NGOs in Papua New Guinea, members of the PNG Environmental Alliance, have written to the Minister for Environment, Conservation and Climate Change, Pogio Ghate, about the government’s submission of REDD+ Safeguards legislation to the National Executive Council, without any consultation about the final draft of the documents.
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The NGOs are also concerned that a Moratorium on voluntary carbon market REDD projects has not been implemented. The Moratorium was issued on 2 March 2022 by Wera Mori, Papua New Guinea’s then-Minister of Environment, Conservation and Climate Change.
The letter from the PNG Environmental Alliance does not oppose REDD or carbon trading. If anything it is in favour of both. The concerns raised in the letter are with the government’s process for regulating REDD and its failure to deal with REDD projects that are causing problems for communities, such as the NIHT Topaiyo REDD+ Project.
But the letter highlights the ongoing problems with REDD projects in the country:
[L]ack of proper awareness at the community level, lack of proper FPIC process before signing of carbon credit contracts, unclear and non-transparent benefit sharing mechanism, unsupported excessive claims made on future benefits, no clear link of benefits (to be) received to actual efforts and long-term commitments by participating clans, no sustainable land use planning done, and cash hand-outs to get clans to sign up.
When REDD-Monitor wrote about the NIHT project in October 2021 it had sold 503,440 carbon offsets. That figure now stands at 1,327,442. A group of NGOs wrote to William Lakain, Acting Managing Director of the Climate Change and Development Authority on 15 September 2021 (not 15 November 2021, as stated in the letter).
Attn: Hon Pogio Ghate Minister for Environment, Conservation and Climate Change 9th Floor, Dynasty Tower Savannah Heights, Waigani Drive Port Moresby, NDC
Ambassador Mr. Ivan Pomaleu, OBE CACC Chairman All CACC Members Manasupe Haus Waigani Port Moresby, NCD
Date: 5 May 2022
Dear Honourable Minister Ghate, CACC Chairman Ambassador Pomelue and all CACC Members,
RE: REDD SAFEGUARDS FINALISATION PROCESS AND MORATORIUM IMPLEMENTATION
We, the Members of the PNG Environmental Alliance (PNGEA), write this urgent letter to you to voice our grave concerns on two essential matters regarding the development and implementation of REDD+ in our country:
The submission to NEC of final versions of the PNG REDD+ Safeguards (FPIC Guidelines, Benefit Sharing & Distribution System Policy, REDD+ Development Guidelines, Grievance Redress Mechanism) without any stakeholder consultation on the final draft of these documents.
Complete lack of implementation of the Moratorium on new voluntary carbon market projects.
Re 1. At the time of the official Validation Workshop on the REDD+ Safeguard documents on 16 March 2022, final draft versions of the Safeguard documents were not yet ready. There were no documents circulated to stakeholders in advance of the workshop. Only after the start of the workshop, working draft versions of the Safeguard documents were handed out to participants present in person at the workshop. Online participants did not have access to these documents. Presentations were made on the documents, with the content of the presentation on the crucial REDD+ Development Guidelines differing considerably from the working draft document given to participants. NGO representatives objected to the incorrect process and asked CCDA to allow more time and follow proper process with completion of final draft documents before validation. CCDA refused to consider this, said that comments would still be submitted and considered after the workshop, but asked participants to validate the incomplete working draft documents at the end of the workshop.
Re 2. The Moratorium on new voluntary carbon market projects put in place in March 2022 is not being enforced, with project developers and their agents continuing to work on new project areas, without any guidance on proper process, due to the lack of completed REDD+ safeguards and Regulations. This is leading to a growing number of social problems and conflicts, some of them being officially registered with CCDA. One of the two main reasons for putting the Moratorium in place was to halt all project preparations until the REDD+ Safeguards and the related Regulations under the CCMA are in place. The members of the PNGEA already notified the CCDA MD, in a letter dated 15 November 2021, of the many issues around the country arising from this unguided project preparations.
