Forest Management Public Summary. for. Ecotrust Canada

Transcription

1 Forest Management Public Summary for Ecotrust Canada Certification Code: SW-FM/COC-1758 Date of Certification: January 25, 2006 Date of Public Summary: February 2006 This document was produced according to the guidelines of the Forest Stewardship Council (FSC) and the SmartWood Program. No part of the report should be published separately. Certifier: SmartWood Program 1 c/o Rainforest Alliance 665 Broadway, 5 th Floor New York, New York USA TEL: (212) FAX: (212) info@smartwood.org Website: 1 SmartWood is implemented worldwide by the nonprofit members of the SmartWood Network. The Network is coordinated by the Rainforest Alliance, an international nonprofit conservation organization. The Rainforest Alliance is the legally registered owner of the SmartWood certification mark and label. All uses of the SmartWood label for promotion must be authorized by SmartWood headquarters. SmartWood certification applies to forest management practices only and does not represent endorsement of other product qualities (e.g., financial performance to investors, product function, etc.). SmartWood is accredited by the Forest Stewardship Council (FSC) for the certification of natural forest management, tree plantations and chain-of-custody.

2 INTRODUCTION This report presents the findings of an independent certification assessment conducted by a team of specialists representing the SmartWood Program of the Rainforest Alliance The purpose of the assessment was to evaluate the ecological, economic and social sustainability of Ecotrust Canada Vancouver Island Ecoforestry Group (Ecotrust Canada VIEG) forest management as defined by the Forest Stewardship Council. This operation meets the qualifications for small and low intensity managed forest (SLIMF) as defined by the FSC and was evaluated using the streamlined FSC SLIMF procedures. To earn SmartWood certification, a forest management operation must undergo an on-site field assessment. This Public Summary Report summarizes information contained in the initial assessment report, which is produced based on information collected during the field assessment. Annual audits are conducted to monitor the forest management operation s activities, to review the operation s progress toward meeting their certification conditions (corrective action requests), and to verify compliance with the SmartWood standards. Addenda providing the updated information obtained during these annual audits are included as attachments to the Public Summary Report. The purpose of the SmartWood program is to recognize conscientious land stewardship through independent evaluation and certification of forestry practices. Forestry operations that attain SmartWood certification may use the SmartWood and FSC labels for public marketing and advertising. Page 2 of 26

3 1. SCOPE OF THE CERTIFICATE 1.1. Scope of the certificate Ecotrust Canada is a not-for-profit organisation based in Vancouver with a mandate to build the conservation economy in British Columbia. The certificate will be held by Ecotrust Canada, and group management functions will be the responsibility of Ecotrust Canada forestry staff and contractors Exclusion of areas from the scope of certificate Ecotrust Canada holds the group certificate and ensures that group member forest management planning and practices comply with the FSC Standard ( Indicators for Compliance with the FSC Principles and Criteria for Small Operations in British Columbia ). Group members retain forest management control over their forest management operation as long as operations comply with the FSC standard. SmartWood considered the issue of exclusions as they pertained to group members. There were no exclusions noted. Ecotrust Canada itself does not control forest management operations in Canada. Through a variety of arrangements Ecotrust Canada has influence over some forest management operations in British Columbia. Ecotrust Canada is dedicated to promoting FSC certification. In 2004 Ecotrust Canada provided technical support to Inlailawatash Holdings Ltd. (Tsleil-Waututh First Nation) to achieve FSC certification for private lands near Vancouver, British Columbia. SmartWood is satisfied that Ecotrust Canada, as group manager, is committed to promoting FSC certification. The issue of exclusions does not apply to Ecotrust Canada directly since the organization does not control forest management operations. Page 3 of 26

4 2. ASSESSMENT PROCESS 2.1. Certification Standard Used SmartWood assessed the Ecotrust Canada Vancouver Island Ecoforestry Group certificate against the Indicators for Compliance with the FSC Principles and Criteria for Small Operations in British Columbia. The certification assessment of the Ecotrust Canada VIEG occurred in two phases: Phase 1. Field Assessment The field assessment was carried out against the Indicators for Compliance with the FSC Principles and Criteria for Small Operations in British Columbia Approved Final Draft 2/26/2005. This draft was approved by the BC regional FSC organization and subsequently by FSC Canada. Phase 2. Assessment Completion The assessment was completed against the version of the Standard approved for use by FSC International: Revised FSC-BC Small Operations Standards October 30, SmartWood reviewed the changes made to the Standard from the 2/26/2005 version to the version approved for use by FSC International and determined that there were no material changes in the Standard requiring additional field assessment. Where the Standard changed SmartWood revised the assessment report and reconsidered its findings and certification decision accordingly. This paper will refer to the Indicators for Compliance with the FSC Principles and Criteria for Small Operations in British Columbia as the Standard, or the Small Operations Standard. The Standard is available at Assessment team and qualifications Bodo von Schilling, Registered Professional Forester Team Leader, Forestry and Ecological Assessor The Team Leader Forester and Social Scientist was Bodo von Schilling, a Registered Professional Forester in British Columbia, Canada. Mr. von Schilling has a B.Sc(F) and has worked in forest management since 1982 both in the interior and on coastal British Columbia writing management plans, implementing forestry projects and conducting compliance and effectiveness audits. He has worked for a wide range of clients including First Nations, government and forest companies. With SmartWood, Mr. von Schilling has been team leader on assessments in boreal Canada, British Columbia and in Montana U.S.A., he has conducted field testing during FSC standards development of the British Columbia and National Boreal Standards and has completed a number of scoping assessments and annual surveillance audits across Canada serving various SmartWood clients. Mr. von Schilling received training from SmartWood as a Lead Auditor and taught other potential SmartWood auditors at subsequent training sessions. In 2004 he completed an ISO Lead Auditor training course. Ms. Tawney Lem Team Community Relations/Indigenous Specialist Ms. Tawney Lem is an independent consultant with a B.A in political science. She provided policy development and analysis services in the areas of governance and land use. Ms. Lem has been a FSC certification assessor on three other SmartWood teams and two surveillance audits. The current focus of her work includes corporate governance policy training, First Nation s territory land use planning, and consultation protocol and process design. She is a member of the CSA Technical and Executive Committees on Sustainable Forest Management. Previously, Ms. Lem spent six years managing the treaty process for a Vancouver Island First Nation. Her bachelor s degree is from the University of British Columbia, and she has taken the SmartWood Assessor training course. SmartWood engaged Dr. Alton Harestad as an expert to provide Mr. von Schilling with advice regarding ecological issues as they pertain to the Standard. Dr. Harestad is a Registered Professional Biologist in British Columbia and has been engaged in research and management of forest wildlife since the mid-1970s. He was a member of the Scientific Panel for Sustainable Forest Practices in Clayoquot Sound and was a member of scientific advisory committees to Page 4 of 26

