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CFCI SFM Plan – Draft 5.1 Page 1

Coast Forest Conservation Initiative New thinking about forest conservation

Coast Forest Conservation Initiative Society

Sustainable Forest Management Plan

Mid Coast Timber Supply Area

November 2008



Table of Contents Introduction ................................................................................................................................ 4 Coast Forest Conservation Initiative Society .............................................................................. 4

CFCI Members ....................................................................................................................... 4 Roles and Responsibilities...................................................................................................... 4

Forest and Environment Policies................................................................................................ 5 BC Timber Sales .................................................................................................................... 5 Canfor .................................................................................................................................... 6 Catalyst .................................................................................................................................. 6 Interfor.................................................................................................................................... 7 Western Forest Products........................................................................................................ 7 CFCI Commitment to Forest Stewardship Council Principles & Criteria.................................. 8

Defined Forest Area................................................................................................................... 9 Comprehensive Description.................................................................................................... 9 Existing Forest Tenures.........................................................................................................10 Legal and Customary Tenure and Use Rights .......................................................................11 Environmental Risk Assessment (ERA) - Summary...............................................................11 High Conservation Value Forests (HCVF) - Summary ...........................................................12

Summary of Existing Management Plans and Agreements.......................................................13 Management Objectives ...........................................................................................................15

CFCI Objectives from Forest Stewardship Plans ...................................................................15 BC Timber Sales - Seaward (Tlasta) Business Area 2006-2011 Forest Stewardship Plan.15 Interfor - SWC - North Island - Central Coast Forest District Mid Coast Multi-Licensee Forest Stewardship Plan ....................................................................................................16 Mainland Coast FSP – WFP ..............................................................................................17

Objectives Jointly Managed by CFCI.....................................................................................18 Adequate and Stable Workforce ........................................................................................18 Local Procurement.............................................................................................................18 Non-Timber Forest Products ..............................................................................................18 Important Fisheries Watersheds ........................................................................................18 Upland Streams .................................................................................................................19 Landscape Level Biodiversity.............................................................................................19 Red-Listed and Blue-Listed Plant Communities .................................................................20

Timber Supply Review and Allowable Annual Cut.....................................................................21 Mid Coast TSA Timber Supply Review and Allowable Annual Cut History.............................21 Mid Coast TSA Harvest Volume History ................................................................................22

Training and Supervision ..........................................................................................................23 Environmental Management Systems ...................................................................................23

Monitoring and Assessment ......................................................................................................23 Chain of Custody ......................................................................................................................23 Adaptive Management ..............................................................................................................25 Appendices ...............................................................................................................................26

Appendix 1 - Forest Stewardship Council Group Certification - Consent Form ......................27 Appendix 2 - CFCI Group Certification – Policies and Procedures 1.1...................................30


Introduction The purpose of this Sustainable Forest Management Plan is to communicate the Coast Forest Conservation Initiative Society’s (CFCI) intention and commitment to seek certification to the Forest Stewardship Council (FSC) Regional Certification Standards for British Columbia for defined areas managed by its members within the Mid Coast Timber Supply Area (TSA). There are a number of existing plans and agreements in place governing management of the Mid Coast TSA as referenced throughout this document and in the Summary of Existing Management Plans and Agreements section of the plan. It is not our intent to duplicate the requirements of other plans and agreements here but instead to highlight areas of collaboration and cooperation among the members in seeking FSC certification as well as to provide a point of reference to other information that is required for successful certification to the FSC BC Standard.

Coast Forest Conservation Initiative Society The Coast Forest Conservation Initiative Society (CFCI) is a collaborative effort of five British Columbia forest companies committed to new approaches to forest conservation and management in BC’s Central and North Coast. Its purpose is to support development of an ecosystem-based conservation and management plan for the region that contains one of the largest intact temperate rainforests in the world. The CFCI Certificate of Incorporation, the Constitution and the Bylaws are on file with the CFCI Treasurer. More information about the CFCI is available on the website at the link below. http://www.coastforestconservationinitiative.com/about_us/the_region.html CFCI Members The CFCI members are:

BC Timber Sales (BCTS) www.for.gov.bc.ca/bcts Canadian Forest Products Ltd. (Canfor) www.canfor.com Catalyst Paper Corporation (Catalyst) www.catalystpaper.com International Forest Products Limited (Interfor) www.interfor.com Western Forest Products Inc. (WFP) www.westernforest.com

Three CFCI members, BC Timber Sales (BCTS), International Forest Products Limited (Interfor) and Western Forest Products Inc. (WFP), have forest operations within the Mid Coast TSA. Roles and Responsibilities Roles and responsibilities for the CFCI Group Certification are included in the Policies and Procedures document in Appendix2, including a complaints and disputes resolution mechanism.


Forest and Environment Policies Each member company of the Coast Forest Conservation Initiative Society has its own forestry-related environment policy, which are reproduced here. BC Timber Sales Forest Sustainability Sustainable forests are a high priority for British Columbians and central to the BCTS mandate. We are committed to excellence in meeting our forest management and stewardship obligations, and strive for continuous improvement of our forest management activities and practices. BCTS strongly advocates strategic resource management planning and sustainable practices based upon objective science and sound data. We collaborate with other government agencies, industry colleagues and forestry professionals on important resource management initiatives such as old growth forests, biodiversity, wildlife management, species at risk and ecosystem-based management (EBM). We work with First Nations, environmental organizations and other parties in these and other areas of shared interest. BCTS is unique in being a government agency that plans, oversees and delivers forestry operations subject to many of the same statutory requirements as forest licensees. This enables BCTS to support government decision making on important forest management matters by providing experience-based, objective and verifiable information about operational implications, costs and benefits.

1. Our cost and pricing benchmark mandate directs us to reflect industry standards and practices in meeting our obligations under the Forest and Range Practices Act.

2. We play a key role in shaping industry standards in forestry practices because we operate

across the province in areas selected to represent the full range of operational conditions. We participate in strategic land use planning initiatives and work with industry and government agency colleagues to develop innovative and cost-effective strategies, standards and practices.

3. We contribute to the development and continuous improvement of forest policy, legislation

and standards through alignment and collaboration with the Ministry of Forests and Range and other resource-focused government agencies.

4. We have achieved certification of an Environmental Management System (EMS) in all 12

Business Areas to the standard of the International Organization for Standardization (ISO 14001). We have a corporate strategy for certification under Sustainable Forest Management (SFM) standards and have achieved SFM certification in a number of our operating areas. For more information about Business Area certification activities, please check our public website.

