2020-2025 ATFS Standards Public Comment

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Your Feedback is Valued in the ATFS Standards Review Process

Stakeholders are invited to submit input into the ATFS Standards Review process during the first 60-Day review period, January 2 – March 2, 2020 using this online form. 


Please note that the ATFS Standards for Sustainability are intended specifically for the size, scale and intensity of small private, family ownerships in the United States, as well as the capacities and resources of their owners. 


You may save your responses and resume at a later time as well. Questions should be directed to Leigh Peters at lpeters@forestfoundation.org.


Welcome

Demographic Information

There are 5 areas of focus within this survey. You can skip between sections by using the page navigation along the top of the page:

 

Ø  General Feedback (page 3)

Ø  Key Considerations for ATFS Standards (page 4)

Ø  Current 2015-2020 Standards and Guidelines (page 7)

Ø  Key consideration for Independently Managed Groups (IMG) Standards (page 13)

Ø  ATFS Independently Managed Group (IMG) Certification  Standards (page 14)

General Feedback

Key Considerations for ATFS Standards

ATFS is recognized as a global leader and innovator in the arena of family and small lands certification. As the ATFS community reviews the ATFS standards, there is a need to also review and grapple with emerging and important issues in forestry and conservation community, to maintain the rigor, relevance and impact of ATFS. Similarly, the Program for Endorsement of Forest Certification (PEFC) has recently revised their “meta standards” which are the international requirements that all endorsed programs, including ATFS, must conform to. These changes to the PEFC meta standards will require additional considerations for incorporation into the revised ATFS standards, in addition to considerations derived from public feedback and developments in the sustainable forestry and family engagement woodland arenas to promote the efficiency and conservation impact of ATFS.

Many of these issues are at the forefront of dialogues about sustainable forest management at the local, state, national and international levels in government, environmental and business communities. The inclusion of these important issues helps to ensure continued recognition of ATFS and of the critical conservation impacts that family woodland owners provide.

Below are a suite of emerging issues, challenges and opportunities for ATFS. Feedback on how ATFS can address these issues is welcome, in addition to feedback on the existing ATFS standards and guidance. 

Conversion
Pesticide Usage
GMO

Standard 3 with Guidance

Refer to the current standards here:

Visit TreeFarmSystem.org for more information.

Standard 1: Commitment to Practicing Sustainable Forestry

Landowner demonstrates commitment to forest health and sustainability by developing a forest management plan and implementing sustainable practices.


Interested parties are encouraged to submit their suggestions for improvement to the ATFS Standards, as well as identify any areas within the 2015-2020 ATFS Standards of Sustainability where additional guidance would help support implementation or auditing of the ATFS Standard in practice.

Comments may be submitted for each individual Standard, Performance Measure and Indicator, as well as the body of the ATFS Standards of Sustainability, as a whole. Please note, you need not comment on every element. 

Performance Measure 1.1

Landowner shall have and implement a written forest management plan consistent with the size of the forest and the scale and intensity of the forest activities.

Guidance Performance Measure 1.1

The management plan may include several separate documents that, taken together, constitute the management plan. Management plans vary widely and may encompass a wide range of formats, language styles and document types, including emerging digital technologies and other tools that illustrate evidence of planning. 

Umbrella management plans may be utilized in the management of multiple parcels and ownerships. Landowners or their designated representatives and qualified natural resource professionals are advised to select language that best reflects landowner’s objectives and property circumstances. Consideration of specific conditions (size, scale and intensity of property and operations), landowner capacities, access to resource professional support and nonliteral interpretations are advised.  

Indicator 1.1.1

Management plan shall be active, adaptive and embody the landowner’s current objectives, remain appropriate for the land certified and reflect the current state of knowledge about natural resources and sustainable forest management.

Guidance Indicator 1.1.1

The management plan’s detail should reflect the forest and habitat complexity of the property as well as the management intensity planned for the property. The Standards do not require a prescribed management plan information structure or hierarchy. The plan preparer has considerable latitude in developing the management plan, or its composition of parts, at a level of complexity that reflects the landowner’s objectives and provides for an accurate method of prescribing any planned treatments or activities on the property. A more formal or structured system is appropriate for larger collections of properties, whether under one ownership or part of an independently managed group (IMG) structure.  A group manager should have a system in place to allow timely retrieval and editing of management plans under his/her authority and responsibility. Handwritten notes to the plan are acceptable as indications of updates to the plan for individual properties. 

The nature of adaptive management requires that the landowner or his/her designated representative not be bound to follow the management plan prescriptions when circumstances influencing the property and its management have changed or when the landowner’s objectives change.  Examples of such changes include changes in family circumstances, the sale or acquisition of lands included in the certificate and disturbance from storms, fires, pests or disease outbreaks.

Forestry involves dealing with dynamic natural systems and some accommodations may be necessary or natural events such as fires, flooding or wind damage, as well as the landowners’ personal circumstances. To respond to such events, management plans must be active and adaptive in nature, as indicated in Indicator 1.1.1.

Indicator 1.1.2 

Management plans shall describe current forest conditions, landowner’s objectives, management activities aimed at achieving landowner’s objectives, document a feasible strategy for activity implementation and include a map accurately depicting significant forest‐related resources. The forest management plan shall demonstrate consideration of the following resource elements: forest health, soil, water, wood and fiber production, threatened or endangered species, special sites, invasive species and forests of recognized importance. Where present and relevant to the property, the plan shall describe management activities related to these resource elements. 

Where present, relevant to the property and consistent with landowner’s objectives, the plan preparer should consider, describe and evaluate the following resource elements: fire, wetlands, desired species, recreation, forest aesthetics, biomass and carbon.

