Public Notification Letter FSC Chain of Custody Controlled Wood Stakeholder Consultation
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2000 Powell Street, Ste. 600
Emeryville, CA 94608 USA
+1.510.452.8000 main
+1.510.452.8001 fax
Public Notification Letter
FSC® Chain of Custody Controlled Wood Stakeholder Consultation
To: Interested Parties
From: SCS Global Services
Consultation period: 11 June 2018 – 23 July 2018
Re: Notification of intent to audit Georgia Biomass LLC against FSC Chain of Custody
Controlled Wood standard FSC-STD-40-005 V3-1
The Forest Stewardship Council® (FSC) requires that a certification body conducting an audit of a certified
organization or applicant must consult stakeholders whenever the audit includes intent to source and use
uncertified material in an FSC Chain of Custody (CoC) program according to the requirements in FSC-STD-
40-005 V3-1 “Requirements for Sourcing FSC Controlled Wood”. Therefore, SCS Global Services (SCS) is
seeking input from interested and directly affected stakeholders regarding the relevance, effectiveness,
and/or adequacy of Georgia Biomass LLC’s Due Diligence System (DDS).
An explanation of ‘FSC Controlled Wood’, as well as a copy of FSC-STD-40-005 V3-1, is available
here: https://ic.fsc.org/en/certification/types-of-certification/controlled-wood-02 ; a copy of this
standard is also available from SCS upon request.
Due Diligence Systems are required for certified organizations in order to avoid the sourcing and
use of material originating from unacceptable sources in their FSC CoC program.
Directly affected stakeholders include any person, group of persons, or entity that is, with high
probability, subject to the effects of the activities related to an organization’s controlled wood
sourcing program, including the activities of their suppliers and sub-suppliers, as well as those
who influence risk identified through the organization’s Due Diligence System.
This letter serves as SCS’ invitation to directly affected stakeholders to participate in our consultation
process. This letter also serves as SCS’ public notification for any interested stakeholders, who are also
invited to participate in the consultation process. Participation in this stakeholder consultation process
is voluntary; stakeholders are not required to submit comments.
Scope of audit and audit details:
The audit will assess the conformity of the organization’s controlled wood program – including Risk
Assessment(s) and DDS – according to the certification requirements as per FSC-STD-40-005 V3-1.
The company’s DDS Public Summary and Risk Assessment (excluding confidential information), as well as
any other information or documents deemed relevant for the purpose of this stakeholder consultation,
are included as appendices to this letter—see below. For a list of the information that is required to be
publically available for stakeholder consultation by SCS, see FSC-STD-40-005 V3-1, Section 6.
Version 1-0 (February 2017) | © SCS Global Services Page 1 of 2
Additional certificate holder information:
https://info.fsc.org/details.php?id=a0240000007TdH4AAK&type=certificate
Options for participation and provision of comments:
Please submit written comments and evidence (where appropriate) by mail, FAX or email to SCS:
SCS Global Services
Att’n: Caitlin Lelles, Chain of Custody Certification Services
2000 Powell Street, Suite 600
Emeryville, CA 94608
Fax: 510-452-6882
Email: CWStakeholder@SCSGlobalServices.com
A summary of the stakeholder consultation and comments received will be made publically available on
the FSC certificate database, as per FSC-STD-20-011 V4-0. Verbatim comments will only by published with
prior consent from the stakeholder and will not be associated with stakeholder names.
Note that, while SCS is required to evaluate all information and comments objectively, SCS certification
decisions are affected by stakeholder comments only insofar as the comments provide evidence of
conformity or nonconformity to the applicable requirements.
Within 30 days of making our certification decision, SCS will respond to all stakeholders who provided
comments to explain how their comments were taken into account.
More information about FSC and SCS can be found on our respective websites: www.fsc.org and
www.scsglobalservices.com.
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2000 Powell Street, Ste. 600
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Publically Available Information for FSC Controlled Wood Certificate
Holders
INSTRUCTIONS
FSC® requires that organizations track their controlled material and publish specific findings. This form
helps you meet the requirements in Section 6 of FSC-STD-40-005 V3-0 “Publically Available Information”.1
Organization Name Georgia Biomass LLC
FSC COC Certificate Number SCS-COC-005306
Barry J Parrish
Fiber Procurement and Sustainability Manager
Name of Authorized Representative Georgia Biomass LLC
(Contact information for person or 3390 Industrial Blvd.
position responsible for addressing Waycross, Georgia 31503
complaints) (912) 490-5335 (Office)
barry.parrish@gabiomass.com
All comments and complaints related to the producer from
stakeholders as related to the Due Diligence System shall
be submitted to the Authorized Representative listed
above.
Below is an excerpt from GBMLLC's Controlled Wood
Procedure for filing complaints Procedures detailing the complaint process:
Note: for further details on complaints
procedure, see section 7 in FSC-STD-40-
005 V3-0
7.1. GBLLC has developed and implemented a
documented procedure to handle comments and
complaints from stakeholders that are related to its DDS.
The Management Representative will receive, manage,
respond to and record all stakeholder input and
complaints.
7.2. The procedure shall include mechanisms (unless
1
This document is meant as guidance only, utilization of templates and guidance documents is no guarantee of
conformity with FSC requirements. It is your organization’s responsibility to conform to relevant FSC requirements.
