BACKGROUND:

In recent years, forest certification has developed as a way to verify sustainable forest management. It is an outgrowth of the desire of many stakeholders here and throughout the world to have forest mangers demonstrate responsible, healthy, and sustainable management of our forests.

Forest Certification is:

• Review of on-the-ground forest practices against standards that address environmental, social and economic issues.
• Provision of an independent, third party view attesting how effectively current management maintains forest health and productivity.
• Periodic reverification and recertification after initial certification of the forest.

On May 28, 2004, Act No 125, Public Acts of 2004 was signed into law by Governor Granholm. The "Sustainable Forestry Act" requires that by January 1, 2006, the Department of Natural Resources shall seek and maintain forestry certification by at least one credible, non-profit, non-governmental certification program.

The Department of Natural Resources sought and attained dual certification of State Forest lands under the Sustainable Forestry Initiative (SFI) and the Forest Stewardship Council (FSC). The SFI program has its origins in the United States and is focused on applied forest management and on maintaining a high standard of forestry performance. The FSC program is an international system that emphasizes social values and the environmental value of natural forest ecosystems, to which it adds an important economic dimension.

Certification of our state forest system demonstrates to interested stakeholders and markets that natural resource management practices are sound and comprehensive. It maintains markets for state forest timber, and continues our ability to manage habitats for wildlife, recreation opportunities, and maintenance of forest health. Certification promotes long-term improvements in program efficiency, and empowers DNR staff at all levels to identify weaknesses and initiate positive change in the sustainable management of forest ecosystems.

ORGANIZATION:

The DNR Forest Certification Implementation Team (FCIT) leads the forest certification effort. Representatives from Forest, Mineral, and Fire Management Division (FMFM), Wildlife Division (WLD), and Fisheries Division (FSHD) currently serve on the team. A list of current team members can be found at: Forest Certification Implementation Team

The Forest Certification Implementation Team has lead the DNR through the entire forest certification process including:

• Pre-Assessment Meetings with DNR Staff
• Hiring of Auditing and Consulting Firms
• Conducting Forest Certification Scoping and Pre-assessment
• Developing an Action Plan
• Developing Forest Certification Work Instructions
• Training DNR Staff
• Conducting Internal Audits
• Organizing Annual Management Reviews
• Oversight of the SFI and FSC Forest Certification Audit
• Oversight of subsequent Surveillance Audits

FOREST CERTIFICATION PRE-ASSESSMENT MEETINGS WITH DNR STAFF:

In May and June of 2004, numerous pre-assessment meetings were conducted across the State to review forest certification standards with staff from Forest, Mineral and Fire Management, Wildlife, and Fisheries Divisions. The sessions provided background information on Forest Certification (FC), reviewed key indicators of the Sustainable Forestry Initiative and Forest Stewardship Council certification standards, and analyzed how the DNR can demonstrate and verify compliance with those standards. Sessions were held for each Forest Management Unit, the three Department Eco-Unit teams, and numerous Lansing staff.

In addition, a special meeting was held with the Forest, Mineral and Fire Management Division (FMFM), Wildlife Division (WLD) and Fisheries Division Management (FSHD) Teams. This joint management team meeting focused on how forest certification can help implement positive changes in our Department in an integrated and holistic manner.

FOREST CERTIFICATION CONSULTANT(S):

Requests for Proposals (RFP) were advertised in August, 2004 to solicit bids from qualified Forest Consultants to assist in the forest certification effort. The consultants were needed to:

• Conduct an FSC scoping to identify fatal flaws that may preclude certification, conduct an FSC certification audit in late 2005, and conduct subsequent surveillance audits.
• Conduct SFI assessment to identify major non-conformance issues, and conduct a SFI certification audit in late 2005, and conduct subsequent surveillance audits.
• Assist and guide the Department in the forest certification process, which includes training Department employees in preparation for certification audits.

Contracts were awarded in October, 2004. A contract for FSC scoping, SFI pre-assessment, and forest certification audits was awarded to NSF International Strategic Registrations (NSF-ISR) and its partner company Scientific Certification Systems (SCS). The contract for DNR forest certification consultant and trainer was awarded to BioForest Technologies Inc. and its Plum Line partner, Strategic Resource Systems.

