FSC STANDARD DEVELOPMENT GROUP INDIA

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FSC STANDARD DEVELOPMENT GROUP INDIA PROPOSAL FOR THE TRANSFER OF FOREST STEWARDSHIP STANDARDS TO THE REVISED P&C FSC-STD-01-001 V5 PREPARED IN ACCORDANCE WITH FSC-TPT-60-007 (VERSION 2-1) EN Submitted to Policy and Statndards Unit, FSC International Centre 2012 Forest Stewardship Council I.C. All rights reserved 31 OCTOBER 2012

FSC STANDARD DEVELOPMENT GROUP- INDIA PROPOSAL FOR THE TRANSFER OF APPROVED FOREST STEWARDSHIP STANDARDS TO THE REVISED P&C FSC-STD-01-001 V5 PREPARED IN ACCORDANCE WITH FSC-TPT-60-007 (VERSION 2-1) EN SUBMITTED TO FSC Policy and Standards Unit Foreword The purpose of this template is to support the development of a proposal and work plan for transferring Forest Stewardship Standards to the revised Principles and Criteria (FSC-STD-01-001 V5). It also serves as a communications tool to inform stakeholders of the transfer process being proposed and to gather input and support for this process. This template is divided into two parts: PART I request general information related to the standards transfer process. Irrespective of when you plan to begin the standard transfer, it is requested that you submit Part I to FSC by 31 October 2012. This will allow FSC to know how you plan to implement the standards transfer, how to engage with you in the development of the International Generic Indicators (IGIs), and how to best provide you with support as you implement the transfer. PART II requests more detailed information related to the transfer process, including a time-bound workplan and budget, contact information for the Standards Development Group and the Consultative Forum, the use of Technical Experts, and the communications plan. Once completed, Part II shall be submitted to FSC to approve the plan for an FSC Forest Stewardship Standard entered for the transfer process. NOTE: It is important that the intended transfer process is registered with FSC prior to beginning the process; if a standard is not registered for transfer then it may be replaced by the International Generic Indicators once developed and any current national indicators will then be lost. Please send both PART I and PART II, either in two parts or as one completed template to FSC s Policy and Standards Unit: Gordian Fanso, FSC Policy Manager for National Standards: g.fanso@fsc.org 2

PART I: GENERAL INFORMATION Please fill out this PART and submit it to FSC by 31 October 2012. 1. Background Proposal to transfer the FSC Forest Stewardship Standard in INDIA to the revised P&C (V5-0). 1.1 This proposal is submitted by: Name: Dr T R Manoharan Position: FSC National Representative India Address: B3/77, 2 nd Floor, Janakpuri, New Delhi-110058, India Telephone:+91-11-25503065 Email: t.manoharan@in.fsc.org Additional Information: Forest Certification Council of India (FCCI) provides the institutional back up for the functioning of FSC SDG in India. FCCI was established by the stakeholders of FSC in India in October 2010. www.fcci.in 1.2 Please state the name and position of the person who will manage the transfer process, if different from above: Not Applicable 1.3 Please state the name and approval date of the standard(s) which you propose to transfer to the revised P&C (V5-0): FSC National Standard do not exist in India. This proposal is for the development of a new standard and transfer to the revised P&C. 2. Description of the type of transfer that will be undertaken The transfer will be undertaken in accordance with the Option C- Super Advanced Model described below. Below are four general options for transferring approved forest stewardship standards to the revised P&C. Please select the one you will generally follow and provide a detailed description of how you plan to undergo the transfer process. Note that the National Standards Development Group in your country is highly encouraged to actively participate in the consultation on the FSC International Generic Indicators. Option A. Basic Model: For recently approved national standards o Transfer of existing indicators to the revised P&C, as appropriate, plus adoption of the FSC IGIs to fill identified gaps. 3

