Assessment of stakeholder
consultation for Preferred by
Nature’s certification
of AS Graanul Invest (Estonia)
based on SDE+ requirements for
biomass energy

20 May 2022

Table of contents
ABBREVIATIONS................................................................................................................................ 4
EXECUTIVE SUMMARY ...................................................................................................................... 5
FINDINGS............................................................................................................................................. 5
RECOMMENDATIONS ............................................................................................................................. 7
1. BACKGROUND............................................................................................................................... 8
1.1. TERMS OF REFERENCE ..................................................................................................................... 8
1.2. THE SDE+ SCHEME ......................................................................................................................... 9
1.3. GRAANUL EVALUATIONS ................................................................................................................ 10
2.

APPROACH TO ASSIGNMENT ................................................................................................... 11

3.

BEST PRACTICE FOR STAKEHOLDER CONSULTATIONS ............................................................. 12

3.1. GLOBAL BEST PRACTICE ................................................................................................................. 12
3.2. STAKEHOLDER CONSULTATION UNDER SDE+ ..................................................................................... 12
3.3. DISCUSSION................................................................................................................................. 13
3.3.1. BEST PRACTICE FOR CERTIFICATION STAKEHOLDER CONSULTATION ......................................................... 13
3.3.2. INCENTIVES FOR QUALITY STAKEHOLDER CONSULTATION ..................................................................... 13
3.3.3. STAKEHOLDER RESPONSE RATES ..................................................................................................... 13
3.3.4. CONFORMITY VERSUS RISK-BASED APPROACH ................................................................................... 13
3.3.6. DOCUMENTATION OF STAKEHOLDER CONSULTATION .......................................................................... 14
3.3.7. MULTI-STAKEHOLDER DIALOGUE AT SYSTEM LEVEL............................................................................. 14
3.4. CONCLUSION ............................................................................................................................... 15
4.

STAKEHOLDER CONSULTATION FOR GRAANUL ....................................................................... 15

4.1. SCOPE CHANGE AUDIT 2019/2020.................................................................................................. 15
4.2. RE-ASSESSMENT AUDIT 2021/2022 ................................................................................................ 16
4.3. DISCUSSION................................................................................................................................. 16
5.

RESPONSE TO STAKEHOLDER CONCERNS ................................................................................ 20

5.1. KEY ISSUES AND THE SDE+ RISK-BASED APPROACH............................................................................. 20
5.2. WOODLAND KEY HABITATS (WKH) ................................................................................................. 20
5.3. NATURA 2000 SITES ..................................................................................................................... 21
5.4. CULTURAL VALUES (INCLUDING “CROSS TREES”) ................................................................................. 22
5.5. THREATENED ANIMAL SPECIES ......................................................................................................... 22
5.6. WATERSHEDS .............................................................................................................................. 23
5.7. PEATLANDS ................................................................................................................................. 24
5.8. CARBON STOCKS .......................................................................................................................... 25

6.

RISK-BASED APPROACH AND SITE-BASED AUDITING ............................................................... 27

7.

NGO PERSPECTIVES ON BIOMASS USE FOR BIOENERGY .......................................................... 27

ANNEX 1: KEY DOCUMENTS, STAKEHOLDER CONSULTATIONS AND COMMENTS ........................... 29
ANNEX 2: ASSESSMENT OF GRAANUL’S RESPONSE TO STAKEHOLDER COMMENTS BY PREFERRED
BY NATURE (2019/2021 EVALUATION) ........................................................................................... 33
ANNEX 3: COMPARISON OF SDE+ AND SBP ID2E STAKEHOLDER CONSULTATION REQUIREMENTS 34
ANNEX 4: OVERVIEW OF STAKEHOLDER ENGAGEMENT ................................................................. 35
REFERENCES .................................................................................................................................... 36

3

Abbreviations
ASI
BP
CAB
CB
ELF
FMU
FSC
HCV
ISEAL
NEa
NEPCon
PEFC
PfN
RBA
RRA
RVO
SBE
SBP
SBP ID2E
SBR
SDE+
SOMO
WKH

Accreditation Services International
Biomass Producer
Conformity Assessment Body (see also CB)
Certification Body (another term for conformity assessment body).
Estonia Fund for Nature
Forestry management unit
Forest Stewardship Council
High Conservation Value
ISEAL Alliance – international organisation that develops principles and
codes
of
best
practice
for
certification
systems.
https://www.isealalliance.org/
Nederlandse Emissieautoriteit / Dutch Emissions Authority
CAB rebranded as Preferred by Nature on 1 October 2020
Programme for the Endorsement of Forest Certification
Preferred by Nature
Risk-based Approach (SDE+)
Regional Risk Assessment (SBP)
Rijksdienst voor Ondernemend Nederland / Netherlands Enterprise Agency
(responsible for effective execution of the SDE system including the
assessment of certification schemes).
Supply Base Evaluation
Sustainable Biomass Programme
Instruction Document 2E: SBP Requirements for Risk Based Approach for
Biomass Category 2 – Demonstrating Compliance with the Netherlands
SDE+ Risk Based Approach Sustainability Requirements for Biomass
Category 2
Supply Base Report
Stimulering Duurzame Energieproductie/Encouraging Sustainable Energy
Production
Centre for Research on Multinational Corporations
Woodland Key Habitat

4

Executive Summary
Findings
The Dutch Emissions Authority (Nederlandse Emissieautoriteit – NEa) is reviewing the
functioning of the Conformity Assessment Body (CAB) that provided the certification of the
forest product company Graanul under the SDE+ system that ensures the sustainability of
biomass imported to the Netherlands for power generation.
A large proportion of biomass used for power in the Netherlands is imported from Estonia. In
order to qualify for subsidies, biomass suppliers must meet the sustainability criteria of
Stimulering Duurzame Energieproductie/Encouraging Sustainable Energy Production
(SDE+). The Minister of Economic Affairs and Climate Policy recognises certification schemes
that comply with SDE+ criteria based on an assessment carried out by Rijksdienst voor
Ondernemend Nederland/Netherlands Enterprise Agency (RVO). Stakeholder consultation is
a key element of this certification system, although it must be said upfront that this element of
the system is complex and opaque. In recent years criticism of the use of biomass for power
has increased in the Netherlands and elsewhere, and some specific accusations have been
made in the press based on a report by SOMO in 2021.
International Conflict and Security Consulting (INCAS) was asked to review whether the CAB
has done an adequate job regarding the stakeholder consultation process in the context of
certification for SDE+. Stakeholder consultation was carried out in 2019 and 2021 by Graanul
to support its four operations in Estonia and audited by the conformity assessment body (CAB)
Preferred by Nature (PfN). PfN also carried out stakeholder consultations and audited the
consultations carried out by Graanul. These consultations were intended to comply with the
Sustainable Biomass Programme Instruction Document 2E: SBP Requirements for Risk
Based Approach for Biomass Category 2 (SBP ID2E). SBP ID2E is a scheme recognised by
the Minister of Economic Affairs and Climate Policy as applying the SDE+ criteria.
INCAS’ assessment consisted of interviews with key actors, review of evaluation
documentation and associated reports and standards as well as regular discussions with NEa.
INCAS found that while the stakeholder consultation carried out by Preferred by Nature met
the requirements of the SBP ID2E standard, there were several factors that contributed to the
criticism of the process by NGOs in Estonia and the Netherlands. These factors described
below relate to the changing views of NGOs relating to the use of forestry biomass for power
generation, the quality of the stakeholder consultation in the SBP ID2E system and the related
expectations of stakeholders from the process. INCAS has made several recommendations
that will improve the SDE+ system as well as next steps to engage stakeholders more
effectively in the process.
Best practice for stakeholder consultation promotes engagement with affected and interested
parties so that an ongoing dialogue can build trust and promote the understanding of different
perspectives even if these cannot be reconciled. While most third-party certification systems
include stakeholder consultation, they generally do not promote ongoing engagement.
Stakeholder engagement may be promoted in principle, but in practice consultation takes
place within a limited timeframe around audits and is based on requesting stakeholder input
5

on documents relating to certification requirements. There are generally low response rates
and limited time during audits to meet with stakeholders. Best practice stakeholder
engagement needs to be supported by clear and concise reporting and documentation. It must
be said that the quality of reports examined by INCAS is variable, with examples of poor
drafting, repetition, unclear references and linkages between documents and previous
versions and various omissions meaning that the reader needed significant background
knowledge of the issues and understanding of the processes concerned. In addition, the audit
reports also do not detail the rationale for how the auditors come to their conclusions on the
treatment of stakeholder input.
SDE+ stakeholder consultation requirements are on a par with other third-party certification
systems but could be improved by requiring meetings between auditors and stakeholders
during audits; promoting ongoing engagement between companies and stakeholders; and
providing more detail on the rational used by CABs in their review of how stakeholder
comments are treated by companies undergoing certification.
A key challenge of SDE+ is consultation on the Risk-based Approach for Category 2 forestry.
This requires consideration of national, and even international issues such as the carbon
balance of national forestry systems. There may be conflicting science, evidence and intense
debate at policy level. It is challenging for auditors to address national or international issues
with limited time during the evaluation of a company. The process can also identify concerns
from stakeholders that go beyond the scope of certification and relate to ongoing national
policy discussions. In addition to the challenge faced by auditors, the process can also raise
expectations among stakeholders that the evaluation process can somehow adjudicate on
these broader issues.
In the case of the Graanul evaluation, INCAS found that the SDE+ stakeholder consultation
process was followed. Preferred by Nature researched the issues raised by stakeholders and
responses given by Graanul. This involved undertaking desk research and interviews with
experts. Preferred by Nature aimed to understand if the criteria of SDE+ had been met. They
did not make judgements on issues beyond the scope of SDE+ criteria. At the same time, they
did note that some of the issues were challenging to deal with within the limited timeframe of
an evaluation.
Third-party certification systems usually have multi-stakeholder mechanisms, or ‘roundtables’
at the system level that set the standard and certification requirements and approve nationallevel interpretations. Risk-based approaches with a national, or regional scope are a relatively
new approach for third-party certification but can also be dealt with by system level multistakeholder mechanisms. For example, this is the case for SBP in the development of
Regional Risk Assessments. This approach allows the certification system to invest the
necessary time and expertise to review the science and political dialogues around national or
international-level issues.
There has been progress on some issues raised by stakeholders albeit at a relatively slow
pace. For example, the protection provided by the Woodland Key Habitats (WKH) designation
was raised by stakeholders as a concern and led to the development of an information system
to support the identification of WKH sites that is used by Graanul. Although there has been
progress, much of it would seem to be initiated outside the SDE+ process. The WKH site
6

