Supply Base Report:
BSL Woodfiber SA
Main (Initial) Audit
www.sbp-cert.org
Completed in accordance with the Supply Base Report Template Version 1.3
For further information on the SBP Framework and to view the full set of documentation see www.sbp-cert.org
Document history
Version 1.0: published 26 March 2015
Version 1.1 published 22 February 2016
Version 1.2 published 23 June 2016
Version 1.3 published 14 January 2019; re-published 3 April 2020
© Copyright Sustainable Biomass Program Limited 2020
Supply Base Report: BSL Woodfiber SA Page ii Contents
1 Overview ...... 1 2 Description of the Supply Base ...... 3 2.1 General description ...... 3 2.2 Actions taken to promote certification amongst feedstock supplier ...... 9 2.3 Final harvest sampling programme ...... 9 2.4 Flow diagram of feedstock inputs showing feedstock type [optional] ...... 9 2.5 Quantification of the Supply Base ...... 11 3 Requirement for a Supply Base Evaluation ...... 13 4 Supply Base Evaluation ...... 14 4.1 Scope ...... 14 4.2 Justification ...... 14 4.3 Results of Risk Assessment ...... 14 4.4 Results of Supplier Verification Programme ...... 15 4.5 Conclusion ...... 15 5 Supply Base Evaluation Process ...... 17 6 Stakeholder Consultation ...... 18 6.1 Response to stakeholder comments ...... 18 7 Overview of Initial Assessment of Risk ...... 19 8 Supplier Verification Programme ...... 20 8.1 Description of the Supplier Verification Programme ...... 20 8.2 Site visits ...... 20 8.3 Conclusions from the Supplier Verification Programme ...... 20 9 Mitigation Measures ...... 21 9.1 Mitigation measures ...... 21 9.2 Monitoring and outcomes ...... 23 10 Detailed Findings for Indicators ...... 24 11 Review of Report ...... 25 11.1 Peer review ...... 25 11.2 Public or additional reviews ...... 25 12 Approval of Report ...... 26 13 Updates ...... 27 13.1 Significant changes in the Supply Base ...... 27 13.2 Effectiveness of previous mitigation measures ...... 27 13.3 New risk ratings and mitigation measures ...... 27
Supply Base Report: BSL Woodfiber SA Page iii 13.4 Actual figures for feedstock over the previous 12 months ...... 27 13.5 Projected figures for feedstock over the next 12 months ...... 27 Annex 1: Detailed Findings for Supply Base Evaluation Indicators ...... 28
Supply Base Report: BSL Woodfiber SA Page iv 1 Overview
Producer name: BSL Woodfiber, S.A.
Producer location: Headoffice: Travesia de La Marina, 51, 3º, 27850, Viveiro (Lugo), SPAIN - Chipping operations: Porto Exterior de Ferrol - Pioriño, 15593, Ferrol (A Coruña) SPAIN - Storage of logs: o Port of Burela: Muelle - Avenida da Mariña, 27880, Burela (Lugo) SPAIN o Port of Cariño: Zona Portuaria de Cariño, 15360, Cariño (A Coruña) SPAIN o Port of Ribadeo: Peirao de Mirasol, 27700, Ribadeo (Lugo), SPAIN o Port of Huelva: Plaza Aurtoridad Pueto de Huelva, (Huelva) Spain
Geographic position: Headoffice: 43°39'36" N - 7°35'48” W - Chipping operations: 43°27'59” N - 8°19'17" W - Port of Burela: 43°39'26’’ N - 7°20'53’’ W - Port of Cariño: 43°44'17’’ N - 7°51'57’’ W - Port of Ribadeo: 43°32'00’’ N - 7°02'16’’ W - Port of Huelva: 37°11'26.4"N+6°55'53.4"W
Primary contact: Cecília Nolasco / Pedro Rodrigues – [email protected]
Company website: http://www.bsl.pt
Date report finalised: 24/Jul/2020
Close of last CB audit: 18/Dec/2020
Name of CB: Control Union Certifications
Translations from English: Yes, to Spanish
SBP Standard(s) used: Standard 1, v. 1.0; Standard 2, v. 1.0; Standard 4, v. 1.0; Standard 5, v. 1.0.
Weblink to Standard(s) used: https://sbp-cert.org/documents/standards-documents/standards
SBP Endorsed Regional Risk Assessment: N/A
Weblink to SBE on Company website: http://www.bsl.pt/madeira/
Supply Base Report: BSL Woodfiber SA Page 1 Indicate how the current evaluation fits within the cycle of Supply Base Evaluations
Main (Initial) First Second Third Fourth Evaluation Surveillance Surveillance Surveillance Surveillance
ý ☐ ☐ ☐ ☐
Supply Base Report: BSL Woodfiber SA Page 2 2 Description of the Supply Base
2.1 General description
BSL Woodfiber is a wood producer that could operates as:
- Woodchips producer in the Port of Ferrol. In this case, the wood is purchased to forest owners, of eucalyptus plantations FSC, and also occasionally PEFC, certified. All of them are small plots from smallhorlders certified under Groups certificates. Port of Ferrol can also receibe eucalyptus wood from external suppliers, but amost all wood is FSC or FSC and PEFC certified. Despite its history of handling wood logs and wood chips in Spain, BSL Woodfiber is in an initial phase of SBP implementation, with the aim of reaching an annual average of 25,000 tonnes per year. Considering the total amount of woodchips that BSL woodfiber processes, BSL Woodfiber is one of the largest woodchips producers Galicia for exportation. - As a loging company, selling logs in Ports of Burela, Cariño and Ribadeo. Wood is purchased also to forest owners of FSC or FSC and PEFC eucalyptus plantations. BSL Woodfiber can also purchase logs of pine to external suppliers. This pine wood is also FSC or PEFC certified in most of the cases. As a Logging company is also a very relevant player in the north of Galicia, especially on the eucalyptus market. - Woodchips producer in the Ports of Huelva. BSL receibes all logs of pine and eucaliptus from one supplier, that is also works as a subcontractor of chipping operations. This wood is not FSC or PEFC certified.
The supply base of BSL Woodfiber can be defined by all the provinces and Autonomous Communities where the company operates:
- Galicia - Principado de Asturias - Andalucía - Castilla y León
The supply Base is considered homogenous with regard to SBP risks despite the different ecoregions, because of the similar legislation and level of compliance.
BSL only accepts wood from a short list species. None of them are listed by CITES or IUCN: Especies principals: • Maritime pine (Pinus pinaster) • Scots pine (Pinus sylvestris) • Monterey pine (Pinus radiata) • Austrian pine (Pinus nigra) • Stone pine (Pinus pinea) • Pino carrasco (Pinus halepensis) • Eucalypt (Eucalyptus spp.) • Poplar (Populus spp.). • Acacia (Acacia spp.) Volúmenes residuales de: • Oak (Quercus rubra), as secondary species, not from natural forest • European oak (Quercus robur), as secondary species, not from natural forest • Sessile oak (Quercus petraea), as secondary species, not from natural forest • Rebollo oak (Quercus pyrenaica), as secondary species, not from natural forest • Willow (Salix babylonica), as secondary species, not from riparian vegetation • Planes (Platanus spp.), as secondary species, not from natural forest • Chestnuts (Castanea spp.), as secondary species, not from natural forest
Supply Base Report: BSL Woodfiber SA Page 3 • Ash (Fraxinus spp.), as secondary species, not from riparian vegetation • Alder (Alnus spp.), as secondary species, not from riparian vegetation
Forest Land
Spanish mainland forest occupies around 55% (27.165.392 hectares)1 of the territory. A global description of mainland Spain by Autonomous Community (CC.AA.):
CC.AA. Total area (ha) Forest area (ha) Andalucía 8.759.100 4.467.070 51% Aragón 4.769.800 2.615.332 55% Cantabria 525.300 364.317 69% Castilla - La Mancha 7.940.900 3.597.537 45% Castilla y León 9.381.400 4.815.357 51% Cataluña 3.209.100 2.008.329 63% Comunidad de Madrid 802.200 438.262 55% Comunidad Foral de Navarra 980.100 594.366 61% Comunidad Valenciana 2.325.400 1.267.036 54% Extremadura 4.163.400 2.872.451 69% Galicia 2.957.400 2.040.754 69% La Rioja 502.800 310.952 62% País Vasco 708.900 491.786 69% Principado de Asturias 1.060.400 770.479 73% Región de Murcia 1.131.300 511.364 45% Total 49.217.500 27.165.392 55%
According to data from the INE (Spanish National Institute of Statistics), Spain has the third longest forest cover in the European Union after Sweden and Finland.
Species The total volume of cuts in 2017 was 17.680.025 m3. And the most relevant species of both softwoods and hardwoods2:
Softwood (54% of total):
Specie Volume (m3) Pinus radiata 3.618.924 Pinus pinaster 3.402.714 Pinus sylvestris 1.362.173 Pinus nigra 552.315 Pinus halepensis 259.821 Pinus pinea 136.388 Other Pinus spp. 123.391
1 Anuario de Estadística Forestal 2017; Instituto Geográfico Nacional 2 Anuario de Estadística Forestal 2017; Instituto Geográfico Nacional
Supply Base Report: BSL Woodfiber SA Page 4 Other softwoods 133.295 TOTAL 9.589.021
And hardwoods (46%):
Specie Volume (m3) Eucalyptus spp. 6.939.402 Populus spp. 531.587 Quercus robur 134.861 Quercus ilex 119.181 Castanea sativa 101.531 Quercus pyrenaica 94.816 Other hardwoods 169.626 TOTAL 8.091.004
Property According to data from MAPA (Ministry of Agriculture, Fisheries and Food), 27% (7,317,900 hectares) of forest cover corresponds to public domain forests that belong to the State, to the Autonomous Communities (AC), to local organisations and to other organisations under public law. And 73% (19,847,488 hectares) is private forests owned by individuals or legal entities under private law and are either individually or co-owned, which can be further categorised into:
• Collectively owned which represent 3% of the total, and • Private forests, with a significant superficial variability according to the different zones, from the Galician micro-property to the large estates in other Autonomous Communities, which represent 70%.
Property Forest area (ha) (%) Communities 823.289 3,03% Private 19.024.198 70,03% State and Aut. Com. 1.458.703 5,37% Local entities 5.859.198 21,57% Total 27.165.388 100,00%
Forestry management practices or land management practices
Article 33 of the Forest Law establishes the necessity for public forests and protected forest areas to have a Forest Management Plan and an Operational Scheme or another equivalent Management Instrument. These documents are elaborated by forest management units and must always be approved by the regional forestry organization. Regional forestry organizations regulate in which cases it is mandatory to have a management instrument for regular private and public forests (not catalogued as protected). Multiple laws in each Autonomous Community regulate the specific technical forestry operating constraints of forest management.
In accordance with Spanish legislation, there are three possible legal documents that prove legality of forest operations: • Notification for harvesting (in private forests with Forest Management Plan or equivalent). The owner must notify the competent body of the Autonomous Community before harvesting. • Authorization for harvesting (in private forests without a Forest Management Plan). It is required to obtain the Authorization before harvesting.
Supply Base Report: BSL Woodfiber SA Page 5 • Adjudication for harvesting (in public forests).
The three documents are evaluated by forestry technicians of the administration and enhance the legality, sustainability and respect for the environment of the requested harvesting operations. The technicians, in all three cases, make an on-site inspection of the forest to be sure of the best sustainable management of the forest. If the area of harvesting is related to any special protection function, they consult with the competent organization to make sure that environmental aspects are respected. For example, if the harvesting is within a natural park, the technician of the natural park, can mark restrictions in the cutting permit, for example, as not to interfere with nesting of certain bird species in a certain season. The technician can also prohibit operating in certain areas.
In the case of natural catastrophes, such as forest fires, wind and snowfall damage, or pests, additional cutting authorizations can be issued to mitigate the impact. These operations aim at preventing forest pests and guaranteeing regeneration of the forest area.
According to the 2010 report of the SECF "Spanish Society of Forestry Sciences", the following characteristics of Spanish forests serve as the basis for understanding the situation in forestry today: • The annual growth (net increment) of wood is three times higher than the amount that is cut and harvested. The increment is 45 million m3 annually and wood extraction is around 17 million m3 a year. • The total annual consumption of wood is around 32 to 33 million m3; Spain imports around 15 million m3 a year. Certain aspects related to the costs of exploitation, the structure of the market for forest products, and the use of current legal, financial and administrative instruments that have become obsolete in today's society, are some of the causes of this disbalance. • Spanish forest area is expanding, and this trend manifests itself to a greater extent than in other European countries. Spanish forests cover over half the national surface. Regarding total forest area Spain is the third country in the European Union, behind Sweden and Finland, but ahead of France, Germany, and Poland. • The forested area per inhabitant is higher in Spain than the average in the European Union. Spain has in average 0.4 ha of forest per inhabitant, compared to 0.3 ha per inhabitant in the EU. • Most of the Spanish forests consists of native species. Contrary to what is often mentioned in various media, the area covered by hardwood species exceeds the area covered by coniferous species. • Spanish forests are multifunctional. Important is the protective role of forests and their ability to conserve the hydrological cycle, and biodiversity. Its production function of forest products (wood, firewood, biomass for energy, cork, resins, edible mushrooms, pinion, livestock) is not negligible either. Hunting is also practised in Spain. The role of forests related to carbon fixation and the maintenance of the landscape and its biological wealth is transcendent. Spanish forests play an important role in improving air quality and mitigating of climate change. A study carried out in the CIFOR-INIA shows that at present, Spanish forests accumulate around 87 million tons of CO2 every year due to their growth. This means that the forests fix more than 24% of the total CO2 emissions of Spain each year. • The current average consumption of wood in Spain is 0.8 m3 per inhabitant, in Central Europe it is 1.5 m3 and in Northern Europe 3.0 m3. Everything indicates that Spanish consumption of wood will continue to grow and that there will be a need to extract more wood from the Spanish forests or import more from other countries. The Forestry Sector has a great potential in the creation of rural employment (unemployment is a major problem in Spain, it decreased to 14.55% of the active population in 2018). If harvesting would increase from 15 to 30 million m3 a year, forestry employment could double, from the current 155 000 to around 300 000 jobs. The Forestry Sector has an increasing influence on rural development through forestry, hunting, recreational use and rural tourism. • More than 2/3 of the Spanish forest area is privately owned, what must be taken into account when encouraging certain forest policies. • Spanish forests are to a large extent abandoned. The forests are accumulating fuel biomass in excess, which increases the risk of large forest fires, and yet the use of its biomass for energy purposes is not considered an attractive business by energy companies.
Supply Base Report: BSL Woodfiber SA Page 6
Ecoregions
There are two main different ecoregions3 in Mainland Spain, each of them can be subdivided:
- Temperate broadleaf and mixed forests 1. Cantabrian mixed forests 2. Pyrenees conifer and mixed forests - Mediterranean forests
3 According to WWF
Supply Base Report: BSL Woodfiber SA Page 7 3. Iberian conifer forests 4. Iberian sclerophyllous and semi-deciduous forests 5. Northeastern Spain and Southern France Mediterranean forests 6. Northwest Iberian montane forests 7. Southeastern Iberian shrubs and woodlands 8. Southwest Iberian Mediterranean sclerophyllous and mixed forests
1 2 6 5
3
4
8 7
According to IUCN,4 “Spain is one of the most diverse countries in terms of biodiversity in the European Union. Situated between the Atlantic and the Mediterranean, Spain contains four of the nine biogeographic regions of the European Union (Atlantic, Alpine, Mediterranean and Macronesian), which provide the coexistence of a large number of species of fauna and flora. The country is located in one of the 25 biodiversity hotspots in the world, thanks to its high rate of endemisms, which requires specific steps to address conservation issues… Protected areas in Spain cover more than 15 million hectares, representing over 27% of its land are”
Because of this, the conservation of HCVF is critical. Biomass production is not a controversial sector, since most part of the feedstsock is coming from co-products, cleanings and pruning. Forest operations in protected areas are limited and controlled, with low impacts in the remain ecosystem.
Despite this diversity, there are no CITES species in Spain.
Biomass sector
More specifically, the biomass sector in Spain is still young, especially if we take into account all its potential5. The overall dynamics of the Spanish forest sector is promoted or supported by other sectors like:
4 https://www.iucn.org/regions/europe/resources/country-focus/spain?page=1 5 http://www.unionporlabiomasa.org/pdf/Balance_Biomasas.pdf
Supply Base Report: BSL Woodfiber SA Page 8 • Pulp and paper • Board panels • Saw timber • Silvopastoral (forest grazing for pork, cows,etc.)
There are also other specific Mediterranean non-timber forest products (NTFPs) such as cork, resin and pine cones, with great social and economic relevance in rural areas.
2.2 Actions taken to promote certification amongst feedstock supplier
BSL encourages FSC and PEFC certification among its suppliers, underlining the advantages and importance of forest certification to the wood sector
2.3 Final harvest sampling programme
BSL feedstock comes 0-20% from forest residues from final fellings or from forest maintenance operations, and aproximately 80-100% comes from logs of final fellings. Most of final fellings are small, around 2 ha or less. In the north clear cuts are restricted to maximally 10 ha. Reforestation is performed by the land owners.
From the species used by BSL, several Pines (Pinus pinaster, Pinus sylvestris, Pinus nigra, Pinus pinea) can have a planned forest management period of more than 40 years, but BSL only uses low grade roundwood. Eucalyptus, poplar and Pinus radiata are fast-growing species, with a rotation of less than 40 years.
BSL examines the forest plots and their age before harvest. The age of the forest is indicated on the comunications / authorizations of harvesting.
