Final comments:

Irving’s past practices, and even present practices veer substantially from the Ideal Performance. The team was more impressed with Irving’s computer model and assurances that the AAC’s will be followed in the future than by Irving’s practices at the time of certification. What should hold more weight is what goes on in the woods, than what is projected in the computer. The score of 90 was thus a case of serious grade inflation that violated the prohibition against certifying assurances (as discussed in section II of this report). SCS should have waited for Irving to comply by getting practices on the ground before issuing such a rating.

This criterion looks at two issues--management of current growing stock and establishment of regeneration--in terms of stocking and forest structure.

The SCS team’s comments made Irving’s on-the-ground management sound mediocre at best. Certainly not worthy of a B+ grade. After all, foresters have no time to mark trees. The machine operators, who make the decision of which trees to cut, are not foresters or forest technicians, nor are they paid for their extra duties, beyond cutting trees, yet they have to make decisions based on basal area, crown conditions, tree vigor, species, quality, and other factors requiring some training. Some of the cutting is done on a night shift, or even in a snow storm, yet operators in machine cabs must decide which tree to cut without getting out of the cab to look at all sides of the trunk or to look at crown condition. The contractors are paid on a weight basis. Irving sells the wood. If an operator is paid by weight and the trees are not marked, there is an incentive to cut the biggest trees first. Machine operators thus have to balance complicated rules (better left to a trained forester to interpret) with incentives to cut the biggest trees. Further, due to poor markets, hardwoods have been highgraded for a long time, and the team presents no evidence that the highgrading has ceased.

Yet, incredibly, after saying that management "could have been much better" the team concluded that the Allagash Timberlands "clearly rate a passing score relative to SCS performance standards." (pg. 17) The team is thus putting more weight on policies rather than performance, which goes against SCS grading protocol.

The intensive management, especially that involving planting boreal or exotic softwoods on Acadian sites, clearly veers far from the ideal to "maintain the original diversity of natural forests endemic to the region, in both species and structure."

Non-certification threshold:

According to J. R. Blais, "Should white spruce plantations become common, they will not only be subject to budworm attack, but will also contribute to increasing the severity of outbreaks. It is noteworthy that the only location where budworm populations were maintained at epidemic levels in the mid-1960s in Quebec was situated in the Grand-Mere white spruce plantations, the largest and one of the oldest (established in 1913-1932) in the province."

White spruce is also susceptible to the spruce bud moth, for which there was spraying in New Brunswick in the past.

Studies have shown that when black spruce grows on drier sites, it is more vulnerable to budworms. The reason for this is that instead of producing a large quantity of foliage, the tree puts out less but more nutritious foliage. Black and white spruce plantations, as mentioned earlier, are susceptible to the yellow-headed spruce sawfly (there were thousands of acres sprayed with carbaryl in Maine as recently as 1998). Entomologists at the Maine Forest Service told me that susceptibility to the sawfly is increased by thinning in young stands, a standard practice used to speed up diameter growth.

Research by Hew Crawford and Dan Jennings found that mature, deep-crowned red spruce offered a favored habitat for budworm-eating warblers. Fir stands and younger spruce stands support lower bird densities. Crawford, Jennings, and Titterington concluded that, "a mature managed forest containing a mix of species and size classes, and scattered openings and patches of regeneration, supports populations of birds that prey effectively on spruce budworm."

Brad Meiklejohn, in looking at buffer zones of various sizes, found that interior species (some of which are known budworm predators, such as Cape May, Blackburnian, and Bay-breasted warblers) nearly dropped out--not only from the heavily cut forest, but also smaller buffer zones.

Thus, to the extent that mature red spruce forests are converted to younger, even-aged forests, susceptibility to spruce budworm outbreaks could increase. The SCS team had very little to say about actual strategies to use this known research (besides fir-only cuts in some stands) to make stands less vulnerable to budworm and to create habitat for predators to the budworm. The team also did not discuss the extent to which Irving’s overstory removals are encouraging young, even-aged stands dominated by fir.

The SCS team made no mention of other known pests to white and black spruce. They argued that the forest is becoming less vulnerable by assertion, not evidence of practices. The most positive statement was of Irving’s financial ability to mount a pest control program, which veers towards the non-certification threshold of relying on chemicals to control future outbreaks.

