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Foxes guarding the henhouse; why "self-certification" in the biomass industry threatens our forests

Sasha Stashwick

Posted June 4, 2013

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You know what happens when the fox is left to guard the henhouse. Unfortunately, the emerging trans-Atlantic biomass energy industry—in which power companies like Drax Power and Dominion Resources, supplied by wood pellet manufacturers like Enviva, cut down forests in the U.S. Southeast to be burned in large-scale power plants—is characterized by just this kind of self-serving dynamic when it comes to environmental sustainability. 

Both Drax and Enviva have made numerous environmental claims of sustainability, relying on “self-certification”—programs under which industries develop and monitor environmental performance without participation and oversight from environmental partners or independent organizations—or certifications like the Sustainable Forestry Initiative (SFI), which fall well short of ensuring sustainable forestry practices. These claims have been roundly discredited as nothing more than greenwashing.

Though they might come with a nice sounding label, SFI and other certifications used by the forestry industry actually allow for destructive forestry practices, including large-scale clearcutting, logging of endangered forests, conversion of natural forests to plantations, and widespread use of toxic chemicals. The NY Times reports on a Federal Trade Commission (FTC) complaint filed against SFI this week by environmental groups. The complaint details how SFI lacks financial independence from the industry it claims to oversee (an FTC requirement) and allows companies carrying the SFI label to engage in damaging forestry methods.

The piece illuminates that SFI is not a credible system for verifying sustainability. The practices of Enviva are a case in point:

The Wall Street Journal’s recent investigation into the biomass industry in the Southeast describes how Enviva sources trees from some of the most environmentally sensitive natural forests in the Southeast, including clear-cutting wood from wetland forests, some with trees more than 100 years old. While the industry typically argues that these types of destructive practices are isolated, such an incident is actually representative of a simple fact: Enviva’s existing forestry management certifications, (which include SFI and are detailed here), are failing to protect important ecosystems, associated species and water resources.

For its part, Drax claims that all its biomass is procured against its own robust sustainability criteria, including greenhouse gas emissions reduction requirements and habitat and biodiversity protection. However, the company has not provided any assurances that it will not source whole trees in its operations and is sourcing wood pellets from Enviva, despite this evidence that they are using whole trees in their mills.

At a time when we need to be quickly cutting carbon emissions and moving our energy sector forward towards energy efficiency and real clean energy technologies like wind, solar, and geothermal, burning trees to generate electricity takes us backwards, increasing carbon pollution compared to fossil fuels like coal or natural gas. The massive fuel needs of biomass energy companies also risk doubling logging rates in the U.S. Southeast, threatening some of the most biologically-diverse forests in the world. 

That’s why NRDC, Dogwood Alliance, and other concerned organizations are putting these companies on notice with a clear and simple message: Our Forests Aren’t Fuel

Our Forests.png

We’re calling on the biggest players in this destructive industry to put a halt on the use of whole trees until they adopt meaningful long-term policies that verify that their projects reduce near-term carbon emissions; protect forest ecosystems; and will not result in net increases to local air pollution. [You can take action and tell them to do just that here.]

Certification systems are necessary to provide independent assessments of industry performance against a set of independent standards. Many established environmental systems—for example, the Forest Stewardship Council (FSC) and the Roundtable on Sustainable Biofuels (RSB) for bioenergy—reliably provide such standards and assessments. [Though it’s important to note that FSC does not include a carbon accounting component]. In other circumstances, negotiated, public agreements between environmental advocates and corporations—such as the ground-breaking agreements struck between NRDC and Dogwood Alliance and large paper companies in the Southeast— provide reliable standards and monitoring. These types of substantive commitments can transform an entire industry, ensuring companies remain profitable while protecting our most precious ecosystems.

Self-certification—whether explicit or implicit within programs that do little more than provide a veneer of “green”—fails to achieve true environmental protections. It’s time for companies like Drax, Dominion and Enviva to make real commitments to sustainability and announce a long-term corporate policy to reject whole trees in their biomass operations.  

