12 January 2004
16 July 2003
Dear Executive Director
Having written to President Chino on 27 May (copied to you) submitting a critique of the June 2002 Forest Policy draft paper I am writing to raise a number of additional points regarding the current status of the Forest Policy Review.
Given the previously noted failings in disclosure of information on this issue it is encouraging that the new June 2003 draft forest policy paper has been posted to the appropriate place on the website. We expect that this positive development will continue with all stages of the process.
However regarding the critique that we have submitted we are still awaiting a response. We have received no acknowledgement of receipt let alone the thorough response requested to the important questions raised. Our questions indicate the pressing need for further inquiry into different assumptions before they should be written as policy. With endorsements from 48 NGOs and individuals worldwide we find it unacceptable that the ADB has been so totally dismissive of the serious concerns raised. We continue to await a thorough response to our original critique.
As you will be having to consider the merits of the June 2003 draft policy paper at the 22 July board meeting we ask you to consider the following points in your assessment.
The forest policy is a safeguard policy and therefore of the highest significance. The policy paper contains no clear commitments to safeguard standards. Without commitment from the ADB to adhere to clearly stated principles and standards the policy fails to be a policy but more a mission statement instead. As such it fails to achieve its stated function.
The paper repeatedly highlights the failures and deficiencies of DMCs in managing their forests or of contributing to continued deforestation. However it fails to define the base line conditions to which recipient countries must adhere in order to receive ADB loans and assistance. In its failure to address this issue the ADB not only side steps all commitment to safeguarding the regions forests but further, allies its forest record with the lowest common denominator – the recipient government with the worst record in forest protection.
Attached please find a copy of ‘Model Forest Policy for Financial Institutions’ a joint document of WWF and FoE. We trust that you will find this useful on a number of levels, from the clear unambiguous approach, conditions for recipients and numerous policy content proposals not currently included in the ADB draft paper. We consider that these proposals represent a minimum level to which the ADB policy should adhere.
If by making the latest draft paper available the ADB expects to have answered the questions raised by NGOs it is mistaken. Though the draft does answer some of the questions posed (such as why the country case studies were chosen), most remain ignored and especially those that question the fundamental basis of many of the bold assumptions contained in the policy.
For example P.17, V., 55. ‘ADBs Vision…’ the document states that: ‘Meeting these challenges will require …sustained annual growth of 3-7% in real GDP per capita by 2015. Forestry should and can play an important role in the fight against poverty…’ The strong equation throughout the document on poverty alleviation through economic growth, together with environmental protection, do not sit easily together and are often incompatible. The ADB assumes that economic growth alleviates poverty. However substantial accumulated evidence shows that external economic interference in forested areas also leads to rapid deforestation and land use change. This is at odds with the aim of environmental protection.
There is broad acceptance amongst policy-makers worldwide that forests are major contributors to the economic, social and spiritual health and well-being of communities living within their reach and in this way are a major pre-existing factor in poverty prevention. Simply put, a healthy forest ecosystem benefits the people living within its reach. Before prescribing further irreversible changes to Asia’s rich forest diversity the ADB needs to resolve its ambiguous position through further inquiry. It also needs to properly assess its role in the devastating forest loss in Asia during the 1990s. Does the ADB intend to cause poverty before then supposing to alleviate it? Or does the ADB strive to prevent poverty from happening in the first place?
Though the policy paper indicates an understanding of the importance of participatory development, this has still a long way to go and is also incompatible with promotion of technologies which are beyond the control of local or forest dwelling people. Biotechnologies and especially Genetic Engineering are an extreme example of how control of local engagement in forest stewardship can be taken away. Ownership of the technology remains with the developer and access by stakeholders is severely restricted. Even more concerning, the genetic raw materials for many biotechnologies are often plundered from forest dwelling peoples through ‘bioprospecting’ otherwise known as ‘biopiracy’. This blatant theft of genetic resources should not be supported by the ADB. The ADB needs to resolve the incompatibility between promotion of community and minority engagement in forest stewardship and promotion of new technologies and exploitative practices.
A further point of unclarity and ambiguity in the document is the lack of clear definitions to distinguish plantations from natural forests. As these ecosystems are so completely different in character there should be no space for confusing the two. Currently there is great confusion on this point leading to misinterpretations of the policy.
The ADB continues to evade the critical question of how stakeholders and other concerned people can engage in a participatory and democratic development process when their freedom of expression is curtailed by an oppressive recipient regime. If the ADB is to appear genuine in its commitment to participatory development it needs to recognize the rights of stakeholders and the bottom-line is respect for Human Rights. The forest policy should integrate throughout a rights led approach and this should be supported by the development of a Human Rights Policy.
We trust that our concerns will be given full consideration and that our questions will be answered soon.
Yours faithfully
Rod Harbinson – ADB Facilitator, Friends of the Earth International
Sameer Dossani – Executive Director, NGO Forum on the ADB