The SCS team and Irving have failed to indicate the status of red spruce, the key species in the Acadian Forest, in terms of its age structure, abundance, and inventory trends. Maintaining old growth red spruce may be one of the more important pest control strategies. The fact that these stands have persisted for hundred of years, weathering all kinds of pests, including the spruce budworm, is testimony to the genetic or structural resistance in such stands. To what extent is Irving cutting older red spruce to meet the demands of the sawmill markets? This is an important question which is not answered--except that Irving’s 25 year plan calls for fewer acres of mature spruce-fir.

Because Irving’s spruce/fir strategy of short-rotation even-aged management may be increasing susceptibility to pests over more natural management, and because the Irving strategy for dealing with the budworm (PCS, pg. 14) will be by "aggressive salvage operations (...) coupled with insecticide protection on younger stands," the SCS score of 90 is a case of serious grade inflation for practices that fail to meet the non-certification threshold.

I will here only address the issue of harvest efficiency, as I assume Irving is good at marketing, mostly to its own mills.

Non-certification threshold (note: I only list these to show how extreme SCS has set the threshold--once again, confusing getting below 80 with flunking):

SCS certified Irving just after Irving had adopted a new plan. Cutting, up to the time of certification, was based on the old plan, which led to serious overcutting of spruce-fir. The new plan allows heavy cutting in spruce/fir based on the allowable cut effect (ACE). The certification is thus based on the promise that management practices will become sustainable, rather than that management practices were or are sustainable. The certifiers have put more weight on the technical virtuosity of the plan than on what the plan actually does.

Interestingly, SCS gave the BP&L a grade of 78 (below certification threshold) for this criterion, even though BP&L’s practices were clearly superior to the listed non-certification thresholds in the Operation Manual. This indicates that the most important issue is how far practices veer from the ideal, rather than from the non-certification threshold.

SCS grade: 75 (below certification threshold)

The SCS team had the most comments and gave the lowest grades with the most conditions to this criterion. Forest community structure and composition is clearly a weak point in Irving management. To be fair, some of the problems pre-date Irving’s ownership, but Irving has also clearly contributed to the skewing of seral stages across the landscape, and continues to do so. The team gave a 75 ("C") where perhaps a lower grade was deserved.

Note: once again, the non-certification threshold is defined by extremes that should rate below 50, rather than 79.

The SCS team, in this section is exceptionally polite. It talks in generalities and asks Irving to consider changes, such as not overcutting forested wetlands, not compacting or desiccating soils, making harvesting more sensitive to soil type, not putting trails in wetlands and causing excessive rutting, returning slash and tops back to the soil, and lengthening the rotations. These issues, including rotation length, are not trivial. Indeed, the reliance on even-age silviculture that does not mimic natural stand regeneration patterns clearly veers from the ideal performance. The fact that the team raises these issues and makes these suggestions implies Irving is not doing what it ought to. The score of 85, therefore, represents serious grade inflation. SCS is, apparently, not measuring how far Irving’s practices veer from the ideal, but, rather, how far the practices veer from the extremes listed in the non-sustainable thresholds.

Since riparian zones are supposed to not only protect stream quality (from siltation, nutrient pollution, temperature swings, and extremes in flow), but also provide nesting and migration habitat, they should be larger than what is required legally. What is now legal includes cutting right up to streamside with small and intermittent streams and having buffers of 75 feet for streams a little larger, where all that is required is "shade" (trees are not even mentioned in the LURC regulations).

Irving does cut in its riparian zones. According to the IMPS, Irving expects to get 8% of its spruce-fir volume from riparian zones. (IMPS, pg. 7). The SCS team neglected to say what the cutting standards are in these zones. For 250 foot riparian zones, Irving’s Standard Operating Procedures calls for contractors to follow LURC guidelines. For the 200 foot buffers for streams that appear on USFS maps, Irving has a 15 foot no-cut zone, but allows overstory removals in the rest. 87% of the 200 foot buffer, therefor, can consist of 5 foot high trees. Standards are even lower for intermittent streams.

The ideal performance would be to maintain riparian habitats in conditions associated with undisturbed forests--which means encouraging well stocked stands with large trees and plenty of cavity trees and potential cavity trees. The Maine Council on Sustainable Forest Management and Biodiversity in the Forests of Maine both recommended stocking of around 65-70% of full crown closure for all water bodies, even small streams (where forested buffers should be 75 feet wide at a minimum). The SCS team did not indicate whether these recommendations were being met, and therefore they give no grounds to support their grade of 95.

