Facts: Mendocino Redwood Company (MRC) is now in compliance with all the Principles of the FSC, and a majority of the criteria of the FSC. There are areas left for MRC to improve. The conditions of certification reflect this. Conditions with timelines are a regular part of the FSC certification process. As an FSC certified forest manager MRC is publicly committed to carry on a process of continuing improvement. This commitment is why certification is so important: the FSC process is the toughest and most rigorous standard that exists. Mendocino Redwood Company (MRC) has already phased out traditional clearcutting (check our policies on Clearcutting and Variable Retention) and adopted a tough old growth protection policy that preserves old growth stands and individual trees (check our Old Growth). The conditions of certification include specific timetables for implementation of herbicide reduction and other challenging, innovative initiatives

Facts: MRC's harvest rates have always been sustainable and harvest rates over the past two and a half years have been at 60% of growth. MRC's target is a rate of harvest that guarantees accelerated rates of restoration and the company is spending a great deal of time and energy to establish and measure this target. The inventory work over 232,000 acres includes a wide variety of ecological as well as traditional tree data to provide for more comprehensive assessment of the impacts of harvesting activities. MRC has been making interim adjustments in different watersheds, the overall allowable harvest calculation will be available at the end of 2001 when the inventory data in the remaining watersheds have been collected

Facts: The credentials of the people who are enforcing the standards are unassailable. Proof of the success of their approach are the substantial changes that have been made at Mendocino Redwood Co to meet the FSC standards. We along with many other major and minor environmental watchdog groups believe that the process we subjected ourselves to (which including using two certifiers, the locally based Institute For Sustainable Forestry,- an affiliate of SmartWood - in Willits, CA, and Scientific Certification Systems in Oakland, CA) has the highest level of integrity. Visit www.fscus.org to see the many environmental groups that support the FSC, or visit www.smartwood.org or www.scscertified.com, and http://www.mrc.com/FSC_Certification.html to find out more about the qualifications of the specific organizations and individuals involved in MRC's certification process.

Facts: The FSC certification process and California or Federal private forestland regulations are entirely separate. The FSC Principles encourage full compliance, and in fact demonstrated leadership, with public regulatory processes. The public has the ability, through the timber harvest planning and approval process, to comment on every THP that MRC submits as well as long-term planning documents.

Facts: FSC Certification is about infusing higher levels of ecological values in the balance of environmental impacts, economic viability, and social benefits of an organization. Activists who are against the harvest of any trees will find it challenging to support the FSC. Environmental organizations including WWF, NRDC, Greenpeace, NWF, The Wilderness Society, Pacific Forest Trust, CalTrout, Trout Unlimited, Ecotrust and EDF all support the FSC standard because it is facilitating a solution to the tough challenge of managing forests in an environmentally responsible manner. MRC is harvesting at only 60% of the growth rate of the forest, and has put in place wildlife and aquatic habitat protection policies that are unrivaled by any neighboring commerical operator. Specifically, MRC's streamzone and Marbled Murrelet protection policies include reserves, equipment exclusion, permanent tree retention, high canopy density, water drafting, and erosion protection measures that exceed that required by the California Forest Practice rules. Watercourse buffers are determined based on watershed analysis work and upslope conditions. The goal of reserves and aquatic habitat policies at MRC are to protect Marbled Murrelet habitat by maintaining and improving current habitat existing on the forestlands, and restore salmon habitat by increasing refurbishment of stream structure (large woody debris), lowering stream temperatures, lowering stream sediment levels, and increasing stream shade. MRC is using technical assistance from a variety of state and federal agencies to develop prescriptive policies for specific sites. From these agency personnel and other experts in the restoration field, it is our understanding that our policies are exemplary.

Facts: FSC certification involves significant input from the public. In fact, in the more than two year certification process, the certification teams consulted with well over 100 stakeholders, including local activists, neighbors, an assortment of regulators, local and national environmental groups and others. It relies on independent third party experts, and in the event of successful certifications a summary of the certifiers findings is made public and these summaries contain a frank discussion of the strengths and weaknesses of the specific company. If the certification comes with conditions, and essentially all do, it opens up the process of improvement to the public through an annual review with the independent third party experts.

Facts: The FSC has members representing the economic, social and environmental stakeholders in forest management. What makes the FSC unusual is the large number of national and regional environmental organizations that support the standards that the FSC represents. Visit www.fscus.org to learn more about the wide support of environmental organizations enjoyed by FSC.

Facts: The facts for MRC tell a different story. In conjunction with a two year process to obtain FSC certification, MRC eliminated traditional clear cutting, protected its old growth, and committed to a substantial reduction in the use of herbicides.

Facts: MRC has been working hard to find alternatives to traditional industrial herbicides for the last 18 months. With this work, MRC is now capable of committing to both the continued restoration of acres covered in tanoak and brush back to redwood and Douglas-fir AND at the same time, to a significant reduction in herbicide use. See http://www.mrc.com/issues/herbicide.html for MRC's latest herbicide update. As more science is applied to these restoration issues, additional reductions will be possible. MRC's protective measures for both listed and unlisted species are exemplary even while we gain a more comprehensive understanding of the abundance of these species across our landscape.

