Conservation Forestry Partners, LP

Transcription

1 Conservation Forestry Partners, LP 8 Center Street, 2nd Floor Exeter, NH NSF-SFI-FM-C SFI Standards and Rules, Section 2 Registration Audit

2 NSF International Forestry Program Audit Report A. Program Participant s Name Conservation Forestry Partners, LP NSF Customer Number (FRS) NSF-SFI-FM-C B. Scope of Certification Management of lands and harvesting activities (by logging companies CF II-B TRS LLC and Country Roads TRS LLC) in Maine, including SFI Land Management Objectives 1-12, List of Locations Included in the Certification Forest ownerships under certification: Sandy Gray Forest LLC North Woods ME LLC Sylvan Timberlands LLC Snowshoe Timberlands LLC Logging Companies under certification: CF II-B TRS LLC Country Roads TRS LLC Address for contact of forest ownerships and logging companies: 1141 Main Street P O Box 554 Old Town, ME C. NSF Audit Team Tucker Watts D. Audit Dates January 17-20, 2017 E. Reference Documentation (Standards, Guidance, etc.) SFI Standards and Rules, Section 2 SFI Standards and Rules, Section 9, Appendix 1: Audits of Multi-Site Organizations Company Documentation (Program Manual, Procedures, etc.) Evidence Matrix Management of 327,300 +/- Acres Aroostook, Hancock, Penobscot, and Piscataquis Counties, Maine Management of Sandy Gray Forest 100,013 +/- Acres Somerset County, Maine F. Audit Results: Based on the results of this assessment, the auditor concluded: Acceptable with no nonconformities The following nonconformities were identified and will require corrective action. This is a confidential document and may be reproduced only with the permission of NSF International. Page 2 of 59

3 Major: Minor: In addition, opportunities for improvement (OFIs) were identified) Corrective actions and supporting documentation should be submitted to NSF through the NSF Online Customer Portal. For assistance, please contact your NSF Certification Project Manager. NSF also identified the following areas where forestry practices and operations of Conservation Forestry Partners, LP exceeds the basic requirements of the standard: Huber Resources Corp. has an ongoing dialogue with the Maine Natural Heritage Program and the Maine Fish and Wildlife Agency to continually update their GIS with additions to these databases. Conservation Forestry Partners, LP exceeds the requirements of this Indicator. (SFI Forest Management Standard, Indicator 4.4.1) Huber Resources Corp. is very knowledgeable of local markets and responds to these markets as changes occur. Conservation Forestry Partners, LP exceed the requirements of this indicator by their involvement in the market and knowledge of available markets and products desired. (SFI Forest Management Standard, Indicator 7.1.1) Licensed foresters are required to pass a test on laws and regulations. Conservation Forestry Partners, LP exceeds this requirement through the requirement of foresters to be licensed foresters and pass a test on laws and regulations. (SFI Forest Management Standard, Indicator 9.1.2) Through the active involvement of Huber Resources Corp. in various agencies and their personal involvement with landowners, Conservation Forestry Partners, LP exceeds this requirement. (SFI Forest Management Standard, Indicator ) G. Changes to Operations or to the Standard Note: Were there any significant changes in operations, procedures, specifications, facility records, etc., from the previous visit? Yes (Please explain: [explanation]) No H. Other Issues Reviewed Yes No N/A Public report from previous audit(s) is posted on the [SFI/SBP/etc.] website Yes No N/A Relevant industry specific logos or labels (SFI, PEFC, etc.) are utilized correctly. Yes No N/A Relevant accreditation logos (ANSI or ANAB) are utilized correctly and meet rules specified in AESOP 4876 sections and AESOP section GP-59. Yes No N/A Nonconformities from previous audit were reviewed. I. Future Audit Schedule [If yes, explain] Following the initial registration audit, continued certification requires annual assessments commonly referred to as Surveillance Audits. Additionally, at the end of the certification period, maintaining certification requires the completion of a recertification or Reassessment Audit. The next audit is a Surveillance Audit scheduled to be conducted during the week of October 16, J. Appendices Appendix 1: Appendix 2: Appendix 3: Appendix 4: Audit Notification Letter and Audit Schedule SFI Forest Management Public Summary Report Template Audit Standard Checklist(s): SFI Forest Management Standard Meeting Attendance Section 9, Appendix 1: Audits of Multi-Site Organizations This is a confidential document and may be reproduced only with the permission of NSF International. Page 3 of 59