SCOPING AND PRE-ASSESSMENT:

The FSC and SFI preliminary certification evaluation was conducted October 25 through October 29, 2004. The DNR agreed to a joint FSC Preliminary Assessment and SFI Scoping using a single three-person audit team and a coordinated auditing protocol. The review was conducted by a three-person audit team, including: SFI Lead Auditor Mr. Mike Ferrucci of NSF-ISR; FSC Lead Auditor Dr. Robert Hrubes of SCS; and Dr. Dave Capen, Team Member.

The scoping included field visits to nine forest management units; the Marquette, Roscommon, Newberry, and Gaylord Operations Service Centers (OSC); and the Lansing office.

The purpose of the preliminary evaluation was to provide an early and strategic insight in regard to DNR preparedness to achieve FSC and SFI endorsed certification. The preliminary evaluation constituted a "gap analysis" which served to identify aspects of our management programs that may be deficient or that may be an obstacle to achieving certification. A formal presentation of audit findings was made to DNR managers on December 16, 2004 at the Lansing office.

SCOPING AND PRE-ASSESSMENT RESULTS:

The auditors from NSF and SCS were very impressed with the breadth and scope of how we manage our state forests. As expected, however, a number of gaps were identified. Some significant efforts to filling identified gaps were required before proceeding to a full certification review in September, 2005.

The gaps identified by the scoping team generally fall into several broad categories:

• Planning Issues: Particularly a need for long-term, landscape-level planning and a focused, systematic method of assessing the social impacts of our management actions.
• Best Management Practices: Management of our transportation system is a significant concern, as is illegal ORV damage that is having resource degrading effects.
• Biodiversity Issues: Need to show what is being done in regard to protecting reference areas and high conservation value forests, and adopt and implement a biodiversity planning initiative.
• State Forest Monitoring: Need a cohesive and integrated forest monitoring framework, incorporation of the results of monitoring into management planning, and development of a system to report inconsistent practices. Chemical Use: Halt use of FSC banned chemicals, and minimize chemical use overall.
• Timber Sale Contract Administration: Require appropriate training of contractors; generate new contract specifications if needed; enforce compliance with safety regulations and other contract specifications.
• Training Systems: Improve organization of staff records and enhance training on Rare & Endangered species.
• Tribal Issues: Enhance cooperation and consultation with indigenous peoples.
• Management Review for Continuous Improvement: Systematic gathering of information about forest certification related issues, reporting that information, and formal management review.

Based upon the information in the scoping and pre-assessment reports, preliminary judgments offered by our forest certification auditors, and feedback from our forest certification consultants (BioForest Technologies), it was determined that the Michigan State Forest Program could achieve FSC and SFI endorsed certification, provided that a dedicated effort is made to address identified gaps of more substantive nature.

2005 ACTION PLAN:

Following receipt of the pre-assessment and scoping reports from forest certification auditors in December 2004, the Forest Certification Implementation Team developed a draft action plan to address identified major non-conformances with FSC and SFI standards. On January 21, 2005, the management teams from FMFM, Wildlife, and Fisheries Divisions met to review and refine the proposed action plan. The plan was then reviewed and approved (with additional changes) at the February 7, 2005 Resource Management Bureau meeting. The plan outlined: what the major gaps were, how to fill the gaps (action plan), what resources were needed, and an implementation timeline.

The Department aggressively addressed identified gaps and took corrective actions prior to the certification audit scheduled for the last two weeks of September, 2005. The FCIT assigned a team member to function as lead in each of the 11 major focus areas of the action plan in order to coordinate and facilitate implementation. Also, a number of work groups and committees assisted in developing work instructions for implementation of the corrective actions.

It is important to note that some portions of the action plan could not be completed by the time of our certification audit - for example: long term, landscape-level planning. However, for those actions that are not completed, substantive progress was made.

WORK INSTRUCTIONS:

Work instructions are new or updated Department operational procedures that closed the forest certification gaps and ensured compliance with all indicators in the forest certification standards. All proposed actions identified in the Department's Forest Certification Action Plan were implemented through 21 work instructions.

