32nd Sharing Meeting of NNN

29th August 2008
ANSAB Meeting Hall

Agenda
Considering the importance of Community Based Forest Enterprises (CBFEs) in poverty reduction, biodiversity conservation and ecosystem services, the main agenda of this meeting was set as: “Discussion on current policy issues relating to NTFPs / Forest based products such as IEE, EIA, etc.”

Summary
Environmental Assessments such as the Initial Environmental Examination (IEE) and Environmental Impact Assessment (EIA) are undoubtedly, some of the important environmental management tools. These tools hold ample significance in terms of environmental protection, and economic development, and can be easily related to developmental activities such as industrial development, pollution prevention etc.

However, in terms of community forest management, which in itself is an exemplary management practices for conservation and livelihood improvement, these tools are acting as a major hindrance, complicating the process of handing over and renewing of community forestry. There already exist many successful tools in community forestry such as operational plan, business plan that incorporates various methodologies to safeguard the environment. In such cases, it is questionable, whether it is commendable to implement EIA / IEE.

The meeting has realized the cost implications of IEE/EIA as a major challenge with regard to their implementing .As such, all participants agreed that these tools are a major setback in direct field level intervention and therefore, it needs to be reviewed considering the importance of community forestry in conservation and community economic development. To initiate a policy review, five ‐member task force was formed, that would draft a proposal and submit it to the required authorities.

Introduction
The meeting started with a brief welcome by Dr Bhishma Subedi, followed by a general introduction of the participants, including Dr Nirmal Bhattarai, who chaired the meeting. Dr. Subedi provided a general description of the agenda of the meeting and highlighted that the major focus would remain on:

1. Issues related to imposition of IEE and EIA policies in relation to NTFPs and community forestry.

2. Recent revisions on royalty rates of NTFPs.

3. Certification

4. Resource potential / mapping

5. Trade restriction / barrier

6. Policy dissemination and absorption

Apart from these issues, the following issues were also raised, however, discussion was held only on the issues related to imposition of IEE and EIA policies in relation to NTFPs and community forestry.

1. Potential NTFPs cultivation for livelihood improvement of community based groups

2. Identification of relevant policy for identifying shed lobbying crops to improve income generation

3. Policy Review in terms of cultivation of vital species

4. Promotion of community forestry for biodiversity conservation through indigenous species

5. Awareness on the facts of conservation measures and issues

6. Promotion of national level enabling environment

7. Policy dissemination and absorption

8. Generation of technical resources

Discussion
1. IEE /EIA Issue: It is a newly amended governmental policy, enforced since Mangsir 2064 (December 2007), which indicates the requirement of environmental assessment for any form of developmental as well as for environmental activities. It includes activities within community forestry (CF) as well, where it states that any activity within 200 ‐ 500 hectors shall undergo IEE and EIA for activities over 500 hector of community forests.

The policy states these requisites for a new community forest to be handed over to the locals. However, it does not affect all community forests as most of the CF is subsistence based and the plot does not always exceed 200 hectors. In such case, it may not affect the very small income generation activities but it certainly hampers enterprise development for community enhancement. Moreover, there is a current trend of handing over 199 hector of forest, in order to avoid the existing IEE/ EIA policy.

However, since most of the CF based on enterprise based model requires a large plot, this policy is acting as a major challenge to community forestry development. In addition, there also exists a loophole in the policy itself as the policy seems mandatory only for handing over new CF, yet, in practice, it is also required to renew existing CF. It often creates confusion and is mostly dependent upon the approval of DFOs. Most of the time, these policies are bound to be enforced only if insisted upon by the DFOs; otherwise they may be ignored. Therefore, this indicates a contradiction in the policy itself and requires action to be taken to ensure a productive and efficient field‐level intervention.

2. Cost Implications: IEE /EIA is not just a matter of policy enforcement. It also requires a considerable amount of money, which in terms of CF, does not seem practical. The entire concept of CF is based on poverty alleviation, where it becomes questionable as to who would be responsible to bear the entire cost of implementation these tools. A mere tentative minimum cost calculation would be around 20 – 25 thousand (News publishing: 7,000‐8,000; Data collection: 6,000‐7,000; Reporting: 10,000). Moreover, if consultants are hired, the cost could even exceed one lakh, which raises ethical concerns over the right of the poor communities involved in CF. As a result, a cost benefit analysis has to be carried out prior to implementation of these kinds of decisions.

