Regional risk assessment for BC endorsed by Sustainable Biomass Program

Following a three-year rigorous assessment including stakeholder consultations, the Regional Risk Assessment for fibre sourcing in British Columbia is completed – providing the global marketplace with the added assurance that one of the world’s largest wood pellet producing regions also has the mechanisms in place to verify the legality and sustainability of uncertified feedstock in the province.

The Wood Pellet Association of Canada (WPAC) initiated the RRA in 2018. Hopkin Forest Management Consulting Ltd. and a team of independent natural resource and certification professionals formed the Working Body responsible for developing the RRA. The RRA was developed in accordance with the Sustainable Biomass Program (SBP) – RRA Procedure.

SBP-endorsed RRAs are a key part of SBP’s focus on identifying and mitigating risks associated with sustainably sourcing feedstock for biomass pellet and woodchip production. RRAs evaluate an entire geographic region and determine the risks associated with sourcing feedstock from that region. This guarantees consistency between biomass producers’ risk assessments and eliminates the need for the Producers to conduct individual risk assessments. RRAs have been completed for a number of European countries, the province of Quebec, and RRAs are also underway for New Brunswick and Nova Scotia. The B.C. and Maritime RRAs received financial support from the Canadian Forest Service, Government of Canada, Export Market Opportunities program.

SBP was established in 2013 to provide assurance that woody biomass – mainly wood pellets and wood chips used for large-scale energy production – is sourced from legal and sustainable sources. While the vast majority of Canadian fibre comes from certified forests, any uncertified fibre must be evaluated against SBP criteria, and the wood pellet manufacturer must carry out a risk assessment to identify the risk of compliance against 38 SBP indicators covering 16 criteria for legality and sustainability.

“If you look at a forest management system like PEFC and FSC, the forest manager has direct control over what happens on the ground but biomass producers don’t have that level of control; so through the RRA we are able to identify, manage and communicate to ensure our expectations are understood and verified,” says Brenda Hopkin, a registered professional forester with over 25 year’s forestry and auditing experience, and who led the assessment.

Guiding much of the team’s work was a philosophy that Hopkin has coined a three-step process the Risk Evaluation Framework (REF). She says it starts with confirming that there is a regulatory framework and oversight to manage the risk; that there are implementation mechanisms to ensure compliance; and finally there is a means to verify results on the ground through publicly available and current information.

The independent Working Body facilitated the risk assessment to ensure that relevant B.C. laws, policies and practices, as well as practical knowledge of forestry in B.C., were accurately captured in the RRA. Important information included interviews with experts and the experience and knowledge of consultants, applicable legislation, reports from provincial authorities and other stakeholders, various databases and statistical data sources. Many stakeholders were consulted in the process and information was obtained verbally and from written public and private sources.

“The whole purpose of a due diligence system is to be able to identify the risk based on the available data; and if that data isn’t there it’s a specified risk and the RRA helps you identify that risk,” adds Hopkin who had the challenging task of reviewing all of the available monitoring mechanisms and data available. “Many of these risks are the same ones that global customers are concerned about so the RRA helps you demonstrate your management of issues that are important to your customers and stakeholders.”

The scope of the RRA for B.C. was the uncertified harvestable forest landbase in B.C. Addressing fibre from uncertified forests will become increasingly important in the context of B.C.’s forests, as the government moves to increase tenure management away from major forest companies to local community groups and First Nations which may not have the resources to undertake third party certification but want to more actively participate in the sector and sell fibre to pellet producers. For the RRA for B.C. there are three types of sub scopes based on ownership type:

• Uncertified Crown/Public land;
• Uncertified Private Managed Forest Land; and
• Other uncertified private land.

“I believe the RRA is a great tool to address increased diversity of management in B.C.’s forests,” says Hopkin. “The framework allows for that flexibility of tenure change and supports conversations with pellet producers’ suppliers so expectations are understood and managed.”

Some of the specified risks with feedstock from uncertified lands (Crown or Private) include:

• uncertified private lands that may come from forests converted to non-forest lands;
• high conservation forest or areas on any uncertified private land where the data does not support that soil integrity, water quality or key ecosystems and habitats are adequately preserved; and
• indicators of biodiversity including intact forest landscapes and old growth.

Hopkin believes that one of the key learnings for her team and the participants in the process, including pellet producers from 14 plants across B.C., was the importance of understanding the supply base – where is the fibre is coming from and how is it being managed especially when it comes to specified risk.

“RRAs get you to focus on both the probability of the risk and the severity,” explains Hopkin. “Once you have that then you can put management practices in place that help you control the probability.”

The RRA was officially endorsed on August 11, 2021 and biomass producers in B.C. will have 12 months to demonstrate alignment with it. The RRA sets a critical path forward for WPAC members as they advance sustainability across the entire supply chain and support domestic and global customers to meet important climate change targets. You can read the SBP-endorsed Regional Risk Assessment here.