Memo to Rainforest Alliance: If REDD is supposed to reduce deforestation, why is Norway giving REDD money to Guyana?

Norway has agreed to fund the Guyana REDD+ Investment Fund to the tune of US$250 million. Obviously, the Norwegian government isn’t just going to hand over the money. Under the agreement between the two countries, an independent organisation will conduct an assessment of whether the “REDD+ enablers” have been met.

Rainforest Alliance, a US-based non-profit organisation, has been contracted by the Norwegian government to “to conduct an independent verification of the cumulative accuracy of two Annual Progress Reports on REDD-plus Enabling Indicators.”

Guyana’s Office of Climate Change has so far produced two “Annual Progress Report on REDD-plus enablers” – one for 2009 released in March 2010 and one for 2010 released in October 2010. (The reports are available on the LCDS website.)

Janette Bulkan produced detailed notes on the March 2010 report, published in the Guyana newspaper, Stabroek News. Yesterday, Stabroek News published notes on the October 2010 report, written by John Palmer, Senior Associate of Forest Management Trust, USA. Palmer’s notes are reproduced in full below. The notes give a detailed critique of what Guyana has achieved so far under REDD.

REDD-Monitor looks forward to seeing Rainforest Alliance’s response to the two reports and in particular to its response to Bulkan’s and Palmer’s notes on the reports. Rainforest Alliance has no excuse for ignoring these issues when it carries out its verification of the two reports for the Norwegian government.¹ REDD-Monitor also looks forward to reporting how the Guyana REDD+ Initiative Fund will contribute to reducing deforestation, improving transparency and governance, and achieving genuine low-carbon development in Guyana – something that so far none of its proponents seem able to do.

Annual Progress Report on REDD-plus enablers – 2010 – for the Norway-Guyana MoU

Notes by John Palmer, 24 October 2010

John Palmer is a consultant to the UK Government on planning of global forest research² and former manager of the UK Government’s tropical forestry research programme. He works on control of illegal logging and trade in illegally harvested timber, and standard setting for forest certification schemes.

The report on the Norway-Guyana MoU from the President’s Office of Climate Change, dated this month of October, is an update from the interim report issued in March and which was commented on in Stabroek News on 04 May. Like the first version in March, this October report concentrates on process, on the numbers of meetings held and the repetitive lists of mostly the same Government agencies which are present. However, in the continued absence of the legally required audited accounts and annual reports from these agencies, the terse summaries are almost the only insights which the public has into the secretive machinery of the Guyana political administration.

The October report, the interim March report and some supporting documents are accessible on the LCDS website. Rainforest Alliance, a US-based NGO which develops standards for and audits the environmentally-friendly or organic production of bananas, coffee, cacao, oil palm, timber, tropical livestock, etc., was selected by the Government of Norway to verify the claims made in this October report. The terms of reference for this verification were set in the Joint Concept Note (JCN) attached to the MoU in November 2009:

“Annual independent overall assessments will be conducted by one or more neutral expert organizations, to be appointed jointly by the Participants in consultation with the international financial institution managing the GRIF [Guyana REDD-plus Investment Fund], on whether the REDD-plus enablers [progress indicators] have been met; and what results Guyana has delivered according to the established indicators for REDD-plus performance. A neutral expert organization will also provide an annual status report for the Governments of Norway and Guyana. In this status report, the organization will outline its independent assessment of all Participants in the REDD+ process, and make recommendations for process and capability improvements. This will include an assessment of whoever is selected as the administrator of GRIF.”

The World Bank was selected as that administrator in early October, although the details of the arrangement were not available to the OCC when it prepared its report.

The Rainforest Alliance mission in October should not be confused with the September mission by LTS International which was part of the rolling review of the Norwegian International Forest and Climate Initiative.

The OCC report follows faithfully the structure of the JCN, with seven components. My numbering follows that used in the OCC report. I have suggested a tick for welcome progress, a half-tick for some signs of positive movement, and a cross for unsatisfactory or no progress.

Section 3.1 – Strategic framework

The JCN requires that “All aspects of Guyana’s planned efforts to reduce deforestation and forest degradation, including forest conservation, sustainable management of forests, and enhancement of forest carbon stocks (“REDD-plus”), are being developed in a consistent manner . . . ” Here we arrive quickly at the paradox. Guyana has made no explicit commitments to reduce deforestation or forest degradation, either through the several versions of the REDD Readiness Proposals (R-PPs) prepared by the Guyana Forestry Commission or through the three versions of the President’s Low Carbon Development Strategy (LCDS).

