Synopsis stakeholder consultations - BG, EE, IN, LV, LT
Synopsis of Stakeholder Consultations:
FSC Centralized National Risk Assessment
2015 - 2016
Contents
Introduction ............................................................................................................... 3
Consultation Details .................................................................................................. 3
Analysis of stakeholder comments ............................................................................ 4
Controlled wood category 1: Illegally harvested wood ........................................... 4
Estonia .............................................................................................................. 4
India .................................................................................................................. 5
Latvia................................................................................................................. 6
Controlled wood category 2: Wood harvested in violation of traditional and human
rights ..................................................................................................................... 8
Bulgaria ............................................................................................................. 8
Estonia .............................................................................................................. 8
Controlled wood category 3: Wood harvested from forests in which high
conservation values are threatened by management activities ............................ 10
Lithuania .......................................................................................................... 10
Controlled wood category 4: Wood from forests being converted to plantations or
non-forest use ..................................................................................................... 10
Lithuania .......................................................................................................... 10
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2015 - 2016
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 5 countries,
assessments for some of these categories have been consulted and are now ready
for approval:
Bulgaria (cat. 2)
Estonia (cat. 1, 2)
India (cat. 1)
Latvia (cat. 1)
Lithuania (cat. 3, 4)
Consulted in May 2016
Consulted in March 2015
Consulted in March 2015
Consulted in March 2015
Consulted in March 2015
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 and 4 were conducted by
NEPCon, and those for controlled wood category 2 were conducted by Wolfgang
Richert Consulting and Leo van der Vlist.
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 either in March 2015 or in May 2016 and were subject to stakeholder
consultation for a period of 30 days. Announcements of the 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 2015 - 2016
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: Estonia,
India, Latvia. Stakeholders submitted comments on the risk assessments for the
following countries: Estonia, India, Latvia.
The number of stakeholders, and their FSC membership/stakeholder type are
specified individually per country.
Estonia
Stakeholder composition
1 Economic North (member)
1 Economic Other
WOLF/FSC Estonia (“inconsistencies”)
Indicator 1.6 Value added taxes and other sales taxes
Stakeholders provided information on new legislation that was not contained in the
initial assessment, stating that there was no need for the new and stricter value
added tax system. According to the Estonian Ministry of Finance & Estonian Tax and
Customs VAT violations in the Forestry sector had reduced.
Response:
This new information was evaluated as valid and the assessment was amended
accordingly, resulting in a change in the risk designation from specified to low risk.
1.11 Health and safety
Stakeholders provided correspondence from the “Work Inspectorate.” According to
their opinion the statistics from the Labour Inspectorate are not representative of the
forest sector because don’t show information about self-employed individuals, since
according to the legislation work inspectorate is not obliged to control them.
New information from the “Estonian Environment Agency and Labour Inspectorate”
about the volume of timber cut by chainsaw operators versus mechanical methods
was also provided, showing the total volume of timber cut in 2014 increased by 1
million m3 from 2013, while total workers accidents in a year decreased from 20 to
19.
Response:
The comment was noted and the risk assessment was amended accordingly,
resulting in a change in the risk designation from specified to low risk.
Indicator 1.12 Legal employment
The comment addressed weaknesses in the analysis, providing additional data on
taxation, unions and legal compliance. It also included one additional source for
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2015 - 2016
2017
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inclusion. It also questioned the level of impact regarding illegal employment of
chainsaw operators as possibly being disproportionally negative on the risk
assessment if these operators comprised a large portion of labour.
Response
The additional data and data source were incorporated in the risk assessment,
though the risk designation of low risk did not change due to the consultant following
up with more recent (2016) data which confirmed their prediction of continued
improvement in relation to illegal employment.
Indicator 1.21 Legislation requiring due diligence/due care procedures
The specified risk designation for this indicator was suggested to be changed to low
risk. The reasoning provided was that Estonian Forest Law requires an EUTRcompatible due diligence system. This together with an IT-based log transport Ewaybill system allows wood tracing online by companies, the Environmental
Inspectorate, Estonian Tax and Customs Board and the Police. It was stated that
there could have been a misunderstanding of the requirement for a written due
diligence system during the risk analysis.
Response:
This comment was noted and the CNRA/risk assessment amended accordingly.
India
No stakeholder comments received.
WOLF/FSC India (“inconsistencies”)
Indicator 1.1 Land tenure and management rights
It was identified that Category 2 found specified risk for the application of relevant
laws (specifically about indigenous peoples’ rights to land and self-governance). FSC
India provided two sources that questioned whether the legislation was effectively
enforced.
