forest stewardship council: stakeholder outreach...

Forest Stewardship Council

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Report on the FSC Stakeholder Outreach on Principles and Criteria Version 5

21st May 2012

1. Background

In February 2012 the Forest Stewardship Council (FSC) membership approved a major revision of the FSC Principles and Criteria (P&C), FSC’s international standard for forest stewardship. The revised FSC P&C is accompanied by a second, longer document, providing extensive, but non-normative ‘explanatory notes’. FSC is now about to initiate a process to develop a set of ‘international generic indicators’ (IGIs), the next level down in a hierarchical approach to implementation of the FSC P&C. Approval of the revised P&C was the culmination of a long consultative process, during which FSC sought to achieve consensus amongst its diverse stakeholders. While many members were quite pleased with the revisions made, particularly regarding social issues, there were also a number of key FSC members who were not fully satisfied with all aspects of the final text. Before the start of the IGI development process the FSC Policy and Standards Unit (PSU) therefore decided to reach out to the membership so that outstanding concerns can be taken fully into account during the process to develop IGIs, and so that the IGIs address key issues in ways which are widely supported. To this end the FSC PSU contracted the independent consultancy OneWorldStandards Ltd to:

o Survey the FSC membership to determine how they perceive key issues and how these should be addressed in the IGIs;

o Determine the nature of any major outstanding concerns as well as remedies

that the stakeholders with such concerns would themselves propose in order for the concerns to be resolved to their satisfaction;

o Inform stakeholders that the results of the analysis are presented to FSC, and

that FSC is undertaking processes to address the issues identified by the analysis;

o Interview stakeholders on best practices for an effective process for the

development of the IGIs. This report summarizes the findings from the survey and interview.


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2. Methodology

In order to achieve the project objectives, OneWorldStandards prepared a Briefing Paper to explain the background and approach of the project to FSC members and potential consultees. The Briefing Paper (‘Briefing Paper: Preliminary Outreach to FSC Membership in Preparation for the Development of FSC International Generic Indicators’, 17th April 2012) was translated into Spanish, circulated to FSC members and published on the FSC website (www.igi.fsc.org).

The paper was accompanied by an on-line survey also available in English and Spanish (submitted separately). FSC members and partner organizations were invited to complete the survey and, if interested could put themselves forward to be interviewed in English or Spanish. In addition the FSC PSU provided the names of FSC representatives that they wished to be included in the interview process.

3. Survey Findings

3.1 Survey Response Ninety five (95) FSC members or Partners provided their names and FSC affiliations in response to the survey, twenty eight (28) of whom provided substantive responses. Eleven (11) individuals were interviewed by phone. A number of the respondents carried out local chamber consultation and responded on behalf of groups of stakeholders. A full list of people who responded to the survey and or were interviewed is given in Annex One. Table 1 shows a breakdown of survey respondents and interviewees by FSC chamber. The preponderance of interviewees from the ‘north’ reflects both the list of interviewees put forward by FSC and self-selection from survey participants. One of the ‘northern environmental’ interviewees noted that he was representing a group of both ‘northern’ and ‘southern’ FSC environment chamber members. Table 1. Survey respondents and interviewees by FSC chamber:

FSC Chamber Entered survey Substantive

responses to survey Interviewed

Economic North 24 5 3

Economic South 14 6 1

Environmental North 19 9 7

Environmental South 4 1 0

Social North 2 0 0

Social South 7 1 0

FSC Network Partner 25 5 0

Sub-total North 45 15 10

Sub-total South 25 8 1

http://www.igi.fsc.org/


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Sub-total Economic 38 11 4

Sub-total Environmental 23 11 7

Sub-total Social 9 1 0

ALL 95 28 11

3.2 Findings: Part One Summary In Part One of the survey stakeholders were asked to identify FSC Criteria where they felt that additional work should be focused in order to resolve ambiguities, apparent inconsistencies or other concerns in relation to the FSC Principles and Criteria. There was no limit to the number of Criteria that each respondent could identify as requiring further work, but respondents were encouraged to identify only those Criteria where they felt the issues requiring further work were most important. Twenty seven (27) respondents completed this part of the survey. Tables summarizing the responses in relation to each FSC principle, by FSC chamber are provided in Annex Two. For each FSC Principle the the first two sections of each table show i) the numbers of respondents in each FSC chamber identifying each Criterion as being associated with important issues requiring further work; and ii) the same information normalized so that the data show the percentage of respondents in each FSC chamber who identified the Criterion as being associated with important issues requiring further work. The column at the end of the table shows the information collated for the Principle as a whole. The figures have been colored to highlight Criteria identified as important by more than one respondent. These tables give a qualitative indication of the numbers of respondents identifying Criteria as important, but should not be interpreted quantitatively. There were different numbers of respondents from each FSC chamber, and some respondents were answering on behalf of a group of stakeholders from their chamber and region (in particular: one Environmental North respondent was responding on behalf of several FSC environmental chamber members from both northern and southern sub-chambers; one Economic North respondent was responding on behalf of nine northern economic sub-chamber members; and one Economic South respondent was responding on behalf of a group of southern economic sub-chamber members). Perhaps the most notable finding is the overall number of different Criteria that different members considered to be in need of further work. Only three Criteria (C1.5, C3.5 and C7.1) were never mentioned. The Criteria of Principles 1, 2, 3 and 8 tended to be mentioned least, and those of Principles 6, 9 and 10 the most. The final section of each table identifies the Criteria for which at least one respondent in the relevant FSC chamber (treating the FSC Network Partners as a chamber in this case) considered the Criterion to be associated with an important issue requiring further work. The final row of this section then highlights the Criteria that were identified as important by at least one FSC member in at least five out of the six chamber categories shown (North, South, Environmental, Social, Economic or FSC Network Partner). This row highlights the Criteria identified as important across the range of FSC chamber categories, even if the


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Criterion was not highlighted as being especially important within any chamber category. This way of identifying issues of broad importance is not affected by the fact that some respondents replied on behalf of multiple FSC members. The final row on each table highlights the Criteria that were identified as important by more than 25% of the respondents within at least one FSC chamber category1. The intent is to identify issues that were considered especially important within any given FSC chamber. The table below lists the Criteria that were highlighted in this way either as being important to a relatively high percentage of respondents within any given chamber, or being recognized as important across a wide range of chambers. There is a high, but not complete level of overlap between the two measures.

Principle

Criteria highlighted as requiring further work by more than 25% of the respondents within at least one FSC chamber

Criteria highlighted as requiring further work by at least one FSC member from at least five of the FSC chamber categories.

Criteria highlighted as requiring further work by either approach, with Criteria identified by both approaches highlighted in green

Principle One C1.4 C1.1 C1.1, C1.4

Principle Two C2.3 C2.3

Principle Three

Principle Four C4.2, C4.3, C4.4 C4.4 C4.2, C4.3, C4.4

Principle Five C5.2, C5.3, C5.4 C5.2, C5.3, C5.4 C5.2, C5.3, C5.4

Principle Six C6.4, C6.5, C6.6, C6.7, C6.8, C6.9, C6.10

C6.1, C6.5, C6.6, C6.9, C6.10

C6.1, C6.4, C6.5, C6.6, C6.7, C6.8, C6.9, C6.10

Principle Seven C7.2, C7.6 C7.2, C7.3, C7.6 C7.2, C7.3, C7.6

Principle Eight

Principle Nine C9.1, C9.2, C9.3 C9.1, C9.2 C9.1, C9.2, C9.3

Principle Ten C10.1, C10.2, C10.3, C10.4, C10.6, C10.7

C10.1, C10.3, C10.4, C10.6, C10.7, C10.9

C10.1, C10.2, C10.3, C10.4, C10.6, C10.7, C10.9

1 In the case of the FSC Social Chamber there was only one respondent, so any issue identified by this

respondent would have recorded a 100% level of importance. Issues identified as important only by this one respondent have not been highlighted.


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3.2 Findings: Part Two Summary Part Two of the survey sought information on the specific issues that were of concern. Respondents were asked: to describe the issues of particular concern; identify the Criterion with which the issue is associated; identify any other references to FSC documentation; and describe how they felt the issue could be best resolved from a range of options. Nineteen respondents completed this part of the survey, but those that did respond provided extensive inputs. The complete set of responses is provided in Annex Three. In summary, respondents identified 113 issues for consideration, covering all ten FSC Principles. The table below gives an indication of the distribution of issues in relation to different FSC Principles.

Principle

Number of times mentioned as issue

Principle One 8

Principle Two 5

Principle Three 2

Principle Four 7

Principle Five 8

Principle Six 27

Principle Seven 8

Principle Eight 6

Principle Nine 16

Principle Ten 10

General 10

For reasons of space the annex does not include the listing of how stakeholders proposed the issue could be resolved in relation to development of IGIs, explanatory notes or revisions to policies or standards, but this information has been provided separately as an Excel spreadsheet. 3.3 Findings: Part Three Summary Part Three of the survey focussed on issues related to the process to be followed for the development of FSC IGIs. The responses are given in Annex Four. Twelve respondents completed this part of the survey, and six of these were also interviewed. Since the interviews focussed on process issues the comments from this part of the survey are considered together with the interview responses in the following section of this report.

4. Interview Findings

The interviews focused mainly on clarifications and questions of process, since the survey format itself provided for most substantive proposals in relation to content. To be completed.


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Annex One: List of consultees:

# Name Affiliation FSC Chamber Entered survey

Substantive response to survey

Inter-viewed

1 Kathryn Fernholz Dovetail Partners Environmental North

2 Meriel Robson individual Environmental North

3 Miguel Sampol Pou individual Economic South

4 Gary Dodge FSC US (non-member)

(FSC Network Partner)

5 Blake Brunsdon individual Economic North

6 Tony Arifiarachman individual Economic South

7 Gerrit Marais SGS South Africa Economic South

8 Karin Fällman Sveaskogs förvaltning AB

Economic North

9 John Dunn Individual Economic South

10 Jan Huyser Komatiland Forests Pty (Ltd)

Economic South

11 Naoya Ogawa AMITA Institute of Environmental Certification Co.

Economic North

12 Yasunori Iwase FSC Japan (FSC Network Partner)

13 Severin K Kalonga NFP Tanzania Economic South

14 Life Forestry Switzerland Economic North

15 David Marren Li-Lo Leisure Products Ltd

Economic North

16 Ben Vickers Individual Social North

17 Peter K. Kristensen Dalhoff Larsen & Horneman A/S

Economic North

18 Joana dos Guiamrães Sá

APCER Associação Portuguesa de Certificação

Economic North

19 Anna FSC Danmark (FSC Network Partner)

20 Clement Chevignon Bureau Veritas Economic North

21 Nick Barnicoat Indivdual Economic North

22 Greg Monteath Individual (FSC Network Partner)

23 Marcella Beers Advertisers Printing (FSC Network Partner)

24 Rodney Blair Eglinton (Timber Products) Ltd

Economic North

25 Andrew Ramirez Midwest Hardwood Corporation

Economic North

26 Jay Francis Collins Companies Economic North

27

Pat Joensuu, independent contract lead auditor

Scientific Certification Systems


28 Kimberly Clark Kimberly Clark (FSC Network Partner)

29 Ayuk Karl Agbor Cafeco SA Social South

30 H. Mahinda Individual Economic South


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Goonasekara

31 Luciana Rocha Antunes

IPEF Economic South

32 Ric Slaco Interfor Economic North

33 Dale Oliver-Jones Bound Oak Ltd Economic North

34 Olatunde Johnson Friends of the Earth Sierra Leone

Environmental South

35 Sheila Andrew individual (FSC Network Partner)

36 Blandine NSOMBO MOSOMBO

UNIVERSITY OF KINSHASA

Environmental South

37 BOLALUEMBE BOLIALE,Papy-Claude

Network Partner (FSC Network Partner)

38 Dr. VERMA DPS Individual Social South

39 Mike Lipke Trillium Pacific Millwork, Inc.

Economic North

40 Rudy Setyawan individual (FSC Network Partner)

41 Malene Tygesen NEPCon Denmark Environmental North

42 David Everard Sappi Southern Africa (Pty) Ltd

Economic South

43 Steve Robinson border Oak ltd (FSC Network Partner)

44 Elmar Seizinger FSC Germany (FSC Network Partner)

45 John SB Scotcher National Representative South Africa


46 Dave Bubser Rainforest Alliance (FSC Network Partner)

47 John W. McNulty Seven Islands Land Company

Economic North

48 John Cathro Individual member, FSC Canada Board Member

Environmental North

49 Cheong FSC COC (FSC Network Partner)

50 Tiago Carvalho de Morais

Plantar Economic South

51 Line Guignard DATA Group of Companies

Economic North

52 Peter Dam individual Economic South

53 Darius Sarshar New Forests Asia Economic South

54 Peter Feilberg NEPCon Economic North

55 Tim Rayden WCS Environmental North

56 Margareta Renström

WWF International Environmental North

57 Bill Barclay Rainforest Action Network

Environmental North

58 José Luis Rengifo Balanta

Individual Social South

59 Marvin Centeno Solorzano

Individual Environmental South

60 Juan Carlos Benitez Individual (FSC Network


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Partner)

61 Rogelio Gonzalez Tato

Iniciativa en Gestion Forestal


62 Osvaldo Munguia CH CFV FSC Honduras

Social South

63 Yellen Aguilar-Ararat

GTCFV / FSC - COLOMBIA


64 Carlos Ramírez de Arellano

MASISA Economic South

65 Luis Javier Sánchez Hernando

Norfor Economic North

66 Leonie van der Maesen

member Environmental North

67 Colin Maunder Timberlands Limited Economic North

68 Henrik von Stedingk FSC Sweden (FSC Network Partner)

69 Caroline Pufalt Sierra Club Environmental North

70 j r palmer individual Environmental North

71 Coen van der Veer FNV Bouw Social North

72 Michael Needham Waddington & Ledger Ltd

Economic North

73 Richard Taylor Columbia Forest Products

Economic South

74 Christoph Thies Greenpeace Environmental North

75 Tom Roche Just Forests Environmental North

76 Guus Bos FSC NL (FSC Network Partner)

77 Arjan Alkema FSC Netherlands (FSC Network Partner)

-

79 Jens Holm Kanstrup Forests of the World / (Formerly Nepenthes)

Environmental North

80 Daniel Hall individual Environmental North

81 Hans Djurberg

SCA Skog AB, Stora Enso Skog AB, Sveaskog, Södra, The Swedish Church, Holmen Skog AB, Bergvik Skog AB, Korsnäs, Skogssällskapet

Economic North

-

83 Marie Vallée FSC France (FSC Network Partner)

84 Dean Hoover Individual Environmental North

85 Jack B Petrie AIA LEED AP

AIA, USGBC (FSC Network Partner)

86 Prasetyo Admojo PT. Kayu Lapis Indonesia

Environmental North

87 Shuhei TOMIMURA Tomimura Economic North


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Environment Research Office

88 mirawati Walhi jabar Environmental North

89

Grant Rosoman, on behalf of FSC member organisations (enviro Nth and Sth)

Greenpeace Environmental North

90 Giulio Di Lallo individual Environmental South

91 Vera Santos FSC Portugal (FSC Network Partner)

92 Terry Cundy Potlatch Forest Holdlings, Inc.

Economic North

93 Manmohan Yadav Individual Social South

94 Neva Murtha Canopy (stakeholder, not member)


95 Hannah Yourd Northwest Natural Resource Group

Environmental North

96 Raul Lopez Individual Social South

97 Isis Valeska Lagos Bustamante

Individual Social South

Jim Newberry Potlatch Corporation Economic North

Fran Price The Nature Conservancy

Environmental North

N 95 28 112

2 Emails were exchanged with Tim Rayden, Martha Nuñez and Anders Lindhe but it was not possible

to arrange a mutually convenient time to carry out interviews.


