11 July 2007
Many opinions have been registered regarding both the substantive and
due process issues about the past performance and future prospects of
the Barama Company Ltd (BCL) under the Forest Stewardship Council (FSC)
certification framework since the January 2007 suspension of BCL’s
certificate (SGS-FM/Coc-2493) by SGS-Qualifor (of the Société Generale
de Surveillance), an independent FSC-accredited certification body).
Many of these opinions are summarized in a recent paper by Janette
Bulkan and John Palmer, entitled "Lazy days at international banks: how
Credit Suisse and HSBC support illegal logging and unsustainable timber
harvesting by Samling/Barama in Guyana, and possible
reforms"(http://www.illegal-logging
item=document&item_id=484
The following summarizes WWF’s views on the key issues raised to date
and our recommendations to move the debate forward constructively,
despite what is clearly a difficult, controversial and often emotive
debate among various stakeholders:
1. WWF agrees with the general recommendations of the report for
greater transparency, pubic disclosure, verification of performance and
accountability mechanisms. This applies equally to the 4 main subjects
of the paper: Credit Suisse, HSBC, BCL and its parent company, Samling
Global Limited.
2.. Many of the issues raised in the report are complex and
interlinked, particularly those pertaining to the interpretation of
Guyanese law, philosophy of responsible forest management and the FSC
certification process. WWF believes the issues summarized below
illustrate the crux of the debate and the divergent views amongst the
more vocal stakeholders:
• The terms of the Foreign Direct Investment (FDI) agreements that gave
rise to BCL.
• The sub-contracting of logging operations by lease holders on their
concessions to third-parties.
• The over-harvesting of logs on BCL’s concession as well as other
lease-hold lands where BCL conducts harvesting operations as a
sub-contractor.
3. WWF believes the legitimacy of the Foreign Direct Investment
agreement should be validated by the authorizing agencies (GOINVEST) in
Guyana. This should include public disclosure of the terms and
conditions therein (while ensuring the confidentiality of commercially
sensitive and proprietary information). A comparison of the FDI
agreement and today’s regulatory requirements, as well as those in
force at the time it was negotiated, would be informative.
Performance of BCL under the terms of the FDI agreement should be
publicly disclosed by the regulatory agencies responsible for
monitoring compliance.
4. The legality of sub-leasing/contracting practices by BCL (or any
other party) from independent concession holders or from Amerindian
titled lands (either directly or through intermediaries) should be
validated by the regulatory agencies. If need be, this could also be
verified via independent means. Substantiated irregularities should
be investigated and pursued through due process. WWF notes the opinion
of the Guyana Commissioner of Forests that BCL’s Timber Sales Agreement
allow it to enter into contractual arrangements with smaller logging
companies to supply logs to BCL milling operations
(http://www.stabroeknews.com
all approvals granted by the Guyanese Forest Commission should become a
matter of public record.
5. Questions regarding the appropriateness of harvesting rates from a
timber production point of view would be greatly facilitated if
credible baseline data were established. Debates over legal limits
versus actual harvest rates on a volume basis are very sensitive to
assumptions over rotation lengths, and difficult to assess in the
absence of credible baseline data. In the absence of a credible
baseline, alternative methods for determining harvesting rates should
be explored by the Guyana Forest Commission (such as area-based
calculations) until a credible baseline can be built to determine
appropriate harvest rates (by volume or species) for the forest type
being managed.
6. WWF categorically denies any and all allegations of undue
interference with the decision to suspend BCL’s certificate by either
SGS-Qaulifor or FSC, and the lack of due process in our participation
in the certification process within Guyana. WWF has no material
interest with any of the direct parties in this debate. Our sole
interest is to support responsible forest management in Guyana and the
viability of certification as a tool to help conserve the world’s
valuable and threatened forests.
7. WWF supports the open debate of concerns and views concerning the
BCL operation in particular and the Guyanese forest sector issues in
general. However, WWF believes that the sheer volume of
unsubstantiated allegations and accusatory inferences in the
abovementioned report oversimplify the complexity of the issues raised
and discredit the equally valid but differing views on the issues. WWF
believes that these issues can only be resolved if all relevant
stakeholders converse based upon facts in a civil and transparent
manner in the common interest of the country.
8. WWF reiterates its support for the certification process under the
FSC framework as a mechanism to address these issues in an open and
transparent manner, with input from all relevant stakeholders. WWF
recognizes the current escalated controversy is rooted in the
inadequate legal and institutional framework, insufficient data and
lack of capacity evident to date within the government, private sector
and civil society. Given this reality, WWF expects the utmost in due
diligence by the FSC-accredited certification bodies, as well as the
oversight by FSC’s accreditation body, Accreditation Services
International (ASI), regarding all aspects of the certification process
in Guyana.
9. WWF reiterates its call upon BCL to conform to the FSC's rigorous
environmental, social and economic standards through a distinct,
time-bound action plan, with periodic public disclosure, which will
implement the combined recommendations of both the SGS-Qualifor and
FSC/ASI assessment reports.
For further information, please contact:
Dominiek Plouvier Patrick Williams Bruce Cabarle
Representative Country Manager Guyana Managing Director, Forest
WWF-Guianas WWF-Guianas WWF-US
d.plouvier@wwf.sr pwilliams@wwf.sr
bruce.cabarle@wwfus.org
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