4 This is a confidential document and may be reproduced only with the permission of NSF International. Page 4 of 59

5 Appendix 1 A. Program Participant s Name Conservation Forestry Partners, LP B. NSF Audit Team Tucker Watts C. Readiness Review Date January 12, 2017 D. Audit Team Recommendation Continue certification process NSF Forestry Program Readiness Review Report Nonconformities were identified that must be resolved prior to the certification audit. The following CARs require proof of corrective action implementation: Major: Minor: Any CARs are provided in the NSF Online System. The Program Participant must take appropriate corrective action prior to the certification audit. E. Scope of Certification The scope of the organization includes: SFI Forest Management SFI Fiber Sourcing American Tree Farm System SBP Standard #1: Feedstock Conformance SBP Standard #2: Verification of SBP-compliant Feedstock SBP Standard #4: Chain of Custody SBP Standard #5: Collection of Data for Energy and Carbon Balance Calculations The wording of the scope of certification as described on the NSF Facility Record Sheet (FRS) has been reviewed with a representative of the Program Participant. The proposed scope: Is correctly listed on the FRS form Has been modified as follows: Management of lands and harvesting activities (by logging companies CF II-B TRS LLC and Country Roads TRS LLC) in Maine, including SFI Land Management Objectives 1-12, Forest ownerships under certification: Sandy Gray Forest LLC North Woods ME LLC Sylvan Timberlands LLC Snowshoe Timberlands LLC Logging Companies under certification: CF II-B TRS LLC AESOP 14855; ISSUE 4; STATUS-PUBLISHED; EFFECTIVE 08 SEP 2016; AUTHORITY STACEY MACK This is a confidential document and may be reproduced only with the permission of NSF International. Page 5 of 59

6 Country Roads TRS LLC Address for contact of forest ownerships and logging companies: 1141 Main Street P O Box 554 Old Town, ME The Performance Measures and Indicators that are outside the scope of the program are described in Attachment 1 Readiness Review Summary Sheet. The program is a Multi-site Organization (SFI only) Yes No Site Organization: An organization having an identified central function (hereafter referred to as a central office but not arily the headquarters of the organization) at which certain activities are planned, controlled or managed and a network of l or branches (sites) at which such activities are fully or partially carried out. Source: SFI Requirements, Section 9, Appendix: Audits of Multi-Site Organizations Comments F. Proprietary Issues Are there any proprietary issues? (e.g., restricted access to areas of the site; restricted access to information such as attorney-client privileged compliance documents, etc.) Yes If Yes, please explain No G. Readiness Review Summary: The readiness review visit was performed by conference call. Participants included the management representative and team. The primary objectives of the review were to define the audit scope, define audit criteria, determine if the Program Participant is ready to continue with the certification process and develop an audit plan. 1. During the RR visit the lead auditor reviewed the following items with the Program Participant s management representative: NSF Procedures Safety Awareness Issues Corrective Action Requests The Composition of the Audit Team and the need for any Special Expertise The Program Participant s SFI Program and supporting documentation Audit Checklist(s) Population of Field Sites for Inspection Identified Interviewees Completed Audit Plan Outlined Audit Itinerary 2. The review conducted by the lead auditor confirms the following items: Program Participant has customized indicators and evidence to demonstrate conformance with the standard? If checked, provide indicators documents with the audit plan. AESOP 14855; ISSUE 4; STATUS-PUBLISHED; EFFECTIVE 08 SEP 2016; AUTHORITY STACEY MACK This is a confidential document and may be reproduced only with the permission of NSF International. Page 6 of 59

7 Program Participant has sufficient documentation of conformance to proceed with the audit. Program appears to address each of the Performance Measures and Indicators that apply. At least one BMP Monitoring and Management Review cycle has been completed. Other Issues or Comments: Inclusion of 2 logging companies owned by Conservation Forestry Partners, LP in the scope of certification Appendices: 1. Readiness Review Summary Sheet(s) 2. Tentative Audit Plan AESOP 14855; ISSUE 4; STATUS-PUBLISHED; EFFECTIVE 08 SEP 2016; AUTHORITY STACEY MACK This is a confidential document and may be reproduced only with the permission of NSF International. Page 7 of 59

8 Appendix 1 SFI , Section 2: Forest Management Standard Reviewer Tucker Watts Date of Review: January 12, 2017 Program Participant Name and Location Kent Gilges Exeter, NH; Kenny Fergusson, Barry Burgason Old Towne, ME Performance Measure Performance Measure Description Indicators Which Do Not Apply *Evidence **Objective Sufficient to Evidence Proceed Incomplete Program Participants shall Ensure that forest management plans include long-term harvest levels that are sustainable and consistent with appropriate growth-and-yield models. Not convert one forest cover type to another forest cover type, unless in justified circumstances Not have within the scope of their certification to this SFI Forest Management Standard, forestlands that have been converted to non-forestland use. 2.1 Promptly reforest after final harvest Minimize chemical use required to achieve management objectives while protecting employees, neighbors, the public and the environment, including wildlife and aquatic habitats Implement forest management practices to protect and maintain forest and soil productivity. Manage so as to protect forests from damaging agents, such as environmentally or economically undesirable wildfire, pests, diseases, and invasive exotic plants and animals, to maintain and improve long-term forest health, productivity and economic viability. Use best scientific methods if/when deploying improved planting stock, including varietal seedlings. Meet or exceed all applicable federal, provincial, state and local water quality laws, and meet or exceed best management practices developed under Canadian or U.S. Environmental Protection Agency approved water quality programs. Implement water, wetland and riparian protection measures based on soil type, terrain, vegetation, ecological function, harvesting system, state best management practices (BMPs), provincial guidelines and other applicable factors. 4.1 Conserve biological diversity Protect threatened and endangered species, Forests with Exceptional Conservation Values (FECV) and old-growth forests. Manage ecologically important sites in a manner that takes into account their unique qualities. AESOP 14855; ISSUE 4; STATUS-PUBLISHED; EFFECTIVE 08 SEP 2016; AUTHORITY STACEY MACK This is a confidential document and may be reproduced only with the permission of NSF International. Page 8 of 59

