FSC Controlled Wood Risk Assessment - hspp.ca · Assessment in accordance with the FSC CW Standard...

FSC® Controlled Wood Risk Assessment

Version 1.1 – April 10 2019

1 HSPP FSC Controlled Wood Risk Assessment – Version 1.1 April 10 2019

A. Introduction Howe Sound Pulp and Paper Corporation (HSPP) is a Kraft pulp producer with a mill located on Howe Sound at Port Mellon, British Columbia, Canada. This Controlled Wood Risk Assessment (CWRA):

• The CWRA describes the risks of sourcing materials unacceptable to the Forest Stewardship Council® (FSC) and this CWRA has been prepared in accordance with the requirements of the FSC Controlled Wood (CW) Standard: ‘Requirements for Sourcing FSC Controlled Wood’ FSC-STD-40-005 V3-1 (https://ic.fsc.org/en/document-center/id/170).

• This CWRA is a ‘company risk assessment’ conducted in accordance with the FSC CW Standard at indicator 3.3 and Annex A. While the Standard uses the term ‘company risk assessment’ to describe this assessment, HSPP chooses to use the more descriptive identifier: ‘controlled wood risk assessment’ (CWRA) to ensure the reader understands the assessment is the HSPP assessment of specified risk regarding HSPP sourcing and FSC CW. (Note: Since all Company Risk Assessments expire on June 30 2019, should the Canada and USA National Risk Assessments not be approved, on July 1 2019 this CWRA meets the requirements of the Extended Company Risk Assessment in accordance with the FSC CW Standard at indicator 3.3 and Annex A).

• The FSC CW Standard at indicator 3.1 gives an organisation the option of applying an FSC risk assessment under development. HSPP’s FSC auditors confirmed the use of the Canada National Risk Assessment Draft 2 to identify low risk and specified risk as meeting both the requirements of a Company Risk Assessment and Extended Company Risk Assessment. This CWRA addresses risk related to sourcing unacceptable materials for five controlled wood categories by considering the Canada and USA Draft National Risk Assessment methodology and results:

o Canada National Risk Assessment Draft 2 (CAN-NRA-D2) (FSC-NRA-CAN V1-0 DRAFT) – October 15 2018 (https://ca.fsc.org/en-ca/standards/national-risk-assessment-01)

o USA National Risk Assessment Draft 3 (USA-NRA-D3) (FSC-NRA-USA V1-0) (https://us.fsc.org/en-us/certification/controlled-wood/fsc-us-controlled-wood-national-risk-assessment-us-nra)

o The Canada and USA Draft NRAs identify geographic areas where FSC has identified the risk of sourcing unacceptable materials as ‘low’. HSPP has chosen to adopt those results in the HSPP CWRA.

o The Canada and USA Draft NRAs identify geographic areas where FSC has identified ‘specified risks’ associated with one or more risk categories and the draft NRAs have identified ‘control measures’ to mitigate or manage the identified risks. This CWRA has acknowledged every instance of specified risk and the control measures relevant to HSPP sourcing areas as presented in the draft USA and Canada NRAs. However, since the NRAs are not approved HSPP has then departed from the NRA recommended control measures and such decisions are made transparently in this paper.

• The Canada and USA Draft NRAs do not, of course, consider the actual HSPP supply area or specific applicability of the identified risks to the actual HSPP supply. This CWRA is about documenting the results of the Canada and USA Draft NRAs and applying the results to the actual HSPP supply area and supply volumes.

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

https://ca.fsc.org/en-ca/standards/national-risk-assessment-01

https://us.fsc.org/en-us/certification/controlled-wood/fsc-us-controlled-wood-national-risk-assessment-us-nra

https://us.fsc.org/en-us/certification/controlled-wood/fsc-us-controlled-wood-national-risk-assessment-us-nra


This CWRA is not: • The CWRA excludes all HSPP sourcing of fibre with an FSC Chain of Custody (CoC) or FSC CW

claim from sources with an FSC CoC/CW certificate, certified to FSC Chain of Custody (CoC) Standard: ‘Chain of Custody Certification’ FSC-STD-40-004 V3-0 (https://ic.fsc.org/en/document-center/id/80).

• This CWRA excludes all HSPP supply sourced under ‘Sourcing Reclaimed Material For Use In FSC Product Groups or FSC Certified Projects’ FSC-STD-40-007 V2-0 (https://ic.fsc.org/en/document-center/id/83).

The CWRA assesses HSPP supply to confirm that the geographic areas from which HSPP receives fibre does not include fibre sourced from 5 CW risk categories.

1. Illegally harvested wood; 2. Wood harvested in violation of traditional and human rights; 3. Wood harvested in forests in which high conservation values (HCVs) are threatened by

management activities; 4. Wood harvested in forests being converted to plantations or non-forest use; 5. Wood from forests in which genetically modified trees are planted.

Once certified as meeting FSC CoC and CW requirements, HSPP will have the ability to source controlled materials from its supply area and sell the resulting pulp products with an FSC Controlled Wood claim. HSPP does not have its own wood supply and all fibre sourcing is achieved on the open market. Sourcing includes:

• HSPP purchases fibre as sawmill by-product chips under contract arrangements. • HSPP also purchases logs and makes arrangements to have the logs chipped. All fibre arrives at

the Port Mellon mill site as chips. • 95% of supply comes from forests certified to a certification scheme including SFI, CSA and FSC

forest certification schemes. • 95% of supply is sourced from publicly owned tenured forest lands primarily from the Coast of

BC but also the Interior of BC and Washington and Oregon States. • Transportation systems for logs and chips is by road to the ocean and transferred to barge and

transported by water to HSPP. HSPP has assessed its wood supply and has determined the overlaps between HSPP supply areas and those geographic areas identified by FSC with a ‘specified risk’ where forest management potentially threatens particular FSC values. The CWRA also considers the HSPP wood supply at the supply chain level to ensure that the fibre transportation systems do not introduce risks of HSPP mixing in unacceptable materials. Regarding the supply area boundaries there are practical outside limits to the HSPP supply area that are dependent on transportation mode and routes and ultimately relating to log value versus transportation costs. ‘High volume’ supply areas are identified, and instances of specified risk are acknowledged. Where risks are identified they are mitigated or managed through ‘control measures’ (CM). ‘Low volume’ and ‘negligible volume’ supply areas are identified and HSPP has acknowledged occurrences of specified risk. 1. NRA and HSPP risk assessment results The CAN-NRA-D2 and USA-NRA-D3 are the bases for this CWRA. Table 1 presents the HSPP risk conclusions considering all HSPP supply areas. Table 2 summarizes specified risk values by HSPP supply






area. Map 1 shows the HSPP risk conclusions of low and specified risk associated with BC supply. Maps 2-4 shows HSPP conclusions of low and specified risk associated with the USA supply. Table 1. HSPP risk conclusion summary Supply Area CW risk category – HSPP risk conclusion

1 Illegal harvesting

2 Human rights

3. High conservation values 4. Forest conversion 5. GMOs

BC supply A. Sunshine Coast and Vancouver Island High volume supply

LOW LOW Specified risk for some HCVs and CMs are applied - See Map 1 and Table 2. LOW for all other HCVs

LOW LOW

B. Fraser Valley and Merritt High volume supply

LOW LOW LOW LOW

C. North Coast Kitimat Low volume supply

LOW LOW Specified risk for some HCVs - See Map 1 and Table 2. HSPP LOW risk conclusion considering HSPP supply volumes.

