CLIMATE MITIGATION – REHABILITATION AND REFORESTATION

2. Climate benefit analysis 2.1. For areas that comply with the requirements at forest sourcing area level to ensure that carbon stocks and sinks levels in the forest are maintained or strengthened over the long term in accordance with Article 29(7), point (b), of Directive (EU) 2018/2001 the activity complies with the following criteria: (a) the climate benefit analysis demonstrates that the net balance of GHG emissions and removals generated by the activity over a period of 30 years after the beginning of the activity is lower than a baseline, corresponding to the balance of GHG emissions and removals over a period of 30 years starting at the beginning of the activity, associated to the business-as-usual practices that would have occurred on the involved area in the absence of the activity;

Performance Measure 9.1 Certified Organizations shall individually and/or through cooperative efforts involving SFI Implementation Committees or other partners identify and address the climate change risks to forests and forest operations and develop appropriate adaptation objectives and strategies. Strategies are based on best scientific information.

Performance Measure 9.2 Certified Organizations shall individually and/or through cooperative efforts involving SFI Implementation Committees or other partners identify and address opportunities to mitigate the effects associated with its forest operations on climate change.

2. Climate benefit analysis (b) long-term climate benefits are considered demonstrated by proof of alignment with Article 29(7), point (b), of Directive (EU) 2018/2001.

Performance Measure 9.1 Certified Organizations shall individually and/or through cooperative efforts involving SFI Implementation Committees or other partners identify and address the climate change risks to forests and forest operations and develop appropriate adaptation objectives and strategies. Strategies are based on best scientific information.

Performance Measure 9.2 Certified Organizations shall individually and/or through cooperative efforts involving SFI Implementation Committees or other partners identify and address opportunities to mitigate the effects associated with its forest operations on climate change.

2. Climate benefit analysis 2.2. For areas that do not comply with the requirements at forest sourcing area level to ensure that carbon stocks and sinks levels in the forest are maintained or strengthened over the long term in accordance with Article 29(7), point (b), of Directive (EU) 2018/2001 the activity complies with the following criteria: (a) the climate benefit analysis demonstrates that the net balance of GHG emissions and removals generated by the activity over a period of 30 years after the beginning of the activity is lower than a baseline, corresponding to the balance of GHG emissions and removals over a period of 30 years starting at the beginning of the activity, associated to the business-as-usual practices that would have occurred on the involved area in the absence of the activity.

Performance Measure 9.1 Certified Organizations shall individually and/or through cooperative efforts involving SFI Implementation Committees or other partners identify and address the climate change risks to forests and forest operations and develop appropriate adaptation objectives and strategies. Strategies are based on best scientific information.

Performance Measure 9.2 Certified Organizations shall individually and/or through cooperative efforts involving SFI Implementation Committees or other partners identify and address opportunities to mitigate the effects associated with its forest operations on climate change.

2. Climate benefit analysis (b) the projected long-term average net GHG balance of the activity is lower than the long-term average GHG balance projected for the baseline, referred to in point 2.2, where long term corresponds to the longer duration between 100 years and the duration of an entire forest cycle.

Performance Measure 9.1 Certified Organizations shall individually and/or through cooperative efforts involving SFI Implementation Committees or other partners identify and address the climate change risks to forests and forest operations and develop appropriate adaptation objectives and strategies. Strategies are based on best scientific information.

Performance Measure 9.2 Certified Organizations shall individually and/or through cooperative efforts involving SFI Implementation Committees or other partners identify and address opportunities to mitigate the effects associated with its forest operations on climate change.

2. Climate benefit analysis 2.3. The calculation of climate benefit complies with all of the following criteria: (a) the analysis is consistent with the 2019 Refinement to the 2006 IPCC Guidelines for National Greenhouse Gas Inventories (35). The climate benefit analysis is based on transparent, accurate, consistent, complete and comparable information, covers all carbon pools impacted by the activity, including above-ground biomass, below-ground biomass, deadwood, litter and soil, relies on the most conservative assumptions for calculations and includes appropriate considerations about the risks of non-permanence and reversals of carbon seques­ tration, the risk of saturation and the risk of leakage.