9 4.4 Apply knowledge gained through research, science, technology and field experience to manage wildlife habitat and contribute to the conservation of biological diversity. 5.1 Manage the impact of harvesting on visual quality. 5.2 Manage the size, shape and placement of clearcut harvests. 5.3 Adopt a greenup requirement or alternative methods that provide for visual quality. 5.4 Support and promote recreational opportunities for the public Identify special sites and manage them in a manner appropriate for their unique features. Employ appropriate forest harvesting technology and in-woods manufacturing processes and practices to minimize waste and ensure efficient utilization of harvested trees, where consistent with other SFI Forest Management Standard Objectives 8.1 Recognize and respect Indigenous Peoples rights Confer with affected Indigenous Peoples with respect to sustainable forest management practices if they have forest management responsibilities on public lands. Respond to local Indigenous Peoples with respect to sustainable forest management practices on their and are encouraged to communicate with them. Comply with applicable federal, provincial, state and local forestry and related social and environmental laws and regulations. Take appropriate steps to comply with all applicable social laws at the federal, provincial, state and local levels in the country in which the Program Participant operates. Individually and/or through cooperative efforts involving SFI Implementation Committees, associations or other partners provide in-kind support or funding for forest research to improve forest health, productivity and sustainable management of forest resources, and the environmental benefits and performance of forest products. Individually and/or through cooperative efforts involving SFI Implementation Committees, associations or other partners develop or use state, provincial or regional analyses in support of their sustainable forestry programs. Individually and/or through cooperative efforts involving SFI Implementation Committees, associations or other partners broaden the awareness of climate change impacts on forests, wildlife and biological diversity. Require appropriate training of personnel and contractors so that they are competent to fulfill their responsibilities under the SFI Forest Management Standard. Work individually and/or with SFI Implementation Committees, logging or forestry associations, or appropriate agencies or others in the forestry community to foster improvement in the professionalism of wood producers. AESOP 14855; ISSUE 4; STATUS-PUBLISHED; EFFECTIVE 08 SEP 2016; AUTHORITY STACEY MACK This is a confidential document and may be reproduced only with the permission of NSF International. Page 9 of 59

10 Support and promote efforts by consulting foresters, state, provincial and federal agencies, state or local groups, professional societies, conservation organizations, Indigenous Peoples and governments, community groups, sporting organizations, labor, universities, extension agencies, the American Tree Farm System and/or other landowner cooperative programs to apply principles of sustainable forest management. Support and promote, at the state, provincial or other appropriate levels, mechanisms for public outreach, education and involvement related to sustainable forest management. Establish, at the state, provincial-or other appropriate levels, procedures to address concerns raised by loggers, consulting foresters, employees, unions, the public or other Program Participants regarding practices that appear inconsistent with the SFI Forest Management Standard principles and objectives. Participate in the development of public land planning and management processes if they have forest management responsibilities on public lands. Provide a summary audit report, prepared by the certification body, to SFI Inc. after the successful completion of a certification, recertification or surveillance audit to the SFI Forest Management Standard. Report annually to SFI Inc. on their conformance with the SFI Forest Management Standard. Establish a management review system to examine findings and progress in implementing the SFI Forest Management Standard, to make appropriate improvements in programs, and to inform their employees of changes. *Does not indicate conformance. **Auditor and Program Participant must discuss the process for compiling sufficient evidence prior to audit. AESOP 14855; ISSUE 4; STATUS-PUBLISHED; EFFECTIVE 08 SEP 2016; AUTHORITY STACEY MACK This is a confidential document and may be reproduced only with the permission of NSF International. Page 10 of 59

11 Appendix 2 Introduction Tentative Audit Plan Conservation Forestry Partners, LP is seeking independent certification that its program conforms to the requirements of SFI Standards and Rules, Sections 2. An audit team assembled by NSF will make a determination of conformance. This audit plan describes the conduct of the audit to be conducted to determine conformance. Additional details about NSF s certification process are provided in the NSF International Forestry Program Policies for Accredited Third-Party Registration and Certification (AESOP 14680) and the Forestry Program Audit and Certification Process (AESOP 15517). Audits for the SFI Standards and Rules, Sections 2 are conducted in accordance with the principles of auditing contained in ISO/IEC 17021:2011 Conformity Assessment Requirements for Bodies Providing Audit and Certification of Management Systems. Organization Overview Conservation Forestry owns 372,922 acres of forestland in Maine divided into 4 ownerships which are included in the scope of this certification: 1. Sylvan Timberlands LLC is comprised of two districts, one near Ashland in northeastern Maine and one near Millinocket in central Maine. 2. North Woods ME Timberlands LLC is near the Katahdin Ironworks (KI) in central Maine. 3. Snowshoe Timberlands LLC is concentrated around the north and northeast borders of Baxter State Park. 4. Sandy Gray Forest LLC is located near Seaboomook Lake. The primary timber types managed include spruce-fir, mixed softwood-hardwood, tolerant hardwoods (sugar maple, birch, beech), intolerant hardwoods (birch and poplar), and wetland softwoods. Partial harvesting and the use of natural regeneration are the predominant approaches, although there is very limited silvicultural clearcutting. The logging companies rely on a full-time forestry staff and require that loggers are trained under the Maine Certified Logger Program to ensure sound, sustainable forestry practices on the land. Conservation Forestry Partners, LP s SFI Program is managed by Kent Gilges, Managing Member. Scope, Objectives, and Criteria for Certification The audit will apply to the implementation and other related activities according to the following scope statement: Management of lands and harvesting activities (by logging companies CF II-B TRS LLC and Country Roads TRS LLC) in Maine, including SFI Land Management Objectives 1-12, Forest ownerships under certification: Sandy Gray Forest LLC North Woods ME LLC Sylvan Timberlands LLC Snowshoe Timberlands LLC Logging Companies under certification: CF II-B TRS LLC Country Roads TRS LLC Address for contact of forest ownerships and logging companies: 1141 Main Street P O Box 554 Old Town, ME The SFI Standards and Rules, Sections 2 certification number is NSF-SFI-FM-C This is a confidential document and may be reproduced only with the permission of NSF International. Page 11 of 59

