Forest Stewardship Council

Transcription

1 Type of Document: Scope of Document: Policy and Standards Unit National Forest Stewardship Standards pre-approval assessment Report. International Deadline for SDG/NO to Report back: Monday Date: 30/07/2013 Unit Responsible for drafting this Report: Policy and Standards Unit (PSU) Author of Report: Fon. Gordian Fanso; Policy Manager National Standard Contact Information: 1 of 13 FSC International Center GmbH Charles-de-Gaulle-Strasse Bonn Germany T +49 (0) F +49 (0) fsc@fsc.org Geschäftsführer Director: Andre de Freitas Handelsregister Commercial register: Bonn HRB12589

2 Name of Standard being assessed: Date submitted for assessment: December 2012 Certification Standard for Plantation Forests - South Africa Document Code: FSC-STD-ZAF South Africa Plantations EN Name of Group that developed the standard: South African FSC Standards Development Group. Address: j.scotcher@za.fsc.org Contact Person for the group: John Scotcher Expected deadline This evaluation report details all the elements to be evaluated by the Policy and Standards Unit (PSU) during the evaluations of Regional/National Forest Stewardship Standards. The suggestions for improvement made in this report are crucial to the approval of FSC-STD-ZAF (South Africa Plantations EN standard) The attached checklists are an integral part of this report. They should be read if further reference is needed. The following terms are used to determine importance of a suggestion for improvement: CONDITIONS to be incorporated in the standard to the satisfaction of the FSC Policy Manager for National standard within specified timeframe indicated at the beginning of this document. Failure to incorporate suggestions within the specified timeframes may result in standard not being submitted on time to the Policy and Standards Committee for decision. RECOMMENDATIONS to be incorporated in the standard at the discretion of the registered Standard Development Group; Failure to incorporate recommendations does not affect the standard being submitted to the FSC Policy and Standards Committee for decision 2 of 13

3 Assessment outcome: Certification Standard for Plantation Forests - South Africa: Summary of Assessment: The South African FSC forest stewardship standard for most of its parts meets the requirements of responsible Forest Stewardship as promoted by FSC. However, in order to fully meet expectations to confidently qualify as good forest stewardship, it is crucial for the standard development group to take into account the suggestions for improvement of the content made by the FSC Policy and Standards Unit. These suggestions are listed below: PART I. Process Assessment as per FSC-STD Process requirements for the development and maintenance of National Forest Stewardship Standards : The assessment of the process is done in the attached document (FSC checklist for standard develpoment Appraisal) please take a look at it and provide the needed information and documentation. 3 of 13

4 PART II: Content Assessment: The attached Pre-approval draft Version FSC-STD-ZAF South Africa Plantations EN FSC Standard has annotations in track changes that must be taken into account before the standard is submitted for approval. Pre-approval condition 1- Indicator and for Indicators structured in a similar way: The SA SDG shall define to which category size indicators are applicable. For example Small (for letter S), Large enterprise only (for letter L). Another way to reflect on this is to ask if an indicator in the SA standard is not applicable to large companies ( above 1000ha) what size would it be applicable to? FSC-STD in its section 3.6 requires: The standard shall include definitions to identify any categories of users to whom special provisions are applicable, e.g. 'small-scale', 'low intensity', 'community' or plantation forest management units section 4.6 Indicators shall apply to all forests covered by the scope of the standard, including smaller or lower intensity managed forests, unless otherwise specified with an explantation in the text. Less than 1000ha applies to SLIMF; greater than 1000ha applies to all other plantation foresta but companies with extensive landholdings and multisites are asked to meet additional criteria, mostly focussed should the SDG not want to change this, the default conclusion would be that indicator is applicable to all forest size and this shall be stated as such in the standard. 4 of 13

5 on providing documented evidence or procedures Pre-approval condition 2- Under criterion 1.4 the SDG shall include the following indicator Pre-approval condition 3- Pre-approval condition x In the event of any conflict being identified, the enterprise shall consult with the body responsible for interpretation of the FSC standard (i.e. either the certification body or the FSC National office), and/or with the relevant authority responsible for interpreting legal requirements, in an attempt to resolve the conflict. The SDG shall add the note under to cover the requirement of the criterion on delegation with free and informed consent. Also see the addition in in the annotated standard. Number indicator for large company under as a separate indicator Important to include indicator 2.3.x as a separate indicator to cover the full requirement of the standard. 5 of 13

6 Pre-approval condition 5- Under Define BEE in the text under defintions Pre-approval condition 6- Please provide guidance on what is meant with forestry sectoral determination and industry norms indicator Pre-approval condition 7- Pre-approval condition 8- Pre-approval condition 9- in the guidance column Indicator has been separated into two indicators. The SDG shall structure this requirement in as indicated in the annotated version of the SA standard the exception made that may imply conversion of plantations to agricultural land use shall be avoided by the SDG. Conversion is only allow within the conversion rules as clearly outlined in 6.10 Amended to remove agricultural land use only conversion for conservation purposes is permitted Provide a definition for TUP in the glossary of terms in the definition Separate this indicator into two as shown in the annotated version of the standard. Formatted: English (South Africa) 6 of 13

