Scoping Mission Report · 2019. 1. 22. · Your contact person within GFA Consulting Group GmbH is Nadia Moutawakkil (+506) 2289.3536 [email protected] INDEPENDENT

GUYANA–INDEPENDENT FOREST MONITORING

SCOPING REPORT

Guyana Forestry Commission

Submitted to: Guyana Forestry Commission Mr. James Singh Commissioner of Forests 1 Water Street, Kingston, Georgetown Guyana, South America

December 16, 2011

Your contact person within GFA Consulting Group GmbH is

Nadia Moutawakkil (+506) 2289.3536

[email protected]

INDEPENDENT FOREST MONITORING

SCOPING REPORT

Regional Direction for Latin America and the Caribbean Hamburg - GERMANY (+49-40)-60306-181

Fax: (+49-40)-60306-189

E-Mail: [email protected]

Regional Office in San José – COSTA RICA

(+506) 2289.3536 Fax: (+506) 2289.4152

E-mail: [email protected]

mailto:[email protected]

mailto:[email protected]

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CONTENTS

LIST OF TABLES II

LIST OF FIGURES III

ABBREVIATIONS IV

1 BACKGROUND 1

1.1 INTRODUCTION 1 1.2 FOREST LAW ENFORCEMENT AND LEGALITY IN GUYANA 1 1.3 CRITERIA AND INDICATORS FOR INDEPENDENT FOREST MONITORING 2 1.4 GUYANA’S FOREST RESOURCE MANAGEMENT AND MONITORING SYSTEMS 3

2 OVERVIEW OF IFM APPROACH 5

2.1 ASSESSMENT OF REGULATORY AND LEGAL SYSTEMS 5 2.2 FIELD VISITS 5 2.3 STAKEHOLDER CONSULTATIONS 6 2.4 SCOPING REPORT 7

3 RESULTS 8

3.1 MAIN STRENGTHS AND WEAKNESSES 8 3.2 IDENTIFIED GAPS WITH IFM CRITERIA 14 3.3 PROPOSED REWORDING OF INDICATORS BY THE REPORTING PANEL 69

4 REAL AUDIT 75

4.1 AREAS OF FOCUS FOR REAL AUDIT 75 4.2 APPROACH TO BE FOLLOWED AT REAL AUDIT 77

5 WORK BREAKDOWN STRUCTURE 79

6 APPENDICES 82

6.1 LIST OF PARTICIPANTS FOCUS GROUP INTERVIEWS AND OTHER MEETINGS 82 6.2 ASSESSMENT TEAM 86 6.3 FIELD TRIP ITINERARY 88

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LIST OF TABLES

Table 1 GFC’s main strengths and weakness vis-à-vis IFM Criteria for Monitoring ................ 9

Table 2. Identified gaps with IFM criteria and indicators with recommendations .................... 15

Table 3 Proposed rewording of indicators ............................................................................ 70

Table 4. Timeline for implementation of corrective actions by GFC ....................................... 79

Table 5. List of participants focus group interviews, individual interviews and meetings ........ 83

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LIST OF FIGURES

Figure 1: Field trip itinerary: A) Hamekaran Basdeo, B) Safiran Mohamed, C) Ramesh Singh,

D) Great Falls, E) Sustainable Forest Inc., F) West-Aikawanna block 48, G) DTL

Sawmill and lumberyard ......................................................................................... 89

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ABBREVIATIONS

AL = Agricultural Lease APA = Amerindian Peoples Association AVC = Amerindian Village Council CFO = Community Forestry Organisation CI = Conservation International DTL = Demerara Timbers Limited EPA = Environmental Protection Agency EU-FLEGT = Forest Law Enforcement, Governance and Trade Action Plan of the

European Union FPA = Forest Producers Association FPDMC = Forest Products Development and Marketing Council FTCI = Forestry Training Centre Inc. GFC = Guyana Forestry Commission GFTN = WWF Global Forest & Trade Network GGMC = Guyana Geology and Mines Commission (G)LAS = Legality Assurance System for Guyana GLSC = Guyana Lands & Surveys Commission GMSA = Guyana Manufacturing & Services Association GOIP = Guyanese Organization of Indigenous Peoples GRA = Guyana Revenue Authority GSA = Guyana School of Agriculture IFM = Independent Forest Monitoring IPC = Indigenous Peoples Commission LCDS = Low Carbon Development Strategy ML = Mining Lease MOAA = Ministry of Amerindian Affairs MSSC = Multi-Stakeholder Steering Committee of the LCDS NADF = National Amerindian Development Foundation NGO = Non-Governmental Organisation NRDDB = North Rupununi District Development Board NTC = National Toshao Council PSC = Private Sector Commission of Guyana REDD+ = Reducing Emissions from Deforestation and Forest Degradation plus the

role of conservation, sustainable management of forests and enhancement of forest carbon stocks

RP = Reporting Panel for IFM (includes reps. of EPA, FPA, FPDMC, FTCI, GGMC, GLSC, IPC, NTC)

SFP = State Forest Permission TAAMOG = The Amerindian Action Movement of Guyana TSA = Timber Sales Agreement UBFAPA = Upper Berbice Forest and Agricultural Producers Association UG = University of Guyana WAB = Women’s Affairs Bureau WCL = Wood Cutting Lease WWF = World Wildlife Fund for Nature

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1 BACKGROUND

1.1 Introduction

This report presents the findings of an independent legality assessment conducted by an Independent Forest Monitoring team of specialists representing the GFA Consulting Group S.A. The purpose of the assessment 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.

This report contains five main sections of information and findings and several appendixes.

1.2 Forest law enforcement and legality in Guyana

In a global context, illegal logging and deforestation cause severe environmental damage, including a loss of biodiversity and impacts on climate change. In many countries, livelihoods of local communities who depend on forests – including indigenous people - are affected by it. Generally, legitimate operators who are trying to manage forests sustainably find it hard to compete with illegally produced timber. The Government of Guyana has realised that policies to conserve and sustainably manage forests and reduce deforestation become much more effective by strengthening forest governance and fighting illegal logging.

Forest law enforcement and legality have therefore been main focus areas of the Guyana Forestry Commission’s (GFC). This has been due not only to the legal requirements as set out in the Forests Act, but also to a recognition of the importance of legality in ensuring that the benefits from forest resources utilization flow to the right beneficiaries, preventing unfair competition between illegal and legal produce, maintaining a low rate of deforestation and forest degradation, ensuring sustainable development of forest dependent communities, and mitigating against climate change in a REDD+ framework.

To this effect, the GFC, with support from its partners including, the Forest Products Development and Marketing Council, the Forestry Training Centre Inc. and private sector counterparts developed the Guyana Legality Assurance System (GLAS). Other efforts that have been undertaken to ensure that legality is maintained at a high level, including the implementation of a Code of Practice for Harvesting Operations, a national log tagging and tracking system, as well as concession level and environmental monitoring through the GFC’s head office along with a number of field monitoring and mobile stations.

In June 2006, an international firm specializing in forest legality systems, ProForest, was contracted by the Guyana Forest Commission (GFC) to assist in the development and field testing of an independent, transparent and suitable timber legal verification system for Guyana’s forestry sector. The development of this voluntary system was done though a process of stakeholder consultation and participation. The LAS has been the basis of engaging with relevant partners as the GFC advances its efforts in exploring the possibility of being part of an international system(s) of legality and verification, including the European Union, though it’s FLEGT Process.

The LAS was designed to be practical to be implemented by the GFC and the forestry sector, and includes built-in controls that provide assurance that forest management units and, where applicable, transport and processing facilities are recognised as legally operating, do operate in full compliance with all laws and regulations that comprise Guyana’s definition of legality. The

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LAS also outlines controls to check that the chain of custody systems used in Guyana provide assurance that only timber from verified legal operations is licensed.

Largely in keeping with EU-FLEGT (as well as the GFTN) requirements for legal assurance systems, the legality verification system for Guyana comprises five main elements:

Definition of legality: a definition of legally produced timber that sets out all the laws and regulations that must be complied with in the production process in Guyana,

Adequate traceability: a secure chain of custody that tracks timber from the forest where it was harvested through different owners and stages in processing to the point of export,

Verification of legality: a verification system to provide reasonable assurance that the requirements of the definition have been met for each export consignment. This involves verification of forest management operations and chain of custody in conformity with the requirements of the definition of legality for Guyana,

Licensing: the issuance of licenses to validate the results of legality verification and chain of custody,

Independent monitoring: independent monitoring of the whole system to assure its credibility and to provide transparency.

The process of development of the LAS re-commenced in 2009 and will extend over a period of 3-4 years.

1.3 Criteria and Indicators for Independent Forest Monitoring

The Memorandum of Understanding between the Government of Guyana and the Government of Norway outlines that activities to be covered in the 2009-2010 period also includes the establishment of a system for Independent Forest Monitoring (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 LAS, the ongoing dialogue with the EU FLEGT, or existing legality procedures/systems being implemented. IFM will be implemented in the State Forest Estate and Amerindian Villages that opt into the LCDS. IFM will be applied to logs, including round wood, piles, poles and posts, and lumber. It will cover all stages of the chain of custody as it relates to logs and lumber, namely: harvesting, transportation, processing, and export.

Independent Forest Monitoring is the use of an independent third party that, by agreement with the Guyana Forestry Commission, provides an assessment of legal compliance, and observation of and guidance on official forest law enforcement 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 final TOR delineates exactly what will be monitored, what information will be required, how quality will be assured and which protocols will be used to govern validation. Following this time period, a monitoring assessment will be conducted in July 2012, while future monitoring assessments will be conducted with a maximum of two year intervals.

For purposes of clarity, it must be understood that the Criteria and Indicators for Independent Forest Monitoring are being implemented at the national scale immediately for certain groups of stakeholders and are not intended to cover all indicators of the Guyana Legal Assurance System. This implies that the following criteria in the LAS are not included in IFM, i.e.:

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Compliance with national laws, regulations and guidelines relevant to labour and welfare,

Compliance with national laws, regulations and guidelines relevant to health and safety.

Some of the indicators in the LAS where compliance with applicable national laws, regulations and guidelines relevant to forest management or relevant to the environment are concerned are not included either, i.e.:

Requirement to conduct a pre-harvest inventory,

Requirement to formally train chainsaw operators,

Requirements relating to construction and maintenance of forest roads, skid trails, and bridges and other watercourse crossings,

Requirement to install buffer zones along waterways,

Requirements relating to the disposal of solid and liquid waste,

Requirements relating to the decommissioning of borrow pits and log markets, and

Requirements relating to the storage, transportation and disposal of fuels, lubricants and oils.

The IFM Criteria for Monitoring are defined for five main areas for monitoring. These are:

1. Timber Sales Agreements (TSAs) and Wood Cutting Leases (WCLs),

2. State Forest Permissions (SFPs),

3. Amerindian Villages if they “opt in” to the LCDS,

4. Agricultural and Mining Property Owners,

5. Processing and Export Stages.

IFM will at this stage cover only active TSAs, WCLs and SFPs on State Forest Land (including SFPs on Mining and Agricultural Leases on State Forest Land), SFPs on State Land where there are Mining or Agricultural leases and transport of logs and lumber from State forest Land, State Land and Amerindian Lands.

At the time of the scoping visit the process of developing a mechanism for Amerindian Communities to opt in the LCDS was still ongoing. Therefore Amerindian Communities were not considered at this time for IFM.

The draft Terms of Reference for IFM (including the Criteria for Monitoring) was prepared by the GFC and was tabled at and approved by the Multi-Stakeholder Steering Committee (MSSC) of the Low Carbon Development Strategy. A Multi-Stakeholder Reporting Panel (RP), a subpanel of the MSSC including representatives of the EPA, FPA, FPDMC, FTCI, GGMC, GLSC, IPC and NTC, is integrally involved in the IFM process. The RP is continuously updated on progress and developments regarding Guyana’s IFM efforts, and gives strategic guidance on the overall process.

1.4 Guyana’s Forest Resource Management and Monitoring Systems

The GFC is responsible for the administration and management of all State Forest Land. The work of the Commission is guided by the National Forest Legislation and the National Forest Plan that has been developed to address the forest policy. The Commission develops and monitors standards for forest sector operations, develops and implements forest protection and

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conservation strategies, oversees forest research and provides support and guidance to forest education and training and to promote sustainable forest management (SFM).

The SFM practices implemented by the GFC include:

1. Submission of Forest Management (FMP) and Annual Operational Plans (AOP),

2. Development of Guidelines to assist in the preparation of the FMP and AOPs,

3. Control of harvesting through the implementation of Annual Allowable Cuts and Annual Allowable Area and compliance to the Code of Practice for Timber Harvesting,

4. Post-harvest assessments and stump inspections,

5. Forest appraisal (forest inventory).

The main forest enforcement guidelines and activities implemented by the GFC are as follows:

1. National Log Tracking System,

2. Legality Monitoring and Assessment,

3. Concession level and Environmental Monitoring,

4. Removal control documentation system.

GFC asserts that its system of forest monitoring and regulation fulfils most elements of a chain of custody management system of forest produce from the point of harvest to export, and a system that allows for verification of legal origin of forest produce. Key monitoring tools are in place including the Code of Practice for Timber Harvesting, the log tracking system, and concession level and environmental monitoring. GFC has 28 forest monitoring stations located at strategic control points throughout the country and 17 additional mobile monitoring units.

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2 OVERVIEW OF IFM APPROACH

2.1 Assessment of regulatory and legal systems

The IFM approach focused on the collection of relevant information to gain a thorough understanding of the context in which IFM would be operating. This included gathering of detailed knowledge of the legal framework and the government agencies involved in forest management; systems of allocation of timber permits and concessions, trade in forest products, and the collection and distribution of taxes, fines and other payments. To this effect the following tools and systems in use by the GFC were reviewed and assessed on their effectiveness and legal status:

TSA, WCL and SFP Agreements,

Forest Management Plans,

Annual Operational Plans,

Quota System,

AAC and AAA computations,

Log tag issuance system,

Log tracking and tagging,

Removal Permitting,

Production Register,

Licensing – Sawmill, Timber Dealer, Export,

Code of Practice for Timber Harvesting,

Legality and Environmental Monitoring Inspection Reports,

Monthly Routine Monitoring Reports,

National laws, regulations and guidelines with respect to mining, agriculture, land use planning and environment. The possible existence of overlapping licenses will receive special attention.

In addition, the IFM team conducted the following assessments:

Legal assessment of the regulatory and legal systems in place,

Assessment of drivers of illegal logging and evaluation of possible ways to stimulate behaviour change,

Assessment of the enforcement of regulatory and legal systems, the quality of forest management, the occurrence and frequency of illegal practices and the accuracy of information provided by industry and/or GFC.

2.2 Field visits

A three-day field visit was undertaken to assess the enforcement of regulatory and legal systems, the quality of forest management, to document illegitimate practices and to check

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information provided by industry and/or GFC for accuracy. Furthermore, the field trip served to quantify the extent of illegal logging and other unauthorised activities, identify actors and to compare what monitors find in the field with the criteria for monitoring.

The three-day field trip included a visit to three SFPs along the Linden-Mabura road, including a chainsaw conversion operation (SFP DEM 043/2011), a stationary portable sawmill operation (SFP DEM 009/2010) and an operation producing both logs and lumber (stationary portable sawmill - SFP DEM 042/1993) on the first day. The second day, a meeting was held at the Great Falls Amerindian Community with the Toshao and AVC members. The purpose of this meeting was exploratory (IFM does not cover Amerindian Communities at the moment, because no mechanism is in place yet for “opting in” the LCDS) and mainly looked at the AVC’s readiness in terms of forest monitoring and to introduce the concept of IFM. A cluster of SFPs with unlimited quota in a gold mining area, held by Sustainable Forest Inc. (SFP ESS 05/2006, SFP ESS 06/2006 & SFP ESS 07/2006) was also visited on the second day. The third day GFC’s monitoring operations in DTL’s TSA 02/91 were visited, where stump inspection and routine monitoring were shown in a logging block. This was followed by a visit to DTL’s log yard, sawmill and lumber yards, including the export lumber yard. GFC’s office in Mabura was visited and methods of data recording and processing were witnessed. On the way back to Georgetown records at Linden Forest Station checkpoint were inspected including document verification. Four patrol checks were witnessed including document verification of logs in transit.

A number of lumber yards and an export wharf were visited in Georgetown.

2.3 Stakeholder consultations

Stakeholder consultations were conducted with representatives of all bodies that are members of the Multi Stakeholder Steering Committee (MSSC) of the Low Carbon Development Strategy. Additional consultations were held with the Amerindian NGOs APA and NADF. Consultations were done in the form of focus group interviews. The following meetings were held:

26 September - Meeting with GFC staff - NRDDB 28 September: - Office of Climate Change - Amerindian NGOs (GOIP, TAAMOG), IPC and MOAA - Private Sector (FPA, GMSA, PSC) 29 September - Hamekaran Basdeo: SFP DEM 043/2011 - Safiran and Royston Mohamed: SFP DEM 009/2010 - Ramesh Singh: SFP DEM 042/1993 30 September - Toshao and AVC of Great Falls Amerindian Community - Dwayne Klass, Forest Manager, Sustainable Forest Inc. (SFPs ESS

05/2006, 06/2006 & 07/2006) 31 September - GFC staff Mabura: Alandia Warde, Kavindra Tularam, Junior Whyte - DTL sawmill manager B.E.Tan - GFC staff Linden Forest Station: Gordon Lorrimer and Donette MacFarlane 6 October - Government Agencies (GRA, EPA, GL&SC, GFC) 6 October - International NGOs (CI-Guyana, WAB, WWF-Guianas, Iwokrama) 7 October - Reporting Panel (EPA, FPDMC, FTCI, GGMC, IPC, NTC) 12 October - EPA - GGMC 13 October - Amerindian NGOs (APA, NADF) - UG (VC office and Forestry Dept.) and GSA

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- GL&SC - Civil Society Individual Experts

See Table 5, Appendix 6.1: List of participants at focus group interviews and other meetings. The purpose of the stakeholder consultation strategy for this assessment was twofold:

1) To ensure that the public is aware of and informed about the IFM process and its objectives;

2) To assist the IFM team in identifying potential issues.

This process is not just stakeholder notification, but wherever possible, detailed and meaningful stakeholder interaction. The process of stakeholder interaction does not stop after the scoping mission, or for that matter, after even the first audit is made. The IFM team welcomes, at any time, comments on the IFM process and such comments often provide a basis for the audit.

2.4 Scoping report

This 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 Section 4.1 of 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.

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3 RESULTS

3.1 Main strengths and weaknesses

A scoping (pre-assessment) was carried out by a team of specialists of GFA Consulting Group to determine if GFC’s monitoring system and its implementation meet the requirements of the IFM criteria for monitoring. The scoping was carried out 26 September - 14 October 2011 using the Criteria for Monitoring published in the ToR for IFM of August 2010.

The goals of the scoping are threefold: First, the scoping provides GFC a clear understanding of the requirements for IFM; Second, the IFM team is able 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; Third, the scoping identified areas of GFC’s forest resource management and monitoring systems and implementation which present gaps to legality certification of GFC’s systems.

During the scoping GFC’s main strengths and weaknesses in relation to the IFM Criteria for Monitoring were identified. These are shown in Table 1 below.

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Table 1 GFC’s main strengths and weakness vis-à-vis IFM Criteria for Monitoring

A) Indicators for Monitoring of Timber Sales Agreement and Wood Cutting Leases & B) Indicators for Monitoring of State Forest Permissions (SFPs) including SFPs overlaying Agricultural and Mining Leases (D)

Principle 1 Legal rights to harvest and other parties’ legal tenure rights are respected

Criterion Strengths Weaknesses

Criterion 1.1

Legal logging rights to the forest

The GFC by virtue of its mandated functions manages the State Forest Estate. Effective legislation is in place for issuing logging permits such as TSAs, WCLs and SFPs.

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.

Criterion 1.2

Compliance with national laws relevant to other parties’ tenure and use rights

Multiple-use of land resources is dealt with at several levels of national policy coordination and inter-agency collaboration.

Policy coordination is effected through the Cabinet Subcommittee on Natural Resources and the Environment, and the Natural Resources and Environment Advisory Committee (NREAC). There is also a Land-use Coordination Committee comprising of the Commissioners of Forests, Lands and Mining, and the head of the environment agency, chaired by the Prime Minister. This committee addresses conflict avoidance and conflict resolution among multiple land users and uses.

Both GGMC and GL&SC appear to lack capacity to produce all valid leases and claims in a format compatible with GFC’s GIS.

There are efforts made to improve inter-agency collaboration but more needs to be done in relation to documentation on the management of multiple uses when they arise.

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.

Grantees are duly bounded to recognize the legal, customary and individual rights of the Amerindian people of Guyana. The MoAA has set procedures for handling disputes as referred to in this indicator.

No weaknesses identified

Principle 2 Compliance with legislation relevant to forest management and the environment

Criterion 2.1

Compliance with national laws, regulations and guidelines relevant to forest management

GFC has implemented a comprehensive set of instruments / practices to achieve SFM:

1. Submission of Forest Management (FMP) and Annual Operational Plans (AOP) is required.

2. Guidelines to assist in the preparation of the FMP and AOPs available.

3. Harvesting controlled through the implementation of Annual Allowable

Some stakeholders experience challenges in meeting the GFC’s requirements of submission of FMPs and AOPs. 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 AAA and AAC need to be documented properly and application of procedure needs to be more consistent; various summary sheets at FRMD

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Cuts and Annual Allowable Area and compliance to the Code of Practice for Timber Harvesting.

4. Post-harvest assessments and stump inspections.

need to provide consistent information.

Wording in the CoP and/or Forest Management Plan Guidelines needs to be updated to fully reflect the procedure being followed.

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.

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.

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.

Not all stakeholders have the capacity to implement CoP requirements; e.g. directional felling. Additional training by FTC Inc. is required.

