Forest Stewardship Council

Transcription

1 PROPOSAL: Development of a new normative document (including impact analysis) Name of normative document: FSC Carbon Footprint Procedure Type of normative document: A procedure linked to FSC-STD , chain-of-custody certification. The procedure will be normative when a chain-of-custody certificate holder makes a claim about the carbon footprint of an FSC-labelled or FSC-certified product. Document code: FSC-PRO-40-XXX This proposal has been developed in accordance with Section 2 of FSC-PRO V3-0 (The Development and Revision of FSC Normative Documents). This document also fulfils the requirements for an impact assessment of new and/or revised normative documents. A. A justification of the need for a new normative document, including an assessment of how the proposed document will meet that need. Motives: a. There is an increasing interest in the carbon footprint of all types of products. Information about this can help consumers to choose for products that contribute less to climate change, and can help producers to reduce the footprint with targeted action. One of the actions to take could be to source from forests that are managed in such a way that harvesting causes no or limited overall loss of carbon stock of the forests (loss of carbon stock equals greenhouse gases emitted). b. To answer demand for certified pellets for electricity/heat production, where greenhouse gas (GHG) calculations are the only missing component in the FSC system. This gap currently obliges FSC certificate holders to certify via a second scheme for this purpose (such as the scheme of the Sustainable Biomass Partnership, SBP). The FSC Carbon Footprint Procedure, verified by an FSC-accredited certification body through the FSC chain-of-custody assurance framework, could substantially reduce costs and complexity for certificate holders. The Carbon Footprint Procedure could make FSC certification more attractive for pellet producers that are not yet FSC certified. c. Existing carbon footprint methodologies ignore or underestimate the importance of carbon changes in the forest. This methodological gap is a missed opportunity to differentiate FSC-certified material in terms of its climate benefits through improved management of forest carbon relative to less responsible sources. There is considerable interest in this topic from many FSC-certified companies. d. The Carbon Footprint Procedure would increase the value of FSC ecosystem services claims regarding carbon maintenance and/or enhancement that are being developed through FSC-PRO (Demonstrating the Impact of Forest Stewardship on Ecosystem Services), because it would enable companies to make product-chainbased claims, rather than only raw-material- (forest-) based claims. Product-chain- 1 of 13 FSC International Center GmbH Charles de Gaulle Strasse Bonn Germany Geschäftsführer Director: Dr Hans-Joachim Droste Handelsregister Commercial register: Bonn HRB12589

2 based claims are much more useful because they enable a company to tell the whole story associated with a product, rather than just a piece of the story. e. The Carbon Footprint Procedure could contribute to resolving the controversy around the carbon debt of pellet use in energy production (carbon debt relates to the fact that using biomass for energy production causes more GHG emissions in the short term than using fossil fuels does; the duration of that debt depends on the biomass used and the management of the ecosystems from which it originates). It would help avoid FSC certification of bio-energy feedstock being regarded as greenwashing bio-energy production and undermining climate change mitigation. f. Interest in the Carbon Footprint Procedure by producers could incentivize improved climate change mitigation along the supply chain including in the forest of origin. B. Reference to any background papers, FSC discussion papers, previous decisions by the FSC Board of Directors, approved FSC general assembly motions, etc., that support the need to develop the proposed normative document. The Carbon Footprint Procedure builds upon three relevant strategic documents. 1. Critical result area (CRA) of the FSC Global Strategic Plan : To conserve critical forest landscapes, new tools will prioritize improved forest management in the tropics, restoration of degraded forestlands, maintenance of intact forest landscapes and climate change mitigation. 2. The Strategic Framework for an FSC Climate Engagement, which calls on FSC operations [to] assess the qualitative and quantitative impacts of their management practices on the carbon stock, ensuring that these practices maintain and/or restore the carbon stock over the long term. 3. The FSC Ecosystem Services Strategy, which commits FSC to develop new tools for certificate holders to access emerging [ecosystem services] markets and to develop practical methods for demonstrating the impact of forest stewardship on the provision of [ecosystem services], including carbon sequestration and storage. All three of these strategic documents focus on improved management of forest-based carbon. The Carbon Footprint Procedure would extend measurement, claims, and incentives regarding climate benefits along the supply chain. Motion 75 from the 2014 FSC general assembly is relevant to this proposed normative document. The motion called for an FSC tool for understanding and offsetting the carbon footprint differential from the trade of FSC-certified products. This motion was withdrawn during the process of motion deliberation at the general assembly; the FSC Secretariat also assessed this motion as technically not feasible. However, the concerns of the Secretariat concentrated on the element of comparison with uncertified products and offsetting elements. The assessment concluded that estimation of the carbon footprint itself was feasible. Further, in terms of potential impact, it also said: This motion could be an opportunity to go beyond forest carbon and to provide an assessment of carbon performance along the value chain. 2 of 13

