Skeena Sawmills Ltd SFI Certification Audit

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1 Skeena Sawmills Ltd SFI Certification Audit From September an audit team from KPMG Performance Registrar Inc. (KPMG PRI) carried out an SFI registration audit of Skeena Sawmills Ltd. woodlands operations and fibre procurement activities against the requirements of the Sustainable Forestry Initiative (SFI) forest management and fibre sourcing standards. To provide for a more efficient audit, a PEFC Chain of Custody registration audit was conducted at the same time. This Certification Summary Report provides an overview of the process and KPMG s findings. Description of Skeena Sawmills Ltd. Woodlands Operations Skeena Sawmills Ltd. woodlands operations are located in the vicinity of Terrace, BC and encompass a total area of 560,923 hectares. Skeena Sawmills has three licenses on crown land (FL A16885, FL A16882, TFL 41) and a total AAC (allowable annual cut) of 316,596 m 3 /year. The 2017 audit found that the Company s forest harvesting conforms to the AAC applicable to these operations. The woodlands operations that are included within the scope of the Company s SFI certification are covered by government-approved harvest plans that address both timber and non-timber values. These are developed to be consistent with their higher level Forest Stewardship Plan for operations administered by Skeena Sawmills Ltd. in the Kalum and Nass Timber Supply Areas located within the Coast Mountains Resource District. The areas covered by Skeena Sawmills Ltd. SFI certification fall within the following WWF ecoregions: (11) Northern Pacific Coastal Forests, (12) Northern Transitional Alpine Forests, and (14) Pacific Coastal Mountains Icefields and Tundra. The forests managed by Skeena Sawmills s are predominantly coniferous with the main commercial tree species being Western hemlock, Amabilis fir, Western redcedar, Sitka spruce, and Yellow-cedar. The forest management approach employed by the the company is based on even-aged management, ground-based harvesting systems, clearcut harvesting with the retention of reserves of standing trees either within or adjacent to harvest areas and replanting of harvest areas within a few years with a mix of ecologically suited tree species. Description of Skeena Sawmill s Manufacturing Facilities and Fibre Sourcing Program The company operates its sawmill in the community of Terrace, BC and sources fibre from the Coast Mountain Resource District. Most of the logs for the mills are sourced from the company s two Forest licenses and one Tree farm License with a small amount being purchased from privately held land. #0746 The Company participates in the Western Canada SFI Implementation Committee (WCSIC) Purchase Wood Monitoring Program by completing risk assessments for all wood purchases and purchase wood inspections as necessary. The results are then collated by WCSIC (of which the Company is a member) in order to identify trends in performance and opportunities for improvement.

2 Audit Scope The audit was conducted against the requirements of the edition of the SFI forest management and fibre sourcing standards, and incorporated an assessment against the SFI program objectives shown in Tables 1 & 2 in the report. The scope of the 2017 SFI surveillance audit of forestry and logging (including planning, roads, harvesting, and silviculture) on Skeena Sawmills Ltd. s forest licenses and fibre sourcing for the company s sawmill located in Terrace, BC. The Audit Audit Team The audit was conducted by Branden Beatty, R.P.Bio, EP(EMSLA) Lead Auditor, and Michael Alexander RPF, EP(EMSLA) as team member. Branden is an employee of KPMG PRI, and has conducted numerous forest management audits under a variety of standards including SFI, ISO 14001, CSA Z809 and FSC. Michael is an independent consultant with experience in conducting forest against the ISO and SFI standards SFI Registration Audit The audit involved an on-site assessment of all elements of the SFI program, and included visits to several field sites (8 roads, 7 harvesting, 2 silviculture sites, and 1 wood procurement site) to evaluate conformance with the requirements of the current SFI forest management and fibre sourcing standards. The 2017 Skeena Sawmills audit took a total of 8 auditor days to complete, 6 days of which were spent on-site at the operations included in the audit sample. The balance of audit time was spent preparing the audit plan, completing an off-site review of selected company documents and records and completing various audit checklists and preparing the main and public summary audit reports. Skeena Sawmills Ltd. SFI Program Representative Greg Demille served as Skeena Sawmills Ltd s SFI program representative during the audit. Use of Substitute Indicators The audit involved an assessment of conformance against the applicable objectives, performance measures and indicators included in the version of the SFI forest management and fiber sourcing standards. None of the indicators included in the SFI standards were modified or substituted for the purpose of this audit. Audit Objectives The objectives of the audit were to evaluate the sustainable forest management system at Skeena Sawmills to: Determine its conformance with the requirements of the SFI forest management and fibre sourcing standards; Evaluate the ability of the system to ensure that Skeena Sawmills woodlands operations meet applicable regulatory requirements, and; Evaluate the effectiveness of the system in ensuring that Skeena Sawmills meets its specified SFM objectives. Where applicable, identify opportunities for improvement. Skeena Sawmills Ltd. SFI Certification Audit Findings Open non-conformities 0 New major nonconformities New minor nonconformities New opportunities for improvement Types of audit findings Major non-conformities: Are pervasive or critical to the achievement of the SFM Objectives. Minor non-conformities: Are isolated incidents that are noncritical to the achievement of SFM Objectives. All non-conformities require the development of a corrective action plan within 30 days of the audit. Corrective action plans to address major nonconformities must be fully implemented by the operation within 3 months or certification cannot be achieved / maintained. Corrective action plans to address minor non-conformities must be fully implemented within 12 months. Opportunities for Improvement: Are not non-conformities but are comments on specific areas of the SFM System where improvements can be made

