West Fraser Mills Ltd. B.C. and Alberta Woodlands 2016

Transcription

1 West Fraser Mills Ltd. B.C. and Alberta Woodlands 2016 Between January and November 2016 an audit team from KPMG Performance Registrar Inc. ( KPMG or KPMG PRI ) carried out a surveillance/scope expansion audit of West Fraser Mills Ltd. (West Fraser) s B.C. and Alberta Woodlands Operations and associated production facilities against the requirements of the Sustainable Forestry Initiative (SFI) forest management and fiber sourcing standards. To provide for a more efficient audit, ISO 14001, PEFC and FSC chain of custody and Canadian Boreal Forest Agreement forestry requirements audits were conducted at the same time. This Certification Summary Report provides an overview of the process and KPMG s findings regarding the Company s conformance with the SFI forest management and fiber sourcing standards. SFI Forest Management and Fiber Sourcing Certifications All of West Fraser s B.C. and Alberta Woodlands Operations are included within the scope of multi-site SFI forest management and fiber sourcing certificates issued by KPMG PRI. The Company s current SFI certifications are valid until August 12, West Fraser s B.C. and Alberta Woodlands Operations The area included within the scope of the Company s ISO and SFI forest management certification includes the following 12 West Fraser Woodlands Operations: 100 Mile Woodllands Alberta Plywood Woodlands Blue Ridge Lumber Woodlands Chetwynd Forest Industries Woodlands Fraser Lake Woodlands High Prairie Forest Products Woodlands Hinton Wood Products Woodlands Manning Forest Products (MFP) Woodlands (SFI only) Pacific Inland Resources Woodlands Quesnel Woodlands Sundre Woodllands Williams Lake Woodlands The above West Fraser woodlands operations currently cover a total of approximately 7.8 million hectares (gross area), and provide the Company with a combined allowable annual cut (AAC) of 14.0 million m 3 per year. The audit found that Company continues to conform to the AACs applicable to these operations (for 2015 the actual harvest level from company tenures was 11.3 million m 3 ). West Fraser s B.C. and Alberta Woodlands operations are all covered by a corporate sustainable forest management (SFM) plan that addresses the Objectives of the SFI forest management standard and includes a variety of targets in relation to them. In addition, government-approved forest stewardship plans (for all B.C. Woodlands) and forest management plans (for all Alberta woodlands) that address both timber and nontimber values are also in place. In addition, various higher level plans developed by government (e.g., Land and Resource Management Plans, etc.) also provide direction to forest management within the areas managed by the Company. #0746 The Company s B.C. and Alberta woodlands operations fall within the following World Wildlife Fund (WWF) ecoregions: (1) Fraser Plateau and Basin Complex, (2) North Central Rockies Forest, (3) Cascade Mountains Leeward Forest, (4) Central British Columbia Mountain Forests, (5) Okanagan Dry Forests, (6) Alberta-British Columbia Foothills Forests, (7) Alberta Mountain Forests, (8) Canadian Aspen Forests and Parklands, (9) Mid-Continental Canadian Forests, and (10) Northern Cordillera Forests. The above ecoregions also represent the area of B.C. and Alberta from which the

2 Findings West Fraser Mills Ltd. B.C. and Alberta Woodlands 2016 Page 2 Company procures fibre from third parties to supplement supplies harvested from its own woodlands operations. The forests managed by the Company are dominated by the following commercial tree species: Pinus contorta var. latifolia (Lodgepole pine), Picea glauca (White spruce and hybrids), Picea engelmannii (Engleman spruce and hybrids), Picea mariana (Black spruce), Pseudotsuga menziesii (Interior Douglas-fir), Abies balsamea (Balsam Fir), Abies lasiocarpa (Sub-alpine fir), Populus tremuloides (Trembling aspen), Populus balsamifera (Balsam poplar), Betula papyrifera (Paper birch). West Fraser Mills Ltd. B.C. and Alberta Woodlands 2016 SFI Surveillance/Scope Expansion Audit Findings Open non-conformities from previous audits 0 The forest management approach employed by the Company at its B.C. and Alberta woodlands operations is based on even-aged management, ground-based and/or cable harvesting systems, clearcut harvesting with the retention of reserves of standing trees either within or adjacent to harvest areas, replanting of harvest areas within a few years with a mix of ecologically suited tree species and control of competing vegetation through the use of government-approved chemical herbicides (only some woodlands operations) and/or mechanical means. Controls are in place to help reduce reliance on chemical brush control where feasible to do so. New major nonconformities New minor nonconformities 0 3 West Fraser s B.C. and Alberta Woodlands Manufacturing Facilities The mills included within the scope of the Company s SFI fibre sourcing certification includes the following West Fraser manufacturing facilities: 100 Mile Lumber sawmill Alberta Plywood sawmill Blue Ridge Lumber sawmill Chasm sawmill Chetwynd Forest Industries sawmill Edson Forest Products sawmill Fraser