Option B. Advanced Model: For approved national standards in need of some specific revisions, identified through a review of the standard o Transfer of existing indicators to the revised P&C, as appropriate, plus adoption of the FSC IGIs to fill identified gaps. o Revision of specific indicators identified by the Standards Development Group as needing additional work. Option C. Super Advanced Model: Only to be applied in countries where approved national forest stewardship standards do not exist or exist but with limited scope, and where there is extensive experience in FSC certification o Harmonization of existing CB Standards with any advanced draft national standards or approved standards with limited scope (e.g. SLIMF only, plantations only, etc.) (Motion #25 GA 2011). o Transfer of existing indicators to the revised P&C, as appropriate, plus adoption of the FSC IGIs to fill identified gaps and for specific indicators needing revision. o Revision of specific indicators identified by the Standards Development Group as needing additional work. All transferred standards need to be approved by FSC IC before they can be put to practice. Additional comments: 3. Timetable Please fill out the below general timetable based on the type of transfer being planned and the expected initiation date. This is not intended to be the work plan for your standard transfer, but rather a basic overview of your transfer schedule, how it aligns with the IGI development process, and general steps you plan to implement. To best align the standards transfer process with the development of the FSC International Generic Indicators (IGIs), the below table provides the dates and key activities related to the IGI process and the regional outreach being planned. Please also consider the following in your planning: Irrespective of the type of transfer option that is chosen, FSC highly encourages all Network Partners/SDGs to do a gap analysis of their standards to the revised P&C early in the IGI development process and to provide input on each draft of the IGIs with respect to the standards. All transfer processes are required to follow similar procedures as with standards revisions/development, including the use of a Standards Development Group and stakeholder consultation. More extensive revision or development (rather than a basic transfer) will require greater resources, such as extensive work of the Standards Development Group, extensive stakeholder consultation, field testing, etc. in order to finish within the transfer period. Please discuss any proposals for revision with the FSC IC National Standards Manager. Estimated Dates IGI Process Schedule Activities for Regional Representatives Transfer Process: suggested actions for SDGs according to the option chosen. 4

Estimated Dates IGI Process Schedule Activities for Regional Representatives Transfer Process: suggested actions for SDGs according to the option chosen. 10-13 July 2012 First IGI Group meeting to launch process and work on Draft Zero Mid August 2012 mid September 2012 3-5 October 2012 November 2012 January 2013 Feb March 2013 Results of first IGI Group meeting available Second IGI Group meeting to prepare Draft 1.0 for public consultation - PSU Drafting Team to work on Draft 1.0. - IGI WG Subcommittees to work on flagged issues and reach final agreement on Draft 1.0. First Public Consultation Regional representative participation in meeting and discussions on how to engage SDGs in the process. Outreach to SDGs to share results of the first IGI meeting and gather input for a second meeting. Regional Representatives share input provided by SDGs with the IGI Group. Plan Regional Workshops, together with PSU Team. Hold regular meetings to keep updated on IGI Process and share best practices. Provide input and technical support to Draft 1.0. First set of Regional Workshops for Regional Representatives, Network Partners/SDGs, FSC staff: Work on Transfer Matrix and identified major gaps. Input gathered for Draft 1.0. Flag Regional and National key issues. Step 1: SUPER ADVANCED MODEL ONLY Conduct harmonization of national draft standards and CB adapted standards; to include 1 month public consultation of the harmonized standard. Step 2: ALL MODELS Identify major gaps between existing approved Indicators and the revised P&C using the FSC Transfer Matrix. Step 3: ALL MODELS Conduct 1 st National/Regional Consultation and Workshop, to focus on major gaps identified in the Transfer Matrix. Step 4: ALL MODELS SDGs meet and report back to Regional Representatives on National consultation on IGIs, by using the Transfer Matrix. SDGs to send to PSU National Transfer Matrix, highlighting key issues. June 2013 July-August 2013 Third IGI Group meeting to review feedback received and work towards Draft 2.0 - PSU Drafting Team to work on Draft 2.0. - IGI WG to reach final agreement on Draft 2.0. Regional Representatives share outcomes of first Regional Workshops (Flagged National issues, best practices, options for improvement, etc.). Plan second round of Regional Workshops, together with PSU Team. Provide input and technical support to Draft 2.0. Step 5: ALL MODELS Incorporate any revised IGIs into their Transfer Matrix as advised by the PSU. 5