12 Determination of conformance will be based on the requirements of the standard. The indicators included in and excluded from the audit scope are outlined in Appendix 1: Readiness Review Summary, which is compiled during the readiness review. Findings will be based upon the language of the objectives, performance measures and indicators as modified by any relevant interpretations. The NSF audit team will not add any requirements that are not specified in the standard. Roles and Responsibilities The Company s management representative with respect to this audit is Kent Gilges. The lead auditor will be Tucker Watts. Auditor qualifications are consistent with the requirements of the standard and are provided in Appendix 2. Confidentiality and Conflict of Interest NSF auditors have signed a confidentiality agreement that includes provisions regarding the avoidance of conflict of interest. Prior to finalizing the audit team, the auditor and audit team members shall disclose to the Company any prior land appraisal or assessment work or land brokerage activity they or their employers conducted related to the property to be audited. Auditors will maintain strict confidentiality regarding all aspects of the audit. The Company reserves the right to release NSF and its subcontractors from specific terms of this confidentiality agreement in writing. NSF will retain a copy of the audit report, and audit team members may each retain the final report and selected components of the Company s documentation. All other Company materials, including detailed evidence, will be destroyed at the conclusion of the final report (exception for public agencies subject to FOIA or similar laws). Readiness Review and Report A readiness review meeting between the Company s staff and the lead auditor was held by phone on January 12, A document review and interviews were performed at that time, the lead auditor s credentials were confirmed, and both parties agreed upon a framework for the audit plan. The Company and the lead auditor also reviewed and came to agreement on the specific indicators of conformance that will be used to judge conformance with the standard. Agreement on the indicators of conformance is necessary to avoid surprises during the audit process. As an outcome of the readiness review the lead auditor determined that the Company is prepared, and necessary documentation is sufficient to undergo a full certification audit as outlined in this plan. The lead auditor prepared a report documenting the Company s readiness to proceed with the certification audit. Field Sites and Interviewees The Company s representatives are responsible for compiling field visit sites and interviewee lists that have a greater number of samples than are expected to be examined. Final selection of samples is at the discretion of the audit team. Potential Field Visit Sites The audit team will inspect a variety of field sites to assess conformance with the standard. Active harvesting sites will be visited. Logging contractors will be interviewed. Marketing will be discussed on the harvesting sites and with managers. Silviculture planning will be discussed and contractors will also be interviewed. Potential Audit Interviewees The lead auditor has identified the following categories of potential interviewees that may be contacted during the audit. The Company personnel are requested to develop and organize a list of names and phone numbers so that the audit team may conduct appropriate interviews. This list will be inserted into this plan as Appendix 4 as potential interviewees. Staff responsible for implementing the program Consultants retained to develop the management plan and assist with any forest management related activities. Certification Audit Schedule The certification audit will be conducted January 17-20, 2017 commencing with an opening meeting at the Huber Resource Corporation Office in Old Town, ME. The schedule for the office and field audit(s) to be performed by the NSF audit team is outlined below. This is a confidential document and may be reproduced only with the permission of NSF International. Page 12 of 59