Lake sawmill Hinton Wood Products sawmill Manning Forest Products sawmill Pacific Inland Resources sawmill Quesnel sawmill and plywood mill Slave Lake pulpmill Sundre Forest Products sawmill West Fraser LVL mill Williams Lake sawmill and plywood mill The Company s fiber sourcing needs vary considerably between facilities. While the majority of fiber is sourced directly from the Company s own woodlands, approximately one-third (5.7 million m 3 in 2015) is purchased from third parties, a small portion of which is purchased stumpage that is logged by West Fraser contractors under the Company s environmental management system (EMS). West Fraser participates in the WCSIC Purchase Wood Monitoring Program by completing risk assessments for all wood purchases and purchase wood inspections as necessary. The results are collated by the WCSIC in order to identify opportunities for improvement. The large majority of wood purchases are from other organizations (forest companies and B.C. Timber Sales) who hold their own SFM certifications, with a small percentage coming from uncertified private land and oilfield salvage operations. New opportunities for improvement Types of audit findings Major non-conformities: Are pervasive or critical to the achievement of the SFM Objectives. Minor non-conformities: Are isolated incidents that are non-critical to the achievement of SFM Objectives. All non-conformities require the development of a corrective action plan within 30 days of the audit. Corrective action plans to address major nonconformities must be fully implemented by the operation within 3 months or certification cannot be achieved / maintained. Corrective action plans to address minor non-conformities must be fully implemented within 12 months. Major non-conformities must be addressed immediately or certification cannot be achieved / maintained. Opportunities for Improvement: Are not non-conformities but are comments on specific areas of the SFM System where improvements can be made. 9

3 Findings West Fraser Mills Ltd. B.C. and Alberta Woodlands 2016 Page 3 Audit Scope The SFI portion of the audit entailed an assessment against the requirements associated with the following SFI forest management and fibre sourcing objectives: Forest management planning; Forest health and productivity; Protection and maintenance of water resources; Conservation of biological diversity; Management of visual quality and recreation benefits; Protection of special sites; Efficient use of fibre resources; Recognize and respect Indigenous Peoples rights; Biodiversity in fiber sourcing; Adherence to best management practices; Use of qualified resource professionals and qualified logging professionals; Legal and regulatory compliance; Forestry research, science and technology; Training and education; Community involvement and landowner outreach; Public land management responsibilities; Communications and public reporting, and; Management review and continual improvement. The audit involved a review of selected EMS and SFI records, interviews with a sample of staff and contractors and visits to field sites (38 roads, 58 cutblocks, 32 silviculture sites, 4 camps and 4 wood procurement sites) to evaluate SFM system implementation and the adequacy of forest management plans and practices. The Audit Audit Team The audit was conducted by Dave Bebb, RPF, EP(EMSLA), Branden Beatty, RPBio, Neil MacEachern, RPF, Yurgen Menninga, RPF, EP(EMSLA), Chris Ridley-Thomas, RPBio, EP(EMSLA) and Bodo von Schilling, RPF, EP(EMSLA). Members of the audit team have conducted numerous forest management audits under a variety of standards including SFI, ISO 14001, CSA Z809 and FSC. SFI Surveillance/Scope Expansion Audit The audit involved an on-site assessment of the West Fraser B.C. and Alberta Woodlands Operation s EMS and SFI program. Site visits were made to a total of 6 out of 12 woodlands divisions (Blue Ridge, Quesnel, 100 Mile, High Prairie, Hinton and Manning Forest Products) as well as the Company s Quesnel, B.C. Corporate Office (the Manning Forest Products portion of the audit was conducted to facilitate the inclusion of this site within the scope of the Company s multi-site SFI forest management and fibre sourcing certifications). This sample size is consistent with IAF requirements regarding audit sampling for multi-site certifications. The audit involved a review of selected EMS and SFI records, interviews with a sample of staff, contractors and regulatory agency personnel and visits to a sample of field sites (38 roads, 58 cutblocks, 32 silviculture sites, 4 camps and 4 wood procurement sites) to evaluate SFM system implementation and effectiveness. The SFI portion of the 2016 West Fraser audit took approximately 40 auditor days to complete, 28 days of which were spent on-site. The balance of audit time was spent preparing the audit plan, conducting an off-site review of selected Company documents, completing various audit checklists and preparing the main and public summary audit reports. West Fraser s SFI Program Representative Stephen Vinnedge, RPF (West Fraser s Stewardship Forester and Corporate EMS Coordinator) served as the Company s SFI program representative during the audit.