7 Pre-approval condition 10- Indicator 6.1.x shall be added as shown in the annotated version. This is to cover the criterion 6.1 in full as it requires assessment at landscape level. Pre-approval condition 10- The enterprise shall complete and document an assessment of the environmental impacts of its management activities at the level of the landscape in which it is situated and includes the identification of ecosystems found within the landscape (required for 6.4. compliance). Under 6.1 more indicators have been added. 6.1.y requires EIA to take into account HCV 6.1.z is an upgrade of the guidance note requiring forest management plans to identify actions to be taken to mitigate impact of Forest management activities on the environment. 7 of 13

8 Pre-approval condition 11- Pre-approval condition 12- Indicator shall be replaced with the following wordings The forest manager shall provide a written guarantee that no genetically modified organisms (including trees and other organisms) are used or are present in the enterprise's management, production or research program, and there shall be no evidence of such use., but we have removed the word research pending further discussuions with the FSC The indicators below are added in the SA standard to further strengthen the intent of C6.9 Indicator 6.9.x if an exotic species is newly introduced within the FMU, the enterprise shall have a documented policy and procedures specifying that if evidence of invasiveness or other adverse ecological impacts is found, the enterprise shall take prompt and effective action to eliminate the species from the FMU and from all other sites in which it may regenerate. 6.9.y If there is evidence that the species has significant adverse ecological impacts outside the areas in which it is already es- 8 of 13

9 Pre-approval condition 12-?? Pre-approval condition 13- tablished, but is not invasive, the forest enterprise shall put in place a plan to eradicate the species within the FMU in shortest financially feasible times pan. but amended to reflect SA legislation and the fact that while some of the commercial timber species are listed as invasive, they are permitted to be grown in what is termed a demarcated area which is the same area for which a water use licence has been issued. NOTE: Plantations grown in the grasslands/fynbos in South Africa use more water than the vegetation they replace and require authorisation in terms of a water use licence. The SDG shall replace with the following in order to align with recent FSC conversion rules: No conversion to plantations or non-forest lands occurs, except in circumstances where the conversion: a) Affects no more than 0.5% of the total area of the Management Unit in the current or any future year and does not result in a cumulative total area converted in excess of 5% of the 9 of 13

10 Management Unit since November 1994; b) Does not damage or threaten High Conservation Values, nor any sites or resources necessary to maintain or enhance those High Conservation Values; and, c) Will produce clear, substantial, additional, secure long-term conservation benefits in the Management Unit., including an explanation Pre-approval condition 14- Pre-approval condition 15- SDG shall fully write P7 to include subsection c as follows (c) Description of silvicultural and/or other management system, based on the ecology of the forest in question and information gathered through resource inventories. FSC criterion 8.1 shall be reoplaced with the correct wordings of FSC P&C V4 as below. In the event that the SDG decide to keep the newly introduced criterion as in SA standard, there shall be reasons submitted to PSU for doimng so. These reasons shall not conflict with FSC international requirements; The frequency and intensity of 10 of 13

11 monitoring should be determined by the scale and intensity of forest management operations as well as the relative complexity and fragility of the affected environment. Monitoring procedures should be consistent and replicable over time to allow comparison of results and assessment of change. Pre-approval condition 16- Indicator avoid using terms like adequate that can lead to unclear interpretations. Amended to exclude the word adequate Pre-approval condition 17- Indicator 9.1.x shall be included to strengthen the intent of the criterion 9.1 Pre-approval condition 18- Included as per condition The SDG shall include the three indicators in 10.4 and number them accordingly. These indicators are introduced in the stand- 11 of 13

12 ard to address the requirement of criterion The two indicators written by the group in the standard do not address sufficiently the requirements of the criterion. with some word changes Pre-approval condition 19- Indicator Conversion can only be allowed within the rules of FSC. Please refer to the annotated version to see suggested indicator for criterion 10.9 with no changes to the condition 12 of 13

13 Reference Recommendations Comments (PSU and SDG) Recommendation 1- SDG comments Recommendation 2- SDG comments Recommendation 3- SDG comments Indicator 1.1.2: Recommended to use the term shall and Forest Management Enterprise consistently through out the standard. Recommended to add: 1.1.x If any non-compliances with legal or regulatory requirements have been identified by the enterprise or by third parties in the previous five years, they shall have been documented by the enterprise, were promptly corrected, and effective action has been taken to prevent their recurrence Recommended to add the following indicator under Ownership and /or use rights shall be compatible with long-term compliance with the requirements of the FSC Principles and Criteria for Forest Stewardship. The insistence in using the terminology shall will no longer be of major problem in future as the revised P&C gets to it implementation. For now it is required to use the shall terminology to denote a requirement that must be met. This is to clarify what to do in the event of non-compliance in the past with legal or regulatory requiremnts. NB: Please check to make sure that the numbering of requirements in the standard are consistent. Also assign numbers to notes for easy reference. 13 of 13