5. We are committed to meeting our silviculture obligations and have a solid record in achieving

statutory requirements from pre-harvest to free growing. BCTS is the largest tree planter in British Columbia, having planted more than 100 million trees since its inception in April 2003. This work is supported through site preparation, stand treatments and other silviculture activities.


Canfor Environment Policy

We are committed to responsible stewardship of the environment throughout our operations. We will:

• Comply with or exceed legal requirements. • Comply with other environmental requirements to which the company is committed. • Achieve and maintain sustainable forest management. • Set and review objectives and targets to prevent pollution and to continually improve our

sustainable forest management and environmental performance. • Provide opportunities for interested parties to have input into our sustainable forest

management planning activities. • Promote environmental awareness throughout our operations. • Conduct regular audits of our forest and environmental management systems. • Communicate our sustainable forest management and environmental performance to

our Board of Directors, shareholders, employees, customers and other interested parties.

Catalyst Environment Policy Catalyst Paper is accountable for the effect of its operations on the environment and we accept responsibility for conserving, sustaining and making efficient use of the resources we consume. While the company’s products play an important role in society, we are mindful that they must also represent the highest standards of environmental integrity we can provide. Catalyst is committed to the principle of continuous improvement and reviews its policies and practices against external benchmarks with the help of independent advisors and partners. We work cooperatively and collaboratively with those who contribute positively, through advice or criticism, to improving our environmental performance. Day-to-day, the responsibility for environmental performance rests with all employees. In applying this policy, Catalyst commits to:

• Adhere to the principles of conservation and sustainability • Meet the requirements of relevant environmental legislation and other voluntary

programs • Be fully transparent in publicly disclosing our environmental performance • Reduce pollution at its source • Set objectives and targets to support continual improvement of our environmental

performance • Operate our facilities with respect for the values of surrounding communities


Interfor Environment Policy International Forest Products Limited is committed to responsible stewardship of the environment.

• We will minimize environmental impact, prevent pollution and strive for continuous improvement of our environmental performance.

• We will operate in compliance with all applicable laws pertaining to the environment. • We will regularly review our practices and procedures to monitor and report on

environmental performance. • We will provide training for employees and contractors in environmentally responsible work

practices. • We will manage our forest resources in a sustainable manner that is environmentally

appropriate, socially beneficial and economically viable. • We will promote the use of our wood products as a good choice for the environment.

Western Forest Products Sustainable Forest Management Statement – Timberlands At Western Forest Products Inc. (WFP) forests are more than a critical timber resource - they are our heritage and our future. Responsible forest stewardship is essential to our success as a company. WFP is committed to sustainable forestry practices on the public and private forest lands in our care. We will strive to be leaders in supplying quality, competitive forest products to global markets through the practice of sustainable forest management. WFP will ensure that all forest management activities meet or exceed relevant legislation, regulations or policies. We will assure the public, First Nations and our customers that we are protecting the environment and the resources under our stewardship. WFP's Sustainable Forest Management (SFM) system is based on three major principles consistent with Canadian and international forest certification principles. Our forest management will be environmentally appropriate, socially beneficial and economically viable. Under these principles, our company is committed to:

• Manage operations to safeguard the health and safety of employees, contractors and the public

• Maintain a team of dedicated managers, professional foresters and planners committed to implementing and practicing SFM with respect to all forest and social values

• Enhance our ability to plan and manage by promoting improved knowledge about the forest and SFM as well as to monitor advances in SFM science and technology and incorporate them where applicable

• Perform regular, internal and independent audits to ensure conformance with our SFM commitments

• Maintain and improve all aspects of our SFM system through adaptive management, review and improvement

• Provide for public participation • Respect First Nations aboriginal and treaty rights, and provide participation opportunities

with respect to their rights and interests in SFM.


CFCI Commitment to Forest Stewardship Council Principles & Criteria The Coast Forest Conservation Initiative Society has chosen to collectively implement a sustainable forest management plan for the purpose of certification to the Forest Stewardship Council Regional Certification Standards for British Columbia. The plan will apply to the Defined Forest Area within the Mid Coast Timber Supply Area as described in the plan (Defined Forest Area section). The CFCI is committed to adhering to the FSC Principles & Criteria as described in the FSC-BC Regional Standard over the long term for the defined forest area within the Mid Coast TSA as defined in this plan. The CFCI has made a commitment to FSC Group Certification as outlined in the FSC Group Certification Consent Form and Appendix, which is included as Appendix 1 of this Plan. A signed original copy of the Consent Form is on file with the CFCI Treasurer.


Defined Forest Area Comprehensive Description The Defined Forest Area (DFA) for this plan includes the forest management areas within the Interfor and WFP chart areas in the Mid-Coast TSA, as well as the current BCTS pricing unit area. The DFA does not include Tree Farm Licences 25 or 39, the Bella Coola Forest Corporation Community Forest Agreement, Nuxalk Community Forest Agreement, protected areas, private land or land within municipalities, communities or Indian Reserves. A comprehensive description of the DFA is included in the Environmental Risk Assessment document which is part of the FSC audit evidence binder.


Existing Forest Tenures Existing forest tenures in the Mid Coast TSA are listed in the following table. Licensee Licence or Operating Area AAC (m

3)

BCTS Burnt Island Harbour BCTS Chatfield Island BCTS Greaves Island BCTS King Island BCTS Lake Island BCTS Link Lake BCTS Naysash Inlet BCTS Nusash Creek BCTS Nygaard Point (King Island) BCTS Pierce Bay BCTS Sheep Passage BCTS Snass Lake BCTS Spiller Channel/Tom Bay BCTS Stone Point/Rivers Inlet BCTS Susan Island Blk 1 & 2 BCTS Yeo Island

101,448

Interfor FL A16850 131,368 Interfor FL A81001 89,950 Interfor FL A81002 32,779 Interfor TO 356 N/A* Interfor TO 364 N/A* Interfor TO 377 N/A* Interfor TO 398 N/A* Interfor TO 407 N/A* Interfor TO 416 N/A* Interfor TO 438 N/A* Interfor TO 474 N/A* Interfor TO 483 N/A* Interfor TO 499 N/A* Interfor TO 572 N/A* Interfor TO 608 N/A* Interfor TO 690 N/A* Interfor TO 697 N/A* Interfor TO 941 N/A* Interfor TO 945 N/A* Interfor TO 952 N/A* Interfor TO 964 N/A* Interfor TO 973 N/A* Interfor TO 980 N/A* Interfor TO 996 N/A* Interfor TO 1001 N/A* Interfor TO 1005 N/A* Interfor Portions of TO 742 in FDU MC 38 N/A* SWC Holdings Ltd. (managed by Interfor) FL A16848 14,693 WFP FL A16845 200,635 WFP FL A16847 29,017 WFP TO 906 N/A* WFP TO 912 N/A*

* Timber Licence (TO) is an old temporary tenure that grants exclusive rights to harvest merchantable

timber from a defined area of Crown land and does not have an Allowable Annual Cut.