identification was initiated by discussions in the Forestry Stewardship Council (FSC) and the
database developed by NGOs. The issues of unsustainable forestry in and around Natura
2000 sites was initiated by legal action taken by an Estonian NGO at EU-level which prompted
action by the European Commission.
In discussion with NGOs from Estonia and the Netherlands it became clear that there is strong
and increasing opposition to the use of biomass for power generation. This can be seen as
the underlying cause of the focus that NGOs are placing on SDE+ process in Estonia. The
development of SDE+ in 2013 included civil society with environmental NGOs agreeing to the
SDE+ sustainability criteria. However, INCAS spoke with NGOs that were involved in the 2013
process and they stated clearly that they now believe that the use of forestry biomass has
detrimental impacts on biodiversity and climate. They are not opposed to the use of forestry
biomass per se but believe that priority should be given to other uses that minimise the volume
of biomass required while at the same time sequestering carbon such as bioplastics. They
would also like to see renewable energy types that do not have other renewable energy
alternatives, such as biofuels for aviation, being prioritised over power generation. The main
driver of this NGO approach appears to be ensuring effective ways to reduce greenhouse gas
emissions. However, there is also concern about the impact on biodiversity of increasing the
demand on forests. The expectation is that lower volumes of biomass will be required for
alternative energy and biomaterials and pressure on forests with thereby be reduced.

Recommendations
Based on the above conclusions, INCAS proposes the following recommendations for
consideration by NEa:


Engage NGOs in a dialogue to understand their concerns around the use of biomass for
energy. This should include Dutch and International NGOs as well as those from Estonia
and other source countries.



Establish a multi-stakeholder mechanism as part of the SDE+ framework to deal with
system-level issues on an ongoing basis. This could include the oversight/review of
RBAs as well as revising SDE+ criteria on an ongoing basis. This would allow for review
of issues such as peatland and carbon stocks in Estonia.



Review the stakeholder consultation requirements of SDE+ to potentially include:
- Meetings with stakeholders during evaluation audits.
- Improved documentation by CABs on their review of issues raised in stakeholder
consultations giving a summary of methodology and rationale for reaching their
conclusions.
- Ways and means to improve ongoing stakeholder engagement. For example,
companies could be required to demonstrate that they have regular meetings
with stakeholders and/or have mechanisms in place to allow stakeholders to raise
concerns on an ongoing basis so that complaints can be dealt with as they arise.



Set up limited series of roundtable meetings in Estonia to engage with Estonian
government, NGOs and industry to look at the issues raised by stakeholders.

7

1. Background
1.1. Terms of Reference
The Dutch Emission Authority (Nederlandse Emissieautoriteit – NEa) engaged INCAS in
November 2021 to assess the stakeholder consultations carried out as part of the audit of four
operations owned by Graanul (Graanul Invest AS – Imavere factory; Ebavere Graanul OÜ;
Helme Graanul OÜ; and Osula Graanul OÜ) under the Sustainable Biomass Program scheme
‘NL SDE controlled (ID2E)’ standard (SBP ID2E). This standard has been recognised by the
Ministry as effectively applying the SDE+ criteria.
NEa is the independent national authority which implements and monitors the market tools
available that contribute to a climate-neutral society. The NEa, among other tasks, supervises
the certification of biomass pellets used in the Netherlands to generate energy according to
the sustainability criteria for solid biomass under the SDE+ scheme.
SOMO (Centre for Research on Multinational Corporations), a Dutch-based NGO, published
a report on the forestry activities of AS Graanul Invest, which criticised the SDE+ certification
process. The SOMO report was reviewed by Indufor Oy from an industry perspective. Indufor
Oy concluded that there were no substantial issues to answer. NEa engaged INCAS to
undertake an independent review of the effectiveness of the stakeholder consultation work
carried out by Preferred by Nature, a conformity assessment body (CAB) recognised by the
Minister of Economic Affairs and Climate Change Policy, and which carried out the Graanul
Invest certification using the SBP ID2E scheme.
The assessment covered five elements related to the Graanul Invest certification:
1.
2.

3.
4.
5.

The stakeholder consultation carried out by Graanul as part of their preparation for
audit by Preferred by Nature
The Preferred by Nature evaluation of how adequately Graanul addressed the
comments from stakeholders and specifically the impact of the comments on the
risk assessment.
The second stakeholder analyses carried out by Preferred by Nature.
The Preferred by Nature evaluation if the comments from stakeholders (from its
own analysis) have an impact on the risk assessment.
The second review currently being carried out by Preferred by Nature in
November/December 2021.

NEa noted that they required an understanding of the details of the external stakeholder
analysis and requested that the assessment focus on key issues raised in the stakeholder
consultation:




Woodland Key Habitats
Natura 2000
Threatened animal species

8





Cultural values (including “cross trees”)
Watersheds
Peatlands

NEa also requested that the assessment cover the following questions:
1. Have all stakeholders been approached that should have been approached
(sufficiently representative)?
2. Have stakeholders been approached with the correct question (and was it sufficiently
clear what was asked from them)?
3. Has Preferred by Nature evaluated the input from the stakeholder analysis
adequately?
i. Are signals and the issues raised investigated sufficiently?
ii. Is it justified (or not) to include the input from stakeholders in the risk
assessment?
4. Is it sufficiently transparent to the stakeholders what was done with their input?

1.2. The SDE+ Scheme
The SDE+ system (Stimulering Duurzame Energieproductie/Encouraging Sustainable Energy
Production) supports the production of renewable energy in the Netherlands by providing
subsidies to energy producers to compensate for the higher cost of renewable energy
production. Producers receive financial compensation for every unit of renewable energy they
generate.
SDE+ covers a range of renewable energy processes including the co-firing of woody biomass
in coal power plants. A 2013 agreement allowed for the production of 25 PJ of energy from
woody biomass under SDE+ provided that the biomass complied with the NTA8080/Better
Biomass sustainability standard. A working group of energy producers, government
organizations and NGOs was set up to develop additional sustainability criteria for
implementation through legislation and regulation. This culminated in the approval of the
Energy Agreement which was signed by 47 organizations including government, NGOs, trade
unions, industry and financial organisations.
A verification protocol was developed by the Netherlands Enterprise Agency (RVO), based on
the sustainability principles and criteria contained in the Energy Agreement, to demonstrate
compliance with the SDE+ sustainability criteria. SDE+ allows for the direct verification of
biomass producers (BPs) and forestry management while also recognising existing
certification systems such as SBP and FSC that have been determined to effectively apply the
SDE+ criteria. The certification systems can also be partially recognised meaning that any
gaps between a certification’s systems sustainability criteria and those of SDE+ can be
bridged through an additional verification audit. SBP ID2E is one such certification scheme
that was developed specifically by SBP to audit SDE+ criteria. It has been recognised by the
Ministry NEa as effectively applying the SDE+ criteria.
SDE+ defines different types of biomass. Two categories are based on the size of the forestry
management units (FMUs) undergoing evaluation. Category I are FMUs greater than 500

9

hectares and Category 2 are FMUs less than 500 hectares. SDE+ allows for a Risk-Based
Approach (RBA) to be used for Category 2 biomass up until the end of 2022. The RBA
assesses risks against criteria and indicators in the SDE+ Verification Protocol/ SBP ID2E.
Risks are classified as ‘low’ or ‘specified’. Where issues are assessed as being a ‘specified
risk’, mitigation measures are required to be put in place and monitored. For low-risk issues,
mitigation measures are not required.

1.3. Graanul Evaluations
The main focus of the assessment was to review the stakeholder consultations carried out as
part of the evaluation, or audit, of Graanul using the SBP ID2E. There were two main
evaluations carried out by Preferred by Nature: in November 2019 (finalised in February 2020)
and November 2021 (finalised in February 2022). There was also a surveillance audit carried
out in August 2021, but this did not include a stakeholder consultation. Under SBP ID2E
stakeholder consultations are only required during full audits every five years.
The first evaluation (2019/2020) is referred as a ‘Scope change audit’ because Graanul was
previously certified by SBP and was expanding its certification to add the specific SBP ID2E,
presumably to facilitate access to the Dutch market. Under SDE+ biomass producers are
required to carry out a Risk-based Approach (RBA) as well as a Supply Base Report. As noted
above, the RBA is relevant for Category 2 biomass (from small forest management units of
less than 500ha). The preparation of the RBA and Supply Base Report require biomass
producers to carry out a stakeholder consultation. The RBA and Supply Base Report were
prepared by Graanul in advance of the audit in October 2019.
During the Fourth Surveillance Audit in August 2021, a stakeholder consultation was not
undertaken but the publication of the SOMO report, ‘Wood Pellet Damage’, which had been
published in July 2021 was noted.
The ‘Re-assessment’ audit was carried out in 2021/2022 in response to the concerns raised
in the SOMO report. This was a full audit, and an updated RBA and Supply Base Report were
prepared in November 2021 with stakeholder consultation. Graanul used the SOMO report as
input as well as a report responding to the SOMO claims from the industry perspective – ‘Peer
Review of the Wood Pellet Damage Report’ by Indufor Oy, which was published in September
2021.
Graanul has four operations which ware audited and considered to be in compliance with SBP
ID2E. These are: Graanul Invest AS – Imavere factory; Ebavere Graanul OÜ; Helme Graanul
OÜ; and Osula Graanul OÜ. The audit reports for each of the four Graanul entities are identical
in terms of their stakeholder consultation and so the INCAS team based its review on one of
these reports for each audit cycle.
In addition to the SPB ID2E evaluations and related reports, it is worth noting the SBPendorsed Regional Risk Assessment (RRA) for Estonia. Although this report is not part of the
SDE+ process, it takes a similar approach to the RBA and reviewed the same issues raised
during the SBP ID2E evaluation of Graanul as well as consulting similar stakeholders. Version
1.0 of the RRA for Estonia was published in 2016 based on stakeholder consultation carried

