A response from Surriekha Khan about Merlins Wood’s REDD projects in Pakistan

A (long) response that leads to more questions than answers.

On 16 February 2012, REDD-Monitor posted an article about a UK-based company called Merlins Wood. The company has signed two Memoranda of Understanding for two REDD-type projects in Pakistan, one with the Secretary of Forests of the province of Khyber-Pakhtunkhwa and one with the government of Pakistan administered Kashmir.

REDD-Monitor raised a series of questions about the projects and on 17 February 2012, the owner and founder of Merlins Wood, Surriekha Khan, sent a response. “I have provided you with an overall picture covering all the points you raised,” she wrote, “rather than individual answers to all your queries.”

Below is Surriekha Khan’s response. It raises many questions and leaves REDD-Monitor’s previous questions unanswered or inadequately answered. REDD-Monitor questions are posted below and REDD-Monitor and looks forward to posting Surriekha Khan’s response to these questions.

From: Surriekha Khan
Date: 17 February 2012 17:39
Subject: Re: Merlins Wood and REDD-type projects in Pakistan
To: Chris Lang 

Hello Chris,

Hope you are well and greetings from London. My name is Surriekha Khan and I am the owner/founder of Merlins Wood. Thanks for the email.

Sadly you have been somewhat misinformed by your sources. Your article is inaccurate on a number of points. However, I appreciate the right to reply, I only wish in the interests of balance you had contacted me before ‘going live’ with the story.

Please find the answers to your questions below. I have provided you with an overall picture covering all the points you raised, rather than individual answers to all your queries.

I would appreciate your thoughts on what you read and hope that you publish a follow on story to provide a full and fair assessment of the project and my company.

Regards

Surriekha Khan

Background

On May 4 2011, my company Merlins Wood signed an MOU with the Government of Khyber Pakhtunkhwa, a province in northern Pakistan, to jointly develop and implement a REDD project in the districts of Swat, Battagram and Manserha.

The province of Khyber Pakhtunkhwa (KP) has around of 1.6 million hectares of forest and our project area covers 232,000 hectares of the forest area in the province.

Half of the land in our project area is state-owned forest and the other half is owned by private landlords (classified as Guzara forests).

As part of the project, my family is one of the private landlords who has owned 34,000 hectares of forest in the project area since the mid 1800s, The company Merlins Wood was founded by me to develop REDD projects in Pakistan to preserve and protect critical remaining forest areas in the country. This land in KP owned by my family provided the foundation for our first project in KP.

After discussing the plans for a project on the land owned by my family with other land-owners in the region and representatives of the environment ministry in the provincial government, I personally convinced them (one by one) that the co-benefits of the project were such that we should widen the area and work in partnership to develop a province-wide REDD programme.

Deforestation is a huge problem in Pakistan and is particularly high in the province of Khyber Pakhtunkhwa.

REDD, whatever you feel its shortcomings may be, is the ONLY alternative available to us at the moment to halt this alarming trend before we lose all our forest cover.

So, the current of 222,831 hectares of primarily Himalayan moist temperate forests was earmarked for the project based on consenting land-owners, which is intended to be a ‘pilot’ for the province and other provinces in Pakistan.

Merlins Wood represents the interest of ALL the major landholders with the consent and support – who are heads of their communities – in the project area.

They are namely, Nawabzada Mohammed Fayyaz Khan, Nawabzada Ayaz Rustam Khan, Saleem Ullah Khan, Mohammed Irshad Khan, Jahanzeb Khan Advocate, Adil Nawaz Khan, Khalid Khan, Haji Jan Mohammed Khan, Mohammed Nawaz Khan (Jagirdar Hillan), Fida Mohammed Khan Allai, Mohammed Farosh Khan Allai, Kurshid Mohammed Khan Thakot, Atta Ullah Kha Thakot, Ameer Khan Kohistan, Abdul Rashid Khan, Afsar Khan, Ghulam Mustafa Shimlai, Syed Vakil Shah Manshera, Syed Nasir Shah Manshera, Shehzad Hussain Shah Mansehra, Mohammed Ali Wald, Mohammed Ajmal Kangwal Allai.

Land tenure rights in the project areas are clear and NONE of the forests are ‘disputed’. This information is publically available in Pakistan.

Consultation with all landholders and the communities they represent began early in 2009 and it was jointly agreed by all parties to develop a project in partnership with the Provincial Government through Merlins Wood.

SAFI are also now aware of this fact and have discovered that they were misinformed.

The Project

The ‘KP Project’ is being carried out under the leadership of Merlins Wood and the Directorates staff of the Khyber Pakhtunkhwa Forest and Wildlife Departments.