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Annex Two: Tables showing results for Part One of the survey. See text for explanation

Principle 1

C1.1 C1.2 C1.3 C1.4 C1.5 C1.6 C1.7 C1.8 P1

Total North N= 14 1 1 0 4 0 0 0 1 7

Total South N= 8 1 0 2 0 0 2 2 1 8

Total Economic N= 12 1 1 1 1 0 2 1 1 8

Total Environmental N= 9 0 0 0 3 0 0 0 1 4

Total Social N= 1 1 0 1 0 0 0 1 0 3

Network Partners N= 5 1 0 1 1 0 0 0 0 3

TOTAL N= 27 3 1 3 5 0 2 2 2 18

Principle 1

C1.1 C1.2 C1.3 C1.4 C1.5 C1.6 C1.7 C1.8 P1

Total North N= 14 7.1 7.1 0.0 28.6 0.0 0.0 0.0 7.1 6.3

Total South N= 8 12.5 0.0 25.0 0.0 0.0 25.0 25.0 12.5 12.5

Total Economic N= 12 8.3 8.3 8.3 8.3 0.0 16.7 8.3 8.3 8.3

Total Environmental N= 9 0.0 0.0 0.0 33.3 0.0 0.0 0.0 11.1 5.6

Total Social N= 1 100.0 0.0 100.0 0.0 0.0 0.0 100.0 0.0 37.5

Network Partners N= 5 20.0 0.0 20.0 20.0 0.0 0.0 0.0 0.0 7.5

ALL N= 27 11.1 3.7 11.1 18.5 0.0 7.4 7.4 7.4 8.3

Principle 1

C1.1 C1.2 C1.3 C1.4 C1.5 C1.6 C1.7 C1.8 P1

Total North N= 14 1 1 0 1 0 0 0 1 50%

Total South N= 8 1 0 1 0 0 1 1 1 63%

Total Economic N= 12 1 1 1 1 0 1 1 1 88%

Total Environmental N= 9 0 0 0 1 0 0 0 1 25%

Total Social N= 1 1 0 1 0 0 0 1 0 38%

Network Partners N= 5 1 0 1 1 0 0 0 0 38%

ALL N= 27 5 2 4 4 0 2 3 4

C1.1 C1.2 C1.3 C1.4 C1.5 C1.6 C1.7 C1.8 P1


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Principle 2

C2.1 C2.2 C2.3 C2.4 C2.5 C2.6 P2

Total North N= 14 1 0 1 2 1 1 6

Total South N= 8 1 1 1 0 0 0 3

Total Economic N= 12 1 0 1 2 1 1 6

Total Environmental N= 9 0 0 0 0 0 0 0

Total Social N= 1 1 1 1 0 0 0 3

Network Partners N= 5 0 1 1 0 0 0 2

TOTAL N= 27 2 2 3 2 1 1 11

Principle 2

C2.1 C2.2 C2.3 C2.4 C2.5 C2.6 P2

Total North N= 14 7.1 0.0 7.1 14.3 7.1 7.1 7.1

Total South N= 8 12.5 12.5 12.5 0.0 0.0 0.0 6.3

Total Economic N= 12 8.3 0.0 8.3 16.7 8.3 8.3 8.3

Total Environmental N= 9 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Total Social N= 1 100.0 100.0 100.0 0.0 0.0 0.0 50.0

Network Partners N= 5 0.0 20.0 20.0 0.0 0.0 0.0 6.7

ALL N= 27 7.4 7.4 11.1 7.4 3.7 3.7 6.8

Principle 2

C2.1 C2.2 C2.3 C2.4 C2.5 C2.6 P2

Total North N= 14 1 0 1 1 1 1 83%

Total South N= 8 1 1 1 0 0 0 50%

Total Economic N= 12 1 0 1 1 1 1 83%

Total Environmental N= 9 0 0 0 0 0 0 0%

Total Social N= 1 1 1 1 0 0 0 50%

Network Partners N= 5 0 1 1 0 0 0 33%

ALL N= 27 4 3 5 2 2 2

C2.1 C2.2 C2.3 C2.4 C2.5 C2.6 P2


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Principle 3

C3.1 C3.2 C3.3 C3.4 C3.5 C3.6 P3

Total North N= 14 1 2 1 1 0 1 6

Total South N= 8 0 0 0 0 0 0 0



Total Social N= 1 0 0 0 0 0 0 0


TOTAL N= 27 1 2 2 1 0 1 7

Principle 3

C3.1 C3.2 C3.3 C3.4 C3.5 C3.6 P3

Total North N= 14 7.1 14.3 7.1 7.1 0.0 7.1 7.1

Total South N= 8 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Total Economic N= 12 0.0 8.3 8.3 8.3 0.0 8.3 5.6


Total Social N= 1 0.0 0.0 0.0 0.0 0.0 0.0 0.0


ALL N= 27 3.7 7.4 7.4 3.7 0.0 3.7 4.3

Principle 3

C3.1 C3.2 C3.3 C3.4 C3.5 C3.6 P3

Total North N= 14 1 1 1 1 0 1 83%

Total South N= 8 0 0 0 0 0 0 0%

Total Economic N= 12 0 1 1 1 0 1 67%


Total Social N= 1 0 0 0 0 0 0 0%


ALL N= 27 2 3 3 2 0 2

C3.1 C3.2 C3.3 C3.4 C3.5 C3.6 P3


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Principle 4

C4.1 C4.2 C4.3 C4.4 C4.5 C4.6 C4.7 C4.8 P4

Total North N= 14 2 2 1 1 0 1 0 1 8

Total South N= 8 0 2 2 5 0 1 2 0 12

Total Economic N= 12 1 4 3 4 0 1 2 1 16

Total Environmental N= 9 1 0 0 1 0 0 0 0 2

Total Social N= 1 0 0 0 1 0 1 0 0 2

Network Partners N= 5 1 0 1 2 1 0 0 0 5

TOTAL N= 27 3 4 4 8 1 2 2 1 25

Principle 4

C4.1 C4.2 C4.3 C4.4 C4.5 C4.6 C4.7 C4.8 P4

Total North N= 14 14.3 14.3 7.1 7.1 0.0 7.1 0.0 7.1 7.1

Total South N= 8 0.0 25.0 25.0 62.5 0.0 12.5 25.0 0.0 18.8

Total Economic N= 12 8.3 33.3 25.0 33.3 0.0 8.3 16.7 8.3 16.7

Total Environmental N= 9 11.1 0.0 0.0 11.1 0.0 0.0 0.0 0.0 2.8

Total Social N= 1 0.0 0.0 0.0 100.0 0.0 100.0 0.0 0.0 25.0

Network Partners N= 5 20.0 0.0 20.0 40.0 20.0 0.0 0.0 0.0 12.5

ALL N= 27 11.1 14.8 14.8 29.6 3.7 7.4 7.4 3.7 11.6

Principle 4

C4.1 C4.2 C4.3 C4.4 C4.5 C4.6 C4.7 C4.8 P4

Total North N= 14 1 1 1 1 0 1 0 1 75%

Total South N= 8 0 1 1 1 0 1 1 0 63%

Total Economic N= 12 1 1 1 1 0 1 1 1 88%

Total Environmental N= 9 1 0 0 1 0 0 0 0 25%

Total Social N= 1 0 0 0 1 0 1 0 0 25%

Network Partners N= 5 1 0 1 1 1 0 0 0 50%

ALL N= 27 4 3 4 6 1 4 2 2

C4.1 C4.2 C4.3 C4.4 C4.5 C4.6 C4.7 C4.8 P4


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Principle 5

C5.1 C5.2 C5.3 C5.4 C5.5 P5

Total North N= 14 1 6 3 3 2 15

Total South N= 8 1 2 1 2 0 6

Total Economic N= 12 2 2 1 4 0 9

Total Environmental N= 9 0 6 3 1 2 12

Total Social N= 1 0 0 0 0 0 0

Network Partners N= 5 0 2 1 1 0 4

TOTAL N= 27 2 10 5 6 2 25

Principle 5

C5.1 C5.2 C5.3 C5.4 C5.5 P5

Total North N= 14 7.1 42.9 21.4 21.4 14.3 21.4

Total South N= 8 12.5 25.0 12.5 25.0 0.0 15.0

Total Economic N= 12 16.7 16.7 8.3 33.3 0.0 15.0

Total Environmental N= 9 0.0 66.7 33.3 11.1 22.2 26.7

Total Social N= 1 0.0 0.0 0.0 0.0 0.0 0.0

Network Partners N= 5 0.0 40.0 20.0 20.0 0.0 16.0

ALL N= 27 7.4 37.0 18.5 22.2 7.4 18.5

Principle 5

C5.1 C5.2 C5.3 C5.4 C5.5 P5

Total North N= 14 1 1 1 1 1 100%

Total South N= 8 1 1 1 1 0 80%

Total Economic N= 12 1 1 1 1 0 80%

Total Environmental N= 9 0 1 1 1 1 80%

Total Social N= 1 0 0 0 0 0 0%

Network Partners N= 5 0 1 1 1 0 60%

ALL N= 27 3 5 5 5 2

C5.1 C5.2 C5.3 C5.4 C5.5 P5


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Principle 6

C6.1 C6.2 C6.3 C6.4 C6.5 C6.6 C6.7 C6.8 C6.9 C6.10 P6

Total North N= 14 2 0 1 3 7 8 6 5 5 4 41

Total South N= 8 2 1 0 0 1 1 0 3 2 3 13

Total Economic N= 12 2 1 0 0 2 2 0 5 3 5 20

Total Environmental N= 9 2 0 1 3 6 7 6 3 3 1 32

Total Social N= 1 0 0 0 0 0 0 0 0 1 1 2

Network Partners N= 5 1 0 0 0 2 1 0 0 1 1 6

TOTAL N= 27 5 1 1 3 10 10 6 8 8 8 60

Principle 6

C6.1 C6.2 C6.3 C6.4 C6.5 C6.6 C6.7 C6.8 C6.9 C6.10 P6

Total North N= 14 14.3 0.0 7.1 21.4 50.0 57.1 42.9 35.7 35.7 28.6 29.3

Total South N= 8 25.0 12.5 0.0 0.0 12.5 12.5 0.0 37.5 25.0 37.5 16.3

Total Economic N= 12 16.7 8.3 0.0 0.0 16.7 16.7 0.0 41.7 25.0 41.7 16.7

Total Environmental N= 9 22.2 0.0 11.1 33.3 66.7 77.8 66.7 33.3 33.3 11.1 35.6

Total Social N= 1 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 100.0 100.0 20.0

