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Certified by: Forest Management SmartWood Headquarters 2008 Annual audit 65 Millet St. Suite 201 Richmond, VT 05477 USA Tel: 802-434-5491 Report for: Fax: 802-434-3116 www.smartwood.org Contact person: Jon Jickling jjickling@ra.org Paul Smith's College in Audit Managed by: Paul Smiths, NY USA United States Regional Office 205 West Third Street, Suite B Northfield, MN 55057 Tel: 507-663-1115 Fax: 507-663-7771 Contact person: Dave Bubser, US Regional Manager Email: dbubser@ra.org Certificate code: SW-FM/CoC-000089 Kara Wires Auditors: Robert Bryan April 22, 2008 Audit Dates: August 13, 2008 October 1, 2008 Report Finalized: Steven McFarland Operation Contact: P.O. Box 265 Address: ACCREDITED Paul Smiths, NY 12970 FSC-ACC-004 © 1996 Forest Stewardship Council A.C. FM-06 April 2007 TABLE OF CONTENTS 1. INTRODUCTION .................................................................................................................................... 3 2. AUDIT FINDINGS AND RESULTS ........ 3 2.1. AUDIT CONCLUSION ...... 3 2.2. CHANGES IN THE FOREST MANAGEMENT OF THE FME ............... 3 2.3. STAKEHOLDER ISSUES ................................................................................................................................. 3 2.4. CONFORMANCE WITH APPLICABLE CORRECTIVE ACTION REQUESTS .......................... 7 2.5. NEW CORRECTIVE ...
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Langue
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Certified by:
SmartWood Headquarters
65 Millet St. Suite 201
Richmond, VT 05477 USA
Tel: 802-434-5491
Fax: 802-434-3116
www.smartwood.org
Contact person: Jon Jickling
jjickling@ra.org
Audit Managed by:
United States Regional Office
205 West Third Street, Suite B
Northfield, MN 55057
Tel: 507-663-1115
Fax: 507-663-7771
Contact person: Dave Bubser, US
Regional Manager
Email: dbubser@ra.org
ACCREDITED
FSC-ACC-004
© 1996 Forest Stewardship Council A.C.
FM-06 April 2007
Forest Management
2008 Annual audit
Report for:
Paul Smith's College
in
Paul Smiths, NY USA
Certificate code:
SW-FM/CoC-000089
Auditors:
Kara Wires
Robert Bryan
Audit Dates:
April 22, 2008
August 13, 2008
Report Finalized:
October 1, 2008
Operation Contact:
Steven McFarland
Address:
P.O. Box 265
Paul Smiths, NY 12970
SmartWood Forest Management Annual Audit Report
Page 2 of 21
TABLE OF CONTENTS
1.
INTRODUCTION .................................................................................................................................... 3
2.
AUDIT FINDINGS AND RESULTS ........................................................................................................ 3
2.1.
A
UDIT CONCLUSION
...................................................................................................................................... 3
2.2.
C
HANGES IN THE FOREST MANAGEMENT OF THE
FME
............................................................................... 3
2.3.
S
TAKEHOLDER ISSUES
................................................................................................................................. 3
2.4.
C
ONFORMANCE WITH APPLICABLE CORRECTIVE ACTION REQUESTS
.......................................................... 7
2.5.
N
EW CORRECTIVE ACTIONS ISSUED AS A RESULT OF THIS AUDIT
............................................................... 7
2.6.
A
UDIT OBSERVATIONS
.................................................................................................................................. 8
3.
AUDIT PROCESS .................................................................................................................................. 9
3.1.
A
UDITORS AND QUALIFICATIONS
:
................................................................................................................. 9
3.2.
A
UDIT SCHEDULE
.......................................................................................................................................... 9
3.3.
S
AMPLING METHODOLOGY
:
.......................................................................................................................... 9
3.4.
S
TAKEHOLDER CONSULTATION PROCESS
.................................................................................................. 10
3.5.