5 government on the conservation and management of wolves, spotted owls, and grizzly bears. He has participated as the team ecologist in three FSC certification assessments in coastal forests of British Columbia Report peer reviewers SmartWood considered the requirement for peer review according to the FSC Policy FSC-POL SLIMF Streamlined Certification Procedures: Summary. Since the total combined area of the two members is less than 1000 ha, no peer review was required Assessment schedule (including pre-assessment and stakeholder consultation) Date May 10, 2005 May May 23 May 18-June 8 General Location* (main sites) Main activities SmartWood posts public notice on website On-going distribution of assessment public notice Ecotrust and SmartWood agree to audit plan SmartWood begins contacting stakeholders and First Nations June 8 Shawnigan Lake, B.C. Opening meeting attended by Ecotrust Canada representatives, one group member and SmartWood assessors. Review of WL 1557 management plan and group manager policies and procedures. June 9 Shawnigan Lake, B.C. Field review of WL 1557 and meetings/telephone interviews with stakeholders and First Nations June 10 Courtenay, B.C. Campbell River, B.C. Field review of WL 082 at two locations, management plan review and meetings/telephone interviews with stakeholders and First Nations. June 10 Courtenay, B.C. Closing meeting attended by Ecotrust Canada representatives, one group member and SmartWood assessors June June 30 July 6 July 8 July 25 November 4 November 7 Consultation with stakeholders and First Nations conclude Draft findings report submitted to Ecotrust Canada for review and comment Draft public section of assessment report submitted to Ecotrust Canada for review and comment Ecotrust response to draft assessment report SmartWood completes the assessment report FSC International approves Small Operation Standard for use SmartWood review and update of findings and certification report to conform to approved Small Operations Standard January 25, 2006 SmartWood issues certificate Total number of person-days used for the assessment:19.5 (including 2 days for ecology expert to provide advice to team leader) * Detail on sites visited provided in Appendix. Page 5 of 26

6 2.5. Evaluation strategy This evaluation follows the FSC streamlined evaluation procedures documented in the following FSC document: FSC-POL SLIMF Streamlined Certification Porcedures: Summary; and FSC-POL SLIMF Eligibility Criteria. SmartWood did not conduct a pre-assessment. Ecotrust Canada is familiar with the Standard because the organization participated in the workshop in November 2004 organised to draw up the Small Operation standard indicators. Furthermore, Ecotrust Canada is familiar with FSC certification by supporting the Inlailawatash Holdings Ltd. (Tsleil-Waututh First Nation) to achieve FSC certification for private lands near Vancouver, B.C., Canada. At the time of the assessment Ecotrust Canada had two group members who had recently been put through the Member Intake Process. Ecotrust Canada issued a list of Correction Action Requests (CARs) documenting gaps between the performance of individual members and the Standard. During the field assessment SmartWood considered the following: Conformance of group manager s policies and procedures against FSC requirements; Effectiveness of group manager s member intake audit, including issues of Standard interpretation and CARs written to group members; and Conformance of individual group member s forest management planning and practices against the Standard. Ecotrust Canada has three staff and/or consultants fulfilling group manager responsibilities. Two are professional foresters with auditing experience and an intimate knowledge of FSC standards. Ecotrust Canada is not the forest manager of the forest management operations. Ecotrust Canada ensures that group members comply with the Standard through an audit process. Part of SmartWood s strategy was geared towards assessing the effectiveness of Ecotrust s audit process and interpretation of the Standard. The two forest management operations in the group are Woodlot Licences. This is a form of tenure over public land held by an individual. Most Woodlot Licences are a combination of public land and a private land contribution both of which are managed the same under the same management plan. These licences are usually under 500 ha in size. The woodlots are chosen by government on sites with as few management problems as possible. The field assessment was geared towards reviewing two types of sites. SmartWood reviewed the majority of forest harvest areas on each Woodlot to observe issues regarding roads, harvest strategy and silviculture. SmartWood also reviewed the majority of special values such as fisheries streams, riparian areas, cultural/archaeological/historical sites, wetlands, wood processing and other sites. SmartWood spent 1.5 field days on WL 1557 and one field day on WL 082. Woodlot 082 has been FSC certified for 5 years and SmartWood felt that the field assessment required reduced sampling Stakeholder consultation process The two Ecotrust Canada Vancouver Island Ecoforestry group members are Woodlot Licences, a form of tenure over public land issued by the government of British Columbia. The Ministry of Forests has very rigorous consultation requirements for the Woodlot Licences. The Woodlot Licencees maintain a list of stakeholders (interested parties in FSC terminology) and have to engage in a rigorous stakeholder consultation process in association with revisions to management planning documents. Ecotrust Canada has established a consultation policy VIEG Consultation Guidelines that explain consultation requirements under the Standard. Page 6 of 26

