Independent forest monitoring (IFM) has played an important role in improving forest governance and tackling illegal logging in the past 20 years, for example by leading to the withdrawal of illegal forest titles and adoption of new ministerial orders improving forest governance. While the concept of IFM first emerged in Cambodia in 1999, it is in the Congo Basin where IFM was further developed over the past 20 years, supporting the preservation of the world’s second largest tropical forest. As new regulations on deforestation-free commodities provide opportunities to expand IFM beyond timber, it is important to reflect on the 20-year experience of independent monitoring in the timber sector and how IFM can be strengthened. A recent paper by WRI, Field Legality Advisory Group (FLAG) and Resource Extraction Monitoring (REM) identified key challenges faced by IFM organizations in the Congo Basin and proposed recommendations to improve the efficiency of IFM in the region. Here are our top 4 recommendations to strengthen IFM in the Congo Basin before expanding the model geographically and moving it beyond timber.
What are IFM organizations?
IFM organizations are usually civil society organizations (CSOs) whose mission is to assess the conformity of forest management and forest activities with the legislative and regulatory framework in force in the forestry sector at the national level. The overall objective of IFM is the improvement of forest governance through monitoring activities that lead to environmental and social benefits. In practice, IFM organizations analyze official documentation and visit forests to detect, report, and highlight potential issues on forest governance and management, as well as on the harvest and transport of timber. They focus on logging activities conducted by the private sector in government-owned forests, law enforcement by local government agencies, and forest governance issues in general. Based on the facts observed, monitors draft reports that are shared with the government. In addition, IFM organizations propose recommendations to improve law enforcement. They also follow up on measures taken by the government following these recommendations.
Figure 1: Activities Performed by IFM Organizations
1. Invest in quality assurance systems and standardization
The credibility of IFM organizations depends on the quality of their reports. Therefore, IFM organizations should invest in quality control and quality assurance systems, and donors should more systematically include quality requirements in IFM grants.
In addition, the need to standardize IFM data grows as the number of CSOs involved in IFM increases. IFM data from different organizations need to be analyzed jointly to identify national and regional trends in illegal logging. Therefore, adopting similar quality standards is crucial for IFM organizations operating in the same region. Increased communication and experience-sharing among IFM organizations through platforms such as the Independent Monitoring African Platform (PA-OI) will help the adoption of common quality standards across IFM organizations, while supporting better information-sharing to tackle transnational infractions. Standardization will also allow regional monitoring of IFM activities and overall forest governance and therefore give IFM organizations, producer country governments, and donors the ability to assess the evolution of compliance and law enforcement in the region, and to adapt their strategies accordingly.
Several initiatives have emerged recently that can be adopted by the IFM community of practice to foster standardization and improved quality of IFM data, such as the ISO-certified SNOIE system in Cameroon. Furthermore, the Open Timber Portal proposes standardized data entry forms and quality control processes for IFM data uploaded to the portal. In addition, IFM organizations FLAG and Observatoire de la Gouvernance Forestière (OGF) have developed quality control tools to review IFM reports. Their tools can be used internally or to support peer-review processes on IFM reports at a regional level.
2. Institutionalize IFM in national laws, and supply-side and demand-side measures
The development of IFM in the Congo Basin was amplified by the signature Voluntary Partnership Agreements (VPAs). These legally binding agreements on timber trade between the European Union (EU) and some producer countries contain some provision for civil society to play a role in monitoring the implementation of the agreements. VPAs have even led some producer country governments to recognize the role of IFM in their laws. For instance, the new Forest Law adopted by the Republic of the Congo in July 2020 explicitly mentions IFM in article 69 (in translation):
An independent monitor, originating from national civil society organizations and recognized by the government, conducts independent field missions alone or jointly with the agents of the forest government agency. The monitor regularly produces reports and recommendations on compliance with forest legislation (Republic of the Congo 2020).
We recommend that policymakers include an official role for IFM organizations in national laws, as well as in international supply-side and demand-side regulations, such as the regulations on deforestation-free commodities currently in discussion in the EU, the UK and the U.S. Donors should also encourage policymakers to adopt such reforms.