C
HANGES TO
C
ERTIFICATION
S
TANDARDS
................................................................................................ 10
APPENDIX I: List of visited sites (confidential) ............................................................................................11
APPENDIX II: List of stakeholders consulted (confidential) .........................................................................12
APPENDIX III: Forest management standard conformance (confidential) ..................................................13
APPENDIX IV: Chain of Custody Conformance (confidential) .....................................................................17
APPENDIX V: FSC Annual Audit Reporting Form: ......................................................................................18
APPENDIX VI: SmartWood Database Update Form ...................................................................................21
Standard Conversions
1 mbf = 5.1 m
3
1 cord = 2.55 m
3
1 gallon (US) = 3.78541 liters
1 inch = 2.54 cm
1 foot = 0.3048 m
1 yard = 0.9144 m
1 mile = 1.60934 km
1 acre = 0.405 hectares
1 pound = 0.4536 kg
1 US ton = 907.185 kg
1 UK ton = 1016.047 kg
1. INTRODUCTION
The purpose of this report is to document annual audit conformance of Paul Smith's College,
hereafter referred to as Forest Management Enterprise (FME). The report presents the findings
of SmartWood auditors who have evaluated company systems and performance against FSC
forest management standards and policies. Section 2 of this report provides the audit
conclusions and any necessary follow-up actions by the company through corrective action
requests.
SmartWood audit reports include information which will become public information. Sections 1-3
will be posted on SmartWood’s website according to FSC requirements. All appendices will
remain confidential.
Dispute resolution: If SmartWood clients encounter organizations or individuals having concerns
or comments about Rainforest Alliance / SmartWood and our services, these parties are strongly
encouraged to contact SmartWood regional or Headquarters offices directly (see contact
information on report cover). Formal complaints or concerns should be sent in writing.
2. AUDIT FINDINGS AND RESULTS
2.1.
Audit conclusion
Based on Company’s conformance with FSC and SmartWood requirements, the audit
team makes the following recommendation:
Certification requirements met, certificate maintenance recommended
Upon acceptance of CAR(s) issued below
Certification requirements not met:
Conformance with Major CAR(s) required
Additional comments
:
Issues identified as
controversial or hard to
evaluate.
2.2.
Changes in the forest management of the FME
None
2.3.
Stakeholder issues
SmartWood was contacted by some stakeholders with concerns regarding the forest
management practices on, primarily, the Currier property of Paul Smith’s College (PSC). The
stakeholders had multiple concerns that were related to the FSC Standard. The issues raised
by the stakeholders were reviewed during the April 2008 field audit and a second field audit in
August 2008.
1. Tax Exempt Status.
Stakeholders indicated that for the Currier property, PSC was claiming
tax exempt status for educational purposes and not paying property taxes but that the students
were not using the property. PSC confirmed that students are currently using the property for
SmartWood Forest Management Annual Audit Report
Page 4 of 21
educational purposes and they intend to continue to do so. Because the Currier property is
approximately one-half hour from campus it is used less than other PSC lands that are
adjacent to the campus. The amount of use varies from time to time with the current activities
on the property and field trip needs of the faculty. Two class trips were planned to the property
in 2008, one to view the marked timber prior to harvest and a second to view harvesting.
However, because the harvesting did not start in time, only the pre-harvest field trip took place
during the spring semester.
2. Gift of Curriers.
The Currier Property was indentured to PSC in 1968 by Alfred M. Currier
and Gertrude B. Currier. Stakeholders expressed concern that the property is not being
managed according to the wishes of the Curriers. The auditor was provided with a copy of the
Indenture and related correspondence. Additionally, the Currier property was visited as part of
the April and August field audits. The only relevant items specifically outlined in the Indenture
are maintenance of the cemetery in which the Curriers are buried and the protection of a white
pine stand. The auditor observed that both of these areas are being protected by PSC. It is the
auditors’ conclusion that all documented wishes of the Curriers are being met.
3. Aggressive Nature of Management.
The 2008 Currier property harvest used whole tree
harvesting and skidding combined with a log slasher, pulp debarker/chipper (―clean chip‖
operation) and grinding of the remaining small limbs and cull material for biomass. One
stakeholder, reportedly speaking for others, felt this was similar to industrial forestry and not
necessary for a college-owned property.
Based on site visits and interviews, the auditors
concluded that the mix of equipment and silviculture was consistent with the potential markets
and products, was appropriate to the needs of the property, and was consistent with some of
the other FSC–certified lands in the region.
