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Page 1 of 3 Certificate holder: Howe Sound Pulp and Paper Corporation Certification Body (CB): Rainforest Alliance SmartWood Program FSC CW certificate code: RA-CW-004231 Date of CB approval: Date of risk assessment: August 2013 Address of CB: 65 Millet Street, Suite 201, Richmond Vermont USA Certificate holder address: 3838 Port Mellon Hwy, Port Mellon, BC V0N 2S0 Risk Assessor Mark Gage, RPF Districts, including countries covered with this risk assessment*: Southern Interior British Columbia (including the MFLNRO Cariboo, Thompson/Okanagan & Kootenay/Boundary Regions) *NB! If sources of information, justification, and/or risk levels vary for different districts, separate tables shall be made for each district. Category FSC Indicator Information Sources Used Brief justification Risk Designation 1. Illegally Harvested Wood The district of origin may be considered low risk in relation to illegal harvesting when all the following indicators related to forest governance are present: 1.1 Evidence of enforcement of logging related laws in the district Compliance and Enforcement Branch www.for.gov.bc.ca/hen/ Forest Act Part 5 Timber Marking & Part 6 Timber Scaling Timber Marking and Transportation Regulation www.for.gov.bc.ca/tasb/legsregs The Ministry of Forests, Lands and Natural Resource Operations - Compliance & Enforcement Branch enforces BC’s forestry laws and takes action where there is non-compliance. Strong legislation is in place in BC regarding the granting and regulation of harvesting rights and the marking, scaling and transportation of timber. See HSPP Chain of Custody Procedure 3.2.7 Risk Assessment of Non-certified Raw Material Low risk 1.2 There is evidence in the district demonstrating the legality of harvests and wood purchases that includes robust and effective systems for granting licenses and harvest permits. 1.3 There is little or no evidence or reporting of illegal harvesting in the district of origin. 1.4 There is a low perception of corruption related to the granting or issuing of harvesting permits and other areas of law enforcement related to harvesting and wood trade. Transparency International www.transparency.org http://cpi.transparency.org/cpi2012/results/ No mention of corruption issues in the district. Canada is ranked “very clean” in Transparency International’s Corruption Perceptions Index 2012 report (9 th in the world and score of 84). 2. Wood harvested in violation of traditional or civil rights The district of origin may be considered low risk in relation to the violation of traditional, civil and collective rights when all the following indicators are present: 2.1 There is no UN Security Council ban on timber exports from the country concerned; UN Security Council www.un.org/sc/committees There is currently no UN Security Council ban on timber exports from Canada. Low risk 2.2 The country or district is not designated a source of conflict timber (e.g. USAID Type 1 conflict timber) Global Policy Forum www.globalpolicy.org/security/natres/timbrindex. htm Canada is not designated as a source of conflict timber. 2.3 There is no evidence of child labour or violation of ILO Fundamental Principles and Rights at work taking place in forest areas in the district concerned Employment Standards Branch Employment Standards Regulation http://www.bclaws.ca/EPLibraries/bclaws_new/d ocument/ID/freeside/00_96113_01 Forest employment in Canada is regulated under federal and provincial labour codes, which prohibit child labour, protect the rights of workers to organize and are in conformity with fundamental ILO Conventions.

HSPP Risk Assessments - Howe Sound Pulp and Paper Ltd

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Page 1 of 3

Certificate holder: Howe Sound Pulp and Paper Corporation Certification Body (CB): Rainforest Alliance SmartWood Program

FSC CW certificate code: RA-CW-004231 Date of CB approval:

Date of risk assessment: August 2013 Address of CB: 65 Millet Street, Suite 201, Richmond Vermont USA

Certificate holder address: 3838 Port Mellon Hwy, Port Mellon, BC V0N 2S0 Risk Assessor Mark Gage, RPF

Districts, including countries covered with this risk assessment*:

Southern Interior British Columbia (including the MFLNRO Cariboo, Thompson/Okanagan & Kootenay/Boundary Regions)

*NB! If sources of information, justification, and/or risk levels vary for different districts, separate tables shall be made for each district.

Category FSC Indicator Information Sources Used Brief justification Risk

Designation 1. Illegally Harvested Wood The district of origin may be considered low risk in relation to illegal harvesting when all the following indicators related to forest governance are present:

1.1 Evidence of enforcement of logging related laws in the district

Compliance and Enforcement Branch www.for.gov.bc.ca/hen/ Forest Act Part 5 Timber Marking & Part 6 Timber Scaling Timber Marking and Transportation Regulation www.for.gov.bc.ca/tasb/legsregs

The Ministry of Forests, Lands and Natural Resource Operations - Compliance & Enforcement Branch enforces BC’s forestry laws and takes action where there is non-compliance. Strong legislation is in place in BC regarding the granting and regulation of harvesting rights and the marking, scaling and transportation of timber. See HSPP Chain of Custody Procedure 3.2.7 Risk Assessment of Non-certified Raw Material

Low risk

1.2 There is evidence in the district demonstrating the legality of harvests and wood purchases that includes robust and effective systems for granting licenses and harvest permits. 1.3 There is little or no evidence or reporting of illegal harvesting in the district of origin.

1.4 There is a low perception of corruption related to the granting or issuing of harvesting permits and other areas of law enforcement related to harvesting and wood trade.

Transparency International www.transparency.org http://cpi.transparency.org/cpi2012/results/

No mention of corruption issues in the district. Canada is ranked “very clean” in Transparency International’s Corruption Perceptions Index 2012 report (9th in the world and score of 84).

2. Wood harvested in violation of traditional or civil rights The district of origin may be considered low risk in relation to the violation of traditional, civil and collective rights when all the following indicators are present:

2.1 There is no UN Security Council ban on timber exports from the country concerned;

UN Security Council www.un.org/sc/committees

There is currently no UN Security Council ban on timber exports from Canada.

Low risk

2.2 The country or district is not designated a source of conflict timber (e.g. USAID Type 1 conflict timber)

Global Policy Forum www.globalpolicy.org/security/natres/timbrindex.htm

Canada is not designated as a source of conflict timber.

2.3 There is no evidence of child labour or violation of ILO Fundamental Principles and Rights at work taking place in forest areas in the district concerned

Employment Standards Branch Employment Standards Regulation http://www.bclaws.ca/EPLibraries/bclaws_new/document/ID/freeside/00_96113_01

Forest employment in Canada is regulated under federal and provincial labour codes, which prohibit child labour, protect the rights of workers to organize and are in conformity with fundamental ILO Conventions.

Page 2 of 3

2.4 There are recognized and equitable processes5 in place to resolve conflicts of substantial magnitude pertaining to traditional rights including use rights, cultural interests or traditional cultural identity in the district concerned

Aboriginal Affairs and Northern Development Canada www.aadnc-aandc.gc.ca/eng/1100100028568/1100100028572 Ministry of Aboriginal Relations and Reconciliation www.gov.bc.ca/arr/treaty/default.html

There are processes in place with both the governments of Canada and BC to negotiate and implement land claims and self government agreements.

2.5 There is no evidence of violation of the ILO Convention 169 on Indigenous and Tribal Peoples taking place in the forest areas in the district concerned.

Canadian Human Rights Commission http://www.chrc-ccdp.gc.ca/eng/content/equal-employment-opportunities

There is no evidence of violation. The Employment Equity Act is a federal law that requires employers to provide equal employment opportunities within your organization to four designated groups: women; Aboriginal peoples; persons with disabilities; and members of visible minorities.

