CW NRA DEVELOPMENT AND NETWORK ENGAGEMENT STRUCTURE

Transcription

1 Slide 1 CW NRA DEVELOPMENT AND NETWORK ENGAGEMENT STRUCTURE Webinar for FSC Network Partners 12 May 2015

2 Slide 2 Risk Assessments Company risk assessment and National Risk Assessment: Key component for the implementation of CW-CoC standard Determines the risk of sourcing unacceptable material from sourcing areas LOW? (UN)SPECIFIED? NRA: a designation of the risk of sourcing from unacceptable sources 2

3 Slide 3 Where are we now? Buy FSC CW from supplier certified according to FSC- STD Verify if material is controlled on one's own Buy FSC CW from supplier certified under FSC-STD Already controlled Check National Risk Assessment OR develop Risk Assessment* If low risk If unspecified risk Material is controlled Field audit of the forest where material is sourced from requirements met * Only until requirements 31 December 2015 not met Already controlled (Requirements consistent with FSC-STD ) Material is controlled Material CANNOT be used Steps for verification of material according to the current requirements of the standard FSC-STD Company Evaluation of Controlled Wood (V 2-1) by Certificate Holder This sourcing model will change with the new standard! (2015)

4 Slide 4 National Risk Assessments Assessing risk of sourcing unacceptable material (for all CW categories) in different areas of a region or country. Chamber-balanced development process (expert working groups) Review and approval by FSC International Revised procedure from 2015 onwards (approved November 2014) NRAs available on Global Forest Registry 4 Question: I have one question about the scope for NRA, it is possible expand the area the scope after starting the process. Answer: We have not had this before. I would have to go through the procedure to make sure I have considered all the requirements but it would involve amendment to the proposal and approaching it directly, explaining the reasons of the extension, explaining how it would affect timelines, and budget for the process but I cannot say the reasons why subject to the issues one would reject the proposal. In principle I would say at the moment yes, but I would also go directly to the procedure after the webinar and make sure we have considered all the requirements. Question: One of your slides suggests that field verification of source forests is a basic expectation where there is risk; can you confirm or expound on this? Answer: This slide illustrates the current sourcing model that is available for current version of the standard. This model is being revised so in the current CW system when we have unspecified risk designation at any rate or case the organization must perform filed verification and CB must also perform sampling and verification in order to confirm how the company has applied/implemented the standard. But this will change. In the revised sourcing model we see that instead of field verification at any rate there is opportunity to develop or implement specific control measures. We are trying to

5 communicate and stress that the revised system is much more demanding but also flexible because we don t require field verification always. However field verification may still be a control measure if the organization or national WG decide that this is the only potentially effective control measure. Then of course it may still be used and relevant for mitigating the risk. Requirements for field verification are aligned with another CW standard that is applicable at the forest level FSC-STD This is also similar to the currently existing sourcing model because field verification requirements today are also aligned in the requirements for CW at the forest level. The same will be in the revised system. What is stressed is that the revised requirements for field verification are also strengthened and more complex than the current ones, at least according to feedback from CHs and CBs. That is the intent of the revision process to strengthen the system. Question: When is FSC-STD V3-0 expected to be approved and when will it be published? Answer: Regarding approval, our current plan is to have the standard approved in November We are still working on the possible publication date and more importantly on the effective date of the standard. Ideally we wanted to have the standard effective at the same time that company risk assessments according to Version 2-1 of the standard are phased out (31 December 2015 / 1 January 2016). The plan was to have the standard made effective on 1 January 2016 but with the planned approval of November this year (and a likely publishing date of 1 December), this will not provide enough time for stakeholders to implement the revised requirements. We are therefore working on a solution that involves moving back the effective date, while enforcing the phase-out of company risk assessments without the revised version of the standard. We plan to release a consultation on this solution in mid-may and the webinar on 26th May will be a part of this consultation and we invite you to participate.

