Dear Editor,
The Forest Products Association (FPA) wishes to respond to a letter from Mr James Singh, Commissioner of Forests, published in the Guyana Chronicle of January 31, 2008, which makes a number of assertions with regard to the performance of the forestry sector in 2007 and in regard to the granting of licences to foresters for 2008.
The Association is surprised and disappointed at the Commissioner resorting to the use of highly intemperate language inappropriate for a professional public servant.
The FPA wishes to point out that the forestry sector is now a significant contributor to the national economy, earning in excess of US$60 million annually and employing over 20,000 persons, exceeding even the contribution of the rice and fisheries sectors.
Exports have increased from US$42 million in 2004 to US$62million in 2007.
This growth and viability of the industry is mainly as a result of the investment of the private sector with little or no government financial support.
The industry’s survival, however, is dependent on the government’s, through the Guyana Forestry Commis-sion, commitment to work in collaboration with the industry and to give due consideration, attention and effect to the needs and concerns of the industry’s stakeholders.
Instead, it is the experience of the FPA that the GFC is unduly focused on implementing punitive measures on an already over- regulated industry, rather than working in partnership with the industry to foster, encourage and facilitate the growth and development of the industry.
At a special FPA meeting, in November last year, attended by a wide cross section of the industry ranging from major producers operating Timber Sale Agreements (TSAs) to small producers, sawmillers and timber dealers, to review outstanding issues between the industry and the GFC, the meeting was unanimous in its call to the Commission to consult more closely with the Association. The meeting registered its concern with regard to a host of proposed changes being rushed into implementation without adequate consultation.
The meeting noted that the GFC’s determination to enforce wholly impractical standards and conditions for wood processing without due consultation would result in significant harm to small producers and sawmillers especially.
The Commission agreed to meet with the FPA’s Technical Sub-Committee on this matter but has chosen to virtually ignore the recommendations of the Committee and has now issued a warning of closure by the 31st January to all timber dealers and sawmillers who are unable to conform to these standards. This will result in small producers and sawmillers shutting down.
The government, through the GFC, has now issued an ultimatum to the industry demanding concessionaires submit “complete pre-harvest inventory (100% commercial species) for all blocks to be harvested in 2008” and that “formal written approval must be obtained from the GFC before harvesting commences in any block, during the year 2008, commencing January 2008.”
This is an arbitrary and capricious decision. It is a complete departure from established practice. If this policy is enforced, it will result in the shutdown of all major forestry production and the consequential unavailability of downstream materials for manufacturing.
Already, as 2008 begins, the majority of the major companies have been unable to commence operations and export their produce while being forced to wait on the GFC to approve licences and Annual Operational Plans (AOPs). The result will be a dramatic reduction in production and in the exports of both primary and downstream product and a significant loss of international market share for Guyana.
The FPA has written to the Commission pointing out that, in fact, the submission of inventories as a requirement of harvesting has always, as a practical matter, been implemented and accepted by the Commission in conjunction with harvesting taking place on a block by block basis, usually covering a period of 2 to 3 months production at a time.
The Commissioner is well aware that the granting of AOPs has never been conditioned by the advance submission of timber inventories. It has always been the accepted practice to conduct timber enumeration progressively in batches of blocks, which are endorsed by the Commission for harvesting on submission of a “notice of intention” by the concessionaire.
The Commissioner is also aware that actual on site inspection by the GFC of inventorised blocks has been performed on an ad hoc basis by the GFC and not as a pre-harvest requirement. The likelihood of the Commission being able to deliver timely inspection of all the concessions to meet the pre-harvest inventory requirement is extremely remote.
The Association must seriously question whether the Commission has professionally advised the Minister on this matter.
For instance, larger concessions are divided into as many as 300 blocks of 100 hectares each, spread over an area of 30,000 hectares of virgin forests to be harvested within the year. A network of main and secondary roads must, therefore, first be constructed to provide access for inventorising. In practice, in order to sustain production, these roads are built in consonance with inventory surveys being progressively conducted in batches of blocks as we have outlined above. If these new requirements are to be enforced from now on, the 300 blocks will increase to 600 blocks to satisfy next year’s AOP requirements.
It has been the norm and accepted standard practice in the industry to employ a highly trained team of 7 to 12 persons in order to complete a 100% species enumeration of 10 blocks in one month at a cost of $300,000 per block. To complete an advanced inventory of a large concession with some 300 blocks would, therefore, take at least 30 months. To shorten this period would mean employing many more survey teams at a substantial increase in cost and would make accurate supervision practically unworkable.
The government’s dictum demands that all of this must be done prior to harvesting in 2008 and each year thereafter, requiring that enumeration for 2008 and 2009 would, in fact, have to be done consecutively, an impossible task, given the availability of trained personnel, the financial cost and the time involved.
The GFC has further directed that the Commission must give “formal written approval