The FCIT action plan leads worked with appropriate committees and work groups to write the work instructions utilizing a standard template. Draft work instructions were reviewed by our Department's Forest Certification consultants, approved by the FCIT, reviewed by DNR Division Management Teams, and approved for implementation by the Resource Management Bureau chiefs.

Work instruction implementation is an important focus of DNR internal audits, and they will make forest certification more manageable. The work instructions will be refined as needed. For example, refinement may be needed based upon findings of the DNR internal audits, and the September forest certification audit.

Work Area Group (WAG) 1 Plan, Monitor, and Review

1.1 Strategic Framework for Sustainable Management of State Forest Land

1.2 Management Review Process for Continual Improvement in the Management of Forest Resources

1.3 Regional State Forest Management Plan Development

1.4 Biodiversity Management on State Forest Lands

1.5 Social Impact Considerations and Public Involvement Processes

1.6 Forest Management Unit Analyses

1.7 State Forest Timber Harvest Trends

Work Area Group 2 Forest Regeneration and Chemical Use

2.1 Reforestation

2.2 Use of Pesticides and other Chemicals on State Forest Lands

2.3 Integrated Pest Management and Forest Health

Work Area Group 3 BMPs

3.1 Forest Operations

3.2 Best Management Practices Non-conformance Reporting Instructions

3.3 Best Management Practices -- Road Closures

Work Area Group 4 deleted - all related indicators were combined with WAG 7

Work Area Group 5 Research

5.1 Coordinated Natural Resource Management Research

Work Area Group 6 Education and Recreation

6.1 Implementing Public Information and Educational Opportunities on State Forests

6.2 Integrating Public Recreational Opportunities with Management on State Forest Lands

6.3 SFI Involvement and the Michigan State Implementation Committee

Work Area Group 7 Integrated Implementation and Contracting

7.1 Timber Sale Preparation and Administration Procedures

7.2 Legal Compliance and Administration of Contracts

Work Area Group 8 Training

8.1 MDNR Staff Training for State Forest Management

Work Area Group 9 Tribal Issues

9.1 Collaboration with Tribes in Regard to Management of State Forest Land

STAFF TRAINING:

Several training events supported implementation of the Michigan Department of Natural Resources forest certification program. Training included:

1. Forest Certification Overview Training for all DNR staff.
2. Auditee training for staff in forest management units being audited by SFI and FSC auditors and by DNR internal auditors.
3. Training of DNR internal auditors.
4. Work Instruction training for field and Lansing staff.

INTERNAL DNR AUDITS:

Internal audits will be the basis of an annual management review system that is focused on continual improvement in sustainable management of State Forest lands. An annual management review process is required in the forest certification standards.

The internal audits are conducted by an internal three or four person audit team. The team members were selected by their respective Division Management Teams and were initially trained by our forest certification consultants. Internal audits are conducted annually. Eight forest management units were audited in 2005, prior to the forest certification audit. In 2006, the year following certification, the remaining seven forest management units were internally audited. Thereafter, four forest management units are being audited annually.

Internal audit plans are developed by DNR lead auditors in consultation with Forest Management Unit (FMU) Unit Managers. Typically, the audits begin on a Tuesday and end on Thursday. Unit Managers and Biologists are responsible for ensuring that appropriate staff are available to review forest treatments at various field sites visited. The audit engages FMFM Unit Managers, Foresters and Forest Technicians; WLD Biologists and Technicians; and FSHD Biologists and Technicians. District Specialists must be also be available to review practices they recommended or conducted.

The audits provide an opportunity to evaluate how well our Forest Management Units comply with DNR work instructions, and identify actions that need to be taken to come into conformance with work instructions and other DNR procedures. The internal audit reports are posted on the DNR internet and intranet. The audits also provide a valuable training opportunity for staff, not only in regard to familiarity with work instructions, but in preparing for external certification and surveillance audits.

ANNUAL MANAGEMENT REVIEW:

An annual management review is required in the forest certification standards and in the DNR work instructions. It is also good business practice. The purpose of a management review is to promote continual improvement in the practice of sustainable forestry. It is an opportunity for all employees to influence the organization.

