Seneca Creek Study
US hardwood legality and sustainability report concludes low risk
The original Seneca Creek study of the US hardwood producing and exporting sectors in 2008 broke new ground in providing timber legality and sustainability analysis and assurance.
Commissioned from international policy and economic consultancy Seneca Creek Associates by the American Hardwood Export Council, no timber market evaluation of its type before or since has surpassed it in scale, breadth of scope or depth of detail.
The final study, ‘Assessment of Lawful Harvesting & Sustainability of U.S. Hardwood Exports’, which was exhaustively independently peer reviewed, was held up as a template for timber legality assessment and reporting globally.
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But no markets stand still. The last decade has witnessed ever rising environmental concern and ever greater scrutiny of timber suppliers’ performance and credentials on legality and sustainability. More markets worldwide have imposed timber import legality requirements to combat the illegal wood trade and such regulation has become more demanding and increasingly strongly policed. At the same time, legality controls and forestry policy in the US have evolved. Consequently AHEC saw a need to review, revise and relaunch the Seneca Creek Report to demonstrate that its core conclusion, that there is minimal risk of illegal timber entering US hardwood supply chains, still stands.
The result is the updated Seneca Creek Report. If anything, this is a more substantial and significant undertaking than the first edition. It is more than an update. It goes into more detail, drills down further into the US hardwoods’ supply story, takes advantage of new and improved tools, such as satellite forest monitoring, provides case studies and also turns the lens more strongly on the sector’s sustainability.
The study and its conclusions were also once more rigorously peer reviewed by an independent panel drawn from the US and Europe.
The original Seneca Creek Report demonstrated that there was less than a 1% chance of illegal wood accessing the US supply chain. More than this, it showed that timber procured in any of the hardwood-producing states was low risk of coming from controversial sources, as defined by the FSC’s Controlled Wood and PEFC chain of custody standards.
The new edition states that current evidence also shows very low or ‘negligible’ risk of US hardwood exports containing timber from illegal, or unsustainable sources. Latest methods used in the US Forest Service and Analysis programme also provide clear proof that forest growth exceeds harvesting in the hardwood forest and that overall forest area is stable.
The outcome is that all US hardwood-producing states are categorized low risk of sourcing illegal hardwood under the requirements of the EU Timber Regulation, Australian Illegal Logging Prohibition Act and Japan’s Goho wood programme. They also satisfy the due diligence and risk assessment demands of most of the certification schemes operating in the US.
Comprehensive training and independent certification of loggers in hardwood producing regions has resulted in increased skills levels and professionalism and, says Seneca Creek, Federal and state forest programmes are even more wide-ranging and demanding than in 2008. They have:
- Introduced obligatory state-wide forest resource and wildlife assessments
- Demonstrated effectiveness in and compliance with forestry best management practices
- Increased conservation easement areas, where landowners implement conservation measures in agreement with government or environmental organizations
- Strengthened scrutiny and control of illegal timber because of the Lacey Act amendment and more robust state initiatives.
The new report found that traditional models of certification, involving forest management unit level audits of individual forest owners, remain a challenge in the US hardwood sector. As a result, certified timber availability is low and declining.
While the American hardwood resource is clearly and demonstrably sustainable, forest management certification has never gained significant traction in the industry. Lack of certification is due to the nature of US hardwood supply, not least the fact that there are over 10 million US private forest owners. Low awareness of certification, high costs, lack of incentives and inappropriate standards for non-industrial forest owners are contributory factors.
The Seneca Creek Report team provided analysis of critical environmental issues in case they raised concerns regarding US hardwood sustainability. The most notable concern related to ‘bottomland hardwood’. But, from a range of evidence, the report concludes that bottomland hardwood forest had not appreciably changed in the last decade.
The report noted too that the US’s anti-illegal timber focus went beyond its own borders.
“The US is a proactive participant in international fora and processes to strengthen legal wood products trade and include provisions prescribing stronger compliance to environmental laws and international conventions in free trade agreements,” says Seneca Creek. “Its international engagement further mitigates risk of US hardwood products originating from illegal sources.”
The interplay of all these factors is what leads to the study’s conclusion, that there remains low to negligible illegality risk or problematic sourcing overall in US hardwood supply and exports.
“The combination of forest growth exceeding removals, stable forest area, well-established private timber ownership, robust and effective legal systems, the safety net of national and state regulation and programmes addressing unlawful conduct and poor forest practices, widespread logger training, high rates of best management practice compliance, comprehensive state forest and wildlife resource assessments and proliferation of public/private sector conservation partnerships all contribute to this finding,” states Seneca Creek.
The independent Technical Review team described the new report as a ‘comprehensive analysis regarding legality and sustainability of US hardwoods’ and ‘more focused, logical, rational and defensible than other current risk assessment approaches’.
“The report analyses available data, as opposed to checking boxes, and provides a model for future US risk assessment activities, with key findings consistently supported by high-quality information and deep analysis,” they said. “It provides a robust, repeatable and defensible risk analysis that demonstrates the low risk of timber coming from illegal or unsustainable sources.”
Seneca Creek’s findings, they said, also showed that US states ‘commit to regulatory programmes that promote sustainable forestry and take best management practices seriously’.
From the report, the panel observed that the market for traditional forms of certification in the US marketplace are ‘fatigued and ready for new solutions’. They concluded too that, lack of certification may be driving assurance mechanism innovation and that, since the 2008 report, risk assessment (due diligence) has emerged strongly as a strategy for supporting responsible sourcing.
AHEC now plans to promote the new Seneca Creek Report widely. It is also taking follow-up actions. These include updating sustainability statements for its American Hardwood Environmental Profile tool (AHEP), a document detailing export consignments’ origins, legality credentials, carbon and wider environmental impacts shipped to any destination worldwide.
It will also develop a web-based ‘risk assessment framework’ tool, based on the report’s Appendix A, to demonstrate how US hardwoods meet procurement policy and certification sustainability criteria.
It will additionally undertake gap analyses, evaluating how the AHEP and evidence presented in the report measure up in European public and private sector procurement policies. This may lead to AHEP being updated to assist European buying decisions.
In another step, AHEC will evaluate developments in US forest inventory and analysis tools and use of earth observation in other commodities sourcing. This in turn will contribute to fine-tuning its own open access mapping tool, which shows US hardwood forest growth and timber removals and can be used in association with the AHEP.
Please note this report was originally published in December 2017, and may be subject to change.