Tolko Industries Ltd. Sustainable Forest Management System

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1 Tolko Industries Ltd. Sustainable Forest Management System Okanagan Regional Woodlands (Lumby, BC) Overview of the Okanagan Regional Woodlands The Defined Forest Area for Tolko s Okanagan Regional Woodlands is part of the Tolko/Gorman Bros./BCTS/ Westbank First Nations Okanagan Operations SFMP DFA. It includes Tolko s traditional operating areas in the Okanagan, Boundary and Arrow TSAs including TFL 49 and several types of Crown forest licenses. FL A18632 is managed by Tolko on behalf of the licensee, Selkirk Timber Company. A portion of Bell Pole Company Ltd s FL A18666, which is also managed by Tolko, is included in the DFA. The Okanagan Woodlands Operation consists of road construction and maintenance, harvesting, hauling logs, administrative offices and silviculture activities. At the time of the audit the total area of the DFA was 803,017 ha, with a harvest of 2,150,000 M 3. The DFA has forests with a mix of age classes and species types. The distribution of age classes is weighed slightly towards trees 140 to 250 years of age (25 percent of all forests). Coniferous tree species comprise 96 percent of the forest types. The DFA is located in the Okanagan region of British Columbia, with the major population centers being Kelowna and Vernon. Background During the period of June 27-29, 2011, Tolko Industries Ltd, Okanagan Regional Woodlands, Lumby, BC underwent a re-assessment audit to the CAN/CSA Z809:2008 Standard. The registration cycle is over 3 years with surveillance audits conducted annually. This report summarizes the audit process and results of the QMI-SAI Global reaudit. Scope of Certification The Sustainable Forest Management System as it applies to the forest management activities on the defined forest area (TFL 49, FL A18632, FL A18667, FL A18672, FL A20191, FL A74912, FL A18666, FL A78062, FL A76247, FL A80260, FL A80627, FL A18969, FLTC A81250 and TO816). These activities include planning, harvest and hauling of logs, road construction, deactivation and maintenance and silviculture activities.

2 #R Rev.01 2 Audit Summary The CAN/CSA Z809:2008 third-party re-assessment audit was undertaken by QMI-SAI Global. QMI-SAI Global is an independent third party registrar that is accredited by the Standards Council of Canada (SCC) for registrations to the CAN/CSA Z809:2008 standard. This ensures the integrity and credibility of the audit process. The audit assessed operations through interviews with 11 Tolko staff and 8 contractor personnel on 7 active sites. An additional 9 completed sites were assessed for conformance to SFM targets. The audit also assessed the SFM and supporting EMS documentation and records at the Tolko Lumby office. There were no non-conformances from the last audit to verify implementation of action plans. For this re-assessment audit, the on-going effectiveness of the SFM system to deliver the intended outputs was assessed against all elements of the CAN/Z809:2008 Standard. Based on the results of the audit, it was identified that Tolko Industries Ltd, Okanagan SFM, has continued to commit the time, resources, and effort necessary to establish, implement, maintain and continually improve an effective SFM system. Two public advisory group members, one provincial Compliance and Enforcement officer and one First Nation representative were interviewed for the audit. No non-conformances or areas of concern were identified during the audit; however 7 opportunities for improvement were noted as detailed in this report. CAN/CSA Z809:2008 Re-Assessment Audit Non-conformance (NCR) 0 Areas of Concern (AOC) 0 Recommendations(OFI) 7 Positive Aspects 9 Non-conformances Non-conformance (NCR): A systemic failure of the program Participant s EMS/SFM system to meet an EMS/SFM objective, performance measure or indicator. All non-conformances require an action plan within 30 days. Non-conformance must be addressed by the operation or registration cannot be achieved / maintained. Area of Concern (AOC): An isolated lapse in EMS/SFM system implementation which does not indicate a systemic failure to consistently meet an EMS/SFM objective, performance measure or indicator. Opportunity for Improvement (OFI): Are isolated observations that are non-critical to the achievement / maintenance of EMS/SFM objectives. Positive Aspects Are features of the EMS/SFM system that are considered as enhancements to the expected level of EMS/SFM performance. Mechanical Site Preparation is used were required to assist in reforestation success. Note the extra water tank (in red on the roof) for use in the case of fire. This is the cluster mounding noted as a good practice.