Guidance Indicator 1.1.2

Current conditions may be described in general terms, including age, species and composition, or identified in accompanying maps and inventories. The depth of narrative and level of detail in current condition descriptions may vary widely with access to technical support, property attributes and the scale and intensity of management. Third‐party assessors are encouraged to recognize a range of approaches in assessing current condition descriptions.  

The plan must clearly describe landowner’s objectives. Landowner objectives are concise, high‐level statements of what the landowner hopes to accomplish through his or her management. Landowner objectives may range widely in language styles and approaches, from specific and technical to general and nontechnical. For example, some plans may describe specific forest conditions (fast‐growing conifer plantations, mixed hardwood bottomland forests, older forests of longleaf pine, etc.) or general goals for the property (good habitat for animals, a healthy forest, etc.) the landowner is attempting to achieve. 

Strategies for achieving the landowner’s objectives should be reflected in the body of the plan. For example, if the landowner’s objective is to increase the occurrence of wildlife on the property, the management plan is expected to prescribe management activities that will enhance, or at least maintain, suitable habitat. 

The plan must specifically mention the required topics (forest health, soil, water, wood and fiber production, threatened or endangered species, special sites, invasive species and forests of recognized importance).  If there is no occurrence of an attribute on the required topic list (threatened or endangered species, for example), the plan should state that the attribute is not While the management plan is not expected to address all possible facets of state‐of‐the‐art forestry or habitat management, the plan is expected to avoid forestry or wildlife management practices that do not support sustainable forest management.  For example, a plan that prescribes practices to maximize short‐term income should not compromise long‐term forest health or resilience.

Management plans can present a suite of options to landowners for their consideration. ATFS does not view management plans as a strict blueprint for landowner action, rather that management plans are adaptive and responsive to a number of factors. Qualified ATFS inspectors and third‐party assessors should contemplate the following question when assessing the conformance of a management plan to the AFF Standards: does the failure to perform the plan‐action constitute a breach of sustainability for this property? If the answer is no, then, the landowner is not out of conformance. If the answer is yes, this is an issue that needs to be addressed.

Indicator 1.1.3

The Landowner should monitor for changes that could interfere with the management objectives as stated in management plan. When problems are found, reasonable actions are taken.

Guidance Indicator 1.1.3

Monitoring for individual landowners or designated representatives can be achieved by visiting the property on a regular basis, riding through it or walking the trails. This can be done annually or more or less frequently depending on the individual circumstances (region, soils, risk of invasive species, risk of pest outbreaks, etc.).

Landowners and designated representatives are encouraged to keep a written record of monitoring observations to reflect and document changing conditions‐‐ including the presence of invasive species, pest or disease or storm damage‐‐ along with management activities. In addition, these records may also be used to defend against adverse possession claims, substantiate any casualty losses and enable timely response to trespass, illegal dumping, timber theft and insect or disease outbreaks.  Records of monitoring may be informal, such as handwritten notes, and could include photos, digital technologies, online tools such as www.mylandplan.org and other emerging media.  Landowners are encouraged to update management plans based on monitoring. Records of management activities should, over time, demonstrate response to information inputs from monitoring.

A management plan is considered current if it remains consistent with the landowner’s objectives and the conditions on the ground, regardless of when the plan was written.

Standard 2 with Guidance

Refer to the current standards here:

Visit TreeFarmSystem.org for more information.

Standard 2: Compliance with Laws

Forest management activities comply with all relevant federal, state and local laws, regulations and ordinances.

Performance Measure 2.1

Landowner shall comply with all relevant federal, state, county and municipal laws,  regulations and ordinances governing forest management activities 

Guidance Performance Measure 2.1

The Standard only applies to laws, regulations and ordinances related to forest management activities taking place on the property.

Landowners or designated representatives should employ the maxim, “When in doubt, ask.” Common forest management activities that are regulated in many states include conservation of state and federally protected species and their habitat, prescribed burning, pesticide application, harvesting, road building, pond construction and stream crossings. 

 Excellent professional resources are available at local natural resource agency offices. Please consult the resource pages on the ATFS website and at www.mylandplan.org for additional help on relevant federal and state laws and regulations.

Indicator 2.1.1

Landowner shall comply with all relevant laws, regulations and ordinances and will correct conditions that led to adverse regulatory actions, if any.

Guidance Indicator 2.1.1

Full legal compliance with relevant laws, regulations and ordinances is the intent of the Standard. Mistakes may occur in carrying out forest management activities.  Landowners must be committed to correcting inadvertent violations.  A pattern of willful violation of relevant laws, regulations or ordinances is not acceptable.

If there is evidence of past nonconformance, then the landowner must show proof of a good‐faith effort to remedy the nonconformance.  If the matter is tied up in court, then the landowner is only disqualified when a final adverse judgment is rendered and the landowner refuses to comply with the ruling. Compliance with all relevant (applicable) laws can be verified by a three‐tiered process:

Step 1 – Observation of conditions on the subject property

Step 2 – The landowner’s verbal or written claim of legal compliance

Step 3 – Research with the state Department of Natural Resources, local Natural Resource Conservation Service office or State Forestry Commission offices

If Step 1 and Step 2 do not raise any issues, then the qualified ATFS inspector or third‐party assessor is not required to employ Step 3.

Indicator 2.1.2

Landowner should obtain advice from appropriate qualified natural resource professionals or qualified contractors who are trained in, and familiar with, relevant laws, regulations and ordinances.

Guidance Indicator 2.1.2

Landowners are advised to engage qualified natural resource professionals and qualified contractors, licensed pesticide applicators and other trained professionals to support regulatory compliance.  

Standard 3 with Guidance

Refer to the current standards here:

Visit TreeFarmSystem.org for more information.

