and mushrooms, despite the simplified state. Things get even more confusing because both the DIS and FSP recommend (see pg. 24 of DIS for example):

  • Preference for native species,
  • Variable rotations,
  • Cut blocks of different size and shape,
  • Maintenance of volunteer seedlings within planted stands.
  • These are some of the activities that Irving is doing, according to the PCS. If the landowner follows such guidelines for plantations, however, there is nothing in the literature that says the plantation will be called a natural forest. It is still a plantation, but the worst impacts are being mitigated.

    While older plantations may be forgiven under FSC standards for natural forests, any plantations established after 1994 can not be certified. Because of this, it is crucial to find out when (if ever) Irving was planting in a way that could be considered a "plantation."

    Irving’s new activities, which SCS admits are short rotation, intensive management, include:

  • Clearcutting a natural, Acadian forest (where the dominant species are shade-tolerant trees such as red spruce or northern hardwoods).
  • Preparing the site with a crusher or dragging the site with a chain to scarify the soil (SCS says this happened "in the past" (PCS, pg. 26)--but some of this is still be going on).
  • Planting species (black spruce, white spruce, and even Norway spruce (an exotic)) that are boreal species that, in most cases, did not historically dominate the site.
  • Herbicide spraying on around 95% of the plantations (and some repeat sprayings). This is an attempt to truncate natural succession (which would normally lead to domination of such disturbed areas by pioneer species).
  • Pre-commercial thinning (by Central American laborers) to give uniform spacing.
  • If necessary, Irving is prepared to spray insecticides to protect these stands (see section on pest control). Landowners in other parts of Maine sprayed thinned black spruce stands to combat the yellow-headed spruce sawfly a few years ago. It is likely that over a rotation, these or other pests, including the spruce budworm, will find these nearly-uniform stands quite inviting.
  • Cutting the planted stands on short rotations (relative to natural disturbance regimes). This truncates later stages of succession, including old growth.
  • That Irving might retain a few trees from the previous stand or some volunteer regeneration mitigates, but does not change, the basic facts listed above. What Irving is doing is very unnatural--converting an Acadian forest to more of a boreal forest, truncating both ends of succession, simplifying the stand, and using intensive methods to do so. In some cases, Irving has even converted hardwood sites to white spruce. How can such conversions be considered "natural"?

    Natural Acadian disturbance regimes. In a recent paper co-written by Robert Seymour, Alan White, and Philip deMaynadier on the, "Natural disturbance regimes in northeastern North America--evaluating silvicultural systems using natural scales and frequencies," the authors concluded that "natural" forestry should use the stand structures and disturbance regimes of the presettlement forest and current old growth forests as a reference point. Based on their research, the authors concluded that return intervals of large-scale catastrophic disturbances were quite far apart on an average site in northeastern Acadian forests. Smaller-scale disturbances, leading to uneven-aged structures were much more common. Indeed, the authors cite Lorimer’s research that showed that stands less than 75 years old occupied only 16% of the landscape in northern Maine (pg. 364). Except for natural "fir flats" in northern Maine and New Brunswick, "boreal species [such as pioneer hardwoods, balsam fir, and white and black spruce] rarely form extensive monocultures in the northeast, except after rare large-scale, stand-replacing disturbances to which they are well adapted."(pg. 361)

    The study mentions spruce plantations that some industrial landowners are establishing on 50-year rotations on 20 ha blocks. "When plotted on the disturbance spectrum, we see immediately that such a plantation falls well outside the boundary of natural disturbances." The authors suggest that a more "natural" rotation for stands of that size would be 347 years. "Leaving a few scattered reserve trees [...] Could offer only limited benefits."(pg. 364)

    "Widespread application of single-cohort sivliculture on rotations under 100 years thus creates a landscape that has no natural precedent for the types of forests we reviewed. Management that deliberately produces such stands thus cannot claim to be emulating natural disturbances, as in the common industrial situation where multiple, short rotations are planned, or where such stands dominate the landscape." (p. 364) and "Once single-cohort stands occupy over ca. 15-25% of the landscape, every stand that is converted or maintained in a single-cohort structure contributes toward an increasingly artificial landscape pattern." According to Irving’s projections (PCS, pg. 15), in 25 years, 28% of the entire Allagash district will be in even-aged stands under 40 years old, but the majority of the spruce/fir type would be in that condition.

    If what Irving is doing with its softwoods at Black Brook or in Maine is not considered plantation forestry, then no industrial landowner in the region is doing plantation forestry (except on cleared fields), since almost all plantations established after clearcutting use native trees (or close relatives) and have volunteers species coming through. Allowing SCS to certify this type of forestry as "natural" sets a disturbing precedent for FSC certification.

    Plantation quality vs. Natural quality. The short rotation, intensive management regimes employed by Irving in its spruce/fir will not only impact forest structure, it will also impact wood quality. Softwood grown in partial shade has tighter growth rings and fewer branches and knots than open-grown wood. It normally takes 60 years for spruce to put on mature wood. Trees younger than that are dominated by juvenile wood, which has less strength and more lignins. At the Penobscot Experimental Forest in Bradley Maine, scientists concluded that pre-commercial thinning in softwoods does speed up diameter growth, but has trade-offs: "...early thinning likely will prolong the period in which juvenile wood is formed and a larger number of larger branches will be retained. Thus any gains in tree growth may be offset by poorer quality wood products." Thus the trade-off for loss of biologically desirable forest structure now is a supply of low-quality wood with fat growth rings, lots of taper, and lots of knots in the future.

    Planted forest or plantation?

    While there may be a lot of gray areas in planting trees, we can at least define what is black and what is white and see on which end of the spectrum Irving’s practices lie. The following chart presents an array, showing the spread between the extremes:

    Planted Forest/Plantation Array


    Planted Forest



    Forest ecosystem restoration

    Commercial crop

    Previous stand

    Non forest or degraded forest

    Natural forest

    Opening size

    Small gap, partial shade


    Site preparation

    None needed

    Crushing, scarification

    Species planted

    Restore native species that would have dominated the site.

    Exotics or native species that would not have naturally dominated the site

    Early stand management

    Allow natural succession

    Herbicides, PCT


    Long--restore natural forest structure, including old trees

    Short--cut before stand develops late-successional characteristics

    Landscape impact

    Extends natural forest

    Fragments natural forest

    From this array, it becomes clear that Irving’s fill planting with red spruce would tend towards the planted forest side, but the planting of relatively short rotations of white, black, and Norway spruce in clearcuts of former natural forests is clearly more of plantation forestry, despite its mitigation (i.e., variable retention).

    Certifiable? I am arguing, therefore, that the certification (as natural forest) should not include what Irving is doing on its spruce-fir timber management zone. This is more plantation forestry than natural forestry, despite mitigations. To certify, and thus legitimize, such practices as "green" undermines years of struggle by forestry activists who have had to live near clearcut, herbicided forests.

    The term "natural" is not scientifically justified when applied to short-rotation forestry. Such practices violate FSC Draft Interim Standards performance indicators for 6.3, (maintaining ecological functions). These indicators include encouraging natural regeneration, leaving biological legacies (including old trees) after harvest, having reserves of representative ecosystems, and the following other indicators:

    b) "Subject to the scale of operations, the forest is managed so as to maintain a full range of successional stages at distributions within the range of natural variability."

    d) "Harvesting prescriptions maintain, enhance or restore natural forest composition..."

    e) "Harvesting is designed and laid out, over time and space, with consideration of the types, sizes and frequency of natural disturbances as well as connectivity of wildlife habitats."

    n) "Harvesting actions do not lead to widespread conversion of naturally-diverse forest communities of forest types into homogenous and simplified stands."

    The widespread conversions already done and planned to be done over the next 25 years stand in contrast to these indicators.


    II. Grade inflation themes

    As I reviewed the SCS grades and compared them to the evidence, I discovered a number of recurring themes that led to grade inflation.

    Promises vs. practices. The FCP Operation Manual (pg. 10) states quite clearly that, "scores should be based strictly upon observed conditions ("what is") rather than upon intentions, plans, and assurances. Specifically, the scores should not reflect anticipated compliance with any stipulated conditions." Given such a strong statement, I was struck by the number of times the PCS relied on assurances and comfort, rather than actual practices in the present or past.

    For example, at the time of certification, Irving was cutting over the allowable cut, but promised to lower this cut over a period of years. The AAC is based on the allowable cut effect (ACE), which allows cutting more than growth now, in the promise that yields will rise from intensive management later. Irving has no ecosystem reserve system in place, but SCS is assured that this will happen eventually, because Irving is cooperating with the Natural Areas Program.

    Process vs. practices. In some cases, the certifiers seemed impressed enough with Irving’s computer programs, Irving’s policy recommendations, or Irving’s consultation with experts so that they overlooked the deficiencies of the actual results on the ground. This high weighting for process over practices is, perhaps, the best explanation for why Irving--which clearcuts, plants, sprays, PCTs, and uses short rotations on its spruce/fir scored better than the Bureau of Parks & Lands for so many criteria, when the BP&L has such a more benign ecological impact and is cutting well under growth. For example:




    Harvest regulation



    Management plan and information base



    Low, low threshold. Scores above 80 (a "B" ) are certifiable as a "well-managed forest." Unfortunately, the SCS sometimes forgets that the scale goes from 0-100, not just 80 to 100. Scores below 80 should not be reserved for only the abysmal, but should also include average or mediocre.

    It is my interpretation that grades should be based on the degree to which practices veer from the ideal (100 score) listed in the Forest Conservation Program, Operations Manual (OM), with further clues coming from the non-certification threshold (<80) guidelines.

    Unfortunately, some of the latter guidelines really specify what should be flunking scores, not just a high C+. There seems to be confusion with flunking certification (i.e., scores <80) and flunking basic forestry. This leads to an absurd situation where a 79 requires practices that cause irreversible destruction, but an 80 is a well-managed forest. If the non-certification threshold (<80) requires extirpating species or other forms of serious harm, then what does it take to get a 60?

    In grading the BP&L, the SCS team demonstrated that variance from the ideal is more important than falling below extreme non-certification thresholds in the Operating Manual. For example, the non-certification thresholds for "A.6. Management Plan and Information Base" include:

  • No current plan.
  • Planning is viewed as an "essentially pointless exercise."
  • Management actions are "extemporaneous and opportunistic."
  • Company lacks operational monitoring program.
  • "Critical management decisions are based largely on intuition."
  • There is no effort to identify potential environmental impacts.
  • There are no written guidelines for impact avoidance. And so on.(OM, pgs. 30-31)
  • None of these are true for the BP&L, yet the SCS team gave the Bureau a rating of 78, which is below the certification threshold.

    Ignoring or discounting negative information. SCS found rutting and desiccation in wetlands, roads going through old growth, evidence of highgrading in hardwoods, evidence of squeezing contractors and many other problems that should have led to lower scores or even scores below certification threshold. The SCS team either ignored its own evidence, or explained it away. Sometimes the explanations strained credibility to the limit, as with contractor relations. In this section, the list of problems was long, but the certifiers stated that, "we are inclined to lay more emphasis on the investment and employment creation we have seen, than on the negative points and complaints uncovered." (PCS, pg. 45). The result was a score of 92.

    A few percent fix. There is a theme that appears from time to time in the PCS that not only elevates questionable practices to pass the non-certification threshold, but actually justifies high grades. A key example is with clearcutting. Irving (as I establish in Appendix I) is one of the biggest clearcutters in Maine (annual clearcuts as a percentage of total acreage). The company, however, tells contractors to leave at least one small island of trees and a few isolated trees for every 25 acres of clearcuts. This "clearcut with retention" of a few percent of the original forest is seen as benign and progressive by the certifiers.

    Likewise, Irving used to spray all of its plantations with herbicides. Now it only sprays 95%. This reduction in herbicide use, even though Irving sprays more than most other landowners, is seen as evidence of an attempt to "minimize" use.

    Irving is suggesting that it will keep at least 10% of its forest as "old" (over 70 years) and 3% as "very old" (over 100 years). Yet, in the presettlement forest, 84% of the forest was in stands over 75 years and 59% was in stands over 150 years from the last stand-replacing disturbance.