Estimated Dates IGI Process Schedule Activities for Regional Representatives Transfer Process: suggested actions for SDGs according to the option chosen. September- October 2013 Second Public Consultation Second round of Regional Workshops. National-level input on Draft 2.0 gathered. Step 6: ALL MODELS Conduct 2 nd National/Regional Consultation and Workshop. SDGs meet and report back to Regional Representatives on National consultation on IGIs, by using the Transfer Matrix. SDGs to send to PSU National Transfer Matrix, highlighting key issues. December 2013 Fourth IGI Group meeting to develop a final Draft of the IGIs for Board approval Regional Representatives share outcomes of second round of Regional Workshops. April 2014 Dec 2014, with exceptions as necessary Approval of the IGIs by the FSC Board -National and CB Adapted Standards transferred to the revised P&C -PSU Team lead on transfer of CB Adapted Standards to the revised P&C. Regional Representatives assist SDGs in the final transfer to the revised P&C. Step 7: ALL MODELS Following approval of the IGIs, final version of transferring National Standards submitted by SDGs to PSU for approval. 4. What is the estimated budget for the transfer? What are your funding sources and funding needs? The SDG will function mainly from the support from the members and institutions, mostly in-kind support committed by them during the meetings. However, it still requires an additional financial support of Euro 100.000 (Euro one hundred thousand only) or INR 7 million to meet the expenses of national standard development and field testing. (1 Euro =INR 70.04 as on 31 Oct 2012) This will be mobilised through support from FSC Network Fund and contribution and project funds. The Forest Certification Council of India (FCCI) (www.fcci.in) will provide the institutional back up besides generating contributions from its members and supporters. The other potential donors are 6

Export Promotion Council of Handicrafts (EPCH)www.epch.com ; Ministry of Environment and Forests, Government of India. PART II: DETAILED PLANNING Please submit this PART of the template once you have defined the details of the transfer process. Note that similar to standards development/revision, the transfer process requires a Coordinator and Chair, a chamber-balanced Standards Development Group, a Consultative Forum, a Communications Plan and stakeholder consultation. 5. Workplan Using the timetable provided at Number 3 above, please provide a detailed work plan of the tasks, activities and dates for the standard transfer. You may submit a workplan using a different format as long as you include all the information in the below table. If you do so, then please attach your work plan to this template. Task Specific Activities Estimated Start/End Dates Step 1 December 2012 Conduct harmonization of CB adapted standards; (there is no national standard exist in India) 1 month public consultation of the harmonized standard. Step 2 Identify major gaps between existing approved Indicators in India developed by CBs and the revised P&C using the FSC Transfer Matrix. Step 3 Conduct 1 st National/Regional Consultation and Workshop, to focus on major gaps identified in the Transfer Matrix. SDG Meetings Gap Analysis Public Consultation Workshops meetings First Public Consultation Inputs to Draft1.0 of IGI January 2013 February- March 2013 Step4 SDG meet and report back to Regional Representatives/FSC PSU on National consultation on IGIs, by using the Transfer Matrix. SDG Meetings Consultative meetings March 2013 SDG to send to PSU National Transfer Matrix, highlighting key issues. Step5 Incorporate any revised IGIs into Inputs to Draft 2.0 of IGI SDG Meetings July-August 2013 7

their Transfer Matrix as advised by the PSU. Step 6 Conduct 2 nd National/Regional Consultation and Workshop. SDG meet and report back to Regional Representatives/FSC PSU on National consultation on IGIs, by using the Transfer Matrix. SDG to send to PSU National Transfer Matrix, highlighting key issues. Conduct 2 nd National/Regional Consultation and Workshop. Second public consultation. SDG Meeting National Workshop September- October 2013 SDG meet and report back to Regional Representatives on National consultation on IGIs, by using the Transfer Matrix. SDG to send to PSU National Transfer Matrix, highlighting key issues. Step 7 Approval of IGI by FSC Board Following approval of the IGIs, final version of transferring National Standards submitted by SDGs to PSU for approval. SDG Meetings Preparation of reports/technical inputs SDG Meetings Meetings with Regional IGI representatives SDG Meetings Announcement of FSC national standard in India December 2013 April 2014 December 2014 6. Funding and resources available, and/or potential sources of funding: Resources Needed Source Amount/ Contribution 1. Personnel (i)contribution from Technical (Technical and Members/institutions support coordination) (ii)fsc-nr India (iii)fsc- IC- PSU 2 Funds for Travel (i)institutions/individuals of SDG volunteered/agreed to contribute (ii)fsc Network Fund 3 Workshop/ Meeting venue and (i) Contribution from Members facilities (ii) FSC Network Fund 4 Communication (i) Contribution from Members of SDG (ii) FSC Network Fund Financial support In-kind and financial In-kind and financial support Confirmed Yes In process. (proposal to Network Fund submitted) Some members have agreed to provide in kind Some members have agreed to provide communication 8