13 January 17, :00 AM Opening Meeting 8:45 AM Documentation review and interviews 12:00 PM Lunch (on-site if possible) 1:00 PM Field Sites Visits and interviews (Snow Shoe Timberlands) 5:00 PM Daily Briefing January 18, :00 AM Field Visits and interviews (Sandy Gray Forest) 5:00 PM Daily Briefing January 19, :00 AM Documentation review and interviews 12:00 PM Lunch (on-site if possible) 1:00 PM Auditor Prepares for Closing Meeting 1:30 PM Closing Meeting January 20, :00 AM Tour Dolby Woodyard and discuss Logging Companies 12:00 PM Summarize findings Daily Briefings Each day of the audit will begin with a brief opening meeting covering the day s schedule, responsibilities, and arrangements; to obtain any needed documents; and to answer other preliminary questions. Each day will conclude with a short closing meeting to review the day s findings, confirm plans for the evening, and plan for activities the next day. Potential areas of minor or major non-conformance identified during the field audit will be discussed at the daily closing meeting. Additional evidence or field site investigations that could clarify the areas of non-conformance should be identified and prepared for the following day. Dispute Resolution Process The lead auditor is responsible for making a recommendation for certification. The NSF Certification Review Board member will review the audit report, consider the lead auditor s recommendation, and make a final determination regarding certification. In the event that there is a dispute between the lead auditor and the Company over interpretations of the standard or any other aspect of the audit, the first step is for the management representative to call the Certification Project Manager to resolve the dispute. If the dispute continues, the dispute resolution process of NSF International Forestry Program Policies for Accredited Third- Party Registration and Certification (SOP 14680) will be followed. Process for Preparation and Review of the Final Report The lead auditor will prepare a draft report consistent with the format and contents outlined in the Forestry Program Audit and Certification Process (AESOP 15517). The lead auditor may confer with the audit team and the customer, but must provide the report to the assigned NSF CB reviewer. The lead auditor will forward the draft final report to the Company for a review of factual accuracy generally within two weeks of the closing meeting. The Company will have up to two weeks to submit comments to the lead auditor. The lead auditor will This is a confidential document and may be reproduced only with the permission of NSF International. Page 13 of 59

14 incorporate appropriate suggestions from the Company and then submit the report to the NSF CB reviewer within one week of receipt of comments. The CB reviewer will review the report for thoroughness and completeness and shall make the final decision regarding certification. The NSF Certification Project Manager will ensure that a copy of the final reviewed report is issued to the Company within eight weeks of the closing meeting. If additional time is required the Certification Project Manager and/or the lead auditor will notify the Company. Public Summary Report A summary report must be provided to SFI, Inc. for posting on their web site for public review. Normally this public report is provided by the client. The summary report will be agreed to by NSF and the Company to ensure that it captures all of the relevant findings. Final Report In addition to the core elements of the Summary Report described above, the final report shall include the following: The audit plan including audit team personnel; The audit checklists and other required reports submitted by the Program Participant; and The report will be formatted according to the latest versions of the report templates for CBs which can be downloaded from the SFI website. Distribution of Reports The final and summary reports are the sole property of the Company which shall determine their distribution. All working documents, draft and final and summary reports in the possession of the audit team members and lead auditor shall be destroyed at the end of the audit process, unless agreed to in writing by NSF and the Company. NSF and the lead auditor may retain one copy of all documents related to the certification in permanent files for purposes of conducting surveillance audits and re-audits, and for other legitimate purposes. Certificate of Conformance Upon successful completion of the certification process, NSF shall issue a certificate of conformance. Certificates are valid for 3 years, with a recertification audit required before issuing each successive 3-year certificate. Surveillance Audit and Re-audit Schedule The final step in the audit planning process is to tentatively schedule periodic surveillance audits. The periodic surveillance audits will be scheduled within twelve months of the initial audit, and will generally occur annually or at shorter intervals. Appendices Attachment 1: Attachment 2: Auditor Qualifications Opening and Closing Meeting Attendees This is a confidential document and may be reproduced only with the permission of NSF International. Page 14 of 59

15 Attachment 1: Auditor Qualifications Tucker Watts is a partner in Watts Consulting LLC. His primary focus is forest certification through system development and auditing. For the past 5 years, Watts has been involved with SFI Forest Management and Chain of Custody auditing, FSC Forest Management and Chain of Custody auditing, Programme for the Endorsement of Forest Certification Chain of Custody auditing, auditing of the American Tree Farm System s Group certification, auditing of the Responsible Procurement Program of the National Wood Flooring Association and the Check Your Paper Program of the World Wildlife Fund. He is also involved with consulting forest products companies in certification system development. Watts has 30 year experience in forest management with a large forest products corporation involved in the manufacturing of paper, lumber and plywood. For 10 years Watts was a system manager for the forest certification system. Certification included the ISO14001 Standard and the SFI Standard for both forest management and Chain of Custody. Watts was also involved with developing the FSC Controlled Wood Risk Assessment for the Gulf South (Florida to Texas). As system manager he was involved with the development, implementation, and the daily management of the web based system. This is a confidential document and may be reproduced only with the permission of NSF International. Page 15 of 59

16 Attachment 2: Opening and Closing Meeting Attendees NSF Audit Attendance Sheet Company Name: Conservation Forestry Partners, LP - Maine Location (Plant # and/or City & State): Old Towne, ME Type of Audit: SFI Forest Management Certification Audit Opening Meeting Date: January 17, 2017 Closing Meeting Date: January 20, 2017 NAME (Printed) TITLE/POSITION OPENING MEETING (Initials) CLOSING MEETING (Initials) Kenny Fergusson Barry Burgason Kent Gilges Tucker Watts Maine Woodlands Forester Wildlife Biologist Conservation Forestry NSF Lead Auditor KF BB KG TW KF BB KG TW This is a confidential document and may be reproduced only with the permission of NSF International. Page 16 of 59

