Synopsis stakeholder consultations - BG, SK, VN

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Synopsis of Stakeholder Consultations:

FSC Centralized National Risk Assessment

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SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK ASSESSMENT 2016 - 2017

2017

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Introduction

During 2014-2016, the FSC Centralized National Risk Assessment (CNRA) was conducted for controlled wood categories 1 (Illegally harvested wood), 2 (Wood harvested in violation of traditional and human rights), 3 (Wood harvested from forests in which high conservation values are threatened by management activities), 4 (Wood from forests being converted to plantations or non-forest use) and 5 (Wood from forests in which genetically modified trees are planted). For the following 8 countries, assessments for some of these categories have been consulted and are now ready for approval: assessments, as outlined in FSC-PRO-60-002a FSC National Risk Assessment Framework. Those for controlled wood categories 1, 3, 4 and 5 were conducted by NEPCon.

This report provides an overview of the results of the public consultation conducted by FSC International on these risk assessments. It includes the details of the consultation, and summaries of the stakeholders that responded and the feedback they provided, and how the feedback was addressed. This information is organized broadly by FSC controlled wood category, and then by country.

Consultation Details

As stated above, the risk assessments were published on the FSC International website in May 2016 and March 2017 for the international consultations (scenario 3 countries) or on the FSC national websites for the national consultations (scenario 2 countries). All drafts were subject to stakeholder consultation for a period of 30 days. Announcements of the international consultation were sent out via:

 Technical news in the FSC newsletter/website  The FSC Network newsletter

 Emails sent to mailing lists of certification bodies and the FSC network

The announcement informed stakeholders that the assessments were available and accessible on the FSC website with information on how to participate in the consultation.

All comments received were analysed, and were evaluated for relevance and reliability (on the basis of being well justified and using evidence), and whether they conform to the requirements of FSC-PRO-60-002a. Analysis of comments, and responses to them, were formulated by FSC International and the consultants responsible for the relevant assessment.

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Analysis of stakeholder comments

A general comment for risk assessments made for below categories is that control measures provided in the CNRA are only recommended and will not be mandatory for organizations to implement.

Controlled wood category 1: Illegally harvested wood

Draft assessments for the following countries were subject to consultation: Bulgaria, Viet Nam. Stakeholders submitted comments on the risk assessments for the following countries: Bulgaria.

The number of stakeholders, and their FSC membership/stakeholder type are specified individually per country.

Bulgaria

Stakeholder composition WWF Bulgaria

General comments:

No comments disagreed with the risk findings of the 21 indicators.

Comments were made regarding the wording of the overview (related to the requirements for harvesting), asking to add wording according to the regulations of the Forest Act.

Additionally, one comment was made regarding the terminology: “Harvesting permit"

should be replaced by "Felling permit”, so that the terminology of the CNRA is

aligned with the terminology of the Bulgarian Forest Act.

Analysis:

The consultant included the proposed wording related to harvesting in the overview and in indicators 1.3 (Management and harvesting planning) and 1.4 (Harvesting permits).

The suggestion to change “Harvesting permits” to “Felling permits” was considered a

translation issue and the terminology was not changed.

Viet Nam

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Controlled wood category 3: Wood harvested from forests in

which high conservation values are threatened by

management activities

Draft assessments for the following countries were subject to consultation: Bulgaria, Slovakia, Viet Nam. Stakeholders submitted comments on the risk assessments for the following countries: Slovakia.

6 CHs (collectively as CB stakeholders & clients)

General comments:

Comments were received “in general” and on categories 1, 2 and 3, even though only categories 3 and 4 were subject to consultation. However, comments received on already approved categories 1 and 2 did not change the risk designations for these categories.

3.0: The stakeholders contested the claim that the term “HCV” is not agreed upon by stating that there are other terms that have been used longer and more successfully in Slovakia, and therefore should be equivalent. The consultant responded by citing studies arguing against the identified equivalency and reiterated that it is a fact that

“HCV” is not used in main-stream Slovakian forest management. They also included reference number in the risk description as in-text citations. The risk designation was unchanged (low risk).

3.1: The stakeholders contested details of the indicator risk description, and argued that the risk designation (specified risk) was inaccurate because specific kinds of forests are strictly protected, and there are existing programs to ensure protection. The stakeholders also contested the proposed CM as being unusable. The

consultant responded by adding to and enumerating the evidence sources and including them in the risk description as in-text citations and by providing critique of the programs mentioned. The risk designation was modified through the use of

functional scales to ensure those areas mentioned were changed to “low risk”. Additionally, the consultant changed the proposed CM to be “more prescriptive” and

utilitarian.