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otherwise stated in the applicable NRA) for:
a) Acknowledging receipt of complaints;
b) Informing stakeholders of the complaint
procedure, and providing an initial response to
complainants within a time period of two (2) weeks;
c) Forwarding complaints related to risk designations
in the relevant FSC risk assessment to the responsible body
(for an NRA: as indicated in the NRA; for a CNRA: FSC);
When a complaint is forwarded to a responsible body,
Clauses 7.2. d) - k) do not apply.
d) Conducting a preliminary assessment to determine
whether evidence provided in a complaint is or is not
substantial, by assessing the evidence provided against the
risk of using material from unacceptable sources;
e) Dialogue with complainants that aims to solve
complaints assessed as substantial before further actions
are taken;
f) Forwarding substantial complaints to the
certification body and relevant FSC National Office for the
supply area within two (2) weeks of receipt of the
complaint. Information on the steps to be taken by the
organization in order to resolve the complaint, as well as
how a precautionary approach will be used, shall be
included with the complaint;
g) Employing a precautionary approach towards the
continued sourcing of the relevant material while a
complaint is pending. This includes a description of how
the precautionary approach is employed by the
organization when a complaint is active. A complaint is
pending if it has been considered to be substantial
(according to Clause 7.2 d), and no effective corrective
action (according to Clauses 7.2 h) - k) has been taken yet.
h) Implementing a process (e.g. field verification
and/or desk verification) to verify a complaint assessed as
substantial by the organization, within two (2) months of
its receipt;
i) Determining the corrective action to be taken by
suppliers and the means to enforce its implementation by a
supplier if a complaint has been assessed and verified as
substantial. If a corrective action cannot be determined
and/or enforced, the relevant material and/or suppliers
shall be excluded by the organization;
j) Verifying whether corrective action has been taken
by suppliers and whether it is effective;
k) Excluding the relevant material and suppliers from
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the organization’s supply chain if no corrective action is
taken;
l) Informing the complainant, the certification body,
and the relevant FSC National Office of the results of the
complaint and any actions taken towards its resolution, and
for maintaining copies of relevant correspondence; and
m) Recording and filing all complaints received and
actions taken.
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Risk Assessment Summary
In the case that there are multiple risk assessments, copy and paste this table below for each
assessment.
GBLLC's District of Origin is comprised of 128 counties: 5 in
Description of Supply Area Alabama, 38 in Florida and 85 in Georgia as described in
GBLCC-DOC-018 FSC Controlled Wood/PEFC Due Diligence
Risk Assessment.
The FSC CNRA and NRA database (Updated: 2017-05-18)
shows that there is no approved National Risk Assessment
(NRA) for the United States of America (USA). There is an
approved Centralized National Risk Assessment (CNRA) for
the USA (FSC-CNRA-USA V1-0 EN). The CNRA reports risk
designations and determinations for all five categories of
unacceptable wood products.
Reference to the applicable
Risk Assessment
Two of them, categories 1 (illegally harvested wood) and 5
(genetically modified trees), are considered low risk with the
exception of indicator 1.4
The company's own Risk Assessment (GBLLC-DOC-018 FSC
Controlled Wood/PEFC Due Diligence Risk Assessment) was
used to assess categories 2-4 at this time.
Submit applicable risk assessment (excluding confidential information) in a separate document
Risk Designations Summary
For any category not rated as “Low” please fill in control Sub-category
measures by risk assessment indicator
In order to select a checkbox, “double-click” on the box, and select default value as “checked”.
Unspecified (see below for
Overall Risk Designation for the Supply Area unspecified risk designations)
Low
1. Illegally harvested wood 1.1 Unspecified Low
Overall Risk Designation: Unspecified Low 1.2 Unspecified Low
Control Measures per indicator (if applicable) 1.3 Unspecified Low
1.4 Unspecified Low
2.1 Unspecified Low
2. Wood harvested in violation of traditional and human rights 2.2 Unspecified Low
Overall Risk Designation: Unspecified Low
2.3 Unspecified Low
Control Measures per indicator (if applicable)
2.4 Unspecified Low
2.5 Unspecified Low
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3. Wood harvested from forests in which high conservation 3.1 Unspecified Low
values are threatened by management activities
Overall Risk Designation: Unspecified Low
Control Measures per indicator (if applicable)
The district of origin may be considered LOW RISK in relation 3.2 Unspecified Low
to threat to high conservation values because the protected
areas in 3.2 eliminates (or greatly mitigates) the threat posed
to the district of origin by non-compliance with 3.1
4. Wood harvested from areas being converted from forests
and other wooded ecosystems to plantations or non-forest
uses 4.1 Unspecified Low
Control Measures (if applicable)
5. Wood harvested from forests in which genetically modified
trees are planted
5 Unspecified Low
Control Measures (if applicable)
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Stakeholder Consultation Summary
N/A No stakeholder consultations conducted
Stakeholder Consultation was conducted prior to the Initial
Sustainable Biomass Partnership (SBP) Certification Audit in
2015. A Stakeholder Consultation is being conducted at this
time by SCS Global for the 2017 Survaillance Audit.
2015 Consultation:
Stakeholder Consultation
A list of twenty seven (27) local and regional stakeholders
was identified for consultation. These stakeholders represent
interests from local contractors and businesses, local
governments, state forestry and wildlife agencies,
conservation organizations such as the Nature Conservancy,
state forestry associations, local forest landowner
associations, US Forest Service and US Fish & Wildlife Service.
A letter was sent to the identified stakeholders in 2015
notifying them the intent of Georgia Biomass LLC to become
SBP certified and asking for input on their thoughts on the
company’s business practices and their impact on sustainable
forestry in their area. Feedback was requested during the
Summary of the consultation certification process via letter, email and/or telephone. All
process(es) performed according to feedback will be reviewed and responses will be provided.
Annex B of FSC-STD-40-005 V3 Response to stakeholder comments
As of 9 June three (3) stakeholders have responded to the
initial notification letter sent out on 2 May 2016.
Stakeholder’s comments are supportive of CE’s presence in
the region and endorse certification. These comments are
summarized below.
Responses were received from three of the twenty seven
stakeholders contacted. Feedback and responses are listed
below:
1. University of Georgia
Daniel B. Warnell School of Forestry and Natural Resources
Dr. W. Dale Greene - Dean
Positive comments reaffirming GBLLC’s commitment to
sustainable forestry practices and the value additional
markets provide to sustainable forestry.