    It could be argued that having grapple skidders drag tops back into skid trails during whole tree harvests is a similar form of ineffective mitigation of a basically unsound trend. These few percent fixes do not fundamentally change the overwhelming impact of the basic problems.

    Marking on the curve. Rather than grade Irving based on variance from the ideal performance, SCS, at times, graded Irving based on comparisons to the performance of "typical industrial practices." This was done when these "typical" practices are worse than mediocre, so being better than that does not necessarily make a forest "well managed." Thus, because Irving may have its feller buncher trails farther apart, or have smaller yards for whole-tree harvesting, or have wider buffers for streams than the industry norm, the company got high grades, even though its practices might still not come close to the ideal performance. The team also did not compare Irving’s practices to the two other large landownerships that SCS has certified in the same region.

    III. Ratings by SCS criteria

    In discussing the grading guidelines from the OM, I will only paraphrase or quote selected excerpts (where Irving’s practices are questionable or that are relevant to the discussion), rather than repeat that whole document.

    A. 1. Harvest Regulation

    SCS grade: 90

    Ideal Performance:

  • Periodic growth clearly exceeds average annual harvest levels.
  • Rotations are long enough to approach maximum mean annual increment (MAI) of volume while also securing high product value.
  • ACEs are not incorporated unless it is clear they will be realized.
  • Regulation is robust against future events (pg. 24).
  • Non-Certification Threshold:

  • Strategy relies on unrealistic or unachievable assumptions.
  • Rotations are set well below peak MAI.
  • AAC is critically dependent on no unforeseen events.
  • Evidence (from PCS) of actual practices:

  • SCS states (pg. 12) that Irving’s previous annual allowable cut (AAC) for spruce-fir was too high. The new AAC is 22% lower.
  • Indeed, the team states that this former strategy "would, if continued, have depleted the growing stock to sub-optimal levels and threatened future sustainability." (pg. 15)
  • SCS states that Irving’s cut 1991-1994 was 37% higher than the AAC established in 1991.Ÿ

  • At time of certification, Irving was still cutting above its new AAC. The lower cut will be "phased in." (pg. 12). SCS is thus awarding points based on assurance, rather than practice.
  • Is CMAI an Appropriate Benchmark?

    Where the Mean Annual Increment culminates depends on how the wood is measured. It comes soonest if measured in cubic feet, then in cords, then in board feet, and later in clear board feet. Simply cutting a tree because it has reached the CMAI may not be good economics, because the value does not culminate when the cubic foot volume does. Also the MAI does not crash soon after reaching culmination, rather it plateaus, or goes down slowly (while value may still rise). Cutting at the CMAI can also be a bad biological strategy, because it might avoid later successional stages. With some species, such as red spruce in natural stands, CMAI can come very late. Seymour studied a stand with 150 year old red spruce where their MAI had not yet peaked (see appendix II). One other fact worth noting. The CMAI is reached soonest at the densest stocking. Thinning tends to lengthen, not shorten, the time before reaching culmination (see discussion in Beyond the Beauty Strip, page150, for references). It is thus quite probable that short rotations in spruce/fir, especially if established by aggressive thinning, are below the CMAI measured by board feet--which is the appropriate measure if the product is to be sawlogs. The PCS did not state what the CMAI was for aggressively-thinned stands, nor did it mention how this culmination was measured, or what was the source for the calculations. Without such data, Sierra Club could not make a conclusive argument.
  • The spruce-fir AAC is based on "substantial allowable-cut effects." (pg. 13). SCS states that cut is 63% higher than with "no-silviculture" (SCS is equating "silviculture" with planting, herbicides, and PCT, rather than selection cutting). I read this to mean that the cut is 63% higher than actual growth, but that the cut is "justified" by expected future growth.
  • This expected growth is dependent on there being no insects, disease, adverse weather or other serious problems. This assumption, considering the potential for spruce sawflies, spruce budworms, and drought, is somewhat heroic. Indeed, "The team noted that Irving did not conduct a sensitivity analysis to estimate potential impacts of future spruce budworm outbreaks on softwood AAC, which could be substantial if protection is limited or ineffective." (pg. 14) Thus the AAC is dependent on there being no unforeseen events--a non-certification threshold.
  • Due to weak markets, Irving is cutting much less than the modeled AAC for hardwoods.
  • By undercutting hardwoods, and overcutting spruce-fir, Irving could contribute to a "serious imbalance" (pg. 14) that will impact mixedwoods and the softwood AAC.
  • Irving "believes they will have the actual hardwood harvest in balance with the modeled AAC within a very short time frame."
  • "The team believes that Irving will make a good-faith effort to eliminate fully this imbalance..." (pg. 14) and the team decided not to set conditions or lower scores, but instead it made recommendations.
  • Final comments:

    Irving’s past practices, and even present practices veer substantially from the Ideal Performance. The team was more impressed with Irving’s computer model and assurances that the AAC’s will be followed in the future than by Irving’s practices at the time of certification. What should hold more weight is what goes on in the woods, than what is projected in the computer. The score of 90 was thus a case of serious grade inflation that violated the prohibition against certifying assurances (as discussed in section II of this report). SCS should have waited for Irving to comply by getting practices on the ground before issuing such a rating.

    A.2. Stocking and Growth Control

    This criterion looks at two issues--management of current growing stock and establishment of regeneration--in terms of stocking and forest structure.

    SCS grade: 87

    Ideal Performance:

  • Stand quality and vigor is improved, rather than highgraded and degraded.
  • "Silvicutural systems used for timber production strive to maintain the original diversity of natural forests endemic to the region, in both species and structure; extensive and unnatural uniformity in composition or structure is avoided, especially with regard to regeneration harvests and planting, when it is used." (OM, pg. 25)
  • Non-certification threshold

  • "Silvicultural systems, including planting regimes, routinely simplify natural forest composition and structure for the sake of administrative efficiency or economic expediency, potentially causing adverse ecological changes."
  • Evidence from PCS of actual practices:

  • SCS suggests (pg. 15) that in 25 years, over 72% of Allagash Timberlands will be "relatively mature" (over 40 years old or in uneven-aged stands). The team neglected to break this down by stand type. Only around ¼ of the forest is spruce/fir. It is possible, based on my calculations (see appendix I), that in 25 years, 55-66% of this type will have been regenerated since 1990, and there was substantial clearcutting before then. For the spruce/fir stand type, the original species ratios and stand structures will not be maintained on much of the area. Indeed, more than 30% of this type will have been planted with boreal species in a proportion that is very unnatural to many sites.
  • While Irving may have some adequate biological and silvicultural prescriptions, these plans have to be implemented on the ground. "Company foresters do not mark prescriptions, but instead rely on harvesting contractors to carry out detailed written instructions." (pg. 16)
  • Irving foresters "are supervising 2-4 times that of other certified forest operations. The team believes this can lead to uneven implementation of certain more complex prescriptions." (pg. 16)
  • The SCS team suggested foresters on certified acreage should have, at most, half the acreage to work as Irving foresters and should mark 40-60% of cuts, "to do consistently high-quality work." (pg. 17)
  • "The team observed that Irving’s harvesting operations, "usually do an adequate job of implementing the harvest prescription..." (does not sound like a rousing endorsement)
  • "...the team observed a number of prescription outcomes that were less than optimal." (pg. 16) "..the team is not charging that many outcomes were "poor" to the point of being uncertifiable; just that many could have been much better. Probably the most common example was a somewhat subtle high-grading (probably too strong a term)--a few too many big or valuable trees taken, generally, that compromised the stand’s future growth potential..."
  • The team found many examples of "’compromises’ that seem to occur when complex prescriptions must be translated into decision rules simple enough to be implemented by machine operators." (pg. 16)
  • The team concluded (pg. 16) that Irving’s machine operators were doing a better job at minimizing residual damage and land taken up in trails than "the industry norm." (pg. 16) The team did not state what level of damage or trail coverage is ideal, or what level Irving was doing. These performance standards can easily be measured on the ground. Comparing to poor performance on other ownerships is hardly an adequate standard for certification.
  • Final comments:

    The SCS team’s comments made Irving’s on-the-ground management sound mediocre at best. Certainly not worthy of a B+ grade. After all, foresters have no time to mark trees. The machine operators, who make the decision of which trees to cut, are not foresters or forest technicians, nor are they paid for their extra duties, beyond cutting trees, yet they have to make decisions based on basal area, crown conditions, tree vigor, species, quality, and other factors requiring some training. Some of the cutting is done on a night shift, or even in a snow storm, yet operators in machine cabs must decide which tree to cut without getting out of the cab to look at all sides of the trunk or to look at crown condition. The contractors are paid on a weight basis. Irving sells the wood. If an operator is paid by weight and the trees are not marked, there is an incentive to cut the biggest trees first. Machine operators thus have to balance complicated rules (better left to a trained forester to interpret) with incentives to cut the biggest trees. Further, due to poor markets, hardwoods have been highgraded for a long time, and the team presents no evidence that the highgrading has ceased.

    Yet, incredibly, after saying that management "could have been much better" the team concluded that the Allagash Timberlands "clearly rate a passing score relative to SCS performance standards." (pg. 17) The team is thus putting more weight on policies rather than performance, which goes against SCS grading protocol.

    The intensive management, especially that involving planting boreal or exotic softwoods on Acadian sites, clearly veers far from the ideal to "maintain the original diversity of natural forests endemic to the region, in both species and structure."

    A.3. Pest and Pathogen Management Strategy

    SCS grade: 90

    Ideal performance:

  • AAC takes into account "cyclical and potentially disruptive effects of future pest and pathogen outbreaks." (OM) pg. 27
  • "Silvicultural systems routinely attempt to lower natural susceptibility and vulnerability of stands to future attacks by favoring resistant species and by promoting healthy stand structures that enhance natural predators, thereby reducing the potential need for chemicals.
  • Non-certification threshold:

  • Management "based on uncritical reliance on low-cost, non-targeted chemical spraying for controlling future outbreaks."
  • "General management practices ignore pest and pathogen biology and future population dynamics, or fail to act on this knowledge." (OM pg. 27)
  • Evidence from PCS of actual practices:

  • (...) Irving’s silvicultural systems tend to favor pest resistant species..." (see my response in "final comments")
  • "There is no question that Irving has the resources and will to spend whatever it takes to protect their strategic investments, so there is no reason to doubt the company’s ability to mount and fund a protection program." (PCS. Pg. 17) That Irving can afford to mount a pest control program (which they demonstrated during the past budworm outbreak by using their own airplanes and spraying chemical pesticides aggressively), does not demonstrate compliance with this criterion--the point of which is to prevent pest outbreak problems.
  • Final comments:

    According to J. R. Blais, "Should white spruce plantations become common, they will not only be subject to budworm attack, but will also contribute to increasing the severity of outbreaks. It is noteworthy that the only location where budworm populations were maintained at epidemic levels in the mid-1960s in Quebec was situated in the Grand-Mere white spruce plantations, the largest and one of the oldest (established in 1913-1932) in the province."

    White spruce is also susceptible to the spruce bud moth, for which there was spraying in New Brunswick in the past.

    Studies have shown that when black spruce grows on drier sites, it is more vulnerable to budworms. The reason for this is that instead of producing a large quantity of foliage, the tree puts out less but more nutritious foliage. Black and white spruce plantations, as mentioned earlier, are susceptible to the yellow-headed spruce sawfly (there were thousands of acres sprayed with carbaryl in Maine as recently as 1998). Entomologists at the Maine Forest Service told me that susceptibility to the sawfly is increased by thinning in young stands, a standard practice used to speed up diameter growth.

    Research by Hew Crawford and Dan Jennings found that mature, deep-crowned red spruce offered a favored habitat for budworm-eating warblers. Fir stands and younger spruce stands support lower bird densities. Crawford, Jennings, and Titterington concluded that, "a mature managed forest containing a mix of species and size classes, and scattered openings and patches of regeneration, supports populations of birds that prey effectively on spruce budworm."

    Brad Meiklejohn, in looking at buffer zones of various sizes, found that interior species (some of which are known budworm predators, such as Cape May, Blackburnian, and Bay-breasted warblers) nearly dropped out--not only from the heavily cut forest, but also smaller buffer zones.