10

out in 2015. The RRA was updated in 2021 (Version 1.1.) and included an additional round of
stakeholder consultation. Both Version 1.0 and 1.1 were prepared by Preferred by Nature for
SBP.
These various reports/assessments are summarised in Table 1 below with additional details
provided in Annex 1.
Table 1: Timeline of Evaluations and Related Reports (evaluation reports in Bold)
Date
22.04.2016
16.10.2019
26.10.2019
03.02.2020
24.02.2020
07.2021
09.08.2021
27.09.2021

Document / Audit
SBP-endorsed Regional Risk Assessment for Estonia, version 1.00.
Graanul Invest SDE+ COC and RBA [Risk-based Approach], Cat .2,
Estonia, Version for SBP ID2E
OÜ Osula Graanul Supply Base Report
Updated: Graanul Invest SDE+ COC and RBA, Cat .2, Estonia, Version
for SBP ID2E.
NEPCon Evaluation of Osula Graanul OÜ Compliance with the
SBP Framework: Public Summary Report, Scope Change Audit
Wood pellet damage How Dutch government subsidies for Estonian
biomass aggravate the biodiversity and climate crisis
Preferred by Nature Evaluation of Graanul Invest AS – Imavere factory
Compliance with the SBP Framework: Public Summary Report, Fourth
Surveillance Audit
Dutch Biomass Certification Foundation (DBC) Peer Review of the
Wood Pellet Damage Report in Estonia by SOMO

22.10.2021

SBP-endorsed Regional Risk Assessment for Estonia, version 1.1.

12.11.2021

Graanul Invest SDE+ COC and RBA Cat .2 Estonia

12.11.2021

Supply Base Report: Graanul Invest AS – Imavere Factory
Preferred by Nature Evaluation of Osula Graanul OÜ Compliance
with the SBP Framework: Public Summary Report, Reassessment

23.02.2022

Author
NEPCon
Peterson
Projects B.V.
OÜ
Osula
Graanul
Peterson
Projects B.V.
NEPCon
SOMO
Preferred
Nature

by

Indufor Oy
Preferred by
Nature
Peterson
Projects/Graa
nul
Graanul
Preferred by
Nature

2. Approach to Assignment
The INCAS team reviewed documentation related to the Preferred by Nature audits of Graanul
as well as the SOMO and Indufor Oy reports and the SBP Regional Risk Assessment for
Estonia. Interviews with key stakeholders were undertaken and there were weekly calls with
the NEa team to report back and discuss findings. The second Preferred by Nature audit, the
re-assessment report, became available in March 2022. Additional interviews with
stakeholders were then undertaken to discuss the second Preferred by Nature audit results
and stakeholder consultation process.
In framing this report, the INCAS team compared the stakeholder consultation carried out by
Preferred by Nature to the requirements of SBP ID2E as well as the approach to stakeholder
consultation by other certification systems and international best practice on stakeholder
consultation and engagement.

11

The INCAS team also reviewed the specific issues raised by the main stakeholder ELF in the
Graanul and Preferred by Nature stakeholder consultations to understand if the responses
and follow-up action by Preferred by Nature were adequate. The responses and follow-up
were reviewed in terms of the SDE+ SBP ID2E framework and as well as what could be
considered adequate in terms of best practice for stakeholder consultation.
The following stakeholders were consulted: Graanul, ELF, Preferred by Nature, Greenpeace
Netherlands, Natuur & Milieu, Accreditation Services International (ASI). The NGO Hiite Maja
Foundation was also contacted but due to language issues they simply referred INCAS to their
original responses.

3. Best practice for stakeholder consultations
3.1. Global Best Practice
There are many international standards relating to best practice for stakeholder consultation.
Standards and guidelines from the International Finance Corporation (IFC), AccountAbility,
and the International Council of Mining and Metals (ICMM) are among those most frequently
referenced and used by practitioners, business and NGOs. Although there are different
approaches they agree on fundamental principles.
Best practice stakeholder engagement requires the active and ongoing engagement of key
stakeholders. This should be done transparently and openly. Detailed discussions on
contentious issues may be required, and while agreement on all sides is not the aim, setting
out clear positions, and understanding and engaging with others’ views is essential. Best
practice engagement also implies that stakeholder views will be considered in decisionmaking and that best efforts will be made to address them. Consultation should be targeted to
those directly affected, accompanied by good and detailed information, meaningful, two-way
and reported back to those consulted.

3.2. Stakeholder Consultation under SDE+
The requirements for biomass producers regarding stakeholder consultation are laid out in the
Verification Protocol for Sustainable Solid Biomass for Energy Applications (January 2021)
and these have been incorporated into SBP ID2E almost verbatim (see comparison in Annex
3). In addition, SBP ID2E notes that the requirements set out in SBP Framework Standard 2:
Verification of SBP-compliant Feedstock are also applicable. These require that stakeholders
should be given one month timeframe to respond; and that a stakeholder consultation is
required for the first audit and, after that, every five years during re-evaluation i.e.,
consultations are not required during annual surveillance audits. The Framework Standard
also notes that the ‘principles in Stakeholder Consultation for Forest Evaluations FSC-STD20-006 (V3-0) EN are recommended as good practice.’
There are also requirements for certification bodies (CBs), another term for conformity
assessment bodies CABs), detailed in SBP Standard 3 - Certification Systems. Requirements

12

for Certification Bodies v1.0. This document requires that CABs carry out their own
stakeholder consultation during the first audit and five-year re-evaluation. The CAB also needs
to check if stakeholders’ comments were adequately addressed by the biomass producer.
While stakeholder consultations only take place every 5 years, the requirements state that any
submissions from stakeholders ‘shall be recorded and evaluated during, or prior to the next
audit’.

3.3. Discussion
3.3.1. Best practice for certification stakeholder consultation
While the SDE+ / SBP ID2E requirements form a good basis for stakeholder consultation there
are several important gaps when compared to best practice for stakeholder consultation. As
noted above, best practice recommends that organisations develop relationships with key
stakeholders rather than periodically requesting feedback on documentation prior to audits.
This allows for ongoing exchange and understanding of issues of concern rather than a onceoff, often written, exchange in the context of periodic audits.
Some certification systems like the Roundtable on Sustainable Biomaterials (RSB) require a
physical meeting with stakeholders during the site audit. Experience has shown that this allows
for more exchange on concerns between the company and stakeholders with the auditor
playing a neutral role.

3.3.2. Incentives for quality stakeholder consultation
Third-party certification approaches generally do not incentivise auditors to go beyond
requirements to apply best practice or undertake more in-depth stakeholder consultation. In
fact, the commercial nature of certification can incentivise CABs to reduce time spent on
stakeholder consultation. When CABs submit offers to companies that are receiving
competing offers from other CABs, they have an incentive to reduce time spent on an audit
and thereby the cost to the client. Spending additional time on stakeholder consultation could
make bids less competitive. It also means that if a CAB wins a contract, they are unlikely to
increase staff costs by engaging in additional outreach and discussions with interested parties.
An approach that encouraged ongoing stakeholder consultation and engagement by the
biomass producer during normal operations would improve the quality of engagement during
audits.

3.3.3. Stakeholder response rates
An additional challenge for certification systems is the response rate, or willingness of
stakeholders to engage with companies and the certification process. This can be due to time
constraints but also lack of confidence that issues raised will be dealt with effectively in the
auditing process. The situation is exacerbated when engagement is limited to sending out
documents at audit time rather than ongoing dialogue and engagement.

3.3.4. Conformity versus Risk-based approach

13

Stakeholder consultation under certification systems is usually focussed on the conformity of
the company undergoing certification. For example, the FSC standard on stakeholder
consultation states: ‘The certification body shall consult with a range of stakeholders who can
provide relevant information as to an applicant's conformity with the environmental, legal,
social, and economic requirements of the Forest Stewardship Standard.’
The approach was set up to gather additional information on the company’s adherence to the
requirements of the standard. Local stakeholders but also national-level NGOs can give
important direct feedback on examples of where companies are not adhering to certification
principles and criteria. For example, there can be direct observation of instances of pollution,
clear-cutting or mistreatment of local communities. The system can work quite well at site level
when stakeholder can act as ‘whistle blowers’ to identify issues that auditors might otherwise
miss. Certification systems also have mechanisms to protect the anonymity of stakeholders
that highlight such issues.
Certification stakeholder consultations were envisaged to deal with specific ‘sites’ or
‘operations’ with clearly defined boundaries and management responsibilities – for example a
facility, a farm, or forestry area. While certification can be applied to multiple-sites through
group certification, processes like stakeholder consultation were not developed to deal with
‘bigger picture’ issues over large regions or entire countries, such as the state of endangered
species, or the prevalence of unsustainable forestry practices near waterbodies. With the
SDE+ approach to Category 2 forestry, the Risk-based Approach, requires that the audit of a
company includes a review of national or international level issues. The science on some
issues such as carbon balance can be contradictory and the issue highly politicised. This
makes the evaluation of these big picture issues within a framework designed for specific sites,
extremely challenging for an auditor with limited capacity to invest in research and consultation
necessary to make a judgement when companies and stakeholders have divergent oppinions.