3. Wood harvested from forest in which high conservation values are threatened by management activities The district of origin may be considered low risk in relation to threat to high conservation values if: a) indicator 3.1 is met; or b) indicator 3.2 eliminates (or greatly mitigates) the threat posed to the district of origin by non-compliance with 3.1.

3.1 Forest management activities in the relevant level (eco-region, sub-eco-region, local) do not threaten eco-regionally significant high conservation values.

Forest & Range Legislation & Regulation http://www.for.gov.bc.ca/tasb/legsregs Conservation International Biodiversity Hotspots http://www.biodiversityhotspots.org/Pages/default.aspx

Forest management activities are regulated by the Forest and Range Practices Act and other legislation and regulations that provide protection for high conservation values. There are no Conservation International Biodiversity Hotspots in British Columbia.

Low risk

3.2 A strong system of protection (effective protected areas and legislation) is in place that ensures survival of the HCVs in the ecoregion.

North Central Rockies Ecoregion http://worldwildlife.org/ecoregions/na0518 Fraser Plateau and Basin Ecoregion http://worldwildlife.org/ecoregions/na0514 Okanagan Dry Forest http://worldwildlife.org/ecoregions/na0522 Cascade Mountain Leeward Forest Ecoregion http://worldwildlife.org/ecoregions/na0507 Cariboo-Chilcotin Land Use Plan http://ilmbwww.gov.bc.ca/slrp/lrmp/williamslake/cariboo_chilcotin/index.html Kootenay-Boundary Regional Land Use Plan http://ilmbwww.gov.bc.ca/slrp/lrmp/cranbrook/kootenay/legaldocuments/index.html Land and Resource Planning - Southern BC http://ilmbwww.gov.bc.ca/category/region/southern-bc

The Southern Interior Region of BC includes 4 ecoregions as listed in the Information Sources Used column. Much of the Fraser Plateau and Basin Ecoregion falls within the boundaries of the Cariboo-Chilcotin regional land use planning process completed by the Commission on Resources and Environment. The result of this planning has been an increase in the system of protected areas and the establishment of objectives to manage for all non-timber and timber forest resources. Most of the North Central Rockies Ecoregion falls within the area of the Kootenay-Boundary Regional Land Use Plan, the result of intensive planning by the Commission on Resources and Environment. These plans resulted in substantial increase in protected areas and the development of guidelines for connectivity corridors to enhance the quality of habitat. There are numerous other district-level Strategic Land and Resource Plans within the Southern Interior Region of BC, which have also enhanced

Page 3 of 3

the system of protected areas. 4. Wood harvested from areas being converted from forests and other wooded ecosystems to plantations or non-forest uses The district of origin may be considered low risk in relation to conversion of forest to plantations or non-forest uses when the following indicator is present:

4.1 There is no net loss AND no significant rate of loss (> 0.5% per year) of natural forests and other naturally wooded ecosystems such as savannahs taking place in the eco-region in question.

The State of British Columbia’s Forests Third Edition 2010 www.for.gov.bc.ca/hfp/sof/2010/SOF_2010_Web.pdf

British Columbia contains vast and diverse forests and rangelands. Almost 60% (55 million hectares) of B.C.′s 95 million hectares is classified as forest land. Less than 3% of B.C.′s original forest has been converted to human (non-forest) use. Since 1850, ecosystem conversion to agriculture, reservoirs, urban areas, and other land uses has occurred on 2% of the province.

Low risk

5. Wood from forests in which genetically modified trees are planted The district of origin may be considered low risk in relation to wood from genetically modified trees when one of the following indicators is complied with:

a) There is no commercial use of genetically modified trees of the species concerned taking place in the country or district concerned

Tree Improvement Branch www.for.gov.bc.ca/hti/grm/generesource.htm

The Tree Improvement Branch of the Ministry of Forests, Lands and Natural Resource Operations is not involved in any genetic engineering, gene insertion, gene splicing or biotechnology that results in genetically modified organisms. The Branch ensures that no genetically modified tree seed is registered or used in operational forest planting on Crown land in British Columbia.

Low risk b) Licenses are required for commercial use of genetically modified trees and there are no licenses for commercial use c) It is forbidden to use genetically modified trees commercially in the country concerned

Page 1 of 3

Certificate holder: Howe Sound Pulp and Paper Corporation Certification Body (CB): Rainforest Alliance SmartWood Program

FSC CW certificate code: RA-CW-004231 Date of CB approval:

Date of risk assessment: August 2013 Address of CB: 65 Millet Street, Suite 201, Richmond Vermont USA

Certificate holder address: 3838 Port Mellon Hwy, Port Mellon, BC V0N 2S0 Risk Assessor Mark Gage, RPF

Districts, including countries covered with this risk assessment*:

Northern Interior British Columbia (including the MFLNRO Omineca, Northeast & Skeena Regions)

*NB! If sources of information, justification, and/or risk levels vary for different districts, separate tables shall be made for each district.

Category FSC Indicator Information Sources Used Brief justification Risk

Designation 1. Illegally Harvested Wood The district of origin may be considered low risk in relation to illegal harvesting when all the following indicators related to forest governance are present:

1.1 Evidence of enforcement of logging related laws in the district

Compliance and Enforcement Branch www.for.gov.bc.ca/hen/ Forest Act Part 5 Timber Marking & Part 6 Timber Scaling Timber Marking and Transportation Regulation www.for.gov.bc.ca/tasb/legsregs

The Ministry of Forests, Lands and Natural Resource Operations - Compliance & Enforcement Branch enforces BC’s forestry laws and takes action where there is non-compliance Strong legislation is in place in BC regarding the granting and regulation of harvesting rights and the marking, scaling and transportation of timber. See HSPP Chain of Custody Procedure 3.2.7 Risk Assessment of Non-certified Raw Material

Low risk

1.2 There is evidence in the district demonstrating the legality of harvests and wood purchases that includes robust and effective systems for granting licenses and harvest permits. 1.3 There is little or no evidence or reporting of illegal harvesting in the district of origin.

1.4 There is a low perception of corruption related to the granting or issuing of harvesting permits and other areas of law enforcement related to harvesting and wood trade.

Transparency International www.transparency.org http://cpi.transparency.org/cpi2012/results/

No mention of corruption issues in the district. Canada is ranked “very clean” in Transparency International’s Corruption Perceptions Index 2012 report (9th in the world and score of 84).

2. Wood harvested in violation of traditional or civil rights The district of origin may be considered low risk in relation to the violation of traditional, civil and collective rights when all the following indicators are present:

2.1 There is no UN Security Council ban on timber exports from the country concerned;

UN Security Council www.un.org/sc/committees

There is currently no UN Security Council ban on timber exports from Canada.

Low risk

2.2 The country or district is not designated a source of conflict timber (e.g. USAID Type 1 conflict timber)

Global Policy Forum www.globalpolicy.org/security/natres/timbrindex.htm

Canada is not designated as a source of conflict timber.

2.3 There is no evidence of child labour or violation of ILO Fundamental Principles and Rights at work taking place in forest areas in the district concerned

Employment Standards Branch Employment Standards Regulation http://www.bclaws.ca/EPLibraries/bclaws_new/document/ID/freeside/00_96113_01

Forest employment in Canada is regulated under federal and provincial labour codes, which prohibit child labour, protect the rights of workers to organize and are in conformity with fundamental ILO Conventions.