Standard 3: Reforestation and Afforestation

Landowner completes timely restocking of desired species of trees on harvested sites and nonstocked areas where tree growing is consistent with land use practices and the landowner’s objectives.  

Performance Measure 3.1

Reforestation or afforestation shall be achieved by a suitable process that ensures adequate stocking levels.

Indicator 3.1.1

Harvested forest land shall achieve adequate stocking of desired species reflecting the landowner’s objectives, within five years after harvest, or within a time interval as specified by applicable regulation.

Guidance Indicator 3.1.1

The landowner or designated representative should ask his or her qualified natural resource professional or check with the state agency responsible for forestry assistance to find out if there is a reforestation law in place, and if so, to ensure compliance with it.

Federal and state reforestation programs may provide guidance regarding adequate stocking levels that landowners may utilize as a reference to support management.  However, certain wildlife habitat management regimes may favor lower stocking rates than the cost‐share program or silvicultural guidelines do.  Therefore, it is important to make sure the chosen guidelines fit the forest conditions and are consistent with landowner objectives.

Natural regeneration stocking assessments should account for both softwood and hardwood regeneration and should take place within the normally accepted time frame for local conditions. For reforestation and afforestation, use of native species and local provenances that are well‐ adapted to site conditions is preferred, where appropriate. If nonnative species are selected, landowner should consult or seek guidance from qualified natural resource professionals, such as agencies, academic institutions or professional associations, to ensure that potential negative impacts on the ecosystem and on the genetic integrity of native species and local provenances have been evaluated, and to determine whether negative impacts can be avoided or minimized.

Standard 4 with Guidance

Refer to the current standards here:

Visit TreeFarmSystem.org for more information.

Standard 4: Air, Water and Soil Protection

Forest management practices maintain or enhance the environment and ecosystems, including air, water, soil and site quality.

Performance Measure 4.1

Landowner shall meet or exceed practices prescribed by state forestry best management practices (BMPs) that are applicable to the property.

Guidance Performance Measure 4.1

Compliance with all state forestry BMPs that apply to air, water, soil and site quality elements are required on all ATFS certified properties, even if voluntary in the state of practice. Landowners and designated representatives are urged to secure a copy of the state forestry BMP guide from their state forestry agency and to familiarize themselves with the guidelines in it for harvesting, road building, reforestation, habitat management and other forest activities.  For many states, this information is available free online and in printed format.  

 For states with forest practice acts, the statutes, administrative rules and guidance for the acts is considered the equivalent of BMPs. Where the Standards note state forestry BMP, the inspector or third‐party assessor should reference the forest practice act in states where present.

Indicator 4.1.1

Landowner shall implement specific state forestry BMPs that are applicable to the property.

Guidance Indicator 4.1.1

When planning management activities that will cause any soil disturbance or require chemical application, the BMP manual for the state in which the property is located should be consulted and applicable BMP methods employed.

Examples of activities requiring BMP application: 

·         Harvest planning – including block design, haul roads, skidder trails, stream crossings and truck‐loading areas

·         Reforestation design – mechanical or chemical site preparation, machine or hand planting

·         Construction of new roads and maintenance of existing roads

·         Prescribed burning plans – fire lane construction, smoke management, agency notification 

No field evidence of BMP implementation is expected where no management activity has occurred.  However, if the property shows evidence of water quality impairment originating on the property that is not caused by the landowner’s or designated representative’s actions, the landowner is strongly encouraged to have plans for remediation.

Examples:

·         Landowner purchases a tract with a forest road that is eroding soil into a water body.

·         ATV riders are trespassing on the property and are crossing a stream causing the banks to erode.

·         Garbage is being dumped on the property near a stream crossing and some of it is getting into the stream during high‐water conditions.

·         Storm damage has impaired the performance of road culverts.

Some BMPs, such as those that are guidelines to enhance a desired species, should only apply where relevant to the property.

Indicator 4.1.2

Landowner shall minimize road construction and other disturbances within riparian zones and wetlands.

Guidance Indicator 4.1.2

Activities in riparian zones and wetlands shall comply with applicable BMPs. BMP manuals are generally quite detailed on recommended practices for road construction and other disturbances of riparian zones.  If there is a point of confusion, the landowner or designated representative is advised to consult with a qualified natural resource professional who is experienced in forest road design and installation. In some states, permits may be required for forest roads or other disturbances that intersect a riparian zone. Landowners should specify with qualified contractors that BMPs must be adhered to.  In all cases, the primary concern is to avoid contaminating watercourses that are adjacent to the forest activity.

Performance Measure 4.2

Landowner shall consider a range of forest management activities to control pests, pathogens and unwanted vegetation.  

Indicator 4.2.1

Landowner should evaluate alternatives to pesticides for the prevention or control of pests, pathogens and unwanted vegetation to achieve specific management objectives.

Guidance Indicator 4.2.1

Landowners or designated representatives should consult with their state forestry agency or qualified natural resource professional to learn about the range of recommended management techniques for any particular disease, invasive species or pest outbreak on their property. Links to these resources are available at the ATFS website.

Integrated pest management (IPM) is an excellent approach to controlling, suppressing or preventing pests and can take many forms. Preventative measures, efforts to improve forest health or, in some other way, protect the property from injurious organisms are often the most practical and effective approaches. Pesticide applications may be used when other control measures are ineffective or impractical.

While landowners and designated representatives are urged to take feasible actions to address pests, pathogens and unwanted vegetation, third-party assessors are advised that, in some cases, there may be no feasible options for controlling a pest or outbreak due to severity, scale and timing of onset. 

Indicator 4.2.2

Pesticides used shall be approved by the Environmental Protection Agency (EPA) and applied, stored and disposed of in accordance with EPA-approved labels and by persons appropriately trained, licensed and supervised.