3.3.6. Documentation of stakeholder consultation
Best practice stakeholder engagement needs to be supported by clear and concise reporting
and documentation. While the comments received by stakeholders, the response from the
company and the conclusions of the CAB on the company’s response are well documented in
Graanul’s RBAs, the conclusions of the CAB do not provide any rationale for how the
conclusions were reached. It would be preferable for the CAB evaluation reports to provide a
summary of literature and experts consulted, reference to site visits if they were undertaken,
and the CABs own experience of the issue. This would give a clearer picture of how the CABs
conclusions were reached. Making this information available to stakeholders would also
provide greater transparency in the overall process.

3.3.7. Multi-stakeholder dialogue at system level
Credible certification systems also have multi-stakeholder dialogue at the level of the
development and revision of the standard and requirements itself. According to ISEAL Codes
of Good Practice standards should be revised every five years with a process that allows for
input from the general public, as well as members of the standards organisation. This enables

14

standards to review their effectiveness and take account of new developments in science and
society.

3.4. Conclusion
SDE+ stakeholder consultation approach cannot be considered best practice mainly because
it does not require:




Ongoing engagement between stakeholder and the biomass producers;
Direct meetings between stakeholders and the auditors, or companies undergoing
certification; and
Details of how CABs reach their conclusions on the issues raised by stakeholders.

SDE+ could improve the quality of stakeholder consultation by incorporating requirements on
these issues in the Verification Protocol and certification systems recognised under SDE+
such as SBP ID2E.
An important aspect of stakeholder consultation in standards and certification systems is in
the multi-stakeholder approach to standard development. Multi-stakeholder mechanisms,
while time consuming, do enable standard systems to ensure that the certification
requirements take account of new policy and scientific information and remain realistic in terms
of implementation. Although developed with multi-stakeholder input, the SDE+ system does
not have a mechanism to update requirements on a regular basis based on new thinking from
NGOs, industry and other stakeholders. SDE+ should consider establishing such a
mechanism.

4. Stakeholder Consultation for Graanul
4.1. Scope change audit 2019/2020
The initial stakeholder consultation by Graanul was not undertaken at the time of the first
(Scope Change) audit in November 2019 and was identified as a non-conformity by Preferred
by Nature. Graanul carried out its stakeholder consultation for the RBA report from 22
November to 22 December 2019 with the report being sent to 11 Estonian stakeholders (see
Annex 4). The Supply Base Report was published on 21 December 2019 on the company
website and also sent to 11 stakeholder organisations. Three responses were received on the
RBA report and Graanul included these in the RBA report.
Preferred by Nature undertook its stakeholder consultation from 5 November to 5 December
2019 contacting 30 organisations as well as publishing an announcement on the Loodusaeg
mailing list with approximately 1,000 subscribers. No direct responses were received during
this period but Preferred by Nature was copied on a letter from one stakeholder (ELF)
addressed to Graanul dated 20 December. Preferred by Nature also called the main
stakeholders on 11 December and succeeded in speaking to one of them. Feedback on this
conversation was provided to Graanul which included the comments to the RBA (as one of
the three stakeholders mentioned above).

15

4.2. Re-assessment audit 2021/2022
For the Reassessment audit in 2021, consultation on the RBA report was undertaken from 5
October to 5 November 2021. In addition, the SOMO and Indufor Oy reports were considered
as stakeholder input and integrated into the RBA. The RBA notes that ten relevant stakeholder
groups received the documents, two provided feedback, while two stakeholders responded
orally that they supported the Graanul approach. Two stakeholders responded to the
consultation. Graanul noted that one stakeholder (ELF) ‘raised the same cases and questions
like in SOMO report’. The second stakeholder represents small forest owners and questioned
international sustainability criteria as well as the designation of specified risks. The Preferred
by Nature consultation was carried out from 21 October to 20 November 2021 with outreach
to 29 organisations and publication on the Loodusaeg mailing list.

4.3. Discussion
It is clearly a matter of concern that Graanul did not carry out any stakeholder consultation
ahead of the audit in 2019. Graanul noted confusion with the requirements as being the reason
for the consultation not being carried out but SBP ID2E clearly lays out the requirements for
stakeholder consultation and it is not a long document (10 pages on requirements). While
there could be confusion between the Supply Base Report consultation and that of the Chain
of Custody Risk-based Approach document, neither consultation was carried out ahead of the
audit. However, given the overall complexity of the SDE scheme, potential confusion between
SBP requirements (the certification was already in place for Graanul) and the SBP ID2E
requirements, and the unlikelihood of a biomass producer knowingly scheduling an audit
without carrying out a key part of the required preparation, credence should be given to the
Graanul claim.
According to the SBP standard (see Table 2), the intent of the conformity assessment body
CAB) stakeholder consultation has two aspects: to verify that management systems of the site
are working; and to check the response of the biomass producer to the issues raised during
the BPs stakeholder consultation.
Table 2: Requirements for CAB Stakeholder Consultations
SBP Framework Standard 3: Certification Systems. Requirements for Certification Bodies
‘9.2 . . .CBs are not expected to identify and consult all possible stakeholders, but shall consult with
a sufficient number of affected stakeholders in order to verify that management systems
(documented or undocumented) are working effectively and consistently under the full range of
conditions present in the area under evaluation.’
‘9.3 The CB shall consult with stakeholders included in the BPs SBE [Supply Base Evaluation]
consultation and the Locally Applicable Verifiers (LAVs) process. As a part of the CB consultation
the CB shall determine if stakeholders’ comments were adequately addressed by the BP.’
Table 3: Requirements for Biomass Producer (BP) Stakeholder Consultations
SBP Framework Standard 2: Verification of SBP-compliant Feedstock

16

Instruction Note 2B: Supply Base Evaluation Stakeholder Consultation – Requirements for Biomass
Producers
1 General Requirements
1.1 The BP shall proactively and transparently engage affected stakeholders in its SBE [Supply
Base Evaluation] planning and monitoring processes, proportionate to the scale, intensity and risk
of management activities. It shall engage interested stakeholders on request.
1.2 Affected stakeholders shall be notified in advance of the SBE if feedstock harvesting is likely to
negatively impact on them. They shall also be provided with opportunities for engagement in order
to identify ways to avoid or reduce any negative impacts.
1.3 Interested stakeholders shall be notified at least one month in advance of the end of the SBE,
and shall be provided with opportunities for engagement in management planning and monitoring
processes likely to impact on their interests.
2 Stakeholder Concerns
2.1 The BP is not required to reach a consensus with stakeholders, but shall consider relevant
stakeholder concerns.
Instruction Note 2C: Supply Base Report – Requirements for Biomass Producers
3 Public availability
3.1 The SBR shall be both uploaded onto the BP website and submitted to the SBP no later than
ninety (90) days after the on-site closing meeting at the end of an audit by a CB. SBP shall publish
SBE public summary reports and annual updates on the SBP website.

The stakeholder consultations carried out by Preferred by Nature had very low response rates.
The one set of feedback received (in 2019) was a copy of comments being sent to Graanul as
part of their consultation. With these low response rates, it was helpful that Preferred by Nature
called the main stakeholders. It should also be noted that in its communication with
stakeholders, Preferred by Nature does offer to meet, or set up a call with stakeholders which
is good practice for consultations.
The CAB consultation for the 2019 /2020 audit started before, and ended during, the BP
(Graanul) consultation. This made it impossible for the CAB to receive any feedback from
stakeholders on how their concerns had been dealt with by Graanul. While Preferred by Nature
could make its own assessment on the issues raised by stakeholders and Graanul’s response,
it would have been more informative to have the potential to discuss the counterarguments
put forth by Graanul.
Also due to the timing overlap, the CAB and Graanul consultations appear to be based almost
entirely on the same set of feedback and it is difficult to make a distinction between the CAB
and Graanul consultations based on input received. The most substantive feedback from ELF
(Estonian environmental NGO) was considered as input for both consultations. The second
set of feedback received by Preferred by Nature via a call, concerning mitigation measures
and databases, was passed on to Graanul and by them as a response to its own consultation.
The third set of feedback received by Graanul was editorial in nature. For both the Graanul
and Preferred by Nature stakeholder consultations a total of three stakeholders participated.
In summary, while the stakeholder consultations carried out in 2019 met the ‘letter of the law’
in terms of both the CAB and BP carrying out stakeholder consultations, the overlap in timing
of the consultations was far from ideal.

17

For the reassessment audit in 2021/2022, the BP and CAB stakeholder consultations were
held sequentially. However, Preferred by Nature did not receive any responses most likely
because the two most active stakeholders had already given their feedback to the Graanul
consultation.
NEa identified four questions to guide this assessment. There are listed below with responses
from the INCAS team.
1. Have all stakeholders been approached that should have been approached
(sufficiently representative)?
The group of 11 stakeholders approached by Graanul for both audits represented a
range of NGOs, business associations and academic institutions. Many of the
stakeholders were associations representing groups of NGOs or businesses in
addition to multi-stakeholder certification systems FSC and PEFC. While the group of
stakeholders included environmental NGOs, it did not include civil society
organisations concerned with social and cultural issues such as Hiite Maja Foundation
which had raised concerns about cross trees. The Preferred by Nature consultation
reached out to a far broader group of stakeholders which also included local parish
councils and government institutions and the cultural NGOs including Hiite Maja.
INCAS concludes that while the combined group of stakeholders approached was
sufficient, more effort could have been made by Graanul to reach out to local
communities (via Parish councils) civil society organisations concerned with social and
cultural issues.
2. Have stakeholders been approached with the correct question (and was it
sufficiently clear what was asked from them)?
While the SDE+ system is quite complex and can be confusing to stakeholders, INCAS
found that the communication with stakeholders was quite clear. For example, the
letter sent to stakeholders included the included mitigation measures description,
overview of the supply base and a link to the SBP-approved Regional Risk Assessment
for Estonia. The RBA document was attached to the letter which asked stakeholders
to provide feedback and comments on mitigation measures taken by the Graanul to
mitigate risk of materials coming from WKHs as well as the RBA document. As noted
above the communications also included the offer to speak directly with the
stakeholders by call or direct meeting. This would have allowed any potential lack of
clarity in the communications to be cleared up.
3. Has Preferred by Nature evaluated the input from the stakeholder analysis
adequately?
Overall, the inputs from stakeholders were found to be evaluated adequately in the
context of SDE+ criteria. However, INCAS believes that some of the issues raised are
of a complexity that cannot be analysed effectively in the course of the audit of a single
company and would have benefited from a consultation beyond the scope of a regular
audit, for example via a multi-stakeholder discussion at national or SDE+ system level
(see sections 3.3.7 and 4.4 above).
Preferred by Nature has a good approach for reviewing the stakeholder consultation
analysis based on the experience of its auditors with forestry in Estonia and other
18