The annual management review evaluates audit results for state forest operations, critiques effectiveness of work instructions, analyzes non-conformances, and determines changes and improvements necessary to continually improve conformance. The review is especially focused on Internal Audits results and non-conformances identified in SFI and FSC Certification and Annual Surveillance Audits.

The first field management review was conducted on August 31, 2005, and involved numerous managers from FMFM, Wildlife, and Fisheries Divisions. At this meeting, Statewide non-conformances identified in the internal audits were reviewed, and status of corrective actions were evaluated, in preparation for September, 2005 Certification Audits.

Subsequent management reviews were conducted on January 6, 2006, January 30, 2007, and January 17, 2008. These meetings focused on:

• Clearing SFI and FSC Corrective Action Requests (CARs) and implementation of DNR corrective action responses.
• Clearing statewide internal audit non-conformances identified in internal audits.
• Reviewing pending actions decided at previous Management Reviews and not fully implemented.
• Identification of other actions for continual improvement in management.
• Identification of needed revisions to work instructions.

A formal management review report is prepared by FMFM and WLD Field Coordinators that documents meeting recommendations which are then reviewed and approved by the Division Management Teams and the DNR's Statewide Council. The FCIT provides oversight of ongoing management review implementation. The Statewide Council ultimately identifies changes and improvements necessary at all Department levels. Division Chiefs ensure changes and improvements approved by the Statewide Council are implemented via written communication to employees.

2005 SFI and FSC CERTIFICATION AUDITS:

The joint SFI and FSC forest certification audit was conducted over a two week period starting Monday, September 19, and ending Friday, September 30. The audit team for this certification evaluation included: SFI Lead Auditor Mr. Mike Ferrucci of NSF-ISR; FSC Lead Auditor Dr. Robert Hrubes of SCS; and team members Dr. Dave Capen and Ms. Jodi Kaiser.

The audit began in Lansing with Department staff providing an overview of the Department's Forest Certification efforts implemented to date. The auditors also conducted interviews with select Department staff to obtain detailed information on department operations. The first of three stakeholder meetings was conducted in the late afternoon at the Lansing office.

The audit team departed for the field on Monday evening to begin its tour of eight Forest Management Units (FMUs) and four District offices. The field days typically started with a brief office visit where an overview of district and unit operations was provided. Then, field tours commenced whereby auditors viewed and critiqued numerous randomly selected sites and conducted field interviews with staff. Two additional stakeholder meetings were conducted while touring the northern portions of the state, one at Gaylord and another in Marquette. The stakeholder meetings were organized and conducted by the auditors without DNR participation.

The auditors held a closing meeting at the Marquette Operations Service Center (OSC) on Friday, September 30. The audit team made an oral presentation of preliminary audit findings, including perceived non-conformances with the standards. An initial evaluation regarding overall conformance with the Forest Stewardship Council (FSC) and Sustainable Forestry Initiative (SFI) Standards was provided.

CERTIFICATION AUDIT RESULTS:

The Michigan DNR had a very positive audit and successfully achieved certification under both Standards. SFI Certification was awarded December 9, 2005, and FSC Certification was awarded December 31, 2005. The certification covers nearly 3.9 million acres of State Forest land managed by the Department of Natural Resources (DNR). Excluded from scope is approximately 112,000 acres of State Forest land in the Northern Lower Peninsula that is under long term lease to the Michigan Department of Military Affairs and managed primarily for military use. Audit reports are available on the DNR's forest certification web site.

NSF-ISR auditors issued six minor SFI Corrective Action Requests (CARs), identified nine areas where forestry practices on Michigan DNR's lands exceed the basic requirements of the SFI Standard, and identified fourteen opportunities for improvement. The opportunities for improvement do not indicate a current deficiency, but serve to alert Michigan DNR to areas that could be strengthened or which merit future attention.

The SCS Auditors made six recommendations that the audit team concluded would help the DNR move even further towards exemplary status. Action on the recommendations is voluntary and does not affect the maintenance of the certification certificate. The SCS Auditors identified thirteen FSC CARs. Two of these were major CARs that were cleared prior to award of certification.