2.4 Flow diagram of feedstock inputs showing feedstock type [optional]
Woodchipping in the Port of Ferrol:
Supply Base Report: BSL Woodfiber SA Page 9 Forest operations Chipping by: by: •BSL Woodfiber Storage (Port of •Suppliers Ferrol) •BSL Woodfiber
Loadding of vessel Client
Logging operations (Ports of Burela, Cariño and Ribadeo):
Forest operations by: Storage (Ports of Burela, Cariño, • Suppliers Ribadeo) • BSL Woodfiber
Loadding of Client vessel
Woodchipping in the Port of Huelva:
Supply Base Report: BSL Woodfiber SA Page 10 Forest Chipping by: operations by: Storage (Port • Supplier (as a of Huelva) • Suppliers subcontractor)
Loadding of Client vessel
2.5 Quantification of the Supply Base Supply Base a. Total Supply Base area (ha): Asturias: 770.000 ha Galicia: 2.030.680 ha Andalucía: 4.467.070 ha Castilla y León: 4.815.357 ha TOTAL: 12.093.660 ha b. Tenure by type (ha): 73% Privately owned and 27% Public owned c. Forest by type (ha): 100% Temperate Forest d. Forest by management type (ha): 12% Plantation, 88% Managed Natural e. Certified forest by scheme (ha): FSC: 313 thousand ha (2020) PEFC 2.311 thousand ha (2020) Feedstock f. Total volume of Feedstock: 0 - 200.000 tonnes (127.546 tonnes of round wood for pulp and paper industries) g. Volume of primary feedstock: 0 - 200.000 tonnes (127.546 tonnes of round wood for pulp and paper industries) h. List percentage of primary feedstock (g), by the following categories: - 80%-100% Certified to an SBP-approved Forest Management Scheme (FSC and PEFC) - 0%-20% Not certified to an SBP-approved Forest Management Scheme i. List all species in primary feedstock, including scientific name • Maritime pine (Pinus pinaster) • Champion oak (Quercus rubra) • Scots pine (Pinus sylvestris) • Weeping willow (Salix babylonica) • Monterey pine (Pinus radiata) • Acacia (Acacia spp.) • Austrian pine (Pinus nigra) • Planes (Platanus spp.) • Stone pine (Pinus pinea) • Chestnuts (Castanea spp.) • Eucalypt (Eucalyptus spp.); • Ash (Fraxinus spp.) • Poplar (Populus spp.). • Alder (Alnus spp.) • Portuguese oak (Quercus fagines)
Supply Base Report: BSL Woodfiber SA Page 11 j. Volume of primary feedstock from primary forest None k. List percentage of primary feedstock from primary forest (j), Not applicable l. Volume of secondary feedstock: None m. Volume of tertiary feedstock: None
Supply Base Report: BSL Woodfiber SA Page 12 3 Requirement for a Supply Base Evaluation
SBE not SBE completed completed
ý ☐
BSL Woodfiber has chosen to implement the SBP Supply Base Evaluation method (SBP Standard 1), to cover the small percentage of inputs (less than 20%) that are no SBP-approved Forest Management Scheme compliant.
BSL Woodfiber is compromised to obtain international recognition considering the quality and sustainability of forest operations and is motivated to cooperate with forest harvesting companies to implement risk mitigation measures.
Supply Base Report: BSL Woodfiber SA Page 13 4 Supply Base Evaluation
4.1 Scope
The scope of this SBE covers:
- Galicia: operations of logging and chipping - Principado de Asturias: operations of logging - Castilla y León: operations of logging - Andalucía: operations of logging and chipping
4.2 Justification
The approach used in this SBE is risk assessment, according to legality and sustainability principles. The following sources of information were studied to assess the risks: - Applicable legislation; - Reports of official organizations; - National statistics; - FSC National Risk Assessment 2018; - Scientific studies; - Mass media sources; - Company specific information of BSL Woodfiber and its suppliers.
Besides that, the SBR and SBE were published online for stakeholder consultation. Stakeholders were proactively approached and invited to provide their input and comments.
4.3 Results of Risk Assessment
Several indicators showed specified risks, but BSL Woodfiber had standard operational procedures in place mitigating these risks, already before start of preparing for SBP certification, and also some additional measures were implemented.
The result of the risk assessment was the identification of 4 specified risks within the supply base related to indicators 2.2.2, 2.3.2, 2.4.2 and 2.8.1.
Table 4.3: Risk Assessment Results of BSL SBP Indicators of specified risk Indicator 2.2.2 The Biomass Producer has implemented appropriate control systems and procedures for verifying that feedstock is sourced from forests where management maintains or improves soil quality. The European Court of Auditors (ECA) research indicates that up to 44% of Spain runs a great risk of soil erosion. According to JRC Science for Policy report “Condition of agricultural soil: Factsheet on soil erosion”, 2017, Soil degradation by water erosion is particularly significant in Spain (3,7 t/ha/year) in years 2000-1012. This indicator is classified as Specified risk for “Mediterranean forests” (Andalucía), because of the erosion, desertification and loss of nutrients. 2.3.2 Adequate training is provided for all personnel, including employees and contractors (CPET S6d).
Supply Base Report: BSL Woodfiber SA Page 14 Training in the forest sector is quite weak. Legislation is mainly focused on health and safety, and there are not specific topics for forestry sector despite the danger of the forest operations. The use of subcontractors and self-employees are quite common on forest sector. Conditions of these forest workers could be one of the weakest points of forestry sector. 2.4.2 The Biomass Producer has implemented appropriate control systems and procedures for verifying that natural processes, such as fires, pests and diseases are managed appropriately. Forest fires: Forest treatments like thinning and clearing has a positive impact on the prevention of forest fires, as it reduces the density and biomass in the forest cover. And forest operations are not considered a relevant cause of forest fires. Despite this, BSL has in place systems to prevent forest fires.
Pest and diseases: The infractions detected with pine wood nematode and its potential impact is so high, the risk related to Pest and diseases is considered Specified Risk. 2.8.1 The Biomass Producer has implemented appropriate control systems and procedures for verifying that appropriate safeguards are put in place to protect the health and safety of forest workers (CPET S12). The forestry sector is, after the construction sector, the one with the highest rate of occupational accidents and occupational diseases.
A more detailed analysis of the main sources of accidents in forestry work reveals that the forestry exploitation phase and, more specifically, the felling, felling and cutting with chainsaws are the forestry activities with the highest accident rate. The use of the chainsaw, which is a widespread tool in rural areas, causes 18% of accidents.
According to International Labour Organization, there have been an increase in fatal and non- fatal injuries related to agriculture, forestry and fishing sector in Spain.
Regardless of its legal requirements, Spain still performs poorly on work safety. Outsourcing and self-employed services are quite common in forest sector
4.4 Results of Supplier Verification Programme
BSL Woodfiber has studied all the indicators of SBP Standard 1 in relation to the scope of the SBE and categorised all indicators as either low risk or specified risk. Therefore, a Supplier Verification Program was not needed.
4.5 Conclusion
Discussion points and opinions on possible sustainability risks in feedstock procurement in Spain have been studied in detail over the last years by a broad group of stakeholders and institutes. In general, there is a good understanding of the necessity of performing additional mitigating measures.
Forest ownership in Spain is fragmented; there are many small holders, it is therefore clear that several forest management tasks, starting with an evaluation of ecological, economic and social impacts of operational plans should be considered before and during the forest operations commence.
Within the framework of the FSC Controlled Wood and Due Diligence evaluations, several mitigation measures were already in place.
Supply Base Report: BSL Woodfiber SA Page 15 Four SBP indicators were assessed ‘specified risk’, of which 1 partly.
These specified risks are, however, well mitigatable. Moreover, corruption in Spain is relatively low, what is confirmed by the CPI score of 58 points (2018). Forestry in Spain has a long history and a sound framework of relevant institutes.
Supply Base Report: BSL Woodfiber SA Page 16 5 Supply Base Evaluation Process
The Supply Base Evaluation (SBE) was performed by Rogelio Gonzalez, Ineva, with the internal support of Cecilia Nolasco from the BSL Chain of Custody Team and her manager, Pedro Rodrigues, also responsible for the operations of the BSL Group, being directly involved in prospecting and supporting the decision to buy wood (raw material) ), as well as inspections / visits to the field.
Rogelio Gonzalez (forestry Engineer) has around 20 years of experience in forest FSC and PEFC certification. He passed the SBP auditor exams in 2019.
The Supply Base Evaluation Process started with public reports into consideration, as also national legislation, national policies, and publications of relevant institutions and authorities. During the preparation of the SBE, a detailed baseline study was made for each of the SBP indicators. A summarised description on each indicator is presented in Annex 1 and covers all relevant indicators of SBP Standard 1.
The certification team took the following steps in developing the Supply Base Evaluation: • Study the draft SBP National Risk Assessments and compare it with BSL Woodfiber’s own experience and procedures • Study publicly available reports on the legality and sustainability risks in Spain; • Develop the Risk Assessment and Risk Mitigation Measures in cooperation with BSL Woodfiber’s suppliers; • Develop procedures and check-lists related to the assessment of forestry operations and feedstock procurement; • Train the harvesting teams of the feedstock suppliers; • Evaluate the effectiveness of the Risk Mitigation Measures in practice (during harvesting operations).
The Forestry Manager is a specialist, who has been involved in wood procurement and field inspections for many years.
The documents stated below are of importance to the management system: • Procedure on the origin of raw material; • Best practices regarding harvesting operations; • Sampling and monitoring procedure; • Training program • Assessment reports and checklists on: o Planned forest operations (field inspections); o Primary feedstock suppliers (companies); • Complaint procedures.
The Risk Assessment (RA) did not result in inconclusive indicators (see paragraph 4.3).
Supply Base Report: BSL Woodfiber SA Page 17 6 Stakeholder Consultation
The risk assessment has been sent to a group of over 100 stakeholders and leading experts in nature conservation and forestry. The stakeholder consultation was open from 28th June, till 28th August 2020.
6.1 Response to stakeholder comments
The stakeholder consultation did not result in any comments.
Supply Base Report: BSL Woodfiber SA Page 18 7 Overview of Initial Assessment of Risk
Table 1. Overview of results from the risk assessment of all Indicators (prior to SVP)
Initial Risk Rating Initial Risk Rating Indicator Indicator Specified Low Unspecified Specified Low Unspecified X X 1.1.1 2.3.1 X X 1.1.2 2.3.2 X X 1.1.3 2.3.3 X X 1.2.1 2.4.1 X X 1.3.1 2.4.2 X X 1.4.1 2.4.3 X X 1.5.1 2.5.1 X X 1.6.1 2.5.2 X X 2.1.1 2.6.1 X X 2.1.2 2.7.1 X X 2.1.3 2.7.2 X X 2.2.1 2.7.3 X X 2.2.2 2.7.4 X X 2.2.3 2.7.5 X X 2.2.4 2.8.1 X X 2.2.5 2.9.1 X X 2.2.6 2.9.2 X X 2.2.7 2.10.1 X 2.2.8 X 2.2.9
Supply Base Report: BSL Woodfiber SA Page 19 8 Supplier Verification Programme
8.1 Description of the Supplier Verification Programme
The Risk Assessment had no inconclusive indicators (no ‘unspecified risks’). The results have been discussed with feedstock suppliers and other stakeholders. The indicators, risks, and mitigation measures were clear.
8.2 Site visits
Not applicable.
8.3 Conclusions from the Supplier Verification Programme
Not applicable.
Supply Base Report: BSL Woodfiber SA Page 20 9 Mitigation Measures
9.1 Mitigation measures
The mitigation measures per indicator are given in the table below.
Table 9.1 Risk Mitgation Measeures Summary
Supply Base Report: BSL Woodfiber SA Page 21 The Biomass Producer has implemented appropriate control systems and procedures 2.2.2 for verifying that feedstock is sourced from forests where management maintains or improves soil quality (CPET S5b). BSL Woodfiber evaluates the impacts of its operations about the erosion, desertification and loss of nutrients in Andalucía, through the implementation of the Manual of good practices: • Were needed, considering the soil and groundwater level, only selective cuttings and small clear cuts of maximally 5 ha are planned; • Leave nutrients in the forests, mainly the green fraction of forest residues less or equal Mitigation to 3 cm (on the other hand other forest residues need to be cleared to prevent forest measures fires. • Do not operate in near-water areas.
On dry locations selective cuttings are often preferable, because the ground gets less direct impact of the sun and the forest can maintain soil quality and regenerate naturally. Adequate training is provided for all personnel, including employees and contractors 2.3.2 (CPET S6d). BSL Woodfiber trains its personnel on all relevant aspects and demands the same from its feedstock suppliers. • Training records obligatory according to legislation and records of qualification are collected during supplier qualification process and checked during supplier inspections; Mitigation • Training conducted by BSL in several fields, including identification of key ecosystems, measures habitats and species biodiversity (annually and based on the results of field visits); • Training on best forest management practices.
BSL performs supplier inspections: the training records, (new) workforce, and the hiring of specialists. The level of knowledge of personnel is inspected during site visits. The Biomass Producer has implemented appropriate control systems and procedures 2.4.2 for verifying that natural processes, such as fires, pests and diseases are managed Forest fires appropriately (CPET S7b). Forest fires: • Visual inspection of the plot before harvesting; • Implementation of forest fire fighting measures according to law; Mitigation • Best forest practices. measures Pest and diseases • BSL Woodfiber do no accept wood cooming from nematode affected area. The Biomass Producer has implemented appropriate control systems and procedures 2.8.1 for verifying that appropriate safeguards are put in place to protect the health and safety of forest workers (CPET S12). BSL has a control system and adequate procedures on the health and safety of forest workers.
BSL demands the same from its feedstock suppliers and checks the health safety of harvesting personnel during its monitoring (administrative and field) inspections. • Supplier qualification process and inspections of the supplier’s administration: o Insurances and aptitude forms; Mitigation o Social Security; measures o Present workforce and training (new) personnel; o Health and safety procedures; o Training records and hiring of specialists; o Records of Personal Protection Equipment (PPE) distribution; o Records of machinery safety tools and equipment on documental register; o Medical record for employment.
Supply Base Report: BSL Woodfiber SA Page 22 • Field inspection supplier: o Protective equipment use; o Medical kit; o Fire extinguisher; o Respect of safety distances; o Level of knowledge of personnel.
9.2 Monitoring and outcomes
With the implementation of the SBP, BSL Woodfiber reinforces its commitment with its principles, while adopting a performance model based on structured procedures for systematic implementation.
Under this framework, the current procedures provide practices that make it possible to evaluate, at regular intervals, the results of the SBP. That means, whether it maintains an adequate level of performance and in accordance with the current Standards and requirements.
BSL uses the information collected from monitoring (through field actions, including audits) to verify that it is achieving the expected results, including the improving of its internal and external performance, the degree of compliance with legal, normative and others obligations needed for reaching the objectives defined by SBP.
The monitoring and measurement actions related with the scope of the SBP include:
• Document and other available information analysis, • Analysis of the records and other information associated with the control of origin, legality and other SBP compliance requirements / criteria applicable to the control of the raw material supply base; • Visits / contacts, with relevant stakeholders; • Training and Information: • Audits, • Treatment of Non-Conformities, Complaints or other Concerns of Stakeholders, including internal follow-up actions and with their subcontractors and suppliers. • Analysis and review of results and decision making, based on the information resulting from the monitoring and measurement carried out, as well as regarding any changes, with an impact on the SBP, ensuring that they are identified, their consequence is determined in the achievement of the desired results and, • Changes are planned in order to mitigate negative effects on the intended results.
The anticipation to situations with the potential to generate non-compliance, will result from proactive monitoring by the entire BSL structure and the creation and development of cooperative relationships with its suppliers and business partners.
Supply Base Report: BSL Woodfiber SA Page 23 10 Detailed Findings for Indicators
Detailed findings for each Indicator are given in Annex 1.
Supply Base Report: BSL Woodfiber SA Page 24 11 Review of Report
11.1 Peer review
The report was sent to a large number of stakeholder, who are experts in different related fields. Therefore, a peer review was not necessary.
11.2 Public or additional reviews
The SBR and SBE were sent to a large group of stakeholders for review (more information in Chapter 6). The SBR and SBE are always available at the SBP web site and BSL web site. Any interested party can contact Cecília Nolasco by mail [email protected] to provide its comment, which will be obligatory taken into consideration
Supply Base Report: BSL Woodfiber SA Page 25 12 Approval of Report
Approval of Supply Base Report by senior management
Cecília Nolasco Report Chain of Custody Team 24-07-2020 Prepared Pedro Rodrigues by: Name Title Date
The undersigned persons confirm that I/we are members of the organisation’s senior management and do hereby affirm that the contents of this evaluation report were duly acknowledged by senior management as being accurate prior to approval and finalisation of the report.
Jose Reis Report Administration 24-07-2020 approved Jaime Reis by: Name Title Date
Supply Base Report: BSL Woodfiber SA Page 26 13 Updates
Initial audit. Not applicable.
13.1 Significant changes in the Supply Base
Initial audit. Not applicable.
13.2 Effectiveness of previous mitigation measures
In the development process of the SBE, additions have been made to BSL’s procedures and evaluation tools. The measures were tested in practise. They proved to be effective.
13.3 New risk ratings and mitigation measures
Initial audit. Not applicable.
13.4 Actual figures for feedstock over the previous 12 months
Based on the historical data, it’s in the range 0 - 200,000 tons (127.546 tonnes of primary raw material roun wood - 2019).
13.5 Projected figures for feedstock over the next 12 months
Con respecto a la proyección de la materia prima para el año en curso, y con base en la evolución esperada y los datos históricos de las ventas de madera, estará en el rango de 0 a 200,000 toneladas (de 10,000 a 25,000 toneladas de madera en rollo para las industrias de pulpa y papel)
Supply Base Report: BSL Woodfiber SA Page 27 Annex 1: Detailed Findings for Supply Base Evaluation Indicators
Indicator
1.1.1 The Biomass Producer’s Supply Base is defined and mapped.
This SBP Regional Risk Assessment covers feedstock coming from material with origin in: - Galicia - Asturias - Andalucía (Mainly province of Huelva, but not only) - Castilla y León
BSL Woodfiber uses the administrative borders (province or Autonomous Community) to define the Supply Base, because the forest policy and competence is defined at Autonomous Community and provice level. Finding The most relevant volume of feedstock is coming from Galicia, where the the wood is mainly harvested by BSL Woodfiber. In the other regions wood is coming from suppliers.
The feedstock from Galicia, Asturias and Castilla y León are logs, that could be chipped in the port of Ferrol, or sended as logs from other ports (Burela, Cariño and Ribadeo). The logs purchased in Andalucía, are chipped by the supplier (as a subcontractor) and sent to the Port of Huelva.