GFC monitoring mechanism reportedly applies criteria to verify evidence of the application of directional felling according to the CoP. The reporting and verification system that was inspected during the scoping visit however did not specify such verifiable criteria or indicators. Besides the criteria in the CoP criteria and indicators should be defined to verify that directional felling sawing techniques were applied.

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Forest rangers and monitoring inspectors require further training or refreshment courses in verifying the application of directional felling.

LMEU and routine stump inspection reports should include measures taken in terms of follow up on occurrences of undersized stumps. Reports that were inspected that documented undersized stumps did not include statements of measures taken in terms of follow up.

CoP needs to be updated to reduce minimum spacing between harvest trees to 8 meters according to stated policy directive.

The system for managing identified non compliances and action requests needs to be more systematic.

GFC has a strong, comprehensive system of forest monitoring and regulation which fulfils most elements of a chain of custody management system of forest produce from the point of harvest to export. Key monitoring tools are:

1. National Log Tracking System, 2. Legality Monitoring and Assessment, 3. Concession level and Environmental

Monitoring, 4. Removal control documentation

system.

GFC has a dedicated and motivated staff complement of 360. The Forest Monitoring Division is properly equipped and counts 241 staffs. There is ongoing field monitoring by FMD field staff on range and patrol inspections together with routine sampling by the Legality Monitoring and Extension Unit (LMEU). The FMD has 4 divisional stations (Berbice, Demerara, Essequibo, and North-West District), 28 well-distributed forest stations with resident officers and 17 mobile units.

For TSAs, a sample of minimum 5% is applied for harvested blocks by the LMEU Unit. In routine concession monitoring, a sample of at least 40% of blocks harvested is applied. Data from LMEU monitoring reports suggested 63% of SFPs audited in 2010, achieving verification of 29% of tags.

Operations of the FMD, FRMD are in turn audited by GFC’s Internal Auditing Unit who reports directly to the Commissioner.

Log tag issuance is facilitated by two interrelated databases; one in FMD and one in the MIS. The database held at FMD is a parallel system using Excel, while the database in MIS is based on SQL database language. Data integrity cannot be guaranteed in Excel. The FMD database should therefore migrate to SQL.

The controlled issuance of tags reportedly serves a number of functions including management of tags used and unused tags, tag reconciliation, and also to inform the GFC the where harvesting has been occurring. There is scope for documenting this procedure and the criteria used.

FMD is allowed to issue tags against unverified production registers in case operators have run out of tags based on its own tag issuance and management database. Reportedly, reconciliation is done continuously at several levels: in the MIS where tag use is identified and recorded and anomies are reported. In the FMD tag use is informed by routine reconciliation of production vs. quota which is linked to tag management and issuance. There is scope for systematising and documenting these reconciliation procedures.

The methodology for sampling of tags during stump inspections is in need of a clear statistical design which is systematically applied.

Strategic analysis of production data, monitoring of conversion rates and reconciliation of volumes on SFPs and TSAs could be more systematic.

There is scope to improve analysis and management of corrective actions.

There is scope to improve consistency of tag

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application to stumps and logs.

There may be scope to improve consistency of policy, recording and application of tags in relation to infrastructure logs.

GFC needs to finalise and formally approve the Forest Monitoring Division Manual of Procedures.

Criterion 2.2

Compliance with national laws, regulations and guidelines relevant to the environment

There are a number of licences that require EPA permit. There is an ESIA requirement for large concession allocation (post 1996 – after the EPA was established), once it is not a reallocated TSA. Secondly, for large concession issued prior to 1996, the EPA in collaboration with GFC is currently working on a phased approach for these operations to be permitted using an Environmental Management Plan through the EMP permitting system.

For timber processing and retail operation operations, e.g. sawmills and lumberyards, a separate kind of environmental permit is required from EPA.

In practice, all such operations are licensed and approved to operate by the GFC only when an Environmental Permit is issued or when evidence is provided that the process has commenced at the level of the EPA.

EPA has capacity constraints in manpower resources and field station assessment capability to ensure timely compliance with the Environmental Protection Act.

In the interim (i.e. until the capacity issue is addressed) GFC has applied mechanisms to address such a situation/s, particularly in relation to the issuing of sawmill and sawpit licences. There is scope to improve documentation of recognition and approval by EPA of such interim mechanism.

The CoP prescribes that no felling should take place on slopes steeper than 40%.

During LMEU and routine monitoring inspections such assessments are reportedly carried out indeed. The current reporting system however does not present any verifiable data that would ascertain the evidence that no trees are felled on slopes steeper than 40%.

Principle 3 Payment of fees and royalties

Criterion 3.1

The payment of fees and royalties is done to the satisfaction of the relevant authorities

Any breach in payment of the outstanding balance of royalties and acreage and license fees result in an invoice addressed to the delinquent enterprise with a deadline for payment. Failure to honour the deadline can result in withholding of permission or reduction in duration of permit or non-renewal of permit, whichever is applicable.

No weaknesses identified.

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E) Indicators for Processing and Export Stages

Principle 1 Effective system for materials for assessment of legality

Criterion Strengths Weaknesses

Criterion 1.1

Verification of legality of origin of all forest produce entering facility

All sawmills and lumberyards are required to register with and be licensed by GFC. All licensed sawmills and lumber yards are issued with and required to keep a Production register (sawmills) or Lumber Yard Register (lumber yards). Operators are required to submit monthly returns- these are used as a basis for royalty calculation where applicable. These registers include the requirement to record material receipts by volume, species, product type and supplier GFC staffs monitor sites to ensure compliance with record keeping requirements and require corrective action/issue penalties for non-compliance. GFC collate data for production on a monthly basis.

There is s requirement that all logs carry GFC tags and that all lumber should be physically identifiable by way of tags and GFC inspection hammer marks. All material held at any location should be verified. There is a system in place for ongoing monitoring of verified status based upon the tag and hammer mark system supported by input records and/or movement documents. This monitoring result in identification of missing or irregular tagging and recording of non-compliances, seizure and/or royalty/penalty payments.

No weaknesses identified.

Criterion 1.2

Accurate records on input and output of forest produce

Sawmill operators and lumberyard operators are required to submit monthly returns of input and output by species and product. This system allows reconciliation of inputs and outputs at the level of each operator together with recovery rates.

There is scope to improve the identification of potential anomalies relating to recovery percent.

Principle 2 Sales and shipping documentation for traceability of legal origin of Logs and Lumber for exports

Criterion 2.1

Compliance with declaration of export sales and shipping information as required by the GFC

There is a GFC standard operating procedure for the export of forest produce. This includes verification that the operator holds an appropriate licence (e.g. Sawmill or Timber Dealer). There is a requirement that independent timber grading be carried out (GFC). Packing lists for logs for export include GFC tag number. Details of export consignments are input on to the GFC MIS database.

Remark: the GFC legal mandate extends to the point of approval of the export application. It is then the legal mandate of the Guyana Revenue Authority to follow on with other requirement.

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3.2 Identified gaps with IFM criteria

The following section of the report provides a summary of the gaps indentified in GFC’s forest resource management and monitoring systems and a number of other observations that will need to be examined during the real audit. While the IFM team has made every effort to conduct a thorough scoping, there may be areas not in compliance with the IFM criteria for monitoring that have not been identified by the IFM team. It is the responsibility of the GFC to review the identified gaps to ensure that they are in compliance at the time of the real audit. Additional details on findings are presented in other sections of the report.

Discrepancies or gaps were identified during the scoping between certain aspects of the GFC’s forest resource management and monitoring systems and one or more of the requirements of the IFM Criteria for Monitoring. No separate major or minor gaps were distinguished, but in certain cases the IFM team concluded that it was not clear whether a requirement was met or not due to lacking or inconclusive evidence.

The following Table 2 identifies the principal areas where gaps in compliance with the IFM Criteria for Monitoring (August 2010) have been identified as well as those indicators for which it was not clear if requirements are met. Indicators for which requirements are judged to be met are included in Appendix 7.5. Each gap is addressed by the IFM team by issuing a corrective action request (CAR).

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Table 2. Identified gaps with IFM criteria and indicators with recommendations

Criteria for Monitoring

The outline below defines the main areas that will be subject to Independent Forest Monitoring:

A. Indicators for Monitoring of Timber Sales Agreement and Wood Cutting Leases

Principle 1 The FMO has legal rights to harvest and other parties’ legal tenure rights are respected

Criterion 1.1 The FMO holds legal logging rights to the forest Source Documents and Information Sources

GFA Assessment

Indicator 1.1.1 The FMO is in possession of a legally valid concession agreement for the area from which all timber is sourced

Valid Concession Agreement in effect. Some concessions may be operating under an interim concession agreement approved by the GFC

Assessment

Requirement met with scope for improvement of documentation of conditions for renewal/extension and variation in life of TSAs

Information available Observations

System objective evidence

Timber Sales Agreements (TSAs) are Authorised under Forests Act CAP 67:01 section 7A introduced by Amendment in Act No. 4 of 1982, the Forest (Miscellaneous Provisions) Act 1982 - The Agreements are in writing, covering 26 sections on average. The Drafting language is identical for most TSAs. The terms of TSAs vary from 10 to 30 years. TSA's from 1997 include a clause permitting for extension. A variation has been observed between agreements in 2000 and those in 2005 and 2010 regarding environmental requirements. Four agreements have expired and are being extended annually.

Currently there are 27 valid TSAs and 2 valid WCLs. Valid TSA agreements for various concessionaires were perused.

The matter of the annual extensions was apparently based on policy directions and was done in accordance with Section 7 of the Forests Act Chapter 67:01.

The procedure and practice described appear to be reflected by a Policy directive given to the GFC for it to execute action in accordance with its powers under the Guyana Forestry Commission Act No. 2 of 1979.

It was observed that GFC has had to implement policy directives as a matter of expedience, which has been reconciled with the Forests Act including the pertinent Sections and Chapters.

There is scope for improvement of the documentation and notification of the conditions that determine whether expired TSAs are extended annually, i.e. expired TSAs not being renewed and the conditions that determine the variation in life of a TSA.

Implementation objective evidence

It was noted that where there were variations in the life of TSA agreements these were based on policy directives, which are discretionary. No list available of such agreements in the discretionary category and the basis for the discretion.

TSA's examined 2 of 1997, 1 of 1999, 01 of 2000, 2 of 2005, 3 of 2005, 1 of 2007, 2 of 2007, 5 of 2007, 1 of 2009 and 4 of 2009. WCL 1 of 2007 and 3 of 2007.

An electronic copy of a letter (jpg format) dated 5th December, 2005 which was provided to GFA in GFC’s submission, provides evidence of the policy directive given for one year extension. This letter also outlines the conditions under which the extensions took place, and criteria for such extension including matters of indebtedness or beneficial occupation of concession. The issuance of large concessions is reportedly based on a number requirements of which is included the approval of a business plan. The variations in the life within the range of 10 to 30 years and renewal of large concessions is then based on compliance with the GFC guidelines, national interest, and compliance with the commitments that the company made in the business plan.

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Indicator 1.1.2

If the FMO is working under contract to another concession holder the contractual arrangements are not in contravention of the Forests Act and has been formally approved by GFC

Contract. The GFC should be contacted to provide information on contract

Assessment

Requirement met

Comments pertaining to indicator (wording) The scope of 'working' in this context should be clearer. Is it intended to cover all acts on a concession, which are done other than by the concession holder? Are the contracts to relate to acts and working amounting to a disposal of interest or related to other activities? Information indicates subletting is prohibited. Use agreements related to machinery are permitted.

It should be clear who are considered contractors?



Regulation 11 of the Forest Regulations provides a procedure for transfers. Transfers, assignments and other acts relating to the exercise of concession rights require the prior consent of the Commission. This is a term of all TSAs. The clause is 12 of the TSA and WCL. "The grantee shall not transfer, sublet, mortgage or otherwise dispose of any interest arising under this Agreement except in accordance with the Forest Regulations".

There is a procedure for arrangements other than transfer, sublet or mortgage as follows: The concessionaire will have to make a formal request to GFC with regards to entering into an agreement with a third party. Thus, the terms and conditions of the agreement have to be verified by GFC. An evaluation is done prior to approval. If approval is granted it is for a period of no more than two year.

System appears appropriate.


From interviews with DCoF FMD, there is currently no TSA with such agreements. Check records of GFC to indicate whether these arrangements have been permitted. The Board Minutes of the GFC prepared in accordance with the Guyana Forestry Commission Act No. 2 of 1979. These would have to be examined to indicate permission. These are in the process of being compiled.

Implementation appears appropriate.

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Criterion 1.2 There is compliance by both the FMO and any contractors with national laws relevant to other parties’ tenure and use rights.

Source Documents and Information Sources

GFA Assessment

Indicator 1.2.1

There are no legal titles by indigenous or other persons on GFC approved concessions

Ministry of Amerindian Affairs (MOAA) and GFC for Maps of Neighbouring Communities that may be affected

Assessment

Requirement met with scope for improvement of systematic documentation



State Lands are regulated by the Guyana Lands and Surveys Commission, by virtue of the powers in the Guyana Lands and Surveys Commission Act No. 15 of 1999. Mining rights under the Mining Act No. 20 of 1989 are managed by the Guyana Geology and Mines Commission by virtue of the Guyana Geology and Mines Commission Act No. 9 of 1979. Indigenous titles are granted under the State Lands Act 62:01 as amended.

GFC’s Land Information System includes data (shape files) on Amerindian Reservations and Mining Leases; updates are sourced from GL&SC, GGMC and MOAA and subsequently digitized by GFC.

Maps and valid TSA agreements are available. There may be mapping issues such as overlaps as well as other issues, which may be identified by stakeholders and during interagency 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. If a complaint is proven valid the operations will be suspended, otherwise it continues.

While there is no evidence of such an occurrence it must be noted that verification of This indicator is subject to the effectiveness and efficiency of inter-institutional/agency arrangements.

This particularly relates to GGMC where only 4000 of the 13000 mining leases are clearly outlined and digitized; hence exact location, size and boundaries of mining leases cannot be verified by GFC.

Similarly, Agricultural Leases rely on Cadastral Surveys by Sworn Surveyors. These may be pre-GIS boundary descriptions or may not agree with the GFC LIS otherwise. GL&SC is currently working to upgrade their LIS. GFC verifies boundaries in the field (GPS) when there is doubt concerning the actual boundary description of the Agricultural or Mining Lease. The latter particularly occurs when boundaries are described using the 1:50,000 topographic base maps, which are based on Aerial Photography from the 1970s.

Multiple uses of land resources are dealt with at several levels of national policy coordination and interagency collaboration. Nevertheless, there remains no written document indicating how multiple uses should be dealt with when they arise.

Board decisions were unavailable for review in this scoping mission. These should support the practice and policy described.

In case of boundary issues GL&SC is the only agency with the required legal status to settle disputes – only a sworn surveyor can represent a case in court.


Allocations on maps of the GFC indicate areas where there are overlaps. Discussions reveal that certain forest areas have multiple uses and users some of which require sub surface utilization. Mining and agricultural leases require (partial) deforestation of the lease area and multiple uses is therefore not (fully) compatible with sustainable forest management. Compliance would be measured by the number of disputes reported and the mechanisms utilised to resolve these disputes.

Both GGMC and GL&SC appear to lack capacity / ability to produce all valid leases and claims in a format compatible with GFC’s GIS.

There are efforts made to improve inter-agency collaboration but more needs to be done in relation to documentation on the management of multiple uses when they arise.

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,

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There were no complaints by stakeholders’ visited - Great Falls and DTL. However, it was noted that Great Falls intends to adjust their boundaries, which will have implications for GFC approved concessions nearby. In such cases also, it will be checked that due process as laid out by the relevant legislations (Amerindian Act 2006 and Forests Act, and other relevant legislations) have been followed.

GFC also provided evidence (in the form of electronic copies of emails – April, May, June 2011) that validates the practice of information across natural resources agencies.

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.

Reporting Panel’s comments

The RP gathers that the issue at hand is that of multiple land use and how this is carried out in an operational sense. We would like to offer some supporting information in this regard:

There already exists a robust system for forest management through policies, legislation, institutions and the mechanisms for coordination in planning and management. Policy coordination is effected through the Cabinet Subcommittee on Natural Resources and the Environment, and the Natural Resources and Environment Advisory Committee (NREAC). There also exists a Land use Coordination Committee comprising of the Commissioners of Forests, Lands and Mining, and the head of the environment agency, chaired by the Prime Minister. This committee addresses conflict avoidance and conflict resolution among multiple land users and uses.

At the level of the agencies responsible for natural resources management (GFC, GGMC, EPA, GLSC), there has been efforts towards improved coordination of land use. There is a National Land Use Policy and several corridor and regional land use plans have been prepared. Currently the Guyana Lands and Surveys Commission is undertaking two important projects aimed at strengthening sustainable land-use management.

Under the framework of the LCDS, the harmonization process will continue. Many agencies have started to align their activities within the context of REDD+ and to effect improved collaboration not only at the inter-agency level, but also with forest users and their representative organisations. Recently a Land Use Committee has been set up to further coordinate activities of mining and logging, in particular as it relates to forest clearance.

Whilst the technical work of harmonization will be conducted by sector institutions, the OCC of facilitating this process. Upon completion of an exercise, which has inter-agency implications, reports are done which are made available to all relevant Agencies. In addition, routine monthly updates are given to sister agencies via e-mail. The GFC has evidence that checked boundary information is shared with the relevant agencies – specifically GGMC, GLSC and MoAA. Further, this not only happens when such matters come up, but on a routine basis through inter-agency collaboration.

Upon completion of an exercise, which has inter-agency implications, reports are done which are made available to all relevant Agencies. In addition, routine monthly updates are given to sister agencies via e-mail. The evidence provided in the form of communications sent to various agencies, substantiates this outline as above. With this clarity, we proposed for the indicator status to be revised to “Met”.

Additionally, the RP is of the view that the statement in the implementation objective evidence under this indicator as follows: “Mining and agricultural leases are given priority over timber concessions”, should be removed as this is factually incorrect. It should be clarified that each of these land uses are governed by legalisations that outline the use, regulation and management.

Due to the complexity and wide variability in which this situation can occur, one set of procedures cannot apply. As such, it is recommended to delete the request to have a written document on procedures. It is also recommended to delete the need for the GFC’s Board involvement as the MoAA governs this aspect and the Amerindian Act therein.

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GFA’s response to RP’s comments

There is no doubt that there is a comprehensive system in place and the appropriate institutional umbrella. Additionally, recognition is given to the new and ongoing initiatives aimed at advancing the LCDS and REDD+. Also the RP did allude to various conflict management strategies viz. conflict avoidance and conflict resolution. However, regarding the last point audits are about verifying conflicts situations (recorded etc.) as well as the procedures and processes for potential and/or real “conflict situations” based upon the working of the system as is operationally or functionally observable and that is the letter and spirit of the observation by the auditors for GFC’s consideration.

Indicator 1.2.2

Legal or traditional uses of the forest are not prevented by the FMO

MOAA, interview Residents of Neighbouring Communities, Guyana Lands and Surveys Commission

Assessment

Requirement met



The MoAA has set procedures for handling disputes as referred to in this indicator. This is part of the mandated work programme of the MoAA and related natural resources agencies (GFC, GLSC, and GGMC).

In TSAs Clause C of Schedule A, provide that the "Grantee is duly bounded to recognize the legal customary and individual rights of the Amerindian people of Guyana". Schedule A is made part of the TSA by clause 14. "The Agreement shall be subject to the provisions of the Forest Act, and any Regulations made there under, and to any terms and conditions contained in the Schedule annexed to this agreement."

Where situations exist that violate the letter and intent of the indicator, which can impact on legality, GFC investigates the matter on the ground to ascertain the nature of traditional use prevented and the reasons. In addition, MOAA is informed of the matter. If the holder is found to be culpable, compensation is sought and operations can be suspended. If the action was criminal in nature by either parties the Toshao and/or law enforcement agencies will investigate.

No evidence of prevention of the traditional and customary user rights of Amerindians as stated in the Amerindian Act No. 6 of 2006. It was noted that such legal traditional and customary uses are related but not limited to wildlife, medicinal plants, seeds, craft materials and construction materials for personal and/or communal uses and not for commercial use.

The GFC Forest Management activity related to this indicator should be checked to ensure that this activity is duly executed.

Board decisions were unavailable for review in this scoping mission. These should support the practice and policy described.


Visit to Great Falls AVC indicated no such problem. The Toshao also indicated that if such a situation occurs he will meet with the relevant concessionaire e.g. DTL to address the matter. No dispute resolution protocol was available.

Implementation appears appropriate.

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Principle 2 The FMO complies with relevant national legislation as it pertains to forest management and the environment

Criterion 2.1 There is compliance by the FMO with applicable national laws, regulations and guidelines relevant to forest management


GFA Assessment

Indicator 2.1.1

Approved management plan exists Management Plan Assessment

Requirement NOT met



Requirement is some TSAs - 1 of 1999, 2 of 1997 and 1 of 2000. Clause 5. Provision removed from TSAs issued in 2005 and thereafter. Section 7 of TSAs requires the Grantee to work the area to the satisfaction of the commissioner in accordance with a Forest Management plan. The plan is described in Schedule A of the TSA. Clause E of Schedule A under the heading 'System of Working' provides that the grantee shall "submit within six (6) months, a Forest Management Plan and Annual Operation Plan prepared in accordance with the GFC Code of Practice for Timber Harvesting, as revised from time to time." Further, in accordance with Clause E the plan shall remain in force and in effect for the first five years.

TSA concession holders are required to produce a 5-year forest management plan (FMP). These are submitted to GFC for approval. GFC review, evaluate and approve plans using a standard checklist and scoring system, which includes a threshold for approval.

An Excel data set of TSA agreements is kept which identifies all TSA and WCL concessions (27 + 2no.) and identifies submission and approval status for FMPs.

System appears appropriate. Full implementation of this indicator requires for all Forest Management Plans to be submitted by TSAs, to be developed in such a way to meet the full requirements of GFC, and to be approved in keeping with evaluation criteria.