6 Slide 5 Changed requirements! 1 - Documents approved on 10 th November 2014

7 Slide 6 Changed risk categories and sourcing model! How can CW be sourced using NRA/CNRA? REVISED REQUIREMENTS! If low risk (all 5 CW Categories) We are an organization wanting to source Controlled Wood using risk assessment (FSC-STD ) Check National Risk Assessment or CNRA Designates the risk of sourcing unacceptable material (low risk or specified risk) If specified risk Risk is not low, and the type of risk(s) present have been specified by the risk assessment Apply specific risk mitigation means (Control Measures) CMs effective CMs not effective Material is controlled Material cannot be used But, what if the country does not have a NRA or is not covered by the CNRA? Areas not covered by FSC risk assessments A certification body can evaluate the forests we want to supply from according to the CW-FM standard Interim Risk Assessment (until 31 Dec 2017) (C)NRA a key component of the revised system as the prime source of risk designation 6 Question: What happens in areas where there is no Interim Risk Assessment available? Can companies source CW from there? Answer: IRA is conducted by the company according to the revised standard. If the company decides not to do it, they may also outsource field verification at the forest level to a certification body. It will likely have some capacity consequences for the company, since in order to do so we included requirements for sampling such forest areas (same as implementing field verification according to annex 3 of current binding standard). If the sourcing area is a country, at country-level it will be challenging for a company to outsource field verification and therefore most likely a company will conduct IRA although it is not the preferred option. And for example, if we have CNRA for 3 out of 5 categories then IRA would have to be conducted for only 2 remaining categories so it doesn t always mean that companies will be allowed to do IRA for all categories for the sourcing area they are working in. Question: Can companies undertake Interim Risk assessments in any place where there is no CNRA or NCWRA? Where are the rules for IRA? and what will happen after 2017? Answer: For the 1 st part of the question, yes, this is allowed in the standard, so if there is no FSC risk assessment (either NRA or CNRA), they may undertake IRA for these lacking CW categories. The

8 requirements are the same as for NRA development, when conducting IRA, a company must use this document, FSC NRAF (FSC PRO a). The set of requirements referring to the procedure will be included in the revised standard FSC STD What will happen after 2017? If there is still no FSC risk assessment available then only the option of outsourcing verification to a CB would remain. All of the sourcing models are presented on this slide and based on the current draft of the standard which is still under additional testing requested by the BoD and we will finalize this testing hopefully before August. Afterwards the WG will make a final decision about sourcing from unassessed risk areas but at the moment there is no discussion about other options, so it is based on previous discussions of the WG during development process. Question: Requirements for IRA are included in the revised Standard. Correct? But this standard is not yet approved. So how to explain to companies what to do after ? Answer: Yes, there are general requirements for IRA, there is an opportunity to conduct an IRA or jointly with other companies etc. The standard provides references to the addendum PRO a, which provides the requirements mainly used for the NRA process. This issue was discussed during the 2 nd consultation of the draft standard during the GA and the extension of the phase out date that was agreed by the WG and the BoD was intended to give companies time to prepare for this scenario and allow them to begin the process of IRA. We also understand that without approved requirements companies will not be willing to do so. We were hoping for an approval of the standard in March this year, but the decision about additional field testing of minimal outcomes moved our timelines ahead. More details about what to do after this year will be provided at the upcoming webinar on 26th of May and in the consultation materials that we will release. Question: By whom is going to be carried out the IRA? What about if in Italy there exist a NRA approved only for Category 1 and 3? 2nd: the Italian WG is now busy within the IGIs, so the process of CW will be slow down. What if we include new members in the WG along the process? Answer: The IRA will be done by CHs (by the company using terminology from the current standard). If in Italy we have existing approved NRA for Cat. 1 & 3 and if the risk for these categories is low, then company can use this risk designation and they will have the opportunity to do IRA for the remaining categories (2,4,5). If the current NRA provides unspecified risk designation in those 2 categories then it means that Italy will be considered as not having an NRA. In that case, the company would have to reassess the area for all the categories. SDG is the preferable option and all the partners will benefit if they are able to cover controlled wood it is always easier to combine 2 processes although we need to keep in mind the distinctions between FM & CW. If it is not possible for the SDG to develop NRA, then in the proposal for a NRA you need to specify this. We will treat this composition as a new WG when assessing the proposal, so it is possible to engage new members, but it will not be called SDG.