Legal and Customary Tenure and Use Rights Legal and customary tenure and use rights of other interests within the DFA are identified, described and mapped. Details are included in the documents listed in the Summary of Existing Management Plans and Agreements section of this Plan. Environmental Risk Assessment (ERA) - Summary An Environmental Risk Assessment (ERA) is the process of examining trends for key environmental values and comparing them to appropriate scientific benchmarks to determine the extent to which ultimate ecological goals are likely to be met. The process of ERA generally consists of:

• Identify key environmental pressures • Identifying appropriate environmental values and indicators • Characterize Environmental Trends, Indicator Relationships and Establish Risk Classes • Establishing benchmarks against which to understand the significance of the trends

through time, and where possible identifying low and high risk thresholds to categorize the significance of changes

• Presenting results and identifying key assumptions and uncertainties so a) decisions can be made with full knowledge of the potential environmental implications and b) adaptive management processes can test the hypotheses being generated.

The context for the ERA includes a long time frame and a large landbase at a regional scale. The CFCI have decided to go with a broad scale assessment due to the level of detail, the amount of data required and geographic limits that the assessment requires. The broad scale approached will be used so that we can focus on maintaining ecosystem elements that provide for a vast majority of species. Terrestrial Biodiversity, Hydro-riparian and Aquatic Ecosystems, Fish and Wildlife Habitat and specifically Grizzly Bear habitat are the environmental values that are potentially at risk within the DFA. In this ERA analysis, because of limited inventory data available for the suite of potential risk elements, coarse filter indicators – ecological representation and old-forest representation will be used. In these analyses we measure ‘coarse filter’ ecological risk using three indicators:

• Amount of protected area • Amount and trends in natural old forest abundance and distribution for individual

ecosystems • Number and area of ecosystems in one of five rarity classes that are then grouped into

two risk classes (reference old RONV targets in LUO) The Coast Land Use Decision, coupled with existing legislation and policy (ie. Forest and Range Practices Act, Forest Act) support Ecosystem Based Management implementation in the DFA. Implementation applies to the Defined Forest Area as part of the North Coast and Central Coast Land and Resource Management Plan areas and subsequent Land Use Orders. The coast land use decision and emerging framework is designed to support a low environmental risk outcome as depicted in this Environmental Risk Assessment. Updating and future improvements in forest information and increased understanding of ecological function will continue to inform sustainable forest management under structured adaptive management principles.


High Conservation Value Forests (HCVF) - Summary Identification and management of High Conservation Value Forests (HCVF) is an important component of the FSC Regional Certification Standards for BC. CFCI have complied and analyzed available existing data to identify HCVFs and describe appropriate management strategies for protecting HCVFs within the Mid Coast Defined Forest Area. The results of this work are incorporated in a separate report, High Conservation Value Forests within the Mid-Coast Forest Management Unit, which is included in the FSC audit evidence binder. The primary basis for high conservation management in the Mid Coast DFA is Ecosystem Based Management (EBM) which is intended to achieve healthy ecosystems and healthy human communities. EBM allows for management flexibility by focusing on overall low-risk management at broad scales, but allowing higher-risk activities at finer scales. This approach is grounded in the EBM Framework, which lists the maintenance of ecological integrity and the application of the precautionary principle to ecological risk among its guiding principles. A basic principle of HCVF assessment is that it be carried out by qualified specialists, including consultation with directly affected persons and relevant interests (e.g., First Nations, regulatory agencies, local communities, conservation organizations). CFCI consulted various specialists (government organizations, NGOs, academia, and conservation organizations) during the assessment of High Conservation Values. In addition, most of the supporting documentation was provided through the multi-year Land and Resource Management Plan process (1996-2004) and the Coast Information Team (CIT), the supporting science body to the LRMP table. During the LRMP process these materials were peer reviewed and involved review and input from affected interest groups as a process. The determination of HCVs for the CFCI report involved researching very recent science. Several peer-reviewed papers still “in press” (e.g., Darimont 2008a) were also considered during the HCVs determination. Isolated areas and several areas of HCVs (e.g. endemic species) are not fully understood but are largely protected through course filter landscape unit planning (e.g., reserves such as conservancies), fine filter planning (e.g., forested swamp reserves) and management strategies (e.g., WFP, Interfor and BCTS best management practices for species at risk). Species specific data for the DFA (as for the rest of BC) is lacking and will need to be analyzed as it becomes available (e.g. EBMWG data on habitat supply management approaches and coastal wolf data). The identified HCVFs in the Mid-coast DFA include forest areas with globally, nationally or regionally significant concentrations of biodiversity values such as habitat for endangered species at risk (e.g., grizzly bears), various levels of protected areas, large landscape level forests, naturally rare ecosystem types and areas of cultural, ecological, economic and religious significance .


Summary of Existing Management Plans and Agreements There are a number of existing land use plans, government decisions, government and First Nations Agreements, Forest Stewardship Plans, etc. governing forest management in the Mid Coast TSA which support this Sustainable Forest Management Plan. A brief description of their content and a link to their website location is included in the table below.

SFM Plan Supporting Documents

Location Content

Central Coast LRMP – Final Report Consensus Recommendations

http://ilmbwww.gov.bc.ca/slrp/lrmp/nanaimo/cencoast/plan/reports/table_rec.htm

Sub-regional land use plan covering approximately 4.6 million ha of BC’s central coast. Recommendations have been developed to direct management of public lands and resources for terrestrial portions of the plan area.

Coast Land Use Decision http://ilmbwww.gov.bc.ca/slrp/lrmp/nanaimo/central_north_coast/index.html

Enabling protected areas, ecosystem based management and government-to-government negotiation

South Central Coast Order http://ilmbwww.gov.bc.ca/slrp/lrmp/nanaimo/cencoast/plan/objectives/index.html

Land use objectives to support ecosystem based management

Central and North Coast Order

http://ilmbwww.gov.bc.ca/slrp/lrmp/nanaimo/cencoast/plan/objectives/index.html

Land use objectives to support ecosystem based management

BC Timber Sales Seaward (Tlasta) Business Area 2006-2011 Forest Stewardship Plan Approved October 12, 2006

http://www.for.gov.bc.ca/bcts/areas/tst/tst_FSP.htm Inserted in evidence binder

Development related to primary forest activities for cutblocks and roads within the Seaward Business Area

