Our entire company – corporate and production – is together in the community of Cosmopolis, WA. Therefore, our approach to community social responsibility is defined by our status as a local business. Beyond providing 200 family-wage jobs, spending $155 million annually into the area economy, and using the services of over 1200 local and regional suppliers, we participate directly in the social life of our community and county both financially and personally.
- Safety: Cosmo’s safety program goes beyond typical mill activities to include a fitness center, health and wellness information, and safety advice for both the work and home environment.
- School visits: Cosmo has an elementary school in close vicinity to the mill. We have partnered with the school for them to obtain technology grants, and we make in-kind donations at their request. Cosmo also presents to any regional school that requests a classroom visit.
- Community complaint resolution: Cosmo answers every legitimate community concern regarding odor, noise, or emissions with call-backs, visits, and internal investigations. If appropriate, Cosmo uses media relations to answer any persistent or widespread concern. The mill also schedules any noisy maintenance work during daylight working hours to minimize community impact.
- Cosmo Code: Cosmo’s approach to workplace culture is unique and includes a flattened organizational hierarchy, team member breakfast meetings with the leadership team, and a web-based anonymous feedback forum. A “Code” of behavior has been developed through consultation that has replaced the traditional third party labor relations model. Cosmo team members also eligible for quarterly bonuses based on the mill meeting certain metrics.
- Grants to recreation and the arts including local theatre, parks programs, educational scholarship, and youth programs such as Young Life and Boy Scouts.
- Grants to youth sports including local softball and little league.
- Grants to local service and social agencies including food banks, services for children, and programs for seniors.
- Grants to local fish enhancement programs.
- Reputation management and feedback with elected officials at all levels.
- Cosmo has also responded to our local community’s request to use of the mill’s fitness center for an employee wellness program.
Ancient & Endangered Forest Conservation Vision and Forest Fiber Procurement Policy
Our Vision Statement
Cosmo Specialty Fibers (CSF) is committed to demonstrating environmental and social leadership in the dissolving pulp and MMCF sector. To achieve this, we have eliminated sourcing of fiber from the world’s Ancient and Endangered Forests and other controversial fiber sources. We will also work in partnership with other companies, our suppliers, customers, and Canopy to reduce carbon emissions and advance conservation of the world’s critically important high carbon value (HCS) and biodiverse (HCV) forest ecosystems.
CSF recognizes that business leadership is a fundamental component for the transformation to sustainable economies. We commit to use our influence in the market for the development of both supply and demand-side environmental solutions. We will collaborate throughout the supply chain to support the creation of pulp made from low footprint sources[i].
As such, CSF is committed to actively implementing the goals noted below and to applying this model and these principles to all our corporate pulp production and use.
Our Implementation Goals
Protect and Conserve Ancient and Endangered Forests, Biodiversity and Ecosystems
CSF recognizes the impact that pulp production has on forests, species and the climate and, therefore, the need to ensure the adoption of environmentally and socially responsible pulp production. We will work in partnership with other companies, our suppliers, customers, and Canopy to advance conservation of the world’s critical high carbon value (HCS) and biodiverse (HCV) forest ecosystems.
CSF is not sourcing from and will not source in the future any fiber from Ancient and Endangered Forests (as initially identified in ForestMapper, then verified through further investigation)[ii] as well as forest fiber from threatened and/or endangered species habitat [iii] and other controversial sources. CSF will be a vocal advocate for conservation of Ancient and Endangered Forests globally.
CSF also recognizes that certain forest regions have been identified as priority for conservation by scientists and other stakeholders. Until meaningful scientifically-based conservation solutions are in place, we will not source from these regions which include but are not limited to: Canada’s Boreal Forests[iv], Indonesia’s Rainforests[v], the Amazon, the Coastal Temperate Rainforests[vi] of Vancouver Island.
CSF has ensured that we are not sourcing from controversial sources including:
- Old growth coastal temperate rainforest [vii]
- Companies that are logging forests illegally[viii].
- Tree plantations[ix] established after 1994 through the conversion or simplification of natural forests, as required by the Forest Stewardship Council. This is due to concern that although plantations can play an important role in supplying fiber for products, [Company] recognizes that clearing natural forests for plantations has contributed significantly to the destruction of forests in many parts of the world.
- Areas being logged in contravention of First Nations and/or Indigenous peoples’ collective community rights, including the right to Free, Prior, and Informed Consent (FPIC) and the rights codified under the UN Guiding Principles on Business and Human Rights. We will require that our suppliers resolve complaints and conflicts and remediate human rights violations through a transparent, accountable, and mutually-agreed dispute resolution process.
- Genetically modified organisms.
If we find that any of our fiber sources or pulp contain fiber from such critical habitat or Ancient and Endangered Forests or other controversial sources, we will immediately terminate this supply from our supply chain either autonomously or by working with our suppliers.
