Colombo Energy, Inc SFI Fiber Sourcing Public Summary Surveillance Audit Report

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Introduction Colombo Energy, Inc. 2018 SFI Fiber Sourcing Public Summary Surveillance Audit Report The SFI Program of the Colombo Energy, Inc. of Greenwood, SC has achieved continued conformance with the SFI 2015-2019 Standard and Rules, Section 3 (excluding Appendix 1 Certified Sourcing), according to the NSF SFI FS Certification Audit Process. Colombo Energy consists of a pellet mill situated in the west central part of South Carolina that processes pine and hardwood into wood pellets. The facility is located near Greenwood, South Carolina. The Company s SFI program is managed by Ken Leach. The facility does not use purchased stumpage. The Company was initially certified in July 2016 and this is the second annual Surveillance Audit. The Company has a robust verifiable monitoring system to maintain rates of conformance to best management practices and to identify areas for improved performance. The system includes conducting BMP inspections on a sample of wood supplier tracts (the Company does not purchase Stumpage). The Company also reviews state BMP data and communicates the findings annually to management. The audit was performed by NSF on May 7-8, 2018 by an audit team headed by Norman Boatwright, Lead Auditor. Audit team members fulfill the qualification criteria for conducting audits contained in the SFI 2015-2019 Standards and Rules. The objective of the audit was to assess conformance of the firm s SFI Program to the requirements of the SFI 2015-2019 Standards and Rules, Section 3. The scope of the audit included procurement operations. Procurement operations occurring in the past 12 months were reviewed to ensure that the standards were met. In addition, SFI obligations to promote sustainable forestry practices, to seek legal compliance, and to incorporate continual improvement systems were within the scope of the audit. The 2015-2019 Sustainable Forestry Initiative Standard was used without modifying any requirements. Several of the SFI Indicators were outside of the scope of the company s program and were excluded from the scope of the audit as follows: Audit Process Core Indicators 1.1.2 and 2.1.1: The company does not purchase stumpage Core Indicator 4.1.5: Program to address risk Core Indicator 5.2: Research on genetically engineered trees Core Indicator 6.2.3: Logger Certification Programs Objective 8: Public Land Management responsibilities The review was governed by a detailed audit protocol designed to enable the audit team determine conformance with the applicable SFI requirements. The process included the assembly and review of audit evidence consisting of documents, interviews, and on-site inspections of ongoing or completed forest practices. Documents describing these activities were provided to the auditor in advance, and a sample of the available audit evidence was designated by the auditor for review. During the audit NSF reviewed a sample of the written documentation assembled to provide objective evidence of SFI FS Conformance. NSF also selected field sites for inspection based upon the risk of environmental impact, likelihood of occurrence, special features, and other criteria outlined in the NSF SFI-SOP. NSF also selected and interviewed stakeholders such as contract loggers, landowners and other interested parties, and interviewed employees within the organization to confirm that the SFI Standard was understood and actively implemented. The possible findings for specific SFI requirements included Full Conformance, Major Non-conformance, and Minor Nonconformance. This document is the property of NSF International. Page 1 of 5

Overview of Audit Findings Colombo was found to be in conformance with the standard with non-conformance or opportunities identified. A minor non-conformance was identified during the 2017 audit and the implementation of the approved corrective action was verified: 5.1.1 Financial or in-kind support of research to address questions of relevance in the region of operations. Examples could include, but are not limited to areas of forest productivity, water quality, biodiversity, community issues, or similar areas which build broader understanding of the benefits and impacts of forest management. Finding: The Company has not provided funding to support research since the 2016 certification audit. Resolution: Colombo Energy will join the NCASI s (National Council for Air and Stream Improvement, Inc.) Forest Biomass Cooperative who s goal is to sponsor and direct scientific investigations that will support sustainable production and use of biomass grown in forestry and agro forestry settings. We will look for other opportunities to support local research as well with an interest in gauging regeneration trends in the basin. This document is the property of NSF International. Page 2 of 5

