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Ghana Forestry Commission’s
‘Validation of Legal Timber’ Programme (VLTP)
-
Proposed Wood Tracking System:
System Requirements Analysis
(Under the Voluntary Partnership Agreement)
Forestry Commission of Ghana
Validation of Legal Timber Programme (VLTP)
Chris Beeko - [email protected]
SGS Project team members:
Marc Parren (Dr) - [email protected]
Antoine de La Rochefordière - [email protected]
John Barne - [email protected]
Blaise Reymondin - [email protected]
May 2007
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TABLE OF CONTENTS
TABLE OF CONTENTS ................................................................................................................ I
ACRONYMS............................................................................................................................. III
PREAMBLE ..............................................................................................................................5
1 BACKGROUND ..................................................................................................................6
2 ‘WOOD TRACKING’: GENERALITIES ....................................................................................7
2.1 DEFINITIONS AND IMPLEMENTATION FRAMEWORKS ...............................................................................7
2.2 OBJECTIVES .......................................................................................................................................9
3 PROJECT SCOPING ANALYSIS ..........................................................................................10
3.1 SCOPE OF A WOOD TRACKING SYSTEM .............................................................................................10
3.2 SEQUENCE OF IMPLEMENTATION OF THE SYSTEM ...............................................................................11
3.3 BUILDING THE TIMBER VALIDATION ENTITY SYSTEM ............................................................................11
3.4 CURRENT ORGANISATION OF THE FC.................................................................................................12
3.5 PROPOSALS FOR THE ROLE OF THE TIMBER VALIDATION ENTITY AND OTHER AGENCIES .......................13
3.6 STAFFING THE TVE...........................................................................................................................15
3.7 CATEGORIES OF STAKEHOLDERS.......................................................................................................15
3.8 THE WTS AND A FOREST SECTOR INFORMATION SYSTEM ..................................................................16
4 EXISTING BUSINESS PROCESS AND CONTROL SYSTEMS .....................................................17
4.1 OVERVIEW........................................................................................................................................17 4.1.1 Forest management (pre-logging activities)........................................................................... 17 4.1.2 Forest exploitation .................................................................................................................. 19 4.1.3 Log Transport......................................................................................................................... 20 4.1.4 Primary processing................................................................................................................. 21 4.1.5 Transport of primary processed wood.................................................................................... 21 4.1.6 Secondary and further processing ......................................................................................... 21 4.1.7 Domestic retail outlets............................................................................................................ 22 4.1.8 Export (by sea or overland) of wood products........................................................................ 22
4.2 PROBLEMS WITH THE SYSTEM............................................................................................................25
5 PROPOSED BUSINESS PROCESSES AND CONTROL SYSTEMS ..............................................26
5.1 INTRODUCTION..................................................................................................................................26
5.2 RESPECTIVE ROLES OF THE TVE AND THE FC....................................................................................26 5.2.1 Database management and reporting.................................................................................... 27 5.2.2 Field verification ..................................................................................................................... 27 5.2.3 Licensing scheme .................................................................................................................. 27 5.2.4 Law enforcement.................................................................................................................... 28
5.3 PROCEDURAL CHANGES TO ACCOMPANY THE INTRODUCTION OF THE WTS .........................................28
5.4 PROPOSED BUSINESS PROCESSES....................................................................................................31 5.4.1 Stock Enumeration and Yield Selection ................................................................................. 32
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5.4.2 Allocation of Tags................................................................................................................... 33 5.4.3 Tree Felling and Log Production ............................................................................................ 33 5.4.4 Log Inspections ...................................................................................................................... 34 5.4.5 Post-Felling Inspection........................................................................................................... 34 5.4.6 Log Arrival at the Sawmill ....................................................................................................... 35 5.4.7 Log Processing....................................................................................................................... 35 5.4.8 Processed wood..................................................................................................................... 36 5.4.9 Export ..................................................................................................................................... 37 5.4.10 Import ..................................................................................................................................... 37 5.4.11 Reporting................................................................................................................................ 38
REFERENCES.........................................................................................................................39
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ACRONYMS
CEPS Customs Excise & Preventive Services
CoC Chain of Custody
dbh Diameter at breast height
DfID Department for International Development
DFO District Forest Office
ECOWAS Economic Community of West African States
EU European Union
FC Forestry Commission
FMP Forest Management Plan
FMU Forest Management Unit
FR Forest Reserve
FSC Forest Stewardship Council
FSD Forest Services Division
FSDP Forest Sector Development Project
FSIS Forest Sector Information System
GCNet Ghana Community Network Services Ltd.
GFTN Global Forest & Trade Network
GIS Geographic Information System
GPS Global Positioning System
GSBA Globally Significant Biodiversity Area
HHC Handheld Computer
HQ Headquarters
IAF International Accreditation Forum
ID Identification / Identity (as used in Information Systems)
LIC Lumber Inspection Certificate
LIF Log Information Form
LMCC Log Measurement and Conveyance Certificate
MoFEP Ministry of Finance and Economic Planning
MLFM Ministry of Lands, Forestry and Mines
NGO Non-Governmental Organisation
NTFP Non-Timber Forest Product
OASL Office of Administrator of Stool Lands
OFR Off Forest Reserve
OWIC Other Wood Product Inspection Certificate
PC Personal Computer
PEFC Programme for the Endorsement of Forest Certification
RFID Radio Frequency Identification Device
RFO Regional Forest Office
RMSC Resource Management Support Centre
SP Salvage Permit
SRA System Requirement Analysis
tbc to be confirmed or to be continued
TIDD Timber Industry Development Division
TIF Tree Information Form
TO Technical Officer
TSP Temporary Sample Plot
TUC Timber Utilisation Contract
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TUP Timber Utilisation Permit
TVE Timber Validation Entity
VAT Value Added Tax
VIC Veneer Inspection Certificate
VLC Verification of Legal Compliance
VLO Verification of Legal Origin
VLTC Validation of Legal Timber Council
VLTP Validation of Legal Timber Programme
WTS Wood Tracking System
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Preamble
This System Requirement Analysis (SRA) document describes the requirements for the national Wood Tracking System that is to be used mainly by the future Timber Validation Entity, as part of the Ghana Forestry Commission’s Validation of Legal Timber Programme (VLTP). The system aims to manage credible datasets gathered along the wood product chain of custody and thereby improve control of the sector.
The timber flows to be monitored and verified are: from forests to logging and to processing, or from import to processing, and to local sales or export, with possible changes of status for the products in between (e.g. ownership, location, properties).
Along with the ‘Selection and Procurement’ and the ‘Technical Terms of Reference’ documents, this ‘System Requirement Analysis’ (SRA) document forms the ‘Procurement’ report due by SGS under this project (Component B – Acquisition and installation of a wood tracking system). A ‘Draft VLTP Inception Report’ has been presented earlier, identifying the objectives and options for the design, establishment, management and operation of the VLT Programme in Ghana over the coming years. In addition, a number of Discussion Papers are being prepared to support discussion with, and attract input from different stakeholder groups.
The Selection and Procurement (S&P) document discusses suitable techniques and identifies the range of relevant hardware and software components, a selection of which could be used as part of the required systems. It then looks at possible approaches and procurement strategies and provides the FC with recommendations in relation with the planning and implementation of the processes of selection and procurement for these systems. The purpose of the Technical Terms of Reference document is to define the information that will be held in the system, the required functionality in terms of data inputs, processing and outputs, the field and office procedures and the relationship to other existing and proposed FC systems.
This System Requirement Analysis (SRA) document particularly undertakes a comprehensive review of the ‘Existing Business Process’ at work in the administration of Ghana’s forest sector. The functions and procedures of the multiple institutions involved in the chain of custody are reviewed with the aim of streamlining workflows and improving performance. A revised Business Process is then proposed, describing procedures to ensure transparency and credibility, based on the use of a national wood tracking system (WTS). The changes proposed will have to be reviewed by the FC and a process started to modify and implement them as relevant.
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1 BACKGROUND
In recent years there has been rapid development of international initiatives to deny market access to illegal timber. Governments in producer countries are being encouraged to establish reliable verification and monitoring systems in order to ensure that their timber exports have been legally sourced and produced. Such systems should, in due course, be extended to encompass the entire domestic market. The benefits to producer countries will include guaranteed access to markets for logs and timber products, improved levels of government revenue, a ‘level playing field’ for their forest sector and an instrument to validate sustainable harvest of timber.
This international situation is accompanied by a national need to monitor timber flows effectively in order to capture the full revenue that is due to forest owners, communities and the state. However there is widespread recognition that the governments involved often lack the necessary skills, resources and systems to control their industries, and there is a perception that corruption often prevents laws and regulations from being properly enforced. Legislation in many producer countries is weak, often contradictory, needs to be revised, while enforcement is weak. It is estimated that due to inadequate control systems, uncollected revenue from forest harvest operations is at least as great as that actually captured. At the same time the process of revenue collection is more expensive than it should be, due to inefficient systems in place and excessive paperwork.
Bilateral and multilateral technical assistance programmes, whether short- or long-term, have largely failed to implant sustainable forest management practices and efficient control systems within tropical timber production and processing chains. Nor is forest management certification the answer: certification systems were not designed to address the fundamental problems of legal enforcement. Certification will remain a voluntary, market-led mechanism that cannot enforce legal compliance and accountability on the part of persistently offending companies and institutions. Similarly, ‘watch-dog’ activities by NGOs have value in identifying problem areas but cannot themselves solve the problems.
It has become clear that one of the surest ways to enforce regulations and ensure credibility in the international timber market is to integrate third-party verification at key points within the systems that verifies legal compliance. Long-term operational partnerships are required between governments and independent verifiers of international reputation. Only in this way can accountability be demonstrated and credibility gained. The international standing of the verifier assures purchasers that procedures are being properly followed and laws respected.
The Forestry Commission (FC) has been implementing its "Validation of Legal Timber Programme” (VLTP) since early 2005. The scope of the VLTP includes enumeration of trees in the forest, labelling of logs and other wood products (including any imports), and tracking them from the forest to the mill and onward to export or (later) the domestic market. The programme aims to enhance the FC’s capacity to control legal and illegal activity, as well as to achieve a clearer definition of its role as forest manager and regulator.
Implementation of the VLTP involves a comprehensive review of FC’s current timber monitoring system, which is largely paper-based and operated by more than one operational division. Major problems include the difficulty of reconciling data across divisions and the long delays that render reconciliation ineffective. Previous efforts at building a credible monitoring system have focused on meeting national regulatory requirements, but the FC now needs to build a system that also meets the new requirements of Ghana’s major export markets, especially the EU. A robust system to guarantee the origin of wood products is therefore required, which will reverse the trend of inadequate forest control and loss of revenue while at the same time improving efficiency. In the longer term the system will bring wood processing capacity in line with sustainable resource management.
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An autonomous agency, the Timber Validation Entity (TVE) is being proposed to implement a reliable monitoring and verification system for both wood product and financial flows (i.e. the payment of related royalties, taxes and fees). The FC has contracted SGS as Technical Partner to assist in, among other activities, establishing the TVE and defining the scope of the VLTP. By linking the issuance of log conveyance forms and export permits with legal compliance, including the payment of stumpage fees (“royalties”) and VAT obligations, the agency will support those businesses that are socially and environmentally responsible.
The application of technology will help to reduce the effects of human error and fraud. Complete and accurate data capture in the field is of critical importance. This must be followed up by effective data communication, and the analysis and presentation of information relying on a comprehensive database system. An appropriate combination of labelling systems, hardware, software and communications technology needs to be specified. The system should be able to use a range of hardware for capturing data, depending on environmental and cost constraints. An effective system that identifies fraud reliably will deter malpractice by the threat of exposure.
This approach will call for a degree of commitment to see the measures through to a time when they yield concrete results. A technical solution such as a log tracking system will not solve all the problems of the timber sector, but if introduced and tightened up progressively over a number of years the system will increase the control of the authorities over a sector that is not yielding the returns to the government that it should. Equally importantly, exporters will be in a position to demonstrate that their products have been legitimately sourced - otherwise major markets will be lost to countries where such systems operate effectively. With time the domestic market will also be regulated reducing the threat posed by clandestine chainsaw operators degrading the resource.
2 ‘WOOD TRACKING’: GENERALITIES
2.1 DEFINITIONS AND IMPLEMENTATION FRAMEWORKS
The following terminology is used in this document.
The Chain of Custody (CoC) is the chain of ownership of an item as it passes from seller to buyer and from one location to another on its way from its source to final retail sale, possibly through several different countries. The chain may also involve changes of state, for example through processing from log to veneer or sawnwood, or by some splitting or re-sorting of a particular lot, or by cross-cutting, re-measurement or re-grading of particular items. CoC also refers to CoC monitoring systems that are deployed throughout the entire chain or part of it (see further below).
