FOREST MANAGEMENT CERTIFICATION REPORT...Equatoria Teak Company (ETC) is based in the town of Nzara,...
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Doc. Number: AD 36A-08 Doc. Version date: 22 January 2009 SGS QUALIFOR (Associated Documents) Page: 1 of 48 SGS services are rendered in accordance with the applicable SGS General Conditions of Service accessible at http://www.sgs.com/terms_and_conditions.htm SGS South Africa (Qualifor Programme) 58 Melville Road, Booysens - PO Box 82582, Southdale 2185 South Africa Systems and Services Certification Division [email protected] SGS South Africa (Qualifor Programme) 58 Melville Road, Booysens - PO Box 82582, Southdale 2185 - South Africa Systems and Services Certification Division Contact Programme Director at t. +27 11 681-2500 www.sgs.com/forestry FOREST MANAGEMENT CERTIFICATION REPORT SECTION A: PUBLIC SUMMARY Project Nr: 12402-SD Client: Equatoria Teak Company Web Page: www. Address: PO Box 20130 Lugogo Kampala Uganda Country: Sudan Certificate Nr. SGS-FM/COC-007104 Certificate Type: Forest Management / Chain of Custody Date of Issue 21 Dec 2009 Date of expiry: 20 Dec 2014 Forest Zone: Tropical Total Certified Area 18 640 ha Scope: Forest Management of the plantations of Equatoria Teak Company in South Sudan for the production, harvesting, transport and sale of teak round logs. Company Contact Person: Hannes Winter: Chief Executive Officer Address: PO Box 20130 Lugogo Kampala Uganda Tel: (+256) (0) 41 223678/88 Fax Email: [email protected] Evaluation dates: Main Evaluation Main assessment done on 6-12 July 2009 and COF done on 12-13 September 2009. Surveillance 1 Surveillance 2 Surveillance 3 Surveillance 4
Transcript of FOREST MANAGEMENT CERTIFICATION REPORT...Equatoria Teak Company (ETC) is based in the town of Nzara,...
Doc. Number: AD 36A-08
Doc. Version date: 22 January 2009
SGS QUALIFOR
(Associated Documents)
Page: 1 of 48
SGS services are rendered in accordance with the applicable SGS General Conditions of Service accessible at http://www.sgs.com/terms_and_conditions.htm
SGS South Africa (Qualifor Programme) 58 Melville Road, Booysens - PO Box 82582, Southdale 2185 South AfricaSystems and Services Certification Division [email protected] South Africa (Qualifor Programme) 58 Melville Road, Booysens - PO Box 82582, Southdale 2185 - South AfricaSystems and Services Certification Division Contact Programme Director at t. +27 11 681-2500 www.sgs.com/forestry
FOREST MANAGEMENT CERTIFICATION REPORT
SSEECCTTIIOONN AA:: PPUUBBLLIICC SSUUMMMMAARRYY
Project Nr: 12402-SD
Client: Equatoria Teak Company
Web Page: www.
Address:
PO Box 20130 Lugogo Kampala
Uganda
Country: Sudan
Certificate Nr. SGS-FM/COC-007104 Certificate Type: Forest Management / Chain of Custody
Date of Issue 21 Dec 2009 Date of expiry: 20 Dec 2014
Forest Zone: Tropical
Total Certified Area 18 640 ha
Scope: Forest Management of the plantations of Equatoria Teak Company in South Sudan for the production, harvesting, transport and sale of teak round logs.
Company Contact Person:
Hannes Winter: Chief Executive Officer
Address:
PO Box 20130 Lugogo Kampala Uganda
Tel: (+256) (0) 41 223678/88
Fax
Email: [email protected]
Evaluation dates:
Main Evaluation Main assessment done on 6-12 July 2009 and COF done on 12-13 September 2009.
Surveillance 1
Surveillance 2
Surveillance 3
Surveillance 4
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TTAABBLLEE OOFF CCOONNTTEENNTTSS
1. SCOPE OF CERTIFICATE...........................................................................................................................6
2. COMPANY BACKGROUND ........................................................................................................................7
2.1 Ownership...........................................................................................................................................7
2.2 Company Key Objectives ..................................................................................................................8
2.3 Company History................................................................................................................................8
2.4 Organisational Structure ...................................................................................................................8
2.5 Ownership and Use Rights ...............................................................................................................9
2.6 Other Land Uses.................................................................................................................................9
2.7 Non-certified Forests .........................................................................................................................9
3. FOREST MANAGEMENT SYSTEM ..........................................................................................................10
3.1 Bio-physical setting .........................................................................................................................10
3.2 History of use ...................................................................................................................................12
3.3 Planning process .............................................................................................................................12
3.4 Harvest and regeneration................................................................................................................12
3.5 Monitoring processes......................................................................................................................13
4. SOCIO-ECONOMIC AND ENVIRONMENTAL CONTEXT........................................................................14
4.1 Social aspects ..................................................................................................................................14
4.2 Environmental aspects....................................................................................................................15
4.3 Administration, Legislation and Guidelines ..................................................................................15
5. CHANGES IN MANAGEMENT, HARVESTING, SILVICULTURE AND MONITORING ...........................18
6. PREPARATION FOR THE EVALUATION.................................................................................................18
6.1 Schedule ...........................................................................................................................................18
6.2 Team..................................................................................................................................................19
6.3 Checklist Preparation ......................................................................................................................19
6.4 Stakeholder notification ..................................................................................................................19
7. THE EVALUATION.....................................................................................................................................19
7.1 Opening meeting..............................................................................................................................19
7.2 Document review .............................................................................................................................19
7.3 Sampling and Evaluation Approach...............................................................................................20
7.4 Field assessments ...........................................................................................................................20
7.5 Stakeholder interviews ....................................................................................................................20
7.6 Summing up and closing meeting..................................................................................................21
8. EVALUATION RESULTS...........................................................................................................................21
8.1 Findings related to the general QUALIFOR Programme ..............................................................21
9. CERTIFICATION DECISION......................................................................................................................35
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10. MAINTENANCE OF CERTIFICATION.......................................................................................................36
11. RECORD OF CORRECTIVE ACTION REQUESTS (CARs).....................................................................37
12. RECORD OF OBSERVATIONS.................................................................................................................43
13. RECORD OF STAKEHOLDER COMMENTS AND INTERVIEWS............................................................44
14. RECORD OF COMPLAINTS......................................................................................................................47
ASSOCIATED DOCUMENTS (not part of the Public Summary)
AD 20: Evaluation Itinerary
AD 21: Attendance Record
AD 26: Corrective Action Requests
AD 36-B: Evaluation - Observations and Information on Logistics
AD 36-C: Evaluation – Information on Group Members
AD 38: Peer Review Report
AD 40: Stakeholder Reports
Evaluation team CV’s
List of stakeholders contacted
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Complaints and Disputes
Procedures for submitting complaints, appeals and disputes, and the SGS processing of such are published on www.sgs.com/forestry. This information is also available on request – refer contact details on the first page.
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INTRODUCTION
The purpose of the evaluation was to evaluate the operations of Equatoria Teak Company against the requirements of the QUALIFOR Programme, the SGS Group’s forest certification programme accredited by Forest Stewardship Council.
1. SCOPE OF CERTIFICATE
The scope of the certificate falls within the Tropical Forest Zone and includes 5 Forest Management Units (FMUs) as described below.
Description of FMUs:
Description Ownership Area (ha) Longitude E/W Latitude N/S
Yabua (block A) State 2 083 28° 18’ 4° 38’
Mbarizanga (block B) State 3 750 28° 13’ 4° 32’
Nangodi (block C) State 2 513 28° 15’ 4° 45’
Magaba (block D) State 3 825 28° 16’ 4° 59’
Ringasi (block E) State 6 469 27° 53’ 4° 36’
TOTAL 18 640
Size of FMUs:
Nr of FMUs Area (ha)
Less than 100 ha 0 0
100 to 1 000 ha in area 0 0
1 001 to 10 000 ha in area 5 18 640
More than 10 000 ha in area 0 0
Total 5 18 640
Total Area in the Scope of the Certificate that is:
Area (ha)
Privately managed 18 640
State Managed 0
Community Managed 0
Composition of the Certified Forest(s)
Area (ha)
Area of forest protected from commercial harvesting of timber and managed primarily for conservation objectives
1 400
Area of forest protected from commercial harvesting of timber and managed primarily for production of NTFPs or services
15 450
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Composition of the Certified Forest(s)
Area (ha)
Area of forest classified as “high conservation value forest” 1 400
Area of non-forest managed primarily for conservation objectives 0
Total area of production forest (i.e. forest from which timber may be harvested) 1 790
Area of production forest classified as “plantation” 1 790
Area of production forest regenerated primarily by replanting 1 790
Area of production forest regenerate primarily by natural regeneration 0
List of High Conservation Values
Description Notes
Forest areas fundamental to meeting basic needs of local communities.
The fairly undisturbed forest areas in the southern parts of the Mbarizanga concession area are recommended for classification as HCVF. This area represents the closest representation of the “Closed Forest” vegetation type and has the potential to meet most of the basic needs of local communities, provided that the area is managed along sound conservation principles.
List of Timber Product Categories
Product Class Product Type Trade Name Category Species
Wood sawn - Teak sawn timber
Deciduous (Hardwood)
Tectona grandis
Annual Timber Production
Maximum Annual Sustainable Yield (m3) Species (botanical name) Species (common name) Area (ha)
Projected Actual
Tectona grandis Teak 1 248 13 000 ¹
Cassia siamea Cassia 399 2 000 ¹
Totals 1 647² 15 000 ¹
¹ Harvesting only started on 30/06/2009. ² Smaller areas of mango exist that will be converted to teak.
Approximate Annual Commercial Production of Non-Timber-Forest-Products
Species Product
Botanical Name Common Name)
Unit of measure Total units
No commercial production of NTFPs takes place on the FMUs.
2. COMPANY BACKGROUND
2.1 Ownership
ETC has 37% local (Southern Sudanese and Ugandan) equity participation. The controlling 63% interest in ETC is owned by Afriforest Investments whose shareholders are Actis (77%), through its Africa Agribusiness Fund, and the Finnish Fund for Industrial Cooperation “Finnfund” (23%). Actis was set up in 2004 as part of a restructuring of CDC Group plc (formerly the Commonwealth Development Corporation), and is now a leading private equity investor in emerging markets whose
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activities are focused on Africa, Latin America, South Asia and China. CDC remains a key investor in the funds managed by Actis and is the sole investor in the Actis Africa Agribusiness Fund which invested in Afriforest Investments and ETC. Consequently the investment in ETC is managed by Actis on behalf of CDC. CDC is a UK government-owned fund of funds. Its sole shareholder is the UK Department for International Development (DfID) and its investment philosophy is aimed at the private sector to achieve a direct economic impact by providing funding for successful companies and an indirect impact by demonstrating the benefits of successful investment to other capital providers. Actis and CDC have been investing in emerging markets for nearly 60 years. Finnfund is a Finnish development finance company that provides long-term risk capital for financing socially responsible, profitable projects in developing countries. Finnfund is owned by the State of Finland (84.2 %), Finnvera (15.7 %) and the Confederation of Finnish Industries EK (0.1 %). Both CDC and Finnfund are members of the EDFI (the Association of European Development Finance Institutions) a group of 17 bilateral institutions which provide long term private sector finance for developing economies.
2.2 Company Key Objectives
Objective Notes
Commercial
The management objectives of ETC are to implement management procedures that will ensure the long term sustainability of the forests while:
1. Allowing for local utilisation of the forest resource 2. Adding value to the harvested resource
Social
3. Securing income for the country and local communities
4. Developing local industries and services
Environmental
5. Reducing the pressure on other natural forests in the area.
2.3 Company History
Equatoria Teak Company (ETC) is based in the town of Nzara, West Equatoria State, Sudan. The operations are based on teak plantings that were established by the British in the early 1950s and are now managed in terms of a concession that was granted to the company on 28 June 2006 by the Government of South Sudan (GOSS). The land of the concession has been acquired on a 32 year lease. It is possible that the lease could be extended to allow for more rotations of planting. The land under consideration has already been gazetted for forestry. The investors (essentially the British and Finnish Governments) view ETC as having the potential to be a viable economic project that will also yield non-commercial benefits to society.
2.4 Organisational Structure
The broad organisational structure of the company is as follows:
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The company currently employs 246 employees and does not make any use of contractors in its forest management operations.
2.5 Ownership and Use Rights
The forest reserves were gazetted between 1947 and 1952 and fall under the direct legal responsibility of the Ministry of Agriculture and Forestry, GOSS. Village populations are concentrated around towns and villages and a large number of people exist and have been living on the forest reserves especially at Yabua close to Nzara. Off and on certain reserves the vegetation and soils are farmed through shifting cultivation. The more remote areas such as Nangodi, Magaba, Ringasi and the southern part of Mbarizanga natural areas do not have significant numbers of people living on and off the reserves.
2.6 Other Land Uses
Stone is being collected on some FMUs for use in construction, as well as on burial sites. This practice is accepted by the company, has no meaningful environmental impacts and does not constitute a conflict between the company and any other parties. A number of people have settled on the forested area of Yabua FMU and have opened up fields for cultivation. These agricultural practices compromise the ecological integrity of the natural forests and a non-conformance was raised in this respect. The company does not intend to make use of non timber forest products itself.
2.7 Non-certified Forests
The owner has some responsibility, whether as owner (including share or partial ownership), manager, consultant or other responsibility over the following forest areas:
Forest Name Location Total Area (ha) Reason for exclusion
Kilombero Valley Teak Company Ltd
Tanzania 28 132 total, with 8 100 planted to teak
Applied for certification, but failed due to conversion of natural forests to teak plantations. FMU is otherwise managed ito the FSC P&C. The operations are ISO 14001 certified and obtained TLTV certification during July 2009.
Central Equatoria Teak South Sudan About 15 000 total, with some
Will apply for certification once
CEO
Admin & Prod Manager
Logistics & Construction
Manager
Forestry Plantation Manager
CFO Group Forestry Manager
Personnel Superintendent
Social & Liaison Superintendent
Maintenance Mechanic
Forester Environmental Superintendent
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1 800 planted to teak and cassia
company is fully established.
Total 43 132
The Board of Directors of the Kilombero Valley Teak Company Ltd resolved on 31/03/ 2009 that KVTC would immediately stop further conversion of areas of natural woodland to teak within the boundaries of its Certificates of Occupancy in the Kilombero and Ulanga Districts of Tanzania and management was instructed to cease, forthwith, the identification and clearfelling of further such areas. An independent TLTV audit of these operations was conducted during 16-18/06/2009. This aspect was inspected in-field during the audit. No evidence of any new conversions could be found and management clearly indicated that this practice has ceased.