7 SmartWood interviewed as many individuals from the stakeholder list as possible. Interviews were held in person or by telephone. The majority of the individuals or groups on the stakeholder list were contacted. FSC considers First Nations to be different from stakeholders. Woodlot Licencees must also engage in consultations with First Nations. SmartWood interviewed appropriate representatives from the First Nations with traditional territory overlapping with the Woodlots. SmartWood also interviewed government representatives to confirm issues such as compliance with legal requirements and to validate tenure over public land. Page 7 of 26

8 3. ASSESSMENT FINDINGS AND OBSERVATIONS 3.1. Stakeholder comments received The stakeholder consultation activities were organized to give participants the opportunity to provide comments according to general categories of interest based upon the assessment criteria. The table below summarizes the issues identified by the assessment team with a brief discussion of each based upon specific interview and/or public meeting comments. FSC Principle Stakeholder comment SmartWood response P1: FSC Commitment and Legal Compliance P2: Tenure & Use Rights & Responsibilities P3 Indigenous Peoples Rights P4: Community Relations & Workers Rights P5: Benefits from the Forest P6: Environmental Impact P7: Management Plan P8: Monitoring & Assessment P9: Maintenance of High Strong consultation process to ensure rights are identified and managed Guide outfitter not interested in more detailed dialogue CVRD needs dialogue with WL 1557 regarding forest management adjacent to the Trans Canada Trail MoF does not do update checks for new legal tenures Manager of WL 1557 doing a good job meeting the needs of the Cowichan Tribes All contractors interviewed are local Stakeholders are utilizing community education provided by the managers Workers report low to zero accident rate and no unsafe practices WL 1557 does not have a formal safety plan Strong consultation processes appreciated by stakeholders Contractors report adequate training and supervision Wood made available to local processors Stakeholders pleased with access to NTFP and recreational opportunities on WLs Contractors qualified to do their job and are provided additional training when reasonable Contractors not aware of FSC requirements Minor CAR related to consultation with the CVRD Observation related to checking for new legal or customary tenure or use rights on a more regular basis Observations issued related to development of safety plans and carrying insurance Observation issued related to training contractors on relevant sections of the FSC BC Small Operators standard Page 8 of 26

9 Conservation Value Forest P10 - Plantations 3.2. Main strengths and weaknesses Principle Strengths Weaknesses P1: FSC Commitment and Legal Compliance P2: Tenure & Use Rights & Responsibilities Regulatory agencies stated that there have been no significant compliance issues on the woodlots. The forest managers are very familiar with legal requirements pertaining to their management of the Woodlots. Woodlot (WL) 082 has been FSC certified for 5 years. The forest manager has included the commitment to FSC in the management plan. The forest managers of WL 082 and 1557 have demonstrated good knowledge of the types of tenures and use rights that might be relevant to their woodlot, and had recorded/mapped the presence or absence of such tenures and use rights in one or more of their planning documents. In the case of the private portion of the woodlots, both managers have strong consultative processes in place with the local communities which would identify any additional customary or use rights. One of the plans legally required by the Ministry of Forests (called the Management Plan) has expired on WL Government is aware of this situation. The Group Manager has written a Precondition to the forest manager of WL 1557 requiring a written acknowledgement from government that the WL Management Plan is out of date and that the forest manager is OK to submit a new one in The forest manager of WL 1557 must make a public commitment to FSC principles and criteria through the next management plan update in The Group Manager has written a Minor CAR. The Group Manager has issued a Minor CAR requiring the forest manager of WL 082 to include a full legal description of the new portion of the Woodlot in his next management plan. The Trans Canada Trail was designated after the last management plan for WL 1557 was written. The forest manager is already engaged in the consultation required and SmartWood has written an observation requiring the group manager to track this consultation process. P3 Indigenous Peoples Rights Neither WL manager has any past or outstanding disputes with legal or customary tenure or use rights holders. Ecotrust Canada has developed a policy on grievances and dispute resolution that is included in the Ecotrust Member Handbook. The forest managers of WL 082 and 1557 have excellent track records of conducting consultation with First Nations. The manager of WL 082 has acknowledged the claims of all First Nations in the area. One lead First Nation has been acknowledged by other First Nations and the manager of WL 082 has drafted a proactive protocol. This process is on-going and all parties acknowledge it as positive. Due to an oversight the forest manager of WL 1557 has not consulted with one First Nation relating to a portion of the woodlot where the forest manager has not proposed any forest management activities to date. The Group Manager wrote a CAR requiring the forest manager to address this shortcoming. Page 9 of 26