Tracking system (in the context of timber): a system, comprising field and office procedures, which makes use of specific information technology for tracking the movements of individual logs or bundles of processed wood products, or else, entire truckloads, from source to destination. It should also be usable for tracing these products back to source (cf. “traceability”).
Log tracking system: a system developed and implemented for tracking logs, potentially from harvesting in the forest (or from import) to processing at a sawmill or to export.
Timber tracking system: same as above for tracking timber products in general (rather than just raw logs), potentially from primary processing (or from import) through further processing, to export or final retail.
Wood tracking system: same as above but “wood” is used here in the most generic sense so as to cover all forms of wood products, both logs and timber.
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Tracking systems may be implemented either in a private environment - normally to control harvesting, processing, transport and sales within the scope of a company’s operations or of a particular supply chain - or in a public environment, to allow an authorised public authority to monitor and control the operations of a number of participating companies and/or public bodies. Clearly the latter case is more complex because it requires the involvement of a larger range of stakeholders and calls for a degree of legal enforcement. It normally incorporates a combination of labelling or tagging, documentary checks and physical inspections.
A typical tracking system operated at country level and on a mandatory basis – therefore in a public environment and also referred to as “national Wood Tracking System” (WTS) under this project - should be designed to allow the recording and verification that a given product was produced from a given log, was successively owned by certain owners and was moved from and to certain locations at known dates, allowing the tracing of the wood in a product back to its specific raw material, for example a log. It cannot confer legality per se, but legal origin, ownership and compliance verification activities can be implemented alongside it. Private tracking systems may form part of a larger public tracking system and can strengthen it.
A Chain of Custody monitoring system (also referred to as “CoC system”) is the succession of material handling systems that are deployed as timber moves down the chain. Traditional CoC systems are paper-based audit-trail systems and rely on conventional product marking or labelling. Systems may however make use of more sophisticated/computerized techniques to monitor production/ tracking information.
The terminology “CoC systems” is more often used in association with forest certification i.e. the process of certifying a forest or forest products to the standards of the FSC, the PEFC or other ISO-compliant forest certification programmes. These programmes include two components: certification of forest management for the forest, and certification of the Chain of Custody (CoC), a mechanism associated with product labelling and designed to provide the final buyers or consumers with assurance that they are buying certified products timber i.e. products originating in a certified forest.
In reality, the CoC certification process only looks at whether an organisation (i.e. a logging, processing or trading company) has adequate management information systems in place to support claims that it sells certified products, be it because it produces them in a certified forest, or because it buys and processes or just trade in certified products and can demonstrate that there is no dilution with material from uncertified sources when it sells the products. The process is designed to ensure the integrity of the ‘certified’ timber through each ‘CoC certified’ custodian, but in an anonymous manner. Such “CoC
systems” should not be confused with tracking systems, as there is no tracking of identified products through the chain and the buyer won’t have any information on the CoC (origin, successive owners, dates of production or transactions) - unless it is voluntarily released by the participants in the supply chain independently of the certification process itself (see below). Likewise, a tracking system implemented within a company should NOT be referred to as a CoC system, because it does not involve any change of ownership for the products and it is therefore incorrect, though not uncommon, to use “CoC system” in this context.
A particular situation also in a private environment is that of trade participants in a supply chain voluntarily linking individual tracking systems in a transparent manner so that the final buyer is informed of the source and, possibly, of other details of the supply chain. This is what a number of international initiatives – most of them led by timber trade federations and NGO-supported forest and trade networks - promote. However, this approach is difficult to apply outside short and integrated chains (for example one integrated concessionaire-logging-processing-exporting company selling to one importer-manufacturer). It also tends to encourage concentration in industry and to eliminate the smaller, usually national, producers.
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2.2 OBJECTIVES
In order to gain recognition by all stakeholders, including export and domestic markets, an effective public Wood Tracking System (WTS) operating at national level should pursue the following objectives:
1. The WTS should allow the monitoring of wood flows and related (e.g. financial) flows through continuous collection, verification and processing of data on all products, product movements, payments and associated events throughout the production chain. The WTS should ensure that no timber is allowed to be transported without being registered in the system and authorised by it.
2. The WTS should allow the tracking of any wood product from its point of export or retail, back through its processing stages and changes of ownership to a known forest source (ideally the tree stump itself). However, these requirements for product traceability do not have to be met by the system in ‘real time’.
3. The WTS should enable compliance with tracking requirements to be easily and efficiently checked by inspectors, both by inspection of the products and their accompanying documentation and by reconciliation of relevant data in the computer system.
4. The system should generate reliable information on national timber flows to allow proper management and control of the forest sector, and to provide a basis upon which to issue reliable timber legality verification statements and permits (e.g. for export).
5. The WTS should aid good governance and law enforcement by strengthening staff capacity and promoting legal adherence by forest owners, regulators and the private sector.
6. The use of a computerised database system allows for the physical inspections, the verification and reconciliation of information and any sanctions (in case of infringements of regulations), to be carried out as three separate functions.
7. The WTS must be transparent and well-documented, allowing audits to be carried out by an independent body.
8. Confidential commercial information (i.e. mainly the identity of the participants, especially in complex supply chains, and details on the origin and on the transactions in the chain) is protected by the Agency at all time i.e. not shared with third parties (other companies, authorities, or the general public) outside strict procedures.
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3 PROJECT SCOPING ANALYSIS
3.1 SCOPE OF A WOOD TRACKING SYSTEM
The timber flows to be monitored and verified are: from standing tree in forests (forest reserves, off-reserve forests, and timber plantations) to logging and to processing, or from import to processing, and to local sales or export - with possible changes of status for the products in between (e.g. ownership, location, properties (e.g. species, re-measurement, new grading, length trimmed), new log(s) cross-cut from existing log, new bundles replacing old bundles following new sorting).
The WTS will enable the tracking of individual logs and consignments of processed products, and will include product labelling, physical inspections and documentary checks. It will consist of four main components:
1. the identification and tagging of individual products or consignments using bar-coded labels or RFIDs (Radio Frequency Identification Devices),
2. the incorporation of these tag numbers onto the statutory forms used for declarations, inspections and other relevant records and reports,
3. the use of electronic technology for data collection & transmission, and
4. the development of a database to receive, analyse and report all wood production and movements.
The system will provide full traceability of timber from both Forest Reserves and OFR (Outside Forest Reserve) areas, certify the origin and legal and regulatory compliance of all wood products, and demonstrate that Ghana complies with all international requirements for the legality of its timber, thus enabling it to export its timber and timber products to restricted markets.
Initially the scope of the WTS will be limited to information on forest and timber operations that will include:
• log production;
• log movements from forest to mill;
• mill inputs and outputs;
• processed wood production and transport;
• processed wood exports.
The domestic market will be addressed at a second stage of the project.
Products to be included are logs, individual bundles of processed timber, closed containers of processed timber and bulk consignments. Transport modes to be included are road, rail and sea. Most products for export pass through Takoradi, although it is reported that there are increasing volumes being exported overland to adjoining ECOWAS countries. Most transport within the country is by road, but some log transport by rail from inland concessions down to Takoradi was reported.
Although planned to be gradually introduced, the VLTP is designed to eventually become compulsory across the whole forest product industry: all wood products and all companies will be added into the system. The WTS will therefore be implemented countrywide. Other forest products such as small roundwood (firewood and pulpwood), wood chips and non-timber products (such as wildlife products, bush meat, cane, rattan, charcoal, fruits, resins and gums) may be included at a later stage of implementation.
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3.2 SEQUENCE OF IMPLEMENTATION OF THE SYSTEM
For the purpose of managing the introduction of the WTS, it will be necessary to adopt a phased approach, concentrating first on the highest priorities. A significant period of transition will be needed. However the introduction of verification activities should not necessarily follow the natural sequence of forest activities (i.e. from forest to final processing and export: putting in place control procedures for the first step of the chain before moving on to the next step and so on). Instead, the programme should start by capturing information on selected timber flows, then gradually increase the level of legal compliance - and simultaneously improve the quality of forest sector information - by strengthening systems and procedures and raising the intensity of verification activities.
The focus will at first be on exports, moving on only later to domestic production, as follows:
First:
A production of processed wood products for export;
B log supplies used in this production;
then, gradually introduced:
C all other log supplies to the mills which supply timber for export;
D all log sales from these other log sources;
E all by-products from export production, as well as all production from exporting mills which
is destined primarily for the domestic market;
And finally
F remaining logging and processing activities carried out for the domestic market.
It may be necessary, prior to the launch of the system, to carry out an inventory of timber products already in the production chain in order to identify and “quarantine” them. These can be specially labelled and tracked to distinguish them from new material subject to the new procedures. Alternatively, a limited “grace” period may be negotiated with producers according to their stocks and planned sales.
A pilot project approach will be adopted, allowing solutions to be tailored to the situation on the ground, and organisational changes to be gradually phased in. It should be noted that the system will need to evolve over the coming months and years, both because it will not be possible to implement a full system within the short time-frame immediately available, and because the implementation of a WTS is likely to bring in new working practices which will themselves require further changes to the computer system.
3.3 BUILDING THE TIMBER VALIDATION ENTITY SYSTEM
The WTS is mainly intended to service the public domain, allowing the FC and other central government departments to monitor and control national timber flows and their associated revenues. However the provision and organisation of wood tracking data will also assist private timber production companies to manage their own harvesting, processing, transport and sales activities. In building a national WTS therefore, a combination of a ‘top-down’ and a ‘bottom-up’ approach will be adopted.
A ‘top-down’ approach would be implemented initially at national level in the public sector. A central database would be constructed and companies would submit relevant datasets to the TVE in the format demanded. Clearly, all relevant data from regions and districts will need to be collated together to generate meaningful national results.
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By contrast, a ‘bottom-up’ approach would start at company level. The size and level of sophistication of the private companies involved will determine the approach which be most useful to them.
• Many of the larger companies already have their own wood control systems: for example those which are receiving support from WWF’s Global Forest & Trade Network (GFTN) are encouraged to build up electronic databases detailing their wood product movements. These would only require the design of a simple data interface to pass appropriate information from their existing systems into a TVE database, which could be held at the District or Regional Office. These FC offices could receive, process and aggregate the data and pass it on to a central database.
• For smaller companies, with office PC capability but no dedicated wood control systems, company-scale systems would need to be developed by the TVE to allow companies to collect their data, report their results and export information to the TVE database.
• Many other small companies will not be using any computers at all and will only be able to provide information on paper, although it would need to be in an agreed format. This will imply manual data entry by FC staff at district or regional level.
The combined (“top and bottom”) approach will address both ends of the data chain at once: building a TVE database system (either centralised at national level or decentralised to regional or district level) and at the same time making it easy for companies to submit their data in electronic form. A gradual phasing out of data submission in paper form will be aimed at. Submission of data to District Forest Offices (DFOs) on paper forms will be the fall-back position for all companies when data capture hardware or communication systems fail.
A strategy of centralisation is proposed, with all data collation and reconciliation being carried out at a central TVE office, and appropriate reports and data being dispersed to FC HQ, national stakeholders, DFOs and other local and area offices according to their information needs.
3.4 CURRENT ORGANISATION OF THE FC
Since 1999, when the Government of Ghana passed the Forestry Commission Act (571), the FC has included the agencies implementing the functions of protection, development, management and regulation of forests and wildlife resources. It now consists of three divisions, of which two, the Forestry Services Division (FSD) and the Timber Industry Development Division (TIDD), are involved in forest industry control functions (see Fig. 1 below). The Resource Management Support Centre (RMSC) and the Forestry Commission Headquarters (FC HQ) are also involved. The revenue flow is monitored by FC HQ who control stumpage payments and TIDD who control export levies.
The District Forest Offices of the FSD are the ‘front-line’ operating units of the FC. Their major management effort in the High Forest Zone includes pre-felling enumeration, control of logging, revenue collection, protection of the forest reserves and regulation of OFR logging activities. Other routine functions of the FSD include clearing boundary lines, prevention of illegal farm establishment, maintenance of firebreaks and monitoring of NTFP extraction in the forest reserves. This means that they have both managerial and regulatory roles.
The RMSC is a technical institution based in Kumasi but does not form part of the FSD. It is mainly involved in management planning activities, with units concentrating on mensuration, production and mapping. It validates the data gathered by FSD for yield regulation purposes.
The TIDD is responsible for wood monitoring and control at roadsides, mills and ports; inspection, measurement, grading and certification of wood products; and product pricing and market intelligence.
Guidelines on operations are provided by FSD HQ. However there is no central database for reporting and checking on field operations, and so no easily available information on companies which are in breach of their harvesting quotas or have payment arrears, lapsed contracts and so on.