Guidance Indicator 4.2.2

The Environmental Protection Agency (EPA) approves the use of pesticides for specific situations and on specific plants or animals, at specified application rates.  The landowner is responsible for ensuring that the planned use of a pesticide is in compliance with the EPA label requirements.

 Please consult the ATFS resource page for links to the EPA and other relevant resources for additional information on EPA-approved pesticides. 

In most states, forestry chemicals must be applied by a licensed applicator.  The landowner is responsible for ensuring that anyone applying forestry use chemicals is in compliance with state and federal regulations.  In some states, landowners or designated representatives can apply certain pesticides on their land without any special permits or licenses. In others, they can apply for and receive a license or permit to apply forestry chemicals on their own lands according to the EPA label limitations. In any event, the requirements for safe use, storage and disposal must be met by landowners. 

Performance Measure 4.3

When used, prescribed fire shall conform with landowner’s objectives and pre-fire planning.
Guidance Performance Measure 4.3

In many states, the state forestry agency employs a permit system for prescribed burning.  Many of these agencies provide training for prescribed burning that is available to landowners and designated representatives.  Successful completion of a prescribed burning course is often required before the state forestry agency will issue a burning permit.  Many states regulate the amount of open burning that can be conducted on a given day in a county or multi-county zone.

 

Prescribed burning includes controlled burning of piles, windrows and broadcast fire applications.  

 

A prescribed burning plan is recommended, which will include reconnaissance of the burning block, estimates of fuel condition, required weather conditions and adequate means of controlling the fire after it is set.  Oral discussion of a burning plan with all of the parties involved, before the burn is started on the property, is acceptable. A written burning plan record is not required by the Standards but may be required by the state agency that regulates open burning in the state.

 

Qualified ATFS inspectors and third-party assessors may verify compliance through interviews with landowners or designated representatives and observing the property.  The landowner or designated representatives may have written records to support conformance claims, but is not required to do so.

Indicator 4.3.1
Prescribed fire shall conform with the landowner’s objectives and state and local laws and regulations.
Guidance Indicator 4.3.1

The landowner’s plans and good-faith actions in using prescribed fire should conform to the management objectives and the relevant laws and regulations.

 Even the best-laid plans may go awry.  Qualified Tree Farm inspectors or assessors are advised to look for a pattern of responsible use of prescribed fire where it is used. 

Standard 5 with Guidance

Refer to the current standards here:

Visit TreeFarmSystem.org for more information.

Standard 5: Fish, Wildlife, Biodiversity and Forest Health

Forest management activities contribute to the conservation of biodiversity.

Performance Measure 5.1

Forest management activities shall protect habitats and communities occupied by threatened or endangered species as required by law.

Guidance Performance Measure 5.1

Under the Endangered Species Act (ESA), landowners are required to protect occupied habitat for threatened or endangered animal species. If landowners or designated representatives become aware of the presence of a threatened or endangered animal species on their property, it is their duty to review the requirements for protecting the habitat for that species and to take appropriate actions in the management of their property. Under ATFS certification, landowners may choose to go above and beyond ESA requirements and protect unoccupied animal habitat.

Although private landowners are not required to protect threatened or endangered plant species under the ESA, landowners are encouraged to do so.   Activities implemented under a federally approved habitat conservation plan (HCP) are deemed in conformance with the ATFS Standard. In addition to ESA requirements, states maintain their own lists of protected species and legal requirements for protection by landowners.

Indicator 5.1.1

Landowner shall confer with natural resource agencies, state natural resource heritage programs, qualified natural resource professionals or review other sources of information to determine occurrences of threatened or endangered species on the property and their habitat requirements.

Guidance Indicator 5.1.1

Although landowners are not required to do an exhaustive search for threatened or endangered species on their property, under the AFF Standards, landowners or designated representatives are expected to make a good-faith effort to identify any known occurrences of these species on their property through on-site review and the use of a qualified natural resource professional or natural heritage databases. Consultation with appropriate resources is demonstrated in management plan documentation.

 Threatened or endangered species lists are maintained by the U.S. Fish and Wildlife Service in accordance with the ESA [http://ecos.fws.gov/tess_public/ ].Nationally listed threatened or endangered freshwater fish that migrate to sea are listed by the National Oceanic and Atmospheric Administration’s National Marine Fisheries Service (NMFS) [http://www.nmfs.noaa.gov/pr/species/esa/]. Contacting the state natural resources agency or service representative is usually an effective way to find out if a property or region is known to contain a threatened or endangered species.

 Some threatened or endangered species are also listed separately by the state agencies. Please consult the ATFS website for additional resources on threatened or endangered species.

Indicator 5.1.2

Forest management activities shall incorporate measures to protect identified threatened or endangered species on the property.

Guidance Indicator 5.1.2

If there are known occurrences of threatened or endangered species on the property, the landowner may be required to make provisions for their protection as specified by regulation. Landowners or designated representatives are encouraged to consult with a qualified natural resource professional for assistance in planning to protect threatened or endangered species. The presence of threatened or endangered species on the property is not considered a prohibition of management but may influence the timing or technique of management activities. 

Measures for habitat protections may include:

·         limited mechanical entry in the habitat area  

·         restricted pesticide use in the habitat area

·         residual tree maintenance in the habitat area

·         buffer zone establishment and maintenance around the habitat area

·         hunting or fishing limitations

·         signage or marking of the habitat area

Performance Measure 5.2

Landowner should address the desired species and/or desired forest communities when conducting forest management activities, if consistent with landowner’s objectives.

Guidance Performance Measure 5.2
Landowners may wish to increase the presence of one or more desired species (fish, wildlife or plants) on their property such as bobwhite quail, longleaf pine or wild berry species.  While these goals may be described in the landowner’s objectives, the body of the management plan should provide a description of management activities planned to achieve the stated objective(s). Desired species management is only relevant if identified as an objective by the landowner.