BC Timber Sales Seaward (Tlasta) Business Area 2006-2011 Forest Stewardship Plan Amendment #1 Submitted February 2, 2008

http://www.for.gov.bc.ca/bcts/areas/tst/tst_FSP.htm Not inserted in evidence binder

BC Timber Sales Seaward (Tlasta) Business Area 2006-2011 Forest Stewardship Plan Amendment #2 Submitted April 17, 2008

http://www.for.gov.bc.ca/bcts/areas/tst/tst_FSP.htm Not inserted in evidence binder


SFM Plan Supporting Documents

Location Content

Interfor – SWC North Island-Central Coast Forest District Mid Coast Multi-Licensee Forest Stewardship Plan Amendment #3 July 2, 2008

Inserted in evidence binder Interfor and SWC Holdings operations in the Mid Coast Timber Supply Area

Western Forest Products Inc. Mainland Coast Forest Stewardship Plan March 4, 2008

Inserted in evidence binder http://www.westernforest.com/fstew/download/WFP%20Mainland%20FSP%20April%2028%202008.pdf

WFP operations within Forest Licences A16845 and A16847 in the Mid Coast Timber Supply Area

Protocol Agreement between the Coastal First Nations (Turning Point) and BC March 23, 2006

http://ilmbwww.gov.bc.ca/slrp/legalobjectives/pdf/protocol_agree.pdf

Establishes Land and Resource Forum and agreement to implement EBM

Land Use Planning Agreement-In-Principle between KNT First Nations and the Province of BC March 27, 2006

http://www.ilmb.gov.bc.ca/slrp/lrmp/nanaimo/central_north_coast/docs/KNT_FN_AIP_Signed.pdf

Establishes Land and Resource Forum, negotiation of land use zones and agreement to implement EBM

Mid Coast Timber Supply Area Timber Supply Review

http://www.for.gov.bc.ca/hts/tsa/tsa19/

Timber Supply Review process documents

Coast Opportunity Funds http://www.coastfunds.ca/index.htm

Total of $120 Mil available for socio-economic and conservation based project funding to assist First Nations community transition.

Coast Sustainability Trust http://www.coastsustainabilitytrust.com/

Trust exists in three parts; to support economic diversification and community sustainability; deal with any negative impacts of full EBM implementation; and a sub trust to fund scientific work by the EBM Working Group

Definition of full implementation of Ecosystem Based Management

http://ilmbwww.gov.bc.ca/slrp/lrmp/nanaimo/central_north_coast/docs/Full_Implementation_(Final%20July%2010%202007).pdf

Joint Land and Resource Forums definition agreed to in government to government agreements

Heiltsuk/Province of BC Strategic Land Use Planning Agreement

http://www.ilmb.gov.bc.ca/slrp/lrmp/nanaimo/central_north_coast/docs/Heiltsuk_FN_Signed_SLUPA.pdf

Confirms outcome of government to government discussions and provides a framework to assist implementing land use planning


Management Objectives CFCI Objectives from Forest Stewardship Plans Each of the CFCI Operating Companies has its own Forest Stewardship Plans which cover operations in the Defined Forest Area in the Mid Coast Timber Supply Area. The management objectives, strategies for achieving them, and targets are detailed in the respective Forest Stewardship Plans as referenced in the Summary of Existing Management Plans and Agreements. A complete list of the management objectives follows. BC Timber Sales - Seaward (Tlasta) Business Area 2006-2011 Forest Stewardship Plan Provincial Order Establishing Non-Spatial Old Growth Objectives Ministerial Order Objectives for South Central Coast

• First Nations’ traditional forest resources

• First Nations’ traditional heritage features

• Culturally modified trees

• Monumental cedar

• Stand level retention of western red and yellow cedar

• Important fisheries watersheds

• High value fish habitat

• Aquatic habitat that is not high value fish habitat

• Forested swamps

• Upland streams

• Active fluvial units

• Landscape level biodiversity

• Red-listed and blue-listed plant communities

• Stand level retention

• Sensitive grizzly bear habitat

Ministerial Order Objectives for Central and North Coast









• Forested swamps

• Upland streams






• Critical grizzly bear habitat Objectives Prescribed under FRPA Sec 149

• Soils • Timber • Wildlife • Ungulate winter range • Species at risk • Riparian area water quality, fish & wildlife habitat and biodiversity • Fish sensitive watersheds • Community watersheds • Wildlife and biodiversity • Visual quality • Cultural heritage resources

Interfor - SWC - North Island - Central Coast Forest District Mid Coast Multi-Licensee Forest Stewardship Plan Ministerial Order Objectives for Central and North Coast









• Forested swamps

• Upland streams





• Critical grizzly bear habitat

Order Establishing Provincial Non-Spatial Old Growth Objectives

Objectives Prescribed under FRPA Sec 149 • Soils • Wildlife • Community watersheds • Water, fish, wildlife and biodiversity within riparian areas • Wildlife and biodiversity • Cultural heritage resources

Objectives Set Under Government Action Requests

• Visual quality


Mainland Coast FSP – WFP Central and North Coast Order

• Stand Level Retention for First Nations and Biodiversity

• Landscape Level Biodiversity

South Central Coast Order

• First Nations’ Traditional Forest Resources • First Nations’ Traditional Heritage Features • Culturally Modified Trees and Culturally Modified Tree Areas • Monumental Cedar • Stand Level Retention for First Nations and Biodiversity • Important Fisheries Watersheds • Upland Streams • High Value Fish Habitat • Aquatic Habitat that is not High Value Fish Habitat • Forested Swamps • Active Fluvial Units (AFU) • Landscape Level Biodiversity • Red-listed and Blue-listed Plant Communities • Sensitive Grizzly Bear Habitat

Objectives Prescribed Under Legislation (FRPA s. 149; FPPR s. 5-10)

• Soils • Wildlife

o Ungulate Winter Ranges (UWR) o Wildlife Habitat Areas (WHAs) o Marbled Murrelet (MaMu) o Queen Charlotte Goshawk o Coastal Tailed Frog o Great Blue Heron o Red Legged Frog o Keen’s Long-eared Myotis

• Riparian Areas o Adopting Regulation Provisions o Restrictions in a Riparian Reserve Zone (RRZ) o Forest Practices in a Riparian Management Zone (RMZ) o Management Zones on L1 lakes (Former Mid-Coast Forest District)

• Wildlife & Biodiversity o Maximum Cutblock Size o Harvesting Adjacent to Another Cutblock o Retention of Wildlife Trees o Restrictions on Harvesting Timber from a Wildlife Tree Retention Area

Objectives Established Under Government Action Requests

• Visual Quality


Objectives Jointly Managed by CFCI In addition to the management objectives included in individual Forest Stewardship Plans, the CFCI operating companies have identified the following objectives that will be jointly managed by the CFCI Group Manager. Adequate and Stable Workforce Objectives for Adequate and Stable Workforce from Local Communities 1) Provide employment and training for people from identified local communities (Bella Bella,

Bella Coola, Hagensborg, Ocean Falls, Shearwater and Dawson’s Landing). 2) Short Term – establish a baseline of direct local employment provided to the identified local

communities. 3) Long Term – maintain or increase on a per m3 of annual harvest basis direct employment

from the identified local communities. Local Procurement Objectives for Local Procurement of Goods and Services 1) Promote local business opportunities through local advertising for the provision of goods

and services from Bella Bella, Bella Coola, Hagensborg, Ocean Falls, Shearwater, Dawson’s Landing, Campbell River, Port Hardy and Port McNeill.