certification systems, literature review, consultation with experts. Preferred by Nature
noted that they did not carry out site visits for the Graanul audits because the auditors
were already familiar with several of the sites referenced from audits under other
systems such as FSC and because the auditors have in-depth knowledge of the
forestry sector and related political context in Estonia.
However, in the audit reports, Preferred by Nature does not give any rationale for its
conclusions on the stakeholder consultation. In the 2019 /2020 audit it mostly stated
its conclusion on the quality of Graanul’s response. In the 2021 /2022 audit, it gave an
overall endorsement of Graanul’s response, except for one issue where it issues a
non-conformity due to lack of information to justify a ‘low risk’ designation. Ideally, the
CAB should give a summary of the rationale for its conclusion on each issue citing
sources such as literature review, auditor experience, familiarity with sites etc. This
information could then be shared with stakeholders which would lend more
transparency to the process.
Based on the literature reviews and several conversations with the team, INCAS
believes that Preferred by Nature has evaluated the input and adequately but would
recommend that SDE+ review requirements for CABs to detail the rationale for their
conclusions in audit reports.
i.

Are signals and the issues raised investigated sufficiently?
As noted above, INCAS concludes that the issues raised were investigated
sufficiently in terms of SDE+ requirements but some of the concerns raised
have conflicting science and therefore cannot be resolved with the limited
resources available during the course of an audit.

ii. Is it justified (or not) to include the input from stakeholders in the risk
assessment?
The input from stakeholders was included in the RBA. INCAS agrees with the
Preferred by Nature assessment on most that the input was adequately
addressed in the RBA except for one case where a non-conformity was issued.
There are also two areas where INCAS believes that further investigation is
warranted. These are the issues of peatlands and carbon stocks (see points
5.7 and 5.8 below). As noted in the Graanul RBA, there is a need for better
approaches to assessing the impact of renovating old drainage systems and
assessing the impact of forestry management on carbon balance. While INCAS
agrees with the conclusions of Graanul in the RBA – that the issue is low risk
in terms of Graanul’s operations – both issues have a potential risk at national
level in Estonia and should be reviewed by SDE+.
4. Is it sufficiently transparent to the stakeholders what was done with their input?
Stakeholders have been able to see the treatment of their inputs by Graanul and
Preferred by Nature. This does not mean that the stakeholders agreed with how their
input was dealt with, but the process was transparent. As noted above transparency
could be improved through the CAB providing a summary of rationale for reaching its
conclusions on the BP’s response to the issues raised by stakeholders.

19

5. Response to Stakeholder Concerns
The main stakeholder feedback received by Graanul was from the NGO ELF as well as the
input of the SOMO and Indufor Oy reports. Other stakeholders provided editorial comments,
requested clarity on mitigation measures and the use of databases (2019/2020) evaluation),
or raised concerns from the perspective of small forestry owners about the criteria being too
restrictive on their practices (2021/2022) evaluation).
For the purpose of the assessment, INCAS focussed on the issues raised by ELF which
overlapped with the issues raised in the SOMO and Indufor Oy reports. NEa also requested
that the assessment focus on the following key issues raised in the stakeholder consultation:







Woodland Key Habitats
Natura 2000
Cultural values (including “cross trees”)
Threatened animal species
Watersheds
Peatlands

In addition, an important issue raised by ELF was the carbon balance of Estonian forests
related to national cutting rates (4.1).

5.1. Key Issues and the SDE+ Risk-based Approach
Under the Risk-based Approach (RBA) set out in the SDE+ Verification Protocol and SBP
ID2E, there are a set of indicators related to sustainability criteria. In the development of the
RBA, each indicator is designated as ‘low risk’ or ‘specified risk’. For specified risks, the
biomass producer (BP) should put in place mitigating measures, while for indicators
designated as low risk mitigation measures are not necessary.
Woodland Key Habitats (WKH), Natura 2000 and cultural values (cross trees) relate to the
protection of high conservation value areas under indicator 7.1 of the SDE+ Verification
Protocol. In Graanul’s RBA finalised in 2019 and updated in November 2021, indicator 7.1 is
designated as a ‘specified risk’. This corresponds to the designation of these issues in the
SBP Regional Risk Assessment (RRA). The 2016 RRA classified the SBP indicator related to
high conservation values (2.1.2) as a specified risk due to WKH. In the updated SBP RRA
(October 2021), the specified risk was expanded to include Natura 2000 and cultural values
(cross trees).
The other key issues (threatened species, peatlands and wetlands) were designated as low
risk in both the 2021 and 2019 Graanul RBA as well as the 2016 and 2021 versions of the
SBP RRA for Estonia.

5.2. Woodland Key Habitats (WKH)

20

Woodland Key Habitats (WKHs) are areas outside of legally designated protected areas where
there is a high probability of species of high conservation importance occurring and therefore
should be conserved. In Estonia there are two problems related to WKHs: the official inventory
of sites is not complete and under Estonian law the protection of Woodland Key Habitat (WKH)
is optional for private forest owners. WKHs were mapped during a 1999- 2002 inventory but
experts believe that only 50% of Estonia’s WKHs have been identified. NGOs have developed
an additional list of potential WKHs based on a database inventory. The NGO database is
used by FSC.
In its RBA reports, Graanul set out how it mitigates this ‘specified risk’. Graanul only sources
biomass from FSC and Programme for the Endorsement of Forest Certification (PEFC)
certified forest areas. FSC has a definition and approach to areas of High Conservation Value
(HCV) that is similar to or even more robust than the SDE+ Verification Protocol/ SBP ID2E
requirements. Therefore, FSC certified biomass is considered SDE+ compliant. This is not the
case for PEFC-certified material because PEFC is not considered to have the same rigour as
FSC in its approach to HCV.
FSC has identified databases of potential HCV areas (such as the NGO database for WKHs)
which it uses for its certification. Graanul uses these FSC databases to screen PEFC-certified
material. Graanul checks the origin of each truck arriving at its pellet plant gate against the
FSC databases. Any PEFC certified material which overlaps with HCV areas identified in the
FSC databases is not considered SDE+ compliant. PEFC certified material that does not
overlap with HCV areas in the databases is considered SDE+ compliant.
Preferred by Nature agreed that WKHs should be classified as a ‘specified risk’ and that the
measures put in place by Graanul offer a robust approach to mitigation this risk. agreed
INCAS agrees with the Preferred by Nature conclusion on this issue. INCAS would also note
that application of the mitigation measures could be improved via regular engagement of
stakeholders to discuss concerns of impacts on WKH sites as well as ways to further improve
mitigation measures.

5.3. Natura 2000 Sites
Natura sites have not been fully inventoried in Estonia. When Estonia joined the European
Union in the 1990s it designated its protected area system as Natura 2000. While this met the
requirement for EU membership, it did not meet the requirements of the EU Habitats Directive.
Stakeholders raised concerns about unsustainable logging activities in areas that have been
designated as Natura sites and specifically in surrounding limited management, or buffer
zones. Logging activities are allowed in Natura sites at EU level provided that they do not
negatively impact on the natural values of the site. In fact, in some cases logging may be
desirable, for example to maintain grassland areas. However, any non-conservation activities
in Natura sites require a thorough assessment of impacts.
ELF took legal action against the government of Estonia on the poor implementation and
safeguarding of Natura sites. This resulted in the European Commission initiating infringement
proceedings against Estonia in June 2021 for not properly implementing EU environmental
impact assessment requirements when permitting logging at Natura sites. This resulted in
21

Estonia, first putting in place stricter approaches for assessments and then halting the granting
of any logging permits.
The infringement procedure led to SBP designating Natura sites as a ‘specified risk’ in the
revised Regional Risk Assessment (RRA) for Estonia finalised in October 2021. And as noted
above, the specified risk for indicator 7.1 in the Graanul RBA also concerns Natura sites.
Graanul mitigates this risk by screening biomass against the forest habitats inventory. Where
there is overlap, material is not considered to be SDE+ Compliant Category 2.
Preferred by Nature agreed with the classification of Natura sites as a ‘specified risk’ in the
2019 and 2021 versions of the Graanul RBA. Preferred by Nature also agreed that the
measures put in place by Graanul offer a reasonable approach to mitigate this risk. INCAS
agrees with the Preferred by Nature conclusion on this issue.

5.4. Cultural values (including “cross trees”)
Estonian legislation does not consider sacred natural sites as having conservation value.
Stakeholders at FSC Estonia have highlighted the insufficient inventory and mapping of sacred
sites - especially cross trees. While there is an official Estonian database listing sites for
heritage protection, stakeholders estimate that there are more than 2,000 sacred sites that
have not been inventoried by the state. The NGO Hiite Maja has developed its own database
of sacred natural sites that includes these additional areas.
As noted above sacred sites are included in the specified risk associated with HCV (indicator
7.1) in the Graanul RBA as well as the 2021 SBP RRA. To mitigate this risk Graanul screens
material against the Hiite Maja database as well as the official heritage protection database.
As for Natura and WKH sites, any material from forest areas overlapping with sites identified
on these databases is considered non-compliant with SDE+ criteria.
Preferred for Nature agreed with the classification of sacred sites as a ‘specified risk’ in both
the 2019 and 2021 version of the RBA and that the measures put in place by Graanul offer a
reasonable approach to mitigate this risk.