No action necessary
2. Georgia Forestry Commission
Robert Farris – State Forester
Positive comments referencing positive growth/drain ration
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and GBLLC track record of forest stewardship
No action necessary
3. United States Department of the Interior
Fish and Wildlife Service
Strant Colwell – Coastal Georgia Supervisor
Positive comments indicating bioenergy industry can be
expanded in Georgia without threatening sustainability of
forest resources. Suggested GBLLC could have a positive
impact on sustainable forestry by supporting management
techniques that are “friendly” to the environment such as
those to protect the gopher tortoise. As a result of this
suggestion, GBLLC will place the brochure “Forest
Management Practices to Enhance Habitat for the Gopher
Tortoise” in Landowner Outreach Packets mailed to
landowners in promotion of sustainable forestry. GBLLC will
also give the brochure to loggers when inspecting active
logging sites.
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Expert Engagement Summary
N/A No expert engagement conducted
GBLLC-DOC-018 FSC Controled Wood/PEFC Due Diligence Risk
Assessment was completed in partnership with Greener
Information on the engagement of
Options Inc., a sustainability consulting company specializing
one or more experts in the
in sustainable forest certification and Biological Integrity LLC,
development of control measures in
a consulting company specializing in conservation and
accordance with Annex C
biodiversity assessments.
of FSC-STD-40-005 V3
Gary Boyd, Greener Options, Inc. is a SAF Certified Forester, a
Georgia Registered Forester and an ISO 14001 Environmental
Note: For individual experts this
Management Lead Auditor. Mark Hughes Ph.D., Biological
includes the names of the experts,
Integrity LLC, is an accomplished wildlife biologist who has
their qualifications, their
published more than 10 scientific articles, books and
license/registration number (if
monographs. He has developed more than thirty (30) risk
applicable), and the scope of their
assessments for forest products companies addressing
services. For publically available
sustainable forestry certification schemes such as the Forest
expertise, the specific sources of
Stewardship Council (FSC), the Programme for the
information shall be cited.
Endorsement of Forest Certification (PEFC) and the
Sustainable BiomassPArtnership (SBP).
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Summary of Field Verification
(undertaken as a control measure)
N/A No field verifications conducted as control measures
A summary of the organization’s
findings from field verification
undertaken as a control measure,
and steps taken by the organization
to address identified non
conformities where they occurred,
Field verification of the company's supply area is completed
unless confidential. The organization
through Tract Inspection Forms conducted by GBLLC
shall provide a justification for the
personnel as part of their SFI Fiber Sourcing program. A
exclusion of confidential
minimum of 10% of all tracts from which standing feedstock
information.
is harvested are inspected annually to assure compliance with
state, national, and international laws as well as the
Note: The confidential nature of the
requirements of the various certification schemes to which
information may be determined by
GMBLLC is certified.
the legislation that the organization
must be in compliance with.
Commercially sensitive information,
and the names of individual
landholders may be treated as
confidential.
Version 1-1 (November 2016) | © SCS Global Services Page 9 of 9Georgia Biomass LLC
Certification Documented Control System
Document: SCS Global Services
GBLLC-DOC-018 FSC Controlled Wood / 2000 Powell St., Suite 600
PEFC Due Diligence Risk Assessment Emeryville, CA 94608
-Last Revised: July 11, 2016 -Approved: December 6, 2017
Risk Assessment
Georgia Biomass LLC
July 11, 2016
Figure 1: Georgia Biomass, LLC Wood Basin
Page 1 of 48Georgia Biomass LLC
Certification Documented Control System
Document: SCS Global Services
GBLLC-DOC-018 FSC Controlled Wood / 2000 Powell St., Suite 600
PEFC Due Diligence Risk Assessment Emeryville, CA 94608
-Last Revised: July 11, 2016 -Approved: December 6, 2017
District of Origin
This risk assessment covers the District of Origin as reported to Biological Integrity, LLC by Georgia
Biomass LLC (the Company). The Company shall be required to document their District of Origin.
(FSC ADVICE-40-005-01). The Company's District of Origin is comprised of 128 counties: five in
Alabama, 38 in Florida and 85 in Georgia. They are mapped in Figure 1 (preceding page) and listed in
Table 1.
Table 1. List of county names by state that define the District of Origin.
Page 2 of 48Georgia Biomass LLC
Certification Documented Control System
Document: SCS Global Services
GBLLC-DOC-018 FSC Controlled Wood / 2000 Powell St., Suite 600
PEFC Due Diligence Risk Assessment Emeryville, CA 94608
-Last Revised: July 11, 2016 -Approved: December 6, 2017
Executive Summary
The Georgia Biomass, LLC (GBLLC) District of Origin has been declared LOW RISK, based on the
assessment of the following five indicators.
DETAILED ASSESSMENT FOR INDICATOR ONE
The risk of receiving illegally harvested wood in the GBLLC wood basin is LOW RISK, because
Indicators 1.1 through 1.4 are met.
DETAILED ASSESSMENT FOR INDICATOR TWO
Wood procured from the GBLLC wood basin is LOW RISK in relation to the threat of violation of
traditional, civil and collective rights. Since all five Indicators (2.1 – 2.5) are met.
DETAILED ASSESSMENT FOR INDICATOR THREE
The district of origin may be considered LOW RISK in relation to threat to high conservation values
because the protected areas evaluated under 3.2 eliminates (or greatly mitigates) the threat posed to the
district of origin by non-compliance with 3.1.
DETAILED ASSESSMENT FOR INDICATOR FOUR
The district of origin is considered to be LOW RISK in relation to the threat of conversion.
DETAILED ASSESSMENT FOR INDICATOR FIVE
There is no commercial use of genetically modified trees of the species concerned taking place in the
country or district concerned. Determined LOW RISK.
Page 3 of 48Georgia Biomass LLC
Certification Documented Control System
Document: SCS Global Services
GBLLC-DOC-018 FSC Controlled Wood / 2000 Powell St., Suite 600
PEFC Due Diligence Risk Assessment Emeryville, CA 94608
-Last Revised: July 11, 2016 -Approved: December 6, 2017
Five Categories of Controlled Wood Standard
• Illegally harvested wood;
• Wood harvested in violation of traditional and civil rights;
• Wood harvested in forests where high conservation values are threatened by management
activities;
• Wood harvested in forests being converted to plantations or non-forest use;
• Wood from forests in which genetically modified trees are planted.