2) Develop and maintain a list of local businesses. Non-Timber Forest Products Objectives for Non-Timber Forest Products 1) Ensure that operations do not unnecessarily impede access for harvesting or gathering

known non-timber forest products. 2) Document procedures on how provisions for non-timber forest products are incorporated

into forest planning. Important Fisheries Watersheds

Objectives for Important Fisheries Watersheds

1) Maintain an equivalent clearcut area of less than 20% in important fisheries watersheds.

2) Despite subsection 1), an equivalent clearcut area of more than 20% may be maintained

after:

a) information-sharing or consultation with the applicable First Nations;

b) a coastal watershed assessment or similar assessment of watershed sensitivity to forest

development disturbance is completed to relevant professional standards;

c) maintaining an amount, type and distribution of forest cover that is sufficient to sustain

natural hydrological and fluvial processes, based on the assessment in subsection 2) b);

and

d) to the extent practicable, an adaptive management plan is developed and implemented

to monitor environmental impacts during any primary forest activity.


Upland Streams

Objectives for Upland Streams

1) Maintain 70% or more of the forest, in the portion of the watershed occupied by upland streams, as functional riparian forest.

2) For the purposes of subsection 1), allocate retention to include upland stream reaches with unique microclimate or other rare ecological or geomorphological characteristics.

3) Despite subsection 1), less than 70% of the forest in the portion of the watershed occupied by upland streams may be maintained as functional riparian forest after: a) information sharing or consultation with the applicable First Nation; b) a coastal watershed assessment or similar assessment of watershed sensitivity to forest

development disturbance is completed to relevant professional standards; c) maintaining an amount, type and distribution of forest cover that is sufficient to sustain

natural hydrological and fluvial processes, based on the assessment in 3) b); and, d) to the extent practicable, an adaptive management plan is developed and implemented

to monitor environmental impacts during any primary forest activity. Landscape Level Biodiversity

Objectives for Landscape Level Biodiversity

1) Except where alteration is required for road access, other infrastructure or to address a

safety concern, retain an amount of old forest equal to or greater than that specified for each

site series surrogate listed in:

a) Schedule 3 of the South Central Coast Order as it applies to DFA, and

b) Schedule 4 of the Central and North Coast Order as it applies to DFA. 2) Where there is less than the required amount of old forest available in the LU, to the extent

practicable, recruit forest to meet the representation requirements: a) within 180 years in South Central Coast Order area, or

b) within 250 years in Central and North Coast Order area. 3) Where recruitment to address 2) is necessary, harvesting will not increase the deficit except

where: a) alteration or removal is required for road access or to address a safety concern, or

b) information sharing or consultation with First Nations determines there is no practicable

alternative.

4) Maintain in each landscape unit less than 50% of each site series surrogate in mid-seral forest age classes to the extent practicable as listed in: a) Schedule 3 of the South Central Coast Order as it applies to the DFA, or

b) Schedule 4 of the Central and North Coast Order as it applies to the DFA. 5) Where there is more than 50% of any site series surrogate in mid-seral forest age class as

listed in 4), reduce the amount to less than 50% within 80 years, to the extent practicable.

6) To the extent practicable, include in old forest retention areas, habitat elements important for

species at risk, ungulates and regionally important wildlife.

7) To the extent practicable, include in old forest retention areas, stands of monumental cedar

for future cultural use in the area of the DFA to which the Central and North Coast Order

applies.


Red-Listed and Blue-Listed Plant Communities Objectives for Red-Listed and Blue-Listed Plant Communities 1) Where occurrences of the specified red-listed plant communities are identified in the field

protect each occurrence during primary forest activities. 2) Despite subsection 1), up to 5% of each occurrence of a red-listed plant community may be

disturbed if there is no practicable alternative for road access, other infrastructure or to address a safety concern.

3) Protect at least 70% of each occurrence of a blue listed plant community as set out in a) Schedule 5 of the South Central Coast Order as it applies to DFA, and

b) Schedule 6 of the Central and North Coast Order as it applies to DFA, during primary forest activities.

4) Where Terrestrial Ecosystem Mapping (TEM) is available or becomes available, protect at least 70% of each type of blue listed plant community that occurs in a landscape unit.


Timber Supply Review and Allowable Annual Cut The Forest Act requires that the Chief Forester of the province determine an Allowable Annual Cut (AAC) for the Crown land in each Timber Supply Area. In carrying out this legislated requirement the Chief Forester uses evidence provided by the Timber Supply Review (TSR) program. The objectives of the TSR are:

• To identify economic, environmental and social information that reflects current forest management practices, including their effects on short and long-term timber supply;

• To identify where improved information is required for future timber supply forecasts; • To provide the Chief Forester with information to use when making an AAC

determination. In making the AAC determination the Chief Forester considers technical reports, analyses and public input as well as government’s social and economic objectives. The Forest Act states that the Chief Forester shall specifically consider the following factors:

• The rate of timber production that may be sustained taking into account forest composition, rate of growth, siviculture treatments, utilization standards and constraints on timber production due to other forest use.

• The short and long-term implications of alternative rates of timber harvesting. • The economic and social objectives of government for the area. • Abnormal insect or disease infestations and planned salvage programs.

Ultimately, the Chief Forester’s AAC determination is an independent professional judgement based on the best available information. Mid Coast TSA Timber Supply Review and Allowable Annual Cut History The first Timber Supply Review for the Mid Coast Timber Supply Area was completed in 1994 and resulted in an AAC determination of 1,000,000 m3 effective January 1, 1995. The second Timber Supply Review was completed in 1999 and led to an AAC determination of 998,000 m3

effective June 1, 2000. On July 3, 2002 the Chief Forester ordered a 203,000 m3 reduction under Section 173 of the Forest Act resulting in an AAC of 795,000 m3. A subsequent Chief Forester order replaced the earlier order and reduced the AAC by 230,000 m3 to 768,000 m3 effective September 28, 2006, which remains the current AAC. Timber Supply Review information for the Mid Coast TSA is available at http://www.for.gov.bc.ca/hts/tsa/tsa19/. The following table shows the AAC history, including the indicated steady long-term harvest level (LTHL). Determination Effective Date AAC

(m3) Indicated LTHL (m3)

TSR 1 January 1, 1995 1,000,000 550,000 TSR 2 June 1, 2000 998,000 730,000-770,000 Section 173 Order - 203,000 m3

reduction July 3, 2002 795,000 NA

Section 173 Order - 230,000 m3

reduction September 28, 2006

768,000 NA


A third Timber Supply Review is underway and the proposed timeline for completion follows.