5.5. Threatened animal species
Threatened animal species come under indicator 7.2 which requires measures to be taken to
protect and enhance endangered species. The Estonian regulations require that forest
operations protect nesting sites of rare and endangered bird species and leave certain types
of trees and dead wood for biodiversity protection. The government carries out inspections to
ensure compliance. Infringements are at a low level -- one percent of sites inspected.
There is likely to be a significant overlap between areas containing threatened and
endangered species and official and potential Nature and WKH sites and therefore the above
sections are also relevant here. The SOMO reports identifies examples of important nesting
sites and habitat being impacted by logging. These cases referred to state forestry operations
(RMK) and Graanul Invest-owned land. Graanul noted in its 2021 RBA that the state forestry

22

operations are classified as Category I biomass (large forest management units) and are
therefore not relevant to the RBA which deals with Category 2 (forest management units less
than 500 ha). Graanul further notes that it does not, and has not previously, owned forestry
land. Forestry land may be owned or managed by other legal entities in the Graanul group,
but this is not stated in the RBA.
The Graanul RBA also notes that the Estonian Environmental Inspectorate inspects forestry
operations each year and that there is a low level (less than 1% from samples sites) of
infringements. This is consistent with the experience of Preferred by Nature that noted on a
call with the INCAS team that infringements are rare and that they are familiar with some of
the sites identified in the SOMO report.
Graanul makes a strong case that infringements are generally at a low level in Estonia. In its
assessment of the Graanul stakeholder consultation, Preferred by Nature was guided by its
own experience of the level of infringements in Estonia from audits under other certification
systems as well as experience with the forest sector. Again, INCAS would recommend regular
stakeholder engagement to discussion cases of infringement.

5.6. Watersheds
Watersheds are considered under indicator 8.2 which requires water balance and quality of
both groundwater and surface water to be maintained and ideally improved. The Water Act of
Estonia requires a water protection zone of 10 metres from the banks of rivers, streams and
large (main) ditches. Logging is forbidden except when permitted by the Estonian
Environmental Board. Stakeholders raised concerns about the clear-cutting of areas adjacent
to waterbodies such as streams. They noted that while Estonian legislation forbid clear-cutting
close to waterbodies, in practice the law is not adhered to by forestry operators. The SOMO
report noted infringements at Graanul’s primary supplier and sourcing area level. It noted that
during 2018-2019, 54 hectares of water protection zones were clearcut on the lands of three
Graanul Invest forestry. SOMO reported that the infringements occurred at 300 separate sites
across Estonia representing seven percent of water protection zones on Graanul-owned lands
and implying a systematic disregard for regulations.
In the 2021 RBA, in responding to these stakeholder comments, Graanul noted that it does
not own land and that the examples given represented legal maintenance cutting and that
instances of clear-cutting are very rare. It also noted that biomass from these cuttings, due to
quality of the wood, is not used for SDE+ compliant biomass.
Preferred by Nature issued Graanul with a non-conformity under this indicator in the RBA. In
correspondence Preferred by Nature noted that the non-conformity was issued because the
RBA did not provide sufficient information to conclude low risk for this requirement. Preferred
by Nature acknowledged that Graanul provided sufficient information about the theoretical
implementation of legislation but raised concerns that the examples from the SOMO report
have shown that in some cases the legislation and best management practices are not
followed. From experience in country with audits under other certification systems and
interaction with the sector and stakeholders, Preferred by Nature believe that it is not common
practice in Estonia to clear cut in water protection zones. Therefore, they are not certain that

23

a specified risk is warranted in this case but rather that the RBA lacked sufficient analyses of
the problem to justify a low risk.
INCAS believes that Preferred by Nature was correct to issue a non-conformity in this case
and again would highlight that any mitigation measures put in place by Graanul would benefit
from regular stakeholder engagement to review cases of potential infringement as they occur.

5.7. Peatlands
Peatlands are considered under indicator 3.1 which prohibits the sourcing of biomass from
drained land considered as peatland on 1 January 2008. There is a particular case in Estonia
and potentially other former-Soviet countries, where peatlands drained in Soviet times have
started to regenerate due to blockage of drainage systems. Under Estonian law these areas
can be re-drained through the repair of the drainage systems. Under the legislation, the
drained area can be increased by an 10%. Stakeholders were concerned that draining these
areas impacts on biodiversity as well as emitting GHGs.
In its 2021 RBA, Graanul argued that lands drained in Soviet times are classified as ‘forest
land’ and that drainage is required to maintain forestry operations. They also noted that
drainage is important to maintain forest roads which are important for fighting fires and that
the drainage expansion limit of 10% is less than the volume that the system has lost since it
was constructed. Graanul also highlighted the need for larger state drainage reconstruction
projects to have public Environmental Impact Assessments. The examples given in the SOMO
report related to RMK operations which as noted above are large operations classified
Category I and therefore Graanul noted that they are not relevant to the RBA which is focussed
on Category 2 biomass.
At the same time, Graanul did agree that renovation works do carry a risk of carbon release if
best practice is not followed. It noted that risk assessments could be improved by including
carbon stock/balance analysis as well as other impacts of renovation works.
In the 2020 evaluation Preferred by Nature stated that they agreed with the stakeholder
comment that the reconstruction of old drainage systems is generally a negative activity.
Presumably because there is regeneration of peat in at least some of these areas and
therefore there is the potential to damage important species habitat and carbon storage.
However, Preferred by Nature did conclude that the drainage activities met the SDE+ criteria,
this is because criterion 3.1 gives a clear cut off date: 1 January 2008. Provided lands were
not classified as peatland after that date, biomass sourced from those areas can qualify under
SDE+.
INCAS believes that Preferred by Nature made the correct judgement in this case based on
the requirements of SDE+but at the at same time it represents and issue that is worthy of
further reflection by NEa/SDE+ with a view to amending the criteria of SDE+. For example,
the criteria could be revised to make exception for areas that have significant regeneration of
peatland / wetland qualities despite qualifying under the cut-off date.

24

5.8. Carbon Stocks
The Verification Protocol requirement for Indicator 4.1 states that ‘The forest management unit
where the wood is sourced is managed with the aim of retaining or increasing carbon stocks
in the medium or long term.’ The SOMO report raises concerns about cutting rates and the
release of carbon from the drainage and disturbance of peatland soils.
In its response in the RBA, Graanul refers to Estonian government forest inventory most over
the last five years which show that the national harvesting rate is less than the forest growing
stock. Graanul also refers to the Estonian Forest Act that requires forest owners to ensure
forest regeneration as well as the Estonian LULUCF strategy that they say regulates forest
management activities to support carbon sequestration.
Graanul also notes that the examples given in the SOMO report are from RMK-managed
forests which are classified as Category I and therefore not relevant to the RBA which deals
with Category 2 forests.
The NGO ELF noted in its comments to Graanul that there is no Estonian LULUCF strategy
and that the document Graanul refers to is in fact a review of scenarios rather than a strategy.
ELF also drew the attention of INCAS to a recent (29 February 2022) press release from the
Estonian Ministry of Environment on the Estonian GHG emissions in the LULUCF sector
(1990-2020) with new data for 2020 emissions.
The 2020 GHG inventory shows that Estonian land use is emitting more carbon than it is
sequestering: ‘the Estonian land use (LULUCF) sector emitted 1.3 million tonnes of CO2
equivalent in 2019. According to a more detailed analysis, the binding capacity of forests was
not sufficient to cover emissions from other land use sectors, as in previous years. Carbon
associated with forest land and wood products are categories that have so far been the only
carbon sinks, while other categories emit CO2 and other greenhouse gases.’
From the graph below it is clear that there has been a marked decrease in sequestration from
forestland (Metsamaa - light blue) from 2010 to 2020.

25

Graph 1: Estonian GHG emissions in the LULUCF sector 1990-2020

Metsamaa: forest land
Põllumaa: arable land
Rohumaa: grassland
Märgalad: wetlands
Asulad: settlements
Muu maa: other land
Puittooted: wood products
Netoheide: net emissions
Source: Estonian Ministry of Environment, press conference presentation, 29-03-22 https://envir.ee/uudised/eestikasvuhoonegaaside-heitkogused-vahenenud

Given the above data there would appear to be a risk for any forestry management unit in
Estonia of not meeting the SDE+ requirement to maintain or increase carbon stocks.
However, it should be noted that the above data was not available at the time of the Preferred
by Nature evaluation of Graanul. It should also be noted that for this kind of data there are
often conflicting studies based on different methodologies. For example, the Estonian biannual
GHG report 2019 and the National Forest Accounting Plan 2019 notes that forests will
decrease as carbon sinks in the period 2030 – 2050 due to the age profile of Estonian forests
(which has a relatively high level of mature trees). The sequestration of carbon is expected to
rise after 2050 and therefore it can be argued that Estonian forests are ‘managed with the aim
of carbon stocks increase” as per SDE+ criterion 4.1.
INCAS agrees that Preferred by Nature made the right decision on this issue when evaluating
the stakeholder consultation, however, carbon balance requires closer examination by SDE+.
For example, in the RBA, Graanul cites the Indufor Oy review of the SOMON report which
noted the need to improve on high level analysis to further reduce risk and demonstrate
continued low risk and concludes that carbon balance criteria should be included in future SBP
standards and risk assessments.