5 Forest Test (i) Contribution from Members 6 Equipments and (I) Contribution from Office Space Members/institution 7 Printing, stationary and miscellaneous expenses (i) (ii) s Contribution from Members FSC Network Fund awaited In-kind support In-kind and financial support Confirmation awaited Some members agreed to provide the support Some members have agreed to provide in kind A proposal for Network fund submitted for financial 7. Coordinator and Chair Please specify who will Coordinate and who will Chair the transfer process. These roles may be fulfilled by one or more people, and should be determined based on the needs of the Standards Development Group. Please put on the top of this list the individual who is responsible for project oversight (the Coordinator ). It is expected that this will also be the main contact for the FSC Policy and Standards Unit. Name Role Contact Dr T R Manoharan Coordinator Dr T R Manoharan, FSC National Representative India B3/77, 2 nd Floor, Janakpuri, New Delhi-110058, India Email: t.manoharan@in.fsc.org Manoharan7@gmail.com Tel: +91-11-25503065 Cell: +91-9350501113 Dr Ram Prasad Chair Dr Ram Prasad (Former Director Indian Institute of Forest Management) 06 Aranya Vihar, Chuna Bhatti Kolar road - Bhopal -462016 Madhya Pradesh, India Tel: +91-755-2424907 Mob:+ 91-9425608259 Email drpresearchcenter@gmail.com 8. Standards Development Group Given the nature of Forest Stewardship Standards in the FSC system, the Standards Development Group shall have three separate chambers representing social, environmental and economic interests, with a minimum of two representatives in each chamber, and equal number of people (or equal weighting) in each chamber. Decisions are made by consensus, defined as 9

general agreement in favor of a proposal, plus the absence of a sustained objection to the proposal 8.1 Please provide the below information on the Standards Development Group. The resume should give brief details of their background and knowledge of the FSC system.. Environment Economic Social Name Representative Name Representative Name Mr Krishna Kumar Singh Organisation WWF India Organisation Confederation of Indian Industry(CII) Organisation Lokvaniki Kisan Samiti, Bhopal WWF- India is India s leading conservation organization established in 1969 CII is India s one of the leading Industry Associations. Name Representative Name Mr Rakesh Kumar Organisation Ministry of Organisation Export Environment and Promotion Forests(MOEF), Council for Government of Handicrafts India (EPCH) Name Organisation Nodal Ministry for Environment and Forests. Prof.Prodyut. Bhattacharya GGS Indraprastha Univeristy Dwarka, New Delhi Dean University School of Environment Management and Professor, Natural Resource Management GGS Indraprastha University Name Organisation Executive Director-EPCH Mr Narayan Murthy Indian Paper Manufacturers Association (IPMA) Secretary General-IPMA Name Organisation Name Organisation FSC Member-Social Chamber; President, Lokvaniki Kisan Samiti, Former Member of Madhya Pradesh Legislative Assembly Mr DPS Verma Individual FSC Member- Social Chamber Former Principal Chief Conservator of Forests, Gujarat State Forest Department. Representative Society for Afforestation Reseach and Allied Works (SARA) Dandeli, Uttara Kannada District, Karnataka State Social NGO based in Karnataka. 10

Name Organisation Prof Asis Mazumdar Regional Centre, National Afforestation and Ecodevelopment Board (NAEB) Jadvapur University Kolkata Name Mr Ajay Abrol Name Ms Ritu Prasad Organisation UA Consultants, Faridabad Organisation Organisation for Industrial, Spiritual and Cultural Advancement (OISCA)- India Professor of Jadvapur University and Coordinator of Regional Centre, NAEB established by the Ministry of Environment and Forests. Consultant- Forest Certification and FSC Member- Economic Chamber Director- OISCA North India Chapter. Name Dr E V Anoop Name Mr Anil Jauhri Name Prof. Manmohan Yadav Organisation College of Forestry, Kerala Agricultural University, Trissur, Kerala Organisation National Board for Accreditation Services, Quality Council Organisation Indian Institute of Forest Management(IIFM) Bhopal Associate Professor and Head, Department of Wood Science. of India (QCI) Director- NBAS, QCI. Professor, IIFM 8.2 Please provide the working Language(s) of the Standards Development Group: English and Hindi. (other local languages may be included in the consultations when such discussions takes place in States/local areas whenever required. (Translation of all proceedings in English will be documented) 9. Technical Experts The Coordinator may appoint technical experts to participate in Standards Development Group discussions. These technical experts shall have voice in discussions but no formal role in its decision-making processes. Experts may also be needed to explore specific issues as they arise in deliberations by the Standards Development Group. Please list below all the experts that will be included in the process. Note: It is not expected that technical experts will be needed for a basic transfer of standards to the revised P&C. Name of Expert Team Members List of Documents (TOR, Work Plan, Documents Produced) 11