Response
The consultant did not provide any specific evidence to counter these claims. As
such, these sources were added to the text, and the designation of specified risk
expanded (it was already specified risk).
NB: No additional control measures were added.
NB: Indicator 1.18 text came to the conclusion of “low risk”, while the risk designation
was “specified risk”. After asking NEPCon, they asserted that it was an error, and the
risk designation was changed to “low risk”.
Indicator 1.12 Legal employment
It was identified that this indicator did not include any information on aspects of
violations of freedom of association, discrimination of women and specific ethnic
groups, and the risk to child labour (which are causes of specified risk in Category 2).
The consultant responded that, pursuant to the scope of FSC-PRO-60-002a (clause
3.1), relevant legislation that does not exist cannot be assessed. As such, they
added data on child labour, but not on the other issues. The resulting risk designation
distinguished between low risk for government forests and specified risk for private
forests (unchanged from previous version of the risk assessment).
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2015 - 2016
2017
– 5 of 10 –
Latvia
Stakeholder composition
LVM
WOLF (“inconsistencies”)
General comments:
Comments stated that there was some confusion regarding the overall structure of
the document, the accuracy of the data, interpretation of information and the lack of
clear data sources. It was stated that the information about the state-owned forest
lands in the overview of the assessment is incorrect.
Response:
It was maintained that the assessment was based on official statistical data of the
Ministry of Agriculture, Ministry of Environment, Ministry of Welfare and subordinated
institutions and that reliable source of information – databases of the Ministry of
Agriculture of the Republic of Latvia, statistical forest inventory results of the State
Forest Service or the Forest Research Institute “Silava” were references.
Indicator 1.2 Concession licenses
Comments stated that the analysis was only conducted for one forest owner in Latvia
and not the general situation. It was argued that the assessment does not contain
clear justification and analysis of whether the “Long-term Logging Contracts” (LLC),
concluded in the 1990s, are comparable to a concession license. It was also stated
that the analysis of LLC has been carried out without justification of the sources used
or for not including historical and national legislative context of the Latvian forest
sector. Information said to correctly describe the non-renewal of the LLC contracts
was provided.
Response:
Based on the criticism, a more profound argumentation, including historical context,
has been added for this indicator for the sake of clarity, and the assessment was
updated based on the new information which has been included in the final
assessment.
Indicator 1.4: Harvesting permits
Stakeholders described the analysis of this indicator as difficult to understand, stating
that it is unclear whether the issuance process of the felling licenses (permits) for all
forest owners, including state and local governments, churches, businesses, and
private owners, was included in the analysis. It was proposed that the assessment of
Indicator 1.4 (the felling license (permit) issuance process) is analysed as per
national legislation. Attention was also drawn to a perceived lack of analysis of the
donation process of the state-owned companies. The company donates a part of the
company’s profit to different social projects (which is strictly regulated by the law),
and therefore it is unacceptable to state that the company gives bribes.
Response:
A more detailed description of harvesting permit issuing process and the legal and
institutional framework was included in the analysis based on the comments.
Indicator 1.12 Legal employment
A comment from WOLF stated that the indicator did not provide analysis nor
conclusion on the topics of minimum working age and minimum age for personnel
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2015 - 2016
2017
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involved in hazardous work, legislation against forced and compulsory labour, and
discrimination and freedom of association.
Response:
Additional data regarding these topics were added to the risk assessment, with the
conclusion changed to specified risk.
NB: Indicator 2.2 has a note that predicates its risk finding of “low risk” on
confirmation by applicable legislation in category 1. Indicator 1.12 relates most
strongly to this topic, and its finding does not confirm 2.2’s risk designation. This is
justified by the understanding that specified risk for legality (Category 1) relates to
issues other than those assessed in Category 2.
Indictor 1.21 Legislation requiring due diligence/due care procedures
Stakeholders provided extensive information regarding EUTR implementation in
Latvia, to correct “mistakes” in the assessment. The final risk designation of
“specified risk” was assigned.
Response:
Text in the assessment was updated to reflect the additional information provided.
However it was still not sufficient enough to warrant a change in the risk designation.
The assessment refers to the relevant legal regulations regarding due diligence/due
care procedures, as per FSC requirements.