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Figure 1. Organisational chart of the existing forest control system
3.5 PROPOSALS FOR THE ROLE OF THE TIMBER VALIDATION ENTITY AND OTHER
AGENCIES
The Timber Validation Entity is being established to strengthen the ministerial monitoring and control obligations of the Ministry of Lands, Forestry and Mines (MLFM) and therefore ministerial responsibility shall vest in the MLFM. The Timber Validation Entity should be autonomous in the sense of maintaining a degree of independence from the FC. Its main role should be to host and manage the WTS database and to coordinate activities which will strengthen forest sector control: these will include collection of data from production companies, execution of field verifications, clearance of export permits, etc. (see Fig. 2 below). More detailed activity descriptions will be discussed in section 5.2.
The FSD should become a dedicated regulatory body that includes the functions of the RMSC, and should consider outsourcing their management activities such as compartment enumeration and writing of management plans. Revenue flow collections and disbursements should become more transparent to allow for increased acceptance of FC’s regulatory role by the different actors. This should also allow for FC’s strategic objective of becoming financially self-sufficient in the long term. Financial independence will also form a pre-requirement for the TVE. In the course of the year 2006, Birikorang et al. (2007) conducted a fiscal review of all royalties, taxes and fees that are relevant to the forest sector in Ghana, while Agyeman et al. (2007) advised on the institutional setting.
There will need to be an independent third-party verifier contracted to the Agency, whose role will be to issue verification statements on the basis of independently monitored, processed and verified information. This verifier will be there to lend credibility to the operations of the Agency through its accreditation to reputable international standards. In the absence of accreditation schemes for assessing the legality of timber, accreditation on the basis of ISO guide 66 (EMS system) is acceptable. However, it would be preferable for the third-party verifier to be specifically accredited by a
FSD
(Regions/Districts)
• Property Mark Authorisation (Logging Licensing)
• Road Transport Permits (Conveyance certificates)
• Post Harvesting Inspection
TIDD RMSC
• Yield Approval
• Management Plans Approval
• Pre/Post Harvesting Inspection
Verification Services – FC Headquarters
Finance Dept
HQ/Districts
• Revenue Collection (Stumpage)
• Road Side Inspection
• Mill Site Inspection (Log yard)
• Post Milling Inspection
• LIC issuance
• VIC issuance
• OWIC issuance
• Mill Certificate Renewal
• Harbour Inspection/Control
• Revenue Collection (Levies)
• Export permit issuance and contract approval
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member of the International Accreditation Forum (IAF) to assess the legality of timber, perhaps as a component of compliance with sustainable forest management standards.
The effectiveness of the whole system, including the FC, the role to play by the Ministry of Finance and Economic Planning (MoFEP) and the TVE needs to be monitored on a regular basis. Periodic checks should be carried out by an Independent Observer who will be able to circulate information and keep up the pressure for systematic reform. The reporting framework within which the Independent Observer works, and the validation of its findings through appropriate channels, is important. Given the many interests that converge on the forest sector, and the dependence of the Independent Observer on limited sources of funding, considerable care needs to be taken with the institutional structures and processes that are put in place. The Independent Observer should be an NGO rather than private sector provider. A distinction should be drawn between the Independent Observer – who will carry out third-party monitoring of the regulatory regime - and other forms of external monitoring such as those provided by the third-party verifier. The Independent Observer must conform to exacting standards of independence and impartiality, and build up national ownership of the system while not compromising on standards.
In addition, an Validation of Legal Timber Council (VLTC) should be formed, with representatives from the main institutions and stakeholder groups involved, to oversee the functioning of the programme based on reporting by the Independent Observer. This supervision will include following up forest law enforcement in general, and managing a conflict resolution mechanism (for more details see Agyeman et al. 2007).
Figure 2. Proposed organisational chart (operational linkages) of a new forest control system
FSD/RMSC
• Post Harvesting Inspection (100%)
• Yield Allocation
• Management Plans Approval
• Log Measurement at Landing
• Property Mark Authorisation (Logging Licensing)
TIDD
• Road Side Inspection
• Mill Site Inspection (Log yard)
• Post Milling Inspection
• LIC issuance
• VIC issuance
• OWIC issuance
• Harbour Inspection
• Contract approval
• Export Permit issuance
Administrative Oversight – FC/HQ
VVEERRIIFFIICCAATTIIOONN SSEERRVVIICCEESS
TTVVEEggeennccyy
• Log & Timber Products Tracking
• Data Verification & Validation
• Revenue collection tracking
• Issuance of
• VLO
• VLC
• Harbour Inspection/Control Verification
• Post Harvesting Inspection Verification
• Export Permit Clearance
Independent Observer (IO)
Periodic Checks
Finance Dept.
HQ/Districts
• Revenue Collection (Levies)
• Revenue Collection (Stumpage)
Validation of Legal Timber Council (Receive Reports form TVE and IO and initiate action on
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An additional handicap to the functioning of all FC units is the level of salaries paid, which are still similar to most other Government agencies even though the FC is now a corporate body. It is in the process of shifting its salaries upwards to be more competitive with the private sector, but they are still very low, for most positions less than $100 per month, in comparison with the value of the resource to be regulated. A gradual rise of salaries next to the introduction of a Code of Conduct should make sure that FC staff will be made accountable for their activities and be motivated to follow the work plan up.
3.6 STAFFING THE TVE
A proposed organisational structure for the TVE is presented in Figure 3. The TVE will have four departments, namely Legal, Standards and Certification, Monitoring and Auditing, and Finance and Administration Departments; and it will be headed by an Executive Director. Skilled staff should be recruited to the TVE database management function to carry out data reconciliation, submit queries, generate reports and prepare statistical analyses on a daily basis. Where infringements are found, legally-trained staff members should prepare correspondence for corrective measures to be taken, and should be able to follow up with court action whenever necessary. Figure 3: Proposed organisational structure for the TVE
Initially a small number of mobile field teams (of three members each) should be formed to perform unannounced monitoring missions at sawmills and compartments closed to logging (post-felling inspection). Field staff will initially be a mix of locally qualified staff with expatriates. Each field team will be composed of two local graduates and one expatriate young professional graduate next to a driver. These field teams should spend most of their time out in the field and should be strategically based to cover the entire high forest zone.
The TVE is to be lean with highly performing staff, highly motivated and able to show a track record of performance. All employees will have to sign a Code of Conduct. Training should be a recurrent activity to keep them updated on the latest national and international developments.
3.7 CATEGORIES OF STAKEHOLDERS
In order to manage the introduction of the TVE it is necessary to recognise different categories of stakeholders. These will include:
• Ministry of Lands, Forestry and Mines staff and Forestry Commission staff: FC HQ; FSD HQ; Regional & District Offices; RMSC; TIDD HQ; TIDD graders and inspectors; and (when monitoring of wildlife products and bush meat is included) the Wildlife Division;
• Other government ministries and departments including the; Customs HQ; Ministry of Finance and Economic Planning; Free Zones Board (Ministry of Trade and Industry); Ministry of Food and Agriculture; Ministry of Environment; Ministry of Local Government and Rural Development; Ghana Standards Board; the Environment Protection Agency; and (when fuel wood and charcoal are included) the Ministry of Energy;
• Parliamentary Select Committee on Lands and Forestry;
Executive Director
Legal
Department
2 staff
Standards and
Certification
Department
3 staff
Finance and
Administration
Department
4 staff
Audit and
Monitoring
Department
6 field teams
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• Customs authorities at points of exit;
• Customs authorities in importing countries;
• The Office of the Administrator of Stool Lands (OASL), which ensures that the stools and landowners are fairly treated in the disbursement of stumpage;
• Timber Rights Evaluation Committees for OFR logging;
• Private forestry and timber companies in Ghana;
• The Independent Observer.
A distinction must be made between the core users of the system, with a variety of access rights to create, amend, view and delete data, and recipients of information generated by the system, who will receive reports in electronic or printed format or will, for example, be granted restricted access to relevant sections of a dedicated website.
3.8 THE WTS AND A FOREST SECTOR INFORMATION SYSTEM
A distinction should be drawn between the WTS and a Forest Sector Information System (FSIS) serving the wider information needs of the FC. While the WTS is designed to manage the tracking of wood products, thought should also be devoted to its evolution into an FSIS at a later date. This will be a long-term process for which additional time and funding will be necessary, involving the incorporation of other datasets and functions, for example:
� data on a wide range of other forest sector entities, including for example concessions, concessionaires, inventories, management plans, harvesting licenses, exporters and local retailers;
� other functionalities dealing with, for example, land use planning, reforestation, export and domestic sales, payment of taxes and the management of personnel and equipment.
It was felt that the first candidates for further development of the WTS were functions addressing enumeration and yield allocation, currently done manually by the FC. Training to ensure the transition towards digital delivery of stock and yield maps by Forest Services Division (FSD) Drawing Officers got started during 2006. For that purpose the appropriate automation tools and procedures were implemented (see Van den Berg and Parren 2007). If trees are tagged with a unique ID at enumeration, and data is captured electronically, digital maps could easily be produced using a GIS system such as ArcView. This would have many advantages: much better monitoring of harvested trees, the production of stock maps for the next felling cycle, accurate prediction of harvesting volumes, and detailed information to feed into growth and yield models. It has become evident that GIS will play a more dominant role in forest management and regulation in Ghana’s forest sector. The risks are that with the multiplicity and duplication of soft- and hardware without proper coordination and direction this can become very costly to FC as data and equipment acquisition as well as data sharing, institutional capacity building and human resource needs are to be synchronized. To counteract this trend a GIS master plan is currently developed to ensure that all GIS and remote sensing application development and deployment are approached from the corporate perspective. It is expected that the development and effective implementation of a well designed master plan will help FC to optimize cost as well as improve efficiency and effectiveness in the use of human as well as material resources in the deployment of GIS and remote sensing. The master plan should present the developments as for GIS needs within the forest sector over the next 10 years and could form the stepping stone to developing it into a Forest Sector Information System.
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4 EXISTING BUSINESS PROCESS AND CONTROL SYSTEMS
4.1 OVERVIEW
The business processes described here are those of the current FC regulatory system, in which a largely paper-based wood monitoring system is operated by FSD and TIDD. The system monitors trees and logs at the various stages of harvesting and trade: during enumeration, felling and extraction, in transit, at the mill and at the port. The objective is to measure all the logs and processed wood products produced in the country. Data holdings collected under the current system are:
• Stock List data: the list of commercial trees over 50 cm dbh present in a compartment after enumeration. This includes their stock number (assigned at enumeration), species and diameter (dbh). This data is currently not computerised.
• Yield List data: the list of trees permitted to be harvested from a compartment. This includes their stock number (assigned at enumeration), species and diameter (dbh). This data is currently not computerised.
• Tree Information Form (TIF) data: the list of trees cut by the producer, and their measurements. This is currently collected on paper forms and entered into the Foxpro TIF database (held at Kumasi for the preparation of national statistics) and the Adom accounting databases held at FSD district offices.
• Log Information Form (LIF) / Log Measurement and Conveyance Certificate (LMCC) data: the official log measurement data recorded onto paper forms at the forest landing at the time of loading onto the truck. LIF forms are stored by FC District Offices. Currently the LMCC forms are sent to the TIDD HQ at Takoradi and entered into a national database. A new database has been developed but is not yet used.
• Lumber Inspection Certificate (LIC), Veneer Inspection Certificate (VIC) and Other Wood Product Inspection Certificate (OWIC) forms. Data on the volumes, species and product types of processed wood products that are about to be exported. These are paper forms filled out by TIDD staff after production of the product, and required for obtaining an export permit. Summary data is entered onto a spreadsheet at Takoradi and used to generate export statistics.
The elements of the current business process and control system are described below.
4.1.1 Forest management (pre-logging activities)
Harvesting1 within Forest Reserves is preceded by a Timber Utilisation Contract (TUC) Area Plan. This
plan provides an overview of the whole contract period: the location of timber production areas, areas excluded, the harvesting schedule and the main access roads and tracks to be used. The main features of the timber operations are included and details of any post-logging activities, including re-forestation if appropriate. More details are expected for the first five years: an operational plan for production and utilisation and detailed map of access tracks and camps. Renewal of Property Marks (for both on and off-reserve areas) takes place every six months.
Before a compartment is opened up for logging, 100% enumeration of all trees over a minimum diameter is carried out by staff of the FSD - or by the contractor if he has adequately trained staff, in which case the District Forest Office (DFO) is responsible for monitoring performance. The data are captured in enumeration booklets, noting the assigned stock number, species code, diameter and x,y-positions in the compartment. These booklets are processed by the District cartographer and manually transformed into a Stock Map and Stock List, although some larger companies apparently do this themselves with their own enumeration teams and send their results to the District for approval. By
1 Harvesting regulations (1998) are outlined in a document titled ‘A logging manual for Ghana. Guidance to companies
operating Timber Utilisation Contracts in the high forest of Ghana.’