Forest Certification Dr H D Kulkarni Vice President(Plantations) ITC Ltd, PSPD Mr Suneel Pandey Vice President BILT Gurgaon, Haryana Mr Sachin Raj Lead Auditor SCS- India Noida, Uttar Pradesh Mr Sanjay Upadhyaya Advocate to the Supreme Court of India & Managing Partner Enviro Legal Defence Firm Delhi Mr Sudhir K Pande Former Director General of Forests, Ministry of Environment and Forests Government of India 10. Consultative Forum The Consultative Forum includes individuals and/or organizations reflecting the full range of stakeholders affected by the standard(s) under development. There should be evidence that these groups support the outcome of the process, such as signed letters from a senior representative of the organization or individual as applicable. It is essential that Non Government Organizations (NGOs) are engaged in the process where they exist, but this does not preclude relevant Government Organizations from contributing. Please list the Consultative Forum on the below table. Some organizations may cover more than one interest, in which case note this on the table. Interest (a) Economic Interests of: Organisation/ Individual Contact Details Evidence of support for this process EPCH, Pocket 6&7 Export Promotion Council for Handicrafts (EPCH) Sector C Local Shoping Complex, Vasant Kunj New Delhi-110070 Tel: +91-11-26135256 Fax: +91-11-26135518 Email:epch@vsnl.com www.epch.in in the FSC formulation of SDG meeting on24.11.2011 Malabar Chamber of The Malabar Chamber of Commerce 12

Commerce, Federation of Rajasthan Handicraft Exporters (FORHEX) Jodhpur Handicraft Exporters Association (JHEA) Indian Paper Manufacturers Assocation (IPMA) Wood Certification India Limited (Representative of Smartwood/Rainforest Alliance in India) Mr Shaji Joesph Managing Partner Atheena Exports 6/1165, Chamber House, Cherooty Road Calicut 673032, Kerala Telegrams - " Chambers" Phone :+91-495- 2365282, +91-495- 2365292 Fax :+91-495- 2766191 E-mail: mail@malabarchamber.com malabarchamber@yahoo.co.in Website:www.malabarchamber.com Federation of Rajasthan Handicraft Exporters,Plot No 12, Krishna Apartments, Scheme No 8,Gandhi Path, Vaishali Nagar, Jaipur - 302 021, Rajasthan State Tel: +91-141-2247544 http://www.forhex.org JHEA 5, Bhaghat Ki Koti Extension Opp. New Campus (Near Tata Motors Service Centre) Pali Road Jodhpur-342005 Rajasthan State Tel:+91-291-27217 Email:thejhea@sancharnet.in Indian Paper Manufacturers Association PHD House (4th Floor), 4/2 Siri Institutional Area (Opp. Asian Games Village), New Delhi 11016 (INDIA) Tel: 91-11-2651 8379 Fax: 91-11-2651 3415 E-mail: sg@ipma.co.in, secretariat@ipma.co.in Website: www.ipma.co.in Wood Certification India Pvt Ltd Near Sidharth Hotel Pusa Road New Delhi, India Tel:+91-41539721 Email: info@woodcert.com 34, Neptune Country, Chilavanoor Road, Kadavanthara, Kochi Kerala State 13