Other collaborating partners include the local communities living in and around the three districts of Battagram, Mansehra and Swat and agencies under UN One. Carbon development is being outsourced to the leading carbon development technical specialist in the field who works in partnership with Merlin’s Wood and the government.

The overall goal of the KP Project is to reduce GHG emissions from deforestation and degradation in the KP Province, while at the same time providing economic incentives to communities for sustainable forest management.

This goal is to be achieved through the implementation of a variety of specific project activities, including land-use planning, forest protection, assisted natural regeneration (ANR), fire prevention, social mobilization and education, distribution of fuel-efficient stoves, planting of woodlots, agricultural intensification, livestock management and non-timber forest product (NTFP) development activities.

The key drivers of deforestation in the project areas include: conversion of forest to crop land, conversion of forest land to settlements, illegal logging for commercial sale, fuel wood gathering, free grazing of livestock, forest fires, leasing of land for mining.

According to the 1973 Constitution of Pakistan, forestry is a provincial responsibility and provinces may draft and implement their own forest policies within the framework of federal forest and environmental policy.

This was further reinforced by the passage of the 18th amendment of the Constitution, which dissolved the Ministry of Environment and devolved all environmental-related responsibilities to the provinces last year.

This same amendment also changed the name of the North West Frontier Province (NWFP) to Khyber Pakhtunkhwa.

The legacy of colonial-era rulemaking in Pakistan, going back to the 1894 Forest Policy, is a top-down, non-participatory approach to the administration and management of forests in Pakistan.

This approach focused on revenue generation from forests rather than sustainable management, and largely excluded communities from the decision making process.

Excessive timber extraction in Pakistan led to the implementation of a ban on commercial timber harvesting that became effective in 1993 and is still in force today. But this has not stopped or even meaningfully slowed the deforestation rates on Pakistan’s few remaining forests.

Provincial Forest Departments (FDs) are responsible for the planning, execution and implementation of forest policies and programmes. In KP, the large majority of forests are encumbered with rights of the local communities for whom forest resources are critically important for subsistence.

Many of the forest policies enacted in Pakistan were not appropriate for land-use patterns in KP. Communities with traditional access to forest land for subsistence never fully accepted the role of the FD as stewards of forest resources, resulting in constant confrontation between government and communities.

To remedy this situation, KP became the first province in Pakistan to reform its forest law, enacting the NWFP Forest Ordinance of 2002, which contains explicit provisions relating to the implementation of community-based forest management.

The ‘KP Project’ will benefit from the active involvement of provincial government agencies and the above provisions.

At the provincial level, the Forest Department will lead other government agencies in design and implementation of the project activities and support for the on-going monitoring of the carbon credits created from the project.

Other provincial agencies that will be involved in this project are Forest Development Corporation, Wildlife Department, Fisheries Department, Agriculture Department, Livestock Department, Local Government and Rural Development Department. The supporting agencies will have their roles in the areas of their relevance to thematic focus of individual project activities

Together government agencies, existing community groups and local organisations will be involved in the implementation of project activities and the on-going monitoring of the carbon credits created from the project through use of participatory field data collection.

The level and intensity of the involvement of each of these organisations will be determined by expertise and relevancy to project activities and monitoring requirements. But the goal is to ensure that project actions will not only address drivers of deforestation, but build alternative livelihoods for forest dependent communities and that capacity to sustainable manage these forests will be built with all project participants.

For example, existing Village Development Committees (VDCs), Women Organisation (WOs) and Joint Forest Management Committees (JFMA) will be involved in capacity development, social mobilisation and income generation activities.

These organisations will also be monitoring the project actions in the field.

Progress

To date, we have completed a feasibility study for the project, which was completed by a leading firm in the field. This was prepared on the back of information gained during field visits and through consultative workshops with foresters in the region over the last three years that Merlins Wood has been planning and preparing the project.

The Khyber Pakhtunkhwa Forest department also has a wealth of historical data relating to these forests, which are divided into compartments for management purposes.

The Project area is home to more than 600 flora and fauna species, including snow leopards and the endangered Kashmir Markhor.

Villages dependent on these forests are organised through the formation of Village Development Committees, each maintaining its own targets and goals and receiving training for Project implementation and monitoring.

The KP project activities were evaluated for their potential to increase carbon sequestration and reduce emissions, and based on the eligibility guidelines under the Verified Carbon Standard (VCS) for the Reduced Emissions from Deforestation and Degradation (REDD) project type.