Click here to take action

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Kathy AbusowJun 6 2013 03:13 PM

I’d like to correct several incorrect statements about the Sustainable Forestry Initiative® Inc. (SFI®) and the SFI Forest Certification Standard. SFI ( is an independent nonprofit organization that promotes sustainable forest management and responsible purchasing of forest products. Our Board of Directors is equally divided among three chambers representing environmental, economic and social interests, with a two-thirds vote needed to approve any decision. SFI Board representatives include accomplished academics, conservationists, leaders in community development and government officials as well as landowners, forest professionals and tree farmers – a diverse group that reflects the variety of interests in the forestry community.

Our forest certification standard is science-based, rigorous and widely accepted – with 240 million acres in North America certified to the SFI Standard. Our Standard, which is revised every five years in an open, public process, includes measures to protect water quality, biodiversity, wildlife habitat, species at risk, and Forests with Exceptional Conservation Value.

Like all credible forest certification standards, the SFI Standard allows for clearcuts in working forests only where appropriate and when other requirements are met (e.g., wildlife habitat, site productivity, biodiversity, size restrictions, etc.); includes special requirements to protect old-growth forests; prohibits conversion to non-forest uses except in justified circumstances where it is documented that ecological impacts are not significant; and has requirements related to minimizing chemical use, including the use of least toxic and narrowest spectrum pesticides and the use of integrated pest management wherever feasible, and using only those chemicals that are approved by federal, state, and local governments.

SFI sets the Standard, but SFI program participants are audited against the SFI standard by independent third-party certification bodies accredited to the American National Standards Institute, the ANSI-ASQ National Accreditation Board and/or the Standards Council of Canada. Independent auditors with appropriate knowledge and skills conduct the thorough, consistent audits needed to make sure forest operations meet SFI's comprehensive standard requirements.

It is imperative that appropriate measures are in place for the bioenergy industry’s procurement of forest fiber in order to maintain the health of the forest resource. SFI and other third-party forest certification programs have a role to play in ensuring the growing demand for bioenergy feedstocks can be met without unintended environmental impacts on forest values such as water quality, soil productivity and biodiversity.

Learn more at

Kathy Abusow
President & CEO
Sustainable Forestry Initiative Inc. Washington, D.C.

Scott LloydJun 8 2013 04:59 PM

I’m having a great deal of difficulty understanding the motive behind NRDC’s campaign against wood pellet production in the southeast U.S. The blog post above references a WSJ report in which biomass obtained from the clearcutting of a wetland forest in North Carolina is apparently being used by Enviva to produce wood pellets. From the report, it appears that such harvesting is not a violation of North Carolina Forest Service rules provided best management practices are followed (the WSJ suggests that BMPs are indeed being adhered to).

The WSJ article then states that the U.K.'s draft rules, under which Drax would operate, indicate it might be permissible to use wood harvested for wetlands if it were determined that logging it didn't permanently change a wetland's ecosystem. This rule is taken directly from the EU’s Renewable Energy Directive governing the sustainability of biomass used for biofuels (but which, as hinted at in the article, is not mandatory for solid biomass such as wood pellets).

The blog post then goes into some detail questioning the environmental sustainability of the SFI certificate under which the aforementioned wetland forest is operating and suggests that the FSC adheres to greater environmental standards. A perusal of the FSC Standards for the United States reveals that harvesting in wetlands is not prohibited in the southeastern U.S. provided:

At a minimum, management of SMZs (streamside management zones) has the following characteristics (available at
• Management meets or exceeds state BMPs
• SMZ width reflects changes in forest condition, stream width, slope, erodibility of soil, and 
potential hazard from windthrow along the length of the watercourse.
• SMZs provide sufficient vegetation and canopy cover to filter sediment, limit nutrient inputs 
and chemical pollution, moderate fluctuations in water temperature, stabilize stream banks, 
and provide habitat for riparian and aquatic flora and fauna.
• Characteristic diameter-class distributions, species composition, and structures are adequately 
maintained within the SMZs.

Given the above FSC guidelines and the limited information in the WSJ report, it is not clear whether the reported harvesting would in fact be prohibited if the forest were FSC-certified.