LOW LOW

D. BC Low volume supply

LOW LOW LOW LOW

E. BC Negligible volume supply

LOW LOW LOW LOW

USA supply D. Washington State Low volume supply

LOW LOW HSPP LOW risk conclusion considering HSPP supply volumes - See Table 2 and Maps 2 and 3. LOW for all other HCVs

HSPP LOW risk conclusion considering HSPP supply volumes - See map 4.

LOW

E. Oregon State Negligible volume supply

LOW LOW LOW

2. Canada NRA Draft 2 The Canada National Risk Assessment – Draft 2 – October 15 2018 (CAN-NRA-D2) is the basis for this CWRA. All instances of specified risk are acknowledged. Where applicable, any departures from the CAN-NRA-D2 specified risk are noted. HSPP anticipates changes to the identification of specified risks as the Canada NRA final report is approved. The Preamble of the CAN-NRA-D2 acknowledges the certification challenges facing HSPP as a pulp mill without a dedicated wood supply.

“Complexity in Supply Chains One of the challenges when designing Control Measures to mitigate the identified risks was taking into account the complexity in supply chains. In some cases, a FSC Certificate Holder may source non-certified material through an indirect chain of suppliers (i.e. not directly from the forest). This is common for pulp mills that source non-FSC chips and residue from various other mills. In several cases, the range in supply areas can encompass several hundred thousand hectares, as well as dozens of suppliers, forests and communities. The NRA Working Group recognized that it may be difficult for Certificate Holders using the Controlled Wood system to confirm, beyond the first point of purchase, that sub-suppliers meet the requirements of Control Measures at the forest-level. Best efforts were made to take this complexity into account, while still ensuring that the Control Measures adequately mitigate the identified risk.”


Table 2. HSPP risk category 3 (HCV) specified risk summary

Supply Canada NRA D2 OR USA NRA D3 HSPP supply volume

HSPP risk assessment conclusion Area % HCV1 – SAR

specified risk HCV2 – IFL specified risk Risk Result

HSPP High volume supply A. Sunshine Coast and Vancouver Island

56% Goshawk and murrelet in the Central Pacific coastal forest ecoregion Caribou habitat overlap to BC mainland coastal forest ecoregion

IFL 169 in the BC mainland coastal forest ecoregion

Specified risk at HCV1 and HCV 2 requiring CMs to mitigate

High volume supply

HSPP specified risk conclusion at HCV1 regarding 2 SAR (goshawk and murrelet) and HCV2 (IFL 169). HSPP CM measures are applied. The HCV1 value of caribou has been assessed at the HSPP supply level with a low risk conclusion. HSPP does not apply CMs.

B. Fraser Valley and Merritt

25% Salamander, shrew and frog in the Puget lowlands forest ecoregion

IFL 131 overlaps the BC mainland coastal forest and the Cascades mountain leeward forest ecoregions

Specified risk at HCV1 and HCV 2requiring CMs to mitigate

HSPP specified risk conclusion at HCV1 for 3 SAR (salamander, shrew and frog). HSPP CM are applied. The HCV2 value of IFL 131 has been assessed considering the HSPP supply with a low risk conclusion.

HSPP Low volume supply C. North Coast Kitimat

4% Caribou in the BC mainland coastal forest ecoregion

IFLs 196, 206, 213, 223, 225, 238 in the BC mainland coastal forest ecoregion

Specified risk at HCV1 and HCV2 requiring CMs to mitigate

Low volume supply

HSPP low risk conclusion at HCV2 for 6 IFLs. The HCV1 SAR value of caribou has been assessed at the HSPP supply level with a low risk conclusion. HSPP doesn’t apply CMs. The HCV2 value of IFL 131 has been assessed considering the HSPP supply with a low risk conclusion. While CMs are not applied additional activities including supply mapping, education and consultation are implemented.


5% Caribou in the Fraser Plateau and Basin Complex ecoregions

IFLs 131, 134, 169 in the BC mainland coastal forest and Cascade mountains leeward forests and Fraser plateau and basin complex ecoregions

Specified risk at HCV1 and HCV2 requiring CMs to mitigate

HSPP low risk conclusion at HCV 1 and HCV2. While CMs are not applied additional activities including supply mapping, education and consultation are implemented.

D. Washington State low volume supply

2% HCV1 Old growth forests are specified risks

NA Specified risk at HCV1 requiring CMs to mitigate

HSPP low risk conclusion at HCV 1 and HCV2. While CMs are not applied additional activities including supply mapping, education and consultation are implemented.

Negligible volume supply E. BC Negligible volume supply

3% Goshawk and murrelet in the Central Pacific coastal forest ecoregion

IFLs 201, 202 in the QCI ecoregion AND IFLs 223, 238, 274 in the BC mainland coastal forest ecoregion

Specified risk at HCV 1 and HCV2 requiring CMs to mitigate

Negligible volume supply

HSPP low risk conclusion at HCV2. While CMs are not applied additional activities including supply mapping, education and consultation are implemented.

E. Oregon State negligible volume supply

5%* HCV1 OG Forests & Klamath-Siskiyou critical biodiversity area

NA Specified risk at HCV1 requiring CMs to mitigate

HSPP low risk conclusion at HCV1. While CMs are not applied additional activities including supply mapping, education and consultation are implemented.

*All Oregon State supply is from one FSC CoC/CW-certified operation, therefore on a conservative basis the Oregon USA supply is deemed negligible risk.


