Synopsis stakeholder consultations - BG, SK, VN
Synopsis of Stakeholder Consultations:
FSC Centralized National Risk Assessment
2016 - 2017
Contents
Introduction ............................................................................................................... 3
Consultation Details .................................................................................................. 3
Analysis of stakeholder comments ............................................................................ 4
Controlled wood category 1: Illegally harvested wood ........................................... 4
Bulgaria ............................................................................................................. 4
Viet Nam ........................................................................................................... 4
Controlled wood category 3: Wood harvested from forests in which high
conservation values are threatened by management activities .............................. 5
Bulgaria ............................................................................................................. 5
Slovakia ............................................................................................................. 5
Viet Nam ........................................................................................................... 6
Controlled wood category 4: Wood from forests being converted to plantations or
non-forest use ....................................................................................................... 7
Bulgaria ............................................................................................................. 7
Slovakia ............................................................................................................. 7
Viet Nam ........................................................................................................... 7
Controlled wood category 5: Wood from forests in which genetically modified trees
are planted ............................................................................................................ 9
Bulgaria ............................................................................................................. 9
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2016 - 2017
2017
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Introduction
During 2014-2016, the FSC Centralized National Risk Assessment (CNRA) was
conducted for controlled wood categories 1 (Illegally harvested wood), 2 (Wood
harvested in violation of traditional and human rights), 3 (Wood harvested from forests
in which high conservation values are threatened by management activities), 4 (Wood
from forests being converted to plantations or non-forest use) and 5 (Wood from forests
in which genetically modified trees are planted). For the following 8 countries,
assessments for some of these categories have been consulted and are now ready
for approval:
Bulgaria (cat. 1, 3, 4, 5)
Slovakia (cat. 3, 4)
Viet Nam (cat. 1, 3, 4)
Consulted Nov/Dec 2016
Consulted in May 2016
Consulted in May 2016
The assessments followed the process steps and requirements for FSC risk
assessments, as outlined in FSC-PRO-60-002a FSC National Risk Assessment
Framework. Those for controlled wood categories 1, 3, 4 and 5 were conducted by
NEPCon.
This report provides an overview of the results of the public consultation conducted by
FSC International on these risk assessments. It includes the details of the consultation,
and summaries of the stakeholders that responded and the feedback they provided,
and how the feedback was addressed. This information is organized broadly by FSC
controlled wood category, and then by country.
Consultation Details
As stated above, the risk assessments were published on the FSC International
website in May 2016 and March 2017 for the international consultations (scenario 3
countries) or on the FSC national websites for the national consultations (scenario 2
countries). All drafts were subject to stakeholder consultation for a period of 30 days.
Announcements of the international consultation were sent out via:
Technical news in the FSC newsletter/website
The FSC Network newsletter
Emails sent to mailing lists of certification bodies and the FSC network
The announcement informed stakeholders that the assessments were available and
accessible on the FSC website with information on how to participate in the
consultation.
All comments received were analysed, and were evaluated for relevance and reliability
(on the basis of being well justified and using evidence), and whether they conform to
the requirements of FSC-PRO-60-002a. Analysis of comments, and responses to
them, were formulated by FSC International and the consultants responsible for the
relevant assessment.
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2016 - 2017
2017
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Analysis of stakeholder comments
A general comment for risk assessments made for below categories is that control
measures provided in the CNRA are only recommended and will not be mandatory for
organizations to implement.
Controlled wood category 1: Illegally harvested wood
Draft assessments for the following countries were subject to consultation: Bulgaria,
Viet Nam. Stakeholders submitted comments on the risk assessments for the
following countries: Bulgaria.
The number of stakeholders, and their FSC membership/stakeholder type are
specified individually per country.
Bulgaria
Stakeholder composition
WWF Bulgaria
General comments:
No comments disagreed with the risk findings of the 21 indicators.
Comments were made regarding the wording of the overview (related to the
requirements for harvesting), asking to add wording according to the regulations of the
Forest Act.
Additionally, one comment was made regarding the terminology: “Harvesting permit"
should be replaced by "Felling permit”, so that the terminology of the CNRA is
aligned with the terminology of the Bulgarian Forest Act.
Analysis:
The consultant included the proposed wording related to harvesting in the overview
and in indicators 1.3 (Management and harvesting planning) and 1.4 (Harvesting
permits).
The suggestion to change “Harvesting permits” to “Felling permits” was considered a
translation issue and the terminology was not changed.
Viet Nam
No stakeholder comments received.