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application of the yield formula (which normally ensures that only one in three of the harvestable trees of each species is allocated to the yield) a Yield Map and Yield List are produced. Detailed environmental protection standards are taken note of during selection of the yield. Yield approval is in the form of a felling permit which lists the stock survey numbers and species of all trees that can be felled. Every felling permit must be dated. The contractor is required to remove all trees indicated in the yield, but this is not common practice: the current practice of removal of only a few species leads to a gradual reduction in the value of the forest as a consequence of the increasing proportion of less desirable species. The producer receives a copy of the Yield List, containing the stock numbers, species and measured (or estimated) diameters of the selected trees. The Stock Maps remain with the DFO. The producer provides a harvesting schedule and compartment logging plan which must be endorsed by a representative of the RMSC and copied to the relevant FSD Regional and District Managers before any harvesting is allowed. Since a couple of years the DFOs/RFOs are also responsible for writing forest management plans, an activity for which RMSC was formally responsible. The management plans provide the overall management objectives and the state of the forest desired within a time frame of 20 years. The plan is prepared by the FC in collaboration with its stakeholders and must be endorsed by land owners. The plans therefore represent a statement of intent by the FC in managing the resource and provide a means of judging their performance in this duty. Forest Management Plans (FMP) for each forest block (reserve) are to specify the subdivision of Forest Management Units (FMU) into production and protection areas, and the nature of sustainable forest management operations to be carried out therein. The new integrated FMPs replace the old working plans which were originally devised to guide exploitation, especially timber harvesting. The management plans have included details on operations and defined programmes of work. A FMP should encompass at least one felling cycle or 20 years, while the operational plans are expected to be revised every five years. The new planning process provide for local consultation in resource management planning. The Regional Managers are required to review the status of the forest reserve plans (FMPs) under their supervision and set an agreed priority with his district staff for preparation or revision. Once the Regional Manager has initiated the process by selecting the priority reserve(s) to be targeted, the planning team needs to be formed. The team is usually led by (1) the Assistant Regional Manager in charge of Technical Operations and further consists of (2) the respective District Manager, (3) the Regional Collaborative Forest Management support team, (4) support staff from the RMSC, (5) a representative each from the landowners, (6) the District Assemblies and (7) other representatives of local interest groups or specialists as required. As early as possible, the District Manager should consult with the landowners and the District Assemblies and inform them of the programme, while identifying communities dependent on the reserve. The planning team should visit the reserve to meet representatives of the land owners and form an initial impression of the planning arrangements necessary taking note of fire, encroachment, illegal felling, that might make the existing TSP data unreliable. Under the Forest Sector Development Project funded by DfID a total of 26 FMPs (drafts) were developed in the late 1990s which until this very day still await to be reviewed, and accordingly finalised and endorsed. Since the year 2000 no new management plans are written apart for all seventeen Globally Significant Biodiversity Areas created. However, also these management plans are still to be endorsed. This lack of progress and commitment seems to be due to the fact that the District Manager and his Deputy are already stretched to the limit with other activities, so a time factor constraint, and partly because they lack the technical skills and resources aggravated by the inadequate use of modern information technology. Most striking is that the development of management plans are not seen as a priority of Technical Operations and accordingly the formation of planning teams is not effected. This could also be due to the fact that consultation of all stakeholders is felt to be cumbersome.
Harvesting outside Forest Reserves (mainly on farm land) is controlled by Timber Utilisation Contracts, as for Forest Reserves. The identification of possible TUC areas, and consultation with the community on the proposed area is done by the DFO. DFOs also obtain clearance of proposals with the District Assembly for incorporation into the District Forestry Plan (although the latter are mostly non-existent). Harvesting is preceded by an enumeration of all harvestable trees, executed by the FSD. Here too the yield allocation process is applied. Each district has a quota of trees that it may allocate for felling each year which is provided by RMSC and the Regional Forest Office (RFO). Endorsement of proposals by the Traditional Council and the Lands Commission is required. The RFO checks the plans before documentation is submitted to the Timber Rights Evaluation Committee. Next the TUC area is advertised, followed by preparation of the Contract Plan and associated documentation by the bidders and a contract is awarded. The Annual Logging Operations Plan includes a harvesting list within the annual coupe and is
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subject to pre-felling inspection before the Annual Plan can be approved. Approval must be given by the DFO in the first instance but must be endorsed by all the involved landowners and the RFO. Felling can only commence once approval is given. The Pre-felling Inspection Forms Form CO2 together with the felling permit Form CO3 form an integral part of the Annual Logging Operations Plan.
Small scale activities - with a maximum of five trees per calendar year – are covered by a Timber Utilisation Permit (TUP). Initially TUPs were issued for companies to fell trees outside Forest Reserves for a period of six months. However, since the late 1990s the nature of the TUPs changed. Since then they are meant for social purposes harvesting of trees by District Assemblies, NGOs, and community groups – not by commercial loggers. Another category are Salvage Permits (SP) are meant to enable harvesting of trees that have to be felled to make way for public infrastructure projects such as road construction. Since February 2001 the FC has allocated over 570 TUPs and SPs covering more than one third of the total production area (see Table 1) mostly to logging companies for commercial purposes. Finally, replacement allocations are made to holders of pre-existing concessions and leases where for any reason these are no longer suitable for timber operations. In some cases, it is the over-logging by the concession holders themselves that has caused these problems. Replacement allocations involve the reserves with the richest timber stocks, such as Sui FR and Pra Anum FR, and seems to be a reward for bad practice.
Table 1. Harvesting license types and their total aerial coverage.
Permit type Pre-1998 concessions & leases
Replacement TUCs TUPs & SPs Total
Area (ha) 1,488,969 250,070 161,908 1,112,347 3,013,295
Area (%) 49.4 8.3 5.4 36.9 100
Source: Forest Watch Ghana (2004)
District Assembly members, traditional authorities, unit committee members and farmers may inspect logging operations in off-reserve areas. If they consider the standard of these operations to be unsatisfactory they may report this to the District Forest Officer who will carry out his own inspection. For off-reserve logging the District Forest Officer must similarly satisfy himself that all the requirements of the Logging Manual and the Timber Utilisation Contract have been met and that all compensation for damage to crops and farms has been paid.
4.1.2 Forest exploitation
In a Forest Reserve, the tree feller finds and cuts the trees listed on the Yield List. Official procedure demands that each felled tree is inspected by an FSD Technical Officer (TO) before it is extracted and cross-cut. If the tree has defects that are judged to be natural, no stumpage is payable. The feller must mark the stump with paint recording the date, property mark number and tree stock number. Any defects that are judged to be due to human causes (e.g. a mistake made by the feller) will mean that stumpage must be paid even if the tree is left behind in the forest. After felling, and before the tree or logs can be moved, the TO measures the tree and fills out the TIF, although this system is said to be widely abused, with many trees being measured by company staff because of logistical difficulties (e.g. no transport) on the part of the FSD. The measured tree volumes are used in the calculation of royalties, with the TO apparently being allowed a certain latitude in estimating the commercial volume in cases where, for example, a tree is seen to contain substantial heart-rot. Cases have been found where the producer was allocated another tree (not in the yield) if the selected tree was found to be unusable due to natural defects. The TIF is eventually taken to the FSD District Office or Regional Office where it is computerised (into the Adom system) and royalties calculated. This data is collected at RMSC where national statistics are collated. Lengthy delays may be experienced, however, which make it impossible to effectively reconcile the trees cut against those permitted on the Yield List.
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Once the tree has been measured it may be cross-cut into convenient lengths and hauled to the log landing. Details such as species code; locality mark; the contractor’s property mark; the sequential tree number (of trees felled in that compartment) and the sequential log number (whereby log number 1 is the butt log) are painted onto the end of each log. The producer fills in the LIF (which is not computerised), showing the species, dimensions and origin (e.g. concession, compartment and producer) of every log. These are kept by the FSD. LIF data are copied onto an LMCC form by FSD field staff to permit transport. The logs are loaded onto trucks. The LMCC shows what logs are on each truck, including log numbers, species, dimensions, ownership, origin, truck ID and destination.
According to FC regulations the contractor must work consistently through the selected compartment removing all approved trees in a single operation. In practice only a subset of the Yield List is actually harvested, according to the commercial needs of the contractor. Returning to a particular locality for a second cut is regarded as bad logging practice. Providing there have been no unsatisfactory reports on the operation of the logger, he is allowed to move into the next compartment for which all planning has been completed and approved. A detailed inspection is supposed to be undertaken of the closed compartment by the DFO, and a checklist completed to confirm that standards have been maintained at an acceptable level. It is not clear how often this is carried out. If standards have been fully met a Completion Certificate is issued. A contractor is expected to have completed logging within any one compartment in no more than 2 years.
Harvesting outside Forest Reserves is similarly controlled by DFO staff who issue TIFs and LMCCs. Trees to be harvested are assigned to the concession holder under a quota system. The logs and stumps are painted in a similar way as above, showing species code, locality mark; the contractor’s property mark; the contractor’s sequential tree number, and the sequential log number. Logs from off-reserve areas must be marked with the code ‘OFR’.
FSD Regional Offices prepare monthly tree harvesting reports based on the TIF data. In addition the Regional Offices send a weekly performance report to the FSD Operational Office describing where harvesting is taking place and the volumes harvested.
Post-harvest inspection by an RMSC team after a compartment has been completed is very sporadic. It is carried out on a schedule which is known beforehand and at a frequency of less than one survey per year per district. The chances that a compartment will be inspected by this team and in addition only partly are therefore extremely low: much more should be done in this area to verify the actions of the producer in the forest.
4.1.3 Log Transport
The LMCC accompanies the log load and is verified, stamped and signed by TIDD staff mostly at fixed road checkpoints or in the sawmill log yard. At these inspection points the log is supposed to be re-measured and graded by TIDD staff, but in most cases only a visual check is performed. Some random physical checking of logs is carried out to confirm compliance, but most of the checking is routine. If inconsistencies are found then a Re-measurement LMCC is issued and extra royalties must be paid. Log yard inspection is in place to ensure that all logs are covered by LMCCs. The TIDD employs 75 graders to oversee over 200 sawmills, although it was indicated at the time of the FC reorganisation that they required 106 persons to do the work effectively. TIDD staff do not work after 6 p.m. each day. At Takoradi, TIDD enters all LMCC and Re-LMCC data in a database but there is no systematic reconciliation with the FSD’s TIF or LIF data.
Consolidation and analysis of timber production data is the responsibility of the Research and Information Management (RIM) unit of the FC, and the Operations Director at FSD headquarters is responsible for reporting on infringements. Computerised TIF and LMCC data are not reconciled systematically, and on the rare occasions when reconciliations have been done companies were not held accountable for infringements.
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Recently a programme of log auditing has been initiated by TIDD’s Log Tracking Manager, involving random checking of logs at mills. He inspects logs at random and fills out a Log Audit Form showing the species, property mark, locality mark, tree & log number, LMCC number and date of issue, for checking against declared data.
4.1.4 Primary processing
Logs are stored at sawmill logyards and converted into primary products such as lumber and rotary or sliced veneer according to commercial demand. Frequently logs are cross-cut just before milling, and/or the ends are cut off to remove stained or damaged parts. Primary conversion can be a complex process to track, often with no simple relationship between the logs used to fulfil a contract and the volumes produced.
When products have been produced for export, a TIDD inspector fills out a paper inspection certificate for each consignment produced, detailing the volume and type of products: an LIC for lumber, a VIC for veneer, a Curl Measurement / Grading Certificate or an OWIC for other products (i.e. plywood). This is a requirement in order for the exporter to obtain an export permit. The issuance of each of these certificates by TIDD attracts a fee of 5,000 Cedis.
Producers have recently been asked to list the LMCC numbers of the logs that they have used to fulfil a contract of processed wood for export. In theory this declaration should allow verification of which logs have been processed for each contract, and reconciliation of the volumes and conversion rates, but only if the data can be independently validated as accurate, and provided that declaration is done across the whole of a company’s operations so that a legal log cannot be claimed several times to conceal the use of illegal logs. When recording the identities of the logs used, TIDD staff must fill out LMCC details on Input/Output Sheets and submit them to the Log Tracking Manager within five days of issuing the LIC/VIC. The producer also has the obligation to fill out an Input (logs) – Output (transformed product) Declaration.
The log yards of most of the smaller sawmills operating in rural areas are not checked by TIDD due to staff limitations. Accordingly the TIDD should consider outsourcing their standard inspection activities. Forms for recording the input and output of sawmills are provided by TIDD but are often not submitted by the operators. This should be made a legal obligation.
Some of the larger production companies, for example John Bitar Ltd, already have sophisticated database systems (with a complete manual backup) which track materials through log production and processing, linking for example log production in the forest with arrivals at the sawmill, and input to sawmills with fulfilment of export contracts for processed wood. Data from these kinds of systems could be exported into a TVE database provided that the requirements are sufficiently well specified.