CSF will be a vocal advocate for conservation of Ancient and Endangered Forests globally. To further restoration in a highly fragmented landscape, we will support TNC’s Emerald Edge Program and/or other opportunities to assist in the purchase and rehabilitation of priority areas within our sourcing region.
Develop Next Generation Fiber Solutions
CSF is committed to participating in the circular economy. Through partnerships and R&D we will develop Next Generation technologies and processes to integrate Next Generation feedstocks such as used cotton textiles into our product. Over a period of 3 years to 2024 we will seek to achieve production of 30,000 tons/year (circa 20%) of Next Gen pulp to supplant wood fiber and will seek by 2030 to produce 70,000 tons (50%) of Next Gen pulp/year for the MMCF market.[x]
Forestry and FSC® (FSC-C137607) Forest Certification
Where virgin forest fiber is required Cosmo will ensure that it is not derived from Ancient and Endangered Forests or controversial sources as defined above. We will also preference wood fiber with FSC Forest Management certification and increase the proportion of FSC certified wood fiber over time. To ensure that more Forest Stewardship Council® (FSC) certified wood fiber becomes available in our sourcing region we will work with our wood suppliers, forest landowners and mills to raise awareness of the importance of FSC, and maintaining its rigorous standards, to us and our markets. We will take actions toward ambitions to both increase the amount of FSC certified wood within our fiber supply area and to annually increase the percentage of our wood fiber from FSC certified sources. We are targeting to increase the percentage of our wood fiber from FSC certified sources by at least 50% each year, from a 2021 baseline, through the objective of sourcing a majority of our wood fiber from FSC certified sources.[xi]
In recognition of the crucial contribution of forests, including well-managed forests, to achieving 2030 and 2050 climate targets, and given that the company is sourcing from the coastal temperate rainforest zone, Cosmo will preference wood sourcing from second growth forests logged prior to 1994 that are managed on 60 year rotations or longer.[xii]
Transparency, Traceability and Verification
We will ensure the transparency & traceability of our own operations and supply chains by 2021, and will identify the origin of our raw material sourcing, including pulp and plantations/wood fiber, through mapping our entire supply chain (chain of custody) back to the mills, plantations, and forest areas. We will be verified low risk of sourcing from ancient & endangered forest by 2021 through a CanopyStyle Audit.
Update: During 2022, CSF was found by Canopy, with independent third-party auditor Preferred by Nature, to be at low risk of sourcing from Ancient and Endangered Forests and other controversial sources. The audit results can be found at the following link:
Reduction of Greenhouse Gas Footprint
Recognizing the importance of forests and peatlands as carbon storehouses, we will support initiatives that advance forest conservation to reduce the loss of high carbon value forests, by encouraging vendors and suppliers to avoid harvest in these areas, and by giving preference to those that use effective strategies to actively reduce their greenhouse gas footprint.
Pulp manufacturing is a resource-intensive process that can lead to air and water emissions that impact overall environmental quality. This policy does not address these other critical environmental issues, however, we will invest in and use the cleanest dissolving pulp manufacturing technology.
We recognize the benefit of creating environmental awareness among our customers, employees and peers. As such, we will highlight our environmental efforts on our website and in public communications.
Setting Benchmarks, Timelines, and other Accountability Mechanisms
CSF will establish benchmarks, timelines, and other accountability mechanisms to implement this policy, and will review and adapt these annually.
[i] Environmentally friendly, lower footprint fiber sources include:
- Post-consumer recycled waste fiber
- Pre-consumer recycled fiber
- Agricultural residue defined below
- Fiber from FSC forest management certified tenures
[ii] Ancient and Endangered Forests are defined as intact forest landscape mosaics, naturally rare forest types, forest types that have been made rare due to human activity, and/or other forests that are ecologically critical for the protection of biological diversity. Ecological components of endangered forests are: Intact forest landscapes; Remnant forests and restoration cores; Landscape connectivity; Rare forest types; Forests of high species richness; Forests containing high concentrations of rare and endangered species; Forests of high endemism; Core habitat for focal species; Forests exhibiting rare ecological and evolutionary phenomena. As a starting point to geographically locate ancient and endangered forests, maps of High Conservation Value Forests (HCVF), as defined by the Forest Stewardship Council (FSC), and of intact forest landscapes (IFL), can be used and paired with maps of other key ecological values like the habitat range of key endangered species and forests containing high concentrations of terrestrial carbon and High Carbon Stocks (HCS). (The Wye River Coalition’s Endangered Forests: High Conservation Value Forests Protection – Guidance for Corporate Commitments. This has been reviewed by conservation groups, corporations, and scientists such as Dr. Jim Strittholt, President and Executive Director of the Conservation Biology Institute, and has been adopted by corporations for their forest sourcing policies). Key endangered forests globally are the Canadian and Russian Boreal Forests; Coastal Temperate Rainforests of British Columbia, Alaska and Chile; Tropical forests and peat lands of Indonesia, the Amazon and West Africa. For more information on the definitions of Ancient and Endangered Forests, please go to: http://canopyplanet.org/solutions/ancient-forest-friendly/ancient-forest-friendly-defined/ and ForestMapper. ForestMapper is a first point of information. For the purpose of this policy, finer scale maps, compiled by independent experts, will be used to delineate priority areas for restoration in Washington State. A CanopyStyle audit will assess these maps to confirm whether Ancient and Endangered Forests are present in Cosmo’s sourcing areas (see Appendix 1).