Indicator 5.2.1

Landowner should consult available and accessible information on management of the forest for desired species and/or forest communities and integrate it into forest management.

Guidance Indicator 5.2.1

Several good sources for desired species management are readily available to the landowner:

·         Nonprofit organizations that focus on the desired species 

·         State and federal agencies that focus on fish and game species 

·         Extension Service publications

Performance Measure 5.3

Landowner should make practical efforts to promote forest health.

Indicator 5.3.1

Landowner should make practical efforts to promote forest health, including prevention, control or response to disturbances such as wildland fire, invasive species and other pests, pathogens or unwanted vegetation, to achieve specific management objectives.

Guidance Indicator 5.3.1

New, previously unknown or under-recognized pests, pathogens and invasive species are, unfortunately, emerging as serious and immediate threats to forest health. Outbreaks and impacts may be sudden, widespread and profound. Given this and a landowner’s deployable resources, he or she may have limited ability to prevent, respond or control the impacts of a disturbance.

 Landowners or designated representatives are advised to take a practical, proactive approach to promoting the resilience, productivity and vitality of their forests. Landowners or designated representatives are encouraged to work with their qualified natural resource professional to understand and identify the range of stressors in which their woodlands may be vulnerable and consider measures to promote the resilience and reduce the susceptibility of their properties. 

 Qualified natural resource professionals can supply the landowner or designated representative with information on emerging forest health issues and techniques for preventing, mitigating the impacts of and responding to stressors and events. Landowners are encouraged to take advantage of opportunities to learn about forest health issues and approaches for preventing and responding to stressors and promoting resilience.

 On monitoring visits to the property, landowners or designated representatives should be alert to potential impacts to forest health.

 Qualified ATFS inspectors and third-party assessors may verify compliance through interviews with landowner or designated representative, review of management plan documents or observing the property.  

Performance Measure 5.4

Where present, forest management activities should maintain or enhance forests of recognized importance.

Guidance Performance Measure 5.4

Forests of recognized importance (FORI) represent globally, regionally and nationally significant large landscape areas of exceptional ecological, social, cultural or biological values. These forests are evaluated at the landscape level, rather than the stand level and are recognized for a combination of unique values, rather than a single attribute. FORIs may include but are not limited to landscapes with exceptionally high concentrations of one or more of the following:

·         protected, rare, sensitive or representative forest ecosystems such as riparian areas and wetland biotopes

·         areas containing endemic species and critical habitats of multiple threatened or endangered plant and animal species, as identified under the Endangered Species Act (ESA) or other recognized listings

·         recognized large‐scale cultural or archeological sites including sites of human habitation, cities, burial grounds and in situ artifacts

·         areas containing identified and protected water resources upon which large metropolitan populations are dependent

·         areas containing identified unique or geologic features including geysers, waterfalls, lava beds, caves or craters

 In the United States, because of their significance, FORIs have, generally, been identified and protected by federal or state governments or are under conservation easement by an environmental nonprofit organization. There is, at this time, no state or federal agency that regulates FORIs on private forest lands in the United States. Several conservation organizations have identified areas that they believe are of exceptional status yet there remains no single central clearinghouse of information regarding such forested landscapes.

Due to the small scale and low‐intensity of family forest operations, informal assessment for the occurrence of FORIs through consultation with experts or review of available and accessible information is appropriate. 

Consideration of FORIs is relatively new to forestry practice and planning in the United States. As such, adoption of the model has been uneven and a range of terms has been deployed in the identification, protection and management for enhancement of FORIs.  Landowners or qualified natural resource professionals may use terms such as “high conservation value forests” or “forests of exceptional value” or other terms to describe this concept, which are considered acceptable in fulfilling this Standard. Qualified ATFS inspectors and third‐party assessors are advised to recognize this diversity of terms and the intent in verifying conformance.

Indicator 5.4.1

Appropriate to the scale and intensity of the situation, forest management activities should incorporate measures to contribute to the conservation of identified forests of recognized importance.

Guidance Indicator 5.4.1

Landowners or designated representatives who have identified some or all of their forest property as part of a FORI should delineate the area on the maps associated with the management plan. Management activities on or adjacent to an identified FORI should seek to contribute to or support the values that led to the designation of the area. 

For family landowners, a more likely scenario is that their property is adjacent to a state or federally protected area and identified as a FORI at a landscape scale.  Landowners should consider the impact to a neighboring FORI and opportunities to support consideration of specific values or attributes when planning and implementing activities on their forest property. Given the size and scale of family ownerships eligible for ATFS certification, landowners may be limited in their abilities to significantly impact FORI presence and quality through management at the small scale.

Standard 6 with Guidance

Refer to the current standards here:

Visit TreeFarmSystem.org for more information.

Standard 6: Forest Aesthetics

Forest management activities recognize the value of forest aesthetics.

Performance Measure 6.1

Landowner should manage the visual impacts of forest management activities consistent with the size of the forest, the scale and intensity of forest management activities and the location of the property.  

Indicator 6.1.1

Forest management activities should apply visual quality measures compatible with appropriate silvicultural practices.

Guidance Indicator 6.1.1

Forest aesthetics considerations can be incorporated into management planning with little cost to the landowner.  Employing forest aesthetics considerations into the management plan can produce a much more visually appealing experience on property visits for owners, their guests and passers‐by using nearby public roads.

Many state agencies have guidelines for forest aesthetics that landowners, designated representatives and qualified natural resource professionals can use to inform their management.