    Thus, to the extent that mature red spruce forests are converted to younger, even-aged forests, susceptibility to spruce budworm outbreaks could increase. The SCS team had very little to say about actual strategies to use this known research (besides fir-only cuts in some stands) to make stands less vulnerable to budworm and to create habitat for predators to the budworm. The team also did not discuss the extent to which Irving’s overstory removals are encouraging young, even-aged stands dominated by fir.

    The SCS team made no mention of other known pests to white and black spruce. They argued that the forest is becoming less vulnerable by assertion, not evidence of practices. The most positive statement was of Irving’s financial ability to mount a pest control program, which veers towards the non-certification threshold of relying on chemicals to control future outbreaks.

    The SCS team and Irving have failed to indicate the status of red spruce, the key species in the Acadian Forest, in terms of its age structure, abundance, and inventory trends. Maintaining old growth red spruce may be one of the more important pest control strategies. The fact that these stands have persisted for hundred of years, weathering all kinds of pests, including the spruce budworm, is testimony to the genetic or structural resistance in such stands. To what extent is Irving cutting older red spruce to meet the demands of the sawmill markets? This is an important question which is not answered--except that Irving’s 25 year plan calls for fewer acres of mature spruce-fir.

    Because Irving’s spruce/fir strategy of short-rotation even-aged management may be increasing susceptibility to pests over more natural management, and because the Irving strategy for dealing with the budworm (PCS, pg. 14) will be by "aggressive salvage operations (...) coupled with insecticide protection on younger stands," the SCS score of 90 is a case of serious grade inflation for practices that fail to meet the non-certification threshold.

    A.4. Forest Access

    SCS grade: 92

    Ideal performance:

  • "All lands under management are accessible for harvesting and silvicultural operations within a short time frame (within one operating season)." (OM, pg. 28)
  • "The area occupied by the road system minimizes loss of productive forest land.
  • "Road construction and maintenance meets rigorous environmental standards and is aesthetically designed." (OM pg. 28)
  • Non-certification threshold:

  • "Area lost to production from rights-of-way and landings is grossly excessive."
  • "Road construction and maintenance practices (or lack thereof) result in serious adverse environmental effects." (OM pg. 28)
  • Other criteria:

  • "(...) The working forest component may not comprise the entire ownership..." (OM pg. 27).
  • Evidence from PCS of actual practices:

  • Irving has 1,360 miles of permanent roads giving access to 410,000 acres. That figures out to be 2.1 miles of road per square mile of forest..
  • This leaves around 125,000 acres still without access. If the land is not accessible within a year, then it does not meet the ideal score.
  • SCS or Irving is figuring that to finish roading this area would take 500 more miles of road. This figures out to be 2.6 miles of road per square mile of forest.
  • The SCS team complained about the "straightness and rigid geometric pattern, regardless of the terrain or landscape." The team found, "one instance where a minor relocation up slope would have avoided constructing a right-of-way through an enriched old-growth cedar habitat." The team members, "strongly urge the company to relax this policy where site conditions suggest a minor modification." (PCS pg. 18) One would think such a geometric layout of roads would score lower for aesthetics.
  • The team made no estimates of % of land in roads and yards and gave no indication of what is an acceptable level, even though these items are measurable and easily comparable.
  • Final comments:

  • The SCS rating system here confuses failing certification (<80) with the most egregious management. Hence, they talk about grossly excessive roads and serious adverse effects. Those, however, would be grades in the 50s not 79. Apparently, to the SCS team, putting a road through an old growth forest, when old growth makes up a fraction of 1% of the Maine woods, is not a serious adverse effect.
  • Over 2 miles of road per square mile is excessive based on recommendations of Biodiversity in the Forests of Maine: Guidelines for Land Management. It mentioned that the standard in the Fundy Model Forest, to help prevent impacts to biodiversity, is a maximum of 1 mile of road per square mile of forest. (pg. 128). This book also gave a maximum recommendation, from an industrial forester, of up to 1.84 miles per square in hilly regions (this may have been the figure from his own woodlands...). Irving’s road system exceeds even this figure, and there is no indication it is justified because of hilly terrain.
  • In contrast, the Bureau of Parks and Lands has 0.8 miles of road per square mile of forest. In the SCS Final Report on BP&L certification, the team states that, "It did not appear to the team that lack of access was a major impediment to management." (pg. 56)
  • The vast majority of Irving’s cutting is done by whole tree harvesting. This system, by necessity, requires large yards to accommodate whole trees (tops, branches, and all), and all the equipment, such as grapple skidders, delimbers, slashers, loaders, and trucks to process and move these trees. There is no discussion of how large these yards are and how they are distributed and what is an appropriate amount of land to take up in yards for a certified operation. That Irving may have WTH yards smaller than the industry average and may be doing things (like taking branches back along the trails) to minimize brush piles at the yard may reduce the gross excesses of WTH, but it cannot eliminate what is an inherent weakness of this system.
  • The SCS team did not indicate what type of forests are unroaded and if it is appropriate to have the entire Allagash Timberlands property roaded.
  • The SCS team is giving out grades with no clear, measurable standards. Based on the above noted problems, and the degree to which Irvings’s practices veer from the ideal, an "A" (92) seems excessive.
  • A.5. Harvest Efficiency and Product Utilization

    SCS grade: 90

    Ideal performance:

  • "Product wastage and residual stand damage are minimal."
  • "Pursuit of full product utilization does not override ecological considerations." (OM pg. 29)
  • Non-certification threshold:

  • "Harvesting operations waste much valuable material and cause extensive residual stand damage."
  • Overzealous pursuit of low-value products such as biomass threatens ecosystem functions, loss of habitat and vertical structure from systematic removal of all large cull trees.
  • Evidence from PCS of actual practices:

  • 70% of the wood and area harvested are done by feller-bunchers (PCS, pg. 4--but on page 18, the figure given is 65%).
  • The team admits that "these systems have inherent limitations that cannot be totally overcome," (PCS, pg. 19) but conclude operations are "quite good."
  • Final comments:

    I will here only address the issue of harvest efficiency, as I assume Irving is good at marketing, mostly to its own mills.

  • The team gave grades with no standards for what is acceptable for portion of land taken out by trails.
  • The team did not state what the inherent limitations of feller-buncher systems are and why, despite such limitations, forestry operations that are mainly dependent on such technologies are rated so high.
  • Feller bunchers and grapple skidders, working with whole tree harvesting, need fairly wide trails. Irving’s Standard Operating Procedure call for trails in hardwoods to be under 18 feet wide. For softwoods, with processors, maximum width is 15 feet, but the distance between trails is shorter than for feller bunchers, so the ratio of trails to area is comparable.
  • The distance between trails for feller bunchers, according to the operating manual, should be between 65’ and 80’ with the "target" being 75’. For feller bunchers with a short reach, this may entail going off trail, which can do more damage. This means that in hardwoods, when operators hit the "target," 24% of the working area is converted into trails. A premature removal of 24% or more of potential crop trees is hardly a result that deserves an "A" grade for harvest efficiency.
  • Removing bunches of whole trees means dragging trees with full crowns down 16 or 18 ft. wide trails. Residual damage is very hard to avoid in such circumstances. Contractors have informed me that dragging hardwood tops back up the trail can do even more damage. The SCS team did not give any figures for stand damage on Irving land, nor did they give a figure that they consider as acceptable for stand damage. Even if Irving loggers are careful and reduce residual damage below what the industry average is for feller-buncher/grapple skidder systems, these industry averages are excessive. Doing better than mediocre is not the same as doing well. Unless there are measurable standards that Irving is passing, it is hard to justify the 92 rating given by SCS.
  • In the SCS Final Report on the certification of Maine Bureau of Parks and Lands, the team states that: "In the Acadian forest region, most partial-cutting prescriptions are best accomplished by systems that leave logging residues in the woods, as close to the stump as possible. [...] Mechanized feller-bunchers are clearly the most economical system now in the woods, but the push to skid large hitches of whole-tree stems with wide, powerful grapple skidders can all-too-easily result in excessive area in trails, soil damage (rutting), damage to residual trees, excessive area in roadside yards, and unsightly accumulations of residues at roadside. Hauling slash back into the woods after roadside delimbing, a common practice to avoid the latter problems, can actually magnify the former, as it merely increases the amount of traffic of loaded grapple skidders and rarely accomplishes a uniform distribution of residues." (Pg. 58). This description from SCS certifiers does not sound like practices that deserve an "A."
  • Some certification systems, such as Silva Forest Foundation in British Columbia, will not certify timberlands that rely on whole tree harvesting because it is so difficult to meet guidelines for trail width and distribution, yard size, soil disturbance, residual damage, and slash management (Wendy Vasbinder, SFF, personal communication). Whole tree logging removes a major source of nutrients (branches and tops) from the forest. Even dragging some of this material back up the trails does not place it around the trees, where the nutrients are needed. That SCS would give an "A" to Irving for relying on a system other certifiers would not pass shows clear grade inflation.
  • A.6. Management Plan and Information Base

    SCS grade: 95

    Ideal performance:

  • Provides full and accurate estimates of potential environmental impacts
  • Non-certification threshold (note: I only list these to show how extreme SCS has set the threshold--once again, confusing getting below 80 with flunking):

  • No current plan exists. No planning process to develop or update policies and strategies.
  • "Planning is viewed as an adjunct essentially pointless exercise..." (OM, pg. 30)
  • "Critical management decisions are based largely on intuition."
  • Evidence from PCS of actual practices:

  • SCS’s evaluation was done just after Irving had completed a new wood supply analysis. "Since the plan was new, we could not assess whether the plan was an effective internal company document." "...we believe it will serve the company well internally."
  • New and Improved! For those who thought the New Brunswick plans were state-of-the-art, comes this news about the Allagash plans, "No longer is the plan largely a wood supply analysis under a few biodiversity constraints..." (pg. 19).

    Final comments:

    SCS certified Irving just after Irving had adopted a new plan. Cutting, up to the time of certification, was based on the old plan, which led to serious overcutting of spruce-fir. The new plan allows heavy cutting in spruce/fir based on the allowable cut effect (ACE). The certification is thus based on the promise that management practices will become sustainable, rather than that management practices were or are sustainable. The certifiers have put more weight on the technical virtuosity of the plan than on what the plan actually does.

    Interestingly, SCS gave the BP&L a grade of 78 (below certification threshold) for this criterion, even though BP&L’s practices were clearly superior to the listed non-certification thresholds in the Operation Manual. This indicates that the most important issue is how far practices veer from the ideal, rather than from the non-certification threshold.

    B.1. Forest Community Structure and Composition

    SCS grade: 75 (below certification threshold)

    Ideal performance:

  • Management actions lead to optimal distribution of seral stages from early regeneration to old growth. SCS defines "old growth" as trees in upper half of their total life span with at least 5 to 10 old trees per acres. (OM pg. 32).
  • The Forest is managed with an ecological landscape perspective.
  • "The vegetative species and habitats found within the ownership are similar to pre-settlement distributions..."
  • Stand size diversity is designed to avoid fragmentation and ensure connectivity.
  • Non-certification threshold:

  • Seral stages are highly skewed (in part due to short rotations).
  • Management leads to "systematic conversion of natural forest landscapes throughout the ownership into highly artificial, regular patterns driven exclusively by managerial concerns." (OM, pg. 32).
  • Harvesting leads to "widespread conversion of naturally diverse forest communities or forest types into homogenous and simplified stands." (OM pg. 32)
  • Evidence from PCS of actual practices:

  • The PCS describes how the present age structure of the forest was created, in large part, by the market. Tolerant hardwoods and cedar have had slow markets--and they are in older stands. Softwoods have had strong markets--and most of them are in younger age classes (plus there is the impact of the spruce budworm).
  • The team was "less comfortable (...) with landscape level considerations related to age class distribution patterns, the natural distribution of stand types, clearcutting, and managing young, even-aged stands."
  • The SCS team believes that some stands cannot be managed without compromising them. In other areas, however, "high-yield, short-rotation forestry may be the best means of meeting future wood supply needs." (PCS pg. 21). The team here confuses mill needs with forest ecosystem objectives--which short rotations forestry contradicts.
  • The SCS team describes the hardwood and mixedwood stands as being dominated by "poor quality trees" and "unacceptable hardwood growing stock." (PCS, pg. 22). While blaming "weak markets," the team neglects to use the more active term that describes how the situation came to be--highgrading. The SCS team gave no indication that highgrading has ceased. Indeed, it said markets for low-grade hardwood are still a problem. This raises the question of whether it is justifiable to give a higher grade for low performance if the landowner has an excuse: "The markets made me do it."
  • The SCS team describes Irving’s plan for spruce-fir to include thinning young stands (some of which were planted) and "planting additional acres and managing them for high yield forestry."(pg. 22). This is a description of plantation forestry, rather than natural forestry.
  • Under the Irving plan, "there will be a substantial increase in pole-sized trees and a small decrease in mature trees in the first 25-year period." Thus, the current plan exacerbates the deficiency of older age classes. But Irving predicts the forest will be "better balanced" in 75 years. Since there will be almost no late-successional spruce/fir forests, except in the riparian zones, it is hard to understand what the word "better" means here.
  • The SCS team had trouble with this promise of better things to come. "A goal of certification, however, is restoring heavily managed forests to more natural conditions. A case could be made that at the end of the 75-year planning cycle the Allagash Timberlands will still exhibit an age class structure that is different from what could be observed in an unmanaged forest." (OM, pg. 23)
  • The company has a Scientific Advisory Committee that can advise it on natural disturbance patterns. "Irving has assured the team" that it will use the information. The team is "comfortable then, that Irving will reconsider" the age-class structure--if studies indicate that it is warranted. (PCS, pg. 23).
  • Irving plans to maintain at least 10% of the forest in old cover types (older than 70) and 3% in very old (over 100). The team was "less comfortable" with these definitions and suggested that "old" should be over 100 years and "very old" over 180 years. In contrast to Irving’s short rotations, both the Bureau of Parks & Lands and the Baxter State Park Scientific Management Area have planned rotations of 100-150 years for all even-aged stands except for fir and poplar.
  • Those traveling on Irving land hoping to see a "well-managed forest" might be disappointed. "The legacy of past management practices, however, lies heavily on portions of the landscape..." (PCS, pg. 24). The SCS team wants Irving to restore this degraded landscape and attached 2 conditions to the certification.
  • The SCS team assumes that "the greater the habitat alteration, the greater the effect on faunal communities." (pg. 24). They thus prefer stands with greater structural diversity. They find that "a mix of even-aged young and old stands in juxtaposition was, however, considered to be an acceptable alternative in some cases..." (PCS, pg. 24). A mosaic made up of fragments of simplified forests of varying ages, however, is not the equivalent an interior forest composed of more complicated stands, especially if the younger even-aged stands are softwood and the older ones are hardwood.
  • The SCS team found inconsistency between Irving foresters in dealing with structural elements. "It was apparent to the team that most foresters have more to learn to properly recognize high quality downed woody debris or cavity trees." (PCS, pg. 25)
  • The SCS team states that for the 25-year planning period, "selection harvests are the most commonly employed harvest prescription." (PCS, pg. 25). The team, here makes a misuse of the word "selection." While it may be true that partial harvests make up around 2/3 of projected cutting (IMPS, pg. 12), it is not clear how much of this is actual selection (managing for an uneven-age forest).
  • Shelterwood overstory removals are generally preceded by one or two thinnings. Assuming an average of just one thinning before an overstory removal, then the majority of cutting will be part of an even-aged system, not an uneven-aged system. Since Irving plans to increase its commercial thinnings towards the end of this 25-year cycle, the proportion of cutting to create or maintain uneven-aged forests (true "Selection") would be even lower.

  • Looking at most recent practices, rather than projected promises, shows that in 1998 (IMPS, pg. 12), nearly half of cuts were regeneration cuts (clearcut or overstory removal). Assuming an acre of shelterwood thinning for each acre of overstory removals means that selection, at most, would have made up 30% of cuts. The BP&L does 2 shelterwood thinnings before overstory removals. To the degree that Irving does 2 such thinnings, the percent of actual selection goes down even more.
  • The SCS team was not impressed by Irving’s "selection" cuts. They noticed "inconsistencies between foresters. (PCS, pg. 25). "Our impression, as well, was that many foresters are more experienced with implementing final regeneration cuts than they are with managing multi-cohort stands."
  • The team was "somewhat concerned" (PCS, pg. 25) with treatment of cedar stands on poorly drained soils. The result of mechanical harvesting "was rutting along some trails, an unusually high amount of downed woody debris, and desiccation of the sphagnum moss ground layer." The team believes these concerns "will be considered" by Irving.
  • "Historically, and in the strictest sense, clearcuts removed every stem from a stand and there was no structure left. These sites were often planted, resulting in an even-aged stand with little opportunity for future structural diversity. In addition, in the past Irving removed or crushed downed woody debris, further reducing the structural diversity of the stand." (PCS, pgs. 25-26). One wonders if SCS considers such practices as plantation establishment. If not, what does qualify? How far in the past did such activities occur? If these practices are considered plantation establishment and if these practices occurred after 1994, then the activities are not certifiable.
  • Irving still does crush woody debris and drag chains to scarify the soil after clearcuts. The certifiers did not mention that.
  • The SCS team assures the public that, "only areas lacking advanced natural regeneration are planted." (PCS, pg. 26). Yet Irving plans to plant around 1,200 acres per year for the next 25 years. So they are planning for a lot of natural regeneration gaps.
  • The SCS team encountered "situations where it was questionable whether clearcutting was the only alternative." (PCS, pg. 26) They attached a condition to the certification due to this concern. As mentioned earlier in this document, Irving’s rate of clearcutting is among the highest of any large landowners in the state, including others operating on similar forest types.
  • To mitigate the worst excesses of clearcuts, Irving employs "variable retention" (little islands of trees and isolated residual trees). The foresters, however, "are still in the process of learning the best ways of doing it." (PCS, pg. 26) The team is "comfortable" that the foresters will consult an ecologist and so gave no conditions. (Note: I found many of the isolated residual trees had blown over in a number of Irving clearcuts that I toured).
  • "...older clearcuts, many of which predate Irving’s ownership, were often very large and resulted in a complete loss of structural diversity. In addition, many areas that were clearcut and planted resulted in substantial areas of stand conversion." (PCS, pg. 26). The SCS team attached a condition to the certification that such stands be managed towards more structural and species diversity.
  • The SCS team does not state if these highly simplified stands are "plantations" or the result of "natural" forestry. The fact that a significant part of the landscape is already in a young, simplified state, should suggest that any new such stands, even with "variable retention" should be seen as a cumulative impact exacerbating the problem.
  • Irving has planted Norway spruce, an exotic species. The team sees Irving’s use of this species as "prudent," even though planting exotics should qualify as conversion by almost any standards. "None-the-less, if a goal of certification is encouraging restoration of more natural forest conditions, we do not encourage the use of Norway spruce." (PCS, pg. 27). They may not encourage the use of an exotic, but they have condoned it by certifying it.
  • Final comments:

    The SCS team had the most comments and gave the lowest grades with the most conditions to this criterion. Forest community structure and composition is clearly a weak point in Irving management. To be fair, some of the problems pre-date Irving’s ownership, but Irving has also clearly contributed to the skewing of seral stages across the landscape, and continues to do so. The team gave a 75 ("C") where perhaps a lower grade was deserved.

    B.2. Long-term Ecological Productivity

    SCS grade: 85

    Ideal performance:

  • "The working component of the ownership is managed on ecological rotations rather than economically optimal but biologically pre-mature rotations."
  • "Even-aged silviculture is applied only where it will mimic natural stand regeneration patterns."
  • "Under all-aged systems, target age/size classes include trees that have achieved biological maturity, in excess of CMAI." (OM, pg. 33).
  • Non-certification threshold:

  • "Widespread, excessive, and non-sustainable" nutrient capital depletion.
  • "Irreversible damage" that compromises ecosystems.
  • Failure to maintain ecological balance to productivity is "significantly" impaired.
  • Note: once again, the non-certification threshold is defined by extremes that should rate below 50, rather than 79.


    Evidence form PCS of actual practices:

  • " isolated instances, excessive rutting has compromised productivity on a small scale." (PCS, pg. 28). The implication here (due to non-certification threshold extremes) is that not passing certification would require excessive rutting as a rule, which would be a difficult task to accomplish given that the ground is hard in some regions and at some times of the year.
  • "The team is somewhat concerned about Irving’s harvesting practices in forested wetlands..." (PCS, pg. 28). "At several sites, we observed harvester trails going through very wet areas when there were alternatives that were clearly more benign."
  • The team observed that wood in the wettest site is of low quality, but the ecosystems (containing rare plants, vernal pools, unique wildlife) are of high value. "We encourage further consideration of how to harvest the wood from these sites without permanently degrading the structure, function, and productivity of the stand." (PCS, pg. 28). If the team is asking Irving to consider ways to cut without damaging these systems, we are left with the conclusion that Irving currently is damaging these systems, otherwise, why would the team raise these points?
  • Speaking in generalities again, the team states that, "Our impression is that most foresters, not just Irving staff, don’t often consider soil type when developing harvest prescriptions." Then the team tells what the theoretical result of this general trend is: (...) Soil compaction or desiccation and reduced site productivity..." Getting more specific, the team states that they "observed some sites with relatively thin soils that had been compacted during harvesting." (PCS, pg. 28). But then they back off and say they don’t "believe that there has been any substantial reduction in site productivity..." But they do recommend that Irving "consider" the subject of soil type and silviculture.
  • Obviously the team had a concern with Irving management on the soil, which clearly veered from the ideal, but since it did not match the extremes of the non-certification threshold, they gave this very polite recommendation.

  • While the team doesn’t "believe" that Irving is "substantially" depleting nutrients with WTH, they do "encourage" the company to "evenly distribute treetops" when hauled back from the landing. (PCS, pg. 29). This indicates that Irving is not evenly distributing slash back into the forest, again veering from the ideal. This recommendation is questioned in a later SCS certification of BP&L lands (see earlier quote regarding feller bunchers).
  • The team once again states that "the goal of certified forest management should be restoring the quality of the forest. This may, in some cases, lead to consideration of longer rotation lengths."
  • Final comments:

    The SCS team, in this section is exceptionally polite. It talks in generalities and asks Irving to consider changes, such as not overcutting forested wetlands, not compacting or desiccating soils, making harvesting more sensitive to soil type, not putting trails in wetlands and causing excessive rutting, returning slash and tops back to the soil, and lengthening the rotations. These issues, including rotation length, are not trivial. Indeed, the reliance on even-age silviculture that does not mimic natural stand regeneration patterns clearly veers from the ideal performance. The fact that the team raises these issues and makes these suggestions implies Irving is not doing what it ought to. The score of 85, therefore, represents serious grade inflation. SCS is, apparently, not measuring how far Irving’s practices veer from the ideal, but, rather, how far the practices veer from the extremes listed in the non-sustainable thresholds.