In general, there has been some stakeholder concern that financial goals are driving the
management activities on PSC lands. However, PSC is continuing to follow the management
plan, PSC has indicated that they have not increased or modified harvest levels specified in
the plan. A PSC administrator emphasized the College’s continued commitment to being a
model of sustainable forestry practices for students and the public. PSC consulting foresters
indicate that while there are financial targets they have never felt pressure to increase the
harvest level or make PSC more money. With the exception of the timing of skidding of felled
timber (see rutting issue below), the auditors saw nothing during the audit that would indicate
harvesting is being driven by financial concerns.
4. Financial Due Diligence.
Two stakeholders felt that the current harvest at the Currier
property did not make sense financially and that PSC’s forest manager, Northwoods Forest
Consultants (NFC) was not providing PSC with financial due diligence. Specific complaints
included high costs of a new road and stream crossing, chipping of small diameter Select, #1,
and #2 white pine logs, and selling logs at a lower stumpage value than had been offered by a
local sawmill.
Prior to signing the harvesting contract PSC was aware that the cost of the road and stream
crossing would be high relative to the income projections, but stated that they made a decision
to prioritize the long-term access and silviculture revenues over maximizing income. The
decision to build the bridge and access road was made to ensure a permanent access from
Goodspeed Road to the west that was entirely on PSC lands rather than relying on a
contested abandoned county road across lands of others and creating conflicts with
landowners along the abandoned county road.
SmartWood Forest Management Annual Audit Report
Page 5 of 21
The primary objective of the harvest was an improvement cut to remove low grade material
that had been left by the previous forest manager and to provide growing space for better
quality stems. Harvest records to date indicate that a significant majority of the volume
harvested has been low grade material (pulp chips and biomass), which is consistent with the
harvest goals. Post harvest stands observed during the field audit were well stocked with
better quality timber.
The issue of chipping sawlogs was reviewed during the field audit. Without actual evidence of
sawlogs being chipped this allegation would be impossible to prove. Piles at the landing may
contain both trees with sawlogs and pulp trees, which are then sorted prior to chipping. There
is a financial incentive for the logging contractor to sell all sawlogs possible, which minimizes
the chance of quality logs being chipped. A sample of mill scale slips indicated approximately
38% of the 218 sawlogs in the sample were less than 12 inches in diameter, which indicates
that operators are being careful to remove low-volume sawlogs from the piles prior to chipping.
The contractor met with a representative of a local pine sawmill (Ward Lumber), but the mill
only offered to buy the better quality logs that were free of black knots. Because of the high
volume of low grade material, the contractor determined that the greatest revenues would be
derived from selling all logs to a single buyer rather then selling the best logs to one buyer and
then attempting to find a second buyer to buy only the low grade logs.
In sum, the auditors have found that at the Currier property the actions of PSC, the logging
contractor and NFC have been consistent with the FSC Northeast standard regarding financial
viability, long-term investments in the forest, silviculture, timber utilization and diversity of forest
products.
5. Rutting, Residual Stand Damage, and Skid Trail Width
. Stakeholders contacted
SmartWood during July 2008 regarding site and stand damage at the Currier property from
ongoing harvest operations. SmartWood sent a second auditor, Robert Bryan, to review the
ongoing operations on August 13, 2008.
Heavy and frequent rainfall in July and August 2008 resulted in sensitive site conditions. On
July 21
st
several skid trails near the landing on to the east of Goodspeed Road were heavily
rutted after a heavy rain. Because this was the last section of previously-felled timber to be
skidded to the east of the road, the contractor decided to complete the skidding and
processing that day and then smooth out the rutted trails, rather than moving all equipment
and then returning at a later date to complete the operation (OBS 01/08). The auditor observed
two main skid trails and two branching trails with a total estimated combined length of several
hundred feet that had been rutted and restored. Trail widths ranged from 12 to 20 feet. While
the distance between skid trails was generally greater than 60 feet (between-trail distances of
40 to 120 feet were observed) throughout the sale area, the area in trails was greater in the
damage area than on other parts of the property due to a network of intersecting trails.
