**8. Lessons learned**

Almost a decade after the development of the SFM strategy framework for Galicia, while it can be said that much has been accomplished with regard to its implementation, it must be admitted that much more needs to be done. Although the complex political and jurisdictional situation in Galicia (as is described below) has contributed to slow and incomplete progress in the implementation of a SFM strategy in Galicia, in the authors' opinions the major direct contributing reasons for this state of affairs has most to do with three major deficiencies in the strategy framework development and/or implementation processes: the insufficient public participation, the lack of clarity with respect to the appropriate roles of major players, and insufficient legislative underpinnings. All of these are described below as "lessons learned", though it should be recognized that our lessons are likely far from complete.

**Lesson One – Earlier and More Complete Public Participation:** Originally, the intent was to present an initial, but comprehensive, draft strategy as a "straw man" or "white paper" to be revised based upon the suggestions and comments, but this has not worked since many stakeholders felt that they were being presented with a "fait accompli". While the DXM forest administration may have the broadest understanding of the situation, it cannot assume that it knows, a priori, all of the major problems in the region's forest sector. The principal forest stakeholders demand that government officials first ask them their opinions concerning the main issues, problems (or potential market opportunities) before beginning to design and develop systems, instruments, tools to satisfy them. Although it is the responsibility of the government to define policies, it is critical that the principal stakeholders are consulted at the outset in order to avoid subsequent rejections or negative political influences. Therefore, it is now felt that it was a mistake not to work with major stakeholders (perhaps by means of workshops and advisory groups) to identify issues and directions BEFORE drawing up any draft document.

**Lesson Two – Clarification of Roles:** While there are several levels of government and government administration that impact SFM in Galicia (the Spanish national government,

Concerned by the situation regarding Forest and Chain-of-Custody certification, in 2009 the Galician forest industry, in cooperation with some forest owners associations, founded a Forest Certification and Chain-of-Custody Group, (Grupo Galego de Certificación Forestal e Cadea de Custodia or CFCCGA) aimed at achieving certification for small forest owners (under PEFC and/or FSC) and designing a due-diligence system that would comply with the imminent introduction of the Commission Regulation (EC) No 1024/2008. According to CFCCGA (2009a), in less than two years, more than 4,500 forest holdings (with an average size of 0.7 ha) have joined the group, making this initiative the first and only one to date which has been able to implement forest certification for small forest owners in Galicia. The aims and actions of this group are relevant to this paper because they can be seen as an attempt by a stressed private sector to take more responsibility for and ownership of broad SFM initiatives despite the fact that the SFM strategy framework developed by DXM has not been fully implemented. It is notable that some of the tools and processes developed by this group, namely Grouped Management Plans (Picos, 2010a), Best Management Practice codes (CFCCGA, 2009b) and Silvicultural Models for major forest species (CFCCGA, 2009b), are quite similar to the FDMPs, BMPs and SMs proposed in the Sustainable Forest Management

Almost a decade after the development of the SFM strategy framework for Galicia, while it can be said that much has been accomplished with regard to its implementation, it must be admitted that much more needs to be done. Although the complex political and jurisdictional situation in Galicia (as is described below) has contributed to slow and incomplete progress in the implementation of a SFM strategy in Galicia, in the authors' opinions the major direct contributing reasons for this state of affairs has most to do with three major deficiencies in the strategy framework development and/or implementation processes: the insufficient public participation, the lack of clarity with respect to the appropriate roles of major players, and insufficient legislative underpinnings. All of these are described below as "lessons learned", though it should be recognized that our lessons

**Lesson One – Earlier and More Complete Public Participation:** Originally, the intent was to present an initial, but comprehensive, draft strategy as a "straw man" or "white paper" to be revised based upon the suggestions and comments, but this has not worked since many stakeholders felt that they were being presented with a "fait accompli". While the DXM forest administration may have the broadest understanding of the situation, it cannot assume that it knows, a priori, all of the major problems in the region's forest sector. The principal forest stakeholders demand that government officials first ask them their opinions concerning the main issues, problems (or potential market opportunities) before beginning to design and develop systems, instruments, tools to satisfy them. Although it is the responsibility of the government to define policies, it is critical that the principal stakeholders are consulted at the outset in order to avoid subsequent rejections or negative political influences. Therefore, it is now felt that it was a mistake not to work with major stakeholders (perhaps by means of workshops and advisory groups) to identify issues and

**Lesson Two – Clarification of Roles:** While there are several levels of government and government administration that impact SFM in Galicia (the Spanish national government,

Framework for Galicia.