3. FOREST MANAGEMENT SYSTEM
3.1 Bio-physical setting
Geography:
The FMUs are located in an ironstone plateau which is separated into western and southern parts and is often referred to as the Yambio forest region. The region is dissected by a dense dendritic network of permanent and intermittent channels. The larger valleys display distinct valley floors. The basement complex in the south-west is represented by an undifferentiated complex of granitic gneiss, charnokitick granites, amphibolites and pyroxene granulites. Here the basement rock is covered by various recent alluvial and colluvial sediments. Further north-east from the border these sediments become a continuous laterite (ironstone plateau). The plateau itself is oriented in NW-SE direction and displays a dendritic pattern. Laterite is found in all three plantations, though often covered by a thin layer of recent sediments. The river valleys are generally free of ironstones (which lie at higher elevations) though the gravels derived from ironstones occur in the valleys. The basement complex crops out to the north-east of the ironstone plateau boundary with younger granite outcrops more common to the east. The geological sequence is similar over most of the FMUs and follows the pattern of: 1. Recent colluvium/alluvium varying in depth (up to 6 m of red loam). Depth of alluvial sand deposits along the rivers is uncertain, but does not seem to exceed a few meters.
2. Ironstone (laterite, ferricrete,) which may vary in depth from a few meters up to 20 meters. It is often exposed at the surface on the ridges and dominates the topographic and drainage pattern.
3. A thick layer of highly-weathered kaolinitic clay, which may reach tens of meters in depth and gradually grades into basement granite/gneiss is located below the ironstone surface.
4. The basement granitic gneisses are of Precambrian age and are seldom exposed on the surface.
The teak plantations are located in the catchment of the Yubo River - a tributary of the river Sue. The river network is very dense and the valley incision is quite shallow resulting in well developed valleys. The elevation difference between watersheds and water level in the rivers and streams usually does not exceed 50 meters. The gradients are also low, which give the landscape a generally flat aspect. The low topography and fine sediments within the river valleys prevent effective drainage of the landscape, leading to slow drainage and the clogging of water courses.
Ecology:
Forest, woodland and secondary grassland integrate in patterns controlled by annual precipitation, duration of water stress and the severity of dry-season fires and human activity. Three main natural vegetation zones are found on the FMUs: open broadleaved deciduous woodlands, swamp grasslands in broad river valleys and gallery forests along riverbanks and in protected areas. Most of the FMUs consist of an open broadleaved deciduous woodland or fairly wet savannah. These moist savannah woodlands with individual tall forest trees are often referred to as derived rain forest
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and stretches in a belt along the borders with Uganda, DRC and Central Africa Republic towards Yei, Maridi and Tambura, and an area on the Boma Plateau. Some trees are over 30 m in height and 250 mm in diameter. The vegetation is a mix of various grass types with tall broadleaved trees. The vegetation has a fairly open canopy and a crown cover not exceeding about 40%. During the wet season with all the grass species fully grown out the ground cover exceed 100%. Characteristic species are Terminalia glaucescens, Albizzia zygia, Vitex doniana, Acacia polyacantha and Anogeissus leiocarpus. Smaller trees include Combretum hinderanum, Grewia mollis, Annona chrysophylla, Bridelia scleroneura and Dombeya quinqueseta. The swamp grasslands in broad river valleys are found in the lower, wide and flat parts of the valleys that are seasonally inundated and these swampy depressions support a dense, low, grassy vegetation with little or no trees except along the banks of these depressions. Most of the riverine areas support a gallery type forest with a considerably higher canopy cover than the surrounding broadleaved woodlands. It is represent by only a very narrow strip along streambeds, with very little of it inside the FMU, showing no extension away from water courses. Closed-canopy forests occupy only a small portion of the total area. Climate and geomorphology of the area are limiting the extent of the moist closed-canopy forest in the area. The dry season (three to four months) is too long to allow the forest to comfortably establish on the watersheds. The laterite on the watersheds is dominated by macro-pores and can not hold a sufficient amount of water to take the forest through the dry season. Subsequently, its habitat is restricted to locations where ground water supporting the streams can be easily accessed during the months of November to March. Elevations above the stream water level and the curvature of the water table supporting these streams are important in determining the uphill expansion of these forests. Most of the vegetation is in a bad state of degradation by invasion of various aggressive invaders or burnt to such an extent that some layers have entirely disappeared. Due to the fact that most of the agricultural practices in the area are crop based and of the smallholder subsistence, shifting-cultivation type, most of the areas of natural vegetation have at some stage been farmed, evidenced by the occurrence of cassava (Manihot esculenta), mango (Mangifera species), groundnuts (Arachis hypogaea) or sorghum (Sorghum species) even in some very remote areas. Plantations and cultivated fields constitute two further non-natural classes of vegetation zones within the FMUs. The plantations are made up of primarily teak (Tectona grandis) and cassia (Cassia siamea). Some smaller areas of mango (Mangifera species) exist. The primary specie Tectona grandis is one of the world's premier hardwood timbers, famous for its mellow colour, fine grain and durability. It occurs naturally in India, Myanmar, the Lao People's Democratic Republic and Thailand. Teak is a large deciduous tree with a rounded crown and, under good growing conditions; a tall clean cylindrical bole of more than 25 m. Cassia siamea is an evergreen tree also originating from Southeast Asia and tolerates both arid lands and tropical climates. It is a fast grower that reaches about 10 m in height and coppices readily once cut. This makes the tree versatile in terms of its applications which are mainly for firewood and fencing poles. Mango is native to southern Asia, has a round crown and can reach heights of 10-30 meters, and is mainly used for fruit production but other versatile uses include structural timber, medicine, tannin and gum production. This ecoregion lies in the tropical savannah climate zone and is climatically transitional between the Sudanian and Guineo-Congolian regions. Most of the region is characterized by a single wet season and a single dry season with the highest rainfall distributed between March and November every year, reaching its peak between May and October. Precipitation may vary substantially from year to year. Forested areas exhibit high dry season relative humidity. Mean annual precipitation ranges locally from about 1 200 mm to 1 600 mm per year. Latitude plays a major role in the general decline in average precipitation as the ecoregion grades into the Sudan/Sahel savannah. The dry season occurs between November and March and lasts three to four months. North-North-Westerly winds are common during this period. In March-April they change to South-Easterly winds laden with moisture, which bring the onset of the long rainy season, which usually peaks in August. This ecoregion experiences small seasonal temperature fluctuations, with rainy season mean daily maximum temperatures of 31° - 34°C and dry season mean daily minimum temperatures of 13° - 18°C.
Soils:
The only available soil map covering the area is the FAO/UNESCO soil map of the world at 1:5 000 000 scale, which depicts the whole watershed region as combination of
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Ferralsols and Plinthosols. Seven major soil types were described by consultants commissioned by the company. These soils can be separated into two major groups: watershed mosaic and alluvial complex. Together they form a Yambio catena. The areas under teak are mainly situated on the iron stone plateau covered by a colluvial/alluvial layer of variable depths. Below the iron stone is clay with a basement rock of granitic gneisses. These soils have over the years been eroded due to continued fires stripping the area bare of any vegetation and ground cover. This includes the areas under teak and care will have to be exercised not to further erode the soils due to harvesting impacts.
3.2 History of use
Equatoria began as a province of Egypt, located in the extreme south of present-day Sudan along the upper reaches of the White Nile. Equatoria was established by Samuel Baker in 1870 and was an idealistic effort to create a model state in the interior of Africa. Equatoria ceased to exist as an Egyptian outpost in 1889. Under Anglo-Egyptian Sudan, most of Equatoria became one of the eight original provinces of Sudan. The area has been subject to a history of disturbance. The region has been troubled with violence during the First and Second Sudanese Civil Wars, as well as the anti-Ugandan insurgencies based in Sudan, such as the Lord's Resistance Army (which is still active in the region on occasion) and West Nile Bank Front. The region has only recently emerged from decades of civil war, is subject to unchecked repatriation of refugees, suffers from a gross lack of infrastructure and has been ecologically severely damaged. Village populations are concentrated around towns and villages and a large number of people live on or adjacent to the forest reserves especially at Yabua close to Nzara. Off and on certain reserves the vegetation and soils are farmed through shifting cultivation. Areas close to Nzara and Yambio have little forest cover left. Outlying areas such as Nangodi, Magaba, Ringasi and the southern part of Mbarizanga natural areas do not have significant numbers of people living on and off the reserves.
3.3 Planning process
Planning revolves around the long term strategic Management Plan, a Tactical Harvest Plan based on yield regulation generated in the Microforest system and the Annual Plan of Operations.
The Microforest system is integrated with the geographical information system component of land use management. It is also integrated with the financial management system (Pastel) and the company log and product tracking system. Microforest consists of a number of modules such as plantation manager for operational planning and control, enumeration and inventory management; harvesting scheduler, log tracking, tactical and strategic planning, etc. A schedule of the harvesting of compartments over a full rotation of the working plan unit is generated in Microforest and a tactical harvest plan is used for defining the short term tactical planning schedule. The tactical harvesting plan is a detailed description of the harvesting activities to be performed over the next three years. The plan is derived from both the Forest Management plan as well as the long term strategic business plan. The plan is a practical document which describes the compartments as well as the harvesting systems to be planned for during this period. It is also a guidance document in terms of the health and safety as well as the environmental issues. A Fire Management Plan is available and updated annually. All areas to be protected through the burning and constructing of fire breaks are described. Communication and resources are listed and fire orders have been formalised. A system of internal memos and procedure documents are used to develop and revise policies and operational procedures. These are communicated to staff via internal training sessions. Progress is monitored by capturing all actuals in the Microforest system where it is compared with the planned targets.
3.4 Harvest and regeneration
The preferred regeneration method is replanting with stumps or seedlings derived from improved seed or cutting material developed through the tree breeding programme. The seedlings are removed in the open root nursery and both the stem and root is removed. The resulting stump is planted in the field and referred to as stump planting. Planting espacement is 3 m x 2 m (first year only) or 3 m x 3 m. Planting espacement is determined according to ETC saw timber regime at 1 667 spha or at 1 111 spha initial planting. A pre-plant spray with glyphosate is carried out if there is excessive weed growth on the site. Coppicing is used as a regeneration method where improved planting material has not been developed -after the coppice reaches a height of 2-3 m all except two
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stems are removed from the original stump. The two stems are then grown for a period following which a thinning is applied to remove one stem to leave the best stem. A normal saw log working cycle pruning and thinning regime is then followed until clear-felling at age 28-32 years. Thinning in the teak will be undertaken at age 8, 13 and 20. Timber inventories are done at 5 years of age and thereafter a year before the next thinning. Yield prediction and a schedule of the harvesting of compartments over a full rotation of the working plan unit are generated in Microforest. Felling will be done according to this harvesting plan on a compartment basis. The piece sizes of the logs are relatively small compared to their age and what could be expected in a managed forest. Felling, crosscutting and to an extent de branching is done by motor manual chainsaw. Extraction is done by 4x4 tractors with cable winch equipment. Stacking is mainly done on roadside where crosscutting to size or mill demand is carried out. Timber size constraints dictate the use of a 3 wheel logger vs. hand or manual stacking. Hauling is carried out by the currently available road tippers; this is however not a lasting solution and once capital is available more specialised vehicles will be used such as tractor with timber trailer. All activities are carried out by own employees – no contractors are used in any process.
The age-class distribution of the plantation resource is as follows:
ETC PLANTATIONS
335
274
137
135
72
65
64
63
60
59
48
6
5
Are
a (
ha)
0 0 1
2
25
26
28
29
30
33
34
35
40
42
Age class
3.5 Monitoring processes
A large number of professional studies were commissioned to obtain baseline information on a wide range of disciplines such as soils, hydrology, water quality, floristics, faunal (butterflies, reptiles, amphibians, birds, small and large mammals) and NTFPs. The following activities have been identified for on-going monitoring:
Plantation
1. Inventories to monitor plantation growing stock 2. Permanent Sampling Plots to monitor growth dynamics 3. Operational monitoring such as harvesting impacts 4. Erosion monitoring
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Natural Forests 5. Permanent Sampling Plots to monitor growth dynamics and regeneration 6. Birds and butterflies biodiversity indicators 7. Mini SASS Water quality monitoring 8. Erosion monitoring Social monitoring
The socio-economic impacts of the project are monitored. This takes the form of a repeat evaluation at intervals of two years of the factors considered in the social baseline studies carried out in 2007. The second evaluation is currently in process using a questionnaire survey amongst local communities. A schedule of all current and planned monitoring activities is available that provides a list of all activities, the monitoring procedure, its location, frequency and responsible staff member. The company has group management expertise and a sound track record in teak forestry and development, particularly through the sister company Kilombero Valley Teak Company (KVTC) in Tanzania. Many of the procedures and policies that have been proven and developed in that company have been transferred to ETC. South Sudan has only recently emerged from a prolonged civil war and one of the main challenges of the management team is to train the supervisors who mostly lack much formal education on the correct procedures and equip them fully to ensure that the prescribed processes are followed.
4. SOCIO-ECONOMIC AND ENVIRONMENTAL CONTEXT
4.1 Social aspects
Number of own workers 246
Number of contract workers 0
Minimum daily wage for agricultural/forestry workers 10.11 Sp
(US$4,6)
Infant mortality rates (under 5 years) (%) 8,2
Proportion of workers employed from the local population (%) 98
South Sudan is peopled by a number of groups, the largest of which is the Dinka, estimated to number more than 4 million residents out of the region's total population of 11million. Other tribes include the Shilluk, Nuer, Azande, Jo Luo, Acholi, and Lotuhu. While the lingua franca of the region is Juba Arabic, the language of government and education is English. The two most widely used African languages are Thuongjang (used by the Dinka) and Nuer. Religious persuasions are predominantly Christian and traditional belief systems. The Azande is the third largest nationality in South Sudan. They are found in Maridi, Yambio (where the FMUs are situated) and Tambura districts in the tropical rain forest belt of western Equatoria and Bahr el Ghazal (remnant of Gbudwe armies that went on the rampage in the area during the eighteenth century). The Azande are also found in DR Congo and Central African Republic; areas, which originally constituted part of the great Azande Kingdom destroyed by the Belgian, French, Mahdist and finally the British in the context of the European scramble for Africa. The Azande speak the Zande language. They are a Bantu group and their language bears a lot of similarities to the other Bantu languages. The Azande society is divided into the royal clans – the Avungara, centred on their great leader Gbudwe, his two sons Yambio and Tambura; and the commoners, most of who have been incorporated into the Azande through wars, conquest and assimilation. Azande settlements are solitary i.e. a household consisting of the man and his wife (or wives), nevertheless they ascribe to certain social norms and practices. The Azande circumcise their boys as a tradition. This is performed when the boy has reached the age of nineteen. There is no special occasion. The Azande don’t circumcise their girls.