General Description of Evidence of Conformity NSF s audit team used a variety of evidence to determine conformance. A general description of this evidence is provided below, organized by SFI Objective. Objective 1 Biodiversity in Fiber Sourcing To address the practice of sustainable forestry by conserving biological diversity. Summary of Evidence: The Company has completed a biodiversity risk assessment (GBLLC-DOC-018 FSC Controlled Wood Risk Assessment) of its wood supply basin as part of its chain of custody program. These assessments used information from World Resources Institute, The Nature Conservancy, NatureServe, Conservation International and State Natural Heritage programs to evaluate the level of risk the company may have when addressing the conservation of biodiversity. The Company participates in and supports the SC SIC which works to promote biodiversity by publishing A Landowner s Guide to Forestry in South Carolina which addresses biodiversity at the individual landowner level. Objective 2 Adherence to Best Management Practices To broaden the practice of sustainable forestry through the use of best management practices to protect water quality. Summary of Evidence: The Master Wood Products Purchase agreement contains a BMP requirement; a sample of supplier tracts are BMP audited, with the results, in conjunction with the available state BMP monitoring data, are summarized and reviewed by management. Objective 3 Use of Qualified Resource and Qualified Logging Professionals To encourage forest landowners to utilize the services of qualified logging professionals, certified logging professionals (where available) and qualified resource professionals. Objective 4 Legal and Regulatory Compliance Compliance with applicable federal, provincial, state and local laws and regulations. Objective 5 Forestry Research, Science, and Technology To support forestry research, science, and technology, upon which sustainable forest management decisions are based. Summary of Evidence: Confirmed via review of records on file and interviews that the Company support research and is aware of the effects of climate change of forest and wildlife and that the Company supports and participates in the SC SIC Objective 6 Training and Education To improve the implementation of sustainable forestry practices through appropriate training and education programs. Objective 7 Community Involvement and Landowner Outreach To broaden the practice of sustainable forestry through public outreach, education, and involvement and to support the efforts of SFI Implementation Committees. Summary of Evidence: The Company supports and participates in the SC SIC. The Company participates in efforts to support or promote conservation of managed forests through voluntary market-based incentive programs such as current-use taxation programs, Forest Legacy Program or conservation easements through the company s participation in the South Carolina SFI Implementation Committee and the Georgia and South Carolina Forestry Associations. Objective 9 Communications and Public Reporting To broaden the practice of sustainable forestry by documenting progress and opportunities for improvement. Summary of Evidence: Confirmed audit report was filed on time with SFI Inc. and that the Company maintains copies of previous reports. Objective 10 Management Review and Continual Improvement To promote continual improvement in the practice of sustainable forestry, and to monitor, measure, and report performance in achieving the commitment to sustainable forestry. Summary of Evidence: The Company s SFI Team annually meets to review the Sustainable Forestry Policy and Procurement Program to evaluate their effectiveness and has a system for annually collecting, reviewing and reporting information addressing progress in achieving the SFI Standard. This document is the property of NSF International. Page 3 of 5

Relevance of Forestry Certification Third-party certification provides assurance that forests are being managed under the principles of sustainable forestry, which are described in the Sustainable Forestry Initiative Standard as: 1. Sustainable Forestry To practice sustainable forestry to meet the needs of the present without compromising the ability of future generations to meet their own needs by practicing a land stewardship ethic that integrates reforestation and the managing, growing, nurturing and harvesting of trees for useful products and ecosystem services such as the conservation of soil, air and water quality, carbon, biological diversity, wildlife and aquatic habitats, recreation and aesthetics. 2. Forest Productivity and Health To provide for regeneration after harvest and maintain the productive capacity of the forest land base, and to protect and maintain long-term forest and soil productivity. In addition, to protect forests from economically or environmentally undesirable levels of wildfire, pests, diseases, invasive exotic plants and animals and other damaging agents and thus maintain and improve long-term forest health and productivity. 3. Protection of Water Resources To protect water bodies and riparian areas and to conform with forestry best management practices to protect water quality. 4. Protection of Biological Diversity To manage forests in ways that protect and promote biological diversity, including animal and plant species, wildlife habitats, and ecological or natural community types. 5. Aesthetics and Recreation To manage the visual impacts of forest operations, and to provide recreational opportunities for the public. 6. Protection of Special Sites To manage lands that are ecologically, geologically or culturally important in a manner that takes into account their unique qualities. 7. Responsible Fiber Sourcing Practices in North America To use and promote among other forest landowners sustainable forestry practices that are both scientifically credible and economically, environmentally and socially responsible. 8. Legal Compliance To comply with applicable federal, provincial, state, and local forestry and related environmental laws, statutes, and regulations. 9. Research To support advances in sustainable forest management through forestry research, science and technology. 10. Training and Education To improve the practice of sustainable forestry through training and education programs. 11. Community Involvement and Social Responsibility To broaden the practice of sustainable forestry on all lands through community involvement, socially responsible practices, and through recognition and respect of Indigenous Peoples rights and traditional forest-related knowledge. 12. Transparency To broaden the understanding of forest certification to the Fiber Sourcing Standard by documenting certification audits and making the findings publicly available. 13. Continual Improvement To continually improve the practice of forest management, and to monitor, measure and report performance in achieving the commitment to sustainable forestry. 14. Avoidance of Controversial Sources including Illegal Logging in Offshore Fiber Sourcing To avoid wood fiber from illegally logged forests when procuring fiber outside of North America, and to avoid sourcing fiber from countries without effective social laws. Source: Sustainable Forestry Initiative (SFI) Standard, 2015-2019 Edition This document is the property of NSF International. Page 4 of 5

For Additional Information Contact Norman Boatwright Daniel Freeman Ken Leach Forestry Program Manager NSF International PO Box 4021 Florence, SC 29502 Project Manager NSF International 789 N. Dixboro Road Ann Arbor, MI 48105 Manager, Wood Procurement Colombo Energy, Inc. 20 Colombo Drive Greenwood, SC 29646 843-229-1851 734-214-6228 864-554-4431 nboatwright12@gmail.com dfreeman@nsf.org Ken.leach@thenavigatorcompany.com END OF PUBLIC REPORT This document is the property of NSF International. Page 5 of 5