9 Question: One of your slides also indicates that control measures must be confirmed to be effective through verification. Does this mean that affirmative evidence of effectiveness is required, or can it just be the absence of evidence of ineffectiveness? Answer: We are still struggling with this issue. In our last consultation on the 2nd draft which has introduced the requirement to prove effectiveness as well as field tests that we performed in 2014 revealed that is one of the major issues in the revised standard. What do we require from the company to prove this effectiveness and how will it be done. So we left proving the effectiveness up to the organization and up to the CB. We already know it s no enough and stakeholders requested to clarify the requirements. We drafted the standard to use in pilot testing that is ongoing in Canada and focused on testing minimum outcomes because testing will involve implementation of the whole standard. We will also further field test among others the effectiveness of measures. In this draft developed for the purpose of field testing we suggested to check effectiveness for Cat. 2 by stakeholder consultation and for Cat. 3 for a particular type of risk would be conducting field verification to check whether control measures are effective. We would like to see how it will be received by stakeholders during pilot testing. This issue is not decided and is one of the areas we will have to discuss with the WG and refined as we are aware of the lack of clarity.

10 NRA developed according to FSC- PPRO V2-0 Slide 7 The new risk assessment concept Limited use of current NRAs! The risk categories and the requirements have changed - this is why OLD NRAs do not fit into the revised system! Low risk Low risk (Material can be considered as FSC Controlled Wood) Unspecified risk Unassessed areas For FSC Controlled Wood to be sourced, The Organization may: - Outsource verification at forest level by FSC-accredited certification body, and/or - Conduct Interim Risk Assessment NRA invalid 31 Dec Dec

11 Slide 8 Main differences between revised and current risk assessment Category 1 Scope of applicable legislation remains the same since updates in March 2014 Revised system requires explicit identification of applicable legislation and assessment of its enforcement corruption considered through all the indicators Category 2 Scope of the assessment similar Free, prior, informed consent procedures (FPIC) to be used for risk mitigation Category 3 Assessing the presence and threats to all HCVs (1-6) Threats determined Defined maximum scale for each HCV Category 4 Single indicator aspects from former indicators captured in guidance/thresholds New spatial thresholds Category 5 Little has changed Single indicator for simplicity General Functional scale SIR Control Measures

12 Slide 9 PSU Mandated by the Board What is a Risk Assessments for Controlled Wood? To set up the structure for NP engagement Tight timelines: publication of revised documents 01 December 2014 Mandatory starting point is CNRA review of the NRA budget after 1 st draft Mandatory expert involvement - PSU may also hire experts to review national NRA drafts in order to ensure consistency Clear thresholds for FSC IC taking process over (e.g. delays, lack of communication) Support NPs by the NRA Network Coordinator and PSU Direct participation of FSC IC in WG meetings (depends on funds) 9

13 Slide 10 Structure of the engagement What is a Risk Assessments for Controlled Wood? Structure described in the stand-alone document: To encourage NP to participate and ensure coordination of the processes Overview of the CW system, including importance of the risk assessments CNRA as base for the NRA (ToR of the engagement created) Outline of the NRA development (proposal, funding, engagement and intervention mechanism) How to keep NPs engaged? Encourage and review proposals from the identified countries Support in answering questions Negotiate and monitor the timelines between NPs and CNRA consultants Frequent updates and reporting later on during the process Support intervention mechanism 10 Question: if the FSC IC budget for NRA development is not yet approved, then how can we updated the proposal? We can updated all other parts of the proposal, but the budget section will be still incomplete, and thus the proposal remains incomplete. Answer: There are still discussions on the strategic fund but we hope to hear this week and Indrek when he approaches you will already be able to confirm budgets. I would like to add the documents that describe development of NRA engagement also describes how funding for the NRA will be considered. I encourage you to explore this document. Question: Concern about funding & timing. I understood from Indrek there is this decision pending about budgeting. FSC will cover costs of the consultant who is going to prepare the drafts of the CNRA? Is this correct? Answer: Yes it is correct and this is why the decisions around the budget are made in relation to that, so we assume we will deliver hopefully 4 out of 5 categories and the originally proposed budget in the proposal will be cut but this is why we are going to deliver 4/5 categories. And we still hope to provide

14 funds subject to the final decision on the budget so you can focus on the remaining work. In terms of Georgia it would be the HCV issue. This is only for your information, we cannot confirm it at the moment, but my colleague Amrita who is supporting CNRA process, has experience in fundraising and obviously any opportunity we have to gather additional funds apart from those given by FSC management, of course we will see opportunities to support you. There is no country that will be supported with the full amount requested in the proposal. This is simply due to our limitations.