Based on data held dated 16th Aug 2011 10 TSAs had approved FMPs and 4 TSAs had submitted FMPs but had not been approved.

Random selection of FMPs for inspection: TSA numbers 04/1991; 01/2010; 06/1985 and 03/1985 together with accompanying evaluation checklists. 3 of 4 not approved as having not met the requirements as outlined on the checklist. Requirement is some TSAs - 1 of 1999, 2 of 1997 and 1 of 2000. Clause 5. Provision is not stated in TSAs issued in 2005 and thereafter however, Section 7 of TSAs requires the Grantee to work the area to the satisfaction of the Commissioner in accordance with a Forest Management Plan. Further, the Plan is described in Schedule A of the TSA. Clause E of Schedule A under the

GFC shall ensure all TSA concession holders have an approved management plan.

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heading 'System of Working' provides that the grantee shall "submit within six (6) months, a Forest Management Plan and Annual Operation Plan prepared in accordance with the GFC Code of Practice for Timber Harvesting, as revised from time to time." Further, in accordance with Clause E the plan shall remain in force and in effect for the first five years.


GFC has considerable evidence to show that it has consistently been appealing to companies to submit FMPs; in fact, GFC even went as far as to accommodate the submission by specific components in a phased manner.

This has been met with limited success, however. In response to the non submission by some companies, GFC could have moved to suspend or even revoke the concessions issued. But since this action would have had serious social implications, policy guidance was given to GFC advising that GFC should keep reminding companies of this obligation, and only move to suspension or revocation if active companies fail to submit an Annual Operational Plan.

The GFC has informed that the Commission requests for Forest Management Plans to be submitted from TSA and WCL holders. The GFC reported that it has taken a number of steps over the years to strengthen submission of FMP by large concessions. The GFC provided examples of this in outlining efforts made over the past 18 months. It was reported that a number of steps were taken, to reach full compliance of this indicator in keeping with the requirement for all large concessions to have approved FMP. These steps include the following:

In the last quarter of 2010, all large concessions that were not in possession of FMP were written to, requesting for FMP to be submitted by the stated date.

A Public Notice was placed in the national media outlining this request.

A meeting was held with all large concessions outlining this request as well as well as other related requirements such as annual plans and pre harvest inventories.

In February of 2011, a meeting was also held with large concessions, further emphasizing this requirement.

Direct contact was also made with TSA that has not submitted FMPs.

The GFC also noted in spite of this requested submission not being met by a small minority of concessions, that the main tenants of Sustainable Forest Management and forest legality have been maintained via the following main procedures which are mandatorily applied for all TSA, and the Commission in so doing, not compromising on the practice of SFM in these areas, in any way:

The requirement for submission of Annual Operational Plan for areas to be harvested in the next year, detaining in full skid trails, etc.

The submission of full Pre harvest Forest inventory detaining all trees to be harvested in the coming year as an integral part of the AOP.

Given that SFM procedures are not compromised by virtue of the full compliance in the submission of the required AOP and Pre Harvest inventory submission, among other areas, whilst not negating the outstanding request for FMP, the GFC has reported that in recognition of the extensive social and economic impacts, in terms of benefits that the continued operation of these TSA (including employment, support to communities, etc), the decision was taken in the interim to continue communication with TSA who have not submitted to advance the process of submission of the FMP to GFC, and to allow for these concessions to operate requiring them to fully comply with required AOP, and other necessary processes.

Also, it is requested that this requirement only apply to TSAs and WCLs in operation.

The RP also requests that it be noted that FMPs can be for a period of 3-5 years.

GFA’s response to RP’s comments

A FMP is one of the main tenants of Sustainable Forest Management and therefore SFM procedures are indeed compromised by virtue of the submission of mere AOP and Pre-Harvest inventory instead of a full FMP.

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The decision taken in the interim to continue communication with TSA who have not submitted an FMP to advance the process of submission of the FMP to GFC, and to allow for these concessions to continue operating requiring them to fully comply with required AOP, and other necessary processes indicates that the appropriate implementation of the current concession allocation and forest management systems do not function as intended.

In this respect, GFA recognises that the GFC would have to apply its policy practically, as a shutdown of the sector will not be a preferred outcome of any forest management decision and will not only affect forest producers but their employees, the housing sector of Guyana, and forest products manufacturers. GFA also recognises that the GFC maintains that effective practice of SFM remains a fundamental priority for the Commission.

Indicator 2.1.2

Approved 1-yr operational plan, covering the source areas for logs, is implemented based on approved forest management plan

Annual Plan that contains outline of current activities.

Assessment

Requirement met with need for appropriate documentation of procedures



Legal Source - Section 7 of TSAs require the Grantee to work the area to the satisfaction of the Commissioner in accordance with a Forest Management plan. The plan is described in Schedule A of the TSA. Clause E of Schedule A under the heading 'System of Working' provides that the grantee shall "submit within six (6) months, a Forest Management Plan and Annual Operation Plan prepared in accordance with the GFC Code of Practice for Timber Harvesting, as revised from time to time."

TSA concession holders are required to produce a 1-year annual operational plan (AOP). These are submitted to GFC for approval prior to the year of harvest. GFC reviews, evaluates and approves plans using a standard checklist and scoring system, which includes a threshold for approval.

An Excel data set of TSA agreements is kept which identifies all TSA and WCL concessions (27 + 2no.) and identifies submission and approval status for AOPs.

In some cases TSA or WCL may not be active and may not therefore have an AOP.

It was not clear from the Excel data set observed during the scoping mission whether TSAs without AOP are indeed inactive. The Excel summary sheet at FRM large concession office did not identify inactive TSAs/WCLs. GFC supplied a separate Excel document showing the active and inactive status of all large concessions following receipt of the GFA initial report asking for such a table.


Excel TSA data summary sheet dated 16th August 2011 indicates 20 of 27 TSAs had an approved AOP.

Random selection of FMPs for inspection: TSA numbers 04/1991; 01/2010; 06/1985 and 03/1985 together with accompanying evaluation checklists. 4 of 4 approved.

All active timber concessions require AOPs and apparently have such.

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This section, by the very wording of the name of the section, applies to the requirements for “working” or harvesting. For the seven concessions that are not operating, these concessions are not active. Also, the indicator itself requires for “Approved 1-yr operational plan, covering the source areas for logs...” “Covering the source of the Logs” requires for harvesting to occur to result in logs being harvested. The indicator therefore only applies to concessions that are active. Had the indicator been worded “All concession must be in possession of an Active AOP”, the requirement would have been different for this indicator.

AOPs outline the plan for harvesting for the coming 12 months. For concessions that, for reasons that include various administrative and technical challenges that are faced, do not have that intention to harvest in the coming 12 months and thus do not submit a Plan to harvest as this will a Plan that will not be translated to “working” or harvesting of the concessions.

As such, given that all seven (7) concessions that were found to not have an AOP are all inactive or are not timber producing concessions, as duly recorded by the GFC, this requirement as covered under Clause E or Schedule does not apply. Also, all Active TSAs have AOP and this provides the basis of their operation. However, note should be taken that all active timber concessions have approved AOPs.

There is therefore no compromising of either SFM or legality in such cases. As such, we propose for the revision of the status of this indicator.

Indicator 2.1.3

The Annual Allowable Cut is appropriately calculated, approved and not surpassed on the basis of 100% inventory of commercial species, to a maximum of 20 m³ per hectare over a 60 year cycle, or a prorated AAC based on the 20m3/ha over 60 year calculation, or at an otherwise agreed level, adequately supported by management level inventory, and in keeping with SFM principles

Management and Annual Plans that outline approved AAC

Assessment


Comments pertaining to indicator (wording) The clause in the indicator "….at an otherwise agreed level, adequately supported by management level inventory, and in keeping with SFM principles." should be worded more specifically; e.g. AAC may be higher or lower in such and such cases based on such and such rationales. SFM principles would need a definition of the criteria used to determine sustainability.

Unclear whether actual realization of the AAC is covered by this indicator.



Legal source - Section 7 of TSAs require the Grantee to work the area to the satisfaction of the Commissioner in accordance with a Forest Management plan.

The plan is described in Schedule A of the TSA. Clause E of Schedule A under the heading 'System of Working' provides that plan should be based on the principle of sustainable management.

1) TSA Agreement Schedule "E" prescribes that FMP and AOP must follow the CoP; CoP Chapter 2 Section 3 prescribes an Allowable Cut of 20 m3/ha

GFC needs to document calculation of AAC and AAA in a separate document or amend FMP guidelines and CoP accordingly.

The method of calculation of the AAC (or AAA, TAC, APFA, PFA, Non-PFA) is based on unlinked statements in the Code of Practice and the Forest Management guidelines:

- Code of Practice for Harvesting (section 2.2, page 7 provides the requirements for 4.5% as protected areas for biodiversity reserve and states on this page the reason for this.

- The Code of Practice for harvesting on Pages 7-8 also covers the yield regulations on 20 m3/ha/60 years.

- The Forest Management Plan Guidelines on Page 31 provides the outline for the

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for a 60 year cutting cycle (AAC = ⅓ m3/ha/yr). FMPs, AOPs and summary sheets on AAC for all TSA / WCLs in FRMD.

2) The AAC is set for three different cycle lengths by the FRMD as follows: for 25 year cycle (8.33 m3/ha), 40 year cycle (13.33 m3/ha) or 60 year cycle (20 m3/ha).

3) Actual calculation method for AAC/AAA(=number of blocks) consists of: a) Productive Forest Area (PFA) = Concession size - Non-Productive

Forest Area (Non-PFA), b) Available Productive Forest Area = PFA - Biodiversity Area (=4.5% of

PFA), c) Net-Productive Forest Area = 80% of APFA, d) Total Allowable Cut (TAC) = Net-PFA x Cutting intensity, e) AAC = TAC÷Cutting Cycle, f) AAA = Net-PFA÷Cutting cycle, g) Number of Blocks = AAA÷100.

In instances where management level inventory is provided by concessions holder, this is used to determine the net productive forest area of that concession. However, for other concessions that have not provided this, the default of 80% of the concession areas are assumed to be the net productive area and this is based on the precautionary principle as a conservative measure.

Blocks are open for a period of three years. This implies that blocks listed in an AOP which are not completed can be brought forward to the AOP of the next year. These are called "re-entry" blocks. AOP should distinguish between "new" blocks and "re-entry" blocks.

application of the 80% to provide for buffers, etc.

However, the CoP states that the 4.5% biodiversity reserve "would include formally protected areas as well as streamside buffer strips, non-productive forest". Technically, non-productive forest would therefore already be included in the deduction for Non-PFA or 20% deduction for buffer zones. Wording in the CoP and/or Forest Management Plan Guidelines needs to be amended to fully reflect the procedure being followed.

Identification of non-productive areas of the concession is described very broadly on page 21 of the Forest Management Plan Guidelines as including areas of non-forest or non-commercial forest (swamps, savannahs), areas that are inaccessible for harvesting, areas set aside for biodiversity reserves, research and protected areas, buffer strips and areas of special cultural, religious or historical significance.

Earmarking of forest types as non-productive is technically supported by GIS vegetation mapping done by the GFC [The national vegetation map (Ter Steege 2001). Major Polygons based on Soil Maps of Guyana (Gross-Brown 1965) Vegetation data from FIDS Base map (GFC 1970s)]. Ground truthing and field exercises conducted by the GFC post 2001 have determined the areas the vegetation types that are productive and non-productive. These forest types are listed as part of the FRMD GIS system.

GFC needs to list forest types that are considered non-productive in the FRMD GIS system, and amend FMP guidelines and CoP, whereby the exact forest types that are considered to fall in this category are indicated.

The Commission, as part of its legislative mandate under Section 67:01, and Act 2 of 1979, allows for maximum of an extension of two year to be granted upon the Commission’s assessment and approval.

GFC needs to indicate in FMP guidelines and CoP that an extension of two years may be granted to allow re-entry of brought forward blocks and indicate circumstances under which this would apply.

FRMD’s Large Concession Planning and Information Unit’s Excel summary sheets need to distinguish between “new” and “re-entry” blocks.


Summary sheet indicating blocks approved for harvesting at FRMD Large Concession Planning Unit.

TSA & WCL Production Sheet (Annual) originating from the MIS Production Database.

AOPs TSA 02/91, TSA 04/91, WCL 01/07 inspected. FMPs TSA 04/91, TSA 02/91, TSA 03/85, and WCL 01/07 inspected.

Data on summary sheet calculating AAC per TSA do not match in five cases with the data on the summary sheet with the number of blocks approved for harvesting.

In four cases, the GIS forest type shape file was reportedly updated based on a re-assessment done of the Net Productive Forest Area; this was not updated in the respective summary sheet.

FRMD Large Concession Planning Unit needs to link the different summary sheets / databases and GIS updates; perhaps by migrating to MS Access or SQL.

In one case, the AAA is reportedly based on calculations in the FMP (and a management level inventory). However, the inspected FMP for a TSA for which the

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AAC/AAA was calculated based on its own management level inventory did not provide the required details.

If the Net-Productive Area is based on the FMP of a TSA holder, the FMP should clearly indicate the Net Productive Area and the underlying inventory information and calculations.

In case of three TSA's approval was granted by FRMD to harvest advance or extra blocks from the quota for 2012 in 2011. In a number of cases, blocks were switched approval granted by FRMD.

Procedure for application and approval of harvesting advanced blocks needs to be formally documented. GFC needs to develop a concession allocation strategy that eventually will lead to an appropriate match between the size and richness of the allocated resource (TSAs) with the capacity and investment level of the TSA holders. AOPs need to be updated to reflect changes in the number blocks that may be harvested and which advanced blocks will be harvested. This should be done within e.g. 3 months after granting approval.

One TSA holder was given permission to re-enter compartments before the end of the cutting cycle. MAC was set at 3.33 m3/ha, based on the assumption that 5 m3/ha had been harvested at first entry. This figure is arbitrary since logging intensity would be variable from block to block depending on the richness of the stands. Appropriate implementation of SFM would require knowledge of the volume removed previously during the current cutting cycle (1991-present) for each individual block, since the MAC is normally determined at the block level.

GFC would need to systematically collect and analyse production data to be able to adjust MAC and cutting cycle appropriately when the need (economic and social impact) arises to do so.

There should be more consistent application of AAA and AAC computation.

Presentation of AAA and AAC at concession level should be presented in all AOPs and FMPs and should be consistently applied taking account of boundary refinement, titling of Amerindian areas, etc.

Formal documents and authorisation letters should be present in all folios for re-entry and additional block allocation.

Reporting Panel’s comments:

It is requested that the following clarification be made on this indicator as the GFC’s statement:

Advance Blocks: “It must be noted that the FRMP and AOP are not static documents. As such, the GFC over the course of the operation period, through a formal

process (that encompasses, request in writing, the GFC’s assessing such requests, the GFC making recommendations on possible options in keeping with SFM and approved AOP and FMP, etc, and granting feedback – approval or non approval), allows for the revision of specific aspects of AOP. However, it must also be noted that changes which are made are in keeping with a number of core tenants of SFM including AAA and AAC. In cases where companies may be granted advanced blocks,

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companies still have to reach the requirement for harvesting such as pre pre-harvest inventory, preparation of stand tables and stock maps and for which the advance blocks are subsequently included in the following years AOP and deducted from the AAC and AAA for that following year. This practice is legal and is in keeping with Guyana’s Forest Policy.”

Permission to Re-enter Block/Compartment: “As is normal practice, the GFC only allows the re-entry of blocks, within any compartment, only if it can be proven by

records, and agreed by GFC and the concessionaire following an evaluation, that the operator has not harvested the full approved allowable cut for a given concession areas working within a given cutting cycle. Additionally, in heterogeneous forest, like in the case of Guyana, for large forest concessions, forest areas are managed in small management units referred to as 1km2 blocks where an average volume per hectare is only allowed to be harvested. Likewise, the same principle applies over a compartment with many blocks, where an average extractable volume per block, is applied based on a cutting cycle. In tandem with this, a number of CoP requirements such as minimum diameter cutting limits, proximity rules and protection of buffer zones, also all contribute to the prevention of overharvesting of any given areas. The application of 5.5m3 MAC for the concession alluded to, in no way breaches SFM, since this level is based on the precautionary principle and is therefore a conservative limit. This therefore allows for SFM within the forest area to be maintained.

The RP also requests that the Monitor notes that any land allocations strategy must take into consideration economic, infrastructure and physical aspects, and other related aspects, in addition to environmental aspects, of forest sector development.

Indicator 2.1.4 Tags are properly obtained and a record of their use is kept. All unused tags are appropriately accounted for at the end of the GFC reporting period

Production Records and relevant Database Reports

Assessment




Log tag management and issuance process is described In the GFC Forest Monitoring Division Manual of Procedures (Draft) Section 5.

1. Log tag issuance is facilitated by two interrelated databases; one in FMD and in the MIS. The database held at FMD is a parallel system using Excel, while the database in the MIS is based on SQL database language.

2. FMD Tag Management and Issuing Officer (TMIO) requests Tags from Central Store (approval DCoF or ACF FMD required). Tags are in sequence in batches of 500 each.

3. TMIO and Store Clerk of Central Store record tag numbers issued in Central Store tag issuance register - signed by both. Tag numbers issued are entered in Finance Central Database.

4. Internal auditor and supervisor check register (monthly, quarterly and annually).

5. TMIO uplifts tags from Central Store and signs ledger.

6. TMIO issues tags to WCL and TSA holders based on a request by the

System appears appropriate but needs improvement of the situation with two parallel databases to ensure data integrity.

The GFC has developed interrelated databases for the management of the Log Tracking System. Log Tag allocation is a controlled process facilitated by databases in FMD (excel) and MIS (SQL). Information in relation to tags issuance and usages are recorded in the databases. Tag allocation is linked to a Quota System which is an initiative to manage and control the volume of forest produce harvested. The need for the parallel system has arisen from issuing of tags on an assumption of 3 m3 per tree. Additionally, in some cases, a percentage of the tags for the approved block Maximum Allowable Cut (MAC) may be issued to the concessionaire. In some instances, The concession holder may harvest trees less than 3 m3 whilst still being in keeping with SFM rules. Hence, concessionaires may request more tags to harvest their approved MAC quota, whilst at the same time submitting removal permits to the GFC and GFC collecting and processing the removal permit may take up several weeks. The parallel system provides for an additional layer of control in tag management and issuance. However, concession harvesting operation is fixed on an approved volume to be harvested and not to a fixed number of trees or tag issued.

The need for the parallel system arises from issuing a limited percentage of the tags of the annual quota and/or logs smaller than 3 m3 being harvested combined with the lag time involved in collecting and processing the production register and removal permit.

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holder according to approved block quota according to block approval letter from FRMD).

7. The total number of tags to be issued is based on the approved block quota in case of WCL's and TSA's and an assumed average volume of 3 m3 per tree.

8. Tags are issued in sequence and batches.

9. Concessionaires sign the FMD Tag issuance letter and register when uplifting Tags (Tags are checked in the presence of both parties). Tag issuance letter is forwarded to MIS.

10. At the end of the year unused tags are returned and return register signed by both parties.

TMIO records and verifies returned unused tags. The returned tags are then handed over to the Internal Audit Unit for verification who then returns the unused tags to the central store where the Inventory Clerk archives the tags and subsequently destroys them.

GFC needs to document a systematic procedure to verify issuance of tags against unverified production registers by cross-checking with the production database (MIS) as soon as production registers are processed.

GFC needs to finalise its Forest Monitoring Division Manual of Procedures and have the procedure and practice approved by a decision of the Board of the GFC in accordance with its powers under the Guyana Forestry Commission Act No. 2 of 1979.


Log tag requisition procedure is described In the GFC Forest Monitoring Division Manual of Procedures (Draft) Section 5.

When requesting tags, TSA/WCL holders must provide block approval letter from FRMD to the Tag Management and Issuance Officers.

The Tag Management and Issuance Officer verifies and issues tags based on the MAC quota as stated in the TSA/WCL block approval letter assuming 3 m3 per tree.

The TMIO processes and signs TSA/WCL Tag issuance letter and forwards it to the DCoF or the ACF FMD for verification and approval.

The information on the tag issuance letter is entered in the FMD Tag Issuance Database and the MIS Production Database (Monthly Production Reports are sent to the Tag Management and Issuance Officer by the Head Planning and Development.

Tag issuance may be approved or rejected by the DCoF or ACF for various reasons.

After approval for issuance, the TMIO issues tags. Relevant registers are signed and completed.

If issuance of tags is not approved, the TMIO communicates this with the

The Tag Management Issuance Officer issues tags for each approved block according to the approved MAC quota per block. However, in some cases a limited percentage of tags are issued for the approved block MAC quota. The TMIO decision to increase or lower the percentage follows directives by the DCoF FMD. Proper documentation of procedure and criteria needed.

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TSA/WCL holder requesting the tags, who may seek an audience with the DCoF or ACF to reconsider the case.

In cases where forest officers uplift and return tags from out-stations, he/she shall complete and sign the relevant register.

When a TSA/WCL holder returns to uplift a second (or third) batch of tags, the Tag Management and Issuance Officer verifies the requested amount of tags with the remaining quota in the FMD Tag Issuance database (monthly production report MIS).

Entire tag issuance procedure witnessed starting from the Central Store to the actual issuance of tags to applicants.

Reporting Panel’s comment:

The percentage of tags issued to concession is based on the assumption that these are of a certain size and for which also, is agreed between the GFC and the operator. It should be noted that the controlled issuance of tags serves a number of functions include management of tags used and unused tags, tag reconciliation, and also to inform the GFC where harvesting has been occurring. It was noted by the RP that the operationalising of this arrangement for coming year will be informed following dialogue/discussions with relevant stakeholders. The FPA noted that it is imperative for a balance to be struck between maintaining a robust system and at the same time ensuring that forest operation is enable in a realistic and practical manner.

Indicator 2.1.5 Logs and stumps are tagged according to the log-tracking system

Log-tracking document Assessment

Requirement met



Log tracking system is described In the GFC Forest Monitoring Division Manual of Procedures (Draft) Section 5.