Assessment of these five categories is documented below, associated with each applicable requirement
from the Standard for Company Evaluation of FSC Controlled Wood FSC-STD-40-005 (Version 2-1).
https://ic.fsc.org/fsc-std-40-005-evaluation-of-controlled-wood.441-20.htm
Assessment
INDICATOR ONE
FSC Controlled Wood Risk Assessment Specific Requirements for illegally harvested wood:
1. The district of origin may be considered low risk in relation to illegal harvesting when all of the
following indicators related to forest governance are present:
1.1. Evidence of enforcement of logging related laws in the district
LOW RISK JUSTIFICATION – There is legislation in place to regulate forestry activities
in the whole country. Each state has its own regulations which are adjusted to regional
conditions governing forestry and forest management. The exact penalties for violations are
mostly determined at the state level, however evidence of law enforcement is generally
found in all states.
http://www.globalforestregistry.org/map
1.2. There is evidence in the district demonstrating the legality of harvests and wood purchases
that includes robust and effective systems for granting licenses and harvest permits.
LOW RISK JUSTIFICATION – Illegal harvesting in the District is prohibited by national
and state laws (see Appendix 1). In most states timber buyers and/or harvesting companies
must be licensed in order to conduct their business. Evidence indicates that major
violations are prosecuted and legal liability is enforced
http://www.globalforestregistry.org/map
Page 4 of 48Georgia Biomass LLC
Certification Documented Control System
Document: SCS Global Services
GBLLC-DOC-018 FSC Controlled Wood / 2000 Powell St., Suite 600
PEFC Due Diligence Risk Assessment Emeryville, CA 94608
-Last Revised: July 11, 2016 -Approved: December 6, 2017
1.3 There is little or no evidence or reporting of illegal harvesting in the district of origin.
LOW RISK JUSTIFICATION - There is no evidence suggesting that illegal logging is a
wide scale problem in the United States (US). Commonly used terms for violations in US
are timber theft, tree poaching and unlawful logging. Thefts do occur, however the share
of illegal felling in hardwoods is much smaller than 1% according to a study conducted by
American Hardwood Export Council. It is logical to conclude that similarly illegal logging
is not a major problem for softwoods in US.
http://www.globalforestregistry.org/map
1.4 There is a low perception of corruption related to the granting or issuing of harvesting
permits and other areas of law enforcement related to harvesting and wood trade.
LOW RISK JUSTIFICATION - According to FSC directive (FSC-DIR-40-005) this
indicator can be considered as low risk only if the Corruption Perception Index (CPI) for
the given country is equal to or above 50. According to the latest (2014) evaluation results
from Transparency International, the CPI for the USA is 74*, clearly ABOVE 50.
*CPI values for all countries and more information about the survey can be found at:
http://cpi.transparency.org/cpi2013/results/
http://www.globalforestregistry.org/map
DETAILED ASSESSMENT FOR INDICATOR ONE
The risk of receiving illegally harvested wood in the GBLLC wood basin is LOW RISK, because
Indicators 1.1 through 1.4 are met.
SUPPORTIVE INFORMATION
Three FSC Opinions
According to the FSC Global Forest Registry the United States can be shown as low risk. They go on to
say that “International assessments of illegal logging do not identify the US as an area of systematic
illegal logging. Additionally, the US Scores high in measures of good governance.”
http://www.fsccontrolledwood.org/Region.aspx?RegionID=191&Source=RiskRegistry.aspx
There have been international assessments of illegal logging from the World Wildlife Fund (WWF),
Page 5 of 48Georgia Biomass LLC
Certification Documented Control System
Document: SCS Global Services
GBLLC-DOC-018 FSC Controlled Wood / 2000 Powell St., Suite 600
PEFC Due Diligence Risk Assessment Emeryville, CA 94608
-Last Revised: July 11, 2016 -Approved: December 6, 2017
Seneca Creek Associates, and Wood Resources International. These organizations have identified areas
where evidence of systematic illegal logging occurs. These areas do not include the US or Canada. In
addition, the US and Canada score high in measures of good governance such as offered by
Transparency International and the World Bank.”
http://fsccontrolledwood.org/Region.aspx?RegionID=191&CategoryID=1&Source=Default.aspx
“It is arguable that illegal logging is a problem in the United States. However, when compared to the
global situation, relatively, illegal logging in this country is of such small magnitude or frequency that
it cannot be considered to be systematic in any areas of the US In addition, any illegal logging that does
occur is often prosecuted or the rightful owner has means to remedy the situation.”
http://www.fsccontrolledwood.org/Region.aspx?RegionID=191&Source=RiskRegistry.aspx
Company Policies
GBLLC has a written Sustainable Forestry Policy. This corporate policy and third-party certifications
demonstrate the company’s best efforts to better track the sources of its fiber as well as avoid trading
and sourcing wood fiber from controversial sources or from illegally harvested wood; wood harvested in
violation of traditional and civil rights; wood harvested in forests where high conservation values are
threatened by management activities; wood harvested in forests being converted to plantations or non-
forest use; and wood from forests in which genetically modified trees are planted.
This commitment is taken seriously and communicated to each of their employees and logging
contractors.
The Florida Office of Agricultural Law Enforcement (OALE) investigates cases of timber theft.
http://www.doacs.state.fl.us/press/2007/07242007.html
http://www.sfr.psu.edu/PDFs/HicksThesis.pdf
INDICATOR TWO
FSC Controlled Wood Risk Assessment Specific Requirements for wood harvested in violation of
traditional, civil and collective rights:
2. The district of origin may be considered low risk in relation to the violation of traditional, civil
and collective rights when all the following indicators are present:
2.1 There is no UN Security Council ban on timber exports from the country concerned;
LOW RISK JUSTIFICATION - There are no U.N. Security Council bans on timber
exports from the United States.