Network Partners N= 5 20.0 0.0 0.0 0.0 40.0 20.0 0.0 0.0 20.0 20.0 12.0

ALL N= 27 18.5 3.7 3.7 11.1 37.0 37.0 22.2 29.6 29.6 29.6 22.2

Principle 6

C6.1 C6.2 C6.3 C6.4 C6.5 C6.6 C6.7 C6.8 C6.9 C6.10 P6

Total North N= 14 1 0 1 1 1 1 1 1 1 1 90%

Total South N= 8 1 1 0 0 1 1 0 1 1 1 70%

Total Economic N= 12 1 1 0 0 1 1 0 1 1 1 70%

Total Environmental N= 9 1 0 1 1 1 1 1 1 1 1 90%

Total Social N= 1 0 0 0 0 0 0 0 0 1 1 20%

Network Partners N= 5 1 0 0 0 1 1 0 0 1 1 50%

ALL N= 27 5 2 2 2 5 5 2 4 6 6

C6.1 C6.2 C6.3 C6.4 C6.5 C6.6 C6.7 C6.8 C6.9 C6.10 P6


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Principle 7

C7.1 C7.2 C7.3 C7.4 C7.5 C7.6 P7

Total North N= 14 0 4 2 2 2 3 13

Total South N= 8 0 1 1 0 0 2 4



Total Social N= 1 0 1 0 0 0 0 1


TOTAL N= 27 0 6 4 2 2 6 20

Principle 7

C7.1 C7.2 C7.3 C7.4 C7.5 C7.6 P7

Total North N= 14 0.0 28.6 14.3 14.3 14.3 21.4 15.5

Total South N= 8 0.0 12.5 12.5 0.0 0.0 25.0 8.3

Total Economic N= 12 0.0 25.0 8.3 16.7 8.3 33.3 15.3


Total Social N= 1 0.0 100.0 0.0 0.0 0.0 0.0 16.7


ALL N= 27 0.0 22.2 14.8 7.4 7.4 22.2 12.3

Principle 7

C7.1 C7.2 C7.3 C7.4 C7.5 C7.6 P7

Total North N= 14 0 1 1 1 1 1 83%

Total South N= 8 0 1 1 0 0 1 50%

Total Economic N= 12 0 1 1 1 1 1 83%


Total Social N= 1 0 1 0 0 0 0 17%


ALL N= 27 0 6 5 2 3 5

C7.1 C7.2 C7.3 C7.4 C7.5 C7.6 P7


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Principle 8 Principle 9

C8.1 C8.2 C8.3 C8.4 C8.5 P8 C9.1 C9.2 C9.3 C9.4 P9

Total North N= 14 0 3 0 2 1 6 3 2 8 2 15

Total South N= 8 0 0 1 0 0 1 1 2 0 0 3

Total Economic N= 12 0 2 0 1 1 4 3 2 2 1 8

Total Environmental N= 9 0 1 1 1 0 3 1 2 6 1 10

Total Social N= 1 0 0 0 0 0 0 0 0 0 0 0

Network Partners N= 5 1 0 1 0 0 2 1 2 2 0 5

TOTAL N= 27 1 3 2 2 1 9 5 6 10 2 23


C8.1 C8.2 C8.3 C8.4 C8.5 P8 C9.1 C9.2 C9.3 C9.4 P9

Total North N= 14 0.0 21.4 0.0 14.3 7.1 8.6 21.4 14.3 57.1 14.3 26.8

Total South N= 8 0.0 0.0 12.5 0.0 0.0 2.5 12.5 25.0 0.0 0.0 9.4

Total Economic N= 12 0.0 16.7 0.0 8.3 8.3 6.7 25.0 16.7 16.7 8.3 16.7

Total Environmental N= 9 0.0 11.1 11.1 11.1 0.0 6.7 11.1 22.2 66.7 11.1 27.8

Total Social N= 1 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Network Partners N= 5 20.0 0.0 20.0 0.0 0.0 8.0 20.0 40.0 40.0 0.0 25.0

ALL N= 27 3.7 11.1 7.4 7.4 3.7 6.7 18.5 22.2 37.0 7.4 21.3


C8.1 C8.2 C8.3 C8.4 C8.5 P8 C9.1 C9.2 C9.3 C9.4 P9

Total North N= 14 0 1 0 1 1 60% 1 1 1 1 100%

Total South N= 8 0 0 1 0 0 20% 1 1 0 0 50%

Total Economic N= 12 0 1 0 1 1 60% 1 1 1 1 100%

Total Environmental N= 9 0 1 1 1 0 60% 1 1 1 1 100%

Total Social N= 1 0 0 0 0 0 0% 0 0 0 0 0%

Network Partners N= 5 1 0 1 0 0 40% 1 1 1 0 75%

ALL N= 27 1 3 3 3 2 5 5 4 3

C8.1 C8.2 C8.3 C8.4 C8.5 P8 C9.1 C9.2 C9.3 C9.4 P9


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Principle 10

C10.1 C10.2 C10.3 C10.4 C10.5 C10.6 C10.7 C10.8 C10.9 C10.10 C10.11 C10.12 P10

Total North N= 14 7 7 2 2 2 3 4 1 2 3 2 0 35

Total South N= 8 3 0 1 1 0 5 3 1 2 0 0 0 16

Total Economic N= 12 2 1 2 1 1 7 5 2 2 1 0 0 24

Total Environmental N= 9 7 6 1 2 1 1 2 0 2 2 2 0 26

Total Social N= 1 1 0 0 0 0 0 0 0 0 0 0 0 1

Network Partners N= 5 1 1 2 2 1 2 1 1 1 1 1 1 15

TOTAL N= 27 11 8 5 5 3 10 8 3 5 4 3 1 66

Principle 10

C10.1 C10.2 C10.3 C10.4 C10.5 C10.6 C10.7 C10.8 C10.9 C10.10 C10.11 C10.12 P10

Total North N= 14 50.0 50.0 14.3 14.3 14.3 21.4 28.6 7.1 14.3 21.4 14.3 0.0 20.8

Total South N= 8 37.5 0.0 12.5 12.5 0.0 62.5 37.5 12.5 25.0 0.0 0.0 0.0 16.7

Total Economic N= 12 16.7 8.3 16.7 8.3 8.3 58.3 41.7 16.7 16.7 8.3 0.0 0.0 16.7

Total Environmental N= 9 77.8 66.7 11.1 22.2 11.1 11.1 22.2 0.0 22.2 22.2 22.2 0.0 24.1

Total Social N= 1 100.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 8.3

Network Partners N= 5 20.0 20.0 40.0 40.0 20.0 40.0 20.0 20.0 20.0 20.0 20.0 20.0 25.0

ALL N= 27 40.7 29.6 18.5 18.5 11.1 37.0 29.6 11.1 18.5 14.8 11.1 3.7 20.4

0

0

Principle 10

C10.1 C10.2 C10.3 C10.4 C10.5 C10.6 C10.7 C10.8 C10.9 C10.10 C10.11 C10.12 P10

Total North N= 14 1 1 1 1 1 1 1 1 1 1 1 0 92%

Total South N= 8 1 0 1 1 0 1 1 1 1 0 0 0 58%

Total Economic N= 12 1 1 1 1 1 1 1 1 1 1 0 0 83%

Total Environmental N= 9 1 1 1 1 1 1 1 0 1 1 1 0 83%

Total Social N= 1 1 0 0 0 0 0 0 0 0 0 0 0 8%

Network Partners N= 5 1 1 1 1 1 1 1 1 1 1 1 1 100%

ALL N= 27 6 4 5 5 4 5 5 4 5 4 3 1

C10.1 C10.2 C10.3 C10.4 C10.5 C10.6 C10.7 C10.8 C10.9 C10.10 C10.11 C10.12 P10


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Annex Three Criteria related to the issue

Description of issue Suggested Solution Additional Notes and Comments, and References

Chamber

P1 One more issue to be considered. Under modular approach principle 1 is foreseen as a stand alone legality assessment standard. Issue is that this risks delinking assessments about other rights holders, particularly indigenous people's. When I raised this issue with he stated view that such delinking should be avoided so that fsc does not provide legality market assurances in situations where indigenous rights are being violated. Indicators group will want to make sure this is addressed.

Environmental North

C1.3 ILO Conventions; so many treaties in force, virtually impossible to interpret all as they apply to a business

Language should be more user friendly and a listing of pertinent treaties should be compiled for certificate holders to compare against

Economic South

C1.3, C2.1, C2.3, C3.3, C4.8 y C6.4 entre otros.

Hay criterios que son demasiados grande, abarcan demasiados aspectos y eso indicaría el desarrollo de muchos indicadores y en términos prácticos disminuye la eficacia de una evaluación aumentando los costos.

priorizando que aspectos son importantes y que se relaciones específicamente a la certificación

Social South


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Criteria related to the issue


Chamber

C1.4 The absolute necessity that illegal or inaprpriate hunting is controlled within the FMU In Gabon and Congo hunting is the major ‘illegal activity’... a much bigger issue than illegal settlement. I want to make sure that this issue is addressed directly somewhere in the standard. I don’t really mind if it is 1.4 or 6.6, but we need to see some, direct language about “measures that effectively prevent illegal hunting” in the indicators.

Generic indicators specific to illegal or inappropriate hunting should be elaborated. It is important that the indicators demand the performance result that illegal or inapropriate hunting is effectively controlled. The intention is not to demand that the company takes law enforcement into its own hands, but that the company takes measures to ensure controls are effective. This may include working with or supporting the local or national forest administration in their role. An indicator is needed to require that control measures are monitored and their effectiveness is evaluated.

Environmental North

C1.4 and C6.6 Illegal hunting must be effectivly controlled - whether it is by the organisation itself or authorities. The current writing of 1.4. opens risk for a company not to take responsibility for illegal activities in their concession referring in legislation. Indicators must be developed to eliminate such risks for “loop holes”. This is particularly important in e.g. the Congo Basin where logging operations in remote areas indirectly facilitate illegal hunting through creation of forest roads. Also 6.6 "demonstrate that effective measures are in place to manage and controll" is too indirect..

Economic North

C1.6 The issue is in the meaning of the term “timely manner”, it isn´t clear for me.

The issue is in the meaning of the term “timely manner”, that once cleared (as a time which can vary according to the demand and the specific case, but it not be greater than the legal time to lead to judge the issue), is solved.

Economic South


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Chamber

C1.7, C2.2, C2.4, C4.4, C4.6 y C10.1

Hay criterios que son difíciles de verificar porque plantean cuestiones subjetivos, en algunos casos podría dar lugar a diferentes interpretaciones.

Redactando el criterio de una manera mas clara que no de lugar a diferentes interpretaciones y también en la elaboración de indicadores que sean bien específicos.

Social South

C1.8 C1.8 Definition of long term commitment needed in the event a plantation is managed over a single rotation and then reverts to agricultural use or other HBU. C5.2 Definition of "permanently sustained" in the event a plantation is converted to other use, or regeneration fails to produce comparable levels of merchantable timber. C5.3 Clarification of how organisations must demonstrate that externalities have been included in the management plan. C10.6 & 10.7. Clarification on the acceptability of chemical use where this is the only practical or cost-effective option available.

Economic South

Principle 2. General Definition of Workers – we are concerned that the definition of workers treats all workers identically. In the U.S. there are very specific and important distinctions between company employees and contractors. The standard needs to acknowledge and maintain these distinctions. We believe these distinctions can be well addressed in the Indicators.

The standard needs to acknowledge and maintain the distinction between company employees and contractors as codified in existing law. We believe these distinctions can be well addressed in the Indicators, but the definition also needs to be changed.

Economic North

C2.1 Criteria 2.1 ILO requirements – The U.S. is not a signatory to the ILO conventions. Our attorneys advice us that some of the conventions are contrary to U.S. law.

We believe the best approach is to develop Generic Indicators that require compliance to the spirit and intent of the conventions, where they do not conflict with established law.

Economic North


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Chamber

C2.1, C2.2, C2.3, C2.4, C4.8, C5.5, C10.6, C10.7, C10.8, C10.10 entre otros

Varios criterios no son adaptados a las condiciones de bosques pequeños, comunitarios sobre todo en la región de Latinoamerica.

1. Elaborando un estándar especifico para comunidades y bosques pequeños y/o baja intensidad 2. Desarrollando indicadores especificos

Social South

C2.3 Criteria 2.3 ILO requirements – The U.S. is not a signatory to the ILO conventions. Our attorneys advice us that some of the conventions are contrary to U.S. law. We believe the best approach is to develop Generic Indicators that require compliance to the spirit and intent of the conventions, where they do not conflict with established law.


Economic North

C2.4 Criteria 2.4 Wages – it is inappropriate for FSC to require a living wage for each worker. As in any business, in forestry wages are geared toward training, knowledge and experience, and it is a fact that some entry-level or menial work does not merit a living wage as defined by FSC. In the U.S. there are minimum wage laws, FSC should honor these laws.

In the U.S. there are minimum wage laws, FSC should honor these laws.

Economic North

C3.4 Criteria 3.4 ILO requirements – The U.S. is not a signatory to the ILO conventions. Our attorneys advice us that some of the conventions are contrary to U.S. law. We believe the best approach is to develop Generic Indicators that require compliance to the spirit and intent of the conventions, where they do not conflict with established law.


Economic North

C3.4, and P3 in general

Indigenous Peoples’ Rights and ILO 169 (Principle 3 and Criterion 3.4): There are significant challenges associated with the complexity of Principle.3. The content of the Principle has not changed significantly compared to the current P&C with two exceptions: (1) the wording

The explanatory notes states that “uphold” does note imply an unlimited responsibility for The Organization and that this responsibility should be further defined in endorsed national or regional standard setting processes. This

Economic North (representing 9 members)


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Chamber

“recognize and uphold” has replaced “recognize and respect” and (2) in 3.4 it is now stated that the Organization shall uphold ILO 169, even if the convention is not ratified by the country. * This issue identified as being a main priority

must be transferred to the IGI to avoid damaging FSC credibility. The term intellectual property (C3.6) has replaced “traditional knowledge” from the current P&C but, according to the explanatory notes, the intention of the wording has not changed. This must be reflected by the IGI.

C4.1 Explanatory note 2 for criterion 4.1 provides a condition to distinguish affected stakeholders from local communities. In the definition of local communities however, this condition also includes communities further out from the FMU as local communities.

Remove explanatory note 2 from criterion 4.1. Explanatory note 2 for C4.1


C4.1 (also C4.4, C4.6, C5.1, C5.2)

Community relations (Principle 4): In P4 the means of engagement (C4.1), the definition of local (C4.4) and means of compensation (C4.6) will require special attention in the IGI process, as will the use of the term Free, Prior and Informed Consent in C4.8. The definition of local also applies to P5 (C5.1 and C5.4) regarding local economies and local processing.

The criteria on community relations must be put in a national context, where the existing legislative and traditional framework is taken into due consideration. The correct application of Scale, Intensity and Risk with a global perspective will be critical.


C4.2 The text of Criterion 4.2 allows different interpretations of the requirements of “free consent” (to the areas of community property, companies property or even adjacent?).

Attention should be paid to how they will be defined by the indicators and explanations from IGI WG, areas within or related with. Furthermore, it should be set how this issue will be conducted when there is ongoing conflict.

Current Explanatory Notes(from FSC-STD-01-001_V5-0_D5-0): C4.2 - Explanatory Notes.

Economic South

C4.4 C4.4 - This sounds like helping with problems of developing nations and would nto be applciable to cerificate holders in well established economies. The use of additional is problematic as it implies there is no limit.

Strong IGI that sets a limit on additional or provides guidance on what is expected, i.e. if a company alreaday uses local businesses then they are already contributing to local economic and social welfare.

Economic North


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Chamber

C4.4 Concern about the meaning of the terms “local development” and “engagement”.