If riparian zones are to function as wildlife corridors, or nesting habitat, then they need to be fairly wide so as to offer interior forest and not just edge. Fifteen foot buffers surrounded by overstory removals are simply inadequate to serve such purposes (and are questionable for protecting water quality as well). If the size and conditions of the riparian zones veer from undisturbed forest and recommended stocking, these buffers do not rate an "A." Comparing Irving’s practices to regulations that are inadequate is a form of grading on the curve, rather than grading based on variance from the ideal.

Note: this statement of the Allagash Certification Summary makes it sound OK to justify use of chemicals if you "minimize" the use and only spray them in limited conditions. But this should not trump the previous statement that states you should not be using silvicultural system that rely on pesticides. If you do use systems that rely on pesticides, but you minimize the use, this should not lead to a grade of "A"--it should lead to a grade below 80.

The team chose not to address the pesticide use in Irving nurseries or the potential pesticide use that will be used on plantations, or Irvings’s history of intensive spraying for spruce budworm in the past. The team also did not discuss to what extent Irving sprays sites more than once with herbicides.

The Irving Management Plan Summary has precisely one paragraph on herbicides, with no real data. Within this document is a sentence, "It is our policy to utilize herbicides only where absolutely necessary." (IMPS, pg. 9) Apparently, Irving thinks (and SCS agrees) that it is absolutely necessary to spray on thousands of acres per year and to be one of the biggest forestry pesticide users in the state of Maine.

The SCS team in this criterion has failed to assess how far Irving has strayed from the ideal performance by Irving’s choice of silvicultural systems that depend on pesticides. Proof that it is not "absolutely necessary" to spray thousands of acres with herbicides per year can be found by looking at the Bureau of Parks and Lands and lands managed by Seven Islands, both of which SCS is quite familiar, and neither of which uses anywhere near as much pesticides as does Irving. In SCS’s certification report on the BP&L (pg. 81), the team states that "the BP&L does not engage in clearcutting, the prescription that most often leads to some herbicide use."

In this criterion, SCS uses a form of logic that does not pass the straight-face test. Irving does more clearcutting and planting (as a percentage of ownership) than almost any other landowner in the state. These are systems that "heighten dependency on pesticides" (which is a non-certification threshold). Indeed, Irving is one of the top herbicide sprayers in the state. Because Irving is taking steps to reduce spraying (it "only" sprays 95% of its plantations, rather than 100%), the SCS team has given Irving a low "A." Giving a 90 to a landowner that mitigates a practice that is still below non-certification threshold is very serious grade inflation.

SCS is interpreting a representative reserve system to mean "protecting" "exemplary natural communities," where "protection" can include putting in roads and cutting trees. Indeed, that is how Irving is currently "protecting" many of its unique areas, which make up only 2% of its productive forest. These "protected areas" only average a few hundred acres in size--which is totally inadequate for consideration as serious ecological reserves. The Scientific Advisory Panel of the Maine Forest Biodiversity Project suggested a minimum average of 5,000-12,000 acres for an individual reserve in an ecological reserve system. In New Brunswick, the minimum average suggested by scientists was 60,000 acres.

The Precautionary Principle suggests the wisdom of emulating the natural processes and structures of unmanaged forests to ensure that species (which are adapted to these processes and structures) are not lost. To the extent that managers intensify management in a way that simplifies, fragments, or converts the forest, the need for ecological reserves increases--if protecting biodiversity is a priority.

Since Irving is doing intensive management on a fairly ambitious scale in the spruce-fir ecosystem types, one could reasonably conclude that to balance this out, there should be a fairly ambitious reserve system in these same types. Indeed, this type of balance is called for in DIS indicator "h" (quoted earlier in this section).

Although one of the SCS certifiers, Bob Seymour, has endorsed the "Triad" model, where the forest is divided into a non-clearcut matrix, an intensively-managed sector, and a reserved sector, he has certified Irving, which lacks the reserved sector. What is being promised is not a true reserve sector--but, rather, tiny examples of some community types--where there is an option to cut in some of these examples.

Maine only has around 2% of its land in ecological reserves. Most of this is in Baxter State Park. The Maine Forest Biodiversity Project found the current reserve system inadequate to create a true representative reserve system. Scientist, Janet McMahon, did an inventory of current public land for the MFBP to see to what extent this land base could complete a reserve system. Her conclusions were that:

Another report done for the MFBP was Biodiversity in Maine, an assessment of biodiversity by species and ecosystem type. This report concluded that, "Eight of the 25 forest community types in Maine are rare; of the types that are not rare, good natural examples are rare. Natural forest diversity, in common as well as rare types, is not adequately represented or protected within the lands that are currently in public ownership or private conservation ownership."

