FOREST CERTIFICATION AS A TOOL FOR
                              GREEN WASHING
                                    
                           Julio Cesar Centeno


The teak plantation scandal involving Flor y Fauna and the Rainforest Alliance portrays the mismanagement of certification to provide "green" credibility to a project based on fundamentally flawed assumptions, with many of the characteristics of a case of fraud. It also highlights the difficulties with implementing credible certification programs, as well as the challenges involved in the operation of reliable accreditation systems, capable of efficiently assessing potential certifiers, and of adequately monitoring their activities. Here are the latest developments of this strange case.

A public controversy has been developing in The Netherlands involving a teak plantation project certified as "well managed" by the Rainforest Alliance in April of 1995. The accreditation body, the Forest Stewardship Council (FSC), openly endorsed the certificate issued to the project, even before the Rainforest Alliance was accredited as a certifier, and before the FSC principle on plantations had been approved. More surprising still is that this took place after serious irregularities with this project had been publicly exposed through the Dutch media.

A widely circulated letter from the FSC Executive Director, dated December 21, 1995, rules with regard to the RA assessment of Flor y Fauna: " We believe that the Flor y Fauna evaluation report was thorough and competent"

In this same message, the FSC Secretariat complements the endorsement with the following claim, referring to the Rainforest Alliance and other certifiers: "... in a limited sense, the FSC Board has approved their certification systems even for plantations."

It is unclear what prompted FSC Secretariat to present such an inopportune endorsement of this certificate, when the FSC constituency had not yet approved the crucial and controversial principle on plantations; when no formal decision had yet been reached by the Board of Directors of the FSC to accredit the Rainforest Alliance or any other certifier; when a public scandal surrounded this particular case had already erupted in The Netherlands; when the validity of this specific certificate was being openly challenged in the Dutch media; and when the beneficiary of that certificate had been claiming for months, through millions of full page adds in the press, that it had been certified, not by the Rainforest Alliance, but by the FSC itself.

KEY ISSUES
The public controversy involving this plantation project revolved around three basic points:

  1. The yield of timber that could be expected from the plantation.
  2. The price at which the timber could be sold.
  3. The rates of return promised to investors, in turn based on the combination of yield and prices.

    YIELDS
    Flor y Fauna promoted public investments in its project, promising rates of return based on specified yields of commercial timber expected from the plantations. For plantations established during the first four years [1989-1992], referred to as Teakwood I to V in the corresponding sales brochures and public advertising, Flor y Fauna assumed it would achieve the production of at least 1,000 M3 of commercial logs per hectare, under a 20 year rotation. This is equivalent to a mean annual increment of 50 cubic meters per hectare per year.

    In the promotional brochure for Teakwood III: AN INVESTMENT IN A GREENER FUTURE [Ref.12] Flor y Fauna promoted investments promising unaware customers a total of 950 M3 of tradable timber per hectare in 20 years. This is equivalent to a mean annual increment of 47.5 M3/ha-yr, and refers only to the proportion of timber whose economic value belonged to investors [95% of the total].

    Starting with Teakwood VI, in 1993, Flor y Fauna comes to an agreement with an insurance company by the name of OHRA, and with the Dutch office of the World Wide Fund for Nature (WWF-NL), to promote investments in the plantations among the Dutch public, in association with life insurance policies. In March of 1993 Flor y Fauna published its Teakwood VI promotional brochure, also entitled EEN INVESTERING IN EEN GROENERE TOEKOMST [An Investment in a Greener Future], where returns to investors are based on the production of 933 to 1,130 M3 of commercial timber per hectare. This is equivalent to a mean annual increment of 46 to 56 M3 per hectare per year [Ref. 13]

    In a letter to WWF-US, dated April 08, 1993, the firm Van Rossum & Van Veen, a representative of Flor y Fauna and a member of the Board of the SCOFF Foundation, a Flor y Fauna derivative, highlights growth rates for commercial timber ranging from 40 to 48 M3 per hectare per year, as the portion of the yield that would belong to investors. The same figures were supported by WWF-NL, a partner of Flor y Fauna and OHRA in this project, in its communication of 17-02- 93, reference avk/rw/93-256 [copies in the Appendix of Reference 1].