17 Appendix 2 NSF International Forestry Program Public Summary Audit Report FI Forest Management The SFI program of Conservation Forestry Partners, LP of Exeter, NH for the Maine Timberlands has demonstrated conformance with the SFI Standard and Rules, Section 2 Forest Management Standard in accordance with the NSF certification process. Conservation Forestry owns 372,922 acres of forestland in Maine divided into 4 ownerships which are included in the scope of this certification: Sylvan Timberlands LLC is comprised of two districts, one near Ashland in northeastern Maine and one near Millinocket in central Maine. North Woods ME Timberlands LLC is near the Katahdin Ironworks (KI) in central Maine. Snowshoe Timberlands LLC is concentrated around the north and northeast borders of Baxter State Park. Sandy Gray Forest LLC is located near Seaboomook Lake. The primary timber types managed include spruce-fir, mixed softwood-hardwood, tolerant hardwoods (sugar maple, birch, beech), intolerant hardwoods (birch and poplar), and wetland softwoods. Partial harvesting and the use of natural regeneration are the predominant approaches, although there is very limited silvicultural clearcutting. The logging companies rely on a full-time forestry staff and require that loggers are trained under the Maine Certified Logger Program to ensure sound, sustainable forestry practices on the land. Conservation Forestry Partners, LP s SFI Program is managed by Kent Gilges, Managing Member. The audit was performed by NSF on January 17-20, 2017 by an audit team headed by Tucker Watts, Lead Auditor. Audit team members fulfill the qualification criteria for conducting audits contained in SFI Standards and Rules, Section 9 - Procedures and Auditor Qualifications and Accreditation. The objective of the audit was to assess conformance of the firm s SFI Program to the requirements of the SFI Standard and Rules, Section 2 Forest Management. The scope of the audit included forest management operations. Forest practices that were the focus of field inspections included those that have been under active management over the planning period of the past 3 years. In addition practices conducted earlier were also reviewed as appropriate (regeneration and BMP issues, for example), SFI obligations to promote sustainable forestry practices, to seek legal compliance, and to incorporate continual improvement systems were also within the scope of the audit. Several of the SFI Section 2 requirements were outside of the scope of Conservation Forestry Partners, LP s SFI program and were excluded from the scope of the audit as follows: Indicator Conservation Forestry Partners, LP does not plant exotic tree species. Indicator Conservation Forestry Partners, LP is not involved in afforestation. Indicator Conservation Forestry Partners, LP does not use artificial regeneration. Indicator Conservation Forestry Partners, LP does not have management responsibility on public land. Indicator Conservation Forestry Partners, LP does not have forest laborers. Indicator Conservation Forestry Partners, LP is not involved with research on genetically engineered trees. Objective 13 is not applicable because Conservation Forestry Partners, LP does not manage public land. Performance Measure 14.1 This is a Certification Audit. The Summary Audit Report will be sent to SFI, Inc. following this audit. AESOP 12516; ISSUE 5; STATUS-PUBLISHED; EFFECTIVE 17 JUN 2016; AUTHORITY STACEY MACK This is a confidential document and may be reproduced only with the permission of NSF International. Page 17 of 59

18 Indicator This is a Certification Audit. The SFI Annual Program Report Summary will be sent to SFI, Inc. for Indicator This is a Certification Audit. There are no past SFI Annual Program Report Summaries. Audit Process NSF initiated the audit process with a readiness review to confirm the scope of the audit, review the SFI Indicators and evidence to be used to assess conformance, verify that Conservation Forestry Partners, LP was prepared to proceed to the audit, and to prepare a detailed audit plan. NSF then conducted the audit of conformance. A report was prepared and approved by an independent certification board member assigned by NSF. Follow-up or surveillance audits are required by SFI, Section 9. The initial surveillance audit is scheduled for the week of October 16, The audit was governed by a detailed audit plan designed to enable the audit team to efficiently determine conformance with the applicable requirements. The plan provided for the assembly and review of audit evidence consisting of documents, interviews, and on-site inspections of ongoing or completed forest practices. During the audit NSF reviewed a sample of the written documentation assembled to provide objective evidence of conformance. NSF also selected field sites for inspection based upon the risk of environmental impact, likelihood of occurrence, special features, and other criteria outlined in the NSF protocols. NSF selected and interviewed stakeholders such as contract loggers, landowners and other interested parties, and interviewed employees within the organization to confirm that the SFI Standard was understood and actively implemented. The surveillance audit covered a multi-site certification containing 4 ownerships and 2 logging companies as follows: Sylvan Timberlands LLC is comprised of two districts, North Woods ME Timberlands LLC,. Snowshoe Timberlands LLC, Sandy Gray Forest LLC, CF II-B TRS LLC Country Roads TRS LLC The ownerships and logging companies are managed by a central office located in Old Town, Maine. Sample size was determined using the guidelines set forth in IAF-MD1; 2 of the 4 ownerships and 2 of the 2 logging companies were selected for the audit. Sampling of the ownerships was based on a date rotation of sample. During the audit 8 field sites were visited consisting of 2 chemical applications (brush control on roadside and invasive species), 1 road and bridge construction, 1 road maintenance, 2 shelterwood/overstory removal harvest operations, and 2 overstory removal/harvest operations. The possible findings of the audit included Full Conformance, Major Non-conformance, Minor Non-conformance, Opportunities for Improvement, and Practices that exceeded the Basic Requirements of the standard. Overview of Audit Findings Conservation Forestry Partners, LP was found to be in conformance with the standard. Audit findings demonstrate Conservation Forestry Partners, LP is in conformance with sustainable harvest level requirements. A long-term sustainable harvest level is established for 100 years. This level is reviewed and reestablished every 5 years. Continuous updates are made to the inventory on a bi-annual basis. Current harvest trends between 2013 to 2016 indicate the actual harvest is below the long-term sustainable harvest level. During 2016, the actual total harvest and roundwood harvest are below the long-term sustainable harvest level. Longterm sustainable harvest and growth and yield are established by the Woodstock model. Forest practices are documented in the GIS sysem. NSF determined that there were no minor non-conformances: No opportunities for improvement were also identified, and included: AESOP 12516; ISSUE 5; STATUS-PUBLISHED; EFFECTIVE 17 JUN 2016; AUTHORITY STACEY MACK This is a confidential document and may be reproduced only with the permission of NSF International. Page 18 of 59