Supply Base Report: BSL Woodfiber SA Page 28
Means of • Delivery notes, felling manifests, invoices, among other legal documents. • Maps to the appropriate scale are available; Verification • Key personnel interviews Forest statistics: • https://www.mapa.gob.es/es/desarrollo- rural/estadisticas/forestal_anuarios_todos.aspx • Galicia: https://mediorural.xunta.gal/gl/recursos/estatisticas/estatisticas-forestais • Andalucia: http://www.juntadeandalucia.es/medioambiente/vem/?c=Menu/tema/441 • Castilla y León: https://medioambiente.jcyl.es/web/jcyl/MedioAmbiente/es/Plantilla100/1131977831 418/_/_/_
Evidence Cartography web visors: Reviewed • https://sig.mapama.gob.es/geoportal/ • Galicia: o https://mapas.xunta.es/visores/conservaciondanatureza/ o http://mapas.xunta.gal/visores/aproveitamentos/ • Andalucia: o https://laboratoriorediam.cica.es/VisorRediam/ o http://ws128.juntadeandalucia.es/agriculturaypesca/sigpac/index.xhtml • Castilla y León: o https://idecyl.jcyl.es/vcig/
Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Comment or Mitigation Measure
Supply Base Report: BSL Woodfiber SA Page 29 Indicator
1.1.2 Feedstock can be traced back to the defined Supply Base.
BSL Woodfiber purchase wood from private forests, all of them with a cadastral reference that always allows to trace back the origin of the feedstock.
Cadastre is the easiest and more effective way to define the origin of the feedstock. “The Cadastre is an administrative register that comes under the remit of the Ministry of Finance and Public Administration. It contains the description of all rural and urban properties as well as those of special characteristics, which must all be registered, free of charge”
All properties are allocated a unique cadastral reference (Número de Referencia catastral) that allows them to be identified and located. “The cadastral reference number is the official and obligatory identifier of properties. It is an alphanumeric code, consisting of twenty characters, which is assigned by the Cadastre, so every property must have its unique cadastral reference number. The cadastral reference number means the properties can be located on the cadastral map.”
Despite the cadastre is not 100% reliable, could be considered as a starting point to identify clearly the Supply Base, since all documentation of feedstock from the forest refers to the cadastral reference as the origin of the biomass.
The cadastre reference identifies each plot, and its geometry can be consulted on the Cadastre and SigPac webpages. Several Autonomous Communities has their own SigPac webpage, with improved tools. See “Evidence Reviewed”.
Finding The Forestry Law (Law 43/2003, of 21 November, on Forests, Law 10/2006, of 28 April, and Law 21/2015, of 20 July, which amends Law 43/2003 – Consolidation Bill) grants the Autonomous Communities the powers of forest management and control.
Chapter IV– Forest uses states that: • When a Management or Equivalent Plan exists, or the forest is included within the scope of a PORF (Forest Resources Management Plan), the holder must notify the competent body of the Autonomous Community before the harvest. • In other cases, (where there is no Management Plan or similar) administrative authorisation is required before harvesting.
Whenever BSL Woodfiber is responsible for the works or has purchased the material from another company responsible for the works, one of the 3 documents listed below will be available, together with the transport documentation: • Work/harvesting notification (with Management Plan) • Work/harvesting authorisation (Felling licence) • Allocation of the public forest works contract
Spain presents a low corruption perception Index (58). There is a high level of law enforcement and surveillance for manifests, invoices and transport documents which are considered reliable sources of information.
On the above background, the risk related to the traceability of feedstock back to the supply base is evaluated to be low. • BSL Woodfiber’s internal records, including information about the origin, species and supplier • Work/harvesting notification (with Management Plan) Means of • Work/harvesting authorisation (Felling licence) Verification • Allocation of the public forest works contract • Transport documents • Invoices, waybills • Contract with private owners
Supply Base Report: BSL Woodfiber SA Page 30 • The existence of a strong legal framework in the region
Cartography web visors: • https://sig.mapama.gob.es/geoportal/ • https://sigpac.mapa.es/fega/visor/ • https://www1.sedecatastro.gob.es/Cartografia/mapa.aspx?buscar=S • Galicia: Evidence o https://mapas.xunta.es/visores/conservaciondanatureza/ o http://mapas.xunta.gal/visores/aproveitamentos/ Reviewed • Andalucia: o https://laboratoriorediam.cica.es/VisorRediam/ o http://ws128.juntadeandalucia.es/agriculturaypesca/sigpac/index.xhtml • Castilla y León: o https://idecyl.jcyl.es/vcig/
Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Comment or Mitigation Measure
Indicator
1.1.3 The feedstock input profile is described and categorised by the mix of inputs.
BSL Woodfiber can purchase wood to the forest owner or from suppliers. In the first case BSL Woodfiber purchase the wood and is responsible of all harvesting operations In the second case, BSL receibes logs from the forest through its suppliers.
In both cases the supply chain is short and reliable information regarding the feedstock can Finding be gathered in collaboration with the forest owners and suppliers.
Hence, accurate classification and description of type, species, and categorization as round wood and/or residual wood material, as well as the approximate proportion of round wood from final felling, is possible.
The risk for this indicator has been assessed as Low. • Submission/ authorization of felling of Forest Authorities • Purchase invoices Means of • Transport/shipping documents Verification • Waybills • Feedstock input records • BSL’s Internal records with information about the origin, species, supplier, carrier Evidence European Atlas of Forest Tree Speies https://forest.jrc.ec.Europa.eu/en/european-atlas Reviewed
Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Comment or Mitigation Measure
Supply Base Report: BSL Woodfiber SA Page 31 Indicator
The Biomass Producer has implemented appropriate control systems and procedures to 1.2.1 ensure that legality of ownership and land use can be demonstrated for the Supply Base. The Cadastre (Catastro), and the Real Estate Registry (Registro de la Propiedad) constitute the basis of the management of property and of the rural and urban buildings, as well as of the acts practiced on them (building refers to any real estate property being that rural or urban, agricultural or forest, comprising edification or not): • The Cadastre strictly defines the characteristics of each rustic parcel, namely the location, configuration, limits and areas of the property and its built-up parts, being based on orthophoto maps with official validity. The Cadastre comprises other complementary information such as easements and restrictions, use and occupation, encumbrances or charges, urban parameter value, licenses, etc. • The Real Estate Registry, which takes place in the land registry office, is the official archive where all property rights and other rights as well as charges on the real estate are registered and confirmed, without updated knowledge of which no legal act (purchase, sale, Mortgage, etc.) can be carried out on a rustic or urban building, or on a part or fraction of such. The most part of forest area is not registered, but when it is, it always prevails over Cadastre.
Differences between both records are quite common in rural plots, specially the geometry and the ownership. At the present, any change of ownership in Real Estate Registry requires previously the review of the Cadastre record.
Finding It is common knowledge that rustic and urban buildings are inscribed in the Cadastro, above all, because these services send, to the owner, a list of the respective articles each year (with the exception of properties not quoted in less value, as is often the case of rural properties), indicating the value of the property, the tax on the properties to be paid, called Property Municipal Tax (IBI).
It is also considered among the stakeholders that there are a very reduced number of cases related to theft of timber and illegal use of land.
The purchase documents (invoice, buyer-seller contract, previous agreement, among others listed here) are considered to be sufficient for the confirmation of legality of the raw material considering that they provide all the relevant information of the seller, namely, name, fiscal number, address and identification number, most of the times more reliable information than the one found in the land registry permit. All the relevant information is disclosed by the seller of the wood and this sale is declared to the fiscal authorities through invoicing, assuring the legality of ownership.
Based on the available information, the risk for this indicator has been assessed as Low.
This conclusion is in line with the FSC National Risk Assessment For Spain (Annex C2, FSC CW NRA). • Internal records with information about the origin, species, supplier, carrier. One of the following documents available: Means of • Work/harvesting notification • Work/harvesting authorisation Verification • Allocation of the public forest works contract • Contract/Allocation with the land-owner/manager
Government sources: Evidence • Real Estate Registry http://geoportal.registradores.org/geoportal/index.html • Cadastre: https://www.sedecatastro.gob.es Reviewed • FSC-NRA-ES V1-1 National Risk Assessment For Spain: https://fsc.org/en/document-centre/documents/resource/168
Supply Base Report: BSL Woodfiber SA Page 32
Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Comment or Mitigation Measure
Indicator
The BP has implemented appropriate control systems and procedures to ensure that 1.3.1 feedstock is legally harvested and supplied and is in compliance with EUTR legality requirements. Regulation (EU) No 995/2010 (RUEM), of 20 October, entered into force in March 2013, and Decree-Law no. 76/2013, for its application in Spain, was published on 5 Of June of the same year.
Within the framework of the EUTR, two types of agents are defined: • Operator, understood as any singular or collective person who places on the market wood or wood products, and • Trader understood as any natural or collective person who in the course of a commercial activity sells or purchase on the internal market of the European Union (EU) wood or wood products already placed on the internal market.
Operators must have a due diligence system in place for each wood/timber acquisition, which includes procedures for access to information, risk assessment and risk mitigation. Furthermore, traders must maintain relevant information about suppliers and buyers of products as well as volumes traded. This information must be kept and be provided to competent authorities upon request. Operators placing timber on the EU market for the first time should provide records of where the timber is originated, species, and quantities. Finding BSL Woodfiber is registered as operator. In Spain operators must submit an annual declaration detailing: • Species, • Volumes, • Certifications and • Country of origin of all purchased wood
The Competent Authority for ensuring implementation of the EUTR are the Autonomous Communities. Several complaints from environmental NGOs were reported, because of the lack of control of the Competent Authorities. But all these claims refer to the lack of verification of wood imports and does not affect the exploitation of national forests. The Spanish government report the monitoring of inspections carried out by the competent authorities and their results (LIGNUM program). Based on the available information, the risk for this indicator has been assessed as Low. Means of EUTR declaration. Verification Evidence • Illegal Logging portal: https://www.illegal-logging.info/regions/spain Reviewed • Client-earth: https://www.clientearth.org/eutr-implementing-legislation/
Supply Base Report: BSL Woodfiber SA Page 33 • Follow-up reports: https://www.mapa.gob.es/es/desarrollo-rural/temas/politica- forestal/Madera_Legal_FLEGT_EUTR/sistema/default.aspx • Greenpeace report: https://es.greenpeace.org/es/sala-de-prensa/informes/cinco- anos-de-permisividad-con-el-comercio-de-madera-ilegal-en-espana/ • Andalucía: http://www.juntadeandalucia.es/medioambiente/site/portalweb/menuitem.7e1cf46dd f59bb227a9ebe205510e1ca/?vgnextoid=8101b10e7fcb3510VgnVCM2000000624e 50aRCRD&vgnextchannel=632dee9b421f4310VgnVCM2000000624e50aRCRD • Galicia: https://www.lugomadera.es/registro-de-empresas-del-sector-forestal-resfor- y-diligencia-debida • Principado de Asturias: https://sedemovil.asturias.es/portal/site/Asturias/menuitem.46a76b28f520ecaaf18e 90dbbb30a0a0/?vgnextoid=e72aabf54de25510VgnVCM10000098030a0aRCRD&i 18n.http.lang=es • Castilla y León: https://medioambiente.jcyl.es/web/jcyl/MedioAmbiente/es/Plantilla100/1284756591 606/_/_/_%20-%20anexos Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Comment or
Mitigation Measure
Indicator
The Biomass Producer has implemented appropriate control systems and procedures to 1.4.1 verify that payments for harvest rights and timber, including duties, relevant royalties and taxes related to timber harvesting, are complete and up to date. There are two types of fees payable for timber harvesting: 1) Fees imposed by the Autonomous Communities and local authorities in the licenses required for the works/harvesting in private forests. Each Autonomous Community and local authority regulate this aspect independently. If fees are applicable, authorization will only be issued after the fees have been paid. In public contracts, there are payments associated with the contact allocation that must be met once the work has been awarded and before it is finally formalized. In all cases the fact of having authorizations or allocations issued by public administrations implies that the corresponding fees have been paid. Therefore, payment of the corresponding fees is certified by holding the following: • Work/harvesting notification Finding • Work/harvesting authorization • Allocation of public forest works contract.
2) Taxes related to timber harvesting, applicable to all economic activities such as value added taxes (VAT) and income taxes (IRPF, IS). Invoices must be issued by the seller, but self-invoicing by the buyer may occur in exceptional circumstances if some conditions are met (previous agreement, data conformity, etc.). As no specific evidence of irregularity has been identified in relation to payment of VAT, this requirement is considered Low risk. The payment of VAT is a simple requisition that is easy to verify and legally undertake by both entities (seller and buyer). The exceptional regimes of reduced taxes or exemption are in place to include the cases of forest owners with special profiles as farmer or forester.
Supply Base Report: BSL Woodfiber SA Page 34 Income taxes are applied according to individual or collective fiscal laws. It was not found any specific evidence of irregularities about income taxes related to harvest companies. The payment of taxes to the Tax Authorities relating to the purchase of source material is credited through: • invoice for the purchase of raw material required for the feedstock or the work carried out (bearing in mind that many times self-billing is applied, so it is the purchasing company itself that issues the invoice) • certificate of being up to date with payments to the Tax Authorities (of the state and the autonomous community) of the company that has purchased the material or carried out the work.
According to the available information, this indicator is classified as low risk.
This conclusion is in line with the FSC National Risk Assessment For Spain (Annex C2, FSC CW NRA).
• Valid invoice/receipts Means of • Certificate of being up to date with payments to the Tax Authorities, of the state Verification and the autonomous community
• Tax Authority VAT Basic Regulations: https://goo.gl/riom9a • Tax Authority IRPF (Income Tax) Basic Regulations: https://goo.gl/95xiX1 Evidence • Tax Authority Corporation Tax Basic Regulations: https://goo.gl/c7JK7o Reviewed • FSC National Risk Assessment Spain (indicators 1.6 and 1.7): https://fsc.org/en/document-centre/documents/resource/168
Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Comment or Mitigation Measure
Indicator
The Biomass Producer has implemented appropriate control systems and procedures to 1.5.1 verify that feedstock is supplied in compliance with the requirements of CITES. There are no CITES species included in the CITES in Spain. Finding Based on the available information, the risk for this indicator has been assessed as Low. Means of List of purchased species Verification • Check list of CITES species: http://checklist.cites.org/#/en • Portal of the CITES administrative authority in Spain: http://www.cites.es/es- Evidence ES/Paginas/default.aspx • Applicable CITES legislation: http://www.cites.es/es- Reviewed ES/legislacion/Paginas/Legislacion-de-aplicacion.aspx • FSC-NRA-ES V1-1 National Risk Assessment For Spain: https://fsc.org/en/document-centre/documents/resource/168 Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Supply Base Report: BSL Woodfiber SA Page 35 Comment or Mitigation Measure
Indicator
The Biomass Producer has implemented appropriate control systems and procedures to 1.6.1 ensure that feedstock is not sourced from areas where there are violations of traditional or civil rights. There is no armed conflict in Spain, nor is the Spanish forestry sector associated with any conflict. Spain is not subject to any UN sanction or ban on timber exports, and there are no persons or entities in the Spanish forestry sector that are sanctioned by the UN.
Spain is well ranked in international reports: • Corruption Perceptions Index score of 58. The perception of the level of corruption has increased significantly in Spain in recent years, although it remains clearly above 50, which implies a relatively low level of perception. • World Bank Governance Indicators (WGI), scores for 2017 between 61.90 and 83.17 (1-100 points). The WBGI report has been produced in 200 countries since 1996 and covers the following governance indicators: i) Voice and Accountability, ii) Political Stability and Absence of Violence/Terrorism, iii) Government Effectiveness, iv) Regulatory Quality, v) Rule of Law, and vi) Control of Corruption.
Although there are some concerns regarding civil rights in Spain reflected in reports from international organisations such as Amnesty International (see the 2017 report of Spain), none of these concerns are directly related to the forestry sector. Spain does not appear in any report from international organisations (Global Witness_Chatham House Illegal Logging portal) regarding illegal timber trade or harvesting.
Finding There are no indigenous peoples in Spain who can claim traditional use of lands, forests or other resources on the basis of customary rights or traditional uses. In Spain there are many ancient customary rights linked to the forests of the Iberian Peninsula. There are no relevant conflicts related to these rights and where they exist there are established channels for their management and resolution. Many of these uses have died out due to disuse but are not exercised and others have been integrated into the management of the forests (public roads, firewood, communal management…).
An example of these uses is the Communal Forests (Montes en Mano Común), both Roman and Germanic, which have been gradually recovered since the establishment of democracy in 1977. Where communities have been able to demonstrate common use by local residents, they have been declared Communal Forests. There are Communal Forest Boards and legislation to regulate their activity. There are many forestry associations or similar groups, at local or regional level, that carry out important work in the recovery or maintenance of customary uses of forests.
Labour rights are observed including those specified in the ILO fundamental principles. Spain has ratified the 8 ILO Fundamental Conventions.
According to the available information, this indicator is classified as low risk.
Means of • Purchase contracts • Allocation of the public forest works contract Verification Evidence • FSC-NRA-ES V1-1 National Risk Assessment For Spain: https://fsc.org/en/document-centre/documents/resource/168 Reviewed • WGI: http://info.worldbank.org/governance/WGI/#reports
Supply Base Report: BSL Woodfiber SA Page 36 • Transparency international, corruption perception index: https://www.transparency.org/ • Amnesty International Spain: https://www.es.amnesty.org/en-que- estamos/espana/ • Illegal Logging portal: https://www.illegal-logging.info/regions/spain • Global Witness: https://www.globalwitness.org/en/
Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Comment or Mitigation Measure
Indicator
The Biomass Producer has implemented appropriate control systems and procedures for 2.1.1 verifying that forests and other areas with high conservation values are identified and mapped. Most important forest areas with high concentration of nature conservation values have been identified and designated as classified or protected areas at national and/or EU level (ZEPA, LIC, Natura 2000 sites, Natural and National Parks).
All these areas are clearly mapped in cartography (see indicator 1.1.1). Information on location and geographical distribution of nature conservation areas, rare, threatened and endangered species and habitats can be considered sufficient.
There are legal instruments to identify, map and protect the network of areas of high conservation importance by the Ministry of Agriculture, Fishing and Food. The Law 42/2007, of December 13, on Natural Heritage and Biodiversity establishes the basic legal regime for the conservation, sustainable use, improvement and restoration of the Spanish natural heritage and biodiversity and includes the basic framework for the management of the Natura 2000 network. This is complemented by relevant regulations in each Autonomous Community. It also includes the international standards and recommendations that international environmental organizations, such as the Council of Europe or the Convention on Biological Diversity, have published. Finding Spain is contributing the most to the Natura 2000 network among all European countries. The implementation of it in Spain means extending the protected area status to approximately 28% of the territory, a significant proportion. In Spain there are 1,863 Natura 2000 sites, of which 1,467 are Sites of Community Importance (LIC, Lugares de Importancia Comunitaria) and 644 are Special Protection Areas for Birds (ZEPA, Zonas Especiales de Protección para las Aves), covering 27.3% of Spanish territory; some LIC and ZEPA overlap.