Page 6 of 48Georgia Biomass LLC
Certification Documented Control System
Document: SCS Global Services
GBLLC-DOC-018 FSC Controlled Wood / 2000 Powell St., Suite 600
PEFC Due Diligence Risk Assessment Emeryville, CA 94608
-Last Revised: July 11, 2016 -Approved: December 6, 2017
2.2 The country or district is not designated a source of conflict timber (e.g. USAID Type 1
conflict timber);
LOW RISK JUSTIFICATION - USAID does not designate districts as source of conflict
timber.
2.3 There is no evidence of child labor or violation of ILO Fundamental Principles and Rights
at work taking place in forest areas in the district concerned;
LOW RISK JUSTIFICATION – There is no evidence of child labor or violation of ILO
Fundamental Principles and Rights at work.
2.4 There are recognized and equitable processes in place to resolve conflicts of substantial
magnitude pertaining to traditional rights including use rights, cultural interests or
traditional cultural identity in the district concerned;
LOW RISK JUSTIFICATION - There are recognized and equitable processes in place to
resolve conflicts of substantial magnitude pertaining to traditional rights in the district of
origin.
2.5 There is no evidence of violation of the ILO Convention 169 on Indigenous and Tribal
Peoples taking place in the forest areas in the district concerned.
LOW RISK JUSTIFICATION - There is no evidence of violation of the ILO Convention
169 in the US.
DETAILED ASSESSMENT FOR INDICATOR TWO
Wood procured from the GBLLC wood basin is LOW RISK in relation to the threat of violation of
traditional, civil and collective rights. Since all five Indicators (2.1 – 2.5) are met.
SUPPORTIVE INFORMATION
FSC Global Forestry Registry Assessment
According to FSC's Global Forestry Registry the United States can be shown as LOW RISK. They go
on to say that “International assessments of violation of traditional or civil rights do not identify the US
as problematic. In addition, the US has equitable processes in place to resolve disputes.
National Parameters
Native Americans are protected by federal law rather than state law according to the Nonintercourse Act
of 1790. The Indian Removal Act of 1830 was intended to promote the voluntary removal of Native
Americans out of the US Territory peacefully through treaties and land sales, but this was not always the
case.
Page 7 of 48Georgia Biomass LLC
Certification Documented Control System
Document: SCS Global Services
GBLLC-DOC-018 FSC Controlled Wood / 2000 Powell St., Suite 600
PEFC Due Diligence Risk Assessment Emeryville, CA 94608
-Last Revised: July 11, 2016 -Approved: December 6, 2017
In many areas of the southeastern US the claims to traditional lands by rival native inhabitants is
obscure. Occupation of those lands was in constant flux.
Prehistoric and Historical Perspective
Throughout the European expansion into North America, counties that make up the GBLLC wood basin
were claimed by multiple tribes of Native Americans that had a wide array of cultural backgrounds and
were in constant conflict with one another. Warfare over territories was frequent; ownership of territory
was in constant dispute. Historical changes in territorial occupation were observed and recorded by
Europeans from the 1500s onward. Even in the late 1700s, it was not clear what tribe or tribes had
rightful claim to disputed areas within the wood basin when compared with that history and the claims
of other indigenous people. Sometimes tribes that occupied a territory were allowed to do so by another
tribe that gave them permission to be there. Territorial boundaries were most-often respected, if the
tribe that claimed the land could forcefully defend their claim. Some examples are given below to
illustrate how indigenous people reacted to one another over territorial disputes.
Prehistory
The South Appalachian Mississippian Culture, known as the mound builders, had dominated the
southeast since about 900 AD. Their villages, ruled by chiefs, were called chiefdoms by early explorers.
Some of the chiefdoms were deemed paramount chiefdoms because they had oversight of multiple,
lesser chiefdoms. Important paramount chiefdoms of mound builders in the GBLLC wood basin in the
early 1500s were the Apalachee, Cofitachequi, Coosa, and Timucua. Most of these tribes did not
survive into the 1700s. Their culture certainly did not. The culture of mound builders was in decline
prior to European contact; when early European explorers entered the land, most of the chiefdoms in the
southeast were already gone. Nevertheless, between 1513 and 1568, early Spanish explorers were given
a brief glimpse of the mound builder culture. They not only saw how the culture worked, but they also
show us where those people lived and how they maintained their territorial boundaries.
For example, in 1513, when the Spanish arrived in Florida, there were multiple villages belonging to at
least thirty-five Timucua chiefdoms in northeastern Florida. Using modern day landmarks, the Timucua
inhabited the area from Tallahassee to Jacksonville and south to Ocala. This area takes up most of
peninsular Florida. Anthropologists believe that the Timucua inhabited the St. Augustine area as early
as 1300 and maybe as long ago as 1100 AD. This means that they may have continuously inhabited this
area between 200 and 400 years.
The Timucua culture was an association of chiefdoms that shared a unique language, but they were not
an allied political body. The Timucua people were about 200,000 strong in the early 1513. Following
European contact, most of the southeastern tribes of Native Americans were decimated primarily by
European-born diseases that they had no resistance. Warfare with other indigenous people as well as
French and Spanish colonists compounded their decline in numbers. By 1595, there were only 50,000
Timucua remaining in Florida. By 1700 only 1,000 were left and all of the survivors were moved to
Cuba by the Spanish where the last member of the tribe died in 1767.
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In 1540, while making a circular expedition throughout the southeast, Hernando DeSoto, a Spanish
explorer, contacted the few remaining chiefdoms of mound builders in Alabama, Georgia, South
Carolina, and Tennessee. With his conquistadors beside him, DeSoto passed from Florida and moved
through Georgia, traversed the coast of South Carolina, crossed over the mountains of North Carolina
and Tennessee, and traveled though the valleys of Tennessee and north Georgia. According to his
accounts, that area was controlled by powerful chiefdoms of mound builders, similar in culture to the
Timucua that were occupying northern Florida where the Spanish had begun their explorations. French
colonists near Jacksonville, FL, also documented the presence of the Timucua in northern Florida and
southeastern Georgia around 1564.