Mid Coast TSA Harvest Volume History The timber harvest volume billed for the entire Mid Coast TSA for last four calendar years, based on data from the Ministry of Forests and Range Harvesting Billing System, is shown in the following table.

Calendar Year Volume Billed (per HBS) (m3) 2007 595,330 2006 546,325 2005 889,101 2004 605,796

The average timber harvest volume billed over the last four completed calendar years is 659,138 m3, well below the current AAC of 768,000 m3 and the indicated Long Term Harvest Level from TSR 2 of 730,000-770,000 m3.


Training and Supervision Environmental Management Systems Each of the CFCI Operating Companies operates under an Environmental Management System (EMS). The purpose of the EMS is to enable the organizations to develop and implement policies and practices which take into account the legal requirements and environmental aspects of forest management in their operations. An important requirement of the EMS is training and awareness. Each of the organizations is required to deliver training and ensure the competence of forest workers for compliance with legal requirements and forest management plan objectives appropriate to their responsibilities. More information on the Operating Companies EM Systems is available at the following links: BC Timber Sales http://www.for.gov.bc.ca/bcts/areas/TST/TST_ems.htm Interfor http://www.interfor.com/interfor/environment/certification WFP http://www.westernforest.com/fstew/iso14001.html

Monitoring and Assessment Monitoring and assessment of forest management in the Mid Coast DFA is already in place through existing CFCI member certification programs (i.e. ISO 14001 and Sustainable Forestry Initiative), Forest Stewardship Plan monitoring and the BC government’s Forest & Range Evaluation Program. In April of 2008, CFCI members and other licensees initiated an FSP Collaboration discussion that focused on generating consistency within data management and tracking for EBM Implementation and assessment methodologies, and thresholds to work with other licensees at the watershed and landscape scale. This has generated a draft FSP Collaboration Framework designed to contribute to the joint monitoring and reporting commitments for ecological objectives indicators. It is anticipated that new members may join the FSC certificate through the Mid Coast TSA Group Certification. New and existing members will be assessed for evidence of and their ability to provide internal systems for monitoring key elements as referenced in Appendix 2 (CFCI Group Certification – Policies and Procedures 1.0 Appendix A).

Chain of Custody The BC system of identifying and tracking harvested wood from the forest to a designated scale site is entrenched in a regulatory requirement under the Forest Act (see link below). The issuance of a cutting permit and its associated Timber Mark allows the tracking and movement of coastal wood to a designated place of scale to ensure proper identification of grade occurs for


the purpose of deriving the stumpage payment owed to the Crown for the consumptive use of the public resource. http://www.for.gov.bc.ca/tasb/legsregs/forest/faregs/timmark/tmr.htm Users of wood from the Defined Forest Area can identify this legal system to effectively communicate the point source of the wood and wood fibre origins in relation to the defined forest area.


Adaptive Management CFCI recognizes that this SFM Plan is not static but will need to change over time through the iterative process of adaptive management in response to the results of monitoring, assessment and new information. The process envisioned is shown in the following diagram (modified from the FSC BC Guidance document, pg 28) where the review of annual and periodic monitoring will be used to generate recommendations for changes to the Plan and its implementation. Revisions to the Plan will be made to respond to:

• The results of monitoring, • New technical or scientific information, and • New social and economic information.

Coast Forest

Conservation Initiative Group Certification

Adaptive Management

CFCI AM

Working Group Review

monitoring outcomes;

Generate recommendations;

Feedback on

necessary modifications.

Forest Manager Reviews summary report

recommendations Initiate necessary

plan modifications

Annual

Monitoring Report generated

and outcomes

summarized.

Forest Stewardship

Plans


Appendices


Appendix 1 - Forest Stewardship Council Group Certification - Consent Form


Coast Forest Conservation Initiative

New thinking about forest conservation

File: FSC – PA 10.1

Date: June 4th, 2008

Forest Stewardship Council Group Certification - Consent Form

As members of the Coast Forest Conservation Society we commit to achieving the following;

As a group will provide resourcing and oversight through each of our respective businesses to meet the

British Columbia Regional Certification Standards – based on the FSC Principles and Criteria.

As a group we agree to identify and respond in a manner that effectively meets the requirements for group

certification that will be evaluated during initial assessment and annual audits (see group certification

criteria below in Appendix A)

We the undersigned members of Coast Forest Conservation Initiative for the purpose of satisfying the

Group Certification Requirement 6, consent to the following;

i. acknowledges and agree to the obligations and responsibilities of group membership;

ii. agree to group membership for the full period of validity of the group certificate;

iii. authorize the group manager to apply for certification on the member's behalf; and,

iv. acknowledges SmartWood and FSC’s right to access their forest for evaluation and

monitoring.

Ric Slaco on behalf of International Forest

Products

Lyn Brown on behalf of Catalyst

Jim Sutherland on behalf of British Columbia

Timber Sales

Ken Higginbotham on behalf of CANFOR

Stan Coleman on behalf of Western Forest

Products




Appendix A

Smartwood Group Certification (GC): Forest Management Model – GC Requirements

GC 1: The group manager is an independent legal entity or an individual acting as a legal entity.

GC 2: The group manager has made a full disclosure of all forest areas over which the GM has

some responsibility, whether as owner (including share or partial ownership), manager,

consultant or other responsibility. Justification for exclusion of forestlands from certified pool

has been provided.

GC 3: The group manager has sufficient legal and management authority and technical and

human resources (e.g. qualified staff, equipment..) to implement their responsibilities

GC 4: The responsibilities of the group manager and group members are clearly defined and

documented, e.g., with respect to management planning, monitoring, harvesting, quality control,

marketing, processing, etc

GC 5: Group membership requirements are documented and include:

i. Procedures and rules of entry and exit from the certified pool; and,

ii. Procedures for the notification of SW of changes in membership within 30 days of

changes.