Facts: In healthy redwood-dominated stands, MRC uses uneven-age management techniques (i.e., single tree and group selection). Typically these stands retain 60% to 80% of the pre-harvest stocking. In stands dominated by tanoak, MRC uses modified forms of even-age management called partial clearing or "variable retention" harvesting. This leaves 10-40% of the stand (a mix of redwood, Douglas-fir, and tanoak) intact, while creating a sufficient opportunity to plant and regenerate redwoods and Douglas-firs. In MRC's next ten year harvest plan submitted and approved by the state of California, the breakout between even to uneven-aged acres is approximately 50/50 over the next ten year period. As stands are restored to redwood and Douglas-fir, they will transition to uneven age harvest techniques. MRC's publicly available long-term harvest plan shows this transition to result in the use of uneven aged harvest methods in over 80% of the harvest plans within 30 years.

Facts: As far as we know, MRC has a more comprehensive old growth protection policy than any other large commercial forestland owner. MRC has identified approximately 130 acres of 14 distinct "never-harvested" (FSC Type I) old growth stands. These acres will be permanently protected by MRC from any kind of harvesting. At this time, MRC believes it has approximately 1,250 acres of previously harvested (FSC Type II) old growth stands where significant old growth characteristics are still present. The residual old growth trees and late successional characteristics of these stands are protected and only silviculture, such as thinning from below, is allowed to enhance or extend these stands. The remaining previously logged second growth forests on MRC lands are estimated to contain a significant number of scattered residual old growth trees in very low densities. These old trees are being preserved based on a policy that protects them by age, size, function and characteristics specific to particular species. Trees preserved from harvesting include:

• Any redwood tree, 48" dbh and larger, established prior to 1800.
• Any Douglas-fir tree, 36" dbh and larger, established prior to 1800.
• Any tree established prior to 1800 (conifer or hardwood), regardless of diameter size, with a preponderance of species-specific Old Growth characteristics.
• Any tree (conifer or hardwood), established before 1800, that cannot be replaced in size and ecological function within 80-130 years, regardless of diameter or presence of Old Growth characteristics.

Facts: MRC harvests less than growth in every watershed area in which it operates. Rates of harvest have varied between 0.6% and 2.6% of total conifer (redwood and Douglas-fir) inventory across the ten watershed areas.

Facts: The overall amount and frequency of application of chemicals in forestry pales by comparison to agriculture, with the highest historical use of chemicals on any given treated acre at MRC equaling significantly less than the use on a treated acre of vineyard land in Mendocino county. In MRC's case, the majority of the acres will never be treated with any chemicals, but for those acres that are treated, the application on an acre will occur only once or twice in the lifetime of the management of the forest, rather than annually as occurs in agriculture. MRC is fully committed to improving its ability to restore the forest with less use of herbicides by being a leader in identifying, testing and implementing viable alternatives that will help reduce and phase out the need for chemicals in forestry entirely. See http://www.mrc.com/Annoucements/index.html for MRC' s latest announcement on herbicide reduction.

Facts: Facts: MRC has abandoned or deactivated approximately the same amount of road that has been reconstructed so there has been no net increase in road density on MRC forestlands. Any new roads that have been built are with far superior environmental standards than the roads that have been deactivated. Road survey work is allowing MRC to monitor these numbers and prioritize road removal and upgrade projects. We are sensitive to the fact that roads are the most significant source of sediment in the streams and can become conduits for silt and water. MRC is investing millions of dollars to improve the old road systems and reduce potential sources of sediment. This investment in road improvement and deactivation has been widely recognized as one of the most important things that can be done to improve aquatic habitat on MRC lands.

Facts: Facts: MRC has made their inventory information of matter of public record by sharing this information to a variety of local organizations and making it available on its Web Site, www.mrc.com. This is atypical for large industrial forestland owners and most choose to keep this information confidential. MRC is currently harvesting at 30% below the planned harvest of the prior owner, and is harvesting at approximately 60% of the growth rate of the forest. Total inventory on MRC forestlands is expected to more than double by 2060.

Facts: Commercially managed forests throughout the west rarely have even 15,000 board feet per acre across their entire ownership although 40,000 board feet might be found on a single acre of mature forest. MRC forests are on a trajectory to improve to over 20,000 board feet per acre in less than 60 years. This restoration target is defined both by improved tree volume and improved tree size.

Facts: The statistics quoting that only 3% of MRC lands are in trees 24" or greater is misleading - it is based on a "Quadratic Mean Diameter" average which is not indicative of the diameter distribution of trees in the forests. (For a technical discussion of quadratic mean diameters, please see http://www.mrc.com/Letters/Letters2.html). The facts are that MRC has a total conifer (redwood and Doug-fir) inventory of 2.4 Billion board feet, of which 1.1 Billion board feet are found in trees with greater than 24" diameter. Regardless, MRC is harvesting in such a manner to improve the distribution of larger trees, especially redwood, across the landscape.

Facts: Facts: The FSC Certification process included input from more than 100 stakeholders. The process is voluntary for a landowner, and substantially raises the level of scrutiny for the landowner's management practices. Mary Pjerrou and Mary Bull, the authors of this critique, participated in MRC's certification, including a private meeting with the certifiers.

Get the Facts: Interested individuals are encouraged to contact NRDC and WWF and find out why those organizations support FSC Certification.

Get the Facts: Interested individuals are encouraged to contact Greenpeace and find out why that organization supports FSC Certification.

Get the Facts: Interested individuals are encouraged to contact American Lands Alliance and find out why that organization supports FSC Certification.

Get the Facts: Interested individuals are encouraged to contact Rainforest Action Network directly to find out what their position is on FSC Certification and MRC.

Facts: Facts: FSC Certification is about infusing higher levels of ecological values in the balance of environmental impacts, economic viability, and social benefits of an organization. Activists who are against the harvest of any trees will find it challenging to support the FSC.