It is presently feasible under the VCS and CCB guidelines to develop the carbon from REDD in KP Province. Given the remarkable social and biodiversity benefits of the project, it is highly likely that the project will qualify for CCB Gold status in at least two areas.

Carbon development work for creation of the VCS and CCB PDs has now begun and this will include the signing of a benefits sharing agreement between all stakeholders as well as a detailed forest management and project implementation plan with clearly defined roles and responsibilities. The final benefits sharing terms and under discussion and not yet finalised.

As part of the Carbon Development process we will be producing a provincial baseline and our project will be nested within that. This will provide Pakistan with valuable experience that they can leverage for the development of their national REDD+ program.

Landowners or communities/groups with tenure will sign a management and benefits sharing agreement with Merlins Wood and only those land tenure holders who do will participate.

They are not to be forced to sign nor can carbon credits be claimed on their land without their approval, support and participation. Please be clear of this.

The Project Document, which will be developed for the project, as you are no doubt aware, is a public document and will be available for scrutiny. We are hoping to complete this process by September.

So, in summary: 

• The KP Project is a community-backed initiative, which has the support of the provincial government and will be the pilot and catalyst for a province-wide REDD initiative.

• All our agreements with the provincial government have gone through a rigorous vetting process, where all concerned departments have had the opportunity to raise concerns and questions.

• The Provincial Government is not so naive as to sign an MOU with us without us clearly demonstrating that we have the consent and truly represent the communities whose lives this project will impact.

• The concerned government departments and the communities dependent on the forests in the region will implement the project jointly.

• This project has been in the public domain for over a year now, but you choose to highlight it now.

Merlins Wood

Merlins Wood in the UK has a small staff and small offices in Berkeley Square UK. We feel the best use of our resources is to keep ‘central costs’ to a minimum.

No fancy websites no big pay packets, we are no ‘Asia Pulp and Paper’.

To date, the venture has been funded by personal contributions made by shareholders in the company. Naturally, we have an interest in the project because a portion of the forests belong to us.

We have an office in Pakistan and are currently recruiting staff there. The idea is to create jobs in the region through the project. We are a small family-owned company with a big goal. However, we are extremely proud of what we have achieved so far.

To date we have created the political will for REDD+ to be implemented, we have gained the support of the communities and have made key strategic alliances with partners who can genuinely make this project a success.

It is very difficult to convince Western businesses to commit to this type of project in Pakistan.

If we had been peddling hydrocarbons or minerals our job would have been much easier.

As for carbon being the ‘worst performing commodity’, we have no control over that. We are not market experts or soothsayers.

Nevertheless, we are confident that the number of credits our project produces will more than adequately cover costs, provide an income for all stakeholders and will ensure the project succeeds. Most importantly, it will help halt the rampant deforestation that is destroying vast swathes of forest in the region.

Merlins Wood has also signed a deal with Kashmir to help the state government develop a REDD project in the region on state-owned forests and this project is in the early stages of development.

We are currently doing a feasibility study for the Kashmir project and a decision on how we will proceed on that project will be made following the report.

On one hand you say we have a share capital of £200 and on the other we are accused of bribing our way to a deal in Kashmir, does that add up?

While we may have no experience of implementing a REDD project, we have allied ourselves with the leading experts in the field to drive forward development of the carbon asset and we are working with the Government of Khyber Pakhtunkhwa who has highly trained foresters with the infrastructure, manpower and expertise to manage a ‘forest conservation project’. Most are graduates of the renowned Pakistan Forest Institute in Peshawar.

However, more importantly, these are our ancestral lands and we have managed them for hundreds of years. And when you look at the newness of REDD+, very few projects are being developed by organisations with experience, and understanding the dynamics of deforestation, how to work productively with stakeholders in the project area and how to engage supporting technical expertise are the most important qualifications.

Our prime motivation now is to save and regenerate these forests for future generations and to provide our forest dependent communities jobs and alternative livelihoods.

If no action is taken now, then these forests will cease to exist in as little as 20 years. REDD offers us the chance to do something about this and we intend to succeed in using it as a mechanism to protection these forests regardless of the criticism and hurdles we may face.

We are fully committed and have a deep passion and personal interest to make this work.

So sadly, NO Taliban, and NO illegal-logging mafia.

Obviously it gives you a good, ‘look at those corrupt Pakistanis’, story for the day but it undermines and seriously damages three years of hard work put in by hundreds of people in the country trying to make a difference.

There is genuine wrenching poverty in these areas and forests are disappearing at an alarming rate. So the community and provincial government take it upon themselves to do something about it through a mechanism that has international backing. And the benefits of this innovative approach are simply dismissed by you all for what seems like a tabloid-style story for your website.