Map 1. BC supply areas and HSPP specified risk conclusions


The FSC Canada NRA Draft 2 acknowledges the particular complexity facing pulp mills like HSPP to become FSC CW certified. HSPP is implementing the Standard including applicable instances of specified risk and the required control measures in two phases and this allows HSPP to manage the complexity of implementing an FSC-conformant controlled wood system. The first phase takes uncertainty regarding finalized NRA values and controls into account. By the end of the second phase HSPP anticipates acting on all specified risk and implementing control measures from the approved Canada NRA. HSPP is also applying a wood supply volume category of ‘negligible supply’ to its FSC CW system in order to manage the complexity and challenges associated with working with forest managers and engaging with stakeholders at the outer margins of the HSPP supply area and far from the HSPP mill physically and where HSPP has limited ability to influence forest management or engage with stakeholders 3. USA NRA Draft 3 The USA National Risk Assessment – Draft 3 – July 2018 (FSC-NRA-USA V1-0) (USA-NRA-D3) is the basis for this CWRA of USA supply. In this CWRA HSPP acknowledges any departures from the results of the USA-NRA-D3. The USA NRA process has completed, and we are anticipating the approval of the NRA results in 2019. Specified risk and CMs are not anticipated to change during the time frames of the HSPP FSC CW certification effort. The HSPP supply assessment has identified HSPP fibre sourced from Washington (WA) State (i.e. 2% supply) and Oregon (OR) State (i.e. 5%). The assessment of the 2013-2017 HSPP wood supply considered the USA supply only to the State level. HSPP has procedures to assess supply to the County jurisdictional level in the USA which will improve the next iteration of the supply assessment. It is worthwhile noting that the HSPP supply assessment indicates that all Oregon supply enters the HSPP supply chain under an FSC CW certificate. For this reason Oregon is considered a negligible volume supply area. Washington State is a low volume supplier to HSPP. Maps 2-4. USA-NRA-D3 specified risk occurrences

Map 2*. Klamath Siskiyou Critical Biodiversity Area

Map 3* Old growth specified risk areas

Map 4*. Counties with specified risk for conversion

*Maps 2-4 are cut from maps supplied by the USA-NRA-D3 The USA-NRA-D3 has identified specified risk associated with supply from Washington and Oregon States including:

• FSC CW risk category 3 and HCV 1 Klamath Siskiyou Critical Biodiversity Area (see map 2) occurring partially in Oregon State (all Oregon supply comes from an FSC-certified forest).


• FSC CW risk category 3 and HCV 1 Old-growth specified risk areas as mapped (see map 3) and occurring in Washington State (low volume supply area) and Oregon State (negligible volume supply area).

• FSC CW risk category 4 forest conversion in specified counties (see map 4) of Washington State (low volume supply area) and Oregon State (negligible volume supply area).

4. Two phase DDS implementation HSPP is implementing the DDS in two phases:

Phase 1 is anticipated as effective until approximately June 2019: • HSPP anticipates the NRA approval by FSC International in June 2019 and HSPP hopes to achieve

FSC CoC and CW certification prior to the approval of the USA and Canada NRAs. • The USA NRA D3 represents the final version going to FSC International for approval. • However, the Canada NRA D2 used in this assessment was an interim draft and has apparently

been superseded by a more recent draft to be considered by FSC International for approval but this final draft has not been released to the public.

• Phase 1 of the HSPP CWRA implementation covers the time from now to when the Canada and USA NRAs are both completed and up to the time of the Canada and USA NRA approvals by FSC International.

Phase 2 is anticipated as effective from approximately June 2019 (or when the Canada/USA NRAs are approved) for six months: • The FSC CW Standard at indicator 3.2 requires a certificate holder to amend the DDS within 6

months of the approval of the Canada/USA NRAs. During phase 1 HSPP has applied thresholds to carve up the HSPP supply areas into logical groupings and better manage the risk that supply might include unacceptable sources:

• Supply areas A and B in BC represent 81% of supply which HSPP considers ‘high volume supply’ areas.

• In phase 1 regarding supply areas A and B HSPP has concluded specified risk for all the HCVs also identified as specified risk by the CAN-NRA-D2 with exceptions noted in this paper. The NRA-recommended CMs are acknowledged in this CWRA and the NRA-recommended CMs have been modified by HSPP to stage their implementation and allow HSPP to build its CW program.

• The remaining HSPP supply areas, including two USA States supplying fibre to HSPP, are considered ‘low volume’ supply or ‘negligible volume’ supply. HSPP has acknowledged the NRA results including specified risk and recommended CMs. HSPP has concluded low risk due to the low supply from jurisdictions. HSPP is undertaking activities such as consultation.

HSPP is hoping to achieve FSC CoC/CW certification during phase 1 of the HSPP program implementation and by approximately May or June 2019. Once the Canada and USA NRAs are approved, then the following six months allowed by the FSC Standard to adapt to the newly approved NRAs becomes phase 2 where HSPP is working to meet the full requirements of the Standard. By the end of phase 2, HSPP anticipates high and low volume supply areas to be fully conformant to the approved Canada and USA NRAs, as required by the Standard. HSPP has concluded low risk of sourcing unacceptable materials regarding HSPP negligible supply areas despite the NRA instances of specified risk and control measures identified. This HSPP position is in effect in phases 1 and 2, and into the


future HSPP anticipates continuing to identify negligible supply volume as low risk to sourcing unacceptable materials. By addressing the specified risk issues associated with only the highest volume of the HSPP supply in phase 1, HSPP gains experience with implementing CMs including stakeholder consultation and working with forest managers on control measures. 5. Stakeholder consultation In February and March 2019 HSPP conducted a stakeholder consultation which concluded:

• No concerns with the HSPP approach of acknowledging all NRA instances of 'specified risk'. HSPP has considered all instances of specified risk as determined by Canada and USA Draft NRAs.

• No concerns with HSPP approach to identify NRA low risk across all risk categories (i.e. with the exception of instances of specified risk). HSPP has adequately identified all instances of low risk.

• HSPP CWRA has adequately considered ecoregions, TSAs and best management practices in its CWRA and DDS. Respondents support the HSPP CWRA.

• HSPP's approach to implementing control measures in two phases was supported by all respondents. Stakeholders support HSPP control measures.

• Respondents supported the use of the questionnaire as an effective tool for providing stakeholder comments.

HSPP has addressed all the stakeholder comments or issues and informed the stakeholders of how their comments were considered. The HSPP DDS Summary includes more information regarding the stakeholder consultation process and the results of the February 2019 stakeholder consultation completed by HSPP. The stakeholder consultation gave HSPP a strong mandate to implement the CWRA and due diligence system across the HSPP supply area in order to avoid sourcing unacceptable fibre.