**8. Lessons learned** 

are likely far from complete.

directions BEFORE drawing up any draft document.

the regional government, the provincial government and the 315 local municipalities), all of which could lead to confusion and problems, the authors believe that it is the lack of clarity regarding the roles of local municipalities, in particular, that impeded the implementation of the proposed strategy framework. For example, local municipalities regularly endorse plans, laws, decrees and regulations that regulate (ban or allow) harvesting operations, plantations and/or specific forest species in ways that contradict the Galician government's plans and laws. On the other hand, there is resistance at higher levels of government to the creation of district SFM committees for SFM due to fears that some local representatives may use these committees to advance political platforms or pressure the government for funding that is not related to SFM objectives. Therefore, before undertaking this process, the roles and responsibilities of the various levels of government (and the reasons for these as they relate to critical competencies with respect to SFM decision-making) should have been clarified and made explicit in a legal framework – preferably one that would advance sustainable management and reduce political manipulation.

**Lesson Three – Legislative Support:** Given the legislative changes required to ensure advancement of such a significant and politically sensitive initiative, it is necessary to receive full political support by the government in power right from the beginning of the process, and continuing support over the implementation period. Unfortunately, the large number of significant actions required to implement the strategy meant that inadequate progress was made before the elections of 2005, when there was a change in the Galician government, at which time the new government had to be educated regarding the strategy framework and the details of its proposed implementation. While progress continued to be made, it was slow and was then again slowed when another new government was elected in 2009. For these reasons, we believe that it would have been advisable to begin the strategy development and implementation process at the beginning of a political mandate and obtain broad political support so that any changes in government would be less likely to impede progress.

**Lesson Four – Operational Priorities and Organizational Gaps:** There are practical problems that impeded the DXM from making a sustained effort to manage and control the continued development and implementation of the new SFM strategy. The DXM has two main responsibilities: to develop and implement forest policies, and to prevent and fight forest fires. The principal forest stakeholders have persistently claimed (Monte Industria et al., 2008a; Monte Industria 2010b; Picos, 2010b) - that 95% of the time of a district director is taken up with organizing and managing forest fire fighting brigades during fire season, while forest services company associations have complained that all the technical staff of forest districts are fully occupied with fire detection and fire-fighting responsibilities from at least July 1st to September 30th, and in bad weather conditions the main fire season period may be further lengthened significantly.

While these complaints may be somewhat exaggerated, it must be recognized that the individuals and units tasked with implementing forest management practices at the district level are preoccupied with fire prevention and fighting for up to six months of the year. This significantly reduces the time and attention they have available for overseeing the implementation of new forest management strategies. It should be recalled that, within the proposed strategy (and generally), district-level staff are expected to:


Sustainable Forest Management in Galicia (Spain): Lessons Learned 235

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CFCCGA (2009b) Grupo Galego de certificacion Forestal e Cadea de Custodia. Documentos

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c. monitor and control the progress of on-the-ground management plans and related actions.

Instead, however, technical staff members in districts are almost completely dedicated to fighting fires for up to half of the year. Therefore, in order to implement any new forest strategy in a coherent manner, it is necessary that responsibilities be changed so that some technical staff would be completely dedicated to forest management regardless of the severity of the fire season.

**Lesson Five – Advantages for Small Ownerships:** The implementation of a well-designed and supported SFM framework would boost forest certification in small non-industrial forestry settings. In Galicia, group and regional certifications are underdeveloped, in part as a result of the high degree of small, fragmented private ownership. It is important to note that the certification initiatives that have been most successful for small non-industrial private forest owners use documentation and processes that are very similar that those designed for the SFM strategy framework by DXM. This may indicate that a complete framework would aid to develop smallholder certification initiatives throughout the region and would reduce their implementation costs, which are a major constraint. Moreover, a SFM framework with a public participation may help auditors and group managers to verify and register the achievement of indicators and ease some of the required procedures. In addition, it also may be possible that strong public participation in the SFM framework development could help in objectively defining the certification requirements in Galicia and comparing them to what is required in other countries. This process could facilitate reviews and modifications to both FSC and PEFC national standards or, perhaps, enable the development of regional ones.