Examples of visual quality measures include:

·         Place log‐truck‐loading zones out of public view

·         Put a bend in the entrance road to block view of tract interior

·         Follow contour lines and timber type margins with roads and harvest boundaries

·         Close and revegetate idle roads with wildlife‐friendly plants

Standard 7 with Guidance

Refer to the current standards here:

Visit TreeFarmSystem.org for more information.

Standard 7: Protect Special Sites

Special sites are managed in ways that recognize their unique historical, archeological, cultural, geological, biological or ecological characteristics.

Performance Measure 7.1

Forest management activities shall consider and maintain any special sites relevant on the property.

Indicator 7.1.1

Landowner shall make a reasonable effort to locate and protect special sites appropriate for the size of the forest and the scale and intensity of forest management activities.

Guidance Indicator 7.1.1

Special sites are diverse and can be identified through consultation and consideration processes described below and during property reconnaissance prior to preparing the management plan. Sites of historical, archeological and cultural importance are identified on the National Register of Historic Places, a listing administered by the National Park Service or by State Historic Preservation Offices (SHPOs), state agencies that oversee the preservation efforts in their state. Listing of sites on the National Register (http://www.nps.gov/nr/index.htm) or SHPO directories (http://www.nps.gov/nr/shpolist.htm) reflect a determination of a site’s significance to the history of

a community, state or the nation. AFF recognizes this determination of significance and requires protections of such sites under certification, as directed by law. 

Federal law does not require protections of sites listed on the National Historic Register so long as there are no federal monies attached to the property. However, there may be state or local preservation laws in place. Many SHPOs maintain web‐based directories of their listings for reference by landowners and designated representatives. Landowners and designated representatives may wish to contact local historical societies and museums for additional information on sites of local significance and any preservation laws applying to them. It is important to note that history agencies vary widely in their staffing and capacities for consultation with landowners or designated representatives. 

Many properties may include historical, cultural or archeological sites that are not listed in National Historic Register or SHPO listings. Landowners may choose to designate sites not listed by relevant authorities as special sites. To do so, landowners and designated representatives should evaluate sites for congruence with all of the following criteria:

·         Significance: Sites may be significant if (A.) associated with events that have made a significant contribution to the broad patterns of our history; or (B.) associated with the lives of significant persons of the past; or (C.) they embody distinctive characteristics of a type, period or method of construction, or represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction; or (D.) they yielded or may be likely to yield information important in history or prehistory. 

·         Age: At least 50 years old. 

·         Integrity:  The site must retain its historical physical integrity with its character‐defining features still present. A building, structure or landscape feature must be relatively unchanged.  An archaeological site must be relatively undisturbed, with its patterns and layers of artifacts and other archaeological evidence relatively intact.  A traditional cultural site must be recognizable to today's affiliated cultural group, evidenced through tradition and still used or revered in some way. In addition to these criteria, landowners may designate sites of personal significance to them, such as a spot their grandparents cherished. 

Special sites of biological and geological significance may be identified through consultation undertaken related to the identification of FORIs and threatened or endangered species and communities (Standard 5).

 

Landowners or designated representatives shall identify special sites on management plan maps and, where appropriate, on the ground.  However, some landowners may choose not to identify some special sites on a map or on the ground in an effort to protect these sites from vandalism or overuse.

 

Landowners or designated representatives shall make efforts to protect any known special sites especially during forest management activities. These efforts may include creating a vegetation buffer, fencing the area or otherwise distinguishing it from surrounding areas. Because special sites are often in the ground, measures may be taken to control erosion and limit soil disturbance. Landowners and designated representatives are advised to review their special sites map and protection plan with qualified natural resource professionals and qualified contractors assisting in forest management activities. After harvests, landowners and designated representatives are encouraged to follow up to ensure adequate protection.

 

Additional information and guidance about special sites are available at the ATFS website at https://www.treefarmsystem.org/special-sites.

 

Examples:

American Indian burial sites, historical building ruins, cemeteries, cave entrances, spring heads, vernal pools, rare mineral outcroppings, Civil War battle grounds, a champion tree, a bear’s den, a pitcher plant bog, a covered bridge, glades, moraines or fish spawning grounds.

 Qualified ATFS inspectors and third-party assessors may verify for conformance by interviewing the landowner or qualified natural resource professional for awareness, reviewing planning documents and associated operating records and/or by observing the property.

Standard 8 with Guidance

Refer to the current standards here:

Visit TreeFarmSystem.org for more information.

Standard 8: Forest Product Harvests and Other Activities

Forest product harvests and other management activities are conducted in accordance with the landowner’s objectives and consider other forest values.

Performance Measure 8.1

Landowner should use qualified natural resource professionals and qualified contractors when contracting for services.

Indicator 8.1.1

Landowner should seek qualified natural resource professionals and qualified contractors

Guidance Indicator 8.1.1

The services of qualified natural resource professionals and qualified contactors can prove very cost-effective for landowners. 

 Many states have registration or licensing systems for foresters and wildlife managers.  The people listed by these systems have passed rigorous qualification exams and are required to regularly obtain continuing education.

 State forestry and wildlife agencies often can provide referral lists of qualified natural resource professionals who are working in the state or county.

 The Society of American Foresters has a Certified Forester program

http://www.safnet.org/certifiedforester/index.cfm


 The Wildlife Society has a Certified Wildlife Biologist program

www.wildlife.org/certification/index.cfm


 The Association of Consulting Foresters is a national association of forestry consultants:

http://www.acf-foresters.org

 

The American Forest Foundation’s www.mylandplan.org has a forester directory.  

 

A qualified natural resource professional often will be familiar with the qualified contractors who are doing forestry-related work in the area and can make recommendations. 

 Please consult the resource pages for landowners on the ATFS website, for help in finding qualified contractors who are trained in BMP and regulatory compliance, as well as assistance in finding qualified natural resource professionals.