3. Improve funding model and cost-efficiency
IFM organizations are typically funded through short-term projects, thereby creating financial insecurity and undermining their ability to develop and implement long-term strategies and to ensure job security for their employees. Donors should consider investing in long-term partnerships with IFM organizations as it was done in Indonesia, either individually or through platforms such as the PA-OI. Donors could also reduce the time spent by IFM organizations in fundraising and reporting by coordinating strategies and adopting more closely aligned funding approaches and mechanisms.
In the meantime, IFM organizations should develop subnational IFM networks to improve their cost-efficiency. Indeed, the model of a single national IFM organization based in the capital city carrying out missions in different regions creates higher costs than a decentralized approach. For instance, one mission in the DRC carried out by the IFM organization OGF based in Kinshasa costs about $20,000. To improve cost-efficiency, OGF led the development of RENOI, a network of provincial IFM organizations. When OGF experts detect issues in a remote province, they can contact the closest IFM organization to initiate an investigation, thereby reducing the cost of a mission.
In addition, tools and resources can help improve IFM cost-efficiency. For instance, remote sensing now provides information about tree cover loss in near-real time and is freely available on smartphones via apps such as Forest Watcher, ForestLink, and FLEGT Watch. These tools allow IFM organizations to identify and target missions in areas impacted by significant deforestation events. Other technologies like drones can support field missions. In addition, emerging technologies like those for wood identification could support supply chain verification in the future. IFM organizations should be trained on available and emerging technologies to understand which tools and associated data sets best address their needs.
4. Improve the utility of IFM data to implement and enforce demand-side measures
Finally, the best asset to ensure that IFM organizations have a role in implementing future regulations on commodities is to increase the use of IFM data in the implementation of current regulations. Therefore, new forms of capacity building, through ongoing coaching and field visits, are urgently needed to further train IFM organizations in producing data that are more actionable for enforcing demand-side regulations. In the meantime, donors, international NGOs, and IFM organizations should also work more closely with importers and enforcement agencies in consumer countries to integrate IFM data as an official source of information in due diligence processes.
IFM primarily focuses on field visits, while demand-side policies such as the U.S. Lacey Act and the EU and the UK Timber Regulation also require importers to analyze documentation to ensure they buy only legal wood. A stronger focus on official compliance documentation in addition to field work would make IFM data more attractive to importers. IFM organizations should conduct more document-based investigations and produce more observations on the validity of official documents. Document-based investigations not only produce observations that are readily applicable to demand-side risk assessments but also increase IFM efficiency as they assist IFM organizations in better targeting their field missions. In addition, IFM organizations should ensure that their observations are available to an international audience by translating their reports into English and/or uploading the observations collected on the Open Timber Portal, which is available in English, French, Chinese, Japanese, Korean, and Vietnamese.
In the meantime, IFM organizations should develop partnerships with timber trade associations and competent authorities in charge of enforcing demand-side measures. Importers should be trained on where to find IFM data and how to use them in their due diligence systems. In addition, donors could invest in establishing more direct communication among importers and IFM organizations. For instance, IFM organizations could help train importers on how to assess the validity of the compliance documents provided by timber producers for specific countries.
Overall, we think IFM has a major role to play both in further improving forest governance in the Congo Basin and beyond, and in the implementation of upcoming regulations on deforestation-free commodities. We recommend that IFM organizations and donors continue working together, along with other stakeholders, to further improve IFM. Whether IFM focuses on timber or other commodities, takes place in the Congo Basin or in any other region, standardization of IFM data through the adoption of quality standards, development of an IFM community of practice, and establishment of subnational IFM networks are paramount. Developing long-term funding solutions tied to a streamlined monitoring and evaluation approach is necessary for IFM in the Congo Basin today and will be equally important as IFM expands to other regions and commodities. Finally, the best asset to ensure that IFM organizations have a role in implementing future regulations on commodities is to increase the use of IFM data in implementing current regulations. Therefore, new forms of capacity building, through ongoing coaching and field visits, are urgently needed to further train IFM organizations in producing data that are more actionable for enforcing demand-side regulations. In the meantime, donors, international NGOs, and IFM organizations should also work more closely with importers and enforcement agencies in consumer countries to officially integrate IFM data as an official source of information in due diligence processes.
Photo source: FLAG