B. HSPP Supply Assessment HSPP assessed the 2013 to 2017 HSPP annual wood supply to generate a 5-year average supply as the basis for defining the HSPP wood supply area. The intersection of the HSPP wood supply and draft specified risk forest values identified by the Canada and USA NRAs is the subject of this CWRA. The HSPP BC wood supply areas are shown on Maps 1 and 5 and wood supply information is provided in Tables 1, 2 and 3. Future iterations of this CWRA will include maps of the USA supply area. The USA supply data is also included in the information tables. 1. Supply assessment methodology HSPP assessed its supply from 2013 to 2017 to the Timber Supply Area (TSA) level in BC and to the State level considering USA supply. HSPP has procedures to conduct annual supply assessments and maintain a 5-year rolling average describing the entire HSPP wood supply. By using a 5-year average HSPP normalizes the annual supply by averaging out annual variability yet maintaining an approach that reflects sourcing trends. This approach is particularly logical since supply shifts trend slowly over years and supply from particular sources vary in the time frame of years not months. The results of the assessment are included in Table 2 where annual average supply percentages are cited. In the future the USA supply will be further broken down to the County level, a logical level to identify origin and the County is a logical forest management unit for planning in the USA. HSPP considers the wood supply assessment to be propriety information relating to its competitiveness and HSPP considers this as a confidential document made available to the certification body in a certification audit but not available to stakeholders. The Canada and USA NRAs present two different kinds of identification of specified risk. Some specified risk forest values are a feature with a hard area boundary. For example, IFL 169 is shown on Map 1 and is acknowledged by HSPP as a BC category 3 and HCV2 specified risk relative to supply area A. HSPP considers the potential impacts and conservation considerations relative to the IFL boundary but further features inside the boundary are not relevant. Alternatively some features have additional considerations inside of the hard area boundaries. Some specified risk species have particular habitat requirements that are the focus of conservation concerns and the habitat occurs in a definable area with hard boundaries. For example, the HCV1 specified risk marbled murrelet requires trees with old growth characteristics for nesting and this habitat has specified risk to conservation in the Central Pacific coastal forest ecoregion (i.e. Vancouver Island). HSPP mapped the HSPP supply in an Esri ArcGIS with Provincial and other data sets to show values at risk identified by USA and Canada NRA processes. Map 5 shows the BC TSAs and ecoregions in addition to the supply area boundaries. Table 3 summarizes this data along with the HSPP specified risk and the HSPP risk conclusion.

• Regarding the low and negligible supply volume areas NRAs have identified instances of specified risk forest values which are potentially unacceptable fibre sourcing areas:

o In phase 1 HSPP is not concluding specified risk and HSPP has concluded a low risk for sourcing unacceptable materials. In phase 1 regarding instances of NRA specified risk values, HSPP is identifying the low and negligible risk supply with a low risk conclusion and no control measures are implemented.

o The issues identified by the NRAs as specified risk but not further considered by HSPP as specified risk during phase 1 of this project are shown in grey italic font in Table 3.


• In phase 2 HSPP anticipates acknowledging all instances of specified risk as per approved NRAs regarding low volume supply areas.

• In phase 2 and beyond HSPP anticipates continuing with a low risk conclusion regarding negligible volume supply areas despite the occurrence of specified risk occurrence in an approved NRA.

HSPP also added GIS layers including:

• Protected areas (National parks, Provincial parks, Ecological reserves and Conservancies - not shown in maps in this presentation). HSPP obtained data from the BC Conservation Data Centre (https://www2.gov.bc.ca/gov/content/environment/plants-animals-ecosystems/conservation-data-centre) mapping species at risk range (hard boundary) in the case of caribou and ‘known occurrence’ in the case of all other species. Regarding SAR where particular habitat represents the specified risk then the ecoregion is the hard boundary to the range of the species.

• Intact forest landscape data was obtained from the Intact Forest Landscapes website (www.intactforests.org/data.ifl.html)

Regarding values at risk such as IFLs or SAR, the HSPP assessment generated area data from the GIS showing overlaps including the HSPP supply area, ecoregion and TSA for each value at risk. In a similar manner as the Canada NRA process, HSPP further assessed individual values such as IFLs and species at risk to determine if the value was material to the HSPP supply. In conducting the BC supply-level assessment HSPP has worked to maintain similar patterns of analyses as applied by the Canada NRA working group. Page 76/153 of FSC-NRA-CAN V2-0 DRAFT states that HCV 2 was analyzed first at an ecoregional-level and then at a more detailed level considering individual IFLs. In a similar manner HSPP has considered supply first at the ecoregional level and indeed HSPP has eliminated ecoregions as low risk. The Canada NRA specifically uses thresholds in assessing risk and HSPP has followed this same methodology. The TSA-level in BC and County-level in the USA are the organisational units that are the basis of a logical and practical supply assessment and a logical land area to apply CMs. In BC harvesting is planned at the TSA-level with timber supply assessments and timber supply allocations to companies under tenure arrangements and plans that include consideration of SAR are important TSA-level planning functions. Forest managers are organised at the TSA-level in higher level plans and this is the same unit of land requiring forest manager stakeholder, community and First Nations consultations mandated by BC regulations. HSPP anticipates building the strongest relationships and applying the most rigorous control measures in TSAs with high volume HSPP supply. The 2013-2017 HSPP supply assessment was conducted to the TSA level in BC. In Washington and Oregon states the next iteration of the HSPP supply assessment will be conducted to the County level where currently the assessment is completed only to the State level. The HSPP HCV2 assessment considered BC IFLs:

• 58 IFLs in BC were considered. • 38 IFLs in BC were identified as specified risk by CAN-NRA-D2. • 12 IFLs materially overlapped with the HSPP supply area. At this time IFL 169 occurs in high

volume supply areas A and B and CMs are applied.

https://www2.gov.bc.ca/gov/content/environment/plants-animals-ecosystems/conservation-data-centre

https://www2.gov.bc.ca/gov/content/environment/plants-animals-ecosystems/conservation-data-centre


Table 3. HSPP supply risk conclusions by supply area, TSA and ecoregion

Supply HSPP Specified risk HSPP risk conclusion Area TSA/County Ecoregions HCV1 HCV2

A. Sunshine Coast and Vancouver Island

Kingcome Strathcona Sunshine Coast Part of Pacific TSA

Central Pacific coastal forests Puget lowlands forest BC mainland coastal forests

Goshawk, murrelet, Pacific shrew

IFL 169 High volume supply area. Specified risk for 5 species at risk and 1 IFL and CMs apply for mitigation. LOW risk for all other HCVs and CW risk categories B. Fraser

Valley and Merritt

Fraser Merritt

Puget lowlands forest BC mainland coastal forests Cascade mountains leeward forests Okanagan dry forests

Pacific giant salamander Oregon spotted frog

C. North Coast Kitimat

Kalum Parts of Pacific & Cascadia TSAs

BC mainland coastal forests 196, 206, 213, 223, 225, 238

Low volume supply area. LOW risk for all HCVs and CW risk categories Additional activities including supply area mapping, education and consultation for 6 IFLs that are expected to become specified risk in phase 2.


Williams Lk Soo Kamloops

BC mainland coastal forests Cascade mountain leeward forests Fraser plateau and basin complex Okanagan dry forests

Caribou 131, 134, 169

Low volume supply area. LOW risk for all HCVs and CW risk categories Additional activities including supply area mapping, education and consultation for one SAR species and 6 IFLs that are expected to become specified risk in phase 2.