15 Slide 11 How to get started? NRA development proposal (Annex B of the FSC-PRO V3-0): 1) Specify NRA-WG 2) Specify the Coordinator 3) Specify responsible body 4) Specify budget 5) FSC RO opinion 6) Terms of Reference for the NRA-WG and Coordinator 7) Seek approval 8) Start the process 11 Question: Do we need to get approval of our proposal before we can continue? Answer: Yes, Indrek will approach you in this regard, because 2 elements: we need to confirm timelines with you and review them. With our late start it is our responsibility and we are all waiting for final confirmation on budget and funds available. Hope it will be confirmed this week. I don t want to provide you wrong estimations and everyone is aware of the importance

16 Slide 12 Before you go check where you are going 1. READ THE REQUIREMENTS FSC-PRO V3-0, FSC-PRO a (NRAF) 2. READ THE REQUIREMENTS 3. READ THE REQUIREMENTS 2 1! 4. Then you may start implementing them Question: What does NRAF stand for? Answer: This stands for National Risk Assessment Framework. It is the document FSC-PRO a V1-0 FSC National Risk Assessment Framework. This is an addendum of the main procedure for the development of National Risk Assessments. The "NRAF" provides process steps and requirements for the designation and specification of risk ( low risk, specified risk ) of sourcing unacceptable material, as well as requirements for risk mitigation. It contains the actual indicators that are assessed in a risk assessment, and thresholds for deciding whether an area is low or specified risk based on the analysis.

17 Slide 13 Two sides of the NRA process Side 1 (FSC-PRO ) - FORMAL PROCESS Stide 2 (FSC-PRO a) - RISK ASSESSMENT Who? Coordination Working Group Consultation Responsible body Templates Supervision Complaints Intervention mechanism Where? HOW? LOW / SPECIFIED??? 5 CW categories Indicators Thresholds Experts Examples BOTH HAVE TO BE FULFILLED! 13 Question: On the proposals for NRA, we think that the selection of the members of the SDG is an integral part of the proposal. For Austria we need to find/confirm their participation, but we are quite sure that this is a process rather than just a nomination. Is this ok with you? Answer: We do consider this element of establishing WG or SDG of a newly created group as very serious and of course the set of experts will decide the quality of future work and I agree that it is a process and not only nomination. Before you nominate these people, you should consult with them and make sure they are aware of the scope of work and the qualification requirements. Knowing the reality the amount of effort is often underestimated at the beginning so it is important to discuss any scope of work thoroughly.

18 Slide 14 Logical progression Coordinator and WG 2 nd Consultation (30 days if necessary) Final Draft (national approval) Proposal to PSU (timetable, budget, communication) Communication 2 nd Draft (if necessary) Reporting Final Draft (CNRA consultant & PSU review) START 1 st Consultation (60 days) Implementation of amendments (if necessary) Interpretations only PSU Review CNRA & use as a basis 1 st Draft (CNRA consultant & PSU review) Approval (PSU Director)

19 Slide 15 Drafting the NRA 1) Use the CNRA as a starting point and review it 2) 1st NRA draft development (use formal template) for all the categories 3) 1st draft reviews by CNRA consultant, then PSU 4) Public consultation 5) Analyze feedback 6) 2nd draft & consultation (optional) 7) Final draft development 8) Final draft reviews by CNRA consultant & PSU 9) Implementation of the amendments 10) Approval Add: Approach FSC IC with any interpretations 15

