Synopsis stakeholder consultations - IN, LA, KR, UA

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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, FSC Centralized National Risk Assessments (CNRAs) were 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).

In addition, and partly based on the previous CNRA work done, National Risk Assessments (NRAs) are being developed by NRA working groups at country level. For the following 4 countries, the assessments for some or all of the controlled wood categories have been consulted and are now ready for approval:

CNRA India (cat. 3) CNRA India (cat. 4) CNRA Lao People´s Democratic Republic CNRA Republic of Korea NRA Ukraine

Consulted Jan 2017 Consulted May-June 2017 Consulted May 2017 Consulted May 2017 Consulted Jan-Feb 2017

The (C)NRA assessments followed the process steps and requirements for FSC risk assessments, as outlined in FSC-PRO-60-002a FSC National Risk Assessment Framework. Those for CNRA controlled wood categories 1, 4 and 5 were conducted by NEPCon, those for controlled wood category 2 were conducted by Wolfgang Richert and Leo van der Vlist and those for controlled wood category 3 were conducted by Daemeter (India), Alexandre Boursier (Lao People´s Democratic Republic) and FSG (Republic of Korea). The NRA Ukraine was only conducted by the NRA working group without previous input from any of the CNRA consultants.

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 2017 for the international consultation (scenario 3 countries) or on the FSC national websites for the national consultations (scenario 1 and scenario 2 countries). All drafts were subject to stakeholder consultation for a period of 30 days, with the exception of the Ukraine draft which was consulted during 60 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

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2017

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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.

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: Lao People´s Democratic Republic, Republic of Korea, Ukraine. Stakeholders submitted comments on the risk assessments for the following countries: Ukraine.

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

Lao People´s Democratic Republic

Stakeholder composition

No stakeholder comments received.

Republic of Korea

Ukraine

27 stakeholders representing all interest groups: 14 forest users, 3

representatives of woodworking enterprises, 4 representatives of educational and scientific institutions, 2 territorial bodies of executive authority in the sphere of forestry and hunting, 3 public organizations, 1 certification body. General comments:

Comments were provided regarding the enforcement of applicable legislation related to various indicators, including consideration of environmental requirements in the process of management activities, management and harvest planning, health and safety, and legal employment.

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2017

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Analysis:

Over 60% of the comments were addressed and partially addressed. The rejection of the remaining comments was substantiated by the corresponding expert and

supported by the working group.

A more detailed revision of the risk designations was done. The conclusions were revised by increasing the quantity and diversity of information sources used (public reports, articles and comments by independent observers, NGO publications, official statistical information of state authorities and materials provided as an answer to submitted requests). To ensure impartiality of the conclusions regarding risk, preference was given to independent information sources, as well as to those with greater public trust.

Taking into account the revised conclusions and using the precautionary approach, specified risk was designated to specific indicators, in relation to environmental requirements in the process of management activities, management and harvest planning, health and safety, and legal employment.

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2017

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Controlled wood category 2: Wood harvested in violation of

traditional and human rights

Lao People´s Democratic Republic

Republic of Korea

Ukraine

Comments were provided related to the upholding of rights of forestry enterprises’ employees, including those defined by the ILO Declaration on Fundamental Principles and Rights at Work.

Analysis:

All the received remarks were approved or partially approved. The conclusions were revised by increasing the quantity and diversity of information sources used. Considering the precautionary approach, and to ensure impartiality of the conclusions regarding risk levels, preference was given to independent information sources, as well as to those with greater public trust (for example, the preference was given to information provided by Central Committee of Trade Union of Forestry Employees). One sub-indicator was added to indicator 2.2 Labor rights are upheld including rights as specified in ILO Fundamental Principles and Rights at Work: “Health safety under conditions of radioactive contamination”which is designated as ‘specified risk’. One existing sub-indicator “Ban on self-organization and collective bargaining” was

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2017

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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: India, Lao People´s Democratic Republic, Republic of Korea, Ukraine. Stakeholders submitted comments on the risk assessments for the following countries: Ukraine.

India

Lao People´s Democratic Republic

Republic of Korea

Ukraine

Comments were provided related to the identification and classification of HCVs, as well as to the enforcement of legislation for protection and conservation of forests with special environmental and protection value. There were also comments related to the proposed control measures.