    B.3. Wildlife Management Actions, Strategies, and Programs

    SCS grade: 92

    Ideal performance:

  • Practices incorporated that "retain or create desirable habitat features such as vegetation suitable as wildlife food, hard and soft mast, standing trees suitable for cavity nesting, large fallen logs for shelter, and vegetative cover sufficient to provide both horizontal and vertical habitat diversity." (OM, pg. 34).
  • Non-certification threshold:

  • Extirpating species.
  • No wildlife considerations in management.
  • "Chronic adversarial relations" with pertinent government officials. (OM. Pg. 35)
  • Evidence from PCS of actual practices:

  • Irving’s position is that "fish and wildlife are a public resource that occurs on company lands and deserves the company’s careful stewardship." (PCS, pg. 29). The SCS team concurs, but encourages Irving to develop "proactive" programs, presumably because they see this lacking in some areas. (PCS, pg. 30).
  • The team thinks the fish and wildlife management could be improved through following a series of suggestions for listing, assessing, developing goals, educating foresters, and monitoring progress. Presumably, if the management could be improved, then it has not reached ideal performance.
  • The team "encourage" long-term management plans for deer wintering areas (DWAs) before any cutting takes place. "Irving’s management activities in DWAs will be the specific focus of future audits." Obviously, Irving’s DWA management must be a concern of the team, otherwise, why would they have such concerns and want to focus on this in future audits?
  • Final comments:

  • The SCS team talks about Irving’s efforts with DWAs, riparian zone buffers, eagles’ nests, and other activities that, actually, are required by law. The PCS does not give details of how these special management zones are managed. What is required stocking for buffer zones (including ones for very small streams)? How does Irving manage its DWAs and how does it plan for replacement stands in the future?
  • The team earlier (PCS, pg. 25) stated that Irving foresters "have more to learn" about recognizing quality dead downed debris and cavity trees. Thus Irving does not rate the ideal score for this item.
  • Wildlife is not just game species--it includes all fauna and flora. Irving’s management of spruce-fir is skewing the landscape of that stand type to be dominated by young and pole-sized trees, while reducing late-successional habitat to exist in thin bands in riparian zones.
  • The team did not discuss the need to have large areas of interior, late-successional habitat that is not in thin bands (riparian zones) or fragments and that can support viable populations of species that require such habitat. The team did talk about Irving’s attempts to provide "connectivity," but did not evaluate whether thin "corridors" are adequate for all species and whether, in the case of spruce-fir, if there is any substantial interior habitat to connect.
  • The non-certification thresholds (such as extirpating species or having an adversarial relationship with government agencies) are so low that one wonders what could be lower.
  • The 92 grade ("A") seems high for a company that is being exhorted to improve on so many basic fronts. Here the scoring should be based on variance from the ideal, rather than from what is listed as the non-certification threshold.
  • B.4. Watercourse Management Policies and Programs

    SCS grade: 95

    Ideal performance:

  • Management is conservative and "places aquatic and riparian covens (sic) above timber considerations." (OM, pg. 35) (note: my dictionary defines covens as "an assembly of witches.")
  • Riparian zones are of adequate dimensions to assure resource protection.
  • "Management maintains water quality and fish habitat and riparian habitat conditions associated with undisturbed forest." (OM, pg. 35)
  • Non-certification threshold:

  • "Frequent and substantive non-compliance" with laws and regulations.
  • "Substantial and persistent ecosystem disturbances" in watercourse zones generated my management activities. (OM, pg. 36).
  • Evidence from PCS of actual practices:

  • In connection with stream crossings, the team "did notice a few site-specific examples of erosion but these were the exception, and we were assured that they would be identified during periodic monitoring and repaired..." (PCS, pg. 32)
  • The team "expressed concerns" about Irvings "virtually straight roads" and the difficulty of avoiding streams and wetland impacts. (PCS, pg. 33). Irving analyzed the problem and reported that only 1% of roads went through cedar stands and non-forested areas when these types make up 19% of Allagash Timberlands.
  • While the team "concurs" with Irving’s analysis, "nonetheless, we also observed site-specific instances where putting a slight curve in an otherwise straight road would have avoided a wetland completely..." (PCS, pg. 33).
  • The team is "impressed" that Irving has increased the riparian zone beyond what is legally called for, but the team does not tell us what stocking Irving requires for this zone, especially for small and intermittent streams.
  • Final comments:

    Since riparian zones are supposed to not only protect stream quality (from siltation, nutrient pollution, temperature swings, and extremes in flow), but also provide nesting and migration habitat, they should be larger than what is required legally. What is now legal includes cutting right up to streamside with small and intermittent streams and having buffers of 75 feet for streams a little larger, where all that is required is "shade" (trees are not even mentioned in the LURC regulations).

    Irving does cut in its riparian zones. According to the IMPS, Irving expects to get 8% of its spruce-fir volume from riparian zones. (IMPS, pg. 7). The SCS team neglected to say what the cutting standards are in these zones. For 250 foot riparian zones, Irving’s Standard Operating Procedures calls for contractors to follow LURC guidelines. For the 200 foot buffers for streams that appear on USFS maps, Irving has a 15 foot no-cut zone, but allows overstory removals in the rest. 87% of the 200 foot buffer, therefor, can consist of 5 foot high trees. Standards are even lower for intermittent streams.

    The ideal performance would be to maintain riparian habitats in conditions associated with undisturbed forests--which means encouraging well stocked stands with large trees and plenty of cavity trees and potential cavity trees. The Maine Council on Sustainable Forest Management and Biodiversity in the Forests of Maine both recommended stocking of around 65-70% of full crown closure for all water bodies, even small streams (where forested buffers should be 75 feet wide at a minimum). The SCS team did not indicate whether these recommendations were being met, and therefore they give no grounds to support their grade of 95.

    If riparian zones are to function as wildlife corridors, or nesting habitat, then they need to be fairly wide so as to offer interior forest and not just edge. Fifteen foot buffers surrounded by overstory removals are simply inadequate to serve such purposes (and are questionable for protecting water quality as well). If the size and conditions of the riparian zones veer from undisturbed forest and recommended stocking, these buffers do not rate an "A." Comparing Irving’s practices to regulations that are inadequate is a form of grading on the curve, rather than grading based on variance from the ideal.


    B.5. Pesticide Use: Practices and Policies

    SCS grade: 90

    Ideal performance:

  • "Pesticides are skillfully used only when absolutely necessary and unavoidable to correct and ecological imbalance caused by stochastic events or man’s interference with natural ecosystem functioning." (OM, pg. 36)
  • "Forest management practices (e.g., silvicultural systems) are selected and designed so as to substantially reduce or eliminate future dependence on pesticides." (OM, pg. 36)
  • Non-certification threshold:

  • "Forest management practices are selected that heighten dependency on pesticides." (OM, pg. 37)
  • Additional statements:

  • "The use of chemicals as an expediency or as an indispensable facet of broadly applied silvicultural prescriptions is fundamentally incompatible with the precepts of sustainable forestry." (OM. Pg. 36)
  • "The objective of a well-managed forest is to minimize the use of chemical pesticides, applying them as a management tool only in limited circumstances and under carefully controlled conditions." (PCS, pg. 33).
  • Note: this statement of the Allagash Certification Summary makes it sound OK to justify use of chemicals if you "minimize" the use and only spray them in limited conditions. But this should not trump the previous statement that states you should not be using silvicultural system that rely on pesticides. If you do use systems that rely on pesticides, but you minimize the use, this should not lead to a grade of "A"--it should lead to a grade below 80.

    Evidence from PCS of actual practices:

  • "Over the last nine years, the area treated with herbicides ranged from 1,800 to 6,000 acres per year." (PCS, pg. 5)
  • "At current planting rates, Irving estimates an annual spray rate of approximately 1,750-3,000 acres in coming years." (PCS, pg. 33)
  • "Treatments have typically been conducted on 95% of planted stands between 2 and 5 years of age..." (PCS, pg. 5)
  • In 1999, Irving used Garlon 4 on around half of its herbicide spray plots acres. (PCS, pg. 34-35). Garlon was one of the chemicals listed in the Corrective Action Request for the Black Brook district.
  • "In general, the team’s concern, which is shared by some stakeholders, is that herbicide use reduces the structural diversity of the stand for the life of the stand, creating, less diverse planted softwood stands. Our conclusion is that there is an initial degradation of the plant community following clearcutting and herbicide application. This effect, however, seems to be temporary, although it can be measured in years." (PCS, pg., 35) (Note: this is an admission that herbicide use does reduce diversity over thousands of acres each year. Given that herbicide use is planned to continue--this maintains a percentage of forest in such a simplified state).
  • "The team is generally comfortable with Irving’s use of the clearcut prescription." (PCS, pg. 34). (Note: The team is comfortable, therefore, that Irving is one of the biggest clearcutters in the state--see figures in Appendix I of this document).
  • Final comments:

    The team chose not to address the pesticide use in Irving nurseries or the potential pesticide use that will be used on plantations, or Irvings’s history of intensive spraying for spruce budworm in the past. The team also did not discuss to what extent Irving sprays sites more than once with herbicides.

    The Irving Management Plan Summary has precisely one paragraph on herbicides, with no real data. Within this document is a sentence, "It is our policy to utilize herbicides only where absolutely necessary." (IMPS, pg. 9) Apparently, Irving thinks (and SCS agrees) that it is absolutely necessary to spray on thousands of acres per year and to be one of the biggest forestry pesticide users in the state of Maine.

    The SCS team in this criterion has failed to assess how far Irving has strayed from the ideal performance by Irving’s choice of silvicultural systems that depend on pesticides. Proof that it is not "absolutely necessary" to spray thousands of acres with herbicides per year can be found by looking at the Bureau of Parks and Lands and lands managed by Seven Islands, both of which SCS is quite familiar, and neither of which uses anywhere near as much pesticides as does Irving. In SCS’s certification report on the BP&L (pg. 81), the team states that "the BP&L does not engage in clearcutting, the prescription that most often leads to some herbicide use."

    In this criterion, SCS uses a form of logic that does not pass the straight-face test. Irving does more clearcutting and planting (as a percentage of ownership) than almost any other landowner in the state. These are systems that "heighten dependency on pesticides" (which is a non-certification threshold). Indeed, Irving is one of the top herbicide sprayers in the state. Because Irving is taking steps to reduce spraying (it "only" sprays 95% of its plantations, rather than 100%), the SCS team has given Irving a low "A." Giving a 90 to a landowner that mitigates a practice that is still below non-certification threshold is very serious grade inflation.

    B.6. Ecosystem Reserve Policies

    SCS grade: 88

    Ideal performance:

  • "Ecologically significant areas are identified and mapped within the ownership." (PCS, pg. 37)
  • If limited in abundance, these areas are "protected" or "reserved."
  • "The extent of reservations within an ownership is appropriately scaled to the size of the ownership."
  • Non-certification threshold:

  • The landowner is unwilling to reserve or transfer land from production regardless of ecological values.
  • Other relevant standards from Draft Indicator Standards:

  • FSC Criterion 6.4, "Representative examples of existing ecosystems within the landscape shall be protected in their natural state and recorded on maps, appropriate to the scale and intensity of operations and the uniqueness of the affected resources." (DIS, pg. 14)
  • Performance indicator g) "All remaining old growth stands within the defined forest area are given highest priority for inclusion in the reserve program. No commercial harvesting takes place in remaining old growth stands pending the outcome of these assessments." (DIS, pg. 15)
  • Performance indicator h) "Considering the scale and intensity of site disturbing activities within the defined forest area, and in light of current landscape-scale patterns of managed and reserved forests, managers of the defined forest area establish reserve areas to an extent that fairly balances ecological and economic considerations." (DIS, pg. 15)
  • Evidence from PCS of actual practices:

  • Irving has either 26 unique areas on 6,805 acres, or 25 sites on 12,050 acres depending on whether you are reading page 6 or page 36 of the PCS. If the latter figure is correct, the average size of these unique areas is 482 acres.
  • Irving cuts wood in many of these "protected" areas. Indeed, 3% of Irving’s spruce-fir volume is coming out of unique areas. (IMPS, pg. 7).
  • The SCS team translates "representative examples of existing ecosystems," to mean "exemplary natural communities," which the Maine Natural Areas Program is screening on Irving lands. (PCS, pg. 36)
  • The team was concerned that Irving’s current field staff did not have the qualifications to spot rare natural communities or rare plants.
  • The SCS team does not believe that Irving’s land occurs on a High Conservation Value Forest (HCVF) or that Irving’s land makes up a HCVF, but that smaller HCVFs might be on Irving land.
  • In a discussion on roads, the SCS team (PCS, pg. 18) revealed that 410,000 acres of Irving’s land is accessible by road. This implies that 125,000 acres of productive forest are not yet commercially roaded.
  • On page 17 of the PCS, the team states that "this is not to imply that an entire ownership must be roaded, as the working forest component may not comprise the entire ownership." Yet there is no discussion in the section on "reserves" about the potential of unroaded areas to stay in that condition.
  • The SCS team noted in the PCS (pg. 18) that Irving constructed "a right-of-way through an enriched old-growth cedar habitat." This would seem to violate the DIS of not cutting any old growth pending the outcome of assessments (quoted earlier).
  • Although the ideal performance is to have ecologically significant areas identified and mapped, this has not yet happened on the Allagash Timberlands. The team, however, "has been assured that the outcome of this process will be identification of areas that should be protected in some fashion, either by prohibiting harvest or mandating moderated harvest regimes." (my emphasis) (PCS, pg. 37). The SCS team, therefore, believes that it is appropriate to cut in a representative reserve that is supposed to maintain the forest in its natural condition.
  • Final comments:

    SCS is interpreting a representative reserve system to mean "protecting" "exemplary natural communities," where "protection" can include putting in roads and cutting trees. Indeed, that is how Irving is currently "protecting" many of its unique areas, which make up only 2% of its productive forest. These "protected areas" only average a few hundred acres in size--which is totally inadequate for consideration as serious ecological reserves. The Scientific Advisory Panel of the Maine Forest Biodiversity Project suggested a minimum average of 5,000-12,000 acres for an individual reserve in an ecological reserve system. In New Brunswick, the minimum average suggested by scientists was 60,000 acres.

