Perhaps we start our analyses by first stating the obvious: Indian Nations are truly unique forestland owners. They differ from their forestland owner counterparts in fundamental ways:

• Public forestland owners work within strong legal frameworks to manage their forests for the general public interest and use. The people and communities that public forestlands serve are external in nature: they do not live within the forest, they may only infrequently visit the forest, and many may even feel disenfranchised from the forest that surrounds them (as is evident with current wildcrafting practices where transient domestic and international populations may be the largest recipients of non-timber forest product offerings such as foods, florals, botanicals, medicinals, decoratives, etc.).

• Public forestland owners work within strong legal frameworks to manage their forests for the general public interest and use. The people and communities that public forestlands serve are external in nature: they do not live within the forest, they may only infrequently visit the forest, and many may even feel senfranchised from the forest that surrounds them (as is evident with current wildcrafting practices where transient domestic and international populations may be the largest recipients of non-timber forest product offerings such as foods, florals, botanicals, medicinals, decoratives, etc.).

• Private forest landowners fall under yet a different category. Private industrial landowners do not serve a public at large, but rather answer to shareholders with land management priority often focused on maximizing return on investment. Private non-industrial forestland owners (NIPFs) are different from their industrial counterparts: they view income generation only on a sporadic basis; they do not typically live off the land; less than 10% have written management plans in place to help guide the management of the land;  almost 30% of them have owned their forestland for less than 30 years, and over 10% will sell or ransfer their forest land to other hands in the next five years.

• Indian Nations operate under different mandates as forestland owners. The people and communities that Indian forests serve are internal: tribes live with the consequences of management decisions that affect their forests everyday in countless ways; the forest has become an integral part of their physical and spiritual life; has been so for many generations and will remain so. And income generation is important, but is only one of many values associated with tribal forest ownership. With these differences as a backdrop, we undertake the task of evaluating the degree to which the Montreal C&Is reflect tribal forest health and sustainability views by asking four questions:

1) Have tribal nations recently participated in an independent evaluation of their forest management practices based on the application of established regional/national/international standards and criteria for forest health and sustainability?

2) If so, how did tribal nations collectively fare in the evaluation? Could their strengths and weaknesses evaluated against these criteria relate to their views regarding forest health and sustainability?

3) How relevant and important to tribal values were the criteria used in the independent evaluation?

4) How might the C&Is correlate to those criteria deemed by tribes to be relevant and important in representing their views concerning forest health and sustainability?

A Nationwide Pre-Assessment Evaluation

In July 2000, Washington DC-based Pinchot Institute for Conservation approached the Intertribal Timber Council (ITC) with a proposal to employ the Sustainable Forestry Initiative (SFI) and the Forest Stewardship Council (FSC) certification pre-assessments as part of the ndependent in-field audit component for the second independent assessment of the status of Indian forests and forestry required under the National Indian Forest Resource Management Act (NIFRMA). The project would also evaluate whether forest management practices of Indian nations might meet certification requirements, and would allow tribes a unique opportunity to evaluate the criteria used in the SFI and FSC systems with respect to relevance and importance to tribal forest health and sustainability values. Each tribe would be independently evaluated by both SFI and FSC auditors, and would receive separate pre-assessment reports. The pre-assessment reports

would also be submitted to the second Indian Forest Management Assessment Team (IFMAT-II) for use in completing its report to Congress and the Bureau of ndian Affairs (BIA). The proposal also included provisions for assisting interested Indian nations to pursue full certification assessments and a reverse assessment regarding the suitability of the selected certification system for Indian forestry. The request was approved by ITC and funding was secured from The Ford and Surdna Foundations to undertake the project reports. The pre-assessment reports would also be submitted to the second Indian Forest Management Assessment Team (IFMAT-II) for use in completing its report to Congress and the Bureau of Indian Affairs (BIA). The proposal also included provisions for  assisting interested Indian nations to pursue full certification assessments and a reverse assessment regarding the suitability of the selected certification system for Indian forestry. The request was approved by ITC and funding was secured from The Ford and Surdna Foundations to undertake the project in 2001. Thirty (30) Indian Nations dispersed throughout the US participated in the project effort representing over four million acres of working forests and over a half a billion board feet of annually-harvested wood resource (seein 2001. Thirty (30) Indian Nations dispersed throughout the US participated in the project effort representing over four million acres of working forests and over a half a billion board feet of annually-harvested wood resource (see Map below). ITC selected the team of Interforest and Arthur Anderson (Connecticut and Washington states, respectively) to undertake the SFI preassessment, and Scientific Certification
Systems (SCS) to undertake the FSC pre-assessment.