    These projections, in combination with the prices at which such timber was expected to be sold, have been the cause of serious problems for the company since 1993. For this reason Flor y Fauna was first taken to a court of law in December of that year. In that opportunity it presented as evidence a supposedly "independent" and "authoritative" document by the Ministry of Agriculture of The Netherlands, dated December 28, 1993, where the minimum expected yield for these plantations is established at 1,057 M3 per hectare in 20 years, equivalent to a minimum mean annual increment of 53 M3 per hectare per year [Ref. 11].

    In that same opportunity, Flor y Fauna's lawyers presented as an additional piece of evidence a Memorandum of Oral Pleading, dated December 7, 1993, claiming that it should not be considered imaginary that OHRA's highest projections [960 M3 per hectare in 20 years] might be surpassed by a factor of 2, with production reaching over 1810 M3 per hectare, equivalent to a mean annual increment of over 90 M3/ha-yr.

    The report by the Ministry of Agriculture has been repeatedly presented as evidence that the company's projections were, in fact, rather conservative. This same document was again introduced as evidence by OHRA to the Reclame Code Commissie [Advertising Standards Committee] of The Netherlands in January of 1996, along with the fact that the project had been certified by the Rainforest Alliance.

    This document has proved to be a regrettable embarrassment to the Ministry of Agriculture of The Netherlands, due to its speculative nature, to its lack of professionalism, and to the inclusion of an astonishing array of the most elementary mistakes. Amongst these mistakes is a totally invalid, burlesque and unprofessional way of collecting the data upon which the report is based. As recorded on film by the Ikon television crew of The Netherlands, The Rainforest Alliance formed part of the party that went to Costa Rica to collect this useless pile of numbers. It also remained silent ever since about the contents of this report, thereby supporting its astounding conclusions.

    It has lately been disclosed that the author of this "independent" report, while an employee of the Ministry of Agriculture, also served as Chairman of the Board of Advisors of Flor y Fauna itself.

    The Teakwood VI promotional brochure was submitted by Flor y Fauna as evidence in a court of law on December 7, 1993, and by OHRA to the Reclame Code Commissie in March and July of 1996.

    PUBLIC EXPOSURE

    After the critical exposure of this case through a television broadcast in The Netherlands in November of 1995, and in the subsequent and extensive press coverage, yield projections for plantations established from 1993 on were quickly modified. On November 30, 1995, a few days after the highly respected NOVA television broadcast, OHRA wrote to NOVA that the new expected yields of commercial timber ranged from 400 to 850 M3/ha over the 20 year cycle, "without doubt", according to their scientists. The huge magnitude of this range should have warned other parties involved about the improvisation and lack of reliability of such projections.

    The certificate issued by the Rainforest Alliance obviously implies an endorsement of the project, especially of the fundamental variables involved: yields, prices and rates of return. Since it establishes no reservations, this is a fair and logical interpretation, particularly by the general public and potential investors.

    Furthermore, the Rainforest Alliance's own criteria for certification establish: "Growth and yield projections in planning and marketing documents must be reasonable and based on a combination of scientific literature and documented or practical local experience". But in this case, no such evidence has ever been produced, in open violation of its own rules of proceedure.

    Nevertheless, the Rainforest Alliance has repeatedly made its endorsement of Flor y Fauna's yield projections plain and specific. In its message of February 01, 1996, it states: "Based on interviews, field work, and research data collected in Costa Rica, we did not find that Flor y Fauna's projections in terms of growth and yields were inaccurate". If the RA did not find Flor y Fauna's projections to be inaccurate, it in fact found them to be accurate.

    On February 03, 1996, I requested from the RA the justification of its conclusions, as expressed in the quotation above [8]. What was the nature of the field work that led to this conclusion? What sort of research data was it referring to? Where could the relevant reports be found? No reply was ever received.

    Due to the unwillingness of the Rainforest Alliance to respond and justify its supposed findings, the request was reiterated four and a half months later, on June 20, 1996, but this time publicly, through an article entitled THE ELUSIVE CREDIBILITY OF FOREST MANAGEMENT CERTIFICATION CLAIMS [Ref. 6]. An answer is still to be received.