Both the GFC and the OCC are soliciting donor funds but making no commitments in return which are compatible with the reductions in forest carbon emissions in Guyana. Yes, there is mention of reductions especially in the May 2010 version of the LCDS, but they are in the form of lectures by the President to the outside world about what other countries should do.

While the R-PPs from the GFC are increasingly conforming to the template supplied by the World Bank-coordinated Forest Carbon Partnership Facility, the President’s LCDS continues to be a shopping list of development projects not sited within a strategic framework such as the National Development Strategy 1995-6 or the National Competitiveness Strategy 2006. In the 16 months since the June 2009 launch of the first draft of the LCDS, this document has failed to harmonise with either national planning policy or “an internationally recognized framework for developing a REDD-plus programme” (as required by the JCN). The President has not yet supplied the comparative studies to justify his project preferences. So a tick for the GFC and a cross for the OCC.

Section 3.2 – Continuous Multi-Stakeholder Consultation Process

The LCDS is associated with a Multi-Stakeholder Steering Committee (MSSC). Composition of this Committee as listed on the LCDS website shows 11 Government representatives, 5 Amerindians, 3 private sector, 2 trades unions, 2 international environmental NGOs, 2 individuals, 2 said to be still representing the International Institute for Environment and Development, 1 civil society. The MSSC is chaired and, as shown by the minutes, dominated by the President. In no sense could the MSSC be said to be a body discussing national development strategy, options are not provided, and “cussing out” of even questions about process shows the futility of this body. Although it is still claimed to meet weekly, the record of minutes shows that it has met only 11 times in 2010, the last recorded being 10 August.

However, the MSSC has been shown a number of documents about management of natural resources which otherwise have not been seen officially in Guyana. These are listed in section 3.2.1 of the report but have not been placed on the LCDS or other Government websites, although some can be found on foreign websites, of Norway and EU/EFI/FLEGT.

The October report claims other consultations, without listing them. References are made by Ministers during hinterland and urban political presentations (and reported in Guyana’s daily newspapers), but there is no evidence that these are strategic debates. Nor is there yet any evidence that the hundreds of unanswered questions raised during the first round of LCDS consultations have been addressed. Certainly they are not addressed in the successive versions of the draft LCDS.

Why there should need to be so many overlapping committees on climate change, dominated as they are by the same group of Government agencies, is unclear. Why a REDD Secretariat in the GFC as well as an Office of Climate Change under the President? Why also a National Climate Committee? Why a Special Land Use Committee (under the Prime Minister) in addition to the Natural Resources and Environment Advisory Committee?

Guyana does not appear to have had a neutral, non-partisan, independently chaired forum on its options for strategic development since the mid-1990s. Journalists are not invited to the MSSC.

Half a tick would be generous for this section.

Section 3.3 – Governance Plan (see also section 5.11 and annex 1)

The JCN lists 11 points to be addressed in the REDD-plus governance development plan (RGDP). This report mentions 23 activities which do not necessarily address the 11 points. The JCN states that “Transparency and accountability are key to success in any REDD-plus effort. REDD-plus-relevant decisions and data should be publicly available”. The report shows no progress on these fronts. No data have been made available, not even the data to support the fantastical deforestation scenario developed by McKinsey & Company for the President in 2008. Instead, there is a long list of steps to revise GFC policies and procedures, overlooking the almost complete failures by the GFC to implement either the National Forest Policy 1997 or the National Forest Plan 2001. Thirteen consultation sessions are claimed to have been held, but no word of these sessions has been reported as such in the daily Press or recorded on the GFC website. Why revise these policies and plans and procedures instead of implementing them? – it looks like fiddling while Rome burns – and clearly this part scores a cross for transparency.

The JCN requires “development of a system for reporting on the multiple benefits of REDD-plus, including on measures to protect biological diversity, improved livelihoods, good, governance, and Constitutional rights”. Section 19 of the annex on the RGDP in the October report says that a specific report on the benefits of REDD+ is “to be prepared”. For biodiversity, section 20 of the annex mentions a workshop on criteria for priority biodiversity areas held in June, although such workshops have been held before during the attempts to create a project for a Guyana Protected Areas System and then a National Protected Areas System, both of which failed. “Good governance” is conspicuously not mentioned in the annex.

The JCN requires “development of a national, inter-sectoral, land use planning system”. The October report does not mention this directly but Section 15 of the annex says that “there has been efforts towards improved coordination of land use”.

That presumably does not include the street protests in Bartica earlier this year about new regulations on small-scale mining and implementation of neglected existing regulations, nor about the shady deals in mining licences involving government officials, and the continued failure to coordinate logging and mining concessions in spite of having a common GIS platform (GINRIS) in the four relevant Government agencies.

