Stakeholder Consultation: KPMG Forest Certification Services Inc. · 2020-05-07 · KPMG Forest Certification Services Inc. Box 10426, 777 Dunsmuir Street Vancouver BC V7Y 1K3 Canada

KPMG Forest Certification Services Inc. Box 10426, 777 Dunsmuir Street Vancouver BC V7Y 1K3 Canada

Telephone (604) 691-3000 Fax (604) 691-3031

www.kpmg.ca

To: Canfor Pulp Ltd. FSC® CoC/CW Stakeholders

October 26, 2017

Dear Stakeholder,

Stakeholder Consultation KPMG Forest Certification Services Inc. (KPMG FCSI) to conduct a Forest Stewardship Council® (FSC) Chain and Custody/Controlled Wood Re-certification Audit of Canfor Pulp Ltd.

Purpose and scope of the audit

KPMG Forest Certification Services Inc. (KPMG FCSI) will be conducting a re-certification audit of Canfor Pulp against the requirements of the current Forest Stewardship Council® (FSC) chain of custody (CoC) and controlled wood (CW) standards. A stakeholder consultation process is planned for the fall of 2017, with the main assessment occurring December 4-8, 2017.

Canfor Pulp holds a multi-site FSC CoC/CW certificate that includes the following sites:

• Pulp mills and paper mill in Prince George BC.

• Pulp mill in Taylor BC

The supply area for the above participating sites includes following the WWF ecoregions:

• Alberta-British Columbia foothills forests

• Canadian Aspen forests and parklands

• Mid-Continental Canadian forests

A map of the WWF ecoregions containing forest landscapes can be found at: http://worldmap.harvard.edu/data/geonode:wwf_terr_ecos_oRn

The audit will be based on the current FSC Chain of Custody (FSC-STD-40-004 V3-0), Controlled Wood (FSC-STD-40-005 V3-1), and Multisite (FSC-STD-40-003) standards.

This letter serves as an invitation to interested and affected stakeholders who wish to provide comments that are pertinent to Canfor Pulp’s FSC CoC/CW certification. The comments received will be considered by KPMG FCSI in reaching its conclusions regarding Canfor Pulp’s conformance with the applicable FSC CoC and CW standards.

http://worldmap.harvard.edu/data/geonode:wwf_terr_ecos_oRn

Canfor Pulp Ltd. FSC® CoC/CW Stakeholders October 26, 2017 Page 2

About FSC and the CoC and CW standards

The FSC is an international non-profit organization founded in 1993 to support environmentally appropriate, socially beneficial, and economically viable management of the world's forests. It supports the development of national and regional standards to be used to evaluate whether a forest is being well-managed.

It is an association of members consisting of a diverse group of representatives from environmental and social organizations, forest and product industries, Indigenous People's organizations, community forestry groups and certification bodies from around the world. Membership is open to all who are involved in forestry or forest products and share its aims and objectives.

FSC, with its head office in the city of Bonn, Germany, is governed by an elected Board which consists of people from industry, environmental, social and labor groups, Indigenous People's representatives and others.

FSC-STD-40-004 V3-0 and FSC-STD-40-005 V3-1 were recently released for use by FSC. Organizations holding certifications to the previous versions of these standards must be assessed against the current version by December 31, 2017 (in the case of FSC-STD-40-005 V3-1) and March 31, 2018 (in the case of FSC-STD-40-005 V3-1).

Your role

We would appreciate your comments on issues that are pertinent to Canfor Pulp’s FSC CoC/CW certification. Such comments may include, but are not necessarily limited to, concerns or observations regarding the Company’s due diligence system (i.e., the system of measures and procedures developed by the organization to minimize the risk of sourcing material from unacceptable sources), one component of which is the company risk assessment (which FSC has decided may continue to be used until an approved national risk assessment for Canada is in place). Comments received will be considered by KPMG FCSI in assessing Canfor Pulp’s performance against the requirements of the applicable FSC CoC and CW standards. A summary of stakeholder comments will also be included in the Canfor Pulp FSC CoC/CW certification audit summary report.

A questionnaire is provided with this letter for your comments on issues that are pertinent to Canfor Pulp’s FSC CoC/CW certification. However, additional materials and other methods of communication will also be accepted. Upon request, arrangements may also be made to allow stakeholders to meet with members of the audit team during the on-site portion of the audit.

Access to information

FSC requires that stakeholders be provided access to certain information as part of the consultation process, including:

• A description of the supply area and respective risk designation. This information is includedwithin the body of this letter and the summary of the Canfor Pulp Due Diligence System (DDS).

• A written summary of the Canfor Pulp DDS. A copy of this document is available on KPMGFCSI’s website at https://home.kpmg.com/ca/en/home/services/audit/sustainability-services/forest-management-consultations.html

https://home.kpmg.com/ca/en/home/services/audit/sustainability-services/forest-management-consultations.html

https://home.kpmg.com/ca/en/home/services/audit/sustainability-services/forest-management-consultations.html

Canfor Pulp Ltd. FSC® CoC/CW Stakeholders October 26, 2017 Page 3

• Copies of the applicable FSC CoC and CW standards. These can be obtained from FSCInternational at https://ic.fsc.org/en/document-center/id/80 and https://ic.fsc.org/en/document-center/id/170. 3

• A copy of the current Canfor Pulp company risk assessments. These can also be obtained athttp://fsc.force.com/servlet/servlet.FileDownload?file=00P3300000ggkofEAA andhttp://fsc.force.com/servlet/servlet.FileDownload?file=00P3300000ggkqZEAQ. Note: Thecompany risk assessment is being finalized at the time of this writing. Once finalized by CanforPulp and approved by KPMG FCSI it will be posted to the above FSC website.

• The procedure for filing complaints. A copy of KPMG FCSI’s dispute resolution procedures areavailable on KPMG FCSI’s website.

• Contact information of the person or position responsible for addressing complaints. This canbe obtained by visiting the KPMG FCSI website noted above.

KPMG FCSI Contact information

All comments and requests for additional information should be directed to Yurgen Menninga by fax at 604-691-3031, or email [email protected].

Our commitments

1 The source of specific comments received will remain confidential unless the commenting party specifically indicates to the contrary.

2 We will respond to all stakeholders who provide comments and provide information on how their comments were taken into account.

3 A summary of stakeholder comments and how they were considered by KPMG FCSI will be included in the Canfor Pulp FSC CoC/CW certification audit summary report.

Yours very truly,

Yurgen Menninga Manager 778-986-3576

https://ic.fsc.org/en/document-center/id/80

https://ic.fsc.org/en/document-center/id/170.%203

https://ic.fsc.org/en/document-center/id/170.%203

http://fsc.force.com/servlet/servlet.FileDownload?file=00P3300000ggkofEAA

http://fsc.force.com/servlet/servlet.FileDownload?file=00P3300000ggkqZEAQ

mailto:[email protected]

Canfor Pulp Ltd. Procedure No. S-E-031

Controlled Wood Risk Assessment Procedure Owner: Sr. Director, Sustainability, Customer Service and Innovation Prince George Pulp and Paper, Intercontinental Pulp, Taylor and Northwood Pulp Mills' CoC Procedures

Revision: April 27, 2017 Page 1 The most recent version of this procedure can be found on the Intranet. A printed copy is an “Uncontrolled Copy”.

A printed copy may only be used for 24 hours after being printed off the Intranet

1. PURPOSE

The purpose of this due diligence system (DDS) maintained by Canfor Pulp is to meet the requirements set out under the Requirements for Sourcing FSC Controlled Wood (FSC-STD-40-005 V3-1) referred to in the remainder of this DDS as the ‘CW Standard’. Canfor Pulp Ltd. has conducted a risk assessment regarding the potential to procure illegally harvested wood raw material for the provinces of British Columbia and Alberta. While currently BC is the only source of wood raw material for CANFOR PULP LTD., the scope of the risk assessment covers both BC and Alberta and is coincident with the scope of sources of the log supply for Canadian Forest Products Ltd. which is CANFOR PULP LTD.’s largest raw material supplier.

2. SCOPE

The Canfor Pulp DDS supports the multi-site chain of custody certification currently registered under FSC Chain of Custody code KF-COC-001056 and FSC Controlled Wood code KF-CW-001056. The list of participating sites covered by the multi-site certification includes:

Prince George Pulp and Paper

Northwood Pulp Mill

Intercontinental Pulp Mill

Taylor Pulp Mill

Controlled wood and FSC Mixed Credit wood are the two FSC product groups Canfor Pulp intends to trade in. The FSC Product Types produced by Canfor Pulp eligible for an FSC Controlled Wood claim include:

• P1.1 (Mechanical pulp, bleached) • P1.3 (Chemical pulp, bleached) • P2.3 (Wrapping and packaging paper) • P1.4 (Chemical pulp, unbleached)

3. DEFINITIONS

Terms in italics are used in a manner as defined in FSC chain of custody standards and include but are not limited to:

Central Office: The identified central function (e.g. office, department, person) of a Multi-site or Group COC, that holds ultimate management responsibility for maintaining the certification contract with the certification body, for being responsible for upholding the Chain of Custody system and for ensuring that the requirements of relevant Chain of Custody certification standard(s) are met at the Participating Sites.

Controlled Material: Input material supplied without an FSC claim, which has been assessed to be in conformity to the requirements of the standard FSC-STD-40-005 V3-1 Requirements for Sourcing FSC Controlled Wood.

Due diligence system (DDS): A system of measures and procedures to minimize the risk of sourcing material from unacceptable sources. A DDS contains the following three elements: obtaining information, risk assessment and risk mitigation (when needed).

Participating Site: Site included in the scope of a multi-site or group COC certificate. Subcontractors that are used within the terms of outsourcing agreements are not considered Participating Sites.





4. DEFINED FIBRE SUPPLY AREA

The defined fibre supply area for the Canfor Pulp DDS are those portions of the ecoregions1 listed below that are located within the provinces of Alberta and British Columbia as detailed in Figures #1 and #2.

Fort Nelson Prince George

Mackenzie Quesnel

100 Mile Vanderhoof

Fort St. James Headwaters

Central Cariboo Alberta

Nadina Peace.

Other forest districts within BC should a procurement by considered

5. DUE DILIGENCE SYSTEM

Part I of the CW Standard requires the Canfor Pulp DDS to contain three elements: (1) obtaining information, (2) risk assessment and (3) risk mitigation (if needed).

In the supply of fibre to participating sites there are two fibre supply chains to consider: (1) co-product fibre or whole log chips obtained from 3rd parties under a Fibre Supply Agreement (2) pulp purchased for use in the mills from controlled sources or be SFM certified. Fibre that cannot be confirmed to be controlled material in accordance with Part I of the CW Standard is excluded from the fibre supply chain.

5.1.1. Fibre Sourced Through a Fibre Supply Agreement

All co-product fibre purchases or trades are done under a fiber supply or trade agreement which satisfies the information requirements of section 2 in the CW Standard. Most 3rd party fibre is received as residual fibre from 3rd party primary processing facilities, but occasionally is obtained from a 3rd party whole log chipping operation. The Fibre Supply or Trade Agreement (1) confirms that the fibre is sourced from within the fibre supply area identified in the risk assessment, (2) provides an assurance that any areas identified in the risk assessment as having ‘unspecified risk’ have been avoided and (3) allows for the FSC-accredited certification body to request additional information as needed to verify the origin. This is facilitated through a graphic illustration of the fibre supply area in an agreement exhibit consistent with Figures #1 and #2 that details the limits of the supply area and identifies any areas of ‘unspecified risk’.

5.1.2. Pulp Purchased from Controlled Wood Sources

Pulp purchased for use in the mills such as BCTMP or hardwood must be from controlled sources or be SFM certified. Suppliers are asked to provide evidence that this is the case.





5.1.3. Variances from DDS Fibre Origin Assumptions

Any variance from the fibre origin assumptions stated in sections 5.1.1 and 5.1.2 must be reported to the central office.

5.2. DDS – Risk Assessment

All residual fibre inputs into participating sites originate from within a fibre supply District that is confirmed as low risk and controlled material in accordance with Section 3 of FSC-STD-40-005 V3.1, as demonstrated by the multi-site FSC Controlled Wood risk assessment (Appendix A).