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2016 - 2017
2017
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Controlled wood category 3: Wood harvested from forests in
which high conservation values are threatened by
management activities
Draft assessments for the following countries were subject to consultation: Bulgaria,
Slovakia, Viet Nam. Stakeholders submitted comments on the risk assessments for
the following countries: Slovakia.
The number of stakeholders, and their FSC membership/stakeholder type are
specified individually per country.
Bulgaria
No stakeholder comments received.
Slovakia
Stakeholder composition
1 CH (independently)
6 CHs (collectively as CB stakeholders & clients)
General comments:
Comments were received “in general” and on categories 1, 2 and 3, even though
only categories 3 and 4 were subject to consultation. However, comments received
on already approved categories 1 and 2 did not change the risk designations for
these categories.
3.0: The stakeholders contested the claim that the term “HCV” is not agreed upon by
stating that there are other terms that have been used longer and more successfully
in Slovakia, and therefore should be equivalent. The consultant responded by citing
studies arguing against the identified equivalency and reiterated that it is a fact that
“HCV” is not used in main-stream Slovakian forest management. They also included
reference number in the risk description as in-text citations. The risk designation was
unchanged (low risk).
3.1: The stakeholders contested details of the indicator risk description, and argued
that the risk designation (specified risk) was inaccurate because specific kinds of
forests are strictly protected, and there are existing programs to ensure protection.
The stakeholders also contested the proposed CM as being unusable. The
consultant responded by adding to and enumerating the evidence sources and
including them in the risk description as in-text citations and by providing critique of
the programs mentioned. The risk designation was modified through the use of
functional scales to ensure those areas mentioned were changed to “low risk”.
Additionally, the consultant changed the proposed CM to be “more prescriptive” and
utilitarian.
3.3: The stakeholders contested the claim that nature conservation in general (and
Yew forest identification and protection) is weak due to the use of strictly protect
areas around known conservation-worthy species, in addition to numerous factual
contestations. Furthermore, the stakeholders stated that the CMs were designed to
financially benefit the members of the consulting team or the experts they consulted.
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2016 - 2017
2017
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The stakeholders argued for a change in the risk designation to “low risk”. The
consultant responded by providing a more nuanced explanation that where RTE are
known, they are well mapped, but they are not known in very many locations, in
addition to reiterating their evidence and adding their source numbers as in-text
references. The risk designation remained the same (“specified risk”).
3.4: The stakeholders contested the factual basis of the claims made by the
consultant, and challenged FSC as to the usability of the CMs. The stakeholder
argued that the identified at-risk forests were not being evaluated for their
hydrological function as they should be, but for their environmental function. The
stakeholders argued for a change in the risk designation to “low risk” for all forests.
The consultant responded by adding and reiterating sources as in-text citations, and
by explaining that the potential environmental damages described demonstrate that
the hydrological functioning cannot be reasonable assured. Furthermore, the
consultant defended the CM as feasible. The risk designation was refined, but
remained the same, as did the CM.
3.6: The stakeholders contested the use of Primeval Beech Forests as HCV 6 and
stated that it is always protected, arguing for a change to “low risk”. The consultant
responded by quoting the criteria upon which the forest was nominated as a
UNESCO world heritage site, which includes “areas of exceptional natural beauty
and aesthetic importance… the real impact that the appearance of Europe’s primeval
forests has exerted on the mindset of people and artists in particular, who in turn
have hugely influenced our culture and standards…”. Additionally, the consultant
reiterated that commercial logging has happened in these forests with varying levels
of protection. The risk designation remained unchanged (“specified risk for Primeval
Beech Forests…”)
Viet Nam
No stakeholder comments received.
Issue of interest:
HCVs 1 to 6 are threatened by illegal logging activities in natural forests in Viet Nam.
The consultant considered that indicators 3.1 to 3.6 should be either ‘low risk’ or ‘N/A’
because illegal logging is not a forest management activity. However, considering that
illegal logging causes loss or degradation of HCVs and that it is highly likely that the
timber derived from this illegal activity enters CW supply chains, PSU considered that
indicators 3.1 to 3.6 should be ‘specified risk’. A logging ban is also in place for natural
forests in Laos and indicators 3.1 to 3.6 were also designated ‘specified risk’ there.
PSU and the consultant came to an agreement and ‘specified risk’ was designated for
natural forests for indicators 3.1 to 3.6 in Viet Nam.
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2016 - 2017
2017
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Controlled wood category 4: Wood from forests being
converted to plantations or non-forest use
Draft assessments for the following countries were subject to consultation: Bulgaria,
Slovakia, Viet Nam. Stakeholders submitted comments on the risk assessments for
the following countries: none.
The number of stakeholders, and their FSC membership/stakeholder type are
specified individually per country.