    Having lost the only piece of "evidence" that supported Flor y Fauna's and OHRA's projections on yield [the notorious report by the Ministry of Agriculture], a new piece of "evidence" came quickly into play. At a press conference on March 4, 1996, OHRA produced a highly unusual collage of separate paragraphs of what it claimed was a report by an organization in Costa Rica by the name of Centro Cientifico Tropical [CCT]. The report is supposed to be the result of a contract between CCT and Flor y Fauna. OHRA called this bizarre collage of paragraphs an "executive summary" of the report [Ref. 14]. Strangely enough, the report itself has never been made available, raising doubts about the true nature of its findings.

    In this highly unusual "executive summary", CCT seems to estimate that Flor y Fauna's plantations will produce 527 to 725 cubic meters of tradable logs per hectare in 20 years. It is not indicated how this estimate was made, or how it is substantiated. The curious "summary" does highlight that conclusions were based on data supplied by Flor y Fauna. Nevertheless, CCT assumed the responsibility of suggesting that a mean annual increment ranging from a minimum of 26 M3/hayr, and possibly as high as 36 M3/ha-yr, should be expected in 20 years.

    A few days later, on March 11, 1996, the Rainforest Alliance made a public statement, in which it continued to endorse Flor y Fauna's yield projections:
    "Smart Wood does not guarantee growth and yield projections. However, Smart Wood did review Flor y Fauna's growth data, and the company already was showing above-average growth performance. Based on this preliminary data, Smart Wood could not determine definitively that Flor y Fauna's range of growth projections would not be obtained."

    In a declaration to the Dutch Financial Daily [Het Financieele Dagblad] of May 7, 1996, Henk Janssen, adjunct director of OHRA, clarified their yield projections as follows:
    "OHRA has, from the very start in March of 1993, used the range from 20 to 42.5 M3 in its advertising materials"

    The Rainforest Alliance insists that it does not guarantee any yield projections. Neither does OHRA nor Flor y Fauna. But what can not be denied is that the RA has clearly endorsed the projections on yield made by Flor y Fauna and OHRA, compromising its name and reputations, as well as the name and reputation of the FSC.

    There is thus considerable documented evidence as to what the claims of Flor y Fauna and OHRA have been with regard to yield projections, ever since this plantation was established. There is also plenty of evidence as to what the position of the Rainforest Alliance has been in this respect. To deny at this stage what the claims to timber yields have been would be absurd.

    However, this is precisely what the Rainforest Alliance is trying to do, raising serious doubts about its reliability as a credible and objective certifier, and about the motives that lead its actions.

    THE RAINFOREST ALLIANCE'S OBSCURE RULING

    On August 16, 1996, The Rainforest alliance published a statement on the Flor y Fauna controversy, assuming the role of a judge, ruling on what it refers to as "the defendants", who are supposed to be OHRA and Flor y Fauna, and a group of what it refers to as "the plaintiffs", of which I am supposed to be a member. This ruling is the outcome of what the RA considers a "formal complaint" on the case.

    I have never presented a formal complaint, neither to the Rainforest Alliance, nor to the FSC. As far as I am aware, neither of the other two persons to which the RA refers as "the plaintiffs" has presented a complaint to the Rainforest Alliance or the FSC regarding this case. Furthermore, at no time have I taken action, or addressed the case, in conjunction with either, or both, of the other two persons to which the RA refers as "the plaintiffs". The implications to that effect seems to be an attempt to purposely mislead the recipients of the RA message.

    The Rainforest Alliance did not give any of the alleged "plaintiffs" the opportunity to be heard. As has become evident from the reaction by the other "plaintiffs", the RA did not bother to contact them, to hear their arguments and position, in order to provide a minimum of impartiality to its own actions. The "plaintiffs" were extensively referred to without consultation; accused and ruled upon without their knowledge. This is contrary to elementary rules of impartiality and professional ethics.