Tags are allocated per block according to the Maximum Allowable Cut (MAC) for the approved block, (base on a stand table derived from the block pre-harvest inventory data and stock map for the block and according to the cutting cycle for the concession) using a clear tag issuance procedure (See Indicator 2.1.4).

Tagging should be carried out at stump and operators are advised to paint tag number on log and stump in addition. Tags have two parts one attached to stump and one attached to log.

There is ongoing field monitoring of tag use by GFC field staff on range and patrol inspections together with routine sampling by GFC central monitoring division.

Monitoring reports identify stumps sampled in each block (20/block) with GPS co-ordinates and tag number recorded. Any breaches in tag use (e.g. stump

Some TSA operators have their own tagging system in operation in addition to the GFC tagging system and their records provide an additional cross-check.

The adoption of the procedure and practice described in the GFC Forest Monitoring Division Manual of Procedures (Draft) should be reflected in a decision of the Board of the GFC in accordance with its powers under the Guyana Forestry Commission Act No. 2 of 1979.

GFC needs to finalise and formally approve the Forest Monitoring Division Manual of Procedures.

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with no tag) are reported.

In addition, patrols and checkpoints regularly check logs in transit.


Field visit to one TSA block at scoping very limited but demonstrated tag use on stumps inspected.

Log yard at TSA03/1991demonstrated full compliance on all logs inspected.

A sample of monitoring reports inspected for blocks being worked in 2011 for TSAs 04/1985, 01/1981, 10/1985, 04/1991, and WCL 01/2007 indicated every stump inspected had an accompanying tag.

Some felling occurs in TSAs to assist bridge construction - some TSA holders (partially) tag these trees (but record no production) others do not tag these infrastructure logs.

Method of attachment of tag affects reliability - some operators use staples, which appear reasonably robust.

Additionally, the number can also be crayoned on in cases of water transport to transport in rough terrain. The methodology for sampling of tags during stump inspection in TSAs is in need of a clear statistical design which is systematically applied.

Some operators tag infrastructure logs (logs used for camps, bridges, culverts, etc.), while others do not. The policies with regard to such logs are not documented and not clear. Policy, recording and application of tags in relation to infrastructure logs needs to be improved.

Indicator 2.1.6

Transportation of logs and lumber is accompanied by relevant GFC approved documents. E.g. removal permits transhipment permit, custody form, clearance pass, bill of sale and receipts

Removal Permits and other valid documents can be cross-referenced to the produce transported to determine accuracy of the information inputted

Assessment

Requirement met

Comments pertaining to indicator (wording) The examples should be removed from the indicator; legal rules of interpretation may suggest a complete list. There would be little room for what is left out with such a degree of specificity as appears intended.



Licences are required by the Forest Regulations - Removal Permits are governed by the provisions of regulation 21 of the Forest Regulations. This regulation provides for the removal of forest produce from State forest. Conveyance of forest produce is governed by the provisions regulation 22. Removal permits are to be produced to the nearest police station or forest officer for inspection - Upon satisfying himself that the forest produce is lawfully obtained and the particulars are correctly entered, endorse the permit and shall enter the place of inspection. Removal of forest produce removal permit, transhipment permit, custody form, clearance pass, - bill of sale and receipts - not required as part of the regulations related to Forestry.

GFC Forest Monitoring Division Manual of Procedures (Draft) Sections 1.3 to 1.9 describes documents required for movement of logs and lumber. These include:

1. Removal Permit - to remove produce from State Forest areas and is

It is recommended for further improvement of the system that, the adoption of the procedure and practice described in the GFC Forest Monitoring Division Manual of Procedures (Draft) be carried out, and should be reflected in a decision of the Board of the GFC in accordance with its powers under the Guyana Forestry Commission Act No. 2 of 1979.

The GFC Forest Monitoring Division Manual of Procedures (Draft) section 1:5:4, deals with issuing transhipment permits. The language of condition (1) should be examined.

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used as basis for calculation of royalty.

2. Private Property Removal Declaration Permit – to remove produce from private own land (legal land title) as a basis to declare the produce remove to the GFC.

3. Transhipment Permit - to accompany produce already assessed for royalty.

4. Trip sheet - a number of trip sheets may be used with one Removal Permit.

5. Clearance Pass – this document to be used for the release/remove of seized/detained forest produce.

6. Custody Form – this document is used to facilitate the removal of forest produce when legality is questionable to a known destination during an investigation.

Officers are expected to examine forest produce at checkpoints and while on patrol and reconcile details on permits to tags. In the event of non-compliance, seizure and custody procedures may be followed together with accompanying documentation e.g. custody form.


Removal permits issued. Removal Permits endorsed.

Records at field station checkpoint inspected and indicated ongoing implementation of document verification.

Checkpoint inspection witnessed included document verification.

Patrol checks witnessed included document verification of logs in transit.

All documents seen complied with documentation requirements.

Indicator 2.1.7

All logs and lumber in transit, and at point of export, that originate from the State Forest Estate, can be traced back to source stump

Details from a permit accompanying produce in transit and when in concession, request to inspect felling area

Assessment

Not clear if requirement met



Legal Sources this represents the movement from the Forests Act Cap 67:01 to the provisions of the Timber Marketing Act Cap 67:04. For the purposes of marketing, other requirements have been identified. Export of timber is regulated by section 8(1) of the Timber Marketing Act Cap 67:04 and requires

It is recommended that the adoption of the procedure and practice described in the GFC Forest Monitoring Division Manual of Procedures (Draft) be done, and should be reflected in a decision of the Board of the GFC in accordance with its powers under the Guyana Forestry Commission Act No. 2 of 1979.

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an Export certificate. Prior to export timber shall be graded in accordance with the Act Cap 67:04 and the Regulations.

Logs. There is a requirement that all logs are tagged. Procedure described in GFC Forest Monitoring Division Manual of Procedures (FMDMP) Section 5. Logs can be linked to stump and forest block of origin and there is regular on going and sample monitoring of tag use at block level. GPS co-ordinates are used to locate stump position on pre harvest inventory stock maps.

Lumber. One clause in GFC FMDMP notes that tags should be placed on some part of lumber to be transported although details of how this should be done are not given.

Tagging is supplemented by documentation e.g. Production Register, Sawmill Register, Summary production reports - these cross reference to tag number.

Logs and lumber is spot checked en route from origin to final destination, (See indicator 2.1.6).

At point of export Produce is accompanied by export documentation (see Criterion 2.1) which references log tag numbers.


Logs. Logs from TSAs and WCLs appeared to be well monitored and regulated, with few non-compliances noted in relation to tag use. Records of production seen appeared complete. Documentation and monitoring of documents appeared to be well managed. GFC monitoring systems effectively identified tagging non-compliances in transit together with fines to encourage improved compliance. Lumber. The point at which logs are converted into multiple pieces (logs) and/or lumber is a critical control point in the overall chain of custody system. Tags are transferred from logs to lumber, and records of production are kept. However there is no guarantee that all converted produce is transported in a single shipment e.g. more than one product may be produced for more than one buyer - one tag cannot accompany more than one load. In addition, conversion is a point in the production process at which theoretically unauthorised logs could enter the system for onward shipment covered by a tag. A tag on lumber is a useful indicator that lumber is from an authorised source but on its own is not a reliable guarantee. Reliable claims regarding Chain of custody for lumber therefore need to be backed up by production records of input and output together with evaluation of conversion factors and reconciliation of volumes. Some TSAs/WCLs operate their own log tagging and tracking systems in addition to the GFC tagging requirements, and operate their own batch processing systems with reliable production records. E.g. seen at TSA

For Lumber sourced from TSAs/WCLs tagging and documentation in transit and at point of export provide an indication that material can be traced back to source stump. It is not clear at this scoping stage whether all TSAs producing lumber operate batch processing systems and/or own tagging systems that allow a reliable claim nor is it clear how or if GFC evaluate this.

It is recommended that to institute improvement of the reconciliation system. GFC’s MIS production database records volume harvested which can be used to reconcile lumber produce from a sawmilling operation and those meant for export; i.e. production records of input and output together with evaluation of conversion factors and reconciliation of volumes.

Audit shall review field compliance.

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03/1991 had own tags, monthly batches and physical identification on output pieces/bundles allowing traceability to individual GFC tags or batches of GFC tags.


The RP recommends for purposes of completeness and to five a fuller representation for the indicators that the text below be added as the GFC’s addition clarification:

“GFC’s MIS production database records volume harvested can be used to track lumber produce from a sawmilling operation. Further, there is ongoing field monitoring at forest concession, at sawmilling operations and at the port of export to verify the origin and legality of the forest produce . GFC’s monitoring field staff on range and patrol inspections together with routine sampling give the system assurance that at all time the forest produce can be traced back to its origin and legality. In addition, patrols and checkpoints regularly check logs and lumber in transit. Uncertainties are investigated. Penalties are in place for breaches.

It is recommended that improvement of the reconciliation system to be instituted. GFC’s MIS production database records volume harvested which can be use to reconcile lumber produce from a sawmilling operation and those meant for export.”

Indicator 2.1.8

All relevant licences are held and up-to-date Actual Licences and Permits with relevant dates

Assessment

Requirement met (after revision of wording of indicator)

Comments pertaining to indicator (wording) Relevant as the basis of an indicator appears vague.



Which licences and permits are being considered? These should be authorised by the regulations, or a practice or other decision.

At the time of the scoping mission it was not clear which licenses were being considered. The GFC has indicated that this information is available for perusal and verification on request. Due to time limitations no records were perused.

Implementation objective evidence Real audit shall review compliance

Indicator 2.1.9

Directional felling is practised to minimise damage to forest

Evidence of directional felling Assessment

Requirement NOT met



Legal Source - Section 7 of TSAs require the Grantee to work the area to the satisfaction of the commissioner in accordance with a Forest Management plan. The plan is described in Schedule A of the TSA. Clause E of Schedule A under the heading 'System of Working' provides that the grantee shall "submit within six (6) months, a Forest Management Plan and Annual Operation Plan prepared in accordance with the GFC Code of Practice for Timber Harvesting, as revised from time to time."

Evidence of directional felling is recorded during routine inspections and inspections by the Legality and Environmental Monitoring Unit. (LMEU).

GFC needs to define verifiable criteria and indicators to assess evidence of directional felling. Criteria: 1) evidence that felling direction was selected based on RIL criteria, 2) evidence that directional felling sawing techniques were applied.

One monthly ranger monitoring report used four indicators to assess directional felling, looking at pre-determined felling direction, whether the intended felling direction was followed, whether correct felling techniques were used and damage to the residual stand.

Monthly Routine Monitoring Inspection Reports by the FMD officers on site do not follow a consistent format.

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Routine inspections in TSAs imply that a number of forest rangers are on site during the felling operation.

Routine inspection monthly reports may include an evaluation of directional felling.

The LMEU Monitoring Inspection Field Form assesses directional felling for each tree that is sampled. Sampling involves 10 trees randomly sampled per block. It is not clear on which criteria and indicators the assessment of directional felling is based.

Application of directional felling is mentioned in Monthly Monitoring Reports by GFC FMD staff on site.

A sample of minimum 5% is applied for harvested blocks by the LMEU Unit. However, in routine concessions monitoring, a sample of at least 40% of blocks harvested is applied.

Reporting format needed for monthly inspection report for routine monitoring of TSAs.

Environmental Monitoring of SFPs Field Form could be used to provide a format for Monthly Monitoring Reports.


6 Environmental Monitoring and Auditing Reports (LMEU) for 2011 that were perused; directional felling appeared to have been practised in 3 out 6 TSAs. Out of the total 254 stumps that were inspected in these audits, 105 stumps were judged affirmatively that directional felling was applied.

Random selection of LMEU TAS audit reports: TSA numbers 01/91; 04/85, 03/85, 04/91 and 10/85, WCL number 01/07.

Five out 6 monthly monitoring and stump inspection reports indicated that directional felling was indeed being applied. Only in one case, indicators were used to arrive at the particular judgement. Other judgements were apparently subjective.

Random selection of Monthly Monitoring and Stump Inspection Reports: TSA 01/09 September 2011, WCL 01/09 June/July 2011, TSA 02/91 Jun 2011, TSA 03/91 August 2011, TSA 03/91 September 2011, TSA 01/00 April-June 2011.

Interview with forest ranger and monitoring inspector on site at TSA 02/91 block 48.

Directional felling was applied in only 40% of the stumps that were assessed by the LMEU; hence the requirement is not met.

Interviews, however, suggest that judgements on directional felling are not based on specific criteria and the application rate could be lower or higher.

Monitoring reports do not report whether chainsaw operators have received training in RIL methods or not.

GFC staffs who have been educated at GSA or UG (both BSc forestry and Diploma Forestry) will have received some RIL training by FTCI. Staffs that are employed straight out of high school may not have undergone such training.

Forest rangers and monitoring inspectors need training in assessment of C&I for directional felling. FTCI may have to design such courses. GFC should keep records of training courses in directional felling followed by chainsaw operators (FTCI records could be copied).


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Based on the GFC’s monitoring activities, which also addresses the added concern raised by GFA, the following proposed criteria are recommended by GFC to addresses this indicator:

Criteria Number

Criteria Propose Score*

Application

1 Evidence of directional notches, felling notches. All Fellers

2 Evidence of the use of wedges to force directional felling.

All Fellers

3 Evidence of clearing around stump and of escape routes away from tree base.

All fellers

4 Efforts to achieve a low stump height during felling. All fellers

5 Evidence of skid trail planning, felling direction in relation to the planned skid trails.

Fellers on TSA/WCL

6 Evidence of operator training. Fellers on TSA/WCL

7 Clear felling, absence of split on log. All fellers

8 Very little evidence of waste from bucking activity especially at stump.

All Fellers

9 Extent of physical damage to crown and stems of neighbouring trees especially commercial tree species.

All Fellers

10 Deliberate felling into natural gaps and out of buffer zones.

Fellers ion TSA/WCL

*The level/score and refinement of criteria, is proposed to be done in six months following discussions with the FTCI and the forest sector.

These criteria are currently being assessed as part of the FMD monitoring but were not mainstreamed into the checklist form. The GFC will amend the monitoring checklist to include these.

The GFC’s Field Monitoring Operation involves assessment of the criteria for directional felling as laid out in Section 5.3 of the Code of Practice. However, the Reporting can be further enhanced to allow for objective quantitative reporting against criteria.

Hence, we recommend that the status of this indicator be revised to be “Not clear if requirements met” since there is evidence that the GFC indeed assesses against the criteria but the reporting could be better streamlined.

GFA response to RP’s comments:

The proposed criteria appear appropriate. Audit will verify field compliance based on these criteria.

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Indicator 2.1.10

Trees felled are above the regulatory, or approved, minimum diameter

Relevant section of CoP that outlines specifications, and verifies information on the ground

Assessment




Legal Source - Provisions regarding Girth limits are provided for in Regulation 16. It provides "No tree shall be felled unless its girth measurement at a point 4 feet 3 inches from the ground, or in the case of a buttressed tree at a point immediately above the top of the buttress, is not less than the measurements prescribed in the Third Schedule. Diameter regulations and amendment to schedule already put into action. Last amendment identified as 1989. Section 18 of TSAs refers back to the Regulations. Diameter provided for in TSA clause 18.

System appears appropriate


Based on 6 Environmental Monitoring and Auditing Reports (LMEU) for 2011 that were perused, stump diameter was below 35 cm dbh in case of 3 out of the total 254 stumps that were inspected in these audits.


2 under-size stump occurrences were recorded in 6 monthly monitoring and stump inspection reports. Random selection of Monthly Monitoring and Stump Inspection Reports: TSA 01/09 September 2011, WCL 01/09 June/July 2011, TSA 02/91 Jun 2011, TSA 03/91 August 2011, TSA 03/91 September 2011, TSA 01/00 April-June 2011.

Stump inspections as part of LMEU and monthly routine inspection reports indicated that the diameter of the stumps was below 35 cm in five cases. Since the approved minimum diameter should be assessed at breast height - at a point 4 feet 3 inches (130 cm) from the ground - or in the case of a buttressed tree at a point immediately above the top of the buttress, it is probable that the felling diameter was lower than the measured stump diameter (except in case of heavily buttressed species such as Purpleheart). Therefore, it is probable that the diameter at breast height of the trees with a stump diameter below 35 cm were cut below the approved diameter at breast height of 35 cm.

Action sheets were not attached to the monitoring reports that were inspected during the mission but submitted separately. It is recommended to attach (copies of) such action sheets to the monitoring reports to ensure verifiable evidence at the audit. Audit shall review field compliance.


The GFC, in keeping with SFM requirements, and also in the promotion of RIL practices, and as required by the CoP Section 5.3 (point 13), recommends the felling of trees to be done in such a way to achieves a low stump height. Additionally, in the planning stages of felling for large concessions, pre-harvest inventory and AOP requires for only trees that are of minimum diameter at breast height of 35cm to be identified for selection for the proposed harvesting operation. The pre harvest inventory and AOP are subject to GFC’s assessment, validation (including field checks) and approval/non approval. As such, given that this minimum diameter is an integral part of the planning stage, it allows for only such trees to be subject to harvesting. In so doing, even if trees are cut below the breast height then the fact that the company would have satisfied the requirement at the planning stages, essentially also assures that minimum diameter requirement is being fulfilled at the felling stage as well.

In instances however, that stumps are found below the minimum diameter size, follow action is taken by GFC. E.g. payment of compensation for breach, etc. which can be verified from monitoring reports including the LMEU report (see enclosed a few examples of action sheets which are part of the LMEU report which were verified by the GFA team during the mission). Also, the GFC’s Compounding Database for procedural breaches also provides verifiable evidence of follow up action for this indicator and it is this database and not the inspection reports that have evidence of follow up action.

Given the precursor requirement at the planning stage of minimum diameter which allows for compliance assessment together with the requirements in the Code of

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Practice as it relates to felling, supported by the available Compounding database that records follow up actions, the RP requests that the status of this indicator be revised to be met.

The GFC has conveyed to the GFA that the GFC has an operational system for monitoring of undersize cutting. The fact that the conclusion emanating from the GFA’s report uses the reports of the GFC is testimony to this fact. In the harvesting of millions of hectares at the national scale there is every likelihood that there at least one instance of undersize cutting. For the full audit, the GFC has expressed that a sample design by GFA, agreed level of materiality, level of accuracy and other related monitoring variables will have to be designed in consultation with the GFC and the Reporting Panel.

Indicator 2.1.11

Restricted species should be harvested / exported in accordance with applicable law, guidelines, policy, and regulation

Production Records / Register / Export documents as it relates to these species

Assessment

Requirement met with need for consistent listing of species

Comments pertaining to indicator (wording) What are the specific restricted species -What is meant by restricted - the word used in the regulations, is protected.



The Forest Regulations provided in regulation 17 for protected species, these are identified in the Third Schedule Clauses 19(1) and 19(2) identify species and also refer to the Third Schedule. The Code of Practice speaks to 'keystone species'.

In Code of Practice, the following species are indicated: Bulletwood, Crabwood, Hog plum, Kokoritiballi, Sawari nut, Ubudi.

In SFP and TSA Clauses 19(1) and 19(2), additional species are indicated. In the Forest Regulations only Bulletwood is mentioned as protected species.

GFC needs to amend Code of Practice and/or adjust clauses in SFP and TSA agreements for consistency of restricted species (independent whether these are protected or so-called keystone species).



Policy directive was granted for this indicator and is provided in this submission. Request is made for the revision of this indicator status. Also, the GFC’s Compounding Database provides verifiable evidence of systematic management of breaches in the indicators.

GFA’s response to RP’s comments:

The comment points at inconsistencies in the species listed in the Code of Practice and SFP and TSA Clauses 19(1) and 19(2). It is recommended to ensure consistency in the listing of restricted species in the various documents where these species are listed.

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Indicator 2.1.12

Spacing of felled tees and number of trees cut meet requirements of the CoP or any GFC approved revised version of the CoP

Relevant section of CoP that outline specifications, and verify information on the ground

Assessment

Requirement met with scope to update relevant regulatory documents (CoP)



Legal Source - Section 7 of TSAs require the Grantee to work the area to the satisfaction of the commissioner in accordance with a Forest Management plan. The plan is described in Schedule A of the TSA. Clause E of Schedule A under the heading 'System of Working' provides that the grantee shall "submit within six (6) months, a Forest Management Plan and Annual Operation Plan prepared in accordance with the GFC Code of Practice for Timber Harvesting, as revised from time to time."

Code of Practice 2nd Edition 2002 (CoP) Clause 5.1.3 defines felling proximity of 10m. Proximity rule revised by Policy Directive of July 2011 to 8m following discussion with Forest Products Association.

Number of trees available to be cut is defined by pre-harvest inventory and associated stock map. GFC prepare stock maps for all blocks on GIS.

Monitoring aims to evaluate adherence by operators with proximity rule and number of trees cut.

System appears appropriate to achieve compliance with this indicator.

Written record of policy directive in adjusting the proximity rule to 8 meters was made available following the scoping mission. Minutes of meeting with FPA do not constitute a policy directive.

CoP should be amended to reduce spacing to 8 meters according to stated policy directive.


GFC Monitoring Division carries out inspections of selected blocks, evaluates and reports upon proximity breaches and trees felled (linked to tag allocation). Monitoring reports reviewed identified instances of operator non-compliance with proximity and tree size - these result in action plan requests to the operator and may result in fines. Field staff is expected to follow up on action plan requests.

Summary Data regarding operator audits and non-compliances is summarised on a quarterly and annual basis. However this data is not systematically analysed to identify patterns of trends, and there is not a systematic approach to managing follow up on non-compliances and action plans.

Based on the limited field sample by the IFM team at this scoping stage it is difficult to conclude how effective the monitoring system is in terms of compliance in practice with the indicator.

The system for managing identified non compliances and action requests needs to be more systematic.