26

6. Risk-Based Approach and Site-based
Auditing
The Risk-based Approach (RBA) of SDE aligns with current trends in voluntary certification
towards focussing on key risks and thereby reducing the cost of certification on one hand and
the impact of certification on the other hand as areas where real change is needed can be
focussed on. Certification systems are also moving towards regional approaches, there are
various initiatives to look at certification at state or provincial level sometimes across multiple
commodities. These approaches are still being piloted but include a mixture of site-based
certification and risk assessments at landscape level – usually aligning with state/national
boundaries.
In the Graanul audit many of the issues raised by stakeholders in relation to the Risk-based
Approach are at national, or even international level e.g. on carbon sequestration rates. The
usual approach to stakeholder consultation is to focus on the level of the site, or the exact
boundaries of the entity being certified. For example, the first requirement for the CAB laid out
in SBP Standard 3 (see Table 2 above) focuses on consulting stakeholders to verify if
management systems are working. The second requirement to verify if the issues raised by
the stakeholders have been adequately addressed by the BP. The issues raised by in the
SOMO report and ELF often concern issues at a national level in Estonia rather than Category
2 biomass sourced by Graanul. While these issues are relevant for the RBA, is it reasonable
to expect the CAB to deal with these bigger-picture issues, especially those that are the
subject of debate at national and international level?
CABs are orientated towards site-based certification and their stakeholder consultations will
usually look at issues related to the compliance of the operator. Expanding this ‘normal’
stakeholder consultation to look at national-level debates risks that the CAB is not adequately
equipped in terms of capacity to properly evaluate the issues. CABs also face constraints on
time as auditing is a commercial activity and so there is a strong incentive to maximise the
time efficiency of audits. Therefore, there is a risk that CABs will not invest the necessary time
to research national and international level policy and scientific debates.
The view of the INCAS team is that the RBA should have a broader consultation with
stakeholders beyond stakeholders interested in one particular BP. For example, as noted
above many standards have multi-stakeholder processes at the standard level based on their
membership. Many standard systems also set up multi-stakeholder technical committees to
manage the revision of standards, their responsibilities often extend to overseeing the
development of guidance as well as national level risk assessments. The Ministry NEa could
give consideration to establishing such a committee to provide input or approve future RBAs.

7. NGO Perspectives on Biomass Use for
Bioenergy
27

From interviews with Dutch-based NGOs – Greenpeace and Natuur & Milieu—it is clear that
the position of NGOs on the use of forest biomass for power generation has changed
considerably since the development of the original SDE criteria in 2013. They see potential for
negative impacts on forest biodiversity and ecosystems from increased demand for biomass
while at the same time they see uncertain carbon benefits from using biomass – especially
roundwood – in coal plants. They also see increased global demand for forest biomass from
other sectors such as biofuels, textiles, chemicals and plastics. They believe that the priority
should be to use forest biomass for products that will sequester carbon in the medium to long
term, for example materials used for building and long-life products such as furniture. They
are not opposed to using biomass for energy but would prefer that the priority should be for
those sectors that do not have alternatives such as the aviation and shipping sectors where
electrification is not feasible in the short term.
This opposition to the use of forest biomass for power generation is clearly the underlying
concern that is driving environmental NGOs to criticise SDE+ and specifically the Graanul
case. While the stakeholder consultations have allowed concerns to be raised by
environmental NGOs, most of the issues raised have been specific to Estonia and it has not
allowed NEa to examine the core issues behind the opposition. The INCAS team would
recommend that a multi-stakeholder platform is established at the system level that can
improve the standard as well as looking at bigger picture issues such as the use of forest
biomass for power generation.

28

Annex 1: Key Documents, Stakeholder Consultations and Comments
Date

Document / Audit

22.04.2016

SBP-endorsed
Regional
Risk
Assessment for Estonia, version 1.00.
(NEPCon)

16.10.2019

26.10.2019
20.12.2019
??.01.2020

Graanul Invest SDE+ COC and RBA
[Risk-based Approach], Cat .2,
Estonia, Version for SBP ID2E
(Peterson Projects B.V.)
OÜ Osula Graanul
Supply Base Report (Osula Graanul
OÜ ).
Letter to Graanul Invest and NEPCon
OÜ (ELF Estonia Fund for Nature).
Graanul
sends
updated
Risk
Assessment to NEPCon

Summary of consultation

2 rounds – sent to 17 organisations:
26.03.15 – 26.04.15
15 05.15 – 20.05.15
- 7 responses.

Stakeholder consultation not carried out.

21.12.2019 published on company website and
sent to 11 organisations – ‘no written comments
received’.

Key Issues raised by stakeholders / General
comments
ELF [Estonian]
EMPL (Estonia Wood & Forest Industries Association)
[Estonian]
Graanul Invest AS
- Highly critical of draft RRA esp. the risks identified:
o Biomass can’t be traced back to supply base
o Tax and duty payments
o Forestry in HCVs not regulated (WKH issue)
o Health & safety of forest workers
FSC Eesti [Estonian]
MTÜ Eesti Erametsaliit [Estonian]
Warmeston OÜ, Purutuli OÜ, Ardor OÜ
- WKHs have de facto protection <1% potentially
harvested
Stora Enso Eesti AS
- WKHs have de facto protection
N/A

N/A
Comments summarised as ‘Stakeholder 3’ below under
03.02.2020 Updated: Graanul Invest SDE+ COC and RBA.
From Scope Change audit report.

29

03.02.2020

Updated: Graanul Invest SDE+ COC
and RBA, Cat .2, Estonia, Version for
SBP ID2E (Peterson Projects B.V.).

22.11.2019- 22.12.19 consultation sent via email to
Estonian stakeholders
- 3 stakeholders sent feedback which was
incorporated into final RBA.
.

Stakeholder 1
- Editorial comments
Stakeholder 2
- Clarity on mitigation measures and use of
databases.
Stakeholder 3 (ELF)
- Wetlands: conversion from drainage upkeep.
- Carbon stocks: logging volumes too high
- Endangered species not surveyed - in decline
- Species mgt.: poor conservation zones/ PA system
- Soil protection: no legislation, widespread damage
- Watershed protection: no nat. system in place
- Water monitoring impact: no nat. system
- Soil compaction: no special measures used
- Soil erosion/fire: no measures in place
- Allowable Annual Cut (ACC)exceeds limit
- State Audit Office found RMK’s ACC unsustainable
Stakeholder that NEPCon spoke to by phone noted that
information on databases used for mitigating measures
for PEFC-Certified material should be added to RBA.
NEPCon informed Graanul and relevant databases were
added to RBA. Presumably this was ‘Stakeholder 2’ who
raised an issue about databases detailed in RBA above. .

24.02.2020

NEPCon Evaluation of Osula Graanul
OÜ Compliance with the SBP
Framework: Public Summary Report,
Scope Change Audit

05.11.19 – 05.12.19 – NEPCon consultation via
email.
- 1 response copy of ELF email to Graanul
(20.12.19).
11.12.19 - NEPCon called main stakeholders.
- 1 response – feedback sent to Graanul.

09.08.2021

Preferred by Nature Evaluation of
Graanul Invest AS – Imavere factory
Compliance
with
the
SBP
Framework: Public Summary Report,
Fourth Surveillance Audit

Stakeholder consultation not required for
surveillance audits (only for main audits every 5
years).

N/A

22.10.2021

SBP-endorsed
Regional
Risk
Assessment for Estonia, version 1.1.
(Preferred by Nature)

None required but stakeholders contacted for
latest data. SBP carried out public consultation.
17. 06.21 - SBP 30-day public consultation
- 4 responses.

ELF
- Case against forest biomass – 800 scientists, EASAC
- Certification can dismiss concerns of science/NGOs
& accept degradation of forest ecosystems

30

-

12.11.2021

Graanul Invest SDE+ COC and RBA
Cat .2 Estonia (Graanul Invest)

5.10.2021- 5.11.2021 Graanul consultation
 10 relevant stakeholder groups received the
documents for comments (a large number of
contacts but some represent the same
group).
 2 stakeholders responded with input,
 2 confirmed that they received the material,
2 stakeholders said that they support Graanul
Invest’s but did do not want to provide comments
SOMO and Indufor Oy reports considered as
stakeholder input & integrated into RBA.

Legality should not be used to imply sustainability
2010- 2019, 5700 ha in WKHs felled in State Forest –
specified risk to WKH accepted by SBP.
- Natura 2000/EC action against Estonia – specified
risk accepted by SBP.
- Decline of bird species
- High carbon stocks (peatlands, WKH)
- Forestry impact on carbon sinks
Warmeston OÜ
- As risks related to HCV are highly debated they
should not be classified as specified risks in the RBA.
Drax Power Station
- HCV (WKH, Natura and cross trees) should not be
classified as specified risk.
- SBP classified risk related to cross trees as
specified.
Graanul Invest AS
- HCV should not be classified as specified risk.
From Preferred by Nature Evaluation (below): ELF ‘raised
the same cases and questions like in SOMO report’.
Stakeholder 1
 Questions on international sustainability
requirements and how to manage HCV areas. The
stakeholder may have been questioning the
specified risk allocated to HCV in the RBA –
comments were in Estonian and INCAS used an
online translation.
Stakeholder 2
- Concern about inadequate response to previous
comments and draft RBA not being complete.

31

-

23.02.2022

Preferred by Nature Evaluation of
Osula Graanul OÜ Compliance with
the
SBP
Framework:
Public
Summary Report, Re-assessment

Condemnation of use of biomass for energy even if
sustainability criteria met.
Drained forests areas should be classified as
peatland / not forest land.
Estonia does not have a LULUCF strategy.
Highlights of SOMO report relevant to RBA:
o WKHs
o Natura 2000
o Endangered species
o Cross trees
o Watersheds
o Peatlands

21.10.2021 – 20.11.2021 Preferred by Nature
consultation.
 10 relevant stakeholder groups received the
documents for comments (a large number of
contacts but some represent the same
group).
 2 stakeholders responded with input,
 2 confirmed that they received the material,
 2 stakeholders said that they support Graanul
Invest’s but did do not want to provide
comments.


32

Annex 2: Assessment of Graanul’s Response to Stakeholder Comments by
Preferred by Nature (2019/2021 evaluation)
[See separate Excel file]

33

Annex 3: Comparison of SDE+ and SBP ID2E Stakeholder Consultation
Requirements
Verification Protocol for Sustainable Solid Biomass for Energy
Applications (January 2021)

Instruction Document 2E: SBP Requirements for Risk Based
Approach for Biomass Category 2

SBP Framework Standard 2: Verification of SBP-compliant Feedstock

9.3 The CB shall consult with stakeholders included in the BPs SBE consultation and the Locally Applicable Verifiers
(LAVs) process. As a part of the CB consultation the CB shall determine if stakeholders’ comments were adequately
addressed by the BP.

