Bulkan responds to Vivian Li’s GFC data on concession allocations

Nov 23, 2008 Letters

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DEAR EDITOR,
I respond to the confusing letter signed by the apparently unofficial spokesperson of the Guyana Forestry Commission (GFC), Vivian Li, entitled “Guyana will continue to be an example in forestry practices” (GC, November 20, 2008), “Janette Bulkan’s assertions are misleading” (Kaieteur News, November 20, 2008).

Contrary to Vivian Li’s assertion, not all the information reported from Minister Robert Persaud’s address to the joint meeting of the Inter American Development Bank/GFC/Conservation International is to be found on the sadly incomplete GFC website.

Minister Persaud’s data on the forest area logged each year are not on the website, nor is the method of calculation now transmitted by Vivian Li.

I used the GFC 2008 mid-year Forest Sector Information Report for the allocated concession areas, and the 1993 forest concession policy for the maximum duration of each type of concession.

This is reasonable because the GFC has not published data on operable areas as opposed to gross areas.
Moreover, the GFC charges area fees to the concession holders on the gross areas, not on the operable areas, although there is no publication on its website or in print which justifies the gross area charge.

I note that the 1993 policy on forest harvesting concessions limits Timber Sales Agreements (TSAs) to 25 years while Vivian Li increases this duration to 30 years for TSAs. On whose authority has this increase been given and where/when was this increase published?

Vivian Li assumes a 65 percentage for operable areas compared with gross concession areas, for all types of forest concession, but quotes no authority for this estimate.

There is one estimate which can be derived from public domain data for TSAs and that is for Barama’s 1.61 million ha concession (from the public summaries of the certification evaluations by SGS Qualifor in 2005 and 2006), where the operable area is 77 per cent overall.

Barama’s speed of cutting of about 36,000 ha per year is based on that figure, for a felling cycle of 40 years and a regeneration rate of 17 cubic metres (m3) per ha.

This does not take into account the unsustainable cutting by Barama in the illegally rented TSAs (285,000 ha) and a WCL (26,000 ha) which should be harvested sustainably.

But Barama’s parent company, Samling Global Limited, was explicit in the documentation provided to the Hong Kong stock exchange in 2007 that Barama would not log these areas sustainably. The GFC has not issued any public statement against this public intention of illegality.

Now turning to the short-term, two-year State Forest Permissions (SFPs, including conversion SFPs) which are intended for harvest of forest damaged by uncontrolled logging, by fire, or otherwise not deemed to be capable of sustainable production and therefore not subject to the environmental controls which apply to TSAs and WCLs.

These areas are not divided up into demarcated logging blocks, and areas are not required to be set aside for conservation.

I assumed in my original letter, for the purpose of the argument, that concession holders would log about half the total area each year.

In fact, the generally very poor condition of these forests cause the loggers to roam around according to where their tree spotters can locate a marketable tree, and thus may be causing environmental damage to more than half the concession each year.

This roaming behaviour has been confirmed many times by loggers interviewed recently by consultants.
But remember that the SFPs are not allocated for sustainable forests.

Suggesting a 65 per cent operable fraction is not in accord with the published information from the SFPs surveyed in 2000-2.

Sensibly, in the 1990s, the GFC recognised that a simple volume quota control based on prior records of annual harvests would have to substitute for field control based on knowledge of actual forest condition or status.

The rapid assessments carried out in 2000-2 recognised that for correct allocation “Field surveys are necessary as existing information held by the GC is either inaccurate or is incomplete” (Neil Bird and K Dhanraj, October 2001).

The GFC re-started a survey of the hundreds of SFPs in 2006, and has flagged 22 out of 331 SFPs as potentially capable of being converted to TSAs for sustainable production.

My estimate in my letter published in SN and Kaieteur News on 16 November was for some 950,000 ha logged per year, six times the Minister’s estimate of 160,000 ha per year.

Recalculating for operable area as opposed to gross allocated area (on which concession holders are billed regardless of the actual operable area), the total is 879,806 ha if the TSA duration is 30 years and the WCL duration is 10 years and the operable area percentage is 77 (as in Barama) or 860,257 ha if the operable percentage is 65 (as in Vivian Li’s letter).

In each of these two cases, I have retained my explained estimate of 754, 358 ha logged per year in SFPs as being more realistic than the GFC’s unexplained 65 per cent.

These operable areas are respectively 5.5 times (my estimate) and 5.4 times (Vivian Li’s estimate) greater than Minister Persaud’s 160,000 ha.

These figures are important for the international negotiations about possible external financial support for forest conservation through the Reduced Emissions from avoided Deforestation and Degradation (REDD) scheme.

As Guyana’s proposal for REDD funding is notably misleading in some aspects, the GFC should be more open about the data on which it makes public statements and about how it charges for resource access rights.

By all means let us debate again the actual areas affected by forest harvesting each year, but let us have the original field data and the remotely sensed imagery put into the public domain.

That would be consistent with Article 13 (open government) in the National Constitution 1980/2003, and with the imminent Freedom of Information Act (“Freedom of Information Bill being fast tracked – PM”, Kaieteur News, November 21, 2008).

Perhaps also the GFC could sign its own letters to the Editor in future, as the non-public information disclosed by Vivian Li could only be derived on authority from the GFC; otherwise Articles 13 (dealing with privileged information) and 27 (offences and penalties) in the revised GFC Act 2007 would cause Vivian Li to risk penalties of G$1 million and prison for one year.
Janette Bulkan

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