Clarify the meaning of the terms “local development” and “engagement”. It should correctly understand the scope and meaning of each one and how they can verify in field.


Economic South

C4.5 Explanatory note 8 for criterion 4.5 states to which situation this criterion applies. It is not clear whether this concerns an example or if it is the sole situation to which the criterion applies.

Mention if this is an example or precondition. Explanatory note 8 for C4.5


C4.7 Concern about aplication of this criterion to medium scale properties. Pay attention to the medium scale properties; it must be specified which corresponds to the affected area and which is in the management area.

Economic South

C5.2 Explanatory note 2 for criterion 5.2 lists examples of situations in which it is appropriate not to comply with this criterion. It apparently fails to mention conversion from plantations to natural forest.

Allow or prohibit accelerated harvesting to convert plantations to natural forest.

Explanatory note 2 for C5.2


C5.2 New 5.2 The addition of the phrase "not normally" is very ambigious and both weakens and muddies the original criteria. The original criteria was quite clear that the rate of harvest should not exceed that which can be sustained. Because normally is not constrained it opens door for depletion logging and degradation of highly natural forests.

"not normally" should be limited to exceptional situations in degraded forests where the intent is one of ecological restoration.

I have broad concerns as well about: * restoration definition, criteria and indicators * application of scale intensity and risk, including in HCVF situations and the precautionary approach * weak forest definitions * delinking of NTFP from production in natural forests I assume the above are also being raised by other

Environmental North


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Chamber

environmental chamber members.

C5.2 Overlogging of primary forests (logging rate higher than the ecosystem can sustain)

Revision of text in order to ensure that logging rates never exceed the natural carrying capacity of the ecosystem

C 5.2, Explanatory Note 3 Environmental North

C5.2 Lack of a requirement for sustaining the yield of forest and plantation products and services

In the short term development of IGIs that clarify that logging or harvesting in primary or intact forests must not be above levels that can not be sustained. In the medium term remove the word 'normally' from the criterion.

The removal of the word 'normally' may not be considered substantive. Explanatory Note 3

Environmental North

C5.2 1. POTENTIAL FOR CERTIFICATION OF INTENSIVE LOGGING IN PRIMARY FOREST EXPANDED: Criteria 5.2, which replaces current Criteria 5.6, explicitly opens the door for first-entry primary forest logging at levels above those then can be sustained. In particular: • Criteria 5.2, Explanatory Note 3, provides for broad exemption of primary forest logging from sustainable harvest expectations;

Develop prescriptive language to protect primary forest values

see above (FSC Network Partner)


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Chamber

C5.2 Note 3. P6 Notes 12, 14, & 15. C6.7 Notes 3 & 6.

There are many serious problems with how the explanatory notes interpret the revised P&C, including in ways that would seriously weaken the existing P&C’s requirements for the protection and restoration of natural forests. Previously, we have been told these notes are to be mandatory for the development and revision of regional/national indicators. While making the notes mandatory is a good thing where they correct problems with the revised P&C, it is unacceptable where they exacerbate or create new problems with the revised P&C. Examples of the harmful notes include but are not limited to C5.2 Note 3, which provides for broad exemption of primary forest logging from sustainable harvest expectations, and P6 Notes 12, 14, & 15 and C6.7 Notes 3 & 6, which go too far in absolving landowners from restoring forests, water quality, and other ecological values where degraded by prior landowners.

The survey does not contain an option for indicating that one or more of the proposed elements is not an acceptable or effective solution. In the case of explanatory notes that are harmful as described in my survey response, provision of additional explanatory notes is not a good solution. In fact, the explanatory notes are already far too expansive and confusing to be useful on a practical level. C5.2 Note 3. P6 Notes 12, 14, & 15. C6.7 Notes 3 & 6.

Environmental North

C5.4 C 5.4 - this was dicussed in great detail at a workign group at the General Assembly, without great resolution. We are very concerned how this could be interpreted that certificate holders would need to develop local processing. In NZ about 50% of logs are exported, and there is very good reason for this. If the test of reasonableness is not robust this would result in certificate holders quitting FSC as the impost to develop local businesses is too great and not good economic management.

Throug very strong wording of Generic INdicators that are linked to economic factors.

Economic North


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Chamber

C5.4 There isn´t a clear definition of “local” for this criteria; there are chains which are not.

Clarify the "local" definition to this Criterion. There should be an attetion to the fact that some product chains don´t have local services, processing or values. Better define limits and what should be done in these cases/regions, where there is no product chains, neitheir potential to development of them.


Economic South

P6 P6, Exp Notes 12, 14, & especially 15: The notes go too far in wholly absolving The Organization from responsibility for restoring the FMU to more natural conditions and other conditions necessary to achieve meaningful compliance with the P&C, when the forest has already been degraded by prior owners, managers, operators, etc., and/or when it has been degraded by other entities that are currently affecting the forest. This potentially renders the P&C ineffective at ensuring that certified forests actually represent well managed forests with basic levels of ecological integrity, given how frequently forest properties change ownership in some regions, and also given problems with how The Organization is defined in the Preamble. Exp Note 14 is also unacceptable in that it would absolve The Organization from responsibility for impacts caused by entities to whom The Organization sold or granted use rights of various types, e.g., mining rights, infrastructure easements, etc. I agree with the WG that subsequent landowners will need time to repair damage caused by prior landowners, and that certification should thus not be contingent upon completion of such repair. Likewise I agree that the restoration objective isn’t necessarily something approximating pristine, heretofore untouched wilderness. However, the current language goes too far the other direction, and only clearly requires restoration/remediation when “degradation… is continuing” (which presumably means “getting worse”).

P6, Exp Notes 12, 14, & especially 15

Environmental North


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Chamber

Principle 6 and several explanatory notes

Principle 6, explanatory notes 12-15 Unless the MU is a plantation, restoration to level of natural forest should be required, eventually. What type of forest, just short of the defintion of plantation, should be "acceptable" for FSC certification? If land is severly degraded, restoration should be required to demonstrate meaningful improvements in presence of native biodiversity and ecological services.

changes in explantory notes regarding restoration, also possible changes in discussion of restoration

Environmental North

C6.1 Criterion 6.1 states that environmental values should be assessed for potential impacts of management activities. Criteria 6.2 and 6.3 then deal with their protection. Rare and threatened species in criterion 6.4, (intact) ecosystems in criterion 6.5, water bodies and water courses in criterion 6.7 are also part of environmental values, and the criteria in which they are addressed again require management activities that do not cause damage to these values. Additionally, the activities in criteria 10.5, 10.10 and 10.11 are all management activities, and according to the criteria environmental values should again be taken special care of. It is confusing that the impact of management activities on environmental values is addressed in so many different criteria.

Provide a decision tree. C6.2; C6.3; C6.4; C6.5; C6.7; C10.5; C10.10; C10.11



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Chamber

C6.1 C6.2 The revised P&C's approach to impact assessment is flawed. C6.1: The risk assessment process per “scale, intensity, and risk” remains far too vague and subject to manipulation by The Organization. Evidence of impact is unlikely to be found when it can be pre-determined that risk is low, without first assessing whether sensitive resources are present. Moreover, few “Organizations” will intentionally acknowledge that their activities will be high risk; they have a vested interest in doing otherwise. The proposed approach veers dangerously close to “self-certification” and does not appear to have a mechanism to ensure consistent, meaningful, and verifiable implementation, or to position the CB’s to independently verify whether The Organization has made the correct judgments. The WG states that the risk approach has always been part of the FSC system, and that it agrees more guidance is needed to ensure reliable implementation of these elements, and that the FSC (ASI) may be undertaking some sort of process towards that end. C6.1, Exp Note 2: The requirement that environmental values and impacts be assessed prior site disturbing activities is crucial, and should be part of the Criterion, and not left to a note that may or may not be adequately reflected in regional/national indicators/standards. C6.2’s requirement for action before sites are disturbed does not rectify this concern because it only addresses the risk of impacting values identified per C6.1 – but C6.1 is not expressly triggered prior to site disturbance. The WG argues that the new language is still better than the existing language. C6.1, Exp Note 4: The note’s assumption that SLIMFs will always have “minimal impacts” that don’t necessitate serious environmental risk and impact evaluations is deeply flawed. Low intensity harvest can still be extremely damaging to some imperiled species and resources. And many small forest properties are managed just as badly as larger ones, and in some cases worse, due to the owners’ lack of capacity to adequately manage contractors, etc. The WG interprets the note as only applying to situations where SLIMFs do in fact have minimal impacts – demonstrating that the note is open to varying interpretations, including better ones.

C6.1, Exp Notes 1, 2, and 4 Environmental North


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Chamber

C6.2, Exp Note 1: The note’s provision allowing for use of impact assessment methods from national governments or development banks is probably deeply flawed. Minimum legal requirements will often not be sufficient. And development bank methods are probably far too “coarse” and superficial. Use of the best scientific methods should be required. As noted by the WG, the note does not mandate such methods, but does permit them – which in my view, is still of concern.

C6.9, C6.10 Conversion of natural forests to plantations (6.9-6.10): The P&C definition of forest types implies that any use of alien (exotic) species would typically equal establishment of a plantation. This is a major concern although the definitions are acceptable and, hence, it should be among the areas of priority for the IGI process. * This issue identified as being a main priority

The normative definitions do allow for further adaptation of these requirements and definitions in national standard setting processes, and this must be reflected in the IGI. Indicators on conversion should recognize the need for certain conversion for “public infrastructure”, e.g. utilities, which can be further defined in national standards. The definitions and handling of such conversion should be proportionate to Scale, Intensity and Risk based on existing legal and socio-economic framework.


C6.10 Plantation management and importance to the industry; even though a plantation, forested hectares are more beneficial to idle hectares;

plantations are vital to environment and industry; plantations should not be a negative

Economic South


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Chamber

C6.10 WWF believes that the arbitrary 1994 cut off rule needs to be replaced as it hampers FSC to become an important global tool to mitigate deforestation and degradation of ecological integrity in poorly managed plantations. Retaining the rule is also likely to boost other less rigorous certification systems - such as PEFC. This in turn is likely to severely limit the possibility of creating market demand for FSC paper on a global scale. The world needs tools to address the threats to the forests that the increased demand from countries like Brazil, China and India will generate.

WWF strongly advocates FSC to develop an alternative, ecologically rigorous, but less arbitrary mechanism to ensure that FSC discourages forest conversion, yet will not be forever locked out of the plantations created in countries where the agriculture frontier had not stabilised by 1994.

FSC Plantation Policy Review Motion 18 at GA 2011

Economic North

C6.10 C6.9 C6.10: The Criterion failed to correct the immense existing loophole in the prohibition of certification of plantations established through forest conversion after 1994, if that conversion was conducted by prior landowners. This is a serious problem, given the frequent turnover in forest ownerships in some regions, including those like the Southeastern US where plantation conversion is rampant. Failed to adopt a simple solution, such as that contained in the FSC US National Standard, whereby existing plantations established by other landowners after 1994 may be certified, but only if they are being restored to natural forest conditions. C6.9, Exp Note 1: The note failed to correct the loophole in existing FSC policy, whereby the policy’s cap on conversion of natural forest to plantation at 5% of the FMU can be circumvented when successive FSC certified landowners each convert 5%, and/or when prior non-FSC certified landowners have converted more than 5%.

C6.9, Exp Note 1 Environmental North


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Chamber

C6.4 C6.4: The last sentence is potentially problematic in that it could be misinterpreted as allowing weak or non-protection of rare and threatened species in the FMU if The Organization can point to the species’ distribution outside the FMU. Exp Note 11: The note in particular is unacceptable in that could more easily be interpreted as saying that species need not be fully protected within the FMU if their status is better outside the FMU. This inappropriately assumes there is a substantial margin of error with such species, that they do not need all of their remaining habitats and populations, and that their future outside the FMU can be predicted and counted-upon. It is also quite ill-advised inasmuch as the FSC will quickly lose credibility if it is associated publicly with harm to rare and threatened species. The WG interprets the note’s language as only increasing the Organization’s responsibility for conserving species where they are doing poorly outside the MU, and not as conversely decreasing responsibility where they are doing relatively well outside the MU; however, this does not appear to be the only possible or likely interpretation.

C6.4, Exp Note 11. Environmental North

C6.4 The protection of habitat that is critical to the survival of threatened species, or where forestry activity will have irreversible or otehrwise unacceptable impacts on the persisitence of the species in the FMU

Indicators for this criterion must ensure two things: 1. that the imacts of forestry activity on threatened species and their habitats is evaluated 2. that where habitat withini the FMU could be regarded as critical to the persistance of the species, and where forestry impacts on the habitat jeapordises the species, the habitat in question should be protected from forestry impacts.

Environmental North


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Chamber

C6.5 Restoration requirements for plantations are now unclear as per old 10.5. The requirement for restoration as per the old 10.5 is different from protecting and restoring representative samples. Firstly, representative samples needs to be defined with clear guidance on what proportion of the different ecosystem types found in the FMU constitutes a 'sample' and should be protected and or restored - there are widely different views on this. It needs to be incorporated into landscape analysis that looks at the matrix and degree of protection of ecosystems. There should be additional restoration requirements in line with the recommendations of the Plantation Policy review process on matching impact and management intensity with conservation response i.e. the larger and more intensive the plantations the large the restorative requirement. Develop an indicator to address the old 10.2 requirement that plantations should promote the protection, restoration and conservation of natural forests not increase pressure on natural forests.

Environmental North

C6.5 Current criterion 6.5 creates risk for different interpretations in the global context. Clear guidance on required scale of set asides/restoration is needed. This criterion is a typical example of where the concept of “the higher impact/risk the more conservation effort” which was recommended by the Plantation Review WG will need to come in to play. Global indicators will be very difficult to develop due to the enormous variation in contexts globally.

WWF has ideas on a matrix to define context in a conceptual way in order to develop thresholds and requirements for local implementation. We recommend that a separate small WG should be set up to develop a matrix that could be added to the explanatory notes.