While collecting information, the biomass producer must establish and implement effective
procedures for the involvement of stakeholders for the specified region(s), as well as relevant
requirements for sustainable forest management that ensure that the rights and opinions of these
stakeholders in relation to their interests are taken into account when assessing the risks. The
procedures shall at least include:

13.1 Stakeholder consultation is required at the initial SBE and at the five-yearly re-evaluation.
2.10.1 As part of the information gathering exercise, the BP shall document and implement
effective procedures for consultation on the sustainability requirements with stakeholders in 13.2 Requirements include those detailed in Instruction Note 2B: Supply Base Evaluation Stakeholder
Consultation Requirements.
specific regions. The procedures shall at least include:
13.3 The principles in Stakeholder Consultation for Forest Evaluations FSC-STD-20-006 (V3-0) EN are
recommended as good practice. The BP shall also take into account any consultations undertaken as a
consequence of e.g. forest operations, plant construction or planning processes, and the outcomes of
stakeholder consultations associated with existing certifications of the BP’s management systems.

• responsibilities for the stakeholder consultation process;
• description of the various stages in the consultation process;
• identification of the stakeholders to be involved;
• a proactive approach of stakeholders, who must be given sufficient time to respond (at least one
month);

• Responsibilities for stakeholder consultation;
• Description of the various stages in the consultation process;
• Identification of the stakeholders to be involved;
• A proactive approach of stakeholders, who must be given sufficient time to respond (at
least one month);

• consultation of qualified and independent experts where specialised knowledge isrequired.

• Consultation of qualified and independent experts where specialised knowledge is
required.

The biomass producer shall keep the reports and the contributions and comments from stakeholders 2.10.2 The BP shall keep the reports and the contributions and comments from stakeholders
and experts, including reactions and measures taken in response.
and experts, including reactions and measures taken in response.
The biomass producer shall make the results of the RBA (risk assessment and mitigating measures
taken) publicly available as part of the stakeholder consultation.

SBP Standard 3 - Certification Systems. Requirements for Certification Bodies v1.0
9 Certification Body stakeholder consultation

8.2.2 Consultation of stakeholders and experts
The outcomes of consultationswith stakeholders and experts are an importantsource of information
forthe risk assessment. A stakeholder is any individual or group that has an interest in any decision or
activity (e.g. logging, forest management) of an organisation (the biomass producer or FMU involved).
Examples of stakeholders are NGOs, local residents or communities, workers or unions, local or
regional government, companies and company associations and contractors.

13.4 Relevant stakeholders shall be informed of the SBE at least one month prior to the end of the evaluation.
Stakeholders shall be provided with adequate information as a basis for informed comment, but may not be
provided with sensitive or commercially confidential information.

9.1 During the main audit of the BP and the re-certification audit, the CB shall undertake a stakeholder consultation
process.
9.2 During the stakeholder consultation process, the CB shall identify relevant individuals and organisations interested
in and affected by the operation of the applicant BP. CBs are not expected to identify and consult all possible
stakeholders, but shall consult with a sufficient number of affected stakeholders in order to verify that management
systems (documented or undocumented) are working effectively and consistently under the full range of conditions
present in the area under evaluation.

9.4 The CB shall give stakeholders at least one month’s notice of the audit. Notification shall include adequate
information to enable stakeholders to make informed comments, but shall not include sensitive or commercially
confidential information.
9.5 The CB shall encourage stakeholders to submit relevant information to the CB, in order to evaluate compliance of
the BP with SBP requirements.

9.6 During the audit process, the CB shall review all submissions and evaluate those that are relevant. All submissions
shall be recorded and the CB shall document actions taken in relation to relevant submissions, and the conclusions of
the CB regarding compliance of the BP with the Standards.

2.10.3 The BP shall make the results of the RBA and the mitigation measures implemented
publicly available as part of the stakeholder consultation.
*2.8.2 Gathering information shall follow the requirements of Standard 2 sections . . . 13
Stakeholder consultation.

9.7 CBs are not required to undertake a stakeholder consultation process during surveillance audits. However, all
submissions received by the CB regarding the compliance of a certified BP, shall be recorded. If submissions contain
information relevant to compliance with SBP requirements, the CB shall evaluate the comments as they affect the
certification, during or prior to the next audit, as appropriate.

9.8 Records of evaluations and outcomes of all stakeholder consultations shall be maintained for at least five years.

List of definitions
Stakeholders (interested parties) Any person, group of persons or entity who or which has
established it has an interest in the activities of the FMU, or who or which is known to have this. This
could be an NGO, trade union, government or representative of a certification scheme, for example.
Stakeholders (affected parties) Any person, group of persons or entity who or which is or probably
will be affected by activities being carried out in an FMU. This could be local residents, the local
popula tion, indigenous people, downstream landowners, owners of land rights or user rights and
organisations acting on behalf of the affected stakeholders.

34

Annex 4: Overview of Stakeholder Engagement
Stakeholder Organisation

SBP Regional
Risk Analysis
2015

BSR INTERREG IIIB Baltic Biomass Network
Drax
Eesti BiokÜtuste Ühing [Estonian Biomass Association]
Eesti Erametsaliit (EPFU) [Estonian Private Forest Union]
Eesti Jahimeeste Selts [Estonian Hunters Society]
Eesti Keskkonnaühenduste Koda - EKO
[Council of Estonian Environmental Nongovernmental Organisations]
Eestimaa Looduse Fond* (ELF) [Estonian Fund for Nature]
Eesti Maaülikool Estonian [Estonian University of Life Sciences]
Eesti Metsa Abiks (EMA) [conservation NGO]
Eesti Metsa- ja Puidutööstuse Liit [Estonia wood & Forest Industries Association]
Eesti Metsatöötajate Ametiühing [Estonian Forest Workers' Trade Union]
Eesti Ornitoloogiaühing [Birdlife Estonia]
Eesti Roheline Liikumine [Estonian Green Movement]
Eesti Taastuvenergia Koda [Estonian Renewable Energy Association]
Erametsakeskus (Private Forest Center Foundation) [state owned]
Estonian environmental inspectorate
Estonian Timber [Woodworking Industry Development Cluster]
FSC Eesti [Estonia]
Graanul Invest AS
Greenpeace
Hiite Maja Foundation [NGO for sacred natural sites]
Järva vald, Imavere [Parish council]
Keskkonnaagentuur [Environment Agency]
Keskkonnaministeerium [Ministry of the Environment]
Keskkonnaamet [Environmental Board]
Kotkaklubi [Eagle Club]
Loodusaeg [mailing list with ca 1000 readers]
Maavalla Koda [Estonian House of Taara and Native Religion]
Maksu- ja Tolliamet [Estonian Tax and Customs Board]
MTÜ Roheline Läänemaa [Lääne County environmental NGO]
MTÜ Eesti Erametsaliit [Estonian Private Forest Association]
Natuur & Milieu [Dutch NGO]
PEFC Eesti [Estonia]
Riigikontroll [National Audit Office]
Riigimetsa Majandamise Keskus (RMK) [State Forest Management Center]
SOMO
Stockholm Environmental Institute (SEI) Tallin
Stora Enso [Finish pulp and paper company]
Sihtasutus Erametsakeskus (PFC) [Private Forest Centre]
Toftan [foresty company]
Tornator Eesti OÜ [foresty company]
Tõrva vald, Helme [Parish Council]
United Loggers OÜ
University of Tartu
Väike-Maarja vald, Ebavere [Parish council]
Võru vald, Osula [Parish council]
Warmeston OÜ [wood pellet manufacturer]
Key
● - outreach to stakehodler
** - response from stakeholder

SBP Regional
OÜ Osula
Risk Analysis Graanul RBA &
2021 (SBP)
Supply Base
Report
26.10.2019

NEPCon
Evaluation
24.02.2020

Graanul Invest
RBA & Supply
Base Report
12.11.2021

PfN evaluation
consultation
23.02.2022

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that contacted
NEa

Greenpeace
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References
SBP Standard Documents
 Instruction Document 2E: SBP Requirements for Risk Based Approach for Biomass
Category 2 – Demonstrating Compliance with the Netherlands SDE+ Risk Based
Approach Sustainability Requirements for Biomass Category 2
 SBP Framework Standard 2: Verification of SBP-compliant Feedstock
Graanul Documentation
 Supply Base Report: Graanul Invest AS – Imavere Factory, 12 November 2021
Stakeholder Engagement International Best Practice
 Stakeholder Engagement: A Good Practice Handbook for Companies Doing Business in
Emerging Markets, IFC
https://www.ifc.org/wps/wcm/connect/topics_ext_content/ifc_external_corporate_site/sust
ainability-atifc/publications/publications_handbook_stakeholderengagement__wci__1319577185063
 Mining Principles, International Council of Mining and Metals (ICMM),
https://www.icmm.com/mining-principles/10
 AA Standard 1000 Stakeholder Engagement Standard, AccountAbility,
https://www.accountability.org/standards/
Government
 Estonia's greenhouse gas emissions have decreased, Estonian Ministry of Environment
press release, 29-03-22. https://envir.ee/uudised/eesti-kasvuhoonegaasideheitkogused-vahenenud
 Estonian Ministry of Environment, Press Conference presentation, 29-03-22
https://envir.ee/uudised/eesti-kasvuhoonegaaside-heitkogused-vahenenud
Media
 Estonian ministry pursuing agreement in European Commission infringement
proceedings, Baltic Times, 02.09. 21
https://www.baltictimes.com/estonian_ministry_pursuing_agreement_in_european_com
mission_infringement_proceedings/
 Estonian court suspends logging at Natura 2000 sites, ERR, 12.06. 21
https://news.err.ee/1608244515/estonian-court-suspends-logging-at-natura-2000sites#:~:text=The%20Tallinn%20Administrative%20Court%20has,Eesti%20Metsa%20A
biks%20(EMA)

36