In other words, it is not just rare ecosystem types that are needed for protection, but also common types, because these common types are those most often roaded and cut. Given so few acres exist of exemplary forests representing all ecosystem types, it will be necessary to use forests currently in the timber base and restore them to more natural conditions if Maine is to have a complete and functional ecosystem reserve system. This reasoning further implies that forests that are currently in the timber base could be considered as HCVFs.

Indeed, the Principle 9 Advisory Panel Recommendation Report Draft (Version 1.2--March 2001), concluded, (pg. 5), that "Identification of HCVFs is most urgent in regions where protected areas networks are deficient or incomplete [...] Unprotected and under-represented forest types have higher conservation priority than types well represented in protected areas."

While it is laudable that Irving is working with the Maine Natural Areas Program, this alone does not qualify the company for a high grade for this criterion. The company currently does not have a representative reserve system as required by FSC Criterion 6.4. Furthermore, to the extent that Irving relies on intensive management in the spruce-fir type, it should be balancing this with a reserve system in the same type. By not doing so, the company is violating the Precautionary Principle, which is the basis for FSC Principle 9. That Irving intends to put 500 miles of road into a roadless area, and has already put a right-of-way through an enriched old-growth cedar stand raises even more questions about the grade of 88 given to Irving. SCS should be grading on actual practices, not promises.

Irving is very strong financially. Irving also seems to be one of the more stable companies in Maine, and is quite likely to be around a long time. The stability of the company, however, does not translate to the stability of the communities dependent on Irving.

One of the reasons for the company’s financial success is that the company can dominate markets and does respond to short-term market trends. Except for low-grade hardwoods, Irving has its own markets for most of the products from the woods. This dominance of markets gives the company a regional competitive edge.

This competitive edge does not mean, however, that Irving is not responding to short-term markets. If the pull of the markets were not a major factor in management, how can one explain Irving’s intensive cutting of its spruce/fir stand type, and much less intensive cutting in stand types (such as hardwoods) where markets are poor? Other landowners, such as the BP&L, are demonstrating that spruce/fir can be managed as uneven-aged or for long rotations (100-150 years). If the goal is restoration of the forest to more natural conditions, Irving could be following that example.

Irving is improving its public relations with local communities. These relations used to be a real problem--to the point that a number of towns passed ordinances to restrict the company’s aggressive intensive management practices. This benign facade, however, drops when it comes to relations with contractors--a topic to be discussed later.

More troubling is the impact of Irving management on local communities. The intensive management surely does not improve the aesthetics or wildlife benefits. There are people who are not that thrilled to live next to herbicide spray programs--including some organic farmers. It is possible that the majority of wood cut on Irving land is being milled in New Brunswick or Quebec and not in Maine. The SCS team gave no statistics on this important issue. If this is so, it means that value-added income is being lost, as well as potential jobs.

There is a trend in northern Maine communities of populations falling, businesses leaving, infrastructures crumbling, and schools closing. Irving’s tenure in the region does not seem to be reversing these trends. The fact that Irving is stable and growing does not mean that the communities in which Irving’s land is located are also thriving and stable as well. While it is certainly admirable that Irving gives to the boyscouts, it would be far more beneficial to the community if the company paid better wages in the woods and sent more wood to mills in northern Maine than in Canada.

The emphasis on benefiting local communities with employment is clear from the Draft Interim Standards performance indicators based on FSC Principle 4, criterion 4.1, "The communities within, or adjacent to, the forest management area should be given opportunities for employment, training, and other services." (DIS, pg. 6). One wonders, therefore, why there are so many foreign workers cutting, planting, and thinning on Irving land.

In the Maritimes, most of the labor used to plant and thin young softwood stands is supplied by local silvicultural contractors. In Maine, however, most of this work is done by Central Americans. One cannot call a Central American "local" by any stretch of the imagination.

Likewise, for years there have been controversies over the use of Canadian loggers in the Maine woods. Lately the percentage of Canadians has gone down on Irving lands in the Allagash district. Some contractors have argued that even many Canadian loggers find that working for Irving, because its payscale for wood is so low, undesirable. While it may be argued that Canadians and Central Americans are hired because labor is in short supply in Maine, the counter argument is that labor is in short supply due to the wages paid. If there really is a shortage, than the company should pay more money and initiate training programs to attract more local labor. Instead, local labor is leaving the area.