In 1500s, the footprint of the GBLLC wood basin was clearly dominated by a culture of mound builders,
controlled by powerful paramount chiefdoms. The entire culture of mound builders in the vicinity of the
wood basin vanished after making contact with Spanish explorers. Individual villages suffered rapid
declines in population numbers. Only a few of these collapses were documented. There are good
historical records obtained from consecutive Spanish explorers that document the fall of the Coosa
chiefdom in north Georgia.
Visits to the Coosa chiefdom were initiated in 1540 A.D. by DeSoto. Captain Juan Pardo made an
excursion into the interior of Georgia in 1568 and visited known villages of mound builders which
included the Coosa. Further documented explorations to the Coosa chiefdom were made in 1597. The
Coosa chiefdom was last visited by officers in the company of soldiers in the Tristain de Luna's
explorations in 1600. Following their exposure to European diseases brought into their villages and
camps by the successive visitations of DeSoto, Tristán de Luna, and Juan Pardo. Most Coosa villages
stood empty while the remaining towns were barely defensible against surrounding tribes. Following
the end of the mound building period, a confederacy of their survivors and perhaps surrounding tribes
grouped together, vying for the recently vacated portions of northern peninsular Florida and south
central Georgia.
It is difficult today to understand where the boundaries of traditional lands of indigenous people were
located in the southeast, because the names and the identities of early inhabitants are often in doubt. The
confusion can be attributed to the inconsistency between the names given to chiefdoms and villages by
French, Dutch, English and Spanish speaking explorers who were writing the names of a people that had
no written language. The names came from either the people themselves or from neighboring tribes.
The names that tribes gave to their neighbors were not the same name that those tribes gave to
themselves. Also, the political relationships and allegiances between villages and chiefdoms were
vague. Outlying chiefdoms may have relationships and ties with more than one paramount chiefdom.
Some people were nomadic and others were not. Whether native people were recent immigrants or truly
indigenous to an area may never be known.
http://www.accessgenealogy.com/native/creek/early-history/hitchiti_tribe.htm
Historic Occupation
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Native American newcomers either moved into the District of Origin in historic times or organized as
new tribes from bands of survivors of the decimated mound builders. It is thought by some
anthropologists that the Muscogee (Muskogee) or Creek who spoke Muskogean, a language endemic to
the southeastern United States, may have been a reorganized political group, arising from remnant
cultures of their presumed ancestors, the mound builders. Certainly, there is evidence that at least one
tribe of mound builders merged with the newcomers. The Hitchiti apparently merged with the Creeks,
but may have merged with the Yamasee, another newcomer to the area. The Hitchiti seem to have been
direct descendants of prehistoric mound builders, yet historically, may have been part of the Creek
Nation. However, some linguists believe that the Hitchiti became part of the Yamasee another group of
Native Americans that moved into the coastal areas of the GBLLC wood basin in historic times.
http://www.accessgenealogy.com/native/creek/early-history/hitchiti_tribe.htm
The Yamasee were historically situated along the Atlantic Coast of Georgia and South Carolina, near
Savannah. Like the Creek, the Yamasee were likely an amalgamation of the early chiefdoms which
included the Cofitachequi and the Ocute from the interior of Georgia. The Yamasee continually fought
in historic times for contested land along Georgia's Atlantic Coast.
In 1670, the Yamasee tribe was driven out of the Savannah, Georgia area by another native American
tribe, the Westo, to the middle Georgia coastal zone with some members traveling even further south
into northern Florida. Pirates split the Yamasee once again, driving some north, back into the Savannah
River area and the others moved deeper into Florida. But in 1687, the Yamasee in Florida revolted
against the Spanish and, upon losing their battles, were driven out of Florida, migrating again to the
north.
The Yamasee were in constant warfare against both European (British and Spanish) and Native
Americans (Creeks, Cherokee, and Shawnee). The Cherokee, a relatively recent arrival to the area, had
been driven south by the Iroquois from the Great Lakes region to the mountains of North Carolina,
South Carolina, and Tennessee. It is unclear how long they lived in the southeast. However, the
Iroquoian language, spoken by the Cherokee, gives support to their oral tradition that they moved into
the south from their ancestral home around the Great Lakes. The Cherokee, Creeks, and Yamasee were
historic rivals due to territorial disputes over land left abandoned by the demise of the mound builder
cultures. These tribes were constantly changing allegiances to protect themselves from one another. In
1715, these three tribes overcame their differences and united to fight a common enemy, the South
Carolina colonists.
Along with almost all of the other southeastern tribes (ie: Catawba, Chickasaw, and Choctaw) the
Cherokee, Creek, and Yamasee grouped together in solidarity against the British and their South
Carolina colony. Prior to the war, the Yamasee had been strong military allies of the South Carolina
colonists, but as the Creeks were preparing for war against the South Carolina colonials, the Yamasee
struck the colonist first. For that reason, the ensuing battles were called the Yamasee Wars. Facing
attacks both on the frontier and at home by all of the local native American tribes, the survival of the
colony was in question. The Cherokee Nation was hesitant from the beginning to side with the Creek,
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their arch rivals. Eventually the Cherokee broke their allegiances with the Creek and Yamasee and
sided with the British colonist. The Cherokee were apparently divided on this move, but it appears that
their mistrust of the Creeks was greater than their fear of colonial encroachment. The Yamasee were
blamed for starting the wars and decided to move away from and abandon any claims to territories near
the Savannah area, retreating once again to northern Florida in 1727 where they sided with the Spanish
against the British. Remember though, the Spanish had driven the Yamassee out of Florida 40 years
earlier.