D. Washington State low volume supply

To be determined at next annual fibre supply review

Willamette valley forests Blue mountains forests BC mainland coastal forests Cascade mtn leeward forests Central pacific coastal forests Central and S cascades forest Eastern cascades forests N. central rockies forests Okanagan dry forests Puget lowlands forests

Old growth forests

Low volume supply area. LOW risk for all HCVs and CW risk categories Additional activities including supply area mapping, education and consultation for 1 HCV1 (old growth forests) as well as Counties with forest conversion risk (risk category 4)

E. BC Negligible volume supply

Arrowsmith, Okanagan, QCI Kispiox Nass 100 Mile

Central pacific coastal forests Okanagan dry forests Queen Charlotte Islands BC mainland coastal forests

201, 202, 223, 238, 274

Negligible volume supply area. LOW risk for all HCVs and CW risk categories Additional activities including supply area mapping, education and consultation for 3 IFLs.

E. Oregon State negligible volume supply

To be determined at next annual fibre supply review

Willamette valley forests Blue mountains forests Central pacific coastal forests Central and S cascades forest Eastern cascades forests Great basin montane forests Klamath siskiyou forests N. California coastal forests

Old growth forests Klamath-Siskiyou critical biodiversity area

Negligible volume supply area. LOW risk for all HCVs and CW risk categories Additional activities including supply area mapping, education and consultation for 2 HCV1 as well as Counties with forest conversion risk (risk category 4)


Map 5. HSPP supply areas, TSAs and ecoregions

HSPP is using best management practices in this CWRA including consideration of ‘Interim Guidance for the Delineation Intact Forest Landscapes – May 25 2017’. The FSC guidance states that forest managers consider IFLs on a supply unit basis and managers must maintain a 50,000 ha core area according to the guidance. Only 20% of the IFL outside of protected areas can be impacted by new harvesting. HSPP is applying the FSC guidance to the TSA as a management unit in order to identify IFLs in TSAs with low risk or specified risk of sourcing unacceptable fibre. This analysis considers the amount of IFL in a TSA and/or ecoregion and if the IFL overlap to the TSA does not meet the 50,000 ha threshold and/or harvest cannot exceed 20% of the IFL within the jurisdiction, HSPP concludes low risk. The HSPP results might differ from the FSC Canada NRA D2 results considered only at the ecoregional level. IFL 131 occurs in both the BC Mainland Coastal Forest (54% of the IFL occurs in the BC Mainland Coastal Forest ecoregion considered by CAN-NRA-D2 as specified risk) and the Cascade Mountains Leeward Forests (46% of the IFL in this ecoregion and it is considered as specified risk) and relative to HSPP supply IFL 131 spans the Fraser TSA (high risk supply area B – 35%), the Soo TSA (low volume supply area D – 27%) and the Lillooet TSA which has no HSPP sourcing (38% of IFL 131 occurs in the Lillooet TSA). The Stein Valley Provincial Park overlaps the IFL providing >100,000 ha of protected area overlapping the IFL and this overlap occurs in the Lillooet TSA. There is not 50,000 ha of IFL in the Fraser TSA (HSPP Supply


Area B) and clarification is required with regard to how HSPP should consider IFL 131 crossing two IFLs and 3 TSA s. HSPP has concluded LOW risk at the individual IFL review level and HSPP will resolve its approach to this IFL during phase 1. HSPP does not provide the full IFL analysis to the public however HSPP is willing to share the results with interested stakeholders during consultations. 2. 2017 HSPP average supply assessment results HSPP used 2013-2017 fibre supply data to identify the BC TSAs and USA States where HSPP sources fibre. HSPP has a procedure to update the annual volume supply assessment and HSPP anticipates significant improvements to the supply assessment over time. HSPP has identified five groupings supply areas as depicted on Map 5 (i.e. showing only BC supply areas):

• BC high volume supply areas A (Vancouver Island and Sunshine Coast) and B (Fraser Valley and Merritt) and the TSAs sourced represents 81% of the average HSPP supply. HSPP has the greatest level of influence over forest managers in these supply areas.

• Low volume supply areas are defined as jurisdictions with 1-5% of annual average HSPP supply: o BC Area C on the BC North Coast is the Kalum TSA, and also includes small bits of the

Pacific and Cascadia TSAs. o BC Area D are 3 additional low volume TSAs in BC including the Williams Lake, Soo and

Kamloops TSAs. o The USA State of Washington is a low volume supply area for HSPP. o In phase 1, while HSPP phases in the full CW program, the low volume supply areas have

been assessed by HSPP with a low risk conclusion for sourcing unacceptable fibre. o In phase 2 HSPP anticipates bringing forward the low volume BC supply areas C and D

and Washington State fully into the CWRA and DDS with CMs to address specified risk, however, this will be done with experience built on a smaller set of specified risk values during phase 1.

• Regarding negligible volume supply HSPP has identified 6 BC TSA jurisdictions considering specified risk including Arrowsmith, Okanagan, QCI, Kispiox, Nass and 100 Mile Timber Supply Areas.

o In phase 1 of the CWRA and DDS implementation HSPP has identified negligible volume supply areas as low risk of sourcing unacceptable materials.

o In phase 2 and after the NRAs are fully integrated into the FSC CW standard, HSPP hopes to continue with the approach of assessing negligible supply areas as low risk of sourcing unacceptable materials. Stakeholders have endorsed this approach.

The 2017 assessment had several weaknesses with implications to the quality of the assessment:

• The assessment did not differentiate sourcing of logs or residual chips and such data can be collected by HSPP to improve future assessments.

• The residual chip sourcing allocation to a TSA reflects the location of the sawmill in a TSA as opposed to reflecting the outside boundaries of the sawmill supply. HSPP fibre sourcing staff reviewed the HSPP fibre sourcing results and commented that they do not anticipate significant changes to the assessment since distance and means of transportation have been considered. The next iteration of supply volume assessment is anticipated to reflect by-product chip supplier sourcing to a more accurate level.


• The current assessment included all sourcing even purchases of FSC-certified, FSC Controlled Wood and FSC reclaimed wood and future assessments may show only the sourcing of uncontrolled materials. Note that Oregon State has been downgraded from a ‘low volume’ to a ‘negligible volume’ supply area. At this time HSPP sources from only one Oregon company who is FSC CoC/CW certified and including Oregon as a negligible volume jurisdiction is a conservative approach.