For the size of our state forest, six SFI CARs and thirteen FSC CARs was a very good audit result. In essence, the DNR was issued fewer CARs than normal for a forest this size. Following the audit, a significant effort was made to address the corrective action requests.

MORE ABOUT CORRECTIVE ACTION REQUESTS

Forest certification auditors assess conformance to each element of the SFI and FSC standards within the scope of an audit. SFI Standard elements are objectives, performance measures, and indicators. FSC elements are principles, criteria, and indicators.

When a major nonconformance is found, a certificate of conformance is not issued until the audit firm verifies that corrective action approved by the lead auditor has been implemented. A revisit may be required to verify implementation of corrective actions to major conformances.

When a minor nonconformance is found, a certificate of conformance is issued only after the lead auditor approves a corrective action plan that addresses the nonconformance within an agreed-upon period, not to exceed one year.

The corrective action requests must be closed out within a specified time period after award of certification. Depending upon case-specific circumstances, failure to close out a minor CAR within the specified time frame can lead to possible elevation of the minor CAR to a major CAR with a very short compliance date upon which continued certification is contingent.

CARs are issued not only following a certification audit, but also following surveillance audits which are conducted annually during the five year term of certification.

2006 SURVEILLANCE AUDITS:

In 2006, two SFI and FSC surveillance audits were conducted. One was a special, supplemental surveillance audit conducted in March; the other was the first annual surveillance audit which occurred in October.

SFI and FSC Supplemental Surveillance Audit (March 2006):

The FSC and SFI supplemental surveillance audit was conducted on March 8, 9 and 10. This audit was conducted by Mr. Mike Ferrucci, representing SFI and Dr. Robert Hrubes representing FSC. Both auditors focused on Corrective Action Requests (CARs) issued during the September 2005 certification audit. The auditors also focused on DNR staff familiarity and conformance with DNR work instructions.

A lesson learned by DNR staff during this March audit is that we must pay close attention to addressing and clearing the CARs by established deadlines, and be prepared to provide clear and concise documentation in regard to how we accomplish this. Field staff did an admirable job in regard to explaining and conforming with work instructions. No new Corrective Action Requests (CARs) were written during this special surveillance audit.

First Annual Surveillance Audit (October 2006):

The first annual surveillance audit for the maintenance of Michigan's forest certification was conducted in the Upper Peninsula during the week of October 23, 2006. This audit was conducted by Mr. Mike Ferrucci representing SFI, and Dr. Robert Hrubes and Mr. Sterling Griffin representing FSC. In addition to the certification team, two FSC accreditation auditors observed the annual audit process on behalf of the FSC national and international organizations. Mr. Hans Achim Droste led the accreditation audit and is the Accreditation Program Manager for FSC world headquarters in Bonn, Germany. Mr. Bill Wilkinson is the Accreditation Auditor representing FSC in the United States.

At the conclusion of the field portion of the audit, the certification auditors indicated the audit highlighted many positive activities the DNR has undertaken, and they recommended closure of all outstanding corrective action requests (CARs). It is rare for a public agency to close all CARs in its first annual audit. The certification auditors, and the FSC accreditation auditors who were observing the process, expressed their appreciation for the forthrightness and cooperative spirit of every DNR employee.

Excerpt from the SFI audit report:

"The Michigan DNR's SFI Program was found to be in continuing conformance with the SFI Standard. The review during the October 2006 Surveillance Audit showed that the department has implemented the corrections for all of the previous non-conformances."

"The sustainable forestry program of the Michigan DNR has many clear strengths which factored strongly into the finding of continuing conformance with the certification requirements. The audit team found that the Michigan DNR has made significant improvements in its already strong performance by continuing to implement and improve its comprehensive management review program, by increasing resources devoted to management plan updates, by completion of a draft Michigan Statewide Forest Plan, and by creating special task forces to consider BMP and ORV issues."