GC 6: A 'consent form' or its equivalent has been signed by each group member

The consent form at a minimum:

i. acknowledges and agrees to the obligations and responsibilities of group membership;

ii. agrees to group membership for the full period of validity of the group certificate;

iii. authorizes the group manager to apply for certification on the member's behalf; and,

iv. acknowledges SmartWood and FSC’s right to access their forest for evaluation and

monitoring.

GC 7: Group manager has provided each group member with documentation including:

i. The applicable forest stewardship standard;

ii. An explanation of the certification process; and,

iii. An explanation of group membership requirements

GC 8: Group manager has a policy and practice for monitoring of the properties in the certified

pool to ensure that they are meeting the FSC P&C and group membership requirement

FM Group Certification (p) page 4 August 2007

GC 9: The group manager has a system for maintaining the following records up to date at all

times:

i List of names and addresses of group members, together with date of entry into group

certification scheme;

ii Maps of all forest areas included in the group certification;

iii Records demonstrating tenure of group members;

iv Evidence of consent of all group members, preferably in the form of a signed 'consent

form';

v Relevant documentation and records regarding forest management of each group

member (e.g. management plans, summary information regarding silvicultural system,

management operations, volume production);

vi Records demonstrating the implementation of any internal control or monitoring systems.

Such records shall include records of internal inspections, non-compliance identified in

such inspections, actions taken to correct any such non-compliance; and,

vii Relevant documentation regarding production and sales


Appendix 2 - CFCI Group Certification – Policies and Procedures 1.1




CFCI Group Certification – Policies and Procedures 1.1

FSC – Mid Coast TSA Date: November 20th, 2008

Preamble The Coast Forest Conservation Initiative society was formed to engage in land use and conservation planning tables in the Central and North Coast and to seek outcomes that were sustainable for the environment and socio-economic needs. The Central Coast LRMP table recommendations in 2004 were followed by the agreed to First Nation – Provincial Government Land Use Decision in 2006. This precipitated the development and coming into force of the Land Use Objectives in the Central and North Coast. The legal objectives found in the orders are a component of implementing the system of Ecosystem Based Management in the Central and North Coast and influence the forest management regime in the region.

“a new approach to planning and resource management known as Ecosystem-based

Management (EBM). EBM is defined as "an adaptive approach to managing human activities that seeks to ensure the coexistence of health, fully functioning ecosystems and human

communities” FSC forest management certification is seen as a vehicle to effectively communicate with the market place an example of forest sustainability achieved in this region. CFCI is seeking FSC certification within the Mid Coast Timber Supply Area on forest lands managed by CFCI Group Members.

FSC Forest Management Certification is; the process of inspecting forestlands or woodlands to verify that they are being managed according to the FSC Principles and Criteria (P&C); designed to ensure that timber harvesting is ecologically sound and socially and economically beneficial to local communities;

a voluntary program that creates market incentives by providing consumers the power to positively "vote" for good forest stewardship: when they buy certified wood products they contribute to the conservation of forests and biodiversity worldwide.




Policies

Roles and Responsibilities Coast Forest Conservation Initiative - Group Manager

i. Establish a Sustainable Forest Management Plan for the defined forest area that ensures conformance with FSC P&C.

ii. Manage the certification and communications with Smartwood, including initial

certification and subsequent surveillance audits

iii. Publicly communicate the commitment to FSC Principles and Criteria. iv. Communicate to members any changes in FSC requirements.

v. Notify members of any changes in the Mid-Coast TSA certification status.

vi. Initiate task groups as required to facilitate maintenance of the Group Certification.

vii. Handle requests for new membership.

viii. Maintain records related funding agreements required for continued maintenance

of the Group Certificate.

Group Certification Member: Tenure owner/managers certification responsibilities

i. Sign the consent letter and adhere to the commitments within – Appendix A

ii. CFCI Group Manager to develop long-term goals and objectives that are compatible with members’ needs and the FSC P&C. Implement Ecosystem Based Management in a manner that can be reflected in the long-term goals and objectives in the Sustainable Forest Management Plan.

iii. Communicate any complaints or issues with harvest contractors, neighbours, and regulators to the CFCI Group Manager regarding the management of members’ tenure(s).




iv. Commit to promote and make available opportunities that maintain or improve the socio-economic well being of communities and businesses within the Defined Forest Area.

v. Participate in external audits

vi. Communicate any changes in the management or ownership of your license.

vii. Seek and maintain the relevant Chain of Custody for certified forest products

utilized by the member. Group Certification Member: Non Tenure holding members

i. Promote their involvement and support for continued FSC certification in the Defined Forest Area.

ii. Seek and maintain the relevant Chain of Custody for certified forest products received from the Defined Forest Area.

Record Keeping – Group Certification Manager CFCI will maintain relevant FSC certification records through its existing Secretariat function under its charter including;

i. A list of names and addresses of group members, together with date of entry into group certification scheme;

ii. Maps of all defined forest areas included in the group certification;

iii. Records demonstrating tenure of group members;

iv. Evidence of consent of all group members, in the form of a signed 'consent form' – see Appendix A;

v. Sustainable Forest Management Plan which includes relevant documentation and records regarding forest management of each group member.

vi. Records related to the dispute resolution mechanism; occurrence, resolution and subsequent knowledge summaries.




Records to be kept by member of the group certification i. Approved Forest Stewardship Plan and FRPA related reporting requirements.

ii. Records demonstrating the implementation of any internal control or monitoring systems (i.e.: Environmental Management System –EMS).

a. Such records shall include records of internal inspections or environmental monitoring; including non-compliance identified in such inspections, actions taken to correct any such non-compliance.

iii. Relevant documentation regarding production and sales

Procedures

Rules of entry and exit from the certified pool Entry into the certified group - To enter the certified group of tenure holders/managers, we ask that you:

i. Acknowledge your acceptance of these terms and conditions of being a member of the certified group by signing the consent form in – Appendix A.

ii. Manage your forest in accordance with the Forest Stewardship Council (FSC)

Principles and Criteria (British Columbia FSC Regional Standard).

iii. Adhere to the management plan prepared and approved for the group certification. iv. Allow the Group Certification Manager and/or the certification auditors to review

forestry practices on your land and review documents pertaining to the management of your land anytime during the certification period with due notice.

v. Notify the Group Certification Manager if there are any changes in the ownership

or management of your land during the certification period. The Members of the Group Certification Program will not be required to pay dues for membership in the society. Each Member upon, and as a condition to, admission to the Society, will be required to enter a funding agreement with the Society for the purpose of maintaining the FSC Group Certification program.




