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SCS Global Services Evaluation of Grand River Pellets, Limited Compliance with the SBP Framework: Public Summary Report

Main (Initial) Audit

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SCS Global Services Evaluation of: Grand River Pellets, Public Summary Report, Main (Initial) Audit Page ii

Completed in accordance with the CB Public Summary Report Template Version 1.4

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 30 January 2018

Version 1.2: published 4 April 2018

Version 1.3: published 10 May 2018

Version 1.4: published 16 August 2018

© Copyright The Sustainable Biomass Program Limited 2018


SCS Global Services Evaluation of: Grand River Pellets, Public Summary Report, Main (Initial) Audit Page iii

Table of Contents 1 Overview

2 Scope of the evaluation and SBP certificate

3 Specific objective

4 SBP Standards utilised

4.1 SBP Standards utilised

4.2 SBP-endorsed Regional Risk Assessment

5 Description of Company, Supply Base and Forest Management

5.1 Description of Company

5.2 Description of Company’s Supply Base

5.3 Detailed description of Supply Base

5.4 Chain of Custody system

6 Evaluation process

6.1 Timing of evaluation activities

6.2 Description of evaluation activities

6.3 Process for consultation with stakeholders

7 Results

7.1 Main strengths and weaknesses

7.2 Rigour of Supply Base Evaluation

7.3 Compilation of data on Greenhouse Gas emissions

7.4 Competency of involved personnel

7.5 Stakeholder feedback

7.6 Preconditions

8 Review of Company’s Risk Assessments

9 Review of Company’s mitigation measures

10 Non-conformities and observations

11 Certification recommendation


SCS Global Services Evaluation of: Grand River Pellets, Public Summary Report, Main (Initial) Audit Page 1

1 Overview CB Name and contact: SCS Global Services, 2000 Powell St. Ste 600 Emeryville, CA 94608

Primary contact for SBP: Sarah Harris, [email protected]

Current report completion date: 20/Jun/2019

Report authors: Kyle Meister

Name of the Company: Grand River Pellets, LTD., 75 Grand River Road, St Leonard, New Brunswick, E2E 2K3, CANADA

Company contact for SBP: Scott MacDougall, [email protected]

Certified Supply Base: New Brunswick and Quebec, Canada; and Maine, USA

SBP Certificate Code: SBP-04-41

Date of certificate issue: 23/Jul/2019

Date of certificate expiry: 22/Jul/2024

This report relates to the Main (Initial) Audit



2 Scope of the evaluation and SBP certificate

The scope of the main evaluation was a conformity assessment to determine Biomass Producer’s (BP) conformance to the following SBP requirements: SBP Standard 2, Verification of SBP-compliant Feedstock, Version 1.0; SBP Standard 4, Chain of Custody, Version 1.0; SBP Standard 5, Collection and Communication of Data, Version 1.0 (including relevant Instruction Documents).

This certificate covers the production, transport, storage, and trade of wood pellets made from SBP-compliant feedstock, including transport by truck from the pellet mill in Saint Leonard, New Brunswick to the Port of Belledune, New Brunswick. It also includes the communication of dynamic batch sustainability data. It does not include supply base evaluation.



3 Specific objective The specific objective of this evaluation was to confirm that the Biomass Producer’s (BP) management system is capable of ensuring that all requirements of specified SBP Standards are implemented across the entire scope of certification.

The following critical control points were identified and evaluated:

Processes for procurement and processing, transport, storage, and trade

• Review of supply source from BP’s sister company, including verification of scaling, transport, and storage; and

• Verification of pellet storage onsite and at the port facility

Volume accounting method

• The volume credit system under PEFC/SFI is used; • Trucks with finished pellets are scaled; and • Pellets are weighed at the port facility upon loading onto the ship;

Documentation of transactions

• BP will use DTS and invoices

Energy data collection and reporting

• Excel spreadsheets are used to track data; • GHG control points were verified at the pellet mill, transport route, and port facility.