4.1.5 Transport of primary processed wood
No special forms or authorities are required to transport processed wood from the mill to the port apart from the LIC issued. No roadside checks are made by TIDD of trucks carrying loads of processed wood. In the case where primary products such as sawnwood or lumber are packed directly into a container for export, TIDD and customs staff, check the products before the container is sealed at the processing plant.
4.1.6 Secondary and further processing
When products have undergone secondary processing before being exported, the regulations are the same as for primary processed products: TIDD inspectors fill out OWIC forms detailing the volumes and types of products produced in order for an export permit to be obtained.
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4.1.7 Domestic retail outlets
No special rules apply to the sales of processed wood on the domestic market. However, TIDD registers all companies that sell on the domestic market. TIDD retailer’s registration is 20,000 Cedis and annually renewable. It should be noted that companies (including most of the larger timber processing companies) who choose to become “Free Zone” companies can only sell up to 30% of their output domestically. Free Zone companies are controlled by the Free Zones Board who require quarterly declarations of imports, production, exports, local sales and other data. Local purchases of raw materials into Free Zones should be made in hard currency but is normally not adhered to. A database of this information is held in Accra at the Free Zones Board HQ. Domestic retail outlets officially have to register and declare VAT of purchases and sales on a monthly base when they have a turnover of more than 200 million Cedis. However, most of these outlets prefer sales without using VAT forms. The VAT Services are having a digital database of these monthly reports.
4.1.8 Export (by sea or overland) of wood products
Timber export procedures can be classified under three broad headings as follows:
• Contract approval. This involves the submission of contracts by exporters and their registration and vetting by TIDD staff.
• Mill and pre-shipment inspection, which involves inspection, measurement and grading of wood products at mill sites and at the port. This also includes random inspections at both mill and port.
• Export permits approval. This involves the reconciliation of mill production against contract, inspection reports and confirmation of payment or payment arrangements. Export permits are issued against specific contracts, inspection reports and vessels. Export permits are valid for twenty one days.
Details of the timber export procedures are highlighted below:
1. Contract Approval
Seller must be a registered exporter of wood products at a fee of 100,000 Cedis, which is annually renewable for 50,000 Cedis. TIDD registers all exporters in accordance with Act 571. Requirements for registration as an exporter include
• Certificate of Incorporation
• Certificate to commence business
• Company’s code (limited liability Companies)
• Income tax clearance certificates
• Inspection reports (compulsory for new mills)
Buyer must be registered with TIDD as a buyer of wood products from Ghana. Buyer must fill out registration form which is now available on line form www.ghanatimber.org. Bank reference of buyer is a requirement. A registration fee of US$50 is paid by the buyer.
Exporters are to provide evidence of source of raw material, while prices are based on guide prices that are issued quarterly by TIDD. TIDD will not approve a sales contract if the contract price is lower than TIDD guidelines. Terminologies such as recovery and firewood are no longer permitted on contracts. Any recovery material must be inspected and contract drawn separately. As much as possible such material will be discouraged from exports with the hope that these will be placed on the domestic market and help bridge the demand gap on the domestic market. Information on contracts should include the following data (1) contract number, (2) species, product, quality, quantity, specifications, (3) prices, terms of payment, (4) destination, (5) signatures of seller and buyer, and (6) terms/conditions specified behind and on Ghana hardwood contract form. The quality must be
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specified in all cases, while the terms of payment should preferably be by irrevocable letters of credit. However in recent times other forms of payment are being encouraged and monitored. Contracts are valid for a period of six months.
2. Pre – Shipment Inspection
Pre-shipment inspection refers to the inspection of timber at mills and at the ports to ascertain the species, product type, quantity, etc. as specified in the approved contract of sale. Inspection at Takoradi port is done by the TIDD. TIDD HQ in Takoradi receives an export dossier from the exporter containing (among other documents) a sales contract approved by TIDD at Kumasi, or Takoradi, and the inspection form (LIC, VIC etc.) issued to confirm specifications, quality, quantity, etc. at the mill. Three TIDD graders of the TIDD inspection office at the port perform a 10% sample of physical inspections on the wood bundles in the port warehouse, which consists usually of a check on dimensions, quality and moisture content (but which theoretically may extend to opening the packs, re-measurement and re-grading). If everything is found to be correct they will endorse the inspection certificates which form the basis for the issue of timber export permits.
If goods are to be directly exported by container load from the processing mill, loading of products into containers must in all cases be done under the supervision of TIDD staff. Containers must be sealed in the presence of CEPS staff who must always sight the TIDD inspection certificate. CEPS staff must be present at the time of sealing up of the container. The exporter must inform the customs service who send an inspector to perform an inspection before the container is sealed. Containerised products are to be appropriately bundled to facilitate loading and off loading for re-inspection purposes.
Random selection of containers containing timber and timber products can take place for final inspection in the harbour. This is done from list provided at the application for permit. Sample size will be dependent on number of containers. As a general rule 5% inspection is under taken. Percentage and frequency to increase with companies found with discrepancies. Containers selected are opened up to sight the product or completely discharged for inspection and measurement. Exporters are required to amend entries when discrepancies are detected before export permits are issued.
3. Export Permit process
Export permits are issued to applicants after reconciliation of contract approved details with inspection
report at mill and port. Requirements for the issue of permit include the following:
• Approved TIDD Contract of sale
• Approved Bank of Ghana Exchange Control form A2 for traditional exports and Export
Form A2 for non traditional exports.
• TIDD inspection report dully endorsed by grader
• Endorsement of specification sheet by buyers representative or agent where such a
representative has registered with the TIDD
• Specification sheets of the company
• Evidence of payment or Letter of Credits. A register of payments and balances on the Letter of
Credits is kept by the TIDD.
Export is approved by TIDD HQ staff who will issue an export permit at no nominal fee. Phytosanitary certificates are sent on by TIDD after shipment, which must take place no more than 21 days after grading..
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The dossier is then passed onto the Customs Service (CEPS). The exporter or his agent has to make a customs declaration using the GCNet system. Each consignment attracts a fee of 25,000 Cedis payable to the Ghana Shippers Council. CEPS check that the exporter has the correct A2 Exchange Control Form from the bank, the TIDD Export Permit, the Packing list and the Shippers Council invoice. When clearance is given, after cross-checking the bill of lading with the ship’s manifest, he is able to export the goods. The exporter presents the export release to the Ghana Ports and Harbour Authority who then advise the stevedoring companies by also providing a release. Exporter makes copy of release to shipping line to make shipping note available to stevedoring company. Shipping line and stevedoring company arrange to make cargo available on arrival of vessel for loading.
Exports are subject to a 1% levy in hard currency for the TIDD London office, and 2% in local currency for the FC. Tertiary products do not attract the 1% levy. There is also an Air-Dry levy imposed for the export of seven species.
Exports at Takoradi are well-controlled, but it is reported that the increasing overland exports to adjoining countries such as Togo, Côte d’Ivoire and Burkina Faso are less well regulated. Overland export sales contracts are approved by TIDD at all five of their area offices. Customs declarations are made on paper forms because GCNet is not yet operational at these borders, apart from at Elubo and Aflao. The existence of many uncontrolled roads over the border means that illegal exporters are able to pass without declaring their products to customs. There is no customs duties payable within ECOWAS.
Free Zone companies are exempt from all taxes for ten years, and afterwards all profits are taxed at 8% Corporation Tax, on both domestic and export sales. Companies other than Free Zone companies are taxed on their export profits at a rate of 8%, while profits from local sales are taxed at 28%. This tax is location sensitive, with up to 50% tax rebate being available in less favoured areas of the country.
VAT declarations of purchases and sales must be made monthly by all companies. The VAT office checks production records against gate records and keeps a digital database of declared data, with sales figures split between domestic sales and exports.
The Export and Import Act of 1995 (Act 503) has classified all timber products with the exception of logs and lumber as non-traditional products. Hence many timber products, including plywood, are not subject to customs duty and VAT, causing loss of revenue to the state. The exporters of these products are also granted corporation tax rebate under the law. MLFM was not consulted in the formulation of the Act, of which the principal architect was the Ministry of Trade and Industry. The export figures of these products are presently not captured by TIDD as the do not require an export permit.
Data on the export of dressed chainsaw lumber - and other products manufactured from it - is unavailable. Odoom (2005) learnt that at the Tarkwa District Office there has been some importation of chainsaw lumber from Côte d’Ivoire through the Elubo, Drobo and Sampa border towns. Attempts to prosecute the importers in Ghana failed as the product is legal in the country of origin. The imported chain sawn lumber is said to find its way to the northern parts of the country and into Burkina Faso.
Due to the worsening shortage of raw materials in Ghana, a few companies are importing processed wood from countries such as Cameroon, and Gabon, for further processing followed by export. No import duties are levied on timber products although there has been some confusion with CEPS about this. In the year 2005, almost 300,000 m
3 of wood products were already imported, and the size of
import volume was 63% of that of exports (see Birikorang et al. 2007). These data are derived from the CEPS/GC-NET database and are not linked up with TIDD data collection and registration.
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4.2 PROBLEMS WITH THE SYSTEM
Preliminary analysis of the present situation reveals a number of areas where problems exist and significant improvements can be made.
• While considerable amounts of data are collected and stored electronically, such as TIF data by the FSD, and LMCC and export volume data by the TIDD, the scale of the delays experienced in bringing the information together, and the lack of systematic analysis, means that there is no effective verification of the data.
• Much data relevant to the tree harvesting process, such as Stock Maps and Stock Lists (derived from forest compartment enumeration), and Yield Lists of trees permitted to be cut, are currently held largely in paper form and so cannot be cross-checked with electronic data. Maps are being drawn by hand which is time-consuming and error-prone.
• Post-felling inspection to assess the quality and extent of the enumeration and harvesting damage after compartment closure though to some extent effected still allows for excessive damage to the forest, and overharvesting by removal of non-allowed trees not forming part of the Yield List. The difficulty here is that at times offences become difficult to identify since a compartment is open for harvesting up to two years.
• Transport is a serious limitation for FSD staff, and this combined with the large number of felling sites in some districts makes it impossible for staff to be always present to fill out TIFs and LMCCs. As a result there is often little control and log producers retain the upper hand.
• Lack of cooperation and collaboration on the part of certain forest fringe communities to assist the FSD in protecting the forest resource and effecting illegal log and chainsaw lumber transport. As a result considerable loss of revenue to both the state and forest owners is evident.
• Field staff spend much of their time on routine data-collection tasks, with TIDD staff checking the LMCC forms filled out by FSD staff. This leaves little time for monitoring and controlling the conduct of the operations themselves.
• Due to TIDD staff limitations, considerable reductions in staff after the organisation came under the umbrella of the FC, the system does not cover all the smaller sawmills operating in rural areas. There are ‘leaks’ in the system, with logs being produced but never declared: examples are the conversion of logs to lumber in the forest by chainsaw operators, the operations of bush sawmills that process chain sawn lumber, and logs that may arrive at sawmills overnight and are never declared to the authorities.
• Fixed checkpoints are not an effective way of detecting illegal log transport because contractors know in advance that they will be required to provide documentation which at least appears valid. Although some rotation of staff was found, personal friendship between staff and drivers erodes the will to enforce regulations properly. Some reorganisation of roles should allow the routine checking of trucks at fixed checkpoints to be reduced in favour of targeted, unannounced checks. Unannounced checks, perhaps involving the rotation of inspection teams between log landings, roadsides and sawmill log yards, have a much better chance of detecting illegal products.
• Communications between FSD, RMSC and TIDD are poor, with offices reporting up and down their respective hierarchies but not across to each other. Most communications are still paper based, making the whole decision making process prolonged and slow. Reporting to other stakeholders is almost non-existing, hardly allowing them to check on the FC’s performance both for capturing the correct timber as well as revenue flows. Data exchange and reconciliation with other government bodies (CEPS, VAT) is also completely lacking.
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5 PROPOSED BUSINESS PROCESSES AND CONTROL SYSTEMS
5.1 INTRODUCTION
The overall aim of the WTS is to speed up and facilitate the collection of tree and log production data at various points in the chain of custody, its transmission to a central database and its subsequent analysis and reporting, in order to provide timely and accurate information about the origin of wood products being produced in the country, especially (in the first instance) those destined for export. What is proposed here is a system that can be implemented relatively simply without major changes to procedures, but which will initiate a process of long-term change to government monitoring procedures
By bringing together electronic data from Yield Lists, TIFs, LIFs/LMCCs and LICs/VICs/OWICs on a regular basis, and performing analyses quickly enough to detect inconsistencies within a matter of days (rather than weeks or months, if at all), it will be possible to verify the source of wood products before they are exported, and in this way validate their legal origin. Questions to be answered should include:
• Which logs were used to produce this batch of processed products: does the volume of logs involved correspond to the volume of products produced?