Although Natura 2000 and other protected areas include a large proportion of HCV present in Spain (mainly HCV 1, 2 and 3), HCV are also present outside protected areas. In these cases, Law 42/2007 and the legislation of the HCV are a complementary safeguard against potential threats to HCV from forest management activities. At the operational level, Law 21/2015 on Forestry with its subsequent amendments and other detailed developments by the HCV provide an additional safeguard against threats to HCV from forest management activities through monitoring and control measures on the ground when forest products are marked and harvested. In terms of law enforcement, it is widely accepted among the experts that there is a high level of implementation of the above-mentioned legislation.
A general map of Spanish protected areas:
Supply Base Report: BSL Woodfiber SA Page 37
Using the definitions High Conservation Values (HCV) provided by FSC and HCV Network, the following attributes will be considered:
HCV 1 Species diversity - Concentrations of biological diversity including endemic species, and rare, threatened or endangered species, that are significant at global, regional or national levels.
HCV 2 Landscape-level ecosystems and mosaics - Large landscape-level ecosystems and ecosystem mosaics that are significant at global, regional or national levels, and that contain viable populations of the great majority of the naturally occurring species in natural patterns of distribution and abundance.
HCV 3 Ecosystems and habitats - Rare, threatened, or endangered ecosystems, habitats or refugia.
HCV 4 Ecosystem services - Basic ecosystem services in critical situations, including protection of water catchments and control of erosion of vulnerable soils and slopes.
HCV 5 Community needs - Sites and resources fundamental for satisfying the necessities of local communities or indigenous peoples (for livelihoods, health, nutrition, water, etc...), identified through engagement with these communities or indigenous peoples.
HCV 6 Cultural values - Sites, resources, habitats and landscapes of global or national cultural, archaeological or historical significance, and/or of critical cultural, ecological, economic or religious/sacred importance for the traditional cultures of local communities or indigenous peoples, identified through engagement with these local communities or indigenous peoples.
HCV attributes are well identified and mapped within the area of assessment, considering the sources of information listed above, as well as data from voluntary forest certification schemes, namely FSC and PEFC.
In this indicator it is considered all the relevant findings of the FSC Controlled Wood National Risk Assessment, and in line with its findings, this indicator is classified as low risk.
Supply Base Report: BSL Woodfiber SA Page 38
• Legislation in force. • Online maps. Means of • Forest Management Plans. • Priority Classified Habitat and species catalogue. Verification • Regional, publicly available data from a credible third party as FSC and PEFC reports
• Europarc: http://www.redeuroparc.org • Law 42/2007 on Natural Heritage and Biodiversity: http://www.boe.es/diario_boe/txt.php?id=BOE-A-2007-21490 • FSC-NRA-ES V1-1 National Risk Assessment For Spain: https://fsc.org/en/document-centre/documents/resource/168
Cartography web visors: • https://sig.mapama.gob.es/geoportal/ • Galicia: Evidence o https://mapas.xunta.es/visores/conservaciondanatureza/ Reviewed o http://mapas.xunta.gal/visores/aproveitamentos/ • Andalucia: o https://laboratoriorediam.cica.es/VisorRediam/ o http://ws128.juntadeandalucia.es/agriculturaypesca/sigpac/index.xhtml • Castilla y León: o https://idecyl.jcyl.es/vcig/ • Principado de Asturias: o http://sitpa.cartografia.asturias.es/Geoportal/extlayout.aspx?userId=FZr4XH q0PJA=&lang=es
Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Comment or
Mitigation Measure
Indicator
The Biomass Producer has implemented appropriate control systems and procedures to 2.1.2 identify and address potential threats to forests and other areas with high conservation values from forest management activities. From the description given in the previous indicator, it can be concluded that there is an effective real framework that allows for the identification and mapping of the six high conservation values categories.
There is a report produced by COSE ( Confederación de Organizaciones de Selvicultores Finding de España) and published by MAPA that indicates that the degree of control by the forestry authority is high or very high in all the Autonomous Communities except in Galicia, where the level of control is considered to be medium. The study concludes that the Spanish regulations and surveillance procedures carried out by the Autonomous Communities are consistent. The Autonomous Communities have their own personnel to carry out the control over the high conservation values, Forestry/Environmental Agents. Within the Civil Guard there is also the SEPRONA unit (Nature Protection Service), which carries out
Supply Base Report: BSL Woodfiber SA Page 39 environmental police work. No reports have been published on relevant environmental damage related to forestry work/harvesting. In all cases there is a clear legal framework and effective control by the authorities of any potential threats to the high conservation values.
With the information above, the following operation guide has been established with regards identifying and addressing potential threats to high conservation values: • For works in public forests, the management services of the Autonomous Community have all the information necessary at their disposal, which will be reflected in the work specifications. Any management limitations related to potential threats to high values are specified in the actual allocation. • For work on private lands that require prior authorization/ submission to carry out any forestry work/harvesting, the management services of the Autonomous Communities themselves will carry out the work of identifying possible threats to the high conservation values in such a way that their presence and the subsequent management limitations are reflected in the authorization/submission they issue.
Also, during the process of approving the Forest Management (FM) plan or Authorization for Harvesting for a particular area, the HCVs are studied. This is related to any harvesting being conducted on the public and private properties. All the restrictions and prescriptions identified during these processes are reflected in the Forest Management Plan or Authorization. Concrete requirements are issued to the owner in writing, for instance describing the time of the year when it is now allowed to perform the harvesting, due to the breeding period of protected birds.
The HCVs 1, 2, 3, 4 and 6 are considered by the Forest Service in the process of evaluating the Forest Management Plan or approving the Authorization for Harvesting. HCV 5 is perceived as a low risk and is not considered by the Forest Service, because there are no indigenous people in Spain and local communities does not depend on forest at the extent that basic needs could be threatened by forest management activities. On the contrary, it is considered that in Spain, the abandonment and depopulation of rural areas endangers the continuity of the local culture.
The economic importance of Spanish forests is not significant; their production level is very low, leading to the abandonment of forest management, an increased risk of fires, pests and a greater impact of natural disasters. Forest management is part of the culture in rural areas and should not be decreased but increased. To solve this problem, the forestry sector and industry should be strengthened.
Because of that, BSL Woodfiber has developed a Good environmental practices Manual to be aware when forest operations are carried out within or close to protected habitats.
With all this information, the risk related to this indicator should be classed as Low Risk.
• Existing legal framework. Laws, regulations and control bodies • Forestry work/harvesting authorisation/ allocation Means of • Technical Specifications for the allocation of the public forest works contract Verification • Good environmental practices manual in Sustainable Forest Management • Forest Management Plans
• Law 42/2007 on Natural Heritage and Biodiversity: http://www.boe.es/diario_boe/txt.php?id=BOE-A-2007-21490 • FSC-NRA-ES V1-1 National Risk Assessment For Spain: Evidence https://fsc.org/en/document-centre/documents/resource/168 • COSE study on wood control procedures and risk assessment in each Autonomous Reviewed Community for the application of the Due Diligence System: https://goo.gl/ZXYiCU • Habitats (2007-2012) Directive Implementation Report: https://www.miteco.gob.es/es/biodiversidad/temas/espacios- protegidos/art17_2007_2012_anexo_d_fichas_tcm30-207218.pdf
Supply Base Report: BSL Woodfiber SA Page 40 • Habitats Directive information (cartography, reports): https://www.miteco.gob.es/es/biodiversidad/temas/espacios-protegidos/red- natura-2000/rn_cons_seguimiento_Art17_inf_2007_2012.aspx
Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Comment or Mitigation Measure
Indicator
The Biomass Producer has implemented appropriate control systems and procedures for 2.1.3 verifying that feedstock is not sourced from forests converted to production plantation forest or non-forest lands after January 2008. Conversion of natural forests to plantations or other land uses is generally not allowed under the Spanish law, except in the following circumstances: • The change in use of a forest when it is not motivated by reasons of general interest, and without prejudice to the provisions of Article 18.4 of Law 21/2015 on Forestry (regarding records of forests catalogued with public declarations other than forest use) and applicable environmental regulations, will be exceptional and require a favourable report of the competent forestry body and, where appropriate, the owner of the forest. • The competent forestry body shall regulate cases in which, without a change in forest use, authorization is required for the substantial modification of the forest canopy.
Article 50 of Law 21/2015 on Forestry stipulates that the autonomous communities must guarantee the conditions for the restoration of forest land burned, and the following shall be prohibited: a) Change in forest use for at least 30 years. b) Any activity inconsistent with the regeneration of the forest canopy, during the period determined by regional legislation.
Law 43/2003 on Forestry was amended in 2015 enabling the possibility of changing forest Finding use where forests have been affected by fire. This new Law on Forestry, particularly controversial, was approved in the first meeting of the Spanish government cabinet in 2015 against the opposition, trade unions and environmentalist organizations who opposed some points they considered harmful to the environment. Article 50.1 says "exceptionally, autonomous communities may agree to change forest use when there are compelling reasons of overriding public interest of the first order that must be assessed by law, provided that the necessary compensatory measures are adopted to recover a forest area equivalent to that burned”. Such compensation measures must be identified before use change in the law itself, together with the source of the change in use.
Environmental groups, including WWF Spain and SEO/Birdlife, strongly criticized the new law. According to their analysis, it includes provisions that allow forest degradation through new urban development plans in forest areas and offers incentives for arson. Under the previous legislation, changes in land use in forests and burned forests were banned for 30 years, so that the restoration of ecosystems would not be hindered.
But, due to the recent entry into force of these amendments to the Law on Forestry, there is no evidence of non-compliance. To date, there is no evidence that article 50.1 of Law 21/2015 on Forestry has been applied.
Supply Base Report: BSL Woodfiber SA Page 41 In the other hand, the Ministry of Agriculture, Fisheries and Food (MAPA) draws the main conclusions of Spanish forests and their evolution through the comparison of national inventories (IFN2/IFN3), among them: • A significant increase is detected in the area of wooded forest at the cost of a decrease in treeless and cultivation areas. • Native hardwoods (oaks, chestnut, beech, gall oaks, etc.) have grown considerably both on the surface and in biomass. • Essentially, all indicators of sustainable development show a positive evolution of the Spanish forests.
The Spanish Society of Forest Sciences (SECF, Sociedad Española de Ciencias Forestales) prepares the Report on the Forest Situation in Spain every 5 years. In the results of the 2017 report, presented at the 7th National Forestry Congress (June 2017), indicates that the area covered by semi-natural forests in Spain has grown over the past 25 years, at an annual growth rate of 1.3%.
This indicator it is considered as low risk, in line with all the relevant findings of the FSC Controlled Wood National Risk Assessment.
• Historical maps and orthophotos from flights prior to 2008. • Records of field inspections • Monitoring records Means of • Forestry work/harvesting authorisation/ allocation • Cartography available and consultation with the competent bodies of the Verification Autonomous Communities regarding transformations • Management Plan, development project • Signed agreements and contracts
• Law 43/2003 and Law 21/2015 • FSC-NRA-ES V1-1 National Risk Assessment For Spain: https://fsc.org/en/document-centre/documents/resource/168 • National forest inventories: https://www.mapa.gob.es/es/desarrollo- rural/temas/politica-forestal/inventario-cartografia/inventario-forestal- nacional/default.aspx • WWF report: https://www.wwf.gr/crisis-watch/crisis-watch/biodiversity-natural- resources/5-biodiversity-natural-resources/new-law-undermines-forest- conservation-in-spain • SECF report: http://secforestales.org/content/informe-isfe • Area covered by semi-natural forests: http://7cfe.congresoforestal.es/content/la- situacion-de-los-bosques-y-el-sector-forestal-en-spain-isfe-2017 Evidence Reviewed Cartography web visors: • https://sig.mapama.gob.es/geoportal/ • Galicia: o https://mapas.xunta.es/visores/conservaciondanatureza/ • Andalucia: o https://laboratoriorediam.cica.es/VisorRediam/ o http://ws128.juntadeandalucia.es/agriculturaypesca/sigpac/index.xhtml • Castilla y León: o https://idecyl.jcyl.es/vcig/ • Principado de Asturias: o http://sitpa.cartografia.asturias.es/Geoportal/extlayout.aspx?userId=FZr4XH q0PJA=&lang=es
Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Supply Base Report: BSL Woodfiber SA Page 42 Comment or
Mitigation Measure
Indicator
The Biomass Producer has implemented appropriate control systems and procedures to 2.2.1 verify that feedstock is sourced from forests where there is appropriate assessment of impacts, and planning, implementation and monitoring to minimise them. By law, forest activities with certain characteristics and of a certain size must have an environmental impact report prior to the request for license activity. Environmental impacts of harvesting activities, like soil or water course damage, are well regulated in Spanish legislation. No reports on violations of this legislation were found.
The assessment of environmental impacts of harvesting activities on the land or watercourses are well regulated in Spanish legislation. The environmental impact report for operations near water zones needs to be provided to the Forest Service when applying for the Authorization for Harvesting, otherwise it cannot be issued. The Autonomous Communities have their own personnel to carrying out law enforcement. Within the Civil Guard there is also the SEPRONA unit (Nature Protection Service), which carries out the enforcement of environmental laws.
Environmental impact assessment projects are required by Law 21/2013, of 9 December. It Finding indicates the obligation to develop an environmental impact assessment for any reforestation area project greater than 50 ha. Environmental assessments do not act as licences but as a prior and binding requirement to obtain a certain authorisation or resolution.
Despite this, BSL Woodfiber always ensure that harvesting operations are authorized by the Forest Service and that are not subjected to environmental impact assessments. BSL Woodfiber always ensures that harvesting operations are authorized by the Forest Service. Besides that, to minimize the impact, BSL Woodfiber and its suppliers always uses best forest management practices during harvesting operations.
Therefore, the risk for this indicator is considered Low Risk since the BSL Woodfiber has developed its own impact verification system.
• Approved EIA when applicable. • Approved Forest Management Plan when applicable Means of • Records of BSL field inspections Verification • Best management practices • Regional Forest Plan
• EIA legislation (national and regional): https://www.eia.es/legislacion/ Evidence • Guides and directives for environmental assessment: Reviewed https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/default.aspx
Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Comment or Mitigation Measure
Supply Base Report: BSL Woodfiber SA Page 43
Indicator
The Biomass Producer has implemented appropriate control systems and procedures for 2.2.2 verifying that feedstock is sourced from forests where management maintains or improves soil quality (CPET S5b). Main problem of soil quality of Mediterranean forests is soil desertification increased by climate change, loss of nutrients and erosion. Climate change will deteriorate soil fertility through a loss of carbon from the soil.
The following conditions of large areas of Spain and the Mediterranean region are associated with desertification processes: • The semi-arid climate in large areas, seasonal droughts, extreme variability of rains and sudden high intensity rains • Poor soils with a marked tendency to erosion • Uneven relief, with steep slopes and very diversified landscapes • Losses of forest cover due forest fires.
The combination of factors and processes such as aridity, drought, erosion, forest fires, overexploitation of coastal areas, etc., gives rise to the different landscapes or scenarios typical of desertification in Spain.
About erosion, The European Court of Auditors (ECA) research indicates that up to 44% of Spain runs a great risk of soil erosion. According to JRC Science for Policy report “Condition of agricultural soil: Factsheet on soil erosion”, 2017, Soil degradation by water erosion is particularly significant in Spain (3,7 t/ha/year) in years 2000-1012.
Finding
Flood protection is addressed by the Flood Risk Prevention and Management Directive, which draws up Flood Risk Management Plans. Protection against erosion is addressed via the National Plan of Prioritized Actions to Hydrological and Forest Restoration, Soil Erosion Control and Combating Desertification. This plan designates the priority watersheds and
Supply Base Report: BSL Woodfiber SA Page 44 develops programs and actions to be carried out. The plan is operating on more than 18,4 million hectares, of which 3,5 million are a priority.
Several laws in each autonomous community regulate management and harvesting, including specific technical limitations (among others, machinery to be used according to the soil conditions, etc.).
The legislation is complemented with a high degree of implementation. There are no published reports on significant impacts of forest activities. The increase of forest and artificial surfaces is considered an important factor for decreasing erosion, new forests on abandoned agricultural lands improve the soil quality.
The risk of erosion also depends on the kind of terrain where harvesting is conducted. Another problem for soil quality in Spain is a loss of nutrients specially in Mediterranean area. And, mountain areas also require a special attention in terms of erosion
According to the available information, this indicator is classified as: • Specified risk for “Mediterranean forests” (Andalucía), because of the erosion, desertification and loss of nutrients • Low risk for “Temperate broadleaf and mixed forests” (Galicia, Asturias and Castilla y León)
• Manual of good practices • Records of field inspections Means of • Assessment at an operational level of measures designed to minimise impacts on the values identified Verification • Erosion and desertification programs and maps • Approved Forest Management Plan
• Map of erosion: https://www.ign.es/espmap/mapas_riesgos_bach/Riesg_Mapa_07.htm • National erosion inventory: https://www.mapa.gob.es/es/desarrollo- Evidence rural/temas/politica-forestal/inventario-cartografia/inventario-nacional-erosion- Reviewed suelos/ • National desertification: https://www.mapa.gob.es/es/desarrollo- rural/temas/politica-forestal/desertificacion-restauracion-forestal/
Risk Rating ☐ Low Risk T Specified Risk ☐ Unspecified Risk at RA
BSL Woodfiber evaluates the impacts of its operations about the erosion, desertification and loss of nutrients in Andalucía, through the implementation of the Manual of good practices: • Were needed, considering the soil and groundwater level, only selective cuttings and small clear cuts of maximally 5 ha are planned; Comment or • Leave nutrients in the forests, mainly the green fraction of forest residues less or Mitigation equal to 3 cm (on the other hand other forest residues need to be cleared to prevent Measure forest fires. • Do not operate in near-water areas.
On dry locations selective cuttings are often preferable, because the ground gets less direct impact of the sun and the forest can maintain soil quality and regenerate naturally.
Supply Base Report: BSL Woodfiber SA Page 45 Indicator
The Biomass Producer has implemented appropriate control systems and procedures to 2.2.3 ensure that key ecosystems and habitats are conserved or set aside in their natural state (CPET S8b). As indicated in indicators 2.1.1. and 2.1.2., in Spain, there is a systematic legal framework for the protection of natural spaces and areas with high conservation values: “In accordance with Law 42/2007 on Natural Heritage and Biodiversity”. These are areas of the national territory, that comply with at least one of the following requisites and are declared as such: • “Contain systems or natural elements that are representative, unique, fragile, threatened or of special ecological, scientific, landscape, geological or educational interest. • Are especially dedicated to the protection and maintenance of biological diversity, geodiversity and associated natural and cultural resources.”
