A Blanket that Smothers?

If the inclusion of an entire genus in CITES Appendix II came as a shock to the lumber industry when Dalbergia was first listed following CITES’ 17th Convention of Parties (CoP17) in 2016, then the decisions made in CoP19 of 2022 might be enough to send some into cardiac arrest. In total, four entire genera were blanket-listed in CITES Appendix II. Those genera are Dipteryx, Handroanthus, Roseodendron, and Tabebuia—woods that we would commonly refer to as cumaru and ipe.

But unlike the listing of Dalbergia, the broad protection of these new genera didn’t go nearly as smoothly, and were not received nearly as broadly as that of true rosewoods. So in the case of Dalbergia, all of the most popular species were also the ones leading the charge for inclusion into CITES Appendix II, with all the other peripheral and lesser-used species coming along for the ride. But for some of these genera (most notably, Dipteryx) nearly the opposite was true—less common species seemed to be leading the way, and taking with them the more widespread and popular species too.

To give some perspective on how unprecedented and sweeping these new changes were, this decision actually included a special 24-month preparatory period before being formally implemented (the CITES norm is just 90 days). This was done to give governments and relevant parties adequate time to implement and comply with all the new regulatory changes that would need to be made.

Getting to “Endangered” Status

When it comes to the term “endangered” there are two groups that deal with these sorts of issues—both have really long names, and both use acronyms. First (as previously mentioned) is CITES, which is the Convention on International Trade in Endangered Species. This group very much has a say on the legality when a wood species crosses international borders. There are basically three levels of protection or restriction that CITES has established which they called Appendices. See my related article on Restricted and Endangered Woods for a more detailed explanation of these levels.

But undergirding all this, there is the IUCN, or the International Union for Conservation of Nature. This group can be thought of more as assessors or advisors, and they mainly just observe population trends and evaluate different tree species and their likelihood of going extinct. They do this through a work called the IUCN Red List of Threatened Species. But it’s important to note that the IUCN’s evaluation, when taken on its own, has absolutely no legal impact whatsoever. These are just observations.

Case in point, just in the last ten years, a tree species literally in my own backyard in Minnesota has been listed as “critically endangered” by the IUCN, basically the most at-risk category there is. This at-risk species would be ash, due to the emerald ash borer. Just because it’s been listed on the Red List doesn’t have any legal ramifications in and of itself. Of course regionally there might be local restrictions on transporting firewood, or logs with bark still on them, etc., but in terms of the IUCN assessment directly, it bears no actual legal authority.

So for woodworkers, architects, or consumers/end-users of wood, the Red List could be a good gauge in terms of ethics. If you believe strongly in absolute sustainability, then you could use these ratings to guide your purchasing decisions. (Or better yet, since it’s very easy to misinterpret these ratings, see my article on the Most Sustainable Woods.)

The Underlying Data

Despite the IUCN’s role being more or less limited to assessors, the fact of the matter is that they do inform a lot of the decisions that CITES makes, so their observations have a lot of sway. And one of the central assessments that has caused ipe to become restricted under CITES appendix II is the IUCN’s most recent assessment of Handroanthus serratifolius—currently the main species supplying commercial ipe lumber.

For reference, the IUCN’s thresholds for population decline for the primary Red List categories are:

• 80%+ Critically Endangered
• 50%+ Endangered
• 30%+ Vulnerable

But one potential shortcoming with the IUCN is that a lot of their definitions are written for animals, and are based on population decline percentages from “the last 10 years, or the last three generations, whichever is the longer…”^[3]IUCN. (2012). IUCN Red List categories and criteria, version 3.1, second edition (p. 16). IUCN Species Survival Commission. With a tree’s lifespan, this would immediately throw out the 10 year threshold, but with trees, it can be very hard to define a “generation,” much less three generations. So with trees, many times the IUCN is dealing with periods of time spanning many decades, or even centuries. (For instance, the most recent assessment for bigleaf mahogany sets a “generation” at 60 years, hence the tri-generational window of time is set at 180 years^[4]Barstow, M. & Negrão, R. 2023. Swietenia macrophylla. The IUCN Red List of Threatened Species 2023. Accessed on 09 December 2024.—a date that predates the American Civil War!) But for many tree species, especially those that have not had as long a history of exploitation, or as well-documented a decline in population, there may not be enough data to do a proper assessment.