    The RA statement is actually a reflection of the point of view of the alleged "defendants", and of the RA own concerns. It is a statement on a subject in which the RA is deeply involved, where it has been severely criticized, where its reputation is at stake, and where its impartiality is highly questionable. It should therefore have avoided any pretention of impartiality, a pretention that the RA itself has demolished with its biased and highly distorted manipulation of evidence.

    DOCUMENTED OR CONSTRUED EVIDENCE ?

    The Rainforest Alliance refers in its statement to several documents upon which it pretends to support its allegations. Under any normal complaint procedure, documents used as evidence are made available to both the defendants and the plaintiffs in the case. A document is not accepted as evidence from one side, if the other has not had access to it, and its opinion heard on its contents.

    I have asked the RA for copies of the documents upon which it is supposed to base the arguments presented in its public "ruling" of August 16, 1996. The RA has refused to provide them. It argues they are all "confidential". The other two "plaintiffs" have also been denied access to them. The RA hence pretends to present "evidence" in a ruling, while preventing access to such evidence by those against whom it is used, or by anyone else. This is not only a violation of the fundamental principles of transparency and credibility that should permeate the actions of a credible certifier. It is also a violation of fundamental ethical and legal principles, for which the RA will have to respond at the appropriate time. These documents are:

    1. The Original assessment report on Flor y Fauna, 1993.
    2. The Assessment report on Flor y Fauna which led to the granting of the certificate, 1995
    3. The yearly assessment reports on Flor y Fauna existing to date.
    4. The report by the Centro Cientifico Tropical, February 1996.
    5. The report by the "independent consultant" who allegedly analyzed the financial aspects of the plantations, 1996
    6. The contract between OHRA and Flor y Fauna of 1993.

      The fact that the RA maintains these fundamental pieces of evidence beyond the reach of the "plaintiffs" raises legitimate concerns about its true contents, and about the validity of their interpretation by the RA. It is clearly an interested party in this debate, and therefore neither I, nor any other recipient of its message, have to take the RA interpretation of such documents as valid.

      I assume the FSC is aware of the dangerous precedent that this action by the RA is establishing. If this is allowed, then any party in a dispute will be able to use classified documents in an official complaint procedure, and have this evidence weighed against the other parties, without allowing the affected parties access to such documents, and therefore violating their right to an appropriate defense of their case. It is only to be expected that credibility in the FSC would be fatally and irreversibly damaged.

      RECIPIENTS IN THE DARK

      This concern is reinforced by the refusal of the Rainforest Alliance to disclose to the alleged "plaintiffs" the list of recipients of its supposedly "public" ruling. The Rainforest Alliance has denied the alleged "plaintiffs" the right to know to whom its message has been delivered, despite their repeated request for such information. Why? What is the Rainforest Alliance hiding? What is it afraid of? Why does it want to prevent me and the other alleged "plaintiffs" from delivering to those same people our opinion about the accusations and allegations concocted in its statement? Why does it want to maintain those recipients in the dark, with access to only the RA opinion on the subject? Are investors in this venture the key victims of this obscure policy of the RA?

      This new element reassures the concern with the RA lack of commitment to transparency and objectivity, fundamental conditions to the success of forest management certification, and crucial to the success of the FSC itself.

      What is even more astonishing is that the FSC Secretariat has informed one of the alleged "plaintiffs" [Paul Romeijn] that it finds these positions of the RA acceptable. The FSC Secretariat indicates that it find it appropriate for the RA to deny the alleged "plaintiffs" access to the documents upon which it pretends to substantiate its allegations. It has also informed that it finds it appropriate for the RA to conceal the list of recipients of its message, thereby denying the "plaintiffs" the right to present their case to those recipients. It is also denying those same recipients their right to hear both sides of the argument.

      It is those recipients, FSC members or not, the public at large, to whom the FSC has made commitments of transparency, impartiality, accountability and objectivity. They are the ultimate judges. Their rights should be acknowledged. One of their fundamental rights is the right to be informed.

      THE INCREDIBLE SHRINKING TREES

      The Rainforest Alliance has finally realized that the exaggerated yields it had been defending, in accord with Flor y Fauna and its associates, could no longer be maintained. The evidence was overwhelming that they were simply speculations, to which the RA had become an accomplice.