• Which trees did these logs come from, and were the trees felled the correct ones permitted on the Yield List?
The main strategies for effective monitoring of the system should include:
• Efficient data collection with the aid of appropriate technology
• Rapid communication of data to a central point
• Regular, frequent analysis and comparison of relevant datasets to ensure data quality and to indicate anomalous results which should be investigated
• Speedy and effective action taken in the cases where infringements are found
• Unannounced sample checks in the forest, in the log yards of sawmills and on the roads.
At the core of the system is the WTS database, which will hold data which has been collected by handheld devices in the field, or submitted to FC offices in other ways. The database will be hosted by the TVE, with authorised users having access to appropriate levels of information. Management reports will enable the analysis and reporting of forest and timber operations including log production, log movements from forest to mill, mill inputs and outputs, timber exports and (in the future) sales to local retail outlets.
Effective use of technology will assist field staff in the collection of data and speed up its transfer to the central database. Technical solutions such as bar-coded or Radio Frequency ID tags, hand-held computers, GPS (Global Positioning System) receivers and other devices are being reviewed (see the Selection & Procurement document). However it will be necessary to transfer data from the field even in districts where electricity supply and telephone links are unreliable, which presents a technical challenge. In some cases the use of satellite technology may be necessary.
5.2 RESPECTIVE ROLES OF THE TVE AND THE FC
The use of technology will minimise the time spent on manual data collection and allow FC staff to devote more effort to the actual supervision of field activities. Attention will be paid to ensure full proof and the system not being open for manipulation.
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Wherever possible the routine tasks of recording and declaring logs and processed products should be left to the private sector, with government agencies performing targeted checks to ensure that the system is working correctly. The Timber Validation Entity (TVE) will act as a verification and validation body, making independent checks on the activities of the private sector and the component divisions of the Forest Commission. There will be three main areas of activity:
5.2.1 Database management and reporting
Private companies will submit data either to their local FC office or directly to the TVE. FSD and TIDD offices will submit data to the TVE. Reconciliation and reporting of national data will be the responsibility of TVE HQ staff. They will ensure that data is submitted on time from each district or area office, to allow reconciliation of the appropriate datasets within the time deadlines required. They will perform the reconciliation and reporting functions and deliver appropriate reports and information to FC HQ. Data reconciliation will encompass verification of both timber and revenue flows. The actual revenue collection (both levies and stumpage) is under control of the FC HQ but might be overseen by the MoFEP. An increased level of transparency is required of revenue collection and expenditure. Summary findings might be published on the FC’s internet page detailing the revenues collected per district and royalties due to the respective traditional authorities.
5.2.2 Field verification
TVE field teams will be set up to monitor the operation of the system in the field. They will perform random checks to verify that FSD and TIDD staff are operating the system correctly, and that private companies are meeting their obligations for declaring data. FSD staff will concentrate on fulfilling 100% post-felling inspection and accurate log measurement at the log landing, while TIDD staff will concentrate on log yard tag checking, input/output declaration checking at the sawmill and finished products inspection at the sawmills and harbour before export.
5.2.3 Licensing scheme
The TVE will issue verification statements of legal origin of logs and timber products based on a modular Verification of Legal Origin (VLO) system, i.e. verification that the logs and timber products in question have been legally sourced and are legally owned.
The TVE will issue verification statements of legal compliance by timber producers based on a modular Verification of Legal Compliance (VLC) system, i.e. verification that the timber producer is complying with all relevant national legislation. This includes legislation relating to forest management planning, land management and forest exploitation, demonstrating that logs and timber products have, in a wider sense, been legally produced.
At operational level, monitoring of VLO and VLC will be by: verification of documentation including production declarations and permits; field inspections to ensure compliance with the documented record; remote sensing by satellite imagery or aerial photography; log and timber product tracking from source to point of export; verification of royalty and other payments; and random checks on logging areas, truck loads and sawmills.
Together, VLO and VLC make up the comprehensive Validation of Legal Timber Programme. Products successfully verified as both legally sourced and legally produced will qualify as validated legal timber. Based on the foregoing the TVE will give clearance for export permits to be delivered for successfully verified export consignments. TIDD will remain issuing the actual export permits but this should be merely a formality to facilitate the exporter and be granted within a couple of days after TVE clearance. When applied to domestic markets, VLO and VLC will support enforcement of legal compliance by the FC for local production.
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With the existing overcapacity by the industry, Property Mark authorisation (logging licensing) should be linked to legality verification and Property Mark clearance services should be handled by the TVE. In principle no new licences should be handed out and existing ones revoked when companies are in breach of VLO and VLC requirements. Newcomers should no longer be accepted since an explosion of Property Marks to over 1000 from around 200 a couple of years back (see also Table1 ) are not in the interest of long-established operators who aim to manage the remaining dwindling forests sustainable. Monitoring of Property Marks allocation together with its spatial allocation can easily be derived from the TVE’s database which will encompass a Geographic Information System (GIS) component. After TVE’s clearance the final Property Mark authorisation and licensing can be done by FSD still.
5.2.4 Law enforcement
The critical elements of a forest sector regulation system that must be in place to successfully implement VLT as we saw above are as follows:
• a system for gathering and managing forest sector information and statistics;
• a system for monitoring forest activities for compliance with laws and regulations to detect and report offences; and
• a system for enforcing laws and regulations and sanctioning offenders (i.e. both non-compliant legitimate timber producers and illegal loggers operating inside and outside legitimate forest production areas).
VLT will assist the FC’s overall forest sector monitoring and control. Law enforcement itself is the preserve of the relevant authorities. As such, overall law enforcement processes should be exposed to scrutiny through a proposed Validation of Legal Timber Council to make sure that any reported forest crime is properly addressed and every case brought to a conclusion. The TVE could assist the FC in the preparation of law cases and monitor and report progress. However, it is up to the FC to take up any legal cases which will be critical to the success of the VLTP. It would be important to note that a VLTP and accordingly TVE without teeth would only lead to the MLFM and FC loosing face. Handling judicial cases of the TVE might be directed to a special court (to be created) to ensure appropriate, transparent and swift handling of these court cases. It will be advisable for the TVE to have judicial staff being recruited on a permanent basis to prepare and follow up cases. Court cases and their verdict might be advertised on the FC internet site, to provide transparency to the process and credibility to the international scene.
5.3 PROCEDURAL CHANGES TO ACCOMPANY THE INTRODUCTION OF THE WTS
The following changes to procedures are recommended to accompany the introduction of the Wood Tracking System: some are significant departures from current practice but it is felt that they are justified in terms of the increased effectiveness that a new system incorporating wood tracking techniques will bring.
• Changes to the Off-Reserve quota system. Off-Reserve (OFR) areas are gradually being cleared and are calculated to last about 25 years until substantial areas of plantation (now being planted) are available for harvesting. However experience suggests that many trees in OFR areas are being cut illegally by farmers and/or chainsaw operators, with no benefit to the nation or to legitimate local authorities. There is no advantage in preventing authorised companies, who are currently short of logs, from taking all trees over the felling limit in their assigned areas, since the trees may well not be there in later years when they are finally permitted to be harvested. A mere area confined (concession system) harvesting system per district (after stock survey) should be worked out (for more details see Parren et al. 2007). That will also encompass legalising one chainsaw gang per district who should occupy that area together with legal operators and prevent others (illegal chainsaw operators) from felling trees. A harvesting regulation like in Côte d’Ivoire might be considered in which the annual allowable yield for OFR is calculated by the formula 0.25 x total surface (ha) = tree removal (m
3). Since current
29
management and regulation of the OFR areas by FSD can be characterized as being (1) time consuming and (2) ineffective in detecting infractions – like looking for a needle in a haystack – a new approach is a necessity. A high resolution remote sensing system with time series of three months in between should guarantee that the allowed yield is adhered to.
• Removal of TIFs. Due to understaffing and logistical problems the current system requiring the presence of FSD staff at both the felling site and the log landing is not working properly: in practice the producer is often measuring the felled tree and logs - and filling out the TIFs and LIFs - himself. By concentrating the control interventions by FSD staff on post-felling inspection and overseeing exploitation at the log landing, effective control over forest operations can be improved since logs from several felling sites are skidded to the same log landing. We therefore propose that the TIF system should be stopped, and that royalties should be based on removed log volumes instead of felled tree volumes. This will better reflect the actual commercial volumes extracted from the forest. Meanwhile increased attention to post-felling inspections will ensure that harvesting standards are well maintained.
• Changes to LMCCs. If logs are declared correctly at the log landings and at the sawmills, and the system is effectively monitored by random inspections by FSD, TIDD and TVE field teams, the LMCC ceases to perform a useful function. The presence of a bar-coded or RFID tag on a log will be sufficient to indicate its legality as long as appropriate checks and reconciliation processes are in place. Meanwhile the LIF form will be retained as a waybill describing the contents of the truck load. At present it is doubtful whether the routine checks of LMCCs by TIDD staff at checkpoints and at sawmills is effective in view of the costs in time and money.
• Outsourcing of enumeration. The FC is acting as both manager and regulator in the forest sector, i.e. both judge and jury. A typical example is the pre-felling stock survey which is usually executed by FSD staff and also checked by them and RMSC. Log producers are sometimes delayed in their operations since there are not enough enumeration teams able to do the stock survey in time. In Central Africa the enumeration is mostly executed by specialised consultancy firms on behalf of concessionaires or by concessionaires themselves. By introducing a similar arrangement in Ghana, backed up by FSD staff conducting a 100% post-felling inspection of compartments, the FC will retain only its role as regulator and will be better placed to check the quality of the enumeration. At the same time a shift from manual to digital handling of the data captured in the surveys to produce the stock and yield maps and lists will increase efficiency (see Van den Berg and Parren 2007). This entire operation could be outsourced to the private sector, in collaboration with the Mensuration Unit, Mapping & Remote Sensing Unit and Computing Unit at RMSC. The electronic yield map should form the basis for a digital harvesting map reflecting terrain conditions by using a digital topographic modelling and showing the essential local features such as streams, roads, villages and conservation areas at both the reserve and compartment level (see Van Oene 2007).
• Outsourcing of management plan writing. Since a couple of years the DFOs are responsible for writing forest management plans. However, since the year 2000 this is no longer happening caused by lack of time and technical skills of staff and inadequate resources made available to collect baseline data. In most tropical countries the concessionaire is responsible for handing in a forest management plan after he has been allocated the concession (for Ghana this implies a TUC-holder) but before he is allowed to operate. He has to hand in his management plan according to specifications provided by the forest service which is then to be endorsed before he can start operating. For Ghana this could imply that specialised consultancy firms on behalf of concessionaires or the concessionaires themselves write a management plan according to certain specifications which then should be endorsed by the RMSC. A management plan should contain a long term vision of the concession and not only be focussed on timber production alone but should deal too with the services provided by the forest at large (see also Van Oene 2007). The management plan should be handed in to the FC in the form of a hard copy but also as a soft copy to include digital (thematic) maps which assist in the decision making process. Certain baseline digital data (to be specified) should be provided in a digital form too next to
30
allow for field verification whenever it is felt necessary. This goes hand in hand with RMSC focussing on the setting, and monitoring of forest management (planning) standards.
• Outsourcing of inspection. The TIDD is facing serious understaffing problems after the reorganisation to fall under the umbrella of FC, especially in the field of inspectors to cover all sawmills at regular intervals. A total of just 85 inspectors are available of which most of them hold only a School of Forestry (Sunyani) Diploma, while five hold a degree from a Forestry School in Gabon and the only ones holding the internationally recognised grading certificate from France are no longer with TIDD. With the challenge to provide inspection covering both exports and the domestic market over time it would be recommendable to outsource most of this activity. At the time of TIDD’s reorganisation it was already suggested to outsource inspection. In Malaysia, under supervision of the Malaysia Timber Industry Board, inspection is mostly executed by private inspectors who could form part of a specialised consultancy firm. These agents are then hired by processing plants operators to quantify and grade the products. They are enumerated based on daily volume inspected. By introducing a similar arrangement in Ghana, backed up by TIDD staff conducting the final inspection in the harbour and an auditing team which visits processing plant sites according to a predefined protocol, the FC will be able to provide services at all areas at regular intervals and be better placed to check the quality of the inspection. TIDD should ensure that all private inspectors are holders of the internationally recognised grading certificate from France, provide refresher courses, handle grading claims and provide arbitration.
Other changes proposed are those that are essential for the introduction of a Wood Tracking system, as follows:
• Allocation of tags to log and processed wood producers for tree stumps, logs and processed wood bundles according to their permitted future production.
• Each tree stump to be marked after felling with a bar-coded or RFID tree tag.
• Each log produced to be marked with a bar-coded or RFID log tag. Logs found not bearing a tag will be regarded as being of illegal origin.
