WWF-DRC comments on RRI report: Mai-Ndombe: Will REDD+ laboratory benefit Indigenous People or Local Communities?
Analysis of the cumulative impacts & risks of REDD+ initiatives
WWF and NGO partners welcome RRI and partners’ analysis assessing, with existing tools, the implementation of the REDD + process, the cumulative risks and impacts of all the REDD + initiatives on local communities and indigenous peoples’ rights and livelihoods.
WWF and NGO partners consider REDD + as a means to achieve holistic conservation and sustainability outcomes, not an end in-and-of itself. These outcomes include non-carbon benefits, particularly those related to biodiversity conservation as well as those supporting the recognition of the rights of indigenous peoples and local communities. REDD + is not a silver bullet solution for forest degradation or destruction and must be planned, developed and implemented in an inclusive and participatory manner to be more effective.
WWF and NGOs partners are involved in the implementation of several REDD + initiatives, projects and programs in the 3 largest tropical forest basins in the world and are actively collaborating in the development of REDD + tools with proven expertise, facilitating South-South exchanges. Knowledge and field lessons (see link below: http://wwf.panda.org/what_we_do/footprint/forest_climate/forest_climate_publications/).
WWF's work on REDD + is not focused on producing offsets for markets, but on increasing results-based finance, strengthening governance and effective stakeholders' participation, and enhancing the profile of forests as a key aspect of national and international programs to achieve the climate goals adopted under the Paris Agreement and negotiated at the United Nations Framework Convention on Climate Change's climate conference (COP21).
WWF and NGO partners adhere to the 5 Guiding Principles for REDD+, developed in collaboration with Greenpeace and CARE International. These principles are:
- Climate: REDD+ demonstrably contributes to greenhouse gas emission reductions with national goals working toward a global objective;
- Biodiversity: REDD+ maintains and/or enhances forest biodiversity and ecosystem services;
- Livelihoods: REDD+ contributes to sustainable and equitable development by strengthening the livelihoods of forest-dependent communities;
- Rights: REDD+ recognizes and respects the rights of Indigenous Peoples and local communities; and,
- Fair & Effective Funding: REDD+ mobilizes immediate, adequate and predictable resources for action in priority forest areas in an equitable, transparent, participatory and coordinated manner.
These guiding principles, as well as the tools, procedures and methodologies developed at the international level have been respected while developing the Emission Reduction Program (ERP) of the province of Mai-Ndombe (MN), as validated by the Carbon Fund of the Forest Carbon Partnership Facility (FCPF).
Several conclusions and action priorities from the report to mitigate the risks of implementing REDD + in Maï-Ndombe are relevant to the continuum of REDD + initiatives, projects and programmes carried out and/or to be carried out in the province of Maï-Ndombe and even across the DRC and beyond. In this document, WWF-DRC and NGO partners do not aim to revisit all recommendations, but wish to focus on recommendation 3 on page 69 stating:
- Finalize and operationalize key governance tools (recourse and feedback mechanism, benefit sharing plan, safeguards information system, independent monitoring mechanism) and strengthen the national and provincial REDD + coordination structure.
Regarding the above recommendation, WWF-DRC would like to emphasise that its position aligns with the DRC civil society and other stakeholders’ position about the ERP - Emissions Reduction Program - Maï-Ndombe already formulated particularly concerning the finalization of the benefits sharing plan still in negotiation following comments presented to the CNREDD and other institutions involved in this process (see Appendices 1,2,3 & 4).
It is true that the REDD + safeguards information system still needs to be improved. A lot of work has been done in the framework of the Maï-Ndombe ERP (see the work of the working group 5 for ERP preparation) with the support of CCBA, the civil society and an effective participation of the representatives of the 8 territories of the Maï-Ndombe province. Moreover, OCEAN NGO facilitated the identification of these representatives. Unfortunately, this action was not completed due to insufficient funding.
To operationalize governance tools and strengthen the national and provincial REDD + coordination structure, WWF-DRC and NGO partners also believe that tools need to be developed. However, it is important to mention that several tools such as regulatory texts and legislation already exist in the DRC without being enforced and/or operationalized. Therefore, some practices should be operationalized in parallel with the development of relative texts to draw the best prospective and practical lessons for an increased application. Without claiming here to be exhaustive, WWF-DRC and NGO partners, through projects implemented in a participatory way, notably carry out actions (recognized and supported by the DRC civil society) to operationalize the governance of Maï- Ndombe and the independent monitoring.