Fallback Option: Forward-looking Estimates

On most IUCN listings, you’ll see a letter and number code next to the listing, like “Endangered A1+2.” That “A” means the assessment was based on population trends (while “B” would refer to the geographic range of the species, and C and D deal with the actual count of remaining specimens left). Usually, A1 and A2 are the most common reasons for a commercial lumber tree species to be Red Listed (and probably the most preferred in terms of robustness of data). An A1 or A2 designation means the IUCN used past data—i.e., it’s based on “an observed, estimated, inferred or suspected population size reduction” in the past three generations.

But the IUCN also has designations (A3 and A4) that flip the equation around and use forward-looking estimates rather than past data. If the originally animal-centric criteria of three generations seemed a bit out of hand when looking at past data for trees, then it’s all the more exaggerated when trying to predict future population levels. Thankfully, the IUCN puts a special cap on the forward-looking estimates at 100 years—but it’s still a rather ambitious timeframe to attempt to predict.

Listing Ipe as Endangered

One point of contention is that the IUCN’s 2021 listing for ipe (Handroanthus serratifolius) was based on future projections, it was listed as “Endangered A3+4.” So rather than relying on any concrete past population trend data, the assessment relied on estimates of population trends going out until the year 2120.

Here is the text of the justification given by IUCN (with my own emphasis added).^[5]Hills, R. 2021. Handroanthus serratifolius. The IUCN Red List of Threatened Species 2021. Accessed on 09 December 2024.

Handroanthus serratifolius is a tree species that is widely distributed in South America. It has an extent of occurrence (EOO) estimated to be 12.4 million km². Species of Handroanthus, Tabebuia and Roseodendron are traded as a timber under the name ipê which is increasingly being exploited unsustainably. Illegal logging and habitat loss are also significant threats to this species. Handroanthus serratifolius is by far the most comonnly traded species of ipê. The species is therefore considered to be threatened by international timber trade. There is considerable pressure on sources of ipê timber due to the value earned from its sale, and the decline in other tropical timber producing tree species such as Big Leaf Mahogany (Swietenia macrophylla). The industrial development of the Amazon is also a major threat to H. serratifolius with some states in Brazil having experienced forest cover loss of over 20% between 2002 and 2019. This species is also considered slow to regenerate, contributing further to population decline. Threats to the species are continuing and may grow in the coming decades, therefore it is suspected that this species will experience a population decline of at least 50% over the next 100 years. The species is globally assessed as Endangered. It is essential that trade in this species and other sources of ipê is better monitored. Survey in the wild is needed to confirm the scale of loss and better inform management plans of the species. Cultivation both for conservation and sustainable use is needed.

Perhaps this justification has been worded intentionally cautious, but I couldn’t help but get the impression that a lot of assumptions were being made in this assessment. For instance, threats to this species were both “continuing” but also “may grow in the coming decades” seems to imply that quite a pessimistic model was being employed in the assessment.

Reading Between the Lines: We just don’t like you

So why would the IUCN choose to use these future-looking A3+4 predictions on a listing of such high profile? I can think of three possibilities, which I’ll list not necessarily in order of probability, but in order of most charitable and giving the benefit of the doubt, to the least:

1. So the most charitable interpretation of this is that they don’t have enough data of population levels in the past to show how many trees there were, so and they can’t do an adequate analysis. Thus, in good faith, they turned to future estimates, and honestly found that with the given data, the trends pointed to endangerment (the 50% threshold within 100 years.)
2. The second, still relatively charitable interpretation is that there was insufficient long term past data, and there was also a sharp rise in demand recently, and that if you extrapolate THAT data set out 100 years, you get a much more compelling case for endangerment than medium-term data, that may have been occurring at a slower pace.
3. The third, and most suspect rationale is that they had adequate past data, and it wasn’t convincing enough. Reading between the lines, an A1 or A2 listing would be much preferable and more objectively sound. And resorting to A3 or A4 on would imply that when the past data and numbers were crunched, there wasn’t sufficient evidence to show such a level of population decline. So instead, this assessment was based on very select, or “cherry picked” data, which could successfully project the needed future population decline of the species.