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Criterion 2.2 There is compliance by the FMO with applicable national laws, regulations and guidelines relevant to the environment


GFA Assessment

Indicator 2.2.1

The FMO has a valid environmental authorisation for logging (in the source area) and any associated operations that would have been / are applicable at the date of issuance of the concession lease

Information on legal requirements for environmental authorisation

Assessment



System objective evidence The requirements are provided for through the Environmental Protection Act, No, 11 of 1996 as amended, section 11 incorporating the provisions of the Fourth Schedule 4(8). Environmental Authorisation Regulations 2000.

These requirements are implemented by the Environmental Protection Agency (EPA).

Operators with a TSA established prior to 1996 are required to hold an Operational Permit issued by the EPA together with an Environmental Management Plan.

Operators with a TSA issued after 1996 in virgin forest are required to conduct an Environmental and Social Impact Assessment (ESIA) and submit this for approval to the EPA. Once approved the EPA issues an Environmental Permit, which may be accompanied by operational conditions.

GFC has pursued initiatives to respond to client demands. The revealed/observed lack of manpower availability and the lack of adequate decentralised field monitoring capability of partner agencies e.g. EPA, has impacted adversely on GFC's legitimate functions which can rebound on the status of agreements. In the interim (i.e. until the capacity issue is addressed) GFC has applied mechanisms to address such a situation/s, particularly in relation to the issuing of sawmill and sawpit licences. There is scope to improve documentation of recognition and approval by EPA of such interim mechanism.


The responsibility for administration of environmental permits and licences lies with EPA. EPA may have capacity constraints in ensuring full compliance with the Environmental Protection Act.

GFC comment upon and hold copies of some ESIAs (copies seen for SFEP01/2007 and TSA 01/2009).

GFC do not appear to have systems in place to monitor and evaluate which concession holders have valid Operational Permits or Environmental Permits. Copies of permits were not available for inspection at GFC. Consultation with EPA suggested that some TSA holders might not have permits in place.

It appears EPA lack manpower availability and the lack of adequate decentralised field monitoring capability to ensure all operators are in possession of valid Operational and/or Environmental Permits.

GFC appear not to have systems in place to evaluate whether TSA and WLC concession holders comply with this indicator.


The ESIA is only necessary when the concession to be issued is located in virgin forest that has never been subjected to timber harvesting. When concessions are allocated otherwise, an ESIA is not necessary. The fact that the concession was harvested previously implies that inventory information is available, and that the social impacts are not unknown.

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There are a number of licences that require an EPA permit. First there are the ESIA requirements for large concession allocation (that have come in placed post 1996 – after the EPA was established). It should be noted that a TSA (except those issued before for logging - i.e. reallocated TSAs) cannot be granted unless an ESIA is completed and approved by EPA - a process that once completed, notification is sent to GFC advising of this approval by EPA. GFC can provide evidence of such if so requested by the Monitors. Secondly, for large concessions issued prior to 1996, the EPA in collaboration with GFC is currently working on a phased approach for these operations to be permitted using an Environmental management Plan through the EMP permitting system.

For timber processing and retail operation operations, e.g. sawmills and lumberyards, a separate kind of environmental permit is required from EPA.

In practice, all such operations are licensed and approved to operate by the GFC only when an Environmental Permit is issued or when evidence is provided that the process has commenced at the level of the EPA. In such cases, the GFC will issue the license.

It should be made clear that in the case of large concessions, the point agency to hold the technical documents relating to the ESIA is the EPA as mandated by the EPA Act. The communication that is conveyed to the GFC is on whether the EPA is fully satisfied with the EPA’s processes being fulfilled or not.

It is on this basis that the GFC would take further appropriate action.

GFC has systems in place to ascertain which concessionaires have valid permits. However, many concessions were issued prior to the EPA being constituted; when the agreements are revised, it will be a requirement for all to have these valid permits.

Additionally, the RP requests that the Monitors note, and the assessment report duly reflect that, “For environmental authorisations issued, the EPA has a full database of these, and is the main source agency for such information. Further, the RP has advises that it is at the EPA level that this can be verified”.

GFA’s response to RP’s comments:

The RP’s comments do not contradict the information regarding how the system should work as was disclosed during the consultations. The question was whether GFC’s actions are legally assured in the cases where it issues licenses pending or anticipating EPA’s functionally legal obligations. However, the auditors’ observations are empathetic with GFC recognizing the capacity/resource issue faced by EPA in fulfilling its legal mandate.

Indicator 2.2.2

Species exported are not listed in CITES appendices I or II

CITES appendices I and II and Production and Export Records of the FMO

Assessment

Requirement met



The CITES appendices are part of the law of Guyana by virtue of the provisions of the Species Protection Regulations 1999, made under the Environmental Protection Act, No, 11 of 1996 as amended.



The Wildlife Division of the EPA indicate that there are no species presently listed on CITES Appendices I or II.

Implementation appears appropriate

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Indicator 2.2.3

Control of logging on slopes should meet the requirements of the CoP

Relevant section of CoP that outline specifications, and verify information on the ground

Assessment




Section 7 of TSAs requires the Grantee to work the area to the satisfaction of the commissioner in accordance with a Forest Management plan. The plan is described in Schedule A of the TSA. Clause E of Schedule A under the heading 'System of Working' provides that the grantee shall "submit within six (6) months, a Forest Management Plan and Annual Operation Plan prepared in accordance with the GFC Code of Practice for Timber Harvesting, as revised from time to time".

There is currently no system to monitor control of logging on slopes > 40% as prescribed in the CoP Section 2, 4 and Clause 3.2.1.

LMEU’s Monitoring Inspection Field Form for TSAs does not include a section on assessment of logging on slopes in e.g. the Appendix II section on timber harvesting inspection (stump inspection). No mention made of inspection of logging on slopes elsewhere in the reports.

During LMEU and routine monitoring inspections such assessments are reportedly carried out. The current reporting and verification system however does not present any verifiable data that would ascertain the evidence that no trees are felled on slopes steeper than 40%. Reporting and verification system needs to be amended to ascertain that such assessments have indeed been made.


No mention made of control of logging on steep slopes in LMEU Monitoring Inspection Reports or FMD Monthly Monitoring Reports.


Random selection of Monthly Monitoring and Stump Inspection Reports: TSA 01/09 September 2011, WCL 01/09 June/July 2011, TSA 02/91 Jun 2011, TSA 03/91 August 2011, TSA 03/91 September 2011, TSA 01/00 April-June 2011.

No mention made of control of logging on steep slopes in LMEU Monitoring Inspection Reports or FMD Monthly Monitoring Reports.


The RP does not agree with the statement that “no system is in place to monitor control of logging on slopes”. In practice the GFC monitoring officer verified felling on slopes using a clinometer. Evidence is only recorded and reported when trees are felled on slopes steeper than 40%. The RP requests that its comments be inserted in the results outline and attributed to the GFC: Proposed criteria:

Identification if harvesting is done on flat terrain or slope,

If harvesting is done on slope, (with use of clinometers), indicate the gradient of the slope,

Based on occurrence of harvesting above 40%, penalties are instituted for breach.

Reporting done based on criteria proposed by GFC.

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GFA’s response to RP’s comment:

It is recommended that LMEU and routine monitoring reports include actual measurement (reading) of slope % within the inspected stump area with GPS coordinates of the point where the measurement was taken. This would provide verifiable evidence that such an assessment was indeed carried out.

Principle 3 The FMO has paid due fees, royalties and penalties

Criterion 3.1 The payment of fees, royalties, and penalties applicable to the FMO is done to the satisfaction of the relevant authorities


GFA Assessment

Indicator 3.1.1

All royalties and fees are paid up to date or according to an agreed payment schedule

Payment Schedules, Receipts etc. to determine financial standing

Assessment

Requirement met

Comments pertaining to indicator (wording) The words 'due' and 'penalties' are not included in the indicator.



Fees are dealt with in the Ninth Schedule of the Forestry Act Cap 67:01; Royalty Rates based on first Schedule. Schedule last amended 10 of 1991. Royalties calculated the when the removal permit has been produced to the officer, within 24 hours of arrival at destination. Regulation 25.



Statement of indebtedness as at August 31, 2011 was perused. Any breach in payment of the outstanding balance results in an invoice addressed to the delinquent enterprise with a deadline for payment. Failure to honour the deadline can result in withholding of permission or reduction in duration of permit or non-renewal of permit, whichever is applicable.

Payment scheduled provided by GFC. Schedule provided for both TSAs and SFPs and indicate the balance if any outstanding for acreage fees and royalties. In addition, the system used by the GFC to monitor compliance with payments was also provided.

Indicator 3.1.2

All acreage fees are paid up to date or according to an agreed payment schedule


Assessment

Requirements met



Acreage fees are authorised and levied in accordance with the Ninth Schedule of the Forestry Act Cap 67:01. These are set by regulations and are presently in metric. Based on Regulation No.8 of 1996.



Applications set out acreage fees; these are not paid in advance. Statement of Indebtedness as at August 31, 2011 was perused. Any breach in payment of

Payment scheduled provided by GFC. Schedule provided for both TSA’S and SFP’s and indicate the balance if any outstanding for acreage fees and royalties. In addition, the system used by the GFC to monitor compliance with payments was also provided.

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the outstanding balance results in an invoice addressed to the delinquent enterprise with a deadline for payment. Failure to honour the deadline can result in withholding of permission or reduction in duration of permit or non-renewal of permit, whichever is applicable.

Indicator 3.1.3

All relevant licence fees are paid Payment records/Receipts etc. to determine financial standing

Assessment

Requirement met

Comments pertaining to indicator (wording) The word "relevant" is vague to identify the licence fees. Several licence fees are levied, which specific ones are to be covered by this indicator.



The system for payment of licences was explained and indicated that licences are paid as due hence no outstanding balance are recorded. Receipts to verify payments are available.

System appears appropriate.


No specific records were perused during the scoping visit.

Records will be perused during audit.

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B. Indicators for Monitoring of State Forest Permissions (SFPs) Principle 1 The FMO has legal rights to harvest and other parties’ legal tenure rights are respected


GFA Assessment

Indicator 1.1.1

The FMO is in possession of a legally valid concession agreement for the area from which all timber is sourced

Valid Concession Agreement in effect Assessment

Not clear if requirement met for CFOs



SFP's are issued under Section 6 the Forestry Act Cap 67:01 and Regulation number 10. The terms of SFP are for 2 years.

List of CFOs with Summary, Examples of Acknowledgement of Registration signed by Office of Registrar of Friendly Societies.

Generally, for individual private concessionaires with SFPs this is evident.

However, anomalies have been noted with Community Forest Organizations (CFOs). For Community Associations, the association should be registered under the Friendly Societies Act 36:04. SFPs for associations do not indicate the status of the association in the recital of parties. This has implications for the certainty of the status of the parties. The status of the party would have to be determined by a review of the actual contents of the SFP.


It was noted that of the 56 out of 61 CFOs allocated concessions under "registered" are 22 out of 61 organizations, with "registration not started" 15 out of 61 organizations and "registration in process" 24 out of 61 organizations. Thus, if registration is a necessary condition for the issuance/allocation of the concession there may be an issue of legality. Of the five (5) not allocated concessions two kiln-drying associations are designated “N/A” which is somewhat inconsistent noting Nos. 47, 48 and 49 in the data provided.

Valid SFP documentation for three concessionaires was viewed on site.

Notably, seven (7) AVCs, which were said to be contemplating change of status of their timber production to CFOs, are captured under “registration not started”. However, there are eight (8) non-AVCs, which are also captured in that category. “Registration in progress” is pertinent to pre-incorporation contracts and can be considered legal.


“For Community Associations, the association should be registered under the Friendly Societies Act 36:04.” This is not a legal requirement for the GFC and the Forests Act does not require this. It also has no bearing on the legal status of these entities. The SFP Agreement gives legal status and this is being strictly applied.

Further, for all communities, those that are registered, not yet registered or in the process of registering, for each the GFC has the list of members and formal communication to GFC as to the representative authorised to transact business on that community’s behalf. This information is available either at the forest station and/or at the Head Office.

The RP disagrees with the classification that this indicator is ‘Not Clear’ especially given the concurrence of the Monitors that registering under the Friendly society Act is NOT a requirement under the Forest Law and also given that the GFC has a robust administrative programme to ensure that the management of these remain structured and formal. Additionally these efforts should also be viewed as accommodating speedy operation and accommodating the socio economic needs of these communities whilst the administrative process is being started or is being processed.

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The GFC has conveyed that it advises and encourages CBOs to register under an appropriate legislative framework to govern the management and accountability of CBO activities and functioning. It is correct that procedurally some CBOs have registered and some have not as this point in time, but this simply points to the fact that the GFC cannot mandate CBOs to register under any legislative framework. GFC has indicated that it will continue to encourage CBOs to register under an appropriate legislative framework for its functioning and management.

Indicator 1.1.2

If the FMO is working under contract to another concession holder the contractual arrangement is not in contravention of the Forests Act and has been formally approved by GFC

Contract. The GFC should be contacted to provide information on contract.

Assessment

Requirement met

Comments pertaining to indicator (wording) The scope of 'working' in this context should be clearer. Is it intended to cover all acts on a concession, which are done other than by the concession holder? Are the contracts to relate to acts and working amounting to a disposal of interest or related to other activities? Information indicates subletting is prohibited. Use agreements related to machinery are permitted.



Regulation 11 of the Forest Regulations provides a procedure for transfers. Transfers, assignments and other acts relating to the exercise of concession rights require the prior consent of the Commission. Clause 2 of the SFPs provides that the permit is "not transferable without the prior consent in writing of the Commissioner. It may not be assigned or sublet nor may the grantee allow any person to work under it on payment to the Grantee of any consideration whatsoever."

SFPs have to make a formal request to GFC in order to be allowed to have third party contracts. Contracts are approved for a period of two years to lease equipment, which the SFP should operate. However, the GFC verifies and evaluates the request prior to approval.


While there was no list of concessionaires with third party arrangements viz. CFOs. Files Env: 4/61 and 4/66 were perused showing the paper trail. These included mainly letters of authorization and responses by GFC granting "permission". There were no indication of terms and conditions of the contracts.

Some concession holders prepare authorisations to other persons. No actual contract between FMO and “contractor” was perused during scoping mission itself. Pertinent documentation was however submitted by GFC after conclusion of the scoping mission.


“The GFC would like to clarify that in the case of CFO ENV. 4/61 which involves a 2 year agreement, there is in file, the detailed agreement accompanying the GFC’s approval that was signed by all parties and Justice of Peace certified. In the case of CFO ENV. 4/66 this involves a 6 months agreement, and in keeping with GFC’s administrative requirements, a request letter from the CFO was done; a letter from the contractor was done, and this preceded the GFC’s approval which was done following GFC’s assessment of the documentation and terms expressed in both documents from the CFO and the contractor. For clarity, these letters outlined clearly, the

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terms of the agreement. “Given that these evidence are all is available in the files given to the Monitors and scanned and attached for reference in this submission, that all clarity is provided for the revision of this indictor to be met.

The GFC would like to note that given the limited time allocated to feedback on the GFA’s findings at the end of the Mission, it was the understanding that following the GFC’s receipt of the GFA’s report, clarification, questions, etc. can be provided. This was done by the GFC as in the case above.

Criterion 1.2 There is compliance by both the FMO and any contractors with national laws relevant to other parties’ tenure and use rights


GFA Assessment

Indicator 1.2.1

There are no legal titles by indigenous or other persons on GFC approved concessions

Ministry of Amerindian Affairs (MOAA) and GFC for Maps of Neighbouring Communities that may be affected

Assessment

Requirement met



SFPs are granted, "save and except all land legally held". State Lands are regulated by the Guyana Lands and Surveys Commission, by virtue of the powers in the Guyana Lands and Surveys Commission Act No. 15 of 1999. Mining rights under the Mining Act No. 20 of 1989 are managed by the Guyana Geology and Mines Commission by virtue of the Guyana Geology and Mines Commission Act No. 9 of 1979. Indigenous titles are granted under the State Lands Act 62:01 as amended.

GFC's FRMD has adequate maps and mapping facilities. State Forest Permission Document of the Forests Act CAP 67:01. Both GLSC and GFC identified possible mapping issues such as overlaps as well as other issues, which may be identified by stakeholders and during interagency 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. If the complaint is proven valid there is a suspension of the operations, otherwise it continues.

There is no written document indicating how these other uses should be dealt with when they arise. An additional element is the notion of a conversion SFP. The written authority for this instrument was not perused during scoping mission.

For certainty, the procedure and practice described should be reflected in a decision of the Board of the GFC in accordance with its powers under the Guyana Forestry Commission Act No. 2 of 1979.


There were no complaints by neighbouring concessions visited along the Linden - Mabura road. Also SFP permission document Conditions 1 and 4 must be noted. FRAC operational guidelines also noted.

No evidence of such an occurrence. The role and function of the FRAC provide reasonable safeguards.

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Indicator 1.2.2

Legal or traditional uses of the forest are not prevented by the FMO

MOAA, interview Residents of Neighbouring Communities, Guyana Lands and Surveys Commission

Assessment

Requirement met

Comments pertaining to indicator (wording) There appears to be a distinction between traditional use, customary use and rights. Some consistency in language of the indicator would be required for certainty.

It was noted that such legal traditional and customary uses are related but not limited to wildlife, medicinal plants, seeds, craft materials and construction materials for personal and/or communal uses and not for commercial use.



Provision 15 of the SFPs providing for the grantee to abide by guidelines of the Guyana Forestry Commission, may provide a basis for this to be observed.

The Amerindian Act. The Forests Act Cap 67:01 SFP condition 4 may apply. Where such situations exist and can impact on legality, GFC investigates the matter on the ground to ascertain the nature of traditional use prevented and the reasons. In addition, MOAA is informed of the matter. If the SFP holder is found to be culpable, compensation is sought and operations can be suspended. If the action was criminal in nature by either parties the Toshao and/or law enforcement agencies will investigate.

System appears appropriate. Nevertheless, it is recommended to bring SFP provisions in line with provisions in the Amerindian Act.


Visit to Great Falls AVC indicated no such problem. The Toshao also indicated that if such a situation occurs he would meet with the relevant concessionaire to address the matter. No dispute resolution protocol was available.

No evidence of prevention of the traditional and customary user rights of Amerindians as stated in the Amerindian Act.

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Principle 2 The FMO complies with relevant national legislation as it pertains to forest management, and the environment.



GFA Assessment

Indicator 2.1.1

The Annual Allowable Cut is appropriately calculated, approved and based on quota allocation informed by 20m3/ha over 60 years, or otherwise approved quota allocation informed by inventory assessment and land use categorisation

SFP Document that outlines AAC quota Assessment

Requirement met with some suggestions for system improvement



All SFPs are kept in a separate file in the FRMD small-concessions planning office. An SFP is issued under Section 6 of the Forests Act, Cap. 67.01, to occupy and harvest a quota of forest produce specified in the Schedule A of the permission. Schedule provides the true volume (logs) to be harvested for a period less than 12 months, 12 months or 24 months and the converted volume (lumber, shingles, etc.) with approx. 50% recovery of the total volume of logs. The starting year for all SFPs is an even year (e.g.). SFPs that are issued at the beginning of 2012 will have a quota calculated for 24 months, SFPs that are issued at the beginning of an odd year will have a quota calculated for 12 months and SFPs that are issued during the year will have a quota issued for the remaining months until the beginning of an even year.

AAC is calculated as follows:

GFC sets the allowable cut at 20 m3/60 years according to CoP Chapter 2 Section 3. In order to calculate the quota in terms of number of trees 20 m3 is remarkably set equal to 10 felled trees (i.e. 2 m3/tree).

An allowance is made for non-productive areas, assuming that 80% of the area is Productive Forest.

AAC per hectare = 80% x (10÷60) = 0.13 trees/ha or 0.27 m3/ha.

Quota = SFP area x 80% x (10÷60) trees or SFP area x 80% x (20÷60) m3.

SFP areas can be adjusted upon request by the holder, e.g. to reduce the productive forest area, or sometimes two SFPs are merged. The holder submits a request to the CoF, who instructs the DCoF FRMD to verify on the ground. After verification and approval, the quota is adjusted. Modified SFPs will receive a new file number.

System appears to be appropriate with a few remarks:

- Allowable Cut of 20 m3 is converted to 10 trees for SFPs according to the calculation shown by the ACF, while it is set at 3 m3 for calculating the number of tags to be issued. The use of two size standards is confusing and unnecessary.

- A column in the Excel sheet that indicates the different types of SFPs (instead of highlighting) is needed to enable sorting etc.

- A column in the Excel sheet indicating new or modified SFPs needed for same reason.

- Manual calculation and entry of data in Excel may lead to erroneous entries. Calculations can be carried out within Excel or, better, within Access or SQL to improve data integrity and linking with FMD and MIS.

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SFPs on mining lease or agricultural leases have an unlimited quota.

SFP database overview in Excel is available at the small-concessions office of FRMD:

1) SFPs above 10,000 acres in area are highlighted in blue; 2) All conversion SFPs and SFPs above 20,000 acres are highlighted in brown; 3) All Agricultural leases are highlighted in green; 4) All Mining Conversion areas are highlighted in red; 5) All concessions within the previous ALGLAS TSA (SFInc.) are highlighted in orange; 6) All SFPs with an asterisk attached to the name are new SFPs.

The list is updated monthly and forwarded to the MIS.


Quota are calculated by calculator and manually entered in SFP database SFP permits and files perused in small-concession planning office. Requests by SFP holders were observed to increase the quota by changing the size of the SFP through boundary adjustment or otherwise, while authorisation letters for changes to quota were not found in the inspected file.

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 folio’s;


“Any adjustment of concession boundaries/sizes area which will impact on the concession quota are tracked and recorded duly, in the Planning and Forest Information Unit in the form of documents and maps.”


What was observed by the Monitor in implementation is that the relevant SFP folios did not include (copies of) letters authorizing adjustment of concession boundaries and/or area sizes which will impact on the concession quota. The Monitor appreciates that changes are requested, authorized, tracked and recorded duly. However, GFA’s comments are about verifying records as well as the procedures and processes for changes in concession quota based upon the working of the system as is operationally or functionally observable and that is the letter and spirit of the observation by the Monitor for GFC’s consideration.