10 P4: Community Relations & Workers Rights P5: Benefits from the Forest The manager of WL 1557 has acknowledged the claims of First Nations in the area. All of the First Nations are satisfied with the positive relationship with the forest manager. The manager of WL 1557 has done a good job of working with a First Nation to ensure forest management does not affect a particular value identified by the First Nation. The forest managers of WL 082 and 1557 have excellent track records of conducting consultation with directly affected persons and stakeholders. Both managers have an objective of hiring local people or contractors. Members of the public use the Woodlots for a variety of different kinds of recreation. The forest managers welcome these recreation uses and work with these people to ensure that forest management complements the recreation use of the Woodlots. The group management demonstrates the importance of local employment opportunities by gathering information on this topic as part of the group member application form. Both WL managers are making strong efforts to provide opportunities for employment training and other services as a regular part of their management strategy. The group management demonstrates the importance of worker health and safety by including the issues of health and safety records and low accident frequency rates as part of the initial screening process. As a result of the safety practices of both managers, there is a consistently low accident frequency rate. There are no past or outstanding disputes between local persons and either WL manager or the group management. Both WL managers are very conscientious of environmental, social and operational costs, and have demonstrated that significant investments have been made to maintain the ecological productivity of the forest. The Ecotrust Canada member application form highlights the importance of costs and investments by enquiring about management Due to time constraints and the potential to overload/confuse stakeholders with interviews, the Group Manager did not conduct their own interviews with First Nations, stakeholders and directly affected persons. The Group Manager did interview staff and government agency representatives. See Minor CAR issued by SmartWood. The forest manager of WL 1557 left some harvested logs piled along the roads of a harvest block for too long and was not able to utilize them. The Group Manager wrote a Minor CAR for this matter. The Group Manager identified a few gaps in the calculation of the rate of harvest. The Group Manager issued a Minor CAR requiring the forest manager to address quantitative factors such as Page 10 of 26

11 activities such as silviculture, conservation and recreation activities, and other forest users. Although the WL managers do not have business plans to guide their operations the managers are knowledgeable and diligent about calculating the costs of each harvest. Since this is their primary family income and both are profitable, SmartWood considers this sufficient to meet the Standard. The group manager demonstrates the importance of marketing, local processing and product diversity by collecting information about each of these areas as part of the member application process. The group management is very aware of the market access challenges that small operators have and recognizes that facilitating access to a certified marketplace can provide benefit to group members. Both managers of WL 082 and 1557 are very active in marketing, local processing and optimizing the use of the wood. full cycle trees, special sites and any other significant reductions or netdowns. The rate of cut for WL 1557 was originally calculated by the Ministry of Forests. Since then the boundaries of the Woodlot have changed significantly. All parties agree that the forest manager of WL 1557 must update the rate of cut calculation. The forest manager of WL 1557 has already undertaken a very ambitious timber inventory. P6: Environmental Impact The forest managers have an excellent track record of harvesting without damaging residual trees, or breaking logs during harvesting. Through consultation, the local communities have expressed an interest in the gathering of non-timber forest products from the WLs. Both managers have made their WLs freely accessible to the public for the collection of materials such as mushrooms and salal. The Group Manager and the forest managers were able to describe and provide a rationale for the management approach regarding natural disturbance processes and the stand and landscape level characteristics that result from those processes including the range of natural variability. The standard has a significant innovation in the form of a Toolkit. The Toolkit is a process designed to help the forest managers of small operations identify those forest values that require particular attention under Principle 6. The forest manager and Group Manager did an excellent job with this process, demonstrating that this innovation is a positive development in the Small Operation Standard. While SmartWood SmartWood noted some deficiencies in the Group Manager s treatment of the Toolkit and member intake audit (identification of values to be managed) for WL 082 and WL SmartWood identified a challenge interpreting the Standard regarding requirements to manage compatible with the range of natural variability. Please see the discussion under section 3.6. The Group Manager and the forest managers were able to describe and provide a rationale for the management approach regarding natural disturbance processes and the stand and landscape level characteristics that result from those processes (including range of natural variability ). However, in the case of WL 1557 the Group Manager and SmartWood issued Minor CARs Page 11 of 26

