Dear Moderator,
Please find attached our response to the CPF Global Core Set (GCS) Indicator Consultation. These comments are provided by the US Department of Agriculture (USDA) Forest Service Research and Development Branch with interagency consultation. Thank you for providing the opportunity to comment.
Regards,
Guy Robertson PhD
Acting Assistant Station Director for Science Program Development
Forest Service
Pacific Northwest Research Station
Portland, OR 97204
US Department of Agriculture (USDA) Submission to CPF Global Core Set (GCS) Indicator Consultation
Introduction
The following comments are provided by the USDA Forest Service Research and Development Branch with interagency consultation.
Thank you for the opportunity to comment on the GCS indicators. The USA has previously been engaged in this process through participation in the international expert workshop in Ottawa (May 2016) and the OLI meeting in Rome (November 2016). We are happy to see the progress made in producing the latest draft GCS indicators as they represent a marked improvement from the set emerging from the OLI meeting in Rome. The current GCS is sensible and clear, though there are a number of issues still left to be resolved (many of which are already noted in the TF meeting comments). The ongoing need for revision, and the impactful nature of the GCS if and when it is implemented, points to the importance of developing explicit provisions for the ongoing adaptation of the GCS up to and, importantly, after implementation.
Strong linkages between GCS and FAO FRA where feasible are an important aspect of the GCS development and implementation process. Several of our indicator-specific comments are derived from observations we have supplied as input to the FAO FRA process. These comments apply where GCS and FRA indicators are closely aligned.
Comments on Specific Indicators
Indicator 4: Forest area designated and managed for protection of soil and water. The various ecosystem services provided by forests are increasingly recognized, and many forests are designated and managed for a broad array of benefits. The current GCS (and FRA) emphasis on primary designated functions runs the risk of mischaracterizing and/or discounting multiple use forests in terms of their benefit provision, both for soil and water conservation and for other values.
The characterization of multiple-use forests has been a perennial challenge for the United States both in FRA reporting and in reporting out for the Montréal Process’s Criterion 4 (which focuses on soil and water conservation). We find that the true contribution of US forests to soil and water conservation is undercounted because this goal is not explicitly designated as a primary function in forests that nonetheless provide these services. A more complete accounting of benefits from multiple use forests is needed. This would likely first be implemented through the FRA (for example, through the inclusion of subcategories listing designated functions, including multiple use), but the GCS Indicator 4 would need to be adjusted accordingly.
Indicator 5: Employment in forestry and logging. (This indicator follows FAO FRA conventions). Forestry and logging is too narrow an employment category to adequately measure the contribution of forests to national economies. In the United States, for example, we estimate approximately 2 million people were employed in the forest sector in 2012, but our FRA 2015 submission identifies only 55,000 people employed in forestry and logging. Note that as the forest sector develops, a decreasing share of activity will be devoted to primary production such as logging and forestry, and an increasing share will be devoted to value-added production (this is true for agriculture as well). So employment trends will also be misleading, indicating declines in forest sector activity when the underlying cause may instead be shifts to value-added production. Finally, the amount and trend of forest sector value-added production is an important indicator of forest sector development in its own right.
As we strive to educate the public as to the importance of forests, including their contribution to national economies, we need a more accurate measure of total employment associated with the forest sector. This will require the inclusion of additional job categories in the FRA (and subsequently GCS).
Indicator 10: Forest area under an independently verified forest management certification scheme. While we understand that third party certification can be one avenue to verify that a forest area is sustainably managed, we want to stress the fact that certification is neither necessary nor sufficient for assuring long term forest sustainability. Other mechanisms (e.g., legal and institutional frameworks, public-private partnerships) are used widely. And the enterprise level focus of certification is not sufficient to assure landscape-scale forest sustainability. Moreover, the adoption of certification is driven by various economic and social forces, and decisions by private land holders to certify their lands may have little connection to their desire and capacity to pursue sustainable forest management. Trends in adoption may likewise be driven by factors other than actual SFM pursuit and attainment.
Indicator 10 is easily reported and therefore a potential candidate for inclusion (with the caveat that it should be accompanied with Indicator 9), but the underlying question of SFM attainment remains. We feel that this indicator, and the issue it addresses, should receive on-going scrutiny and, if needed, adjustment
Indicator 14. Forest health and vitality: % of forest area disturbed. We note that this indicator is still in development (designated orange in GCS list). Elevated disturbance activity has been identified as a principle threat to forest sustainability in the United States, and this observation likely extends to many other countries. This is an important indicator, and its development should be pursued.
As noted in the TF meeting comments, the measurement challenges for this indicator are considerable. Breaking it up into sub-indicators (e.g., area of fire, area of pathogen-induced mortality) may be the best way to proceed as the combination of different disturbance types in a single indicator is very problematic.
Guy Robertson