Dear Editor,
I was pleased to see an unusually quick response by the Commissioner of the Guyana Forestry Commission (GFC) (‘Guyana has a well established record of forest management which is compliant with international environmental and best practice,’ SN, August 12; and ‘Guyana has a well established record of forest management, harvesting,’ GC, August 13) to my letter ‘Will the Minister of Agriculture now be moving towards independent forest monitoring in the forest industry?’ SN, August 11).
Unfortunately, the Commissioner provides only his standard type of reply to any queries about implementation of national forest policies and procedures: that Guyana has a set of policies and procedures, and people have been trained. No evidence is provided about implementation. We are apparently expected to believe that if Mr James Singh says that something is or is not happening in forestry then that is the case. Instead, what evidence we have is that this is not actually the case, hence the importance of independent forest monitoring, which was the subject of my original letter.
Mr Singh invites attention to the LCDS and GFC websites. The LCDS website continues to reflect the President’s back-of-envelope approach to major projects, with no publication of comparative economic studies to indicate why any one of the President’s schemes should be preferred over other options. For example, the Amaila Falls dam gets just a single paragraph of justification on page 26 of the May 2010 version of the LCDS draft, in spite of its US$650 million estimated cost.
Would it not be worth asking if fixing the 44 per cent transmission line losses in the existing electricity distribution system, or the 20 per cent losses through illegal connections, might not provide more value for money? Recently we were told that the IDB is now doing a feasibility study for the Amaila hydro; meanwhile a contract was awarded to build a road before the feasibility study was actually conducted.
Forestry gets two pages (30-32) in the May 2010 LCDS draft, but nothing is said about improved forest management or about reducing the 4.6 million tonnes of carbon emitted annually from poorly controlled logging and construction of forest roads (estimated and published by Janette Bulkan in SN in July-August 2009 from GFC data). Instead, this section in the LCDS proposes adding value to forest products and says, “Guyana can use market mechanisms to keep logs in the country for processing.” As the monthly statistics from the GFC-controlled Forest Products Marketing and Development Council show, the GFC’s idea of market mechanism has done nothing to stem the flow of our best timbers as logs to India and China for processing and adding value there.
In contrast, the GFC’s website and the international e-circulation system advertised on August 10 (after my letter was written) a call for independent forest monitoring. I will come to that advertisement later. I would like first to analyse the GFC response of August 12/13, 2010.
Mr Singh says that “Guyana has a well established record of forest management and harvesting which is compliant with international environmental and best practices.” This is not correct. What Guyana has is a set of procedures on paper, mostly dating from the donor-funded GFC institutional reform project 1995-2002. The Code of Practice for Timber Harvesting, developed in 1996 and revised in 2002, is still voluntary instead of being incorporated into the Forest Regulations 1953 and thereby being made obligatory for all relevant (long-term) concessions; obviously the techniques for sustainable forest management which should be implemented by the loggers who hold 25-year concessions would not also be applicable to salvage-logging concessions which are issued for two-year periods (State Forest Permissions) nor to the long-term concessions which the GFC now rolls over on annual licences (entirely contrary to the National Forest Policy 1997 and the National Forest Plan 2001). The lack of transparency by the GFC extends to not indicating which concession licences do oblige conformity to the Code of Practice; selectivity of such obligation appears to be in contradiction to the requirement of the Guyana Constitution for equality of legal obligations/non-discrimination.
The GFC Act revised in 2007 requires an annual report and audited accounts for presentation to the National Assembly. This reporting has not been done, nor indeed for many years previously, so the citizens of Guyana have no means of formally examining just what the GFC does. We have only the unsupported statements from the GFC Commissioner.
The independent assessments which are available are not supportive of the Commis-sioner’s claim to compliance with international best practice. The conformity assessment body SGS Qualifor and Accreditation Services International (ASI) found in late 2006 that the largest-scale logger, Barama, was grossly deficient in its management practices. Barama’s FSC certificate was and remains suspended.