Spanish forests have a wide range of HCV in terms of biodiversity, water protection and other ecosystem services. (see 2.2.4) According to a report of the IUCN of 2013 the Biodiversity in Spain is at risk.
All Autonomous Communities have legislation on vulnerable ecosystems: They are referred to as National Parks, Natural Parks, Nature Reserves, Natura 2000 Network Areas, Biosphere Reserves, etc. The protected area in Spain is 13% for natural areas and this increases to 28% if the Natura 2000 Network is included, with Spain being the country that contributes most to the Natura 2000 Network, the main instrument of European conservation policy. The protected areas cover both public and private forests.
All Autonomous Communities are preparing or have already a strategy for Biodiversity and Red Natura 2000 for horizon 2030.
There is a good level of governance and a comprehensive legal framework developed for Spanish protected areas. In turn, the aforementioned report produced by COSE and published Finding by MAPA indicates that the degree of control by the forestry authority is high or very high in all the Autonomous Communities except in Galicia, where the level of control is considered to be medium. The study concludes that the Spanish regulations and surveillance procedures carried out by the Autonomous Communities are consistent. The Autonomous Communities have their own personnel to carry out the control over the high conservation values, Forestry/Environmental Agents.
Within the Civil Guard there is also the SEPRONA unit (Nature Protection Service), which carries out environmental police work. No reports have been published on relevant environmental damage related to forestry work/harvesting. In all cases there is a clear legal framework and effective control by the authorities of any potential threats to the high conservation values.
Any harvesting activity that may affect rare or endangered species has limitations specified in the harvesting permit. In turn, the Autonomous Communities have a wealth of information both on websites and in viewers and geographic information (GIS) on protected areas, priority ecosystems and habitat (Natura 2000 Network).
But, in the other hand, the Habitats Directive Report (2007-2012) describe several ecosystems which conservation trends are unknown or unfavourable. Forest operations are not on the eye of the storm, but BSL Woodfiber is proactive in order to protect this areas.
Because of that, BSL Woodfiber has developed a Manual of good practices to be aware when forest operations are carried out within or close to protected habitats.
With all this information, the risk related to this indicator should be classed as Low Risk.
Supply Base Report: BSL Woodfiber SA Page 46 • Best Management Practices • Supply contracts Means of • Assessment of potential impacts at operational level and of measures to minimise impacts Verificatio • Monitoring results n • Publicly available information on the protection of the identified values • Regional, publicly available data from a credible third party
• COSE study on wood control procedures and risk assessment in each Autonomous Community for the application of the Due Diligence System: https://goo.gl/ZXYiCU • Europarc 2016 yearbook on the state of protected areas in Spain: http://www.redeuroparc.org/system/files/shared/Publicaciones/Anuario_2016/anuario Evidence _2016_europarc-espana.pdf • Habitats (2007-2012) Directive Implementation Report: Reviewed https://www.miteco.gob.es/es/biodiversidad/temas/espacios- protegidos/art17_2007_2012_anexo_d_fichas_tcm30-207218.pdf • Habitats Directive information (cartography, reports): https://www.miteco.gob.es/es/biodiversidad/temas/espacios-protegidos/red-natura- 2000/rn_cons_seguimiento_Art17_inf_2007_2012.aspx Risk T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA Rating Comment or
Mitigation Measure
Indicator
The Biomass Producer has implemented appropriate control systems and procedures to 2.2.4 ensure that biodiversity is protected (CPET S5b). Spain is especially rich in fauna species in Europe due to its location on the southwestern edge of the European continent, just 14 km away from Africa. Around 95 species of land mammals inhabit Spain; some of the most valuable have already been mentioned. More than 270 species of birds breed in Spain each year, around 50 species of wintering birds and 30 species that use Spain as a migratory corridor. Also, almost 100 species of amphibians and reptiles, of which almost 40 are endemic to the country. In Spain there are about 50,000 species of insects and 1,500 species of spiders. As for flora, more than 8,000 plant species and subspecies have been identified within the Spanish territory.
Spain hosts 48% of all the mammals that exist in Europe. Of these 111 species of mammals, 19% are threatened at the European level and at least an additional 11% are considered Finding Near Threatened.
The major threats at the European level that can possibly (or potentially) affect mammals in Spain are invasive and other problematic species, both native and non-native. Mammal populations are also highly threatened mainly by agricultural and forestry effluents and noise pollution. Hunting, trapping, logging and wood harvesting also pose serious threats to mammals in the country.
Spain signed the Convention on Biological Diversity in June 1992 and is also a member of the rest of main environmental agreements (Ramsar, Bonn, CITES, Bern Convention, etc.). In Spain, the Convention's Strategic Plan for 2011-2020 has been adopted, which contains a long-term vision for 2050, a mission for 2020 and 20 operational targets for conservation and sustainable use of biodiversity.
Supply Base Report: BSL Woodfiber SA Page 47
Ecologistas en Acción has prepared a national-level report evaluating compliance with the Aichi Biodiversity Targets (2011-2012) and concludes that in these two years it has not implemented the necessary measures to achieve the Aichi Targets by 2020 and urges the State to take measures to meet them.
Additionally, the Spanish Forestry Plan aims to integrate conservation criteria within sectoral policy planning and management, as well as within improvement, protection and restoration practices for forest areas and measures for the conservation and recovery of vulnerable or endangered species of wild fauna and flora.
Work is also being carried out for conservation of genetic biodiversity. The Spanish Strategy for the Conservation and Sustainable Use of Forest Genetic Resources has been adopted, as has legislation for marketing forest biodiversity. For species that are more economically valuable, seed inventories and banks have been developed.
All the operations performed in the forest must be approved by the Forest Service (through the approved Forest Management Plan or Authorization). The restrictions are followed for specific areas and in certain seasons of the year, for example regarding the conservation of habitats. Best forest management practices are applied for the harvesting operations.
But, in the other hand, the Habitats Directive Report (2007-2012) describe several ecosystems which conservation trends are unknown or unfavourable. Forest operations are not on the eye of the storm, but BSL Woodfiber is proactive in order to protect this areas.
Because of that, BSL Woodfiber has developed a Manual of good practices to be aware when forest operations are carried out within or close to protected habitats.
With all this information, the risk related to this indicator should be classed as Low Risk.
• Best Management Practices • Supply contracts Means of • Assessment of potential impacts at operational level and of measures to minimise impacts Verification • Monitoring results • Publicly available information on the protection of the identified values • Regional, publicly available data from a credible third party • Biodiversity conservation plans: https://www.miteco.gob.es/es/biodiversidad/temas/conservacion-de-la- biodiversidad/conservacion-de-la-biodiversidad-en-espana/default.aspx • Biodiversity legislation: https://www.miteco.gob.es/es/biodiversidad/legislacion/ • IUCN 2017 annual report: https://portals.iucn.org/library/sites/library/files/documents/2018-023-En.pdf • Spanish Inventory of Natural Heritage and Biodiversity: https://www.miteco.gob.es/es/biodiversidad/temas/inventarios- Evidence nacionales/inventario-espanol-patrimonio-natural-biodiv/ Reviewed • IUCN reports: https://www.iucn.org/regions/europe/resources/country- focus/spain?page=1 • Habitats (2007-2012) Directive Implementation Report: https://www.miteco.gob.es/es/biodiversidad/temas/espacios- protegidos/art17_2007_2012_anexo_d_fichas_tcm30-207218.pdf • Habitats Directive information (cartography, reports): https://www.miteco.gob.es/es/biodiversidad/temas/espacios-protegidos/red- natura-2000/rn_cons_seguimiento_Art17_inf_2007_2012.aspx
Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Supply Base Report: BSL Woodfiber SA Page 48 Comment or Mitigation Measure
Indicator
The Biomass Producer has implemented appropriate control systems and procedures for 2.2.5 verifying that the process of residue removal minimises harm to ecosystems. The Authorization for Harvesting is issued by Forest Service of every community. Among other things, it regulates the residue removal management in every particular case. Burning of harvesting residues requires prior authorization as well.
In Spain there are competent bodies carrying out the control tasks of the harvesting operations. The Autonomous Communities have their own personnel (forest rangers) to carry out the control tasks. Within the Civil Guard there is also the SEPRONA unit (Nature Protection Service), which carries out environmental police work.
Finding So far, there was not any reports from both authorities specifying any damage to the ecosystems due to the harvesting operations, carried out under the legal frame and authorized by the Forest Service. The Nature Protection Service carries out the work as environmental police and can verify the compliance of the work performed to the authorization issued by the Forest Service.
BSL Woodfiber has developed a Manual of good practices to be aware when forest operations are carried out within or close to protected habitats.
Based on the available information this indicator is considered low risk • Best Management Practices Means of • Records of field inspection • Forestry work/harvesting authorisation/ Allocation Verification • Management Plan, development project • Signed agreements and contracts • Guide of Good Practices for the Prevention of Forest Fires: http://lifeomontevivo.org/docs/guiaprevinforpropfor.pdf
General information: • Galicia: o https://mediorural.xunta.gal/es/areas/forestal/presentacion/ • Andalucia: Evidence o http://www.juntadeandalucia.es/medioambiente/site/portalweb/vgn-ext- templating/v/index.jsp?vgnextoid=fa99193566a68210VgnVCM100000550 Reviewed 11eacRCRD • Castilla y León: o http://www.pfcyl.es • Principado de Asturias: o https://www.asturias.es/portal/site/webasturias/menuitem.a76385ecc6516 87bd9db8433f2300030/?vgnextoid=11df7e1385dfe210VgnVCM1000009 7030a0
Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Supply Base Report: BSL Woodfiber SA Page 49 Comment or Mitigation Measure
Indicator
The Biomass Producer has implemented appropriate control systems and procedures to 2.2.6 verify that negative impacts on ground water, surface water and water downstream from forest management are minimised (CPET S5b). Forest lands have a positive impact on water resources compared with other land uses such as agriculture.
And once again, depending on the type of forest work, there are three types of control impacts: • In public forest, the allocations include the restrictions to forest operations close to any water flows. • In private forest with Forest Management Plan approved, there are a previous revision by the authorities of all impacts on ground or surface water • In private forest without Management Plan, the Authorization for Harvesting issued by Forest Service of every community, also regulates the water management in every particular case. When a forest exploration is within 100 meters of any water stream, the Forest Service ask to the specific competent authority, the River Basin Agencies (Confederaciones hidrográficas), for a previous approval.
The FSC NRA for Spain states the following: “Forest activities with certain characteristics and Finding of a certain size, as set out in the law, must have an environmental impact report prior to the request for license activity. Environmental impacts of harvesting activities, like soil or water course damage, are generally well regulated in Spanish legislation. As a major branch of forest policy in Spain has been and continues to be aimed at ensuring the supply of water in sufficient quantity and quality.”
SEPRONA (Nature Protection Service) or Agentes Forestales / Medioambientales (Autonomous Communities controlling officers) are the organisations dealing with inspections and law enforcement.
Nature conservation societies also have an active role in Spain and there are no reports about relevant environmental damages linked to harvesting activities.
Because of that, BSL Woodfiber has developed a Manual of good practices to be aware when forest operations are carried out within or close to protected habitats.
Based on the foregoing, the risk related to this indicator is low.
• Maps of water streams and ground water • Map of forest explorations Means of • Forest Operating Procedures Verification • Forestry work/harvesting authorisation/ Allocation • Records of BSL field inspections
Evidence • FSC-NRA-ES V1-1 National Risk Assessment For Spain: https://fsc.org/en/document-centre/documents/resource/168 Reviewed
• Authorization process:
Supply Base Report: BSL Woodfiber SA Page 50 General information: • Galicia: o https://mediorural.xunta.gal/es/areas/forestal/presentacion/ • Andalucia: o http://www.juntadeandalucia.es/medioambiente/site/portalweb/vgn-ext- templating/v/index.jsp?vgnextoid=fa99193566a68210VgnVCM1000005501 1eacRCRD • Castilla y León: o http://www.pfcyl.es • Principado de Asturias: o https://www.asturias.es/portal/site/webasturias/menuitem.a76385ecc65168 7bd9db8433f2300030/?vgnextoid=11df7e1385dfe210VgnVCM1000009703 0a0
Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Comment or
Mitigation Measure
Indicator
The Biomass Producer has implemented appropriate control systems and procedures for 2.2.7 verifying that air quality is not adversely affected by forest management activities. Regarding this issue Spain has a legal framework based upon the European Air Quality Directive. The Spanish regulations and the surveillance procedures are carried out by the Autonomous Communities. The Autonomous Communities have their own personnel to carry out the control tasks
In Spain on air quality in general, there are reports from the European Commission and NGOs that too little is being done with regard to air pollution control. There have been law- suites, because plans to reduce Ozon are missing at Autonomous Communities.
Within the Civil Guard there is also the SEPRONA unit (Nature Protection Service), which carries out environmental police work. No reports have been published on relevant environmental damage related to forestry operations and harvesting.
Finding The greatest impacts on air quality in forests are caused by fires or emissions from nearby heavy industries. Neither of these two factors are a consequence of forestry harvesting operations and forest management activities.
The scope of the work carried out by BSL, the impacts on air quality are caused by the emissions from the machinery used to complete the work. Therefore, the work is not continuous in just one zone, so the impact is intermittent. About this point, the most relevant issue it’s a good maintenance of machinery, following the requirements of law 711/2006, about the Technical test of vehicles (ITV), compulsory for all vehicles. The non-compliance with this inspection is quite common.
In forestry works three main sources of atmospheric pollution have been identified: 1) Dust. To minimise the amount of dust produced by the works, it is necessary to proceed in moderation in those places where dust is generated.
Supply Base Report: BSL Woodfiber SA Page 51 2) Combustion gases from machinery and vehicles. To minimise the emission of gasses, the engines must be kept perfectly maintained and switched off when not in use. Machinery shall be reviewed in Vehicle Inspection Tests (ITV), but the non-compliance if these inspections is quite common in Spain. 3) Incineration of forest waste.
Because of that, BSL Woodfiber always asks for the ITV inspections of forestry machinery to subcontractors and suppliers.
Therefore, the risk for this indicator is considered Low Risk.
• Existing legal framework. Laws, regulations and control bodies • Manual of good practices Means of • Code of good environmental practices in Sustainable Forest Management Verification • Contracts with suppliers • ITV documents (BSL Woodfiber, subcontractors and suppliers)
• Non-compliance with ITV revision: https://itv.com.es/la-itv-es-obligatoria-aunque- no-toquemos-el-coche • Technical Inspection of Vehicles (ITV): http://www.dgt.es/es/seguridad- vial/normativa-y-legislacion/reglamento-trafico/vehiculos/modificaciones/rdl-711- 2006-de-9-junio.shtml https://www.captor-project.eu/en/a-spanish-court-forces-a-region-to-approve-air- Evidence quality-plansfor-the-first-time-in-history/ • The European parliament asked questions about air pollution in Spain: Reviewed http://www.europarl.europa.eu/doceo/document//E-8-2016-002926_EN.html • An NGO is also asking for improvement of the quality of air in Spain: https://www.captor-project.eu/en/extension-of-the-complaint-against-spain-for- dropping-plansto-reduce-ozone-levels • Overview of Legislation and regulations on air quality in Spain: http://www.aragonaire.es/moreinfo.php?n_action=policy
Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Comment or Mitigation Measure
Indicator
The Biomass Producer has implemented appropriate control systems and procedures for verifying that there is controlled and appropriate use of chemicals, and that Integrated Pest 2.2.8 Management (IPM) is implemented wherever possible in forest management activities (CPET S5c). Spain has a clear and effective legal framework and competent authorities that carry out the control tasks. The Spanish regulations and the surveillance procedures carried out by the Autonomous Communities are consistent. The Autonomous Communities have their own personnel to carry out inspections and law enforcement. Finding No reports have been published on relevant environmental damage caused by using chemicals linked to forestry operations. To be able to apply biocides and chemical agents it is necessary to have a licence issued by a body recognised by the competent authority and to have completed training in this field.
Supply Base Report: BSL Woodfiber SA Page 52
In the other hand, Spain was the largest consumer of pesticides in Europe. In pine can prosper a problematic moth (pine processionary moth, Thaumetopoea pityocampa). But these applications are promoted by public authorities, and not by BSL Woodfiber.
The Royal Decree 1311/2012, of 14 September, is to establish the framework sustainable use of pesticides by reducing of the risks and effects of their use on human health and the environment. The Royal Decree is an answer to Directive 2009/128 / EC of the European Parliament, of October 21, 2009, which establishes a framework to achieve a sustainable use of pesticides. With this Directive, the European Union regulates the use of plant protection products. Royal Decree provides for protection of the environment and the drinking water, reducing risks in specific areas (habitats and aquatic species), and measures PPP use in areas outside of agriculture. Royal Decree establishes a ban on aerial spraying in general, allowing them, in special cases only, if authorized by territorial delegations.
Because of that, BSL Woodfiber has developed a Manual of good practices to be aware that there is controlled and appropriate use of chemicals.
Based on the foregoing, the risk related to this indicator is classed as low.
• Existing legal framework. Laws, regulations and control bodies Means of • Manual of good practices • Code of good environmental practices in Sustainable Forest Management Verification • Monitoring results
Ministry of Health, Social Services and Equality: • Chemical substances legislation: https://www.msssi.gob.es/ciudadanos/saludAmbLaboral/prodQuimicos/legislacion.h tm Evidence • Royal Decree 830/2010, of 25 June, which establishes the regulations governing training in biocide treatment: Reviewed https://www.boe.es/boe/dias/2010/07/14/pdfs/BOEaAa2010a11157.pdf • Ministry of the Presidency, Royal Decree 1311/2012, of 14 September, establishing the framework for action to achieve a sustainable use of plant protection products: https://www.boe.es/boe/dias/2012/09/15/pdfs/BOEaAa2012a11605.pdf
Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Comment or
Mitigation Measure
Indicator
The Biomass Producer has implemented appropriate control systems and procedures for 2.2.9 verifying that methods of waste disposal minimise negative impacts on forest ecosystems (CPET S5d). There are laws in force that forbid any waste disposal in the forest, such as Law 22/2011 Finding on “The contaminated soil by waste”.