3. Alternative options: Indeed, considering IEE /EIA as an effective tool for conservation is questionable. In terms of CF where certain tools already exist to safeguard the environment and eventually promote conservation, it is quite debatable to adapt these tools just for the sake of policy enforcement.

Serious concern should be given when choosing the best conservation tool for certification, for example, which has already been successful ‐‐ not just in conservation, but also in community economic development.

Moreover, other tools such as operational plans, inventories, and business plans are already used in CF, which in itself is a part of forest policy. Therefore, it raises questions on the practicality and feasibility of the overly imposed IEE/EIA tools as compared to CF’s sustainable conservation and harvesting tools.

4. Limitations: These IEE/EIA tools are not just simple tools that could be implemented easily, but hold certain restrictions in terms of required techniques and materials. A multidisciplinary task force is required for technical analysis and also demands extensive documents. Moreover, there is no existing monitoring mechanism and it is just a one time assessment with no follow up and guarantee for environmental sustainability. In such cases, there are limitations in terms of genuine capacity needed to perform the task and, more importantly, someone to invest in the assessment.

Logical Argument
Considering the above mentioned aspects, the following arguments were presented to help decide upon the most logical initiative for the IEE /EIA challenges.

1. Certain assessments are already a prerequisite for CFUG formation. Handing over of CF takes place in close collaboration with DFOs, where an agreement is signed between the DFOs and CFUGs. The process cannot be completed without final approval of concerned DFOs where one of three major responsibility of DFOs is to assure long term environmental sustainability, achieving a balance between conservation and economic development. Hence, conservation efforts are well considered in CF and DFOs play an important role in scrutinizing the overall processes. Thus, IEE/EIA policy imposes undue burden in the community development, adding no value in the conservation and environmental safeguard of the CF.

Also, at present, when renewal for most of the CF is already lagging behind, such policy is affecting the conservation effort, hampering smooth functioning of the CFUG activities and local development.

2. Other conservative tools such as operation plan, business plan etc requires equal scrutiny and technical assistance, which also ensures conservation effort. Hence these tools could be strengthened, if required, instead of IEE /EIA

3. CF management promotes an incentive based mechanism, for conservation and livelihood upliftment. Further, it provides an opportunity value addition and market linkage to enhance community economic development. In such cases, it is quite natural that communities have concerns about the actual benefits and incentives associates with the IEE/ EIA.

4. In terms of CF, most of the authorities are handed over to the CFUG. Formation of CF constitution and operation plan is also participatory and quite strong. However, formulation of IEE/EIA policy hasn’t incorporate participatory approach and concerns of stakeholders have not been well addressed in the IEE/EIA policy.

5. There is no clear cut description of NTFPs in community forest based IEE/EIA reports. This raises concern over whether or not the assessment made is at all effective and genuine. Moreover, a monitoring aspect is completely lacking. Therefore, if the implementation of these tools is to be made mandatory, monitoring aspects should be incorporated within the policy itself.

Conclusion
Though government action has been quite commendable, both in terms of community forestry, and NTFPs (royalty revision of NTFPs through NNN), the current IEE/EIA policy sounds impractical and unviable in terms of present community forest management practices. Since community forestry is based on sustainable management and conservation practices, additional costs and efforts required for the implementation of IEE/ EIA in CF does not seem to add further value on conservation. Tools of CF management practices such as inventories, operation plan and business plan incorporates different form of assessment for sustainable conservation and economic development. And additional gain from IEE/EIA is minimal.

Moreover, the process of hand over CF is already lagging behind, which, in turn, is hampering the growth of local development and community enhancement. It is hindering the growth of local organizations and any policy affecting the local development does not sound feasible, for any kind of conservation or developmental activities.

In order to overcome these challenges and make an effective move forward, the meeting decided to form a task force, to draft the proposal, and make an appeal to the concerned authorities. The task force consists of the following members:

1. IUCN – Coordinator

2. HNCC ‐ Member

3. FECOFUN – Member

4. NEPPHA ‐ Member

5. Practical Action – Member

6. ANSAB ‐ Member

Recommendations

1. Participatory approach needed for policy formulation

2. Awareness to be created among the stakeholders regarding the policy issues

3. Other feasible options for conservation efforts could be brought into practice, such as

forest certification, for example

4. Existing tools such as inventories, business plans, operational plans could be strengthened as opposed to opting for the IEE/ EIA

Follow up action
It has been decided that the task force would draft the policy recommendation and submit the proposal to the concerned authority. IUCN, (Coordinator) of the task would coordinate the entire process and finally lead the task force in implementing the outcome of the NNN sharing meeting.