Instruction Document 5D: Dynamic Batch Sustainability Data



4 SBP Standards utilised

4.1 SBP Standards utilised ☐ SBP Framework Standard 1: Feedstock Compliance Standard (Version 1.0, 26 March 2015) ☒ SBP Framework Standard 2: Verification of SBP-compliant Feedstock (Version 1.0, 26 March 2015)

☒ SBP Framework Standard 4: Chain of Custody (Version 1.0, 26 March 2015)

☒ SBP Framework Standard 5: Collection and Communication of Data (Version 1.0, 26 March 2015)

4.2 SBP-endorsed Regional Risk Assessment Not applicable – there is no SBP-endorsed Regional Risk Assessment.

Please select all SBP Standards used during this evaluation. All Standards can be accessed and downloaded from https://sbp-cert.org/documents/standards-documents/standards



5 Description of Company, Supply Base and Forest Management

5.1 Description of Company The BP, Grand River Pellet, LTD., is a subsidiary of J.D. Irving, LTD., based in New Brunswick, Canada and is registered in the province under reference number 698486. The BP was formed specifically to produce pellets from secondary and tertiary material from regional saw and lumber mills.

5.2 Description of Company’s Supply Base Per the BP’s supply base report: J. D. Irving, Limited owned land and New Brunswick Crown Land is managed to achieve economic, social, environmental and ecological objectives. The forest has been zoned into the general forest, where timber production is a primary objective, and special management zones including unique sites, deer wintering areas, and mapped riparian zones, each of which has specific environmental, habitat or social objectives. The Supply Base is within the Acadian Forest Region and consists of spruce, balsam fir, cedar, maple, birch and poplar. Adjacent lands are similar in forest composition and land use structure. Two other forest-based industries (pulp mills) in the area would operate under a similar scale of harvesting. Forest Management practices are similar on crown land and large freehold land. They consist of 80-year rotation forest management plans that ensure sustainability of the wood supply for local mills. Annual operating plans are implemented to meet the forest management plan objectives. Third Party audited Forest Certification is used to ensure economic, environmental and social principles are met. Private land harvesting is managed through Marketing boards that provide woodlot management advice, and plans, to private woodlot owners. SBP Product Groups 100% SBP compliant Secondary Feedstock – 100% certified - 100% Spruce, Balsam Fir, Pine



5.3 Detailed description of Supply Base Per the BP’s supply base report: Supply Base a. Total Supply Base area (ha): 8.2 million hectares b. Tenure by type (ha): 3.2 million hectares publicly owned, and 5 million hectares privately owned c. Forest by type (ha): 8.2 million hectares of temperate forest d. Forest by management type (ha): 2 million hectares managed (planted and/or pre-commercially thinned) natural forest and 6.2 million hectares natural forest e. Certified forest by scheme (ha): 0.8 million hectares FSC certified forest and 5 million hectares SFI certified forest. The credit system will be used as not 100% of the supply base is certified. Feedstock f. Total volume of Feedstock: tonnes or m3 : 175,000 tonnes g. Volume of primary feedstock: tonnes or m3 : 0 tonnes h. List percentage of primary feedstock (g), by the following categories. - 100% Certified to an SBP-approved Forest Management Scheme - 0% Not certified to an SBP-approved Forest Management Scheme i. List all species in primary feedstock, including scientific name: Species Conifers Abies balsamea - Balsam Fir Picea rubens - Red Spruce Picea glauca - White Spruce Picea mariana - Black Spruce Picea abies - Norway Spruce Pinus banksiana - Jack Pine Pinus strobus – White Pine Pinus resinosa – Red Pine Larix laricina – Tamarack Tsuga canadensis – Hemlock Thuja occidentalis – Eastern White Cedar Species Deciduous Acer saccharum - Sugar Maple Acer rubrum - Red Maple Acer pensylvancium – Striped Maple Betula alleghaniensis - Yellow Birch Betula papyrifera - White Birch Betula populifolia – Grey Birch Fagus grandifolia - Beech Quercus rubra - Red Oak Quercus macrocarpa - Bur Oak Populus tremuloides – Trembling Aspen Populus balsamifera – Balsam Poplar Populus grandidentata – Large Tooth Aspen Ostrya virginiana – Ironwood For more detail on the supply base please refer to the organization’s supply base report.

5.4 Chain of Custody system BP provided copies of its FSC (KF-COC-001034, KF-CW-001034) and SFI (PRI-SFI-COC-020) certificates from its certifier. SFI certificate was confirmed via SFI and PEFC database entries. FSC certificate was also



confirmed via the FSC database entry. The BP uses the FSC credit system and SFI volume credit system to source certified and non-certified material, including associated risk assessments and Due Diligence Systems.