[iii] A good source to identify endangered, threatened and imperiled species is NatureServe’s Conservation Status rankings for imperiled species that are at high risk of extinction due to very restricted range, very few populations (often 20 or fewer), steep declines in populations, or other factors. There are conditions under which sourcing from areas that were historically the habitat of threatened and endangered species may occur. These include: if habitat destruction has been halted, and precautionary, science and TEK-driven, species-specific recovery plans with broad multi-stakeholder support have been agreed, and are being actively implemented. Elements of recovery plans include connectivity corridors and functionality such as forest interior conditions.
[iv] Protection of Boreal Forests where the largest remaining tracts of forests are located worldwide is critical. Canada’s Boreal Forest contain the largest source of unfrozen freshwater worldwide and are part of the world’s largest terrestrial carbon sink – equivalent to 26 years worth of global fossil fuel use. Canopy is committed to working collaboratively on the establishment of new protected areas, the protection of endangered species and the implementation of sustainable harvesting in Canada’s Boreal Forest.
[v] Indonesia experiences the second highest rate of deforestation among tropical countries, with the island of Sumatra standing out due to the intensive forest clearing that has resulted in the conversion of 70% of the island's forested area (FAO Forest Assessment 2010; Margono, B.A. et al. 2012). Canopy and our NGO partners are focused on forwarding lasting protection of the Leuser Ecosystem – the last place on earth where orangutans, tigers, elephants, rhinoceros and sun bears still co-exist.
[vi] Coastal temperate rainforests are rare and only ever covered 0.2% of the planet. On Vancouver Island only 10% of Vancouver Island’s productive old growth rare coastal temperate rainforest remain. These stands of 1,000-year old trees continue to be harvested despite their immense value to local communities for tourism. Their accessibility and beauty is a remarkable global asset and Canopy is working to see these last stands protected. A legal conservation plan is now finalized for the Great Bear Rainforest. On February 1st, 2016 the Government of British Columbia, First Nations, environmental organizations and the forest industry announced an Ecosystem-based Management framework that sets 85% of this region off limits to logging and stringent logging rules in the other 15%. Provided these agreements are fully implemented – sourcing from this ancient and endangered forest region can be considered to be within sustainable levels. We encourage ongoing verification of this through renewal of Forest Stewardship Council certification.
[vii] For the purposes of this policy, see areas identified on the FSC National Risk assessment map of specified risk areas for old growth (see p.13), https://https://preferredbynature.org/sites/default/files/publicsummaries/CanopyStyle%20audit%20report_revised%20Xinxiang%20Chemical%20with%20Cosmo%20audit%20attached.pdfus.fsc.org/en-us/certification/controlled-wood/fsc-us-controlled-wood-national-risk-assessment-us-nra
[viii] Legal forest management: Management that complies with all applicable international, national, and local laws, including environmental, forestry, and civil rights laws and treaties.
[ix] Plantations are areas planted predominately with non-native trees or other commercial plants. Forests comprised of native species can also be managed as plantations and/or tree farms, including via single species plantings on sites that would normally support multiple species, exclusion of other species via herbicide applications, short logging rotations that preclude the development of forest composition and structure, and/or other practices. This type of planted forest management is common in Cosmo’s sourcing area.
[x] This tonnage represents the 2% proportion of dissolving pulp Cosmo currently supplies to the market under a scenario consistent with shifting 50% of global pulp supply to recycled and Next Gen feedstocks by 2030, as a means to allow forests to recuperate carbon stocks and habitat to meet IPCC and IUCN climate and habitat targets in 2030 and 2050.
[xi] Plantations are areas planted predominately with non-native trees or other commercial plants. Forests comprised of native species can also be managed as plantations and/or tree farms, including via single species plantings on sites that would normally support multiple species, exclusion of other species via herbicide applications, short logging rotations that preclude the development of forest composition and structure, and/or other practices. This type of planted forest management is common in Cosmo’s sourcing area,
[xii] Appropriate rotation length will vary by forest type.