The Azande land is a tropical forest area that enjoys high annual rainfall. This has rendered it a very high agricultural potential area. They engage in subsistence [due to long distances from markets] production of food crops mainly maize, cassava, telebun, yams, fruits: mangoes, citrus, pineapples, palm trees [from which they extract palm oil – ombiro], coffee, etc. They also have exotic and economically important hard wood trees such as mahogany and teak. The Azande engage in hunting [using traps, nets, and heavy spears] and fishing [in the streams] as part of their economic
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activities. In 1948 The Equatoria Project Board [EPB] was established to exploit the economic potential of the Zandeland. The Nzara agro-industrial complex was founded to gin and weave cloth, produce edible oil, soap and other produce from the cotton that the Azande people were encouraged to grow as a cash crop. This project helped monetise and link the Azande economy to other markets in South Sudan.
The HIV/Aids adult prevalence rate is officially stated as 1,4% (2007). However, sources at a hospital in Nzara put the figure locally in excess of 50%. Nationally it is estimated that 40% of the population live below the poverty line. The infrastructure in the Nzara county is limited with most infrastructure, such as buildings and services requiring reconstruction. Main roads in the area are passable in the dry season but passable only with four wheel drive vehicles in the wet season. The social impacts of the company’s activities are largely seen to be positive with the main social impact being the creation of employment opportunities where practically none currently exist. The majority of people are poor and are just settling down after a very long period of unrest. The demand for jobs is very high. The largest contribution the company can make in these circumstances is to create a sustainable system of employment. This positive view on the social impact of the company was strongly supported by the local missionary station.
4.2 Environmental aspects
A large majority of the Southern Sudanese rely directly on natural resources for food, water, and other benefits. Conserving the wildlife and the wild lands on which they depend directly benefits the region's population in terms of food security. An important statistic provided in the 2007 State of the World’s Forests report is an annual decline of 0.8% in the area of forest in Sudan. Several studies over many years have reported advancing desertification in the centre of the country and the decline in forest cover is most likely due to this phenomenon.
The native forest in Western Equatoria state is an extension of the Congo basin forests. However, this has been degraded first by an increasing local population engaging in shifting cultivation followed by British colonial agricultural projects on a large scale in the middle of the 20
th century.
The introduction of exotic species such as Lantana, Chromolaena and mango, exodus of the local population during the civil war, some to live in the forest, ingress of military who decimated the animal population, and most recently the return of the refugees after the Comprehensive Peace Agreement (CPA) to clear land once more for farming exacerbated the environmental situation. Current environmental issues in Sudan include uncontrolled wild fires, inadequate supplies of potable water; wildlife populations threatened by excessive hunting; soil erosion; desertification and periodic drought. All the expert reports single out uncontrolled wild fires as possibly the single most important environmental factor in the region. It is commonly accepted that miombo-type vegetation should ideally not burn more frequently than on a three year cycle, whilst large areas are currently burnt on an annual basis. Pressure on the environment as a source of additional food and non-wood forest products is severe, and results in environmental degradation through, amongst others, poaching as well as subsistence hunting. The combined effects of the civil war, famine and general lawlessness has gleaned the entire region of its larger mammals. Even cryptic small antelope such as duiker has become increasingly scarce as the hunting pressure for protein increases.
Man has been the most powerful and persistent factor that caused the deforestation and disturbance of Sudan natural ecosystems. The main human activities that are threatening the natural environment are unregulated cutting for timber and fuelwood, clearing of forestland for agriculture, overgrazing of livestock, burning and civil wars.
The protected areas in this ecoregion are few and widely dispersed. Unprotected patches of suitable but imminently threatened habitat remains scattered throughout this region.
4.3 Administration, Legislation and Guidelines
The legal system is based on English common law and Islamic law. The southern Sudan legal system is still developing under the CPA following the civil war. Islamic law does not apply to the southern states.
The 9 January 2005 signing of the CPA by the Sudan People’s Liberation Movement (SPLM) and the Government of Sudan brought an end to Africa’s longest running conflict. The CPA is at an
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advanced stage of implementation, and national elections are scheduled to be held between July and September 2009. The peace process, ongoing conflict in Darfur, and the effort it is going to take to complete all the outstanding issues of the CPA, are the most pressing and pertinent issues on Sudan’s political horizon. The parties to the CPA agreed on a government structure that established a Government of National Unity (GONU) and the autonomous Government of Southern Sudan (GOSS). The GONU is comprised of the members of the National Congress, SPLM, and other northern and southern political forces. The GOSS governs Southern Sudan, and provides a link with the GONU. The CPA establishes “one country, two systems” in which the GOSS and GONU essentially share roles and responsibilities. Southern Sudan is divided into ten states of which Western Equatoria is one. The Executive Branch of the State Government is headed by the Governor and is composed of the Governor, the Governor’s advisors, and the State Ministers. Governors are accountable to the President of Southern Sudan, while the State Ministers are accountable to the Governor.
Local government consists of the County, Payam, and Boma. A “Payam” is equivalent to a district. A “Boma” is the smallest unit of local government. Local government is charged with promoting self governance and enhancing the participation of people and communities in maintaining law and order and promoting democratic, transparent, and accountable government.
The Ministry of Environment, Wildlife Conservation, and Tourism (MEWCT) is the main GOSS ministry charged with conservation and environmental protection.
Normally, laws are a reflection of a country’s constitution, but as the New Sudan had no constitution yet, its laws had to be built on resolutions taken at the occasion of the SPLM Convention of 1994 which later become the charter of the movement. When on 16 May 1983, the second civil war erupted in the Sudan and the people of Southern Sudan took up arms against the national government in Khartoum, the leadership of the SPLM/A initiated the Punitive Law to regulate and govern the conduct of the armed forces. In 1984, a committee drafted the Penal and Discipline Law of the SPLA; - these laws remained in force until 1994. Ten years later, the laws were repealed through the 1994 SPLA Act; however, the SPLM/A leadership later on reinstated the 1984 laws except for their civilian provisions, applying now only to the military. In 2003, the 1984 Laws were repealed once more and replaced by the 2003 SPLA Act. It should be mentioned that in 1995 not less than 23 committees had been set up by the leadership of the SPLM, which were to concentrate on basic law, such as the Penal Code and Criminal and Civil Procedures. Eventually, there were 16 laws recommended by the convention to be drafted but after proof-reading, only 4 laws were published. In 2002, a law review committee was formed by the Chairman of the SPLM/A. It was headed by the Commissioner for Legal Affairs and Constitutional Development, and its members comprised of Army, Police, Prison and Wildlife commissions that reviewed 16 laws and drafted 7 new laws, bringing the total number of laws to 23. Today there are 22 laws applicable to Forestry, as well as the constitution of Southern Sudan and Forest Policy Framework. The Forest Policy framework has been submitted but not yet authorised.
The first draft of a new forestry policy was produced in June 2006 and has been under discussion since then. The policy is in line with best practice in sustainable forest management and is based on guiding principles that include sustainable development, poverty eradication, equity, and community involvement. The current draft includes commitment to community involvement in forest management and expansion of planted forests, and encourages private sector involvement in plantation expansion and management of the existing plantation resources. The Forests Act of 1989 is the law that still governs the management and conservation of forests in Sudan. This law was produced by the north, and is not in line with the new policy in the south. A new Forestry Act will be required to implement Southern Sudan’s new forestry policy. In terms of the agreement signed between the Government of Western Equatoria State, the Government of Southern Sudan and Equatoria Teak Company the concession will be managed in accordance and in compliance with the laws of South Sudan.
The forest management and regulatory institution is the Forestry Directorate (FD) under the GOSS Ministry of Agriculture and Forestry (MAF). The lead administration position is the Under Secretary for Forestry and the Director General for Forestry is the lead technical officer. Each of the ten States has its own Forest Department. The GOSS level FD is responsible for managing Central Forest Reserves and the State level Forest Departments are responsible for managing Provincial Forest Reserves. The GOSS level has other roles such as policy development, regulation, provision of technical oversight, and technical staff management.
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The following table lists the key national legislation, regulations, guidelines and codes of best practice that are relevant to forestry in the commercial, environmental and social sectors. This list does not purport to be comprehensive, but indicates information that is key to the forestry sector.
A. NATIONAL LEGISLATION
Forestry, Agriculture and Environment:
1. The Financial Institution Act of 2003
2. The Companies Act of 2003
3. Interpretation of Laws and General Provisions Act of 2003
4. Timber Utilization and Management Act of 2003
5. Institute for Developmental, Environmental Studies of 2003
6. The Investment Act of 2003
7. The Attorney General Chambers Act of 2003
8. The Forestry Commission Act, 2003
9. Wildlife Conservation and National Parks Act, 2003
10. The Investment Promotion Act of 2008
Cultural and social:
11. The High Judicial Council Act of 2003
12. The SPLA Act of 2003
13. Civil Procedure Act of 2003
14. Public Co-operation Act 0f 2003
15. The Code of Criminal Procedure Act of 2003
16. The Evidence Act of 2003
17. Cooperative Societies Act of 2003
18. Non Governmental Organisation Act of 2003
19. The Penal Code Act of 2003
20. The Prison Act of 2003
21. Passport and Immigration Act of 2003
22. The Telecommunication Corporation Act 2004
B. REGULATIONS PERTINENT TO FORESTRY RELATED TO AND EMERGING FROM NATIONAL LEGISLATION AND OTHER LEGISLATIVE INSTITUTIONS:
23. The Interim Constitution of Southern Sudan of 2005
24. Forest Policy Framework – submitted but not authorised.
C. SUDANESE INTERNATIONAL AGREEMENTS PERTINENT TO FORESTRY
25. Convention on Biological Diversity
26. Convention on the International Trade in Endangered Species (CITES)
27. International Labour Organisation (ILO)
D. LOCAL STANDARDS AND BEST OPERATING PRACTICES
28. N/A
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E. ILO RATIFICATIONS BY SUDAN
27 C2 Unemployment Convention, 1919
28 C19 Equality of Treatment (Accident Compensation) Convention, 1925
29 C26 Minimum Wage-Fixing Machinery Convention, 1928
30 C29 Forced Labour Convention, 1930
31 C81 Labour Inspection Convention, 1947
32 C95 Protection of Wages Convention, 1949
33 C98 Right to Organise and Collective Bargaining Convention, 1949
34 C100 Equal Remuneration Convention, 1951
35 C105 Abolition of Forced Labour Convention, 1957
36 C111 Discrimination (Employment and Occupation) Convention, 1958
37 C117 Social Policy (Basic Aims and Standards) Convention, 1962
38 C122 Employment Policy Convention, 1964
39 C138 Minimum Age Convention, 1973
40 C182 Worst Forms of Child Labour Convention, 1999
5. CHANGES IN MANAGEMENT, HARVESTING, SILVICULTURE AND MONITORING
The following table shows significant changes that took place in the management, monitoring, harvesting and regeneration practices of the certificate holder over the certificate period.
Description of Change Notes
SURVEILLANCE 1
SURVEILLANCE 2
SURVEILLANCE 3
SURVEILLANCE 4
6. PREPARATION FOR THE EVALUATION
6.1 Schedule
The Evaluation was preceded by a pre-evaluation by SGS QUALIFOR during 10-12 February 2009. This examined the management systems and identified any gaps that might preclude certification. Information gathered was used to plan the main evaluation. Key stakeholders were identified.
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6.2 Team
The table below shows the team that conducted the main evaluation and the independent specialist(s) that were selected to review the main evaluation report before certification is considered.
Evaluation Team Notes
Team Leader Has an M Sc in Forestry/Nature Conservation, 33 years experience in forestry, involved with the FSC process since 1995, speaks English and Afrikaans, qualified lead auditor since 2004 and lead trainer auditor since 2007.
Local Specialist Has a Diploma in Computer Skills, 3 years experience in State Administration (gender and HIV), speaks Azande, English and Arabic.
Trainee Auditor Has an M Sc in Integrated Forest Management, 3 years experience in natural forest management, speaks French, English and Portuguese.
Peer Reviewers Notes
Peer Reviewer 1 Has a Ph.D. in Applied Ecology), 15 years experience in forestry internationally, and currently works in academia.
Peer Reviewer 2 Has a Ph.D. in Forest Resources Management , 27 years experience in forestry nationally and currently works in academia.
6.3 Checklist Preparation
A checklist was prepared that consisted of the document listed below. This checklist was prepared by adapting the QUALIFOR generic forest management checklist. This adaptation included significant elaboration on especially verifiers and guidance, based on Sudanese legal requirements, and canvassing comments from stakeholders 4 weeks before the field evaluation. Although the draft checklist was sent out to everyone on the Sudan national stakeholder list (28), no comments were received. A copy of this checklist is available on the SGS Qualifor website, www.sgs.com/forestry.
Standard Used in Evaluation Effective Date Version Nr Changes to Standard
SGS Qualifor: Generic Forest Management Standard (AD33) adapted for Sudan
01/06/2009 AD 33-SD-01
6.4 Stakeholder notification
A wide range of stakeholders were contacted 4 weeks before the planned evaluation to inform them of the evaluation and ask for their views on relevant forest management issues, These included environmental interest groups, local government agencies, local community leaders and forestry authorities. The full list of stakeholders that were contacted is available from SGS. Responses received and comments from interviews are recorded under paragraph 13 of this Public Summary.
7. THE EVALUATION
The Main Evaluation was conducted in the steps outlined below.
7.1 Opening meeting
An opening meeting was held at Nzara, West Equatoria State. The scope of the evaluation was explained and schedules were determined. Record was kept of all persons that attended this meeting.
7.2 Document review
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A review of the main forest management documentation was conducted to evaluate the adequacy of coverage of the QUALIFOR Programme requirements. This involved examination of policies, management plans, systems, procedures, instructions and controls.
7.3 Sampling and Evaluation Approach
A detailed record of the following is available in section B of the evaluation report. This section does not form part of the public summary, but includes information on:
� Sampling methodology and rationale;
� FMUs included in the sample;
� Sites visited during the field evaluation; and
� Man-day allocation.
Two of the 5 FMUs were sampled. This was based on visiting Yabua FMU where all forest management activities currently take place, plus one of the other FMUs i.e. Nangodi. Thus 100 % of the areas where forest activities take place were sampled. A third FMU, Mbarizanga, was visited during the pre-assessment. The first 1,5 days were spent on document review, followed by field visits and stakeholder consultations. The team operated mostly as a unit, except on one day when it split into two to cover more stakeholders during the consultation phase. The sawmill at Nzara was also visited.