6 Evaluation process

6.1 Timing of evaluation activities A desk pre-assessment was conducted in March 2019. The main evaluation onsite occurred 18-20 June 2019.

6.2 Description of evaluation activities The main evaluation onsite occurred 18-20 June 2019 and included review of relevant documentation and records; observation and confirmation of production, transport, and critical Chain-of-Custody (COC) and Greenhouse Gas (GHG) control points; and interviews with BP workers and service providers. The sites evaluated included the BP’s pellet mill, the transport route to the Port of Belledune, and the storage and loading facility at the Port of Belledune, New Brunswick. Critical control points for COC evaluated included: feedstock procurement, storage, and staging for production; production; pellet storage areas; loading of pellets onto trucks onsite prior to transport from the pellet mill; and transport to, storage, and loading at the Port of Belledune. Critical control points for GHG emissions evaluated included: feedstock and pellet moisture content measurements, fuel and energy usage measurements at the pellet mill, and transport to, storage and loading at the Port of Belledune. GHG measurements at the Port include fuel use for loading and handling, and electricity for storage, handling, and loading onto ships.

6.3 Process for consultation with stakeholders A notification letter was sent to stakeholders and rightsholders in March 2019. No comments were received.



7 Results

7.1 Main strengths and weaknesses The BP demonstrated overall conformance to Standards 2, 4, and 5. The data collection system is ready to be used once energy use and other data become available for reporting in the SAR. Refer to the findings section for weaknesses.

7.2 Rigour of Supply Base Evaluation Not applicable – the BP did not conduct an SBE.

7.3 Collection and Communication of Data The BP has procedures and data collection systems to gather and communicate data after tallying and/or making calculations, as applicable. The BP has the cooperation of its engineering staff and service providers in gathering data and making calculations, as confirmed in interviews and via observation of records.

7.4 Competency of involved personnel The BP did not conduct an SBE. The BP only sources SBP-compliant feedstock. The BP prepared a Supply Base Report which is publicly available on its website. The BP maintains several sustainable forestry certifications in two countries and thus has competent personnel to ensure long-term conformance. BP staff involved in the audit were knowledgeable of forest management, wood products, engineering, and manufacturing.

7.5 Stakeholder feedback Stakeholders and rightsholders did not provide any comments.

7.6 Preconditions No Preconditions were identified during the assessment.



8 Review of Company’s Risk Assessments

Not applicable – the BP determined that an SBE was not necessary since it only sources SBP-compliant feedstock per rules of recognised sustainable forestry programmes.

Table 1. Final risk ratings of Indicators as determined BEFORE the SVP and any mitigation measures.

Indicator Risk rating

(Low or Specified)


(Low or Specified)

Producer CB Producer CB 1.1.1 Low Low 2.3.3 Low Low

1.1.2 Low Low 2.4.1 Low Low















2.2.6 Low Low

2.2.7 Low Low

2.2.8 Low Low

2.2.9 Low Low

Describe how the Certification Body assessed risk for the Indicators. Summarise the CB’s final risk ratings in Table 1, together with the Company’s final risk ratings. Default for each indicator is ‘Low’, click on the rating to change. Note: this summary should show the risk ratings before AND after the SVP has been performed and after any mitigation measures have been implemented.



2.3.1 Low Low

2.3.2 Low Low

Table 2. Final risk ratings of Indicators as determined AFTER the SVP and any mitigation measures.


(Low or Specified)


(Low or Specified)

Producer CB Producer CB 1.1.1 Low Low 2.3.3 Low Low
















2.2.6 Low Low

2.2.7 Low Low

2.2.8 Low Low

2.2.9 Low Low

2.3.1 Low Low

2.3.2 Low Low



9 Review of Company’s mitigation measures

Not applicable – the BP determined that an SBE was not necessary since it only sources SBP-compliant feedstock per rules of recognised sustainable forestry programmes.



10 Non-conformities and observations

NC number 01 NC Grading: Minor

Standard & Requirement: ST 5, ID 5B, 3.2.1 / ID 5C 3.2.1

Description of Non-conformance and Related Evidence:

The reporting period in the SAR must be in the past. The SAR indicates that Reporting Period will be from June 11 to December 31, 2019 which is less than 12 months. As this is a new production unit that started producing June 11, 2019 the reporting period is from June 11 to June 16, 2019 (stated in the SAR, section B part 2: “This production has been achieved from June 11 to June 16, 2019”). Next year’s reporting period will be 19-June-2019 to 18-June-2020. Timeline for Conformance: Other

Pre-conditional to SAR approval

Evidence Provided by Company to close NC:

Review of the updated SAR

Findings for Evaluation of Evidence:

The reporting period has been updated to June 11 to June 16, 2019 in the SAR.