3 #R Rev.01 3 The auditors The QMI audit team who performed the audit consisted of Will Sloan, RFT, EMS(LA), SFM(LA) and Dave Barker, RPF, SFM(LA). The auditors are Forest Professionals and certified lead auditors. Areas of Non-conformance No areas of non-conformance were identified during the audit. Areas of Concern No areas of concern were identified during the audit. Opportunities for Improvement 5.2 Interested Parties: Consider reviewing the information in the PAG Membership List to ensure it meets the SFM requirements. The Tolko Internal Audit of June 9, 2011 identified weaknesses in the list but there may be additional ones not yet dealt with. 5.2 Interested Parties: Consider a more proactive process for inviting First Nations to participate in the SFM and the external audit. Due to capacity within bands, the ability to respond in a timely manner may be better served with more direct contact other than mail or . This is shown by the response to the invitation for participation in the audit by the Neskonlith Band. Their response was sent to Tolko on the last day of the audit, but due to the postal disruption, was not received until July 12. The Band noted they get hundreds of s per day and following up on all of them is a challenge. Challenging terrain calls for specialized solutions. Here a 48 cable yarder using chokers is used to harvest on a steep slope. This type of equipment is more common on the coast of BC rather than the interior. This setting is using an old existing road system, eliminating the need to build new roads. The harvest contractor was involved with the design of the cutblock. Note the blue safety warning on the cables at the rear of the machine. This is to remind truck drivers of the hazard that exists in hitting the cables. 6.3 SFM criteria, elements, and core indicators: The organization may wish to consider re-analysing targets that may not make practical sense. Examples include stub requirements currently being reported by number of blocks rather than by area (target 6). A second example is ECA calculations (target 20).

4 7.4.7 Emergency Preparedness and Response: the audit found that some ERP testing had been done, but there is no documented testing for the Slide and Slump ERP, nor has there been any documented testing of silviculture operations. Consider conducting ERP tests on a broader range of operations and testing all ERP s on a regular basis Monitoring and Measurement: the audit found 4 of 5 hand tank pumps for fire prevention did not work when tested during the field audit and one contractor had not tested a new pump to see if would actually pump water. Consider including in the fire equipment inspection process verification that fire tools actually function as intended Internal Audits: The Standard requires that internal audits be planned and scheduled to ensure conformance to the Standard. Although there is a schedule to ensure that all the VOITS are audited over a three cycle, it is unclear how the entire Standard will be audited. Consider developing a schedule of internal audits that will ensure that the internal audits cover all CSA requirements over a three period. 7.6 Management Review: Consider including a statement by Top Management that indicates that the SFM continues to be suitable, adequate, and effective. Although it is implied in the Management Review meeting minutes, it is not specifically stated as such. Positive Aspects The audit found that Tolko is using the Process Improvement procedure to deal with VOIT s that are not met. This is a good use of an existing process for dealing with these non-conformances. Tolko is requesting input from harvesting contractors during the layout stage of blocks. This is notable as with tough conditions such as cable harvesting blocks potential issues can be dealt with at the layout stage. Site Plans include a section on what should be discussed at the pre-works. This includes information that is not required to be in the SP such as retaining the active placer access through CP 452, Blk LL9007. All contractors interviewed noted good communications with Tolko, and good organization and good information provided. Stubbing practices around wet areas and riparian zones was noted as being very good. #R Rev.01 This is an example of the riparian stubbing good practice noted during the audit. Both a wet area in the foreground and a small stream are protected by the stubbing practices. 4

5 The requirement for cluster mounding on CP 433, Blk 1 was well documented and implemented. This was noted as a good practice for mimicking the natural occurrence of trees on mounds, in clumps. This should help reforestation success in this high elevation, high snow loading area as well as providing good habitat for grizzly bear foraging. Using pavement grinder carbide tips on the grader blade to break down rocky sections of the road. Use of emerging technology such as: 1. GPS with SP information on feller bunchers and 2. Effective use of road tracking automated queries (recently re-designed software) in Phoenix. Excellent bridge installation at km 23 on the Aberdeen Road; especially the realignment of approaches and increased elevation of the bridge. This picture illustrates the practice of post harvest road rehabilitation. This short spur was completely put to bed and is ready for reforestation. QM-SAI Global forestry specialist group registers/certifies forest companies to ISO 14001, OHSAS 18001, CSA Z809 SFM, FSC FM & CoC, SFIS, SFI CoC and PEFC. The group, led by Sylvain Frappier F.Eng., Product Manager, Forestry Sector, consists of a highly qualified team of professional foresters, technical and industry experts. Contact marketingservices@qmi.com for more information. This report may only be reproduced by the intended client, with the express consent of Company Contact: QMI-SAI Global. Information in this issue is of a general nature with respect to audit Rob Kennett, RPF, Regional Forester Planning and Silviculture findings and is not intended to be acted upon without appropriate professional advice. Tolko Industries Ltd. Okanagan Regional Woodlands Phone or Robert.Kennett@tolko.com #R Rev.01 5