For now, we’ll give them the benefit of the doubt, but let me go back to this tree right here. Tabebuia rosea. If I were to cut this tree down and use its wood, expecting ipe, well, I’d be pretty disappointed. The wood has an average density of about 39 lbs/ft3 (620 kg/m3), while commercial ipe, tends to be around 60-70 lbs/ft3—nearly double this tree.

Things brings up another contributing factor, which is the problem of lookalikes. Most scientists recognize that individual species in these affect genera are very difficult to tell apart. And due to a loophole in the CITES listing rules, if you can show that one species is at risk and needs to be protected, you can by extension have that stretch out to all lookalike species.

So what this leads to is an imbalance in all sort of ways.

Take for instance, where this resolution was passed, and where it was held. It was in Panama, which coincidentally was the chief co-sponsor of this proposal for Ipe. Now in some nations, like Panama and Colombia, they may be having real struggles to control illegal logging. Whereas Brazil, at least according to their own representatives, did not. But just consider the imbalance here:

Brazil                           Panama

Econ    $2t (24x)                     $84b

Pop      216m (48x)                  4.5m

Area    8.5m kg2 (113x)          75k kg2

So when every country has an equal vote, it seems pretty unfair, even from an economical or political standpoint. For the record, the United States and Brazil both opposed this listed, as well as other South America countries including Bolivia and Guyana.

Now if you think Ipe was possibly a bit heavy handed, cumaru’s inclusion was even more eyebrow raising. Because the data from the IUCN was even more shaky here.

Only eight Dipteryx spp. have been globally assessed against IUCN Red List categories and criteria (see Section 4.4). Of those that have been assessed, two (D. alata and D. charapilla) were considered Vulnerable (WCMC, 1998a; WCMC, 1998b), one (D. polyphylla) was considered Near Threatened, and two were assessed as Data Deficient but in decline (D. micrantha and D. odorata, Requena Suarez 2017a; 2017b). However, even among the three species considered globally Least Concern, two assessments (D. lacunifera and D. punctata, BGCI and IUCN SSC, 2019a; BGCI and IUCN SSC, 2019b) were data poor and the third species, D. oleifera, is considered nationally vulnerable in several range States (Estrada Chavarría et al., 2005 in Fliesswasser, 2014; Cardenas and Salinas, 2007; Government of Panama, 2016a).

So in listening to the proceedings, this imbalance became even more pronounced. And it was very hard to assign proper weight to all the claims. For instance, if a place like Panama (or even Colombia, at 1/7^th the size of Brazil) they speak of particular species in decline locally, but not globally, you can see how things can be put into a wrong proportion.

I just want to highlight a comment Brazil made in the proceedings that I think encapsulates this the best:

“…in Brazil (and allow me to say it again) the country is the biggest population of Dipteryx. The most recent studies and analysis carried out by renowned institutions like the Brazilian Agricultural Research Corporation (Embrapa) did not find any current risk for the populations that are commercially exploited in the country.

This is even more evident when we observe that the last update of our official list of Brazilian official list of species of flora threatened with extinction carried out in June of the current year [2022, CITES discussion was in November 2022] did not include any species of these

Genus. Therefore, in our view the approval of proposal 48 would imply the loosening of the criteria for inclusion of species in the appendices of CITES, weakening the mechanisms for implementing the convention’s rules. Consequently, it would also set a dangerous precedent for the convention, harming all parties who put faith in undue and scientifically unfounded restrictions on their international trade.”

He said it very politely, but that’s basically a gut punch to the stiff scientists that were there.

So it’s a confused, tangled mess. They can’t tell any of the species apart, so the entire genus, in all countries, are protected. Even ipe and cumaru would be very difficult to tell apart, and they were considered in separate proposals.

I should add, these trees growing in very spread out regions, and necessitate clear cutting large swathes of forest. So if done irresponsibly, you can see how that would clear out a lot of forest area. But I can’t help thinking that this was possibly not the best way to go about solving the problem.

What does this mean going forward?

I don’t know, today’s the first day. As I said, appendix II isn’t a death sentence, but it does increase the amount of paperwork and administrative burden that will need to be done. Put simply, law of supply and demand, supply will go down, demand would remain, meaning higher prices. But I don’t foresee things becoming impossibly expensive or unobtainable.