3 This would increase credibility of FSC and could raise additional funds from carbon markets. Additionally, this might facilitate the access to subsidies and incentives from biomass production. Finally, this analysis might increase environmental performance along the value chain (FSC-REP-GA V1-0 Motions Analysis). C. Assessment of how the new normative document is aligned with critical result areas of the FSC Global Strategic Plan Please list relevant project cases and actions from the draft implementation plan: Streaming/simplifying the normative framework Increase quality and consistency in practice Advance governance and engagement Deploy new solutions N/A N/A N/A The Carbon Footprint Procedure would represent one of the new solutions that FSC could develop to satisfy CRA 1.4, specifically in support of climate change mitigation. Demand for carbon data from forest managers and along the supply chain could create incentives to improve climate performance and increase the climate benefits of FSC certification. Rapidly increased consumer demand Overcome certification barriers The Carbon Footprint Procedure could also enable differentiation of companies demonstrating more positive climate performance and also differentiate sources of biogenic energy production on the basis of their actual GHG emission reductions. The Carbon Footprint Procedure would create greater demand for FSC-certified biomass-for-energy because external carbon accounting tools would no longer be required. It would also differentiate FSCcertified pellets from other sources based on a reduced carbon/climate impact. The Carbon Footprint Procedure would help to overcome the certification barrier for bioenergy, a growing market for which FSC stakeholders are looking for robust evidence 3 of 13

4 Empowering people to access and develop new markets Align functions globally Excellence in service delivery Unleash the power of knowledge of avoidance of perverse impacts. The Carbon Footprint Procedure would be a new tool for certificate holders to access emerging ecosystem service markets, notably for renewable energy (CRA 2.3.1). N/A The Carbon Footprint Procedure would offer a new service for chain-of-custody certificate holders, that would improve access to certified bio-energy markets (CRA 3.2.3) The Carbon Footprint Procedure would increase the availability of information about FSC impacts on climate along the supply chain (CRA 3.3.5). D. An assessment of the proposed normative document using the strategic filters identified in the FSC Global Strategic Plan : Future relevant Does the proposed action take into account future trends in markets, demographics, economic development, technology, and other key factors? Will it maintain or enhance FSC s relevance? Does it have the capacity to be a paradigm-shifting action? Climate is likely to remain at the top of the agenda of governments, businesses, and civil society for some decades. Carbon footprinting of policy, production, and consumption will become increasingly relevant. Modern use of biomass for energy purposes is likely to grow considerably. It will remain, in the next two decades, the main renewable energy source ; it will also remain important after that as it is, unlike wind and solar, a flexible energy source that can be inserted instantly following demand. At the same time, because of controversy about this specific energy source, public policy to support this, may falter, and the FSC tool can help ensure that use of bioenergy truly results in the best possible climate outcomes. Science-based Does the proposed action have a firm basis in the scientific literature? Carbon debt and the pros and cons of bioenergy are subject to hot scientific 4 of 13

5 Is it supported by academic partners? Deliverable Is the proposed action realistic given our capacities? Can it be delivered in a meaningful time frame? Can it be delivered in many cultures with many different languages? discussion. The Carbon Footprint Procedure could be highly influential in this debate by delivering a rigorous science-based tool that for the first time properly addresses the issue of carbon debt and allows credible science-based claims of climate impact. The tool will be based on the best science in this area and on advise from Quantis, a highly respected consultancy firm with the support of WWF. Quantis has prepared a clear and feasible roadmap for developing the Carbon Footprint Procedure. The method can be integrated with the existing FSC forest carbon monitoring tool (to be launched), as well as the Online Claims Platform. The Carbon Footprint Procedure could be developed in under a year. As it is essentially an extension of the FSC Chain of Custody Standard, we assume that it is a rather culture- and language-neutral tool. Financially sound Can FSC afford the investment relative to all the other financial priorities of the organization? Is it likely to be on ongoing burden or benefit to the organization? What are the social, environmental, and economic returns on investment? Once the Carbon Footprint Procedure is developed it will run its course as other procedures and standards: The Policy and Standards Unit will have to monitor its use and revise the tool from time to time using the usual procedures. The cost of developing the tool will be between EUR 70,000 and EUR150,000, depending on the precise attributes of the tool and whether we commission an MS Excel-based or a webbased tool. Environmental/social return on investment: more FSC-certified forests and an improvement of the environmental performance of bio-energy in the world. In a wider sense, a contribution to reducing the carbon footprint of production and 5 of 13