The JCN requires “development of valuation systems for determining the costs and benefits of different alternatives and courses of action on the forest resources”. No mention in the October report on the RGDP.

The continued evasion of governance issues means that this section deserves a cross.

Section 3.4 – Financial Mechanism

It is understandable that the October report had little to say about the mechanism because this was just approaching finalization and has been announced only this month. The report does say that “The Government intends to comply with REDD funding safeguards which are currently being discussed in the UNFCCC negotiations” but says nothing about the safeguards in the FCPF in which the GFC is involved, nor about the environmental and social safeguards and due diligence procedures of the Partner Entities which may actually manage the Norwegian funds after they have been passed through the World Bank. By no means do the potential Partner Entities (PEs) all have the same stringency as those of the World Bank, as the correspondence on the Amaila Falls access road construction is showing, nor do all PEs apply their safeguards in the same way.

The high level and high volume of allegations of corruption and financial mal-practice in Guyana should be a warning to the Norwegian donor and to the potential PEs about management of donor money. And note also the repeated failures of Government offices to respond effectively to the annual annotations in the Auditor General’s report. The President’s opposition to the application of well-established World Bank safeguards and due diligence, as recorded in the MSSC minutes, scores a cross for this section.

Section 3.5 – Monitoring, Reporting and Verification (MRV)

This is where the GFC has been the most active, in creating committees, devising terms of reference and arranging consultancies. Much of the October report and the GFC’s April 2010 version of its R-PP deal with these matters. However, the GFC (and the President) have failed to respond to questions about the need for such large internal and external effort. In 2007-8, the GFC detected deforestation due to mining (24428 ha), agriculture (21903ha) and forest roads (2626 km) to the exact number of hectares, a claim not made in any other country, so why the need for such tremendous effort to increase yet further the accuracy and precision of these estimates?

Also, given such capability, it is odd that there have been no prosecutions at all for alleged forest offences including illegal logging.

Unlike past years, since mid-2009, the GFC has placed several reports and consultancy presentations on its website, as well as the terms of reference for MRV-related consultancies. Other documents can be found on the Guyana page of the FCPF website, but are not referenced in the October report. Five sets of action points for the MRV System steer six meetings of the MRVS technical committee. What is discussed at these meetings, or what data are on the table, is not mentioned.

The R-PP explains that the GFC is preparing to be able to meet the as-yet undetermined UNFCCC standards for assessment of standing stock of forest carbon, and changes in those stocks but in the meantime is progressing towards IPCC/GOFC-GOLD standards. It is unclear why this effort is needed if the GFC is unable to carry out normal monitoring of logging operations or to make effective use of its increased number of field stations. Why such efforts with remote sensing if no practical use is made of the data and when Guyana makes no commitment to reduce deforestation or forest degradation (11.4 million tonnes of forest carbon per year)?

Item 5 under section 3.5 deals with the development of the forest carbon reference scenario, arbitrarily set in the Norway-Guyana MoU for the period until October 2010 at 50 per cent above the estimated annual deforestation rate of 0.29 per cent. By now, according to the MoU, the Government should have proposed a new figure but is only just beginning to do so through an external consultancy by Poyry of New Zealand. Again it is unclear why the GFC is engaging external support when its R-PIN in 2008 listed some of the available remote sensing data going back to 1950, and the R-PPs have added to that list. The positive efforts of the GFC in this section deserve a tick but the contextual paradox scores a cross.

Section 3.6 – The rights of indigenous peoples and other local forest communities as regards REDD-plus

As in many other Government statements, the October report fails to appreciate that the partial rights in the Amerindian Act 2006 do not compensate for failure to uphold the National Constitution, Article 154A and Schedule 4 which deal with human rights. The Government’s failure to implement the Convention on the Elimination of All Forms of Racial Discrimination (CERD), which is listed in Schedule 4 and Guyana ratified in 1977, and the UN Declaration on the Rights of Indigenous Peoples for which it voted in 2007, make a nonsense of its claims to be at the forefront of indigenous rights.

The Government fails to state in section 3.6 that Amerindian rights are not as recognized in international law, are only partial, are granted in a patronal ex gratia manner through a non-transparent process and are subject to revocation without defined criteria.

The Government claim that the statutory National Toshaos Council is the only body of its kind in the world is just wrong; think of the Sami Parliament for the reindeer-herding people of the tundra, to give just one example.

This section also claims that “mechanisms have been put in place to enable the effective participation of all indigenous peoples and other local forest communities”. Just what are these mechanisms? The MSSC, as indicated above, is simply a theatre for the President’s ever-changing ideas. He decides how much and where Norwegian money is going to be spent on Amerindians.