Kochi, Kerala (b) Social Interests of: OISCA-International South India Chapter Lokvaniki Kisan Samiti, Bhopal Society for Afforestation, Research and Allied Works(SARA), OISCA International, South India, UKS Road, Behind Veterinary Hospital, Calicut- 673001, Kerala, India. Mob +91-9447113567 Tel:+ 91 495 2760360, 2760140 Fax 91 495 2760360 Email oiscaindia@gmail.com Lok Vaniki Kisan Samiti. Ansal Lake View Apartments. Shamla Hill. Bhopal - 462013. Tel :+91-0755 - 2660904. Email : info@lokvaniki.org Society for Afforestation, Research and Allied Works(SARA), A Hostel, Room No.5, Dandeli Uttara Kannada, Karnataka State. Tel:+91-8284231306 www.saraworks.org (c) Environmental interests of: Indian Council for Forestry Research and Education (ICFRE), Dehradun Indian Plywood Industries Research and Training Institute (IPRITI) Dr B S Corrie, IFS Additional Principal Chief Conservator of Forests, Kerala Forests and Wildlife Department. The Energy and Resources Institute (TERI), New Delhi Centre for Science and Environment New Forest PO, Dehradun, Uttar Pradesh IPRITI, Bangalore, Karnataka State Forest Head quarters Vazhuthacaud Thiruvananthapuram PIN:695014 Kerala State TERI India Habitat Centre Lodhi Road New Delhi-110003 CSE, Tukhlakhabad Institutional Area Delhi Interested in the process. Interested in the process. 14

(CSE), New Delhi Indian Wood Science Institute, Bangalore Dr S Chand Basha, IFS(Rtd) Former Director, Kerala Forest Research Institute (KFRI) and Retired Principal Chief Conservator of Forests, Govt of Kerala. Green Peace -India Bombay Natural History Soceity (BNHS) WWF-India Mr Inder Dhamija, IFS Chief Conservator of Forests(Wildlife) Tamil Nadu Forest Department Indian Wood Science Institute Chowdaiah Rd, NH 4, National Highway 4, NH 4, Kodandarampura Bangalore, Karnataka Tel:+91-80 23341731 Dr S Chand Basha IFS (RtD0 Rtired Principal Chief Conservator of Forests & Former Director Kerala Forest Research Institute Palarivattom Ernakulam Kerala State Email:schandbasha@yahoo.com Greenpeace #60 Wellignton Street Richmond Town Bangalore-560025, India Te;:+91-80-41154861 Fax:+91-8041154862 Bombay Natural History Society Hornbill House, Opp.Lion Gate, Shaheed Bhagat Singh Road, Mumbai 400 001, Maharashtra, India Tel - 91-22-2282 1811 Fax - 91-22-22837615 Email: info@bnhs.org www.bnhs.org 172 B Lodhi Estate New Delhi-110003 Chief Conservator of Forests Tamil nadu Forest Department Chennai, Tamil Nadu cell: +91-9873090700 Email: inderdhamija@yahoo.co.in Interested in the process. Interested in the process 11. Communications Plan Please describe how you plan to ensure that stakeholder have access to information related to the transfer process, and how you plan to engage them in consultation. Note that the 15

communications plan needs to be culturally appropriate, taking into account access to email, literacy, etc. 1. Emails 2. Newsletter ( FSC India/SDG Update): Monthly (Print and soft copy) 3. Website (www.fcci.in and the relevant sections in the www.fsc.org). The information will also be circulated through the websites of the SDG Members/Institutions. 4. Radio/FM (by providing update to the relevant programme/special programme) 5. Poster (in English and local language) 6. Make use of Social media/discussion forums. 12. Other elements of the transfer process under the responsibility of the Coordinator 12.1 Complaints and disputes Complaints/disputes related to the content of the approved standard shall be responded to by the Coordinator, by providing an explanation of why a particular point of view was not incorporated into the final standard submitted for approval, and/or explaining how the point may be raised again in relation to future revisions of the standard. Complaints/disputes related to procedural issues shall be responded to initially by the Coordinator. If the complainant is not satisfied with the explanation provided by the Coordinator, the complaint /dispute shall be addressed through the FSC Dispute Resolution process. 12.2 Record keeping The Coordinator is responsible for maintaining the following records: a) Approved proposal to transfer the standard; b) Names and affiliations of members of Standards Development Group and Consultative Forum, and of other stakeholders that were consulted on the standards during their transfer; c) Minutes of meetings held by the Standards Development Group; d) Copies of public draft standards circulated for comment; e) Copies of all comments received on public draft standards; f) Summary of comments received in response to each public draft, together with a general response to those comments; g) Copies of technical drafts; h) The Standards Development Group report and all comments received on the Standards Development Group report; i) A description of all departures from the specified procedures for standards development, and the actions taken in respect of those departures; and j) The decisions of the FSC Board of Directors, FSC Executive Director and Policy and Standards Unit in relation to the requirements of this standard 16