6 consumption. Economic: if pellet producers and users choose to use this system it will be an additional incentive for them to work with FSC certification, so it would then increase the number of FSC certificate holders. Value-additive Does the proposed action create social, environmental, and/or economic value? Are the benefits balanced across stakeholder groups? Innovative Does the proposed action provide something new and impactful to the global forest system? Consensus Is the proposed action likely to result in chamber-balanced support from members, as well as support from network partners, certificate holders, certification assessment bodies, and staff? Is it controversial with any particular stakeholder group? Synergistic Does the proposed action build on or reinforce our other work or the work of key partners? Is it redundant to other internal or external actions? Easily communicated Can the purpose and impact of this action be easily communicated to FSC stakeholders? Straightforward Is the proposed action easy to implement or excessively complex? Can it be streamlined? The possible environmental and social values are already mentioned above. The obvious benefits are for the user, as it will increase their credibility, and for environmental and social groups that are currently concerned about non-sustainable bio-energy use. Indeed, it is likely to be unique in the sense that it will be the first major system that manages to include carbon debt issues in a GHG calculation system. The issue is controversial, so the challenge is to create consensus among the FSC stakeholders on the basis of a strong proposal. It can help to convince pellet producers, in particular in the United States of America, to go for FSC certification rather than using Sustainable Forest Initiative certification or the SBP Supply Base Evaluation approach. It also reinforces and builds upon WWF s work to promote more climate-positive energy. Carbon footprint can be easily communicated and is relevant for all actors given the dominance of the climate agenda. Carbon accounting is being increasingly carried out in supply chains and, except for the forest level, the information collected has become rather standard. We expect that the 6 of 13

7 companies interested in using this method will be able to collect and input the necessary information without too much effort. Our proposal includes the use of the Online Claims Platform as carrier of the information between the certificate holders involved. Adaptable Can the proposed action be applied in other contexts? The Carbon Footprint Procedure will be applicable to any product type. E. Specification of clear aims and objectives of the new normative document, in particular those objectives that focus on social, environmental, and/or economic aspects. Aims: to ensure that FSC-certified biomass that is directly used for production of energy brings real substantial benefits compared to the use of fossil fuels in terms of reduction of GHG emissions; to assist companies in measuring the carbon footprint of any FSC-certified product, enabling the communication of this information to the public and actions to reduce the footprint. Objective: to describe the information and analyses that shall be used when a chain-ofcustody certificate holder makes a claim about the carbon footprint associated with a specific FSC-labelled or -certified product. F. Additionally in the case of standards a documentation of what other standards exist or are in the process of development which meet all or part of the expressed need; and an assessment of how broadly the final standard is intended to be applied. Not applicable proposed document is not a standard. G. Policy coherence: Reference to how the proposed normative document relates to other FSC normative documents and analysis of the likely impact it will have on them. 7 of 13

8 The table below describes the relationship and impact of the FSC Carbon Footprint Procedure to other FSC normative documents. Other FSC normative document to which The Carbon Footprinting Procedure relates FSC-STD , chain-of-custody certification FSC-PRO , demonstrating the impact of forest stewardship on ecosystem services Impact The Carbon Footprint Procedure will be linked with the requirements of FSC-STD The method is for voluntary use, but shall be applied in its entirety when a chain-of-custody certificate holder makes an FSC claim about the forest carbon footprint of an FSC-labelled product. The Carbon Footprint Procedure will describe the procedure necessary for chainof-custody certificate holders to make carbon footprint claims about FSC-labelled products. The requirements of the Carbon Footprint Procedure will need to align with those of FSC-PRO H. An assessment of risks in implementing the normative document and how to mitigate these, including identification of factors that could have a negative impact on the ability of the normative document to achieve its objectives; unintended consequences that could arise from its implementation; and possible mitigation measures that could be taken to address these potential risks. Table of risks and mitigation measures: Risks Risks of project failure Mitigation measures 8 of 13