    The Precautionary Principle suggests the wisdom of emulating the natural processes and structures of unmanaged forests to ensure that species (which are adapted to these processes and structures) are not lost. To the extent that managers intensify management in a way that simplifies, fragments, or converts the forest, the need for ecological reserves increases--if protecting biodiversity is a priority.

    Since Irving is doing intensive management on a fairly ambitious scale in the spruce-fir ecosystem types, one could reasonably conclude that to balance this out, there should be a fairly ambitious reserve system in these same types. Indeed, this type of balance is called for in DIS indicator "h" (quoted earlier in this section).

    Although one of the SCS certifiers, Bob Seymour, has endorsed the "Triad" model, where the forest is divided into a non-clearcut matrix, an intensively-managed sector, and a reserved sector, he has certified Irving, which lacks the reserved sector. What is being promised is not a true reserve sector--but, rather, tiny examples of some community types--where there is an option to cut in some of these examples.

    Maine only has around 2% of its land in ecological reserves. Most of this is in Baxter State Park. The Maine Forest Biodiversity Project found the current reserve system inadequate to create a true representative reserve system. Scientist, Janet McMahon, did an inventory of current public land for the MFBP to see to what extent this land base could complete a reserve system. Her conclusions were that:

  • The median size of reserves would only be 1,893 acres for lands that met their criteria.
  • Only 25% of potential reserves had the scientific advisory committee's minimum acreage.
  • Only 23% (16 of the 69 potential reserves) would be "self contained" ( have the ecosystem all in reserve boundaries).
  • Only 46% of ecosystem types are represented at least once by geographical area in the potential reserves.Ÿ

    Another report done for the MFBP was Biodiversity in Maine, an assessment of biodiversity by species and ecosystem type. This report concluded that, "Eight of the 25 forest community types in Maine are rare; of the types that are not rare, good natural examples are rare. Natural forest diversity, in common as well as rare types, is not adequately represented or protected within the lands that are currently in public ownership or private conservation ownership."

    In other words, it is not just rare ecosystem types that are needed for protection, but also common types, because these common types are those most often roaded and cut. Given so few acres exist of exemplary forests representing all ecosystem types, it will be necessary to use forests currently in the timber base and restore them to more natural conditions if Maine is to have a complete and functional ecosystem reserve system. This reasoning further implies that forests that are currently in the timber base could be considered as HCVFs.

    Indeed, the Principle 9 Advisory Panel Recommendation Report Draft (Version 1.2--March 2001), concluded, (pg. 5), that "Identification of HCVFs is most urgent in regions where protected areas networks are deficient or incomplete [...] Unprotected and under-represented forest types have higher conservation priority than types well represented in protected areas."

    While it is laudable that Irving is working with the Maine Natural Areas Program, this alone does not qualify the company for a high grade for this criterion. The company currently does not have a representative reserve system as required by FSC Criterion 6.4. Furthermore, to the extent that Irving relies on intensive management in the spruce-fir type, it should be balancing this with a reserve system in the same type. By not doing so, the company is violating the Precautionary Principle, which is the basis for FSC Principle 9. That Irving intends to put 500 miles of road into a roadless area, and has already put a right-of-way through an enriched old-growth cedar stand raises even more questions about the grade of 88 given to Irving. SCS should be grading on actual practices, not promises.

    C.1. Financial Stability

    SCS grade: 98

    Ideal performance:

  • Management decisions are driven by resource conditions rather than financial demands.
  • Non-certification threshold:

  • "Short-term financial exigencies lead to management decisions that materially compromise the long term heath and productivity of the forest." (OM, pg. 39)
  • Evidence from PCS of actual practices:

  • "The very size and diversity of the organization is a testament to the financial stability of the enterprise." (PCS, pg. 37). So, based on this logic, what happened to Diamond, Great Northern, St. Regis, Champion, and Scott all of which were large and diverse and none of which exists now?
  • Final comments:

    Irving is very strong financially. Irving also seems to be one of the more stable companies in Maine, and is quite likely to be around a long time. The stability of the company, however, does not translate to the stability of the communities dependent on Irving.

    One of the reasons for the company’s financial success is that the company can dominate markets and does respond to short-term market trends. Except for low-grade hardwoods, Irving has its own markets for most of the products from the woods. This dominance of markets gives the company a regional competitive edge.

    This competitive edge does not mean, however, that Irving is not responding to short-term markets. If the pull of the markets were not a major factor in management, how can one explain Irving’s intensive cutting of its spruce/fir stand type, and much less intensive cutting in stand types (such as hardwoods) where markets are poor? Other landowners, such as the BP&L, are demonstrating that spruce/fir can be managed as uneven-aged or for long rotations (100-150 years). If the goal is restoration of the forest to more natural conditions, Irving could be following that example.

    C.2. Community and Public Involvement

    SCS grade: 97

    Ideal performance:

  • "The forest, as a source of consumptive and non-consumptive resources (including environmental/aesthetic attributes) and a source of employment opportunity, contributes rather than detracts from the quality of life in affected communities, over the long run."
  • "The company is an advocate of sustainable forest management in public arenas of policy debate and formulation." (OM, pg. 40)
  • Non-certification threshold:

  • "The company, through its land management policies, marketing strategies, and community programs (or lack thereof) exhibits a fundamental insensitivity or indifference to the long-term interests of affected communities and regional economies." (OM, pg. 41)
  • "The company takes an active role in opposing the advancement of sustainable forestry concepts and principals." (OM, pg. 41).
  • Evidence from PCS of actual practices:

  • Irving gave a million dollar endowment for a professorship at the University of Maine (where Robert Seymour works).
  • The zoning regulations in Stockholm and New Sweden, passed in the 1980s by the communities in response to Irving’s aggressive clearcut and spray activities, "do not seem controversial at the moment." (PCS, pg. 39).
  • Irving gives a lot of tax deductible money to various local programs.
  • Final comments:

    Irving is improving its public relations with local communities. These relations used to be a real problem--to the point that a number of towns passed ordinances to restrict the company’s aggressive intensive management practices. This benign facade, however, drops when it comes to relations with contractors--a topic to be discussed later.

    More troubling is the impact of Irving management on local communities. The intensive management surely does not improve the aesthetics or wildlife benefits. There are people who are not that thrilled to live next to herbicide spray programs--including some organic farmers. It is possible that the majority of wood cut on Irving land is being milled in New Brunswick or Quebec and not in Maine. The SCS team gave no statistics on this important issue. If this is so, it means that value-added income is being lost, as well as potential jobs.

    There is a trend in northern Maine communities of populations falling, businesses leaving, infrastructures crumbling, and schools closing. Irving’s tenure in the region does not seem to be reversing these trends. The fact that Irving is stable and growing does not mean that the communities in which Irving’s land is located are also thriving and stable as well. While it is certainly admirable that Irving gives to the boyscouts, it would be far more beneficial to the community if the company paid better wages in the woods and sent more wood to mills in northern Maine than in Canada.

    The emphasis on benefiting local communities with employment is clear from the Draft Interim Standards performance indicators based on FSC Principle 4, criterion 4.1, "The communities within, or adjacent to, the forest management area should be given opportunities for employment, training, and other services." (DIS, pg. 6). One wonders, therefore, why there are so many foreign workers cutting, planting, and thinning on Irving land.

    In the Maritimes, most of the labor used to plant and thin young softwood stands is supplied by local silvicultural contractors. In Maine, however, most of this work is done by Central Americans. One cannot call a Central American "local" by any stretch of the imagination.

    Likewise, for years there have been controversies over the use of Canadian loggers in the Maine woods. Lately the percentage of Canadians has gone down on Irving lands in the Allagash district. Some contractors have argued that even many Canadian loggers find that working for Irving, because its payscale for wood is so low, undesirable. While it may be argued that Canadians and Central Americans are hired because labor is in short supply in Maine, the counter argument is that labor is in short supply due to the wages paid. If there really is a shortage, than the company should pay more money and initiate training programs to attract more local labor. Instead, local labor is leaving the area.

    Given that the land is foreign-owned, and profits leave the state (and country), much of the wood is milled in Canada, so value added leaves the state, many of the workers are from Central America or Canada and so wages leave the state, and the clearcut forests are surely not an attraction to tourists, one wonders how Irving deserved a score of 97 for community benefits.

    Likewise, when there are bills to limit liquidation or rationalize riparian zone standards, Irving representatives have not been in the forefront as advocates for sustainability. While the donations to community activities are certainly a mitigating factor, and the expansion of Maine mills is welcome, this is like clearcutting 25 acres, but leaving a small island of "reserve" trees behind, and then getting praise for caring about ecosystem structure. It lessens, but does not change, the basic problem.

    C.3. Public Use Management

    SCS grade: 95

    Ideal Performance:

  • "Harvest operations and road designs are modified so as to minimize aesthetic externalities, especially in the vicinity of high use areas." (OM, pg. 42)
  • Non-certification threshold:

  • "Land management actions ignore and/or compromise public use values of the forest." (OM, pg. 42).
  • Evidence from PCS of actual practices:

  • While Irving does allow public access to its roads, the harvest operations and road designs have aesthetic externalities (see discussion in section A.4. Forest Access).
  • Final Comment:

  • In early 2002, some locals were so upset with Irving’s gating of its forest in Allagash townsip and charges for access that they burned down two gatehouses. There are some houses beyond the checkpoints. Even though the inhabitants who live beyond the checkpoints do not have to pay a fee, the location of the checkpoints has been a contentious issue for years, and townspeople have asked Irving to move checkpoint locations outside the town boundaries.
  • C.4. Investment of Capital and Personnel

    SCS grade: 95

    Ideal Performance:

  • "Investments (direct or indirect) are regularly made in machinery such as processor-forwarders and feller-bunchers to keep the harvesting operations at the cutting edge of technical efficiency and environmental protection."(OM, pg. 43)
  • Non-certification threshold:

  • "Because of inadequate training and supervision, employees are unable to properly implement the management plan." (OM, pg. 43)
  • Evidence from PCS of actual practices:

  • In earlier sections I offered evidence that feller bunchers are not on the "cutting edge" when it comes to efficiency and environmental protection.
  • In earlier sections I cite the SCS team’s concerns that there are insufficient foresters given the acreage and that supervision of cuts may not be up to par.
  • Final comment:

    Given just Irving’s very indadequate investment in foresters who can mark and supervise cuts, the SCS grade is inflated. Adding on Irving’s reliance on feller bunchers, run by independent contractors marginal operating budgets, brings further question to awarding of such high grades. Irving is investing in many areas (such as mill improvements) but is clearly stinting where it counts in the forest--foresters and woods workers.

    C.5. Employee and Contractor Relations

    SCS grade: 92

    Ideal Performance:

  • The employee compensation package is an industry leader.
  • "The company is as concerned with the welfare of contractors operating on their lands as it is concerned with the employees' welfare. The decision to contract for field work is not made strictly as a cost reduction measure that is borne by the contract laborer." (OM, pg. 43)
  • "Employees and contractors can derive a competitive, living wage from association with the company." (OM, pg. 44)
  • Non-certification threshold:

  • "The company’s policies towards employees and contractors amount to exploitation." (OM, 0g. 44)
  • "Working conditions and benefits to contract laborers are substantially inferior to employee work conditions and benefits."
  • "There is little or no security in employment or contracting relationship."
  • Evidence from PCS of actual practices:


  • There has been a shift to contract-for-logging services (CLS) in which landowners sell delivered logs to mills and then contract with loggers to cut and haul them. "This system enables owners to increase their returns on wood cut." (PCS, pg. 42)
  • "The demand for labor in harvesting has declined dramatically as the productivity of the machines has increased." (PCS, pg. 42)
  • "The capital intensity of the logging business has increased, and margins in logging have fallen."
  • The absolute number of contractors has declined, and fewer people want to work in the woods..."
  • Note: These trends show that even though labor productivity has gone up and landowner profits (through CLS) have gone up, contractor margins have gone down, and fewer people want to work in the woods--because it does not pay to do so.