4 Findings West Fraser Mills Ltd. B.C. and Alberta Woodlands 2016 Page 4 Audit Objectives The objectives of the audit were to evaluate the SFM system at West Fraser s B.C. and Alberta woodlands operations to: Determine its conformance with the requirements of the SFI forest management and fibre sourcing standards; Evaluate the ability of the system to ensure that the Company meets applicable regulatory requirements; Evaluate the effectiveness of the system in ensuring that West Fraser Mills Ltd. meets its specified SFM objectives, and; Where applicable, identify opportunities for improvement. Audit Conclusions The audit found that West Fraser Mills Ltd. B.C. and Alberta Woodland s SFM system: Was in conformance with the requirements of the SFI standards included within the scope of the audit, including the requirement to complete internal audits and management reviews at planned intervals, except where noted otherwise in this report; Continues to be effectively implemented, except to the extent that non-conformities have been identified during the current audit or in previous audits if they have yet to be adequately addressed, and; Is sufficient to systematically meet applicable requirements and expected outcomes, provided that the system continues to be implemented and maintained as required. As a result, a decision was reached by the lead auditor to recommend that: West Fraser Mills Ltd. B.C. and Alberta Woodlands continue to be certified to the SFI forest management and fibre sourcing standards, and; Manning Forest Products be added to the scope of the Company s multi-site SFI forest management and fibre sourcing certifications (MFP was previously covered under separate single-site SFI forest management and fibre sourcing certificates issued by KPMG PRI). A total of 7 West Fraser woodlands operations are subject to the Canadian Boreal Forest Agreement (CBFA) forestry requirements for natural range of variation (NRV) analysis and target setting which were publicly released in January In order to ensure as efficient an audit as possible, audits of conformance with the CBFA forestry requirements were conducted concurrently at those woodlands operations included in the 2016 audit sample to which the CBFA applies. Evidence of Conformity with SFI Standards SFI Forest Management Objective Sources of Key Evidence of Conformity 1. Forest Management Planning SFM plan, FSPs, DFMPs, GDPs, AOPs, TSR AAC Rationales, GIS, review of site plans, harvesting records interviews with a sample of staff and contractors, field inspections. 2. Forest Health and Productivity SFM plan, FSPs, DFMPs, EMS operational controls, review of site plans, interviews with a sample of staff and contractors, review of silviculture records for selected operations, field inspections. (MFP only)

5 Findings West Fraser Mills Ltd. B.C. and Alberta Woodlands 2016 Page 5 SFI Forest Management Objective Sources of Key Evidence of Conformity 3. Protection and Maintenance of Water Resources 4. Conservation of Biological Diversity 5. Management of Visual Quality and Recreational Benefits SFM plan, FSPs, DFMPs, review of site plans and associated VIA results, interviews with a sample of staff and contractors, inspection of a sample of field sites. 6. Protection of Special Sites SFM plan, FSPs, DFMPs, staff interviews, review of site plans and stakeholder consultation records, field inspections. (MFP only) 7. Efficient Use of Fibre Resources SFM plan, divisional waste survey results, government-issued cut control letters, final block inspections, field inspections. 8. Recognize and Respect Indigenous Peoples Rights 9. Legal and Regulatory Compliance 10. Forestry Research, Science & Technology Company policy on Indigenous Peoples rights, records of consultation with local Indigenous Peoples, pre-audit questionnaire responses, staff interviews. (MFP only) SFM plan, corporate environmental, social and health & safety policies, Corporate Stewardship Report, management review records, non-compliance records, field inspections, interviews with regulatory agency personnel. SFM plan, Corporate Stewardship Report, corporate and divisional management review records, divisional research records, interviews with divisional staff. 11. Training and Education SFM plan, EMS and SFI awareness training materials and records, WCSIC minutes & resources, interviews with a sample of staff and contractor employees. (MFP only) 12. Community Involvement and Landowner Outreach 13. Public Land Management Responsibilities 14. Communications and Public Reporting 15. Management Review and Continual Improvement SFM plan, FSPs, DFMPs, divisional operational controls, conformance with the results of watershed assessments, review of site plans & harvest plans, field inspections. SFM plan, FSPs, DFMPs, staff interviews, divisional operational controls, review of wildlife and biodiversity information and strategies contained in divisional GIS, site plans, field inspections. (MFP only) SFM plan and related monitoring results, WCSIC meeting minutes & resources, community outreach records, staff interviews. FSPs, DFMPs, GDPs, AOPs and stakeholder referral correspondence, site plans and selected stakeholder consultation records, staff interviews, field inspections. MFP only) Certification summary report, annual report to SFI Inc. SFM plan, management reviews, internal audit reports and associated action plans, divisional EMPs, staff interviews. West Fraser acquired Manning Forest Products in October KPMG PRI conducted a scope expansion audit of Manning Forest Products in November 2016 in order to include this operation within the scope of West Fraser s SFI forest management and fibre sourcing certifications.