Excerpt from the FSC draft audit report:

"The overall impression formed by the audit team as a result of this surveillance audit is that Michigan DNR continues to be very earnestly and strongly committed to meeting its obligations as a FSC-certified forestland manager. Notably, DNR has now undergone three very substantive and demanding audits within a 12-month time period and in each instance has demonstrated strong improvement in the overall level of conformance to the Lake States Regional Standard. Most importantly, DNR has demonstrated solid efforts at closing out each of the corrective action requests (CARs) that were stipulated at the time of award of certification."

"This focused effort has generated the tangible result of all 13 of the CARs issued at the time of award of certification are now closed as of the completion of the October surveillance audit. The audit team considers this to be truly commendable performance."

"We wish also to memorialize in this report the fact that the FSC conducted an accreditation (shadow/witness) audit of SCS as part of our surveillance audit of Michigan DNR... On the basis of the exit interview comments presented to both SCS and DNR representatives by the FSC auditors on October 27th, we are pleased to note in this report that FSC fully endorses the award of certification to the DNR for its management of the Michigan State Forests. FSC has informed us that, on the basis of their in-depth surveillance of our auditing of DNR, they are issuing no corrective action requests to SCS. This can rightly be construed as a clear endorsement of both SCS, in its role as an FSC-accredited certification body, and DNR, in its role as manager of a FSC-certified forest estate."

Forest certification is a continuous improvement system so there are always new challenges, new CARs, and opportunities to improve. Two new SFI CARs and five new FSC CARs were issued following the October 2006 surveillance audit. Addressing these seven external surveillance audit CARs, the five statewide non-conformances identified during the internal audits, and completing unfinished assignments from the previous management review was the focus of the forest certification effort in 2007.

SECOND ANNUAL SURVEILLANCE AUDIT (October/November 2007):

The second annual surveillance audit for the maintenance of Michigan's forest certification was conducted in the Northern Lower Peninsula between October 30 and November 1, 2007, with a visit to Lansing for staff interviews on November 2, the final day of the audit. This audit was conducted by Mr. Mike Ferrucci, representing SFI and Dr. Robert Hrubes representing FSC.

Mike Ferrucci (SFI lead) concluded that Michigan remains under continuing conformance with the SFI standards. He commented that our internal audit and management review process is a very strong part of Michigan's program and is a highly functioning and excellent process that we should continue to implement. The department had 2 open CARs from the 2006 audit relating to rutting specifications and BMP/road/trail damage issues. The CAR regarding rutting was closed and we were commended for a job well done regarding our action plan to address this issue. The CAR regarding BMPs/damage issues was closed following receipt of additional reports after the audit. One new minor non conformance (CAR), two Opportunities for Improvements, and one concern were issued. The CAR involves the state forest plan, and the need to complete this plan.

Dr. Robert Hrubes (FSC lead) conducted the audit for the FSC standards and reaffirmed the award of certification and added that he was very confident in that decision. The department had five open CARs from the 2006 audit which involved (1) rutting standards, (2) stakeholder consultation specific to High Conservation Value Areas (HCVAs), (3) environmental analysis and documentation, (4) statewide and regional planning, and (5) stakeholder consultation processes. The CARs involving rutting and HCVA stakeholder consultation were both closed. The other 3 CARs were closed for 2006, but new and more focused CARs under those topics were issued.

In addition to the CARs that follow-up on three issued in 2006, one new minor CAR was issued related to ORV concerns. ORV issues are new on the radar screen for FSC and we expect to see revised regional standards under FSC addressing this in the future. The new CAR is focused on a need to develop a timeline and to follow through with approval of an ORV management plan. In addition, two Opportunities for Improvement were issued.

Dr. Hrubes and SFI auditor Mike Ferrucci both stated that Michigan is on the cutting edge with its internal audit system and unparalleled across the nation. Both feel this is a very important part of Michigan's forest certification program.

2008 EFFORT:

The focus of the forest certification program for 2008 is outlined in the January 17, 2008 Management Review Report which was approved by the Department Management Teams and the Statewide Council on May 6, 2008. Addressing the 2007 surveillance audit CARs, the five statewide non-conformances identified during the 2007 internal audits, and completing unfinished assignments from the previous management reviews are the priority areas to be addressed in the coming year.