Dear Editor,
I respond to your news item (`Bulkan, manufacturers differ on sustainable management of greenheart.’ Stabroek News, 11 October).
I suggest that the GMSA consider the analogy of passing examinations, a great point of pride for the few successful children (and distress for the majority) when the Secondary School Entrance Examination (SSEE) results are announced each year. It does not matter that all children have innate and boundless intelligence. Our system for assigning places at the top secondary schools is based on performance as certified by SSEE marks.
Similarly, if you want to sell greenheart for use in a UK government project, you have to pass the equivalent of their SSEE examination.
As the GMSA notes, ‘the UK Environment Agency’s Technical Note refers to the sustainable forest management of the “Forests of Origin”. That means ‘the concession area from which a timber species has originated’. I do not know how that could be stated any more plainly.
The UK Government published in 2000 a policy and set of associated procurement rules for timber to be purchased for use on Government projects. Initially these rules covered only the legality of origin of the timber. Later the rules required demonstration of sustainable management of the source forest. A further change in 2009 allowed valid FLEGT licensing as a demonstration of both legality and sustainability. In 2010, the rules were extended to cover other social criteria.
It is for the UK importer to demonstrate in the competitive bid for a Government procurement contract that the timber to be offered comes from a source which is legal and a forest which is under sustainable management. It is for the UK importer to obtain that information from the exporting supplier. A forest may be under legal logging concession and managed sustainably, but if the exporter or importer does not provide the rule-defined information the bid will fail.
The GMSA seems to misunderstand the evolving UK Government timber procurement policy and rules. The policy and rules are not subject to government-to-government negotiation. The demonstration of compliance is at forest (concession) level, not country level. In plain English, the ‘forest of origin’.
An exporting country may hold a FLEGT Voluntary Partnership Agreement (VPA) but if the exporter does not have a valid legality verification certificate, the VPA itself is not a substitute.
The UK policy says nothing about management of forest carbon. References in GMSA’s paper to a Monitoring, Reporting and Verification System (MRVS) findings are irrelevant. References to ITTO desk reviews of the status of tropical forest management on paper are irrelevant. Indirect references to the partial and process-based monitoring by the GFA Consulting Group for Norway are irrelevant. Why? – because they do not audit the specific performance and conditions in a particular source forest.
Here is what a Winrock International report produced for the GFC in June 2014 had to say about illegal logging in Guyana:
“The majority of illegal logging in Guyana is the result of legal concessions extracting more than the allowable cut specified by the Guyana Forestry Commission. As a result, no additional infrastructure, such as skid trails, are developed for illegal logging, and the methods of harvesting are the same as those for legal logging. In addition, the volume of logs harvested illegally is reported as a percentage of annual production of timber in Guyana” (Goslee, Katherine, Sandra Brown, and Felipe M Casarim. 2014. Forest Carbon Monitoring System: Emission Factors and Their Uncertainties, Version 2, p. 10). This report is on the GFC website, http://www.forestry.gov.gy/wp-content/uploads/2015/09/Guyana-Emission-Factors-Report.pdf
Sourcing of greenheart for a UK Government contract from a SFP would not be acceptable, because 2-year SFPs are not sustainable; see the 1993 GFC concession policy.
Sourcing of greenheart from an illegally held TSA would not be acceptable because the concessions would be held in violation of the forest law and terms of the GFC-issued licence agreement.
Sourcing of greenheart from most TSAs would be unacceptable because, inter alia, the UK rules require that ‘all relevant royalties and taxes are paid’.
The UK sustainability rules require demonstration of ‘harvest levels that do not exceed the long-term production capacity of the forest, based on adequate inventory and growth and yield data’. For many years the harvest of greenheart has greatly exceeded the regeneration capacity of the forest, as shown by the University of Utrecht and Tropenbos. There should be concern about the more recent damage shown by Winrock International. However, the dismal national-level statistics do not prevent a local-level forest manager from doing better, and that is where GMSA’s reference to Iwokrama is correct and exceptional.
Iwokrama was created in 1989 to provide best-practice demonstrations. Within a decade, Iwokrama had good management plans but failed to find a reliable commercial partner to undertake sustainable harvesting. The Soil Association Woodmark audit against the Forest Stewardship Standard in 2008 carried a large number of Corrective Action Requests, few of which were closed before the certificate lapsed. Iwokrama is making another bid now for FSC certification. Therefore any wood harvested from Iwokrama’s certified area could be sold for use by the UK Government, if the present audit is positive for compliance with the FSC Standard for quality of forest management.
Minister of Business Dominic Gaskin said “greenheart is more than a local industry, it is part of our Guyanese identity” (Guyana Times, 4 October 2016). All Guyanese would agree and I suggest that all Guyanese would want to see greenheart sustainability demonstrated at the forest level. Just as we still demand that our little children pass the SSEE examination.
Yours faithfully,
Janette Bulkan
