Inventories of the forest have been made since 1908, data suggest
purpleheart is about 0.6 per cent of the tree population
Sunday, July 15th 2007
Dear Editor,
I am sorry that the technical forestry expertise of Samantha Griffith is
weak, in her letter captioned "Large concessions are managed on the
principle of cyclic rotation" (Kaieteur News, 2007.07.12). Responding to
some of Ms Griffith's technical points -
Purpleheart - reliable data
on forest frequency
The GFC manual on Guyana strategic forest resource appraisals indicates "a
wealth of data" on forest composition. Inventories have been made of the
forests of Guyana since 1908. Reconnaissance-level studies were carried out
especially in the late 1960s in the FAO-assisted Forest Industries
Development Surveys, ecological studies have been boosted in the 1980s/90s
in the Tropenbos-Guyana programme, and the GFC currently accumulates
management-level data.
In a compilation covering the forest regions of Guyana in 1998, Hans ter
Steege of the Tropenbos Guyana Programme summarised data from 16 widely
distributed plots covering 50 hectares in the central wet forest, with an
average of 4,101 trees per 100 hectares, of which 26 were purpleheart. In
the northwest wet region, from 14 plots covering 24 hectares, with an
average of 4,824 trees per 100 hectares, 25 were purpleheart. Occurrences in
these two main regions of 0.6 and 0.5 per cent of the tree population
(counting trees more than 30 cm in diameter at breast height) mean an
average of one purpleheart tree every four hectares.
However, purpleheart is not uniformly distributed through the forest, and
sometimes the loggers encounter "reefs" or groups of trees. It is precisely
in these reefs that the GFC minimum inter-tree felling distance of 10 metres
should be obeyed by loggers. Chapter 14 of the National Development Strategy
2001-2010 says that the regenerative capacities of identified forest types
and species will be conservatively estimated (section 14.IV.2.11). In
contrast, there are reports of groups of giant purpleheart trees in a TSA in
Essequibo, logged destructively by the illegally sub-contracting Asian-owned
company, not in accordance with the specifications cited by Ms. Griffith.
[In a background paper for the meeting on log export policy in February
2007, the GFC provided forest inventory data from 7 representative current
logging operations (numbers of plots and areas were not mentioned).
Purpleheart trees of 40 cm diameter or larger in these areas ranged from 0.9
to 6.1 per cent, with an average of 2.3 per cent.]
Landlording or sub-letting under-
performing forest harvesting concessions
Landlording is not a matter of short-term contracts between large-scale
holders of forest harvesting concessions (like Barama) and large-scale but
inactive concession holders; Ms. Griffith implies that such contracts are of
one-year duration, which is not correct. The Initial Public Offering
prospectus of Samling Global Limited, the parent company of Barama, in March
2007 clearly indicated that Barama's renting arrangements (called
"harvesting rights") are for the remaining multi-year durations of these
concessions. Samling notes that these concessions expire in the period up to
2016 (having started from 1985 onwards and having 25-year durations).
Samling believes that the remaining periods are too short to justify
sustainable forest management (IPO prospectus pages VI-68 and VI-69; URL =
http://www.hkex.com.hk/listedc
sehk/20070223/LTN20070223016
report of the monitoring by ASI of the surveillance mission by SGS Qualifor,
Accreditation Services International GmbH notes that [Barama's] "areas
visited by the audit team outside the compartments under evaluation were not
managed in the spirit of the Forest Stewardship Council's principles and
criteria and major nonconformities could be witnessed by the ASI audit team"
(major corrective action request number CAR.SGS. FM.2006.04, URL =
http://www.accreditation
asiforestmanagementauditguyana
The GFC policy statement on concessions of April 1993 is explicit about
under-performing and inactive concessions. Failure to work a concession over
a two-year period (to the satisfaction of the minister) in accordance with
the terms of and schedules to the concession agreement, or failure to
extract timber at a volume which produces royalty in excess of the minimum
royalty over a three-year period may lead to cancellation of the concession.
I have quoted in recent letters to the Editor the exact sections of the
Forests Act and Forest Regulations concerning subletting of concessions, and
I note again here that Condition 13 of Timber Sales Agreements makes
explicit prohibition except with the prior written permission of the
President - not, as claimed by the GFC, the permission of the Commissioner
of Forests.
In any case, Barama is not a TSA holder which should be allowed to take over
any concession. The 1993 policy is also explicit that "No additional areas
will be granted to TSA holders until they have demonstrated their ability to
work existing concessions for maximum sustained yield." Barama has
repeatedly noted that it is harvesting less than one third of that level, so
it could not be eligible for more areas. And in addition, the National
Forest Plan of February 2001 specifies that "Alloca-tion of the resource is
made in a competitive, fair and transparent manner" (NFP 300), which the
sub-letting to Barama (and other Asian-owned loggers) is clearly not.