Chris, you clearly have strong views on the potential pitfalls of REDD, but to make such serious allegations against us without so much as a phone call or email, will not help anyone.

For the sake of what you thought was an ‘appealing story’ you have cast aspersions on me and the people and the government of both Khyber Pakhtunkhwa and Kashmir.

Plus you have thrown the Taliban into the mix. Why, what is the implication here?

I would personally like to invite you to come with me to Pakistan to see the work we are doing and to write about what you see on the ground.

It is not all corrupt politicians, corrupt institutions and extremists. Contrary to what you may have heard or believe, there are good people in the country.

If you really want to report the truth then please come and see what we are doing and then make an informed opinion.

I’m sure your readers would appreciate your efforts to dig for the truth. I appreciate you are a busy man, but the offer is genuine and there for you. We have NOTHING to hide.

If not, then I wish you well in your ‘anti-Third-World potential REDD corruption’ crusade. You did a great job on the anti-roads campaign in the UK I am sure you will help weed out corruption in REDD.

But in us, I can genuinely say that this time you have picked the wrong target.

Pakistan has made great strides in recent years to become REDD ready.

Through the tireless work of the country’s Inspector General of Forest Syed Mehmood Nasir, the country has achieved observer status on UN-REDD.

There is healthy debate in the country on how REDD can work here and leading environmentalist groups, stakeholders and government officials are all fully engaged and involved in making sure the problem of deforestation and forest degradation is tackled in the best way possible.

But based on the evidence on your article on us, you clearly are happy just to label ALL of us as corrupt, criminal extremists and maybe ask questions later.

Sincerely

Surriekha Khan for and on behalf of Nawabzada Mohammed Fayyaz Khan, Nawabzada Ayaz Rustam Khan, Saleem Ullah Khan, Mohammed Irshad Khan, Jahanzeb Khan Advocate, Adil Nawaz Khan, Khalid Khan, Haji Jan Mohammed Khan, Mohammed Nawaz Khan (Jagirdar Hillan), Fida Mohammed Khan Allai, Mohammed Farosh Khan Allai, Kurshid Mohammed Khan Thakot, Atta Ullah Kha Thakot, Ameer Khan Kohistan, Abdul Rashid Khan, Afsar Khan, Ghulam Mustafa Shimlai, Syed Vakil Shah Manshera, Syed Nasir Shah Manshera, Shehzad Hussain Shah Mansehra, Mohammed Ali Wald, Mohammed Ajmal Kangwal Allai.

From: Chris Lang
Date: 21 February 2012 13:42
Subject: Re: Merlins Wood and REDD-type projects in Pakistan
To: Surriekha Khan

Dear Surriekha Khan,

Thank you for your response to REDD-Monitor’s questions. I have posted your reply today. However, several questions remain about Merlins Wood and its REDD projects in Pakistan including some of REDD-Monitor’s previous questions.

While corruption is one of the risks involved in REDD, REDD-Monitor is not, as you suggest part of an “anti-Third-World potential REDD corruption crusade”. I wrote about this particular company because it seemed curious that Merlins Wood, a company registered in the UK, with only £200 capital and no experience of REDD, forestry or conservation projects would attempt to carry out this type of project. The fact that the Merlin Wood’s website provides no further information about the project just made me more curious.

As you say you have nothing to hide, I would be grateful if you could answer the following questions. “Sunlight is the best disinfectant,” as Louis D. Brandeis famously noted in 1913. I would like to post your reply as an interview on REDD-Monitor, so I would be grateful if you could respond to the specific questions rather than writing a general reply.

1. Your response does not explain exactly how Merlins Wood intends to reduce deforestation in its project areas, although you note that “Deforestation is a huge problem in Pakistan and is particularly high in the province of Khyber Pakhtunkhwa,” and that, “If no action is taken now, then these forests will cease to exist in as little as 20 years.” Could you please explain exactly what action Merlins Wood intends to take to reduce deforestation.

2. The previous post on REDD-Monitor referred to the Taliban control of Swat district between 2007 and 2009. This was based on an IPS article published in January 2012 (linked from the R-M article). The reference to illegal logging mafia came from an article titled “Illegal logging in Swat”, by PACT Radio, also linked from the R-M article. You include “illegal logging for commercial sale” among the key drivers of deforestation. Are you claiming that the Taliban did not control Swat district, or was it simply in an area outside your proposed project area? Perhaps it would help if you could provide a map of your project area, marked to indicate where the Taliban controlled the land and where the illegal logging is currently taking place.