Stakeholders commented on the need to o harmonize the conclusions of all indicators in category 3 with the conclusions for indicators 1.9 and 1.10 (“Protected sites and

species” and “Environmental requirements”) in terms of potential threats to

biodiversity.

Stakeholders asked to consider the Emerald Network objects in the HCV assessment. Stakeholders also asked to strengthen the argumentation on assessment of threats related to HCV 4.

Analysis:

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about the procedures regulating the NRA development (PRO-60-002 V3-0, FSC-PRO-60-002a V1-0). The conclusions were revised by increasing the quantity and diversity of information sources used.

The conclusions for all indicators in category 3 were harmonized with the conclusions for indicators 1.9 and 1.10 (“Protected sites and species” and “Environmental

requirements”) in terms of potential threats to biodiversity.

Emerald Network objects were included to the list of HCVs, and threats for such objects were assessed.

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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: India, Lao People´s Democratic Republic, Republic of Korea, Ukraine. Stakeholders submitted comments on the risk assessments for the following countries: India, Republic of Korea, Ukraine.

India

1 certification body, 1 certificate holder General comments:

One comment was made suggesting to add statements about two sections of the Forest Conservation Act (shift from forest land to non-forest land irrespective of cover and penalties). One comment was made suggesting to add a statement about large scale conversion from India’s State of Forest Report.

Analysis:

Both suggestions were included. They did not change the risk designation. 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 by PSU using data provided by FAO, India’s State of Forest Report, and the Ministry of

Environment, Forests & Climate Change. According to the State Forest Report, there has been large scale conversion of forest land in North East India due to shifting cultivation. However, at the country level the forest area has still increased. The

‘specified risk’ threshold is not met and, therefore, the conclusion for indicator 4.1 is

‘low risk’.

Lao People´s Democratic Republic

Republic of Korea

Stakeholder composition 1 economic stakeholder General comments:

A comment was made pointing out that the category at the time only includes a legality assessment. The stakeholder asserted that the threshold of conversion to non-forest usage is less than 0.5% per year, and the category should therefore be

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Analysis:

The stakeholder provided no sources to support their claim, and it was not supported by the consultant’s later assessment, nor by the FAO data assessed by FSC.

Therefore, the risk designation remained ‘specified risk’.

Ukraine

The comments referred to issues related to the legislative framework and to the existing practice of conversion of forests to non-forest land categories.

The comments focused on the risk designation and the proposed control measures. The need to strengthen the justification of risk designation by supplementing relevant information sources was noted, as well as the need to review individual control measures.

Analysis:

All the comments and suggestions from the stakeholders were taken into account, which in turn required a more detailed revision of the risk designation. The conclusions were revised by increasing the quantity and diversity of information sources used. For forests of state ownership subordinated to the State Agency of Forest Resources of Ukraine (SAFRU), the risk was changed from ‘low’ to ‘specified’. The risk designation

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2017

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Controlled wood category 5: Wood from forests in which

genetically modified trees are planted

Lao People´s Democratic Republic

Republic of Korea

Ukraine

The comments provided supported a ‘low risk’ designation. Suggestions were provided to strengthen the conclusion on risk designation.

Analysis:

Synopsis stakeholder consultations - IN, LA, KR, UA

Synopsis of Stakeholder Consultations:

FSC Centralized National Risk Assessment

Contents

Introduction

Consultation Details

Analysis of stakeholder comments

Controlled wood category 1: Illegally harvested wood

Lao People´s Democratic Republic

Republic of Korea

Ukraine

Controlled wood category 2: Wood harvested in violation of

traditional and human rights

Lao People´s Democratic Republic

Republic of Korea

Ukraine

Controlled wood category 3: Wood harvested from forests in

which high conservation values are threatened by

management activities

India

Lao People´s Democratic Republic

Republic of Korea

Ukraine

Controlled wood category 4: Wood from forests being

converted to plantations or non-forest use

India

Lao People´s Democratic Republic

Republic of Korea

Ukraine

Controlled wood category 5: Wood from forests in which

genetically modified trees are planted

Lao People´s Democratic Republic

Republic of Korea

Ukraine