• Log producers to submit log production data (i.e. LIF data) to the DFO or directly to the TVE, for entry into the WTS database. These data are to be in electronic form where possible. If not then data entry will need to be done at the DFO and the results sent on electronically to the TVE
• A systematic programme of post-felling inspections of harvested compartments to be carried out by FSD staff. Data to be captured electronically to allow comparison of results with permitted yield
• FC staff to check the measurements and documentation of samples of logs in the forest (FSD) and at roadside or in log yards (TIDD), using a systematic programme of unannounced, targeted checks. Data to be captured electronically to allow comparison of inspections with company log declarations.
• Processed wood producers to make declarations of their daily production, showing the tag numbers of the logs received, the logs used for each processed wood contract, and the volume of processed wood produced.
• Each consignment of processed wood (initially only those prepared for export) to be marked with a bar-coded or RFID processed wood tag, and this data to be submitted to FC.
• TIDD staff to check the measurements and documentation of samples of processed wood bundles at sawmill yards, roadsides and/or the port. Data to be captured electronically to allow comparison of inspections with company declarations.
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5.4 PROPOSED BUSINESS PROCESSES
This following description is of the proposed new procedures for tracking wood from stock enumeration through felling, cross-cutting of logs, conversion into primary and secondary products and export, as visualized in the diagram below.
Activity Output Data source Reconciliation Key data
Enumeration Stock List / Map Private Stock no
↓
Yield selection Yield List / Map Private Stock no
↓
Yield endorsement Yield List / Map RMSC Stock no
↓
Post-felling insp. Felled tree list FSD / TVE Yield List, LIFs Stock no, tree tag no
Log produced and
transported Log (LIF) data
(declaration)
FSD / Log Producer Yield List Tree tag no, stock no,
Log tag no
↓
Roadside Log
Inspection
Log data
(inspection)
TIDD (HHC) Against log
declaration
Log tag no
↓
Log yard Log arrival Primary Processor
TIDD / TVE
Against log declaration
Log tag no
↓
Log converted Log conversion Primary Processor Log tag no.,
Contract no.
↓
Primary PW
transported PW data
(declaration)
Primary Processor Against logs
converted
Log tag no. Primary PW tag no., Contract no.
↓
Primary PW
inspected PW data
(inspection)
FC (HHC) Against primary
PW declaration
Primary PW tag no.
↓
Primary PW
exported PW arrival
(at port)
Exporter Against declared
waybill no.
Primary PW tag no.
Export dossier no.
Or … arrival at
secondary mill Processed wood
Arrival
Secondary Processor
Against Primary PW declaration
Primary PW tag no.
Contract no.
↓
Secondary PW
transported PW data
(declaration)
Secondary Processor
Against primary PW converted
Secondary PW tag no.
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↓
Secondary PW
inspected PW data
(inspection)
FC (HHC) Against secondary PW declaration
Secondary PW tag no.
↓
Secondary PW
exported PW arrival
(at port)
Exporter
TIDD / TVE
Complete history Secondary PW tag no
Export dossier no.
5.4.1 Stock Enumeration and Yield Selection
Stock enumeration and yield selection will be ceded from the FSD to private companies. For Ghana this could imply that specialised consultancy firms on behalf of concessionaires or the concessionaires themselves could do this. This implies building capacity of specialised consultancy firms of which at least one professional forester forms part, as a form of quality insurance. In case of non-compliance to the standards a penalty system will come into force which will consist of the license removal of the professional forester who signed for quality control of the final products (output).
Blocking of compartments to be opened up for exploitation, is still to be done by FSD until all compartment pillars are in place. When this activity has been completed for all timber production forests in the country it will automatically become void. After opening of the compartment boundary (demarcation) a detailed stock enumeration will be carried out before a compartment is opened for production. The system will be similar to that employed currently, except that more information will be collected for each tree than is currently the case. This will include tree quality (i.e. rotten, senescence), bole length (up to first branch) and form data (i.e. crown, stem) in addition to the current data of position, species and diameter. This will be beneficial in the decision making process on what trees to retain, to be assisted (liberation thinning) and to form part of the yield, taking into account wood quality, bole length to prepare more accurate volume tables per species, stem form to consider higher conversion rates, crown form to determine the individual tree’s growth potential as part of the forests biological processes. As at present, a stock number is written onto the tree bark using a scribe. There is considerable scope for streamlining data capture and data entry by using hand-held computers in the forest to record data, possibly combined with GPS (if it is found to work well enough under the forest canopy). Whether GPS is used or not, plotting of stock maps will be done electronically to speed up the process and reduce human error. The FSD is to do verification of the quality enumeration after the private companies have handed in the digitised Stock List and Stock Map. These two electronic products are to be archived by the RMSC GIS-lab and copies provided to TIDD and the TVE. However, when there is a routine of proper post-felling inspection by FSD this activity will become void (see section on post-felling inspection 5.4.5). After FSD enumeration verification and clearance the private companies can hand in their digitised Yield List and Yield Map based on the RMSC revised standard for selecting these. Also these products are to be archived by the RMSC GIS-lab and copied to TIDD and the TVE.
Forest survey stands at the base of sustainable forest management leading to a well-founded yield allocation. In Ghana however, the information currently gathered during the survey is limited to the position of the individual tree, species name, its diameter, forest condition score and presence of seed trees. Any defects of the stem or crown form or position are not taken into account. As a result there is an urgent need to improve forest survey techniques to design a more balanced yield allocation process, taking into account ecological qualities and the stem defects which are not accepted by the timber trade. The preliminary yield selection is to be done by the private companies and to be endorsed by RMSC. At the moment the yield selection is principally a theoretical exercise based on nearest neighbour distance. It is not based on the ecological qualities of individual trees. Yield allocation will be done as at present, but using improved criteria for selecting trees into the yield, based on scientific criteria to ensure the sustainability of the harvest and improvement of tree stocks in future rotations. This also implies that the RMSC should focus on the setting, monitoring, and enforcing of improved standards. Some findings by Van Oene (2007) on current stock survey and yield selection emphasis that certain verifications and corrections are to be made. Concerns about the sustainability of the yield
33
selection method, including the yield formula, used for the Ghanaian high forest have been raised since it has been introduced in 1991 (e.g. Vanclay 1993, Wong 1998). The contradiction between the yield formula and the logging intensity per ha is often noticed so a review of the complete yield selection system might be the best option where more factors determine the yield. Interesting options have been presented by Wong (1998). With the introduction of digitised stock maps this opens up the possibility to analyse patterns and relationships between trees, and such features as topography, soil types, hydrology, road networks, proximity of villages, etc. So many more criteria and information could be included in the selection of the yield when GIS is used by RMSC. GIS gives the possibility to interpolate stocking, basal area and condition scores for every location within a compartment. This gives the ability to exclude areas with too low basal areas, low stocking levels and poor forest condition within a compartment. A compartment does not have to be judged on its average status, one figure representing the entire compartment, but a mere site specific classification can be worked out. So the RMSC-GIS lab is to do simulation of digital yield maps based on the handed in stock maps by using kringing and other criteria to allow for the endorsement of proposed yield maps by private companies or to request modifications to be made.
Normally before any operations start, the development of a harvesting plan as described before, should form part of a larger forest management plan which is site specific. Such a forest management plan should contain a long term vision of the concession and not only be focussed on timber production alone but should deal too with the services provided by the forest at large and encompass conservation objectives such as dealing with wildfires (fire breaks) and biodiversity issues (fauna- and flora-monitoring protocol). Such forest management plans are also to be developed by the private companies and should be handed in to the FC in the form of a hard copy but also as a soft copy to include digital (thematic) maps which assist in the decision making process. Certain baseline digital data (to be specified) should be provided in a digital form too next to allow for field verification and simulation whenever it is felt necessary. At the end these plans are to be endorsed by RMSC. Also in this case RMSC is to review the standard and to set it at international standards. A multiplication of plans is to be avoided so the District Forestry Plan should become void.
5.4.2 Allocation of Tags
Tags will be allocated to log producers and processed wood producers according to their permitted production. Tree tags will be attached by producers to tree stumps at the time of felling, to logs at the time of measurement at the log landing, and processed wood products (both primary, secondary and tertiary) at the time of production. Processed wood products are normally tagged by bundle and not by individual product. The allocation of tags for each purpose to each producer is recorded in the database. The three different types of tag should be of different colours.
5.4.3 Tree Felling and Log Production
After felling, the producer must mark the stump with a tree tag. The tree tag number is also painted on the stump. However, tree measurement at the felling sites will be abolished which will lead to the removal of TIFs. TIF measurements are currently based on the logs of the felled tree and not standing tree measurements. Accordingly the volumes on which the stumpage fees are calculated will not be different when they are based on log measurements (LIFs). Any abandoned logs in the forest will have to be declared the same day to the FSD TO present at the landing place or at the DFO and the reason for this provided. In case of natural log defects (protocol to be provided by RMSC) logs will be exempt of royalties while defects caused by the feller will be charged. FSD staff will have to check these abandoned logs at least once per week and make up a report on these. Next the tree is cross-cut at the felling site and the respective logs extracted to the log landing. At the log landing the logs are then dressed by the producer. The producer measures the logs and puts a log tag on each one. The tag number is also painted on both ends of the log, as well as the tree stock number, property mark and location code. The logs are loaded onto trucks.
The producer records the log data, including log tag number, dimensions, species, tree tag number, tree stock number, (possibly GPS position) onto the LIF form (one numbered form for each truckload,
34
showing also the truck licence number and destination). The LIF form, a copy of which is carried in the truck, therefore acts as a waybill and no longer LMCCs. Usually a FSD TO will be present at the log landing, measuring the logs himself and capturing the data, with the HHC user being personally identified (ideally by an iris scan or finger print). On those days the FSD TO is responsible for the paper and electronic log production declarations. If the TO is not present the producer must declare LIF data daily both on paper forms and in electronic form, to the DFO or direct to the TVE. Supervision of these procedures will by the Regional Forest Office. In the database the declared stock numbers of the trees from which the logs have been cut can be compared against the Yield List to verify that the correct trees have been cut. When pre-felling total bole length assessment is included in the enumeration, the extracted log lengths can be compared with the total bole length of the enumeration taking into account certain waste margins. The latter (excessive waste) will also be evaluated in the post-felling assessment (see 5.4.5). The preparation of royalty invoices “revenue flows”, based on log volumes and species, is to be carried out by the Finance Department at FC HQ based on “timber flows” through a direct access to the central TVE database and (partly) published on the FC website which will have to be externally accessible.
5.4.4 Log Inspections
FSD will perform unannounced checks at forest log landings and at log yards and TIDD inspectors likewise on sampled truckloads along the road. In certain districts where understaffing created major problems the FSD manned road checkpoints and accordingly reduced their presence in the forest as these road checkpoints worked like a funnel. However, these FSD checkpoints are to be abandoned while at the same time the number of TIDD road checkpoints are to be increased to ca. 18 like in the past. In a transitional phase these fixed TIDD checkpoints will be maintained but they will gradually be phased out when new post-felling procedures and log arrival procedures at the sawmill are performed as foreseen (see next paragraphs) and when the chainsaw problem is tackled (see Parren et al. 2007).
The inspectors check the LIFs against the truck contents and verify that the numbered forms are not being re-used, and that the truck and property mark details are correct. They check that the species are declared correctly. They also do a random sample of log inspections, collecting independent data on the identity (i.e. tag number), dimensions of selected logs. For the latter a deviation of ± 1 cm for the diameter and ± 5 cm for length measurements are allowed. They also check deformities on logs and assess the aggregate penalty points for all deformities noticed. This checking will involve verification that the log tags appear valid (i.e. not re-used or forged). These checks could include the use of GPS for mobile teams, recording the location and time of their inspections. Data is captured onto hand-held computers and transmitted at the end of each day to the central database (probably via the District Forest Office and at TIDD offices). Inspectors should carry out independent measurements without reference to the log declared log data. The sampling density is determined by the history of the producer involved. The use of mobile teams instead of fixed checkpoints will mean that log producers will not know if they are going to be checked on any given day.
At the central database reconciliations are run to check that the volumes of logs inspected are within (say) 3% of the volumes declared by the producer, and that the species are correct. Discrepancies are reported to the FC for further action.
5.4.5 Post-Felling Inspection
When the log producer has finished harvesting in a compartment he declares this to the District Forest Office. FSD then carry out a detailed post-felling inspection. This is of critical importance since it is the FSD’s opportunity to verify the accuracy of the enumeration process and the adherence of log producers to the regulations. They will check which trees have been felled in a compartment, and whether the operator has adhered to the harvesting plan and left the compartment in good condition. This activity will initially at least be subject to close oversight by the TVE. FSD teams will inspect the whole compartment (100% check), ensuring that all stumps and trees have a numbered tree tag on them. The TVE field teams will verify at least one compartment per operator annually. This data can again be captured using hand-held computers. The FSD and TVE inspection report is to reflect:
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� A quality control on the enumeration
� Verification of tree removal of the allocated yield (tagged stumps)
� Control on excessive logging damage
� No retrievable volume left behind
So this information will then be reconciled with the stock list and yield list supplied to the producer, as well as with the LIF declarations that he has made. This will verify that:
• The enumeration was complete and tree diameters were correctly measured (validation enumeration);
• The producer has only taken those trees that were in the yield list (compliance logging regulations);
• The numbers, species and sizes of the logs declared correspond to the trees that were felled.
