3.2.2. Damages inflicted on communities

of indigenous peoples, including damages to biological

resources to which they have rights, are compensated as prescribed

by law

Reference to legislation in this indicator is not enough and also inappropriate. A compensation for any damage, done to native population communities, should take place irrespective of national legislation's perfection. This mechanism should exist and be estimated as much as possible during certification process. Otherwise the whole criterion will not be executed.

3.3.1. Sites of special cultural, ecological, economic or religious significance are:a) Identified in cooperation with indigenous peoples and recognizedb) Mapped and marked on-sitec) Reserved for special use and/or protection

3.3.1.1. Forest inventory materials

3.3.1.2. List of identified sites

3.3.1.3. Discussion with indigenous peoples

3.3.1.4. Maps

3.3.1.5. Field inspection

3.3.1.6. Documents describing the regime of use or protection

3.3.1.7. Discussion with enterprise managers

At the present time information, got from regional administrative and scientific organizations, is used for valuation of places of cultural, ecological, economic and religious values. These organizations have the most complete information about it. But in the standard this approach is not mentioned. At the same time less factual sources are cited.

4.1.1. The company makes active efforts to employ workers from local communities

An additional explanation at the term «local population». There are some disagreements in attracting workers from neighbouring inhabited localities and from the whole region. Sometimes there are complaints from regional social organizations.

4.1.2. The enterprise, as a matter of policy, strives to provide professional

training for new staff from local communities

4.1.2.1. Training plans and programmes, documented qualifications.

4.1.2.2. Discussion with trade union representatives.

4.1.2.3. Discussion with employees

This indicator is formulated roughly, and its confirmation is inaccurate. A confirmation of staff qualification does not mean that there is a policy of training for new staff from local population and that this policy will be realized in future. 

4.1.3. The enterprise helps to maintain the social infrastructure of forest settlements and provides assistance to local residents

4.1.3.1. Discussion with administration

4.1.3.2. Discussion with local residents

4.1.3.3. Documents confirming assistance to local communities

It is an inaccurate formulating of the indicator. In order to make more or less objective estimation it is necessary to identify an approximate volume of the infrastructure support and what this volume is depend on.

4.2.3. The enterprise provides individual safety equipment in accordance with industrial safety and sanitary standards

It is an incorrect interpretation of indicator for Criterion 4.2 support.

Standards of safety measures concerning individual protection frames often do not meet the requirements of used technologies in harvesting places. Such interpretation will increase industrial injuries.

4.3.2. Labour relations are maintained

in accordance with the national Code of Labour Laws, tariff agreements for the forest industry of the Russian Federation,

collective labour (union) agreement, or individual labour contracts

Indicator 4.3.2 relates to Criterion 4.2 more than to criterion 4.3. At the same time none of the indicators reflects the workers' right to negotiate with their employers or some insurance arrangements, and also methods of possible estimations during certification process.

4.4.2. The enterprise consults with local residents and affected groups to evaluate the possible social consequences of forest management operations

Though Criterion 4.4 demands an estimation of forestry actions to social sphere, none of all indicators of this criterion shows it neither straight nor even indirectly. «Consultations with local population and single interested groups» and partial calculation of social questions in forest management plans can not substitute for a full value and a result of the estimation.  A realization of two indicators does not confirm a realization of the whole criterion. It allows an auditor to draw subjective conclusions about the realization of this part of standard by an enterprise.  In practice many auditors in Russia do not demand of compliance of the criterion.  

4.5.1. The enterprise respects the legal rights of local communities to employ traditional methods of using forest and other biological resources

Criterion 4.5 concerning damage and its compensation for local population and indicator 4.5.1 practically does not reflect a realization of this criterion. The local population right of resources is reflected in another criterion of this standard.

5.2.1. Forest management is oriented

toward multipurpose use of forest resources

In order to perform FSC criterion 5.2 it necessary to develop special indicators for Russia. At the present time majority certified Russian companies do not perform the criterion and auditors can not demand that.

5.3.1. The enterprise takes steps to implement advanced low-waste methods of wood harvesting and processing

Demand of criterion 5.3 should conform to requirements of indicators included. Forest legislation contains definite technologies of waste utilization and control for its realization. It is possible that a realization of legislation on enterprises is enough.

5.4.2. The enterprise practices different kinds of forest use and markets non-timber forest products and services (tourism, use of forest management units to enhance the feed resources of hunting grounds, etc.)

Indicator 5.4.2 is irrelevant. The majority of Russian enterprises carry out only harvesting. A requirement concerning a presence of «different kinds of forest management» will lead to a certification refusal or to a fictitious auditor estimation. Especially it concerns small enterprises. At the same time criterion 5.4 demands actions only from an enterprise and does not regulate so strict result.

6.1.2. The enterprise controls and evaluates the impact of silviculture

and harvesting on the environment

6.1.2.4. Technological map.

Technological maps of cutting areas development do not contain any information related with control or estimation of forestry and harvesting actions' influence upon environment and to suppose it to be an index of its realization is inappropriate.

6.2.3. The enterprise has protected

sites with restrictions on the use

Criterion 6.2 demands from an enterprise a creation of a system, providing protection of rare and disappearing species in present time and in future. None of 3 developed  indicators points out this requirement

6.3.3. Forest areas degraded by forest operations are identified and marked in maps (at the level of forest administration unit - leskhoz)

Adaptation of indicator 6.3.3 only for forestry (state enterprises) is not reasonably, because it reduces requirements to private entrepreneurs, which mostly  carry out FSC certification in Russia. During a certification of any forest enterprises should be revealed areas of forest degrade.