3. You write that “The company Merlins Wood was founded by me to develop REDD projects in Pakistan”. Merlins Wood was registered with Companies House on 10 June 2009. The only director was Barbara Kahan. You became director on 12 August 2009. The object of the company was “To carry on business as a General Commercial Company”. There was no mention of REDD until the Articles of Association of the company were amended in December 2011 following a General Meeting of the company. Please confirm that this is in fact the case.

4. The Merlins Wood website includes several pages of timber species (walnut, lacewood, pine, yew and fir). At the top of each page are the words “Suppliers of Himalayan hardwoods and softwoods”. A page titled “Merlins Wood Timber Seasoning” explains that, “For our steaming and drying process we use steamers and kilns manufactured by Nardi Srl of Italy.” Could you please explain this? Was (or is) Merlins Wood a timber trader/importer?

5. You describe REDD as “the ONLY alternative available to us at the moment to halt this alarming trend before we lose all our forest cover.” Globally over the years, there have been many attempts to reduce deforestation and to protect forests. Some are more successful than others. Why do you consider REDD to be the only alternative in this particular area of the world?

6. You write that collaborating partners include “agencies under UN One”. Are you referring to United Nations agencies? Please clarify which UN agencies are collaborating on the KP project and explain exactly what their role is.

7. You write that “Carbon development is being outsourced to the leading carbon development technical specialist in the field”. What is the name of the company that you are referring to? Could you please provide contact details for the staff from this company who are working on this project.

8. You mention that you intend to provide “economic incentives to communities for sustainable forest management”. Could you please explain exactly how you intend to do this and how you propose to determine that the forest management being carried out is “sustainable”. Will this involve a forest certification system? If so, which one?

9. You don’t mention free, prior and informed consent in your response, but you explain that “Merlins Wood represents the interest of ALL the major landholders with the consent and support – who are heads of their communities”. Could you please explain how Merlins Wood (or its consultants) carried out a process of free, prior and informed consent. And could you explain how you explained carbon trading to all concerned.

10. “To date, we have completed a feasibility study for the project,” you write, “which was completed by a leading firm in the field.” Could you please send a copy of this feasibility study. Which company carried out the study?

11. You write that, “The KP project activities were evaluated for their potential to increase carbon sequestration and reduce emissions, and based on the eligibility guidelines under the Verified Carbon Standard (VCS) for the Reduced Emissions from Deforestation and Degradation (REDD) project type.” Which firm carried out this evaluation? Could you please send me a copy.

12. You write that, “Carbon development work for creation of the VCS and CCB PDs has now begun.” Which company is writing the Project Documents?

13. I previously asked whether Merlins Wood actually has an office in Berkeley Square, or whether it is a virtual office. I also asked how many people Merlins Wood employs. You replied, “Merlins Wood in the UK has a small staff and small offices in Berkeley Square UK.” So how many people does Merlins Wood employ? And is the office in Berkeley Square a virtual office?

14. I previously asked about whether you were concerned about the current price of carbon and the fact that the ETS is in crisis. I asked, “How many carbon credits do you expect to generate and how much do you anticipate being able to sell them for?” You replied that, “we are confident that the number of credits our project produces will more than adequately cover costs, provide an income for all stakeholders and will ensure the project succeeds.” One of the problems with carbon trading, as The Munden Project points out, is that a large amount of the money generated goes to intermediaries rather than to communities. I would be grateful if you could provide an overview of how many credits you expect to generate, how much income you hope to produce and where this money will end up. You must have, presumably, explained this already to the communities living in the project area as well as to the Government of Pakistan.

15. To clarify, REDD-Monitor did not accuse Merlins Wood of bribing anyone. Barrister Iftikhar Gillani, an opposition politician in Pakistan was reported as saying that “We believe that kickbacks, not in rupees but dollars and pounds, are involved in this highly controversial and dubious deal.” Your company is registered in the UK and you are a British citizen, according to the company registration documents. REDD-Monitor’s question was as follows: As of 16 December 2011, according to documents filed with Companies House, Merlins Wood had capital of £200. How does the company plan to raise the finance to carry out the two REDD-type projects? I would be grateful for an answer to this question.

16. You confirm that you have “no experience of implementing a REDD project”, but add that “we have allied ourselves with the leading experts in the field to drive forward development of the carbon asset.” Could you please name the companies with which Merlins Wood has “allied” itself and please explain the contractual relationship between Merlins Wood and these companies.

Thank you for your time and I look forward to hearing from you. Please consider your response to be on the record.

Regards, Chris Lang