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The stakeholders argued for a change in the risk designation to “low risk”. The

consultant responded by providing a more nuanced explanation that where RTE are known, they are well mapped, but they are not known in very many locations, in addition to reiterating their evidence and adding their source numbers as in-text

references. The risk designation remained the same (“specified risk”).

3.4: The stakeholders contested the factual basis of the claims made by the consultant, and challenged FSC as to the usability of the CMs. The stakeholder argued that the identified at-risk forests were not being evaluated for their

hydrological function as they should be, but for their environmental function. The

stakeholders argued for a change in the risk designation to “low risk” for all forests.

The consultant responded by adding and reiterating sources as in-text citations, and by explaining that the potential environmental damages described demonstrate that the hydrological functioning cannot be reasonable assured. Furthermore, the consultant defended the CM as feasible. The risk designation was refined, but remained the same, as did the CM.

3.6: The stakeholders contested the use of Primeval Beech Forests as HCV 6 and

stated that it is always protected, arguing for a change to “low risk”. The consultant

responded by quoting the criteria upon which the forest was nominated as a UNESCO world heritage site, which includes “areas of exceptional natural beauty and aesthetic importance… the real impact that the appearance of Europe’s primeval forests has exerted on the mindset of people and artists in particular, who in turn have hugely influenced our culture and standards…”. Additionally, the consultant reiterated that commercial logging has happened in these forests with varying levels

of protection. The risk designation remained unchanged (“specified risk for Primeval Beech Forests…”)

Viet Nam

No stakeholder comments received.

Issue of interest:

HCVs 1 to 6 are threatened by illegal logging activities in natural forests in Viet Nam. The consultant considered that indicators 3.1 to 3.6 should be either ‘low risk’ or ‘N/A’ because illegal logging is not a forest management activity. However, considering that illegal logging causes loss or degradation of HCVs and that it is highly likely that the timber derived from this illegal activity enters CW supply chains, PSU considered that

indicators 3.1 to 3.6 should be ‘specified risk’. A logging ban is also in place for natural forests in Laos and indicators 3.1 to 3.6 were also designated ‘specified risk’ there.

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Controlled wood category 4: Wood from forests being

converted to plantations or non-forest use

Draft assessments for the following countries were subject to consultation: Bulgaria, Slovakia, Viet Nam. Stakeholders submitted comments on the risk assessments for the following countries: none.

Bulgaria

Issue of interest:

The assessment based on legislation was not enough to conclude if the spatial threshold is met. The assessment based on spatial data was done using data provided by the government of Bulgaria and by FAO. Available spatial data is limited.

Based on the available spatial information, until 2015 conversion of natural forests in Bulgaria was still below the spatial thresholds of indicator 4.1.

However, according to the assessment based on legality, the Forest Act allows the spatially unrestricted conversion of forests into non-forest lands for the purpose of urban development, industrial, sport or infrastructure projects.

The urbanisation of forest areas is also "stimulated" by the provisions of the Forest Act which allow the sale of state-owned or municipal forests to private parties.

WWF Bulgaria states that the recently adopted Forest Act amendments doom Bulgaria's forests because the amendments mean further deforestation and building up of forest. They practically allow for the construction of ski and other facilities without changing land use and for the acquisition of building rights on public land without tender and for an indefinite period.

The present risk assessment shall deal with the current situation and at the time of

the assessment the available spatial data leads to a ‘low risk’ designation.

Slovakia

Viet Nam

Issue of interest:

The assessment based on spatial data was done by PSU using data provided by FAO. Based on the spatial information, until 2015 conversion of natural forests in Viet Nam was still below the spatial thresholds of indicator 4.1.

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export revenue has been among the top ten in terms of dollar export earners for the country. This is a significant economic driver for conversion of natural forests to rubber plantations. The timber derived from this conversion is highly likely to enter CW supply chains. In principle, the law establishes that only degraded forests can be converted, but the law is not enforced and natural forests have also been converted.

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Controlled wood category 5: Wood from forests in which

genetically modified trees are planted

Draft assessments for the following countries were subject to consultation: Bulgaria. Stakeholders submitted comments on the risk assessments for the following

countries: none.

Synopsis stakeholder consultations - BG, SK, VN

Synopsis of Stakeholder Consultations:

FSC Centralized National Risk Assessment

Contents

Introduction

Consultation Details

Analysis of stakeholder comments

Controlled wood category 1: Illegally harvested wood

Bulgaria

Viet Nam

Controlled wood category 3: Wood harvested from forests in

which high conservation values are threatened by

management activities

Viet Nam

Controlled wood category 4: Wood from forests being

converted to plantations or non-forest use

Bulgaria

Slovakia

Viet Nam

Controlled wood category 5: Wood from forests in which

genetically modified trees are planted

Bulgaria