At last! Norwegian government responds to the Open Letter outlining eight problems with Norway’s REDD support to Guyana

On 10 June 2011, the Norwegian government responded to the Open Letter sent on 24 March 2011. While the Open Letter raised eight problems with Guyana’s Low Carbon Development Strategy, the vast majority of the discussion generated by the letter focussed on the signatories to the letter rather than the problems they were raising.

To its credit, the Norwegian government does respond to each of the eight problems originally raised in the Open Letter, although whether the signatories to the Open Letter will be satisfied with this response remains to be seen. [UPDATE – 24 June 2011: Janette Bulkan wrote to Ambassador Hans Brattskar, director of Norway’s International Climate and Forestry Initiative on 21 June 2011. Her letter is posted below.] The Norwegian government’s letter is posted in full below and can be downloaded here (pdf file 2.3 MB).

REDD-Monitor looks forward to further discussion about these issues.

Just to add a little to the debate, one of the aspects of Guyana that I’ve not yet fully understood is that the rate of deforestation is so low in Guyana, despite the presence of several large-scale logging operations in the country. As the website Global Timber points out,

the quantity of timber being exported from Guyana has risen strongly since the signing of the MoU between Guyana and Norway (November 2009), particularly as logs whose export is officially discouraged. Under that MoU, penalties will be triggered if timber production annually exceeds the average for 2003-2008[p20] and if the percentage of timber production which is illegal exceeds 15%[p22] (the Illegal Timber content of Guyana’s timber exports to India and China is likely greatly to exceed 15%).

Further evidence that Guayana is not serious about reducing deforestation or forest degardation derives both from the number of logging concessions being granted – which has increased – and the nature of the enterprises which have been allocated the new concessions.

There is much more information on Global Timber’s website about the logging companies operating in Guyana – it’s worth taking a look.

Royal Ministry of the Environment

Your ref:
Our ref: 201101925-
Date: 10.06.2011

Dear all,

Thank you for your letter of May 20 this year with reference to your letter of March 24 and Minister Solheim’s reply to that dated May 10. In your last letter you request a more detailed reply to the eight points you made in your open letter of March 24.

The Government of Guyana and the Guyanese people are in charge of the development of their country. This includes the implementation of the Guyana Low Carbon Development Strategy and the Reduced Emissions from Deforestation and Forest Degradation (REDD+) agenda. Norway has entered into a partnership with Guyana to support its efforts to maintain a low rate of deforestation and forest degradation and improve forest governance. In the process we hope to contribute to the creation of a global model for such partnerships.

The partnership is very much work in progress. It is not perfect, but we are breaking new ground and learning and adapting as we go. We will continue to improve the partnership over time.

On that note, allow us to address the eight key points in your letter of March 24:

1. Delays in preparation of projects
The first transfer of funds to the GRIF was made according to the agreement with the World Bank and was disbursed for the fund to start operating. As of now, no funds have been disbursed from the GRIF. You are referring to “allegations in the independent press of corruption and malfeasance”. Without substantiation, such claims cannot easily be refuted. However, to understand how GRIF works, we encourage you to read the relevant documentation being publicly available on the LCDS website under FRIF. Funds from the GRIF are only disbursed on approval by the Steering Committee, and they are channelled through the Partner Entities. The timing of disbursements into the GRIF does not change this. Getting the modalities and modus operandi of the GRIF sufficiently established and thus getting projects approved by the GRIF Steering Committee, has taken longer than expected. This is a reflection of getting a new system to work, including with respect to the application of fiduciary, environmental and social safeguards. As described in our revised Joint Concept Note, this is an issue we are taking seriously. Also, we are aware that six projects have been prepared by the Government of Guyana and are currently being reviewed by the respective Partner Entities.

2. Deforestation appears to have increased, not decreased
Norway entered into a partnership with Guyana to create a model that could be used for High Forest Cover Low Deforestation countries. The objective is to avoid leakages that would lead to deforestation pressures moving to countries with currently low deforestation, like Guyana, when current high deforesters start to reduce their rates.