The Global Forest Registry (https://www.globalforestregistry.org/) provides a risk outcome at the national level for all five controlled wood categories and this outcome is ‘Low’ for categories 1, 2, 4 and 5: legality, traditional and civil rights, conversion to non-forest use and use of genetically modified organisms (GMOs). Conversely, controlled wood category 3 ‘High Conservation Values (HCV’s) is identified as having unspecified risk with specific mention of Global 200 Ecoregions (http://www.nationalgeographic.com/wildworld/profiles/g200_index.html) and intact forest landscapes (www.intactforests.org) being HCVs that are present. Additional ecoregionally significant HCV’s within the fibre supply district that are considered by the risk assessment are WWF terrestrial ecoregions that are not Global 200 Ecoregions but identified by WWF wildfinder (https://www.worldwildlife.org/science/wildfinder/) as having a status of critical or endangered and boreal and woodland caribou. The CW Standard requires the implementation of section 4 ‘Risk Mitigation’ where a low risk determination cannot be concluded. The risk assessment currently concludes a low risk outcome for all controlled wood categories; however, for some ecorgerionally significant (HCV) this requires the assessment of risk mitigation under Indicator 3.2 following a conclusion of ‘unspecified risk’ under Indicator 3.1. Section 4 of the CW Standard does not apply to risk mitigation at this stage of the assessment, only taking effect in the event that low risk cannot be concluded under Indicator 3.2.

5.2.1. DDS - Risk Mitigation Under 3.2

A low risk outcome for controlled Wood category 3 (ecoregionally significant HCVs) under indicator 3.2 is dependent upon demonstrating avoidance of specified risk (‘Risk Avoidance) or the management of risk through regulatory or voluntary measures (‘Managed Risk’). For each HCV the risk assessment (Appendix A) demonstrates how risk identified under Indicator 3.1 is mitigated through risk avoidance, managed risk or a combination of both,

5.3. DDS – Risk Mitigation Under Section 4 of the CW Standard

Control Measures to mitigate unspecified risk identified for a controlled wood indicator must be developed in accordance with Section 4 ‘Risk Mitigation’ of the CW Standard which in the case of unspecified risk for category 2 and 3 indicators also requires stakeholder consultation to be done in accordance with Annex B: ‘Minimum requirements for stakeholder consultation’.

Given that low risk is established under all five controlled wood categories the development of control measures in accordance with section 4 of the CW standard is not required,

5.4. DDS – Internal Audits

As required by section 1.7 of the controlled wood standard internal audits of the Canfor Pulp DDS will be conducted annually by Canfor Forest Management Group.

https://www.globalforestregistry.org/

http://www.nationalgeographic.com/wildworld/profiles/g200_index.html

https://www.worldwildlife.org/science/wildfinder/





Figure #1 – Fibre Supply Area with British Columbia









Figure #2 – Fiber Supply with Alberta





REVISIONS: R1 Title changes – January 24, 2012 R2 Pulp purchases added – April 18th 2012 R3 Title Changes, Name Change – June 4, 2014 R4 Header Change – February 23, 2015 R5 Title changes – May 12, 2016 R6 Complete update to comply with new FSC CW standard – April 27, 2017

Document Owner: Sr. Director, Sustainability, Customer Service and Innovation May 2017 Page 1

Canfor Pulp Ltd. PEFC ST 2002:2013 & FSC Controlled Wood Risk Assessment

Certificate holder: Canfor Pulp Ltd. Certificate holder address:

230-1700 West 75th Ave. Vancouver, BC, V6P 6G2

PEFC Chain of Custody Certificate #: 2563 Date of Annual Risk Assessment Review: (minimum annual review)

May 2018, unless origin changes (country/region level) or the level of risk changes.

FSC CW/CoC Certificate #: KF-CoC-001056/KF-CW-001056 Certification Body (CB): KPMG Performance Registrar Inc.

Date of Risk Assessment: May 2017 Date of CB Review: (i.e. date of last external audit)

Result

The risk assessment is based on PEFC ST 2002:2013, element 5.3 estimates the likelihood at the origin level and likelihood at the supply chain level and for the FSC-STD-40-005 V3-1 EN uses the indicators in that standard to estimate the risk at the supply area level.

As a result of assessment using the criteria presented in the standards the likelihood of procuring significant risk chips is estimated, for PEFC CoC as negligible at the supply chain level and at the country/region level and for FSC-CW, low at the supply area level.

Administrative Data

Geographic Area (Country/region) of procurement (forest districts as defined by the Province of British Columbia from time to time):

Hyperlink to MoFLNRO Region and District Map http://www.for.gov.bc.ca/mof/regdis.htm

Province of Alberta

Ecoregions1 covered in this assessment #2/Alberta-BC Foothills Forests, #3/Alberta Mtn Forests, #6/Canadian Aspen Forest & Parklands, #19/Mid-continental Canadian Forests, #21/Muskwa-Slave Forests.

Species covered in the risk assessment: Lodgepole Pine (Pinus contorta), Jack pine (Pinus banksiana), White Spruce (Picea glauca), Engelmann Spruce (Picea engelmannii), Hybrid White Spruce (Picea spp.), Balsam fir (Abies lasiocarpa), Aspen (Populas tremuloides), Balsam poplar (Populas trichocarpa), Paper Birch (Betula papyrifera)

Product/s covered in this risk assessment: Chips as measured in ODT’s. The PEFC product group is chips manufactured into NBSK pulp, thermo-mechanical pulp and wrapping/packaging paper.

The FSC product groups from which the chips are manufactured into that may contain the FSC CW or FSC Mixed Credit claims are: P1.1 (mechanical pulp, bleached, P1.3 (chemical pulp, bleached), P2.3 (wrapping and packaging paper), P1.4 (chemical pulp, unbleached)

This risk assessment updates the initial PEFC ST 2002:2010 and FSC-STD-30-010 V3-0 EN risk assessment. The risk assessment covers Canfor Pulp Ltd.’s fiber basket, a broadly defined geographical area from which softwood chips may be sourced in Alberta. The risk assessment is an annual risk assessment based on the criteria specified in PEFC ST 2002:2013, element 5.3.8 and FSC-STD-40-005 V3-1 EN. Canfor Pulp Ltd. shall review and, where necessary, revise this risk assessment on an annual basis. Revisions shall also be made where the origin changes (Country/region level – PEFC and Supply Area level – FSC) or the level of risk changes.

A Centralized National Risk Assessment (CNRA) exists for Canada that addresses Controlled Wood Category 1, 2 and 5 but not Categories 3 and 4. As a result the CNRA does not apply to certifications under legacy FSC-40-005 v2-1 and current FSC-STD-40-005 V3-1 EN and is of no force or effect until all five Controlled Wood Categories are addressed in the CNRA. https://ic.fsc.org/en/our-impact/program-areas/controlled-wood-01/controlled-wood-risk-assessments/fsc-risk-assessment-database

1 World Wildlife Fund – US, Terrestrial Ecosystems of the World, 2004, URL:http//www.worldwildlife.org/science/data.cfm

http://www.for.gov.bc.ca/mof/regdis.htm

https://ic.fsc.org/en/our-impact/program-areas/controlled-wood-01/controlled-wood-risk-assessments/fsc-risk-assessment-database%0c


http://www.worldwildlife.org/science/data.cfm


Controversial/Controlled Wood Definition

The intent of this risk assessment is to assess the fiber basket for the level of risk of procuring controversial or uncontrolled sources of chips. Controversial and controlled sources are defined as raw material from forests where the party completing the harvesting:

(a) does not comply with local, national or international legislation applying to forest related activities (i.e. illegal harvesting) in particular in the following areas:

forestry operations and harvesting, including biodiversity conservation and conversion of forests to non-forest use, management of areas with designated high environmental and cultural values, protected and endangered species, including species listed in CITES, health, safety and labour issues relating to forest workers, indigenous peoples’ property, tenure and use rights, third parties’ property, tenure and use rights, payment of taxes and royalties.

(b) does not comply with legislation in the country of harvest relating to environmental legislation, trade and customs in so far as the forest sector is concerned,

(c) utilizing genetically modified forest based organisms,

(d) converting forests to other vegetation types including conversion of primary forests to forest plantations.

Conflict timber is not considered applicable in Canada and North America based on international knowledge.


PEFC Risk Assessment Table One Indicators - positive results provide a negligible risk at the origin and supply chain level and result in the indicator being not applicable.

Indicator Rationale Determination

PEFC recognized certified logs - CSA Z909-08 & SFI 2015-2019 No risk of certified logs originating from a controversial source. N/A

Non PEFC recognized certified logs - FSC BC Regional Standard, October 2005

No risk of certified logs originating from a controversial source. N/A

PEFC CoC certified logs - PEFC ST 2002:2013 No risk of certified logs originating from a controversial source. N/A

SFI CoC certified logs No risk of certified logs originating from a controversial source. N/A

FSC CoC/CW logs - FSC-STD-40-004 V2-1 (EN) & FSC-STD-40-005 (Version 2-0) EN

No risk of FSC certified logs/FSC controlled wood logs originating from a controversial source. N/A

Uncertified logs originating from government issued tenures (Forest Management Agreements, Timber Quotas, Timber Permits).

Regulatory oversight through Forest Management Plans (detailed forest management plans/other) are a requirement of tenure holders. Compliance and Enforcement agencies in Alberta enforce forestry laws and take action if there is non-compliance. Instances of non-compliance are reported annually.

https://www.agric.gov.ab.ca/app21/forestrypage?cat1=Forest%20Management&cat2=Compliance%20%26%20Enforcement

Strong legislation in place in Alberta regarding the granting and regulation of harvesting rights and the marking, scaling and transportation of timber as well as Wildlife Management Plans and SARA there is a negligible risk of uncertified logs originating on government tenures being a controversial source.

N/A

Uncertified logs originating on federal lands Regulatory oversight through SARA and the timber marking and transport regulations there is a negligible risk of uncertified logs originating on a federal timber permit being a controversial source.

Control available – Canadian Forest Products Ltd. will, as required, review harvest plans & timber marks for purchases from federal lands to ensure they are relevant and valid.

N/A

Uncertified logs originating on private lands With regulatory oversight through SARA and the timber marking and transport regulations there is a higher yet still negligible risk of uncertified logs originating on private lands being a controversial source.

Control available - Canadian Forest Products Ltd., the primary supplier to Canfor Pulp as well as others supplying chips will, as required, review harvest plans & timber marks for purchases from federal lands to ensure they are relevant and valid. This has been communicated as a standard practice prior to signing log purchase agreements.

N/A

Supplies supported by verifiable documentation which clearly identifies

country of harvest and/or sub-national region where the timber was harvested (including consideration of the prevalence of armed conflict)

trade name and type of product as well as the common name of tree species and, where applicable, its full scientific name

all suppliers within the supply chain and the forest management unit of the supply origin documents or other reliable information indicating

compliance of those timber and timber products with activities referred to by the term controversial sources.

Special attention shall be given to documentation which is produced by a governmental body of the country with TI CPI below 50.

Canadian Forest Products Ltd., the primary supplier to Canfor Pulp as well as others supplying chips require a declaration of non-controversial source to be completed for each purchase. Log purchase agreements include an indication and check of the origin and certification status. Where certified sources are procured Canadian Forest Products Ltd. As well as others supplying chips ensure the relevant certificate (i.e. SFM or CoC) is received or made available and validated.

Canfor Pulp Ltd. maintains agreements with Canadian Forest Products Ltd., the primary supplier to Canfor Pulp as well as others supplying chips that address the transfer of chips.

Canfor Pulp Ltd.’s review of the Corruption Perception Index for Canada, 2016 (http://www.transparency.org/research/cpi/overview) revealed a CPI of 82 ranking: 9/176.

N/A

https://www.agric.gov.ab.ca/app21/forestrypage?cat1=Forest%20Management&cat2=Compliance%20%26%20Enforcement

http://www.transparency.org/research/cpi/overview


PEFC Risk Assessment Table Two Indicators - positive results provide a negligible risk at the origin and supply chain level and result in the indicator being not applicable.


The actual corruption perception index (CPI) of the country presented by Transparency International (TI) is lower than 50.


N/A

The country/region has a prevalence of armed conflict. Canada does not have a prevalence of armed conflict. The last armed conflict of any significance was Oka, Quebec, July - September 1990 involving the Mohawk community of Kanestake and the Town of Oka. The dispute was resolved. Canada maintains the “Law of Armed Conflict” maintained at the tactical and operation level of National Defense (https://www.fichl.org/fileadmin/_migrated/content_uploads/Canadian_LOAC_Manual_2001_English.pdf).