      Flor y Faunaīs monitoring report No. 13, dated June 8, 1996, unveils dramatically lower yield projections for its plantations. According to this internal report, projections for tree growth dropped to half of their original projections. Yield is now estimated to fall between 259 and 416 m3 of commercial timber per hectare in 20 years. These figures were verified by the Rainforest Alliance, and endorsed in its own public statement of August 16, 1996.

      Flor y Fauna and The Rainforest Alliance have thus finally recognized that the yield of commercial timber that can be expected from such a plantation, assuming very good management and site conditions, should remain within 12 to 20 M3 per hectare per year. These are the same figures I have been sustaining from the beginning of this debate [Refs. 1,2,3,4,6]

      But the acknowledgement of this unavoidable basic fact is hard to swallow, particularly after Flor y Fauna, OHRA and the Rainforest Alliance have repeatedly and publicly argued that these figures were incorrect and riddled with mistakes. Itīs like accepting that their trees suddenly shrunk to half their original size.

      Nevertheless, I would have expected the Rainforest Alliance to assume its responsibility with integrity, recognizing the error in which it has incurred, standing tall in defense of the principles of reliability, credibility and transparency, to which it has made public vows. Unfortunately this has not been the case. It has embraced a course of action which can only lead to the crumbling of its own credibility, dragging with it the credibility of the FSC itself.

      The RA now pretends to clumsily cover up the fictitious figures it has been defending for years, printed in black and white in hundreds of thousands of brochures, and presented in three courts of law, with the argument that they did not really refer to commercial teak in the form of logs. The RA ventures to convince us now that such figures actually referred to total biomass, but they had simply forgotten to say so.

      Does the Rainforest Alliance actually deem possible that it will get away with this allegation, when the evidence against it is so overwhelming? Anyone with the most basic knowledge of forestry knows that, in a commercial plantation project of a highly valuable timber such as teak, biomass is not the base upon which financial returns are calculated. How does the Rainforest Alliance pretend anyone to believe that Flor y Fauna, OHRA and WWF planned to use funds, supplied by the general public in The Netherlands, to produce biomass, which they would then pledge to sell for over 2000 dollars the cubic meter?

      The Rainforest Alliance is well aware that the figures that have been used in the past by Flor y Fauna, OHRA, WWF-NL and the RA itself, all referred to commercial timber in the form of logs. There has never been a mention of biomass. It is the production of commercial teak logs that forms the base of the whole project. This can be corroborated by any observer with a minimum of objectivity and professional ethics.

      CONTRADICTIONS
      If the yield figures that have been finally accepted by Flor y Fauna and the Rainforest Alliance are taken as valid, how can OHRA continue to advertise rates of return ranging from "14 to 18 percent .... or more", as portrayed in the WWF magazine PANDA, of September 1996? Are we to believe that these bizarre teak logs first shrunk to half their original size, then miraculously doubled in price, so that the yield can be halved, while still maintaining the same rates of return previously estimated?

      PRICES AND RATES OF RETURN

      The other fundamental variables about which serious concerns have been publicly raised refer to prices and rates of return. The position on these issues by the different parties involved is well documented in the references at the end of this posting. Very much in tune with the highly speculative projections on yields, the projections on prices are beyond any logical expectations. The combination of both converge in highly speculative rates of return, the fundamental product offered to investors.

      The yield figures now accepted as valid by the Rainforest Alliance [12 to 20 M3/ha-yr] should be expected to seriously diminish the projected rates of return of the project. But this may trigger an avalanche of legal actions from investors, who may legitimately feel swindled in the process.

      Since price projections are already significantly inflated, far beyond logical limits, how can then claims on financial returns be maintained? Someone seems to have come up with a glowing idea. The financial returns offered to investors, according to the Rainforest Alliance latest revelation, actually refer to returns based on the sale of high addedvalue, finished products. But they had also forgotten to say.

      Here again we encounter what seems to be a futile attempt to continue to mislead the public, no matter how conspicuously evident the manipulation of facts may be. Returns promised to investors have always been, and still are, based on the sale of teak logs. Any possible processing, or added value, has always been explicitly presented as a source of additional benefit to investors. It is only a matter of time, a rather short period of time, before this whole charade explodes in the face of its perpetrators.

