Assessment finds several weaknesses in forestry commission practices

An assessment of Guyana’s forestry sector in preparation of Independent Forest Monitoring (IFM) under the Guyana-Norway forest protection pact has identified several weaknesses in Guyana Forestry Commission (GFC) practices including the procedure to renew expired Timber Sales Agreements (TSA).

The Independent Forest Monitoring Scoping Report done by the GFA Consulting Group made several recommendations which are expected to be implemented. The Memorandum of Understanding between the governments of Guyana and Norway outlines that activities to be covered in the 2009-2010 period includes the establishment of a system for IFM.

IFM will allow for a mechanism for assessment of illegality in the forest sector, but will not replace the implementing of, or completely cover the Legality Assurance System, the ongoing dialogue with the EU FLEGT, or existing legality procedures/systems being implemented. The purpose of the assessment by GFA Consulting Group was to evaluate the forest monitoring system in Guyana and its implementation in preparation of an audit of forest monitoring in Guyana which will take place in July 2012. IFM is the use of an independent third party that, by agreement with the GFC, provides an assessment of legal compliance, and observation of and guidance on official forest law enforcement systems.

The scoping report says that while effective legislation is in place for issuing logging permits such as TSAs, WCLs (Wood Cutting Leases) and SFPs (State Forest Permission), there is scope to improve structural procedure for the documentation for cases of annual extension of expired TSAs which should include the condition of such extension.

It also observes that both the Guyana Geology and Mines Commission (GGMC) and the Guyana Land and Surveys Commission (GLSC) appear to lack capacity to produce all valid leases and claims in a format compatible with GFC’s GIS and while there are efforts made to improve inter-agency collaboration more needs to be done in relation to documentation on the management of multiple uses when they arise.

The report said there may be mapping issues such as overlaps as well as other issues, which may be identified by stakeholders and during inter-agency meetings. “Where such situations exist and can impact on legality, GFC investigates the matter on the ground, reviews maps and relevant legal documents, outlines findings and acts upon them. In this respect, documentation concerning the practice and policy relating to GFC’s investigations in case of boundary disputes and the sharing of checked boundary information with relevant agencies – specifically GGMC and GLSC does exist but this can be improved through stronger inter-agency collaboration. Furthermore, there is scope for improving the filing system of such documentation,” it observed.

Meantime, the report noted that some stakeholders experience challenges in meeting the GFC’s requirements of submission of Forest Management Plans (FMP) and Annual Operational Plans (AOP). It was observed that the GFC has to implement policy directives as a matter of expedience to deal with this. Procedure and practice to compute Annual Allowable Area (AAA) and Annual Allowable Cut (AAC) need to be documented properly and application of procedure needs to be more consistent; various summary sheets at the GFC’s Forest Resource Management Division (FRMD) need to provide consistent information, the report said.

Wording in the CoP and/or Forest Management Plan Guidelines needs to be updated to fully reflect the procedure being followed, it added. “It was observed that the GFC has had to implement policy directives related to compliance with this criterion as a matter of expedience related to an apparent mismatch between the size and richness of the allocated resource and the capacity and investment level of certain TSA holders.

It was also observed that the potential occurrence of such mismatch is dealt with in case of applicants for TSAs for previously unallocated areas who have to undergo a SFEP process which includes the conducting of strategic level inventory as well matching resources to investment. There is scope to apply a similar process to existing TSAs when these come up for renewal/extension,” it pointed out.

It said that in the interim, a formal process accompanied by documentation is executed of the approval by GFC of new as well as re-entry blocks.

A request is made by the concessionaire, this is assessed by the GFC and, if approved, a formal letter is issued to the operators detailing the approval of new or re entry blocks. There is scope to improve Excel summary sheets in the FRMD files by distinguishing between “new” and “re-entry” blocks, it pointed out.

The report also said that adjustment of concession boundaries/sizes, which will impact on the concession quota, are tracked and recorded in the Planning and Forest Information Unit in the form of documents and maps.

Copies of both letters requesting and authorising such adjustments should however also be included in the respective SFP folios. “Overall, there is scope for the preparation of a Manual of Procedures for the Forest Resource Management Division,” the report said.

The goals of the scoping were to provide the GFC with a clear understanding of the requirements for IFM; to develop a clear view of GFC’s forest resource management and monitoring systems and practices- information which will be needed to design the real audit; and identify areas of GFC’s forest resource management and monitoring systems and implementation which present gaps to legality certification of GFC’s systems.

The first step of the IFM process was the conducting of a scoping mission to assess the identified aspects of the IFM system for Guyana, to propose initial recommendations for improvements in the system and its implementation and to identify a time frame for Guyana to implement recommendations made as a result of the scoping mission and to further develop the Terms of Reference for IFM. The scoping report was produced, based on the analysis of the assessment of the legal framework, field trip observations and stakeholder consultations. The scoping report assesses the implementation of policies, laws, regulations and procedures of the forest authority within the framework as laid out in the ToR for IFM. The report is advisory in nature and provides recommendations as a preparatory mechanism for the real IFM audit, as well as system and operations improvement.