A group of Paraguayan and international organisations have sent an open letter to the board of the Green Climate Fund which will meet in Songdo, Republic of Korea, from 12 to 14 November 2019. Several of the funding requests under consideration are related to REDD, including an extraordinarily bad proposal to subsidise REDD offsets from the International Finance Corporation.
The letter notes that the Paraguayan government has “shown no intention to halt deforestation” and highlights Paraguay’s inflated Forest Reference Emissions Levels.
The fall in deforestation that Paraguay is hoping to receive “results-based payments” for had “no relation whatsoever with government action”. The fall in deforestation in 2015 was a result of an exceptionally wet year, meaning that it was difficult for landholders to clear the forest.
In August and September 2019, Paraguay suffered severe forest fires. The letter points out that “the reductions of 2015 have already literally gone up in flames”.
The Ayoreo People living in the Paraguayan Chaco were not consulted about the funding proposal to the Green Climate Fund. Indigenous women were also excluded from the process.
Open letter of concern to the Green Climate Fund Board about FP-121, “REDD+ Results-based payments in Paraguay for the period 2015 – 2017”
The undersigned Paraguayan and international NGOs would like to express their strong concerns about the funding proposal titled “REDD+ Results-based payments in Paraguay for the period 2015 – 2017” that has been submitted for consideration at the November 2019 BM24 of the Green Climate Fund (GCF) and we recommend the Board to reject this funding proposal and profoundly review and revise its current REDD+ RBF funding window for the following reasons:
Perverse incentives and inflated Forest Reference Emissions Levels (FREL)
The proposal demonstrates clearly how the current GCF REDD+ results-based payments (RBP) mechanism will not only trigger funding applications from governments that have made virtually no effort to contribute to climate change mitigation, but that it also provides a strong perverse incentive for governments to increase deforestation so as to obtain a more favorable forest reference emissions level (FREL). Rather than rewarding countries who are committed to comply with the Sustainable Development Goal target 15.2 to halt deforestation by 2020, the GCF REDD+ RBP has started a tradition of handing out massive payments to some of the governments that have the worst record on the planet in terms of failing to halt forest loss. The approval of 96.5 million of RBP in February 2019 to the government of Brazil, a government that has openly declared its unwillingness to halt deforestation by 2020, already formed a very perverse signal. Similar to the Brazilian government, the Paraguayan government has shown no intention to halt deforestation. Rather, it has formally adopted a livestock and soy production expansion plan that will trigger the deforestation of 400.000ha/yr between now and 20301. As shown in the latest national communication, this will significantly contribute to increasing Paraguay’s net greenhouse gas emissions.
It should also be noted that the funding proposal itself describes how there are many flaws in Paraguayan forest monitoring methodology and the calculation of the FREL. For example, the average deforestation rate used by the FREL of 330.000 ha/yr is higher than the deforestation rate mentioned in the Statistics the Ministry of Environment itself (see footnote 11) of 286.000 ha/yr. While the Paraguayan government has committed to “improvements” in this respect, it is as yet unclear when and how these improvements will be implemented. In fact, the iTAP also mentions in its assessment many of these flaws as well, and amendments to the methodology cannot be postpone to future potential applications as is suggested in FP-121. This would further undermine the GCF REDD+ RBP funding window.
Claiming “results” for a climatic extreme
Due to its deliberate policy to convert the remaining forests in the country, Paraguay has faced one of the highest deforestation rates on the planet for more than 20 years. As can be read from the funding proposal, between 2000 and 2005 the estimated deforestation rate was 281.745,56 ha per year, which increased to 351.396,89 ha per year in the period between 2006 and 2011. After another increase between 2011 and 2013 the deforestation rate slightly decreased to 286.626,06 ha/year between 2013 and 2014, but by 2017 it had increased to 340.928 ha/year again. The only exception to this trend was the period 2015 – 2016, and this temporary improvement had no relation whatsoever with government action or other “results” the government would be able to claim, but with climatic extremes: 2015 was an exceptionally wet year, which meant it was difficult for landholders to clear an equal amount of forests, as in previous years. Only for that reason, and not as a result of government action, the deforestation rate declined to 214.093 ha that year.