      The Rainforest Alliance argues that the rates of return promised to investors could be met, according to a "secret" document prepared for the RA by an unspecified independent financial analyst. According to the RAīs public statement of August 16, 1996: "In June 1996 an independent financial analysis of Flor y Fauna was prepared for Smart Wood by a PhD forest economist and university professor. This analysis uses standard conservative economic approaches to assess a number of variables. It estimates that the return on investment may be 13-22% under the independent financial analyst's pessimistic and optimistic scenarios. Without recreating OHRA's calculations, this analysis tends to independently support OHRA's projected returns of 11-23% (stated in its most recent brochure) and 14%, 18% or more (stated in its most recent adds)."

      However, the Rainforest Alliance fails to mention to what returns this "secret" report is referring to, in comparison to the returns mentioned in the policies signed by investors. In the "secret" report mentioned by the Rainforest Alliance, the rates of return seem to be based on a whole range of factors. The Rainforest Alliance's own statement indicates:
      "In his economic analysis, the Smart Wood consultant independently calculated projected returns using a number of key factors that help clarify the basis of the Flor y Fauna and OHRA financial forecasts. These factors include a more fully developed market strategy, value-added production facilities capable of producing a wide range of products, available technology capable of processing roundwood down to 5 cm diameter, and improved product mix and wood utilization over time".

      On the other hand, investors subscribe to policies which clearly delimits their rights strictly to revenues from cuttings of standing timber. In addition, the 1993 Teakwood VI brochure explicitly states that the projected revenues (then 15-25%) are based on proceeds from standing timber alone. This brochure leaves open the possibility of higher rates of return, should further processing take place, but explicitly excludes these possible additional revenues from the projected 15-25% rates of return on investments. These are based solely on the proceeds of standing timber.

      The Rainforest Alliance argumentation that the expected rates of return would not be affected by lowering the yield forecasts by half or more is only possible by comparing 'apples and oranges'.

      THE SCOPE OF CERTIFICATION

      It has never been suggested that the Rainforest Alliance, or any other certification program, should guarantees specific financial returns from forest management operations anywhere. That is obviously not the intent of certification, and has not been proposed or implied by anyone, as far as I am aware.

      It is true, though, that the Rainforest Alliance's Smartwood Program, like other certification programs, is expected to operate according to the Principles and Criteria approved by the Forest Stewardship Council. The FSC statutes indicate that a balanced consideration of social, environmental, and economic issues forms the core of FSC's activities. In addition to that, FSC Principle 7 explicitly indicates: "The long term objective of management, and the means to achieve them, shall be clearly stated"

      The fundamental objective of the Flor y Fauna teak plantations is the achievement of a certain financial return, based on specified projections on yields and prices. Expected returns form a particularly important objective in this case, due to the sale of policies to the general public, based on advertisement and promotional material which explicitly highlight the high revenues to be expected. The same general public, as a matter of fact, from which we expect trust and credibility in the certification process in general, and in the FSC in particular.

      In compliance with FSC Principles, then, the means to achieve this fundamental objective should have been properly and thoroughly assessed during the certification process. This should apply, at the very least, to the question of yields.

      The certification of Flor y Fauna by the Rainforest Alliance is obviously a formal endorsement of the company's projections on yields, prices and rates of return. This is a logical and legitimate interpretation by the public. Specially if no reservations were made to this effect when the certificate was issued.

      Furthermore, the Rainforest Alliance has publicly referred to this project as "... an impressive combination of social responsibility and economic viability" [Ref. 15].

      OHRA has also insisted publicly that:
      "Our projections and assumptions are extremely well substantiated. This was proven by recent independent research by the Tropical Science Center and the Rainforest Alliance..." [Ref. 16]

      Nonetheless, the Rainforest Alliance argues that their main concerns during the certification process were that:

      • The operation was silviculturally sound.
      • Environmental benefits were maximized
      • A positive impact on local communities and F&F employees

      This is possible, while still violating FSC Principle 7.