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Indicator 2.1.2

Tags are properly obtained and a record of their use is kept. All unused tags are appropriately accounted for at the end of the GFC reporting period


Assessment




Refer to indicator 2.1.4 under A. “Indicators for Monitoring of Timber Sales Agreement and Wood Cutting Leases”.





Indicator 2.1.3

Logs and stumps are tagged according to the log-tracking system




System objective evidence The requirement in this regard is provided for in clause 14 of the SFPs mandating the grantee to affix log tags to tree stumps and forest produce.

Log tracking system is described In the GFC Forest Monitoring Division Manual of Procedures (Draft) Section 5.

Tags are allocated per annual quota for each SFP and according to a clear tag issuance procedure (See Indicator 2.1.4).Tagging should be carried out at stump and operators are advised to paint tag number on log and stump in addition. Tags have two parts one attached to stump and one attached to log.

There is ongoing field monitoring of tag use by GFC field staff on range and patrol inspections together with routine sampling by GFC central monitoring division. Monitoring reports evaluate number of tags issued, number of tags used, stumps with GPS co-ordinates, and tag use. b) Any breaches in tag use (e.g. stump with no tag) are reported.

In addition, patrols and checkpoints regularly check logs in transit.



Data on monitoring reports (at Legality and Environmental Monitoring Unit) suggested 63% of SFPs audited in 2010, achieving verification of 29% of tags.

Random selection of small number of monitoring reports reviewed for SFPs DEM34/02, ESS08/09, BCE02/05, DEM04/05, NWD02/03, ESS013/2009,

There may be scope to improve evaluation and/or reconciliation of missing tags identified at concession level.

There is scope to improve analysis and management of corrective actions.

There is scope to improve systematic overview analysis (e.g. identifying patterns, trends, underlying causes) or strategic analysis of data collected.

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BCE 42/85, and DEM039/2008.

Reports taken as a whole indicated of 655 stumps inspected 26 were not tagged (4%).

Missing tags were reported as a deficiency and corrective action recommended by way of formal letter to the concession holder (i.e. there is a corrective action system in place). However, there was no apparent analysis as to why tags were missing, or whether the GFC monitoring officer attempted to reconcile the missing tag numbers with tags used in production and tags unused. (I.e. If a tag number is recorded in production records, it may be an indication that the tag at stump has been lost. By contrast if a tag is missing from stock and there is no production record, it may have been misused - in this instance the misuse would be picked up when the tag number was entered into the MIS database).

There does not appear to be a systematic or strategic analysis of data nor a systematic approach to follow up on corrective actions.

Field evidence SFPs visited (DEM 043/2011, DEM 009/2009, DEM 042/1993, DEM 042/1993, ESS 005/2006, ESS 006/2006, ESS 007/2006) suggested varying techniques used to attach tags to stumps with varying degrees of reliability. (In some cases, missing stump tags may be due to inadequate fixing methods). Stumps seen during the field visit were all tagged.

Some felling occurs in SFPs to assist camp or bridge construction - some SFP holders tag these trees (but record no production) others do not tag these infrastructure logs.

There is scope to improve consistency of tag application to stumps and logs.

There may be scope to improve consistency of policy, recording and application of tags in relation to infrastructure logs.


“The GFC has in place, a system to record and to verify tag usage. This system allows for tags used and tags, unused to be recorded, and tags returned. The GFC conducts reconciliation of used and unused tags (missing and returned tags) periodically as needed (at time of the operator’s request for additional tags and at the end of the reporting year). The system in place currently, therefore allows for, at the national level, and at the operation level, the used and unused tags. In cases where tags are not found on stumps (lost or not initially placed) during the GFC monitoring inspections, an investigation is conducted and a decision is taken as necessary. The GFC’s Compounding Database and Tag Management and Issuance database in FMD provides sources of evidence for the above references. “Given the above, the RP is proposing that the sentences as below be reworded:

“However, there was no apparent analysis as to why tags were missing” and “There does not appear to be a systematic or strategic....”

Further, the statement in the Implementation Objective Evidence that “If a tag is recorded...it may be misused” is not accurate and should be reworded. In actual fact, if such a situation occurs, it is also a possibility that the tag could be misplaced.

The GFC has conveyed that reconciliation that is conducted “as needed” is for the very purpose as the Monitor has alluded to: that of overall analysis on a monthly basis and importantly upon instances of request for additional tags, additional permits, as well as renewal of concession at end of lease period. In this way, the GFC indicated, a good starting point is well established to conduct more in depth analyses of tag usage which is planned. The GFC emphasized that a missing tags, misplaced tags, etc are investigated through a formal process of which the monitoring report is just the first step. After the monitoring report identifies a discrepancy, then this triggers a host

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of other steps which includes the investigation of these. The GFC has indicated that strengthening follow up on identified gaps is an area for greater emphasis in the coming period.

Indicator 2.1.4

Transportation of logs and lumber is accompanied by relevant GFC approved documents. E.g., removal permits, transhipment permit, custody form, clearance pass, bill of sale and receipts


Assessment

Requirement met

Comments pertaining to indicator (wording) The specificity of this indicator can be somewhat limiting.




In the case of CFOs, there are three requested signatories viz. officers of the organizations to validate documents, any one of whom can sign the relevant documents.




Seen at GFC's Soesdyke Forest Station on Friday, September 30, 2011. Additionally, records were examined on site for two SFPs, which had transported logs or lumber. There was one case where the GFC officer did not affix his/her signature.

Indicator 2.1.5

All logs and lumber in transit, and at point of export, that originate from the State Forest Estate, can be traced back to source stump


Assessment



System objective evidence Logs. There is a requirement that all logs are tagged. Procedure described in GFC Forest Monitoring Division Manual of Procedures (FMDMP) Section 5. Logs can be linked to stump and forest block of origin and there is regular ongoing and sample monitoring of tag use at SFP level GPS co-ordinates are used to locate stump position. Monitoring plans aim to review performance at least 25% of SFP s annually.

Lumber. One clause in GFC FMDMP notes that tags should be placed on some part of lumber to be transported although details of how this should be

It is recommended that the adoption of the procedure and practice described in the GFC Forest Monitoring Division Manual of Procedures (Draft) be done, and should be reflected in a decision of the Board of the GFC in accordance with its powers under the Guyana Forestry Commission Act No. 2 of 1979.

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done are not given.

Tagging is supplemented by documentation e.g. Production Register, Sawmill Register, Summary production reports - these cross reference to tag number.

Logs and lumber is spot checked en route from origin to final destination (see indicator 2.1.6).

At point of export, Produce is accompanied by export documentation (see Criterion 2.1) which references log tag numbers.


Logs. Logs from SFPs appeared to be well monitored and regulated. Non-compliances noted in relation to tag use results in corrective actions and/or financial penalty Records of production seen appeared complete. Documentation and monitoring of documents appeared to be well managed. GFC monitoring systems effectively identified tagging non-compliances in transit together with fines to encourage improved compliance.

Lumber. The point at which logs are converted into multiple pieces (logs) and/or lumber is a critical control point in the overall chain of custody system. Tags are transferred from logs to lumber, and records of production are kept. However, there is no guarantee that all converted produce is transported in a single shipment, e.g. more than one product may be produced for more than one buyer - one tag cannot accompany more than one load. In addition, conversion is a point in the production process at which theoretically unauthorised logs could enter the system for onward shipment covered by a tag. A tag on lumber is a useful indicator that lumber is from an authorised source but on its own is not a reliable guarantee.

Reliable claims regarding Chain of custody for lumber therefore need to be backed up by production records of input and output together with evaluation of conversion factors and reconciliation of volumes.

At SFPs visited (DEM 043/2011, DEM 009/2010, DEM 042/1993, ESS 006/2006, ESS 007/2006) Production registers were being kept although to varying degrees of consistency (influenced by operation type e.g. Chainsaw lumber, portable mill, log sales; and operator capacity / attitude). Some operators had a clear batch system in which all production was recorded in detail, and all pieces produced had log tag number applied with lumber crayon. Others recorded production for each individual log (e.g. chainsaw lumber) only; others appeared to operate with batches of logs.

GFC monitoring staffs do investigate anomalies when detected and discuss production with producers.

For Logs sourced from SFPs, tagging and documentation in transit and at point of export provide a reliable basis for compliance with this indicator.

For Lumber sourced from SFPs, tagging and documentation in transit and at point of export provide an indication that material can be traced back to source stump.

Record keeping and production returns from SFPs appear variable in quality.

Method of production recording (e.g. batches) on SFPs appears variable.

Strategic analysis of production data, monitoring of conversion rates and reconciliation of volumes on SFPs could be more systematic.


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Data from production records reviewed at GFC Georgetown suggested wide variation in conversion rates. On first inspection, some appeared high. Some variation in conversion rates was detected and the system for reconciling conversion rates should be strengthened although data was available and some initial analysis had been carried out.

Indicator 2.1.6

All relevant licences are held and up-to-date Actual Licences and Permits with relevant dates

Assessment

Requirement met (after revision of indicator)

Comments pertaining to indicator (wording) What is meant by relevant licences are these linked to indicator 2.1.4.The licences are that of the FMO? This should be stated in the indicator.




At the time of the scoping mission it was not clear which licenses were being considered. The GFC has indicated that this information is available for perusal and verification on request.


Three sawmill licenses and two lumberyard licences were checked during field visit.

Sawmill and Lumberyard Licenses were verified in the field.

Real audit shall review compliance.

Principle 3 The FMO has paid due fees, duties, royalties and penalties

Criterion 3.1 The payment of fees, royalties, and penalties applicable to the FMO is done to the satisfaction of the relevant authorities


GFA Assessment

Indicator 3.1.1



Assessment

Requirement met




Fees are dealt with in the Ninth Schedule of the Forestry Act Cap 67:01; Royalty Rates based on first Schedule. Schedule last amended 10 of 1991. Royalties calculated when the removal permit has been produced to the officer, within 24 hours of arrival at destination. Regulation 25.



Data provided by GFC captioned “SFP Companies Statement of

According to GFC no SFP has royalties outstanding.

Payment scheduled provided by GFC. Schedule provided for both TSA’S and SFP’s and

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Indebtedness” showing Royalty outstanding as at 31.08.2011” show no dollar figures. It identifies 445 SFPs.

indicate the balance if any outstanding for acreage fees and royalties. In addition, the system used by the GFC to monitor compliance with payments was also provided.

Indicator 3.1.2

All acreage fees are paid up to date or according to an agreed payment schedule


Assessment

Requirement met



Acreage fees are authorised and levied in accordance with the Ninth Schedule of the Forestry Act Cap 67:01. These are set by regulations and are presently in metric. Based on Regulation No.8 of 1996.



Statement of indebtedness as at August 31, 2011 was perused. Any breach in payment of the outstanding balance results in an invoice addressed to the delinquent enterprise with a deadline for payment. Failure to honour the deadline can result in withholding of permission or reduction in duration of permit or non-renewal of permit, whichever is applicable.

Payment scheduled provided by GFC. Schedule provided for both TSA’S and SFP’s and indicate the balance if any outstanding for acreage fees and royalties. In addition, the system used by the GFC to monitor compliance with payments was also provided.

Indicator 3.1.3

All relevant licence fees are paid Payment records/Receipts etc. to determine financial standing

Assessment


Comments pertaining to indicator (wording) The word "relevant" is vague to identify the licence fees. Several licence fees are levied, unclear which specific ones are to be covered by this indicator.



The system for payment of licences was explained and indicated that licences are paid as due hence no outstanding balance are recorded. Receipts to verify payments are available.



No specific records were perused during the scoping visit.

Records will be perused during audit.

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C. Indicators for Monitoring of Amerindian Villages if they opt into the LCDS

At the time of the scoping mission no opt in mechanism was in place yet



GFA Assessment

Indicator 1.1.1

The FMO is in possession of a legally valid title for the area from which all timber is sourced

Amerindian Lands Title Document and check with Village Captain, MOAA and GFC

Assessment

Requirement met



Amerindian Act. Generally, for AVCs this is evident.

This was an exploratory visit to gauge awareness of LCDS as regards to AVCs pertaining to "opt in readiness". N.B. the preconditions for such a process is still engaging the MSSC.


Visited Great Falls AVC and consulted with Toshao and community representatives.

Indicator 1.1.2

If the Amerindian Land is worked under contract to another entity the contractual arrangement is not in contravention of the Forests Act, has been formally approved by GFC and has been agreed by the Village representatives with free, prior and informed consent. The MOAA should also be made aware of the contract

Actual Contract. The GFC should be contacted to solicit their views on the Actual Contract

Assessment

No opt in - Not yet applicable



Several AVCs have such arrangements and are required to submit copies of contracts to GFC.

A formal request regarding the third party arrangement is made to GFC, which evaluates the request upon verifying the terms and conditions of the agreement. Once approved the agreement is valid for two years.

It was noted that free, prior and informed consent (FPIC) should be a principle, which should be given clear and objective indicators.

It should be clarified whether there are prerequisite requirements to be submitted to GFC to allow for monitoring contracted forest activities on Amerindian titled Lands by GFC based on the Amerindian Act No. 6 of 2006 Section 55(4).


Three copies of signed authorizations in lieu of contracts by the Toshaos were perused. Three copies of letters of authorization and inclusive of seeking permission from GFC were perused. There were no clear terms and conditions of the agreement.

Apparently, sometimes, no contractual arrangement is made and only a letter of authorisation is issued in lieu. Absence of a legal agreement may put either the AVC or the Contractor in jeopardy.

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Visited Great Falls AVC and there was evidence of such arrangement for machinery use.


It is recommended for FPIC as currently prevails, to be a cross cutting principle and not a specific indicator as the former allow for greater strength of FPIC across several areas. Also FPIC will likely be a prerequisite for opting into the LCDS and as such, will be handled at this initial level.”


The Monitor recommends that FPIC must be concretized or operationalized and understood as being achieved (or not) through clear indicators or measures understood by those from whom FPIC is being sought and should be an integral aspect of the Opt In Mechanism as this is the basis for Amerindian Titled areas to be included in the IFM framework.

Criterion 1.2 There is compliance by both the FMO and any contractors with national laws relevant to other parties’ tenure and use rights


GFA Assessment

Indicator 1.2.1

Legal title to log source area by other persons, complies with legally required procedures as set out in relevant legislations

MOAA and GFC for Maps of Neighbouring Communities. Interview Captains and Village Councils of Neighbouring Communities.

Assessment




There may be mapping issues such as overlaps as well as other issues, which may be identified by stakeholders and during interagency 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. If the complaint is proven valid, there is a suspension of the operations until the matter is resolved.


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Principle 2 The FMO complies with relevant national legislation as it pertains to forest management and the environment.

Criterion 2.1

There is compliance by the FMO with applicable national laws, regulations and guidelines relevant to forest management


GFA Assessment

Indicator 2.1.1

The Annual Allowable Cut is appropriately calculated, approved and based on quota allocation informed by 20m3/ha over 60 years, or otherwise approved quota allocation informed by inventory assessment and land use categorisation

SFP Document that outlines AAC quota Assessment




Opt in mechanism not in place as yet.


Indicator 2.1.2

Tags are properly obtained and a record of their use is kept. All unused tags are appropriately accounted for at the end of the GFC reporting period


Assessment




At the time of this scoping mission, no Amerindian Communities had chosen to opt in.

Refer to indicator 2.1.4 under A. “Indicators for Monitoring of Timber Sales Agreement and Wood Cutting Leases”. Note - whilst there has been no opt in to date (Oct 2011), GFC systems are in place to address these requirements. The GFC has developed databases for the management of the Log Tracking System. Log Tag allocation is a controlled process facilitated by databases in FMD (excel) and MIS (SQL). Information in relation to tags issuance and usages is recorded in the databases. Tags are issued in batches to Amerindian Reservations and Private Property holders. At the end of the reporting period all tags issued are accounted for (production register for used tags and unused tags are return to the GFC).





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Indicator 2.1.3

Logs and stumps are tagged according the log-tracking system





At the time of this scoping mission, the Opt In mechanism has not been finalised.

Log tags are issued to Amerindian communities according to Section 5 of GFC Forest Monitoring Division manual of Procedures (Draft).

For all Amerindian communities there is a requirement that their produce carry log tags once it leaves their titled land and enters the transport and distribution system monitored by GFC and as described under Sections A and B above.

Currently although there is no mechanism yet for opting in, log tags are commonly used to identify stumps as well as logs leaving titled land. There is no requirement to tag all stumps (e.g. trees felled for village use).

In the event that Amerindian Communities opt in GFC will need to develop systems to monitor Tag use on titled lands.



At Great Falls, tags were seen to be in use on stumps and logs. Some stumps did not carry tags as not all produce leaves the titled land. All logs prepared for removal from titled land seen carried tags.

Efforts are being made just to have effective systems. Obvious need for greater support and training viz. attention to relevant details and the secure placing of tags on stumps.

Indicator 2.1.4



Assessment

Requirement met



Transport and documentation requirements for produce arising from Amerindian titled lands are the same as for other forest concessions (as described in A and B above) at the point where produce leaves titled land.

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Records at field station checkpoint inspected and indicated ongoing implementation of document verification.

Checkpoint inspection witnessed included document verification.

Patrol checks witnessed included document verification of logs in transit.

All documents seen were in compliance with documentation requirements.

Examples of produce arising from Amerindian titled land in transit on the public transport network were seen together with GFC monitoring checks.

Efforts are being made just to have effective systems. Obvious need for greater support and training viz. attention to relevant details.

Private Property holder removal declaration permit and production register records trees that were felled. The production register is used to reconcile the location of trees that were felled using a log tracking tag. Additionally, the removal declaration permit and production register records (log tag number and log measurement) are used in planned field monitoring and monitoring audits by the GFC’s monitoring officers to verify that logs and lumber can be traced back to the source stump and stumps are tagged according to the GFC log tracking system.

Note - whilst there has been no “opt in” to date (Oct 2011) GFC systems in place already address requirements on public transport network and measures in place appear to comply with the requirements of the indicator. In practice all logs and lumber for commercial use must be able to transport with a removal document and can be traced back to the source stump using the GFC log tracking tags.

In the event that Amerindian Communities opt in GFC will need to develop systems to monitor tag use on titled lands.

Also, it should be clarified whether there are prerequisite requirements to be submitted to GFC to allow for monitoring contracted forest activities on Amerindian titled Land by GFC based on the Amerindian Act No. 6 of 2006 Section 55(4).

Indicator 2.1.5

All logs and lumber in transit, and at point of export, that originate from Amerindian Villages that opt into the LCDS, can be traced back to source stump


Assessment





In the event that opt in takes place the same observations made under Section B 2.1.7 would apply.



Efforts are being made just to have effective systems. Obvious need for greater support and training viz. attention to relevant details and the secure placing of tags on stumps.

In the event that Amerindian Communities opt in GFC will need to develop systems to monitor Tag use on titled lands.

Also, it should be clarified whether there are prerequisite requirements to be submitted to GFC to allow for monitoring contracted forest activities on Amerindian titled Land by GFC based on the Amerindian Act No. 6 of 2006 Section 55(4).

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Indicator 2.1.6

All relevant permits and licences are held and up-to-date Actual Licences and Permits with relevant dates

Assessment





Principle 3 The FMO has paid due licenses fees, and penalties

Criterion 3.1 The payment of fees and penalties applicable to the FMO is done to the satisfaction of the relevant authorities


GFA Assessment

Indicator 3.1.1

All relevant license fees are paid as applicable to the satisfaction of relevant authorities

Payment records/Receipts etc. to determine financial standing

Assessment






D. Indicators for Monitoring of Agricultural and Mining Property Owners

Observation: once logs or lumber are being removed from a mining or agricultural lease, GFC will issue an SFP for the area; hence this stakeholder group should be referred to as (Indicators for Monitoring) SFPs issued on Agricultural and Mining Leases



GFA Assessment

Indicator 1.1.1

The FMO is in possession of a legally valid concession agreement or title for the area from which all timber is sourced

Valid Concession Agreement in effect. Extraction of forest produce should be in keeping with the protocols set by the Land Use Committee or other applicable Guidelines

Assessment

Requirement met with some scope for system improvement



The relevant agency (GGMC or GLSC) provides the evidence of the appropriate lease before GFC approves an SFP. Currently, there are

Valid concession agreements in effect. It must be noted that verification of this indicator is subject to the effectiveness and efficiency of inter-institutional/agency arrangements viz. GLSC and GGMC.

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apparently 21 SFP mining leases (total area: 85,048 ha) and 24 SFP agricultural leases (total area: 12,609 ha) and one uncategorised SFP with unlimited quota (1,171 ha).

State Lands are regulated by the Guyana Lands and Surveys Commission, by virtue of the powers in the Guyana Lands and Surveys Commission Act No. 15 of 1999. Mining rights under the Mining Act No. 20 of 1989 are managed by the Guyana Geology and Mines Commission by virtue of the Guyana Geology and Mines Commission Act No. 9 of 1979.

Based on information provided by GGMC there is need for clarification as to whether the following: large-scale, medium-scale or small-scale mining licence, claims, mining permits or prospecting licence is being referred to. There is scope for refining the proportion of an SFP on a Mining Lease where the unlimited quota would apply. According to GGMC deforestation is very limited in case of prospecting licenses and small-scale mining licenses and permits.

Improvement of SFP Database System needed to distinguish SFPs on Mining or Agricultural Lease, since these SFPs have unlimited quota.

Implementation objective evidence N.B. there are some inconsistencies in the identification of the mining leases in the data set provided. Not all SFPs with unlimited quota that are not on Agricultural Leases are indentified as Mining Lease with the code “ml” in the data set. One SFP with code “ml” has a purple colour code. Other Mining Leases are apparently identified with red colour code.

Principle 2 The FMO complies with relevant national legislation as it pertains to forest management and the environment.