N/A

The country/region is known as a country with low level of forest governance and law enforcement.

Illegal logging is a rare occurrence in Alberta. Regulatory instruments and the judicial system provide recourse and penalties in the event of timber theft.

Contracts are in place between purchaser and supplier to ensure legality.

Compliance and Enforcement agencies in Alberta enforce forestry laws and take action if there is non-compliance. Instances of non-compliance are reported annually.

Strong legislation is in place in Alberta regarding the granting and regulation of harvesting rights and the marking, scaling and transportation of timber.

A high level of government legislation is prevalent in the natural resource industries in Canada and Alberta. Specific to the forest industry and the region, the Alberta Environment and Sustainable Resource Development (AESRD) maintains the forestry legislation and implementation of associated regulations plans.

N/A

Tree species included in the material/product is known as species with prevalence of activities covered by the term controversial sources.

The species listed in the risk assessment are historically traded by Canadian Forest Products Ltd., the primary supplier to Canfor Pulp as well as others supplying chips and are not associated with controversial sources.

N/A

PEFC Risk Assessment Table Three Indicators - positive results provide a negligible risk at the origin and supply chain level and result in the indicator being not applicable.


Actors and steps in the supply chain before the first verification by a verification system accepted as indicator for low risk in this risk matrix are unknown

Canfor Pulp procures chips from consistent vendors with well established relationships with the company.

Canfor Pulp’s chip suppliers also maintain agreements with consistent suppliers for non-tenure logs with a majority of the logs processed having a forest management certification.

N/A

Countries/regions where the timber and timber products have been traded before the first verification by a verification system accepted as indicator for low risk in this risk matrix are unknown.

Canfor Pulp Ltd.’s risk assessment for Alberta recognizes no/minimal chips procured originate from this geographic area however due to disruption in the supply chain may require shifts resulting in chips being procured form Alberta.

Chips are supplied by consistent vendors who harvest logs from their tenured lands or purchase the logs from consistent vendors. The chips are transferred to Canfor Pulp Ltd. with a certification claim under the supplier’s CoC certificate as the chips have lost their origin at log processing. The origin of the logs from which the chips are produced have a unique timber mark that links to the origin and the timbermark is identified and validated prior to delivery/purchase.

N/A

Tree species in the product are unknown Canfor Pulp Ltd. only procures softwood chips with some hardwood chips for Taylor Pulp. The species it deals with and are natural to the area of origin and are listed at the front of this risk assessment.

N/A

Evidence of illegal practices by any company in the supply chain

Canfor Pulp Ltd. is not aware of illegal practices of their chip vendors or their sub-contractors. Should concerns arise Canfor Pulp Ltd. will investigate and determine if any corrective actions required which can include cancelling the chip agreement.

N/A




FSC CW Risk Assessment Categories & Indicators

Category Indicator Information Sources Used Brief Justification Risk Designation

1. Illegally Harvested Wood

The district of origin may be considered having a low risk in relation to illegal harvesting when all the following indicators related to forest governance are present:

1.1 Evidence of enforcement of logging related laws in the district

http://www.agric.gov.ab.ca/app21/forestrypage?cat1=ForestManagement

https://www.agric.gov.ab.ca/app21/ministrypage?cat1=Ministry&cat2=Legislation

https://www.agric.gov.ab.ca/app21/forestrypage?cat1=Forest%20Management&cat2=Forest%20Management%20Facts%20%26%20Statistics&cat3=Compliance%20Monitoring%20%26%20Enforcement%20Statistics

The Alberta AESRD monitors compliance by conducting planned and random audits of forest operations and timber production and by conducting field inspections

Low

1.2 There is evidence in the supply area demonstrating that legality of harvests and wood purchases, including for example, robust and effective systems for granting licenses and harvest permits.

http://www2.gov.bc.ca/gov/content/environment/natural-resource-stewardship/natural-resource-law-enforcement/natural-resource-officers/compliance-reports http://www.for.gov.bc.ca/HTH/timten/documents/timber-tenures-2006.pdf http://opentextbc.ca/geography/chapter/7-5-forest-tree-tenures/

Compliance and Enforcement did not report any illegal logging in Alberta.

All crown land with harvesting operations requires a timber mark allowing tracking of the logs to the origin.

Canadian Forest Products Ltd., Canfor Pulp primary co-product supplier uses a standardized Log Purchase agreement in BC and Alberta for non-tenure logs that includes a declaration that the logs are legal and from a non-controversial source.

1.3 There is little or no evidence or reporting of illegal harvesting in the supply area.


https://www.illegal-logging.info/regions/canada

http://www.forestlegality.org/risk-tool

https://www.globalwitness.org/en/campaigns/conflict-minerals/river-of-gold-drc/

http://www.euflegt.efi.int/map-flegt-projects

http://www.eldis.org/go/country-profiles#.WSYFcOv1CHs

https://eia-international.org/report-category/forests

https://cites.org/eng/app/index.php

AESRD did not report any illegal logging in Alberta. Canada and Alberta are not identified as having illegal logging on illegal-logging and forestlegality websites.

Canada is not listed on the global witness website.

There are no EU FLEGT project in Canada.

Canada is not listed on the ELDIS website. Canada is not listed in reports on the EIA website.

CITES does not list the softwood and hardwood species that Canfor Pulp procures.









http://www.for.gov.bc.ca/HTH/timten/documents/timber-tenures-2006.pdf


http://opentextbc.ca/geography/chapter/7-5-forest-tree-tenures/
















1.4 There is a low perception of corruption related to the granting or issuing of harvesting permits and other areas of law enforcement related to harvesting and wood trade.

www.transparency.org

Canada is considered one of the least corrupt countries in the world by Transparency International.

Canfor Pulp Ltd.’s review of the Corruption Perception Index for Canada, 2016 (http://www.transparency.org/research/cpi/overview) revealed a CPI of 82 with a ranking of 9th of 176 countries assessed.

2. Wood harvested in violation of traditional or civil rightsi

The supply area may be considered low risk in relation to the violation of traditional and human rights when all the following indicators are met.

2.1 There is no UN Security Council ban on timber exports from the country concerned.

www.un.org/en/

http://www.international.gc.ca/controls-controles/systems-systemes/excol-ceed/notices-avis/102.aspx?lang=eng#Prov

http://www.agric.gov.ab.ca/app21/forestrypage?cat1=Directives

There is no UN Security Council ban on the timber exports from Alberta or Canada.

The export of unmanufactured logs and residual fibre is controlled by the sec 31 opf the Forests Act.

Whole log and residual fibre exports are subject to Directive 2011-02 (June 2,2011) which states an authorization from the province is required and is valid for a period up to one year.

Low

2.2 The country or supply area is not designated a source of conflict timber (e.g. USAID Type 1 conflict timber).

http://www.illegal-logging.info/

http://www.globalpolicy.org/security/natres/timbrindex.htm

http://www2.gov.bc.ca/gov/content/governments/organizational-structure/ministries-organizations/ministries/forest-and-natural-resource-operations

http://www.agric.gov.ab.ca/app21/rtw/index.jsp

Canada is not designated as a source of conflict timber

2.3 There is no evidence of child labor or violation of ILO Fundamental Principles and Rights at Work taking place in forest areas in the assessed supply area.

http://laws-lois.justice.gc.ca/eng/acts/L-2/

http://work.alberta.ca/

http://www.qp.alberta.ca/1266.cfm?page=E09.cfm&leg_type=Acts&isbncln=9780779725663 http://www.qp.alberta.ca/1266.cfm?page=1997_014.cfm&leg_type=Regs&isbncln=9780779733927

Canada and Alberta have strong federal and provincial labour legislation. There is no evidence of child labour or violation of ILO Fundamental Principles and Rights in forest related workplaces.

Alberta has regulatory instruments in place to monitor and enforce workers rights.

WCB Alberta administers health and safety legislation and enforces occupational health and safety standards.

http://www.transparency.org/

http://www.un.org/en/











http://www.agric.gov.ab.ca/app21/rtw/index.jsp


http://work.alberta.ca/

http://www.qp.alberta.ca/1266.cfm?page=E09.cfm&leg_type=Acts&isbncln=9780779725663

http://www.qp.alberta.ca/1266.cfm?page=E09.cfm&leg_type=Acts&isbncln=9780779725663

http://www.qp.alberta.ca/1266.cfm?page=1997_014.cfm&leg_type=Regs&isbncln=9780779733927

http://www.qp.alberta.ca/1266.cfm?page=1997_014.cfm&leg_type=Regs&isbncln=9780779733927



2. Wood harvested in violation of traditional or civil rights


2.4 There are recognized and equitable processes in place to resolve conflicts of substantial magnitude pertaining to traditional rights including use rights, cultural interests or traditional cultural identity in the assessed supply area.

http://www.ainc-inac.gc.ca/al/index-eng.asp

http://www.aboriginal.alberta.ca/1.cfm

The courts of Canada have established a legally binding consultation system. There is a process in place with both the governments of Canada and the provinces to negotiate and implement land claims and self government agreements. The treaty process is largely complete in Alberta.

Alberta has a First Nations consultation policy that must be followed by industry. Approvals are dependent upon adequate First Nations consultation.

Low

2.5 There is no evidence of violation of the ILO Convention 169 on Indigenous and Tribal Peoples taking place in the forest areas in the supply area concerned.

http://www.ilo.org/ilolex/cgi-lex/convde.pl?C169




http://www.albertahumanrights.ab.ca/about/legislation.asp

http://www.albertahumanrights.ab.ca/

Canada has not ratified ILO Convention 169 however federal and provincial social and labour legislation protects the rights of all workers including aboriginal employees.

Violation of ILO Convention 169 and the rights of Indigenous and Tribal Peoples is not indicated by international sources and not reported to be a concern within the supply area.

Human rights related to equal employment opportunity and treatment are protected in Alberta by the Alberta Humans Right Act and through the Human Rights Commission. The regulatory instruments and Commission address discrimination in wages and employment. Personal complaints can be filed and adjudicated through the Alberta Human Rights Commission.

Violation of ILO Convention 169 and the rights of Indigenous and Tribal peoples is not indicated by international sources and reports to be a concern within the district of origin.


http://www.aboriginal.alberta.ca/1.cfm








http://www.albertahumanrights.ab.ca/


Category Indicator Information Sources Used Brief justification Risk Designation

3. Wood harvested from forests in which high conservation values are threatened by management activities. The supply area may be considered low risk in relation to threat to HCV’s if: a) indicator 3.1 is met; or b) indicator 3.2 eliminates (or greatly mitigates) the threat posed to the supply area by non-conformity with 3.1.

3.1 Forest management activities in the relevant level (eco-region, sub-eco-region, local) do not threaten eco-regionally significant HCV’s.


http://www.worldwildlife.org/biome-categories/terrestrial-ecoregions

https://worldwildlife.org/publications/global-200

http://en.wikipedia.org/wiki/Global_200

http://worldwildlife.org/places

http://www.conservation.org/where/priority_areas/hotspots/Pages/hotspots_main.aspx http://www.cbd.int/countries/?country=ca

http://www.biodiversitya-z.org/areas/11

http://intactforests.org/

http://www.canadianborealforestagreement.com/

http://info.worldbank.org/governance/wgi/#home

https://www.globalforestregistry.org

Ecoregionally Significant HCVs not present in the fibre supply area

Critical and Endangered WWF Global 200 ecoregions and WWF priority places are not present. Conservation International Biodiversity Hot Spots or high priority wilderness areas are not present. Centres of plant diversity as identified by IUCN and WWF are not present.

Low Risk at the Ecoregion Level

Ecoregionally Significant HCVs present in the fibre supply area but not threatened by forest management activities at the ecoregion level

There is potential to source fibre from the Muskwa-Slave Lake Forests (Muskwa-Slave Lake Forest WWF terrestrial ecoregion), identified as a WWF Global 200 ecoregion but having a current status of “relatively stable/ intact”. In accordance with the guidance set out in the Global Forest Registry (http://www.globalforestregistry.org/map) the risk is low.