Cherokee tribes were likely living in the southern Appalachians by the early 1500s and moved into north
Georgia as land was vacated by the failing culture of mound builders. This occurred at about the same
time that the Creeks were developing a new nation from the remnants of mound builders. The Cherokee
occupied the former Coosa site in north Georgia but later abandoned it. After the Cherokee abandoned
the Coosa site, the Creeks moved in.
From 1753 to 1756, Cherokee and Creek fought for hunting rights in north Georgia. In 1756, the
Cherokee defeated the Creek and the dispute over north Georgia was settled. Nevertheless, The Creek
still occupied the site of the former Coosa chiefdom in north Georgia as late as 1759, probably with the
blessings of the Cherokee.
Native Americans were constantly forming allegiances and treaties between both neighboring tribes of
indigenous people and European colonists that may have been friend or foe. They were constantly
restructuring agreements and treaties in the best interests of each party. This can be best illustrated by
looking at the changes that took place between the Cherokee and the British.
Prior to the American Revolution, the Cherokee fought with the British against the French and later
fought with other tribes directly against the British, and later defended the British against the Creeks.
One reason for this allegiance was that the British were opposed to colonists moving west of the
Appalachian Mountains into present day Tennessee. Maybe for that reason, during the American
Revolution the Cherokee sided with the British against the American colonists. The American's victory
over the British dealt a fatal blow to many of the tribes occupying the GBLLC wood basin. Although a
triangle of potential enemies, the Cherokee and upper Creeks had sided with the British during the
American Revolution while the lower Creeks in Georgia tried to remain neutral. In 1779, even the lower
Creeks reluctantly gave their support to the British troops. British loyalists, Cherokees, and Creeks had
all sided with the British and were now in an awkward position. The Americans who had fought British,
Cherokee, and Creeks for so many years did not forget who their enemies had been.
After the American Revolution ended in 1783, the British ceded all their claims in America to the
colonists. The lower Creeks ceded their land to the newly formed State of Georgia. Many creeks and
members of other tribes moved into Florida which was controlled, in part, by Spanish immigrants.
Searching for a new capital far from the colonies, the Cherokee capital was moved from South Carolina
to a town called “Ustanali” on the Coosawattee River in 1788. In 1819, the Cherokee capital was again
moved nearby at the confluence of the Conasauga and Coosawattee rivers which form the Oostanaula
River. This town, New Echota, is between the present day towns of Calhoun and Resaca, Georgia. On
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November 12, 1825, New Echota was officially designated capital of the Cherokee Nation on land that
was formerly claimed and occupied by the Creeks.
In 1819, Florida was abandoned by the Spanish and turned over to the Americans. Tribes that moved to
Florida under Spanish protection found themselves at war once again with the Americans. Individuals
and small groups of related people from other tribes abandoned their tribal allegiances and formed an
alliance called the Seminoles. Members of this alliance waged three successive wars that were fought
between 1817and1858 against the US in a desperate effort to regain some land in the East. These battles
were most prevalent in south Georgia and Florida.
The Indian Removal Act of 1830 was enacted to move Native Americans from their territories in the
East to a newly designated “Indian Territory” which is now Oklahoma. In 1832, the Creek National
Council signed the Treaty of Cusseta, ceding their remaining lands east of the Mississippi to the US and
accepted relocation to the Indian Territory. In the same year, the Cherokee land was given away to
Georgia residents by the state of Georgia in a land lottery. In May 1835, a small band of Cherokee about
500 strong signed the New Echota Treaty which ceded their land in Georgia for land west of the
Mississippi River. This treaty gave the federal government the justification they needed to forcefully
remove the remaining Cherokee to Oklahoma in 1838.
Tribes responded to the Removal Act in different ways. Some indigenous people voted to move, other
tribal members cautiously ceded a portion of their territories to the federal government in hopes to save
the remainder of their land in the East.
Some individuals from multiple southeastern tribes fought to retain their land. Strength is in numbers,
so they formed an alliance of tribes, predominately Lower Creeks with a few members from the
Cherokee, Chickasaw, and Choctaw nations. The newly formed tribe called Seminoles rejected their
ancestral roots. Most of the Seminoles eventually moved to Oklahoma, but some fled to the Everglades
and live their today. The Seminoles never surrendered to the US Army.
http://en.wikipedia.org/wiki/Indian_Removal
http://www.pbs.org/wgbh/aia/part4/4p2959.html
http://www.civics-online.org/library/formatted/texts/indian_act.html
INDICATOR THREE
FSC Controlled Wood Risk Assessment Specific Requirements for wood harvested from forest in which
high conservation values are threatened by management activities:
3. The district of origin may be considered low risk in relation to threat to high conservation values
if: a) indicator 3.1 is met; or 3.2 eliminates (or greatly mitigates) the threat posed to the district of
origin by non-compliance with 3.1.
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3.1 Forest management activities in the relevant level (eco-region, sub-eco-region, local) do
not threaten eco-regionally significant high conservation values.
INDICATOR NOT MET - See Detailed Assessment for 3.1 beginning on next page. The
wood basin of GBLLC cannot be considered LOW RISK in relation to presence of high
conservation values within the wood basin. There is one Alliance for Zero Extinction Site
(AZE), two Centre for Plant Diversity (CPD) sites, one GreenPeace Intact Forest (IF), one
World Wildlife Fund (WWF) Global 200 ecoregion overlapping the wood basin. Therefore
an assessment of LOW RISK depends on to the next indicator.
3.2 A strong system of protection (effective protected areas and legislation) is in place that
ensures survival of the HCVs in the District of Origin.
LOW RISK JUSTIFICATION - There are protected areas with a strong protection system
for each HCV in the wood basin.
DETAILED ASSESSMENT FOR INDICATOR THREE
The district of origin may be considered LOW RISK in relation to threat to high conservation
values because the protected areas in 3.2 eliminates (or greatly mitigates) the threat posed to the
district of origin by non-compliance with 3.1.
FSC Controlled Wood Assessment Guidance
“...determining threat to ecoregionally significant HCVs is complex. Users can demonstrate low
risk by determining there is no HCVF in the source area or through demonstration of adequate
protection of the HCVs.”