Indicator 8.1.2

Landowner should engage qualified contractors who carry appropriate insurance and comply with appropriate federal, state and local safety and fair labor rules, regulations and standard practices

[1].


[1] Auditors shall consider any complaints alleging violation of fair labor rules filed by workers or organized labor since the previous third-party certification audit. The auditor shall not take action on any labor issues pending in a formal grievance process or before federal, state or local agencies or the courts, however, until those processes are completed. Absent a record of documented complaints or noncompliances, contractors and managers are assumed to be in compliance with this indicator. 

 

Guidance Indicator 8.1.2

 Landowners and designated representatives are encouraged to stipulate that contractors must be in compliance with all relevant laws and regulations.  A qualified natural resource professional can help with this process.

Landowners are encouraged to discuss liability issues with their insurance agent and their attorney to gain a perspective on appropriate insurance minimums that they might require of contractors.

Indicator 8.1.3

Landowners should retain appropriate contracts or records for forest product harvests and other management activities to demonstrate conformance to the Standards.

Guidance Indicator 8.1.3

Landowners or designated representatives should review the Standards before planning management activities.  When contracting for forestry activities, landowners or designated representatives should specify that appropriate state forestry BMPs must be adhered to. 

Other contract specifications might include:

  • Protection of special sites or habitats
  • Adherence to labor laws
  • Requirements for adequate insurance
  • Protection of soil and water integrity
  • Residual tree damage
  • Forest road maintenance and restoration
  • Fence and gate protection and/or restoration
  • Litter control
  • Hazardous material spill prevention and clean-up

Examples of forestry activities requiring review for AFF Standards compliance:

  • Harvest operations including timber and nontimber products
  • Site preparation and reforestation
  • Forest road construction and maintenance
  • Mineral extraction
  • Hunting and fishing
  • Invasive species control
  • Pest management

As a general rule, landowners are encouraged to retain contracts or records for management activities for three years. 

Performance Measure 8.2 

Landowner shall monitor forest product harvests and other management activities to ensure they conform to their objectives.

Indicator 8.2.1

Harvest, utilization, removal and other management activities shall be conducted in compliance with the landowner’s objectives and to maintain the potential of the property to produce forest products and other benefits sustainably

Guidance Indicator 8.2.1

The landowners may monitor harvesting and other activities personally or they may employ someone else to do it for them.  Many landowners engage a qualified natural resource professional for this function.

 If the landowner’s objectives do not specify directives as to harvest, utilization and removals, regional norms and accepted practices are expected. 

 The intent of Performance measure 8.2 is to ensure the maintenance of “the potential of the property to produce forest products and other benefits sustainably.”  Good planning, utilizing qualified natural resource professionals, engaging competent qualified contractors and using an effective contract go a long way toward this end.

Key consideration for Independently Managed Groups (IMG) Standards 

As the ATFS Standards undergo review, we have the opportunity to explore options for greater efficiency and reduced costs of group certification.  Similarly, PEFC has introduced new elements into group certification including formalized group management systems and plans. Per PEFC the definitions for these terms are as follows:

Group management plan- Documented information specifying objectives, action, and control arrangements It covers planned changes of the group management system and requirements of the sustainable forest management standard which are covered on group level.

 

Group management system- Set of interrelated or interacting elements of an organization to achieve the objectives and outcomes of the sustainable forest management standard. 

 ATFS Independently Managed Group (IMG) Certification  Standards

The American Tree Farm System ® (ATFS) Independently Managed Group (IMG) Certification  Standards (2015-2020) contain the requirements for the implementation by, and independent  ertification of, group organizations that manage a number of group member properties under one centrally administered program. The Group Organization holds the single certificate on behalf of the Group Members. This process is referred to throughout as “group certification.”

 Generally, the Group Organization administers the overall functions of the group and

coordinates certain activities, such as:

  • ensuring conformance to the AFF Standards of Sustainability,

  • administering entry and departure of members,

  • maintaining records and reporting,

  • conducting ongoing monitoring,

  • managing the group certification process.

 

Reference Documents

The 2015-2020 version of the ATFS IMG Certification Standards There are a number of other ATFS standards, policies and guidelines that should be followed to effectively achieve independent certification and conform to overall ATFS requirements. Those standards, policies and guidelines include:

·         AFF 2015-2020 Standards of Sustainability for Forest Certification and Guidance

·         ATFS Eligibility Requirements

·         ATFS Logo Use Guidelines

·         ATFS Signage Use Guidelines

·         ATFS Group Certification Reporting and Invoicing

·         AFF Disputes and Appeals Procedures

 

ATFS has identified three categories of Group Members for purposes of completing annual reporting and submission of annual fees to ATFS. Group organizations seeking certification

through the ATFS IMG program must categorize Group Members into one of three categories

listed below.

The designation of the three categories of Group Members is for the exclusive purpose of ATFS

annual reporting and fees. Reporting forms are released to Group Organizations at the

beginning of each reporting year and will detail the reporting requirements for each category.

The three types of Group Members are:

·         Category 1 Group Members retain final decision-making authority for management

activities to be conducted on their property. This category may include individuals, family ownerships, LLCs and other similar entities. The Group Member may, through contract or other agreements, utilize the Group Organization’s services for some or all management

activities. Group Members may also participate in group management plans where

management decisions and responsibilities are shared between the Group Organization and

the Group Members.

·         Category 2 Group Members have knowingly and affirmatively delegated full management

responsibility for implementation of the AFF Standards to the Group Manager. Category 2

properties are under aggregated ownership as part of an investment fund portfolio. The

Group Organization as the management consultant assumes overall operational

management responsibility and performs all of the functions required for conformance to

the AFF Standards. This category may include properties that meet the ATFS eligibility

requirements and are managed by a Timber Investment Management Organization (TIMO).