3. HSPP supply and ecoregions The HSPP 2017 supply analysis showed the following ecoregions overlapping with the HSPP supply areas as shown on Map 2:

High, low and negligible volume supply in BC • BC mainland coastal forests – More than half of this ecoregion is considered, much of it is high

volume supply. • Central Pacific coastal forests – Most of the ecoregion is included in either low volume or high

volume HSPP supply areas. • Cascades mountains leeward forests – Almost all of this ecoregion is included in either negligible

volume or high volume HSPP supply areas. • Queen Charlotte Islands – The entire ecoregion is included in the HSPP negligible volume supply

area. • Okanagan dry forests – Almost all of this ecoregion is included in the either low volume or high

volume HSPP supply areas. Ecoregions with no or negligible HSPP supply in BC • North central rockies forests. • Central BC mountain forests. • Northern transitional alpine forests. • Pacific coastal mountain icefields and tundra.

At this time there is no indication of supply from the Central BC Mountain forest ecoregion, however, there may be supply originating from the North central Rockies forests and Northern transitional alpine forest ecoregions. In accordance with the HSPP approach as long as sourcing is less than 1% of annual mill supply, these ecoregions are excluded from the HSPP FSC CW system. Washington State and Oregon States have ecoregions as detailed in Table 3. Future HSPP CWRAs may take ecoregion into account in a more active manner regarding USA States and supply. 4. HSPP supply and BC TSAs The HSPP BC supply area assessment eliminated ecoregions from the HSPP supply area and this also resulted in the exclusion of some BC TSAs. Map 5 shows the BC HSPP supply areas and TSA boundaries. For example with the exclusion of the North central rockies forests ecoregion, TSAs are also eliminated including the Arrow, Cranbrook, Invermere, Revelstoke, Golden and Robson Valley TSAs. While it is possible that future HSPP supply assessments might find additional TSAs to have some level of HSPP sourcing, such new source TSAs are expected to have negligible volume sourcing resulting in a low risk conclusion for sourcing unacceptable fibre. Also applicable to this assessment is the consideration of fibre transportation method and location of the source. Very little HSPP supply comes to the pulp mill directly by road from local sources. Almost all


supply is transported by road to the ocean and barged to Port Mellon on the Pacific Ocean. HSPP has a means test considering distance and means of transport that is applied to consider supply origin. Supply amounts follow transportation corridors including:

• Vancouver Island forest roads and highways to ocean log dumps • BC Mainland Coast forest roads and highways to ocean log dumps • Interior highway transportation corridors to the Coast and ocean log dumps including Hwy 1

through the Fraser Valley and Hwy 16 to Kitimat. Areas at the margins of the HSPP supply area and at the margins of TSA/ecoregion boundaries are subject to some exclusions of supply including:

• The exclusion of the North central rockies forest ecoregion excludes the eastern portions of the Okanagan TSA, the Kamloops TSA and Williams Lake TSAs. As stated, future HSPP supply assessments might identify some supply from the eastern ends of these TSAs and the North central rockies forest ecoregion, however, supply is anticipated to be negligible volume.

• TSAs are anticipated to toggle between no sourcing and negligible sourcing from one assessment to the next. HSPP has procedures to bring new TSAs into the HSPP supply area or remove TSAs from consideration.

5. High volume supply areas In phase 1 HSPP is acknowledging all instances of specified risk associated with high volume supply areas including:

• Fraser TSA: o HCV1: Coastal Giant Salamander, Pacific water shrew, Oregon spotted frog o IFL 131 supply review assessed low risk in phase 1 as discussed in a section above.

• Kingcome TSA: o HCV1: Marbled murellet and Northern goshawk o HCV1: Caribou supply review assessed low risk o HCV2: IFL 169

Control measures include consultation, information gathering, education/awareness and experts. The control measures are oriented towards meeting the mandatory control measures of FSC Canada NRA D2. The HSPP assessment considered individual instances of HCV1 and HCV2 specified risk occurrence identified by the CAN-NRA-D2 to determine if the HCV occurrence was relevant. Best Management Practices (BMPs) have been considered. HCV1 caribou occurs in the HSPP supply area and HSPP examined in detail the overlap between mapped caribou range and the HSPP high risk supply area A. Regarding an overlap of caribou range with the HSPP high volume supply area A, HSPP used the GIS database and other resources to characterize the area. As seen in figure 1, imagery shows a mountainous area without discernable access and with little or no merchantable timber available for harvesting. HSPP research indicates that this area may be in a zone planned for ecosystem restoration and there are no plans for harvesting at this time. Finally the size of the area is negligible within the Kingcome TSA or supply area A. According to the HSPP assessment the caribou occurrence in the BC Mainland coastal forest ecoregion is not material in magnitude and there the caribou value is not under logging threat.


Figure 1. HCV1 Caribou specified risk site specific assessment

Figure 1 shows the caribou habitat overlap with HSPP supply area A and this is our ‘study area’ or ‘subject area’. Specifically the area in red is indicated as caribou habitat by the BC Conservation Data Centre and this area in red is also in the HSPP high volume supply area A. The blue area to the north and east is the caribou habitat area outside of the HSPP supply area and this is no longer the BC Mainland Forest ecoregion (identified as specified risk for caribou by CAN-NRA-D2) but is the Cascades Mountain leeward forest ecoregion (identified as low risk by CAN-NRA-D2). The subject area is at the margins of the caribou zone mapped by the CDC however, this study does not make any comments regarding the relative value of the subject area as caribou habitat … simply because it is inside the mapped boundary this initial analysis does not consider the value of the subject area to caribou. The green area is the Upper Klinaklini River Conservancy. The photo shows a previously harvested area to the north-west of the subject area. However, timber values in the subject area are low and the difficult terrain represents a significant barrier to further development. In conclusion, this detailed assessment of the small overlap area between high volume supply area A and mapped caribou habitat indicates a negligible risk of HSPP sourcing fibre from caribou habitat at this location. This assessment concludes low risk for caribou relative to supply area A. The HSPP approach to the inclusion of NRA instances of specified risk and the application of control measures that are modified from the Draft NRAs is as follows:

• HSPP has acknowledged all instances of specified risk identified by the Canada-NRA-D2. One IFL has been assessed as low risk.


• The Canada NRA remains a draft document awaiting approval. In phase 1 HSPP has modified the mandatory control measures of the draft NRAs.

• HSPP is not a forest manager and is using phase 1 to make connections to forest managers and learn about the species at risk and IFLs and their management as well as to make connections with stakeholders and experts.

• By concentrating on high volume jurisdictions to implement the HSPP CW system, HSPP is building capacity to take on additional instances of specified risk and implement control measures.

6. HSPP and low volume (1-5%) supply Low volume jurisdictions contribute 1-5% of the annual supply of fibre to the HSPP pulp mill. In phase 1 HSPP is acknowledging all instances of specified risk associated with low volume supply areas including:

• The Kalum TSA currently supplies 4% of annual volume supply to the HSPP mill and is supply area C.

o There are potential overlaps with 6 IFLs. o The potential overlap with a boreal caribou area to the Kalum TSA has been assessed as

not material to the HSPP supply. • The Williams Lake TSA supplies 3% of annual supply, the Soo TSA 1.3% and the Kamloops TSA

2.1%. o There is potential overlap with a boreal caribou area to the Williams Lake TSA.