Given that the land is foreign-owned, and profits leave the state (and country), much of the wood is milled in Canada, so value added leaves the state, many of the workers are from Central America or Canada and so wages leave the state, and the clearcut forests are surely not an attraction to tourists, one wonders how Irving deserved a score of 97 for community benefits.

Likewise, when there are bills to limit liquidation or rationalize riparian zone standards, Irving representatives have not been in the forefront as advocates for sustainability. While the donations to community activities are certainly a mitigating factor, and the expansion of Maine mills is welcome, this is like clearcutting 25 acres, but leaving a small island of "reserve" trees behind, and then getting praise for caring about ecosystem structure. It lessens, but does not change, the basic problem.

Given just Irving’s very indadequate investment in foresters who can mark and supervise cuts, the SCS grade is inflated. Adding on Irving’s reliance on feller bunchers, run by independent contractors marginal operating budgets, brings further question to awarding of such high grades. Irving is investing in many areas (such as mill improvements) but is clearly stinting where it counts in the forest--foresters and woods workers.

The SCS team gives some fairly damning evidence of a squeeze on contractors. The contractors’ complaints were labeled "anecdotes" and the team suggested that there was "another side of the story." The "other side" that the team mentioned was that the squeeze on contractors was an industry-wide trend, suggesting that Irving was being passively swept up in this trend. The team suggested monitoring the situation to see if this was a temporary market shift or something more serious, even though these trends did not start the year Irving got certified.

But there is another side to this "other side" that the SCS team chose not to address. The market for woods labor in northern Maine is not "free." It is an oligopsony--where just a few big players control purchasing. This oligopsony is an even more potent force for having power over labor than the threat of Canadian labor. Irving is thus not a passive player--it has control over that market, and is using its position to cut costs. And it has been successful in cutting labor costs:

These cost reductions for Irving have not been passed on as higher wages for either contractors or loggers. These cost reductions for labor have been used to leverage higher profits for Irving. Indeed, the PCS suggests contractor margins have gone down.

Irving has further reduced costs (and the SCS team neglected to discuss this) by going from large contractors to smaller contractors--owner-operators. The report on bonded labor stated that these small independent contractors and subcontractos are not subject to protections such as WC, OSHA, FICA, or Unionization. "...from the standpoint of US labor law, these workers do not exist." (pg. 64) These smaller operators, making huge investments in machinery, are even more at the mercy of Irving. If Irving fires them, they have nowhere else to go with their equipment. And they have big payments to make. What the contractors told the interviewers is that Irving is not just following an industry-wide trend--Irving is setting the trend. Irving is not forced to treat contractors this way; it chooses to do so.

At the time Irving got certified, loggers and truckers, in unrelated actions, were blockading the border with Canada in protest (to some extent) over the squeeze on labor. Truckers complained that they were forced to drive overloaded trucks and work long hours just to break even. The loggers’ blockade led to the Pan Atlantic study done for the Department of Labor. This study showed that while landowner profits over the last few decades went up 169%, real wages for loggers went down 32%. This study uncovered a sobering trend: "The intergenerational chain which has produced loggers in the woods for perhaps hundreds of years may be strained to the point of breaking.." (pg. 198) (my emphasis). One logging contractor quoted in the Pan Atlantic Study claimed that Irving cut his rates by 30% after the company bought land from Bowater. "Irving has taken over," he said, "they set the low prices and the competition will follow. The State of Maine needs to protect its people. Logging will never be the same."

The "shortage" of labor in northern Maine is not due to the remote location. It is a shortage of people who want to work at wages considered too low. When oil companies wanted to build a pipeline in Alaska several decades ago, they had no trouble finding workers when they paid good wages. Indeed, workers came to Alaska all the way from Maine.

The Maine Center for Economic Policy did a study estimating the living hourly wage for various counties and metropolitan areas on Maine for 1999. For Aroostook County, the figures were:

8.12 9.87 12.46 15.33 20.13

This estimate of living wage was based on local costs for food, housing, transportation, phone, health care, clothing, personal care, and other factors. For loggers, the costs for transportation would go up, because a more substantial vehicle is needed and the distances traveled are greater. Based on this information, it becomes more evident why loggers working at wages of 9 or 10 dollars an hour end up working 50-60 hours per week. They need the overtime to break even.

The study suggested that many families are not earning a living wage and that the result is many families have large debts, they go without, or they require public assistance. The cost of living is lower in Central America (which has a lower standard of living) and Canada (which has less expensive health care costs), and thus the wages are more acceptable to workers from these regions.