Economic North


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Chamber

C6.5 NATURAL FOREST RESTORATION THRESHOLDS FOR PLANTATIONS HAVE BEEN WEAKENED: Requirements that plantation certification furthers natural forest conservation found in the current P&C is not adequately reflected in the new P&C. In particular: • The requirement of existing C10.2 that “plantations should promote the protection, restoration, and conservation of natural forests, and not increase pressures on natural forests” is not sufficiently reflected in the revised P&C; • New Criteria 6.5 is written too broadly to ensure that the existing Criteria 10.5’s requirement that portions of existing plantations be restored to natural conditions will be met.

Require that plantation certification furthers natural forest conservation


C6.5 C6.8 C10.3

Existing P&C language intended to ensure that plantation certification furthers natural forest conservation is not adequately reflected in the revised P&C. C6.8 (and elsewhere): The language fails to maintain the requirement of existing C10.2 that “plantations should promote the protection, restoration, and conservation of natural forests, and not increase pressures on natural forests.” While the WG states that these objectives are covered elsewhere in the proposed revised P&C, it is not clear to me where that occurs. C6.5: Depending on how the language is interpreted, it fails to adequately maintain the requirement of existing C10.5 for portions of existing plantations – specifically for “a proportion of the overall forest management area, appropriate to the scale of the plantation” -- to be restored to natural conditions, to ensure that plantation certification benefits natural forest conservation objectives. Existing windbreaks or stream buffers in plantations could probably be deemed sufficient to meet C6.5, meaning no conservation gain would result from certification. Minimal amounts of conservation/restoration can also be justified by pointing to the existence of natural forest areas outside the FMU, including in regions where there is no public or conservation good that results from even small parts of the landscape being converted to plantation. C10.3, Exp Note 6: The note’s assumption that the existence

C10.3, Exp Note 6 Environmental North


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of protected areas demonstrates the effectiveness of plantations at reducing natural forest degradation is fundamentally flawed. While there are circumstances where forest protection has been part of agreements allowing plantation conversion, in many cases plantation conversion occurs independently of any forest protection, while also directly impacting the forest being converted. In the Southeastern US, for example, the extensive plantation conversion that has been occurring has not leveraged any conservation on other sites – and to the extent that public forests in the region enjoy some partial protection, this generally predated the plantation conversion trend.


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C6.5 /EN 7, C10.2 /EN 1

the P&C WG had no mandate to develop or change FSC policy nor to change the stringency of the P&C requirements. I think that was quite correct. However, the WG has been criticised for not taking positions on the significance of carbon in forest management, on conversion, or on adaptative management for climatically-resilient forests. NEW POLICY ISSUES Carbon was the subject of the FCWG exploratory studies simultaneous with the P&C revision and it was not clear to the P&C WG that there was any consensus in the P&C membership on this matter. Conversion had essentially been left hanging by the FSC Board after the Plantations Review policy and technical phases, the Board having taken no explicit decisions. Policy Motion a8 at GA 2011 re-opens the debate on conversion, so modification of the two relevant Criteria in V4-0 of the P&C (C6.10 and C10.9) would have been premature. Adaptive management for climate change has not been debated at policy level in FSC. For some members the idea opens the door to 'creeping conversion', and is currently opposed. Climate change is happening quickly and events such as the massive dieback of North American pine forests from bark beetle attack may be related to climate-induced stress. Cautious wording in V5-0 of the P&C allows attention to adaptive management for resilience in the development of the IGIs but a supporting policy statement would be desirable before IGI work begins.

first step = commission a FSC Discussion Paper on options for FSC requirements. After that, the FSC process for developing and revising normative documents should be used.

a large scientific literature exists. See especially the report by a committee under Professor Sir David Read on UK/European forests (2009).

Environmental North


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C6.6 the revised 6.6 does not required that ALL naturally occuring native species occuring in the Managment Unit prior to managment activities are still maintained at some level after managment activities.

a clear statement in explanatory note that existing native species should not be put at risk from the MU due to management activities

explanatory note one refers to" the" naturally occuring species, which would assume to refer to all existing naturally occuring native species in the MU. This could easily be added to the actual criteria language too. Explanatory note 3 indicates that is may be impossible for all species to be identified, but some language needs to be included to protect those that are.

Environmental North

C6.6 As for 1.4 The absolute necessity that illegal or inaprpriate hunting is controlled within the FMU.

Generic indicators specific to illegal or inappropriate hunting should be elaborated. It is important that the indicators demand the performance result that illegal or inapropriate hunting is effectively controlled. The intention is not to demand that the company takes law enforcement into its own hands, but that the company takes measures to ensure controls are effective. This may include working with or supporting the local or national forest administration in their role. An indicator is needed to require that control measures are monitored and their effectiveness is evaluated.

Environmental North


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C6.6 FSC Highly Hazardous Chemical list is not based on good science. Chemicals on list which do not present health issues as they are commonly used in the industry with no ill effects. Additionally, derogation process and wait period excessive to the point certificate holder suffers economically.

Review of Highly Hazardous listing by region Economic South

C6.6, C10.1, P10, C10.2, Explanatory notes

3. BASIC PRICIPLE OF NATURAL FOREST MANGEMENT LOST: Failure to adequately maintain common sense interpretations for the maintenance and restoration of natural forest conditions. In particular: • New Criteria 6.6 fails to maintain requirements for enhancement or restoration of native species, genetic, and ecosystem diversity; • New Criteria 6.6, Principle 10, and Principle 10’s various Criteria fail to maintain the requirements of existing Criteria 6.3 for maintenance and restoration of natural forest regeneration and succession; • New Criteria 10.1 does not require silvicultural and regeneration practices sufficient to correct degraded pre-harvest conditions; and, • New Criteria 10.2 fails to sufficiently retain the requirements of existing Criteria 6.3 to maintain a natural diversity of species, and weakens existing Criteria 10.4’s preference for native species over exotic species. • New Principle 6, Explanatory Notes 12, 14, & 15 and Critieria 6.7, Explanatory Notes 3 & 6 go too far in absolving landowners from restoring forests, water quality, and other ecological values where degraded by prior landowners.

Revert to protection and definitions and criteria from old P&C or adopt the suggested language put forth by Grant Rosoman - Greenpeace Bill Barclay- Rainforest Action Network Daniel Hall – Environmental Chamber, USA Sean Cadman – Environmental Chamber, Australia


C6.6, C6.7, C10.1, C10.2

In order to accommodate plantations the main requirements of management to maintain a natural forest have been weakened or lost.

Short term; mitigate with some IGI clarifications Medium term: modify criteria

Environmental North


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C6.6. C6.6 P10 C10.1 C10.2 P10's other various Criteria

A number of the revised P&C fail to adequately maintain common sense interpretations of the existing P&C for the maintenance and restoration of natural forest conditions. The new C6.6, for example, fails to maintain requirements for enhancement or restoration of native species, genetic, and ecosystem diversity. While an explanatory note begins to correct this problem, the notes as a whole are a very problematic element of the process, and this note still does not maintain the requirement for enhancement or restoration. The new C6.6, P10, and P10’s various Criteria fail to maintain the requirements of existing C6.3 for maintenance and restoration of natural forest regeneration and succession. The new C10.1 also does not require silvicultural and regeneration practices sufficient to correct degraded pre-harvest conditions. Again, a note provides a partial solution, but fails to include the concept of “natural.” And the new C10.2 fails to sufficiently retain the requirements of existing C6.3 to maintain a natural diversity of species, and weakens existing C10.4’s preference for native species over exotic species. C6.6: The Criterion fails to maintain the existing requirement for enhancement or restoration of native species, genetic, and ecosystem diversity – which can be quite important, given the prevalence in many regions of situations where it has been reduced or eliminated by recent or past management. While Exp Note 1 says that the Criterion applies to “gentic, species, and ecosystem” diversity, this a mere explanatory note, and may or may not be adequately incorporated into regional/national standards/indicators. Moreover, neither the Criterion nor any of the notes maintain the existing requirement for enhancement or restoration. In addition, persons evaluating the new P&C for various purposes – including comparison with other certification systems – are unlikely to be aware of this particular note. C6.6, P10, and P10’s various Criteria: The revised language fails to maintain the requirements of existing C6.3 for maintenance and restoration of natural forest regeneration and succession. While the WG correctly points out some problems with the existing language, the revised language appears to throw the baby out with

C10.1, Exp Note 1 C10.2, Exp Note 1

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the bathwater. Exp Note 2: The note references “forest regeneration, succession, and natural cycles,” but this language is not part of the P&C, so it remains to be seen whether it will be adequately incorporated into national and regional indicators/standards. The note also fails to reference them as “natural” forest regeneration, etc. Moreover, persons evaluating the new P&C for various purposes – including comparison with other certification systems – are unlikely to be aware of this particular note. C10.1: The language is not a sufficient replacement for existing C6.3, as it would allow silvicultural and regeneration practices that merely maintain existing simplified and degraded pre-harvest forest conditions, in cases where past and recent practices have impacted the diversity of forest species, structure, etc. Exp Note 1, bullet 2: As noted by the WG, the language about restoring degraded areas to more natural conditions would be valuable – if it happens to be adequately incorporated into regional/national standards/indicators, which is far from certain. Also of concern, persons evaluating the new P&C for various purposes – including comparison with other certification systems – are unlikely to be aware of this note. C10.2: The Criterion fails to sufficiently maintain the requirements of existing C6.3 to maintain a natural diversity of species, and also weakens existing C10.4’s preference for native species over exotic species. Indeed, it allows extensive planting of non-native species if merely desired and “justified” by The Organization – which could presumably justify it on the basis of enhanced productivity, higher values for products from non-native species, or any number of other rationale. Exp Note 1: The note states that FSC prefers the use of local species; however, this language is weaker than existing C6.3. Moreover, it is far from certain this will be adequately incorporated into regional/national indicators/standards. Persons evaluating the new P&C for various purposes – including comparison with other certification systems – are also unlikely to be aware of this note.


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C6.7 C10.10 C10.11

The revised P&C does not consistently protect and restore water bodies and water quality. C6.7, C10.10, C10.11, & Glossary: The Criteria fail to clearly/explicitly require protection and restoration of all water bodies and of water quality per se. The Criteria fail to require restoration of water quality to natural levels or to other basic benchmark levels, e.g. those that support healthy populations of all native aquatic species or human consumption. Water resources are also not defined to include water quality. (Note that existing P&C were also non-explicit about these points, including the inclusion of “water quality” within “water resources.”) And the Criteria fail to explicitly/clearly maintain existing requirements to control erosion, including to protect water quality. C10.10, Exp Note 4, and C10.11, Exp Note 6: The notes do explicitly cover water quality, which is crucial; however, there is no guarantee these notes will be adequately reflected in regional/national standards/indicators. C6.7, Exp Note 7: The note discourages Organizations from blocking stream flows with dams, road crossings, etc., and encourages remediation of existing blockages. This is a basic element of sound forest ecosystem management, and should be part of the P&C, not a note which may or may not be adequately reflected in national/regional standards/indicators

Glossary C10.10, Exp Note 4 C10.11, Exp Note 6 C6.7, Exp Note 7

Environmental North

C6.7 and expanatory note 6

6.7, the language "protect or restore" would be adequate if it were not limited by explanatory note 6 which does not require restoring some prior damage to water courses. If the "water courses" or significantly damaged some degree of restoration should be eventually required, although sensitive to scale and risk.

clarification of explanatory notes Environmental North

C6.8 Concern about the concept and scope of the term landscape. The indicators should bring definitions to indicate when the landscape refers to the Forest Management Unit (FMU) or the surrounding areas, and also, to landscape planting or natural.

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C6.9 On behalf of our institutional investor clients, we are interested in acquiring a shareholding in several Asian plantation companies that have plantations that fail to comply with the following requirements: C6.9 Prohibits the conversion of natural forests to plantations except where the conversion affected a very limited area of the management unit, did not affect HCVs and resulted in secure, long term net conservation benefits. C6.10 Prohibits the certification of plantations established after Nov 1994 on areas of natural forest except if the Organisation was not responsible and the conversion affected a very limited area of the management unit and resulted in secure, long term net conservation benefits. The companies control plantation areas established through the conversion of natural forests and areas of natural forest that retain high conservation values eg viable tiger, orangutan habitat that the company intends to convert to plantations. If we are able to take a majority shareholding in these companies, we will immediately cease all further conversion activities and fund the protection and restoration of the natural forest areas and HCVs under threat directly or through the development of VCS REDD projects over these carbon-rich forests. However, due to FSC requirement P6.10 we would be unable to achieve FSC certification on these plantations, and as this is a corporate-level investment requirement for us, we will be unable to take up a shareholding in these companies. As a result, the forests will be converted and the plantations sold to a less scrupulous buyer or retained and managed by the existing owner. We propose indicators and/or explanatory notes be developed to guide national working groups and certification bodies on how to deal with such situations if the Organisation enters new majority ownership. We also propose indicators and/or explanatory notes that provide guidance on the sorts of acceptable activities that would enable demonstration of secure, long term net conservation benefits. Amongst these activities, we would like to see included the use of in situ restoration and ex situ biodiversity offsets, where these meet the highest international standards. A Plantations Review was

See above See above Economic South


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undertaken in two phases starting in 2004 and ending in 2009. The recommendation of the technical working group reviewing the conversion requirements was that reform was needed and that plantation owners and managers should be required to restore areas converted from natural forest in order to qualify for certification. This recommendation had a number of pros and cons but was ultimately not endorsed by the FSC Board of Directors. Priority Policy Motion 18 at the FSC GA in 2011 calls for the conclusion of the Plantations Review process. In June 2011 we prepared a paper outlining some proposals on how restoration and offset provisions could be incorporated under FSC requirements. This is available on request.

C6.9 C6.10 Natural forest//Plantation : if spliting the forest between natural forests and plantation make sense in tropical forest, it is really difficult in temperate forests where we have 3 types of forests : natural, semi natural and plantation. Because of the way the criteria are defined, the national working group has to define wether the semi natural forest should be considered as natural forest or as plantation. In France, we do not manage to get a consensus around this until now.

by enabling the creation of a third category. Or by clarifying the definitions.

The definitions in the explanatory notes and in the standard are for no help with this. These definition is too vague and depending on how we read it, we can both classify all the French forests into plantations are into natural forests.