7.4 Field assessments
Field assessments aimed to determine how closely activities in the field complied with documented management systems and QUALIFOR Programme requirements. Interviews with staff, operators and contractors were conducted to determine their familiarity with and their application of policies, procedures and practices that are relevant to their activities. A carefully selected sample of sites was visited to evaluate whether practices met the required performance levels.
7.5 Stakeholder interviews
Meetings or telephone interviews were held with stakeholders as determined by the responses to notification letters and SGS discretion as to key stakeholders that should be interviewed. These aimed to:
� clarify any issues raised and the company’s responses to them;
� obtain additional information where necessary; and
� obtain the views of key stakeholders that did not respond to the written invitation sent out before the evaluation.
Nr of Interviews with Nr of Stakeholders contacted
NGOs Government Other
MAIN EVALUATION
68 3 8 18
SURVEILLANCE 1
SURVEILLANCE 2
SURVEILLANCE 3
SURVEILLANCE 4
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Responses received and comments from interviews are recorded under paragraph 13 of this Public Summary.
7.6 Summing up and closing meeting
At the conclusion of the field evaluation, findings were presented to company management at a closing meeting. Any areas of non-conformance with the QUALIFOR Programme were raised as one of two types of Corrective Action Request (CAR):
� Major CARs - which must be addressed and re-assessed before certification can proceed
� Minor CARs - which do not preclude certification, but must be addressed within an agreed time frame, and will be checked at the first surveillance visit
A record was kept of persons that attended this meeting.
8. EVALUATION RESULTS
Detailed evaluation findings are included in Section B of the evaluation report. This does not form part of the public summary. For each QUALIFOR requirement, these show the related findings, and any observations or corrective actions raised. The main issues are discussed below.
8.1 Findings related to the general QUALIFOR Programme
PRINCIPLE 1: COMPLIANCE WITH LAW AND FSC PRINCIPLES
Criterion 1.1 Respect for national and local laws and administrative requirements
Strengths
Weaknesses
Compliance The legislative system in South Sudan is still poorly developed and the company will conform to the ILO guidelines in respect of matters where legislation is absent or inadequate such as health and safety and labour matters. A procedure document is in place that provides for company lawyers to identify and regularly update those aspects of the legislation, regulations, treaties, conventions, regional and international laws applicable to South Sudan that have a legal implication on the company. Once a year management reviews the complete legal register to determine: any changes to the legal register, legal conformance level of the legal register, non conformances past and present, corrective actions, procedures, objectives and targets and effectiveness of procedures.
Criterion 1.2 Payment of legally prescribed fees, royalties, taxes and other charges
Strengths
Weaknesses
Compliance Full financial budgets for the three years 2009 – 2011 are available. These budgets provide for royalties, social contribution, other fees and duties. All payments are up to date.
Criterion 1.3 Respect for provisions of international agreements
Strengths
Weaknesses
Compliance The company is aware of the need to respect international agreements such as CITES and the ILO conventions. These aspects are also addressed in the company environmental policy where it is stated that e.g. rare, endangered and protected species or areas that have high biodiversity will be identified and protected from damage – actions have been taken to implement this. The company subscribes to the ILO guidelines and does not e.g. employ anyone younger than 18 years and the right to negotiate with the employer and freedom of association is respected. A number of company documents are available to provide guidance to employees on these subjects.
Criterion 1.4 Conflicts between laws and regulations, and the FSC P&C
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Strengths
Weaknesses
Compliance No conflicts between laws and regulations and the FSC P&C have been identified. This should be viewed in the context of the poorly developed legal environment in South Sudan.
Criterion 1.5 Protection of forests from illegal activities
Strengths
Weaknesses The boundaries of FMUs are not clearly marked and signposted to assist with the prevention of unauthorised activities. Observation 01 was raised.
Compliance A system is being developed in terms of which the local communities are involved in plantation security and fire prevention. A contract is entered into with the chief for the patrolling and security of designated areas. Areas are checked for poaching of timber, natural resources and animals. An incentive bonus system is in place with these communities in terms of which they lose income should unauthorized activities be detected. A no fire incident bonus also applies.
COF2009: Signposts were erected on the entrances to the FMUs. The boundary issues will be dealt with through the village contracts system that is established and will be more clear during the fire season when the villagers have established the firebreaks. Observation 01 was closed.
Criterion 1.6 Demonstration of a long-term commitment to the FSC P&C
Strengths
Weaknesses
Compliance The company has a publicly available environmental policy, signed by the CEO, stating, amongst others, that it will achieve FSC certification and will avoid uncertified wood from controversial sources entering its chain of custody. The environmental policy was explained at a formal stakeholder meeting and a copy of the policy is also displayed on the company notice board.
PRINCIPLE 2: TENURE AND USE RIGHTS AND RESPONSIBILITIES
Criterion 2.1 Demonstration of land tenure and forest use rights
Strengths
Weaknesses
Compliance A legal document is available that describes the concession over Yabua, Nangodi, Ringasi, Magaba and Mbarizanga FMUs. This is an extensive document that describes the land tenure and forest use rights in some detail. The concession is valid for a period of 32 years (equivalent to one rotation) with an option to extend it for a second full rotation. The Government supports the activities of the company and has not imposed constraints on the company that would impair its ability to comply with FSC standards.
Criterion 2.2 Local communities’ legal or customary tenure or use rights
Strengths
Weaknesses Some 100 subsistence settlements housing about 1 000 people are located on the natural forest part of Yabua FMU. These villagers have cleared areas for housing and cultivated fields. This situation resulted in the destruction of forests and has a negative effect on the integrity of the forest ecosystem. Minor CAR 08 was raised.
Compliance The concession agreement provides that the company shall, as far as is practical, have due regard for the wishes of the village communities living adjacent to the plantations and their customary dependence on the plantations with respect to forest products (including controlled access to fuel wood, house construction material, thatching grass and NTFPs) and must avoid any action that might prejudice the good relations between these communities, the company and the Government. The company adheres to the provisions in the concession agreement and local people have free access to the FMUs to exercise these rights.
Criterion 2.3 Disputes over tenure claims and use rights
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Strengths
Weaknesses
Compliance The company has developed a conflict resolution procedure that can be used by external parties to communicate complaints to the company, in such a manner that the complaint gets dealt with in a satisfactory and acceptable way for both parties. Two major stakeholder meetings have already been initiated by the company where opportunity was presented to raise any issues of concern. These meetings were fully minuted. No issues of conflict were raised and there are currently no disputes between local communities and the company. The Lords Resistance Army conflict that on occasion has spilled over into one of the FMUs is not over tenure claims and use rights and entirely limited to looting sprees by a few small groups of terrorists. This conflict is outside the company’s control and unfortunately still out of the control of Government too.
PRINCIPLE 3: INDIGENOUS PEOPLES’ RIGHTS
Criterion 3.1 Indigenous peoples’ control of forest management
Strengths
Weaknesses
Compliance The local Azande people consider themselves as South-Sudanese people. Tribal feeling amongst the local people, or self-identification as Indigenous People, a fundamental criterion presented in the ILO Convention 169, does not exist in this part of Sudan. No indigenous communities claim use rights to the forests on the FMU.
Criterion 3.2 Maintenance of indigenous peoples’ resources or tenure rights
Strengths
Weaknesses
Compliance Not applicable.
Criterion 3.3 Protection of sites of special cultural, ecological, economic or religious significance to indigenous peoples
Strengths
Weaknesses A survey of sites of special cultural, ecological, economic or religious significance has only been done for Yabua and Mbarizanga FMUs and only a limited number of these sites have been fully described. No survey has yet been undertaken for the remaining three FMUs. Minor CAR 09 was raised. A procedure document has been developed to identify, describe and map and protect such sites. However, this procedure is not fully implemented because management objectives have only been developed for two sites, whilst some 76 sites have been identified on Yabua FMU alone. Minor CAR 10 was raised.
Compliance A survey of sites of special cultural, ecological, economic or religious significance has been done for Yabua and Mbarizanga FMUs. Documentation is available and these sites are also indicated on maps. A process is under way to establish the GPS position of each site. By far the majority of sites identified are grave sites and the relevant stakeholders prefer that no identification or other steps be taken than to not interfere with the sites. A specific tool box talk document was also prepared that provides guidance to workers on how to treat these sites.
COF2009: All sites of special significance are mapped and GPS referenced. Details for the individual sites are kept on register and management prescriptions are described for all sites. Minor CAR 10 was closed.
Criterion 3.4 Compensation of indigenous peoples for the application of their traditional knowledge
Strengths
Weaknesses
Compliance No evidence was found of any traditional knowledge that has been commercially exploited.
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PRINCIPLE 4: COMMUNITY RELATIONS AND WORKERS RIGHTS
Criterion 4.1 Employment, training, and other services for local communities
Strengths
Weaknesses
Compliance The company is currently the largest employer of labour in the Nzara area. Company policy stipulates that preference must be given to local people for all positions for which they are qualified. Some ±98% of all workers is sourced from local communities, with only a few Ugandan citizens employed as drivers and technical staff. Only own employees are deployed and contractors are not normally used. Evidence of the training of local workers to meet the organisation’s long-staffing requirements is available such as IT training for office workers. Development of staff is largely based on on-the-job training. A proper CSI strategy and budget have been formulated. This document addresses aspects such as local community policy, identifies a number of projects, and provides for implementation and monitoring guidelines. A social fund structure has been set up as part of this strategy to support local infrastructure and facilities in the Nzara area. Communities are allowed to collect NTFPs within the FMUs, but hunting is not allowed. A comparative wage survey indicates that the company is paying about 4-5 % more than most industries in the region.
Criterion 4.2 Compliance with health and safety regulations
Strengths
Weaknesses Adequate PPE is only available for most members of the harvesting team, particularly the chain saw operators who were well equipped. All other teams had either very little (nose and mouth protection at the chemical weed control team) or no PPE at all. Minor CAR 11 was raised. Supervisors do not always ensure that PPE are consistently used at work sites with e.g. chain saw operators not using their eye visors during felling operations. A breakdown exists in the transfer of information on accidents between the field and the office. Both aspects formed part of the evidence for raising Major CAR M01 in 7.3. Little attempt has been made to periodically analyse drinking water for workers to determine their suitability for human consumption. Observation 02 was raised.
Compliance The company has a Health and Safety policy document that addresses aspects such as occupation health and safety policy, legal framework, codes of practice, risk assessments, working environment, medical examinations, training, emergencies, monitoring, health management, working conditions, policy implementation and review. This policy has been distributed to all employees, awareness training was given to them and health and safety topics are included in a documented set of toolbox talks that is used by supervisors to sensitise workers on a continuous basis. A senior manager has been appointed to oversee health and safety matters. Two formal training courses for chainsaw operators and first-aiders as well as a range of in-house training has been conducted on subjects such as chemical spraying, grader operator, silvicultural operations and conflict resolution for supervisors. Medical treatment for workers and their families is available through trained first-aiders and the local mission hospital. The company has developed and is busy implementing a strategy based on a public–private partnership approach against malaria based on using the mission hospital for monitoring and counselling, the WHO in Juba to provide the framework and funding, and private contractor teams to do the actual spraying of privately owned houses off
the FMU. The company provides the technical support (transport, spraying equipment) necessary for this programme.
COF2009: At all operations visited, equipment and PPE were in good condition and worn by all staff. Spraying teams also had nose and mouth protection. Spray cans were well taken care of and were free from any leaks. Minor CAR 11 was closed.
Criterion 4.3 Workers’ rights to organise and negotiate with employers
Strengths
Weaknesses
Compliance The Labour Relations policy of the company provides that the rights of workers to organise and voluntarily negotiate with their employers shall be guaranteed. A supervisor’s forum consisting of all 14 of the supervisors meet as required with the CEO to discuss issues raised by workers. A workers committee system is also in the process of being established with the election of five representatives already having taken place. A documented grievance
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procedure is available.
Criterion 4.4 Social impact evaluations and consultation
Strengths
Weaknesses
Compliance A social survey baseline was done at the inception of the project by a consultant. This baseline is currently being updated with a follow-up monitoring report planned every two years. The initial social impact study found that the social impacts of the company are largely positive with the main social impacts identified being the creation of employment opportunities. The main negative impacts are decreased access to land, and inadequate access to natural resources. The possible displacement of people is also seen as a major social and economic cost. Stakeholder consultations are done with Government authorities at a national level and at a county level. Full formal stakeholder meetings were conducted twice during 2008 and once in 2009. The meetings were well attended by a wide range of local community stakeholders and Government representatives. Assurances were given by the company to address the concerns raised.
Criterion 4.5 Resolution of grievances and settlement of compensation claims
Strengths
Weaknesses
Compliance The local community policy of the company provides for a mechanism to deal with disputes and states inter alia that when a dispute exists, no forestry activities shall take place in the disputed area without the agreement of the affected community and that the company will compensate local communities for any damage inadvertently caused to their customary resources or rights in the FMU. No evidence was found of a significant existing dispute between the company and local communities. A range of stakeholders all confirmed that the current relationship between the company and local communities is good.
PRINCIPLE 5: BENEFITS FROM THE FOREST
Criterion 5.1 Economic viability taking full environmental, social, and operational costs into account
Strengths
Weaknesses
Compliance Management aims to achieve break-even by about December 2010. Labour productivity is currently low for all tasks performed which is being addressed by implementing a bonus system based on task work. Task work is determined on a daily basis and workers have the opportunity to exceed it voluntarily and to receive extra money on top of their minimum wage. The task
system therefore can not result in an employee being paid below the minimum wage. An accelerated 10-year harvesting model has been compiled. The basis of this is to optimise the growing sites as the current growing stock is moribund and of poor quality. Hence a decision was made to clear-fell this stock over a 10 year period and replaces it with better genetic material. To overcome the volume shortfall that this will create in 10 years time, another tree resource of fast growing Eucalyptus will be established that will produce volumes to bridge this gap. This decision will enable better utilization of the growth site and optimize the returns on the investment. Optimization in this instance does not equal high growth rates, as the niche market targeted demands high quality material, which can only be achieved at relatively low growth rates. Management is keenly aware that they need to maintain a fine balance between good growth rates and timber quality features.
Criterion 5.2 Optimal use and local processing of forest products
Strengths
Weaknesses
Compliance The company processes all teak logs coming from either their own FMU or from outgrowers at the company sawmill in Nzara. The company plans to establish 700 ha of Eucalyptus plantations as an alternative species in order to supplement their shortage of teak timber within the next 10 years. The company studied the potential of introducing plantings of five native species but none of them has shown satisfactory potential. No NTFP is used by the
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company.