12 P7: Management Plan considers the Group Manager s work to be a strength, a few gaps were noted that constitute a weakness and some Minor CARs have been issued. The forest managers of WL O82 and 1557 have excellent and very thoughtful forest management approaches that conserve forest resources and consider environmental impact. WL 082 is managed for continuous forest cover and restoration towards a late seral forest. Portions of WL 1557 are managed as even aged forests and others are uneven aged forests. The managers have implemented policies such as: Retaining full cycle trees (WL 082) Identifying protected reserves and stand level retention (WL 1557) Managing for tree species at natural proportions. Retaining cedar and minor species such as arbutus and pacific yew Managing for continuous forest cover and late seral conditions (WL 082) Forest restoration. The manager of WL 082 has conducted an inventory of coarse woody debris and manages to retain specific coarse woody debris levels. The Group Manager supports members on matters where FSC requirements exceed the Ministry of Forests forest management planning and practices requirements. A riparian assessment was conducted for WL 082. SmartWood conducted a review of the assessment and determined that it was conducted by a qualified expert and that the assessment met the Standard. SmartWood has required the Group Manager to have the riparian assessment independently peer reviewed. SmartWood notes that woodlot licensees with tenure rights over public land (such as WL 082 and 1557) are required to write higher level plans by the Ministry of Forests. The Group Manager did a good job reviewing the management plans (all documents involved in management, not just the document title management plan ) of its potential group members during the Member Intake Audit. requiring a strategy for addressing stand level forest attributes compatible with the range of natural variability. The forest managers have conducted some wildlife and/or plant assessments with regard to red, blue listed, threatened, engangered or species of concern. However, gaps have been identified and SmartWood and the Group Manager have issued Minor CARs. SmartWood noted that neither woodlots have processes in place to measure detrimental soil disturbance. A Minor CAR has been written to address this gap. SmartWood identified a challenge to interpret the standard with regard to protected reserves on WL Please see the discussion under section 3.6. SmartWood issued a Minor CAR requiring the forest manager to identify protected reserves and riparian management areas and provide a written rationale supporting the manager s approach to protected reserves. The Group Manager and SmartWood have not been able to address the issue of pesticide use on seedling at the time of the audit. The forest manager of WL 1557 is seeking additional information regarding the use of pesticides on seedlings planted in the past. SmartWood notes that it is most important for the forest manager to purchase appropriate seedlots as defined by the Ministry of Forests. A secondary consideration is whether or not pesticides were used on the seedlings. The Group Manager has stated that members will try to source pesticide free seedlings. SmartWood has issued a Minor CAR to the Group Manager to develop a pesticide policy. The forest management planning documents for WL 1557 are out of date and are currently being updated by the forest manager. SmartWood has written an observation requiring the Group Manager to monitor the rewriting of the management plan for WL 1557 to ensure that it meets the Standard. SmartWood notes that a number of the Minor CARs issued by the Group Manager and SmartWood will also Page 12 of 26

13 The forest manager of WL 082 recently revised the required planning documents. Because the Woodlot has been FSC certified for a number of years the management planning documents are compatible with the FSC planning requirements. result in revisions to the management plan. P8: Monitoring & Assessment SmartWood found that the MPs for WLs 082 and 1557 provided and described natural processes, environmental hazards, HCVF, land use of adjacent lands and descriptions/inventories/maps used for management. SmartWood also accepts the documented Toolkit descriptions themselves as a mechanism to satisfy the indicators. The forest managers of WL 082 and 1557 have excellent stand level planning documents. Both WL managers have been diligent in selecting well qualified workers who have strong experience in the type of work required to implement the management plan. In many cases the work done for the WL managers is only a small portion of the work that the contractors do, so workers are often receiving job specific training (e.g. falling, wild life tree identification, fire suppression) from other sources. Contractor interviews reveal that there is no expectation for the managers to be providing major training. WL 082 has an excellent growth and yield and forest condition monitoring approach. SmartWood is satisfied that the forest managers track timber yield from the Woodlots. SmartWood is satisfied that the forest managers collect rigorous data regarding tree growth rates through the forest inventory work (PSPs on WL 082 and inventory cruise on WL 1557). Data regarding regeneration, condition of the forest, forest health and regeneration is collected on WL 082. SmartWood is satisfied with data collection on WL 1557 regarding forest health, condition of the forest and growth rates. SmartWood notes that the Group Manager has established some guidance documents for members regarding chain of custody. The Vancouver Island Ecoforestry Group SmartWood considers indicator to be specific and unambiguous in requiring a documented monitoring plan. SmartWood expects every group member to have a written monitoring plan in place. In most cases SmartWood considers that informal or qualitative monitoring is sufficient to meet the Standard since operations are limited in extent and intensity and there are generally few significant values or management challenges. Where monitoring is informal or qualitative the forest manager must still describe the monitoring strategy in a documented statement. Formal or quantitative monitoring must also be documented. Indicator describes the minimum requirements for monitoring. WL 082 has documented the G&Y monitoring but has not documented the informal monitoring effort. WL 1557 does not have a documented monitoring plan in place. SmartWood has written a Minor CAR to address this situation. Page 13 of 26