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C6.9 and C6.9b)

C6.9, with the subtle addition of platnations to other land use - which means any plantatin conversion to farm or ifestyle must meet b) will produce clear, substantial, additional, secure long term conservation benefits in the FMU. This was introduced at a late stage and was not picked up by NZers until the final votinf draft. Consequent discussions with some of the P&C Working Group found that the intent was not for minor plantation coversions to other uses to have to meet b. This is a very serious issue for NZ (and other countris) as plantaitons are dynamic and from time to time some concervsiosn (even small areas) are a logical and good management practice. This also conflicts with P3 in NZ as much of the land is Maori owned. The absolute wording says that even a small conversion (say less than 1 ha) would have to produce clear, substantial, additional, secure long term conservation benefits in the FMU - which is impossable in a plantation to farm or lifestyle situation. There have been suggestiosn that such areas could be excised from the FMU - which I do not consider a long term fix (i.e. it doesn't fit so exclude it???). There are also iplaications for controlled wood if this Criterion is tranferred through to the CW definitions.

There will need to be a very strong worded exclusion that 6.9b) does not apply to plantation to other uses. Perhaps in conjunction with 6.9a) where the scale is "limited".

Economic North

C7.1, C7.5 This requirement on sharing information (C7.1+C7.5) may lead to new requirements on making summaries of management plans public. This is problematic in at least two ways; (1) the sharing of confidential information, (2) increased administrative burden related to a specific summary to meet FSC requirements.

This is primarily a concern for small-holders (SLIMF) or group certificate holders, and this must be reflected by the IGIs. The purpose of the public information must be reflected by the IGI’s.


C7.1 – C7.5 Management planning (Principle 7): There is a risk that the requirements on “social management planning” (C7.2 – C7.5) will add little more than undesired administration and associated costs.

The level of detail in the requirements must be proportionate to Scale, Intensity and Risk, and take into account the socio-economic context in the country using a global perspective.



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C7.2 Explanatory note 4 for criterion 7.2 lists elements of forest management planning and social management planning. Many of these elements are addressed in several criteria, but a reference to these criteria is not always present (in the explanatory note).

Add references. Explanatory note 4 for C7.2


C7.2 Criteria 7.2 Social management planning – this is a large unknown as mentioned in the standard. We see this as a potentially large, costly, unwieldy and ultimately unattainable exercise. We simply do not believe our operations can manage society…we have government for that purpose.

We need to keep the requirements of social planning at a level consistent with landowners abilities.

Economic North

C7.4 C7.4 the addition of social management planning. This is not well understood and new - needs some very precise descriptiona with care to avoid bogging down forest managers.

Better explanation of social managementn planning.

C7.4 Economic North

C7.6 Many explanatory notes throughout the FSC Principles and Criteria refer to criterion 7.6 and state what the Organization should do in relation to affected stakeholders. However, the formulation of the explanatory note of criterion 7.6 itself these obligations are much less clear (or firm). See for example criterion 5.3 explanatory note 1, criterion 6.2 explanatory note 4, criterion 6.3 explanatory note 7.

Add the obligations with a reference to criterion 7.6 plain and simple to the explanatory notes of criterion 7.6.

Amongst others C5.3; C6.2; C6.3


C7.6 The criterion text creates doubt as to the meaning of "engage" affected and interested stakeholders. And how to identify areas of direct and indirect influences of the FMU? How to set these boundaries?

The indicators created to this criterion should guide as to what means “engage” affected / interested stakeholders. The management plan should consider the identification of areas of direct and indirect influences.

Current Explanatory Notes(from FSC-STD-01-001_V5-0_D5-0): C7.6 - Explanatory Notes 1.

Economic South


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C7.6 Proactive engagement with stakeholders (C7.6) should be done proportionate to Scale, Intensity and Risk, as already stated in the criterion. This must take into account the socio-economic context in the country in question so that the measures taken by the Organization are effective and efficient, and to avoid redundancy.

The indicators should focus on the outcome of the “planning and monitoring process”, rather than being prescriptive about the means of engagement.


C8.1 Criterion 8.1 states that the implementation of the management plan should be monitored. Criterion 7.2 states that the management plan should be implemented. Compliance with criterion 7.2 is properly demonstrated by providing documents that are inherently based on monitoring the implementation of the management plan. This appears to make criterion 8.1 redundant.

Indicate how it is different, or that is indeed redundant.

C7.2 (FSC Network Partner)

C8.2 Criteria 8.2 Social impacts – as we understand it, social impact monitoring can be a very expensive undertaking. We believe it is inappropriate to put this burden on landowners. So, the specification of exactly what is involved here is critically important.

The specification of exactly what is involved here is critically important. Monitoring metrics need to be easy, cheap, and meaningful.

Economic North

C8.2 Monitoring of ecological impacts Indicators should be developed that require the monitoring of forestry impacts on threatened species and their habitats. Monitoring should provide data, which should be regularly analysed and contribute to changes in forest management if impacts exceed tollerable levels.

Environmental North

C8.2 The requirement on monitoring of conditions (C8.2) is very broad (“environmental and social impacts”) and not defined further.

The intention must for the forest manager to monitor conditions directly relevant to forest management, i.e. primarily information relevant for decision making in the forest management process. The IGI should allow for some processes and



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occurrences to be monitored by other stakeholders, such as research institutions, government bodies etc. This may include monitoring of certain species, ground carbon stock etc that may in the future be integrated in operational procedures.

C8.4 Making a summary publically available summary (C8.4) will increase the administrative burden and also raise concerns about confidentiality. The requirement shall be implemented proportionate to SIR (which makes it even more ambiguous).

Requirements on public summary must be worded such that confidential information may be excluded.


C8.5

The requirement on Tracking and tracing (C.8.5) has changed from the current P&C where is reads “to enable monitoring and certifying organizations to trace each forest product from its origin”. The new wording, although it should be implemented proportionate to SIR, implies a regular, periodic review and documentation of production and sales of FSC products.

The IGI requirements must take into account the administrative burden, especially for SLIMF operations, in producing forecasts and reports.


P.9 Explanatory note for principle 9 states that HCV should be described in the management plan according to criterion 7.2. Explanatory note 4 for criterion 7.2 list HCV as an element of forest management planning. But then rationale note 2 for criterion 7.2 states that the elements of forest management planning have purposely been moved to the explanatory notes to provide some flexibility. In other words: is HCV a compulsory element to be addressed in the management plan or not?

Remove either of the contradictory notes. C7.2 (FSC Network Partner)

P 9, Expl note 4.

P 9 expl note 4 confuses magniture of threat (severe and irreversible) with magnitude of values that may be lost.

Clearer Explanatory Notes Economic North


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C9.1 – C9.3 Engagement (C9.1-C9.3): Engagement must be carefully defined to safeguard efficient and effective measures for all parties (see also Principle 7).

The indicators should focus on the outcome of the process, rather than being prescriptive about the means of engagement.


C9.1 Explanatory note 1 for criterion 9.1 states that the entire space of the forest management unit should be assessed for the presence of HCV. This seems to contradict the criterion itself (assessment depends on scale, intensity and risk), as well as explanatory notes 9 and 11 for this criterion.

Remove first line in explanatory note 1 for C9.1. Explanatory note 1 for C9.1


C9.1 The explanatory notes for HCV2 are not sufficient. Further guidance on management of HCV 2 in different context must be developed.

A separate stakeholder to developm guidance on on HCV 1-3 with a particular focus on HCV2.

Economic North

C9.1 Criteria 9.1 Identifying HCVF – we are concerned about the imprecision in definitions, tools, etc., and believe they can be interpreted to cast a very broad net on HCVF.

We need added precision in definitions, tools, etc.

Economic North

C9.1 and missing criterion from P5

Lack of specific recognition of forest carbon. Revision of HCV definition to include High Carbon Store forest areas, and addition of a new criterion on maintaining and restoring forest carbon. Short term partial mitigation possible through indicators on maintaining forest carbon.

Environmental North

C9.2 For criterion 9.2 the Organization is required to develop effective strategies for maintaining and/or enhancing HCV. These strategies must be based on the precautionary approach, but this approach is not mentioned in this criterion at all. The precautionary approach is first addressed in criterion 9.3.

Add an explanatory notes that explains this criterion in relation to the precautionary approach.

C9.3 (FSC Network Partner)


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C9.2 For criterion 9.2 the Organization is required to develop effective strategies for maintaining and/or enhancing HCV. It is not indicated whether these strategies concern simple adaptations to regular management activities, or if these strategies should be more pro-active and directed at maintaining and/or enhancing HCV and ‘overrule’ regular management activities.

Add an explanatory note that explains the nature of the strategy.


C9.2 and C9.3 The protection and maintenance of HCVs, particularly HCV2, are not guaranteed

Revision of text. Only the implementation of strategies to maintain HCVs are required istead of directly requiring the protection and maintenace of HCVs. Also it contains a weak reference to the precationary principle.

Environmental North

C9.3 Explanatory note 2 for criterion 9.3 states that “..The Organization will take explicit and effective measures to prevent the damage and avoid the risks to welfare, even when the scientific information is incomplete or inconclusive, and when the vulnerability and sensitivity of environmental values are uncertain..”. I believe the whole purpose of the precautionary approach is dealing with uncertainty, thus in that sense ‘even’ should be ‘especially’. This is also the case in explanatory note 4 for principle 9.

Solution: Change wording. Explanatory note 4 for P9 (FSC Network Partner)


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C9.3 Precautionary approach Indicators should be developped that spell out the implementation of the precautionary appraoch. These should ensure that the potential impacts of managment activities are evaluated before operations commence, and that, in the event of likely negative impacts, effective mitigation measures are put in place in advance. The effectiveness of these mitigation measures should also be followed by an appropriate monitoring approach.

Environmental North

C9.3 P9 P9, Exp Note 4, C9.3, and especially Glossary, Definition “Precautionary Approach:” The new language is likely to create unacceptable loopholes in the protections for HCVs. Whereas the existing P&C is quite straightforward in requiring that “management activities… shall maintain or enhance the attributes which define” HCVs, and then also requires consideration of the precautionary approach, the new language at C9.3 and especially P9 channel all HCV protections through the precautionary approach which -- of particular concern -- protections will only be triggered management activities pose a “threat of severe or irreversible damage” per the definition of precautionary approach in Exp Note 4 and the glossary. A simple solution would be to delete “threat of severe or irreversible damage” in this definition, as previously noted. While as noted by the WG, Exp Note 3 of C9.3 states that “any threat to a HCV is considered to be a threat of severe or irreversible damage,” this is at best a confusing and easily overlooked way to correct the problematic definition. Indeed, there is no guarantee that this particular note will be adequately incorporated into regional/national indicators/standards. Moreover, persons evaluating the new P&C for various purposes – including comparison with other certification systems – are unlikely to be aware of this particular note.

The simplest approach would be to delete “threat of severe or irreversible damage" from the definitions of "precautionary principle," including in the glossary and applicable explanatory notes. Otherwise, the problem will need to be corrected in the IGI and various national and regional standards, as they are brought into conformance with the revised P&C.

The simplest approach would be to delete “threat of severe or irreversible damage" from the definitions of "precautionary principle," including in the glossary and applicable explanatory notes. Otherwise, the problem will need to be corrected in the IGI and various national and regional standards, as they are brought into conformance with the revised P&C. P9, Exp Note 4, Glossary C9.3 Exp Note 3

Environmental North


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C9.3 and glossary

Implementation of the precautionary approach. Revise the definition to bring into line with international definitions. Ensure the explanatory note 2 is converted into IGIs

FSC definitions/glossary Explanatory note 2

Environmental North

C9.3, P9 DEFINITION AND REQUIREMENTS FOR HIGH CONSERVATION VALUE FORESTS WEAKENED: Effective and consistent protections for HCV forests hinges upon regional/national indicators’ adoption of an explanatory note that redefines the more fundamental glossary definition of “precautionary approach.” In particular: • The new language at C9.3 and P9 channel all HCV protections through the precautionary approach – which is defined in the glossary and an explanatory note as only being triggered when management activities pose a “threat of severe or irreversible damage.” • While another note at C9.3 states that “any threat to a HCV is considered to be a threat of severe or irreversible damage,” this is a confusing and too easily overlooked way to truly correct the situation.

this is a confusing and too easily overlooked way to truly correct the situation. Revert to HVCF protections from previous P&C.


C9.4 Managing HCVs is often an integrated step in forest management processes, and monitoring of changes may in many cases only occur if the activity is a part of a research project or similar. Monitoring of HCVs (C9.4) could potentially require significant resources, which must be considered, especially for SLIMF operations.

Such monitoring is only done when relevant, i.e. as a basis for decision making. In the explanatory notes, it is stated that the Organization is not obliged to perform the monitoring and may instead “draw upon monitoring undertaken by third parties if the data are relevant, comparable and transferrable”.


C10.1 There is a concern is related to the partnership between companies and areas of (small) forest producers, because, depending on your interpretation, may hinder the relationship between the company and the small producer, or even hamper the certification of these small forest producers.

It should be more specified how could be complying this criterion when there is a partnership between small forestry producers and companies. How small producers can fit into the criteria that is required - "The Organization* shall, by natural or artificial regeneration methods, regenerate vegetation cover in a timely fashion to pre-harvesting or

Economic South


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more natural conditions".

C10.2 Local genotypes: To use other genotypes than local (C10.2), the Org must be provide “clear and convincing justification”. In some cases, the use of non-local provenances improves survival rate and growth in the regenerated forest, and it provides an opportunity to adapt to looming climate change.

The indicator for clear and convincing justification must include survival and growth of the future stand, and take into account potential risks associated with climate change.


C10.2 C10.3 Native/exotic species : same thing. We have 3 types : native/exotic/ and "acclimatées" (those which were exotic but which are now proved to be well adapted to the ecological context and here since a while already.)


C10.4 Criterion 10.4 states that the Organization shall not use genetically modified organisms in the management unit. It is not clear how this could possibly be proven without DNA analysis.