HCV: Globally (>500,000 ha), Nationally (> 200,000 ha) and Provincially (50,000 ha) Intact Forest Landscapes

All ecoregions in the supply area, with the exception of Okanagan Dry Forest contain areas of provincially, nationally and/or globally significant intact forest landscapes (IFLs) [http://intactforests.org/], last updated in 2014 (2000-2013 change map).

Intact Forest Landscapes (IFL) are defined as a territory within today's global extent of forest cover which contain forest and non-forest ecosystems minimally influenced by human economic activity with an area of at least 50,000 ha and a minimal width of 10 km as measured as the diameter of a circle that is entirely within the boundaries of the territory.2 This definition is consistent with the FSC Canada Advice Note effective January 2017 (https://ca.fsc.org/en-ca/newsroom/id/687 and the more recent FSC Canada Controlled Wood Interpretation: FSC-STD-40-005 V3-1, Topic #8 (May 2017).

Work by Global Forest Watch Canada was considered however that coverage adds additional IFL area that is inconsistent with the 10km diameter rule. Testing work, currently underway by FSC Canada was not considered as the draft rule set identifies IFL area that is inconsistent with the 10km rule and removes non-forest area (rock and water) from the IFL which again, is inconsistent with the definition.

Current and planned harvesting within the operating areas (Canadian Forest Products Ltd. and other co-product suppliers) is within the risk thresholds specified in the FSC Advice Note for the interpretation of the default clause for Motion 65 (ADVICE-20-007-018 V1-0) and the more recent FSC Canada Controlled Wood Interpretation: FSC-STD-40-005 V3-1, Topic #9 (May 2017) allowing for activity in IFL’s in advance of embedding IFL mitigation measures within national forest management standards. The thresholds are: (1) not more than a 20% impact to an IFL area in a management unit, and (2) to maintain each IFL at a minimum size of > 50,000 ha.


2 http://intactforests.org/concept.html










http://www.conservation.org/where/priority_areas/hotspots/Pages/hotspots_main.aspx



http://www.cbd.int/countries/?country=ca









http://www.globalforestregistry.org/map


https://ca.fsc.org/en-ca/newsroom/id/687

http://intactforests.org/concept.html





http://www.canfor.com/responsibility/forest-management/plans

https://www.dmi.ca/certification/detailed-forest-management-plans/

https://www.dmi.ca/certification/

The IFL review3 completed for this risk assessment shows impacts to IFLs of 0% - 12.5% for the original IFL’s and 0% - 10.7% for the refined IFL’s that removed nodes in IFL’s that did not meet the 10km diameter rule.

Within Alberta there were no conflicts with Canadian Forest Products Ltd.’s FMA or Quota License areas. Other licensee tenure areas have de minimus overlap with IFL’s that are of no effect.

Further protection measures for Canadian Forest Products Ltd.’s FMA and Quota License can be found in Canfor Grande Prairie’s Sustainable Forest Management Plan, registered to the CSA Z809-08 forest management standard and Diashowa-Marubini International’s Detailed Forest Management Plan and SFI 2015-2019 Sustainable Forest Management Plan (for Canadian Forest Products Ltd. Grande Prairie Quota Licence area).


3 IFL Review of Canfor Pulp Ltd. Co-product Supply Area, May 2017









Ecoregionally significant HCV’s present in the fibre supply area but cannot be confirmed as low risk under Indicator 3.1 at the ecoregion level

Canadian Ecoregions Containing Forest Landscapes Map. Global Forestwatch Canada August 2007 & World Wildlife Fund – US. Terrestrial Ecoregions of the World. 2004

https://www.worldwildlife.org/pages/conservation-science-data-and-tools

HCV: Boreal and Woodland Caribou Populations

Both the boreal and southern mountain woodland caribou populations are listed in SARA Schedule 1 as threatened and the SARA Recovery Strategy lists forest harvesting as one of the threats. Refer to the justification for Indicator 3.2.

HCV: WWF Ecoregion Status

The supply area contains WWF ecoregions that are not Global 200 ranked but are determined by WWF as having a status of critical/endangered. The Alberta-British Columbia Foothills Forest (AB & BC) are cited by WWF as critical/endangered. Refer to the justification for Indicator 3.2.

Unspecified Risk

Refer to Indicator 3.2




3.2 A strong system of protection (effective protected areas and legislation) is in place that ensures survival of the HCVs in the ecoregion

Also refer to information sources for indicator 3.1.

http://www.sararegistry.gc.ca/document/default_e.cfm?documentID=2253


Caribou Recovery Plan: http://AESRD.alberta.ca/fish-wildlife/species-at-risk/species-at-risk-publications-web-resources/mammals/documents/SAR-WoodlandCaribouRecoveryPlan-Jul2005.pdf

Status of the Woodland Caribou in Alberta (2010 Update): http://www.ab-conservation.com/go/default/assets/File/Programs/AWSR/Mammal%20Reports/Status%20of%20Woodland%20Caribou%20in%20Alberta_update%202010.pdf

AB Woodland Caribou Policy (2011): http://AESRD.alberta.ca/fish-wildlife/wildlife-management/caribou-management/documents/WoodlandCaribouPolicy-Alberta-Jun2011.pdf

West Central Alberta Caribou Landscape Plan: https://landusekn.ca/resource/west-central-alberta-caribou-landscape-plan

Alberta SRD Land Use Framework: https://landuse.alberta.ca/PLANFORALBERTA/LANDUSEFRAMEWORK/Pages/default.aspx

Alberta Caribou Action & Range Planning Multi-Stakeholder Advisory Group for Little Smokey and A La Peche Caribou Ranges. http://www.aenweb.ca/files/caribou_planning_charter_2013-07-30.pdf

Ecoregionally Significant HCV’s present in the fibre supply area and potentially threatened by forest management activities

HCV: Woodland Caribou – Alberta Populations

There are six caribou ranges within the portion of the supply area where there is potential to source fibre. These herds and associated ecoregion(s) are as follows: A La Peche Alberta – British Columbia Foothills Forest Little Smoky Alberta-British Columbia Foothills Forest Slave Lake Mid-Continental Canadian Forest Nipisi Mid-Continental Canadian Forest West Side Mid-Continental Canadian Forest Athabasca River/Red Earth Mid-Continental Canadian Forest

The 2005 Alberta Caribou Recovery plan identified the Little Smoky Herd as at ‘Immediate Risk of Extirpation’ and the A La Peche herd as ‘Stable’. Roughly 2/3 of the A La Peche herd is in protected area. Table 8 in the 2010 status update suggests a stabilization of the trend for the Little Smoky Herd following the introduction of a predator/prey control program commencing in 2005 with a gain in the trend through the winter of 2008-09. Recent monitoring data obtained from AESRD indicates a stable trend for both herds. Other herds located in the ecoregion are the Narraway, Redrock-Prairie Creek and Chinchaga herds with population status noted in the 2005 recovery strategy as “unknown” for the first, “stable” for the second and “in decline” for the third however the 2010 update indicates a population decline for all three herds. Of the three ranges there is only potential to source residual conifer fibre from the Chinchaga range. Given Canfor Pulp does not source co-product from Alberta but is completing the risk assessment to address situations where sourcing could occur due to supply chain disruption there is a low risk of sourcing chips from the Chinchaga range and given the haul distance, it is the least preferred.

Little Smoky and A La Peche Caribou Ranges:

Through 2015 the forest industry, oil & gas and the mining sectors remained engaged with the Alberta government and others, including members of the ENGO Alberta Environmental Network as part of the Alberta Caribou Action & Range Planning Multi-Stakeholder Advisory Group: Little Smoky and A La Peche Caribou Ranges. Canadian Forest Products Ltd.’s past Alberta Chief Forester worked with the Alberta government and industry sectors to start this group focusing on solutions to protect the herds and allow the industry sectors access to the landbase albeit in a limited capacity given specific areas required protection including significant areas within the southern most area of FMA #9900037/Main Block that includes primarily the Little Smokey range and a lesser portions of the A La Peche range.

Canadian Forest Products Ltd. as a signatory to the Canadian Boreal Forest Agreement was also an active participant in working group for Goal 3 ‘Species at Risk Recovery Plans (i.e. Woodland Caribou) and remains a member of the Alberta Forest Products Association (AFPA) working to ensure a viable recovery plan is implemented.






http://esrd.alberta.ca/fish-wildlife/species-at-risk/species-at-risk-publications-web-resources/mammals/documents/SAR-WoodlandCaribouRecoveryPlan-Jul2005.pdf




http://www.ab-conservation.com/go/default/assets/File/Programs/AWSR/Mammal%20Reports/Status%20of%20Woodland%20Caribou%20in%20Alberta_update%202010.pdf





http://esrd.alberta.ca/fish-wildlife/wildlife-management/caribou-management/documents/WoodlandCaribouPolicy-Alberta-Jun2011.pdf




https://landusekn.ca/resource/west-central-alberta-caribou-landscape-plan

https://landusekn.ca/resource/west-central-alberta-caribou-landscape-plan

https://landuse.alberta.ca/PLANFORALBERTA/LANDUSEFRAMEWORK/Pages/default.aspx

https://landuse.alberta.ca/PLANFORALBERTA/LANDUSEFRAMEWORK/Pages/default.aspx

http://www.aenweb.ca/files/caribou_planning_charter_2013-07-30.pdf

http://www.aenweb.ca/files/caribou_planning_charter_2013-07-30.pdf


http://www.aenweb.ca/files/little_smoky_a_la_peche_msag_draft_terms_of_reference_2013-07-30.pdf

Draft Range Plan for the Little Smoky and A La Peche (June 2, 2016) http://aep.alberta.ca/fish-wildlife/wildlife-management/caribou-management/caribou-action-range-planning/documents/LittleSmokeyAlaPecheRangePlan-Draft-Jun2-2016.pdf

Setting Alberta on the Path to Caribou Recovery (Eric Denhoff, 2016) http://aep.alberta.ca/fish-wildlife/wildlife-management/caribou-management/caribou-action-range-planning/documents/OnThePathtoCaribouRecovery-May-2016.pdf

Hinton Wood Products (HWP) 2014 Detailed Forest Management Plan – Pending Approval. http://www.agric.gov.ab.ca/app21/forestrypage?cat1=Forest Management&cat2=Forest Management Plans&cat3=West Fraser Mills Ltd. (Hinton) LandWeb Study (FRI)

https://landweb.friresearch.ca/

Subject to the draft range plan being finalized, a suspension of harvesting within critical zones identified in the 2008 West Central Alberta Caribou Landscape Plan as core/primary woodland caribou range with additional buffer area remains in place until the cessation of the 2017-18 harvest season. Canadian Forest Products Ltd., Grande Prairie operations remains committed to the agreement and has focused harvest directly outside the protected zones harvesting Mountain Pine Beetle (Dendroctonus ponderosae) infestations as part of the approved Healthy Pine amendment to the Detailed Forest Management Plan in an effort to control the bark beetles impact on growing stock and Caribou habitat.

Canadian Forest Products Ltd., Grande Prairie operations maintains active in the FLMF given their operations within the Little Smoky and A La Peche Caribou ranges along with other forest licensees, the energy and mining sectors and the Aseniwuche Winewak Nation of Grande Cache.

Of note is the government’s work around regional plans; the majority of the Caribou ranges fall within the area of the Upper Athabasca Regional Plan with the remainder Upper Peace Regional Plan. While both plans development is scheduled, the intent is to address range planning for all woodland caribou herds within the plan area integrating existing range plan work in a comprehensive fashion.

Risk mitigation measures implemented include “risk avoidance” and “managed risk” approaches of which the ongoing recovery plans development includes both approaches.

In accordance with Section 2 of Advice-40-005-14 compliance with FSC Indicator 3.2 is met as Canada’s “Rule of Law” index rating of 95% (2a) with support by relevant national and regional stakeholders for (2b) from the supply area for the current caribou range plan approach is provided through:

support through Canadian Forest Products Ltd.’s Grande Prairie Forest Management Advisory Committee (FMAC),

the public review and comment period for the draft range plan for the Little Smoky and A La Peche starting on May 8, 2016 and ending on August 6, 2016 preceded by a multi-stakeholder engagement process that resulted in the recommendations document ‘Setting Alberta on the Path to Caribou Recovery (Denholf 2016)’.