Skidding and processing were ongoing to the west of the Goodspeed Road at the time of the
August 13
th
site visit. The contractor had shut down the operation on Friday August 8
th
due to
wet soils. Skidding resumed on August 11
th
, with contractor and forester moving some skid
trails to reduce rutting damage. However, due to heavy skidding traffic and continuing damage,
the decision was made to close the operation and not harvest about 40 acres of marked timber
until site conditions improved. While many skid trails were in good condition, several trails
north of the landing had been heavily rutted and then smoothed over.
SmartWood Forest Management Annual Audit Report
Page 6 of 21
In considering the issues related to skidding, the auditor found that the skid trail spacing was
generally very good. However, because the main trails are not flagged in advance but are
determined by the harvester, the density of trails (a combination of trail spacing and/or
intersecting trails) in some locations was greater than desirable and could likely be reduced by
trail layout in advance of operations (OBS 02/08). This in turn could lead to reduced site
damage.
Specific to the rutting, the amount of damage was greater than desirable and was probably
exacerbated by the slim financial margins of the operation due to its focus on low-value wood.
Both the forester and contractor noted the costs of moving all the equipment and returning
later exceeded the value of wood that had been felled but not yet skidded. Although a smaller
non-mechanized operation might not have been subject to such financial constraints and thus
might have been able to shut down sooner, such a non-mechanized operation might not have
been able to turn a profit removing such a high percentage of low-value wood. Rutting was
limited to two locations on the property, and was confined to main skid trails with minimal
damage between trails. Furthermore, the forester, contractor, and PSC were in communication
regarding the issue and in deciding to close the operation to prevent further damage. Rutting
had not been identified as an issue in previous audits and the current amount of rutting thus
appears to be an exception resulting from the very heavy rainfall this summer. Smoothing of
rutted trails is consistent with NY Best Management Practices (p. 35).
Some damage to residual trees was noted, but this was almost exclusively limited to trees
along the skid trail. Where marked trees were located along skid trails ―bumper trees‖ (tall
stumps) were retained, but in other cases some crop trees along the trails were damaged.
There was very little damage to residual crop trees or regeneration between skid trails – less
so than would result from most chainsaw/cable skidder operations.
In total, the level of damage appeared to be within acceptable limits, but some improvement
might be possible if the main skid trail were laid out by the foresters as the trees are being
marked (OBS 02/08). While PSC faculty were involved in review of the management plan and
use operations for field trips, they are not generally involved in ongoing review of operations
and management policies. In light of PSC’s educational mission, further review and
management policy development that considers the tradeoffs of income, stand improvement,
and potential damage from mechanized operations would also be appropriate (OBS 03/08).
6. Beech Management.
There is some stakeholder concern not enough investment is being
made in addressing the beech problem. Regarding the beech problem, PSC is aware of the
issue and trying to address it. They are doing regeneration studies and monitoring at 3-5 year
intervals. They have only isolated beech issues and have been trying to open up stands to
more sun to encourage other species to regenerate. They have found this approach is
working. They considered prescriptive fire but have not implemented it. The auditor believes
these approaches are adequate and did not see a prevalent beech problem on site during the
audit.
6. Stakeholder Input into Management.
Another stakeholder concern is regarding notification
of neighbors and PSC community regarding management activities and input the stakeholders
have in management decisions. Some stakeholders do not feel there is adequate consultation
regarding management activities. PSC indicates they notify NY DEC for the land that is under
easement. Additionally, they notify facility and staff and someone from PSC presents on
management of the PSC forest lands every year in the silviculture class. Finally, PSC indicates
that they informally notify neighbors if there will be management activities close to them. A
SmartWood Forest Management Annual Audit Report
Page 7 of 21
stakeholder did indicate to the auditor that this was done when planning a harvest but the
stakeholder felt PSC was not willing to explain what type of activity was planned. Other
stakeholders felt that PSC was responsive to their comments. For example, a landing was
moved and a goshawk nest was protected based on input from stakeholders. However, some
stakeholders feel they do not have adequate opportunities to discover what management
activities are planned and to provide appropriate feedback. Additionally, PSC does not keep
records of stakeholder input received and their response (CAR 01/08).