We would like to emphasize that WWF-DRC has been working for several years in good collaboration with stakeholders in the sector, including the civil society. Without sustained support and effective participation of these stakeholders in the REDD+ work in the DRC, it wouldn’t have been possible to record all the progress noticed in recent years.
With regard to our work, we focused on facilitating the installation of local governance bodies for effective stakeholders’ participation, especially through:
- Support to communities and indigenous people to be officially recognized as well as their customary lands/their territory. Their comments and FPICs - free, prior and informed consents - are obviously essential. Many communities are now officially recognized as a result of our efforts in Maï-Ndombe;
- Support to the Rural Agricultural Management Council and collaboration platform with respect to the various appropriate levels of decentralization of the province to allow exchanges (and observations) between actors;
- Support to the REDD + Maï-Ndombe Steering Committee chaired by the Governor of the Province and where representatives of the civil society, local communities, Indigenous People and other actors are involved and of course, can deliver and share their opinions and comments;
- Support to the establishment and operationalization of the Provincial Forest Advisory Council, in a representative way, also allowing to collect stakeholders’ views, settle conflicts, etc.
Regarding the PIREDD Plateaux project, WWF-DRC and NGO partners are planning to organize a provincial workshop in the near future outlining key methodologies and progress (see Appendices 18 & 19). These frequent public consultations which characterized the Maï-Ndombe REDD + work have always proven to be very useful to respond to misunderstandings and fill the gaps still existing in the implementation of the REDD + mechanism in the DRC.
Globally, WWF-DRC and NGO partners therefore agree with RRI about the ongoing work that should be quickly finalized as regards the benefits sharing plan, the complaints and appeals mechanism, the formalization of the mandated independent observation, etc.
However, several other aspects of the report need some clarifications and/or require some precisions from our side such as:
- RRI methodology is based on a desk research/documentary with only some field information collected, not exhaustive and even less systematic. This approach with incomplete field sources may lead to biased recommendations.
- Some stakeholders, depending on their level of involvement, should have benefited from more consultation such as the PIREDD project leader quoted in the report, indigenous representatives, local communities, etc. Indeed, WWF is the only organization among all actors working continuously in the province of Maï-Ndombe and is still present in all the territories. However, WWF wasprobably the least consulted during the RRI survey while many statements question its ways of working. Two staff have been interviewed on the phone for a few minutes but questions asked and answers given are not disclosed;
- Normally, stakeholders and especially those mentioned in the report could have benefited from transparency in the processing of information gathering and thus be consulted before publication of the report to countercheck the statements made in the document;
- WWF-DRC's working approach was questioned, for example, concerning the number of days taken to produce the participatory mapping. It was mentioned that WWF-DRC spent only 2 days in the participatory mapping missions. However, it was not mentioned that participatory mapping is just one of the steps of the WWF implementing process (see Annex 5). In fact, RRI noted only one step in a much more complex and useful process that helps clarify (officially) use rights, define land uses, prepare resource management plans (Natural Resources Management Plan), support communities in choosing their priority activities, etc. Furthermore, this whole process makes it possible to carry out land use plans as prescribed to date in the legal provision and absolutely necessary for sustainable development of the country.
- Also, WWF-DRC’s involvement in Maï-Ndombe with local communities and indigenous peoples is not a new and one-off fact. WWF DRC has offices as well as permanent activities with staff working in Malebo, in the North-Batéké Chiefdom, Bolobo territory and other representations in Oshwe, Mushie, Kwamouth, Yumbi, Bonobo city and Inongo. This is a long-term commitment and sustainability approach in supporting local communities and indigenous peoples compared to other organizations operating in the DRC.
Although WWF-DRC and NGO partners agree with several recommendations as mentioned in the RRI report, we did notice some inaccurate statements about WWF DRC & partners’ approaches, practices and activities. As a contribution to a better understanding of the REDD + mechanism in the DRC and to set the record straight with regard to their activities, some aspects of the report have been commented as explained below:
Section 2.7: Limited community participation in the decision-making processes
In this section of the report and others, RRI states that:
- The Free, Prior and Informed Consent Guide produced by the CN-REDD in 2014… Unfortunately, these works results have never been, so far, tested on the ground… P. 41.
WWF highly contributed in the development of the FPIC project, in particular through:
- Support to the development of the first FPIC guide validated by the national REDD + committee and tested by several organizations including the NRN in the 11 former DRC provinces;
- Development of the second Guide at the international level by WWF International Forest and Climate Program hub based on field experiences of three forest basins, namely Amazonia, Mekong and Congo.