Bulgaria
No stakeholder comments received.
Issue of interest:
The assessment based on legislation was not enough to conclude if the spatial
threshold is met. The assessment based on spatial data was done using data provided
by the government of Bulgaria and by FAO. Available spatial data is limited.
Based on the available spatial information, until 2015 conversion of natural forests in
Bulgaria was still below the spatial thresholds of indicator 4.1.
However, according to the assessment based on legality, the Forest Act allows the
spatially unrestricted conversion of forests into non-forest lands for the purpose of
urban development, industrial, sport or infrastructure projects.
The urbanisation of forest areas is also "stimulated" by the provisions of the Forest Act
which allow the sale of state-owned or municipal forests to private parties.
WWF Bulgaria states that the recently adopted Forest Act amendments doom
Bulgaria's forests because the amendments mean further deforestation and building
up of forest. They practically allow for the construction of ski and other facilities without
changing land use and for the acquisition of building rights on public land without
tender and for an indefinite period.
The present risk assessment shall deal with the current situation and at the time of
the assessment the available spatial data leads to a ‘low risk’ designation.
Slovakia
No stakeholder comments received.
Viet Nam
No stakeholder comments received.
Issue of interest:
The assessment based on spatial data was done by PSU using data provided by FAO.
Based on the spatial information, until 2015 conversion of natural forests in Viet Nam
was still below the spatial thresholds of indicator 4.1.
However, according to the assessment based on legality, there is a clear intention by
the government of Viet Nam to convert large forest areas to rubber plantations. Rubber
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2016 - 2017
2017
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export revenue has been among the top ten in terms of dollar export earners for the
country. This is a significant economic driver for conversion of natural forests to rubber
plantations. The timber derived from this conversion is highly likely to enter CW supply
chains. In principle, the law establishes that only degraded forests can be converted,
but the law is not enforced and natural forests have also been converted.
The existing national conditions and the requirement to apply the precautionary
approach in case of doubts, justify a specified risk designation.
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2016 - 2017
2017
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Controlled wood category 5: Wood from forests in which
genetically modified trees are planted
Draft assessments for the following countries were subject to consultation: Bulgaria.
Stakeholders submitted comments on the risk assessments for the following
countries: none.
Bulgaria
No stakeholder comments received.
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2016 - 2017
2017
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FSC Centralized National Risk Assessment
2016 - 2017
Contents
Introduction ............................................................................................................... 3
Consultation Details .................................................................................................. 3
Analysis of stakeholder comments ............................................................................ 4
Controlled wood category 1: Illegally harvested wood ........................................... 4
Bulgaria ............................................................................................................. 4
Viet Nam ........................................................................................................... 4
Controlled wood category 3: Wood harvested from forests in which high
conservation values are threatened by management activities .............................. 5
Bulgaria ............................................................................................................. 5
Slovakia ............................................................................................................. 5
Viet Nam ........................................................................................................... 6
Controlled wood category 4: Wood from forests being converted to plantations or
non-forest use ....................................................................................................... 7
Bulgaria ............................................................................................................. 7
Slovakia ............................................................................................................. 7
Viet Nam ........................................................................................................... 7
Controlled wood category 5: Wood from forests in which genetically modified trees
are planted ............................................................................................................ 9
Bulgaria ............................................................................................................. 9
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2016 - 2017
2017
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Introduction
During 2014-2016, the FSC Centralized National Risk Assessment (CNRA) was
conducted for controlled wood categories 1 (Illegally harvested wood), 2 (Wood
harvested in violation of traditional and human rights), 3 (Wood harvested from forests
in which high conservation values are threatened by management activities), 4 (Wood
from forests being converted to plantations or non-forest use) and 5 (Wood from forests
in which genetically modified trees are planted). For the following 8 countries,
assessments for some of these categories have been consulted and are now ready
for approval:
Bulgaria (cat. 1, 3, 4, 5)
Slovakia (cat. 3, 4)
Viet Nam (cat. 1, 3, 4)
Consulted Nov/Dec 2016
Consulted in May 2016
Consulted in May 2016
The assessments followed the process steps and requirements for FSC risk
assessments, as outlined in FSC-PRO-60-002a FSC National Risk Assessment
Framework. Those for controlled wood categories 1, 3, 4 and 5 were conducted by
NEPCon.
This report provides an overview of the results of the public consultation conducted by
FSC International on these risk assessments. It includes the details of the consultation,
and summaries of the stakeholders that responded and the feedback they provided,
and how the feedback was addressed. This information is organized broadly by FSC
controlled wood category, and then by country.