      Despite what it is argued to be an emphasis on silvicultural, environmental and social issues in the Rainforest Alliance certification program, the scope of the economic analysis included in this assessment has been presented to the public as rather thorough. In a brochure published by WWF-NL and IUCN [BOS INFO, October 1995] the director of the Rainforest Alliance is quoted as follows, with relation to Flor & Fauna:
      "Richard Donovan emphasized that certification processes encompass more than ecological criteria. He qualified the project as an impressive combination of social responsibility and economic viability"

      On July 29, 1996, the Court of Appeals of the Advertising Standards Committee of The Netherlands, brought a final settlement to two of the points of controversy in the teak scandal raging there: the false claim to an FSC certificate, and the misleading nature of advertisements on rates of return, both used to lure the general public into investing in Flor y Fauna's plantations.

      In a press release of July 31, 1996, following the ruling mentioned above, which clearly refers to rates of return, OHRA insists: "Our projections and assumptions are extremely well substantiated. This was proven by recent independent research by the Tropical Science Center and the Rainforest Alliance..."

      Since none of these statements have been objected by the RA, it seems legitimate to conclude that the Rainforest Alliance directly supports, or in the worst case allows its name to be used to provide support, to the allegations of its client on rates of return. By default, so does the FSC, as the accreditation body involved.

      CONCLUSIONS
      The case involving Flor y Fauna, OHRA and the Rainforest Alliance portrays the mismanagement of certification to provide "green" credibility to a project based on fundamentally flawed assumptions, with many of the characteristics of a case of fraud. It also highlights the difficulties with implementing credible certification programs, as well as the challenges involved in the operation of reliable accreditation systems, capable of efficiently assessing potential certifiers, and of adequately monitoring their activities.

      REFERENCES
      1]. Centeno, J.C: ECONOMIC ANALYSIS OF FLOR Y FAUNA'S TEAK PLANTATIONS IN COSTA RICA. Assessment Report prepared by request of WWF-International and WWF-Netherlands. December 1993.
      2]. Centeno, J.C: TEAK CONTROVERSY FLARES UP IN THE NETHERLANDS. Posting to Internet, February 05, 1996. 3]. Centeno, J.C: TEAK STING. Posting to Internet, February 19, 1996.
      4]. Centeno, J.C: WORLD RECORD ON TEAK GROWTH: TRUTH OR TRICKERY? Posting to Internet, March 12, 1996. 5]. Centeno, J.C: BLASTING THE FSC IN THE NETHERLANDS. Posting to Internet, March 1996.
      6]. Centeno, JC: THE ELUSIVE CREDIBILITY OF FOREST MANAGEMENT CERTIFICATION CLAIMS. Internet posting of June 20, 1996.
      7]. The Rainforest Alliance: Open letter dated December 28, 1996, actually received on February 1, 1996.
      8] Communication to the Rainforest Alliance of February 03, 1996, copied to the FSC Board and Secretariat. 9]. The Rainforest Alliance, February 22, 1996 open statement. 10]. WWF-NL: NAAR EEN HOUTBARE WERELD, 1996. 11]. DE TEAK PLANTAGES VAN FLOR Y FAUNA SA IN COSTA RICA. A.J.M. Wouters, Ministry of Agriculture of The Netherlands, December 28, 1993.
      12]. Flor y Fauna: TEAKWOOD III: AN INVESTMENT IN A GREENER FUTURE.
      13]. Flor y Fauna - WWF-NL: TEAKWOOD VI: EEN INVESTERING IN EEN GROENERE TOEKOMST. March 1993.
      14]. CCT: TECHNICHAL AUDITING ON THE GROWTH AND YIELD PROJECTIONS FOR TECTONA GRANDIS PLANTATIONS ESTABLISHED BY FLOR Y FAUNA S.A. Second Preliminary Report. February 1996. A Summary.
      15]. BOS INFO, October 1995
      16]. OHRA's press release of July 31, 1996


      November 04, 1996

      JULIO CESAR CENTENO
      Tel: Int+58-74-714576
      Fax: Int+58-74-714576
      Email:JCenteno@ciens.ula.ve


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