Small-Scale Environmental Impact Assessment in Japanese Private Industrial Forest － A SWOT
Analysis Based on Risk Management Processes

Dennis GAIN＊

Abstract
Environmental impact assessment (EIA) has been an established measure to mitigate environmental risks invarious larger construction projects around the world. In Japan, the management of private industrial forest ishighly dependent on governmental financial stimulus which has led to a planned top-down management
scheme guided by the Ministry of Agriculture, Forestry and Fisheries. However, the identification, prediction,
evaluation, and mitigation of potential environmental hazards due to human action in forest ecosystems inJapan is currently not a component within the scope of management of local private industrial forest. The
purpose of this study is to analyze the potential of implementing the recently established Japanese forester
system into the collaborative risk management process of Local Expert Risk Mediation (LERM) for the
possibility to introduce environmental impact assessment at a l-scale in local private industrial forest. A
grounded-theory approach was conducted by collecting qualitative data from local forest officials. It was
found that at the current time activities by foresters are usually limited to enhancing the efficiency ofroundwood production, and therefore do not show characteristics compatible to the early stages of EIA. This is
likely to the fact that management shows strict top-down characteristics. An implementation of foresters totake role of mediators within the core of LERM has, from a theoretical and practical perspective, the potential
to enable bottom-up management, and therefore allow room for the implementation of EIA in small-scale
private forestry.
Key words: sustainable forest management, mediation, policy decentralization, Japan

1. Introduction
For more than a century, forest planning in Japan has been the essential method to implement forest
management strategy and policy at local level. The Japan Forest Planning System (JFPS), setting out national
forest management plans for private and non-private forests in prefectures throughout the nation, takes over
the administrative role of implementing national forestry visions and goals. Forest planning in Japan has been
essential for a variety reasons. (1) Japanese forest policy is arranged in forestry related laws, all pointing out
the significance of multi-functional forestry, however, enforceability is highly limited at the local level. (2)Regional and local forest plans are dynamic and regularly renewed based on the developing and environmental
conditions of forests. (3) Financial support schemes for the implementation of forest management actions inprivate forests such as thinning and rejuvenation are embedded in the JFPS. However, with the current
worldwide trend towards the promotion of Sustainable Forest Management (SFM), the participative role ofprivate forest owners in forest management decisions has become a significant requirement in local small* National Institute of Technology, Kochi College, Dept. of Social Design Eng., Associate Professor
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scale management decision making to achieve a shift from forest exploitation to sustainable forest use.
However, such a shift is likely only to be realized with adequate local incentive-based policies, and guidance.
The recently introduced Forester scheme by the Ministry of Agriculture, Forestry and Fisheries wasestablished to facilitate its vision of creating a secure environment for future generations. Previous research
conducted by the author suggests that forester qualifications were predominantly taken by officials working atforest owners’ associations (FOA). Despite these new foresters possessing the qualifications for influencing
sustainable management decision at the local level, it appears that most of these officials returned to theirprevious jobs resuming the work they performed prior to taking the forester qualification, without or little
adaptation to activities that would influence a shift toward a more sustainable forest use. The purpose of thisstudy is to conduct a follow-up institutional analysis, and mainly discuss the applicability of pairing thecurrent forester scheme with Local Expert Risk Management (LERM), a mediation-based risk management
structure developed by the author in 2018, as can be seen in Figure 1, and as described in previous research. In
this analysis, the concept of LERM shall provide guidance at the local level for forest management actions thatwould consider environmental aspects in decision-making related to forest intervention incorporating EIA,
and therefore, improve the likelihood for a sustainable management outcome as it is defined in international
context.