Add explanatory note on how to prove this. (FSC Network Partner)

C10.6 Elimination of fertilizers (10.6): A narrow interpretation of the proposed wording “to avoid or aim at eliminating the use of fertilizers” does not give any room for adaptation to the prevailing national circumstances in national standard setting processes. The wording allows for the use of fertilization only if it can not be avoided, and does not address the environmental and/or social impact, e.g. if it can be verified that the negative impact on environmental and social values are under tight and rigorous control. The current wording creates a significant risk to the credibility of FSC since fertilizers are widely used in certified plantations in the tropics and also in boreal forests in some countries.

A proposed new wording would be ““The Organization shall avoid all adverse effects to environmental, social and economic values due to use of fertilizers. When fertilizers are used, The Organization shall prevent, mitigate, and/or repair damage to environmental values. Planning and monitoring shall correspond to scale, intensity and risk of the activity.””

In the previous P&C, the use of fertilizers was only regulated in Principle 10: Plantations. The IGI should further define the concept of “to avoid” in relation to prevention, mitigation and/or repair of (social and) environmental

Economic North (group of nine members)


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* This issue identified as being a main priority

values. Defining IGI for this criterion may not be sufficient – the text of the criterion will ultimately have to be revised. This will require a motion to the General Assembly 2014.

C10.6 The text of Criterion 10.6 is contradictory, because it doesn´t define which is the FSC position in the use of fertilizers, whether organic or not. This criterion is deterrent, because if the correct interpretation of FSC is to ban the use of fertilizers, forestry companies would be harmed.

The criterion text should be done by leaving explicit that there must be a minimum effort to use and controlled, but the use of fertilizer is prohibited. Since the present text the expression focus in the removal, can give the interpretation that this removal is required for use. And this case is too complicated for forestry companies in general.

Economic South

C10.6 C10.7 Criteria 10.6 Fertilizers – we believe inclusion of this criteria is simply off-base. Fertilizers of all types are used around the world in agricultural and forestry settings to promote the well being of people and ecosystems. The presumption stated in the criteria that use of fertilizers requires repair or mitigation is simply untrue. Criteria 10.7 Pesticides – the use of pesticide, especially herbicides, is a critical component in the establishment of native forests throughout the world. The benefits of herbicide use with respect to the environmental, social and economic chambers is clear. We completely understand and support the contention that all pesticides should be used cautiously and responsibly, and believe that should be the focus of the Indicators.

The presumption stated in the criteria that use of fertilizers requires repair or mitigation is simply untrue. The criterion should focus on appropriate and responsible use of fertilizers...not elimination. We believe the focus on pesticides should be cautious and responsible use, and believe that should be the focus of the Indicators.

The "scores" above apply to both the fertilizer and pesticide issue.

Economic North


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C10.6, C 10.7 10.6 and 10.7 - In particular the requirement to avoid or eliminate fertiliser. This will inhibit good management practice and the focus shoudl be to avoid adverse effects of fertiliser rather than eliminate. Where is the evidence that wel managed fertiliser applciation is a problem? The continued focus on eliminating pesticide is also an issue as there are circumstances where pesticides are necessary. There needs to be a better process.

Some improved background work on the problem (if there is one) and effects based approach.

Economic North

C10.7 Pesticide requirements weakened Revision of the criterion to restore to the equivalent level of strength as the old P&C requirements under 6.6, in particular the requirement to 'strive' to avoid the use of chemical pesticides. Short-term partial mitigation possible through IGIs including that require the above

Environmental North

C10.10 The wording of C10.10 regarding disturbance and damage using “and/or repair” is problematic, since it is poorly defined and not clear if it refers to a previous state (before the damage) or some other natural condition.

The indicators must clarify the desired state and require actions for repair that are sensible and proportionate to the damage inflicted by the organization.


applies generally

COMMUNICATIONS FOR THE REVISED P&C It was not reasonable to expect the FSC membership to read and appreciate 150 pages of revised P&C and then vote Yes/No. Hence the request of the P&C WG in mid-2010 that PSU engage a professional communications enterprise to make the technical draft into media which were more understandable and votable. The WG itself developed 12 FSC Briefing Papers in late 2010, PSU and the WG developed 40+ FAQs in late 2011, and Green Ink provided a sort of short guide to the revised P&C in late 2011. PSU did not attempt to monitor how influential were any of these efforts, nor I think did FSC Communications check on their use. So far as I am aware, FSC is not using these documents now to explain or promote the revised P&C, but that may just be the usual problem of the navigationally unfriendly FSC website. I believe that FSC

contact international training agencies, don't expect overloaded FSC national offices to do this.

contact FSC smallholder/SLIMFs unit

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should be thinking more in terms of 'FSC for dummies', perhaps some of them along the lines of the products now coming out of the FSC smallholder project and SLIMFs. It is unreasonable to expect anyone but insomniacs to take and understand the revised P&C as they stand. There should be a subsequent exercise to aid uptake and application of the P&C and IGIs, by training materials for applicants and certificate holders and CABs and ASI staff. I am not aware that this is even remotely on the FSC work plan. I suppose that this effort could be funded by donor agencies and executed by training specialists (which I believe FSC does not have in-house).

Criteria related to the issue Description of issue Suggested Solution Additional Notes and Comments, and

References Chamber


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Criteria related to the issue Description of issue Suggested Solution Additional Notes and Comments, and References

Chamber

contested issues include (1) the degree to which FSC's purpose is focussed on the conservation of and restoration to primary natural forest - FSC global strategy, Preamble -scope, P6, P7 and P9; (2) management of tree-related space within the MU boundary rather than focus on natural forest - Preamble - scope; (3) validity of certification of the variety of forms of plantations including 'row crops' - Policy phase of Plantations Review, P6 and P10 - and alien species (P10); (4) logging in primary forest, and importance of IFLs - Preamble, P6 and P9 especially C9.1/HCV-2; (5) treatment of Nature's Bounty versus even-flow yield control -C5.2; (6) long-term use of non-prohibited chemicals - C10.6 and C10.7; (7) management for climate change - P6 - P10, especially C6.8 and C10.2; (8) responsibility for repair of environmental damage caused by neighbours/upstream/over historical time for which The Organization has no legal responsibility - P6 especially C6.7, C10.9-C10.11. for scope, see FSC-POL-10-004 and FSC-DIS-01-001.

note - these key issues are not treated in any sequence of priority UNRESOLVED OR OUTSTANDING POLICY ISSUES These are briefly summarised in the letter from some members of the environmental chamber dated 05 January 2012. P&C WG drafted a brief point-by-point response, circulated by FSC PSU/DG on 24 January 2012. Although this response was technically correct, it clearly does not deal with the underlying concerns of those environmental chamber members. In essence, the vague wording of V4-0 of the P&C allowed a variety of interpretations to be held simultaneously. This resulted in variable qualities of certification audit, leading (properly) to complaints from much the same environmental chamber members. Clarifying the meaning and wording of the Criteria thus sharpened the underlying disagreements about the nature and purpose of FSC. The underlying problem is the reluctance of FSC IC to (re-)open such fundamental debate when there are more business-related problems (CoC and CW) occupying the attention of FSC IC. Exchanging e-mails is not going to resolve the underlying problem. It is possible that FSC IC is taking the view that better P&C (plus IGIs) will be easier to implement by applicants and auditors, leading to fewer arguments about quality of forest management and audits, and that fewer disputes will cause the philosophical disputes to fade away. Such a pragmatic view is unlikely to appease the vocal disputants and is not, I suggest, good for the FSC system.

1. ideally FSC IC would call a conference to deal with the outstanding or disputed issues, to determine the weight of support for different options. However, it seems that FSC IC would prefer a festering sore to an open wound, and I accept that this is one IC management strategy. 2. at least put on record that FSC will not use development or revision of normative documents to solve policy issues. Resolve those issues, or formally shelve or postpone them, before embarking on normative work, but don't again put a volunteer WG into impossible positions when it has no mandate to deal with outstanding policy matters. Ensure that the membership knows the state of these outstandin or disputed policy matters. At present it appears that PSU expects the IGI development again to fudge solutions, keeping the lid on the pot instead of fixing the problem.

substantive revision of standards should of course follow work on policy norms. FSC has not successfully communicated the shift from the vague wording of V4-0 (requirements imposed on some nebulous 'forest management' instead of on The Organization, areas of application undefined instead of within and related to the Management Unit, etc.) to a more ISO-compatible approach where it is more clear who does what,wo whom, when and where. ISO-compatibility should also permeate the IGIs. I disagree entirely with NEPCON about ISO influence. The objectors in the FSC environmental chamber often/sometimes take a view of forest as essentially in stasis instead of being highly dynamic in most situations, both natural and under formal management. This is in my view just poor biology. Perhaps FSC Communications Unit should study and adapt or distribute widely the excellent educational (schools) material from IUCN on forest dynamics. Other long-standing issues - such as FSC to act more as a rural development agency and a market promoter - were raised repeatedly by stakeholders with the P&C WG and need to be addressed by FSC IC but outside the P/C/I context. Refs: Too many to list in the time available. The P&C WG listed most FSC references in ENs to the revised P&C. FSC should be more inclusive in looking at the C/Is prepared by CIFOR, CIRAD, FAO, ITTO, LEI, PEFC, etc. The P&C WG did not have time to review possibly adaptable wording in national, regional

Environmental North


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definitions 2. PROBLEMATIC FOREST DEFINITIONS: Changes to glossary definitions for “forest”, “natural forest”, “native ecosystem”, “non-timber forest products”, “restore”, “long term” and “precautionary principle”, which together: • define forests by the presence of trees alone; • fail to recognize and distinguish highly natural forests from semi natural forests; • de-link Non Timber Forest Products from any natural forest context; • eliminate specific meaningful ecological time frames (definition of “long term” deleted); • adopt a weak definition of the precautionary principle; and, • put forward a definition of “restore” that is delinked from any pre-existing natural conditions of the area.

Revert to the former definitions (FSC Network Partner)

General General - thre are substantive changes that will need to be implimented by certificate holders. These are the materially affected members of FSC who face large amounts of work and resourcing. FSC needs to be mindful that this could result in difficulties in meeting the P&C in the medium term - some leeway should be considered to phase in.

Good IGI's and leeway to phase in substantive new changes.

Economic North

General comment at Criteria from Principle 2 to 10. An example is C6.9 b) will produce clear, substantial, additional, secure long term conservation benefits in the FMU.

In general the P&C are too specific making complaince at a national or regional level difficult. Plus they are not effects based and often absolute - Forest operations that have positive, nil or mnor effects should be acceptable rather than attempting a panacea. FSC aim should be the mainstream standard rather than the gold lable that woudl limit uptake.

Through comiplation of effects based IGI's. By aking and effects approach the IGI's will be more universally applicable as the onus is on effcts management rather than an absolute threshold that may not actually reflect good managment in local cicumstances. Aso guidance or explanatory notes will help.

Economic North


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Glossary Definitional problems (several) Revise definitions including, 'forest' to clarify that a forest is more than simply trees, 'natural forest' to better distinguish 'semi natural forests' or 'primary forests' or 'intact forests' in order to prevent degradation of natural forest, NTFPs to ensure from natural forest systems, 'precautionary principle' to reflect proper definition, 'restore' to really mean restore to some former state, and add definitions of 'long-term' and 'representative sample'.

As I understand it FSC glossary of definitions is a stand alone document - so it could be modified. FSC Definition doc/glossary

Environmental North

Lots of places Conversion, natural forests and plantations. The criteria and definitions are fine as written. I believe this is one area where we simply need to watch carefully since these definitions are key to the entire standard.

Any changes in these definitions need to be evaluated in the context of the entire standard.

Economic North

P1 C1.4, Exp Note 2. P5 P6 P9 P10

Preamble 5, Responsibility for Compliance with the P&C: The definition of “The Organization” as the entity for which compliance with the various P&C rests remains fundamentally flawed. Within the P&C, it is not defined as the entity which is responsible for all decisions and activities affecting the FMU. It is not even defined as the entity which is most responsible, compared to other entities with responsibilities and authorizations for the FMU. Rather, it appears that it could simply be a stumpage purchaser, contractor, or other entity that is responsible for only a small fraction of the decisions and activities on the FMU, which would easily lead to a failure to ensure that the FMU is actually well managed despite it being certified. This has serious ramifications, including for P1, P5, P6, P9, and P10, and their various requirements for legal compliance, sustainable harvest, environmental protection, HCV protection, chemical applications, etc. For example, at P1, because of how “The Organization” is defined, the P&C may no longer require that all forest management in the FMU comply

Preamble 5, Responsibility for Compliance with the P&C. Preamble 5, Exp Notes 2 & 3. Preamble 5, Exp Note 4. P1, Exp Note 15 C1.4, Exp Note 2.

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with all applicable laws. This is affirmed by Exp Note 15, which states that applicable law does not mean those laws for which The Organization does not have legal responsibility. The Working Group (WG) states that the Preamble makes it clear that an MU can not be certified if unacceptable impacts are being caused by any entity, and if “the Organization” has not done what it reasonably can to address the situation, e.g., by excising the problem area from coverage under the certificate. However, under the Preamble, the Organization is only responsible for its own actions and those of its contractors and permittees, so concerns remain with cases where the Organization is not the entity in control of most activities in a MU. Moreover, excision does not actually correct problems “on the ground.” Exp Notes 2 & 3: The notes further absolve The Organization from responsibility for activities in the FMU conducted by other entities with legal rights there. As noted above, this could be the majority of activities in the FMU and/or particularly important activities in the FMU. Exp Note 4: The note affirms that The Organization need not be the actual forest land owner. While there may be times where this is acceptable (e.g., long-term holders of very large concessions within even larger ownerships, where the concession-holders are the sole managers of the FMUs, e.g., tenure holders in Canada), the Note allows it to be the case universally, rather than as an exception. C1.4, Exp Note 2: The note affirms that The Organization may not have the authority to restrict illegal activities in the FMU by other entities, because The Organization may not be the entity with the authority to regulate what happens in the FMU.


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Chamber

P3 and to some extent P1 especially C1.3. I suggest that this is going to be a major issue raised by the FSC permanent indigenous peoples commission.