14 P9: Maintenance of High Conservation Value Forest P10 - Plantations Chain of custody Group Certification Requirements Member Handbook (Version April 2005). The policy explains what chain of custody is and provides information regarding the documented control system, storage, sales and shipping, personnel training, records and examples of applying CoC requirements. The Group Manager has provides some documents or templates to assist members meet the Standard including a Outsourcing Agreement Template and a Bill of Lading Template. The forest manager of WL 082 has an acceptable chain of custody process. The Group Manager did a good job addressing the indicators in the Member Intake Audit. The approach of the Standard to HCVF is innovative. As with Principle 6 the Small Operation Standard offers a Toolkit to identify HCVF attributes that must be addressed by Principle 9. The Group Manager and the forest manager completed the Toolkit Table 3. Some of the HCVF values identified on WL 082 include northern goshawk, red-legged frog and fireinterface values. On WL 1557 some of the HCVF values identified include possible bear and cougar, adjacent ungulate winter range, red/blue list plant communities, wetland mosaic, declining cedar, fire interface. No plantations. The certificate allows for group members to process wood themselves or in some cases through outsourcing agreements with third parties as long as the forest manager retains ownership of the wood. The Group Manager has established policy in the Vancouver Island Ecoforestry Group Member Handbook regarding Chain of Custody. The policy requires the individual group member to prepare a Documented Control Procedure. The Group Manager has a strong set of policies and procedures meeting the content requirements of FSC. The 'Vancouver Island Ecoforestry Group Member Handbook and Business Plan are very thorough and well written. A number of Minor CARs were issued by SmartWood or the Group Manager under other indicators that may require monitoring. SmartWood has concerns regarding WL 1557 and with stocking on one opening and stocking and reforestation responsibility on another opening. SmartWood has issued a Minor CAR to address these issues. The Group Manager issued a CAR under indicator to the manager of WL 1557 requiring a management strategy with rationale for the identified First Nations cultural values Since the group members have not written documented control procedures SmartWood has written a CAR requiring a documented control system that addresses issues such as the separation and identification of FSC wood, outsourcing, logo use, records etc. Ecotrust Canada as the Group Manager is not also the forest manager. Ecotrust Canada relies on the Member Intake Audit and Annual Surveillance Audit of each operation to ensure that the individual group members are meeting the Standard. SmartWood has issued an observation urging the Group Manager to ensure that the personnel conducting the audits have appropriate training, skills and experience. Page 14 of 26

15 3.3. Identified non-compliances and corrective actions A non-compliance is a discrepancy or gap identified during the assessment between some aspect of the FMO s management system and one or more of the requirements of the forest stewardship standard. Depending on the severity of the non-compliance the assessment team differentiates between major and minor non compliances. Major non-compliance results where there is a fundamental failure to achieve the objective of the relevant FSC criterion. A number of minor non-compliances against one requirement may be considered to have a cumulative effect, and therefore be considered a major noncompliance. Minor non-compliance is a temporary, unusual or non-systematic noncompliance, for which the effects are limited. Major non compliances must be corrected before the certificate can be issued. While minor non-compliances do not prohibit issuing the certificate, they must be addressed within the given timeframe to maintain the certificate. Each non-compliance is addressed by the audit team by issuing a corrective action request (CAR) CARs are requirements that candidate operations must agree to, and which must be addressed, within the given timeframe of a maximum of one year period. CAR #: 1/05 Reference Standard #: Non-compliance: The Group Manager has not considered whether or not the management Major Minor rationale results in minimal environmental impacts. Corrective Action Request: Ecotrust Canada shall ensure that the forest manager of WL 1557 has put in place a strategy for addressing stand level forest attributes compatible with RONV and applicable to the woodlot as a whole. Some of the stand level forest attributes to be considered include canopy complexity, live wildlife trees, snags and coarse woody debris. The strategy must consider tree species diversity in regenerating stands, canopy complexity, live wildlife trees, snags and coarse wood debris, and describe actions taken to address: environmental impact, restoration, landscape considerations, management objectives, maps, descriptions, HCVF, inclusion in the management plan and monitoring. Timeline for Compliance: By the end of Year 1 CAR #: 2/05 Reference Standard #: Non-compliance: Major Minor SmartWood notes inconsistency between similar CARs written by the group manager for WL 082 and WL The WL 1557 CAR addresses management strategy and monitoring while the CAR for WL 082 addresses only the assessment. The CAR for WL 082 refers to red/blue, threatened, endangered, species of concern flora/fauna while the CAR for WL 1557 refers only to red and blue listed plant and animal species. Corrective Action Request: Ecotrust Canada shall ensure that the forest managers of WL 082 and 1557 have conducted assessments of red and blue listed, threatened and endangered species, species at risk and/or plant communities, and as appropriate, map the results and establish a management strategy and a monitoring plan. Timeline for Compliance: By the end of Year 1 CAR #: 3/05 Reference Standard #: Non-compliance: Major Minor With regard to WL 082 the forest manager has less than 1% of the woodlot designated as reserve. For WL 1557, the forest manager is not sure of the amount of reserve currently on the woodlot. Corrective Action Request: Ecotrust Canada shall ensure that the forest managers for WL 082 and 1557 establish, document and map protected reserves and riparian management areas, and provide management objectives consistent with restoration or no harvesting and a description of the management strategy. This shall be documented in the management plan. If the area in protected reserves on WL 082 does not meet the 8% requirements the Group Manager must ensure that the forest manager provides a written rationale as to why the forest management strategy for managing toward late seral forest effectively meets the characteristics of a reserve. Page 15 of 26