Figure 1: Local Expert Risk Mediation Process

2. Methodology
This study follows a grounded theory approach with open coding. Officials and foresters at two forestry
related government and non-government offices in Kochi Prefecture were interviewed on two systematic
issues (1) the Strengths, Weaknesses, Opportunities, Risks, and implementability for incorporating EIA to the2Small-Scale Environmental Impact Assessment in Japanese Private Industrial Forest － A SWOT Analysis Based on Risk Management Processes

current purview of foresters, and (2) the Strengths, Weaknesses, Opportunities, Risks, and implementability
for incorporating the new forester purview into LERM as a means to take the role of Risk Mediation for
stimulating decision-making processes between a) the private forest owner, b) the forest owners’ association,and c) the decision-making body for granting subsidies for forest work at the forest department of theprefectural government. Following coding, data was summarized in a SWOT grid separately to each
respective party. Finally, relations between items within the finalized SWOT grid were identified anddiscussed.

3. Results
It was suggested in the Introduction that the concept of LERM could have the potential to provide
environmental and sustainability guidance at the local level to influence forest management decision-making
processes by focusing on forest intervention incorporating EIA.

Figure 2: SWOT analysis based on EIA and forester integration into LERM
It was found that the involvement of foresters in taking the role of risk mediators to perform EIA may hold an
opportunity but also a weakness. The opportunity being that foresters would currently fill the empty gap of
performing EIA and risk mediation within LERM. The weakness is that the purview of foresters is currently
limited to the efficient production of roundwood rather than an efficient production of ecosystem services.
The strengths of EIA and forester integration into LERM were reported to be local-level centralization which
could interfere and pose compatibility issues with the forest planning of the Ministry of Agriculture, Forestry,
and Fisheries due to its top-down management approach with management decisions being made at thenational level. Another strength may be that a change of forest legislation may not be required to produce
sustainable outcomes, because centralized mediation, if successful, can lead to consensus among mainstakeholders, as these are incorporated in the decision-making process.
As for Opportunities, the prospect of foresters as independent mediators applying EIA during consensusbuilding processes among stakeholders, was reported to potentially lead to a restructuring of the current
subsidy scheme for forest works in private forest, in terms of limiting financial support for works for forest
exploitation and including support for alternative works that lead to sustainable forest structures focusing on
ecosystem services.
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Threats of EIA and forester integration into LERM were reported to be compatibility issues with MAFF forest
planning. Moreover, incorporating EIA and foresters into current decision-making structures is likely toincrease the cost of roundwood production which would affect regional competitiveness, at least in the shortand medium terms.

4. Discussion
4.1 Implementation scenario
Respecting the findings of the SWOT analysis demonstrated in Results, a possible implementation scenario of
LERM with EIA and forester integration is shown in Figure 3. The left illustration shows the currently
administered management scheme. The illustration on the right shows the LERM Forester EIA Risk
Mediation Scheme. The improvements are:(1) the workplace of the forester moves from the Forest Owners’ Association to the respective municipality
silviculture department. The forester becomes a public servant with decision-making authority regarding theassessment of the sustainability of forest as defined by international norm and issues EIA statements (EIS) to
the Prefecture Forestry Promotion and Environment Division. Based on the outcome of the issued EIS, thePrefecture discusses an appropriate forest management action plan under forester guidance, which is adequate
for each individual forest site. Subsidies for forest works are issued whenever appropriate. Suggestions for an
adaptation of the subsidy scheme to better serve a long-term sustainable outcome are communicated bottomup to MAFF. Forests structures being unique and non-comparable depending on site, enabling bottom-up

Figure 3: Current management scheme (left), LERM Forester EIA Risk Mediation Scheme (right)
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Small-Scale Environmental Impact Assessment in Japanese Private Industrial Forest － A SWOT Analysis Based on Risk Management Processes

communication between MAFF and the Prefecture allows for MAFF to better understand the resources
necessary for producing long-term sustainable outcomes.
(2) EIA is performed by the risk mediator (forester) as defined by international norm during site assessment.
Currently, this site assessment is solely performed by the Forest Owners’ Association. EIA is performed infour steps and involves the risk mediator, private forest owner, Forest Owners’ Association, and other forest
stake holding organizations focusing on environmental conservation, industry, and society. EIA is performedby the risk mediator and the municipality forest department and then mediated among stake holding
organizations in stages 9 and 10, as demonstrated in Table 1. The Environmental Impact Statement (EIS) will
act as the guideline to steer and facilitate decision-making. To implement decisions, subsidies are applied as
usual, whenever applicable. The current subsidy scheme is revised according to forest sustainability needs thatare revealed during LERM.

