Synopsis stakeholder consultations - BE, DK, IE, VN

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Synopsis of Stakeholder Consultations:

FSC Centralized National Risk Assessments

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SYNOPSIS OF STAKEHOLDER CONSULTATIONS: FSC CENTRALIZED NATIONAL RISK ASSESSMENTS 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 4 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 except for Belgium and Ireland which were conducted by FSC, and those for controlled wood category 2 were conducted by Wolfgang Richert and Leo van der Vlist.

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 / May 2017 for the international consultation (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, with the exception of the Belgium 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

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: Denmark. No stakeholders submitted comments on the risk assessment for this category.

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

Denmark

No stakeholder comments received.

Issue of interest:

The risk designation of indicator 1.21 (legal requirements and implementation of due diligence/due care systems) states that many forester do not have/do not implement a DDS, though it is a requirement under given circumstances. The final risk

designation is, however, designated as ‘low’. When asked, the consultant stated that there are two reasons for a finding of low risk despite this fact:

1. It is true for most of Europe that many foresters do not develop/implement DDS. This would require most European countries already approved to be reviewed/changed.

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Controlled wood category 2: Wood harvested in violation of

traditional and human rights

Draft assessments for the following countries were subject to consultation: Denmark, Viet Nam. No stakeholders submitted comments on the risk assessments for this category.

Denmark

Issue of interest:

The risk designation of indicator 2.2 (labor rights are upheld including rights as specified in ILO Fundamental Principles and Rights at Work) was designated as ‘specified’ for gender wage discrimination by the consultant. The consultant based the finding of ‘specified risk’ in reliable but general sources. PSU received a formal request from FSC Denmark to change the designation to ‘low risk’, based on the following:

1. The central authority on Danish statistics does not support the ‘specified risk’ conclusion. There are no wage statistics specific to the forest sector, but the lumped data available show that women’s wages are higher than men’s. 2. The ‘specified risk’ conclusion is not supported by the Danish national center

for social research (SFI). SFI calculated the size of the unexplained wage gap for every year in the period 1997-2011, and the result greatly differs from the 25 pct. mentioned in the ILO Global Wage Report 2014/15 (source used by the consultant). SFI’s analysis found that the difference in salary was 13-17 pct. in 2011, while the unexplained salary difference was 4-7 pct.

3. In Denmark the labor participation rate for women is 75 pct (4th highest in the

world) and there is a legal requirement for equal pay.

4. A ‘specified risk’ conclusion will give the impression that FSC has no understanding of reality and it will distance FSC from key stakeholders in Denmark.

Based on this arguments, the risk designation was changed to ‘low’ and the assessment was modified accordingly.

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: Belgium, Denmark, Ireland. Stakeholders submitted comments on the risk assessments for the following countries: Belgium, Denmark, Ireland.

Belgium

Stakeholder composition

See evaluation report (national consultation)

General comments:

Stakeholder consultation was done on an assessment changed by FSC Belgium and not approved for consultation by PSU.

Analysis:

The consultant rewrote the entire assessment taking into account the comments from PSU, FSC Belgium and the stakeholders. ‘Low risk’ was concluded by the consultant for all indicators based on the available evidence.

Denmark

1 Economic North member

General comments:

Comments from the stakeholder disagreed with the ‘specified risk’ finding of indicators 3.1 and 3.3. Comments were made pointing out the perceived contradiction between Category 1, wherein it was determined that Denmark’s legislation was well enforced and constituted a low risk, and these indicators wherein the implementation of certain legislation (such as Natura 2000) was called into question, resulting in specified risk to HCV 1 and HCV 3 for privately owned forests without a green management plan.

It was stated that Danish law is rigorously enforced for all legislation, including the legislation ensuring protection of HCVs, regardless of forest ownership. No additional sources were provided.

Analysis:

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Ireland

Stakeholder composition FSC UK

General comments:

No comments from the stakeholder disagreed with the “low risk” finding of indicators 3.0 to 3.6. Comments were made expressing general agreement and similarities with UK National HCV Framework. Some comments were made pointing out minor editorial and style mistakes (e.g., incomplete references, repeated information), and the need to add general clarifications (e.g., definitions).

Regarding content related comments, for indicator 3.1 a comment was made recommending caution in the use of reporting on biodiversity trends to determine whether regulation successfully protects HCV 1. Additionally, for indicator 3.4 the question was posed whether or not it is relevant to describe in detail a flood risk assessment system which is not yet in place.

Analysis:

The consultant did not need to change the evaluation in response to the stakeholder comments. The mentioned editorial and style mistakes were amended where considered necessary by the consultant and by PSU.

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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: Belgium, Denmark, Ireland, Viet Nam. Stakeholders submitted comments on the risk assessments for the following countries: Belgium, Denmark, Ireland.

Belgium

See evaluation report (national consultation)

General comments:

A comments was made by a CB criticizing the adequacy of two measurement tools mentioned in the spatial analysis ('Boswijzer', 'Bosbarometer 2012').

Analysis:

The spatial data mentioned in relation to measurements made by both tools is only a reference. In addition to this, spatial data provided by FAO in its Global Forest

The comment from the stakeholder disagreed with the specified risk finding of indicator 4.1. It was stated that if Category 1 is found to be low risk (that is, there is a low risk of sourcing illegally harvested wood), then assuming laws are well enforced in Denmark, forests would not be systematically converted to plantations or non-forest uses. Furthermore, the FAO determined that the forested area of Denmark increased by 1.1% between the years 2000 and 2010.

Analysis:

The consultant concluded that there has been increased forest cover in Demark between the years 2000 and 2010, and while their sources indicate 28% of the current forest cover is not safeguarded by Denmark’s Forest Act, it nevertheless did not pose a significant risk to forests outside the so-called “reserved forests”. Risk designation was changed to ‘low risk’.

Ireland

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General comments:

The comment from the stakeholder referred to the ‘undesignated risk’ conclusion by the consultant.

Analysis:

Following an agreement with PSU, ‘undesignated risk’ is given by the consultants when the assessment based on legislation is 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. The conclusion for indicator 4.1 is ‘low risk’.

Viet Nam

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. The conclusion for indicator 4.1 is ‘low risk’.

According to the assessment made by the consultant, the government of Viet Nam has stated clearly that its intention is to convert large forest areas to rubber plantations. However, the assessment shall deal with the current situation and at the time of the assessment this was not yet an issue. Additionally, the spatial data provided by FAO in its Global Forest Resources Assessment leads to a ‘low risk’ designation. In the case that the threshold is exceeded in the future, an urgent revision according to FSC-PRO-60-002 V3-0 can be conducted to change the risk designation.

NOTE: Category 4 for Viet Nam was not approved. Further research is needed in the

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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: Denmark, Viet Nam. No stakeholders submitted comments on the risk assessments for this category.

Synopsis stakeholder consultations - BE, DK, IE, VN

Synopsis of Stakeholder Consultations:

FSC Centralized National Risk Assessments

Contents

Introduction

Consultation Details

Analysis of stakeholder comments

Controlled wood category 1: Illegally harvested wood

Denmark

Controlled wood category 2: Wood harvested in violation of

traditional and human rights

Denmark

Viet Nam

Controlled wood category 3: Wood harvested from forests in

which high conservation values are threatened by

management activities

Belgium

Denmark

Ireland

Controlled wood category 4: Wood from forests being

converted to plantations or non-forest use

Belgium

Ireland

Viet Nam

Controlled wood category 5: Wood from forests in which

genetically modified trees are planted

Denmark

Viet Nam