In a nutshell, in Spain the waste management consist in:
Supply Base Report: BSL Woodfiber SA Page 53 • Urban waste: areas must be kept clean and free from residue of rubbish scattered in the floor. Urban waste must be collected and deposited in the nearest municipal container. • Hazardous waste. Proper management of hazardous waste begins at the moment the waste is generated, and all personnel are involved, following the instructions listed below: o Do not mix hazardous waste. o Dispose of hazardous waste through an authorised waste management company
The Autonomous Communities have their own personnel (forest rangers) to carry out the control tasks, and within the Civil Guard there is also the SEPRONA unit (Nature Protection Service), which carries out environmental police work.
Among other things, they are also involved in protection of natural spaces, and survey how the waste management is carried out by the responsible for harvesting.
In addition, BSL Woodfiber has developed a Manual of good practices to verify that methods of waste disposal minimise negative impacts on forest ecosystems.
Therefore, the risk for this indicator is considered Low Risk.
Means of • Field inspections • Delivery records of hazardous waste to an authorised waste management company Verification • Law 22/2011 on the contaminated soil by waste: https://www.boe.es/eli/es/l/2011/07/28/22 Evidence • Legislation on waste management and prevention, regulations and planning: Reviewed https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/prevencion-y- gestionresiduos/normativa-y-planificacion/
Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Comment or Mitigation Measure
Indicator
Analysis shows that feedstock harvesting does not exceed the long-term production 2.3.1 capacity of the forest, avoids significant negative impacts on forest productivity and ensures long-term economic viability. Harvest levels are justified by inventory and growth data. The available forestry statistics of national forestry inventory (IFN3) show a significant increase in timber stocks in Spain from inventory to inventory as a result of both the continued increase in forest area in recent decades and the improvement in forest cover.
Also, according to the reports produced by the Ministry’s Forestry Service, the annual growth Finding of wood in Spanish forests (45 million m3) is about three times greater than the amount harvested (15 million m3 per year). This balance, with an extraction rate of 35%, is maintained with the current data. However, the figures vary widely between Autonomous Communities. In all cases, the felling figures are lower than the growth figures.
The different laws in each Autonomous Community regulate forest operations, use and specific technical limitations (type of logging, maximum allowable cutting area, machinery to
Supply Base Report: BSL Woodfiber SA Page 54 be used according to the soil conditions, etc.), diameters (minimum and/or maximum), species and other parameters.
Based on the foregoing, the risk related to this indicator is low.
• Management Plan, stocks and growth data National or regional inventories, stocks and growth data. Means of • • Harvested volume data Verification • Type of forestry operations
• Source of information of volume and species explored by Autonomous Community: o Andalucía http://www.juntadeandalucia.es/medioambiente/vem/?c=Menu/tem a/441 o Galicia https://mediorural.xunta.gal/es/recursos/estadisticas/estadisticas- forestales/ o Castilla y León https://medioambiente.jcyl.es/web/jcyl/MedioAmbiente/es/Plantilla1 00/1131977831418/_/_/_ Evidence Reviewed • Montero, G. and SERRADA, R. 2013. La situación de los Bosques y el sector en España - ISFE 2013 Sociedad Española de Ciencias Forestales. Lourizán (Pontevedra): http://secforestales.org/content/informe-isfe
• 7th Spanish Forestry Congress. The situation of forests and the forestry sector in Spain. ISFE 2017: https://7cfe.congresoforestal.es/content/la-situacion-de-losbosques-y-el- sector-forestal-en-espana-isfe-2017
• ORDER of December 29, 2011, which regulates the use of forest biomass for energy use: https://www.juntadeandalucia.es/boja/2012/12/3
Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Comment or
Mitigation Measure
Indicator
Adequate training is provided for all personnel, including employees and contractors 2.3.2 (CPET S6d). Training in the forest sector is quite weak. Legislation is mainly focused on health and safety, and there are not specific topics for forestry sector despite the danger of the forest operations. The use of subcontractors and self-employees are quite common on forest sector. Conditions of these forest workers could be one of the weakest points of forestry Finding sector.
Most part of the companies holds prevention service contract with external companies. This companies provides training according to the legislation that, as has been noted before, is
Supply Base Report: BSL Woodfiber SA Page 55 not deep enough and do not always cover subcontractors and self-employees. The professionalization and training of the different actors in the forestry sector is unfinished business.
In some Autonomous Communities, like Andalucía, Aragón, Galicia, there are public and private initiatives promoting specific training for forest sector. But all these programs, despite they could be for free, are voluntary.
Based on these findings, the risk related to this indicator is Specified Risk.
• Contract with the prevention service enterprise • Training records by the prevention service Means of • Training Certificates Verification • Manual of Good Forestry Practices • Contracts with providers
• Law 31/1995 on the Prevention of Occupational Risks: https://www.boe.es/eli/es/l/1995/11/08/31 • Ministry of labour, migration & social security: http://www.mitramiss.gob.es/en/index.htm • All legislation related to Employment and Social Security: Evidence https://www.boe.es/legislacion/codigos/codigo.php?id=93&modo=1¬a=0&tab=2 Reviewed • Royal Decree 1215/1997, of 18 July, establishing the minimum health and safety requirements for the use of work equipment by workers. Modified by RD 2177/04, of 12 November, regarding temporary work at height. o https://www.boe.es/buscar/doc.php?id=BOE-A-1997-17824 o https://www.boe.es/buscar/doc.php?id=BOE-A-2004-19311
Risk Rating ☐ Low Risk T Specified Risk ☐ Unspecified Risk at RA
BSL Woodfiber trains its personnel on all relevant aspects and demands the same from its feedstock suppliers. • Training records obligatory according to legislation and records of qualification are collected during supplier qualification process and checked during supplier Comment or inspections; • Training conducted by BSL in several fields, including identification of key Mitigation ecosystems, habitats and species biodiversity (annually and based on the results of Measure field visits); • Training on best forest management practices.
BSL performs supplier inspections: the training records, (new) workforce, and the hiring of specialists. The level of knowledge of personnel is inspected during site visits.
Supply Base Report: BSL Woodfiber SA Page 56 Indicator
Analysis shows that feedstock harvesting and biomass production positively contribute to 2.3.3 the local economy, including employment. The biomass sector in Spain is complementary with other wood industries, as it uses and processes low-quality wood and forest residues and secondary feedstock.
The biomass producers create a market for these kinds of remaining forest and wood industry residues. This market makes forest thinning feasible. Ever more people have a job at a biomass producer in Spain, and the sector is pushing sustainability of the whole sector forward through strict and critical certification programs such as SBP. All these activities decrease the chance of forest fires, which are perceived as the greatest threat to local communities.
Finding The forest sector impacts positively in rural areas, proving alternatives in the long term for local communities to keep its population.
The population employed in fields related to the forestry sector represented 5.7% of the total employed population in 2016. This percentage has remained fairly constant since 2008. It is expected, that these percentages will increase, because of employment generated by the increased use of sustainable energy, such as biomass, as also a greater enhancement of the multifunctionality of forestry.
Galicia:
Supply Base Report: BSL Woodfiber SA Page 57
Asturias:
Supply Base Report: BSL Woodfiber SA Page 58
Andalucía:
Supply Base Report: BSL Woodfiber SA Page 59
Castilla y León:
Supply Base Report: BSL Woodfiber SA Page 60
Wood logging figures in Spain (2018):
Supply Base Report: BSL Woodfiber SA Page 61 Based on the foregoing, the risk related to this indicator is classed as low.
Means of List of employees (TC1 and TC2) Verification • ASEMFO, Employment and investment study in the forestry sector: http://www.asemfo.org/empresas/asemfo/X_estudio_DEF_web.pdf • Forestry economy and foreign trade (2016): https://www.unece.org/fileadmin/DAM/timber/country- info/statements/Spain2016.pdf • Statistics on the forestry sector: https://www.mapa.gob.es/es/desarrollo- rural/estadisticas/Est_Comercio_Exterior.aspx https://www.mapa.gob.es/es/desarrollo- Evidence rural/estadisticas/forestal_aprovechamientos.aspx Reviewed • Source of information of volume and species explored by Autonomous Community: o Andalucía http://www.juntadeandalucia.es/medioambiente/vem/?c=Menu/tem a/441 o Galicia https://mediorural.xunta.gal/es/recursos/estadisticas/estadisticas- forestales/ o Castilla y León https://medioambiente.jcyl.es/web/jcyl/MedioAmbiente/es/Plantilla1 00/1131977831418/_/_/_
Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Comment or
Mitigation Measure
Indicator
The Biomass Producer has implemented appropriate control systems and procedures for 2.4.1 verifying that the health, vitality and other services provided by forest ecosystems are maintained or improved (CPET S7a). The most relevant threats to the health and vitality of Spanish forests is the drought, (85% percent of abiotic damages).
Finding The introduction of foreign pests and pathogens and climate change are also relevant threats, along with forest fires. Other factors like snow and windfalls also affects to the stability of the forest. Animals cause less damages on the forest.
Supply Base Report: BSL Woodfiber SA Page 62
And climate change increases the vulnerability of forests to the most relevant risks: drought, forest fires, pest and diseases.
There is a systematic legal framework, with action plans implemented at government level to manage the main problems detected and a data monitoring network (European Forest Damage Monitoring Network). In addition, the level of control by the forestry authority is medium/high throughout the whole country. Therefore, the Spanish regulations and the surveillance procedures carried out by the Autonomous Communities are coherent.
The scope of this evaluation is the impact/effect of forestry operations on the indicators assessed. Forest operations normally have a positive impact on the control of forest pest and diseases. Forest operations also help to control the accumulation of fine biomass, to prevent forest fires. The effects of drought in the forest is largely beyond fighting against climate change.
Level of defoliation:
It is concluded that the situation is being addressed and the risk related to this indicator is low. • Existing legal framework. Laws, regulations and control bodies. • Assessment of the potential impacts of forestry operations on the health and vitality of forests. Means of • Assessment of potential impacts at site level and of the measures taken to minimise Verification them • Good Environmental Practices in Sustainable Forest Management • Contracts with suppliers • Information received from suppliers
Supply Base Report: BSL Woodfiber SA Page 63 • Monitoring results
• European Forest Damage Network, Level I - Forest Damage Inventory 2018: https://www.mapa.gob.es/es/desarrollo-rural/temas/politica-forestal/inventario- cartografia/redes-europeas-seguimiento-bosques/default.aspx • SECF report: http://secforestales.org/content/informe-isfe Evidence • Plant Health: https://www.mapa.gob.es/es/agricultura/temas/sanidadvegetal/default.aspx Reviewed • Pine Wood Nematode: https://www.mapa.gob.es/es/agricultura/temas/sanidadvegetal/nematodo-de-la- madera-del-pino/ • Law 43/2002 on Plant Health: https://www.boe.es/eli/es/l/2002/11/20/43
Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Comment or Mitigation Measure
Indicator
The Biomass Producer has implemented appropriate control systems and procedures for 2.4.2 verifying that natural processes, such as fires, pests and diseases are managed appropriately (CPET S7b). Forest Fires
It cannot be denied that that they currently represent one of the greatest threats to forests in Spain. Between 1990 and 2010, the annual average number of forest fires was 17,864, with a maximum of 25,557 in 1995. During the same period, the annual average area burned was 139,775 ha, of which approximately 51,000 ha were forested areas, and 88,000 ha were areas without trees.
Climate change is expected to affect, and probably already does affect, the susceptibility of Finding forests to disturbances, as well as the frequency, intensity, duration and timing of these disturbances. For example, there may be increased fuel accumulation in forests, the fire seasons may last for longer and more extreme weather conditions may occur more frequently. In addition, the frequency and intensity of forest fires is also expected to increase.
The current trend is for forests to offer an increasingly dangerous vegetation structure in this regard, as they accumulate the fine biomass that was once used to cover livestock feed and heating requirements, and have a greater spatial continuity of forest fuel, taking into account the vegetation being installed in previously agriculture lands.
Supply Base Report: BSL Woodfiber SA Page 64
At management level public administrations, mainly Autonomous Communities, are the responsible for forest fires prevention and control. However, forest owners have certain responsibilities for the proper management of the forest and of fire prevention and defence infrastructures. The analysis of this indicator will focus on these issues, resulting from forestry operations.
On forests management level we can make next classification: 1. Public forests: The administration itself is the manager of these forests and is therefore responsible for maintaining adequate defence and prevention infrastructure. In this respect, the level of implementation of these infrastructures can be considered adequate. 2. Private forests. The existing legislation from Autonomous Communities stablishes specific obligations or responsibilities of forest managers/owners concerning prevention/defence against forest fires. As example, in Andalusia the law requires the preparation of Forest Fire Prevention Plans or Management Plans, in Galicia forest owners has several limitations for pine and eucalyptus plantations close to houses and infrastructures. 3. Each Autonomous Community developes its own Emergency Plan for forest fires: a. Galicia: PLADIGA ( https://mediorural.xunta.gal/gl/temas/defensa- monte/pladiga-2020) b. Asturias: https://www.asturias.es/Asturias/descargas/PDF_TEMAS/Agricultura/Politica %20Forestal/incendios/estrategia_prevencion_2013_2016.pdf c. Andalucía: INFOCA ( http://www.juntadeandalucia.es/medioambiente/site/portalweb/menuitem.220 de8226575045b25f09a105510e1ca/?vgnextoid=2076a5f862fa5310VgnVCM 1000001325e50aRCRD&vgnextchannel=321cc98d5b40b410VgnVCM20000 00624e50aRCRD) d. Castilla y León: INFOCAL ( https://medioambiente.jcyl.es/web/jcyl/MedioAmbiente/es/Plantilla100/11319 77710119/_/_/_)
Supply Base Report: BSL Woodfiber SA Page 65 About the impact of the biomass production, forest treatments like thinning and clearing has a positive impact on the prevention of forest fires, as it reduces the density and biomass in the forest cover. And forest operations are not considered a relevant cause of forest fires. Despite this, BSL Woodfibe has included prevention measures into the Good Environmental Practices Manual.
Because of that, this indicator is classified as Specified Risk for forest fires.
Pest and diseases
The introduction of foreign pests and pathogens and climate change are currently the main threats to the health of Spanish forests, along with forest fires.
Changes in climate are changing the dynamics of alterations caused by native insects and forest pathogens, as well as facilitating the establishment and spread of introduced species of pests. Such changes in the dynamics of alterations, coupled with the direct impact of climate change on trees and forest ecosystems, can have negative effects and increase the vulnerability of forests to other disturbances.
The introduction of dangerous invasive alien species into our forests continues. New organisms, such as the bacterium Xylella fastidiosa, the chestnut gall wasp (Dryocosmus kuriphilus) or the western conifer seed bug (Leptoglossus occidentalis), have recently joined other quarantined organisms detected, such as the the pine pitch canker (Fusarium circinatum).
There is a particular concern in relation of the first outbreaks of the pine wood nematode (Phelenchus xylophilus) in Castilla y León and Galicia, close to the Portuguese border. Autonomous Communities had created laws in order to avoid the expansion of the disease (https://www.mapa.gob.es/es/agricultura/temas/sanidadvegetal/nematodo-de-la-madera-del- pino/). Wood must not go out of the affected area. Despite this, some infractions of this rule were detected, despite the high risk and impact of the non-fulfilment of the law.
Supply Base Report: BSL Woodfiber SA Page 66
BSL Woodfiber is always aware of any change, related with the nematode or any potential plague or disease.
Yearly a forest damage inventory is carried out related to the European Forest Damage Network Level I and Level II inventory. Detailed information about damages in the forest per region are available.
Here it’s a general overview for Spain:
Supply Base Report: BSL Woodfiber SA Page 67
There is a systematic legal framework, with action plans implemented at government level to manage the main problems detected and a data monitoring network (European Forest Damage Monitoring Network). In addition, the level of control by the forestry authority is medium/high throughout the whole country. Therefore, the Spanish regulations and the surveillance procedures carried out by the Autonomous Communities are coherent.
The scope of this evaluation is the impact/effect of forestry operations on the indicators assessed. Forestry operations normally have a positive impact on the control of forest diseases such as pine wood nematode, since one of the control measures is to reduce the plants that show signs of deterioration.
It is concluded that the situation is broadly addressed but, because of the infractions detected with pine wood nematode and its potential impact is so high, the risk related to Pest and diseases is considered Specified Risk.
• Existing legal framework. Laws, regulations and control bodies. • Assessment of the potential impacts of forestry operations on the health and vitality of forests. Means of • Assessment of potential impacts at site level and of the measures taken to minimise Verificatio them n • Good Environmental Practices in Sustainable Forest Management • Contracts with suppliers • Information received from suppliers Monitoring results Forest fires Evidence • Forest fires: https://www.mapa.gob.es/es/desarrollo-rural/temas/politica- Reviewed forestal/incendiosforestales/default.aspx • Forest fire regulations:
Supply Base Report: BSL Woodfiber SA Page 68 o General - Spain https://www.mapa.gob.es/es/desarrollo-rural/legislacion/leg- espanolaforestal-incendios.aspx o Andalucía http://www.juntadeandalucia.es/medioambiente/site/portalweb/menui tem.220de8226575045b25f09a105510e1ca/?vgnextoid=321cc98d5b40b410 VgnVCM2000000624e50aRCRD&vgnextchannel=fa99193566a68210VgnVC M10000055011eacRCRD o Galicia https://mediorural.xunta.gal/gl/temas/defensa-monte/pladiga-2020 o Principado de Asturias https://www.asturias.es/portal/site/webasturias/menuitem.4b280f821 4549ead3e2d6f77f2300030/?vgnextoid=1530d4e871b59210VgnVCM100000 97030a0aRCRD&vgnextchannel=11df7e1385dfe210VgnVCM10000097030a 0aRCRD&i18n.http.lang=es o Castilla y León https://medioambiente.jcyl.es/web/jcyl/MedioAmbiente/es/Plantilla10 0/1131977708586/_/_/_ • Forest Fire Statistics: https://www.mapa.gob.es/es/desarrollorural/estadisticas/Incendios_default.aspx
Pest and diseases: • European Forest Damage Network, Level I - Forest Damage Inventory 2018: https://www.mapa.gob.es/es/desarrollo-rural/temas/politica- forestal/inventariocartografia/redes-europeas-seguimiento- bosques/red_nivel_l_resultados.aspx • European Forest Damage Network, Level II European intensive and continuous monitoring of forest ecosystems, Level II: https://www.mapa.gob.es/es/desarrollo- rural/temas/politica-forestal/inventariocartografia/redes-europeas-seguimiento- bosques/red_nivel_ll_resultados.aspx • SECF report: http://secforestales.org/content/informe-isfe • Plant Health: https://www.mapa.gob.es/es/agricultura/temas/sanidadvegetal/default.aspx • Pine Wood Nematode: https://www.mapa.gob.es/es/agricultura/temas/sanidadvegetal/nematodo-de-la- madera-del-pino/ • Law 43/2002 on Plant Health: https://www.boe.es/eli/es/l/2002/11/20/43 • Commercialization of infected wood: https://elpais.com/sociedad/2019/08/14/actualidad/1565766326_362414.html
Risk ☐ Low Risk T Specified Risk ☐ Unspecified Risk at RA Rating Forest fires: Comment • Visual inspection of the plot before harvesting; • Implementation of forest fire fighting measures according to law; or • Best forest practices. Mitigation Measure Pest and diseases BSL Woodfiber do no accept wood cooming from nematode affected area.