20 Slide 16 When assessing the risk - steps START 1 Geographical scope determination (E.g. Country) Yes 2 Gathering information (Determining sources; Data quality assessment) 4 Risk designation (Based on thresholds and gathered information) Low risk thresholds met & no specified risk thresholds met? No 3 Scale determination (E.g. Provinces & ownership & type of forest & SIR) (NRA must state as in the NRAF) To be included at later stage Minimum outcomes to be achieved by Control Measures Cat. 2(2.3) and Cat.3 LOW RISK SPECIFIED RISK (optional) 5 Control Measure(s) establishment (primary by The Organization, NRA may state mandatory or recommended CMs) Question: Can you elaborate a bit more on Control Measures? Is there a description of what they are, or are there limits/boundaries for what they can be? Answer: Control measures are means of risk mitigation. They are actions to mitigate risk of sourcing unacceptable material for them to mitigate risks. There are many possibilities for what a control measure can be, and they are usually company-specific. In the revised draft of FSC-STD V3-0 there is an annex that was developed during the revision process by the working group that provides some examples of control measures. The annex is available along with the second draft consulted publicly. The website address for the 2nd consultation of documents is: For pilot testing we are using the redrafted standard, since for 2nd consultation we already had some initial field testing and based on the outcomes we had a subsequent draft that is now being used for testing minimum outcomes. So the pilot testing draft is the newest. The annex with examples is the same as in the 2nd draft. The only changes were editorial and combining examples of control measures with guidance on how to actually write control measures to meet the concept of SMART. The website

21 address for Pilot Testing with the latest draft is: Examples include document verification, field verification, stakeholder consultation, internal audit of supply chain, etc. There is great flexibility to address particular risks in the revised system, not only field verification the key is that they are successful in mitigating the relevant risk that has been identified to exist. There was also a discussion if it can be developed by company or does it have to be in the NRA. Although in the NRA there could be mandatory control measures specified, the chance was also was given to companies due to being very specific to different operations. Therefore having mandatory control measures could lead to different results in different companies, to an extent that the outcome is reversed and unacceptable material enters the supply chain. For NRA, if control measures are really needed and WG decides it, then they can be mandatory. Since control measures are specific and ay be very different we need to remember what we want to achieve with these. This is where minimum outcomes enter the system. Control measures can be very specific but not less than minimum outcome for a certain type of risk. Originally they were proposed to be relevant for traditional and human rights and FPIC implementation, but also for HCV. The fact that they are not included in the revised framework yet is related to FPIC and IFLs. As soon as NRA would specify areas where the only way to mitigate risk was to source from forest with FPIC implemented, it would have great impact on some companies. Currently the greatest concern is from Canada. The minimum outcome for IFLs suggested that if there is commercial logging in IFL, it is not acceptable. This again lead to great concerns by Canada. So additional field testing is in progress for the minimum outcomes and for the whole standard. Question: Does the "commercially available" threshold for GMOs pertain to the availability of seedlings or harvest-ready trees? Answer: I would consider first how long GMO seedlings would be available. Our thinking is always around the trees and harvesting and the wood and material that may or may not enter our supply chain and therefore is assessed as acceptable or unacceptable because we hardly use seedlings in manufacturing of FSC Mix products. Our original thinking behind requirements therefore relates to trees. But if we look at the NRA in longer perspective we know they will be revised every 5 years for e.g. if at year 0 there is no risk related to seedlings available in forest resources and risk assessed as low, those seedlings at some point will turn into trees if there is allowance for planting them in forests areas, therefore at some point of the revision process this issue would have to approached from a different perspective and then risk designation would change according to this. But we do need to clarify in harvesting material that may enter FSC supply chain when designation risk.