Any anomalies found as a result of this inspection are reported and prompt action must be taken either if the enumeration teams were at fault, or if the producer is found to have felled the wrong trees or if the producer caused excessive logging damage or left retrievable volume behind.
At the moment compartments are two years open to remove the allowed yield. However, this is too long a period since with the regrowth of the vegetation it is difficult to enable to trace all the enumerated trees and tagged stumps. This would imply that a day-to-day FSD felling inspection would be required at all felling sites which as we have seen before are impossible with the actual staff numbers at hand. To overcome these complications compartments opening should be limited to one year to make day-to-day FSD felling inspections redundant and concentrate all monitoring and verification efforts to post-felling inspection only
5.4.6 Log Arrival at the Sawmill
When logs arrive at a log yard the receiving sawmill or factory must declare the arrival of each one (log number, location, date, LIF form number) at the end of each day. This will preferably be done in electronic form, but, if not, in paper form to the nearest DFO or TIDD office for data entry. Data is transferred to the central database. If the log is moved again then every arrival at a new location must be reported to the TVE. TIDD staff at sawmill logyards make regular checks that all logs bear a bar-coded or RFID tag (incl. dimensions and species). In case of non-compliance, non-issued or re-appearance of registered tag numbers the FSD and TIDD will have to take the necessary action against the companies involved. Log movements to other sawmills are to be declared by the private operator on a daily basis to TIDD (and TVE) by means of a new LIF (showing log number, location, date, LIF form number). The TVE field teams do random quality control on these procedures.
If a log is cut in half at any stage (except immediately before processing), the log tag number must be painted on both ends of each of the resulting logs, with suffix “A” and “B”. The tag is transferred to the “A” log. If the end of the log is cut off the tag number is again repainted and the tag transferred to the resulting log. In each case the new dimensions must be declared to the DFO, TIDD office or TVE.
5.4.7 Log Processing
At the end of every day the sawmill/processing company declares to the DFO, TIDD (or TVE) a list of logs and log pieces (“A”, “B” etc.) which were processed that day, listing the date, location, log tag numbers and respective processing contract number. He also declares the quantities of processed wood that have been produced that day, with the respective number of pieces processed for a certain order per shift. The latter will allow for a more accurate reconciliation of sawmill input and output. Tags are collected off the logs just before they are sawn, and are returned to the TIDD inspectors for them to be decoded to prevent possible reuse and returned to TVE. TIDD inspectors are present at unannounced days to verify whether input-output data are correctly captured and reports findings to
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TVE. Reconciliations are run at the central TVE database, checking that the volumes and species of processed wood produced are compatible with the volumes of the logs used for each contract. Also checks are made as to whether a single log has been declared for more than one contract. Non-conformances are reported by the Agency to the FC which will allow for necessary action to be taken by TIDD.
5.4.8 Processed wood
Processed wood bundles, when completed, are strapped and marked with a processed wood tag. The linked tag information specifies next to the contract specifications the grade. Processed wood is loaded onto a truck for transport. If processed wood is transported in bulk or in a sealed container the whole truckload is treated as one bundle, with the tag attached to the transport document. Every truck must have a numbered waybill showing the tag numbers of the wood bundles it contains. Declarations are made to TIDD (and TVE) daily of the processed wood consignments that have been despatched by truck, accompanied by a dated waybill with an ID number and limited period of validity. Processed wood transport declaration data are entered into the database. Data for each processed wood bundle includes tag number, type, species, grade, volume, no. of pieces, contract number, destination and waybill number. If applicable the moisture content level will be checked. TIDD will issue Inspection Certificate.
TIDD staff check at the sawmill that the waybill describes the processed wood bundles on the truck correctly, and they do a random sample of inspections of bundles (or truckloads). The sampling density is determined by the history of the producer involved. Data is stored on hand-held computers and transmitted at the end of the day to the central database. Inspectors do blind checks against the full extent of the declared data for the processed wood bundles.
Reconciliations between processed wood inspections and declarations are run to check whether producers are declaring their production correctly. If anomalies are found, details are passed on to the FC HQ for further action.
If timber is sent on for secondary processing it will need to be listed on a waybill during transport and declared again on arrival. Secondary processors will declare the arrival and use of raw materials, the production of product bundles (marked with new tags) and the onward transport of products, in the same way as primary processors. So the producer declares the quantities of secondary processed wood that have been produced that day, with the respective number of pieces processed for a certain order per shift linked to the original logs as defined by its input. All off cuts are reported in a similar way. Similarly truckloads will be liable for TIDD inspection, and data will be collected and analysed as before.
Overland exports will have their final check done by TIDD staff at the processing plant and, after clearance by the TVE, the truck can leave the producer’s premises. The truck will carry a tagged waybill which will be checked and stamped at the overland crossing and returned to the TVE by CEPS. When sealed containers for overseas export are prepared at the processing plant they will have to be checked by CEPS in the presence of TIDD staff and sealed. Also in this case the truck will carry a tagged waybill for onward transport to the harbour before final clearance. When domestic sales are included in the system, domestic retail outlets will declare the arrival of sawmill products at their yards. Data will be entered into the database and reconciled against sawmill production and timber transport records.
Over time a shift from TIDD inspectors to private inspectors doing grading & inspection is foreseen since the present numbers of TIDD inspectors are insufficient to cover both the export and domestic market. TIDD is to retain some core staff (graders) to do quality control to guarantee expected output standards. This would imply that private inspectors check all logs and wood bundles have tags (incl. dimensions and species) while TIDD core staff do random quality control. TIDD will handle grading claims and provide arbitration.
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5.4.9 Export
Exporters request for TIDD Contract of sale approval and follow the same procedure as described in section 4.1.8. However, they are to submit a request in electronic (web) form to the TIDD (while copies provided to TVE). Information on contracts should include the following data (1) contract number, (2) species, product, quality, quantity, specifications, (3) prices, terms of payment, (4) destination, (5) electronic signatures of seller and buyer, and (6) terms/conditions specified behind according to Ghana hardwood contract form. Approved contracts are once more valid for a period of six months.
Next, shortly before the exporter prepares the wood products for pre-shipment inspection he will submit a request in electronic (web) form to the TVE for the export of a dossier of processed wood based on the approved contract. The electronic approved Contract of sale number will be provided by the exporter and a list of processed wood bundle tag numbers. The central database will receive the list of tag numbers and produce a report indicating the history of the wood in those bundles, showing when and where any secondary processing was done, when and where primary processing was done, the ID numbers of the logs and source trees involved, when and where the source trees were cut (in future a digital map of source trees at compartment level could be included). If no anomalies are noted pre-shipment inspection can take place and afterwards the Certificate of Legal Origin can be issued. The TVE database will next to the timber flows also capture the following financial flows (1) stumpage fees, (2) approved Bank of Ghana Exchange Control form A2 for traditional exports and Export Form A2 for non traditional exports, and (3) evidence of payment or Letter of Credits. Payments and balances on the Letter of Credits are kept by the TVE database and Certificates of Legal Compliance are only issued at exporters who have no arrears in payments for these three financial obligations.
Pre-shipment inspection takes place by TIDD graders at the port by performing at random sampling of physical inspections on the wood bundles in the port warehouse, which consists usually of a check on dimensions, quality and moisture content (but which theoretically may extend to opening the packs, re-measurement and re-grading). If everything is found to be correct (no volume and species disparities) they will endorse the inspection certificates which form the basis for the issue of timber export permits which will be in the form of Certifates of Legal Origin and the Certificate of Legal Compliance.
Next within 72 hours the Export Permit will be issued by TIDD as a transitional face since Certificates of Legal Compliance embody more than just financial obligations. When procedures have been put in place to enable verification of all requirements for issuing of Certificates of Legal Compliance the TIDD issuance of Export Permits becomes void and exports will be based on Certificates of Legal origin and Legal Compliance only to be issued by the TVE. Stevedoring and clearance by CEPS will normally be done the next two days before ship loading in which a TVE officer verifies that all bundles are exported and that they conform to the contract (Export Permit).
Details of product export certificates issued are stored in the database (authoriser’s name, certificate number, volume, species, type of product, date of issue, exporter, purchaser, etc).
5.4.10 Import
Ghana imported about 292,000 m3 of various wood products in 2005. Imported wood is predominantly
sawn wood (78%), with the next in importance, veneers and panels accounting for 11%. CEPS (cq. GCNet) should contact TIDD to inform that any wood products form part of the bill of loading. Importers of less than one metric ton will not fall under this scheme. However, larger consignments of processed wood transported in bulk or in a sealed container will require TIDD inspection. Declarations by the importer are made through GCNet and copies provided to TIDD (and TVE) daily of the processed wood consignments that have arrived by ship or been despatched by truck overland. TIDD inspectors should open containers and tag each bundle in case they are not already tagged. Data for each processed wood bundle includes tag number, type, species, grade, volume, no. of pieces, contract number, country of origin, its destination and waybill number. The same applies for wood bundles to be
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imported by truck overland, and for the latter it is to be accompanied by a dated waybill with an ID number and limited period of validity. Every truck transporting a container or wood bundles must have a numbered waybill showing the tag numbers of the wood bundles it contains. Processed wood transport declaration data are entered into the database. TIDD will issue Inspection Certificate. The final destination of the imported wood products whether it is a wholesaler or retailer will be visited by TIDD.
For logs imported, log data have to be captured by TIDD staff present in the harbour or at the overland crossing, all logs will have to be tagged (with a different colour for imported logs) first if not done so already and next data capture will include log tag number, dimensions, species onto the LIF form (one numbered form for each truckload, showing also the truck licence number and destination). The LIF form, a copy of which is carried in the truck, therefore acts as a waybill. Further monitoring follows the procedures described at the section ‘Log Arrival at the Sawmill’ and following.
5.4.11 Reporting
• Monthly reports of log production by species, producer, concession, district
• Reports of discrepancies between yield list and trees felled
• Reports of discrepancies between felled tree volumes and log volumes produced
• Reports of discrepancies between log declarations and log inspections
• Reports of discrepancies between processed wood declarations and inspections
• Reports of conversion rates in sawmills and secondary processing factories • Reports of export contracts and constituent logs
• Reports of log histories (to be archived after compartment closure)
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REFERENCES
Anon. (2004). Ghana loses ¢ 900 billion ($100 million dollars) annually from uncollected Timber Rights Fees! Forest Watch Ghana, Accra, Ghana.
Agyeman, V.K., Oduro, K.A and K. Gyan (2007). Institutional framework for implementation of VLTP. VLTP Background Paper No. 3. Validation of Legal Timber Programme, Forestry Commission, Accra, Ghana.
Birikorang, G., Hansen, C.P. and T. Treue (2007). Review of the current taxation system relevant to the forest sector in Ghana. VLTP Background Paper No. 1. Validation of Legal Timber Programme, Forestry Commission, Accra, Ghana.
Odoom, F.K. (2005). A study of chain sawing in the natural forests of Ghana. As assessment of the socio-economic impacts of the practice. FAO Forest Harvesting Case Study No. 21. FAO, Rome, Italy.
Parren, M.P.E., Cardoso, R.D., Okai, E.N.A., Eshun, A.A., Haizel, K.E. and F.K. Odoom (2007). Review of the domestic timber market with an emphasis on Off-Forest Reserve timber production and management in Ghana. VLTP Background Paper No. 2. Validation of Legal Timber Programme, Forestry Commission, Accra, Ghana.
Van den Berg, T.F. and M.P.E. Parren (2007). Analog to digital stock & yield mapping. VLTP Background Paper No. 5. Validation of Legal Timber Programme, Forestry Commission, Accra, Ghana.
Van Oene, R. (2007). GIS as a tool for Forest Management Planning. The example of Asenanyo River FR. VLTP Background Paper No. 6. Validation of Legal Timber Programme, Forestry Commission, Accra, Ghana.
Vanclay, J.K. (1993). Review of the Forest Inventory and Management Project. Annex IV of Kemp, R.H., Flint, M. and J.K. Vanclay (eds.), Forest Inventory and Management Project. Review and project preparation report. Overseas Development Administration, London, UK.
Wong, J.L.G. (1998). Growth, mortality and yield of the reserved forests of Ghana. Technical assistance to the Forest Sector Development Project Ghana. Consultancy report No. 10. FRR Ltd. Bristol, U.K.