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2015 - 2016
2017
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Controlled wood category 2: Wood harvested in violation of
traditional and human rights
Draft assessments for the following countries were subject to consultation: Bulgaria,
Estonia. Stakeholders submitted comments on the risk assessments for the following
countries: Bulgaria, Estonia.
The number of stakeholders, and their FSC membership/stakeholder type are
specified individually per country.
Bulgaria
Stakeholder composition
1 CNRA coordinator (WWF)
General Comments:
Comment from stakeholder disagreed with the low risk finding for indicator 2.3. The
comment focused on the importance of local communities with traditional and legal
rights in the absence of indigenous or traditional peoples (IP/TP). It stated that reports
from WWF Bulgaria could be used to review that indicator assessment.
The source stated that local community rights, while formally protected by law, are not
always upheld. Local communities’ opinions are not always taken into account or
respected in forest management decisions. In particular, protection of forestdependent water sources, protection of municipal roads, and compensation for
property damage are highlighted as being deficient. It is stated that these risks are
widespread, and there are reports of them happening in FSC-certified forestry units.
Analysis:
Although it is acknowledged that IP/TP do not exist in Bulgaria, the consultant has
argued that these local communities are covered by the same traditional rights. Upon
reviewing the consultation feedback provided by the stakeholder, the consultant
agreed that there is evidence of possible violation of the traditional rights of local
communities. Therefore, the risk designation was changed to specified risk.
Estonia
Stakeholder composition
1 Economic North member/Accredited CB
1 Economic Other
WOLF/FSC Estonia (inconsistencies)
General Comments:
Comments from stakeholder supported the low risk designation for Indicators 2.1 and
2.3, and disagreed with the specified risk finding for indicator 2.2. Comments were
made in reference to the difference in the numbers of men and women working in the
Estonian forest sector and the pay gap between members of the two sexes, the
presence of illegal workers, and referenced the Category 1 assessment. It was stated
that indicator 1.12 for the category 1 assessment was evaluated as low risk, and that
the sources provided for that assessment could also be used to review the category 2
assessment.
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2015 - 2016
2017
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It was stated that a low number of women working in the forestry sector compared to
men does not indicate discrimination. Experience from forest management audits, and
correspondence with companies was said to indicate that many women work for
forestry companies in specialist or office roles, and that it is natural that the physical
work in the forest sector means less women are employed within it. Furthermore, few
women choose to study forestry or pursue a forestry career. With respect to the pay
gap between the two genders, it was stated that the evidence provided is not specific
to the Estonian forest sector and there was no information from local authorities. The
relevant Estonian statistics were said to not include the forestry sector, and that data
from Eurostat does not take into account the indicators of enterprises and institutions
with fewer than 10 employees, and excludes the earnings of employees in agriculture,
forestry and fishing and in public administration and defence. Statistics specific to the
forestry sector or some information from local authorities was expected.
Analysis:
There is very little data on the forestry sector. Other sector-specific information could
not be found, neither positive nor negative, and conclusions had to be drawn based on
the information referred to in the assessment. In review of the available data, it is
agreed with the stakeholders that (1) there is evidence that the gender pay gap is less
in the forestry sector compared to other Estonian sectors, and (2) there is no specific
evidence that this gender pay gap is very large in the forestry sector. Therefore the
risk determination has been changed to low risk of gender discrimination in this sector.
Comment: Regarding data on illegal workers, the statistic that “27% workers working
without the contract” was questioned if that is representative of the forest sector.
Analysis: The guidance provided are being followed and the issue of 'use of illegal
workers' is not an issue that should be included in Category 2 and the conclusions and
the risk assessment have been changed accordingly to low.
Comment: The statistic of 27% of workers being unregistered was indicated as being
high, with the addition that the Tax and Customs board determined that 60% of their
field audits of harvest sites included illegal labour.
Analysis: This information was included, but in accordance with the previous comment
and analysis (and in alignment with indicator 1.12), the specified risk of illegal labour
was removed from the risk designation, while the specified risk indication remained.
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2015 - 2016
2017
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Controlled wood category 3: Wood harvested from forests in
which high conservation values are threatened by
management activities
Lithuania
The assessment was done as part of a pilot testing (in 2013) and, based on the
national feedback received, the final report version was developed.
Controlled wood category 4: Wood from forests being
converted to plantations or non-forest use
Lithuania
The assessment was done as part of a pilot testing (in 2013) and, based on the
national feedback received, the final report version was developed.
