World Bank Forest Carbon Fund approves Emissions Reduction Concept, amid continuing concerns over rights and livelihood impactsThe Ninth meeting of the FCPF Carbon Fund held on April 9-11 in Brussels approved a controversial Emissions Reduction Programme Idea Note (ER-PIN) for the Democratic Republic of Congo (DRC), despite serious concerns raised by international organisations, including FPP, over potential severe negative social impacts. The DRC ER-PIN was approved alongside proposals from Ghana, Mexico and Nepal, while ER-PINs from Republic of Congo and Chile were re-invited for consideration during the next Carbon Fund meeting in June 2014. Green model?The DRC ER-PIN proposal covers an area of 12.3 million hectares in the District (future province) of Mai-Ndombe, where the REDD program will directly affect the livelihoods of between 1.5 and 1.8 million forest dwellers and rural people, including hunters and gatherers, small farmers engaged in rotational farming and ‘bush charcoal’ producers. The ER-PIN describes the pilot project as a “model provincial green development program that provides alternatives and rewards performance to address the challenges of climate change, poverty reduction, natural resource conservation and protection of biodiversity”. According to existing plans in the ER-PIN this intervention would consist of:• Agro forestry on degraded land to sustainably produce food and fuel wood.• Agricultural intensification and phase out slash-and-burn agriculture (emphasis added)• Bush fire control (major regeneration of primary forest expected).• Reforestation• Community forestry and conservation• Incentives for reduced-impact logging, forest certification, etc.While some reporters have applauded the DRC proposal as a model for “green development” and the recent FCPF approvals of ER-PINs as “a turning point from the lofty, theoretical policy deliberation to real action on the ground to save our planet’s green lungs and our global climate”, local and international NGOs have raised major concerns over the FCPF’s flawed treatment of rights, livelihood and benefit sharing issues in the DRC ER-PIN development process. Potential rights violations and poverty risksAlthough the need to respect customary land rights is noted in the existing DRC ER-PIN, its proposals lack any solid plans to uphold customary tenure rights and secure community forests. A critical review of the ER-PIN completed by FERN and FPP strongly criticises the FCPF for failing to ensure robust poverty and social risk analysis as part of the project design. The same critique identifies serious gaps that risk negative social and livelihood impacts on forest dependent people and communities, including, inter alia:• lack of clear commitments to respect communities' FPIC;• flawed deforestation assessments, mainly blaming communities for forest destruction• weak treatment of community land tenure issues affecting many people living in the area who depend on forest resources and land for their subsistence economies;• defective plans for land use zoning, alternative livelihoods and actions to limit local subsistence activities
There are also major concerns that the process for public consultation on the ER-PIN has been rushed and seriously defective as key documents, including later versions of the ER-PIN in 2014, were not made available in French prior to validation. In addition, the formal “validation” of the final proposal (required under FCPF rules) did not allow for open public criticism or rejection of the ER-PIN plan, thus raising major questions about the credibility of such validation meetings.Whilst there has been some multi-stakeholder engagement at some stages in development of the proposal, there have been clear weaknesses in consultation during the design process, especially for the revision of the document in 2014. There is no evidence of meaningful consultation with local communities or civil society organizations working in the project area itself. The lack of local understanding and ownership of the project is a serious cause for concern, and is likely to lead to problems during project implementation.
Lack of clear conditionsWhile the FCPF Carbon Fund (Chair’s Summary) has asked the DRC government to “describe how the (future) ER Program will contribute to progress towards clarifying land and resource tenure in the Accounting Area…”, it has not required any specific revisions of the ER-PIN document. The Carbon Fund Resolution (no.2) makes no explicit mention whatsoever of social and rights issues, though it requires conformity with the Carbon’s Fund Methodological Framework. Although this framework does refer to social safeguards, it has also been criticised for being narrowly focused on carbon benefits and for containing perverse incentives for the nationalisation of forest carbon stocks. For its part, the government of DRC has promised to address CSO concerns about the ER-PIN, maintain the current moratorium on industrial logging concessions and take actions to move forwards the Community Forestry Decree that has been stalled since 2010. Local NGOs and communities are now seeking to follow up with the government to hold it to its word. International organisations, including FERN and FPP, will continue to track this process to assess compliance with social commitments and agreed standards by the FCPF and related REDD initiatives of the Forest Investment Programme (FIP) and UNREDD Programme.