Criterion 5.3 Waste minimisation and avoidance of damage to forest resources
Strengths
Weaknesses Although the pre-harvest checklist indicated a good coverage of the main elements of harvest planning, very little of this was actually executed. During actual harvesting the felling direction is haphazard and inconsistent felling techniques are used with e.g. a proper felling hinge not used in all cases. Felling is also done too far in advance of the extraction operations, letting logs get too old before they are extracted to road-side. This aspect formed part of the evidence for raising Major CAR M01 in 7.3.
Compliance Teak as a spp is resilient against damage during harvesting operations and is also able to handle fires well. Felled trees are topped at 10 cm thin end diameter and the tops are left in-field. There is currently no use for the tops, but the company is considering charcoal production as one potential use for this material. Felled trees are debranched on site leaving a significant amount of organic material in the field. Harvesting only commenced over the last 2-3 weeks and no compartment is yet fully felled, making it difficult to assess the degree of waste. Current impressions are that there will be more than adequate organic material left in the stands after harvesting is completed.
Criterion 5.4 Forest management and the local economy
Strengths
Weaknesses
Compliance The company proposes to bring in Eucalyptus as a second crop in the medium term and plans to establish 700 ha of Eucalyptus plantations on degraded land. No NTFPs are currently utilised commercially, but some such as thatch and fuelwood are used by communities. The company is the sole processor of all logs from the plantations and its main impact on the local economy is via the creation of significant employment opportunities in an area where no other such opportunities exist.
Criterion 5.5 Maintenance of the value of forest services and resources
Strengths
Weaknesses
Compliance The protection of natural forests and their associated biodiversity, water yield from these areas and the conservation of the soil resource are seen as the main forest services that are provided by the FMUs. Soil conservation is particularly important in its role to enhance water quality in streams. Monitoring of selected streams is being done to assess the water quality of streams flowing through the FMUs. Initial results from this monitoring conclude that forest practices have a low to almost non-existent impact on water courses within the FMU. A high level stratification and classification was done of the natural forests to understand their composition better. Uncontrolled fires that are probably the single most important negative impact on the resource are being controlled through an active community patrol service and an incentive system.
Criterion 5.6 Harvest levels
Strengths
Weaknesses
Compliance A systematic sampling method was used for assessing the standing timber resource at the commissioning of the project. Timber inventories are done at 5 years of age and then prior to each thinning at 8, 13, and 18 years of age. Growth ring analysis indicated that the trees grew well for the first eight years, then came under pressure for a further two to four years after which the growth increment reduced significantly. The slow growth of these teak stands is fundamental to the high timber quality being achieved and which is an important reason for the keen market interest in the product. Due to the large stock of over-mature timber the company made a strategic decision that the current teak stock will be harvested over a10 year period and replaced with better genetic material. The immediate replanting of the harvested area is critically important due to the reliance on thinning stock for income over the remaining period of the management agreement. Harvest levels are scheduled using the Microforest forest planning system.
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PRINCIPLE 6: ENVIRONMENTAL IMPACT
Criterion 6.1 Environmental impacts evaluation
Strengths
Weaknesses The monitoring of the spread of alien species within the natural forests is assessed via a system of permanent sample plots. Four of these sample plots have been established within Yabua FMU. However, this programme is incomplete because photo-monitoring is proving difficult to use as a practical tool for assessing alien vegetation. No map of these sample plots is available and no direction of the photos is provided, making it difficult to ensure the integrity of the information. This was part of the evidence used for the raising of Minor CAR 12 in 6.9.2.
Compliance A number of specialist studies were first undertaken to achieve a baseline understanding of the current biodiversity, and to identify the potential impacts of the project and mitigation or optimisation measures that would be appropriate. Four main EIA for specific activities were then undertaken viz. for the sawmill site, the main camp, nursery and the plantations. The main impacts for these activities were classified into environmental, social and socio-economic impacts. Positive impacts included employment opportunities, training, improved health coverage, increased development and wealth, income from processing timber would remain within the area where the teak is grown rather than being earned abroad, community projects such as outgrowers and taungya and a reduction in hunting. Negative impacts included reduction in land available for farming and relocation of existing farms, involuntary relocation of residents, loss of biodiversity, water pollution and increased immigration to the area. Mitigating steps have been described for all the main impacts and a number of steps are being implemented such as regular communication with local communities, monitoring of stream water quality and instigating community projects such as taungya plantings. All this background information was synthesized into an environmental management plan where the main practical environmental problems were defined and mitigating measures prescribed. Procedures have been developed and implemented for an internal EIA system for site-disturbing activities.
Criterion 6.2 Protection of rare, threatened and endangered species
Strengths
Weaknesses The ETC Environmental Policy stipulates that “rare, endangered and protected species or areas that have high biodiversity will be identified and protected from damage.” Nevertheless, field interviews with workers and supervisors reveal a lack of knowledge about identification of such species and measures to protect them. This aspect formed part of the evidence for raising Major CAR M01 in 7.3. The natural forest areas on all FMUs are totally protected. The company established four Permanent Sampling Plots in natural forests to monitor overstorey and understorey development and natural regeneration. The PSPs are GPS recorded but no map showing their location on the FMU is available. Observation 03 was raised.
Compliance A number of botanical, faunal and butterfly surveys were conducted by specialist consultants. The environmental management plan contains a description of the various biota and lists of all the spp occurring on the FMU, indicating the RTE status of each. Some 11 bird spp are described as rare or CITES listed. Most of these spp are associated with evergreen forests and wetlands. The reason for their status is mostly related to their sensitivity to disturbance. The most important bird habitats in the FMUs are therefore the larger patches of evergreen forest, and the riverine areas. These are automatically excluded from planting, but warrants focused conservation management. There were no endangered or CITES listed mammals, reptiles, amphibians or butterflies recorded. The company maintains a no hunting policy. Participating villages are contracted in to assist the company with anti poaching patrols.
Criterion 6.3 Maintenance of ecological functions and values
Strengths
Weaknesses Although mitigating measures have been identified for various environmental impacts such as erosion, uncontrolled fires, poaching and the collection of NTFPs, many of these mitigating measures are yet to be fully implemented such as meaningful erosion control measures, control of invasive alien plant spp. and the effective control of wild fires. Minor CAR 16 was
raised.
Compliance The company made extensive use of specialists to obtain a better understanding of the natural ecosystem and how it functions. These studies included floristics, hydrology, soils, fauna, butterflies, etc. Most of the FMUs consist of an open broadleaved deciduous woodland or fairly
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wet savannah. The natural habitat is seriously modified by burning, cutting of trees and invasion of exotic plants. Mitigation measures include restoration measures such as a reduction of burning frequency, limiting fires to small areas at a time and controlling the spread of exotic species. A specialist hydrological study concluded that the current teak plantations have a negligible hydrological effect on surface and groundwater resources. The company does not do any harvesting of indigenous trees and no silvicultural management of the natural forest areas take place. A system of total protection is being followed.
Criterion 6.4 Protection of representative samples of existing ecosystems
Strengths
Weaknesses
Compliance Within any single locality the plantation does not occupy all the land because of the wide and open drainage lines and other unplanted areas (rocks and very shallow soils). Only some 19 % of the three main FMUs are used for timber production, and this figure goes down to 9 % for all five the FMUs. Two protected areas of 650 ha and 750 ha of very dense to closed canopy forest communities, have been identified on Mbarizanga as conservation areas, being representative of the least disturbed natural forests on the FMUs. These same two areas have also been recommended for classification as HCVFs.
Criterion 6.5 Protection against damage to soils, residual forest and water resources during operations
Strengths
Weaknesses Although the management plan and procedure documents prescribe various actions to address the poor condition of roads, very little of these actions have been implemented. Most roads are in a poor condition and some have become impassable. Properly constructed stream crossings are not always in place to allow access to major parts of the FMU that are currently inaccessible. Almost no road maintenance has yet been done on any FMU in terms of providing drainage structures to remove water from road surfaces. Many roads are overgrown and restrict vehicle access. No road management plan is in place to address this situation. Major CAR M02 was raised. Some compartments on Nangodi were planted too close to a stream and wetland with trees within 5 m from the water’s edge, as opposed to the 20 m specified in company procedures. No information on buffer zones is also displayed on plantation maps. Minor CAR 15 was raised in 10.2.3. Supervisors had no understanding how to deal with oil or chemical spills in-field. No equipment for the remedial action required in case of oil spillage was available at the planting sites. This aspect formed part of the evidence for raising Major CAR M01 in 7.3.
Compliance A complete environmental impact assessment was done during the inception of ETC. Environmental impacts were identified and mitigating measures prescribed. These include the effect of roads, felling and extraction on soil erosion and biodiversity. Written guidelines are thus available that identify sensitive forest operations and steps are prescribed to minimize their impacts.
COF2009: A road management plan was compiled and the actions prescribed in the plan were done. More equipment was purchased to ensure the continuous maintenance of the roads. There is now a grader, tipper truck and TLB available that are constantly working on the roads. Roads with bad erosion were closed. Major CAR M02 was closed.
Criterion 6.6 Chemical pest management
Strengths
Weaknesses The use of the herbicide Roundup is not recorded on a per hectare basis per year. Observation 04 was raised.
Compliance Company policy states that it will minimise its use of chemicals and chemicals will only be used as part of an integrated approach to problem management such as mechanical clearing and the use of the taungya system to grow agricultural crops in-between young trees, thus reducing the need for chemical weed control operations. The list of pesticides used in the company is up-to-date. The company only uses Roundup (glyphosate) in the plantation for weed control and uses Aqua Matrix as fertilizer in the plantation. No prohibited chemicals are used on the FMU. The company has trained their chemical team (workers and supervisors) on chemical use and awareness and the correct handling and storage procedures are followed at the chemical store.
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Criterion 6.7 Use and disposal of chemicals, containers, liquid and solid non-organic wastes
Strengths
Weaknesses
Compliance Appropriate procedures for dealing with general waste and hazardous waste are available and implemented. Plastic bags and other containers are available at work sites for the collection of general waste. These are periodically removed and emptied at the central refuse dump in Nzara village. Recycling was investigated but very limited opportunities exist locally with e.g. old oils being used for various lubrication purposes in the sawmill or on chain saws.
Criterion 6.8 Use of biological control agents and genetically modified organisms
Strengths
Weaknesses
Compliance No biological control agents or genetically modified organisms are in use by the company.
Criterion 6.9 The use of exotic species
Strengths
Weaknesses No monitoring of the spread of teak natural regeneration outside compartments is in place and very limited actual control of such regeneration has yet been done. Minor CAR 12 was raised.
Compliance Teak Tectona grandis and Cassia siamea are default spp since plantations establishment started in ± 1948 and form the core of the resource that is incorporated into the concession agreement. Teak is a native spp from South East Asia that has been cultivated for more than 100 years in various parts of the world as a plantation spp. It is not known to cause significant adverse ecological impacts although some natural regeneration does occur.
COF2009: Permanent sampling plots are established and the extent of Teak spread was monitored as a baseline. The plantations were neglected for more than 30 years and the spread of teak beyond the boundary was found not to be more than 50 meters and at very sparse occurrences. Minor CAR 12 was closed.
Criterion 6.10 Forest conversion to plantations or non-forest land uses
Strengths
Weaknesses
Compliance No forest conversion is done by the company at the moment. In order to address their anticipated shortage of teak timber the company plans to establish 700 ha of new Eucalyptus plantations on degraded land. Before starting this programme, the management team will conduct an Environmental Impact Assessment on these 700 ha to ensure that no forest conversion will occur.
PRINCIPLE 7: MANAGEMENT PLAN
Criterion 7.1 Management plan requirements
Strengths
Weaknesses Plantation maps on a 1:10 000 scale are available which provide information on FMU boundaries, rivers, roads, compartment boundaries with compartment numbers, plantation spp, infrastructure such as air strip, camp and nursery. However, the non plantation parts of FMUs have not been classified and mapped, and are currently indicated as one land-use type only. This does not reflect the reality on the ground and reduces the usefulness of maps to e.g. provide information for forest conservation measures. Minor CAR 13 was raised.
Compliance A detailed management plan is available for the company that covers all the subjects required ito the standard (either in the management plan itself or associated documents) such as management objectives, the social-economic environment, the basic resource information, including descriptions of the natural environment (topography, hydrology, climate, geology, soils, flora & fauna), plantation and natural forest resources. The boundaries of the FMUs are
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described in detail and plantation maps are available for each FMU. Corporate social responsibility, inventories, yield regulation, road planning and maintenance, silvicultural and harvesting systems and practices, environmental conservation measures including buffer zones, protection of biodiversity, natural forests, soil and water resources are described. Monitoring and research is also addressed as well as forest protection, NTFPs, marketing and management information systems. The plan is updated annually to include updated information and plans for the following year. An annual plan of operations is also prepared that consists of a scheduling of all field activities on a monthly basis, indicating planned work vs actual achieved.
Criterion 7.2 Management plan revision
Strengths
Weaknesses
Compliance The Forest Manager has been tasked in writing to update the forest management plan on an annual basis. The first revision is scheduled for 2010. The management team depends on information on the internet as well as their contacts with a range of specialist consultants to keep them updated on the latest scientific and technical developments. Work procedures are largely adapted from those of a sister company in Tanzania that is ISO 14001 and TLTV certified – all procedures are drawn up to reflect the best available knowledge.
Criterion 7.3 Training and supervision of forest workers
Strengths
Weaknesses Numerous examples were found that indicated a lack of technical / supervisory / management training across all levels of staff that, coupled to inadequate supervision, resulted in low work performance such as poor harvest planning and execution, a break down of information flow between operations and the admin office, supervisors that were unaware of the procedures to handle oil spillages, unaware of RTE spp, unaware of sites of special significance, showed inadequate safety awareness or do not ensure acceptable sanitary procedures in-field.
All the above non-conformances have as their root cause a lack of training and adequate supervision. Management had a skills needs analysis matrix compiled, but this was not used to compile a proper long term training plan, scheduling specific training for specific individuals, nor has such training plan been implemented. A practical internal auditing system is also not yet effectively implemented to ensure that supervision is of an acceptable standard. Major CAR M01 was raised.
Compliance A skills needs analysis matrix has been compiled that identifies the range of skills for which training is needed by employees. Two specific training courses have been held on chainsaw operators and first aid and certificates were issued to participants. Besides these formal training courses a range of in-house training has been conducted on subjects such as chemical spraying, grader operator, silvicultural operations and conflict resolution for supervisors.