- Implementation of the FPIC approach in the field and development of a practical, operational and proposed FPIC process within the framework of the Maï-Ndombe ERP (see Appendix 11);
Section 3.2: Conflict Mitigation- Undervaluation and Threat to REDD + Outcomes
In this section, the RRI underlines that:
- The risks of land conflicts are underestimated and neglected by REDD + programmes: "These pressures make both PIREDD projects be of high risk in terms of land conflicts and even expulsion ..." "PIREDD Plateaux project, managed by WWF, includes also community-based agroforestry activities and "integrated" food activities (mixing livestock and small-scale farming) without land clarification activities. P. 46. "
It is however necessary to specify that the PIREDD project does not implement livestock activities contrary to what has been mentioned in the report.
It is also unfortunate that land rights clarification works carried out, in particular the delimitation of customary lands and others, is not recognized by RRI. The customary lands mapping is however sufficiently advanced under the PIREDD Plateaux project defining community land in a participative way for more than 150. RRI should inquire how the work has been progressing since the launch of the PIREDD Plateaux project supported by FIP - Forest Investment Program - unit and / or decentralized administrations and officially recognized communities in their areas.
- Conflicts between forest loggers and community raise again with the REDD+ projects: Cases of ERA/WWC and WWF. « The PES system set up under WWF's Carbon Map and Model (Mapping Carbon Model) project also suffers from conflicts with communities ... P. 47 ».
Generally, the CMM (Carbon Map & Model) project, a project on national scale, has developed a national biomass map using the innovative Light Detection And Ranging (LiDAR) technology that provides key data on the accurate carbon contents stored in the DRC's forests and the concrete implementation of REDD + concepts, in collaboration with 3 different actors implementing activities in the Mai-Ndombe Province as area of interest.
More specifically, the CM & M project has:
1) supported the DRC identify the most effective areas to implement activities to reduce these emissions to achieve its climate objectives;
2) set up pilot field projects with local communities, working with a cattle farming company and a forest logger to develop and suggest management strategies that are economically viable, but also reduce emissions;
3) provided the DRC with concepts to operationalize and translate its intention to reduce emissions through concrete activities;
4) played a key role in preparing an Emissions Reduction Program (ERP) for the Carbon Fund of the Forest Carbon Partnership Facility (FCPF);
5) supported the concerned institutions in the DRC to prepare the ERP (for the Maï-Ndombe province) and gave technical advice how structure the process to receive REDD + payments);
6) encouraged the transfer of technology and knowledge regarding biomass estimation and implementation of REDD + within national institutions and relevant government structures.
As for conflicts raised in the report, there is, to our knowledge, no conflict to date that has affected the PES (Payment for Environmental Services) as implemented by the CM & M project. The only conflict between the Nkala and Mpelu villages in 2014 after reforestation implementation by Tombokolo consultant, was sorted out. The two communities met and reached a settlement and also agreed that the boundary dispute should be arbitrated by the customary court of Mbee mutually recognized by the two villages. The minutes of the settlement of this conflict is available. This is an additional example of positive conflict management initiated by structures supported by the projects related to CM & M.
With regards to the terms of payment as mentioned in the report, contracts drawn up for this purpose are clear and payment procedures, monitoring and verification are sufficiently detailed (see Appendices 12, 13 & 14). Contracts under CM & M project are always signed between WWF management and local community, but also the territory’s Administrator (province administrative subdivision in the DRC) and are subject to a customary land use approval. However, like any contract, misunderstanding and interpretation are always possible. This is why WWF-DRC is promoting detailed contracts, signed with indigenous peoples and local communities for activities implementation.
Section 3.3 REDD + structures’ activities: lack of environmental and community anchoring
- This suggests a patchwork initiative, made of multiple initiatives… »P.48
RRI also states that:
- "Local development committees, central community structures in the majority of projects do not offer representativeness guarantee, and their management is not transparent" P. 49:
- "Despite their importance, very little information is available on their setting up, operation and therefore their legitimacy. P. 49;
- "Despite requests, no minutes of Local Development Committee meetings have been shared by the PIREDD Plateaux's Implementing Local Agency, WWF. P. 49;
- “Only 10% of representatives are from Indigenous People with limited speaking rights .”