• There is overlap with 3 IFLs and the Soo TSA: o IFL 131 also overlaps high volume supply area B and has been assessed as low risk in

phase 1. o IFL 169 also overlaps with high volume supply area A and HSPP is moving forward with

control measures relative to the area A supply. o HSPP has not implementing control measures regarding low volume jurisdictions in

phase 1 regarding IFLs 131, 134 and 169 and an overlap with the Soo TSA. Additional activities include supply area mapping, education and consultation.

• The Sunshine Coast TSA supplies only 3% of annual supply but this TSA is contiguous with Supply Area A and logically fits into the high-volume supply category particularly considering that this is home territory for the HSPP pulp mill.

• Also considered to be a low volume supply jurisdiction is Washington State. The USA-NRA-D3 acknowledges old growth forests as a category 3 specified risk as well as category 4 forest conversion concerns applied to some Washington State Counties.

Regarding this first iteration of the HSPP CWRA the low volume supply jurisdictions are low risk at a supply level:

• The NRA processes in Canada and the USA have not been completed and there is continued uncertainty regarding specified risk and control measures.

• HSPP has no formal business relationships with forest managers or stakeholders. It is in the interest of all parties to allow HSPP to start consultations regarding control measures relative to high volume source areas.

• USA supply in particular is more challenging for HSPP to assess due to a lack of familiarity with American stakeholders and risk considerations to the BC-based HSPP.

Regarding an overlap of caribou range with the HSPP low volume supply area C, HSPP conducted a site-specific assessment of this supply area. HSPP found that most of the caribou overlap with the Kalum


TSA and HSPP supply was actually the Kitlope Heritage Conservancy Provincial Park. Although there is an area of caribou habitat available for harvest it is less than several hundred hectares in size. One cutblock harvested in 1979 occurs in this area. HSPP considers there to be no material risk that harvesting will impact this caribou zone. The aerial photos involved in the analysis is not provided in this paper but is available upon request. During phase 1 HSPP has acknowledged the boreal caribou habitat overlap to the Williams Lake TSA and HSPP is not applying control measures to low volume jurisdictions. The caribou habitat overlap occurs at the limits of the HSPP supply area and HSPP is undertaking additional activities to prepare for phase 2 and full implementation of the Canada NRA. Supply area mapping will be of particular interest to HSPP to determine if caribou is at risk relative to the HSPP supply area. During phase 1 HSPP has acknowledged the Washington State instances of specified risk and HSPP is not applying the Draft NRA control measures recommended by the USA NRA Draft 3. Additional activities including contacting the FSC US-coordinated Controlled Wood Regional Meetings and to contact forest managers and undertake supply area mapping, education and consultation. In phase 2 HSPP will be implementing the full NRA results including acknowledging all instances of specified risk and applying mandatory control measures. 7. HSPP and negligible (<1%) supply Negligible volume supply jurisdictions are those supplying less than 1% of the annual HSPP fibre supply. In phase 1 HSPP is acknowledging all instances of specified risk associated with negligible supply volume area E:

• In the Kispiox TSA IFLs 223, 238 and 274 potentially overlap with the HSPP supply area E. • In the Queen Charlotte TSA IFLs 201 and 202 potentially overlap with the HSPP supply area E. • In the Arrowsmith TSA there are two species at risk, the marbled murrelet and the Northern

goshawk. • The state of Oregon has several HCVs identified by the USA-NRA-D3 with specified risk including

controlled wood category 3 HCVs old growth forests and the Klamath-Siskiyou critical biodiversity area and controlled wood category 4 are select Counties with forest conversion risk.

• While the HSPP CWRA acknowledges the BC values at risk including two species at risk and 5 IFLs as specified risk, no control measures are being implemented during phase 1. Additional activities include supply area mapping, education and consultation.

• While HSPP is acknowledging the Oregon instances of specified risk (two HCVs and forest conversion) no control measures are being implemented in phase 1. Additional activities include contacting the FSC USA Controlled Wood Regional Meeting and engage in supply area mapping, education and consultation.

Maps 1 and 5 show HSPP supply area E and these are the negligible volume supply areas. At this time HSPP has set an arbitrary threshold of 1% of annual HSPP supply applied at the TSA-level to define ‘negligible volume’ supply areas. The following are the considerations:

• The FSC CW standard defines ‘low risk’ as “negligible” risk of sourcing unacceptable materials and HSPP notes that the standard does not state NO risk.

• The application of thresholds is common in conservation biology. The FSC Canada working group applied thresholds regularly to determine the forest values that are identified with specified risk of being sourced as unacceptable materials. HSPP is taking the exact same


approach as the FSC Canada working group and HSPP is applying defensible thresholds to its supply area.

• As of the 2017 HSPP fibre sourcing assessment there were six BC TSAs with supply less than 1% each: Kispiox 0.1%, Okanagan 0.5%, QCI 0.8%, Arrowsmith 0.6%, Nass 0.1% and 100 Mile 0.1%. The maps showing the supply areas demonstrate these areas to be logical end zones of highway transportation corridors to the Coast. Not only is HSPP sourcing from these TSA at a negligible volume level, the probability of sourcing specified risk HCVs has a further diminishing probability since specified risks affect only a small portion of the TSAs.

• The negligible supply areas have HCV1 and HCV2 identified by Draft NRAs with CMs indicated. HSPP is declaring negligible supply jurisdictions as low risk.

• Marginal supply areas are anticipated to vary from no supply to negligible supply from one assessment period to another. Since HSPP does not action negligible supply with control measures this category of supply serves as a buffer to stop supply areas popping in and out of the system over successive years.

• HSPP has more influence over forest managers and harvesting planning and practices in high volume supply areas and little or no influence at negligible supply areas. HSPP considers that forest managers may be difficult to engage considering that the HSPP supply is negligible in their supply area.

• HSPP has not built relationships with communities, stakeholders, aboriginal groups and the public. It will be a challenge for HSPP to start the process of building relationships relative to even a smaller number of HCVs associated with the high volume supply areas and it is not practical to consider that HSPP can implement meaningful programs involving areas with negligible supply.

The HSPP supply assessment identified Oregon State as supply of 5% of HSPP annual average fibre usage. However, all the Oregon supply is purchased from a supplier with a current FSC CoC/CW certificate. At this time Oregon State is considered as a negligible supply area and this is a conservative approach. HSPP has procedures to annually test supply and identify negligible risk ecoregions and TSAs. With the next HSPP supply assessment HSPP anticipates a greater number of negligible risk areas will be identified.