3 Evidence of Conformity with the SFI Forest Management and Fibre Sourcing Standards Primary sources of evidence assessed to determine conformity with the SFI forest management and fibre sourcing standards are presented in the following tables. SFI Forest Management Objective Key Evidence of Conformity 1. Forest Management Planning Forest Stewardship Plan, geographic information system, forest inventory records, harvesting records, interviews with planning staff. 2. Forest Health and Productivity Site plans, silviculture reports, field 3. Protection and Maintenance of Water Resources 4. Conservation of Biological Diversity 5. Management of Visual Quality and Recreational Benefits Field inspections of riparian areas, review of site plans & harvest plans. Forest management plan, FSP, site plans, interviews with planning staff, field Forest management plan, FSP, harvest plans, field 6. Protection of Special Sites Forest management plan, FSP, site plans, special site 7. Efficient Use of Fibre Resources Forest management plan, waste reports, field 8. Recognize and Respect Indigenous Peoples Rights 9. Legal and Regulatory Compliance 10. Forestry Research, Science and Technology Company policy on Indigenous Peoples rights, records of consultation with local Indigenous Peoples, pre-audit questionnaire responses, interviews with Company staff Forest management plan, environmental management plan (EMP), health & safety policy, field Forest management plan, EMP, records of research projects and funding, staff interviews. 11. Training and Education Forest management plan, EMP, training records, SIC minutes & resources, interviews with staff and contractors. 12. Community Involvement and Landowner Outreach 13. Public Land Management Responsibilities 14. Communications and Public Reporting 15. Management Review and Continual Improvement Forest management plan, EMP, SIC minutes & resources, community and landowner outreach records, staff interviews. Records of cooperative public land planning processes, forest management plan, FSPs and associated referral process, site plans, records of plan referrals to local stakeholders, staff interviews. Certification summary report, annual report to SFI Inc. Forest management plan, management review records, internal audit and related action plans. An example of the coarse woody debris distribution throughout a cutblock under Skeena Sawmill s management An example of land clearing and slash piling on a nearby private cutblock with material having been purchased by Skeena Sawmills.

4 Evidence of Conformity with the SFI Fibre Sourcing Standard SFI Fibre Sourcing Objective # Key Evidence of Conformity 1. Biodiversity in Fibre Sourcing Program to promote biodiversity in fibre sourcing, records of involvement in local or regional conservation efforts, interviews with procurement staff. 2. Adherence to Best Management Fibre sourcing policy and records of its Practices distribution to wood producers, written fibre sourcing agreements, records of implementation of the BMP monitoring system, inspection of a sample of procurement sites. 3. Use of Qualified Resource and Qualified Logging Professionals List of Qualified Resource and Logging Professionals, records of proportion of fibre delivered by QLPs, interviews with procurement staff. 4. Legal and Regulatory Compliance Company policies regarding regulatory compliance, procedures to ensure compliance with applicable regulatory requirements, inspection of a sample of procurement sites, interviews with regulatory agency personnel. 5. Forestry Research, Science and Technology Records of research projects and funding, staff interviews. 6. Training and Education Training records, SIC minutes & resources, interviews with staff and contractors. 7. Community Involvement and Landowner Outreach 8. Public Land Management Responsibilities 9. Communications and Public Reporting 10. Management Review and Continual Improvement SIC minutes & resources, community and landowner outreach records, staff interviews. Records of cooperative public land planning processes, records of plan referrals to local stakeholders, procurement staff interviews. Certification summary report, annual report to SFI Inc. Management review records, internal audit and related action plans. Green-up of block in region. 11. Promote Conservation of Biological Diversity, Biodiversity Hotspots and High-Biodiversity Wilderness Areas 12. Avoidance of Controversial Sources Including Illegal Logging 13. Avoidance of Controversial Sources Including Fibre Sourced from Areas without Effective Social Laws This objective only applies outside Canada and the US. This objective only applies outside Canada and the US. This objective only applies outside Canada and the US.