  • "In our observation, the employees are motivated and enthusiastic. The challenge of nearly tripling the area under management is invigorating the is our observation that it attracts and retains competent, high-energy people for long periods." (PCS, pg. 43). The team, unfortunately does not back up this statement by giving statistics of turnover rate of employees.
  • Irving’s contract rates for mechanical operations assumes two-shifts (80-100 hours per week). "Operating such an investment on a single shift alone has proven to be uneconomical. Contractors operating for Irving must get used to two shift operations wherever possible." (PCS, pg. 43). The SCS team did not consider the implications of double shifts, including extra wear on equipment in a shorter time, or the problems of maintenance when there are several shifts responsible (and both are trying to maximize cut in a given amount of time).
  • "Typical shifts on many of the largest machines are 50 hours."
  • "There are many stories of contractor discontent with this management approach. It is easy to see these methods as a form of squeezing against suppliers with little or no bargaining power. On the other hand, it is a means of driving cost out of the system entirely, and has much in common with business trends of this sort in the entire U.S. economy today." (PCS, pg. 43)
  • The team interviewed 6 current contractors. "We found what we would expect to find in a relationship where some tension is normal at a time of unusual stress and change in the Maine logging industry."
  • The loggers were willing to "vent complaints." The team did not know "what weight to place on anecdotes." "There is no accounting system to which we can appeal for data on many points, and for every complaint, there is ‘another side of the story,’ which is obviously difficult to ascertain without intensive investigations." (PCS, pg. 43)
  • "...many contractors have only a limited choice of where to work, and they feel boxed in."
  • "Statements that Irving pays the ‘lowest rates’ in the industry were common, along with statements that other owners are cutting rates to follow suit."
  • "Mechanical contractors, once having made the decision to invest, often feel pressured to accept whatever terms they can negotiate." (PCS, pg. 43)
  • The team sees a key issue being the extent that Irving can retain these contractors--this will be subject to future audits.
  • When wood is not sold to an Irving mill there can be delays. "...wood cut may not get hauled and paid for in as timely a manner." The SCS team seemed to be unaware that there is a state law that requires payment for wood cut within 14 days. Irving is thus breaking contracts and violating laws and yet it still gets a 92.
  • Silvicultural contractors

  • Most of the planting and thinning is done by Central American migrant laborers. The "wage" in 1999 was $10.09 and hour. The team did not discuss how much of this "wage" was piece work and how much of this wage paid for equipment, transportation, food and lodging for the workers.
  • The SCS team sees use of migrant laborers as a passive acceptance of larger market forces, rather than an active attempt to cut costs. "There is a nationwide trend toward the use of migrant workers for silvicultural contracting." (PCS, pg. 44)
  • ...due to the age structure of the workforce in this area, the wages offered, and the arduous nature of the work, the use of migrant workers does not result in any American workers losing employment opportunities." This statement makes it clear that wages for this type of work are too low to attract American workers. The reasoning here is that low wages are a given, and that if Americans don’t want to work at these wages, it is justified to ship workers from Third-World nations for whom these wages are acceptable.
  • The team observed that for these migrant workers, "morale seemed relatively high, and most of the men interviewed indicated they were glad to have the opportunity to work on the Allagash Timberlands, and all were happy with the hourly wage." The SCS team neglected to describe the H2B contract relationship, however, where these workers can only work in this country for the company to whom they are bonded. If these workers complain, they can be kicked out of the country. They have virtually no bargaining power and are completely at the mercy of their employers.
  • "Most sent much of their salary home to support their families, and they indicated that the remittances are an important contribution to the local economies back home." (PCS, pg. 44). The "local economies" that are supposed to benefit from silvicultural practices, however, are the ones in which the practices occur.
  • The mills

  • There is no union at the Irving Forest Products mill.
  • The Pinkham mill has hired dual citizens in an effort to get skilled workers. This mill has a union. "Retirement and healthcare policy changes have apparently caused concerns among workers." (PCS, pg. 45)
  • SCS summing up

  • "In the area of harvesting contractors, responses we received were diverse. Some were comfortable with the working relationship, while others were quite bitter."(PCS, pg. 45)
  • "Considering the issues in the areas of migrants, forestry employees and millworkers, and contractors, we have noted the frequent expressions of discontent, but at the same time we understand the overall market pressures are part of the source of the problem." (PCS, pg. 45)
  • "In scoring, we are inclined to lay more emphasis on the investment and employment creation we have seen, than on the negative points and complaints uncovered." (PCS, pg. 45). This "accentuate the positive, eliminate the negative" attitude allowed the team to come up with a grade of 92.
  • Final comments:

    The SCS team gives some fairly damning evidence of a squeeze on contractors. The contractors’ complaints were labeled "anecdotes" and the team suggested that there was "another side of the story." The "other side" that the team mentioned was that the squeeze on contractors was an industry-wide trend, suggesting that Irving was being passively swept up in this trend. The team suggested monitoring the situation to see if this was a temporary market shift or something more serious, even though these trends did not start the year Irving got certified.

    But there is another side to this "other side" that the SCS team chose not to address. The market for woods labor in northern Maine is not "free." It is an oligopsony--where just a few big players control purchasing. This oligopsony is an even more potent force for having power over labor than the threat of Canadian labor. Irving is thus not a passive player--it has control over that market, and is using its position to cut costs. And it has been successful in cutting labor costs:

  • Labor productivity has gone up, due to mechanization.
  • Mechanization has lowered injury rates and workers’ compensation costs have gone down.
  • The relative cost of machinery has gone down, due to double shifts.
  • The cost of contractors has also been reduced through contracted logging services.
  • Irving is saving on the cost of foresters and forest technicians by having feller-buncher operators make the decisions of what trees to cut.
  • These cost reductions for Irving have not been passed on as higher wages for either contractors or loggers. These cost reductions for labor have been used to leverage higher profits for Irving. Indeed, the PCS suggests contractor margins have gone down.

    Irving has further reduced costs (and the SCS team neglected to discuss this) by going from large contractors to smaller contractors--owner-operators. The report on bonded labor stated that these small independent contractors and subcontractos are not subject to protections such as WC, OSHA, FICA, or Unionization. "...from the standpoint of US labor law, these workers do not exist." (pg. 64) These smaller operators, making huge investments in machinery, are even more at the mercy of Irving. If Irving fires them, they have nowhere else to go with their equipment. And they have big payments to make. What the contractors told the interviewers is that Irving is not just following an industry-wide trend--Irving is setting the trend. Irving is not forced to treat contractors this way; it chooses to do so.

    At the time Irving got certified, loggers and truckers, in unrelated actions, were blockading the border with Canada in protest (to some extent) over the squeeze on labor. Truckers complained that they were forced to drive overloaded trucks and work long hours just to break even. The loggers’ blockade led to the Pan Atlantic study done for the Department of Labor. This study showed that while landowner profits over the last few decades went up 169%, real wages for loggers went down 32%. This study uncovered a sobering trend: "The intergenerational chain which has produced loggers in the woods for perhaps hundreds of years may be strained to the point of breaking.." (pg. 198) (my emphasis). One logging contractor quoted in the Pan Atlantic Study claimed that Irving cut his rates by 30% after the company bought land from Bowater. "Irving has taken over," he said, "they set the low prices and the competition will follow. The State of Maine needs to protect its people. Logging will never be the same."

    The "shortage" of labor in northern Maine is not due to the remote location. It is a shortage of people who want to work at wages considered too low. When oil companies wanted to build a pipeline in Alaska several decades ago, they had no trouble finding workers when they paid good wages. Indeed, workers came to Alaska all the way from Maine.

    The Maine Center for Economic Policy did a study estimating the living hourly wage for various counties and metropolitan areas on Maine for 1999. For Aroostook County, the figures were:

    Living Hourly Wage for Aroostook County, 1999

    2 parents 2 parents

    Single parent Single parent (1 earner) (2 earners)

    Single 1 child 2 children 2 children 2 children

    8.12 9.87 12.46 15.33 20.13

    This estimate of living wage was based on local costs for food, housing, transportation, phone, health care, clothing, personal care, and other factors. For loggers, the costs for transportation would go up, because a more substantial vehicle is needed and the distances traveled are greater. Based on this information, it becomes more evident why loggers working at wages of 9 or 10 dollars an hour end up working 50-60 hours per week. They need the overtime to break even.

    The study suggested that many families are not earning a living wage and that the result is many families have large debts, they go without, or they require public assistance. The cost of living is lower in Central America (which has a lower standard of living) and Canada (which has less expensive health care costs), and thus the wages are more acceptable to workers from these regions.

    Local labor has little ability to negotiate in the economic climate of northern Maine. The SCS team did not discuss what types of contracts Irving has with its small contractors and to what degree Irving can unilaterally change the terms. The Irving contract that contractors have to sign has the following clause in it:

    "... Irving shall have the right to terminate this agreement whenever and for whatever reasons it chooses, including but not limited to market conditions. Such termination shall be effective immediately after written notice is given to the Contractor or any other time specified in such termination notice. In the event of such termination, the QILC shall have ten days to remove itself and all of its equipment, supplies and materials..." There are no grievance procedures for contractors if they feel that Irving is breaking the contract or unfairly withholding payments.

    Certification has led to increased responsibilities for contractors--such as returning tops to the trails, leaving more wood behind in configurations that slow production, or making yards smaller and trails further apart. While these practices may be marginally better for the woods, the contractors are losing production with no reward. One contractor told me that his rates with Irving have not changed in 10 years, even though his expenses have doubled. When he complained about this, he was told to go on a double shift.

    Irving does have a clause in its contracts relating to certification:

    "Irving is committed to fostering Best Management Practices in its intensive forest management practices in working towards it (sic) goal of Green Forest Certification. To this end, Irving may, but is not required to, make payment(s) to QILC as a premium when performance under this agreement demonstrates, in Irving’s exclusive judgment, superior compliance with the terms and conditions of this contract so as to further extraordinarily Irving’s commitment to Green Forest Certification. Premium payments, if any, may be monetary or otherwise, and shall be made, if at all, at Irvings’s sole discretion and under terms and conditions which Irving alone determines to be prudent."

    Irving does seem to be a stable, if not growing, entity in northern Maine, but as stated earlier, this does not always translate to stability for those from the local communities. One 4th generation logger from the Allagash area told me that an Irving forester had told him, that Irving may pay the lowest, but it will be around the longest of the big landowners. The logger’s response to this was, "Yes, Irving will still be here, but I won’t."

    The SCS grade of 92 for employee and contractor relations has certainly raised a lot of eyebrows in northern Maine, where people are familiar with Irving’s practices. The evidence from the PCS (and from other sources) shows practices that veer widely from the Ideal performance. Indeed, the word "exploitation," a non-certification threshold, easily comes to mind.





    Appendix I

    Figures on intensive management

    What percentage of the spruce-fir forest in the Allagash Timberlands is under intensive management and how short are the rotations? This basic information is not contained in a direct form in either the certification Public Summary (PCS) or Irving Management Plan Public Summary (IMPS). To assess many certification issues--both silvicultural and biological, this information is basic.

    Fuzzy math. Unfortunately, there are a number of errors in the PCS, IMPS and Irving brochures, that make calculations difficult:

  • For plantations, for example, the PCS (pg. 5) says that by June 1999, there were 21,830 acres planted, but elsewhere in the PCS and IMPS, the figure is 8,333 acres.
  • On pg. 6, the PCS states that there are 25 unique area sites adding up to 12,050 acres. On page 36, it states that there are 26 unique areas adding up to 6,805 acres.
  • On page 12, the 25 year AAC for spruce-fir is listed as 90,400 cords (or .17 cords per acre). On page 13, the AAC for spruce-fir is listed as 77,000 cords per acre. This is also the figure given in the IMPS for the 25 year AAC.
  • On page 4, the PCS states that 70% of cutting is done with feller bunchers, but on page 18 the figure goes down to 65%.
  • On page 42 the PCS states that the Irving plan is to PCT (pre-commercial thin) 3,000 acres per year. In the IMPS (pg. 8) the figure is 2,400 acres. On page 9 of the same document the figure given is 2,300 acres.
  • These disparities do not inspire confidence in the reader and make it difficult to determine what is the actual scale of certain types of activities in specific areas.