16 Timeline for Compliance: By the end of Year 1 CAR #: 4/05 Reference Standard #: Non-compliance: To ensure the independence of his riparian assessment, the Group Manager Major Minor must have the assessment peer reviewed by a third party as a Minor CAR. Corrective Action Request: Ecotrust Canada shall have the riparian assessment completed for WL 082, independently peer reviewed and the results used to improve management. Timeline for Compliance: By the end of Year 1 CAR #: 5/05 Reference Standard #: Non-compliance: Major Minor The Group Manager was unable to assess this indicator at the time of the Member Intake Audit and has requested additional information from the forest managers. Group manager does not have a pesticide policy. Corrective Action Request: The Group Manager shall formulate and distribute to group members a policy requiring members to source tree seedlings from proper seedlots and, where possible, free of pesticides. Group members should document their efforts to purchase pesticide-free seedlings. If seedlings treated with pesticides are used, the type of pesticide treatments shall be documented and forest workers involved in tree planting notified that seedlings were treated with pesticides. Timeline for Compliance: By the end of Year 1 CAR #: 6/05 Reference Standard #: Non-compliance: Group manager does not have a monitoring plan. Major Minor Corrective Action Request: Ecotrust Canada shall ensure that the forest managers of WL 082 and 1557 prepare monitoring plans. The monitoring plans must meet content requirements of BC Small Operations Standard indicator Timeline for Compliance: By the end of Year 1 CAR #: 7/05 Reference Standard #: Non-compliance: Major Minor Data concerning growth rates, regeneration, forest health, productivity, condition of the forest, and disturbances resulting from forest operations is incomplete or out of date. Corrective Action Request: Ecotrust Canada must ensure that the forest manager of WL 1557 conducts regeneration surveys on opening 7C and communicate with the Ministry of Forests to ensure that regeneration surveys are conducted on the previously harvested area adjacent to the processing mill. Timeline for Compliance: By the end of Year 1 CAR #: 8/05 Reference Standard #: CoC 1 Non-compliance: Group members do not have written documented COC control procedures. Major Minor Corrective Action Request: Ecotrust Canada shall require every member to have a completed documented control procedure available prior to acceptance into the group. The documented control procedure must be tailored to the forest management operation and must address the separation and identification of FSC wood, outsourcing, shipping and sales documents, records, logo use and compilation of information for annual audits Timeline for Compliance: By the end of Year Follow-up actions by client to meet certification Ecotrust Canada must meet the requirements of Minor CARs within time frames specified Observations Observations are voluntary actions suggested by the assessment team, but are not mandated or required. Page 16 of 26

17 Observation Ecotrust Canada should develop policy or guidance to ensure that group members check for new legal or customary tenure or use rights on a more regular basis. Prior to any harvesting or development (e.g. recreational) taking place adjacent to the Trans Canada Trail, the Group Manager should ensure that the forest manager of WL 1557 develops a plan with the Cowichan Valley Regional District to ensure the interests of the CVRD are addressed. As appropriate the forest manager should prepare maps, management objectives, consider environmental impact, prepare a management strategy or rationale, include the Trail in the management plan and include the Trail in the monitoring plan Ecotrust Canada should clarify the Ecotrust Member Handbook policy regarding whether or not the Appeals Committee is to be used for any dispute, or only those with the group management. Consider providing additional guidance for: o Other non-binding processes (e.g. independent facilitator); and o Developing culturally appropriate processes. Ecotrust Canada should develop a procedure to ensure group members have identified all affected First Nations Ensure recreation management strategies for WL 1557 including drawing recreational activity away from the features identified as having cultural significance. Ecotrust Canada should consider providing guidance to group members on the development of safety and fire response plans. Ecotrust Canada should consider proving guidance to group members about acceptable levels of insurance for the managers, employees and contractors Ecotrust Canada should ensure that group members update stakeholder lists on an regular basis (to be stipulated by Ecotrust Canada). Ecotrust Canada should consider providing examples of best practices in the Consultation Guidelines for group members who have not had extensive contact with First Nations or stakeholders. The guidance for consulting with First Nations could include guidance to ensure that consultation takes place with the duly recognized / authorized authority within the First Nation. Ecotrust Canada should implement existing procedures to ensure that interviews with directly affected persons, stakeholders and First Nations occur during the member intake audit and surveillance audit procedures. Failure to implement the consultation approach in the future could result in either a major or minor CAR The Ecotrust Canada Group management Consultation Guidelines should require members to make management plans available for review by interested parties, stakeholders and First Nations. This is a legal requirement in BC. Concurrent with the next management plan revision Ecotrust Canada should ensure that the forest manager of Woodlot 1557 determines a rate of harvest that meets the requirements of the Standard under criterion 5.6. Toolkit Tables are the key to successfully meeting P6 and P9 and should be filled out rigorously. There were some deficiencies noted that do not warrant a CAR but that should be addressed by the Group Manager for WL 082 and WL 1557 and all future Toolkit assessments as follows: WL 082 o Table 1 Topic 8 and indicator cursory description of adjacent lands WL 1557 Standard Reference A B A B C o Table 1 Topic 5 Koksilah River not explicitly discussed o Table 1 Topic 6 and 7 local studies from adjacent Brascan lands not considered o Table 1 Topic 8 and indicator cursory description of adjacent lands When issuing a CAR to a group member requiring an inventory or Page 17 of 26