Local labor has little ability to negotiate in the economic climate of northern Maine. The SCS team did not discuss what types of contracts Irving has with its small contractors and to what degree Irving can unilaterally change the terms. The Irving contract that contractors have to sign has the following clause in it:

"... Irving shall have the right to terminate this agreement whenever and for whatever reasons it chooses, including but not limited to market conditions. Such termination shall be effective immediately after written notice is given to the Contractor or any other time specified in such termination notice. In the event of such termination, the QILC shall have ten days to remove itself and all of its equipment, supplies and materials..." There are no grievance procedures for contractors if they feel that Irving is breaking the contract or unfairly withholding payments.

Certification has led to increased responsibilities for contractors--such as returning tops to the trails, leaving more wood behind in configurations that slow production, or making yards smaller and trails further apart. While these practices may be marginally better for the woods, the contractors are losing production with no reward. One contractor told me that his rates with Irving have not changed in 10 years, even though his expenses have doubled. When he complained about this, he was told to go on a double shift.

Irving does have a clause in its contracts relating to certification:

"Irving is committed to fostering Best Management Practices in its intensive forest management practices in working towards it (sic) goal of Green Forest Certification. To this end, Irving may, but is not required to, make payment(s) to QILC as a premium when performance under this agreement demonstrates, in Irving’s exclusive judgment, superior compliance with the terms and conditions of this contract so as to further extraordinarily Irving’s commitment to Green Forest Certification. Premium payments, if any, may be monetary or otherwise, and shall be made, if at all, at Irvings’s sole discretion and under terms and conditions which Irving alone determines to be prudent."

Irving does seem to be a stable, if not growing, entity in northern Maine, but as stated earlier, this does not always translate to stability for those from the local communities. One 4th generation logger from the Allagash area told me that an Irving forester had told him, that Irving may pay the lowest, but it will be around the longest of the big landowners. The logger’s response to this was, "Yes, Irving will still be here, but I won’t."

The SCS grade of 92 for employee and contractor relations has certainly raised a lot of eyebrows in northern Maine, where people are familiar with Irving’s practices. The evidence from the PCS (and from other sources) shows practices that veer widely from the Ideal performance. Indeed, the word "exploitation," a non-certification threshold, easily comes to mind.

What percentage of the spruce-fir forest in the Allagash Timberlands is under intensive management and how short are the rotations? This basic information is not contained in a direct form in either the certification Public Summary (PCS) or Irving Management Plan Public Summary (IMPS). To assess many certification issues--both silvicultural and biological, this information is basic.

Fuzzy math. Unfortunately, there are a number of errors in the PCS, IMPS and Irving brochures, that make calculations difficult:

These disparities do not inspire confidence in the reader and make it difficult to determine what is the actual scale of certain types of activities in specific areas.

Besides the confusion over numbers, there is also variability over how the numbers are used. The two documents, for example, give plantations as a percentage of total acres (to make it look insignificant), but special management zones as a percentage of productive acres (to make it look more significant). While the PCS and IMPS add up the 10% riparian, 5% deer yards, and 2% unique areas to create a special management zone (SMZ) of 14%, or around 74,900 acres (implying that there is overlap), the Irving Allagash Woodlands Management Plan brochure adds it all up to be over 90,000 acres or 15% of the entire holding (actually it would be closer to 16%, but who’s counting?).

Spruce/fir acreage in the Timber Management Zone. I have been able to make estimates of spruce-fir acreage, the extent of intensive activities, and potential rotation length (but this may change with thinning in the next 25 years) despite the failure of both SCS and JDI to provide that information. My estimates are conservative, so if I err, it is on the side of caution.

Below I reveal the process and sources with which I made the calculations so that Sierra Club can determine which ones are most likely to be "in the ballpark." I recommend that the Sierra Club not rely on my figures, however. I did the calculations to show why there is strong room for concern. I will separately make a list of questions that Irving and SCS should answer for the auditors so that the auditors do not have to guess over these crucial issues as I have had to.

Total acreage: 569,320 (PCS and IMPS)

Productive acreage = 94% of total = 535,161 (PCS and IMPS)

Acreage of softwood = 35% of total = 199,262

On page 20 of IMPS are two graphs of Western Ecosystem and Eastern Ecosystem

From these we find that

Percent of softwood in WE = 34%

Percent of softwood in EE = 46%

These figures are for productive forest.

