GFC has to implement guidelines to meet environmental standards

GFC has to implement guidelines to meet environmental standards
Guyana Chronicle, 16 February 2008
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, January 26, 2008 edition of Kaieteur News by one
Anthony Lim under the heading “ The Guyana Forestry 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, January 27, 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 Management
(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
(FMP’s; AOP’s); 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 Association (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 (TSA’s and
WCL’s) 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 AOP’s 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 November 30,2007), only seventeen (17) of the twenty four
(24) companies submitted their AOP’s (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 TSA’a and WCL’s is approximately four million
hectares (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 TSA’s and WCL’s
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 (TSA’a, WCL’s) 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 FPA’s 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
sub-committee and that saw millers and timber dealers who are unable to
confirm 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 Democratic 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 FPA and non-FPA 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.
JAMES SINGH
Commissioner of Forests