COF 2009: Training requirements were done for the remainder of the year July 2009 – December 2009. Several in-house training modules were identified and were all done. The training was focussed on the operational procedures for the specific tasks. Professional training was given by an eternal training group for selected requirements. These included Introduction to Principles of Supervision, Silviculture and Harvesting. The training helped to identify the potential for leadership development training and to focus efforts on supervisors that had shown real potential. For most of the workforce, forestry practices are new concepts and they are adapting well to the newfound skills and training they received. Supervision has improved and the company has embarked on a system of continuously improving on the quality of supervision through training and operational controls. In relation to the specific objective evidence raised the following is reported. Many of the issues listed like awareness of RTE species, ASI sites, sanitation and incident reporting etc were all specific modules on which training was done. Major CAR M01 was closed.
Criterion 7.4 Public availability of the management plan elements
Strengths
Weaknesses
Compliance The full management plan is publicly available at the company offices upon request. Management indicated that work on a company website has started and that a summary of the
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management plan will be put on such website.
PRINCIPLE 8: MONITORING AND EVALUATION
Criterion 8.1 Frequency, intensity and consistency of monitoring
Strengths
Weaknesses
Compliance A schedule of all current and planned monitoring activities is available that provides a list of all activities, the monitoring procedure, its location, frequency and responsible staff member. The activities include inventories to monitor plantation growing stock, Permanent Sampling Plots in plantations to monitor growth dynamics, operational monitoring such as harvesting impacts, erosion monitoring using steel erosion pegs, PSPs to monitor growth dynamics and regeneration in natural forests, birds and butterflies biodiversity indicators and mini SASS water quality monitoring. Although in the initial stages of development, a number of detailed reports are already available on the results of specific monitoring programmes such as reports on mini-SASS monitoring of water quality, a report on the results of PSP monitoring of tree increment and regeneration studies in natural forests, bird, butterfly, small mammal and reptile baseline surveys, and a 2
nd questionnaire survey to determine social impacts is under way.
Criterion 8.2 Research and data collection for monitoring
Strengths
Weaknesses Management is able to show operational itemised expenditure on a monthly basis, but little information on activity costs, and none on productivity and efficiency of forest management activities are available and none are incorporated into plans. Minor CAR 14 was raised.
Compliance A timber resource inventory was done on a 5-10% sample intensity for assessing the standing timber volumes at the commissioning of the project. Timber inventories are done at 5 years of age and thereafter a year before the next thinning. Both mapping and inventory data is available in different report formats. The company has developed a post harvest checklist verifying if the felling operations have respected erosion sites, site of special interest, the size and quality of the trees felled, if all material have been extracted, the site left clean of rubbish, oil spillage, etc. The checklist also includes a summary of log classes that were harvested. The second social survey is currently in process and is based on a questionnaire survey amongst local communities.
Criterion 8.3 Chain of custody
Strengths
Weaknesses
Compliance All logs are marked on road-side with the compartment number, length and diameter on the thin end of the log. Every log is recorded onto a tally sheet indicating its length, thin end diameter and compartment number. A colour coding system is used to clearly identify the origin of the logs, red chalk for the outgrowers and blue for ETC logs. Logs are taken by company transport directly from the compartment to the log yard at the sawmill. At the log yard there are designated areas for logs originating from company FMUs and those from outgrowers i.e. controlled wood and certified wood is kept clearly separated. The origin of each log can be precisely determined through the compartment number or controlled wood supplier number that is put on the thin end of each log. A vehicle monitoring form is kept that records the driver’s name, date, vehicle registration, time of off-loading, origin of the logs and number of logs. Once logs have been off-loaded at the log yard the load is again tallied for log length, diameter and grade. Staff has instructions not to transport any unmarked logs.
Criterion 8.4 Incorporation of monitoring results into the management plan
Strengths
Weaknesses
Compliance All monitoring activities are still too recent to be incorporated into planning. Only analysed data from mini-SASS monitoring are available and the results show that no changes need to be incorporated into planning. The social survey is the next monitoring activity that will provide a second round of results and which may produce results that can be considered during planning and management activities – the survey is in process and results should be available
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soon. The next revision of the management plan is due in 2010 when some monitoring results should be available for incorporation.
Criterion 8.5 Publicly available summary of monitoring
Strengths
Weaknesses
Compliance Since monitoring has only recently started, it is not possible for the company to produce a publicly available summary of its monitoring activities. Following the data analysis of mini-SASS monitoring of water quality, the commissioner of Nzara has been contacted so that the company could share those results which can be considered of public interest. All existing results from the monitoring programme are publicly available upon request at the company offices.
PRINCIPLE 9: HIGH CONSERVATION VALUE FORESTS
Criterion 9.1 Evaluation to determine high conservation value attributes
Strengths
Weaknesses Although an evaluation for the occurrence of HCVFs has been done and two such areas have been recommended on Mbarizanga, there has been no stakeholder consultation, either at the scientific or local community level, to substantiate and support this recommendation. Minor CAR 04 was raised. Since a further three Minor CARs were raised on aspects related to HCVFs (see Minor CARs 05, 06 and 07), Major CAR M03 was raised due to the failure to ensure adequate compliance with FSC Principle 9.
Compliance The company has contracted a consultant to identify if any HCVF is occurring within the FMU, who has produced a report comprising some background, motivation for the recommendation, floristic descriptions, a map and scientific references. The result of this assessment is the identification of two large conservation areas in the Mbarizanga FMU that could fall into the HCV 5 type – forest areas fundamental to meeting basic needs of local communities. The company plans to link these two HCVFs with a corridor in order to facilitate the restoration of the integrity of the ecosystem and the movement of wildlife between them.
COF 2009: An external consultant was used to assess the FMU for HCVFs and this was verified with another external consultant. The Commissioner and the Director of forestry and the local traditional leader were consulted in joint management committees. Access to the forests is now secured and the rest of the stakeholder consultation process is on track. Minor CAR 04 was closed. Since Minor CARs 04, 05 and 06 were closed Major CAR M03 was thus closed.
Criterion 9.2 Consultation process
Strengths
Weaknesses No management prescriptions are available for the two areas that have been recommended as HCVFs. Minor CAR 05 was raised. The potential HCVFs have been recommended on the basis of forest areas fundamental to meeting basic needs of local communities. However, no effort has yet been made to establish a co-management agreement with the local communities, nor have there been joint analyses and decision-making with them regarding the management of the HCVFs. Minor CAR 06 was raised.
Compliance No compliance was achieved.
COF 2009: With the help of the external experts the baseline conservation values were determined and some management prescriptions were defined such as the control of alien plants, monitoring and better access. Achievements with regard to the prescriptions are on track. Minor CAR 05 was closed. The local chiefs and the local government structures were included in a committee that was established to inter alia discuss HCVF issues. Monthly meetings are held and minutes are available. Minor CAR 06 was closed.
Criterion 9.3 Measures to maintain and enhance high conservation value attributes
Strengths
Weaknesses The HCVF report states that the forests have the potential to meet most of the basic needs of local communities, provided that the area is managed along sound conservation principles.
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However, no further evidence is provided to substantiate this statement – see Minor CAR 04 in 9.1.1. Specific measures to enhance the HCVF features have not been formulated yet – see Minor CAR 05 in 9.2.1. No summary of the management plan is yet available and the full management plan that is publicly available does not contain information on HCVFs and the measures to ensure their maintenance. Minor CAR 07 was raised.
Compliance The identification of these HCVFs is based on being forest areas fundamental to meeting basic needs of local communities only. Their biological values were not judged to be sufficient to warrant classification as HCVFs. Nonetheless, a policy of total protection will be followed and an attempt will be made to link the two areas thus promoting natural dispersal and movement patterns. The biological features of the proposed HCVFs are described in the report on this subject. In the southern part of Mbarizanga FMU especially, fairly large areas of dense forests still exist. This vegetation unit is most likely the closest resemblance of what the vegetation in most of the area should be. The report provides a floristic and structural description of these forests.
Criterion 9.4 Monitoring to assess effectiveness
Strengths
Weaknesses
Compliance A study was commissioned to establish a series of PSPs in natural forests, including in the two proposed HCVFs. These PSP will be used to monitor overstorey and understorey development via photo monitoring, biodiversity (via Shannon-Weiner and Simpson biodiversity index calculation), DBH distribution and natural regeneration. Although the establishment of PSP’s in the Mbarizanga forests was considered to be the most important, the area was however inaccessible due to security issues with the presence of the Lord’s Resistance Army in the area at the time. The enumeration team was therefore trained to establish plots in Mbarizanga once the situation has stabilized. Management is confident that these PSPs will be established within the next two months. The monitoring frequency is defined as every five years. The company has an active network of specialist consultants who ensures that the latest information in this field is incorporated into their reports that are used as the basis for forest conservation planning.
PRINCIPLE 10: PLANTATIONS
Criterion 10.1 Statement of objectives in the management plan
Strengths
Weaknesses
Compliance The management objectives of the company are to implement management procedures that will ensure the long term sustainability of the forest while allowing for local utilisation of the forest resource, adding value to harvested resource, securing income for the country and local communities, developing local industries and services and reducing pressure on other natural forest in the area. At this point the management team is able to demonstrate the achievement of four of the five management objectives through local processing of the resource into a high value export product, replanting with improved genetic material, employing almost only local people and stimulating the local economy. However, the company has not yet been able to reduce the pressure on other natural forests in the area. These achievements are considered to be significant for such a young company.
Criterion 10.2 Plantation design and layout
Strengths
Weaknesses Buffer zones along water courses do not always comply with company guidelines. Some compartments were planted too close to a stream and wetland with trees within 5 m from the water’s edge, as opposed to the 20 m specified in company procedures. No information on buffer zones is also displayed on plantation maps. Minor CAR 15 was raised. The non plantation part of FMUs has not been classified and mapped, and is currently indicated as one land-use type only. This does not reflect the reality on the ground and reduces the usefulness of maps to e.g. provide information for forest conservation measures. Minor CAR 13 was raised in 7.1.10.
Compliance The current plantation design and lay-out is a legacy of the historical situation (most of the existing compartments are more than 35 years of age) that the present management can do
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little about. The fact that the plantation spp is a broad-leaved tree makes for less contrast with the surrounding natural vegetation and allows a degree of blending. Due to a lack of Sudanese legislation concerning buffer zones along water courses, the company developed its own procedure ensuring that buffer zones are maintained along water courses. This procedure stipulates that where areas border onto permanently wet zones, rivers and wetlands a buffer zone of 20 m must be created with a further 10 m as a road reserve. Some areas containing plantation teak were initially established closer than this distance. A process of phasing out must be followed as these compartments are harvested. The HCVF report also presents the desirability to create a corridor between the two conservation areas. This aspect will be addressed in the forest management plan for the HCVFs that is in the process of compilation.
Criterion 10.3 Diversity in composition
Strengths
Weaknesses
Compliance Only some 9% of the total area of all five FMUs is covered by plantations. The rest of the concession i.e. 91% is covered by mostly natural forests or degraded forest areas with a high biodiversity of tree spp. Only two plantation spp are currently used i.e. teak Tectona grandis and Cassia siamea. Management intends to introduce Eucalyptus (probably E camaldulensis) as a third spp. Five Malaysian clones of Tectona grandis have also been obtained and will be used in future regeneration plantings. The management plan stipulates that the company will not clearfell contiguous areas larger than 100 ha on flat terrain and 50 ha on steep terrain in one season.
Criterion 10.4 Species selection
Strengths
Weaknesses
Compliance Teak Tectona grandis and Cassia siamea are default spp since plantation establishment started in ± 1948 and form the core of the resource that is incorporated into the concession agreement. The company does not have a choice in their type of timber resource. The company has studied the potential of introducing plantings of five native species i.e. Afzelia africana, Albizia zygia, Chlorophora excelsa, Khaya grandifolia and Anogeissus leiocarpus. None of these five species has shown satisfactory potential.
Criterion 10.5 Restoration of natural forest
Strengths
Weaknesses
Compliance The majority of the FMUs are covered by either plantations (9%) or by natural forests (most of the balance). The natural forests will receive total protection from the company. The vast majority of the FMU is therefore already covered by natural forests. Some areas have been seriously invaded by invasive exotic spp such as Lantana camara and Chromolaena; and control over wild fires, as well as the systematic eradication of these alien plant spp, will play an important role in assisting with the restoration of natural forests.
Criterion 10.6 Impacts on soil and water
Strengths
Weaknesses
Compliance A specialist study concluded that the impact of teak plantations on soils is highly localised and very site-specific, primarily due to their very limited extent and scattered locations. One of the main problems is erosion, which is common in teak plantations due to the rather poor soil surface cover. Management identified that fire is the major cause of soil erosion, with the litter cover being burnt almost annually and hence increasing the risk of runoff erosion and loss of nutrients. The company introduced a new programme for fire control that actively involves the local communities. Such an agreement has been signed for one of the FMUs and a second contract will be signed before the end of August 2009. Management is confident that since they have started with their active fire prevention policies, a significant reduction of fires within Yabua FMU has been noticed.
A specialist hydrological study concluded that the current teak plantations have a negligible
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hydrological effect on surface and groundwater resources at the scale of drainage basins (on a scale of hundreds of square kilometres), and these effects are most probably not detectable. The potential effects of a considerably expanded area of teak plantations have also been considered and are similarly expected to be of minor significance.
Criterion 10.7 Pests and diseases
Strengths
Weaknesses
Compliance The company Silviculture Self Assessment Programme identifies an exhaustive list of pests and diseases including the symptoms to assist with the identification of the problem. A remedial action is suggested for each of these pest and disease. The forestry manager has experience in teak plantation management, and is able to check for pest and disease incidents on a daily basis. The company is in the process of finalising a contract with a specialist tree pathology group to ensure that a specialist in teak pests and diseases visits the FMUs every 2
nd year to detect any problems due to pest or disease pathogens.
A Fire Management Plan is available and updated annually. All areas to be protected through the burning and constructing of fire breaks are described. Communication and resources are listed and fire orders have been formalised. The company has also recently introduced a new fire control programme that consists of actively involving local communities in fire prevention. It established an incentive system based on the number of fires occurring within the FMUs. This fire prevention concept involving local communities is relatively new and hence the success of it has not yet been monitored and documented. However, the management team is confident that since they have started with their active fire prevention policies, a significant reduction of fires within Yabua FMU has been noticed.
Criterion 10.8 Monitoring of impacts, species testing and tenure rights
Strengths
Weaknesses Limited spreading of natural regeneration of the plantation spp Tectona grandis has been observed along some compartment boundaries. No monitoring of the spread of teak natural regeneration outside compartments is in place and very limited actual control of such regeneration has yet been done. Minor CAR 12 was raised in 6.9.2.