22 Slide 17 Intervention mechanisms FSC International can intervene the NRA process when (e.g.): 1. Reporting is insufficient 2. Drafts not submitted for review 3. Delays on the process not justified and agreed with PSU 4. Complaints issued against the NRA process 17

23 Slide 18 Other sources of the risk assessment Introduction of Centralized National Risk Assessment (stemming from Nov 2013 FSC Board of Directors conclusion on implementation of the revised Controlled Wood system) CNRA to bridge gap between the current and revised processes, focusing on priority countries NRA processes to follow, including specified risk designations and control measures (where decided by FSC Partner). Where no NRA or CNRA: Allowance of Interim Risk Assessments until 31 Dec 2017 Areas of unassessed risk only Must follow the revised and strengthened risk assessment requirements

24 Slide 19 Recap - sources of risk assessments after 31 Dec 2015 NRA-C National Risk Assessment developed and approved according to FSC-PRO V 2-0 (current Procedure)* CNRA Centralized National Risk Assessment developed at the international level to provide at least low risk designations for Controlled Wood priority countries follows revised requirements NRA-R National Risk Assessment developed and approved according to the revised procedures, developed in the CW revision process** IRA Interim Risk Assessment to be carried out by organizations wishing to source Controlled Wood from unassessed areas according to revised risk assessment requirements *Using Risk assessment requirements as for current company risk assessments ** Using Risk assessment requirements from FSC-PRO a FSC F FSC International All rights reserved

25 Hierarchy of the risk assessments Slide 20 Risk assessment hierarchy in revised system ( ) NRA-R (highest priority) Must be followed if it exists Supersedes the CNRA CNRA Takes priority over NRA-C Focuses on low risk areas NRA-C To be used only if no NRA-R or CNRA Only low risk designation Only until IRA The least favourable option Only unassessed areas (includes current unspecified risk!) Only until FSC F FSC International All rights reserved

26 Slide 21 Centralized NRA International experts with local experts and FSC network partners assess chosen CW categories in priority countries Facilitate sourcing CW in the revised system Reduce uncertainty in planning of CW sourcing for CHs To stimulate NRA processes and contribute to NRA development national process can focus on risk specification Deliver harmonized international risk determination NB! CNRA IS BASED ON REVISED REQUIREMENTS!

27 Slide 22 Engagement in the CNRA Different scenarios for cooperation: When developing the NRA the CNRA will constitute the 1 st phase of the NRA (where available). => The more you get out from the CNRA, the less work under NRA IF THERE IS NO CNRA NRA MUST UNDERTAKE THE ASSESSMENT INDEPENDENTLY When not developing the NRA a possibility for direct involvement, which will include 30 days of national consultation (at minimum with existing working group and published on the website) NRA Network Coordinator will be approaching NPs regarding the NRA processes For direct involvement, please approach Amrita Narayanan at a.narayanan@fsc.org by 31 May Question: Is there any idea how long it might take for the entire process, first from funding to hiring of consultants, conducting the CNRA and then transferring to the national WG to revise when can we expect it roughly? Now we are in the middle of May and if everything goes smoothly? Answer: Right now we are negotiation assessments. As soon as we have agreement, with CNRA consultants in place. For Cat. 1 for example, I don t want to provide wrong information, but it can take up to 2 months to wait for delivery from them. It depends on them approaching their own local consultants and if the person from a particular country is available than our main consultants can deliver work for us quickly. The whole idea about scenarios and ways of coordination between NRA and CNRA is for us to speed up in order to reach your proposed timeline. Our consultants know that Georgia is a priority country and has submitted a formal proposal so you are on the top of the list for delivery. They know your timetable and will consult will Indrek. Right now they are waiting for final timetables in order to start ASAP subject to our negotiations. Question: Regarding the first question, do these 2 months include those 30 days of public consultations? Answer: No, these 2 months do not include public consultation because in your situation you are in the formal NRA process they will only deliver your RA for various categories and then you will conduct public

28 consultation for all categories together for 60 days. Our idea is while waiting for CNRAs, we suggest you focus on work related to HCVs. This is complex work for this category and will take time.