Supply Base Report: BSL Woodfiber SA Page 69 Indicator
The Biomass Producer has implemented appropriate control systems and procedures for 2.4.3 verifying that there is adequate protection of the forest from unauthorised activities, such as illegal logging, mining and encroachment (CPETS7c). There are no significant problems in Spain with unauthorized or illegal activities in forests such as logging, mining or illegal occupation. Small scale problems are identified, such as unauthorized sports activities, theft of firewood, wood or fruit, poaching, fly tipping, feral dogs, etc. Finding Illegal or unauthorized activities have a small impact on Spanish forests and there are no reports of situations of substantial magnitude with regards this issue.
Therefore, the risk related to this indicator is classed as low. • Records of field inspections and monitoring Means of • Interviews with workers • Interviews with relevant parties Verification • Public information available (media)
• Illegal Logging Portal, Spain: https://www.illegal-logging.info/regions/spain Evidence • Transparency International. CPI Spain: https://www.transparency.org/country/ESP Reviewed • CIFOR fact sheet on illegal logging: https://www.cifor.org
Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Comment or Mitigation Measure
Indicator
The Biomass Producer has implemented appropriate control systems and procedures for verifying that legal, customary and traditional tenure and use rights of indigenous people 2.5.1 and local communities related to the forest are identified, documented and respected (CPET S9). In Spain there are many ancient customary rights linked to the forests of the Iberian Peninsula. In the northwest of Spain the Communitarian Forest (Montes en Mano Común) have a relevant weight within the forest sector. Communitarian forest can be managed by their own or by the public administration.
Finding There are no relevant conflicts related to these rights, and where they exist there are established channels for their management and resolution.
The Communitarian Forests, both Roman and Germanic, have been gradually recovered since the establishment of democracy in 1977. Where communities have been able to
Supply Base Report: BSL Woodfiber SA Page 70 demonstrate common use by local residents, they have been declared Communitarian Forests. There are Communitarian Forest Boards and legislation to regulate their activity. There are many forestry associations or similar groups, at local or regional level, that carry out important work in the recovery or maintenance of customary uses of forests.
Conflicts related to customary rights can be addressed through the Ombudsman (Defensor del Pueblo). For the last several years there were no issues linked to forest use rights reported in the Ombudsmen’s annual report.
In many cases, customary rights have been integrated into modern management of forests (droving roads, public roads, firewood production, etc) and many others have fallen into disuse.
There are no indigenous people in Spain that require special protection in terms of their forests use rights, and there are no local communities that depend on the services of the forests in order to survive. In the past, people were more dependent of the services that forest provide (firewood, charcoal production, hunting and fishing, etc). Nowadays urbanization is taking over and the rural population decreases. The customary rights remain unused by people and this is clearly illustrated by the shape of the forests. In most cases, forests are abandoned and require thinning and maintenance. This way forest services are useful to local communities.
Therefore, the risk related to this indicator is classed as low. • Customary rights, when applicable, are identified and documented Means of • Interviews with local communities or other relevant parties Verification • Appropriate procedures in place to resolve any conflicts
• FSC-NRA-ES V1-1 National Risk Assessment For Spain: https://fsc.org/en/document- Evidence centre/documents/resource/168 • Ley de Montes 43/2003 https://www.boe.es/buscar/act.php?id=BOE-A-2003-21339 Reviewed • Civil code: http://derechocivil-ugr.es/attachments/article/45/spanish-civil-code.pdf
Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Comment or Mitigation Measure
Indicator
The Biomass Producer has implemented appropriate control systems and procedures for verifying that production of feedstock does not endanger food, water supply or subsistence 2.5.2 means of communities, where the use of this specific feedstock or water is essential for the fulfilment of basic needs. Regarding the basic needs of local communities, the dependence of some local Finding communities on ecosystem goods and services has been identified, which could grant
Supply Base Report: BSL Woodfiber SA Page 71 those goods and services the character of HCV, specifically dependence on unregulated water for human consumption and sanitary water. Despite this, it is widely accepted among the experts consulted in the development of FSC NRA report (including a public workshop conducted by FSC Spain) that forest management activities do not threaten water availability under the conditions described, and that water policy and forest restoration and hydrological protection measures are sufficient safeguards.
Regarding this indicator, only the protection of the headwaters of the hydrographic basins in the driest areas of southern and eastern Spain is considered applicable. These areas normally have protected reforested areas carried out by the state administration and are protected by both national and regional legislation. In addition, they are usually public forests managed by the administration itself (in fact, these forests are one of the types of forests that can be included in the catalogue of public utility forests).
Therefore, the risk related to this indicator is classed as low. • Existing legal framework. Laws, regulations and control bodies Means of • Technical Specifications for the allocation of the public forest works contract Verification • Forestry work/harvesting authorisation
• FSC-NRA-ES V1-1 National Risk Assessment For Spain: https://fsc.org/en/document- Evidence centre/documents/resource/168 • Regulatory Framework for Hydrological Planning: Reviewed https://www.miteco.gob.es/es/agua/legislacion/Marco_normativo_planificacion.aspx
Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Comment or Mitigation Measure
Indicator
The Biomass Producer has implemented appropriate control systems and procedures for verifying that appropriate mechanisms are in place for resolving grievances and disputes, 2.6.1 including those relating to tenure and use rights, to forest management practices and to work conditions. In Spain there are clear and well-known legal channels for resolving conflicts that are also regulated by the corresponding laws.
The legal framework of reference regarding land use and ownership rights, forest management Finding activities and workers’ conditions includes, among others: • Civil Code • Spanish Constitution • Forestry Law of the State and of the Autonomous Communities.
Supply Base Report: BSL Woodfiber SA Page 72 The exiting legal framework and different laws clearly define the responsibilities and duties of the people involved in these matters, as well as providing a clear framework for appeals or complaints in the event of disputes concerning these issues.
Besides that, BSL Woodfiber is FSC and PEFC certified, and implements a complaint procedure regarding it’s questions regarding forestry activities the company is performing.
Therefore, the risk related to this indicator is classed as low. Means of • Existing legal framework Verificatio • Level of governance • Manuals of good forestry practices n • Existence of contracts • Civil code: http://derechocivil-ugr.es/attachments/article/45/spanish-civil-code.pdf • Forestry Law consolidated text (Forestry Law 43/2003 amended by Laws 10/2006, of 28 April and 21/2015, of 20 July): https://www.boe.es/buscar/act.php?id=BOEaAa2003a21339 • General - Spain https://www.mapa.gob.es/es/desarrollo-rural/temas/politica- forestal/inventario-cartografia/inventario-forestal-nacional/default.aspx Evidence • Andalucía http://www.juntadeandalucia.es/medioambiente/site/portalweb/vgn-ext- templating/v/index.jsp?vgnextoid=fa99193566a68210VgnVCM10000055011eacRCRD Reviewed • Castilla y León http://www.pfcyl.es • Galicia https://mediorural.xunta.gal/es/areas/forestal/presentacion/ • Principado de Asturias https://www.asturias.es/portal/site/webasturias/menuitem.a76385ecc651687bd9db8433f2 300030/?vgnextoid=11df7e1385dfe210VgnVCM10000097030a0aRCRD&vgnextchannel =854344faf08ad210VgnVCM1000002f030003RCRD&i18n.http.lang=es
Risk T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA Rating Comment or
Mitigation Measure
Indicator
The Biomass Producer has implemented appropriate control systems and procedures for 2.7.1 verifying that Freedom of Association and the effective recognition of the right to collective bargaining are respected. Labour rights are adequately protected in Spain, including those specified in the ILO’s fundamental principles. Spain has ratified the ILO’s eight Fundamental Conventions.
One of the fundamental legal principles that underpins the current system of labour relations Finding in Spain is the one contained in section 1, article 28 of the Spanish Constitution, which recognises freedom of association as being a fundamental right for all people to freely form trade unions. Article 37 of the Constitution, together with articles 35 and 38, covers the constitutional framework of labour relations.
Supply Base Report: BSL Woodfiber SA Page 73 Pursuant to that precept, the law must guarantee the right to collective labour bargaining and the binding force of conventions, in addition to recognising the rights of workers and businesspeople to take industrial action. The law that regulates the exercise of that right, without prejudice to the limitation that may be set, shall include the guarantees needed to ensure the functioning of the community’s essential services.
Despite the strong legal framework, there are some concerns over civil rights in Spain, as reflected in reports by international organisations like the International Trade Union Confederation (ITUC). The ITUC published a report on working conditions in 139 countries, carrying out a study in 2019 using 97 internationally recognised indicators. Spain was given a score has a rating of 3, from 1 to 5+. This score is given for countries where: (There are) ‘Regular violation of rights. The government and/or companies are regularly interfering in collective labour rights. There are deficiencies in laws and/or certain practices which make frequent violations possible.’
There is a National Plan to fight illegal employment and Social Security fraud. Labour inspectors form the Government appointed authority check labour and safety rights. Companies are inspected in respect of those matters, with violations being sanctioned and corrected. No relevant violations were found of the laws or rights of free association and collective bargaining in relation to the forestry sector. None of the concerns is directly related to the forestry sector.
The risk relating to the indicator is classified as low, in line with FSC-NRA-ES V1-1 (Indicator 2.2).
• Existing legal framework and level of governance • Contracts of employment Means of • The existence of a collective-bargaining agreement • Company policies Verification • Interviews with Heads of Human Resources • Interviews with workers
• ILO Spain: http://www.ilo.org/madrid/oitaenaespaña/langaaes/index.htm • ITUC Global Rights Index: https://survey.ituc-csi.org/spain.html#tabs-3 • Spanish Constitution: https://www.boe.es/eli/es/c/1978/12/27/(1) • Workers’ Statute: https://www.boe.es/eli/es/rdlg/2015/10/23/2 • Ministry of labour, migration & social security: http://www.mitramiss.gob.es/en/index.htm • Legislation related to Employment and Social Security: o https://www.boe.es/legislacion/codigos/codigo.php?id=93&modo=1¬a=0 &tab=2 Evidence o http://www.congreso.es/consti/constitucion/indice/sinopsis/sinopsis.jsp?art= Reviewed 37&tipo=2 • Spanish Ministry of Employment and Social Security, 2018 Guide to Collective Bargaining: http://www.empleo.gob.es/es/sec_trabajo/ccncc/B_Actuaciones/Guia/GuiaNC_2018 _web.pdf • Spanish Ministry of Employment and Social Security, Strategic Plan for the Labour Inspectorate and Social Security: https://www.boe.es/boe/dias/2018/04/19/pdfs/BOE-A-2018-5329.pdf • FSC-NRA-ES V1-1 National Risk Assessment For Spain: https://fsc.org/en/document-centre/documents/resource/168
Supply Base Report: BSL Woodfiber SA Page 74
Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Comment or
Mitigation Measure
Indicator
The Biomass Producer has implemented appropriate control systems and procedures for 2.7.2 verifying that feedstock is not supplied using any form of compulsory labour. Labour rights are adequately protected in Spain, including those specified in the ILO’s fundamental principles. Spain has ratified the ILO’s eight Fundamental Conventions.
Spain was actually one of the first countries to ratify the 1930 Convention on Forced Labour (No. 29), doing so in 1932. It has developed a solid legal and institutional framework to fight human rights violations and illegal employment, especially with the constant adaptation of the relevant repressive provisions of the Criminal Code, through the adoption in 2009 of an initial Integral Plan against human trafficking, and with the specific role played by the labour inspectorate in detecting criminal conditions arising from exploitation at work or human trafficking.
Labour exploitation is prohibited by the Penal Code, as well as by immigration law. Under article 311 of the Penal Code, those who impose on workers (by deception or exploitation of vulnerability) such services and working conditions that prejudice social security are punishable by imprisonment from six months to six years and a fine of six to twelve months' salary. Article 312 prohibits the smuggling of labour and the hiring of undocumented workers Finding in working conditions below permitted standards.
Under article 173 of the Criminal Code, a person who, through the use of his superior position in an employment relationship, inflicts degrading treatment on another by seriously undermining his moral integrity is liable to imprisonment.
There is no provision in Spanish law that limits workers to change or leave work. Workers must give prior notice as specified in the collective agreement or as custom requires. The usual period of notice is 15 days. Workers normal working hours are 9 a day and 40 a week on average over a twelve-month reference period. The maximum number of overtime hours per year is 80.
There is also a National Plan to fight illegal employment and Social Security fraud. Labour inspectors form the Government appointed authority check labour and safety rights. Companies are inspected in respect of those matters, with violations being sanctioned and corrected.
Supply Base Report: BSL Woodfiber SA Page 75
No relevant violations have been found of the laws on forced labour in relation to the forestry sector.
The risk relating to the indicator is classified as low, in line with FSC-NRA-ES V1-1 (Indicator 2.2). • Existing legal framework and level of governance • Contracts of employment Means of • The existence of a collective-bargaining agreement Verification • Company policies • Interviews with Heads of Human Resources • Interviews with workers • ILO Spain: http://www.ilo.org/madrid/oitaenaespaña/langaaes/index.htm • ITUC Global Rights Index: https://survey.ituc-csi.org/spain.html#tabs-3 • Spanish Constitution: https://www.boe.es/eli/es/c/1978/12/27/(1) • Workers’ Statute: https://www.boe.es/eli/es/rdlg/2015/10/23/2 • Ministry of labour, migration & social security: http://www.mitramiss.gob.es/en/index.htm • Legislation related to Employment and Social Security: o https://www.boe.es/legislacion/codigos/codigo.php?id=93&modo=1¬a=0 &tab=2 Evidence o http://www.congreso.es/consti/constitucion/indice/sinopsis/sinopsis.jsp?art= Reviewed 37&tipo=2 • Spanish Ministry of Employment and Social Security, 2018 Guide to Collective Bargaining: http://www.empleo.gob.es/es/sec_trabajo/ccncc/B_Actuaciones/Guia/GuiaNC_2018 _web.pdf • Spanish Ministry of Employment and Social Security, Strategic Plan for the Labour Inspectorate and Social Security: https://www.boe.es/boe/dias/2018/04/19/pdfs/BOE-A-2018-5329.pdf • FSC-NRA-ES V1-1 National Risk Assessment For Spain: https://fsc.org/en/document-centre/documents/resource/168 Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Comment or
Mitigation Measure
Indicator
The Biomass Producer has implemented appropriate control systems and procedures to 2.7.3 verify that feedstock is not supplied using child labour. Labour rights are adequately protected in Spain, including those specified in the ILO’s fundamental principles. Spain has ratified the ILO’s eight Fundamental Conventions.
Finding Article 6 “Child Labour” of the Workers’ Statute specifies: 1. Persons aged under 16 must not enter the world of work. 2. Workers aged under 18 cannot carry out night duties. They must also not carry out any work activities or fill any work posts that are covered by limitations on contracting persons
Supply Base Report: BSL Woodfiber SA Page 76 aged under 18, pursuant to the provisions of Law 31 / 1995 of 8 November on Preventing Risks in the Workplace, and in applicable regulations. 3. Persons aged under 18 must not do overtime. 4. Persons aged under 18 can only take part in public shows in exceptional cases subject to the labour authority, provided that doing so is not injurious to the health, professional development, and human development of those persons. Permission must be given in writing and for specific events.”
There is a Government of Spain Plan to fight illegal working and Social Security fraud. Labour inspectors form the Government appointed authority to check labour and safety rights. Companies are inspected in respect of those matters, with violations being sanctioned and corrected.
No relevant violations are found of the laws on child labour in relation to the forestry sector.
The risk relating to the indicator is classified as low, in line with FSC-NRA-ES V1-1 (Indicator 2.2). • Existing legal framework and level of governance • Contracts of employment Means of • The existence of a collective-bargaining agreement • Company policies Verification • Interviews with Heads of Human Resources • Interviews with workers
• ILO Spain: http://www.ilo.org/madrid/oitaenaespaña/langaaes/index.htm • ITUC Global Rights Index: https://survey.ituc-csi.org/spain.html#tabs-3 • Spanish Constitution: https://www.boe.es/eli/es/c/1978/12/27/(1) • Workers’ Statute: https://www.boe.es/eli/es/rdlg/2015/10/23/2 • Ministry of labour, migration & social security: http://www.mitramiss.gob.es/en/index.htm • Legislation related to Employment and Social Security: o https://www.boe.es/legislacion/codigos/codigo.php?id=93&modo=1¬a=0 &tab=2 Evidence o http://www.congreso.es/consti/constitucion/indice/sinopsis/sinopsis.jsp?art= 37&tipo=2 Reviewed • Spanish Ministry of Employment and Social Security, 2018 Guide to Collective Bargaining: http://www.empleo.gob.es/es/sec_trabajo/ccncc/B_Actuaciones/Guia/GuiaNC_2018 _web.pdf • Spanish Ministry of Employment and Social Security, Strategic Plan for the Labour Inspectorate and Social Security: https://www.boe.es/boe/dias/2018/04/19/pdfs/BOE-A-2018-5329.pdf • FSC-NRA-ES V1-1 National Risk Assessment For Spain: https://fsc.org/en/document-centre/documents/resource/168
Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Comment or
Mitigation Measure
Supply Base Report: BSL Woodfiber SA Page 77 Indicator
The Biomass Producer has implemented appropriate control systems and procedures for 2.7.4 verifying that feedstock is not supplied using labour which is discriminated against in respect of employment and occupation. Labour rights are adequately protected in Spain, including those specified in the ILO’s fundamental principles. Spain has ratified the ILO’s eight Fundamental Conventions.