New Members into the certified group - New member entries will be accepted provided they;

i. make a written request for membership to the Group Manager who in turn will notify the existing membership of the request and respond within 30 days;

ii. agree to follow the responsibilities and rules for New Member entry Exiting the group of certified landowners/managers - Leaving the group of certified tenure owners/managers will be precipitated if a member:

i. Requests to be removed from the group certificate giving 30 days notice with no further requirements as it is a voluntary program;

ii. Does not adhere to the management plan and BC Regional Standard FSC P&C as identified through the mechanism or group surveillance monitoring can result in expulsion through a notice of removal by the Group Manager;

iii. Refuses to allow us and/or our Certifier access to your land for auditing,

monitoring, or land management purposes; iv. Ceases to be the owner of the forest license in the defined forest area or;

v. Does not make the required contribution under the funding agreement

Monitoring of member tenures in the Defined Forest Area: The Group Certification Manager will work with its members to ensure an internal monitoring program exists for each member that will satisfy key components of a monitoring plan, including;

i. Goals and objectives for monitoring—rationale for monitoring, intensity of monitoring

ii. Indicators to be monitored; examples are provided in Appendix A

iii. Incorporating monitoring results into the management plan

iv. Generate a monitoring summary for public review




v. Relationship with other monitoring or adaptive management initiatives in the region. i.e. – full Ecosystem Based Management implementation requires an Adaptive Management Framework be in place.

The Group Certification Manager will also verify that the members are conforming to the requirements of monitoring and assessment as found in the Group Certification - Sustainable Forest Management Plan. Complaints and/or Dispute Resolution Complaint and/or disputes that are related to the groups approach to sustainable forest management and activities required to maintain FSC certification will be respectfully and fairly addressed. Members are responsible for maintaining internal records associated with receipt, response and resolution of complaints (see Appendix D – Mechanism) including any formal dispute resolution process used. Members will provide a notice of occurrence report within 30 days of complaint or completion of the dispute resolution process to the Group Certification Manager. The GC Manager may strike a review committee to generate a knowledge summary bulletin for its members if the complaint or dispute puts the Group Certification and commitment to FSC P&C at risk. Corrective Action Requests The Group Certification Manager will establish committees comprised of the appropriate staff across the members to identify timely responses, action and/or remedy to identified CAR’s by the certified auditor. Description of the Defined Forest Area – Reference Sustainable Forest Management Plan Disclosure statement – Insert list of tenures in table format and may include a relevant Map – To be appended upon receipt of FSC certificate. Use of Logo FSC owns three trademarks: the name "FOREST STEWARDSHIP COUNCIL", the initials "FSC", and the "checkmark-and-tree" logo. All uses of these trademarks, especially on certified products or for promotion, are considered under license.




Smartwood as the FSC accredited certification body will issue the authorization to use the FSC trademarks upon completion of a successful assessment and issuance of a FSC certificate at which time members can begin to utilize the logo on its products, labels and communication medium.




Appendix A Monitoring Elements and System Requirements Indicators to be monitored in the field Document monitoring by keeping appropriate records (e.g. inventory results), forms (e.g. harvest inspection), or notes (e.g. field observations, discussions with neighbours) Yield of forest products harvested—records are maintained of the following:

• Standing timber and timber harvest volumes by species, volume, and grade • Yield of harvested non-timber forest products by species, volume and grade • Unanticipated removals (e.g., theft and poaching) of forest products

Growth rates, regeneration, and condition of the forest (this may be qualitative on small and medium sized forests—keep inventory records or notes to document)

• Growth rates, regeneration, and condition of the forest are assessed at least every 10 years

The monitoring system assesses: Timber growth, mortality, stocking, and regeneration Stand composition and structure Effects of disturbance to the resources (e.g., management activities, disease, wind, flood, fire, and damage by insects and/or mammals) Abundance, regeneration, and habitat conditions of NTFP Quality and quantity of water Terrestrial and aquatic habitat Ecosystem composition, structures, and functions Soil characteristics Vulnerability to fire and pests




Composition and observed changes in flora and fauna—assess, at least every 5 years, changes in the following resources (keep inventory records or notes on observations to document): Major forest habitat elements

Occurrence of rare, threatened, and endangered species and their habitats Environmental impacts of harvesting and other operations— using a Preharvest Plan and Harvest Inspection form are good ways to document environmental impacts monitoring:

• Environmental impacts of site-disturbing activities (e.g., road construction and repair, harvesting, site preparation) are assessed after their completion

• Condition and environmental impacts of road system

Social impacts of harvesting and other operations—seek to maintain good relations with neighbours and communities through:

• Local job creation and maintenance • Information sharing related to management activities • Protection of sites of special significance (e.g. cemeteries, grave sites)

addressed with appropriate representative for the site




Appendix B Member Dispute Resolution - Mechanism [Business] process for responding to complaints about our operations, labor practices and employment decisions, community relationships, user right decisions, [other] is as follows: A. [The business] may receive either a written or verbal complaint. As a general policy, we will encourage the complainant to put the complaint in writing. If they choose not to do so, the person they have contacted at [our business] may put the complaint in writing and distribute to the relevant manager. B. Written Response to All Complaints: [Our] staff will document and respond in writing to all written complaints within 15 days. [Our] staff will review verbal complaints and request that the complainant put the complaint in writing. If the complainant fails to put the complaint in writing, we may or may not respond. C. Notification of the Group Member or Staff Person who the Complaint is Being Filed Against (if applicable): As per the above, upon receiving and/or documenting a complaint, the [group entity] will send this written complaint, or documentation of said complaint, to the member or staff person to which it has been lodged. D. Opportunity for Response (if applicable): [Business] will always give an opportunity to the member or staff person to give a perspective on the complaint (e.g., their own version of the incident, historical background). This may be done in either verbal or written fashion, preferably in writing. E. Initial Group Entity Response: [Business] will provide a written response to the complainant within a 15-day period. Group entity will deal with such situations expeditiously and professionally with a priority on fairness to both parties.

Group Certification Manager – Involvement F. Resolution: If resolution is reached during any of the steps outlined above, memorandums for the record are distributed to the CFCI Group Manager within 30 days upon receiving a complaint or the completion of the dispute resolution process. The complainant will receive final documentation and/or closure on the complaint and follow-up. Continued….




G. Dispute Resolution: If the complainant is not satisfied with the [business] response, a third party, agreed upon by both CFCI and the complainant will be engaged to clarify and, if possible, resolve the complaint. The third party must be independent (i.e., not have been involved with either the business or the complainant in the past in any way). Costs of the third party’s time will be shared equally. If, after input and actions by the third party, there is no resolution, CFCI will ask that the complainant accept binding arbitration. Failing that, the courts will have to decide. H. In consultation the approach used for dispute resolution will be agreed to between the parties; where applicable the appropriate Government agency may be requested or required to be involved.