7. Contractor Bids and Contractor Size.
Stakeholders expressed frustration that only large
contractors are used on PSC property. There is some confusion regarding how to get on the
bid list and how bids are awarded. PSC has indicated that they are willing to put all qualified
contractors on the bid list. Qualifications include workers compensation, liability insurance,
quality/reputation (will check past jobs), logistics (distance to harvests), and specific provisions
for each job (road building, harvest of low quality wood). PSC should do more to ensure all
qualified contractors are aware of how to get on the bid list and how bid are awarded (OBS
04/08). Additionally, PSC needs to structure some sales opportunities to allow for small
contractors to bid competitively (CAR 02/08).
2.4.
Conformance with applicable corrective action requests
The section below describes the activities of the certificate holder to address each applicable
corrective action issued during previous evaluations. For each CAR a finding is presented along
with a description of its current status using the following categories. Failure to meet CARs will
result in nonconformances being upgraded from minor to major status with conformance required
within 3 months with risk of suspension or termination of the SmartWood certificate if Major CARs
are not met. The following classification is used to indicate the status of the CAR:
CAR Status
Categories
Explanation
Closed
Certified operation has successfully met the
CAR and addressed the underlying
nonconformance.
Open
Certified operation has not met the CAR;
underlying nonconformance is still present.
CAR becomes a Major CAR with a 3 month
deadline for conformance
There were no corrective actions to be evaluated during this audit.
2.5.
New corrective actions issued as a result of this audit
CAR 01/08
Reference to Standard:
4.4.a; 4.4.c
Non-conformance
Some stakeholders feel they do not have adequate opportunities to
discover what management activities are planned and to provide
appropriate feedback. Additionally, PSC does not keep records of
stakeholder input received and their response.
Major
Minor
Corrective Action Request:
PSC shall develop and implement a formal procedure for
apprising neighbors and the PSC community of management activities and offer them a venue
to provide input. PSC shall develop a system to track all comments and their response.
SmartWood Forest Management Annual Audit Report
Page 8 of 21
Timeline for conformance:
By the next annual audit
Evidence to close CAR:
Pending
CAR Status:
OPEN
Follow-up Actions (if app.):
CAR 02/08
Reference to Standard:
5.2.c
Non-conformance
Stakeholders expressed frustration that only large contractors are used
on PSC property.
Major
Minor
Corrective Action Request:
PSC shall develop and implement a system to ensure that some
timber sales are structured to allow for small contractors to bid competitively.
Timeline for conformance:
By the next annual audit
Evidence to close CAR:
Pending
CAR Status:
OPEN
Follow-up Actions (if app.):
2.6.
Audit observations
Observations
are
very minor problems or the early stages of a problem which does not of itself
constitute a non-conformance, but which the auditor considers may lead to a future non-
conformance if not addressed by the client. An observation may be a warning signal on a
particular issue that, if not addressed, could turn into a CAR in the future (or a pre-condition or
condition during a 5 year re-assessment).
OBS 01/08
Reference Standard & Requirement: 6.5.b
Heavy and frequent rainfall in July and August 2008 resulted in sensitive site conditions on the
Currier property. The contractor decided to complete the skidding and processing that day and
then smooth out the rutted trails, rather than moving all equipment and then returning at a later
date to complete the operation
Observation
: PSC should consider developing a clear and documented policy on rutting that
includes a process for when harvests should be shut down and how shut down is
communicated along the chain of command.
OBS 02/08
Reference Standard & Requirement: 6.5.b
Field observations at the Currier property indicated that soil and stand damage might be
reduced if the main skid trails were laid out by the forester or the forester working in
conjunction with the logging contractor.
Observation
: PSC should consider having foresters lay out main skid trails to minimize the
area in trails and limit the potential for soil and stand damage.
OBS 03/08
Reference Standard & Requirement: 5.1.e, 6.5.a, 6.5.b, 6.5.e
Choice of equipment and contractor profit margins may lead to tradeoffs between silvicultural
goals and potential for site damage. While PSC faculty were involved in review of the
management plan and use operations for field trips, they are not generally involved in ongoing
review of operations and management policies.