5 Good Practices A number of good practices were identified during the course of the audit. Examples included: SFI Forest Management Objective 2 (forest health and productivity) the audit found the understory retention on block A to be widespread and well protected. SFI Forest Management General evidence packages provided for the document review were comprehensive. SFI Forest Management Objective 15 (management review) final Inspections of two blocks were noted to be completed with great attention to detail, including maps of slash piles, and culvert deactivation ( as-is map). Follow-up on Findings from Previous Audits As this was an initial certification audit, at the time of this assessment there were no open nonconformities from previous Skeena Sawmill s external SFI audits. Areas of Nonconformance A total of 3 minor non-conformities were identified during the SFI certification audit of Skeena Sawmills Ltd. woodlands and fibre sourcing operations. These were: SFI Forest Management Objective 9 (communication and public reporting) SFM FM Objective 9.2 requires the operation to have a system to achieve compliance with applicable laws and regulations. The audit noted that during the harvesting of block , a spur road had been added to the map and block due to harvesting access issues, and a large area was removed from the map and block, due to concentrated riparian issues. While these changes were discussed with forestry staff, no formal site plan amendment had occurred prior to their construction. SFI Forest Management Objective 15 (management review and continual improvement) SFI FM Objective 15.2 requires program participants to have a system for collecting, reviewing, and reporting information to management regarding progress in achieving SFI Forest Management Standard objectives and performance measures. While harvesting site inspections were being completed for block , the audit found a slash pile placed close (less than 30 m) to a wildlife tree patch had not been captured within the SFII Forest Management Objective 4 (forest resreach, science and technology ) SFI FM Objective 4.8 requires the participant to consider the role of natural disturbance when developing forest management plans. The audit noted numerous blocks had boundaries planned and cut up to OGMAs and wildlife conservations areas. No wind throw assessments were available to provide a rationale why wind throw mitigation around boundaries was not required. Opportunities for Improvement A total of 2 opportunities for improvement were also identified during the audit., these were: SFI Forest Management Objective 15 (management review and continual improvement). SFI FM Objective 15.2 requires program participants to have a system for collecting, reviewing, and reporting information to management regarding progress in achieving SFI Forest Management Standard objectives and performance measures. Skeena Sawmill s FSP provides, for each resource value that has an assigned objective, a stand-alone set of results and strategies for Skeena s primary forest activities that will be undertaken within the Kalum TSA, TFL 41, and the Nass TSA. The audit found that the management review did not

6 provide enough detail in order to determine whether Skeena Sawmills is evaluating performance pertaining to the various commitments under the FSP. SFI Forest Management Objective 15 (management review and continual improvement) SFI FM Objective 15.2 requires program participants to have a system for collecting, reviewing, and reporting information to management regarding progress in achieving SFI Forest Management Standard objectives and performance measures. The audit noted that harvesting site inspections were being completed according to a frequency assigned by a risk rating, however the operation was found to not have a standard approach to risk rating. Audit Conclusions The audit found that the Skeena Sawmill s sustainable forest management system and fibre sourcing program: Were in full conformance with the requirements of the SFI forest management and fibre sourcing standards included within the scope of the audit, except where noted otherwise in this report; Have been effectively implemented, and; Are sufficient to systematically meet the commitments included within the organization s environmental and SFM policies, provided that the systems continues to be implemented and maintained as required. As a result, a decision has been reached by the lead auditor to recommend that Skeena Sawmill s continue to be certified to the SFI forest management and fibre sourcing standards. Corrective Action Plans Corrective action plans designed to address the root causes of the non-conformities identified during the audit have been developed by Skeena Sawmills Ltd. and reviewed and approved by KPMG PRI. The next surveillance audit will include a follow-up assessment of these issues to confirm that the corrective action plans developed to address them have been implemented as required. Focus Areas for the Next Audit Visit The following issues/potential concerns have been identified as focus areas for the next audit visit: Stream buffer procedure changes. Full implementation of the certified volume credit input and sales tracking system. Waste utilization advancements under Skeena Sawmills bioenergy program. Contacts: Chris Ridley-Thomas, RPBio, EP(EMSLA) (604) David Bebb, RPF, EP(EMSLA) (604) This report may only be reproduced by the intended client, Skeena Sawmills Ltd., with the express consent of KPMG. Information in this issue is of a general nature with respect to audit findings and is not intended to be acted upon without appropriate professional advice KPMG. All rights reserved. Through KPMG PRI, KPMG s Vancouver based forestry group is accredited to register forest companies to ISO 14001, CSA-SFM, SFI and PEFC certification standards.