GFA Assessment

Indicator 2.1.1



Assessment

Requirement met



SFP requirements under Section B above apply. See observations under Section B Indicator 2.1.4


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Indicator 2.1.2

All logs and lumber in transit, and at point of export, that originate from Agricultural leases or mining property, can be traced back to mining property or agriculture lease area


Assessment




SFP requirements under Section B above apply. See observations under Section B Indicator 2.1.5.

See observations under Section B Indicator 2.1.5.


Indicator 2.1.3

All relevant permits and licences are held and up-to-date Actual Licences and Permits with relevant dates

Assessment


Comments pertaining to indicator (wording) The word "relevant" is vague to identify the licences.




Since it was not clear which licenses are being considered, no records were perused.

Implementation objective evidence Audit shall review additional field compliance.

PRINCIPLE 3 The FMO has paid due licenses fees and royalties

Criterion 3.1 The payment of fees, royalties, duties and penalties applicable to the FMO is done to the satisfaction of the relevant authorities


GFA Assessment

Indicator 3.1.1

All relevant licence fees are paid as applicable to the satisfaction of the relevant authorities

Payment records/Receipts etc. to determine financial standing

Assessment



The word "relevant" is vague to identify the licence fees. Several licence fees are levied, unclear which specific ones are to be covered by this indicator.


System objective evidence According to the GFC those “specific issued SFPs are not allocated quotas, since the area(s) are for a different land use purpose i.e. either agriculture or mining.” (See doc.

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“Issuance of Agricultural and Mining State Forest Permissions”).


The data provided in two documents by GFC “Agricultural Leases SFP Companies Statement of Indebtedness showing Acreage Fees outstanding as at 31.08.2011” and “Mining Lease SFP Companies Statement of Indebtedness showing Acreage Fees outstanding as at 31.08.2011” show that no fees are outstanding. It shows 24 ALs and 1 ML.

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E. Indicators for Processing and Export Stages

Principle 1 The Operator has in place an effective system for materials receipts and storage that allows for assessment of legality

Criterion 1.1 The Operator can verify legality of origin of all forest produce entering facility


GFA Assessment

Indicator 1.1.1

Materials are accompanied by appropriate documentation, demonstrating legally verified source and compliance with GFC procedures

Removal Permit, Transhipment Permit, Custody Form, Clearance Pass, Bill of Sale, Receipts, Sawmill Register, Timber Dealers Register

Assessment


Comments pertaining to indicator (wording) The meaning of “Operator” in this context should be clarified.



Timber Dealers are required by Regulation 29 of the Forest Regulations made under the Forest Act Cap 67:01 to maintain certain books. They shall record “the time of purchase, each purchase of timber produced in Guyana, the species, measurements and quantity of such timber together with the name and address of the seller, the names and addresses of the persons from whom such timber was received, and the numbers of any permits under which such timber was transported.” (Regulation 29(1).)

Regulation 30 permits a holder of a sawmill licence to carry on a business of purchasing timber for resale.

The particulars indicate operators are Sawmill operators and Timber Dealers.


Indicator 1.1.2

Materials receipts are recorded on a form that contains supplier information, quantity of delivery, species, and date of delivery, permit or other documentation number

Sawmill Register, Timber Dealers Register Assessment

Requirement met



All sawmills and lumberyards are required to register with and be licensed by GFC, by virtue of the provisions of Regulations 26 and 27 of the Forest Regulations under the Forest Act Cap 67:01. All licencesed sawmills and lumber yards are issued with and required to keep a Production register (sawmills) or Lumber Yard Register (lumber yards).Operators are required to submit monthly returns- these are used as a basis for royalty calculation where applicable.

These registers include the requirement to record material receipts by volume,


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species, product type and supplier.

GFC staff monitors sites to ensure compliance with record keeping requirements and require corrective action/issue penalties for non-compliance.

GFC collate data for production on a monthly basis.


Production registers were inspected in the field (2x mobile sawmill; 1x Chainsaw lumber; 1x log trader; 1x lumberyard). Most appeared complete and up to date although there was variation in consistency and one was not fully up to date. Interview with operators indicated regular GFC monitoring; this was confirmed by entries in registers by GFC monitoring officers. One operator noted penalty for late submission of register (1 day late). Removal permit number and/or receipt numbers were seen on registers inspected. Tags sampled at local lumberyard in Georgetown could be traced back to frost area of origin (TSA 02/85).

There is scope to improve the consistency of data being recorded and submitted to GFC

Indicator 1.1.3

All materials at facility are differentiable by status: verified and un-verified produce

Physical checks of produce, Sawmill Register, Timber Dealers Register

Assessment

Requirement met



There is s requirement that all logs carry GFC tags and that all lumber should be physically identifiable by way of tags and GFC inspection hammer marks. All material held at any location should be verified. There is a system in place for ongoing monitoring of verified status based upon the tag and hammer mark system supported by input records and/or movement documents. This monitoring result in identification of missing or irregular tagging and recording of non-compliances, seizure and/or royalty/penalty payments.



Sawmills (3) and lumberyard visited demonstrated that recording by operators was ongoing and status (tagging) was being consistently used. Field stations visited (Linden, Mabura) demonstrated ongoing monitoring in progress and records being kept and reported on to GFC Georgetown. Road patrols witnessed accurately identified non-compliances with tagging procedures and corrective actions/penalties applied. All materials seen at facilities visited were identified and accompanied by appropriate records suggesting that they were from verified sources.

Implementation appears appropriate

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Criterion 1.2 There exist accurate records on a monthly basis on input and output of forest produce


GFA Assessment

Indicator 1.2.1

There is a monthly record of total quantity (volume) of raw materials inputs, by species and output by species, to allow for reconciliation of these amounts, to determine whether recovery percent is within expected norms

Sawmill Returns, Lumberyard returns Assessment

Requirement NOT met



Sawmill operators and lumberyard operators are required to submit monthly returns of input and output by species and product. Data is input to the central Management Information System (MIS) at GFC Georgetown. This system can provide output that allows reconciliation of inputs and outputs at the level of each operator together with recovery rates. GFC have estimates of normal recovery rates for different types of operation.



Data on inputs and outputs was available and reviewed for all mobile sawmill and chainsaw lumber operations on SFPs. These showed wide variation in recovery rates. Mobile mills (2) and Chainsaw lumber operation (1) were visited. Recovery rates at one mill appeared high although possibly achievable as it was producing small dimension product and re-sawing was being practised.

It was not clear how GFC evaluate the production data to identify anomalies and/or assess recovery rates.

Note that as per indicators A 2.1.7 and B 2.1.5 - conversion to lumber a critical control point in relation to reliability of tagging as an indicator of material origin - this would place emphasis upon the need to use input and output data to highlight potential anomalies and evaluate recovery rates.

Reconciliation of inputs and outputs should be improved.

The identification of potential anomalies relating to recovery percent needs to be improved.

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Principle 2 The Operator has in place sales and shipping documentation that allows for traceability of legal origin of Logs and Lumber for exports

Criterion 2.1 There is compliance with declaration of export sales and shipping information as required by the GFC


GFA Assessment

Indicator 2.1.1

Information is declared for logs and lumber to be exported on: name and address of buyer, date of export, description of produce, quantity, sales invoice/receipt/permit number

Export Invoice, Timber Marketing Certificate, Application for Export, Export Certificate

Assessment

Requirement met (as far as legal responsibility of GFC is concerned)



There is a GFC standard operating procedure for the export of forest produce.

This includes verification that the operator holds an appropriate licence (e.g. Sawmill or Timber Dealer). There is a requirement that independent timber grading be carried out (GFC). The procedure requires standard metrication guidelines be followed.

Documentation required for export include:

- Application for export of forest produce,

- Timber Marketing Certificate (TMC),

- Timber Export Certificate (TEC),

- Commercial invoice,

- C72 Customs Form.

GFC require 2 signatures on C72 to release a consignment to Customs.

Packing lists for logs for export include GFC tag number.

Details of export consignments are input on to the GFC MIS database.


File copies of export documents were sampled; those inspected were complete.

Records of export consignments due for loading on the date of audit were reviewed - 10 consignments totalling 1275 cu.m. These were verified as having been entered onto the MIS database.

Site visit to wharf demonstrated multiple storage and loading locations used including direct loading of logs from domestic river barges to international

The GFC legal mandate extends to the point of approval of the export application. It is then the legal mandate of the Guyana Revenue Authority to follow on with other requirement.

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carrier.

It was also noted that once GFC sign over a consignment to customs there may be a time lag before it is shipped.


“GFC’s legal mandate for export of forest produce extends to the point of verification of forest produce for export and approving the Customs documents. From thereafter, it is the legal responsibility of the Guyana Revenue Authority. GFC is not legally allowed to subsume this function. This does not only apply to forest produce but to any other kind of produce being exported.

In addition, it must be noted that the GFC has full-time presence at the port of export of forest produce which allows for further verification of legality of produce reaching to the port. This is done to supplement the Guyana Revenue Authority systems of controls”.

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3.3 Proposed rewording of indicators by the Reporting Panel

The following section of the report provides proposed rewording of a number of criteria and indicators on the basis of the scoping mission and discussions between the GFC and the IFM team. In most cases GFA agrees with the proposed rewording. In a limited number of cases GFA does not recommend the rewording, because the rewording relaxes the requirements to the extent that certain observed anomalies are brought within the limits of the definition of legality for IFM, while there does not appear to be an immediate need to do this.

Table 3 shows the principles, criteria and indicators for which rewording is proposed by the Reporting Panel as well as GFA’s response to the proposed text.

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Table 3 Proposed rewording of indicators

A. Indicators for Monitoring of Timber Sales Agreement and Wood Cutting Leases

IFM criterion or indicator GFC proposed rewording GFA response

Indicator 1.1.2

If the FMO is working under contract to another concession holder the contractual arrangement are not in contravention of the Forests Act and has been formally approved by GFC.

If the FMO is working (includes concession activities relating to harvesting, transporting, processing and export, of forest produce) under contract to another concession holder and this has been formally approved by GFC, the contractual arrangements are not in contravention of the Forests Act and has been formally approved by GFC.

With the clarification and adjustment of wording in the indicator, the comment “The scope of 'working' in this context should be clearer” can be removed.

Rewording satisfactory and recommended.

Criterion 1.2

There is compliance by both the FMO and any contractors with national laws relevant to other parties’ tenure and use rights.

There is compliance by both the FMO and any party contracted by the FMO, with national laws relevant to other parties’ tenure and use rights


Principle 2

The FMO complies with relevant national legislation as it pertains to forest management and the environment.

The FMO complies with relevant national legislation as it pertains to forest management and the environment and any special condition as the Commission institutes in keeping with the GFC’s mandate.

Rewording not recommended, because this will institutionalise that TSAs could be allowed to continue working without an FMP under certain circumstances. This gives off a wrong signal.

Indicator 2.1.1

Approved management plan exists

Approved management plan exists or special condition prevailing as instituted by the Commission in keeping with the GFC’s mandate.

Rewording not recommended. This weakens GFC’s position vis-à-vis non-compliant operators who seek to continue to work while avoiding submission of FMPs.

Indicator 2.1.2

Approved 1-yr operational plan, covering the source areas for logs, is implemented based on approved forest management plan.

Approved 1-yr operational plan, covering the source areas for logs, is implemented based on approved forest management plan, or special condition prevailing as instituted by the Commission in keeping with the GFC’s mandate.

Rewording not recommended, but apparently required if indicator 2.1.1 is not complied with, since there are TSAs operating with an AOP but without FMP.

Indicator 2.1.3

The Annual Allowable Cut is appropriately calculated, approved and not surpassed on the basis of 100% inventory of commercial species, to a maximum of 20 m³ per hectare over a 60 year cycle, or a prorated AAC based on the 20 m3/ha over 60 year calculation, or at an otherwise agreed level, adequately supported by management level inventory, and in keeping with SFM principles.

The Annual Allowable Cut is appropriately calculated, approved and not surpassed on the basis of 100% inventory of commercial species, to a maximum of 20 m³ per hectare over a 60 year cycle, or a prorated AAC based on the 20 m3/ha over 60 year calculation, or AAC may be higher or lower in cases where such level is adequately supported by management level inventory applying growth and yield model, and complies with the requirements of the Code of Practice for Harvesting.


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Indicator 2.1.6

Transportation of logs and lumber is accompanied by relevant GFC approved documents. E.g. removal permits transhipment permit, custody form, clearance pass, bill of sale and receipts.

Transportation of logs and lumber is accompanied by relevant GFC approved documents.


Indicator 2.1.7

All logs and lumber in transit, and at point of export, that originate from the State Forest Estate, can be traced back to source stump.

Logs and batches of lumber in transit, and at point of export that originate from the State Forest Estate can be traced back to source stump.


Indicator 2.1.8

All relevant licences are held and up-to-date.

Sawmill and Timber Dealers licences are held and up-to-date.

With revised text of indicator, requirement met.

Indicator 2.1.9

Directional felling is practised to minimise damage to forest.

Directional felling is practiced as required by the GFC criteria checklist.


Indicator 2.1.11

Restricted species should be harvested / exported in accordance with applicable law, guidelines, policy, and regulation.

Restricted, protected, and key stone species, should be harvested and exported in accordance with applicable law, guidelines, policy, and regulation, including and forest concession agreements, and GFC approval.


Principle 3

The FMO has paid due fees, royalties and penalties.

The FMO has paid required fees, and royalties. Rewording satisfactory and recommended.

Criterion 3.1

The payment of fees, royalties, and penalties applicable to the FMO is done to the satisfaction of the relevant authorities.

The payment of fees and royalties, applicable to the FMO is done to the satisfaction of the relevant authorities.


Indicator 3.1.1

All royalties and fees are paid up to date or according to an agreed payment schedule.

Royalties and fees are paid up to date or according to an agreed payment schedule.


Indicator 3.1.2

All acreage fees are paid up to date or according to an agreed payment schedule.

Acreage fees are paid up to date or according to an agreed payment schedule.


Indicator 3.1.3

All relevant licence fees are paid.

Sawmills and Timber Dealers licence fees are paid. Rewording satisfactory and recommended.

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B. Indicators for Monitoring of State Forest Permissions (SFPs)


Indicator 1.1.2

If the FMO is working under contract to another concession holder the contractual arrangement is not in contravention of the Forests Act and has been formally approved by GFC.

If the FMO is working (includes concession activities relating to harvesting, transporting, processing and export, of forest produce) under contract to another concession holder and this has been formally approved by GFC, the contractual arrangements are not in contravention of the Forests Act and has been formally approved by GFC.

With the clarification and adjustment of wording in the indicator, the comment “The scope of 'working' in this context should be clearer” can be removed.


Criterion 1.2

There is compliance by both the FMO and any contractors with national laws relevant to other parties’ tenure and use rights.

There is compliance by both the FMO and any party contracted by the FMO, with national laws relevant to other parties’ tenure and use rights.


Indicator 1.2.2

Legal or traditional uses of the forest are not prevented by the FMO.

Legal or traditional uses of the forest and customary rights are not prevented by the FMO.


Indicator 2.1.4

Transportation of logs and lumber is accompanied by relevant GFC approved documents. E.g., removal permits, transhipment permit, custody form, clearance pass, bill of sale and receipts.



Indicator 2.1.5

All logs and lumber in transit, and at point of export, that originate from the State Forest Estate, can be traced back to source stump.

Logs and batches of lumber in transit, and at point of export that originate from the State Forest Estate can be traced back to source stump.


Indicator 2.1.6

All relevant licences are held and up-to-date.



Principle 3

The FMO has paid due fees, duties, royalties and penalties.



Criterion 3.1




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Indicator 3.1.1


Royalties and fees are paid up to date or according to an agreed payment schedule.


Indicator 3.1.2

All acreage fees are paid up to date or according to an agreed payment schedule.

Acreage fees are paid up to date or according to an agreed payment schedule.


Indicator 3.1.3



C. Indicators for Monitoring of Amerindian Villages if they Opt In to the LCDS


Indicator 2.1.4

Transportation of logs and lumber is accompanied by relevant GFC approved documents. E.g., removal permits, transhipment permit, custody form, clearance pass, bill of sale and receipts.



Indicator 2.1.5

All logs and lumber in transit, and at point of export, that originate from Amerindian Villages that opt into the LCDS, can be traced back to source stump.

Logs and batches of lumber and at point of export that originate from Amerindian Villages that opt into the LCDS can be traced back to source stump.


Indicator 2.1.6

All relevant licences are held and up-to-date



Principle 3

The FMO has paid due fees, duties, royalties and penalties.



Criterion 3.1




Indicator 3.1.1



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D. Indicators for Monitoring of Agricultural and Mining Property Owners


Indicator 2.1.1

Transportation of logs and lumber is accompanied by relevant GFC approved documents. E.g., removal permits, transhipment permit, custody form, clearance pass, bill of sale and receipt



Indicator 2.1.2

All logs and lumber in transit, and at point of export, that originate from Agricultural leases or mining property, can be traced back to mining property or agriculture lease.

Logs and batches of lumber in transit, and at point of export, that originate from Agricultural leases or mining property, can be traced back to mining property or agriculture lease area.


Indicator 2.1.3

All relevant licences are held and up-to-date



Criterion 3.1

The payment of fees, royalties, duties and penalties applicable to the FMO is done to the satisfaction of the relevant authorities



Indicator 3.1.3

All relevant licence fees are paid


E. Indicators for Processing and Export Stages


Criterion 1.1

The Operator can verify legality of origin of all forest produce entering facility.

The Sawmill or Timber Dealer License Holder can verify legality of origin of logs and first point of sale of primary lumber entering facility.


Criterion 1.2

There exist accurate records on a monthly basis on input and output of forest produce.

There exist accurate records on a monthly basis on input of logs and batches of lumber and the output of batches of lumber.


Indicator 1.2.1

There is a monthly record of total quantity (volume) of raw materials inputs, by species and output by species, to allow for reconciliation of these amounts, to determine whether recovery percent is within expected norms.

There is a monthly record of total quantity (volume) of logs and lumber input and output by species, to allow for reconciliation of these amounts, to determine whether recovery percent is within expected norms.


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4 REAL AUDIT

4.1 Areas of focus for real audit

The following issues have been identified as potentially significant for the main assessment:

General

o Summary of GFC Board decisions where these relate to IFM matters,

o GFC’s policy, procedure and associated manuals of operational procedures to cover all key processes in order to support consistency of application of systems.

Legal logging rights to the forest

o Documentation of the procedure and practice concerning annual extension of expired TSAs instead of their renewal and concerning variation in life of TSAs,

o Updated list of valid, active and inactive concessions showing AOP and FMP updates, and ensuring consistencies in FMPs and AOPs,

o Registration of Community Based Organisations - CBO would not be recognised as a separate legal person from those forming the organisation. Obligations of an unformed society may fall on the signatories of the SFP.

Compliance with national laws relevant to other parties’ tenure and use rights

o Inter-agency Collaboration and sharing of data on land boundaries, allocations and other relevant information,

o Updated relevant Agency databases:

- Mining Leases Database (Focal Agency: GGMC),

- Agriculture Leases Database (Focal Agency: GLSC),

- Amerindian Titles Lands Database (Focal Agency: GLSC),

- Forest Concession Allocation (Focal Agency: GFC).

Compliance with national laws, regulations and guidelines relevant to forest management (FRMD)

o Documentation of AAC and AAA computation and consistent application of protocol,

o TSA database updated and consistency in summary sheets (approved blocks versus AAC),

o Formal approval documentation of special conditions as it relates to FMO's operations, such as for re-entry, additional block allocation and waiving of requirement for submission of FMPs by valid TSAs and WCLs and document and data control systems (paper trails),

o Presentation of AAA and AAC at concession level in AOPs and FMPs and consistently applied,

o Submission of FMPs by valid TSAs and WCLs in keeping with conditions outlined by the GFC,

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o Formal approval documentation relative to adjustment to SFP areas and quota’s and improve document and data control systems (paper trails),

o SFP database identifiable by Stakeholder Type [quota based, unlimited quota – mining lease (ml) and agricultural lease (al) and status of issuance (new, renewed, merged)],

o SFPs Holder with Formal Registration, the name of the entity revised to duly reflect this,

o SFP Quota Database and monthly updates documented,

o Manual of Procedures for the Forest Resource Management Division.

Compliance with national laws, regulations and guidelines relevant to forest management (FMD)

o Verifiable criteria and indicators to assess evidence of directional felling,

o Forest Monitoring Forms and Reporting Format to detail Monitoring Assessment as it relates to Directional Felling,

o Training of GFC Monitoring Staff in assessment of Directional Felling,

o Document procedure and practice to assess undersize felling in production registers and stump inspection reports and systematic management of identified non-compliances and action requests,

o Consistent definition and documentation of restricted species (protected and keystone species) in Code of Practice and Clauses 19(1) and 19(2) in TSA and SFP agreements,

o Formal approval documentation of reduction of spacing between felled trees to 8 meters and Code of Practice updated accordingly,

o Finalisation and formal approval of FMD Manual of Procedures,

o SQL Database of FMD tag management that will include the management of tags for all uses and systematic cross-referencing of the FMD tag issuance and management database with the production database (MIS),

o Documentation of procedure and criteria to issue a limited percentage of tags for the approved block MAC/SFP quota,

o Clear statistical design for sampling of tags during stump inspections and systematic application,

o Strategic analysis and systematic monitoring of conversion rates and reconciliation of volumes on SFPs and TSAs,

o Strategic, systematic analysis and management of corrective actions,

o Documentation consistent policy, recording and application of tags in relation to infrastructure logs,

o Quality and consistency of monitoring reports.

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Compliance with national laws, regulations and guidelines relevant to the environment

o Status update table on ESIA and Environmental Permit submission for forestry operations (ESIA for Harvesting Operations and Environmental Permits for Sawmills and Lumberyards),

o MoU between GFC and EPA as it relates to Environmental Authorisation and Permits for Forestry Operations,

o Forest Monitoring Forms and Reporting Format to detail Monitoring Assessment as it relates to felling on slopes steeper than 40%,

o Training of GFC Monitoring Staff in assessment of felling on slopes steeper than 40%.

