Below is an anonymous post that we received: Proposed CW Mitigation Measure: Overall avoidance of trees equal to/or greater than 150 years of age. Response: The first point we need to raise is our strong objection to this proposed mitigation action. We see this as a “Critical Fail” for the FSC CW standard. Meaning, many FSC Certificate Holders will choose to leave FSC rather than attempt to implement a poorly developed, ineffective and costly mitigation measure. Reasons for our Adamant Opposition to the Proposed Mitigation Measure: 1. The proposed 150 year age limitation on individual trees is outside the scope of the FSC US NRA specified risk to old growth forests. The NRA specifies risk only to Type 1 and Type 2 forests. The proposal would extend that risk to stands that do not meet the definition of Type 1 and Type 2 forests, and potentially pull all forestland within the United States into specified risk. 2. The proposed 150 year age limitation fails to meet the topline filters established by this FSC stakeholder process for development of mitigation actions. a. Clarity: The relationship between individual old trees from any forest and Type 1 and Type 2 old growth late-successional forest stands structure and function has not been established. b. Efficiency and Practicality: The proposed 150 year age limitation clearly fails this test. The fact that this proposed action would require an assessment/measurement of individual trees makes the resource requirements to implement the mitigation measure completely excessive to any size of an organization. As a mid-size organization we estimate that we process approximately 1.8 million logs per year. c. Auditability: Certification bodies would also be required to assess/measure individual logs which would increase audits costs significantly even if applied through a sampling methodology. 3. The proposed mitigation action does not decrease negative impacts to Type 1 and Type 2 late-successional old growth stands. The logs from any potential harvest in Type 1 and Type 2 would simply be diverted to non-FSC CW organizations. 4. The proposed mitigation action does not provide any proven or reasonable expectation of effectiveness. The logs from any potential harvest in Type 1 and Type 2 would simply be diverted to non-FSC CW organizations. 5. The proposed mitigation action would require extensive investments by organizations attempting to implement. Changes to raw material input processes and assessment/measurement of individual logs would be excessively costly which would far outweigh the benefit an organization receives from participation in FSC CW. 6. The proposed mitigation action goes well beyond the bounds of knowledge about specific sites by requiring knowledge about individual tree/log raw material inputs adding complexity and cost. 7. The proposed mitigation action fails to meet the criteria of applicability to different types of organizations (those that deal directly with forests and those that don’t). The proposed mitigation action is non-implementable for secondary production facilities. There is no possible methodology to test the age of raw material inputs such as chips, veneer, and market-pulp (all raw material inputs to CW systems). Attempts to implement the proposed mitigation action would create an unlevel playing field by placing undue burden on primary facilities and an unachievable expectation on secondary facilities. 8. It would appear that the proposed mitigation action is an attempt to utilize the FSC CW standard to influence/control/limit outputs from Federal and State forests (NOT APPROPRIATE). Federal and State forests have existing stakeholder input processes which support the development of sustainable forest resource plans. 9. Procurement only certificate holder organizations have no control over what Federal and State agencies designate as harvest cutting specifications in their legal contractual agreements. Therefore, no decision power exists over which trees are designated to remain and which trees are designated to be harvested. Those decisions belong to the forestland owners, making this proposed mitigation action a better fit in a Forest Management Standard, and not applicable to the FSC CW Standard. 10. The proposed mitigation action is not a landscape level mitigation measure as directed by this regional FSC process. Rather it is targeted at individual tree management/assessment that is a completely different scale. 11. If the proposed mitigation action is implemented by FSC as a mandatory requirement, it could potentially be viewed as a market restriction or barrier. 12. The proposed mitigation action does not increase the knowledge about conservation value of Type 1 and Type 2 old growth late-successional forests. 13. Forests certified to the FSC Forest Management Standard would not meet the proposed mitigation measure. Attempts to implement the proposed mitigation measure would make the Controlled Wood standard more restrictive than the FSC FM standard.