WWF-Russia’s Position on Salvage Logging
According to the regulations, salvage (sanitary) logging means wood harvesting in dead or damaged forests, that is, a measure aimed at preventing the spread of pests. However, in practice, salvage logging in Russia is often used only as a mechanism to bypass various prohibitions and restrictions on logging, including those in protected areas, going beyond the permitted volumes or methods of harvesting.
Salvage logging accounts for about 1/7 of the total recorded volume of wood harvested annually in Russia. According to the official statistics , for the period from 2009 to 2018 (inclusive), selective and continuous salvage logging amounted to an average of 28.7 million cubic meters of wood per year, with an average total volume of harvesting for the same period of 200.5 million cubic meters per year.
The WWF-Russia’s experience gained in the Russian regions confirms that the main reason to conduct salvage logging is precisely the need to harvest wood in those forests or in those ways that are normally unacceptable for such forests, for instance, due to legal restrictions. Selective salvage logging most often literally means the selection of the best trees from an economic point of view, and often leads to deterioration of forest health, reduced productivity and degradation. Salvage clear-cut is often similar to final felling, with the only difference that it often does not take into account the restrictions related to the environmental or social functions of the forest. Even if all permits for salvage logging are issued correctly, field inspections often reveal gross violations of the Russian legislation. There are cases when salvage logging is carried out conscientiously and efficiently, but it is not a common practice. Thus, in Irkutsk Region, up to 80% of acts of forest pathology examination  were canceled on WWF-Russia’s requests, and WWF field inspections in the Russian Far East, Altai Region and the Russian Caucasus confirmed numerous violations as early as during logging .
The big number of criminalized salvage logging is also admitted by law enforcement agencies: among the reasons for high-profile criminal cases, made known to public by investigative authorities, unjustified salvage logging consistently occupies one of the first places.
At the same time, wood harvested during salvage logging, with rare exceptions, is purchased by consumers and exporters on the same basis as wood from any other logging operations, and goes to those companies that strive to be law-abiding and responsible, for example, acting within the framework of voluntary forest certification and international legislation on combating illegal logging.
In this regard, WWF-Russia supposes that there is a very high risk that wood obtained from salvage logging in Russia may be harvested with gross violations of the requirements of the current legislation, in other words - illegally.
WWF-Russia urges that such salvage logging causes significant environmental damage, as it usually affects forests of the highest conservation value; leads to economic losses, since the fee for this type of logging is significantly lower than for logging for the purpose of wood harvesting; threatens to worsen the sanitary condition of forests; undermines the prestige of authorities responsible for protecting forests from pests and diseases, and the entire Russian forest sector.
It should also be noted that the problems typical for selective sanitary logging i.e. selection of the most commercially attractive trees , leading to a deterioration of the forests health and reducing their productivity and degradation, might also be characteristic of thinning in ripe and over-ripe forest stands.
WWF-Russia also supposes that these problematic aspects of salvage logging in Russia should be taken into account when auditing wood supplies under voluntary forest certification schemes, including FSC or confirming the legality of wood origin, including compliance with the requirements of the European Union Timber Regulation 995/2010 and the Lacey Act.
In view of the above, WWF-Russia calls on state authorities, forest companies and voluntary forest certification organizations to make every effort to promptly and completely eliminate the practice of using salvage logging for any other purpose, except for the actual prevention of pest outbreaks and diseases of the forest and the felling of dead trees, namely:
- strengthen control over the allocation and conduction of salvage logging, strengthen the personal responsibility of forest pathologists for the quality of drafting forest pathology survey reports and the responsibility of forest management bodies specialists who are in charge of making up the act of field inspection of forest sites after salvage logging over assessment of quality of logging and the accuracy of information specified in the inspection act;
- develop and implement a digital form of the forest pathology survey report, with mandatory permanent storage of all reports in a centralized database and the possibility of downloading them freely in open data format;
- make all the records of inspection of harvest areas for salvage logging publicly available online on the websites of regional bodies of state authority.
All responsible forest managers: to refuse unjustified and illegal salvage logging, as well as thinning in ripe and overripe stands;
All responsible consumers and processors of wood: refuse to purchase wood harvested during salvage logging, as well as from thinning in ripe and overripe stands, without a thorough field check of their legality.
Forest Stewardship Council (FSC): implement special measures to ensure mandatory control of the legality of salvage logging, when timber comes to FSC-certified chains of custody, and introduce these measures into the FSC regulatory framework. Control measures should include mandatory in-house and field verification of the validity of salvage logging and the absence of violations during its conduct. In the course of desk and field inspections, it is necessary to:
- make sure that there is a Forest Pathology Survey Report (FPSR);
- make sure that the location of the salvage logging corresponds to the information stated in the FPSR;
- check the compliance of the species composition and stock of the harvested stand according to documents and on the ground;
- compare the data of the FPSR with the information about damage to the stand, and the data of the lists of calculation of trees;
- check the function by the sanitary status categories;
- check the remaining density of a forest stand;
- check that felling residues are handled in compliance with the rules of sanitary safety in forests;
- take other measures necessary to check the legality of carrying out of salvage logging.
Before developing and implementing the measures that will minimize the risk of illegal wood from salvage logging entering chains of custody, WWF-Russia recommends that FSC-certified companies either implement their own measures to control legality, or completely abandon the use of wood obtained during salvage logging.