6 Findings West Fraser Mills Ltd. B.C. and Alberta Woodlands 2016 Page 6 SFI Fibre Sourcing Objective Sources of Key Evidence of Conformity 1. Biodiversity in Fibre Sourcing Program to promote biodiversity in fibre sourcing, records of involvement in local or regional conservation efforts, interviews with procurement staff. (MFP only) 2. Adherence to Best Management Practices 3. Use of Qualified Resource and Logging Professionals 4. Legal and Regulatory Compliance 5. Forestry Research, Science & Technology Fibre sourcing policy and records of its distribution to wood producers, written fibre sourcing agreements, records of implementation of the BMP monitoring system, inspection of a sample of procurement sites. List of Qualified Resource and Logging Professionals, records of proportion of fibre delivered by QLPs, interviews with procurement staff. SFM plan, corporate environmental, social and health & safety policies, Corporate Stewardship Report, corporate and divisional management review records, noncompliance records, inspection of a sample of procurement sites, interviews with regulatory agency personnel. SFM plan, Corporate Stewardship Report, management review records, divisional research records, staff interviews. 6. Training and education SFM plan, EMS and SFI training materials and records, WCSIC minutes & resources, interviews with a sample of procurement staff and contractor employees. (MFP only) 7. Community Involvement and Landowner Outreach 8. Public Land Management Responsibilities 9. Communications and Public Reporting 10. Management Review and Continual Improvement 11. Promote Conservation of Biological Diversity, Biodiversity Hotspots and High-Biodiversity Wilderness Areas WCSIC minutes & resources, community and landowner outreach records, staff interviews. Records of cooperative public land planning processes, plan referrals to local stakeholders, staff interviews. (MFP only) Certification summary report, annual report to SFI Inc. SFM plan, management review records, internal audit reports and associated action plans, interviews with a sample of corporate and divisional procurement staff. Program with direct suppliers to promote the principles of sustainable forestry (POSF), records of direct supplier implementation of the POSF, staff interviews. West Fraser maintains a corporate SFM plan that outlines how the Company addresses the requirements of the SFI forest management and fibre sourcing standards. The SFM plan includes a variety of objectives and targets in relation to the SFI requirements, and is applicable to all of the woodland divisions that are included within the scope of West Fraser s SFI certifications. In addition, divisional forest management plans that are required by government (Detailed Forest Management Plans (DFMPs) in Alberta and Forest Stewardship Plans (FSPs) in B.C.) outline additional forest management requirements at the local level. West Fraser s Hinton operation has recently developed a new DFMP (depicted above) that incorporates an NRV-based approach to the management of biological diversity. 12. Avoidance of Controversial Sources including Illegal Logging 13. Avoidance of Controversial Sources including Sources without Effective Social Laws Controversial sources risk assessment, procedures to address any significant risks that have been identified, interviews with procurement staff. (MFP only) Controversial sources risk assessment, procedures to address any significant risks identified, interviews with procurement staff.