29 Slide 23 CNRA Consultants and scope Phase 1 (2014, Top 20) Phase 2 ( , 53 Countries) Argentina Colombia India (19) New Zealand Spain (11) Australia Czech Republic (14) Indonesia Norway Swaziland Austria (13) Denmark Ireland (18) Peru Sweden (5) Belarus Ecuador Italy PNG Switzerland Belgium (17) Estonia (6) Japan (16) Poland (9) Turkey Bolivia Finland (12) Laos (Greater Mekong) Portugal Ukraine Brazil (10) France (7) Latvia (3) Romania United Kingdom Bulgaria Georgia Lithuania (8) Russia (4) USA (1) Canada (2)** Germany Malaysia Slovakia (15) Vietnam Chile Guatemala Mexico South Africa (20) China Honduras Myanmar (Greater Mekong) South Korea Consultants: NEPCon (Cat. 1,3,4,5), Wolfgang Richert Consulting (Cat 2), Proforest (Cat. 3), Sarmap (Cat. 4), others Question: Where can we find information about when which category of CW is planned to be covered by CNRA for top 20 countries? For example category 3 of Japan. Answer: The categories which have not been included in the first phase of rthe CNRA (assessments conducted in 2014) will be included in the second phase from Right now we are negotiating timelines of further assessments to be conducted with the consultants in Phase 2 and right now we are negotiating timetables with the consultants. As soon as we have agreements in place, the plans and timetables will be communicated. Specifically regarding category 3, currently we lack experts to cooperate with us to conduct assessments in a larger number of countries and it is therefore likely that the assessments for category 3 will need to be conducted nationally by working groups. Communications has been released asking for interested entities to approach us in terms of HCV assessment - the news article is on our website. We look forward to your suggestions.

30 Slide 24 Scenario 1- for countries assessed in phase 1 For NRA processes that will be conducted after the 1st phase of the project Timetables between NPs and CNRA consultants agreed before the start of the process, The Consultant to adjust timetables to the NRA process Main steps: FSC Partner reviews the CNRA developed in 2014 and may amend it CNRA Consultant reviews the amendments FSC Partner submits draft NRA to PSU for pre-consultation approval FSC Partner conducts stakeholder consultation FSC Partner reviews and incorporates consultation feedback CNRA Consultant reviews final draft FSC Partner submits final draft to PSU after addressing feedback NRA Network Coordinator will be approaching NPs regarding the NRA processes Question: Can you explain again scenario 1 and 2? Answer: The main difference between the 2 scenarios is at the beginning of the process. Under Scenario 1 you are using the CNRA developed in 2014 which is almost available already. For scenario 2 the CNRA will have to be developed from this year. Both scenario 1 & 2 are for those partners who did submit proposals for a full NRA process. You will follow formal requirements from the procedure: you will appoint a coordinator, establish a working group, and submit a proposal. We will deliver CNRA for Cat. 1,2,4,5 for your pre-assessment and you will use them as a basis for your NRA draft subject to review by your chamber balanced WG. Then you can focus the NRA on the remaining category or categories, usually HCV. You will have to follow the same requirements used for NRA, procedure addendum a NRAF. We hope to provide 4 out of 5 categories and then, as soon as all the categories are covered, you can draft the full NRA including all 5 categories for consultation. We give you authority to amend the CNRA during the review of your chamber balanced WG. Then we would ask our consultants their thoughts on the amendments before we publish the document for stakeholders. The 1 st consultation is the moment the stakeholders in your countries see this document for the 1 st time and the more changes along the process later on, the more difficult it is to follow. So if the 1 st draft is not prepared thoroughly, we have the risk of less engagement, therefore the 1 st draft

31 should be as good as possible so that we have addressed all the potential issues that may pop up during the process. This is why we like to engage the consultants as experts working on same issues for many countries to identify potential issues during the process. After 1 st consultation you are working on the draft on your own and when the final draft is developed, we ask the CNRA consultant to review again and provide advice. Question: If the country has already been included in the CNRA list ( ), such as China, can China develop an NRA at the same time? How will the two procedures be coordinated? Answer: In terms of China, if you wish to conduct an NRA process, then Scenario 2 would be relevant for you. We have no proposal for NRA for China, so from the point of view of FSC IC there is no NRA process in China. If you really wish to enter into a full process the basic step, unavoidable and necessary, is to submit to us a proposal including all elements required by the procedure and if you look at the main steps in this Scenario we have a plan for a full NRA process we would still like to engage CNRA consultants to ensure uniformity of the assessment. Therefore when we know your timetables we will ask the consultant to align with your timetables and to provide you with CNRAs on time. Then you can use the CNRAs as a basis for your NRA.