NC Status: Closed


Standard & Requirement: ST 5, ID 5B, 3.2.2


Where a Reporting Period other than 12 months is used the BP has justified the Reporting Period used to the CB, but has not recorded the Reporting Period dates and its justification in the SAR

Identify all non-conformities and observations raised/closed during the evaluation (a tabular format below may be used here). Please use as many copies of the table as needed. For each, give details to include at least the following:

- applicable requirement(s) - grading of the non-conformity (major or minor) or observation with supporting rationale - timeframe for resolution of the non-conformity - a statement as to whether the non-conformity is likely to impact upon the integrity of the

affected SBP-certified products and the credibility of the SBP trademarks.



Timeline for Conformance: By the next surveillance audit, but no later than 12 monhts from report finalisation date


The BP updated the reporting period for 2019 to 11 June – 31 December on page 1 of the SAR. The justification is included in the first data table of SECTION B: Energy use for biomass production, PART 2 – Biomass production chain.


Appropriate steps have been taken to close this CAR.

NC Status: Closed


Standard & Requirement: ST 5, ID 5B, 4.1.1


The SBR indicates that the BP sources primary feedstock, but the SAR does not include an input group for primary feedstock. It was found during the audit that only secondary feedstock is sourced and that there are plans to source tertiary feedstock. Timeline for Conformance: By the next surveillance audit, but no later than 12 monhts from report

finalisation date


Review of the updated SBR and SAR.


The total volume of primary feedstock was updated to zero.

NC Status: Closed

NC number 04 NC Grading: Observation

Standard & Requirement: ST 5, ID 5C, 4.1.2


1. Shavings from kiln-dried lumber at the planer mill in Saint Leonard have not been sourced as feedstock yet, but may be in the next few months. This feedstock is currently classified as secondary in the SAR and associated documents, but since it is waste material from kiln-dried lumber it is considered tertiary by SBP (see definition for “SBP-compliant tertiary feedstock” in the SBP Glossary of Terms and Definitions).2. The Static Biomass Profiling Data Sheet (SBPD) includes percentage for shavings (21%) and green sawdust



(79%). Since the first batch is not complete, this should be updated in time to deliver the first set of GHG data to the BP’s customer(s). Timeline for Conformance: Other


Revised SAR and SBPD


Item 1 has been addressed in the SAR; the BP updated the Feedstock IDs and added another to cover the shavings as Tertiary Feedstock. Refer to FEEDSTOCK ID# 4- Saint Leonard Sawmill – Shavings in SECTION A: Input Groups for Biomass Production, Feedstock sourcing and certification. Procedures do not mention feedstocks by primary, secondary or tertiary, but rather by name (e.g., shavings). Thus, item 1 of the OBS is closed. Review of the updated SBPD. The feedstock discription has been revised.

NC Status: Closed


Standard & Requirement: ST 5 ID 5B, 6.2.4, ID 5B, 6.2.6


The BP and the service provider at the Port of Belledune have not formally agreed upon how often energy consumption at the Port (e.g., diesel, electricity usage) will be recorded and reported to the BP. This also should be stated in procedures or another pertinent document. Timeline for Conformance: Other

Response is optional


Review of the updated procedures (page 5 – section 4.7.5).


The process for collecting energy consuption will be reported on an annual basis.

NC Status: Closed


Standard & Requirement: ST 5, ID 5D, 2.6




Procedure 4 covers ID 5A, 2.3.2, but the BP has not addressed ID 5D, 2.6 yet in its procedure. Timeline for Conformance: Other

Response is optional


OBS 64 is covered with the addition in section 4.4 in our revised procedure 4.0 Collection and Communication of Data.


The PBid values have been addressed in procedures as the BP has stated.

NC Status: Closed



11 Certification decision Based on the auditor’s recommendation and the Certification Body’s quality review, the following certification decision is taken:

Certification decision: Certification approved

Certification decision by (name of the person): Theodore Brauer

Date of decision: 12/Jul/2019

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