Lack of permanence and expected reversals
The suggestion in the funding proposal that “the direct, indirect and underlying causes of deforestation and forest degradation are addressed”(page 34/35) is simply false, as the Paraguayan government does not only continue to promote, through its formal agricultural policies, the further expansion of beef and soy production, which are scientifically and politically acknowledged as the main drivers of forest loss, but as pointed out it also formally promotes associated deforestation.2 As part of its formal policy to promote deforestation, the Paraguayan government has handed out deforestation licenses for approximately 400.000 ha/year, including in the period 2015 – 2016. These licenses do not oblige landholders to use them within the year they are granted. This implies that the accumulated licenses may be used on later dates and enhance the destructive legacy of governmental policies. Both actions to “address” illegal logging and actions to “address” human-induced fires have dramatically failed. Partly triggered by an exceptional drought, Paraguay suffered equally severe forest fires as the Amazon and other Latin American biomes in August and September 2019, which means that the reductions of 2015 have already literally gone up in flames. The exact amount of total forest cover loss has not yet been calculated although the estimates point that just in the Western part, 60,000 ha of forest has been lost to the fires. What is clear is that it would be irresponsible of the GCF to pay Paraguay for temporary results without any firm guarantees of permanence of results in this situation or any firm commitments to address the main drivers of forest loss in general. The funding proposal itself states that annual emissions will fall to “average levels”, which implies a continued deforestation rate of more than 330.000 ha/yr (according to the FREL) and a complete removal of all natural forest cover by 2080. It is clear a buffer of 18% cannot address this reversal of results.
Lack of Free Prior and Informed Consent of Indigenous rightsholders
Last but not least, we would like to point out that another factor not identified by the evaluators of the project, or condoned by them, is that most of the deforestation takes place on Indigenous Peoples’ territories in the Paraguayan Chaco, including in particular the territories of the Ayoreo People, who were never consulted about this proposal. The Ayoreo People and their Union of Ayoreo Peoples (UNAP) are not part of the Indigenous organizations mentioned in the proposal, yet their territories cover the majority of the lands where most of the deforestation takes place (the Bosque Seco Chaqueño). They never gave their free prior and informed consent to go ahead with this proposal, or to compensate third parties for their rights. This is particularly problematic as the funding proposal explicitly acknowledges it could trigger resettlements of populations. As some Ayoreo tribes continue to live in voluntary isolation, such resettlement would have significant negative impacts on their health and livelihoods.
Many other social movements of rightsholders were excluded from the consultations as well. We are particularly concerned about the lack of consultation with Indigenous women, including Ayoreo women, who tend to face cultural as well as language barriers to full and effective participation in consultation processes. Moreover, as women barely received 13.6 percent of the fiscal lands allocated between 1940 and 2008, the proposal’s emphasis on the further operationalization of the Payments for Environmental Services law will increase their economic and social marginalization, as these payments are normally accrued by fiscal landowners only, to the detriment of women who do not have a formal land title yet depend on and often manage the forest areas involved. The lack of a proper benefit-sharing mechanism that involves women, indigenous peoples and peasants in this funding proposal will worsen this situation.
In light of the above-mentioned concerns we would like to reiterate our recommendation to the Board of the Green Climate Fund to reject funding proposal FP-121 and to profoundly review and revise its current REDD+ RBF funding window so that it no longer forms a perverse incentive for continued deforestation.
1. Aksi! For gender, social and ecological justice- Indonesia
4. Global Forest Coalition
5. Henoi- Paraguay
6. Indigenous Environmental Network
7. Iniciativa Amotocodie – Paraguay
8. NAPE (National Association of Professional Environmentalists)- Uganda
9. Salva la Selva- Spain
10. Sobrevivencia- Paraguay
11. WECF (Women Engage for a Common Future)
12. WEDO (Women’s Environment & Development Organization)
 “Viceministro asegura que la deforestación no es un problema” (www.rdn.com.py)
 “Viceministro asegura que la deforestación no es un problema” (www.rdn.com.py)