Performance Measure 9.1 Certified Organizations shall individually and/or through cooperative efforts involving SFI Implementation Committees or other partners identify and address the climate change risks to forests and forest operations and develop appropriate adaptation objectives and strategies. Strategies are based on best scientific information.

Performance Measure 9.2 Certified Organizations shall individually and/or through cooperative efforts involving SFI Implementation Committees or other partners identify and address opportunities to mitigate the effects associated with its forest operations on climate change.

2. Climate benefit analysis (b) the business-as-usual practices, including harvesting practices, are one of the following: (i) the management practices as documented in the latest version of the forest management plan or equivalent instrument before the start of the activity, if any; (ii) the most recent business-as-usual practices prior to the start of the activity;

Performance Measure 9.1 Certified Organizations shall individually and/or through cooperative efforts involving SFI Implementation Committees or other partners identify and address the climate change risks to forests and forest operations and develop appropriate adaptation objectives and strategies. Strategies are based on best scientific information.

Performance Measure 9.2 Certified Organizations shall individually and/or through cooperative efforts involving SFI Implementation Committees or other partners identify and address opportunities to mitigate the effects associated with its forest operations on climate change.

2. Climate benefit analysis (c) the resolution of the analysis is proportionate to the size of the area concerned and values specific to the area concerned are used.

Performance Measure 9.1 Certified Organizations shall individually and/or through cooperative efforts involving SFI Implementation Committees or other partners identify and address the climate change risks to forests and forest operations and develop appropriate adaptation objectives and strategies. Strategies are based on best scientific information.

Performance Measure 9.2 Certified Organizations shall individually and/or through cooperative efforts involving SFI Implementation Committees or other partners identify and address opportunities to mitigate the effects associated with its forest operations on climate change.

2. Climate benefit analysis (d) emissions and removals that occur due to natural disturbances, such as pests and diseases infestations, forest fires, wind, storm damages, that impact the area and cause underperformance do not result in non- compliance with Regulation (EU) 2020/852, provided that the climate benefit analysis is consistent with the 2019 Refinement to the 2006 IPCC Guidelines for National Greenhouse Gas Inventories regarding emissions and removals due to natural disturbances.

Performance Measure 9.1 Certified Organizations shall individually and/or through cooperative efforts involving SFI Implementation Committees or other partners identify and address the climate change risks to forests and forest operations and develop appropriate adaptation objectives and strategies. Strategies are based on best scientific information.

Performance Measure 9.2 Certified Organizations shall individually and/or through cooperative efforts involving SFI Implementation Committees or other partners identify and address opportunities to mitigate the effects associated with its forest operations on climate change.

2. Climate benefit analysis 2.4. Forest holdings under 13ha are not required to perform a climate benefit analysis.

SFI FM Standard does not cover a forest area of this size.

3.     Guarantee of permanence 3.1. In accordance with national law, the forest status of the area in which the activity takes place is guaranteed by one of the following measures: (a) the area is classified in the permanent forest estate as defined by the FAO (36); (b) the area is classified as a protected area; (c) the area is the subject of any legal or contractual guarantee ensuring that it will remain a forest.

Performance Measure 1.3. Certified Organizations shall not have within the scope of their certification to this SFI Standard, forest lands that have been converted to non-forest land use.

3.     Guarantee of permanence 3.2. In accordance with national law, the operator of the activity commits that future updates to the forest management plan or equivalent instrument, beyond the activity that is financed, will continue to seek the climate benefits as determined in point 2. Besides, the operator of the activity commits to compensate any reduction in the climate benefit determined in point 2 with an equivalent climate benefit resulting from the conduct of an activity that corresponds to one of the forestry activities defined in this Regulation.