Chinchaga Caribou Range:

Greater than 50% of the Caribou range defined in the Federal Recovery Strategy is located in Alberta with the remainder in British Columbia. For caribou management in BC refer to thr BC risk assessment.

The range area within Alberta is further broken down into:

36% in the Manning FMA, 24% in the DMI FMA, 11% in the Tolko FMA, 5% in the Chinchaga Wildland Park, 20% in the P8 Forest Management Unit with no forest harvesting allocations, 4% outside of FMA’s.

The range is not within Canadian Forest Products Ltd. license areas.




http://aep.alberta.ca/fish-wildlife/wildlife-management/caribou-management/caribou-action-range-planning/documents/LittleSmokeyAlaPecheRangePlan-Draft-Jun2-2016.pdf





http://aep.alberta.ca/fish-wildlife/wildlife-management/caribou-management/caribou-action-range-planning/documents/OnThePathtoCaribouRecovery-May-2016.pdf





http://www.agric.gov.ab.ca/app21/forestrypage?cat1=Forest%20Management&cat2=Forest%20Management%20Plans&cat3=West%20Fraser%20Mills%20Ltd.%20(Hinton)




https://landweb.friresearch.ca/


The P8 FMU has been recommended for addition to the Chinchaga Wildland Provincial Park in the document “Setting Alberta on the Path to Caribou Recovery” (Denhoff, 2016) paper guiding development of the Chinchaga range plan.

The harvesting sequence for the western portion of the Manning FMU does not indicate any harvest for the period 2012-2032. Given the unallocated P8 FMU, the Chinchaga Wilderness Area and the western unit of the Manning short term planning horizon ~32% of the range in Alberta is located in units with no commercial forest management activity. In this area any anthropogenic activity will be “other” industrial activity. Within the FMU’ ~50% of the landbase does not support forest types that are suitable for commercial timber harvesting (i.e non Timber Harvesting Landbase).

Risk mitigation measures implemented include “risk avoidance” for the unallocated and wilderness areas and “managed risk” approaches in the short term for the Manning FMU with ~50% considered non-operable and therefore avoided.

In accordance with Section 2 of Advice-40-005-14 compliance with FSC Indicator 3.2 is met as Canada’s “Rule of Law” index rating of 95% (2a) with support by relevant national and regional stakeholders for (2b) from the supply area for the current caribou range plan approach is provided through:

Incorporation of DMI’s stakeholder input into the caribou management strategy received through their Public Advisory Committee (PAC) and stakeholder input received for FMA specific Detailed Forest Management Plans (DFMP) including First nations and Manning Diversified’s DFMP which resulted in an expansion of the caribou range beyond that identified by the provincial government,

FMU level habitat management strategies and harvest sequence planning in DFMPs specifically designed to mitigate impacts to Caribou habitat with consideration to government strategies and policy with ongoing referral to stakeholders.

Mid-Continental Canadian Forest

Alberta’s 2005 Caribou Recovery Plan identifies the Slave Lake herd, inclusive of the Nipisi herd, as at “Immediate Risk of Extirpation”, the Red Earth Herd as “In Decline” and the West Side Athabasca River herd as “Stable”. Table 8 in the 2010 status update suggests that the West Side Athabasca River herd is “In decline” with an update for the Nipisi and Slave Lake herds not provided due to insufficient data. Other herds located in this ecoregion, but not having potential as a fibre source are the Caribou Mountains herd, Richardson herd, East Side Athabasca River herd and Cold Lake herd with population status noted in the 2005 recovery plan as unknown for the Richardson herd and “In decline” for the others.

The Lower Athabasca Regional Plan (LARP) was approved and effective September 1, 2012 and is in the implementation phase. This plan has added significant wildland provincial park area that includes large portions of the Red Earth, Eastern Athabasca River and Richardson herds. Work has yet to commence on the Lower Peace and Upper Athabasca Region Plans which will provide direction on range planning for the remainder of the herds in the ecoregion.

The CBFA working group for Goal 3 “Species at Risk Recovery Plans” is conducting stakeholder outreach (i.e. government, First Nations and energy sector) for a North East C caribou range action


plan that addresses both the Cold Lake and East Side Athabasca River herds. The intent is a draft range plan to be presented to the provincial government by the CBFA.

In addition to the work on Regional Plans, actions taken by licensees to mitigate risk through both “risk avoidance” and/or “managed risk” approaches within the FMU’s with potential to supply co-product include:

Slave Lake Herd. ~50% of the herd range has been impacted by wildfire in the previous 50 years. In FMU’s S20 and FMU S7 no harvest is sequenced or planned for the next 20-30 years. In FMU S17 a limited harvest entry was scheduled in the first quadrant of the current DFMP commencing in 2009 followed by no harvest for the remainder of the 20 year planning horizon.

Nipisi Herd. No harvest is planned in FMU S17 in the short term (20-30 years). The portion of the range within FMU S19 was impacted by wildfire in 2011. The only harvest in FMU S19 following the 2005 range plan has been wildfire salvage. The portion of the herd in FMU S18 is managed under a DFMP holder landbase certified to the FSC Boreal FM standard.

West Side Athabasca River Herd. The portion of this herd where there is potential to source fibre is the western node that extends into FMU’s S11/S18 both of which are within the a DFMP holder landbase certified to the FSC Boreal FM standard.

The risk mitigation measures demonstrate continued efforts to avoid and minimize harvest in Caribou ranges while recognizing the natural disturbances that occur and in specific cases, force salvage efforts due to wildfire events. The plans, inclusive of 20 year harvest sequences that include Caribou management strategies continue to be referred to multiple stakeholders, as part of the regulatory process and as part of the licensees certification and social license efforts prior to approval by government. In accordance with Section 2 of Advice-40-005-14 compliance with FSC Indicator 3.2 is met as Canada’s “Rule of Law” index rating of 95% (2a) with support by relevant national and regional stakeholders for (2b) from the supply area for the current caribou range plan approach is provided through:

Stakeholder support for the LARP which includes all of the Cold Lake (not including range within Federal Cold Lake Military Reserve), Richardson and East Side Athabasca River herds, about half of the Red Earth herd and about 2/3 of the West Side Athabasca herd. In combination with establishment of large new wildland provincial parks setting direction for range plans.

The bilateral agreement between the forest industry and ENGOs the CBFA working group for Goal 3 ‘Species at Risk Recovery Plans’ ha conducted stakeholder outreach for a NE caribou range action plan that addresses both the Cold Lake and East Side Athabasca River herds.

FMU level caribou management strategies and harvest sequence planning in DFMPs, referred to stakeholders and approved by government that typically demonstrate avoidance or minimization of harvesting in caribou range over the next 20-30 years.


The East Site Athabasca River herd range is ~50% of the Cold Lake herd, >50% of the Nipisi herd and the West Side Athabasca River herd are primarily located in FMU’s where the DFMP holder’s landbase is certified under the FSC Boreal standard. The expectation is that the DFMP holder’s FSC FM certification will address HCV caribou.





HCV WWF Ecoregion Status

Mitigating risk for ecoregion forests is achieved through risk avoidance and a managed risk approach using both regulatory instruments and voluntary actions such as sustainable forest management certification. The regulatory instruments as identified throughout this risk assessment include regulated risk mitigation such as protected areas, regulations that govern the spatial and temporal distribution of forests, species composition and structural retention requirements with planning initiatives that result biodiversity and conservation areas. The legal requirements are woven into voluntary efforts such as sustainable forest management (SFM) certification efforts as well as Canadian Forest Products Ltd. and Canfor Pulp’s commitment to managing their boreal forest tenures based on the natural range of variation (NRV) work underway. Within the supply area > 75% of the managed forest is certified to an SFM standard.

Voluntary third party certification as identified in SFMP’s incorporates the regulatory approach and adds additional requirements developed by Canadian Forest products Ltd.’s Grande Prairie Forest Management Advisory Committee (FMAC) that guides the implementation of the SFM plan. Other licensees certified to the Sustainable Forestry Initiatives 2015-2019 Forest Management standard include indicators that are often met by greater than minimum legal requirements and while there is no mandatory public advisory group component, licensees remain engaged with the public through alternate/parallel processes to identify and address concerns as part of maintaining their social license required to operate on public lands.

Within Alberta > 75% of the provincial forest is certified to a recognized sustainable forest management standard. Within the province and overlapping the certified and uncertified forest area Ecoregion Forests include the BC & Alberta – Alberta-BC Columbia Foothills Forest and Canadian Aspen Forest and Parklands Forest.

The government planning process, regulatory and voluntary approaches applies equally to the portions of the ecoregion forests identified in Alberta.

Alberta & BC: The ecoregions identified do not contain globally, regionally or provincially significant intact forests threatened at the ecoregion level by forest management activities and as per the Indicator 3.1 rationale for HCV: Intact Forests and the Indicator 3.2 rationale for HCV: Globally Significant Intact Forest.

Alberta & BC: The rate of forest conversion to non-forest use is within the acceptable limit at the provincial level and notes Controlled Wood Category #4. harvesting followed by reforestation does not meet the definition of deforestation.





3.2 A strong system of protection (effective protected areas and legislation) is in place that ensures survival of the HCVs in the ecoregion.

http://cbfa-efbc.ca/signatories/

http://cbfa-efbc.ca/innovative-new-commitment-to-natural-landscapes-in-canadian-boreal-forest/

Canadian Forest Products Ltd. and other FPAC (Forest Products Association of Canada) members that supply co-products to Canfor Pulp are signatories to the Canadian Boreal Forestry Agreement (CBFA) as is Canfor Pulp Ltd.

Since the signing agreement Canadian Forest Products Ltd. has been involved in Natural Range of Variation management approach developed with the participation of NGO stakeholders to aid in defining successional processes and the variation in the scale of disturbance across the boreal forests.

This approach is has been used by Canadian Forest Products Ltd’s Grande Prairie operations on Forest Management Agreement (FMA) 9900037 that falls within the Alberta-British Columbia Foothills Forest ecoregion. The approach is supported by NRV analysis demonstrating old and mature forests are within and outside of the upper limit of the natural range largely due to the more recent fire history and suppression efforts in the fire dominated landscape. The NRV approach is integrated Canadian Forest Products Ltd.’s Grande Prairie operation’s Detailed Forest Management Plan. The WWF Wildfinder identifies the primary threat to the Canadian Aspen Forests and Parklands of which a portion falls within Alberta, as land clearing of aspen stands for agriculture. Forests management activities are along the periphery of this ecoregion in provincial forest with the majority outside the supply area extending across Saskatchewan into Manitoba.

Forest cover loss due to conversion is addressed by Controlled Wood Category 4. While de minimus volumes of purchased fibre can originate from the ecoregion utilizing the fibre resulting from land conversion is preferable to excluding it from the fibre supply chain and disposing of it through burning or piling/decomposition. Any perceived threat due to forest management activities is mitigated by the commitments made to NRV management approach as described above.

Given section 2 of Advice-40-005-14 compliance with FSC Indicator 3.2 is met as Canada has a ‘Rule of Law’ index rating of 95% (2a) and significant support by relevant national and regional stakeholders for (2b) from the supply area is provided as identified earlier in this risk assessment and through the collaborative effort between ENGO’s and industry to develop the NRV management approach, publicly announced on January 14th, 2016.





4. Wood harvested from areas being converted from forests and other wooded ecosystems to plantations or non-forest uses. The district of origin may be considered low risk in relation to conversion of forest to plantations or non-forest uses when the following indicator is met

4.1 There is no net loss or no significant rate of loss (> 0.5% per year) of natural forests and other naturally wooded ecosystems such as savannahs taking place in the eco-region in question.


http://www1.agric.gov.ab.ca/$department/deptdocs.nsf/all/formain15737/$file/Forest-Resource-Ftsht.pdf?OpenElement

http://www.fao.org/documents/card/en/c/8202f908-3990-4321-a2b4-a2e346dbf68c/

There is minimal loss of forest land n Alberta and within the supply area. Given the forest management incentive where increases in productivity based on applied management activities (on FMA’s) accrue to the license holder, Canadian Forest Products Ltd. continues to minimize road/landing area lost through rehabilitation efforts and continuously exceeds plantation performance. While there is some private forest land being converted to real estate development it is primarily interface area and within city/township limits. Net loss is less than 0.5 % per year.