Consultation Details
As stated above, the risk assessments were published on the FSC International
website in May 2016 and March 2017 for the international consultations (scenario 3
countries) or on the FSC national websites for the national consultations (scenario 2
countries). All drafts were subject to stakeholder consultation for a period of 30 days.
Announcements of the international consultation were sent out via:
Technical news in the FSC newsletter/website
The FSC Network newsletter
Emails sent to mailing lists of certification bodies and the FSC network
The announcement informed stakeholders that the assessments were available and
accessible on the FSC website with information on how to participate in the
consultation.
All comments received were analysed, and were evaluated for relevance and reliability
(on the basis of being well justified and using evidence), and whether they conform to
the requirements of FSC-PRO-60-002a. Analysis of comments, and responses to
them, were formulated by FSC International and the consultants responsible for the
relevant assessment.
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2016 - 2017
2017
– 3 of 9 –
Analysis of stakeholder comments
A general comment for risk assessments made for below categories is that control
measures provided in the CNRA are only recommended and will not be mandatory for
organizations to implement.
Controlled wood category 1: Illegally harvested wood
Draft assessments for the following countries were subject to consultation: Bulgaria,
Viet Nam. Stakeholders submitted comments on the risk assessments for the
following countries: Bulgaria.
The number of stakeholders, and their FSC membership/stakeholder type are
specified individually per country.
Bulgaria
Stakeholder composition
WWF Bulgaria
General comments:
No comments disagreed with the risk findings of the 21 indicators.
Comments were made regarding the wording of the overview (related to the
requirements for harvesting), asking to add wording according to the regulations of the
Forest Act.
Additionally, one comment was made regarding the terminology: “Harvesting permit"
should be replaced by "Felling permit”, so that the terminology of the CNRA is
aligned with the terminology of the Bulgarian Forest Act.
Analysis:
The consultant included the proposed wording related to harvesting in the overview
and in indicators 1.3 (Management and harvesting planning) and 1.4 (Harvesting
permits).
The suggestion to change “Harvesting permits” to “Felling permits” was considered a
translation issue and the terminology was not changed.
Viet Nam
No stakeholder comments received.
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2016 - 2017
2017
– 4 of 9 –
Controlled wood category 3: Wood harvested from forests in
which high conservation values are threatened by
management activities
Draft assessments for the following countries were subject to consultation: Bulgaria,
Slovakia, Viet Nam. Stakeholders submitted comments on the risk assessments for
the following countries: Slovakia.
The number of stakeholders, and their FSC membership/stakeholder type are
specified individually per country.
Bulgaria
No stakeholder comments received.
Slovakia
Stakeholder composition
1 CH (independently)
6 CHs (collectively as CB stakeholders & clients)
General comments:
Comments were received “in general” and on categories 1, 2 and 3, even though
only categories 3 and 4 were subject to consultation. However, comments received
on already approved categories 1 and 2 did not change the risk designations for
these categories.
3.0: The stakeholders contested the claim that the term “HCV” is not agreed upon by
stating that there are other terms that have been used longer and more successfully
in Slovakia, and therefore should be equivalent. The consultant responded by citing
studies arguing against the identified equivalency and reiterated that it is a fact that
“HCV” is not used in main-stream Slovakian forest management. They also included
reference number in the risk description as in-text citations. The risk designation was
unchanged (low risk).
3.1: The stakeholders contested details of the indicator risk description, and argued
that the risk designation (specified risk) was inaccurate because specific kinds of
forests are strictly protected, and there are existing programs to ensure protection.
The stakeholders also contested the proposed CM as being unusable. The
consultant responded by adding to and enumerating the evidence sources and
including them in the risk description as in-text citations and by providing critique of
the programs mentioned. The risk designation was modified through the use of
functional scales to ensure those areas mentioned were changed to “low risk”.
Additionally, the consultant changed the proposed CM to be “more prescriptive” and
utilitarian.
3.3: The stakeholders contested the claim that nature conservation in general (and
Yew forest identification and protection) is weak due to the use of strictly protect
areas around known conservation-worthy species, in addition to numerous factual
contestations. Furthermore, the stakeholders stated that the CMs were designed to
financially benefit the members of the consulting team or the experts they consulted.
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2016 - 2017
2017
– 5 of 9 –
The stakeholders argued for a change in the risk designation to “low risk”. The
consultant responded by providing a more nuanced explanation that where RTE are
known, they are well mapped, but they are not known in very many locations, in
addition to reiterating their evidence and adding their source numbers as in-text
references. The risk designation remained the same (“specified risk”).