For whole productive forest we can determine that softwoods make up (.35/.94) or 37%

Based on this we can determine that 75% of the area is in WE and 25% in EE

(to test .75*.34 + .25*.46 = .37)

In 1999, percent of bs + s/f (black spruce and spruce/fir) in WE was 22%

Percent of bs + s/f in EE was 29%

Therefore, using the above determined weightings,

the percent of bs +s/f for productive forest is 24% or (.24*535,161) 127,100 acres.

The same chart on page 20 of IMPS gives projections of stand types 80 years from now.

Based on these charts and the same mathematical reasoning,

I estimated that the percent of bs and s/f 80 years from now would be 30% or 161,886 acres.

This means that in 80 years, s/f will increase by 34,785 acres, or 448 acres per year on average.

According to the charts in the IMPS, most of this increase would come from decreases in intolerant hardwoods, intolerant mixedwoods, and cedar.

My experience viewing Irving management on the ground is that Irving has clearcut some tolerant hardwood and tolerant mixedwood and converted them to plantations. The company has also removed softwoods from mixedwoods, turning them into hardwoods. I have serious doubts about the accuracy of the figures supplied by Irving. For this exercise, however, I will use the Irving figures as if they were reliable.

Calculating the percentage of spruce-fir in Special Management Zones (SMZ) is less exact.

While 10% of productive forest is in riparian zones, 5% in deer yards, and 2% in unique areas, this only adds up to 14%, not 17%. There is obviously an overlap of deer yards and unique areas with riparian zones. Also, the percentage, 14%, does not carry across all timber types.

The PCS states (pg. 32) that softwoods are by far the dominant forest type in the riparian zones.

If we are conservative and call "dominant" at least 60%, then we can estimate that at least 17% of softwoods are in riparian zones.

Since there is overlap with deer yards and unique areas, but since deer yards are predominantly softwood, by necessity, and since the IMPS (pg. 7) shows 8% of s-f volume coming from riparian areas, 4% from deer yards, and 3% from unique areas, (15% total). I will estimate (and here I am making a conservative guess) that anywhere from 20-25% of spruce/fir acreage is in SMZs. I am assuming that Irving has tried, to the extent possible, to put deer yards in cedar, if the yards are not in riparian zones. If the figure is 20%, that means that JDI is cutting the spruce/fir SMZ at around 75% of the intensity of the spruce/fir timber management zone (TMZ). That would be pretty heavy cutting to be called "protection."

Indeed, heavy cutting is allowed under Irving’s Standard Operating Procedures. Only 15 feet of the 200 foot buffer zone around streams needs to be standing trees. The rest, 92.5%, can be subject to overstory removals and consist in 5 foot high trees. For the sake of being conservative, I assume that only 5% of the spruce/fir type is actually protected from even-aged management.

So, what we are establishing is that the actual spruce-fir and black spruce TMZ (where even-aged management can be practiced) is probably around 95% of total for that type or less than 120,745 acres.

In 25 years, this figure will increase by (448*25) 11,200 acres to 131,945 acres.

Planting. Both the IMPS and PCS state that JDI is going to plant 1200 acres of trees a year for the next 25 years.

In 25 years, the PCS (p. 5) states that there will be around 40,000 planted acres. That figures to be 30% of our estimate of the TMZ.

Herbicides. For herbicides, the information is not helpful. For the last 9 years (PCS, pg. 5) between 1,800 and 6,000 acres were sprayed per year. No totals per year were given. A logical guess would be to find the average and multiply that by 9. That gives 35,000 acres sprayed up until 1999. For the next 25 years, Irving plans to spray from 1,800 to 3,000 acres per year (PCS pg. 33). That might average out to be 2,375 per year or 59,375 acres after 25 years. Total acres sprayed in 25 years would be 94,375. But we can not estimate this as a percentage of acres in the TMZ, because Irving has often sprayed stands more than once and might be spraying some herbicides in other stand types. We do know that Irving sprays 95% of plantation acres and a good percentage of natural regeneration cuts. The percent of the spruce-fir TMZ sprayed in 25 years could be anywhere from 50% to 70%, depending on how much double spraying goes on.

Pre-commercial thinning. For PCT, the IMP states (p. 9) that 12,000 acres have already been treated and there will be around 2,400 acres of PCT a year for next 25 years. On the next page, however, this figure turns into 2,300 acres, despite the fact that the last year listed (1998) the acreage was 2,929 acres. And on page 42 of the PCS, the estimated average for the next 25 years is 3,000 acres. Go figure. Assuming 2,400 acres, in 25 years, 72,000 acres will have received PCT. That would be 55% of the high estimate of TMZ acres. If the average acreage of PCT is 3,000, the 25-year figure would be 87,000 acres--or 66% of the spruce fir type.