Page 2 of 3

2.4 There are recognized and equitable processes5 in place to resolve conflicts of substantial magnitude pertaining to traditional rights including use rights, cultural interests or traditional cultural identity in the district concerned

Aboriginal Affairs and Northern Development Canada www.aadnc-aandc.gc.ca/eng/1100100028568/1100100028572 Ministry of Aboriginal Relations and Reconciliation www.gov.bc.ca/arr/treaty/default.html

There are processes in place with both the governments of Canada and BC to negotiate and implement land claims and self government agreements.

2.5 There is no evidence of violation of the ILO Convention 169 on Indigenous and Tribal Peoples taking place in the forest areas in the district concerned.

Canadian Human Rights Commission http://www.chrc-ccdp.gc.ca/eng/content/equal-employment-opportunities

There is no evidence of violation. The Employment Equity Act is a federal law that requires employers to provide equal employment opportunities within your organization to four designated groups: women; Aboriginal peoples; persons with disabilities; and members of visible minorities.

3. Wood harvested from forest in which high conservation values are threatened by management activities The district of origin may be considered low risk in relation to threat to high conservation values if: a) indicator 3.1 is met; or b) indicator 3.2 eliminates (or greatly mitigates) the threat posed to the district of origin by non-compliance with 3.1.

3.1 Forest management activities in the relevant level (eco-region, sub-eco-region, local) do not threaten eco-regionally significant high conservation values.

Forest & Range Legislation & Regulation http://www.for.gov.bc.ca/tasb/legsregs Conservation International Biodiversity Hotspots http://www.biodiversityhotspots.org/Pages/default.aspx

Forest management activities are regulated by the Forest and Range Practices Act and other legislation and regulations that provide protection for high conservation values. There are no Conservation International Biodiversity Hotspots in British Columbia.

Low risk

3.2 A strong system of protection (effective protected areas and legislation) is in place that ensures survival of the HCVs in the ecoregion.

Fraser Plateau and Basin Ecoregion http://worldwildlife.org/ecoregions/na0514 Central BC Mountain Forest Ecoregion http://worldwildlife.org/ecoregions/na0509 Muskwa-Slave Lake Forests Ecoregion http://worldwildlife.org/ecoregions/na0610 Northern Cordillera Forests Ecoregion http://worldwildlife.org/ecoregions/na0613 Alberta-BC Foothills Forest Ecoregion http://worldwildlife.org/ecoregions/na0502 http://worldwildlife.org/places Fort St John Pilot Project http://fsjpilotproject.com/project.html Muskwa-Kechika Management Area http://www.muskwa-kechika.com/ Land and Resource Planning-Northern BC

The Northern Interior Region of BC includes 5 ecoregions as listed in the Information Sources Used column. None of the ecoregions are listed as a priority place by the WWF. The Fraser Plateau and Basin and the Central BC Mountain Forest are the most significant ecoregions in terms of commercial forestry operations. Much of these areas are managed under district-level joint licensee Sustainable Forest Management Plans. HCV issues of note in these plans include maintenance of critical winter range for mountain caribou and conservation of sites of special biological significance. A significant area of the Muskwa-Slave Lake Forests Ecoregion is within the Fort St John Forest Practices Code Pilot Project area. The Pilot Project participants have developed and manage according to a Sustainable Forest Management Plan that includes an objective to have areas of naturally occurring important ecosystems and rare physical environments protected at both broad and site-specific levels within the plan area

Page 3 of 3

http://www.ilmb.gov.bc.ca/category/region/northern-bc

The 6.4 million ha Muskwa-Kechika Management Area, which includes over 1 million ha of permanently protected areas, is within this region. The area is “a globally significant area of wilderness, wildlife and cultures, to be maintained in perpetuity”. There are numerous other district-level Strategic Land and Resource Plans within the Northern Interior Region of BC, which have also enhanced the system of protected areas.

4. Wood harvested from areas being converted from forests and other wooded ecosystems to plantations or non-forest uses The district of origin may be considered low risk in relation to conversion of forest to plantations or non-forest uses when the following indicator is present:

4.1 There is no net loss AND no significant rate of loss (> 0.5% per year) of natural forests and other naturally wooded ecosystems such as savannahs taking place in the eco-region in question.

The State of British Columbia’s Forests Third Edition 2010 www.for.gov.bc.ca/hfp/sof/2010/SOF_2010_Web.pdf

British Columbia contains vast and diverse forests and rangelands. Almost 60% (55 million hectares) of B.C.′s 95 million hectares is classified as forest land. Less than 3% of B.C.′s original forest has been converted to human (non-forest) use. Since 1850, ecosystem conversion to agriculture, reservoirs, urban areas, and other land uses has occurred on 2% of the province.

Low risk

5. Wood from forests in which genetically modified trees are planted The district of origin may be considered low risk in relation to wood from genetically modified trees when one of the following indicators is complied with:

a) There is no commercial use of genetically modified trees of the species concerned taking place in the country or district concerned

Tree Improvement Branch www.for.gov.bc.ca/hti/grm/generesource.htm

The Tree Improvement Branch of the Ministry of Forests, Lands and Natural Resource Operations is not involved in any genetic engineering, gene insertion, gene splicing or biotechnology that results in genetically modified organisms. The Branch ensures that no genetically modified tree seed is registered or used in operational forest planting on Crown land in British Columbia.

Low risk b) Licenses are required for commercial use of genetically modified trees and there are no licenses for commercial use c) It is forbidden to use genetically modified trees commercially in the country concerned

Page 1 of 3

Certificate holder: Howe Sound Pulp and Paper Corporation Certification Body (CB): Rainforest Alliance SmartWood Program

FSC CW certificate code: RA-CW-004231 Date of CB approval:

Date of risk assessment: August 2013 Address of CB: 65 Millet Street, Suite 201, Richmond Vermont USA

Certificate holder address: 3838 Port Mellon Hwy, Port Mellon, BC V0N 2S0 Risk Assessor : Mark Gage, RPF

Districts, including countries covered with this risk assessment*:

Coastal British Columbia (including the MFLNRO South Coast and West Coast Regions except Haida Gwaii District)

*NB! If sources of information, justification, and/or risk levels vary for different districts, separate tables shall be made for each district.

Category FSC Indicator Information Sources Used Brief justification Risk

Designation 1. Illegally Harvested Wood The district of origin may be considered low risk in relation to illegal harvesting when all the following indicators related to forest governance are present:

1.1 Evidence of enforcement of logging related laws in the district

Compliance and Enforcement Branch www.for.gov.bc.ca/hen/ Forest Act Part 5 Timber Marking & Part 6 Timber Scaling Timber Marking and Transportation Regulation www.for.gov.bc.ca/tasb/legsregs

The Ministry of Forests, Lands and Natural Resource Operations - Compliance & Enforcement Branch enforces BC’s forestry laws and takes action where there is non-compliance Strong legislation is in place in BC regarding the granting and regulation of harvesting rights and the marking, scaling and transportation of timber. See HSPP Chain of Custody Procedure 3.2.7 Risk Assessment of Non-certified Raw Material

Low risk

1.2 There is evidence in the district demonstrating the legality of harvests and wood purchases that includes robust and effective systems for granting licenses and harvest permits. 1.3 There is little or no evidence or reporting of illegal harvesting in the district of origin.

1.4 There is a low perception of corruption related to the granting or issuing of harvesting permits and other areas of law enforcement related to harvesting and wood trade.

Transparency International www.transparency.org http://cpi.transparency.org/cpi2012/results/

No mention of corruption issues in the district. Canada is ranked “very clean” in Transparency International’s Corruption Perceptions Index 2012 report (9th in the world and score of 84).