The SFI 2022 Forest Management Standard does require long-term sustainable management of forests, but it cannot account for future disposition of forest lands to a new owner. They can be no way to guarantee ongoing financing of the climate benefits after a change in ownership.

5. Group Assessment The compliance with the criteria for substantial contribution to climate change mitigation and with DNSH criteria may be checked: (a) at the level of the forest sourcing area (37) as defined in Article 2, point (30), of Directive (EU) 2018/2001;

SFI has three standards that address forest sustainability and therefore address climate change mitigation.

-SFI 2022 Forest Management Standard -SFI Small Lands Group Certification Module -SFI Small Scale Forest Management Module for Indigenous Peoples and Families

5. Group Assessment (b) at the level of a group of holdings sufficiently homogeneous to evaluate the risk of the sustainability of the forest activity, provided that all those holdings have a durable relationship between them and participate in the activity and the group of those holdings remains the same for all subsequent audits.

Addressed by SFI Section 10, Appendix 2 - Group Certification Organizations

DNSH 2 - Climate Change Adaptation The activity complies with the criteria set out in Appendix A to this Annex.

Performance Measure 9.2 Certified Organizations shall individually and/or through cooperative efforts involving SFI Implementation Committees or other partners identify and address opportunities to mitigate the effects associated with its forest operations on climate change.

DNSH 5 - Pollution prevention and control The use of pesticides is reduced and alternative approaches or techniques, which may include non-chemical alternatives to pesticides, are favored, in accordance with Directive 2009/128/EC, with exception of occasions where the use of pesticides is needed to control outbreaks of pests and of diseases.

Performance Measure 2.2. Certified Organizations shall have a program to minimize chemical use required to achieve management objectives while protecting employees, neighbors, the public and the environment, including wildlife and aquatic habitats.

DNSH 5 - Pollution prevention and control. The activity minimizes the use of fertilizers and does not use manure. The activity complies with Regulation (EU) 2019/1009 or national rules on fertilizers or soil improvers for agricultural use.

Performance Measure 2.2. Certified Organizations shall have a program to minimize chemical use required to achieve management objectives while protecting employees, neighbors, the public and the environment, including wildlife and aquatic habitats.

DNSH 5 - Pollution prevention and control Well documented and verifiable measures are taken to avoid the use of active ingredients that are listed in the Annex I, part A, of Regulation (EU) 2019/1021 (38), the Rotterdam Convention on the prior informed consent procedure for certain hazardous chemicals and pesticides in international trade, the Minamata Convention on Mercury, the Montreal Protocol on Substances that Deplete the Ozone Layer, and of active ingredients that are listed as classification Ia (‘extremely hazardous’) or Ib (‘highly hazardous’) in the WHO Recommended Classification of Pesticides by Hazard. The activity complies with the relevant national law on active ingredients.

Performance Measure 2.2. Certified Organizations shall have a program to minimize chemical use required to achieve management objectives while protecting employees, neighbors, the public and the environment, including wildlife and aquatic habitats.

Indicator 5. The World Health Organization (WHO) type 1A and 1B pesticides shall be prohibited, except where no other viable alternative is available.

DNSH 5 - Pollution prevention and control. Pollution of water and soil is prevented and cleaning up measures are undertaken when pollution occurs.

Performance Measure 2.2. Certified Organizations shall have a program to minimize chemical use required to achieve management objectives while protecting employees, neighbors, the public and the environment, including wildlife and aquatic habitats.

Indicator 8: Use of management practices appropriate to the situation, such as: i. use of spill response plans and chemical spill kits

Performance Measure 3.1. Certified Organizations shall meet or exceed all applicable federal, provincial, state and local water quality laws and meet or exceed best management practices.

Performance Measure 3.2. Certified Organizations shall implement water, wetland, and riparian protection programs based on climate, soil type, terrain, vegetation, ecological function, harvesting system, state best management practices (BMPs), provincial guidelines and other applicable factors.

Performance Measure 11.1 Certified Organizations shall comply with applicable federal, provincial, state, and local forestry and environmental laws and regulations.