Spruce/fir rotation? Assuming that all acres that are planted also get PCT, the rotation for spruce-fir in the TMZ, using the highest, most conservative estimate of acres would be (112,880/2400) 55 years.

That also assumes that all spruce-fir in the TMZ is even aged and all acres regenerated get thinned, even those planted. It also assumes that all spruce-fir that can get regenerated, even in "special management zones" is. Any change in those assumptions would lead to shorter, not longer rotations.

Clues that these statistics may be correct? Page 13 of PCS states that Irving is planning to cut 2.4% of s-f volume per year. If this were all even-aged, and if cut equals growth, that would work out to a 42 year rotation. Some of the spruce and fir, however, is coming from partial cuts in mixed woods, so this figure alone is inadequate.

On pg. 21 of PCS, SCS suggests that in some areas, "high-yield, short-rotation forestry may be the best means of meeting future wood supply needs." This statement is both an admission to and a sign of acceptance of short-rotation forestry on Irving lands.

How Irving’s intensive management compares to other landowners in Maine Despite the dilution of the intensive management with less drastic cutting regimes in other forest types, Irving’s use of intensive management stands out in Maine. Its rate of clearcutting as a percentage of the entire holding would put it as one of the top two clearcutters in the state, based on figures found in the 2000 Silvicultural Report of the Maine Forest Service.

For 25 landowners with over 100,000 acres:

Thus even Irving’s projected rate of clearcutting would put it in a range now occupied by only 2 landowners in the state ofMaine.

Similarly, Irving’s use of herbicides is near the top. Although Irving may have reduced its use of clearcutting and herbicides, so have the other landowners in the state. In 2000, clearcutting made up only 2.5% of all cuts in the state. Herbicides were sprayed for release on 24,000 acres in the entire state, with 4,352 acres in Aroostook County. Herbicide use by Irving thus made up the bulk of herbicides in Aroostook.

SCS is thus certifying a landowner that is a leading user of practices of which much of the public disapproves. Other certified land managers in the same region, the Bureau of Parks and Lands and Seven Islands, use very little clearcutting and very little herbicides, demonstrating that these practices are not necessities at the levels used by Irving.

Rate of cutting for entire productive acres. Even using statistical dilution with hardwoods and cedar to mask the intensity of cutting in the spruce/fir stand type, if you look at the 25 year projected combined rate of clearcutting plus overstory removals (2,568 + 3,400) you get close to 6,000 acres of regeneration cuts per year. Taking out the 10% of the productive forest that is in riparian zones (I’m assuming, to be conservative, that Irving will clearcut or overstory remove most of its deer yards and unique areas), and discounting this by 50% to account for regneration cuts in the riparian zone (I’m assuming not so much heavy cutting in zones dominated by hardwoods) you get a possible regeneration zone for Allagash Timberlands of 598,403 acres. At the projected rate of regeneration cuts, it would take around 85 years to go through the entire zone where regeneration cuts are allowed. If we subtract areas where Irving plans to do uneven-aged management, this rotation shortens. Unfortunately, none of the SCS or Irving literature gives adequate information with which to make an estimate of rotations in even-aged stand types, but this upper possible estimate is far too low to be in a range that could be considered "natural." The natural rotation for stand-replacing disturbances in the Acadian Forest type is hundreds of years at a minimum, certainly not 85 or fewer years.

The culmination of the mean annual increment occurs when the annual growth is equal to the average growth over the life of the stand. This chart shows that in a red spruce stand with trees regenerated after the budworm outbreak of 1919 and a cohort of older trees (up to 275 years), neither the younger cohort (up to 75 years old) nor the older cohort had culminated the mean annual increment. The annual growth was still greater than the average growth. Since the non-certification threshold for SCS criterion A.1 is that rotations are well below the culmination of the mean annual increment, this information from Weymouth point brings into question the certifiability of Irving’s short rotations if they occur in red spruce.

It is interesting to note that the annual growth in 1990-1994 is equivalent to around 1 and one fourth cords per acre per year of high quality, large diameter red spruce. Plantation management of boreal softwoods would be lucky to equal such a volume yield, but the trees grown in such plantations have high taper, big growth rings, and lots of knots, leading to lower quality and value.