Some of these major issues are lack of proper awareness at the community level, lack of proper FPIC process before signing of carbon credit contracts, unclear and non-transparent benefit sharing mechanism, unsupported excessive claims made on future benefits, no clear link of benefits (to be) received to actual efforts and long-term commitments by participating clans, no sustainable land use planning done, and cash hand-outs to get clans to sign up.
This letter also highlighted that most of these issues were caused by the expansion activities of an existing Verified Carbon Standard (VCS) project, the NIHT Topaiyo REDD Project. This is a grouped project covering ENBP and NIP, with at present one first group member, or project instance area, located at King village, Namatanai. When the Moratorium was put in place, CCDA senior management verbally informed that this would also mean that NIHT would not be allowed to add any new project areas to their grouped project.
We have gone through a lengthy process to develop REDD+ in PNG. These combined efforts have led to the present situation of our country, where after lots of inputs from national and international stakeholders, financially and in kind, we can now start to generate financial benefits from improvements in the management of our precious forest resources. These benefits will come from a national system with nested voluntary market projects, but in order to safeguard the interest of our people and the country, all REDD+ project need to be properly regulated through a strong national REDD+ implementation system. The most important part of this system is that it needs to be transparent and equitable, appropriate for our PNG customary societies, guarantees permanence of emissions reductions, and ensures the vast majority of REDD+ benefits are reaching the owners and custodians of the land and forests were are talking about, and will be used for long-term improvements of their livelihoods.
The REDD+ Safeguards and resulting Regulations under the CCMA form the backbone of our REDD+ implementation system and need to be developed through a correct and fully transparent process with proper stakeholder consultation at all stages. The process used for the development of the MRV related safeguards and regulations can serve as an example and guide on this.
Project developers should not be allowed to continue their project preparation activities while we do not yet have our final Safeguards and Regulations in place, as this creates dangerous precedents, and a situation that will be extremely difficult to remedy.
We are deeply concerned by the seriousness of the situation and the partnership of CCDA with NIHT, despite the many reports of problems caused by NIHT’s inappropriate approach, allowing them to continue preparations to add new project areas, and even expand beyond the scope of their existing project (ENB & NIP) into other provinces in PNG.
The current situation with a short-cut of the development process for the REDD+ Safeguards together with the lack of clarification on and enforcement of the Moratorium, is endangering the development and implementation of a transparent and equitable REDD+ system for PNG and is damaging our international reputation, hence urgent action is needed.
We ask you to show your leadership to protect the reputation of the country in REDD+ by:
a) Directing CCDA to properly complete the development process of the REDD+ Safeguard document through stakeholder consultation on the final draft versions of the documents, and conducting a real Validation Workshop on their final versions, after processing of the comments received on the final draft versions, with sufficient time allocated for both steps.
b) Putting out a public notice detailing and explaining the meaning of the Moratorium on new voluntary carbon market projects, i.e., a stop to ALL preparation activities for any projects, including for new project area instances of the existing NIHT grouped project.
We welcome the interest and engagement by investors and communities in PNG towards REDD+ and the Voluntary Carbon Market, and the potential we envisage that it will provide into the future. It is for this reason that it is critically important to ensure all the required regulations and institutional arrangement are developed and in place first, and that systems are functioning to ensure oversight and compliance. Without these in place the prospects for PNG and its resource owners will be jeopardised. Businesses and landowners with a genuine interest and commitment to this mechanism, and the opportunities it provides over the longer term, would surely not wish to jeopardise these prospects by bypassing due process and standards now, but rather would support the steps necessary to put in place these fundamental institutional building blocks.
Thank you very much for your consideration and prompt action.
Bismarck Ramu Group (BRG) Centre for Environmental Law & Community Rights (CELCOR) Consultative Implementation & Monitoring Council (CMC) FORCERT – Forests for Certain: Forests for Life! Partners with Melanesians (PwM) PNG Council of Churches (PNGCC) Research & Conservation Foundation (RCF0 Wide Bay Conservation Association (WBCA) Wildlife Conservation Society (WCS-PNG)
Cc: Hon. James Marape, Prime Minister CC: Hon. Solan Mirisim, Minister for Forest Cc: Mr. William Lakain, A/MD CCDA
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