2. Wood harvested in violation of traditional or civil rights The district of origin may be considered low risk in relation to the violation of traditional, civil and collective rights when all the following indicators are present:

2.1 There is no UN Security Council ban on timber exports from the country concerned;

UN Security Council www.un.org/sc/committees

There is currently no UN Security Council ban on timber exports from Canada.

Low risk

2.2 The country or district is not designated a source of conflict timber (e.g. USAID Type 1 conflict timber)

Global Policy Forum www.globalpolicy.org/security/natres/timbrindex.htm

Canada is not designated as a source of conflict timber.

2.3 There is no evidence of child labour or violation of ILO Fundamental Principles and Rights at work taking place in forest areas in the district concerned

Employment Standards Branch Employment Standards Regulation http://www.bclaws.ca/EPLibraries/bclaws_new/document/ID/freeside/00_96113_01

Forest employment in Canada is regulated under federal and provincial labour codes, which prohibit child labour, protect the rights of workers to organize and are in conformity with fundamental ILO Conventions.

Page 2 of 3

2.4 There are recognized and equitable processes5 in place to resolve conflicts of substantial magnitude pertaining to traditional rights including use rights, cultural interests or traditional cultural identity in the district concerned

Aboriginal Affairs and Northern Development Canada www.aadnc-aandc.gc.ca/eng/1100100028568/1100100028572 Ministry of Aboriginal Relations and Reconciliation www.gov.bc.ca/arr/treaty/default.html

There are processes in place with both the governments of Canada and BC to negotiate and implement land claims and self government agreements.

2.5 There is no evidence of violation of the ILO Convention 169 on Indigenous and Tribal Peoples taking place in the forest areas in the district concerned.

Canadian Human Rights Commission http://www.chrc-ccdp.gc.ca/eng/content/equal-employment-opportunities

There is no evidence of violation. The Employment Equity Act is a federal law that requires employers to provide equal employment opportunities within your organization to four designated groups: women; Aboriginal peoples; persons with disabilities; and members of visible minorities..

3. Wood harvested from forest in which high conservation values are threatened by management activities The district of origin may be considered low risk in relation to threat to high conservation values if: a) indicator 3.1 is met; or b) indicator 3.2 eliminates (or greatly mitigates) the threat posed to the district of origin by non-compliance with 3.1.

3.1 Forest management activities in the relevant level (eco-region, sub-eco-region, local) do not threaten eco-regionally significant high conservation values.

Forest & Range Legislation & Regulation http://www.for.gov.bc.ca/tasb/legsregs Conservation International Biodiversity Hotspots http://www.biodiversityhotspots.org/Pages/default.aspx

Forest management activities are regulated by the Forest and Range Practices Act and other legislation and regulations that provide protection for high conservation values. There are no Conservation International Biodiversity Hotspots in British Columbia.

Low risk

3.2 A strong system of protection (effective protected areas and legislation) is in place that ensures survival of the HCVs in the ecoregion.

The HSPP coastal fibre supply comes from two ecoregions: 1. Central Pacific Coastal Forests (Vancouver

Island) http://worldwildlife.org/ecoregions/na0510 2. BC Mainland Coastal Forests http://worldwildlife.org/ecoregions/na0506 Vancouver Island Land Use Plan http://ilmbwww.gov.bc.ca/slrp/lrmp/nanaimo/vancouver_island/index.html Coast Land Use Decision http://ilmbwww.gov.bc.ca/slrp/lrmp/nanaimo/central_north_coast/index.html

Both of these ecoregions have undergone extensive land use planning that has included the designation of increased protected areas. The Commission on Resources and Environment developed land use planning recommendations which led to the BC government-approved Vancouver Island Land Use Plan. In the plan government made a commitment to increasing protected areas to 13% of the land area, with an emphasis on underrepresented areas. The Central and North Coast has undergone an extensive and broad stakeholder-based planning process resulting in protected areas of 1.8 million ha and a commitment by all parties to the implementation of Ecosystem Based Management.

Page 3 of 3

Land and Resource Planning – Coast BC http://ilmbwww.gov.bc.ca/category/region/coast-bc

Other district-level Land and ResourcePlans within the Coastal BC region have also enhanced the system of protected areas.

4. Wood harvested from areas being converted from forests and other wooded ecosystems to plantations or non-forest uses The district of origin may be considered low risk in relation to conversion of forest to plantations or non-forest uses when the following indicator is present:

4.1 There is no net loss AND no significant rate of loss (> 0.5% per year) of natural forests and other naturally wooded ecosystems such as savannahs taking place in the eco-region in question.

The State of British Columbia’s Forests Third Edition 2010 www.for.gov.bc.ca/hfp/sof/2010/SOF_2010_Web.pdf

British Columbia contains vast and diverse forests and rangelands. Almost 60% (55 million hectares) of B.C.′s 95 million hectares is classified as forest land. Less than 3% of B.C.′s original forest has been converted to human (non-forest) use. Since 1850, ecosystem conversion to agriculture, reservoirs, urban areas, and other land uses has occurred on 2% of the province.

Low risk

5. Wood from forests in which genetically modified trees are planted The district of origin may be considered low risk in relation to wood from genetically modified trees when one of the following indicators is complied with:

a) There is no commercial use of genetically modified trees of the species concerned taking place in the country or district concerned

Tree Improvement Branch www.for.gov.bc.ca/hti/grm/generesource.htm

The Tree Improvement Branch of the Ministry of Forests, Lands and Natural Resource Operations is not involved in any genetic engineering, gene insertion, gene splicing or biotechnology that results in genetically modified organisms. The Branch ensures that no genetically modified tree seed is registered or used in operational forest planting on Crown land in British Columbia.

Low risk b) Licenses are required for commercial use of genetically modified trees and there are no licenses for commercial use c) It is forbidden to use genetically modified trees commercially in the country concerned

Howe Sound Pulp and Paper Corporation – Controlled Wood Risk Assessment – Oregon

Page 1 of 4

Certificate holder: Howe Sound Pulp and Paper Corporation Certification Body (CB): Rainforest Alliance SmartWood Program

FSC CW certificate code: RA-CW-004231 Date of CB approval:

Date of risk assessment: July 2013 Address of CB: 65 Millet Street, Suite 201, Richmond Vermont USA

Certificate holder address: 3838 Port Mellon Hwy, Port Mellon, BC V0N 2S0 Risk Assessor: Mark Gage, RPF

Districts, including countries covered with this risk assessment*:

Oregon, USA

*NB! If sources of information, justification, and/or risk levels vary for different districts, separate tables shall be made for each district.

Category FSC Indicator Information Sources Used Brief justification Risk

Designation 1. Illegally Harvested Wood The district of origin may be considered low risk in relation to illegal harvesting when all the following indicators related to forest governance are present:

1.1 Evidence of enforcement of logging related laws in the district

Oregon Forest Practices Act http://www.oregon.gov/ODF/privateforests/Pages/fpaKeys.aspx State owned lands: http://arcweb.sos.state.or.us/pages/rules/oars_600/oar_629/629_034.html

Legislation is in place in Oregon regarding the granting and regulation of harvesting rights and the marking, scaling and transportation of timber. The Oregon FPA and forest practice rules apply to any of the activities that are part of the commercial growing and harvesting of forest trees. See HSPP Chain of Custody Procedure Sec. 3.2.7 Risk Assessment of Non-certified Raw Material

Low risk

1.2 There is evidence in the district demonstrating the legality of harvests and wood purchases that includes robust and effective systems for granting licenses and harvest permits. 1.3 There is little or no evidence or reporting of illegal harvesting in the district of origin.