The intention is to maintain a low level of deforestation. By any means of comparison, the deforestation rate in Guyana remains extremely low. At deforestation rates as low as those observed in Guyana, even very small deforestation events will cause significant percentual changes in the deforestation rate. The results report indicates an increase from the 2000-09 mean of 0.03% to 0.056%. This can be interpreted either as an 87% increase, or more positively, as an upward variation smaller than 0.3 per thousand points. As to climate change effects, the latter perspective would be the more relevant one. It should also be noted that the 2009-2010 number is an annual number, while the 2000-2009 number is an average. It is possible, indeed it is highly probable, that within that period there were signicant annual deviations, meaning last years numbers are highly likely not as large a deviation – even in percentage terms – as you make them out to be.

That said, both Guyana and Norway are intent on quickly disincentivizing any systematic upward trend in Guyana’s deforestation rates. Based on the revised numbers – which were generated as an intrinsic element of the Partnership – we have therefore put in place an incentive structure for that purpose. This incentive structure is publicly available in our revised Joint Concept Note (enclosed), and implies payments start to fall rapidly at 0.056 per cent deforestation, and cease completely at 0.1 per cent. by any measure, this is exceptionally ambitious.

Regarding the Pöyry report, it was subject to an open period for comments (2 weeks). The comments received are reflected and commented upon in the DNV report. If you, despite this, have substantive and verifiable information that challenges the findings on a signifcant scale, we would welcome such information for the next round of verification.

To further strengthen transparency and credibility of forest management practices and authorities in Guyana, we have agreed on the establishment of Independent Forest Monitoring (IFM) in the country. An open, competitive tender process to procure the services of a credible party to fill this role has just been completed. When the IFM becomes operational in the near future, this will also be an important recipient of any information you may possess regarding suspected irregularities in the Guyanese forestry sector.

3. Need for strong and consistent safeguards
The safeguards to be applied will be those of the IDB, the World Bank or the UNDP, dependent on which institution will be Partner Entity for the relevant project. these institutions have played an important role as channels for Norwegian multilateral cooperation for many years. They have environmental, social and fiduciary safeguards that are compatible with the requirements for the use of Norwegian funds. In our view then, the chosen Partner Entities do meet the requirement for strong and consistent safeguards.

4. Weak participatory process
The Memorandum of Understanding states that “Guyana’s LCDS Multi-Stakeholder Steering Committee and other arrangements to ensure systematic and transparent multi-stakeholder consultations will continue and evolve, and enable the participation of all affected and interested stakeholders…” As stated in the MoU, this is an evolving process, and Guyana is continuously working to improve it. We would encourage you to contact the Guyanese authorities with any constructive inputs you might have in that regard.

Regarding the two LCDS projects (solar panels for low-wattage household electricty and a laptop to each family) that you mention, these two projects have not been presented to the GRIF Steering Committee, which is the reason why they are not posted on the LCDS/GRIF website. This is also the case for Amaila Falls Hydropower project. However, your claim that no public information is available on that project, seems to contradict the fact that an Environmental and Social Impact Assessment study was already publicly available when you published your letter.

5. Indigenous Land Demarcation
Guyana’s LCDS emphasizes the national aim to satisfactorily address all land titling requests by 2015, for those Amerindian villages that request this to be done. The land titling project addresses a complex issues and is under preparation by the Guyanese government in collaboration with the UNDP. As with all other projects it will, to get the approval of the GRIF Steering Committee once submitted to that body, have to conform to the Partner Entity’s (in this case UNDP’s) safeguards. Norway has confidence that the United Nations Development Programme as one of the key organizations of the United Nations working with governance, local democracy and human rights, has the experience and know-how to deliver in partnership with Guyana.

6. Risks of the Amaila Falls Hydro Project
The Amila Falls Hydropower Project is one of the projects listed in Guyana’s LCDS. It has, however, not been submitted to the Steering Committee for assessment and approval for GRIF financing. It will only be submitted once Guyana and the IDB have complied with all their requirements. If the financing of equity is presented to the Steering Committee, IDB’s assessment will be used by Norway as the base for assessing GRIF support. As you will be aware, Mr Erik Helland-Hansen, the day after being quoted as making the statement you refer to in your letter, publicly retracted that statement. He said that he had been misunderstood, and that the panel had not reached any final conclusion.

Regarding “Plan B” for the use of funds and the alleged risk of misuse referred to in your letter, allow us to reference our response under 1 above. The application of high standards when it comes to fiduciary, environmental and social safeguards are to be applied to all projects funded from the GRIF.