We work at Cosmo Specialty Fibers, but we live in Grays Harbor County. As such, we respect and represent the values held by this community. Accordingly, our environmental values reflect Grays Harbor community values.
We understand the importance of preserving water quality so that the sport and commercial fishery and the shellfish industry – a crucial part of the area’s economic diversity – can thrive. And we know that maintaining great air quality will encourage families and businesses to locate here and remain here.
This is why one of the primary tenets of our mission statement is “operating environmentally responsibly.”
- Reduction in oil consumption: Our use of fossil fuel has steadily declined since the mill opened – on average from about 15% of fuel used to produce mill power to less than 5%.
- Renewable energy: We now use, on average, 95% biomass and deconstructed biomass from our cooking process to produce energy. We are a qualified green power producer and produce Renewable Energy Certificates for the renewable energy market.
- Fiber Chain of Custody: Cosmo has attained PEFC™ certification. With over 30 endorsed national certification systems and more than 240 million hectares of certified forests, the Program for the Endorsement of Forest Certification is the world's largest forest certification system.
- Fossil fuel substitution: Cosmo has partnered with Conoco Philips to test the use of petroleum coke pellets – a unique product that will significantly reduce SO2 emissions when used as a substitute for fossil fuel.
- Residual Stream Uses: Cosmo is working with the Wisconsin Institute of Sustainable Technology at the University of Wisconsin, and a Weyerhaeuser/Chevron partnership to direct residual cellulosic streams into possible production of sugar for ethanol, poly-lactic acid, or aromatic compounds.
- Ocean Acidification/Oyster Bed Protection: Cosmo has teamed with CH2M Hill to produce state-of-the-art hydrodynamic studies of the mill’s effluent diffusion zone. This will allow the mill to control any effluent issues with significantly less chemical treatment. The outcome will ensure the highest water quality standard for local oyster growers and reduce treatment chemicals that may contribute to ocean acidification.
The heart of our environmental safety: air and effluent emission permit compliance
By working with local and federal government agencies tasked with protecting the environmental needs of our area – the Washington State Department of Ecology (DOE) and the Environmental Protection Agency – we can do our part to look after the environment, an economic driver in the community we share.
As part of that stewardship, Cosmo Specialty Fibers operates under a strict set of environmental permits issued by the government agencies for air and water impacts, as well as any operational impacts on the land within the mill footprint. These permits are “living documents” (viewable here: http://www.ecy.wa.gov/database.html ) in that they are subject to change at any time as directed by the DOE or EPA, thus ensuring that our local environment and community is always cared for.
There are five important considerations – mandated by the DOE in the development and approval of these permits – that guide the mill’s environmental approach:
- Strict air emission and water effluent limits. The mill must be financially sustainable to remain open. To be financially viable, the mill must be globally competitive in terms of product mix, quality and cost. These operational characteristics drive the feedstocks we use, which, in turn, results in certain potential mill effluent and emission levels. These effluent and emission levels cannot leave the mill until they are within strict limits determined as environmentally acceptable by the DOE and EPA. These limits are written into our permits as law, along with the accompanying reporting requirements.
- Best Management Practices (BMPs). Another government agency and industry term, BMPs means that we work to adopt best management practices used in other, similar mills in our handling of environmental processes and regulations. Importantly, the Weyerhaeuser legacy resulted in this mill often being officially cited as “best in class” and an example for other mills to look at. Our capital expenditure plan is intended to carry on that legacy.
- Renewing, recycling, cleaning. For over 60 years, the mill has been a major recycler of operational feedstocks. Our softwood fiber is a renewable resource, and is PEFC™ certified. A major part of our energy generation is biomass or “green” energy from the use of bark and other waste material. We reuse a significant volume of our chemicals in the pulping process through our recovery system and as much pulp byproduct waste as possible is dried out and used in energy generation. We then use washing, clarifying, secondary treatment and diffusing on the effluent side, and scrubbers and precipitators on the emissions side.
- Legal obligation to report on all mill activities. As part of our legal obligations under our environmental permits, we must consistently and transparently report to the DOE on what effluent or emissions leave the mill. We also must report any episodes where a permit level was exceeded, and what we did about it. And, if we are contemplating any engineering or product changes to our operations that might have an impact on our legal effluent or emission levels, we must report these planned changes to the DOE, before any implementation is approved. Finally, we must have appropriate community relations plans in place to advise the surrounding communities of our activities or issues in a timely manner.
- Accountability. We are a human enterprise running complex technology and we recognize the ongoing challenges associated with meeting our public and regulatory environmental obligations. But, because we live here and intend to be here for the long-term, our commitment is to consistently meet those challenges and to keep our surrounding communities informed of our actions in this regard.