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2015 - 2016
2017
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FSC Centralized National Risk Assessment
2015 - 2016
Contents
Introduction ............................................................................................................... 3
Consultation Details .................................................................................................. 3
Analysis of stakeholder comments ............................................................................ 4
Controlled wood category 1: Illegally harvested wood ........................................... 4
Estonia .............................................................................................................. 4
India .................................................................................................................. 5
Latvia................................................................................................................. 6
Controlled wood category 2: Wood harvested in violation of traditional and human
rights ..................................................................................................................... 8
Bulgaria ............................................................................................................. 8
Estonia .............................................................................................................. 8
Controlled wood category 3: Wood harvested from forests in which high
conservation values are threatened by management activities ............................ 10
Lithuania .......................................................................................................... 10
Controlled wood category 4: Wood from forests being converted to plantations or
non-forest use ..................................................................................................... 10
Lithuania .......................................................................................................... 10
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2015 - 2016
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 5 countries,
assessments for some of these categories have been consulted and are now ready
for approval:
Bulgaria (cat. 2)
Estonia (cat. 1, 2)
India (cat. 1)
Latvia (cat. 1)
Lithuania (cat. 3, 4)
Consulted in May 2016
Consulted in March 2015
Consulted in March 2015
Consulted in March 2015
Consulted in March 2015
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 and 4 were conducted by
NEPCon, and those for controlled wood category 2 were conducted by Wolfgang
Richert Consulting and Leo van der Vlist.
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 either in March 2015 or in May 2016 and were subject to stakeholder
consultation for a period of 30 days. Announcements of the 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 2015 - 2016
2017
– 3 of 10 –
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: Estonia,
India, Latvia. Stakeholders submitted comments on the risk assessments for the
following countries: Estonia, India, Latvia.
The number of stakeholders, and their FSC membership/stakeholder type are
specified individually per country.
Estonia
Stakeholder composition
1 Economic North (member)
1 Economic Other
WOLF/FSC Estonia (“inconsistencies”)
Indicator 1.6 Value added taxes and other sales taxes
Stakeholders provided information on new legislation that was not contained in the
initial assessment, stating that there was no need for the new and stricter value
added tax system. According to the Estonian Ministry of Finance & Estonian Tax and
Customs VAT violations in the Forestry sector had reduced.
Response:
This new information was evaluated as valid and the assessment was amended
accordingly, resulting in a change in the risk designation from specified to low risk.
1.11 Health and safety
Stakeholders provided correspondence from the “Work Inspectorate.” According to
their opinion the statistics from the Labour Inspectorate are not representative of the
forest sector because don’t show information about self-employed individuals, since
according to the legislation work inspectorate is not obliged to control them.
New information from the “Estonian Environment Agency and Labour Inspectorate”
about the volume of timber cut by chainsaw operators versus mechanical methods
was also provided, showing the total volume of timber cut in 2014 increased by 1
million m3 from 2013, while total workers accidents in a year decreased from 20 to
19.
Response:
The comment was noted and the risk assessment was amended accordingly,
resulting in a change in the risk designation from specified to low risk.
Indicator 1.12 Legal employment
The comment addressed weaknesses in the analysis, providing additional data on
taxation, unions and legal compliance. It also included one additional source for
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2015 - 2016
2017
– 4 of 10 –
inclusion. It also questioned the level of impact regarding illegal employment of
chainsaw operators as possibly being disproportionally negative on the risk
assessment if these operators comprised a large portion of labour.
Response
The additional data and data source were incorporated in the risk assessment,
though the risk designation of low risk did not change due to the consultant following
up with more recent (2016) data which confirmed their prediction of continued
improvement in relation to illegal employment.
Indicator 1.21 Legislation requiring due diligence/due care procedures
The specified risk designation for this indicator was suggested to be changed to low
risk. The reasoning provided was that Estonian Forest Law requires an EUTRcompatible due diligence system. This together with an IT-based log transport Ewaybill system allows wood tracing online by companies, the Environmental
Inspectorate, Estonian Tax and Customs Board and the Police. It was stated that
there could have been a misunderstanding of the requirement for a written due
diligence system during the risk analysis.
Response:
This comment was noted and the CNRA/risk assessment amended accordingly.
India
No stakeholder comments received.
WOLF/FSC India (“inconsistencies”)
Indicator 1.1 Land tenure and management rights
It was identified that Category 2 found specified risk for the application of relevant
laws (specifically about indigenous peoples’ rights to land and self-governance). FSC
India provided two sources that questioned whether the legislation was effectively
enforced.