Observation
: In light of PSC’s educational mission, PSC should consider faculty involvement
SmartWood Forest Management Annual Audit Report
Page 9 of 21
in case study review of the Currier harvest and possible management policy development that
considers the tradeoffs that come with choice of equipment, including, but not limited to,
income, stand improvement, and potential site and stand damage.
OBS 04/08
Reference Standard & Requirement: 4.1.d
There is some confusion regarding how to get on the bid list and how bids are awarded.
Observation
: PSC should do more to ensure all qualified contractors are aware of how to get
on the bid list and how bid are awarded.
3. AUDIT PROCESS
3.1.
Auditors and qualifications:
Kara Wires:
SmartWood USA Forestry Technical Coordinator. Education: M.S. in forestry.
University of Vermont; B.S. Natural Resources, University of Michigan. Experience: Forestry
Technical Coordinator, US Regions (2005- present); 4 years as SmartWood Certification
Services Coordinator; and two years as a consulting forester in New England. Auditor on over
10 forest management audits and assessments. Experience of teaching College forest ecology
workshops, Project manager on over 100 forest management audits and more than 10 forest
management assessments. Completed a SmartWood Forest Management Assessor Training.
Member of the Society of American Foresters and the Forest Guild.
Robert R. Bryan:
M.S. Forestry, University of Vermont (1984); B.S. Botany and Environmental
Studies, University of Vermont (1976). Currently employed as Forest and Wetlands Habitat
Ecologist/Forester, Maine Audubon (1995 - present) and self-employed as Consulting
Forester/Ecologist (2003 - present). Licensed Maine Forester #907. Member SAF and Forest
Guild.
Certification Experience:
Lead auditor (SmartWood), including over 20 FSC Forest
Management certification audits and assessments in the Northeast, Lake States, and
Appalachia (family forests, investment and industrial forests, managed conservation forests,
and public lands). Member of FSC Northeast Standards Committee 1997-2003 and FSC-US
national standards advisory committee (2007-2008), peer review of SFI industrial forest
certification in Northern Maine, member of state-level forest certification policy committees.
3.2.
Audit schedule
Date
Location /Main sites
Principal Activities
4/22/08
Office
Review documentation and changes since last audit
4/22/08
Paul Smith’s College
property
Visit field sites with planned and completed activities
8/13/08
Currier Property
Review ongoing and completed operations with
forester, contractor, and PSC forest manager.
8/13/08
PSC Campus
Discuss Currier harvest and PSC goals with college
administration.
Total number of person days used for the audit: 3.0
= number of auditors participating
2
times total number of days spent for the audit
1.5
3.3.
Sampling methodology:
SmartWood Forest Management Annual Audit Report
Page 10 of 21
The audit focused on continued conformance with the FSC standards. The April audit began
with a meeting to discuss management activities and changes since last audit.
During the
meeting, management activities and changes since last audit were discussed. Appropriate
documentation was reviewed. Properties were selected that could be visited within the
timeframe of the audit. The properties selected to visit were those that had recent management
activities and/or had not been visited by previous auditors. Sites were visited with the goal of
seeing management activities—current and past as well as planned and to review different
types of operations, site level practices and protection of sensitive areas/sites. Documentation
pertaining to these activities was reviewed prior to, and after, the site visits. Additionally, roads,
gates and signage were also inspected.
The August field audit focused issues raised by stakeholders regarding sensitive sites and
stand damage at the Currier property.
3.4.
Stakeholder consultation process
There were some unsolicited stakeholder comments that were evaluated as part of this audit.
PSC and other stakeholders provided the auditor with a list of additional stakeholders to
contact. The auditor attempted to contact as many as possible from the lists.
Stakeholder type
(i.e. NGO, government, local
inhabitant etc.)
Stakeholders notified
(#)
Stakeholders consulted
or
providing input (#)
Neighbor
4
2
Logging Contractor
5
4
Consulting Forester
3
1
Other area residents
2
2
3.5.
Changes to Certification Standards
Forest stewardship
standard used in audit:
Revised Final Forest Stewardship Standard for the Northeast
Region (USA), VERSION V9.0, 2/10/05
Revisions to the standard
since the last audit:
No changes to standard.
Standard was changed
(detail changes below
)
Changes in standard:
Implications for FME:
Not applicable - no new requirements