Plantation forestry as defined in FSC’s Glossary of Terms (FSC-STD-01-002) is not practiced in Alberta. Alberta AESRD states that the annual growth rate of Alberta’s forest exceeds the annual approved harvest and actual harvest.

FOA’s most recent Canada report (2014) statistics show a negligible loss of forest cover and ongoing afforestation.

Low


5. Wood from forests in which genetically modified trees are planted The supply area may be considered low risk in relation to wood from genetically modified trees when one of the following indicators met.

a) There is no commercial use of genetically modified trees of the species being sourced,

http://abtreegene.com/

https://www.agric.gov.ab.ca/app21/forestrypage?cat1=Forest%20Health%20and%20Adaptation

Sustainable Resource Development (AESRD) Tree Improvement and Seed Centre remains involved with tree breeding and climate adaption trials but are not involved with any genetic engineering, gene insertion, gene splicing or biotechnology that results in genetically modified organisms.

The provincial government ensures that no genetically modified seed is registered or used in operational planting on Crown land in Alberta.

AESRD prohibits the use of genetically modified seed Low

b) Licenses are required for commercial use of genetically modified trees and there are no licenses for commercial use of the species being sourced.

c) It is forbidden to use genetically modified trees commercially in the country concerned











http://abtreegene.com/





Canfor Pulp Ltd. PEFC ST 2002:2013 & FSC Controlled Wood Risk Assessment

Certificate holder: Canfor Pulp Ltd. Certificate holder address:

230-1700 West 75th Ave. Vancouver, BC, V6P 6G2

PEFC Chain of Custody Certificate #: 2563 Date of Annual Risk Assessment Review: (minimum annual review)

May 2018, unless origin changes (country/region level) or the level of risk changes.

FSC CW/CoC Certificate #: KF-CoC-001056/KF-CW-001056 Certification Body (CB): KPMG Performance Registrar Inc.

Date of Risk Assessment: May 2017 Date of CB Review: (i.e. date of last external audit)

Result

The risk assessment is based on PEFC ST 2002:2013, element 5.3 estimates the likelihood at the origin level and likelihood at the supply chain level and for the FSC-STD-40-005 V3-1 EN uses the indicators in that standard to estimate the risk at the supply area level.

As a result of assessment using the criteria presented in the standards the likelihood of procuring significant risk chips is estimated, for PEFC CoC as negligible at the supply chain level and at the country/region level and for FSC-CW, low at the supply area level.

Administrative Data

Geographic Area (Country/region) of procurement (forest districts as defined by the Province of British Columbia from time to time):

Hyperlink to MoFLNRO Region and District Map http://www.for.gov.bc.ca/mof/regdis.htm

The following MoFLNRO interior forest districts:

Fort Nelson Mackenzie 100 Mile Fort St. James Central Cariboo Headwaters Nadina Peace Prince George Quesnel Vanderhoof Other forest districts within BC should a procurement be considered.

Ecoregions1 covered in this assessment #2/Alberta-BC Foothills Forests, #7/Cascade Mtns Leeward Forests, #8/Central BC Mountain Forests, #15/Fraser Plateau & Basin Forests, #21/Muskwa-Slave Forests, #24/North Central Rockies Forests, #26/Northern Cordillera Forests, #31/Okanagan Dry Forests

Species covered in the risk assessment: Lodgepole Pine (Pinus contorta), White Spruce (Picea glauca), Engelmann Spruce (Picea engelmannii), Hybrid White Spruce (Picea spp.), Subalpine Fir (Abies lasiocarpa), Douglas fir (Pseudotsuga menziesii), Aspen (Populas tremuloides), Cottonwood (Populas trichocarpa), Birch (Betula papyrifera)

Product/s covered in this risk assessment: Chips as measured in ODT’s. The PEFC product group is chips manufactured into NBSK pulp, thermo-mechanical pulp and wrapping/packaging paper.

The FSC product groups from which the chips are manufactured into that may contain the FSC CW or FSC Mixed Credit claims are: P1.1 (mechanical pulp, bleached, P1.3 (chemical pulp, bleached), P2.3 (wrapping and packaging paper), P1.4 (chemical pulp, unbleached)

1 World Wildlife Fund – US, Terrestrial Ecosystems of the World, 2004, URL:http//www.worldwildlife.org/science/data.cfm

http://www.for.gov.bc.ca/mof/regdis.htm

http://www.worldwildlife.org/science/data.cfm


This risk assessment updates the initial PEFC ST 2002:2010 and FSC-STD-30-010 V3-0 EN risk assessment. The risk assessment covers Canfor Pulp Ltd.’s fiber basket, a broadly defined geographical area from which softwood chips are sourced in British Columbia. The risk assessment is an annual risk assessment based on the criteria specified in PEFC ST 2002:2013, element 5.3.8 and FSC-STD-40-005 V3-1 EN. Canfor Pulp Ltd. shall review and, where necessary, revise this risk assessment on an annual basis. Revisions shall also be made where the origin changes (Country/region level – PEFC and Supply Area level – FSC) or the level of risk changes.

A Centralized National Risk Assessment (CNRA) exists for Canada that addresses Controlled Wood Category 1, 2 and 5 but not Categories 3 and 4. As a result the CNRA does not apply to certifications under legacy FSC-40-005 v2-1 and current FSC-STD-40-005 V3-1 EN and is of no force or effect until all five Controlled Wood Categories are addressed in the CNRA. https://ic.fsc.org/en/our-impact/program-areas/controlled-wood-01/controlled-wood-risk-assessments/fsc-risk-assessment-database

Controversial/Controlled Wood Definition

The intent of this risk assessment is to assess the fiber basket for the level of risk of procuring controversial or uncontrolled sources of chips. Controversial and controlled sources are defined as raw material from forests where the party completing the harvesting:

(a) does not comply with local, national or international legislation applying to forest related activities (i.e. illegal harvesting) in particular in the following areas:

forestry operations and harvesting, including biodiversity conservation and conversion of forests to non-forest use, management of areas with designated high environmental and cultural values, protected and endangered species, including species listed in CITES, health, safety and labour issues relating to forest workers, indigenous peoples’ property, tenure and use rights, third parties’ property, tenure and use rights, payment of taxes and royalties.

(b) does not comply with legislation in the country of harvest relating to environmental legislation, trade and customs in so far as the forest sector is concerned,

(c) utilizing genetically modified forest based organisms,

(d) converting forests to other vegetation types including conversion of primary forests to forest plantations.

Conflict timber is not considered applicable in Canada and North America based on international knowledge.




PEFC Risk Assessment Table One Indicators - positive results provide a negligible risk at the origin and supply chain level and result in the indicator being not applicable.


PEFC recognized certified logs - CSA Z909-08 & SFI 2015-2019 No risk of certified logs originating from a controversial source. N/A.

Non PEFC recognized certified logs - FSC BC Regional Standard, October 2005

No risk of certified logs originating from a controversial source. N/A.

PEFC CoC certified logs - PEFC ST 2002:2013 No risk of certified logs originating from a controversial source. N/A.

SFI CoC certified logs No risk of certified logs originating from a controversial source. N/A.

FSC CoC/CW logs - FSC-STD-40-004 V2-1 (EN) & FSC-STD-40-005 (Version 2-0) EN

No risk of FSC certified logs/FSC controlled wood logs originating from a controversial source. N/A.

Uncertified logs originating from government issued tenures (TFL's, FL's/NRFL's, Community Forests, Timber Licences, woodlots, Forest Licenses to Cut).

With strong regulatory oversight through FRPA, the FPPR, Forest Act and pursuant regulations, the Wildlife Act, SARA and the timber marking and transport regulations there is a negligible risk of uncertified logs originating on government issued tenures being a controversial source.

N/A.

Uncertified logs originating on federal lands With regulatory oversight through SARA and the timber marking and transport regulations there is a negligible risk of uncertified logs originating on a federal timber permit being a controversial source.

Control available – Canadian Forest Products Ltd., the primary supplier to Canfor Pulp as well as others supplying chips will, as required, review harvest plans & timber marks for purchases from federal lands to ensure they are relevant and valid. This has been communicated as a standard practice prior to signing log purchase agreements.

N/A.

Uncertified logs originating on private lands With regulatory oversight through SARA and the timber marking and transport regulations there is a higher yet still negligible risk of uncertified logs originating on private lands being a controversial source.

Control available - Canadian Forest Products Ltd., the primary supplier to Canfor Pulp as well as others supplying chips will, as required, review harvest plans & timber marks for purchases from federal lands to ensure they are relevant and valid. This has been communicated as a standard practice prior to signing log purchase agreements.

N/A.

Supplies supported by verifiable documentation which clearly identifies

country of harvest and/or sub-national region where the timber was harvested (including consideration of the prevalence of armed conflict)

trade name and type of product as well as the common name of tree species and, where applicable, its full scientific name

all suppliers within the supply chain and the forest management unit of the supply origin documents or other reliable information indicating

compliance of those timber and timber products with activities referred to by the term controversial sources.

Special attention shall be given to documentation which is produced by a governmental body of the country with TI CPI below 50.

Canadian Forest Products Ltd., the primary supplier to Canfor Pulp as well as others supplying chips require a declaration of non-controversial source to be completed for each purchase. Log purchase agreements include an indication and check of the origin and certification status. Where certified sources are procured Canadian Forest Products Ltd. As well as others supplying chips ensure the relevant certificate (i.e. SFM or CoC) is received or made available and validated.

Canfor Pulp Ltd. maintain agreements with Canadian Forest Products Ltd., the primary supplier to Canfor Pulp as well as others supplying chips that address the transfer of chips.


N/A.



PEFC Risk Assessment Table Two Indicators - positive results provide a negligible risk at the origin and supply chain level and result in the indicator being not applicable.


The actual corruption perception index (CPI) of the country presented by Transparency International (TI) is lower than 50.


N/A

The country/region has a prevalence of armed conflict. Canada does not have a prevalence of armed conflict. The last armed conflict of any significance was Oka, Quebec, July - September 1990 involving the Mohawk community of Kanestake and the Town of Oka. The dispute was resolved. Canada maintains the “Law of Armed Conflict” maintained at the tactical and operation level of National Defense (https://www.fichl.org/fileadmin/_migrated/content_uploads/Canadian_LOAC_Manual_2001_English.pdf).

N/A

The country/region is known as a country with low level of forest governance and law enforcement.

A high level of government legislation is prevalent in the natural resource industries in Canada and British Columbia. Specific to the forest industry and the region, Forest and Range Practices Act (FRPA), the Forest Planning and Practices Regulation (FPPR), the Forest Act and associated regulations and area specific land use plans with legally established objectives provide direction that must be approved in Forest Stewardship/Woodlot License Plans before lower level Cutting Permits are approved.

On private managed forest lands the Private Managed Forest Land Act (PMFLA) and the associated regulations provide direction for the management of private managed forest lands.

N/A

Tree species included in the material/product is known as species with prevalence of activities covered by the term controversial sources.

The species listed in the risk assessment are historically traded by Canadian Forest Products Ltd., the primary supplier to Canfor Pulp as well as others supplying chips and are not associated with controversial sources.

N/A

PEFC Risk Assessment Table Three Indicators - positive results provide a negligible risk at the origin and supply chain level and result in the indicator being not applicable.


Actors and steps in the supply chain before the first verification by a verification system accepted as indicator for low risk in this risk matrix are unknown

Canfor Pulp procures chips from consistent vendors with well established relationships with the company.

Canfor Pulp’s chip suppliers also maintain agreements with consistent suppliers for non-tenure logs with a majority of the logs processed having a forest management certification.

N/A

Countries/regions where the timber and timber products have been traded before the first verification by a verification system accepted as indicator for low risk in this risk matrix are unknown.

Canfor Pulp Ltd.’s risk assessment is for the interior of BC and the majority of the chips procured originate from this geographic area. Chips procured in Alberta are addressed under an Alberta risk assessment and form a minority of the supply.

Chips are supplied by consistent vendors who harvest logs from their tenured lands or purchase the logs from consistent vendors. The chips are transferred to Canfor Pulp Ltd. with a certification claim under the supplier’s CoC certificate as the chips have lost their origin at log processing. The origin of the logs from which the chips are produced have a unique timber mark that links to the origin and the timbermark is identified and validated prior to delivery/purchase.

N/A

Tree species in the product are unknown Canfor Pulp Ltd. only procures softwood chips with some hardwood chips for Taylor Pulp. The species it deals with and are natural to the area of origin and are listed at the front of this risk assessment.