Response
The consultant did not provide any specific evidence to counter these claims. As
such, these sources were added to the text, and the designation of specified risk
expanded (it was already specified risk).
NB: No additional control measures were added.
NB: Indicator 1.18 text came to the conclusion of “low risk”, while the risk designation
was “specified risk”. After asking NEPCon, they asserted that it was an error, and the
risk designation was changed to “low risk”.
Indicator 1.12 Legal employment
It was identified that this indicator did not include any information on aspects of
violations of freedom of association, discrimination of women and specific ethnic
groups, and the risk to child labour (which are causes of specified risk in Category 2).
The consultant responded that, pursuant to the scope of FSC-PRO-60-002a (clause
3.1), relevant legislation that does not exist cannot be assessed. As such, they
added data on child labour, but not on the other issues. The resulting risk designation
distinguished between low risk for government forests and specified risk for private
forests (unchanged from previous version of the risk assessment).
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2015 - 2016
2017
– 5 of 10 –
Latvia
Stakeholder composition
LVM
WOLF (“inconsistencies”)
General comments:
Comments stated that there was some confusion regarding the overall structure of
the document, the accuracy of the data, interpretation of information and the lack of
clear data sources. It was stated that the information about the state-owned forest
lands in the overview of the assessment is incorrect.
Response:
It was maintained that the assessment was based on official statistical data of the
Ministry of Agriculture, Ministry of Environment, Ministry of Welfare and subordinated
institutions and that reliable source of information – databases of the Ministry of
Agriculture of the Republic of Latvia, statistical forest inventory results of the State
Forest Service or the Forest Research Institute “Silava” were references.
Indicator 1.2 Concession licenses
Comments stated that the analysis was only conducted for one forest owner in Latvia
and not the general situation. It was argued that the assessment does not contain
clear justification and analysis of whether the “Long-term Logging Contracts” (LLC),
concluded in the 1990s, are comparable to a concession license. It was also stated
that the analysis of LLC has been carried out without justification of the sources used
or for not including historical and national legislative context of the Latvian forest
sector. Information said to correctly describe the non-renewal of the LLC contracts
was provided.
Response:
Based on the criticism, a more profound argumentation, including historical context,
has been added for this indicator for the sake of clarity, and the assessment was
updated based on the new information which has been included in the final
assessment.
Indicator 1.4: Harvesting permits
Stakeholders described the analysis of this indicator as difficult to understand, stating
that it is unclear whether the issuance process of the felling licenses (permits) for all
forest owners, including state and local governments, churches, businesses, and
private owners, was included in the analysis. It was proposed that the assessment of
Indicator 1.4 (the felling license (permit) issuance process) is analysed as per
national legislation. Attention was also drawn to a perceived lack of analysis of the
donation process of the state-owned companies. The company donates a part of the
company’s profit to different social projects (which is strictly regulated by the law),
and therefore it is unacceptable to state that the company gives bribes.
Response:
A more detailed description of harvesting permit issuing process and the legal and
institutional framework was included in the analysis based on the comments.
Indicator 1.12 Legal employment
A comment from WOLF stated that the indicator did not provide analysis nor
conclusion on the topics of minimum working age and minimum age for personnel
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2015 - 2016
2017
– 6 of 10 –
involved in hazardous work, legislation against forced and compulsory labour, and
discrimination and freedom of association.
Response:
Additional data regarding these topics were added to the risk assessment, with the
conclusion changed to specified risk.
NB: Indicator 2.2 has a note that predicates its risk finding of “low risk” on
confirmation by applicable legislation in category 1. Indicator 1.12 relates most
strongly to this topic, and its finding does not confirm 2.2’s risk designation. This is
justified by the understanding that specified risk for legality (Category 1) relates to
issues other than those assessed in Category 2.
Indictor 1.21 Legislation requiring due diligence/due care procedures
Stakeholders provided extensive information regarding EUTR implementation in
Latvia, to correct “mistakes” in the assessment. The final risk designation of
“specified risk” was assigned.
Response:
Text in the assessment was updated to reflect the additional information provided.
However it was still not sufficient enough to warrant a change in the risk designation.
The assessment refers to the relevant legal regulations regarding due diligence/due
care procedures, as per FSC requirements.
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2015 - 2016
2017
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Controlled wood category 2: Wood harvested in violation of
traditional and human rights
Draft assessments for the following countries were subject to consultation: Bulgaria,
Estonia. Stakeholders submitted comments on the risk assessments for the following
countries: Bulgaria, Estonia.