9 It is possible that the economic and environmental chambers will not agree on the specifics of the calculation method, in particular with regards to carbon debt. Though they may have concerns about FSC being involved in climate benefit claims for bio-energy, environmental chamber members will likely see the benefits of bringing rigour and credibility to the issue of carbon debt. Risks from unintended effects It is possible that FSC certificate holders will not use the Carbon Footprint Procedure if the outcomes are less favourable than expected (a higher carbon footprint than expected) and when they discover that other tools are bringing a more favourable picture. Risk of not implementing the suggested option - Disappointing certificate holders who would like to complement information about sustainable forest management with carbon footprint information. - Risk of losing certificate holders and/or market visibility to PEFC, which plans to provide a GHG tool, as well as increased use of SBP certification. - Increased exposure from certain NGOs that FSC certification is part of greenwashing bio-energy with substantial carbon debt. While economic chamber members may be concerned about FSC developing an approach that is more rigorous than the status quo, they may see the value of resolving a positional campaign over bioenergy and may also see the benefits of a single FSC-based process to certify pellets for energy production. Public, government, and NGO interest in credibility should differentiate the FSC method, and drive demand for its use. Successfully develop the tool with sufficient stakeholder engagement. Other risks 9 of 13

10 I. The results of a stakeholder mapping exercise or updated version of an existing stakeholder map to identify all stakeholders that will be affected by the new normative document and the potential impacts upon them. Stakeholder Potential impacts Mitigation measures General Forest management certificate holders Requests from companies downstream in the supply chain to provide data according to the Carbon Footprint Procedure. Providing the data is voluntary and upstream companies could request compensation for providing data. Also, make reporting requirements as light and simple as possible. Forest management chain-ofcustody certificate holders Certification bodies See above Will need to do additional work in terms of auditing the application of the Carbon Footprint Procedure. While the certificate holder at the end of the supply chain (the end-product producer) is the one with the motivation to apply the method, all their suppliers and those further up the supply chains will need to apply the method as well, and so all the certification bodies in the affected supply chains will have additional work. See above The extra costs have to be borne by the certificate holders, and those higher up the supply chain may want to negotiate any compensation with the final certificate holder. 10 of 13

11 Stakeholder Potential impacts Mitigation measures Accreditation Services International (ASI) FSC network partners FSC International Center FSC members and supporters Indigenous Peoples Will need to get acquainted with the method and its purpose, to be able to assess the performance of certificate holders. Need to understand the purpose and technical specificities of the method. PSU will need to incorporate this method into its regular work. If informed, can play a positive role in promoting the use and its environmental benefits. No specific impacts foreseen, except as certificate holders (see above). FSC IC would provide training. FSC IC would provide training. A modest increase of capacity might be needed. FSC IC and network partners could provide training and outreach. J. Stakeholder participation goals to establish clear targets for stakeholder engagement. Stakeholder FSC members FSC network partners Participation goal Review of draft Carbon Footprint Procedure and provision of feedback. Potential participation in a technical working group. Participation in webinars. Review of draft Carbon Footprint Procedure and provision of feedback. 11 of 13

12 FSC certificate holders Certification bodies Governments, NGOs outside FSC, and SBP Participation in webinars. Participation in consultative forum. Potential participation in a technical expert working group. Review of draft procedure and submission of comments. Participation in webinars. Participation in consultative forum. Potential participation in a technical expert working group. Review of draft procedure and submission of comments. Participation in consultative forum. K. Specification whether pilot testing is recommended. Only desk-based testing is recommended for the Carbon Footprint Procedure. L. An estimated budget for the development process of the new normative document. Activity Budget 2017 Budget 2018 Staff time (days) Consultants Travel Meeting costs 21 days EUR70, ,000 EUR500 EUR500 TOTAL EUR71, , days M. Feasibility analysis: Technical: Which technical expertise is required to implement the proposed option? How will this expertise be recruited? Does the implementation of the proposed option involve any technical challenges (in terms of process and content)? Financial: What are the resource In-house expertise on chain of custody. In-house expertise on ecosystem services and ecosystem services claims. External carbon accounting expertise. If we hire a consultant (carbon accounting 12 of 13

13 requirements for FSC (HR, costs)? Are these resources available and justifiable (cost benefit)? expertise) the rest of the required resources are from PSU: Chain of Custody Program Ecosystem Services Program These resources are available and justifiable given the importance of having this tool. Legal: Does the proposed option create any conflicts with legal requirements (data protection, WTO, anti-trust, etc.)? Operational: Does the proposed option deliver on the expected operational outcome? Is it feasible for the target audience to implement the changed/new requirements? We are confident that the proposed option will deliver on the expected operational outcome. 13 of 13