Verification of legality of origin of all forest produces entering processing facilities

o Sawmill Register and Sawmill Returns Forms and Reporting Format,

o Submission by sawmill of GFC required monthly Sawmill Register and Sawmill Returns.

4.2 Approach to be followed at real audit

An assessment will be carried out against all IFM criteria and indicators related to the production of such randomly selected final produce.

In other words, based on a random shipment of logs or a batch of lumber,

firstly an assessment will be carried out against the indicators of processing and export stages (sales and shipping documentation that allows for traceability of legal origin of Logs and Lumber for exports and system for materials receipts and storage that allows for assessment of legality;

secondly an assessment will be carried out against the compliance by the FMO - who has harvested the said forest produce - with the payment of acreage, license and other fees and royalties (relevant to the type of stakeholder) related to the shipment of logs or batch of lumber;

thirdly an assessment will be carried against all indicators (relevant to the type of stakeholder) pertaining to compliance by the FMO - who has harvested the said forest produce - with national laws, regulations and guidelines relevant to the environment;

fourthly, .an assessment will be carried out against all indicators (relevant to the type of stakeholder) pertaining to compliance by the FMO with national laws, regulations and guidelines relevant to forest management;

fifthly an assessment will be done against all indicators (relevant to the type of stakeholder) pertaining to compliance by the FMO - who has harvested the said forest produce - with national laws, regulations and guidelines relevant to other parties tenure and use rights;

Finally an assessment will be done against all indicators (relevant to the type of stakeholder) pertaining to the FMO’s - who has harvested the said forest produce - legal logging rights to the forest.

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Two TSA operation will be sampled; one TSA that exports logs and one TSA that produces lumber for the domestic and/or export market. Documents that will be verified are TSA agreement itself, FMP, AOP, Production Registers, Removal Permits, Transhipment Permits, Trip sheets, Sawmill registers, Lumberyard registers, batch processing systems, relevant routine and LMEU monitoring reports, relevant field station and mobile patrol records, Timber Marketing Certificate, Timber Export Certificate, Commercial invoice, C72 Customs Form, royalty, acreage fee and other license fees payments.

Besides the TSAs one SFP will be drawn at random and a random cluster of SFPs will be sampled near this SFP. At least one SFP should produce chainsaw lumber while at least one other one should have a (stationary) portable sawmill. The same documents as with the TSAs will be inspected once they apply to the situation. Otherwise documents of similar nature that apply instead will be inspected.

GFC monitoring systems will be evaluated where these are encountered.

In addition, all focus areas mentioned in the section above will be inspected as far as these have not already been considered during the chain of custody exercise.

Finally, a stakeholder meeting will be organised where stakeholders will be invited to comment on monitoring systems and implementation relevant to the IFM criteria and indicators.

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5 WORK BREAKDOWN STRUCTURE

Table 4 Timeline for implementation of corrective actions by GFC

Activity 2011 2012

4th Qrt

1st Qrt

2nd Qrt

3rd Qrt

General

Finalise Board Decisions Summary relevant to IFM aspects X

Finalise and formally approve FMD Manual of Procedures X

Develop Manual of Operations FRMD X X

Develop Manual of Operations related to Production and other databases (MIS) X X

A) Indicators for Monitoring of Timber Sales Agreement and Wood Cutting Leases & B) Indicators for Monitoring of State Forest Permissions (SFPs) including SFPs overlaying Agricultural and Mining Leases (D)

Principle 1 Legal rights to harvest and other parties’ legal tenure rights are

respected

Criterion 1.1 Legal logging rights to the forest.

1. TSAs: Documents and policy directive supporting annual extension of expired TSAs instead of their renewal and concerning variation in life of TSAs.

X X

2. TSAs: Update list of valid, active and inactive concessions showing AOP and FMP updates, and ensuring consistencies in FMPs and AOPs.

X X X

3. SFPs: Inform Community Based Organisations of potential consequences of ongoing registration for individual CBO members who are not registered.

X X X

Criterion 1.2 Compliance with national laws relevant to other parties’ tenure and

use rights.

4. TSAs & SFPs: Strengthen inter-agency Collaboration and sharing of data on land boundaries, allocations and other relevant information.

X X X

5. SFPs: Request updated information from relevant Agency databases (mining leases, agricultural leases, Amerindian titled Lands) and share relevant field data.

X X X

Principle 2 Compliance with legislation relevant to forest management and the

environment.

Criterion 2.1 Compliance with national laws, regulations and guidelines relevant to

forest management.

6. TSAs and SFPs: Document AAC and AAA computation properly and integrate protocols into a consolidated document and ensure consistent application of protocol.

X

7. TSAs: Document formal approval in all cases for re-entry and additional block allocation and waiving of FMP requirement Large Concession Planning Unit Excel summary sheets need to distinguish between “new” and “re-entry” blocks.

X X

8. TSAs: Actively follow up on submission of Forest Management Plans by valid, active TSAs and WCLs.

X X X X

9. TSAs: Ensure presentation of AAA and AAC at concession level in AOPs and FMPs and taking account of boundary refinement, titling of Amerindian areas, etc.

X X X

10. TSAs: Update TSA database and ensure consistency in summary sheets (approved blocks versus AAC).

X X

11. TSAs: Develop verifiable criteria and indicators to assess evidence of directional felling.

X

12. TSAs: Revise Forest Monitoring Forms and Reporting Format to detail X X

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Activity 2011 2012

4th Qrt

1st Qrt

2nd Qrt

3rd Qrt

Monitoring Assessment as it relates to Directional Felling.

13. Train FMD field staff in assessment of Directional Felling. X X X X

14. TSAs & SFPs: Strengthen procedure and practice to assess undersize felling in production registers and stump inspection reports and systematic management of identified non-compliances and action requests.

X X

15. TSAs & SFPs: Define and document restricted species (protected and keystone species) consistently in Code of Practice and Clauses 19(1) and 19(2) in TSA and SFP agreements.

X X

16. TSAs: Document formal approval of reduction of spacing between felled trees to 8 meters and update Code of Practice accordingly.

X

17. TSAs & SFPs: Develop SQL Database of FMD tag management that will include the management of tags for all uses.

X X X

18. TSAs & SFPs: Develop clear statistical design for sampling of tags during stump inspections.

X X X

19. TSAs & SFPs: Develop and document consistent policy, recording and application of tags in relation to infrastructure logs.

X X X

20. TSAs & SFPs: Improve the quality and consistency of monitoring reports. X X

21. TSAs & SFPs: Strategic, systematic analysis and management of corrective actions routine monitoring and LMEU monitoring.

X X

22. TSAs & SFPs: Document procedure and criteria for issuing a limited percentage of tags for the approved block MAC/SFP quota.

X X X

23. TSAs & SFPs: Carry out strategic analysis and systematically monitor conversion rates and reconciliation of volumes in MIS.

X X

24. SFPs: Provide formal approval documentation relative to adjustment to SFP areas and quotas’s and improve document and data control systems.

X

25. SFPs: Render SFP database identifiable by Stakeholder Type [quota based, unlimited quota – mining lease (ml) and agricultural lease (al) and status of issuance (new, renewed and merged)].

X

26. SFPs: Improve data validation in SFP Quota Database and document monthly updates.

X

Criterion 2.2 Compliance with national laws, regulations and guidelines relevant to

the environment.

27. Develop MoU between GFC and EPA as it relates to Environmental Authorisation and Permits for Forestry Operations.

X X X X

28. Maintain status update table on ESIA and Environmental Permit submission for forestry operations (ESIA for Harvesting Operations and Environmental Permits for Sawmills and Lumberyards).

X X

29. Revise Forest Monitoring Forms and Reporting Format to detail Monitoring Assessment as it relates to felling on slopes steeper than 40%.

X

30. Train GFC Monitoring Staff in assessment of felling on slopes steeper than 40%.

X X X X

E) Indicators for Processing and Export Stages

Principle 1 Effective system for materials for assessment of legality.

Criterion 1.1 Verification of legality of origin of all forest produce entering facility.

31. Finalise updating of Sawmill Register and Sawmill Returns Forms and Reporting Format.

X

32. Actively follow up on submission by sawmill of GFC required monthly Sawmill Register and Sawmill Returns.

X X

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Activity 2011 2012

4th Qrt

1st Qrt

2nd Qrt

3rd Qrt

Criterion 1.2 Accurate records on input and output of forest produce.

33. Improve the identification of potential anomalies relating to recovery percent. X X X

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6 APPENDICES

6.1 List of participants focus group interviews and other meetings

26 September - Introductory meeting with GFC staff 26 September: - NRDDB 28 September: - Office of Climate Change - Amerindian NGOs (IPC, GOIP, TAAMOG) and MOAA - Private Sector (FPA, GMSA, PSC) 29 September - Hamekaran Basdeo: SFP DEM 043/2011 - Safiran and Royston Mohamed: SFP DEM 009/2010 - Ramesh Singh: SFP DEM 042/1993 30 September - Toshao and AVC of Great Falls Amerindian Community - Dwayne Klass, Forest Manager, Sustainable Forest Inc. (SFP ESS 05/2006,

SFP ESS 06/2006 & SFP ESS 07/2006) 31 September - GFC staff Warde, Tularam, Whyte - DTL sawmill manager 6 October - Government Agencies (GRA, EPA, GL&SC, GFC) 6 October - International NGOs (CI-Guyana, WAB, WWF-Guianas, Iwokrama) 7 October - Reporting Panel (EPA, FPDMC, FTCI, GGMC, IPC, NTC) 12 October - EPA - GGMC 13 October - Amerindian NGOs (APA, NADF) - UG (VC office and Forestry Dept.) and GSA - GL&SC - Civil Society Individual Experts

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Table 5 List of participants focus group interviews, individual interviews and

meetings

Name Organization / Agency Portfolio

Alselmo, Lawrence APA Representative

George, Laura APA Representative

Bernhard, Curtis CI Guyana Technical Manager

Tan, B.E. DTL Sawmill Manager

Davi Singh, Geeta EPA Director, Environmental Management Division

Persaud, Tajvarti EPA Senior Environmental Officer

Ramdass, Dr. Indarjit EPA Executive Director

Redmond, Tashana EPA Senior Environmental Officer

Chand, Mohindra FPA / Barama Company Ltd. Jr. Vice President

Manbodh, Reggie FPA Exec. Member

Persaud, Avinash FPA / Toolsie Persaud Ltd Director

Ramotar, Leo FPA / A. Mazaharally & Sons Ltd.

Director

Sukhraj, Luvindra FPA / Toolsie Persaud Ltd General Manager

Vieira, D. for Anthony Yung

FPA / Demerara Timbers Ltd.

Marketing manager

Singh, Rajnarine FPDMC Executive Chairman

Boyan, Howard FTCI Forestry Trainer

Atkinson, Romayne GFC Ass. Commissioner, FRMD

Bholanath, Pradeepa GFC Head, Planning and Development Division

Bipcharran, Dhanraj GFC Head, Human Resources and Administration Division

Bremner, Quacy GFC Ass. Commissioner, FMD

Buchoon, Chayon GFC Tag Management and Issuance Officer

Coggins, Quacy GFC Central Store Clerk

Correia, Roxanne GFC Compounding Database Management Officer

David, Kenny GFC Ass. Commissioner, FMD

Dewnath, Nasheta GFC Programme Coordinator

Goberdhan, Edward GFC Head of Finance Division

Khan, Tasreef GFC Deputy Commissioner, FMD

Lewis, Rawle GFC Ass. Commissioner, FRMD

Lorrimer, Gordon GFC Forest Ranger 1 (Officer in charge) – Linden Forest Station

MacFarlane, Donette GFC Forest Ranger 2 – Linden Forest Station

Nero, Luann GFC Legality Monitoring Officer, FMD

Persaud, Haimwant GFC Ass. Commissioner, FRMD

Singh, Jagdesh GFC Deputy Commissioner, FRMD

Singh, James GFC Commissioner of Forests

Toney, Junior GFC Ass. Commissioner, FRMD

Tularam, Kavindra GFC Legality Monitoring Officer, FMD

Warde, Alandia GFC Monitoring Inspector (Officer in charge), Mabura Forest Station

Whyte, Junior GFC Forest Ranger 2, Mabura Forest Station

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Allen, Wendel GGMC Environmental Manger (ag)

Bobb, Derrick GGMC Mines Manager

Gibbs, Arthur GGMC Audit Manager

Gossai, Mr. GGMC Deputy Mines Manager

Livan, Karen GGMC Commissioner (ag)

Persaud, Kampta GGMC Geological Science manager

Persaud, Mohan GGMC Chief Mines Manager

Singh, Donald GGMC GIS Officer

Monize, Enrique GLSC Land Allocation Manager

Nasir, Naseem GLSC Manager, Land Information Management

Mendes, Andrew GMSA Chairman Wood Subsector

Klautky, Colin GOIP (outgoing) PRO

Henry, Coronell GRA Manager

Allicock, James Great Falls Community Forest ranger

Allicock, Orin Great Falls Community Community member

Barclay, Scottie Great Falls Community Community member

Burnett, Lloyd Great Falls Community Community member

Caleb, Orlando Great Falls Community Community member

Couchman, Brenda Great Falls Community Community member

Couchman, Carla Great Falls Community Community member

Couchman, Clifford Great Falls Community Community member

Couchman, Harold Great Falls Community Toshao

Couchman, Lorna Great Falls Community Community member

Couchman, Michael Great Falls Community Community member

Couchman, Ronald Great Falls Community Community member

Daniels, Carl Great Falls Community Community member

Daniels, Franklin Great Falls Community Community member

Daniels, Godfrey Great Falls Community Community member

Harry, Eunice Great Falls Community Community member

Nathan, Eva Great Falls Community Community member

Nathan, Lindsay Great Falls Community Forest ranger

Nathan, Vanessa Great Falls Community Community member

Peters, Deyone Great Falls Community Community member

Scarter, Elfreda Great Falls Community Community member

Talbot, David Great Falls Community Community member

Williams, A. Great Falls Community Community member

Williams, Francis Great Falls Community Community member

Wilson, S. Great Falls Community Community member

Withney, Dimeon Great Falls Community Community member

Pereira, Shemika GSA Representative

Dow, Jocelyn Individual Expert – Civil Society

Radznik, Vanda Individual Expert – Civil Society

Singh, Maj.-Gen. Joe Individual Expert – Civil Society

James, David IPC Representative

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Gobin, Dane Iwokrama CEO

Rodney, Ken Iwokrama Forest Manager

Lagou, Hymawattie Min. of Labour, Human Services and Social Security, WAB

Administrator

Austin, Sharon Ministry of AA Project coordination of project management

The Hon Sukhai, Pauline, MP

Ministry of AA Minister

Simon, Ashton NADF President

Simon, Rommel NADF Youth Forum Coordinator

Pearson, Yvonne NTC Chairperson

Nokta, Shyam Office of Climate Change Head

Dookhoo, Ramesh PSC Chairman

Marslow, Ivor NRDDB CEO

Williams, Michael NRDDB Toshao Annai

Mohamed, Royston SFP DEM 009/2010 Manager

Mohamed, Safiran SFP DEM 009/2010 SFP Holder

Singh, Ramesh SFP DEM 042/1993 SFP Holder

Basdeo, Hamekaran SFP DEM 043/2011 SFP Holder

Klass, Dwayne Sustainable Forest Inc. Forest Manager

Persaud, Peter TAAMOG President

Thom, Charles UBFAPA Kwakwani Chairman

Lewis, Lawrence UG, Faculty of Agriculture and Forestry

Dean

Fraser, Dr. Ror UG, Representative of the Vice Chancellor

Visiting Professor

John, Samantha Ultra Woods Enterprise Marketing Representative

Williams, Patrick WWF-Guianas Country Manager

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6.2 Assessment team

Assessor’s name

Peter van der Hout Assessor’s role Team leader / Forestry Expert

Qualifications Independent Forestry Consultant. Worked in Guyana with Guyana Forestry Commission (GFC), Tropenbos / Utrecht University and the Forestry Training Centre Inc. From 1989 to 1991 as an advisor in forest inventory with the GFC. From 1992 to 2001 with the Tropenbos-Guyana programme conducting research on the impact of selective logging and the design of a reduced impact logging system for Guyana. In 2002 wrote the Code of Practice for Timber Harvesting for the GFC. From 2002 to 2004 project director of an ITTO-project to provide capacity building in reduced impact logging in Guyana; instituted and managed the Forestry Training Centre Inc. until November 2004.

Carried out assignments in Belize, Cameroon, Gabon, Suriname and the Netherlands since 2005. Coordinated an ITTO pre-project to improve strategies and assess training needs to achieve sustainable forest management in Suriname and developed a strategic action plan to implement the national forest policy.

Successfully guided a timber company in Suriname in the process of FSC certification, and conducted several training courses in reduced impact logging, forest management planning and inventory data processing.

Assignments related to capacity building for sustainable forest management were carried out in Gabon, Cameroon and Belize. For the governments of Belize and Suriname a Code of Practice for Timber Harvesting was produced.

Peter van der Hout offers substantial experience and specialized knowledge in:

Impact assessment of logging operations,

Reduced impact logging techniques,

Excellent knowledge of codes of conduct, forest regulations and forest management planning requirements,

Outstanding project management capacities.

Assessor’s name

Kevin Jones Assessor’s role Forestry Expert / Auditor

Qualifications Programme manager of the Woodmark FSC programme - development and management of an international network of staff, partners and auditors. 8 million ha forest certified globally with 1200+ FSC clients.

Experienced FSC Forest Auditor with global experience leading teams carrying out complex and challenging forest assessment projects. Examples include state forests in Croatia (2 mio ha), Romania (1 mio ha), Ireland (400,000 ha), Indonesia; large commercial companies in South Africa, Chile; private owners; community based organisations Kenya, Tanzania, Zambia.

FSC certification body representative on FSC Accreditation Advisory Committee.

Experienced facilitator of standards development processes and development of innovative approaches to audit, verification and contribution to FSC policy development.

E.g., development and field testing of FSC SLIMF standards, forest standard development UK, Ireland, Australia.

Training and capacity building work in relation to forest evaluation and audit; examples include World Bank projects in Armenia and Belarus; WWF capacity building projects in Morocco, Lebanon, Algeria; Fauna and Flora International projects in Mozambique and Tanzania.

Facilitation of stakeholder input to standards development and evaluation of forestry projects.

Familiarity with forest management context in Guyana – three audits of Iwokrama including stakeholder consultation with competent authorities, civil society and Amerindian representatives and communities.

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Assessor’s name

Teni Housty Assessor’s role Attorney-at-Law / Legal Advisor

Qualifications Attorney-at-Law, Mediator and Legal Consultant, with over 13 years experience in the practice of law in Guyana. Several areas of expertise including environmental law and related areas.

Member of the Project Advisory Committee - The Chainsaw Milling Project, Guyana. Project title “Developing Alternatives for illegal chainsaw lumbering through multi-stakeholder dialogue in Ghana and Guyana”.

Assessor’s name

Michael E. Scott Assessor’s role Social Scientist / Auditor

Qualifications Lecturer and former Dean, Faculty of Social Sciences, member of the University Council, Finance and General Purposes Committees among other committees of the University of Guyana. He is also the current Chairman of the Board of Trustees of the Caribbean Nazarene College in Trinidad and Tobago. As a Social Scientist, his career spans the worlds of academia, public policy and institutional management.

He has been an active contributor to sociological and public policy issues in Guyana and the Caribbean since 1996. He has also authored and co-authored several publications, and advisory reports for international development institutions.

He has also served as a social aspects auditor for the Forest Stewardship Council’s certification of local forest concessions and has also conducted social impact assessments for infrastructural and mining projects in Guyana as well as training of EPA staff. Thus, he also has knowledge of the natural resources sector in the country.

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6.3 Field trip itinerary

Friday – September 30

05:00 – 09:00 Travel from Georgetown to Concession (Hamekaran Basdeo: SFP DEM 043/2011).

09:00– 11:00 Check the system and operation at the concession.

11:00 – 13:00 Lunch and Travel to Safiran Mohamed’s Concession (SFP DEM 009/2010) & Ramesh Singh: (SFP DEM 042/1993).

13:00 – 15:00 Check the system and operation at the concession (Safiran Mohamed: SFP DEM 009/2010).

15:00 – 17:00 Check the system and operation at the concession (Ramesh Singh: SFP DEM 042/1993).

17:00 – 18:30 Travel to Mabura End of Day.

Saturday - October 01

06:30 – 07:30 Breakfast.

07:30 – 08:00 Depart for Great Falls Amerindian Village.

08:00 – 09:30 Meeting with Great Falls Community at Water Front.

09:30 – 11:00 Visit forest operation (Great Falls).

11:00 – 12:30 Travel to Mabura and Have lunch.

12:30 – 13:30 Depart Mabura for Sustainable Forest Inc.(SFP ESS 005/2006, SFP ESS 006/2006 & SFP ESS 007/2006).

14:00 – 16:00 Review Sustainable Forest Inc. Operation and system.

16:00 – 18:00 Return to Mabura, Close of Day.

Sunday – October 02

07:00 – 12:00 Visit and Inspect Block 48, West-Aikawanna compartment, harvested in DTL concession TSA 2/91 to observe forest harvest, management and monitoring procedures.

12:00 – 15:00 Visit Log yard and inspect logs, at DTL Central Compound at Mabura Tour of Sawmilling Complex at DTL, visit lumberyard.

15:00 – 16:30 Inspection of GFC’s Record at GFC Mabura Forest Station. Lunch

16:30 – 23:00 Travel to Georgetown Inspections (4) of Forest Produce in Transit along the Linden Mabura Road Inspect operations at GFC Linden 24 hr Station.

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Figure 1: Field trip itinerary: A) Hamekaran Basdeo, B) Safiran Mohamed, C) Ramesh

Singh, D) Great Falls, E) Sustainable Forest Inc., F) West-Aikawanna block

48, G) DTL Sawmill and lumberyard