Titan Group: Greenpeace statements about Russia are destructive for the entire FSC system
February 22, 2018 Greenpeace published inaccurate information regarding certification of LLC “Karpogoryles”, a member of Titan Group. In its turn, Titan Group would like to report on the true situation subject matter. The Holding’s logging companies have been participants of the FSC voluntary certification system since 2005. Titan has a FSC certificate (NC-ÑoC-014137, NC-CW-014137). LLC “Karpogoryles” has a FSC certificate (NC-FM/CoC 014140). For the entire period of these certificates possession, the aforementioned companies have always abided by the principles of sustainable forest management and observance of the Standard environmental, social and economic requirements in their activity, and also passed annual audits with FSC auditing companies. Meeting requirements of the FSC forest certification and compliance with the Standard stipulates preservation of high conservation value forests (HCVF), including conservation of the intact forest landscapes (IFL) in the lease/sublease base of the logging companies. LLC “Karpogoryles” still keeps to the moratorium agreement with involved parties according to conservation of HCVF 2, which include IFL.. This agreement is fully observed by LLC “Karpogoryles”. The territories defined in the agreement are referred to high conservation value forests of the company, marked in the HCVF register of the company and in the plans and maps of HCVF, which are publicly available for all the parties involved. The moratorium agreement for LLC “Karpogoryles” expires in April 2018. Neither prolongation nor revision of the agreement currently exists. However, effective from January 01 the MOTION 65 and Directive 20-007-018 V 1-0 came into force, which requirements to IFL conservation exceed the area values for HCVF 2 conservation in accordance with the presently active agreement. According to MOTION 65 implementation process, effective from January 01, 2018, the companies are supposed to provide conservation of not less than 80% IFL territory of the government unit (lease/sublease contract). All the logging companies of Titan Group have carried out additional work to define areas of intact forest landscapes for every lease/sublease contract. They have also allocated the 20% zone, where economic activity is possible and the 80% zone, where such activity is limited until the new national standard of the forest management to the FSC forest management system comes into force. The companies have defined absolute and relative values of IFL areas subject to conservation, which are indicated in the cartographical materials. Greenpeace, one of the involved parties, is an initiator to take the Motion 65 decision at the FSC general assembly. Therefore, Motion 65 explicit realization is a coordinated position of Greenpeace International and Greenpeace Russia. The logging companies still leasing/subleasing large landscapes of intact forests, effective from January 01, shall meet requirements of MOTION 65 and Directive 20-007-018 V 1-0, and LLC “Karpogoryles” certainly does it. In order to implement the priority investment project in 2014, JSC “APPM” received several leased areas as a source of pulpwood. These areas are adjacent to the borders of the projected reserve in the interfluve of the Northern Dvina and the Pinega. In Gorkovskiy district forestry of Vyiskoe forestry, Arkhangelsk region, the APPM/Titan specialists carried out demarcation of the forest area located within the boundaries of the projected reserve, and a request was made to exclude the given area from the forest quarters planned for sublease under the priority investment project of JSC “APPM”. Since then the forest lot in question about 70 thousand hectares has been listed as a reserve to create the forest reserve in the interfluve of the Northern Dvina and the Pinega. All the involved parties are aware that APPM refused to lease a part of the IFL area coinciding with the projected reserve “Verkhneyulovskiy”. The representative of Greenpeace Russia knew about the lessee’s and sub-lessee’s contribution to conservation of IFL in Vyiskoe forestry, it is confirmed by his signature on the protocol of the working meeting dated June 30, 2017. Another confirmation of the involved parties’ awareness about Titan Group logging companies activity in part of IFL represented on the space images of the forest landscapes under the sublease contract ¹ 1702 in Vyiskoe forestry, is the protocol of the working meeting dated December 21, 2016 (the protocol is publically available on the websites of LLC “PKP Titan” and JSC “APPM”). According to Item 4 of the working meeting protocol, Titan Group continues to work in the territories of IFL not included to the projected reserve and in the moratorium areas, in order to provide transition to a new model of forest management. Thus, LLC “Karpogoryles” and JSC “APPM” meet requirements of the criterion 9.3 to conserve the large forest landscapes minimally impacted by human economic activity and those at the stage of the lease contract signing. They carried out works to provide a status of a reserve to the largest part of IFL in Gorkovskiy district forestry to create a future forest reserve in the interfluve of the Northern Dvina and the Pinega. The economic activity of the company is performed according to Item 4 of the protocol dated December 21, 2016 and does not contradict the requirements of MOTION 65 and Directive 20-007-018 V 1-0 (i.e. it does not include more than 20% IFL actualized on January 31, 2017, according to the IFL allocation methods). The representatives of Greenpeace Russia often mistakenly classify the territory as an IFL category and every so often they include here the areas impacted by the human economic activity, the areas not corresponding to the methods and definitions of IFL allocation, which results in discrepancies with logging companies. We declare that the requirements of the indicator 9.2.3 at this time are strictly adhered by the certificate holder, LLC “Karpogoryles”, according to the moratorium agreement; and in respect of the sub-lease contract ¹ 1702 the statement is applicable, which is described in accordance with Item 4 of the working meeting protocol dated December 21, 2016 signed by Titan Group (LLC “Karpogoryles” being a member of the group), JSC “APPM”, CJSC “Sawmill 25” and international environmental organizations. The above-mentioned sources contain measures on conservation and management of HCVF. Besides, the requirements of MOTION 65 and Directive 20-007-018 V 1-0 explicitly define measures on IFL conservation and management. Titan Group logging companies meet and will meet these requirements until the moment Directive 20-007-018 expires. We would like to reiterate that creation of the regional reserve Verkhneyulovskiy is an exclusive competence of Arkhangelsk Region Government. Titan Group together with APPM already work on development and implementation of an intense model of forest usage and reproduction in the north-taiga forest region. Throughout 2017 we invited Greenpeace Russia to take part in the given work, however we were refused. February 01, 2018 on the websites of Titan Group and APPM we placed again our proposal to Greenpeace Russia to join the working group on development of Titan Group forest management Strategy till 2025 and in the long-term. But, unfortunately as in previous cases we received another article by the News Editor of the Forest Forum, Greenpeace Russia, about impossibility to issue a forest management certificate to one of the leading logging companies of Titan Group — LLC “Karpogoryles”. Mr. Yaroshenko’s statements about allegedly poorly managed forest economy are not credible because the forest economy in Arkhangelsk region in general, including the forest areas under Titan Group operating management, is run in full compliance with the Russian forestry legislation. We have fully carried out reforestation activities for all the previous years and the thinning operations in young forests. These forest operations are crucial to run the forest economy and reforestation. The state expertise conclusions in materials of the complex environmental examination of the Northern Dvina and the Pinega interfluve justifying the legal status of a regional importance landscape reserve to this territory, read: “Proposals and recommendations of the expert commission are compulsory conditions of the environmental management”. The proposals and recommendations of the export commission specify the necessity to carry out explanatory work among the local population and obtain consent from the lessees of the forest fund areas, which was not fully done. Only due to a responsible position of Titan Group and World Wildlife Fund (WWF) it became possible to agree on the borders of the projected EPNA in the interfluve of the Northern Dvina and the Pinega in the leased forest areas under the operative management of our logging companies. Unfortunately Greenpeace Russia has withdrawn itself from this difficult work, which nevertheless produces certain results. Apparently, they consider for themselves a position of an outside, partly qualified critic of any actions by Titan Group and APPM as more appropriate, comfortable and irresponsible. Thus, Greenpeace Russia criticizes our actions concerning the normal forest economy and forest management in the leased forest areas based on the Russian forest legislation forestry, as well as our actions on implementation of modern forest management methods. We think that the information published at the Forest Forum of Greenpeace Russia is destructive for the entire system of Forest Stewardship Council (FSC) and will not lead to the expected effect on HCVF conservation.