N/A

Evidence of illegal practices by any company in the supply chain

Canfor Pulp Ltd. is not aware of illegal practices of their chip vendors or their sub-contractors. Should concerns arise Canfor Pulp Ltd. will investigate and determine if any corrective actions required which can include cancelling the chip agreement.

N/A



FSC CW Risk Assessment Categories & Indicators


1. Illegally Harvested Wood

The district of origin may be considered having a low risk in relation to illegal harvesting when all the following indicators related to forest governance are present:

1.1 Evidence of enforcement of logging related laws in the district

http://www2.gov.bc.ca/gov/content/environment/natural-resource-stewardship/policy-legislation/legislation-regulation/forest-range-practices-act

http://www2.gov.bc.ca/gov/content/environment/natural-resource-stewardship/natural-resource-law-enforcement

https://www.bcfpb.ca/

http://mfcouncil.ca/

FRPA, the Forest Act and associated regulations guide forestry operations in British Columbia using a strong statute/regulatory framework addressing the planning, harvesting, reforestation, environmental protection and transport of timber which is supported by the Province of BC’s Compliance & Enforcement Branch.

In addition, the Province of BC created the Forest Practices Board circa 1994 which completes random compliance audits on public land tenure holders. On private managed forest lands the Managed Forest council completes random audits and inspections of managed private forest lands.

Low

1.2 There is evidence in the supply area demonstrating that legality of harvests and wood purchases, including for example, robust and effective systems for granting licenses and harvest permits.

http://www2.gov.bc.ca/gov/content/environment/natural-resource-stewardship/natural-resource-law-enforcement/natural-resource-officers/compliance-reports http://www.for.gov.bc.ca/HTH/timten/documents/timber-tenures-2006.pdf http://opentextbc.ca/geography/chapter/7-5-forest-tree-tenures/

Compliance and Enforcement did not report any illegal logging in BC.

All crown land with harvesting operations must have a valid tenure and cutting permit to which a unique timber mark/brand is issued. The permit identifies site specific harvesting requirements.

The MoFLNRO administers the harvesting of timber and does not permit harvest without a valid cutting authority (i.e. permit). Legal requirements are enforced by the C&E division.

The timber tenure system is well established in BC and has developed over time. Licenses are issued by the province of BC that have license specific terms and conditions inclusive of stumpage payments linked to the timbermark. Each license includes a timber mark/brand that links the timber harvested to the license and license specific cutting permit allowing tracking of the origin of the harvested logs.

1.3 There is little or no evidence or reporting of illegal harvesting in the supply area.

http://www.for.gov.bc.ca/hen/index.htm







https://cites.org/eng/app/index.php

The Compliance and Enforcement Branch did not report any illegal logging in BC. Canada and BC are not identified as having illegal logging on illegal-logging and forestlegality websites.

Canada is not listed on the global witness website.

There are no EU FLEGT project in Canada.

Canada is not listed on the ELDIS website. Canada is not listed in reports on the EIA website.

CITES does not list the softwood and hardwood species that Canfor Pulp procures.

1.4 There is a low perception of corruption related to the granting or issuing of harvesting permits and other areas of law enforcement related to harvesting and wood trade.

www.transparency.org

Canada is considered one of the least corrupt countries in the world by Transparency International.

Canfor Pulp Ltd.’s review of the Corruption Perception Index for Canada, 2016 (http://www.transparency.org/research/cpi/overview) revealed a CPI of 82 with a ranking of 9th of 176 countries assessed.








http://www.for.gov.bc.ca/hen/index.htm









http://www.transparency.org/



2. Wood harvested in violation of traditional or civil rightsi


2.1 There is no UN Security Council ban on timber exports from the country concerned.

www.un.org/en/

http://www.bclaws.ca/EPLibraries/bclaws_new/document/ID/freeside/240_2003

http://www2.gov.bc.ca/gov/content/industry/forestry/competitive-forest-industry/log-exports


http://www.bclaws.ca/EPLibraries/bclaws_new/document/ID/freeside/240_2003

There is no UN Security Council ban on the timber exports from British Columbia or Canada.

The export of unmanufactured logs and residual fibre is controlled by the Manufactured Products Regulation enabled under the Forest Act.

Whole log and residual fibre exports are strictly governed by the provincial log export policy and federal and provincial export regulatory requirements.

Low

2.2 The country or supply area is not designated a source of conflict timber (e.g. USAID Type 1 conflict timber).




Canada is not designated as a source of conflict timber

2.3 There is no evidence of child labor or violation of ILO Fundamental Principles and Rights at Work taking place in forest areas in the assessed supply area.


http://www.labour.gov.bc.ca/esb/

http://www.qp.gov.bc.ca/statreg/stat/e/96113_01.htm#section9

http://www.bclaws.ca/EPLibraries/bclaws_new/document/ID/freeside/39

www.worksafebc.com

Canada and BC have strong federal and provincial labour legislation. There is no evidence of child labour or violation of ILO Fundamental Principles and Rights in forest related workplaces.

The BC Employment Standards Act restricts employment to 15 years of age and older.

British Columbia has laws in place to monitor and enforce workers rights.

WorksafeBC administers the Workers Compensation Act/OH&S regulation to enforce occupational health and safety standards.

http://www.un.org/en/








http://www.labour.gov.bc.ca/esb/



http://www.worksafebc.com/



2. Wood harvested in violation of traditional or civil rights


2.4 There are recognized and equitable processes in place to resolve conflicts of substantial magnitude pertaining to traditional rights including use rights, cultural interests or traditional cultural identity in the assessed supply area.


http://www.gov.bc.ca/arr/

http://www2.gov.bc.ca/gov/content/environment/natural-resource-stewardship/consulting-with-first-nations/first-nations-negotiations/forestry-agreements

http://www.for.gov.bc.ca/hth/timten/FRPA_implementation/First%20Nations%20and%20FSPs.htm

http://www.bclaws.ca/civix/document/id/consol20/consol20/00_96187_01

The courts of Canada have established a legally binding consultation system. There is a process in place with both the governments of Canada and the provinces to negotiate and implement land claims and self government agreements. Many First Nations have treaties with the government of Canada. In British Columbia, the treaty process continues with some successes.

The Forest and Range Practices Act requires efforts to be made in information sharing between industry and First Nations as a means of identifying and where necessary, conserving and/or protecting cultural heritage resources. Where necessary and based on the recommendations of a registered archaeologist, an identified site may be protected under the Heritage Conservation Act.

The MoFLNRO consults with First Nations to determine if a decision will impact First Nations title and rights. If the First Nation’s title and rights are impacted the government will seek to accommodate their interests.

Low

2.5 There is no evidence of violation of the ILO Convention 169 on Indigenous and Tribal Peoples taking place in the forest areas in the supply area concerned.



http://www.bclaws.ca/EPLibraries/bclaws_new/document/ID/freeside/00_96210_01

http://www.bchrt.bc.ca/index.htm

Canada has not ratified ILO Convention 169 however federal and provincial social and labour legislation protects the rights of all workers including aboriginal employees.

Violation of ILO Convention 169 and the rights of Indigenous and Tribal Peoples is not indicated by international sources and not reported to be a concern within the supply area.

Human rights related to equal employment opportunity and treatment are protected in British Columbia by the Human Rights Code. The legislation addresses discrimination in wages and employment. Personal complaints can be filed and adjudicated through the BC Human Rights Tribunal.



http://www.gov.bc.ca/arr/










http://www.bchrt.bc.ca/index.htm










http://www.conservation.org/where/priority_areas/hotspots/Pages/hotspots_main.aspx http://www.cbd.int/countries/?country=ca





https://www.for.gov.bc.ca/hth/frpa-admin/systems.htm

https://www.globalforestregistry.org

Ecoregionally Significant HCVs not present in the fibre supply area

Critical and Endangered WWF Global 200 ecoregions and WWF priority places are not present. Conservation International Biodiversity Hot Spots or high priority wilderness areas are not present. Centres of plant diversity as identified by IUCN and WWF are not present.


Ecoregionally Significant HCVs present in the fibre supply area but not threatened by forest management activities at the ecoregion level

There is potential to source fibre from the Muskwa-Slave Lake Forests (comprised of the Muskwa-Slave Lake Forest and Northern Cordillera Forest WWF terrestrial ecoregions), identified as a WWF Global 200 ecoregion but having a current status of “relatively stable/ intact”. In accordance with the guidance set out in the Global Forest Registry (http://www.globalforestregistry.org/map) the risk is low.

HCV: Globally (>500,000 ha), Nationally (> 200,000 ha) and Provincially (50,000 ha) Intact Forest Landscapes

All ecoregions in the supply area, with the exception of Okanagan Dry Forest contain areas of provincially, nationally and/or globally significant intact forest landscapes (IFLs) [http://intactforests.org/], last updated in 2014 (2000-2013 change map).

Intact Forest Landscapes (IFL) are defined as a territory within today's global extent of forest cover which contain forest and non-forest ecosystems minimally influenced by human economic activity with an area of at least 50,000 ha and a minimal width of 10 km as measured as the diameter of a circle that is entirely within the boundaries of the territory.2 This definition is consistent with the FSC Canada Advice Note effective January 2017 (https://ca.fsc.org/en-ca/newsroom/id/687 and the more recent FSC Canada Controlled Wood Interpretation: FSC-STD-40-005 V3-1, Topic #8 (May 2017).

Work by Global Forest Watch Canada was considered however that coverage adds additional IFL area that is inconsistent with the 10km diameter rule. Testing work, currently underway by FSC Canada was not considered as the draft rule set identifies IFL area that is inconsistent with the 10km rule and removes non-forest area (rock and water) from the IFL which again, is inconsistent with the definition.

Current and planned harvesting within the operating areas (Canadian Forest Products Ltd. and other co-product suppliers) is within the risk thresholds specified in the FSC Advice Note for the interpretation of the default clause for Motion 65 (ADVICE-20-007-018 V1-0) and the more recent FSC Canada Controlled Wood Interpretation: FSC-STD-40-005 V3-1, Topic #9 (May 2017) allowing for activity in IFL’s in advance of embedding IFL mitigation measures within national forest management standards. The thresholds are: (1) not more than a 20% impact to an IFL area in a management unit, and (2) to maintain each IFL at a minimum size of > 50,000 ha.


2 http://intactforests.org/concept.html






















http://www.globalforestregistry.org/map


https://ca.fsc.org/en-ca/newsroom/id/687

http://intactforests.org/concept.html






The IFL review3 completed for this risk assessment shows impacts to IFLs of 0% - 12.5% for the original IFL’s and 0% - 10.7% for the refined IFL’s that removed nodes in IFL’s that did not meet the 10km diameter rule.

The review assessed the total operating area and the Timber Harvesting Landbase (THLB) area within Canadian Forest Products Ltd. operating areas/Tree Farm Licence areas that overlap the 2013 IFL shapes and revised IFL’s that removed nodes that did not meet the 10km rule.

Actual harvesting within the Canadian Forest Products Ltd. and others tenure chart areas/Tree Farm Licence areas that overlap portions of the 2013 and revised IFL is far less than the THLB area in any year and will be well within the tolerance of 20% previously identified.

Further protection measures for Canadian Forest Products Ltd.’s operating areas can be found in their Sustainable Forest Management Plans, registered to the CSA Z809-08 forest management standard noting these plans incorporate government policy developed through the multi-stakeholder Land and Resource Management Plan process as well as legal requirements identified in FRPA/FRRP and other relevant statues and regulations.


3 IFL Review of Canfor Pulp Ltd. Co-product Supply Area, May 2017







Ecoregionally significant HCV’s present in the fibre supply area but cannot be confirmed as low risk under Indicator 3.1 at the ecoregion level

Canadian Ecoregions Containing Forest Landscapes Map. Global Forestwatch Canada August 2007 & World Wildlife Fund – US. Terrestrial Ecoregions of the World. 2004

https://www.worldwildlife.org/pages/conservation-science-data-and-tools

HCV: Boreal and Woodland Caribou Populations

Both the boreal and southern mountain woodland caribou populations are listed in SARA Schedule 1 as threatened and the SARA Recovery Strategy lists forest harvesting as one of the threats. Refer to the justification for Indicator 3.2.