Category 2 Group Members include those entities referred to as Aggregated Management

Groups (AMGs) in the ATFS Eligibility Requirements and Guidance.

·         Category 3 Group Members are government entities. The property owner may have

knowingly and affirmatively delegated full or partial authority for management and

decision-making to the Group Manager, or the owner may retain all management

authority. The Group Organization may perform some, or all, of the functions required for

conformance to the AFF Standards. Examples of Category 3 members are: a local

municipality, a public grade-school, a public university, a publicly owned watershed

authority, a tribal government, a state or federal agency.

Section 1. Group Organization Administration

1.1 Legal and General Requirements

a. The Group Organization must be a legal entity competent to sign agreements with

Group Members and to enter into binding contracts with certification bodies and

other outside entities.

b. The Group Organization must identify Group Members’ category.

I. The Group Organization must document the group member category (see

above section on Group Member types).

II. The Group Organization must describe roles and responsibilities of the Group

Manager and Group Members with respect to forest management decisions

and actions with respect to the implementation of the AFF Standards (e.g.

plan development, harvesting, monitoring, etc.).

III. The Group Organization must have a written commitment to sustainable

forestry and conformance to the AFF Standards.

IV. The Group Organization must ensure Group Members have a written

commitment to sustainable forestry and conformance to the AFF Standards

of Sustainability.

1.2 Roles and Responsibilities

a. The Group Organization must adhere to ATFS eligibility requirements and may

further define membership parameters for its Group, if desired.

b. The Group Organization must designate a Group Manager(s) who is responsible for

overseeing all of the administrative details of ATFS Group Certification and for

ensuring compliance with all applicable requirements.

1.3 Group Membership

a. The Group Organization must inform Group Members of any and all fees associated

with administration of the Group, if any, when they join the Group Organization.

b. The Group Organization must hold the ATFS Certificate on behalf of the Group

Members.

c. The Group Organization must follow the ATFS logo use guidelines and ensure proper use of promotional claims about the Group Certification.

d. The Group Organization must issue a document to each Group Member that

confirms the Group Member participation and coverage by the scope of the third-party certificate.

1.4 Group Member Entry and Departure

a. The Group Organization must ensure that Group Members are notified that they are subject to all of the requirements and privileges of membership in the American

Tree Farm System®. Under this requirement, category 1 Group Members must be

notified to the individual landowner level and category 2 Group Members must be

notified to the portfolio level.

a. The Group Organization must define and administer a procedure for admitting

Group Members.

b. The Group Organization must maintain a procedure for expelling Group Members if

they do not meet the requirements of the AFF Standards, and are not willing or able

to take appropriate corrective action.

c. The Group Organization must maintain and update the membership list and ATFS

database to reflect entries and departures of Group Members from the Group

Organization.

1.5 Dispute Resolution

a. The Group Organization must have a procedure for addressing and resolving

disputes regarding conformance with the AFF Standards between and among the

Group Members and the Group Organization pertaining to Tree Farm certification.

b. The Group Organization must follow and conform to the AFF Dispute Resolution

Policy and assist ATFS in resolving any such complaints.

1.6 Maintaining Records of Group Members

a. The Group Organization must maintain internal Group Member records and provide

updated information on a regular basis to the ATFS database.

Section 2. Requirements of Participation in the American Tree Farm System®

 2.1 Access to the AFF Standards

a. The Group Organization must make the AFF Standards of Sustainability for Forest

Certification accessible to Group Members.

2.2 Conformance with AFF Standards

a. The Group Organization must have a procedure for evaluating conformance with

AFF Standards prior to property enrollment under the group certificate.

b. Management Plan:

The Group Organization must ensure that each Group Member either has an

individual management plan or is covered by a larger group management plan where

responsibility for management has been delegated to a Category 2 with a qualified

natural resource professional.

2.3 Eligibility

a. The Group Organization must have a procedure for evaluating eligibility according to the ATFS Eligibility Requirements prior to property enrollment under the group certificate

Section 3. Internal Monitoring and Reporting

3.1 Ongoing Monitoring

a. The Group Organization must establish and maintain a procedure and schedule for

conducting ongoing monitoring of conformance with AFF Standards.

b. IMG inspectors of the Group Organization conducting internal monitoring must have

completed the current ATFS Tree Farm Inspector training course.

c. The Group Organization must review conformance to the AFF Standards and

document the relevant findings.

d. Where a non-conformance is identified during ongoing monitoring, the Group

Organization must document the non-conformity and work with the Group Member

and other appropriate parties to take corrective action.

e. The Group Organization must ensure implementation of the corrective action and

monitor conformity as part of the regular schedule of internal monitoring.

3.2 Annual Reporting to the American Tree Farm System®

a. The Group Organization must adhere to the annual reporting requirements as

defined by ATFS and maintain copies of past annual reports.

Section 4. Independent Audit

4.1 Managing the Group Certification Process

a. The Group Organization must contract with an accredited certification body to

conduct the independent certification. The accredited certification body is required

to conduct the audit according to accreditation rule, #27 under ANSI American

National Accreditation Body or the Standards Council of Canada.

b. The Group Organization must coordinate the independent audit procedure to

ensure the Certification Body has access to sufficient information and Group

Member properties to determine conformance to the AFF Standards and ATFS

Group Certification Standard.

c. If the certification audit results in a nonconformity, the Group Organization must

work with all appropriate parties to take corrective action and ensure timely

implementation.

d. The Group Organization must submit a copy of the ATFS Certificate and a summary

of the audit report that is appropriate for public distribution to ATFS.

e. The Group Organization must keep the Group Organization’s program up-to-date

and in ongoing conformance with the AFF Standards.

Thank you