By Chris Lang
On 5 May 2022, the Papua New Guinea Environmental Alliance wrote to Pogio Ghate, Minister for Environment, Conservation and Climate Change. Their letter expressed their concerns about the government’s submission of REDD+ Safeguards legislation to the National Executive Council, without having carryied out a consultation process about the final draft of the documents.
On 2 March 2022, Wera Mori, then-Minister of Environment, Conservation and Change issued a Moratorium on voluntary carbon market REDD projects. The NGO’s letter also expressed their concern that the government’s Moratorium was not being implemented.
The NGO’s letter is available here:
The PNG Environmental Alliance took out a full page advertisement in the Post Courier, published on 20 May 2022. The statement repeats the concerns highlighted in the 5 May 2022 letter, in particular the ongoing expansion of the NIHT Toapiyo REDD Project, in breach of the Moratorium on voluntary carbon market REDD projects.
The advertisement is posted below in full, and is available here as a pdf file.
On the 5th of May 2022, the Members of the PNG Environmental Alliance (PNGEA) wrote an urgent letter to Minister for Environment, Conservation and Climate Change, Hon. Pogio Ghate, to voice our grave concerns on two essential matters regarding the development and implementation of REDD+ in our country:
- The submission to NEC of final versions of the PNG REDD+ Safeguards (FPIC Guidelines, Benefit Sharing & Distribution System Policy, REDD+ Development Guidelines, Grievance Redress Mechanism) without any stakeholder consultation on the final draft of these documents.
- Complete lack of implementation of the Moratorium on new voluntary carbon market projects.
Re 1. While we acknowledge that constructive progress has been made in preparing the draft REDD+ Safeguard Documents, the official Validation Workshop on the REDD+ Safeguard documents on 16 March 2022, was done without final draft versions of the documents being ready. No documents were circulated to stakeholders in advance of the workshop, and only working draft versions were made available during the workshop. The Climate Change & Development Authority (CCDA) refused NGO requests to allow more time and follow proper process, and asked participants to validate incomplete working draft documents at the end of the workshop. The REDD+ Safeguards and resulting Regulations under the Climate Change Management Act (CCMA) form the backbone of our REDD+ implementation system, as they have to safeguard our people against unscrupulous project developers. They need to be developed through a correct and fully transparent process with proper stakeholder consultation at all stages.
Re 2. One of the main reasons for putting a Moratorium on new voluntary forest carbon market projects in place, was to halt all project preparations until the REDD+ Safeguards and the related Regulations under the CCMA are in place. The Moratorium was put in place in March 2022 but is not being enforced, with project developers and their agents continuing to work on new project areas, without any guidance on proper process, due to the lack of safeguards and regulations. These unguided project preparations leading to a growing number of social problems and conflicts, due to, among others, no proper awareness at the community level, lack of proper FPIC process before signing of carbon credit contracts, unclear and non-transparent benefit sharing mechanism, unsupported excessive claims made on future benefits, no sustainable land use planning done, and cash hand-outs to get clans to sign up.
Most of these issues are caused by the expansion activities of an existing carbon project, the NIHT Topaiyo REDD Project. We are deeply concerned that despite the many reports of problems caused by NIHT’s inappropriate approach, CCDA is partnering with them, and allowing them to continue preparations to add new project areas to their grouped project, and even expand beyond the scope of their existing project (ENB & NIP) into other provinces in PNG. NIHT’s project only meets the international Verified Carbon Standard (VCS) requirements, which have proven not to be able to guarantee safeguards like proper FPIC and equitable benefit sharing for our landholding communities. NIHT’s expansion activities have to be guided and controlled by the REDD+ Safeguards and Regulations, and as long as these are not in place, NIHT should not be allowed to expand their activities beyond their current first project area.
REDD+ benefits will come from a national system with nested voluntary market projects, but in order to safeguard the interest of our people and the country, all REDD+ projects need to be properly regulated through a strong national REDD+ implementation system. The most important part of this system is that it needs to be transparent and equitable, appropriate for our PNG customary societies, guarantees permanence of emissions reductions, and ensures the vast majority of REDD+ benefits are reaching the owners and custodians of the land and forests we are talking about, and will be used for long-term improvements of their livelihoods. Project developers should not be allowed to continue project preparation activities while we do not yet have our final Safeguards and Regulations in place, as this creates dangerous precedents, and a situation that will be extremely difficult to remedy.
The current situation with a short-cut of the development process for the REDD+ Safeguards together with the lack of clarification on and enforcement of the Moratorium, is endangering the development and implementation of a transparent and equitable REDD+ system for PNG, and is damaging our international reputation, hence urgent action is needed.
In our letter, we ask Minister Ghate to show his leadership to protect the reputation of the country in REDD+ and the interest of our people by:
a) Directing CCDA to properly complete the development process of the REDD+ Safeguard document through stakeholder consultation on the final draft versions of the documents, and conducting a real Validation Workshop on their final versions, after processing of the comments received on the final draft versions, with sufficient time allocated for both steps.
b) Putting out a public notice detailing and explaining the meaning of the Moratorium on new voluntary carbon market projects, i.e., a stop to ALL preparation activities for any projects, including for new project area instances of the existing NIHT grouped project.
We welcome the interest and engagement by investors and communities in PNG towards REDD+ and the Voluntary Carbon Market, and the potential we envisage that it will provide into the future. It is for this reason that it is critically important to ensure all the required regulations and institutional arrangements are developed and in place first, and that systems are functioning to ensure oversight and compliance. Without these in place the prospects for PNG and its resource owners will be jeopardised. Businesses and landowners with a genuine interest and commitment to this mechanism, and the opportunities it provides over the longer term, would surely not wish to jeopardise these prospects by bypassing due process and standards now, but rather would support the steps necessary to put in place these fundamental institutional building blocks.
Congratulations to PNG Environmental Alliance! It will be great if you can ensure these regulations come into force before more project approvals. Then an important experiment begins: Can Capitalism still make a “profit” within a rules-based system structure?