7 Findings West Fraser Mills Ltd. B.C. and Alberta Woodlands 2016 Page 7 Follow-up on Findings from Previous Audits At the time of this assessment there were a total of 4 open minor non-conformities from previous external SFI audits. The audit team reviewed the status of the action plans that were developed by the Company to address these audit findings and concluded that they: (1) had been implemented as required, and (2) were effective in addressing the root cause(s) of these non-conformities. As a result, all of the previously identified minor non-conformities have now been closed. Good Practices A number of good practices were identified during the course of the 2016 audit. Examples included: SFI Forest Management Objective 2: The Company s Alberta woodlands operations are significantly outperforming the coniferous and deciduous MAI (Mean Annual Increment) reforestation performance targets for the applicable FMAs in the large majority of instances. (Alberta Woodlands Operations) SFI Forest Management Objective 3: In response to a large erosion event due to historic hydraulic mining that occurred during spring freshet on Grouse Creek, the Quesnel operation devoted significant effort to the stabilization of the creek bank approaching the Antler/Grouse creek confluence (i.e., applying groyne armoring along the road, re-vegetation with willow and cottonwood stakes and pine seedlings, grass seeding of exposed soil, etc.). (Quesnel) SFI Forest Management Objective 4: The Company is in the process of implementing a risk-based migratory bird conservation strategy for forest operations in order to help reduce the risk of incidental take of migratory birds during harvesting. (Corporate) SFI Forest Management Objective 5: The 100 Mile operation recently hosted a workshop on visual resource management that included staff from the 100 Mile operation as well as the Ministry of Forests, Lands and Natural Resource Operations (MFLNRO), BCTS, other licensees and Company divisions. (100 Mile) SFI Forest Management Objective 7: The audit found that MFP has a diverse program for the utilization of wood waste produced by the sawmill that includes energy co-generation, pellet production and the sale of chips to local pulp mills. (Manning Forest Products) SFI Forest Management Objective 9: The audit found that a number of Company operations now require their logging contractors to use GPS units in their fellerbunchers as a means to reduce the potential for harvest boundary trespass. (Blue Ridge and Quesnel) SFI Forest Management Objective 10: West Fraser continues to devote considerable resources to forest-related research. In 2015 the Company spent approximately $11.9 million on forest-related research (including internal Company research projects and contributions to external research organizations), which is equivalent to approximately $1.05/m 3 harvested in 2015 from Company tenures. (Corporate) SFI Forest Management Objective 12: The audit found that West Fraser Hinton had demonstrated strong corporate citizenship through its involvement with the Foothills Recreation and Management Association which manages and maintains 20 campgrounds and over 200 km of recreational trails, providing affordable recreation to the region s population and promoting tourism. (Hinton) The audit found that the Company had done a good job of protecting riparian features during forest operations on the large majority of sites visited.

8 Findings West Fraser Mills Ltd. B.C. and Alberta Woodlands 2016 Page 8 Minor non-conformities The following 3 minor non-conformities were identified during the audit in relation to the requirements of the SFI forest management and fiber sourcing standards: SFI Forest Management Objective 9: The audit identified 1 instance of non-conformance with applicable EMS procedures and Operating Ground Rules (OGRs) that had not been identified through the Company s internal inspection processes. On one harvest block the buncher and skidder operators failed to shut down when rutting occurred. This incident was later reported to the Company by Alberta Agriculture and Forestry (Alberta AaF), who then developed an action plan to address it. (Blue Ridge) SFI Forest Management Objective 9: The audit found that the OGRs had been met on the majority of sites included in the 2016 Blue Ridge audit field sample. In one harvest block there was a large permanent watercourse for which the block layout document noted that there was a variance to the standard 60 metre riparian buffer requirements for this watercourse due to an existing road right of way. However, review of the Final Harvest Plan (FHP) found the variance had not been approved by Alberta AaF. (Blue Ridge) SFI Forest Management Objective 9: The Alberta Gas Code Regulation cites CSA Standards B and 15 sections and and requires that propane cylinders be set upon firm, level, weather-proof bases. However, an inspection of a reforestation field camp during the audit noted four 100 pound propane cylinders that were stored upright without a proper base. (Hinton) Opportunities for improvement The following 9 opportunities for improvement were identified during the audit in relation to the requirements of the SFI forest management and fiber sourcing standards: SFI Forest Management Objective 2: While MFP has been providing the required SFI training to contractors, the frequency of the operation s formal refresher training programs has been every 3 years, which is not consistent with the recently revised (fall 2017) WCSIC requirement to provide training every 2 years. In addition, MFP typically provides training to contractors a few weeks after the start-up of the winter harvesting season. However, this approach does not adequately address new hires at the beginning of the logging season, nor does it ensure that new employees who start mid-season obtain the