C. Control Measures Mitigate Specified Supply Risk to Low Risk Table 4. Control measures summary

HSPP Supply Risk NRA Proposed Mandatory CMs HSPP Actions Area/TSAs HCV at risk HSPP CM applied Other actions

A. Kingcome, Strathcona, N. Island, Pacific TSA overlap with Central Pacific coastal forest ecoregion (Vancouver Island) B. Fraser and Merritt TSAs and overlap with Puget Sound lowlands ecoregion

Marbled murrelet Northern goshawk Oregon spotted frog Coastal Giant Salamander Pacific water shrew

Evidence demonstrates harvesting does not take place in critical habitats for Specified Risk species identified. Experts confirm that the forests in the sourcing area have a forest management plan that details their contribution to the recovery of the species at risk, consistent with the Federal Recovery Strategy or approved Action Plan

A. 5 SAR in BC high volume jurisdictions Objective: Prepare for full implementation of the relevant approved NRAs regarding 5 SAR in high volume supply jurisdictions. During phase 1 HSPP will identify and map species at risk known occurrence and habitat relative to the HSPP wood supply and other conservation considerations (e.g. protected areas) to determine if the SAR is at risk due to HSPP fibre supplier’s forest management activities. Engage in consultation activities, information gathering, conduct education and awareness activities and contact forest managers and experts. Activities that may be considered include: 1. Consultation activities • Summarize forest management legal requirements

regarding these SAR species including federal, provincial and municipal governments.

• From credible sources or experts summarize the conservation status relative to specific habitat values of concern regarding forest management considering private and public land ownership.

• Information gathering and/or information exchange with forest managers at the planning and practices levels regarding conservation and values at risk.

• Information gathering and exchange with stakeholders as per FSC CW Standard at Annex B.

• Contact industry, Provincial, Federal or other groups with similar conservation goals and assess the information available from established and credible sources.

2. Education and awareness activities

6. Explore partnering with organisations to facilitate consultation, education and awareness, experts in order to streamline and focus HSPP effort and mitigate costs of applying the CM.



• Make conservation information available to Forest Managers and stakeholders.

• Make information on conservation status and planning and practices available.

• Make information from experts available. 3. Use of experts • Identify experts as per FSC CW Standard Annex C. • Contact experts and communicate the HSPP CWRA. 4. The HSPP DDS Summary includes a summary of HSPP process and progress to the identification of experts confirming that forest management plans as required by the CM..

Managers of private forests, interested and affected stakeholders, Indigenous Peoples, Species at Risk experts*, provincial and/federal representatives and Certificate Holders involved in the sourcing area participate in a regional meeting that result in agreed-upon actions related to regionally appropriate best practices. The agreed-upon actions related to regionally appropriate best practices are being implemented in the sourcing area.

Managers of private land also participate in CMs 1-4 above. 5. The HSPP DDS Summary includes a summary of HSPP process and progress regarding a regional meeting as required by the CM.

7. Explore partnering with private forest land organisations with an interest in implementing the CM.

IFL 169 Forest operations do not occur within IFLs. OR Forest operations do not reduce IFLs below 50,000 ha, AND all meet cumulative impact parameters as detailed in the CAN-NRA-D2. Evidence demonstrates that a minimum of 80% of the IFL is not threatened by forest management operations in the long-term. AND The cumulative impacts of forest harvesting will not reduce the IFL to below 50,000 ha.

B. IFL 169 in BC high volume Kingcome TSA Objective: Prepare for full implementation of the relevant approved NRAs regarding one IFL in a high volume supply jurisdiction (i.e. Kingcome TSA). During phase 1 HSPP will identify and map the IFL relative to the HSPP wood supply and other conservation considerations (e.g. protected areas) to determine if the IFL is at risk due to HSPP fibre supplier’s forest management activities. Engage in consultation activities, information gathering, conduct education and awareness activities and contact forest managers and experts. Activities that may be considered include: 1. Consultation activities

3. Explore partnering with organisations to facilitate consultation, education and awareness in order to streamline and focus HSPP effort and mitigate costs of applying the CM.



• Information gathering and/or information exchange with forest managers at the planning and practices levels regarding conservation and IFL values at risk.

• Information gathering and exchange with stakeholders as per FSC CW Standard at Annex B.

• Contact industry, Provincial, Federal or other groups with similar conservation goals and assess the information available from established and credible sources.

• Detailed GIS-based assessment of the IFL to confirm the boundaries and assess the landform to ensure the definitions of an IFL are met.

2. Education and awareness activities • Make conservation information available to Forest

Managers and stakeholders. • Make information on conservation status and

planning and practices available. C. Kalum TSA in the BC mainland coastal forest D. Soo TSA and Williams Lake TSAs in the BC mainland coastal forest and Cascade Mountains leeward forests and Fraser Plateau and Basin complex ecoregions E. Kispiox TSA in the BC mainland coastal forest E. Queen Charlotte TSA in the Queen Charlotte ecoregion

IFLs 196, 206, 213, 223, 225 and 238 131, 134 and 169 223, 238, 274 201, 202

As per IFL above Control Measures do not apply to LOW supply risk sources

1. Additional activities including supply area mapping, education and consultation. 2. Explore partnering with other organisations to streamline and focus HSPP conservation efforts.



E. Arrowsmith TSA in the Central Pacific coastal forest Ecoregion (VI)

Marbled murrelet Northern goshawk

D. Williams Lake TSAs in the Fraser Plateau and Basin complex ecoregions

Caribou Evidence demonstrates that harvesting does not take place in critical habitats

Control Measures do not apply to LOW supply risk sources

1. Additional activities including supply area mapping, education and consultation. 2. Explore partnering with other organisations to streamline and focus HSPP conservation efforts.

D Washington State Old growth forests

The Organization avoids sourcing from sites where the HCV that is associated with the specified risk area occurs. OR A representative of the Organization attends FSC US-coordinated Controlled Wood Regional Meetings when they occur. AND For each area of specified risk from which the Organization sources materials, the Organization implements one or more of the actions identified during the collaborative dialogue at the Controlled Wood Regional Meeting, as detailed in the Controlled Wood Regional Meeting Report

Control Measures do not apply to LOW supply risk sources

1. Contact FSC US-coordinated Controlled Wood Regional Meetings and notify organisation of HSPP assessment findings. 2. Additional activities including supply area mapping, education and consultation.

E. Oregon State E. Oregon State Klamath-

Siskiyou critical biodiversity area

D Washington State Category 4 forest conversion

The Organization avoids sourcing from sites where natural or semi-natural forest is being converted to non-forest or plantations. OR A representative of the Organization attends FSC US-coordinated Controlled Wood Regional Meetings when they occur. AND Actions identified must help to achieve an outcome specified in the Standard.

1. Contact FSC US-coordinated Controlled Wood Regional Meetings and notify organisation of HSPP assessment findings. Request the 4.1 Exception. 2. Additional activities including supply area mapping, education and consultation

E. Oregon State

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