The number of stakeholders, and their FSC membership/stakeholder type are
specified individually per country.
Bulgaria
Stakeholder composition
1 CNRA coordinator (WWF)
General Comments:
Comment from stakeholder disagreed with the low risk finding for indicator 2.3. The
comment focused on the importance of local communities with traditional and legal
rights in the absence of indigenous or traditional peoples (IP/TP). It stated that reports
from WWF Bulgaria could be used to review that indicator assessment.
The source stated that local community rights, while formally protected by law, are not
always upheld. Local communities’ opinions are not always taken into account or
respected in forest management decisions. In particular, protection of forestdependent water sources, protection of municipal roads, and compensation for
property damage are highlighted as being deficient. It is stated that these risks are
widespread, and there are reports of them happening in FSC-certified forestry units.
Analysis:
Although it is acknowledged that IP/TP do not exist in Bulgaria, the consultant has
argued that these local communities are covered by the same traditional rights. Upon
reviewing the consultation feedback provided by the stakeholder, the consultant
agreed that there is evidence of possible violation of the traditional rights of local
communities. Therefore, the risk designation was changed to specified risk.
Estonia
Stakeholder composition
1 Economic North member/Accredited CB
1 Economic Other
WOLF/FSC Estonia (inconsistencies)
General Comments:
Comments from stakeholder supported the low risk designation for Indicators 2.1 and
2.3, and disagreed with the specified risk finding for indicator 2.2. Comments were
made in reference to the difference in the numbers of men and women working in the
Estonian forest sector and the pay gap between members of the two sexes, the
presence of illegal workers, and referenced the Category 1 assessment. It was stated
that indicator 1.12 for the category 1 assessment was evaluated as low risk, and that
the sources provided for that assessment could also be used to review the category 2
assessment.
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2015 - 2016
2017
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It was stated that a low number of women working in the forestry sector compared to
men does not indicate discrimination. Experience from forest management audits, and
correspondence with companies was said to indicate that many women work for
forestry companies in specialist or office roles, and that it is natural that the physical
work in the forest sector means less women are employed within it. Furthermore, few
women choose to study forestry or pursue a forestry career. With respect to the pay
gap between the two genders, it was stated that the evidence provided is not specific
to the Estonian forest sector and there was no information from local authorities. The
relevant Estonian statistics were said to not include the forestry sector, and that data
from Eurostat does not take into account the indicators of enterprises and institutions
with fewer than 10 employees, and excludes the earnings of employees in agriculture,
forestry and fishing and in public administration and defence. Statistics specific to the
forestry sector or some information from local authorities was expected.
Analysis:
There is very little data on the forestry sector. Other sector-specific information could
not be found, neither positive nor negative, and conclusions had to be drawn based on
the information referred to in the assessment. In review of the available data, it is
agreed with the stakeholders that (1) there is evidence that the gender pay gap is less
in the forestry sector compared to other Estonian sectors, and (2) there is no specific
evidence that this gender pay gap is very large in the forestry sector. Therefore the
risk determination has been changed to low risk of gender discrimination in this sector.
Comment: Regarding data on illegal workers, the statistic that “27% workers working
without the contract” was questioned if that is representative of the forest sector.
Analysis: The guidance provided are being followed and the issue of 'use of illegal
workers' is not an issue that should be included in Category 2 and the conclusions and
the risk assessment have been changed accordingly to low.
Comment: The statistic of 27% of workers being unregistered was indicated as being
high, with the addition that the Tax and Customs board determined that 60% of their
field audits of harvest sites included illegal labour.
Analysis: This information was included, but in accordance with the previous comment
and analysis (and in alignment with indicator 1.12), the specified risk of illegal labour
was removed from the risk designation, while the specified risk indication remained.
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2015 - 2016
2017
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Controlled wood category 3: Wood harvested from forests in
which high conservation values are threatened by
management activities
Lithuania
The assessment was done as part of a pilot testing (in 2013) and, based on the
national feedback received, the final report version was developed.
Controlled wood category 4: Wood from forests being
converted to plantations or non-forest use
Lithuania
The assessment was done as part of a pilot testing (in 2013) and, based on the
national feedback received, the final report version was developed.
SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC CENTRALIZED NATIONAL RISK
ASSESSMENT 2015 - 2016
2017
– 10 of 10 –