1.4 There is a low perception of corruption related to the granting or issuing of harvesting permits and other areas of law enforcement related to harvesting and wood trade.

Transparency International www.transparency.org www.transparency.org/policy_research/surveys_indices/cpi/2010/results

No mention of corruption issues in district. The United States scored 7.1 out of 10 in Transparency International’s Corruption Perceptions Index 2010 report.

2. Wood harvested in violation of traditional or civil rights The district of origin may be considered low risk in relation to the violation of traditional, civil and collective rights when all the following indicators are present:

2.1 There is no UN Security Council ban on timber exports from the country concerned;

UN Security Council www.un.org/sc/committees

There is no UN Security Council ban on timber exports from Oregon.

Low risk

2.2 The country or district is not designated a source of conflict timber (e.g. USAID Type 1 conflict timber)

Global Policy Forum www.globalpolicy.org/security/natres/timbrindex.htm USAID http://www.usaid.gov/gsearch/16%20conflict%20timber

Oregon is not designated as a source of conflict timber by Global Policy Forum or USAID.

2.3 There is no evidence of child labour or violation of ILO Fundamental Principles and Rights at work taking place in forest areas in the district concerned

Oregon State Legislature http://www.oregon.gov/boli/whd/clu/pages/index.aspx

Oregon's child labor law gives the Wage and Hour Commission authority to regulate working conditions for minors under age 18 working in Oregon. All employers in Oregon are subject to the state rules providing for minors' working

Howe Sound Pulp and Paper Corporation – Controlled Wood Risk Assessment – Oregon

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conditions (meal periods, rest periods, adequate work, weight lifting, etc.). There is no evidence of violation of ILO Fundamental Principles and Rights in the district.

2.4 There are recognized and equitable processes in place to resolve conflicts of substantial magnitude pertaining to traditional rights including use rights, cultural interests or traditional cultural identity in the district concerned

Oregon Board of Forestry http://www.oregon.gov/odf/Pages/board/index.aspx Oregon Forest Practices Act

There are a number of avenues for the public and FN groups to be involved in the forest management planning in Oregon. In addition, all timber operators must notify the Oregon Department of Forestry at least 15 days before starting operations to allow time for cooperative discussion before activities begin.

2.5 There is no evidence of violation of the ILO Convention 169 on Indigenous and Tribal Peoples taking place in the forest areas in the district concerned.

Oregon Department of Land Conservation and Development http://www.oregon.gov/LCD/Pages/govtogov.aspx

While the US is not a signatory to ILO Convention 169, there is no evidence of violation of indigenous peoples’ rights in Oregon forests. Oregon Department of Land Conservation and Development website references legislation and orders that have been passed to protect tribal peoples rights. This includes the requirement that state agencies develop and implement policies on tribal relations. Agency managers and others who communicate with the Tribes are to be trained in tribal matters, participate in annual meetings and prepare annual reports. An executive order established a process to "assist in resolving potential conflicts, maximize key inter-governmental relations, and enhance an exchange of ideas and resources for the greater good of all of Oregon´s citizens."

3. Wood harvested from forest in which high conservation values are threatened by management activities The district of origin may be considered low risk in relation to threat to high conservation values if: a) indicator 3.1 is met; or b) indicator 3.2 eliminates (or greatly mitigates) the threat posed to the district of origin by non-

3.1 Forest management activities in the relevant level (eco-region, sub-eco-region, local) do not threaten eco-regionally significant high conservation values.

Conservation International Biodiversity Hotspots http://www.conservation.org/where/priority_areas/hotspots/north_central_america/California-Floristic-Province/Pages/default.aspx Federal Agencies (BLM) http://www.blm.gov/or/plans/index.php Oregon Forest Practices Act (FPA) http://www.oregon.gov/odf/privateforests/pages/fpakeys.aspx

There is one Conservation International Biodiversity Hotspots in Oregon – the California Floristic Province. As one of only five areas with a Mediterranean-type climate in the world — all of which are on the hotspot list — the California Floristic Province is characterized by hot, dry summers and cool, wet winters. The region contains a wide variety of ecosystems The National Environmental Policy Act (NEPA) ensures that the BLM (and other Federal

Low risk

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compliance with 3.1. Oregon Forest Law (Oregon Revised Statutes http://www.leg.state.or.us/ors/527.html

Agencies) considers the impact of timber harvesting on endangered or threatened species or ecosystems. On state-owned and private land forest management activities are regulated by the Forest Practices Act and other legislation and regulations that provide protection for high conservation values.

3.2 A strong system of protection (effective protected areas and legislation) is in place that ensures survival of the HCVs in the ecoregion.

Oregon Department of Land Conservation and Development http://www.oregon.gov/LCD/Pages/goals.aspx Endangered Species List http://ecos.fws.gov/tess_public/pub/stateListingAndOccurrenceIndividual.jsp?state=OR&s8fid=112761032792&s8fid=112762573902 Endangered Species Act (ESA) http://www.fws.gov/endangered/about/index.html

State protection: Oregon´s statewide goals are achieved through local comprehensive planning. State law requires each city and county to adopt a comprehensive plan and the zoning and land-division ordinances needed to put the plan into effect. The local comprehensive plans must be consistent with the Statewide Planning Goals. Plans are reviewed for such consistency by the state´s Land Conservation and Development Commission (LCDC). When LCDC officially approves a local government´s plan, the plan is said to be acknowledged. It then becomes the controlling document for land use in the area covered by that plan. Oregon´s planning laws apply not only to local governments but also to special districts and state agencies. The laws strongly emphasize coordination -- keeping plans and programs consistent with each other, with the goals, and with acknowledged local plans. Federal protection: The ESA directs all Federal agencies to use their existing authorities to conserve threatened and endangered species and, in consultation with the Service, to ensure that their actions do not jeopardize listed species or destroy or adversely modify critical habitat. This applies to management of Federal lands as well as other Federal actions that may affect listed species, such as Federal approval of private activities through the issuance of Federal permits, licenses, or other actions

Howe Sound Pulp and Paper Corporation – Controlled Wood Risk Assessment – Oregon

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4. Wood harvested from areas being converted from forests and other wooded ecosystems to plantations or non-forest uses The district of origin may be considered low risk in relation to conversion of forest to plantations or non-forest uses when the following indicator is present:

4.1 There is no net loss AND no significant rate of loss (> 0.5% per year) of natural forests and other naturally wooded ecosystems such as savannahs taking place in the eco-region in question.

Oregon Forest Area http://www.oregon.gov/odf/pages/resource_planning/fa5.aspx Oregon Forest Assessment and Resource Strategy 2010 http://www.oregon.gov/ODF/Pages/resource_planning/2010fars.aspx

Oregon's forests are held by a variety of owners - federal, tribal, state, and local governments, as well as private industrial owners and family forest or small woodland landowners. Note that federal agencies are the majority owners (about 60%) of forestland in Oregon, particularly in eastern Oregon. The 2010 State of Oregon Statewide Forest Assessment and Resource Strategy is designed to identify Oregon’s current forest resources and develop a strategy for integrating federal, state and private forestry programs with efforts to address issues such as wildfire, keeping working forests as forestland, promoting diversity of forest habitats for fish and wildlife, controlling invasive species and managing climate change. The Forest Assessment will identify high priority areas within Oregon for taking action. The primary deliverables from the project are a Statewide Assessment, which identifies current forest resources, conditions and trends in Oregon, and the Resource Strategy, a document that makes recommendations for high priority action regarding Oregon’s forests and serves as an operating plan leading to development of the next assessment in 2015. Most references indicate the harvest rates have significantly decreased in Oregon over the past decade, particularly on BLM (federal) lands. State legislation requires the sustainability of the harvest rate.