18 assessment, Ecotrust Canada should specify the minimum requirements regarding the qualifications of the specialist and any other special actions such as peer review etc. The Member Intake Audit checklist should be modified as follows: Indicator (6.1.4, 6.3.6, 6.3.8) Break out stand level biodiversity attributes and explicitly consider RONV, the management rationale and potential ecological impact on a line by line basis; and Indicator Create a row in the table for unique ecosystem features and special sites generally Ecotrust Canada should complete the Member Intake Audit for WL 082 and 1557 and at a minimum address: Management responsibility over other forests from the forest manager of WL 082; Additional information regarding renewal of WL 082; Example of logging contract from WL , Seedling pesticide information not provided by WL 1557; Management rationale and environmental impact not addressed for both WL 082 and 1557; Timber harvest data for WL 1557; and Monitoring issues on WL 082 and As the group grows in size it will become more important for Ecotrust Canada to compile stand level RONV data, set thresholds and make determinations whether or not certain management strategies meet RONV. This should be feasible since most VIEG operations will be in the CWH xm subzone and management strategies will be similar from one operation to the next. Ecotrust Canada should put in place a system for determining detrimental soil disturbance of individual forest management operations. If the level of soil disturbance exceeds 7%, Ecotrust Canada should ensure that the forest manager supplies a rationale and/or implements a rehabilitation plan. On all future Member Intake Audits Ecotrust Canada should monitor the forest managers approach to temporary access structures and unplanned soil disturbance and rehabilitation if required Observation 7.1.3: Ecotrust Canada should monitor the WL 1557 forest manager s revision of the management plan to ensure that it meets with the standard. The Group Manager should develop guidance material for group members for the preparation and implementation of measurable objectives and management indicators. Ecotrust Canada should ensure that the forest manager of WL 1557 maps the Trans Canada Trail in the upcoming management plan revision. Ecotrust Canada should ensure that the forest manager of WL 1557 includes a description of environmental hazards on the WL (as per Toolkit). Ecotrust Canada should consider requiring members to maintain a ledger for new plans, inventories, assessments or maps to be prepared by the member in preparation for the annual audit. Ecotrust Canada should consider providing training to contractors so they are aware of any sections of the FSC BC Small Operators standard that may be relevant their job. Ecotrust Canada should provide guidance to Group members regarding the requirements under the Standard regarding monitoring and guidance for establishing an effective monitoring regime for a small operation. Ecotrust Canada should work with the forest manager of WL 1557 to review the strategy for monitoring growth rates, productivity and condition of the forest and determine whether or not the 2005 inventory can become the basis of a PSP system. Ecotrust Canada should include reference to HCVF and conservation attributes in the VIEG Consultation Guidelines. Observation CoC: Ecotrust Canada should amend the logo use policy to specifying that the Group Manager must forward all logo use proposals to SmartWood for approval A B C A B CoC Page 18 of 26

19 Ecotrust Canada should ensure that the person or team conducting the Member Intake Audit and annual monitoring audits is properly qualified. At a minimum they must have the following qualifications, training and experience: Education and/or training with a significant knowledge of forest management legislation and practices common to woodlots and the forest industry particularly on Vancouver Island. Experience with FSC Standards, preferably with the BC Small Operations Standard. Experience as an auditor. The Group Manager should use current terminology accepted by FSC. Conditions should be referred to as Minor CARs and recommendations should be referred to as observations Group Requirements Group Requirements 3.6. Certification Recommendation SmartWood had a particular challenge interpreting the Standard with regard to the concept of range of natural variability and the requirement to establish protected reserves. Interpretation Issue RONV The Small Operations Standards writers included the concept of range of natural variability (RONV) as a fundamental management concept to small operations. RONV is referenced in the Standard under Principle 6 under indicators 6.1.2, 6.1.4, 6.1.5, 6.3.2, 6.3.6, For example, indicator requires the forest manager to ensure that regeneration methods result in stand and landscape patterns compatible with RONV. SmartWood s expectation for managing stand and landscape characteristics compatible with RONV on a large industrial operation requires literature review or assessments to define RONV and then set targets and monitor to ensure that the targets have been met. SmartWood considers that while it is possible for a small operation to engage in this process, particularly at the stand level, SmartWood considers that this process is beyond the ability and resources of an average small operations manager. SmartWood reviewed FSC Approved Policy GUI , pertaining to the interpretation of Standards in Canada for small operations, and determined that FSC Canada intends for an average forest manager to be able to implement FSC Standards in Canada. SmartWood considers that the average forest manager can use a coarse filter or general approach to managing forest attributes compatible with RONV. The forest manager must be able to provide a rationale explaining how the management strategy generally supports the management of forest attributes within the range of natural variability. Interpretation Issue Protected Reserves SmartWood reviewed FSC policy pertaining to the issue of reserves and small operations. FSC Canada-GUI states that Small and Low Intensity Managed Forests (SLIMFs) cannot realistically protect representative samples of forest ecosystems. The policy is definitive about SLIMFs not requiring protected areas and reserves and suggests that these might significantly and negatively affect the operation economically. SmartWood notes that the Standard is inconsistent with the policy. However the Standard has greater authority and is definitive about the need for protected reserves. However, the apparent discrepancy between the standard and FSC policy suggests to SmartWood that some flexibility can be applied to interpreting the Standard regarding protected reserves. The forest manager determined that 8% protected reserves are required in the ecological zone in which Woodlot Licences 082 and 1557 occur. The forest manager of WL 082 noted that allocating protected reserves on the WL is problematic. The forest management strategy on WL 082 is oriented toward maintaining continuous forest cover on the Woodlot and maintaining 10% full cycle trees. The forest manager notes that the forest management approach is to restore the forest that has been heavily impacted by past harvesting toward late seral conditions. Essentially, the forest management strategy for the whole property to manage towards late seral conditions serves the same biodiversity enhancement objectives as a protected reserve. The forest manager states that he has already foregone economic opportunities through his forest management approach and that allocating protected reserves would impact his operation economically. Page 19 of 26