    Besides the confusion over numbers, there is also variability over how the numbers are used. The two documents, for example, give plantations as a percentage of total acres (to make it look insignificant), but special management zones as a percentage of productive acres (to make it look more significant). While the PCS and IMPS add up the 10% riparian, 5% deer yards, and 2% unique areas to create a special management zone (SMZ) of 14%, or around 74,900 acres (implying that there is overlap), the Irving Allagash Woodlands Management Plan brochure adds it all up to be over 90,000 acres or 15% of the entire holding (actually it would be closer to 16%, but who’s counting?).

    Spruce/fir acreage in the Timber Management Zone. I have been able to make estimates of spruce-fir acreage, the extent of intensive activities, and potential rotation length (but this may change with thinning in the next 25 years) despite the failure of both SCS and JDI to provide that information. My estimates are conservative, so if I err, it is on the side of caution.

    Below I reveal the process and sources with which I made the calculations so that Sierra Club can determine which ones are most likely to be "in the ballpark." I recommend that the Sierra Club not rely on my figures, however. I did the calculations to show why there is strong room for concern. I will separately make a list of questions that Irving and SCS should answer for the auditors so that the auditors do not have to guess over these crucial issues as I have had to.


    Extent of spruce/fir

    Total acreage: 569,320 (PCS and IMPS)

    Productive acreage = 94% of total = 535,161 (PCS and IMPS)

    Acreage of softwood = 35% of total = 199,262

    On page 20 of IMPS are two graphs of Western Ecosystem and Eastern Ecosystem

    From these we find that

    Percent of softwood in WE = 34%

    Percent of softwood in EE = 46%

    These figures are for productive forest.

    For whole productive forest we can determine that softwoods make up (.35/.94) or 37%

    Based on this we can determine that 75% of the area is in WE and 25% in EE

    (to test .75*.34 + .25*.46 = .37)

    In 1999, percent of bs + s/f (black spruce and spruce/fir) in WE was 22%

    Percent of bs + s/f in EE was 29%

    Therefore, using the above determined weightings,

    the percent of bs +s/f for productive forest is 24% or (.24*535,161) 127,100 acres.

    Planned extent of spruce/fir in 80 years

    The same chart on page 20 of IMPS gives projections of stand types 80 years from now.

    Based on these charts and the same mathematical reasoning,

    I estimated that the percent of bs and s/f 80 years from now would be 30% or 161,886 acres.

    This means that in 80 years, s/f will increase by 34,785 acres, or 448 acres per year on average.

    According to the charts in the IMPS, most of this increase would come from decreases in intolerant hardwoods, intolerant mixedwoods, and cedar.

    My experience viewing Irving management on the ground is that Irving has clearcut some tolerant hardwood and tolerant mixedwood and converted them to plantations. The company has also removed softwoods from mixedwoods, turning them into hardwoods. I have serious doubts about the accuracy of the figures supplied by Irving. For this exercise, however, I will use the Irving figures as if they were reliable.

    Spruce/fir in SMZ and TMZ?

    Calculating the percentage of spruce-fir in Special Management Zones (SMZ) is less exact.

    While 10% of productive forest is in riparian zones, 5% in deer yards, and 2% in unique areas, this only adds up to 14%, not 17%. There is obviously an overlap of deer yards and unique areas with riparian zones. Also, the percentage, 14%, does not carry across all timber types.

    The PCS states (pg. 32) that softwoods are by far the dominant forest type in the riparian zones.

    If we are conservative and call "dominant" at least 60%, then we can estimate that at least 17% of softwoods are in riparian zones.

    Since there is overlap with deer yards and unique areas, but since deer yards are predominantly softwood, by necessity, and since the IMPS (pg. 7) shows 8% of s-f volume coming from riparian areas, 4% from deer yards, and 3% from unique areas, (15% total). I will estimate (and here I am making a conservative guess) that anywhere from 20-25% of spruce/fir acreage is in SMZs. I am assuming that Irving has tried, to the extent possible, to put deer yards in cedar, if the yards are not in riparian zones. If the figure is 20%, that means that JDI is cutting the spruce/fir SMZ at around 75% of the intensity of the spruce/fir timber management zone (TMZ). That would be pretty heavy cutting to be called "protection."

    Indeed, heavy cutting is allowed under Irving’s Standard Operating Procedures. Only 15 feet of the 200 foot buffer zone around streams needs to be standing trees. The rest, 92.5%, can be subject to overstory removals and consist in 5 foot high trees. For the sake of being conservative, I assume that only 5% of the spruce/fir type is actually protected from even-aged management.

    So, what we are establishing is that the actual spruce-fir and black spruce TMZ (where even-aged management can be practiced) is probably around 95% of total for that type or less than 120,745 acres.

    In 25 years, this figure will increase by (448*25) 11,200 acres to 131,945 acres.

    Planting. Both the IMPS and PCS state that JDI is going to plant 1200 acres of trees a year for the next 25 years.

    In 25 years, the PCS (p. 5) states that there will be around 40,000 planted acres. That figures to be 30% of our estimate of the TMZ.

    Conclusion: You could conservatively estimate that more than 30% of the bs and s/f forest type in the Timber Management Zone will have been planted 25 years from now.

    Herbicides. For herbicides, the information is not helpful. For the last 9 years (PCS, pg. 5) between 1,800 and 6,000 acres were sprayed per year. No totals per year were given. A logical guess would be to find the average and multiply that by 9. That gives 35,000 acres sprayed up until 1999. For the next 25 years, Irving plans to spray from 1,800 to 3,000 acres per year (PCS pg. 33). That might average out to be 2,375 per year or 59,375 acres after 25 years. Total acres sprayed in 25 years would be 94,375. But we can not estimate this as a percentage of acres in the TMZ, because Irving has often sprayed stands more than once and might be spraying some herbicides in other stand types. We do know that Irving sprays 95% of plantation acres and a good percentage of natural regeneration cuts. The percent of the spruce-fir TMZ sprayed in 25 years could be anywhere from 50% to 70%, depending on how much double spraying goes on.

    Pre-commercial thinning. For PCT, the IMP states (p. 9) that 12,000 acres have already been treated and there will be around 2,400 acres of PCT a year for next 25 years. On the next page, however, this figure turns into 2,300 acres, despite the fact that the last year listed (1998) the acreage was 2,929 acres. And on page 42 of the PCS, the estimated average for the next 25 years is 3,000 acres. Go figure. Assuming 2,400 acres, in 25 years, 72,000 acres will have received PCT. That would be 55% of the high estimate of TMZ acres. If the average acreage of PCT is 3,000, the 25-year figure would be 87,000 acres--or 66% of the spruce fir type.

    Conclusion: You could conservatively estimate that more than 55% of the bs and s/f forest type in the Timber Management Zone will have received PCT 25 years from now.

    Spruce/fir rotation? Assuming that all acres that are planted also get PCT, the rotation for spruce-fir in the TMZ, using the highest, most conservative estimate of acres would be (112,880/2400) 55 years.

    That also assumes that all spruce-fir in the TMZ is even aged and all acres regenerated get thinned, even those planted. It also assumes that all spruce-fir that can get regenerated, even in "special management zones" is. Any change in those assumptions would lead to shorter, not longer rotations.

    Conclusion: You could conservatively estimate that the rotation for even-aged management of s/f in the Timber Management Zone is around 55 years, more or less. This rotation, however, could be lengthened out later by getting some spruce volume through commercial thinning. Irving (PCS, pg. 15) claims to not have a fixed rotation. For the next 25 years, however, this is the rate of regeneration cutting on an area basis.

    Clues that these statistics may be correct? Page 13 of PCS states that Irving is planning to cut 2.4% of s-f volume per year. If this were all even-aged, and if cut equals growth, that would work out to a 42 year rotation. Some of the spruce and fir, however, is coming from partial cuts in mixed woods, so this figure alone is inadequate.

    On pg. 21 of PCS, SCS suggests that in some areas, "high-yield, short-rotation forestry may be the best means of meeting future wood supply needs." This statement is both an admission to and a sign of acceptance of short-rotation forestry on Irving lands.

    How Irving’s intensive management compares to other landowners in Maine Despite the dilution of the intensive management with less drastic cutting regimes in other forest types, Irving’s use of intensive management stands out in Maine. Its rate of clearcutting as a percentage of the entire holding would put it as one of the top two clearcutters in the state, based on figures found in the 2000 Silvicultural Report of the Maine Forest Service.

    For 25 landowners with over 100,000 acres:

    13 clearcut less than .001% of their holdings

    10 clearcut between .001% and .25%

    2 clearcut between .26% and .75%

    In 1998 (IMPS, pg. 12) Irving clearcut .68% of entire Allagash Timberlands holdings.

    For the next 25 years, Irving plans to clearcut an average of .45% of entire holdings per year.

    Thus even Irving’s projected rate of clearcutting would put it in a range now occupied by only 2 landowners in the state ofMaine.

    Similarly, Irving’s use of herbicides is near the top. Although Irving may have reduced its use of clearcutting and herbicides, so have the other landowners in the state. In 2000, clearcutting made up only 2.5% of all cuts in the state. Herbicides were sprayed for release on 24,000 acres in the entire state, with 4,352 acres in Aroostook County. Herbicide use by Irving thus made up the bulk of herbicides in Aroostook.

    SCS is thus certifying a landowner that is a leading user of practices of which much of the public disapproves. Other certified land managers in the same region, the Bureau of Parks and Lands and Seven Islands, use very little clearcutting and very little herbicides, demonstrating that these practices are not necessities at the levels used by Irving.

    Rate of cutting for entire productive acres. Even using statistical dilution with hardwoods and cedar to mask the intensity of cutting in the spruce/fir stand type, if you look at the 25 year projected combined rate of clearcutting plus overstory removals (2,568 + 3,400) you get close to 6,000 acres of regeneration cuts per year. Taking out the 10% of the productive forest that is in riparian zones (I’m assuming, to be conservative, that Irving will clearcut or overstory remove most of its deer yards and unique areas), and discounting this by 50% to account for regneration cuts in the riparian zone (I’m assuming not so much heavy cutting in zones dominated by hardwoods) you get a possible regeneration zone for Allagash Timberlands of 598,403 acres. At the projected rate of regeneration cuts, it would take around 85 years to go through the entire zone where regeneration cuts are allowed. If we subtract areas where Irving plans to do uneven-aged management, this rotation shortens. Unfortunately, none of the SCS or Irving literature gives adequate information with which to make an estimate of rotations in even-aged stand types, but this upper possible estimate is far too low to be in a range that could be considered "natural." The natural rotation for stand-replacing disturbances in the Acadian Forest type is hundreds of years at a minimum, certainly not 85 or fewer years.

    Appendix II

    Stocking and growth of a fully stocked, two-aged, red spruce stand on the Weymouth Point Control Watershed, T4R12, Maine. Volumes are total stemwood; site index = 40


    Trees per acre

    Basal Area

    (ft2 /acre)

    1995 Volume (ft3/acre)


    Volume (ft3/acre)

    1990-94 Growth

    Mean Annual Increment since 1920








    Pre-1920 residual







    Total stand







    The culmination of the mean annual increment occurs when the annual growth is equal to the average growth over the life of the stand. This chart shows that in a red spruce stand with trees regenerated after the budworm outbreak of 1919 and a cohort of older trees (up to 275 years), neither the younger cohort (up to 75 years old) nor the older cohort had culminated the mean annual increment. The annual growth was still greater than the average growth. Since the non-certification threshold for SCS criterion A.1 is that rotations are well below the culmination of the mean annual increment, this information from Weymouth point brings into question the certifiability of Irving’s short rotations if they occur in red spruce.

    It is interesting to note that the annual growth in 1990-1994 is equivalent to around 1 and one fourth cords per acre per year of high quality, large diameter red spruce. Plantation management of boreal softwoods would be lucky to equal such a volume yield, but the trees grown in such plantations have high taper, big growth rings, and lots of knots, leading to lower quality and value.