19 NSF also identified the following areas where forestry practices and operations of Conservation Forestry Partners, LP exceeds the basic requirements of the standard: Huber Resources Corp. has an ongoing dialogue with the Maine Natural Heritage Program and the Maine Fish and Wildlife Agency to continually update their GIS with additions to these databases. Conservation Forestry Partners, LP exceeds the requirements of this Indicator. (SFI Forest Management Standard, Indicator 4.4.1) Huber Resources Corp. is very knowledgeable of local markets and responds to these markets as changes occur. Conservation Forestry Partners, LP exceed the requirements of this indicator by their involvement in the market and knowledge of available markets and products desired. (SFI Forest Management Standard, Indicator 7.1.1) Licensed foresters are required to pass a test on laws and regulations. Conservation Forestry Partners, LP exceeds this requirement through the requirement of foresters to be licensed foresters and pass a test on laws and regulations. (SFI Forest Management Standard, Indicator 9.1.2) Through the active involvement of Huber Resources Corp. in various agencies and their personal involvement with landowners, Conservation Forestry Partners, LP exceeds this requirement. (SFI Forest Management Standard, Indicator ) The next audit is a Surveillance Audit scheduled to be conducted during the week of October 16, AESOP 12516; ISSUE 5; STATUS-PUBLISHED; EFFECTIVE 17 JUN 2016; AUTHORITY STACEY MACK This is a confidential document and may be reproduced only with the permission of NSF International. Page 19 of 59

20 General Description of Evidence of Conformity NSF s audit team used a variety of evidence to determine conformance. A general description of this evidence is provided below, organized by SFI Objective. Objective 1 Forest Management Planning To ensure forest management plans include long-term sustainable harvest levels and measures to avoid forest conversion. Summary of Evidence: Model of 100 year sustainable harvest level, with associated harvest trends, annual budgets, and monthly progress reports were used to assess long-term sustainable harvest levels. Other systems were evaluated for inventory, stand types, growth & yield modeling, biodiversity, soil type, and non-timber issues documentation and mapping. Objective 2 Forest Health and Productivity To ensure long-term forest productivity, carbon storage and conservation of forest resources through prompt reforestation, afforestation, minimized chemical use, soil conservation, and protecting forests from damaging agents. Summary of Evidence: Field observations and associated contracts and monitoring records were used to confirm practices. Forest Management Plan, Operational Guidelines, and BMP Manual provided criteria for implementation of practices. Interviews were also conducted with various types of contractors. Objective 3 Protection and Maintenance of Water Resources To protect the water quality of rivers, streams, lakes, wetlands and other water bodies through meeting or exceeding best management practices. Summary of Evidence: Field observations of a range of sites were the key evidence. Auditor visited the portions of field sites closest to water resources. Review of forest management plan, state BMPs, Maine F.P.A., Operating Guidelines, and contracts were also conducted. Objective 4 Conservation of Biological Diversity To manage the quality and distribution of wildlife habitats and contribute to the conservation of biological diversity by developing and implementing stand- and landscape-level measures that promote a diversity of types of habitat and successional stages, and the conservation of forest plants and animals, including aquatic species, as well as threatened and endangered species, Forests with Exceptional Conservation Value, old-growth forests and ecologically important sites. Summary of Evidence: Field observations, forest management plan, use of MOIST database, Marten Landscape Scale Planning Tool, and FIN Program provided evidence of conservation of biological diversity. Contacts with Maine Forest Service, US F&W, NRCS demonstrate landscape management. MNAR and Maine Fish & Wildlife databases assist in identification and mapping of special habitats on owned lands. Objective 5 Management of Visual Quality and Recreational Benefits To manage the visual impact of forest operations and provide recreational opportunities for the public. Summary of Evidence: Field observations of completed operations, forest management plans, and Maine F.P.A. provided guidance in visual quality evaluation. Maps of recreation sites, combined with field visits and interviews, confirmed a strong recreation program. Objective 6 Protection of Special Sites To manage lands that are geologically or culturally important in a manner that takes into account their unique qualities. Summary of Evidence: Field observations of completed operations, GIS, and records of special sites from MNAR and Maine F&W demonstrated protection of special sites. AESOP 12516; ISSUE 5; STATUS-PUBLISHED; EFFECTIVE 17 JUN 2016; AUTHORITY STACEY MACK This is a confidential document and may be reproduced only with the permission of NSF International. Page 20 of 59