Low risk

5. Wood from forests in which genetically modified trees are planted The district of origin may be considered low risk in relation to wood from genetically modified trees when one of the following indicators is complied with:

a) There is no commercial use of genetically modified trees of the species concerned taking place in the country or district concerned

FAO Forest Genetic Resources Working Paper www.fao.org/docrep/008/ae574e/AE574E00.htm#TopOfPage

There is no commercial use of genetically modified trees in Oregon.

Low risk b) Licenses are required for commercial use of genetically modified trees and there are no licenses for commercial use c) It is forbidden to use genetically modified trees commercially in the country concerned

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Certificate holder: Howe Sound Pulp and Paper Ltd. Partnership Certification Body (CB): Rainforest Alliance SmartWood Program

FSC CW certificate code: RA-CW-004231 Date of CB approval:

Date of risk assessment: August 2013 Address of CB: 65 Millet Street, Suite 201, Richmond Vermont USA

Certificate holder address: 3838 Port Mellon Hwy, Port Mellon, BC V0N 2S0 Risk Assessor Mark Gage, RPF

Districts, including countries covered with this risk assessment*:

Washington State – Everson/Sumas area (West of Cascades)

*NB! If sources of information, justification, and/or risk levels vary for different districts, separate tables shall be made for each district.

Category FSC Indicator Information Sources Used Brief justification Risk

Designation 1. Illegally Harvested Wood The district of origin may be considered low risk in relation to illegal harvesting when all the following indicators related to forest governance are present:

1.1 Evidence of enforcement of logging related laws in the district

Washington State DNR Forest Practices Board www.dnr.wa.gov/AboutDNR/BoardsCouncils/FPB/Pages/Home.aspx www.dnr.wa.gov/BusinessPermits/Topics/ForestPracticesRules/Pages/fp_rules.aspx

The Forest Practices Board adopts forest practice rules designed to protect public resources such as water quality and fish habitat while maintaining a viable timber industry. The Forest Practices Rules establish standards for forest practices such as timber harvest, pre-commercial thinning, road construction, fertilization, and forest chemical. The rules are designed to protect public resources such as water quality and fish habitat while maintaining a viable timber industry. They are under constant review through the adaptive management program

Low risk 1.2 There is evidence in the district demonstrating the legality of harvests and wood purchases that includes robust and effective systems for granting licenses and harvest permits.

Washington State DNR Forest Practices Permits www.dnr.wa.gov/BusinessPermits/Topics/ForestPracticesApplications/Pages/fp_forms.aspx

Washington has an effective and robust permitting system for the harvesting of timber. See HSPP Chain of Custody Procedure 3.2.7 Risk Assessment of Non-certified Raw Material

1.3 There is little or no evidence or reporting of illegal harvesting in the district of origin.

Illegal Logging. Info www.illegal-logging.info/index.php

No incidents of illegal logging in Washington on website illegal-logging.info The US Lacey Act makes the import and sale of illegally-produced timber illegal in its jurisdiction. In 2008, the Lacey Act was amended to include a wider variety of prohibited plants and plant products, including illegally logged woods, for import.

1.4 There is a low perception of corruption related to the granting or issuing of

Transparency International www.transparency.org

There is no mention of corruption issues in the district.

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harvesting permits and other areas of law enforcement related to harvesting and wood trade.

http://cpi.transparency.org/cpi2012/results/

The United States scored 73 and ranked 19th in Transparency International’s Corruption Perceptions Index 2012 report.

2. Wood harvested in violation of traditional or civil rights The district of origin may be considered low risk in relation to the violation of traditional, civil and collective rights when all the following indicators are present:

2.1 There is no UN Security Council ban on timber exports from the country concerned;

UN Security Council www.un.org/sc/committees

There is currently no UN Security Council ban on timber exports from Washington State.

Low risk

2.2 The country or district is not designated a source of conflict timber (e.g. USAID Type 1 conflict timber)

Global Policy Forum www.globalpolicy.org/security/natres/timbrindex.htm

Alaska is not designated as a source of conflict timber by Global Policy Forum.

2.3 There is no evidence of child labour or violation of ILO Fundamental Principles and Rights at work taking place in forest areas in the district concerned

Washington State Legislature http://apps.leg.wa.gov/RCW/default.aspx?cite=26.28.060

Washington state legislation prohibits the use of child labor. There is no evidence of violation of ILO Fundamental Principles and Rights in the district.

2.4 There are recognized and equitable processes in place to resolve conflicts of substantial magnitude pertaining to traditional rights including use rights, cultural interests or traditional cultural identity in the district concerned

Tribal Relations www.dnr.wa.gov/Publications/fp_hcp_annrep07_ch10.pdf

Forest Practices Board rules promote cooperative relationships and agreements with the tribes and direct DNR Forest Practices staff to consult and cooperate with affected tribes when developing and implementing many parts of the Forest Practices program.

2.5 There is no evidence of violation of the ILO Convention 169 on Indigenous and Tribal Peoples taking place in the forest areas in the district concerned.

ILO Indigenous and Tribal Peoples www.ilo.org/indigenous/lang--en/index.htm

While the US is not a signatory to ILO Convention 169, there is no evidence of violation of indigenous peoples’ rights in the forests of Washington.

3. Wood harvested from forest in which high conservation values are threatened by management activities The district of origin may be considered low risk in relation to threat to high conservation values if: a) indicator 3.1 is met; or b) indicator 3.2 eliminates (or greatly mitigates) the threat posed to the district of origin by non-compliance with 3.1.

3.1 Forest management activities in the relevant level (eco-region, sub-eco-region, local) do not threaten eco-regionally significant high conservation values.

Puget Lowland Forests Ecoregion http://worldwildlife.org/ecoregions/na0524 Conservation International Biodiversity Hotspots http://www.biodiversityhotspots.org/Pages/default.aspx http://www.conservation.org/where/north_america/pages/priorities.aspx

The Everson/Sumas area is in the Puget Lowland Forests Ecoregion. The area is relatively densely populated and no known eco-regionally significant high conservation values exist. There are no Conservation International Biodiversity Hotspots in Washington.

Low risk

3.2 A strong system of protection (effective protected areas and legislation) is in place that ensures survival of the HCVs in the ecoregion.

Forest Practices Habitat Conservation Plan http://www.dnr.wa.gov/BusinessPermits/Topics/ForestPracticesHCP/Pages/fp_hcp.aspx

Washington’s Forest Practices Habitat Conservation Plan seeks to provide long-term conservation of ESA covered species while supporting an economically viable timber industry.

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4. Wood harvested from areas being converted from forests and other wooded ecosystems to plantations or non-forest uses The district of origin may be considered low risk in relation to conversion of forest to plantations or non-forest uses when the following indicator is present:

4.1 There is no net loss AND no significant rate of loss (> 0.5% per year) of natural forests and other naturally wooded ecosystems such as savannahs taking place in the eco-region in question.

Future of Washington Forests www.dnr.wa.gov/ResearchScience/Topics/ForestResearch/Pages/futureofwashingtonsforest.aspx

Washington DNR and the University of Washington have embarked on a project to look at the future of the state’s forests to help shape forest policy. The project report estimates that harvest, combined with natural mortality, will continue to be less than growth in western Washington. The overall expected result is that the standing volume of Washington’s forests will increase over time

Low risk

5. Wood from forests in which genetically modified trees are planted The district of origin may be considered low risk in relation to wood from genetically modified trees when one of the following indicators is complied with:

a) There is no commercial use of genetically modified trees of the species concerned taking place in the country or district concerned

FAO Forest Genetic Resources Working Paper www.fao.org/docrep/008/ae574e/AE574E00.htm#TopOfPage

There is no commercial use of genetically modified trees in Washington.