required training. (Manning) SFI Forest Management Objective 3: The audit noted a few isolated weaknesses In implementation of riparian management practices by HPFP (e.g., minor sediment input into streams was noted in relation to 2 timber crossings that were left in place on partially completed winter harvest blocks, and the removal of a log fill crossing on 1 block was not complete with debris left in the drainage depression near the stream (although not directly in the stream)). (HPFP) SFI Forest Management Objective 4: A number of Quesnel site plans include text indicating that if piling occurs that it would be beneficial for furbearers to leave small critter piles (i.e., accumulations of logging slash) along timber edges and riparian areas. However, a field audit of 1 harvest block found that no critter piles were left within block. There is an opportunity for the operation to revise the wording of site plans to remove unnecessary text and more clearly define the expectations for practices such as the creation of critter piles. (Quesnel) SFI Forest Management Objective 9: The audit noted isolated weaknesses regarding the availability of key documents on active sites, as follows: (1) a contractor working on an active harvest block did not have a copy of the applicable site plan (Quesnel), and (2) two operators were found to not have copies of the applicable EMS procedures in their machines, and one operator was working without a block map (Hinton). SFI Forest Management Objective 9: The West Fraser Fuel Handling Guide lists which construction standards are acceptable for specification tanks >450 litres that are used for The Company s Alberta woodlands operations are significantly outperforming the coniferous and deciduous MAI (Mean Annual Increment) reforestation performance targets for the applicable FMAs in the large majority of instances. (Alberta Woodlands Operations)

9 Findings West Fraser Mills Ltd. B.C. and Alberta Woodlands 2016 Page 9 transporting fuel. However, the audit found that multiple contractors were using tanks that were built to a standard (UN 31A/Y) that is not referenced in the Fuel Handling Guide as an acceptable standard for use in Company forest operations. (Corporate) SFI Forest Management Objective 9: The audit noted a number of isolated weaknesses in the completion of inspections by Company staff, as follows: (1) a damaged culvert was noted on a recent harvest block that had not been identified in a recent inspection (Quesnel), (2) winter harvest blocks that are not fully completed may not receive a formal inspection after the end of the winter logging season (Hinton), (3) post-harvest comparisons of the actual visual quality achieved to that predicted in the pre-harvest visual impact assessment (VIA) are not conducted as a means to confirm that the required visual quality objectives (VQOs) were met (100 Mile), and (4) the Operation Monitoring Form used by Manning Forest Products is somewhat lacking in detail, which limits its usefulness as a means to demonstrate due diligence in monitoring compliance with applicable regulatory requirements (Manning). SFI Forest Management Objective 9: Isolated weaknesses in the documentation and/or implementation of divisional internal audit action plans were noted, as follows: (1) one of the action plans from the 2014 Hinton internal audit remains outstanding as two of five actions from the action plan related to road inspections have yet to be completed (Hinton), and (2) review of MFP s action plans to address the opportunities for improvement identified during the 2015 internal audit found that although preventive actions (to help reduce the potential for a recurrence of the issues that gave rise to these findings) had been developed and implemented, corrective actions (to address the site specific conditions associated with these findings) were often lacking. (Manning) SFI Forest Management Objective 13: The current Blue Ridge Communications Log includes a number of stakeholder concerns that have been raised over the past few years. However, in most cases the Communication Log lacks any comments regarding either the proposed mitigating strategies or the outcome of having implemented them. (Blue Ridge) SFI Forest Management Objective 15: The audit found that a number of action plans arising from the most recent Hinton management review were overdue. (Hinton) Corrective Action Plans Corrective action plans designed to address the root cause(s) of the non-conformities identified during the audit have been developed by West Fraser and reviewed and approved by KPMG PRI. The next surveillance audit will include a follow-up assessment of these issues to confirm that the corrective action plans developed to address them have been implemented as required. The forest management approach employed by the Company at its B.C. and Alberta woodlands operations is based on even-aged management, ground-based harvesting systems, clearcut harvesting with the retention of reserves of standing trees either within or adjacent to harvest areas (as depicted above), replanting of harvest areas within a few years with a mix of ecologically suited tree species and control of competing vegetation through the use of government-approved chemical herbicides (only some woodlands operations) and/or mechanical means. Contacts: Chris Ridley-Thomas, RPBio, EP(EMSLA) (604) David Bebb, RPF, EP(EMSLA) (604) This report may only be reproduced by the intended client, West Fraser Mills Ltd. with the express consent of KPMG. Information in this issue is of a general nature with respect to audit findings and is not intended to be acted upon without appropriate professional advice KPMG. All rights reserved. Through KPMG PRI, KPMG s Vancouver based forestry group is accredited to register forest companies to ISO 14001, CSA-SFM, SFI and PEFC certification standards.