6.3.4. The enterprise contributes to the restoration of forest lands degraded by forest operations

Participation  in a reforestation of degrade areas is not a strict requirement  for Russian enterprises. In this case there should be at least requirements concerning a level of this participation.

6.4.1. Representative samples of forest ecosystems are being/have been identified

(For Russian version) Criterion 6.4 unambiguously requires of realization some works for  representational forest areas and take them over the control before assessment. Indicator 6.4.1, contained in this criterion, requires only of realization some works without mentions about any result. In this case an enterprise can conduct such works during 5-year period and display nothing. Such lowering of standard requirements is inadmissible.

(At the same time English version of the indicator has other sense).

6.5.2. Personnel is aware of the methods and measures to minimize

adverse impact on the forest and employs them in its work

Criterion 6.5 demands of development and implantation of guides concerning different aspects of forest activity and first of all for erosion control. None of indicators in this criterion mentions about it. In fact it is the most frequently occurring problem of forest recreation process practically in all Russian regions. 

6.6.3. Use of fertilizers in forestry

is allowed only in permanent seed production areas, plantations,

forest tree nurseries, and on reforesting bare lands and, in exceptional cases, where the necessity of using fertilizers for the regeneration of forest lands can be demonstrated

Indicator concerning fertilizer use (6.6.3) is inappropriate here. Criterion 6.6 is in general about control upon vermin quantity but not about improvement of forest soil fertility.

7.1.6. The forest management plan includes:a) fire prevention and protection measures; fire prevention management;

b) pest and disease control;c) provisions for machinery/equipment for fire detection and suppression

Requirements of indicator 7.1.6 lowers greatly requirements of Principle 7 to forest management planning of an enterprise. FSC criterion 7.1 describes requirements to a quality of a plan, which includes long-term, medium-term and short-term aspects. In formulating of Principle 7 this aspects are mentioned as fundamental. All nine indicators of Criterion 7.1 (7.1.1-7.1.9) concern the quality of Felling plan and Forest regulation plan, which are short-term and medium-term (5, 10 years).

7.2.1. The forest management plan is periodically revised to respond to changing environmental,

social and economic circumstances

as well as financial capabilities

Criterion 7.2 is represented by one indicator 7.2.1. Contents of this indicator formally repeats matter of foregoing criterion. Meanwhile there is an important peculiarity for plans' revision. Very often it is difficult to revise and make changes in the majority of plan's aspects without infringements of legislation in Russia. Often it makes results of Principle 8 realization useless and therefore there is a discrepancy to FSC Standard as a whole

7.4.2. There is a procedure for handling inquiries by the public about the forest management plan

Requirements of indicator 7.4.2 about a procedure of social inquiries' processing are not related neither with Principle 7 significantly nor with criterion 7.4. According to criterion 7.4 an enterprise must inform community about main elements of a plan. At the same time according to developed indicator 7.4.1 an enterprise should only have this information in available form. It lowerings criterion's requirements

8.1.1. Annual monitoring is conducted

to assess the condition of the forest resource, the scale and intensity of forest management, and its environmental impact, in keeping with established norms

8.1.1.3. Maps

8.1.1.4. Forest inventory materials

Requirements of indicator 8.1.1 are too tough in the part related with annual monitoring for main aspects of activity, because criterion 8.1 unambiguously supposes more rational approach - «Monitoring periodicity and character should depend on scale and intensity of forestry actions and also complication and vulnerability of the environment».

Forest inventory materials and map materials are documents of planning and its can not be evidences of annual monitoring realization in the enterprise.

Can not be "established norms" for monitoring programs.

8.2.1. Forest management includes data collection to monitor

the following indicators:* ratio of actual to estimated rates of harvest during final felling

and intermediate felling (thinning);

* ratio of selective and clear cutting

by area and its dynamics;* yield of different types of forest products, except timber, by species;

* dynamics of average growth rate (total, by economically accessible

forests, and by forestry units and sections);* rate of forest regeneration, by types and methods;* species, age, and quality structure

of stand;* areas of protected lands by categories;

* scale of biotechnical operations;* scale and type of forest protection

and conservation measures;* population dynamics of protected

species; * environmental and social impact of harvesting and other forestry operations;* total costs of forest management

-     Operations

A description of information indexes in indicator 8.2.1 for monitoring are not in compliance with a list of indexes of FSC standard in criterion 8.2.

8.3.2. All forest products certified

a)     for realization must be accompanied by the following information:a) type of product;b) quantity of product;c) harvesting/production site;d) date of harvesting/production;e) number of FSC certificate;f) information about customer;g) transfer point of control

Inappropriate notation of the indicator. «All realized certification production of an enterprise should be escorted with following information» - probably it is not about production, but about accompanying documents.

8.4.1. The annual management plan is revised to incorporate monitoring results.

Indicator 8.4.1 is inappropriate here, because it concerns Principle 7. According to criterion 8.4 it is necessary to use results of monitoring.

8.5.1. The enterprise makes available

to all interested parties a summary of the results of forest management monitoring according

to 8.2.1

(For Russian version). According to criterion 8.5 an enterprise should have a short  monitoring report, which are available to a community. But it is not necessary to send this report to all interested organizations (stakeholders) as it is mentioned in indicator 8.5.1. (At the same time English version of the indicator has other sense).

9.4.2. The enterprise promotes regular and independent monitoring

of the state of the HCVF by other interested parties

Indicator 9.4.2 is inappropriate because according to this indicator an enterprise shoud admit all interested organizations to commercial information.