Synopsis stakeholder consultations - IN, LA, KR, UA

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
Lao People´s Democratic Republic .................................................................... 4
Republic of Korea .............................................................................................. 4
Ukraine .............................................................................................................. 4
Controlled wood category 2: Wood harvested in violation of traditional and human
rights ..................................................................................................................... 6
Lao People´s Democratic Republic .................................................................... 6
Republic of Korea .............................................................................................. 6
Ukraine .............................................................................................................. 6
Controlled wood category 3: Wood harvested from forests in which high
conservation values are threatened by management activities .............................. 7
India .................................................................................................................. 7
Lao People´s Democratic Republic .................................................................... 7

Republic of Korea .............................................................................................. 7
Ukraine .............................................................................................................. 7
Controlled wood category 4: Wood from forests being converted to plantations or
non-forest use ....................................................................................................... 9
India .................................................................................................................. 9
Lao People´s Democratic Republic .................................................................... 9
Republic of Korea .............................................................................................. 9
Ukraine ............................................................................................................ 10
Controlled wood category 5: Wood from forests in which genetically modified trees
are planted .......................................................................................................... 11
Lao People´s Democratic Republic .................................................................. 11
Republic of Korea ............................................................................................ 11
Ukraine ............................................................................................................ 11

SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC (CENTRALIZED) NATIONAL RISK
ASSESSMENT 2016 - 2017
2017
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Introduction

During 2014-2016, FSC Centralized National Risk Assessments (CNRAs) were
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).
In addition, and partly based on the previous CNRA work done, National Risk
Assessments (NRAs) are being developed by NRA working groups at country level.
For the following 4 countries, the assessments for some or all of the controlled wood
categories have been consulted and are now ready for approval:
CNRA India (cat. 3)
CNRA India (cat. 4)
CNRA
Lao
People´s
Democratic Republic
CNRA Republic of Korea
NRA Ukraine

Consulted Jan 2017

Consulted May-June 2017
Consulted May 2017
Consulted May 2017
Consulted Jan-Feb 2017

The (C)NRA 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 CNRA controlled wood categories 1, 4 and 5 were conducted
by NEPCon, those for controlled wood category 2 were conducted by Wolfgang Richert
and Leo van der Vlist and those for controlled wood category 3 were conducted by
Daemeter (India), Alexandre Boursier (Lao People´s Democratic Republic) and FSG
(Republic of Korea). The NRA Ukraine was only conducted by the NRA working group
without previous input from any of the CNRA consultants.
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 2017 for the international consultation (scenario 3 countries) or on the
FSC national websites for the national consultations (scenario 1 and scenario 2
countries). All drafts were subject to stakeholder consultation for a period of 30 days,
with the exception of the Ukraine draft which was consulted during 60 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.

SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC (CENTRALIZED) NATIONAL RISK
ASSESSMENT 2016 - 2017
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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.

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: Lao
People´s Democratic Republic, Republic of Korea, Ukraine. Stakeholders submitted
comments on the risk assessments for the following countries: Ukraine.
The number of stakeholders, and their FSC membership/stakeholder type are
specified individually per country.

Lao People´s Democratic Republic
Stakeholder composition
No stakeholder comments received.


Republic of Korea
Stakeholder composition
No stakeholder comments received.

Ukraine
Stakeholder composition
27 stakeholders representing all interest groups: 14 forest users, 3
representatives of woodworking enterprises, 4 representatives of educational
and scientific institutions, 2 territorial bodies of executive authority in the
sphere of forestry and hunting, 3 public organizations, 1 certification body.
General comments:
Comments were provided regarding the enforcement of applicable legislation related
to various indicators, including consideration of environmental requirements in the
process of management activities, management and harvest planning, health and
safety, and legal employment.
In general, the comments were related to the designated risk and the necessary control
measures.

SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC (CENTRALIZED) NATIONAL RISK
ASSESSMENT 2016 - 2017

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Analysis:
Over 60% of the comments were addressed and partially addressed. The rejection of
the remaining comments was substantiated by the corresponding expert and
supported by the working group.
A more detailed revision of the risk designations was done. The conclusions were
revised by increasing the quantity and diversity of information sources used (public
reports, articles and comments by independent observers, NGO publications, official
statistical information of state authorities and materials provided as an answer to
submitted requests). To ensure impartiality of the conclusions regarding risk,
preference was given to independent information sources, as well as to those with
greater public trust.
Taking into account the revised conclusions and using the precautionary approach,
specified risk was designated to specific indicators, in relation to environmental
requirements in the process of management activities, management and harvest
planning, health and safety, and legal employment.
The control measures were formulated in more detail to make them verifiable.


SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC (CENTRALIZED) NATIONAL RISK
ASSESSMENT 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: Lao
People´s Democratic Republic, Republic of Korea, Ukraine. Stakeholders submitted
comments on the risk assessments for the following countries: Ukraine.

Lao People´s Democratic Republic
Stakeholder composition
No stakeholder comments received.

Republic of Korea
Stakeholder composition
No stakeholder comments received.

Ukraine

Stakeholder composition
27 stakeholders representing all interest groups: 14 forest users, 3
representatives of woodworking enterprises, 4 representatives of educational
and scientific institutions, 2 territorial bodies of executive authority in the
sphere of forestry and hunting, 3 public organizations, 1 certification body.
General comments:
Comments were provided related to the upholding of rights of forestry enterprises’
employees, including those defined by the ILO Declaration on Fundamental Principles
and Rights at Work.
Analysis:
All the received remarks were approved or partially approved. The conclusions were
revised by increasing the quantity and diversity of information sources used.
Considering the precautionary approach, and to ensure impartiality of the conclusions
regarding risk levels, preference was given to independent information sources, as
well as to those with greater public trust (for example, the preference was given to
information provided by Central Committee of Trade Union of Forestry Employees).
One sub-indicator was added to indicator 2.2 Labor rights are upheld including rights
as specified in ILO Fundamental Principles and Rights at Work: “Health safety under
conditions of radioactive contamination” which is designated as ‘specified risk’. One
existing sub-indicator “Ban on self-organization and collective bargaining” was

changed from ‘low’ to ‘specified’ risk.

SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC (CENTRALIZED) NATIONAL RISK
ASSESSMENT 2016 - 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: India, Lao
People´s Democratic Republic, Republic of Korea, Ukraine. Stakeholders submitted
comments on the risk assessments for the following countries: Ukraine.
The number of stakeholders, and their FSC membership/stakeholder type are
specified individually per country.

India
No stakeholder comments received.

Lao People´s Democratic Republic

No stakeholder comments received.

Republic of Korea
No stakeholder comments received.

Ukraine
Stakeholder composition
27 stakeholders representing all interest groups: 14 forest users, 3
representatives of woodworking enterprises, 4 representatives of educational
and scientific institutions, 2 territorial bodies of executive authority in the
sphere of forestry and hunting, 3 public organizations, 1 certification body.
General comments:
Comments were provided related to the identification and classification of HCVs, as
well as to the enforcement of legislation for protection and conservation of forests with
special environmental and protection value. There were also comments related to the
proposed control measures.
Stakeholders commented on the need to o harmonize the conclusions of all indicators
in category 3 with the conclusions for indicators 1.9 and 1.10 (“Protected sites and
species” and “Environmental requirements”) in terms of potential threats to
biodiversity.
Stakeholders asked to consider the Emerald Network objects in the HCV assessment.
Stakeholders also asked to strengthen the argumentation on assessment of threats
related to HCV 4.
Analysis:
The analysis of the comments resulted in the revision and further elaboration of the
whole category in relation to identification of HCVs and assessment of threats, as well
as formulation of appropriate control measures. A small proportion of comments was
rejected. These comments were related to a lack of awareness by the stakeholders

SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC (CENTRALIZED) NATIONAL RISK
ASSESSMENT 2016 - 2017
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about the procedures regulating the NRA development (FSC-PRO-60-002 V3-0, FSCPRO-60-002a V1-0). The conclusions were revised by increasing the quantity and
diversity of information sources used.
The conclusions for all indicators in category 3 were harmonized with the conclusions
for indicators 1.9 and 1.10 (“Protected sites and species” and “Environmental
requirements”) in terms of potential threats to biodiversity.
Emerald Network objects were included to the list of HCVs, and threats for such objects
were assessed.
The threat assessment for HCV 4 was strengthened with additional involvement of
experts for this HCV.

SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC (CENTRALIZED) NATIONAL RISK
ASSESSMENT 2016 - 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: India, Lao
People´s Democratic Republic, Republic of Korea, Ukraine. Stakeholders submitted
comments on the risk assessments for the following countries: India, Republic of
Korea, Ukraine.
The number of stakeholders, and their FSC membership/stakeholder type are
specified individually per country.

India
Stakeholder composition
1 certification body, 1 certificate holder
General comments:
One comment was made suggesting to add statements about two sections of the
Forest Conservation Act (shift from forest land to non-forest land irrespective of cover
and penalties). One comment was made suggesting to add a statement about large
scale conversion from India’s State of Forest Report.
Analysis:
Both suggestions were included. They did not change the risk designation.
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 by PSU using
data provided by FAO, India’s State of Forest Report, and the Ministry of
Environment, Forests & Climate Change. According to the State Forest Report, there
has been large scale conversion of forest land in North East India due to shifting
cultivation. However, at the country level the forest area has still increased. The
‘specified risk’ threshold is not met and, therefore, the conclusion for indicator 4.1 is
‘low risk’.

Lao People´s Democratic Republic
Stakeholder composition
No stakeholder comments received.

Republic of Korea
Stakeholder composition
1 economic stakeholder
General comments:
A comment was made pointing out that the category at the time only includes a
legality assessment. The stakeholder asserted that the threshold of conversion to
non-forest usage is less than 0.5% per year, and the category should therefore be
designated as ‘low risk’.

SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC (CENTRALIZED) NATIONAL RISK
ASSESSMENT 2016 - 2017
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Analysis:
The stakeholder provided no sources to support their claim, and it was not supported
by the consultant’s later assessment, nor by the FAO data assessed by FSC.
Therefore, the risk designation remained ‘specified risk’.

Ukraine
Stakeholder composition
27 stakeholders representing all interest groups: 14 forest users, 3
representatives of woodworking enterprises, 4 representatives of educational
and scientific institutions, 2 territorial bodies of executive authority in the
sphere of forestry and hunting, 3 public organizations, 1 certification body.
General comments:
The comments referred to issues related to the legislative framework and to the
existing practice of conversion of forests to non-forest land categories.
The comments focused on the risk designation and the proposed control measures.
The need to strengthen the justification of risk designation by supplementing relevant
information sources was noted, as well as the need to review individual control
measures.
Analysis:
All the comments and suggestions from the stakeholders were taken into account,
which in turn required a more detailed revision of the risk designation. The conclusions
were revised by increasing the quantity and diversity of information sources used.
For forests of state ownership subordinated to the State Agency of Forest Resources
of Ukraine (SAFRU), the risk was changed from ‘low’ to ‘specified’. The risk designation
for the rest of the forests remains as ‘specified risk’.

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: Lao
People´s Democratic Republic, Republic of Korea, Ukraine. Stakeholders submitted
comments on the risk assessments for the following countries: Ukraine.

Lao People´s Democratic Republic
Stakeholder composition
No stakeholder comments received.

Republic of Korea
Stakeholder composition
No stakeholder comments received.

Ukraine
Stakeholder composition
27 stakeholders representing all interest groups: 14 forest users, 3
representatives of woodworking enterprises, 4 representatives of educational
and scientific institutions, 2 territorial bodies of executive authority in the
sphere of forestry and hunting, 3 public organizations, 1 certification body.
General comments:
The comments provided supported a ‘low risk’ designation. Suggestions were
provided to strengthen the conclusion on risk designation.
Analysis:
All the suggestions from the stakeholders were taken into account.

SYNOPSIS OF STAKEHOLDER CONSULTATION: FSC (CENTRALIZED) NATIONAL RISK
ASSESSMENT 2016 - 2017
2017
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