3.4: The stakeholders contested the factual basis of the claims made by the
consultant, and challenged FSC as to the usability of the CMs. The stakeholder
argued that the identified at-risk forests were not being evaluated for their
hydrological function as they should be, but for their environmental function. The
stakeholders argued for a change in the risk designation to “low risk” for all forests.
The consultant responded by adding and reiterating sources as in-text citations, and
by explaining that the potential environmental damages described demonstrate that
the hydrological functioning cannot be reasonable assured. Furthermore, the
consultant defended the CM as feasible. The risk designation was refined, but
remained the same, as did the CM.
3.6: The stakeholders contested the use of Primeval Beech Forests as HCV 6 and
stated that it is always protected, arguing for a change to “low risk”. The consultant
responded by quoting the criteria upon which the forest was nominated as a
UNESCO world heritage site, which includes “areas of exceptional natural beauty
and aesthetic importance… the real impact that the appearance of Europe’s primeval
forests has exerted on the mindset of people and artists in particular, who in turn
have hugely influenced our culture and standards…”. Additionally, the consultant
reiterated that commercial logging has happened in these forests with varying levels
of protection. The risk designation remained unchanged (“specified risk for Primeval
Beech Forests…”)
Viet Nam
No stakeholder comments received.
Issue of interest:
HCVs 1 to 6 are threatened by illegal logging activities in natural forests in Viet Nam.
The consultant considered that indicators 3.1 to 3.6 should be either ‘low risk’ or ‘N/A’
because illegal logging is not a forest management activity. However, considering that
illegal logging causes loss or degradation of HCVs and that it is highly likely that the
timber derived from this illegal activity enters CW supply chains, PSU considered that
indicators 3.1 to 3.6 should be ‘specified risk’. A logging ban is also in place for natural
forests in Laos and indicators 3.1 to 3.6 were also designated ‘specified risk’ there.
PSU and the consultant came to an agreement and ‘specified risk’ was designated for
natural forests for indicators 3.1 to 3.6 in Viet Nam.
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2016 - 2017
2017
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Controlled wood category 4: Wood from forests being
converted to plantations or non-forest use
Draft assessments for the following countries were subject to consultation: Bulgaria,
Slovakia, Viet Nam. Stakeholders submitted comments on the risk assessments for
the following countries: none.
The number of stakeholders, and their FSC membership/stakeholder type are
specified individually per country.
Bulgaria
No stakeholder comments received.
Issue of interest:
The assessment based on legislation was not enough to conclude if the spatial
threshold is met. The assessment based on spatial data was done using data provided
by the government of Bulgaria and by FAO. Available spatial data is limited.
Based on the available spatial information, until 2015 conversion of natural forests in
Bulgaria was still below the spatial thresholds of indicator 4.1.
However, according to the assessment based on legality, the Forest Act allows the
spatially unrestricted conversion of forests into non-forest lands for the purpose of
urban development, industrial, sport or infrastructure projects.
The urbanisation of forest areas is also "stimulated" by the provisions of the Forest Act
which allow the sale of state-owned or municipal forests to private parties.
WWF Bulgaria states that the recently adopted Forest Act amendments doom
Bulgaria's forests because the amendments mean further deforestation and building
up of forest. They practically allow for the construction of ski and other facilities without
changing land use and for the acquisition of building rights on public land without
tender and for an indefinite period.
The present risk assessment shall deal with the current situation and at the time of
the assessment the available spatial data leads to a ‘low risk’ designation.
Slovakia
No stakeholder comments received.
Viet Nam
No stakeholder comments received.
Issue of interest:
The assessment based on spatial data was done by PSU using data provided by FAO.
Based on the spatial information, until 2015 conversion of natural forests in Viet Nam
was still below the spatial thresholds of indicator 4.1.
However, according to the assessment based on legality, there is a clear intention by
the government of Viet Nam to convert large forest areas to rubber plantations. Rubber
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2016 - 2017
2017
– 7 of 9 –
export revenue has been among the top ten in terms of dollar export earners for the
country. This is a significant economic driver for conversion of natural forests to rubber
plantations. The timber derived from this conversion is highly likely to enter CW supply
chains. In principle, the law establishes that only degraded forests can be converted,
but the law is not enforced and natural forests have also been converted.
The existing national conditions and the requirement to apply the precautionary
approach in case of doubts, justify a specified risk designation.
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2016 - 2017
2017
– 8 of 9 –
Controlled wood category 5: Wood from forests in which
genetically modified trees are planted
Draft assessments for the following countries were subject to consultation: Bulgaria.
Stakeholders submitted comments on the risk assessments for the following
countries: none.
Bulgaria
No stakeholder comments received.
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2016 - 2017
2017
– 9 of 9 –