States and Participating Tribes

Participating Tribes: Choctaw, Fort Bidwell, Penobscot, Fond du Lac, Mescalero, Metlakatla, Spokane, Quinault, Flathead, Cherokee, Alabama-Coushatta, Round Valley, Red Lake, White Mountain, Southern Ute, Tanana Chiefs, Colville, Coeur d’ Alene, Grand Ronde, Northern Cheyenne, Chucachmiut, Tule River, White Earth, Blackfeet, Lummi, Siletz, Makah, Nez Perce, Leech Lake and Warm Springs.

The pre-assessments were conducted over a twelve-month period, with the following results:

• the FSC system placed maximum value on evaluation of field performance first, but allowed for continuous improvement via contract conditions that would mandate improvement (in documentation and/or field performance) within a short period of time. Both systems identified key areas where improvements in performance would be required in order to achieve certification consideration. With the FSC preassessments being based on more field evaluations (vs documents review by SFI auditors), it was interesting to note that over 50% of all tribes were found to be “above” certification standards in eleven key areas: pest pathogen management strategies; harvest/utilization in association with waste avoidance and product marketing; forest structure, a full range of seral stages and other vegetative species associated with natural forests in self-sustaining proportions within working forests; ecological productivity, the ability of the forest to sustain key biological components and ecological functions though time; fish/wildlife management, including habitat protection in association with timber management; watercourse management including tribal policies and programs for protecting bio-physical functions in rivers and streams impacted by harvestingand road building; pesticide use, specifically programs for protecting public health and biological diversity; community/public, specifically, how tribal timberlands contribute to economic and social well-being; public use management, facilitating other non and road building; pesticide use, specifically programs for protecting public health and biological diversity; community/public, specifically, how tribal timberlands contribute to economic and social well-being; public
use management, facilitating other non-timber uses of tribal timberlands and resolving conflicts where they occur; employee/contractor, the welfare of employees of timber management firms working on tribal lands; and legal compliance with all relevant laws, regulations, treaties and conventions.

The FSC auditors, however, also found that over 50% of all tribes were determined to be either “marginal” or “below” certification standards in seven key areas: harvest regulation, the regulation of harvest and forest structure, especially age-class and geographic distribution; stocking/growth, are timber stands in a well-stocked, productive condition; forest access, is there an adequate, well designed, well maintained road system; management planning/ information base, is there a solid, long term information base including environmental assessments and monitoring; ecosystem reserve, are ecologically significant areas identified, mapped and protected; financial stability in relation to compliance with relevant laws, regulations, treaties and conventions; investment capital and personnel, is the tribe investing in both infrastructure and people needed to sustain its forestry operation.

The second IFMAT report evaluated Indian forestry ten years after completion of the first independent assessment. Both IFMAT reviews found that per acre funding available for management of Indian forests is substantially below that provided for federal public land managers and private industry. Given fiscal limitations, we conjectured that those criteria that were met by the tribes might be deemed to be more relevant and important to tribal priorities on forest health and sustainability. But we also acknowledge that it may be incorrect to assume that criteria where tribes were marginal or fell below certification status were less important to them. The pre-assessment phase of this project did not address this question. However, the next project phase (full FSC assessment)specifically did.

The Next Step: A “Reverse Assessment” Phase

Of the 14 tribes that were well positioned to proceed with full FSC certification assessment, seven tribes chose to do so: Confederated Tribes of Warm Springs, Nez Perce Tribe, Red Lake Band of Chippewa Indians, Confederated Salish & Kootenai Tribes of the Flathead Reservation, Spokane Indian Reservation, Mescalero Apache Tribe, and the White Mountain Apache Tribe. The full assessments for the Warm Springs and White Mountain tribes were funded directly by the tribes, while assessments for the remaining five tribes were funded through the Pinchot Institute, and completed in 2003. While specific results of the full assessments
remain confidential to the tribes, the project incorporated a valuable ‘reverse assessment’ component that allowed the Institute to better understand the question of criteria relevance and importance to tribal views on forest assessment’ component that allowed the assessment’ component that allowed the
importance to tribal views on forest health and sustainability.