Low risk b) Licenses are required for commercial use of genetically modified trees and there are no licenses for commercial use c) It is forbidden to use genetically modified trees commercially in the country concerned

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Certificate holder: Howe Sound Pulp and Paper Ltd. Partnership Certification Body (CB): Rainforest Alliance SmartWood Program

FSC CW certificate code: RA-CW-004231 Date of CB approval:

Date of risk assessment: August 2013 Address of CB: 65 Millet Street, Suite 201, Richmond Vermont USA

Certificate holder address: 3838 Port Mellon Hwy, Port Mellon, BC V0N 2S0 Risk Assessor Mark Gage, RPF

Districts, including countries covered with this risk assessment*:

SE Alaska

*NB! If sources of information, justification, and/or risk levels vary for different districts, separate tables shall be made for each district.

Category FSC Indicator Information Sources Used Brief justification Risk

Designation 1. Illegally Harvested Wood The district of origin may be considered low risk in relation to illegal harvesting when all the following indicators related to forest governance are present:

1.1 Evidence of enforcement of logging related laws in the district

Alaska Dept. of Natural Resources – Division of Forestry http://forestry.alaska.gov/forestpractices.htm Alaska Forest Resources and Practices Act (FRPA) http://forestry.alaska.gov/pdfs/2009ForestResources&PracticesAct-EO114revisions.pdf

Division of Forestry governs forest management activities according to state statutes and regulations. It prepares Forest Land Use Plans for timber sales and harvest areas. FRPA regulates forest management activities on, state, private, municipal and federal land (July 2006 version). See HSPP Chain of Custody Procedure 3.2.7 Risk Assessment of Non-certified Raw Material Low risk

1.2 There is evidence in the district demonstrating the legality of harvests and wood purchases that includes robust and effective systems for granting licenses and harvest permits.

1.3 There is little or no evidence or reporting of illegal harvesting in the district of origin.

Illegal Logging. Info www.illegal-logging.info/index.php

No incidents of illegal logging in Alaska on website illegal-logging.info The US Lacey Act makes the import and sale of illegally-produced timber illegal in its jurisdiction.

1.4 There is a low perception of corruption related to the granting or issuing of harvesting permits and other areas of law enforcement related to harvesting and wood trade.

Transparency International www.transparency.org http://cpi.transparency.org/cpi2012/results/

There is no mention of corruption issues in the district. The United States scored 73 and ranked 19th in Transparency International’s Corruption Perceptions Index 2012 report.

2. Wood harvested in violation of traditional or civil rights The district of origin may be considered low risk in relation to the violation of traditional, civil and collective rights when all the following indicators are present:

2.1 There is no UN Security Council ban on timber exports from the country concerned;

UN Security Council www.un.org/sc/committees

There is currently no UN Security Council ban on timber exports from Alaska.

Low risk

2.2 The country or district is not designated a source of conflict timber (e.g. USAID Type 1 conflict timber)

Global Policy Forum www.globalpolicy.org/security/natres/timbrindex.htm

Alaska is not designated as a source of conflict timber by Global Policy Forum.

2.3 There is no evidence of child labour or violation of ILO Fundamental Principles and Rights at work taking place in forest areas in the district concerned

Division of Labor Standards and Safety http://labor.state.ak.us/lss/home.htm

Forest employment in Alaska is regulated under labor laws which include just compensation, protection from unfair practices and prohibition of child labor.

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2.4 There are recognized and equitable processes5 in place to resolve conflicts of substantial magnitude pertaining to traditional rights including use rights, cultural interests or traditional cultural identity in the district concerned

Alaska Native Claims Settlement Acthttp://www.fws.gov/laws/lawsdigest/alasnat.html

The Alaska Natives Claims Settlement Act provided land and cash as settlement of aboriginal claim to land in the State. The Act established a system of village and regional Native corporations to manage the lands and cash payments, and made extensive provisions regarding the operations of the corporations

2.5 There is no evidence of violation of the ILO Convention 169 on Indigenous and Tribal Peoples taking place in the forest areas in the district concerned.

ILO Indigenous and Tribal Peoples http://www.ilo.org/indigenous/lang--en/index.htm

While the US is not a signatory to ILO Convention 169, there is no evidence of violation of indigenous peoples’ rights in the forests of Alaska.

3. Wood harvested from forest in which high conservation values are threatened by management activities The district of origin may be considered low risk in relation to threat to high conservation values if: a) indicator 3.1 is met; or b) indicator 3.2 eliminates (or greatly mitigates) the threat posed to the district of origin by non-compliance with 3.1.

3.1 Forest management activities in the relevant level (eco-region, sub-eco-region, local) do not threaten eco-regionally significant high conservation values.

Alaska Forest Resources and Practices Act (FRPA) http://forestry.alaska.gov/pdfs/2009ForestResources&PracticesAct-EO114revisions.pdf Conservation International Biodiversity Hotspots http://www.biodiversityhotspots.org/Pages/default.aspx http://www.conservation.org/where/north_america/pages/priorities.aspx

FRPA regulates forest management activities on, state, private, municipal and federal land. There are no Conservation International Biodiversity Hotspots in Alaska, and no priority areas are located in Alaska.

Low risk

3.2 A strong system of protection (effective protected areas and legislation) is in place that ensures survival of the HCVs in the ecoregion.

Northern Pacific Coastal Forests http://worldwildlife.org/ecoregions/na0520 Division of Parks and Outdoor Recreation http://dnr.alaska.gov/parks/index.htm National Parks Service http://www.nps.gov/state/ak/

SE Alaska lies within the Northern Pacific Coastal Forests ecoregion. Alaska has an extensive network of state and national parks to ensure maintenance of high conservation values.

4. Wood harvested from areas being converted from forests and other wooded ecosystems to plantations or non-forest uses The district of origin may be considered low risk in relation to conversion of forest to plantations or non-forest uses when the following indicator is present:

4.1 There is no net loss AND no significant rate of loss (> 0.5% per year) of natural forests and other naturally wooded ecosystems such as savannahs taking place in the eco-region in question.

Alaska Forest Resources and Practices Act (FRPA) http://forestry.alaska.gov/pdfs/2009ForestResources&PracticesAct-EO114revisions.pdf http://forestry.alaska.gov/stateforests.htm#plans

FRPA requires that harvested land shall be reforested naturally or artificially. Artificial reforestation must be carried out with silviculturally acceptable seedlings.

Low risk

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5. Wood from forests in which genetically modified trees are planted The district of origin may be considered low risk in relation to wood from genetically modified trees when one of the following indicators is complied with:

a) There is no commercial use of genetically modified trees of the species concerned taking place in the country or district concerned

FAO Forest Genetic Resources Working Paper http://www.fao.org/docrep/008/ae574e/AE574E00.htm#TopOfPage

There is no commercial use of genetically modified trees in Alaskan forestry.

