Dear Editor,
The Guyana Forestry Commission (GFC) refers to an article published on page 23 of the Sunday February 10, 2008 edition of Kaieteur News under the caption “FPA lashes out at GFC over new regulations”.
This article is as equally misleading as a letter published on pages 4 and 5 of the Saturday 26th January 2008 edition of Kaieteur News by one Anthony Lim under the heading ” The Guyana For-estry Commission is crippling the forestry sector” since it is in essence, a repetition of the misinformation peddled by Mr Lim.
The GFC submitted a comprehensive factual response to the letter penned by Mr Lim on Sunday 27th January 2008 to the print media. To date, Kaieteur News has not seen it fit to publish the GFC response; instead it chooses to publish yet another article that is unjustly critical of the GFC without giving the GFC an opportunity to set the record straight.
As the regulatory agency for forestry in Guyana, the GFC is duty bound to let stakeholders be aware of what the real issues are, and GFC will therefore address this matter again, hopefully for the last time.
The state forest estate of Guyana is the patrimony of all stakeholders and GFC has a responsibility to promote Sustainable Forest Manage-ment (SFM) in Guyana. In order to achieve this, a system of guidelines to govern the state forest estate must be in place starting from the allocation of concessions, to harvesting, processing and export of forest produce.
These guidelines such as those for conducting Forest Inventories, preparation of Forest Management Plans and Annual Operational Plans (FMPs; AOPs); the Code of Practice for Forestry Operations etc. have been in existence for at least seven (7) years, and were arrived at through a thoroughly consultative process, involving all stakeholders, especially those directly linked to the sector.
Over the last six (6) years, GFC embarked on an aggressive sensitization campaign aimed at further educating stakeholders on these guidelines, so that implementation could be done in a phased manner with full compliance in 2006.
Pre-harvest inventory gives a clear picture of the commercial trees present in the blocks to be harvested, and therefore facilitates better operational planning for harvesting, marketing etc. It is an essential aspect of planning if companies are serious about doing efficient business and maintaining competitiveness.
Contrary to the claims of the Forest Products Assoc-iation (FPA), the government has not issued a recent ultimatum to the industry to submit complete pre-harvest inventory as outlined below.
Since 2006, the GFC held meetings with all companies that had active Timber Sales Agreements and Wood Cutting Leases (TSAs and WCLs) to remind them that they had to be operational under a five (5) year Forest Management Plan (FMP) and that the 100 % inventory for all blocks to be harvested in 2007 had to be included as an integral part of the Annual Operational Plan (AOP) for the calendar year 2007. This information was also formally sent to concessionaires by way of individual letters, and also via public notices in the media, and posted at forest stations country wide.
To further assist companies, the GFC offered to provide technical support on a cost recovery basis, based on written requests. Only a few companies took up this offer.
A comprehensive audit of field activities in the latter part of 2007 indicated that whilst many companies identified the blocks to be harvested in 2007 and actually harvested in these blocks, all of the required 100 % inventory information was not submitted. Several companies were penalized because of this non compliance.
In September 2007, the GFC again sent notices to concessionaires reminding them of their obligation to submit AOPs by November 30, 2007, inclusive of the 100 % inventory information for the blocks proposed for harvesting in 2008. Companies were again offered technical assistance by the GFC, based on written requests.
The facts reveal that by January 31, 2008 (two months after the deadline of November30,2007),only seventeen (17) of the twenty four (24) companies submitted their AOPs (70.8 %). However, only five (5) companies (20.8 %) had provided partial 100 % information. The remaining companies are still to provide the GFC with this information.
The GFC has to do field verification of the inventory information before it gives approval for harvesting to commence. This field verification is not a 100 % exercise as the FPA tries to imply, but rather a 2 % quality control sampling to give assurances that it meets the GFC’s standards. More detailed sampling intensities would only be needed if a lot of variation is observed in the initial 2% sampling.
The total acreage under TSAs and WCLs is approximately four million (4,000,000) hectares of productive forest. This corresponds to a total annual allowable acreage of approximately fifty thousand hectares (50,000 ha) on a sixty (60) year cycle or a maximum of five hundred (500) blocks to be inventoried by all the TSAs and WCLs combined.
To further elaborate on this, Barama Company Limited (BCL) accounts for more than 50 % of this total annual allowable acreage. The combined inventory required to be done by all of the other concessionaires (TSAs, WCLs ) is less than two hundred and fifty blocks (250).
