To all at Greenpeace:

I have had a quick read through the draft report and will comment in more detail in the margins of it. However I have one pretty general and more principle problem with it. I see it badly flawed in what it is trying to achieve.

The first few sections make it clear that Greenpeace accepts that in the case of Congo Brazzaville one is dealing with a dysfunctional government and that in this context nothing much has changed since independence.

There are a wide range of World Bank and other studies out there making the point that with dysfunctional governments you do not get functional extractive industries - meaning real socio economic development on the back of these industries.

While the existing FSC criteria might mean something in places like Finland or Canada, they are clearly not dealing with some of the key issues when it comes to governance in places like Central Africa. The end result might be that despite a certification an operator like CIB will have an overall negative impact on poverty alleviation.

While CIB might pay its taxes, what guarantees are they that the same funds will not be used the next day to buy helicopter gun ships to hammer the people in the Pool or finance the wedding of another Sassou daughter, this time to young Kabila??

CIB might comply with criteria concering FSC and be within the law but what does that mean in the context of an overall lawless country?

This report makes again clear that the supposedly public information on shareholders and directors of a registered company is indeed not public information. While Greenpeace was provided with some documents, if anything they have thrown up even more questions concerning ownership of the company. However what is clear is that CIB and the government have the same interest to keep some of this info hidden. But it is the government which infringes on the law and not CIB (when CIB filed the case against Retted den Regenwald and the lawyers asked Dr. Stoll to produce evidence that he was indeed representing CIB, he immediately produced a document from the registrar of companies in Ouesso confirming that he was still president. This after tt-Timber stating over and over that Dr. Stoll had resigned).

The same with Dr. Stoll's early rejection of the FSC process on the basis that it was 'contradictory'. That CIB could not give any kind of preferential treatment to any of the original inhabitants of the region. The reason: The government did not want him to and had deported the previous owner of the company because of it. So again the government ignores the supposedly wide range of international conventions they have signed and CIB hides behind the dysfunctional government.

Joseph's case was another clear cut illustration of the above.

Unless a formula can be found whereby the FSC criteria can be extended to ensure that FSC extraction of timber actively helps establish good governance the end result of FSC extraction might still be a country poorer than it was before.

Then there is another issue of principle which is not being addressed:

CIB has been logging these forests for 30 years and has pulled out millions of cubic meters of timber and hundreds of millions of dollars have been earned with this timber.

They have admitted in interviews that the bush meat trade inside the concession was totally out of control until about 8 years ago when WCS had to step in.

We know from various reports that what has been happening to the minority groups in the concession, until recently, was barely short of serious human rights violations.

We know that the CIB tax payments have not really resulted in socio economic development in the region in general or the country as a whole.

Now 30 years later Greenpeace and some others seems to be saying, once they get an FSC certificate this will represent a new start. In any other context there would be screams for: "Wiedergutmachung". Who are we to grant this amnesty. Has Greenpeace consulted the local people on this issue?

Dr. Stoll has been lecturing for years under the heading "Ein Ja zum Tropenholz". For the last decade he has hardly written a letter in which does not seem to have mentioned CIB's close collaboration with the 'Worlds oldest Conservation Organization". I have very little doubt that any endorsement of the CIB operation - whatever the caveats- will be interpreted by him and the tt-Timber propaganda team as an endorsement of industrial logging of the remaining primary rain forests. If the consumer was confused before, this approach to certification will only add to the problem. Endorsement of one logging operation will easily be interpeted as an endorsment of the ' the good, the bad, the ugly'.

So clearly Greenpeace has ended up in a situation whereby they either join Dr. Stoll with : "Ein Ja zum Tropenholz", or reevaluate Russ Mittermeier of CI's position: The endorsing of industrial logging of the remaining primary rain forests, by any conservation organization, is absurd.

Best regards
Karl Ammann