21 Objective 7 Efficient Use of Fiber Resources To minimize waste and ensure the efficient use of fiber resources. Summary of Evidence: Field observations of completed operations, contract clauses, monitoring reports, and discussions with supervising foresters provided the key evidence. Objective 8 Recognize and Respect Indigenous Peoples Rights To recognize and respect Indigenous Peoples rights and traditional knowledge. Summary of Evidence: Sustainability Policy and Sustainable Forestry Policy, along with communication and response to affected Indigenous People were witnessed as evidence. Objective 9 Legal and Regulatory Compliance To comply with applicable federal, provincial, state and local laws and regulations. Summary of Evidence: Field reviews of ongoing and completed operations and interviews with state agencies were the most critical evidence. Forestry Rules of Maine 2014 provided by state agencies also assisted in documentation. Objective 10 Forestry Research, Science and Technology To invest in forestry research, science and technology, upon which sustainable forest management decisions are based and broaden the awareness of climate change impacts on forests, wildlife and biological diversity. Summary of Evidence: Membership and participation in the Maine Forest Products Council, Maine SIC, and CFRU document involvement in research. Attendance of meeting and seminars on climate change contributed to understanding of climate change impacts. Objective 11 Training and Education To improve the implementation of sustainable forestry practices through appropriate training and education programs. Summary of Evidence: Training records of personnel, and records associated with harvest sites and silviculture operations audited provided confirmation of participation in training programs. Objective 12 Community Involvement and Landowner Outreach To broaden the practice of sustainable forestry through public outreach, education, and involvement, and to support the efforts of SFI Implementation Committees. Summary of Evidence: Membership in various organizations, and agendas for meetings and selected summaries of comments were sufficient to assess the requirements. Objective 13 Public Land Management Responsibilities To participate and implement sustainable forest management on public lands. Summary of Evidence: N.A. The Company does not have management responsibilities for public lands. Objective 14 Communications and Public Reporting To increase transparency and to annually report progress on conformance with the SFI Forest Management Standard. Summary of Evidence: N.A. This is a certification audit. Documents have not been developed due to no past certification. Objective 15. Management Review and Continual Improvement To promote continual improvement in the practice of sustainable forestry by conducting a management review and monitoring performance. Summary of Evidence: Records of program reviews, agendas and notes from management review meetings, and interviews with personnel involved in management review were assessed. AESOP 12516; ISSUE 5; STATUS-PUBLISHED; EFFECTIVE 17 JUN 2016; AUTHORITY STACEY MACK This is a confidential document and may be reproduced only with the permission of NSF International. Page 21 of 59

22 Relevance of Forestry Certification Third-party certification provides assurance that forests are being managed under the principles of sustainable forestry, which are described in the Sustainable Forestry Initiative Standard as: 1. Sustainable Forestry To practice sustainable forestry to meet the needs of the present without compromising the ability of future generations to meet their own needs by practicing a land stewardship ethic that integrates reforestation and the managing, growing, nurturing and harvesting of trees for useful products and ecosystem services such as the conservation of soil, air and water quality, carbon, biological diversity, wildlife and aquatic habitats, recreation and aesthetics. 2. Forest Productivity and Health To provide for regeneration after harvest and maintain the productive capacity of the forest land base, and to protect and maintain long-term forest and soil productivity. In addition, to protect forests from economically or environmentally undesirable levels of wildfire, pests, diseases, invasive exotic plants and animals and other damaging agents and thus maintain and improve long-term forest health and productivity. 3. Protection of Water Resources To protect water bodies and riparian areas, and to conform with forestry best management practices to protect water quality. 4. Protection of Biological Diversity To manage forests in ways that protect and promote biological diversity, including animal and plant species, wildlife habitats, and ecological or natural community types. 5. Aesthetics and Recreation To manage the visual impacts of forest operations, and to provide recreational opportunities for the public. 6. Protection of Special Sites To manage lands that are ecologically, geologically or culturally important in a manner that takes into account their unique qualities. 7. Responsible Fiber Sourcing Practices in North America To use and promote among other forest landowners sustainable forestry practices that are both scientifically credible and economically, environmentally and socially responsible. 8. Legal Compliance To comply with applicable federal, provincial, state, and local forestry and related environmental laws, statutes, and regulations. 9. Research To support advances in sustainable forest management through forestry research, science and technology. 10. Training and Education To improve the practice of sustainable forestry through training and education programs. 11. Community Involvement and Social Responsibility To broaden the practice of sustainable forestry on all lands through community involvement, socially responsible practices, and through recognition and respect of Indigenous Peoples rights and traditional forest-related knowledge. 12. Transparency To broaden the understanding of forest certification to the SFI Standard by documenting certification audits and making the findings publicly available. 13. Continual Improvement AESOP 12516; ISSUE 5; STATUS-PUBLISHED; EFFECTIVE 17 JUN 2016; AUTHORITY STACEY MACK This is a confidential document and may be reproduced only with the permission of NSF International. Page 22 of 59