The FSC certificate is one of the most significant tools for demonstrating the responsibility of the forest sector. At the same time, it must be ensured that increasing requirements do not take unreasonable resources from operators. In our view, it is questionable whether the reforms related to risk assessment bring added value from the operator’s point of view while at the same time increasing the obligations. In particular, the burden on small operators and operators in certain regions may increase disproportionately.
FSC’s risk assessment must take into account that the harvesting of energy wood can be an essential part of the security of supply, circular economy and vitality of an individual region in Finland. The requirements must be proportionate so that the rights of indigenous peoples, ecological sustainability and local vitality can be reconciled.
The new requirements according to the FSC risk assessment, such as the application of FPIC procedures to all felling sites in private forests, may lead to an unreasonable reporting and negotiation burden that is not proportionate to the scope of the regional company’s operations. This may jeopardise the security of supply of heat production in the area and may lead to a situation where local renewable energy is replaced by imported fuels or fossil fuels. Local wood chips are a strategic resource in crisis situations, when the availability of imported fuels may decrease.
For example, in upper Lapland, wood sales are an important source of secondary income for many municipal residents. There are no forest industry plants in the Sámi Homeland, and timber trade is based on local demand. If the requirements of the FSC risk assessment lead to a total halt in timber trade, it will have a direct impact on the livelihoods of local residents and the vitality of the area. Another possible consequence scenario may be an increase in the size of felling sites in order to cover the increased indirect costs with the unit prices of forestry. If the requirements increase costs, small owners are excluded from the market, which weakens the vitality of the region and increases social inequality.
The FSC’s risk assessment should recognise that the harvesting of energy wood is part of the local circular economy and security of supply, and that its restriction must not take place without a clear impact assessment. The FPIC principle is important, but its application must be proportionate to the scope of the activity and the local context. In our opinion, the FSC should constitute a lighter procedure for energy wood, which safeguards the rights of the Sámi people without an unreasonable administrative burden.
In our opinion, the measures taken in accordance with the FSC’s risk assessment must not lead to unreasonable difficulties for local forest owners and heating companies. Timber trade is a multi-stakeholder process in which the interests of forest owners, harvesting entrepreneurs, energy companies, industry, authorities and local communities meet. We believe that the rights of indigenous peoples, ecological sustainability and local vitality can be reconciled when the risk assessment is based on regional understanding and reasonable measures.