- « Created in Maï Ndombe by WWF to negotiate specifications with SODEFOR, they were the main source of conflicts» P. 49
Also, it is clear that, after analysing how this situation is depicted in this report, RRI and consulted organizations do not seem to master the process, or understand the relevance of the civil society NGOs’ role since the development of Decree 023 setting out the agreement model, which is under review to this day. To enhance their understanding we would recommend to RRI to engage directly with community representatives’ to witness how choices are made in various committees meetings with signed minutes as concluding basis.
- « Deforestation drivers are not locally known… » P. 50
Work carried out with communities under the Natural Resources Management Plan (PGRN) ensuresto address the causes of deforestation directly at the level of the community with the community management structure set up through the FPIC process.
- "The support of REDD + funds to industrial logging is not in agreement with deforestation drivers as targeted by current projects, nor with the destructive reality of this industry on the field" P. 59
The establishment of a REDD + jurisdictional programme reached an historical moment in responsible forest management in Central Africa when the majority of actors recognize a major decline in legally founded forest management for the benefit of informal exploitation as well as the concomitant growth of less demanding markets when it comes to sustainablity in production.. WWF-DRC will continue to make efforts to bring the private sector into the local social, economic and environmental dynamics, hoping for the best for the future of the forests in Central Africa and people living in.
We therefore take this opportunity to once again share the proposal for integration of the forest sector into REDD + (see Annex 17).
Section 3.4 Right to land: isolation of the problem and not taking into account land dynamics
- "Community forestry, an underused approach to REDD + ..." P. 57
Section 3.6 Gender: Women are still at the margins of REDD+ projects
- "Support for women's participation in CLDs needs to be encouraged" P. 59
Former local structures were poorly organized, and woman hardly involved due to traditional practices being a burden preventing womens voice to be heard. In reality, there was a lack of a representative structure at the Community level through which development actions should be channelled and steered. CLDs (or equivalent) are therefore the only structures to date that address this issue effectively. Curiously, in the RRI report, none of the structures RRI consulted ever had to set up a single CLD to understand the installation, operation and empowerment process.
It would therefore be useful to better understand the organizational context of communities, the living conditions, the importance of the dynamics put in place and their progressive impact on the improvement of inclusive local governance.
Section 3.7 REDD+ benefit sharing: risks compromising REDD+ objectives
- The benefits sharing plan does not permit the REDD+ to be sure that the communities are the only beneficiaries”. P. 60
Section 3.8 Improvement of living conditions: poorly-targeted beneficiaries and poorly-controlled impacts
“ No project can yet prove its positive impact on the living conditions of local communities’’ P.62
It is true that the impacts on local communities living conditions are difficult to prove seeing the timeline of the project. It is for this reason that WWF-DRC, with the support of other organizations, is developing a methodology for a participatory monitoring of the Sustainable Development Goals (SDGs) of local communities and indigenous peoples. Hope is that this joint and permanent measure within the voluntary communities will enable effectively monitor improvements of living conditions in accordance with SDGs. This methodology, already under field experimentation, will soon be publicly presented for opinion sharing and comments before being validated by competent authorities. As a result, it will soon be possible to monitor the progress of Local Communities & Indigenous People (CLPAs) with regard to SDGs and to steer projects more precisely according to the local diagnoses periodically updated by the CLPAs.
Section 3.9 Stakeholder participation and accountability: low community ownership
- "The methodology proposed by Rainforest Foundation UK and the Natural Resources Network emphasizes on a twenty days period at lease per month in villages and the whole community participation..."
Participatory mapping should be a tool to support micro-zoning to highlight the association between land and local people using the known and recognized language of mapping. This methodology was also clarified during the participatory development of the macro and micro zoning guides of the DRC. It is therefore a process that aims to help communities formulate and transmit their spatial knowledge to outside organizations; Enable communities to retain and archive local knowledge; assist communities to plan land use and resource management, enable people to advocate for change; Improve capacity within communities address resource conflicts, etc. (Operational guide for forest micro-zoning 2014).
- The results-based payments methodology ... does not encourage community ownership ... "
WWF-DRC and NGO Partners are conscious that many REDD + aspects in the DRC need to be improved. It is very useful to welcome different queries and others external observations to the process. However, it is important to question the basis and legitimacy of some recommendations as long as they have not been subject to wider consultations and that key beneficiaries of ongoing actions did not really have opportunity to comment on the positions/recommendations made.
