By Chris Lang
The Papua New Guinea Environmental Allliance has once again written to the Climate Change and Development Authority (CCDA) raising concerns about the process of validating REDD+ Safeguards in the country. The CCDA is organising a validation workshop on 28 and 29 June 2022.
On 5 May 2022, the PNG Environmental Alliance wrote to Pogio Ghate, Minister for Environment, Conservation and Climate Change raising their concerns about the government’s submission of REDD+ Safeguards legislation to the National Executive Council, without any consultation about the final draft of the documents.
And on 20 May 2022, the PNG Environmental Alliance took out a full page advertisement in the Post Courier repeating its concerns about the REDD+ Safeguards process and the failure to implement a Moratorium on voluntary carbon market REDD projects in the country.
The most recent letter is addressed to William Lakain, the current Managing Director of the CCDA, with copies to the following: Gwen Sissiou, the General Manager REDD+/Mitigation Division; Terence Barambi, Manager REDD+ Branch; Eunice Dus and Kenneth Nobi, senior officers in the REDD+/Mitigation Division.
REDD-Monitor looks forward to posting CCDA’s reply (in full and unedited).
From: Pamela Avusi
Sent: Thursday, 9 June 2022
To: William Lakain
Cc: Gwen Sissiou, Terence Barambi, Eunice Dus, and Kenneth Nobi
Subject: Draft REDD+ Guidelines ValidationDear Mr. William Lakain,
This email is sent to you on behalf of the members of the PNG Environmental Alliance.
We have been informed that CCDA is organising another Validation Workshop on the REDD+ Safeguards on the 28th & 29th of this month.
Although we welcome this decision, considering the manner in which the first Validation Workshop was held, we do have our serious concerns and want to specify in what manner a proper resumption of the REDD+ Safeguards stakeholder consultation process should be resumed, i.e.
- First current draft versions of all REDD+ Safeguard documents (FPIC Guidelines, BSDS Policy, GRM and REDD+ Development Guidelines) are to be shared with all stakeholders, with sufficient time given (at least 2 weeks) to submit written comment on them using a feedback matrix that forces CCDA to respond to each comment on if and how it has been considered.
- Then comments received should be processed by CCDA, producing final draft versions of the docs, again to be distributed to all stakeholders together with the filled out feedback matrix for each Safeguard doc of all stakeholders comments combined (all stakeholders able to see ALL comments submitted and how these have been considered), with sufficient time (again at least 2 weeks) for stakeholders to read through them in preparation for the Validation Workshop, and to respond in case they do not agree with how their comments have been considered.
- Then the Validation Workshop will be held for 2 days, with half a day for each safeguard doc, and the option given to submit last written comments to CCDA till one week after the workshop, again using a feedback matrix.
- The Validation workshop agenda has to include the outline of the Regulation drafting process (which will start once the Safeguard docs have been approved by NEC), specifying the stakeholder consultation process for the Regulations development.
- Then after processing of all comments received during the Validation Workshop and in writing, the final versions of the safeguards are to be shared with all stakeholders, again together with the filled out feedback matrix for each Safeguard doc of all stakeholder comments combined, and one week given for stakeholders to voice any left over major concerns or objections.
- CCDA to communicate directly with any stakeholder still voicing major concerns to explain how concerns will still be accommodated or to explain motivation for not being able to do so, and then reporting on these direct communication to all stakeholders.
- Final version of all REDD+ Safeguards to be submitted to NEC for approval and start of Regulation drafting process.
An independent facilitator should be engaged to properly guide this process. Our recommendation for this would be Sarah Stocks, considering her experience and expertise in this matter, and track record from the CCMA review stakeholder consultation workshops.
If the above outlined proper process for the resumption of the REDD+ Safeguards stakeholder consultation process is followed, this would mean a total time period needed of at least 8 weeks, meaning a timing for the new Validation Workshop earliest the week of 25 July.
Thank you for your consideration and action, and we look forward to your response.
Kind regards,
Pamela Avusi
Interim Coordinator PNG Environmental Alliance
Bismarck Ramu Group (BRG)
Centre for Environmental Law & Community Rights (CELCOR)
Consultative Implementation & Monitoring Council (CIMC)
FORCERT – Forests for Certain: Forests for Life!
Partners with Melanesians (PwM)
PNG Council of Churches (PNGCC)
Research & Conservation Foundation (RCF)
Wide Bay Conservation Association (WBCA)
Wildlife Conservation Society (WCS-PNG)