Dear Dr Ani Dasgupta
We noted with surprise a congratulatory message attributed to WRI on the issuance of Winrock-ART’s TREES jurisdictional forest-based carbon credits to Guyana on 5 December 2022 (Department of Public Information (2022) ‘Sale of carbon credits: $157B for investments in low-carbon development across Guyana’, Department of Public Information, 21 December. Available at: https://dpi.gov.gy/sale-of-carbon-credits-157b-for-investments-in-low-carbon-development-across-guyana/) .
WRI allegedly stated that ‘HFLD-labelled credits … have high environmental integrity because credits fully address legitimate additionality, conservativeness and permanence, and counteract international leakage …’.
Respectfully, we note that Winrock-ART have not provided any evidence for their claims. Here is the Guyana reality (repeated also in the news items below).
- REDD+ – this acronym includes the active verb ‘Reducing’ for [carbon] emissions from forest-based deforestation and forest degradation. It indicates both a formal policy commitment and also verifiable activities and results. However, the two concerned government agencies in Guyana (Guyana Forestry Commission – GFC and Guyana Geology and Mines Commission – GGMC) have no active programmes or activities for reducing emission of forest carbon. The GFC’s Code of Practice specified reduced-impact logging (RIL) but that is intended to protect the soils and advance tree regeneration from logging damage. There are no recent reports that RIL is being practised by the loggers. The GGMC has a requirement in the Mining Regulations 2005 for restoration of the deforested areas cleared for artisanal hydraulic mining for gold, but restoration does not take place anywhere routinely. That is, the aspiration for REDD+ included in the Norway-Guyana Memorandum of Understanding (2009-2015) and the current Low Carbon Development Strategy 2030 is not being backed by serious policy commitments or practices.
- You may wish also to question exactly what these carbon credits represent. Some of Guyana’s natural tropical rainforests have not yet been logged or destroyed by gold mining but over 5 Mha are currently licensed for logging and most of that area has been repeatedly logged. There is no formal reforestation or post-logging silviculture to restore the slow-growing natural forest on these very infertile soils.
- The natural forest is in ecological equilibrium. The trees ‘breathe’ in carbon dioxide by day and synthesise the gas into sugars and wood fibre, and ‘exhale’ carbon dioxide continuously as a by-product of generating energy for survival and growth. Trees grow over long periods, and trees die and decay over short periods, but the system is in equilibrium; obviously, otherwise the globe would be covered by enormous trees. Certainly the standing forests of Guyana contain gigatonnes of carbon, but that carbon is recycled through growth and death. The idea that the forests sequester additional large amounts of carbon continuously is wrong, indeed ludicrous. These forests are not expanding into the natural savannas of Guyana, and the repeated logging is largely preventing recovery of the amount of the pre-logging carbon stock, just as re-entry logging did in Malaysia a few decades ago.
WRI also allegedly stated that the Winrock-ART’s TREES credits ‘reward forest stewardship by Indigenous Peoples’. Here are how the forests of Guyana are apportioned:
- Relevant State agencies in Guyana for administration of forest are the GFC for 12.143 million hectares (Mha) of natural tropical rainforest, Guyana Lands and Surveys Commission for 2.453 Mha of forest on State Lands, and the Protected Areas Commission for 1.092 Mha of forest; a total of 15.687 Mha of forest or 87 per cent out of a national total of 18.070 Mha.
- The 2.299 Mha of forest standing on titled Indigenous areas (Amerindian Village Lands, 3.305 Mha) are not at the disposal of the Government of Guyana, without the explicit agreement by vote at a formal Village meeting. That is the law in the Amerindian Act cap. 29:01 2006. No such vote has been taken in any Amerindian Village.
- Since 2009 the Government of Guyana has also subscribed to the principle of Free, Prior and Informed Consent (FPIC), as laid out in the United Nations Declaration of the Rights of Indigenous Peoples (UNDRIP) which Guyana endorsed formally in 2007. As the Amerindian Peoples Association notes in a Press release on December 15, this implies that the carbon in the State Forests and State Lands forests which overlie the customary lands of the Indigenous Peoples also cannot be traded by the Government without explicit agreement of the relevant Amerindian Villages and untitled Communities (Stabroek News (2022) ‘APA raps carbon credits scheme for breaching consultation process’, Stabroek News, 15 December. Available at: https://www.stabroeknews.com/2022/12/15/news/guyana/apa-raps-carbon-credits-scheme-for-breaching-consultation-process/ ). These are the forests standing on the approximately 5.774 Mha of (untitled) customary lands.
- It appears from the Press release of Winrock/ART on December 1, 2022, that the 33.47 million jurisdictional carbon credits issued by Winrock/ART through its TREES scheme include credits attributed to those Amerindian forests. It appears also that the Hess Corporation has purchased or committed to purchasing such credits in its total of 37.5 million credits for a nominal USD 750 million. These credits have not been offered for sale by the Amerindian communities.
Some references:
- Usher, A. D. (2022) ‘Indigenous groups in Guyana raise alarm over historic issuance of carbon credits by Norwegian-funded certifier’, Development Today, 23 December. Available at: https://development-today.com/archive/dt-2022/dt-9-10–2022/indigenous-groups-in-guyana-raise-alarm-over-historic-issuance-of-carbon-credits-by-norwegian-funded-certifier.
- Bulkan, J. and Palmer, J. (2022) ‘Queries about the purchase by Hess Corporation of jurisdictional carbon credits from the Government of Guyana’, Oil and Gas Governance Network, 15 December. Available at: https://www.oggn.org/2022/12/16/queries-about-the-purchase-by-hess-corporation-of-jurisdictional-carbon-credits-from-the-government-of-guyana/ .
- Bulkan, J. (2022) ‘The range of tenures (property rights) that underlie the jurisdictional carbon credits sold by Guyana to oil company Hess Corporation’, Stabroek News, 15 December. Available at: https://www.stabroeknews.com/2022/12/15/features/the-range-of-tenures-property-rights-that-underlie-the-jurisdictional-carbon-credits-sold-by-guyana-to-oil-company-hess-corporation/.
- Bulkan, J. (2022) ‘Jurisdictional forest-based carbon credits’, Stabroek News, 13 December. Available at: https://www.stabroeknews.com/2022/12/13/features/jurisdictional-forest-based-carbon-credits/.
- Bulkan, J. (2022) ‘Gov’t and its partner Winrock have illegally arrogated to themselves the rights vested solely in Amerindian land title holders’, Stabroek News, 13 December. Available at: https://www.stabroeknews.com/2022/12/13/opinion/letters/govt-and-its-partner-winrock-have-illegally-arrogated-to-themselves-the-rights-vested-solely-in-amerindian-land-title-holders/.
- Bulkan, J. (2022) ‘NTC must explain legal basis of their endorsement of government’s move to make decisions over Indigenous titled lands’, Stabroek News, 8 December. Available at: https://www.stabroeknews.com/2022/12/08/opinion/letters/ntc-must-explain-legal-basis-of-their-endorsement-of-governments-move-to-make-decisions-over-indigenous-titled-lands/
We look forward to your reply.
Yours truly,
Janette Bulkan
Associate Professor, Department of Forest Resources Management
Faculty of Forestry
The University of British Columbia
2021-2424 Main Mall, Vancouver, BC Canada. V6T 1Z4
Email: janette.bulkan@ubc.ca
AND
John Palmer
Senior Associate, Forest Management Trust, Bozeman, Montana 59715, USA
E-mail jrpalmer2005@outlook.com