For this phase of the project, each tribe was asked to rank over 50 FSC certification criteria in several key areas. Along with comprehensiveness of standards, tribes also provided rankings on standards for measuring a) protection of biological resources; b) monitoring performance; c) socio-economic performance; d) continuous improvement; e) clear management objectives; and f) staff training and performance. Tribes were asked to rank a series of statements regarding importance and relevance of criteria to their tribal forest management objectives. The rankings ranged from one to five, with one designating criteria as irrelevant/unimportant to tribal views on forest health and sustainability; three designating criteria as only somewhat relevant/ important; and five designating criteria as extremely relevant/important. Averaged tribal rankings for all FSC criteria fell between 2.8 to 4.8. For this assessment, areas were determined to be
“highly relevant/important” if a combined tribal averaged ranking of 4.5 or greater was achieved. Areas designated as “relevant” received a combined tribal
averaged ranking of 3.8 to 4.4, and averaged rankings below 3.8 were designated “less relevant/important” to tribes. Summarizing, the reverse assessment results indicate the following (see Table 4, page 14):

1. Tribes appeared to value most those standards and criteria that dealt with protecting the rights of indigenous people, protecting areas of culturalsignificance,
protecting water quality, and maintaining a balance between social, ecological, and economic values.

2. Tribes appeared to assign less value to those criteria that focused on

The Final Step: Correlation to The Montreal Process Criteria and Indicators (C&I).

Lessons Learned – Is there a Match?

Before answering this question, it’s important to acknowledge the obvious limitations of this assessment. Two are most notable

•the small sample size of tribes that participated in the full FSC audits and reverse assessment results that became the comparative baseline to the Montreal Process C&I assessment. We do not know whether assessment results would remain relatively the same or change significantly with a larger Indian population sampling; and

•the generic nature of the C&Is that do not serve as operational criteria but are intentionally designed to guide the development of specific and operational criteria in individual settings. It is sustainability as achieved on individual Indian reservations.

There is tremendous diversity among Indian forests; both as to the biological character of the resource and to the dependence of tribal economies on the harvest and utilization of forest products, fish, water, and wildlife. At its core, the reluctance of tribal governments to accept and employ standards comprised of criteria and indicators that reflect values of external societies is a matter or policy. To attempt to measure sustainability of tribal forests in a judgmental way through the imposition of an inflexible universal yardstick represents a fundamental failure to respect the legitimacy of tribal prerogatives to use and manage their own resources according to their own values for the benefit of their own people. A useful reporting and assessment program for tribal forests should
have at its design core the separate ability to allow for the unique internal community features each Indian Nation must serve. Since the cultural values shaping tribal forest management are driven by the diverse ways in which forests affect tribal communities, tribes would likely be reluctant to embrace the imposition of externallydriven operational criteria as a basis for evaluating the effectiveness or appropriateness of their management practices. However, the “generic” nature of the C&Is noted above matched with an ability to weight the importance and relevance of individual criterion by individual tribes (as was done in this assessment) may prove a valuable protocol for establishing a minimum standards framework against which the adequacy of the forestry programs of the BIA in
fulfilling its trust responsibility to Indian tribes can be measured (NIFRMA mandate #7). Introducing this “importance and relevance” protocol to the C&I process may be useful in growing a stronger connective link between tribal forest health and sustainability values, and the BIA’s trust oversight responsibilities.

At the end of the day, it continues to be important to acknowledge the influence of a persistent lack of adequate funding for Indian forest management provided through Congressional appropriations. Indian forestry has long been forced to operate on a shoestring budget. In such an environment, activities are
closely scrutinized and competition for alternative uses of funds is fierce. In Indian country, the relevance and importance of several criteria and indicators employed by third party certification and the Montreal process, such as those related to production of paper documentation or monitoring and reporting to
satisfy administrative desires for data, will fare poorly when weighed against the needs to invest time and energy in activities that will improve conditions “on-the-ground.” These decisions can only be made at the local level where the unique character and significance of forests to individual tribal communities can
be taken into account along with potential impacts on already over-worked tribal staff who struggle daily to try to manage the forests with inadequate budgets.

Written by Catherine M. Mater
President, Mater Engineering, Ltd.
Senior Fellow – The Pinchot Institute for Conservation

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