Spain is referred to in a positive manner in international reports: • Corruption Perception Index score of 58 (2018). It is clearly above 50, which means that the population has trust in governmental documents and control. • The World Governance Indicators (WGIs) of the World Bank, with 2018 values of between 55.24 and 82.76 (1 – 100 points). The World Bank’s WGI report has been prepared in 200 countries since 1996 and covers the following governance indicators: i) Voice and Accountability, ii) Political Stability and Absence of Violence / Terrorism, iii) Government Effectiveness, iv) Regulatory Quality, v) Rule of Law, and vi) Control of Corruption.)
According to information from Eurostat, Spain has a gender gap of 14.9% (the average gender salary gap in the EU is 16.3%). The gap continues to diminish since 2002, when it was 19%. In turn, the forestry and logging sector is the most masculinized, since just 6% of the people working in it are women.
The gender pay gap is not an indicator of the total inequality between men and women, as it Finding only refers to wages for individuals. The gender pay gap should be considered together with other indicators related to the labour market, in particular those that reflect women's different types of work. In countries where the employment rate for women is low (e.g. Italy), the pay gap is below average. This may reflect the small proportion of women with little or no skills in the workforce. A large difference is usually related to a labour market that is highly segregated, meaning that women are more concentrated in a restricted number of sectors and/or professions (e.g. Czech Republic, Estonia and Finland), or where a significant proportion of women work part-time (e.g. Germany and Austria). Finally, institutional mechanisms and wage-setting systems can influence pay gap. Spain's unadjusted gender pay gap in 2012 was 17.8%.
There are several collective bargaining agreement for forestry sector for each province. See Evendences Reviewed.
The risk relating to the indicator is classified as low, in line with FSC-NRA-ES V1-1 (Indicator 2.2).
• Existing legal framework and level of governance • Contracts of employment Means of • The existence of a collective-bargaining agreement • Company policies Verification • Interviews with Heads of Human Resources • Interviews with workers
Supply Base Report: BSL Woodfiber SA Page 78 • ILO Spain: http://www.ilo.org/madrid/oitaenaespaña/langaaes/index.htm • ITUC Global Rights Index: https://survey.ituc-csi.org/spain.html#tabs-3 • Spanish Constitution: https://www.boe.es/eli/es/c/1978/12/27/(1) • Workers’ Statute: https://www.boe.es/eli/es/rdlg/2015/10/23/2 • Ministry of labour, migration & social security: http://www.mitramiss.gob.es/en/index.htm • Legislation related to Employment and Social Security: o https://www.boe.es/legislacion/codigos/codigo.php?id=93&modo=1¬a=0 &tab=2 o http://www.congreso.es/consti/constitucion/indice/sinopsis/sinopsis.jsp?art= 37&tipo=2 • Spanish Ministry of Employment and Social Security, 2018 Guide to Collective Bargaining: http://www.empleo.gob.es/es/sec_trabajo/ccncc/B_Actuaciones/Guia/GuiaNC_2018 _web.pdf • Spanish Ministry of Employment and Social Security, Strategic Plan for the Labour Inspectorate and Social Security: https://www.boe.es/boe/dias/2018/04/19/pdfs/BOE-A-2018-5329.pdf Evidence • FSC-NRA-ES V1-1 National Risk Assessment For Spain: Reviewed https://fsc.org/en/document-centre/documents/resource/168 • Gender equality policies in Spain: http://www.europarl.europa.eu/RegData/etudes/STUD/2016/583112/IPOL_STU(20 16)583112_EN.pdf • Collective bargaining agreement for forestry sector: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2019-10265 o General - Spain https://www.boe.es/diario_boe/txt.php?id=BOE-A-2019- 10265 o Andalucía http://www.juntadeandalucia.es/empleo/mapaNegociacionColectiva /buscadorConvenios!visualizarVistaBuscadorConvenios.action?pulsado=1 o Galicia http://maderasdegalicia.com/normativa/laboral/ o Principado de Asturias https://sede.asturias.es/portal/site/Asturias/menuitem.1003733838d b7342ebc4e191100000f7/?vgnextoid=d7d79d16b61ee010VgnVCM100000 0100007fRCRD&fecha=30/10/2019&refArticulo=2019- 10888&i18n.http.lang=es o Castilla y León http://bocyl.jcyl.es/boletines/2016/10/27/pdf/BOCYL-D- 27102016-10.pdf Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Comment or
Mitigation Measure
Indicator
The Biomass Producer has implemented appropriate control systems and procedures for 2.7.5 verifying that feedstock is supplied using labour where the pay and employment conditions are fair and meet, or exceed, minimum requirements. Labour rights are adequately protected in Spain, including those specified in the ILO’s Finding fundamental principles. Spain has ratified the ILO’s eight Fundamental Conventions.
Supply Base Report: BSL Woodfiber SA Page 79 In Spain, the government holds consultations with the most representative trade union organisations and business associations before setting the Minimum Wage (Salario Mínimo Interprofesional) for permanent, casual, and temporary workers alike, as well as for domestic employees, taking account of the Consumer Price Index, the average national productivity achieved, the increase in the share of work in national income, and the general economic situation. The value set for 2020 rises to 950 euros/month.
Also, in 2019 it was approved the first collective bargaining agreement for forestry sector. There are also several collective bargaining agreement for forestry sector for each province. See “Evidence Reviewed”.
In the same way if taxes are not paid by its suppliers, Tax Authorities notifies to its clients as a counteragent of the debtor, as does Social Security. These are the two most powerful agencies in the state about these issues.
If the debt is not paid, the state automatically interrupts the activity of that company, leading to prison sentences as well as high fines.
There are some concerns over civil rights in Spain, as reflected in reports by international organisations like Amnesty International (see the 2017 report on Spain), but none of the concerns is directly related to the forestry sector. The risk relating to the indicator is low.
• Existing legal framework and level of governance • Contracts with suppliers Means of • Records of field inspections and monitoring Verification • Interviews with workers • Forms TC1 and TC2
Collective bargaining agreement for forestry sector: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2019-10265 • General - Spain https://www.boe.es/diario_boe/txt.php?id=BOE-A-2019-10265 • Andalucía http://www.juntadeandalucia.es/empleo/mapaNegociacionColectiva/busca dorConvenios!visualizarVistaBuscadorConvenios.action?pulsado=1 Evidence • Galicia http://maderasdegalicia.com/normativa/laboral/ Reviewed • Principado de Asturias https://sede.asturias.es/portal/site/Asturias/menuitem.1003733838db7342 ebc4e191100000f7/?vgnextoid=d7d79d16b61ee010VgnVCM1000000100007fRC RD&fecha=30/10/2019&refArticulo=2019-10888&i18n.http.lang=es • Castilla y León http://bocyl.jcyl.es/boletines/2016/10/27/pdf/BOCYL-D-27102016- 10.pdf
Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Comment or Mitigation Measure
Supply Base Report: BSL Woodfiber SA Page 80 Indicator
The Biomass Producer has implemented appropriate control systems and procedures for 2.8.1 verifying that appropriate safeguards are put in place to protect the health and safety of forest workers (CPET S12). The following laws regulate the issue of security and health in the forest sector:
Law on Prevention of Occupational Risks and Regulation of Prevention Services
As for any labour activity, Law 31/1995 of November 8, modified by Law 54/2003, is applicable, which legally regulates the basic framework for the protection of the safety and health of workers against the risks arising from work. On the other hand, it is also necessary to indicate the application to forestry work of the Regulation of Prevention Services (Royal Decree 39/1997, of January 17), and the modifications introduced to it by Royal Decree 780/1998, of 30 April, and by Royal Decree 604/2006, of May 19.
Regulations for the development of the Law on the Prevention of Occupational Risks
The regulations that emanate from the aforementioned Law 31/1995 and from Law 54/2003 that modify it, developed by various regulatory standards, in accordance with article 6 of said law, are applicable to forestry operations, although one must highlight a very important exclusion such as Royal Decree 486/1997, of 14 April, which establishes the minimum health and safety provisions in workplaces, since the fields of cultivation, forests and other lands that are part of a company or centre of agricultural or forestry work, but that are located outside the built zone of the same. Finding R.D. 1215/1997, of 18 July, on minimum safety and health provisions for the use by workers of work equipment, in terms of the use by workers of equipment such as tractors, processors, etc. Royal Decree 773/1997, of May 30, on minimum health and safety regulations regarding the use by workers of personal protective equipment.
All companies (BSL Woodfiber also) have the obligation to have a contracted with a mutual insurance company which is entrusted to: • Annual medical review of all workers • Annual training for all workers on occupational health and safety, specific training for each workplace • In case of accident, evaluation of the same and corrective measures to avoid a repetition Issue a certificate to be aware of compliance with all legislation related to occupational health and safety.
The concept of occupational accidents refers to the production of work accidents and occupational diseases linked to the exercise of a professional activity. The forestry sector is, after the construction sector, the one with the highest rate of occupational accidents and occupational diseases.
A more detailed analysis of the main sources of accidents in forestry work reveals that the forestry exploitation phase and, more specifically, the felling, felling and cutting with
Supply Base Report: BSL Woodfiber SA Page 81 chainsaws are the forestry activities with the highest accident rate. The use of the chainsaw, which is a widespread tool in rural areas, causes 18% of accidents.
According to International Labour Organization, there have been an increase in fatal and non-fatal injuries related to agriculture, forestry and fishing sector in Spain.
Regardless of its legal requirements, Spain still performs poorly on work safety. Outsourcing and self-employed services are quite common in forest sector.
In the other hand, for work on public forests, the public administration appoints a Health and Safety Coordinator who ensures that all documentation is in order and that field work is carried out in compliance with legal requirements.
Given that, the risk relating to this indicator is classified as: • Low in respect of work done in public forests, and • Specified risk for private forest
• Record of internal and external training carried out for forest workers and sources taken on the risk and safety Means of • Record of delivery of PPE to all workers • Records of field inspections Verification • Workplace assessment results carried out by mutual insurance • Interviews with staff
• Law 31/1995 on Preventing Occupational Risks and Regulation of Prevention Services: https://www.boe.es/buscar/doc.php?id=BOE-A-1995-24292 • Law 54/2003, of December 12, on the reform of the regulatory framework for the prevention of occupational hazards: https://www.boe.es/buscar/doc.php?id=BOE-A-2003-22861 • Royal Decree 39/1997, of January 17, which approves the Regulation of Evidence Prevention Services: https://www.boe.es/buscar/doc.php?id=BOE-A-1997-1853 Reviewed • Ministry of Employment, Migration and Social Security, Statistics of work accidents: http://www.mitramiss.gob.es/estadisticas/eat/welcome.htm • Occupational accidents in the sector: http://forestales.ibv.org/index.php?option=com_content&view=article&id=10&Ite mid=137 • Prevention of risks in forestry activities: https://www.insst.es/trabajos-forestales
☐ Low Risk T Specified Risk ☐ Unspecified Risk at Risk Rating RA BSL has a control system and adequate procedures on the health and safety of forest workers.
BSL demands the same from its feedstock suppliers and checks the health safety of Comment or harvesting personnel during its monitoring (administrative and field) inspections. Mitigation • Supplier qualification process and inspections of the supplier’s administration: Measure o Insurances and aptitude forms; o Social Security; o Present workforce and training (new) personnel; o Health and safety procedures; o Training records and hiring of specialists; o Records of Personal Protection Equipment (PPE) distribution; o Records of machinery safety tools and equipment on documental register;
Supply Base Report: BSL Woodfiber SA Page 82 o Medical record for employment. • Field inspection supplier: o Protective equipment use; o Medical kit; o Fire extinguisher; o Respect of safety distances; o Level of knowledge of personnel.
Indicator
Biomass is not sourced from areas that had high carbon stocks in January 2008 and no 2.9.1 longer have those high carbon stocks. Spain accounts activities of land use, land use change and forestry. The Spanish Inventory System is established in Law 34/2007 on air quality and protection of the atmosphere and its operation is developed in Royal Decree 818/2018, which assigns the General Directorate of Biodiversity and Environmental Quality of the Ministry for Transition Ecological the role of competent authority of the Spanish System of Inventory and Projections of Emissions to the Atmosphere (SEI).
The carbon stored in terrestrial ecosystems is distributed in three compartments: biomass of living plants (stem, branches, foliage and roots), plant detritus (branches and cones, forest litter, tree stumps, toppings and logs) and soil (organic mineral humus, surface and deep mineral soil).
However, carbon stock are not homogeneous throughout the country. Mediterranean forests are drier the North and store less carbon. Mean concentration of carbon is 8,7 kg/m2, ranging from 2,3 kg/m2 in dry Mediterranean areas to 20,4 kg/m2 in wetter northern Finding locations with mountainous areas and high precipitation rates.
Forests occupy almost 29 percent of the country’s total land area and they are increasing by about 86.000 ha per year, both through natural expansion and through the forest plantation program that has been under way for more than 50 years, with soil protection and erosion prevention as its main aims. This affected carbon stock in a very positive way as well, though this trend is stabilizing now.
Carbon sequestration according to last available data is higher in 2016 than in 2008. According to global forestry watch, in Spain, the land-use changed, and forestry sector is a net sink of CO₂, sequestering an average of 43.5 tCO₂e/yr from 1990 to 2014. This represents an offset of 14% of Spain's total greenhouse gas emissions over the same period.
Considering all mentioned above, the risk is considered low.
Means of • Existing legal framework • Information available: maps, web sites, statistics Verification • Results of analysis of carbon storage
Supply Base Report: BSL Woodfiber SA Page 83 • Interviews with experts
• Global forestry watch: https://www.globalforestwatch.org/dashboards/country/ESP?category=climate • Spanish system of emissions inventory: https://www.miteco.gob.es/es/calidad-y- Evidence evaluacion-ambiental/temas/sistema-espanol-de-inventario-sei-/Inventario- Reviewed GEI.aspx • Ministry of ecological transition: https://www.miteco.gob.es/es/cambio- climatico/temas/mecanismos-de-flexibilidad-ysumideros/sumideros-de-carbono/
Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Comment or Mitigation Measure
Indicator
Analysis demonstrates that feedstock harvesting does not diminish the capability of the 2.9.2 forest to act as an effective sink or store of carbon over the long term. The measures aimed at the reduction of emissions in the framework of forest lands can be classified into the following categories: • Promoting sustainable forest management • Restoration of a vegetation cover and expansion of woody surface
These measures are established at the national level and are monitored and controlled by the competent authorities.
Study “Soil carbon stocks and their variability across the forests, shrublands and grasslands of peninsular Spain” has found that, however, there is no statistically significant differences between forestlands and grasslands. The lowest carbon levels are associated with agricultural soils. Certain changes in agricultural practises (conservation tillage) or converting some unproductive croplands into grasslands or forestlands can increase carbon Finding sequestration in soils.
In forests, silviculture practices also affect the level of carbon stock. For example Río et al. (2008a), using a growth model to compare different thinning regimes (simulations), found that in the case of Mediterranean maritime pine (Pine pinaster) in central Spain (rotation period of 80 years), the best carbon sequestration strategy was to adopt an early (20 years), heavy thinning regime. Garcia-Gonzalo et al. (2007), using a modelling approach, found that an increase in the thinning intensity also led to an increase in the total carbon stock, the pattern being similar for the different species considered. Thinning from below presented the highest carbon sequestration rate, while mixed thinning and thinning from above resulted in lower carbon storage rates than in no-thinned stands. Hence, thinning regimes and product lifespan should be taken into account in order to determine the most suitable forest management for carbon sequestration.
Supply Base Report: BSL Woodfiber SA Page 84 Considering all mentioned above, the risk is considered low.
• Existing legal framework Means of • Information available: maps, web sites, statistics • Results of analysis of carbon storage Verification • Interviews with experts.
• Forest management and carbon sequestration in the Mediterranean region: http://revistas.inia.es/index.php/fs/article/view/11205/3639 • Information on actions in the sector of land use, land use change and forestry in Evidence Spain: https://www.miteco.gob.es/images/es/acciones_lulucf_espana_def_tcm30- Reviewed 178767.pdf • Study “Soil carbon stocks and their variability across the forests, shrublands and grasslands of peninsular Spain”: https://core.ac.uk/download/pdf/132083936.pdf
Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Comment or Mitigation Measure
Indicator
2.10.1 Genetically modified trees are not used.
There is no legal prohibition on using genetically modified material, but there is a legal framework that regulates its use, for which it is necessary to obtain a government licence. There is the Comisión Nacional de Bioseguridad (National Commission on Biodiversity, Spain), which, “pursuant to the provisions of the second additional provision of Law 9 / 2003, is a collegiate body that is consultative in nature and of which the function is to inform on authorisation requests presented to the State General Administration and to the Autonomous Communities in respect of genetically modified organisms (contained use, voluntary release, and marketing). It comes under the Spanish Ministry of Agriculture, Fisheries, Food, and the Environment, and it is made up of representatives of the various Ministries involved, representatives of the Autonomous Communities, as well as subject matter expert persons and institutions.” Finding
There is also a Public Register of Genetically Modified Organisms that “is set up pursuant to Royal Decree 178 / 2004 of 30 January, which approves the General Regulation for the Implementation and Execution of Law 9 / 2003, in its first additional provision, pursuant to the third additional provision of the said law. It is enriched by such data as are available, by reason of their competence, to the Spanish Inter-ministerial Council on Genetically Modified Organisms, the National Commission on Biosecurity, the ministerial departments that are competent in the matter, and the competent bodies of the Autonomous Communities, as well as data arising from handling communications and authorisation requests for the contained use, voluntary release, and marketing of genetically modified organisms.”
Supply Base Report: BSL Woodfiber SA Page 85 There are no records and there is no evidence of use of genetically modified organisms in the forestry sector.
Based on the foregoing, the risk relating to this indicator is classified as low.
• EU Register of authorised GMOs: Means of http://ec.europa.eu/food/dyna/gm_register/index_en.cfm Verification • List of species explored by BSL
• Law 9/2003, of April 25, which establishes the legal regime of confined use, voluntary release and commercialization of genetically modified organisms: https://www.boe.es/buscar/doc.php?id=BOE-A-2003-8588 Evidence • List of species that could be approved for GMO use: Reviewed https://www.miteco.gob.es/es/calidad-y-evaluacion- ambiental/temas/biotecnologia/organismos-modificados-geneticamente-omg-/registro- publico-OMG/
Risk Rating T Low Risk ☐ Specified Risk ☐ Unspecified Risk at RA
Comment or Mitigation Measure
Supply Base Report: BSL Woodfiber SA Page 86