This debunks the example of the FPA that larger concessions (other than BCL) have to inventorise three hundred (300) blocks in a calendar year. Also, pre-harvest inventory is expected to be an ongoing exercise; it is a requirement of the planning process, and an obligation that all concessionaires were aware of when they applied for their forestry concession lease. It is not an optional exercise.
As part of his ongoing meetings with stakeholders, the Hon. Minister of Agriculture invited the FPA to a meeting on January 8, 2008. The Commissioner of Forests was also in attendance. At that meeting, the FPA members accepted that they were delinquent in their inventory submissions, and requested additional time to submit this 100 % inventory information. The Minister and the GFC agreed to facilitate this request on the conditions that:
– All 100 % inventory information must be submitted on or before May 31, 2008
– No harvesting would occur in any block unless the 100 % inventory information was submitted to, and approved by the GFC.
The GFC wrote to the individual concessionaires after that meeting, clearly outlining that once 100% inventory was submitted for specific block(s), those block(s) would immediately be verified by the GFC, and based on that exercise, a decision would be taken whether approval would be granted for harvesting. There was never any conditionality as is stated by the FPA that the 100 % inventory information for all blocks in the AOP had to be submitted together to the GFC before any verification was done. What was explicitly stated was that all 100 % inventory information has to be submitted by May 31, 2008.
After careful review, approval has now been granted by the Government for the renewal of some of the leases which expired in 2007. Contrary to the FPAs statements that these companies must complete their FMP and AOP before harvesting is allowed to begin, the GFC met with these concessionaires on Thursday February 7, 2008. At that meeting, companies were informed that they had to submit at least one (1) block of 100 % inventory information to be verified; once the results of the verification was acceptable, then permission would be granted for harvesting to commence.
The companies were further advised that the AOP was to be submitted to the GFC by February 29, 2008, and the FMP by June 2008. All companies represented at that meeting were in agreement with the timelines established for AOP and FMP submission, and the decision taken with respect to the 100 % inventory.
On the issue of standards for the wood processing industry, again the FPA is misinforming the public. The
GFC had made several presentations in 2007 to remind stakeholders of the standards to be implemented in 2008, and emphasized the fact that these standards were publicized since 2005, with the objective of full implementation in 2006. During these outreach meetings in 2007, stakeholders made several submissions which were all discussed at joint meetings of the FPA and GFC. Agreement was reached on a final document, and this document is now being publicized throughout the sector with the implementation date now set for April 1, 2008.
This is completely contrary to the assertion of the FPA that the GFC chose to ignore the recommendations of the subcommittee and that saw millers and timber dealers who are unable to conform to these standards will be shut down.
Companies that manage sawmill /lumber yard operations were advised in 2007 that they had to have approvals/no objections from several agencies including the Environmental Protection Agency, the Central and Housing Planning Authority, the Neighbourhood Dem-ocratic Council before the GFC could issue a licence for 2008. These operators were advised that this documentation was essential and that it would take some time to acquire all. However, most companies have not provided the GFC with all of the required documentation, even though applications for renewals should have been made since 2007. The GFC has extended the renewal process up to February 29, 2008.
The above facts clearly show that the GFC is in no way culpable for the lateness of renewals and for the inactivity in the forestry sector during January/February 2008.
The GFC in the interest of the sector commits itself to processing documentation as soon as it is received. However, in keeping with GFC’s motto of “Ensuring Sustainable Forestry”, all procedures must be applied in a consistent, transparent and credible manner. It must be stressed too, that these are not new rules being imposed overnight on the sector; these guidelines were developed in a consultative manner with all stakeholders several years ago.
The GFC has spent considerable time and resources to publicize these guidelines, and also train stakeholders on how to interpret and implement same. Constant reminders were sent out in 2007, in addition to the outreach meetings.
To state then that “The GFC is unduly focused on implementing punitive measures on an already regulated industry, rather than working in partnership with the industry to foster, encourage and facilitate growth and development of the industry” is most unjustified.
Without the continued implementation of the guidelines for SFM by the sector and the rigid enforcement and monitoring of the GFC, maintaining access to the current overseas markets would be in jeopardy. Entering new niche markets would be practically impossible.
It is a fact that forestry is now a significant contributor to the national economy. To further improve on this contribution, the FP A and non-FP A stakeholders must appreciate that the GFC has to enforce implementation of these collaboratively formulated and agreed on guidelines so that we meet the environmental standards expected of us in order to achieve Sustainable Forest Management.
Yours faithfully,
James Singh
Commissioner of Forests