In addition, the blog posts implies that the FSC Standard prohibits clearcutting. This is not so. The FSC Standards for the United States ( state the following:

The guidelines describe below are not binding to the certification of forest management in the Southeastern United States. They have been retained in order to provide certification bodies and other stakeholders in forest certification with the spirit of the original, SE Regional Standard position on the use and size of clear-cuts.
Indicator 6.3.g.1.a
• Primary and natural forests: clear-cutting is not allowed. Harvesting is not allowed at all in primary forests.
• Semi-natural forests: stands with trees greater than 100 years old: clear-cutting is not allowed; even-aged stands of hardwood and cypress: clear-cutting is allowed; the size of openings should be conservative.
• Even-aged stands of pine and pine/hardwood: clear-cutting is allowed; the size of openings should not be higher than the limit for plantations and should be justified by natural regeneration requirements.

Clear-cuts up to 80 acres are allowed in cases where a 40-acre stand would not provide enough timber volume to secure an economically operable timber sale, meaning that the sale would not attract a buyer and/or the landowner would not make a profit from the sale. Examples of such cases include stands that have been high graded and the most valuable species of trees have already been removed, or where a site has been planted with inappropriate, poorly growing species and the landowner/manager wants to clear and restore the site. This exception cannot be used when a 40-acre clearcut would be economically operable and a landowner wants to cut 80 acres simply to make a greater profit.

Clearcuts up to 80 acres are allowed in cases where harvesting a stand in 40 acre blocks would cause unnecessary environmental disturbance to the area surrounding the stand.

An exception to all of the limits on the use and size of clearcuts can be made in cases of ecologic necessity. Clearcutting may be used in natural forest stands--where appropriate and necessary--as a tool for maintaining ecosystems that are dependent on large, contiguous openings. An example is the sand pine scrub ecosystem, which supports the ecologically significant Florida scrub jay and is currently being managed with large, contiguous clear-cuts.

Ecologists urge the use of large clearcuts in the sand pine scrub ecosystem to mimic the stand-replacing, catastrophic fires that historically maintained the ecosystem. This exception may only be used when supported by scientific literature.”

Thus, one can observe that the FSC allows clearcutting to take place under a rather wide variety of circumstances.

Finally, the blog post states that burning trees increases carbon pollution compared to fossil fuels. A recent peer-reviewed article by Jonker et al. ( documents that using softwood plantations (admittedly the aforementioned Enviva forest is not a plantation) to source biomass for wood pellet production results in a reduction in greenhouse gas emissions relative to coal (carbon offset parity point within one to two rotations).

Taking all of the above into account, I can understand the NRDC’s concern with harvesting mature wetland forests. I would have such concerns whether such harvesting was used to source material for home building or pulp and paper, as opposed to wood pellets. Certainly, EU wood pellet demand is an additional driver that will place increasing pressure on the forests of the southeast U.S. However, I don’t see the point in launching a campaign against wood pellet producers in particular. What we are observing is that, despite significant efforts by a wide variety of actors, there are significant gaps in the framework governing sustainable forest management. This entails supranational regulations (the EU Renewable Energy Directive), national standards (UK Office of Gas and Electricity Markets), individual State forestry practices and guidelines, as well as third-party forest certification schemes (including both the FSC and the SFI). My point is that if the NRDC feels that stricter forest management standards are needed (and I am in agreement that they are), then why not lobby the aforementioned agencies to tighten their standards? Even if the NRDC campaign against wood pellets is successful, existing gaps in the forest management framework will only be exploited by other industries.

Thinkaboutit PeopleJun 10 2013 09:56 AM

It is apparent NRDC, or at least the author, is flogging Europe's use of wood for energy, which we should be reminded is better than coal, or nuclear, maybe even hydro. It would have been commendable for the author to point out a solution, or at least an improvement to the perceived problem. That would require real effort. or even real journalism. I challenge you all to put the guns down and offer solutions in lieu of rhetoric...

Don CurtisJun 10 2013 12:32 PM

My forests are NOT your forests! Your ad "Our forests aren't fuel" is offensive. I bought the land, planted the trees, and paid the taxes. I will harvest my trees for any use I choose. It's called PRIVATE property rights. In fact, in the spirit of free trade, you're welcome to purchase my forest if you can more than energy, pulpwood, or lumber firms. PUT YOUR MONEY WHERE YOUR MOUTH IS!

Brandon RampryJun 10 2013 09:26 PM

The forestry community does a pretty good job, as a whole at protecting the forest and ecosystems. We depend on them now and in the future for our livelyhoods. Sustainability of our forest have been around longer than any of these certifications, pellets, and the NRDC.
Thanks, South GA Logger

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