Compliance Teak Tectona grandis is a native spp from South East Asia that has been cultivated for more than 100 years in various parts of the world as a plantation spp. It is not known to cause significant adverse ecological impacts.
Criterion 10.9 Plantations established in areas converted from natural forests after November 1994
Strengths
Weaknesses
Compliance The company is able to provide evidence that the plantations it is managing have been established 35 - 60 years ago with the first plantings done in ± 1948. A dendrochronological study has been done in order to determine the exact age of these teaks, showing the teak trees to be between 35 - 50 years old.
9. CERTIFICATION DECISION
SGS considers that Equatoria Teak Company’s forest management of its teak forests, in the vicinity of Nzara, West Equatoria State, South Sudan, can be certified as:
i. There are no outstanding Major Corrective Action Requests
ii. The outstanding Minor Corrective Action Requests do not preclude certification, but Equatoria Teak Company is required to take the agreed actions before 1 March 2010. These will be verified by SGS QUALIFOR at the first surveillance to be carried out about 6 months from the date of the issuance of the certificate. If satisfactory actions have been taken, the CARs will be ‘closed out’; otherwise, Minor CARs will be raised to Major CARs.
AD 36A-08 Page 36 of 48
iii. The management system, if implemented as described, is capable of ensuring that all of the requirements of the applicable standard(s) are met over the whole forest area covered by the scope of the evaluation;
iv. The certificate holder has demonstrated, subject to the specified corrective actions, that the described system of management is being implemented consistently over the whole forest area covered by the scope of the certificate.
10. MAINTENANCE OF CERTIFICATION
During the surveillance evaluation, it is assessed if there is continuing compliance with the requirements of the Qualifor Programme. Any areas of non-conformance with the QUALIFOR Programme are raised as one of two types of Corrective Action Request (CAR):
01. Major CARs - which must be addressed and closed out urgently with an agreed short time frame since the organisation is already a QUALIFOR certified organisation. Failure to close out within the agreed time frame can lead to suspension of the certificate.
02. Minor CARs - which must be addressed within an agreed time frame, and will normally be checked at the next surveillance visit
The full record of CARs raised over the certification period is listed under section 11 below.
The table below provides a progressive summary of findings for each surveillance. A complete record of observations demonstrating compliance or non-compliance with each criterion of the Forest Stewardship Standard is contained in a separate document that does not form part of the public summary.
MAIN EVALUATION
Issues that were hard to assess
The activities of the Lords Resistance Army (a recognised terrorist organisation) on one of the FMUs on occasion were initially a cause of concern. However, through interaction with various stakeholders it became clear that this is a diminishing situation and more importantly, it has no bearing on land tenure or use rights. The situation is also completely outside the control of either the company and mostly the Government too.
Number of CARs raised 3 New Major CARs and 12 Minor CARs were raised.
COF
Issues that were hard to assess
The problems relating access to some of the reserves were overcome by cooperation with government. The audit team was able to access the area with support from government forces.
Number of CARs closed 9 Outstanding CARs were closed.
Nr of CARs remaining open 6 Outstanding CARs from previous evaluations were not closed.
New CARs raised 0 New Major CARs and 0 Minor CARs were raised.
SURVEILLANCE 1
Issues that were hard to assess
Number of CARs closed Outstanding CARs were closed.
Nr of CARs remaining open Outstanding CARs from previous evaluations were not closed.
New CARs raised New Major CARs and Minor CARs were raised.
Certification Decision The forest management of the forests of remains certified as:
� The management system is capable of ensuring that all of the requirements of the applicable standard(s) are met over the whole forest area covered by the scope of the evaluation; and
� The certificate holder has demonstrated, subject to the specified corrective actions, that the described system of management is being implemented
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consistently over the whole forest area covered by the scope of the certificate.
SURVEILLANCE 2
Issues that were hard to assess
Number of CARs closed
Nr of CARs remaining open
Nr of New CARs raised
Certification Decision
SURVEILLANCE 3
Issues that were hard to assess
Number of CARs closed
Nr of CARs remaining open
Nr of New CARs raised
Certification Decision
SURVEILLANCE 4
Issues that were hard to assess
Number of CARs closed
Nr of CARs remaining open
Nr of New CARs raised
Certification Decision
11. RECORD OF CORRECTIVE ACTION REQUESTS (CARS)
CAR # Indicator CAR Detail
Date Recorded>
12/07/2009 Due Date> 11/01/2010 Date Closed> 14/9/2009
Non-Conformance:
Forest workers have not received adequate training and supervision to ensure proper implementation of the management plan.
M01 7.3
Objective Evidence:
AD 36A-08 Page 38 of 48
CAR # Indicator CAR Detail
Numerous examples were found that indicated a lack of technical / supervisory / management training across all levels of staff that, coupled to inadequate supervision, resulted in low work performance such as:
1. Both harvest planning and execution showed a lack of skills and supervision. Although the pre-harvest checklist indicated a good coverage of the main elements of harvest planning, very little of this was actually executed. During actual harvesting the felling direction was haphazard and inconsistent felling techniques were used with e.g. a proper felling hinge not used in all cases. Felling was also done too far in advance of the extraction operations, letting logs get too old before they were extracted to road-side.
2. Although incident registers are kept at most work sites, both supervisors and management do not follow up on this, resulting in a breakdown of information flow to company offices. Management thus do not track incident profiles or act upon them.
3. Supervisors had no understanding how to deal with oil or chemical spills in-field.
4. Supervisors had no awareness of RTE spp and how this may relate to their work.
5. Supervisors and workers have received no guidance on acceptable sanitary procedures in-field.
6. Supervisors do not ensure that PPE are always used at work sites with e.g. chain saw operators not using their eye visors during felling operations.
7. Some supervisors had no awareness of sites of special significance.
All the above non-conformances have as their root cause a lack of training and adequate supervision. Management had a skills needs analysis matrix compiled, but this was not used to compile a proper long term training plan, scheduling specific training for specific individuals, nor has such training plan been implemented. A practical internal auditing system is also not yet effectively implemented to ensure that supervision is of an acceptable standard.
Close-out evidence:
AD 36A-08 Page 39 of 48
CAR # Indicator CAR Detail
The root cause to all the above mentioned issues are captured as a lack of training and inadequate supervision. Training requirements were done for the remainder of the year July 2009 – December 2009. Several in-house training modules were identified and were all done. The training was done on the operational procedures for the specific tasks. Professional training was given for selected requirements. These are: Introduction to Principles of supervision, Silviculture, & Harvesting. These courses were completed before the audit. It was done by external forestry training group: Lottenburg Edu-farm. The training helped to identify the potential for leadership development training and to focus efforts on supervisors that had shown real potential. For most of the workforce, forestry practices are new concepts and they are adapting well to the newfound skills and training they received. Supervision has improved and the company has embarked on a system of continuously improving on the quality of supervision through training and operational controls. In relation to the specific objective evidence raised the following is reported.
Production is limited by the mill intake. The company has established the production rate of 60 m
3 and the field operation is adjusted to that, The production is also not
continuous as the operations do not allow for it and operations are started and stopped as required. There is a strategic plan in place whereby an accelerated felling regime will be applied to get plantations back on a managed rotation regime. That is accepted as a measure to enhance the sustainability of the project. Issues relating to felling techniques, Etc. were all addressed during the comprehensive training program that was done.
Many of the issues listed like RTE species, ASI sites, sanitation and incident reporting etc were all specific modules on which training was done. Reports were also followed through and issues raised in field like the length of the guide-bar and the round file sizes were recorded in the office and acted upon.
Date Recorded>
12/07/2009 Due Date> 11/01/2010 Date Closed> 14/9/2009
Non-Conformance:
Guidelines developed for environmentally sensitive operations are not always implemented during operations and planning.
Objective Evidence:
Although the management plan prescribes various actions to address the poor condition of roads, very little of these actions have been implemented. Most roads are in a poor condition and at least one road (Nangodi C3/C4) has degenerated into an erosion gulley and has become impassable. Properly constructed stream crossings are not in place on e.g. Nangodi to allow access to major parts of the FMU that are currently inaccessible. Almost no road maintenance has yet been done in terms of providing drainage structures to remove water from road surfaces. Many roads are overgrown and restrict vehicle access. No road management plan is in place to address this situation.
Close-out evidence:
M02 6.5.2
A road management plan has been compiled and the actions prescribed in this plan are being executed. More equipment was purchased to ensure the continuous maintenance of the roads. There is a grader, tipper truck and TLB available that are constantly working on the roads. Roads with bad erosion were closed. Major effort went into the upgrading of the road system on Nangondi and all the shortcomings identified during the main assessment have been rectified. The general road network on Yabua, where virtually all current operations are happening, is of a acceptable standard. A project has been initiated to improve access to and the quality of the road network on Mborizanga. No activities are currently taking place on the remaining two FMUs. However, these two FMUs cover a planted area of 41 ha only and has little meaningful impact on the operations of the company as a whole. The road network of the company is considered to be of an acceptable standard and shortcomings that were identified earlier, have been adequately addressed.
Date Recorded>
12/07/2009 Due Date> 11/01/2010 Date
Closed> 14/9/2009 M03 9
Non-Conformance:
AD 36A-08 Page 40 of 48
CAR # Indicator CAR Detail
Failure to ensure adequate compliance with FSC Principle 9.
Objective Evidence:
See Minor CARs 04-07.
Close-out evidence:
Minor CARs 04, 05 & 06 were closed during the CoF visit and is sufficient to close this major CAR M03.
Date Recorded>
12/07/2009 Due Date> 1
st
surveillance Date
Closed> 14/9/2009
Non-Conformance:
The FMU has not been adequately assessed for HCVF attributes in consultation with conservation organisations, regulatory authorities and other local and national stakeholders.
Objective Evidence:
An evaluation for the occurrence of HCVFs has been done and two such areas have been recommended on Mbarizanga. However, there has been no stakeholder consultation, either at the scientific or local community level, to substantiate and support this recommendation.
Close-out evidence:
04 9.1.1
External experts were consulted in establishing the Conservation Values of the forest. Due to the security situation in this part of the country the local residents are mainly displaced. The government structures were involved to negotiate access to the area. The Commissioner and the Director of forestry and the local traditional leader were consulted in joint management committees to establish the workgroups that will be involved. Military protection is a prerequisite from government and is established through various government initiatives. Access to the forests is now secured and the rest of the stakeholder consultation process is on track. The company does have a security guard at the sawmill. The plantations have a system of village contracts where villages receive bonuses for protection of the forests. This system is also envisaged for the Mbarizanga plantations where the HCVF are. The company has no other security measures and rely on government for security. CAR 04 Closed.
Date Recorded>
12/07/2009 Due Date> 1
st
surveillance Date
Closed> 14/09/2009
Non-Conformance:
Appropriate management prescriptions have not been determined for HCVFs in consultation with conservation organisations, regulatory authorities and other local and national stakeholders.
Objective Evidence:
No management prescriptions are available for the two areas that have been recommended as HCVFs.
Close-out evidence:
05 9.2.1
With the help of the external experts the baseline conservation values were determined and management prescriptions were made. Achievements with regard to the prescriptions are on track and it relies on the stakeholder consultation process as described above. Access to the forest was only recently established and the technical work such as invasive plant control can now resume. CAR 05 closed.
Date Recorded>
12/07/2009 Due Date> 1
st
surveillance Date
Closed> 14/09/2009
Non-Conformance:
06 9.2.2
Joint analyses and decision-making with the stakeholders directly affected by the HCVFs have not been undertaken, and efforts have not been made to establish co-management agreements with them.
AD 36A-08 Page 41 of 48
CAR # Indicator CAR Detail
Objective Evidence:
No effort has yet been made to establish a co-management agreement with the local communities, nor has there been joint analyses and decision-making with them regarding the management of the HCVFs.
Close-out evidence:
The local chiefs (8) and the local government structures are included in the committee called the Nzara Social Development Fund that was established in this regard. Monthly meetings are held and minutes are available. The local chiefs confirmed their presence and participation in those meetings. HCVF is only part of what is discussed by this group. CAR 06 closed.
Date Recorded>
12/07/2009 Due Date> 1
st
surveillance Date
Closed> dd mmm yy
Non-Conformance:
Measures that ensure the maintenance of the HCVF attributes are not described in the public summary of the management plan.
Objective Evidence:
No summary of the management plan is yet available and the full management plan that is publicly available does not contain information on HCVFs and the measures to ensure their maintenance.
Close-out evidence:
07 9.3.3
Date Recorded>
12/07/2009 Due Date> 1
st
surveillance Date
Closed> dd mmm yy
Non-Conformance:
The forests have been accessed by local rights holders to the extent that the forest’s ecological function is jeopardised.
Objective Evidence:
Some 100 subsistence settlements housing about 1 000 people are located on the natural forest part of Yabua FMU. These villagers have cleared areas for housing and cultivated fields. This situation resulted in the destruction of forests and has a negative effect on the integrity of the forest ecosystem. However, no conversion is happening at the moment. All activities by the settlers are done on areas that have already been cleared in the past. A system is not in place to either relocate the people to alternative sites off the FMU (which was confirmed by two Government sources as a practical and achievable solution), redefine the boundaries of the FMU to exclude these areas, or to establish a co-management agreement that will regulate this situation to ensure that the ecological function of the forests is not harmed.
Close-out evidence:
08 2.2.5
Date Recorded>
12/07/2009 Due Date> 1
st
surveillance Date
Closed> dd mmm yy
Non-Conformance:
Sites of special cultural, ecological, economic or religious significance have not been fully identified, described and mapped.
Objective Evidence:
A survey of sites of special cultural, ecological, economic or religious significance has only been done for Yabua and Mbarizanga FMUs and only a limited number of their sites have been fully described. No survey has yet been undertaken for the remaining three FMUs.
09 3.3.1
Close-out evidence:
AD 36A-08 Page 42 of 48
CAR # Indicator CAR Detail
Date Recorded>
12/07/2009 Due Date> 1
st
surveillance Date
Closed> 14/9/2009
Non-Conformance:
Management objectives and prescriptions have not been developed for sites of special cultural, ecological, economic or religious significance in co-operation with affected stakeholders.
Objective Evidence:
Management objectives have only been developed for two sites, whilst some 76 sites have been identified on Yabua FMU alone.
Close-out evidence:
10 3.3.2
All ASIs are mapped and GPS referenced. Management for the individual sites are kept on register and management prescriptions are described for all identified ASIs. CAR 10 closed.
Date Recorded>
12/07/2009 Due Date> 1
st
surveillance Date
Closed> 14/9/2009
Non-Conformance:
All necessary tools, equipment, including PPE are not available at the work sites.