While there are brief mentions of other forest-dependent communities in the 2010 versions of both the R-PP and the LCDS, no formal provision has been made for them to consider their ideas and options.

The “opting into LCDS” document, which is to explain to the Amerindian communities what would be their rights and responsibilities if a Village Council should choose to associate with the LCDS, has been in draft since March 2010 but it is not yet a public document. There is no document about benefit-sharing or replacement livelihoods for other forest-dependent communities.

The Government’s foot-dragging in the face of the clear legal situation and abundant advice scores a cross in this section.

Section 5.4 Annual verification by neutral experts that the REDD-plus enabling activities have been completed as appropriate

Curiously, the October report inserts here a mention of two background reports commissioned by Norway in advance of the MoU and delivered in July and August 2009. As noted in the May 4 commentary in SN on the interim OCC report, the authors of these two reports seemed not to have had full access to GFC files, data, databases or remotely sensed imagery, so they are extremely tentative. Even so, the GFC contested the draft reports, as recorded in the MSSC minutes, and perhaps that is why the reports have not been put into the public domain in Guyana, although they have been seen by the MMSC. So zero for transparency. Other work has been delayed, so score a cross.

Section 5.6 The establishment of a system for Independent Forest Monitoring (IFM)

It was entirely predictable that the Government in general and the GFC in particular would drag out the establishment of IFM. The GFC is publicly opposed to the application of quality assurance scrutiny by the Forest Stewardship Council (see minutes of the MSSC), and was unenthusiastic about the report score card system for forest governance devised by Global Witness. However, the GFC has put the full terms of reference on its website, and these have been circulated internationally, so score a half-tick.

Sections 5.9 on EU-FLEGT and 5.10 on EITI

Norway wanted clear evidence that Guyana would begin to engage with the European Union’s Forest Law Enforcement, Governance and Trade (FLEGT) scheme and the Extractive Industries Transparency Initiative for reporting of payments to government by the private sector and reports of official receipts of income by the government agencies. Unsurprisingly in view of the many allegations of corruption the October report shows little progress in respect of either process. The LCDS website is silent on both processes but the GFC website shows seven FLEGT documents including its work on a national legality assurance system which it has previously circulated for public comment. Yes, there are big gaps between the GFC position and what are likely to be “red-line” issues for EU-FLEGT, but it is a start and the GFC has been more open than usual on what must be a really tricky issue, given the level of regulatory capture. So score a full tick for the GFC and half a tick for the rest of government.

So how does this October report score in general? A fairly full record of committees established and meetings held is not the same as a transparent public record of what is debated. This report gives almost no details on the contents of the debates. On what is Guyana making real progress against the MoU indicators, and what are the perceived difficulties and obstacles?

Why do the GFC and the OCC not invite the independent journalists to record the debates and publish accounts? Instead of the technical language in nearly all the documents on the GFC and LCDS websites, including the series on climate change begun by the OCC but abandoned in mid-June 2010, why not get professional journalists to interpret and relay progress on the R-PP and LCDS?

Why not more efforts to make REDD intelligible to the man in Morawhanna or the woman in Kanashen, the families dependent on small-scale gold mining of chainsaw-milling? These are the people whose livelihoods are most likely to be affected negatively if Guyana did begin to control its emission of forest carbon.

If the President feels that the LCDS is so central to his last couple of years in office, why be so secretive? It is such a contrast to the openness of the process in the National Development Strategy of 15 years ago. So score zero for transparency, a great opportunity for multi-way communication and national debate is being missed.

The paradox remains of the President claiming to be fully involved in the global REDD – Reduction in Emissions from Deforestation and forest Degradation (and certainly clocking up impressive carbon-emitting air-miles in his global travels) while opposing any such reductions for Guyana. The undoubted efforts being made by some stakeholders in Guyana are undermined by the appearance of a Presidential shadow play.

This play is expressed most clearly in the 32 sets of minutes of the MSSC, where the target is the pot of barely accountable Norwegian money to be paid in effect for Guyana to do nothing, as the President has agreed.

This sets a terrible example to other countries engaged in the REDD preparation process. If Guyana gets so much money, and can even expand deforestation without penalty, why should other countries be more honest? Is this what Guyana wants to be known for?

1. UPDATE: 6 November 2010: The words “when it carries out its verification of the two reports for the Norwegian government,” were added to this sentence – to clarify that Rainforest Alliance has not yet ignored these issues. See the comment from David Diaz and my reply to him.

2. John Palmer points out that he is an independent, occasional consultant and is not in any sense employed by the UK Government.