HCV: WWF Ecoregion Status

The supply area contains WWF ecoregions that are not Global 200 ranked but are determined by WWF as having a status of critical/endangered. The Fraser Plateau and Basin Complex (BC), Okanagan Dry Forests (BC), Alberta-British Columbia Foothills Forest (AB & BC) are cited by WWF as critical/endangered. Refer to the justification for Indicator 3.2.

Unspecified Risk

Refer to Indicator 3.2





Also refer to information sources for indicator 3.1.



Identified Wildlife Management Strategy: http://www.env.gov.bc.ca/wld/frpa/iwms/index.html

BC Caribou Recovery Plan: http://www.env.gov.bc.ca/wld/speciesconservation/mc/index.html

Approved UWR’s http://www.env.gov.bc.ca/wld/frpa/uwr/approved_uwr.html

Stakeholder Notification https://archive.news.gov.bc.ca/releases/news_releases_2013-2017/2017ENV0035-000996.htm

https://www.google.ca/search?q=bc+caribou+recpovery+%5Bplan+stakeholders&oq=bc+caribou+recpovery+%5Bplan+stakeholders&aqs=chrome.69i57.8705j0j7&sourceid=chrome&ie=UTF-8 BC Parks: http://www.env.gov.bc.ca/bcparks/aboutBCParks.html

SFM Forests http://www.naturallywood.com/sustainable-forests/certified-forests

Land & Resource Management Plans

https://www.for.gov.bc.ca/tasb/slrp/

Ecoregionally Significant HCV’s present in the fibre supply area and potentially threatened by forest management activities

HCV: Woodland Caribou – BC Populations

Under the direction of the BC Caribou Recovery Plan the provincial government established ungulate winter ranges (UWRs) as part of FRPA. These General Wildlife Measures for UWR’s incorporate “risk avoidance” and “managed risk” approaches and are considered adequate to maintain Caribou herds at the ecoregion level and have orders establishing the UWR’s in the following forest districts within the supply area: for:

Mountain Caribou – Headwaters, Columbia & Okanagan Shuswap, Arrow-Boundary, Rocky Mountain, Kootenay Lake, Fort St. James, Prince George, Quesnel Forest Districts,

Caribou – Prince George, Quesnel, Williams Lake, 100 Mile House, Peace Forest Districts, Northern Caribou – Mackenzie, Prince George, Peace Forest Districts, Boreal Caribou – Peace Forest District

Caribou populations that span the BC/Alberta border include the:

A La Peche herd Alberta-BC Foothills Forest ecoregion, Little Smokey herd Alberta-BC Foothills Forest ecoregion.

Management actions for the Alberta portion of these herds is identified in the Alberta risk assessment.

Within BC the UWR’s are supported by the multi-stakeholder developed government policy documents - Land and Resource Management Plans (LRMP’s) established across all forest districts. The UWR’s refine Caribou zones identified in the ecoregions encompassed by each LRMP and provide the legal framework for the avoidance and managed risk approaches used.

In accordance with Section 2 of Advice-40-005-14 conformity with Indicator 3.2 is met as Canada has a “Rule of Law” index rating of 95% (2a) and support from relevant national and regional stakeholders (2b) from these supply areas as demonstrated through completion and implementation of a BC Caribou Recovery Plan developed through the






http://www.env.gov.bc.ca/wld/frpa/iwms/index.html

http://www.env.gov.bc.ca/wld/frpa/iwms/index.html

http://www.env.gov.bc.ca/wld/speciesconservation/mc/index.html

http://www.env.gov.bc.ca/wld/speciesconservation/mc/index.html

http://www.env.gov.bc.ca/wld/frpa/uwr/approved_uwr.html

http://www.env.gov.bc.ca/wld/frpa/uwr/approved_uwr.html

https://archive.news.gov.bc.ca/releases/news_releases_2013-2017/2017ENV0035-000996.htm

https://archive.news.gov.bc.ca/releases/news_releases_2013-2017/2017ENV0035-000996.htm

http://www.env.gov.bc.ca/bcparks/aboutBCParks.html



http://www.naturallywood.com/sustainable-forests/certified-forests

http://www.naturallywood.com/sustainable-forests/certified-forests





HCV WWF Ecoregion Status

Mitigating risk to ecoregion forests is achieved through a risk avoidance and managed risk approach using both regulatory instruments and voluntary actions such as sustainable forest management certification. The regulatory instruments as identified throughout this risk assessment include legal objectives often developed through the multi–stakeholder developed LRMP’s, UWR’s, and for non-ungulate species Wildlife Habitat Areas (WHA’s), a protected areas network where no industrial activity is permitted as well as a regulatory framework that patterns harvest activities across the landscape in a manner that resembles the natural disturbance pattern (i.e. spatial and temporal distribution) identified in the Biodiversity Guidebook4 developed under the legacy Forest Practices Code of BC Act. Harvesting that follows the natural disturbance patterns identified at the ecoregion level integrating similar biogeoclimatic zones by natural disturbance type is intended to mimic natural disturbance patterns and provide wildlife habitat across the landscape for different suites of species incorporating composition and structure at the stand and landscape levels.

Voluntary third party certification as identified in SFMP’s incorporates the regulatory approach and adds additional requirements developed by public advisory groups (PAG’s) for Canadian Forest Products Ltd.’s CSA Z809-08/16 certified operations. Other licensees certified to the Sustainable Forestry Initiatives 2015-2019 Forest Management standard include indicators that are often met by greater than minimum legal requirements and while there is no mandatory public advisory group component, licensees remain engaged with the public through alternate/parallel processes to identify and address concerns as part of maintaining their social license required to operate on public lands.

Within BC > 75% of the Crown provincial forest is certified to a recognized sustainable forest management standard. Within the province and overlapping the certified and uncertified forest area Ecoregion Forests include:

BC - Fraser Plateau and Okanagan Dry Forests, BC & Alberta – Alberta-BC Columbia Foothills Forest and Canadian Aspen Forest and Parklands

Forest.

The LRMP process, regulatory and voluntary approaches applies equally to the portions of the ecoregion forests identified in BC.

Alberta & BC: The ecoregions identified do not contain globally, regionally or provincially significant intact forests threatened at the ecoregion level by forest management activities and as per the Indicator 3.1 rationale for HCV: Intact Forests and the Indicator 3.2 rationale for HCV: Globally Significant Intact Forest.

Alberta & BC: The rate of forest conversion to non-forest use is within the acceptable limit at the provincial level and notes Controlled Wood Category #4. harvesting followed by reforestation does not meet the definition of deforestation.


4 https://www.crownpub.bc.ca/Product/Details/7610000517_S





3.2 A strong system of protection (effective protected areas and legislation) is in place that ensures survival of the HCVs in the ecoregion.


http://cbfa-efbc.ca/innovative-new-commitment-to-natural-landscapes-in-canadian-boreal-forest/

Canadian Forest Products Ltd. and other FPAC (Forest Products Association of Canada) members that supply co-products to Canfor Pulp are signatories to the Canadian Boreal Forestry Agreement (CBFA) as is Canfor Pulp Ltd.

Since the signing agreement Canadian Forest Products Ltd. has been involved in Natural Range of Variation management approach developed with the participation of NGO stakeholders to aid in defining successional processes and the variation in the scale of disturbance across the boreal forests.

While not within BC this approach is has been used by Canadian Forest Products Ltd’s Grande Prairie operations on Forest Management Agreement (FMA) 9900037 that falls within the Alberta-British Columbia Foothills Forest ecoregion. The approach is supported by NRV analysis demonstrating old and mature forests are within and outside of the upper limit of the natural range largely due to the more recent fire history and suppression efforts in the fire dominated landscape. The NRV approach is integrated Canadian Forest Products Ltd.’s Grande Prairie operation’s Detailed Forest Management Plan with additional NRV analysis occurring for Canadian Forest Products Ltd’s Peace region operations in British Columbia (i.e. Chetwynd, Fort St. John, Fort Nelson and Mackenzie) although not complete. The SFMP’s for those operations do follow the Biodiversity Guidebook approach that is based on NRV and uses a similar but different approach.

The WWF Wildfinder identifies the primary threat to the Canadian Aspen Forests and Parklands of which a small portion falls within BC, as land clearing of aspen stands for agriculture. Forests management activities are along the periphery of this ecoregion in Crown provincial forest with the majority outside the supply area extending across Saskatchewan into Manitoba.

Forest cover loss due to conversion is addressed by Controlled Wood Category 4. While de minimus volumes of purchased fibre can originate from the ecoregion utilizing the fibre resulting from land conversion is preferable to excluding it from the fibre supply chain and disposing of it through burning or piling/decomposition. Any perceived threat due to forest management activities is mitigated by the commitments made to NRV management approach as described above.

Given section 2 of Advice-40-005-14 compliance with FSC Indicator 3.2 is met as Canada has a ‘Rule of Law’ index rating of 95% (2a) and significant support by relevant national and regional stakeholders for (2b) from the supply area is provided as identified earlier in this risk assessment and through the collaborative effort between ENGO’s and industry to develop the NRV management approach, publicly announced on January 14th, 2016.





4. Wood harvested from areas being converted from forests and other wooded ecosystems to plantations or non-forest uses. The district of origin may be considered low risk in relation to conversion of forest to plantations or non-forest uses when the following indicator is met

4.1 There is no net loss or no significant rate of loss (> 0.5% per year) of natural forests and other naturally wooded ecosystems such as savannahs taking place in the eco-region in question.

http://www2.gov.bc.ca/gov/content/environment/research-monitoring-reporting/reporting/environmental-reporting-bc/previous-reports-indicators https://www.for.gov.bc.ca/hts/analysis.htm

http://www.fao.org/documents/card/en/c/8202f908-3990-4321-a2b4-a2e346dbf68c/

There is very little net loss of forest land in the forest districts identified within the supply area. While there is some private forest land being converted to real estate development it is primarily interface areas and within city/township limits or within agriculture belts in some forest districts and is not classified as Crown provincial forest land. Net loss is less than 0.5 % per year.

Plantation forestry as defined in FSC’s Glossary of Terms (FSC-STD-01-002) is not practiced in British Columbia. The State of British Columbia’s Forests 2010 report states that the current rate of forest conversion is very low.

The MoFLNRO has completed timber supply reviews for the management units (TSA’s) and determined annual allowable cuts in response to social, environmental, and economic considerations. The analyses show harvesting and reforestation rates, protection of biodiversity at the landscape level describes the social and economic considerations considered when setting the rate of cut in the management units.

FOA’s most recent Canada report (2014) statistics show a negligible loss of forest cover and ongoing afforestation.

Low


5. Wood from forests in which genetically modified trees are planted The supply area may be considered low risk in relation to wood from genetically modified trees when one of the following indicators met.

a) There is no commercial use of genetically modified trees of the species being sourced,

http://www.for.gov.bc.ca/hti/grm/generesource.htm http://www2.gov.bc.ca/gov/content/industry/forestry/managing-our-forest-resources/tree-seed

http://www2.gov.bc.ca/gov/content/industry/forestry/managing-our-forest-resources/tree-seed/legislation-standards/chief-forester-s-standards-for-seed-use

The MoFLNRO Tree Improvement Branch is responsible for protecting, managing and conserving BC’s forests genetic resources.

The Chief Foresters standards for seed use control seed use across the province. Tree breeding programs are in place however they do not genetically modify trees but rather breed for favourable traits in a tightly regulated environment.

Low

b) Licenses are required for commercial use of genetically modified trees and there are no licenses for commercial use of the species being sourced.

c) It is forbidden to use genetically modified trees commercially in the country concerned

http://www2.gov.bc.ca/gov/content/environment/research-monitoring-reporting/reporting/environmental-reporting-bc/previous-reports-indicators





https://www.for.gov.bc.ca/hts/analysis.htm

https://www.for.gov.bc.ca/hts/analysis.htm

http://www.for.gov.bc.ca/hti/grm/generesource.htm

http://www.for.gov.bc.ca/hti/grm/generesource.htm

http://www2.gov.bc.ca/gov/content/industry/forestry/managing-our-forest-resources/tree-seed



Documents

Stakeholder Consultation: KPMG Forest Certification Services Inc. · 2020-05-07 · KPMG Forest Certification Services Inc. Box 10426, 777 Dunsmuir Street Vancouver BC V7Y 1K3 Canada