Specialisms in timber use
It is normal for specialist timber-using operations to concentrate on those
species which best serve technically and economically the objectives of the
enterprise. It would not be sensible to use low-density, rot-susceptible
timbers for garden furniture, but these semi-soft timbers may be quite
suitable for core veneers of utility-grade plywood at Land of Canaan. It is
surely in the interests of Guyana, with over one thousand timber types, to
have a variety of industries capable of using appropriately this variety of
timbers. Consultant reports have repeatedly advised Guyana to develop and
promote niche markets, because its location off the main shipping routes and
its relative industrial inefficiencies make it difficult to compete in mass
markets; see for example the diagnostic mission of the International
Tropical Timber Organization published in 2003, and the support of the
USAID-funded Guyana Trade and Investment Support Programme for penetration
of new markets.
Investment incentives
The Guyana Revenue Authority records that 76 per cent of tax incentives in
2004 in the forest sector went to Barama, and 87 per cent in 2005. Later
data are not yet available. This great preponderance allowed to one single
foreign-owned company is questionable when that company is exporting
unprocessed logs instead of processing them in-country, the latter being a
major intention (from the Guyanese side) of the foreign direct investment
arrangements of 1991, 2001 and 2004. Barama exported at least 119,000 m3 of
logs (almost 80 per cent out of a GFC-recorded national total of 150,000 m3)
in 2005-6 but processed only 63,000 m3 of logs in its plywood mill (running
at 25 per cent capacity) and only 14,000 m3 of logs in its two sawmills
(running at 6-7 per cent capacity, data from Samling's IPO prospectus).
GFC Board papers
GFC Board papers have been quoted before in public domain publications,
including those in Stabroek News' 'History This Week' columns of January 29,
February 5 and February 12, 2004 which featured the Guyana Forestry
Com-mission. A GFC Board Member has publicly expressed fears about the link
between narcotics and forestry concessions in Guyana (see letter in SN
titled 'The drug cartel has already penetrated our timber industry and has
much bigger plans', March 16, 2005) and about forestry practices more
generally (see, for example, 'Indiscriminate log exports a creation of
Forestry Commission… PNCR' in Kaieteur News, November 27, 2006).
This is what democracy is about. The democracy we all enjoy today is the
result of a long struggle by many Guyanese. That democracy permits any
citizen the freedom to comment on any aspect of our national life.
Conservation of particular timbers
Section 2.3 on page 8 of the GFC code of practice on timber harvesting
(November 2002) includes a note that "sustained yields can only be ensured
if a minimum stocking is retained after logging for each individual
(emphasised in the GFC code) desirable species... This means that individual
tree-marking rules need to be developed for each particular forest type
under different stand conditions. Yield regulation is an area of active GFC
policy and research."
So, nearly five years later, can we be sure that the GFC has such individual
rules and that they are being applied? Especially when the production and
export of a relatively rare but valuable timber such as purpleheart is
comprising an increasing proportion of the outturn? As noted above,
purpleheart is a generally uncommon tree yet in 2005 it comprised 31 per
cent of total log exports and 42 per cent of sawn lumber exports.
The reports to Barama by its technical consultant ECTF during 1992-2000
indicate how easily degraded is this forest resource by careless logging.
Barama wastes and damages much more timber than it extracts. Barama's
piratical and self-acknowledged unsustainable logging should give every
ground for caution by the GFC when the proportion of purpleheart to all
other timbers in log production and log exports is so much higher than the
proportion in the standing forest.
Appeal to the national laws,
regulations and policies
My analyses and observations on the forest sector have been referenced
invariably against our published laws, regulations and procedures. My main
and repeated observation is not that these documents are inappropriate but
that they are not properly or equitably applied; this is hardly the
"misinformed, hypocritical and anti-Guyanese" stance which Ms Griffith
alleges. Evolution of these documents took place vigorously during 1993-2002
but little has been visible since then. The revised forest law of 1995-1996
still has not reached the National Assembly, and the draft is now well
behind best international practice. Of course it would be desirable to
follow the practice of many other countries and to have an open and
participatory forest forum for sector debates in which the GFC is just one
among the stakeholders and without a dominant and domineering voice,
although obviously a key player. We are not seeing those wide stakeholder
consultations which Ms Griffith advocates, only GFC-controlled admissions
and GFC-commanded attendances. I am sure that governance problems in Guyana
are not confined to the forestry sector, but it would be a start to clean up
governance in this area.
Yours faithfully,
Janette Bulkan
Please Email Comments to guyanaforestryblog@gmail.com
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