Another ASI-accredited conformity assessment body was subsequently hired by Barama and likewise found gross deficiencies. Since then, Barama has abandoned its interest in forest certification, and only the Iwokrama Inter-national Centre for Rainforest Conservation and Development is now FSC-certified. Moreover, the GFC Commissioner has been discouraging about such voluntary, independent, third-party certification in Guyana: see minute 5.14 of meeting 23 of the LCDS Multi-Stakeholder Steering Committee (MSSC) on March 2, 2010. Why would the GFC Com-missioner be so discouraging about best-practice forest certification when some 135 million hectares of forest (ten times the size of the Guyana State Forests) are FSC-certified globally through 1026 certificates, and 223 million hectares through the Programme for the Endorsement of Forest Certification (PEFC) scheme?
Norway commissioned the CGIAR Centre for International Forestry Research (CIFOR) to assess forest law enforcement and governance and practices in Guyana in relation to the country’s process to reduce emissions from deforestation and forest degradation. Undoubtedly the report of that consultancy contains errors, but the draft appears to have suffered from lack of access to the correspondence files, office records, databases and maps held at GFC HQ, as well as to the absence of regular and complete annual reports. MSSC minutes indicate that CIFOR is not willing to accept the unverifiable assurances of the GFC as the last word.
The GFC Commissioner claims that “Guyana has probably the only truly national log tagging and log tracking system in the entire world.” It is not clear what this means, and many countries have their own tagging and chain of custody systems. A system was proposed for Guyana through a consultancy by SGS in 1999 and was partly implemented by the GFC, but has become widely abused; see http://www.illegal-logging.info/uploads/ Timber_Tags_Guyana_Paper_CH_Update.doc.
A two-stage project with donor funds to re-develop a tracking system suffers (relative to global best practice) from the insistence by the GFC Commissioner that the databases should be held on servers in Guyana under his control. Other countries, such as Liberia in West Africa, have the timber tracking information uploaded to servers outside that country and thus not subject to internal political or other interference or discrimination. Guyana has a long way to go to match best practice.
The non-functioning of the 25 forest stations was mentioned in the CIFOR report of 2009, in relation to their effectiveness in monitoring (page 19). If the forest checking stations were functioning, then one would expect to see alleged offenders against the forest law being prosecuted in court. But even when the President (as Minister of Forests) was fretting about Barama’s numerous illegalities in 2007-8 that company was given administratively-decided penalties instead of being taken to court, and that administrative procedure was itself not correctly applied. There have been no court prosecutions for alleged in-forest offences for many years. And no annual report where such cases are reported by law and custom as in other countries.
The low rate of deforestation in Guyana is due to the extreme natural poverty of the ancient soils. Unlike the basin of the River Amazon in Brazil, which has been subject to geological cycles of uplift and downwarping, of accretion and erosion, most of the soils of the hinterland of Guyana have been stable and exposed for millions of years to rain which leaches out the plant nutrients. Amerindians and Brazilians alike recognise that farming such ancient soils is very hard work and needs long periods of fallow to sustain even modest crops.
So, unlike Brazil, there is little demand for hinterland conversion of forest to farm. That has been known for many years, although apparently the President did not inform the McKinsey Consultants who produced the first draft of his Low Carbon Development scenario in 2008. So the low rate of deforestation (~0.29 per cent in 2007-8 according to the GFC’s own surveys) has nothing to do with the GFC’s feeble field presence.
The claimed “proactivity” with respect to the EU’s Action Plan on Forest Law Enforcement, Governance and Trade (FLEGT) appears from the public record to consist of one exchange of letters with the European Commission’s FLEGT office, one brief visit in March this year by a FLEGT staffer from the European Forest Institute in Finland (EFI, not ETI as stated by the GFC Commissioner) and some discussions scheduled for next month. This is proactive engagement by the GFC?
Then the GFC Commissioner lists a number of activities from his annual work plan which have little or nothing to do with my enquiry to the Minister, which was about independent forest monitoring (IFM).
However, he did also mention that the GFC has developed detailed terms of reference (TORs) for IFM. These 15 pages were published on the GFC website on 10 August (after my letter was written to SN) and circulated internationally on August 12.
The mixture of good points and bad points in these TORs is surely worth a public discussion, as they illustrate how a Guyana government agency grapples with the conflicts between what is international best practice and what the government’s democratic centralism means for these agencies.
Yours faithfully,
Tarron Khemraj