Table 1: Stages of EIA

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第68号(3) Forest owners keep their positions, however, take an active role in EIA Stages 9 and 10. Such a change inforest owner behavior has several managerial advantages. Currently, the forest owner takes a passive role indecision making processes. The subsidy scheme awards financial support in exchange for the forest owners’
authority to make decisions regarding the management of their forest land. This buyout of authority leaves theforest owner in a passive position.
4.2 Adaption of the subsidy scheme
For financial support strategies that involve sustainability risk, economic, environmental, or social, to beeffective they are required to be assessed upon predictability (Stage 7) and outweighed equally prior to
implementation. Stakeholder demand is varied and requires efficiently balanced policy and adequate
stakeholder mediation. Otherwise, the risk may occur that certain interest groups become favorized leaving
behind the interests of other stakeholders (12). This is a common phenomenon in Japanese forestry where forest
management decisions are usually made while excluding the stake of environmental conservation groups.
However, the implementation of these prerequisites of Sustainable Forest Management (SFM) seems to be
problematic. Japan’s legal framework does not allow the passing of legally binding prefecture-level forest
laws, and national forest policy addresses SFM in a very general and rather undetailed sense (3). In addition,
unlike other industrialized nations, Japan is not in possession of a forester system where foresters are given theauthority to enforce forest law, or at least hold a position that would be capable of acting as a source forprofessional silviculture information, let alone to act as a mediator to negotiate the demands of local
stakeholders. It is of general public interest to maintain vital forest, however, an internationally increasing
demand for roundwood may increase the uncertainty of forest management like never before (7). SFM delivers
the framework for sustainable development, but it is not a concept to eliminate uncertainty (8,1,15).
Sustainability risks continue to be a significant challenge in decision making processes and any centralized
top-down policy is an insufficient measure to address them (16). Decentralization of forest policy andmanagement seems to be the logical move towards successful implementation because of the uniquecharacteristics of every forest and surrounding habitats. Therefore, local policies and support measures shouldincorporate stakeholder assessment to see whether decisions are appropriate for the target environment (11).
The homogeneity of tree plantations and their negative effects on the production of natural capital should be
reevaluated, and proper mediation between private and non-private stakeholders will play an important role inthis process (13,14).
4.3 EIA within LERM
Including EIA in decision-making processes at the local level may have the potential to produce moresustainable decisions. Currently, decisions on how to perform forest interventions, as well as forest design are
predominantly made between the forest owner and forest owners’ associations. As both parties usually pursue
for-profit strategies, environmental factors are seldom considered. Foresters would take the role of mediatorsand perform EIAs that act as a guideline within the scope of LERM for the prefecture to award subsidies (seeFigure 3). As this would require communication about environmental matters, the need for a redesign of thecurrently used subsidy scheme may occur to improve the compatibility with decisions. Moreover, theinclusion of EIA would require the collecting and analysis of information from a wider range of stakeholders,such as environmental conservation groups, to administer it in the appropriate way. The chance is thatenvironmental conservation groups could become an active and essential part in the EIA and forest
intervention related decision-making process, since foresters being no experts in environmental issues,
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Small-Scale Environmental Impact Assessment in Japanese Private Industrial Forest － A SWOT Analysis Based on Risk Management Processes