7. Inadequate independent Verification Report
The Rainforest Alliance won an open public tender to fulfill the role of independent verifier. Its verification report was the first report of its kind, and it assessed the first year plus a few months of the partnership. Rainforest Alliance has confirmed that their auditors had complete freedom to interview or discuss the process with any stakeholder who indicated interest. The audit was publicly announced, and auditors followed up on each and every request for either information submission or a discussion/interview. The report established that Guyana had met the benchmarks for the first year, which to a large degree consisted of initiating various processes. Rainforest Alliance itself, however, has acknowledged that it was limited as to the amount of fieldwork it could perform. This will be taken into account when commissioning the next verification report. The enablers for the next year have been updated in the revised Joint Concept Note and made more specific to reflect that the partnership has advanced.

8. Restricted access to government information
Transparency is essential to the Guyana-Norway Partnership. Our efforts to provide adequate and timely information will continue. As was stated in the letter from Minister Solheim, none of the consultants responsible for the verification reports related to the cooperation have indicated to us that they had problems in obtaining relevant information from the government of Guyana.

To end this letter where we started, allow me to reiterate that our partnership with Guyana moves into unknown territory. Its main service may turn out to be the lessons and the learning it provides. In that context, we will continue to welcome constructive, facts based exchanges of opinion on how our efforts can be improved.

Finally, this is our second letter in response to concerns you have. We would like to distribute these letters to others in civil society in Guyana who might be interested in our response. It would therefore be very helpful for us to have the names of the organizations you represent and receive their e mail addresses so that copies can be sent directly to your colleagues in these organizations.

Addressees:
Diana Abraham
Malcolm Alli
Seelochan Beharry
Janette Bulkan
Tanya Chung Tiam Fook
Anand Daljeet
Everall Franklin, MP
Malcolm Harripaul
Christina Jardim
Tarron Khemraj
Allison Lindner
Colette McDermott
Alissa Trotz
Karen Jardim
Edward Meertins-George
Sharon Ousman-Arjoon
Christopher Ram
Khemraj Ramjattan, MP
Oma Swehdat
Charlene Wilkinson
Fitzgerald Yaw
David Yhann

From: Janette Bulkan
Date: Tue, Jun 21, 2011 at 12:30 PM
Subject: Re: Norway-Guyana Memorandum of Understanding, November 2009
To: Marte Nordseth
Cc: Hans Brattskar, Per Fredrik Ilsaas Pharo, Andreas Dahl-Jørgensen, Ellen Bruzelius Backer, Tove Stub

Dear Ambassador Brattskar,

I am writing on behalf of the civil society group which sent a letter on 24 March 2011 to Minister of the Environment and International Development, Erik Solheim, in advance of his visit to Guyana at the end of that month and before NICFI had released a number of relevant documents. Your response to our eight points in parts repeats the information contained in our letter. What we seek is a practical demonstration of the transparency mentioned in the Norway-Guyana MoU/JCN. We appreciate completely that a political administration which applies the principle of democratic centralism to stifle the flow of information, contrary to Article 146 in Guyana’s National Constitution 1980/2003, will need substantial change to enter a world of Freedom of Information. The long and extensive history of corruption noted recently by the Public Accounts Committee of the National Assembly confirms the almost daily flow of allegations of corruption emanating from the apex of government. With almost nine per cent of Guyana’s national budget this year tied to disbursement of GRIF money, we would suppose that Norwegian taxpayers would also have a vested interest in NICFI taking more account of the information published almost daily in the independent Press about the Government of Guyana not following legal requirements and/or bypassing approved procedures.

We will come back to NICFI later on specific points. We would have expected NICFI to have expressed concern that the large-scale and rapid deforestation of coastal mangrove forests was apparently overlooked by all three sets of consultants looking at areas of forest/non-forest and changes in area. We would have expected NICFI to have been concerned by the inability of the rolling review team to penetrate beneath the assurances of government staff, partly because of mission time being too short. While Norway talks about verification, the various missions do not seem to have practised independent triangulation of the data provided by government agencies even when (as in the Poyry study) the consultants recognized what should have been done.

We do, however, much appreciate the practice of the Norwegian tradition of open government and that after 11 weeks we did receive at least a partial reply to our major concerns.

Sincerely

Janette Bulkan

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