Objective Evidence:
Adequate PPE is only available for most members of the harvesting team, particularly the chain saw operators who were well equipped. All other teams had either very little (nose and mouth protection at the chemical weed control team) or no PPE at all.
Close-out evidence:
11 4.2.5
At all operations visited, equipment and PPE was in good condition and worn by all staff. Spraying teams also had their nose and mouth protection. Spray cans were well taken care of and were free from any leaks. CAR 11 closed.
Date Recorded>
12/07/2009 Due Date> 1
st
surveillance Date
Closed> 14/9/2009
Non-Conformance:
Unwanted regeneration of exotic spp is not monitored and controlled.
Objective Evidence:
No monitoring of the spread of teak natural regeneration outside compartments is in place and very limited actual control of such regeneration has yet been done.
Close-out evidence:
12 6.9.2
Permanent sampling plots are established and the extent of Teak spread was monitored as a baseline. Taking into consideration that the plantations were neglected for more than 30 years and the spread of teak beyond the boundary was found not to be more than 50 meters and at very sparse occurrences. CAR 12 Closed.
Date Recorded>
12/07/2009 Due Date> 1
st
surveillance Date
Closed> dd mmm yy
Non-Conformance:
Appropriate maps showing the forest resource base is not available.
Objective Evidence:
13 7.1.10
The non plantation part of FMUs has not been classified and mapped, and is currently indicated as one land-use type only. This does not reflect the reality on the ground and reduces the usefulness of maps to e.g. provide information for forest conservation measures.
AD 36A-08 Page 43 of 48
CAR # Indicator CAR Detail
Close-out evidence:
Date Recorded>
12/07/2009 Due Date> 1
st
surveillance Date
Closed> dd mmm yy
Non-Conformance:
Data on the costs, productivity and efficiency of forest management activities have not been recorded and analysed, and the results of such analyses are not incorporated into plans.
Objective Evidence:
Little information on costs, and none on productivity and efficiency of forest management activities are available and none are incorporated into plans.
Close-out evidence:
14 8.2.8
Date Recorded>
12/07/2009 Due Date> 1
st
surveillance Date
Closed> dd mmm yy
Non-Conformance:
Buffer zones are not maintained along water courses and are not demarcated on maps.
Objective Evidence:
Buffer zones along water courses do not always comply with guidelines. Some compartments on Nangodi (C5) were planted too close to a stream and wetland with trees within 5 m from the water’s edge, as opposed to the 20 m specified in company procedures. No information on buffer zones is also displayed on plantation maps.
Close-out evidence:
15 10.2.3
Date Recorded>
28/11/2009 Due Date> 1
st
surveillance Date
Closed> dd mmm yy
Non-Conformance:
Ecological functions (regeneration, succession, diversity, natural cycles) are not always maintained and a programme for restoration of degraded sites is not always implemented.
Objective Evidence:
Although mitigating measures have been identified for various environmental impacts such as erosion, uncontrolled fires, poaching and the collection of NTFPs, many of these mitigating measures are yet to be fully implemented such as meaningful erosion control measures, control of invasive alien plant spp. and the effective control of wild fires.
Close-out evidence:
16 6.3.3
12. RECORD OF OBSERVATIONS
OBS # Indicator Observation Detail
Date Recorded> 12/07/2009 Date Closed> 14/9/2009 01 1.5.1
Observation:
AD 36A-08 Page 44 of 48
OBS # Indicator Observation Detail
Despite management prescriptions in this regard, the boundaries of FMUs are not clearly marked and signposted to assist with the prevention of unauthorised activities.
Follow-up evidence:
Signposts are erected on the entrances to the FMUs. The boundary issues will be dealt with through the village contracts system that is established and will be more clear during the fire season when the villagers have established the firebreaks. Observation closed.
Date Recorded> 12/07/2009 Date Closed> dd MMM yy
Observation:
Little attempt has been made to periodically analyse drinking water for workers to determine the suitability for human consumption.
Follow-up evidence:
02 4.2.9
Date Recorded> 12/07/2009 Date Closed> dd MMM yy
Observation:
Four PSPs have been established in the natural forests on Yabua and Nangodi FMUs. The positions of these PSPs have been GPS recorded, but their positions have not been indicated on any map.
Follow-up evidence:
03 6.2.5
Date Recorded> 12/07/2009 Date Closed> dd MMM yy
Observation:
The use of the herbicide Roundup (glyphosate) is not recorded on a per hectare basis per year and per catchment.
Follow-up evidence:
04 6.6.3
13. RECORD OF STAKEHOLDER COMMENTS AND INTERVIEWS
Nr Comment Response
Main Evaluation
01 Labour force (two are part of the workers committee):
A total of 4 workers have been interviewed about their view of the company and workers issues. A recurrent complaint was raised concerning the minimum wage provided. Nevertheless, they all highlighted their satisfaction about the new worker representative group, recently introduced by the company, playing two major roles: to settle conflicts among workers in the field and to raise workers issues to the senior management. Up to now, no major issue has been addressed to senior managers.
During this main assessment, the management team was able to provide a report on wage levels within the general area. It concluded that the company pays a minimum wage 4 to 5% higher than the one for the surrounding area. In addition, a system of bonus based on productivity has been introduced to give workers the chance to increase their minimum income. Management has recently organised a meeting among workers to elect five worker representatives. A meeting will be arranged each end of month between senior management and this group of workers to discuss specific issues raised by the workers. The first meeting is scheduled for the end of July 2009.
AD 36A-08 Page 45 of 48
Nr Comment Response
02 Community leader (Sakure Payam):
The community leader indicated his general happiness and good relation with the company because he believes that ETC will become a significant factor in the development of Nzara, improving education and medical facilities and injecting money into the local economy and hence raising standards of living.
However, he shared his impatience concerning the situation of teak outgrowers. Many privately owned teak trees had been marked a long time ago with the promise that ETC was going to buy them, once the sawmill was fully operating, that has now happened. This issue has been raised during the general stakeholder meeting and the verbal answer given was satisfactory.
A final remark was addressed about the need for more water points, especially within FMUs. However, the issue has not been raised yet to the company, because he is aware of the difficulties for ETC to get some authorisations (trading license, FSC certification), which slows down the company’s ability to start generating trading income.
Management has answered verbally to these issues raised by various stakeholders. In addition, a written response has been sent to senior members of the community. This written answer states that:
Trees will be purchased from outgrowers once the sawmill is operational. This will start when ETC has been issued with the required permits. The company has a well structured outgrowers programme.
According to the management team, the sawmill is still in its test period and more equipment will arrive soon, and hence the sawmill is not fully operational. In addition, all the required authorisations and certificates still have not been issued to the company, leaving the out growers programme in limbo.
The management team is not aware about the water point situation because the issue has not been presented to them yet, but the company will treat this situation with full attention.
03 Community leader (Nzara Payam):
This community leader appeared happy and satisfied with the presence of ETC on his traditional land, creating job opportunity and raising the local living standards, ditto “for people from outside, they show that now they are also people”. He could not raise any relevant issue. He considered having enough contact with them (last meeting in March) and they are welcome to come whenever they want.
He also highlighted his total agreement with the new system in place to control illegal felling using community guards. However, he raised the lack of effective patrols to fully protect the area (3 community guards for the whole Yabua FMU). His community is ready to provide more community guards but, according to his view, he does not have the power to suggest it directly to ETC. He waits for the invitation to do so from the company first.
For the management team, the “ETC Village Contract” is still a new system and needs to prove its efficiency in the implementation. The “ETC Village Contract” is a contract involving the community in a large spectrum of actions, all linked to the prevention and protection against illegal activities within the FMUs.
At this point only the Yaboa Contract has been signed and the four other FMUs will be included in this programme in a short period of time. If the programme has demonstrated its success, the company is fully aware of the need to increase its surveillance resources on each FMU.
04 Community leader (Elder representative):
This community leader is grateful to ETC for offering job opportunities to Nzara county for the first time since the end of the war. He can already see signs of social development, such as the approval for the secondary school project.
Nevertheless, he raised the issues of minimum wages that are considered to be too low for the costs of living, and the significant reduction in the number of workers (from 600 at the beginning to 246 now) employed by the company. At the start of the company two years ago, management was promising larger numbers for employment.
These issues were raised during the previous stakeholder consultation meeting and verbal answers given by the company were satisfactory. He now waits for the implementation of these promises to give more judgement about the company but he is ready to talk about it again at the next meeting. He has not been informed about the date of the next meeting yet.
Following the stakeholder consultation meeting, management has answered verbally to these issues raised by different stakeholders. In addition, a written response has been sent to senior members of the community. This written answer states that:
Despite the community expectation of 5 000 jobs, with an annual yield of 15 000 m3, ETC is only able to provide 250 jobs. However, the potential 700 ha of new plantations will create more jobs. The misunderstanding initially comes from the GoSS-MAF overstatement of the plantation area.
The management team was able to provide a report on wage levels within the general area. It concluded that the company pays a minimum wage 4 to 5% higher than the one for the surrounding area. In addition, a system of bonus based on productivity has been introduced to give workers the chance to increase their minimum income.
AD 36A-08 Page 46 of 48
Nr Comment Response
05 President of Association (Taungya chairman):
This stakeholder sees ETC as a great help for local communities and no major issues could be raised. Nzara development will soon be more visible with direct benefits from ETC through the social development fund, maintenance of roads and bridges, improvement of education and medical facilities.
He recently highlighted the fact to the company that loans given via the Taungya project were not enough to satisfy the community requirements but the decision taken by the management team to solve this situation has been accepted with satisfaction.
The management team has fully considered this request from local farmers, and increased the funds dedicated to the Taungya project. This project will now be able to include 13 more farmers, increasing the number from 67 to 80 farmers for this year.
06 Political Leader (SPLM secretary):
According to this stakeholder, the company plays undoubtedly a role in Nzara development, and signs of change confirm that ETC must remain in the area.
Despite his involvement in advising the company on corruption between workers and solving strike threats, he can notice a growing disagreement among workers about ETC minimum wages. In addition, during the meeting held with local authorities at the company’s arrival, the management team was quoting larger numbers for employment, which did not happen with the recent reduction of the labour force. The answers given verbally to these issues (FSC certification, increase of production, trading license) appears satisfactory and he waits to see the results.
Following the stakeholder consultation meeting, the management has answered verbally to these issues raised by different stakeholders. In addition, a written response has been sent to senior members of the community. This written answer states that:
Despite the community expectation of 5 000 jobs, with an annual yield of 15 000 m3, ETC is only able to provide 250 jobs. However, the potential 700 ha of new plantations will create more jobs. The misunderstanding initially comes from the GoSS-MAF overstatement of the plantation area.
The management team was able to provide a report on wage levels within the general area. It concluded that the company pays a minimum wage 4 to 5% higher than the one for the surrounding area. In addition, a system of bonus based on productivity has been introduced to give workers the chance to increase their minimum income.
07 Religious representative:
The local missionaries do not have any problem with the company management, organisation and practices. They have established a regular “Help-Help” collaboration facilitating their relationship. On one hand they ensure that, since the beginning of the company’s operations, the number of injuries requiring medical facilities has not increased. On the other hand, they could notice an increase of interest from the company concerning local health statistics.
Senior management confirmed that the company has developed a “Help-Help” relationship with this institution on a regular basis.
During the Main Assessment, ETC has been able to provide an analysis concerning health risks in Nzara area. This analysis includes recent statistics on Malaria, HIV and other less recurrent illness. Most of data have been collected thanks to the collaboration between the company and local missionaries.
08 Senior local politician
Stated that company is well accepted by local communities. They comply with all regulations of Government and the Social Fund is appreciated. Mentioned impression of low wages and temporary nature of management’s camp. Indicated that he believes the people living in the forest reserve can be easily moved to alternative sites without any problem
The company currently still has no revenue and it is not possible to do anything about wages at this point. A task work system has been introduced that will allow workers to increase their earning, based on improved productivity. The camp of management is built from expensive high quality teak and is seen as a permanent structure, and is far superior to most other structures in the area. The comment on possible removal of forest people is noted and will be considered.
09 Senior official Dept of Agric & Forestry
He visited the company personally and was impressed by the Taungya plantings and the social fund. He was concerned that they were cutting a lot of trees and were not replanting enough. He would like to encourage the outgrowers scheme without cutting any indigenous trees. He believes the company complies well with all rules and regulations.
The company has felled not more than 10 ha since harvesting started and has planted 100 ha since they commenced operations.
AD 36A-08 Page 47 of 48
Nr Comment Response
10 Group of Members: Legislative Assembly
All have visited the company and see a lot of benefits from the company’s presence. Subject of low wages raised as well as lack of training to Sudanese employees to eventually take over from expats. Would like to extend the project wider in the State. They mainly raised the same issues that were discussed during their recent visit in June 2009 to the company and which were fully documented.
The company currently still has no revenue and it is not possible to do anything about wages at this point. A task work system has been introduced that will allow workers to increase their earning, based on improved productivity. All the admin work in the company office is already handled by local people, 2 pupil saw doctors are in training, 2 wet mill sawyers are in training, 2 mechanics are in training, 2 drivers have been appointed on the tractor and tipper, carpenter and builders are in training. The company would like to extend their operations but have not been able to get more land concessions.
11 FAO Project Officer
He was aware of the company but had no personal exposure to them. He was concerned that the teak may be harvested without any real benefits to the local communities He confirmed that there are no ENGO in Yambio.
The company’s CSI strategy provides for projects such as the building of schools, health facilities and crime prevention infrastructure projects, loans for small business development projects, malaria prevention program, HIV prevention and education, outgrowers projects and Taungya agro forestry projects.
12 Office Head: UNICEF
He was aware of the company but had not yet visited them. He has not heard of any concerns about teak plantations or indigenous forests in the Nzara area.
Noted.
13 Various Officers: UNMIS & UPDF
There was awareness about the company and personal contacts from the UPDF side. No comments on any negative developments in the Nzara area were raised. An overview of the LRA situation was given. They are a difficult group to monitor, but their strength has decreased and currently consists of about 3 mobile groups very widely distributed over South Sudan, DRC, and CAR; and 5-6 smaller groups operating more or less independently. The military assessment is that they are currently not a military force of any consequence, but have rumour value. The unknown factor is what will happen subsequent to the 2011 referendum.
The military assessment is appreciated as it gives management better information on how to proceed with forest management activities in areas like Mbarizanga FMU.
Surveillance 1
Surveillance 2
Surveillance 3
Surveillance 4
14. RECORD OF COMPLAINTS
Detail Nr
Complaint: Date Recorded > dd MMM yy
No complaints to date.
Objective evidence obtained:
AD 36A-08 Page 48 of 48
Detail
Close-out information: Date Closed > dd MMM yy
End of Public Summary