wouldn’t be qualified in providing proper environmental advice, and therefore, not be in the position to
perform EIA. Mediation, however, may not produce successful outcomes in certain cases as the need forconsideration of environmental matters is momentarily not backed by enforceable policy.
4.4 Risk mediation and competency
The first step in implementing risk mediation in forest management may be a clear definition of risk-politics inwhich the central principle of management is formed. The central principle addresses the unique local
characteristics of forests, as well as the various demands of stakeholders. Risk-strategy refines and structures
the central principles into applicable action instructions. Like forester systems, risk mediation combines internand extern risk communication to act as a driving system that has the aim to effectively administrate among
stakeholders to produce fair and sustainable decisions. Vital in this approach is the unbiased treatment of risk
management as a dynamic process; identification → assessment → implementation → control →monitoring (6). Sustainability risks are not one-time phenomena and require constant monitoring and control.
However, for risk monitoring to become effective, an adequate level of risk competency is necessary. Risk
itself is an abstract construct lying somewhere between complete confidence and complete uncertainty andperception can therefore differ from individual to individual (5). The possession of an adequate degree of risk
competency is vital for managers and the local public to be able to assess risks and their possible outcomesover a wider spectrum, and to enhance local risk decision making processes. A risk management approach thatincorporates effective local stakeholder collaboration, a proper degree of risk competency, and with access tomarket and technology information, investment opportunities, unharmful promotion programs, andtransparent forest policy may be a more efficient forest management approach in terms of achieving
sustainability.
4.5 Sustainable involvement of private forest owners
Dynamics in Japanese domestic wood markets and policy development would make extended stakeholder
participation inevitable (17). There is an increasing loss of interest of private forest owners in forest
management that involves activities other than the creation of fast financial value. Even higher subsidies do
not seem to be enough of an incentive for active participation anymore (4,10). Therefore, the introduction of
new financial incentives for public forest management projects, as frequently introduced by the Japanese
forest planning system, bring about the elemental risk of merely “purchasing” forest owner participation (9).
These types of currently existing one-time agreements are not designed for a long-term relationship, andinterest shown by forest owners is in most cases simply for the present moment. If forest management projects
require participation of private forest owners, long-term active involvement should be targeted to avoid such aloss of interest. As other research has observed, the reason for lack of active long-term participation is in theleast cases lack of capital, but instead lack of available information on available market chances, access tosilvicultural technology, forest law development, and taxation support. Investments that would have been
made by private forest owners themselves with proper advice and guidance are lost with one-time subsidy
projects (2). To achieve a condition in which communication with and among multi-stakeholders is effective, ashift from passive to active forest owner participation in management issues is likely to be unavoidable in thelong term.

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5. Conclusion
As stated in Introduction, the purpose of this study was to discuss the applicability of pairing the current
forester scheme with Local Expert Risk Management (LERM), and conduct EIA at the local-level in order torealize alternative management approaches that focus on forest as ecosystems, rather than predominantly areas
for the industrial production of marketable roundwood. The SWOT analysis provided insight into the pros andcons of how foresters could apply EIA at the local level while mediating sustainable forest management
approaches among stakeholders. While a shift from top-down management to LERM may lead to production
inefficiencies for the short and medium terms, it is clear that LERM may have the potential to realize
management structures and outcomes that are conform with international sustainability standards in the longterm, even without or a minor need for policy adaptations. Nevertheless, implementation of LERM may face
the challenge of being rejected by local authorities if the advantages of LERM cannot be communicatedeffectively. Rather than presenting the concept of LERM at the executive level to organizations individually, it
may be necessary to discuss the advantages simultaneously to allow room for interaction.

Future research
Future research is highly encouraged and should include follow-up work on the complicity in how mediationand EIA are to be executed, which incorporates equal rights communication and decision-making processes
among stakeholders through collaborative risk management. Especially the consultative role of risk mediation
regarding authority structures, decision making processes, as well as the formulation and access to long-term
participation strategies should be included.

Acknowledgement
The author thanks the Japanese Ministry of Agriculture, Forests, and Fisheries, Shikoku Forest Management
Bureau, and Kami Forest Owners Association for their time to provide insight in administerial and practicalforest management practices, as well as to elaborate on issues related to this study.

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