FSC goes on to say “Internationally, consultation with global conservation organizations (Conservation
International, World Wildlife Fund, IUCN, Greenpeace, World Resources Institute), local conservation
organizations, and FSC national initiatives will provide perspective on conservation priorities.” This is
the model used within.
http://www.fsccontrolledwood.org/Region.aspx?RegionID=191&Source=RiskRegistry.aspx
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Evaluation of HCVs of ecoregional significance under guidance for 3.1
Alliance for Zero Extinctions (AZE) sites
One Alliance for Zero Extinction Site (AZE), the Torreya State Park, is located within the wood basin in
Gadsden County, Florida. The AZE site is confined to two Florida counties, Gadsden and Liberty. It
protects the bulk of extant occurrences of the Florida Torreya, Torreya taxifolia, within its native range.
Two additional management areas near the park protect additional Torreya occurrences (Figure 2). The
Florida Torreya, the target species within this AZE site, is an endemic to limestone bluffs along the
Apalachicola River in Gadsden and Liberty counties FL as well as a few kilometers into Decatur
County, GA, The Torreya is a tree. It originally comprised about 4% of the forest in this area. Its stems
were used primarily for fence posts. A fungal blight destroyed the population. Its associate tree species
include beech (Fagus grandifolia), yellow-poplar (Liriodendron tulipifera), American holly (Ilex
opaca), Florida maple (Acer barbatum), loblolly pine (Pinus taeda), spruce pine (P. glabra), white oak
(Quercus alba), eastern hophornbeam (Ostrya virginiana), and sweetgum (Liquidambar styraciflua).
Artificial propagation of the Florida Torreya is ongoing. Cultivated individuals have survived in North
Carolina for over 40 years.
The risk of impacting this habitat is UNDETERMINED.
Conservation International Hotspots
There are no Conservation International Hotspots (CI) in the GBLLC wood basin. The closest CI
hotspots are located in the southwestern United States, as well as areas in the Gulf of Mexico and the
Caribbean (Figure 3).
The Centre for Plant Diversity (CPD)
NA24. Piedmont granitic rock outcrops; This rare community does not occur in the wood
basin. Occurrences are sporadic in Georgia, South Carolina and Alabama. Granite rock outcrops
are a prominent feature of the Piedmont region. Georgia is full of them; Florida has none. There
are about 10,800 acres of exposed granite in Georgia which is about 90% of all the exposed
granite in the Southeast. GIS data is available that shows the location of granite bedrock which
identifies possible locations of granite outcrops. Weathering of soils over granite bedrock
exposes the bedrock at the surface. Once exposed, the granite bedrock is called a granite
outcrop, granite outcrops are another name for exposed granite bedrock. The location of granite
bedrock in Georgia is mapped on Figure 4. The only county with granite deposits within the
GBLLC wood basin is Bibb County, Georgia. A high percentage (33%) of plants associated
with these rock outcrops are endemics. A handful of rare species are known to occupy high
quality granite outcrops and their occurrences indicate the locations of granite outcrops. They are
pool sprite (Minuartia uniflora), black-spored quillwort (Isoetes melanospora), mat-forming
quillwort (Isoetes tegetiformans), and harperella (Ptilimnium nodosum). Based on a search of
NatureServe on May 2014, none of these species occur in Bibb County, Georgia. The USFWS
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Recovery Plan: Three Granite Outcrop Plants (1993) did not report any records for pool sprite
(Minuartia uniflora), black-spored quillwort (Isoetes melanospora), or mat-forming quillwort
(Isoetes tegetiformans) in Bibb County.
http://www.fws.gov/ecos/ajax/docs/recovery_plan/930707.pdf
Some other obligate granite outcrop associates are diamorpha (Diamorpha smalli), white-
flowered sandwort (Arenaria uniflora), bentgrass (Agrostis elliottiana), and blue-flowered
toadflax (Linaria canadensis). Based on NRCS distribution data none of these taxa occur in
Bibb County, GA.
http://plants.usda.gov/java/county?state_name=Georgia&statefips=13&symbol=DISM3
Based on these plant distribution records this rare natural community does not occur in the Bibb
County, GA.
NA25. Serpentine flora (eastern) are restricted to soils derived from serpentine rock outcrops
found in association with utramafic rock (Figure 5). NA25 is restricted to the Piedmont
physiographic province. There is no ultramafic bedrock in the GMLLC wood basin, based on
the distribution of this bedrock given by the United States Geological Survey (USGS).
Serpentine soils, associated with ultramafic bedrock, formed along a linear boundary between
ancient continents. There are two of these zones in North America, one on the west coast and
another on the east coast. The eastern zone extends from Alabama north into Quebec. Serpentine
soils have relatively higher levels of heavy metals (cadmium and nickel) and lower levels of
calcium than other soils. Therefore, are toxic to most plants. Clays in serpentine soils have a
high affinity for water, more so than other clays, making less water available to plants. Plants
found in this CPD are specialists. They are adapted to the harsh conditions created by these soils
and cannot survive outside of this habitat, making them obligate endemics to serpentine soils.
As already stated, most plants cannot live in this environment. Therefore it is unlikely that
commercial timber products would or could occur on these serpentine soils. Since this CPD is
outside the wood basin and wood products do not occur in this CPD, the threat to this CPD is
LOW RISK.
http://www.gabotsoc.org/articleTrackrock.htm
NA28. Apalachicola River drainage of north-western Florida (panhandle) and adjacent
Georgia is described below. NA 28 is within Gadsden County, Florida which is included in the
wood basin (Figure 6). This CPD is different from the AZE site described above in that it
includes other targeted species in the watershed.
The risk of impacting this habitat is UNDETERMINED.
The east side of the Apalachicola River is one of the classic areas of both endemics and rare
plants, such as Torreya taxifolia, with its nearest relative in California, and the associated herb
Croomia pauciflora, this occurrence is the only record of any member of a the family
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