WWF-DRC and NGO Partners recommend to ascertain all beneficiaries' views on risks aspects as raised in the report and this consultation process should be carried out in accordance with FPIC principles for beneficiaries to understand the potential impacts of adopted positions/recommendations since they may be deprived of their rights to benefit from REDD + support, despite their willingness to participate voluntarily in ongoing projects.
WWF-DRC and NGO Partners believe that land conflicts and expulsion risks, even population displacement in the DRC are increasing day after day without reactions (business as usual) and there is an urgent need to continue with the recognition process of local communities and indigenous peoples’ lands (villages terroirs) to allow their rights be taken into account and implementation of the regional planning process in a participatory way under supervision of decentralized entities, as implemented by the PIREDD Plateaux project
Also, it would be useful to assess the risk of not continuing the work in progress, in particular not to facilitate lands clarification in the province of Mai-Ndombe as well as not to support the establishment of local governance structures such as already engaged under PIREDD Plateaux project.
Finally, WWF-DRC and NGO partners recommend that stakeholders interested in the ongoing work actively participate in the public consultations opportunity to better understand the ongoing process and contribute positively to the development of the DRC.
- La note conjointe d'analyse de la société civile, WWF et autres acteurs sur le plan de partage des bénéfices du PRE Mai Ndombe. Ces commentaires étant considérés par le WWF comme la dernière concertation effective sur les documents soumis / Joint analysis note from the civil society, WWF and other stakeholders on the benefits sharing plan of Mai-Ndombe’s ERP. WWF considers these comments as the last effective consultation on submitted documents ;
- Le compte rendu de la réunion avec la CN REDD et les parties prenantes concernant la carte de risque et plan de partage de bénéfices du PRE Mai Ndombe / CN-REDD & stakeholders meetings report on risks mapping and benefits sharing plan of Maï-Ndombe’s ERP) ;
- La présentation d'une proposition pour informer le plan de partage de bénéfices.La note conceptuelle de proposition d'un mécanisme d'évaluation de la performance locale / Proposal presentation to inform about the benefits sharing plan. The proposal concept note for a local performance assessment mechanism
- Les étapes du processus d’élaboration participative des plans de gestion des ressources naturelles / Natural resources management plans participatory développement process;
- Etude sur les moteurs de déforestations dans la zone de Malebo / Deforestation drivers survey in the Malebo area ;
- Etude MRV dans la région de Malebo / MRV survey in the Malebo region ;
- Exemple de statuts d’un CLD / CLD Statutes sample ;
- Exemple d’un document d’ordre intérieur d’un CLD / A CLD Internal regulation document sample;
- Exemple d’un compte rendu d’une Assemblée Générale du CLD / A CLD general assembly report ;
- Poster sur le processus CLIP / FPIC processus poster;
- Poster sur le reboisement / Reforestation poster ;
- Poster sur la mise en défens / Protected areas posters ;
- Poster sur l’appui à la protection des forêts communautaires / Community forests protection support poster ;
- Exemple de contrat Agroforesterie / Agroforestry contract sample;
- Exemple de contrat de mise en défens de savanes anthropiques / Anthropic savannahs protected lands contract sample ;
- Proposition pour une exploitation à impact réduite/ Proposal for reduced impact logging;
- Principales avancées du PIREDD Plateaux; PIREDD Plateaux key achievements
- Méthodologie d’appui avec les PSE/ Methodology of support with PES
- Les Peuples Autochtones et la Conservation: Déclaration de Principes du WWF/ Indigenous People & Conservation : WWF policy;
- Cadre fonctionnel de la stratégie du WWF sur les PA Pygmées en RDC/ Functional chart of WWF strategy on the AP in DRC / Functional Framework of WWF Strategy on IP Pygmies in the DRC ;
- Rapport CIFOR et WWF de suivi des cahiers des charges sociales / CIFOR and WWF report on social specifications follow up
* Above appendices are available on http://www.wwf-congobasin.org/news/?uNewsID=326955
NB: WWF-DRC comments on RRI report has been developed with the contribution of NGO Partners as listed below:
CVDP, AMAR, CENADEP, AVOCATS VERTS, OCEAN, REPALEF, UDME, CDE, CEDEN, CWS, GAPE, CFLEDD, NTOMBOKOLO, ILDI, IGED, CNCEIB, CODHOD, PABO, RAIFORCO, CIAPAFED, and GTF.
- Opinions expressed in the hereby document are WWF and NGO Partners’ position, and may not necessarily be the point of views of WWF-DRC Financial partners.