SOVERIEGN RIGHTS OR CLAIMS OF INDIGENOUS PEOPLES the revision of P3 did not address the situation in which IPs have de facto or de jure or customary law status as Governments in their own right. In these conditions, applicant Organizations which hold concessions for forest harvesting or management from central or State Governments also have to manage a possibly/probably contentious relationship with the IP Government where both kinds of Government claim supremacy over forest resources. By default, the P&C WG treated this situation as needing case-by-case work by the CAB under FSC-STD-20-007 section 8.20, but gave no further guidance.

FSC IC needs to get ahead by taking specialist advice, including through FSC Canada and the UN Special Rapporteur on the rights of Indigenous Issues (currently James Anaya at the University of Arizona).

this problem exists in Canada and is expressed to a lesser extent in Melanesia and New Zealand. James Anaya is opening an investigation of treatment of IPs in the USA, so this is both an opportune time and also a possible upcoming problem for FSC.

Environmental North

right through, from Preamble to Glossary

MESSY TEXT OF THE REVISED P&C D5-0 of V5-0 of FSC-STD-01-001 (the revisedP&C) is essentially a set of Principles individually re-written by WG members and other folk with different writing styles. PSU refused in 2009 to start the P&C revision with agreement on a uniform approach (a style manual) and the editors of Green Ink refused to re-draft the last versions of D4-x of V5-0, which WG members had understood to be part of the Green Ink brief. But Green Ink did agree on the desirability of FSC having such a style manual. Consequently, V5-0 D5-0 ranges from the staccato incomplete sentences of P2 to the more colloquial P5. Syntax is sometimes clumsy, there are errors of grammar, and punctuation is erratic, especially of commas and subordinate clauses; I can see these problems in my own contributions, which I failed to correct. A native English-speaker can work out what is intended but the unclean text presents unreasonable problems to interpreters.

Contract Green Ink again to develop a style guide, with FSC Communications Unit, and ensure that this is used during development of IGIs and other FSC normnative documents. Use the facility in FSC-PRO-01-001 for the head of PSU to engage a native English-speaking editor (possibly also Green Ink) to clean the revised P&C, and then ensure that the Spanish and any other translations match the cleaned English-language text.

Make the style guide itself a FSC normative document. The Guardian Weekly's style guide?

Environmental North


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Chamber

General Issues Scale, Intensity and Risk (SIR): The concept implies that the requirements in the P&C will in many cases be different for different types of Organizations, depending on SIR (spatially and over time). Furthermore, SIR shall be combined with a precautionary approach. The fact that SIR applies in general to “almost all Criteria” and explicitly to some, will make the national standard setting process. SIR is explicit in e.g. Principle 5: local processing etc; Principle 6: Assessing and managing environmental values; Principle 7: Management planning and engagement with stakeholders; Principle 9: Assessment, management and monitoring of HCVs.


General Issues Management planning (including engagement and social planning): The requirements in Principle 4 and 7 will most likely require an increased “social component“ in forest management plans, as well extended stakeholder “engagement” which may increase overall administrative costs.

EconomicNorth

(representing 9 members)

General Issues Environmental values (including carbon sequestration and storage): According to Principle 6 and 8 we will be expected to monitor and manage carbon sequestration and storage as an integral part of forest management. Such monitoring must focus on information relevant for decision making



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General Issues Performance based standard: The P&C are regarded as a “performance based, outcome oriented, world wide standard” for forest management. We should keep in mind that the P&C must focus on field performance of forest management rather than on the management systems behind the performance. It should avoid prescribing how activities are to be carried out.


General Issues Vegetation types: The P&C are applicable to all types and scales of forests and other vegetation types. “Other types” is limited to those land-uses involving the growing of trees and must contribute to the mission of FSC. This is more a matter of principle than a significant problem for forest managers. One observation is that areas “included in agricultural production systems” are not subject to the P&C, and we must make this explicit in our management plans in the future.



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General Issues Free, Prior and Informed Consent (FPIC) The Current definition of FPIC as included in the normative glossary of terms: “A legal condition whereby a person or community can be said to have given consent to an action prior to its commencement, based upon a clear appreciation and understanding of the facts, implications and future consequences of that action, and the possession of all relevant facts at the time when consent is given. Free, prior and informed consent includes the right to grant, modify, withhold or withdraw approval (Source: Based on the Preliminary working paper on the principle of Free, Prior and Informed Consent of Indigenous Peoples (…) (E/CN.4/Sub.2/AC.4/2004/4 8 July 2004) of the 22nd Session of the United Nations Commission on Human Rights, Sub-commission on the Promotion and Protection of Human Rights, Working Group on Indigenous Populations, 19–23 July 2004).” The term FPIC is referenced in Principles 1, 3, 4 and indirectly also in Principle 7 (C1.2, C3.2, C3.3, C3.4, C3.6, C4.2, C4.8, C7.5 (indirectly), C7.6 (indirectly)).



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Annex Four

FSC Chamber Issues related to process

Economic South Involvement of certificate holders; premise is that users of the system should have a part in designing it

Economic South During the consultation process of IGI Development would be very important that there were national workshops for clarification of doubts and a space for suggestions to the WG. We have a good exercise (although in my opinion later) here in Brazil with a webinar where P&C WG could clarify many aspects of the Final Draft to the Brazilian members. But a timely manner to organize and the FSC National Office involvement are essential.

Economic South FSC Plantations Review Process was not properly concluded and the P&C review process was therefore incomplete.

Environmental North

There was a lack of opportunity for FSC members to review and comment on a number of definitions in the glossary before final voting. Agreements that I thought had been reached in breakout groups at the FSC GA were not reflected in the final P&C explanatory notes.

Economic North Thought process was thorough, but one issues was some subtle changes were introduced during the iterations that were not picked up by stakeholders. I.e. introdcution of plantations to other uses in C6.9. FSC should provide track change version or some means to show what chagnes (even single words can be critical).

Environmental North

MANAGEMENT OF THE IGI DEVELOPMENT PROCESS this has been the subject of separate correspondence and this Survey Monkey format is unsuitable for treating the subject here. The proposed use again of a six-sub-chamber WG (repeating the P&C revision exercise) is a slow and clumsy and inherently unsatisfactory approach to a technical problem. I believe strongly, after working on two such or similar exercises, that technical drafts should be prepared by technical specialists - in-house or on contract - and that the WG should be used to review those technical drafts but not to engage in drafting itself, especially if again the WG is part-time and essentially unpaid. I do support the FSC chamber balance in general, which seems to overcome problems encountered by less inclusive approaches. I support also the control of the IGI development process being firmly in the hands of PSU permanent staff. More attention should be paid to document handling software, so that contribution by multiple authors and contributors are tracked and recorded without the current text being reduced to an unreadable mess. MS Word TrackChanges was never intended to handle such tasks. Green Ink suggested the use of BaseCamp software. DropBox is quick and convenient but has no tracking and cannot cope with simultaneous users, so far as I have discovered. Better document handling should include file naming processes (including version number tracking). In spite of the care, attention, experimentation and saintly sustained patience of Matthias Fecht as PSU controller for the revision of the P&C, we never had a really satisfactory teleconference system. I cannot make a recommendation but FSC IC should keep trying. I favour employment of professional secretaries to retrieve, sequence, and handle simultaneously mutiple documents and manage multiple monitor displays during physical meetings for


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IGI development, and enter draft text and edits. Leave the PSU controller to manage the meeting and take the sense of the discussion. Employment of external facilitators wastes time in educating the facilitators who want to participate in the technical discussions themselves instead of dealing with philosophical differences between participants.

Environmental North

INCLUSION IN IGIs OF MORE ATTENTION TO SOCIAL ACCOUNTABILITY? ISO 26000 social responsibility and SA8000 social accountability standards were under development while the P&C were in revision in 2009-2011. FSC shoould at least consider if these new standards should be addressed through IGIs, or if the contents should be addressed during the next revision of the P&C. Standards developed or used by ETI, EITI, IFOAM, Marine Stewardship Council and Rugmark should also be reviewed during the IGI process. Others may be suggested by ISEAL.

Environmental North

A BROADER RANGE OF SOURCES FOR IGIs other organisations with much greater resources and more extensive consultations than FSC have developed C/Is which should be reviewed systematically for their utility and adaptability: CIFOR (8 volumes), CIRAD, FAO, LEI, ITTO, PEFC at least, plus the FSC national and regional standards development units and the national adaptations of CAB generic standards. None of these were reviewed systematically during P&C revision. For P1, we drew on the VLO/VLC standards of SGS and RALL/Smartwood and they are certainly appropriate for IGIs. Legality verfication systems (LVS) developments are moving quite quickly in FLEGT VPA countries and should also be reviewed; contact EFI for details. World Resources Institute, through its Governance of Forests Initiative, has some 94 indicators which may be useful. FAOs' regional processes should be examined, including - ATO, Dry Zones Africa, Lepaterique - Central America, Tarapoto - Amazon Basin. I suggest also reviewing the complaints against FSC recorded by FERN, FSC-Watch, Greenpeace - two Holding the Line reviews. Also at least12 academic studies of FSC certification processes.

Environmental North

SCENARIO TESTING and GAP ANALYSIS IGIs are of course required to map all the elements of each Criterion. The P&C WG tried to disaggregate the compound Criteria in V4-0 but sometimes we were defeated by PSU's anxiety about increases in numbers of Criteria. Thus, revised C1.3 deals with legality of operations plus payment of taxes, instead separating these two matters. IGIs may need to differentiate between large-scale industrial plantations; small-scale commercial plantations; government-managed forests; community-managed full-time forests; SLIMFs including family-managed part-time and NTFP-orientated forests; natural and semi-natural forests; agroforests; forests managed for commercial environmental services but no wood-related outputs; management units managed for non-consumptive services such as biological and habitat diversity, aesthetic landscapes and recreation, etc. IGIs should also be tested against the conditions of boreal, temperate and tropical forests; wet and dry and monsoonal climates; mountain and lowland forests; mtulti-dominant and single-dominant forests; fast-growing and slow-growing. IGIs have to work for individually-managed forests; group/resource-managers schemes; traditional family managements. Perhaps also forests in zones of conflict?


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Environmental North

the most important lesson from the P&C review process was the value of dealing with (resolving, or getting stakeholder agreement to park) known policy issues before attempting to revise the P&C themselves. This did not happen, and the consequent fudging and work-arounds were inherently unsatisfactory, timeconsuming, and will continue to be troublesome.

Economic North The document on the P&C was extensive and written in a very technical language, making it challenging for members to read, comprehend and provide feedback on. Suggestions: 1. Simplify the language, e.g. by using professional editors specialized in this, 2. Make the the material more accessible by dividing the issues (e.g. the indicators) in a few different categories depending on the level of consensus reached in the working group. This would potentially help members get more effectively engaged in the review process.

Economic North Workshops are critical to efficient and effective handling of complex issues and may serve to secure broad support through discussions and networking. The workshop in Malaysia, at the GA, was not successful in delivering the above. First and foremost due to the fact that the design was changed in the very morning of the workshop, and members were faced with a set-up completely different from what they expected and had prepared for. Suggestion: Use the workshop format but find people who can deliver good results, preferably using tools that are proven in practice.


The indicators already definied by the already in place working groups, on the new P&C could be taken into account into the process, as a first proposal to be discussed for instance.

Environmental North

All concerns on process have been given via phone interview.

Economic North We believe representatives of the various chambers need to have better means of communication with their chambers. In the development of the standard, comments went in, but we never heard much back. The only feedback was a new draft of the standard with little explanation of how the outcome was achieved. We recommend that minutes be kept that document key discussions and decisions. These minutes should be made generally available in a timely manner. All votes should be recorded with a detailed roll call.


That the new P&C was accepted without consensus.

Social South No se incluyo la opinión de actores principales como productores


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Social South Varias Recomendaciones enviadas durante el proceso de elaboración no fueron tomadas en cuenta

Social South no se respeto la moción original de simplificar el estándar si no que mas bien se hizo mas riguroso dificultando el acceso a la certificación principales a organizaciones medianas, pequeñas y comunitarias.

Social South Los indicadores deben ser adaptado a la realidad del manejo sobre todo en países en vías de desarrollo


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Annex Five: Final Comments

Additional feedback

Economic South During the consultation process of IGI Development would be very important that there were national workshops for clarification of doubts and a space for suggestions to the WG. We have a good exercise (although in my opinion later) here in Brazil with a webinar where P&C WG could clarify many aspects of the Final Draft to the Brazilian members. But a timely manner to organize and the FSC National Office involvement are essential.

Economic North Thank you

Economic North I believe the approach for the IGI process is ambitious and has great potential.

Environmental (South and North)

The survey allowed no place for concerns on the preamble, even though this is a binding component of the P&C. In particular the scope of the P&C is still contentious and relates to the revised definition of forest - meaning FSC covers anything to do with trees, including agricultural and horticultural systems, which it's criteria are not designed for.


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FSC Network Partner We strongly support language that supports FSC’s ability to serve as a credible measure of responsible forestry in the marketplace. Failure to improve the language sited above will fundamentally undermine the FSC’s effectiveness as a forest conservation and restoration tool—and would play directly into the hands of the FSC’s competitor certification systems, whose strategy for marketplace competition is to mislead the consumers and companies into believing their systems are equivalent to the FSC. If the weaknesses in the new P&C are not corrected, the FSC would in fact move dramatically closer to these substandard certification systems, seriously eroding the FSC’s market differentiation, and making the FSC vulnerable to the same charges of “greenwash” that are being levied against its weakest competitors. As long-standing supporters and participants in the FSC process in the environmental caucas, we support a strong P&C and return to the spirit of credibly and effectively ‘identifying’ and ‘promoting’ HCVF and intact forest management practices that protect and restore forest ecosystem values, protect communities indigenous people, biodiversity, endangered species habitat, as well as carbon storage values, and provide solid economic returns to forest managers. The FSC’s true strength and success lies with that spirit, and not with a short-sighted strategy of increasing the FSC’s numbers by lowering its thresholds.

forest stewardship council: stakeholder outreach...

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