Low risk b) Licenses are required for commercial use of genetically modified trees and there are no licenses for commercial use c) It is forbidden to use genetically modified trees commercially in the country concerned

Page 1 of 3

Certificate holder: Howe Sound Pulp and Paper Corporation Certification Body (CB): Rainforest Alliance SmartWood Program

FSC CW certificate code: RA-CW-004231 Date of CB approval:

Date of risk assessment: August 2013 Address of CB: 65 Millet Street, Suite 201, Richmond Vermont USA

Certificate holder address: 3838 Port Mellon Hwy, Port Mellon, BC V0N 2S0 Risk Assessor Mark Gage, RPF

Districts, including countries covered with this risk assessment*:

Haida Gwaii (Crown land only)

*NB! If sources of information, justification, and/or risk levels vary for different districts, separate tables shall be made for each district.

Category FSC Indicator Information Sources Used Brief justification Risk

Designation 1. Illegally Harvested Wood The district of origin may be considered low risk in relation to illegal harvesting when all the following indicators related to forest governance are present:

1.1 Evidence of enforcement of logging related laws in the district

Compliance and Enforcement Branch www.for.gov.bc.ca/hen/ Forest Act Part 5 Timber Marking & Part 6 Timber Scaling Timber Marking and Transportation Regulation www.for.gov.bc.ca/tasb/legsregs

The Ministry of Forests, Lands and Natural Resource Operations - Compliance & Enforcement Branch enforces BC’s forestry laws and takes action where there is non-compliance Strong legislation is in place in BC regarding the granting and regulation of harvesting rights and the marking, scaling and transportation of timber See HSPP Chain of Custody Procedure 3.2.7 Risk Assessment of Non-certified Raw Material

Low risk

1.2 There is evidence in the district demonstrating the legality of harvests and wood purchases that includes robust and effective systems for granting licenses and harvest permits. 1.3 There is little or no evidence or reporting of illegal harvesting in the district of origin.

1.4 There is a low perception of corruption related to the granting or issuing of harvesting permits and other areas of law enforcement related to harvesting and wood trade.

Transparency International www.transparency.org http://cpi.transparency.org/cpi2012/results/

No mention of corruption issues in the district. Canada is ranked “very clean” in Transparency International’s Corruption Perceptions Index 2012 report (9th in the world and score of 84).

2. Wood harvested in violation of traditional or civil rights The district of origin may be considered low risk in relation to the violation of traditional, civil and collective rights when all the following indicators are present:

2.1 There is no UN Security Council ban on timber exports from the country concerned;

UN Security Council www.un.org/sc/committees

There is currently no UN Security Council ban on timber exports from Canada.

Low risk

2.2 The country or district is not designated a source of conflict timber (e.g. USAID Type 1 conflict timber)

Global Policy Forum www.globalpolicy.org/security/natres/timbrindex.htm

Canada is not designated as a source of conflict timber.

2.3 There is no evidence of child labour or violation of ILO Fundamental Principles and Rights at work taking place in forest areas in the district concerned

Employment Standards Branch Employment Standards Regulation http://www.bclaws.ca/EPLibraries/bclaws_new/document/ID/freeside/00_96113_01

Forest employment in Canada is regulated under federal and provincial labour codes, which prohibit child labour, protect the rights of workers to organize and are in conformity with fundamental ILO Conventions.

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2.4 There are recognized and equitable processes5 in place to resolve conflicts of substantial magnitude pertaining to traditional rights including use rights, cultural interests or traditional cultural identity in the district concerned

Aboriginal Affairs and Northern Development Canada www.aadnc-aandc.gc.ca/eng/1100100028568/1100100028572 Ministry of Aboriginal Relations and Reconciliation www.gov.bc.ca/arr/treaty/default.html

There are processes in place with both the governments of Canada and BC to negotiate and implement land claims and self government agreements.

2.5 There is no evidence of violation of the ILO Convention 169 on Indigenous and Tribal Peoples taking place in the forest areas in the district concerned.

Canadian Human Rights Commission http://www.chrc-ccdp.gc.ca/eng/content/equal-employment-opportunities

There is no evidence of violation. The Employment Equity Act is a federal law that requires employers to provide equal employment opportunities within your organization to four designated groups: women; Aboriginal peoples; persons with disabilities; and members of visible minorities..

3. Wood harvested from forest in which high conservation values are threatened by management activities The district of origin may be considered low risk in relation to threat to high conservation values if: a) indicator 3.1 is met; or b) indicator 3.2 eliminates (or greatly mitigates) the threat posed to the district of origin by non-compliance with 3.1.

3.1 Forest management activities in the relevant level (eco-region, sub-eco-region, local) do not threaten eco-regionally significant high conservation values.

Forest & Range Legislation & Regulation http://www.for.gov.bc.ca/tasb/legsregs Conservation International Biodiversity Hotspots http://www.biodiversityhotspots.org/Pages/default.aspx

Forest management activities are regulated by the Forest and Range Practices Act and other legislation and regulations that provide protection for high conservation values. There are no Conservation International Biodiversity Hotspots in British Columbia.

Low risk

3.2 A strong system of protection (effective protected areas and legislation) is in place that ensures survival of the HCVs in the ecoregion.

Queen Charlotte Islands http://www.worldwildlife.org/wildworld/profiles/terrestrial/na/na0525_full.html Haida Gwaii Strategic Land Use Agreement http://ilmbwww.gov.bc.ca/slrp/lrmp/nanaimo/haidagwaii/index.html http://ilmbwww.gov.bc.ca/sites/default/files/resources/public/PDF/LRMP/haidaGwaii/NR_Haida_Gwaii%20LUO_Dec_17_2010_FINAL.pdf

Haida Gwaii is in the Queen Charlotte Islands ecoregion and has undergone extensive land use planning that has included the designation of increased protected areas. Agreement on the Haida Gwaii Strategic Land Use plan was reached between the Government of BC and the Haida Nation in December 2007. Additional protected areas in the Agreement bring the total protected area on the islands to about 50% of the land base. Forestry on the islands is implemented using Ecosystem Based Management objectives. In December 2010 legal objectives were established to sustain cultural heritage values and fish and wildlife habitat.

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4. Wood harvested from areas being converted from forests and other wooded ecosystems to plantations or non-forest uses The district of origin may be considered low risk in relation to conversion of forest to plantations or non-forest uses when the following indicator is present:

4.1 There is no net loss AND no significant rate of loss (> 0.5% per year) of natural forests and other naturally wooded ecosystems such as savannahs taking place in the eco-region in question.

The State of British Columbia’s Forests Third Edition 2010 www.for.gov.bc.ca/hfp/sof/2010/SOF_2010_Web.pdf The total protected area on the islands to about 50% of the land base.

British Columbia contains vast and diverse forests and rangelands. Almost 60% (55 million hectares) of B.C.′s 95 million hectares is classified as forest land. Less than 3% of B.C.′s original forest has been converted to human (non-forest) use. Since 1850, ecosystem conversion to agriculture, reservoirs, urban areas, and other land uses has occurred on 2% of the province.

Low risk

5. Wood from forests in which genetically modified trees are planted The district of origin may be considered low risk in relation to wood from genetically modified trees when one of the following indicators is complied with:

a) There is no commercial use of genetically modified trees of the species concerned taking place in the country or district concerned

Tree Improvement Branch www.for.gov.bc.ca/hti/grm/generesource.htm

The Tree Improvement Branch of the Ministry of Forests, Lands and Natural Resource Operations is not involved in any genetic engineering, gene insertion, gene splicing or biotechnology that results in genetically modified organisms. The Branch ensures that no genetically modified tree seed is registered or used in operational forest planting on Crown land in British Columbia.

Low risk b) Licenses are required for commercial use of genetically modified trees and there are no licenses for commercial use c) It is forbidden to use genetically modified trees commercially in the country concerned