32 Slide 25 Scenario 2 For NRA processes that will be conducted simultaneously with the CNRA For CW categories not covered by CNRA the NRA process will follow independently and working bodies shall focus on these categories first during the risk assessment process. Main steps: FSC Partner provides Consultant with existing materials CNRA Consultant develops draft CNRA FSC Partner reviews the draft and may amend it CNRA Consultant reviews the amendments FSC Partner submits draft NRA to PSU for pre-consultation approval FSC Partner conducts stakeholder consultation FSC Partner reviews and incorporates consultation feedback CNRA Consultant reviews final draft FSC Partner submits final draft to PSU

33 Slide 26 Scenario 3 For countries without formal NRA process in place Direct participation in CNRA process optional Main steps: FSC Partner provides Consultant with existing materials CNRA Consultant develops draft CNRA FSC Partner conducts national consultation on the draft CNRA for minimum of 30 days FSC Partner analyzes and provides collated SH feedback to Consultant in English CNRA Consultant reviews and if necessary amends the CNRA CNRA Consultant submits the CNRA to FSC For direct involvement, please approach Amrita Narayanan at a.narayanan@fsc.org by 31 May Question: Can we confirm with you if our expression about active engagement in CNRA process is duly received by you or not? In other words, if we have to contact you again to express out will for active engagement? Answer: Yes, and please contact Amrita (a.narayanan@fsc.org) to confirm it. However, we would need you to first study the documents to be fully aware of what is required. On this slide (Scenario 3) you can see the steps for direct involvement. Please remember that we need you to adapt to timelines proposed by CNRA consultants and also to conduct the 30 day consultation. It will not be as much of an effort as to do a full NRA, but engagement of WG and publishing the consultation on your website in local language will be required. We would like you to be aware of the expected scope of work before deciding.

34 Slide 27 Scenario 4 For all countries where FSC Partners do not confirm direct participation Countries where direct participation was unsuccessful may be included here Main steps: CNRA Consultant develops draft CNRA FSC International conducts public consultation on the draft CNRA for minimum of 30 days FSC International analyzes and provides collated SH feedback to Consultant CNRA Consultant reviews and if necessary amends the CNRA CNRA Consultant submits the CNRA to FSC

35 Slide 28 NP Participation Choose your favourable scenario for participation Contact FSC and let us know how you would like to proceed by the end of MAY 2015 WE STRONGLY ENCOURAGE THE NPs TO 1) GET INVOLVED IN EITHER NRA DEVELOPMENT OR; 2) DIRECT PARTICIPATION IN CNRA DEVELOPMENT Send your preference to Indrek at Question: Is there a deadline for submitting a proposal for NRA development? Answer: There is no formal deadline. At any stage you can decide to develop or revise your existing NRA. If you wish to submit a proposal this year it will be difficult unless you have resources for it since we will not be able to support new applicants this year. If you have plans for full NRAs we still welcome proposals that include timelines for future years. Just be aware of the scope of the proposal and what would be included and potential limitations to get it approved and started. I encourage you to contact Indrek for any advice or questions. Question: In the UK, we have submitted a proposal to develop a National Risk Assessment for all five CW categories. From the four scenarios you presented, it seems that you expect CNRA consultants to be involved in all NRAs, even if it is only to review and comment on drafts. Is this correct? Answer: Yes, it is correct, CNRA will be carried out as a first step for most categories and it is to ensure uniformity. We already see from currently approved NRAs that there are different approaches to indicators. In 2014 when we were working on the 1 st set of countries and categories we could see potential differences between the countries. We would like to avoid this situation in the future in NRAs and make sure it is all in line with the requirements and methodology we ve arrived through the CNRA process. We know we cannot specify all the relevant information at international level by consultants

36 and this is why NRA is preferable and that is why we treat CNRA as a pre-draft to be verified through the formal process with the chamber balanced WG and other relevant stakeholders.

37 Slide 29 More information Controlled Wood website Controlled Wood revision

38 Slide 30 Forest Stewardship Council FSC International Charles-de-Gaulle-Str Bonn, Germany T +49 (0) F +49 (0)