Through inspection of Ngoc Linh ginseng cultivation in Puxailaileng protective forest: Need to promptly and seriously correct violations!
Conducting an inspection of Ngoc Linh ginseng cultivation by Ngoc Linh Ginseng Pharmaceutical Joint Stock Company, which negatively impacted Puxailaileng protective forest as reported by Nghe An Newspaper, Ky Son Forest Protection Department pointed out a number of shortcomings and violations. However, there are still contents that need to be clarified for serious correction.
Temporarily stop growing Ngoc Linh ginseng
Nghe An Newspaper published a series of articles on October 29, 30, and 31, 2024, "Clarifying the negative impacts of Ngoc Linh ginseng cultivation on Puxailaileng protective forest". On October 31, 2024, the Forest Protection Department and the People's Committee of Ky Son district simultaneously issued a directive document.Ky Son Forest Protection Departmentand relevant units check and verify the information reflected by Nghe An Newspaper.
On November 5, 2024, an on-site inspection of the Ngoc Linh ginseng growing area at plot 8, sub-zone 490, Na Ngoi commune was carried out; on November 7, 2024, Ky Son Forest Protection Department issued Document No. 74/BC-KL reporting the inspection results.
According to Document No. 74/BC-KL, from November 2023 to the time Nghe An Newspaper reported, Ky Son Forest Protection Department and related units proactively organized inspections of the medicinal plant cultivation cooperation and association areas (4 times, on November 6, 2023; December 5, 2023; June 15, 2024 and October 28, 2024). During the inspections, Ky Son Forest Protection Department reminded and warned the construction unit about negative impacts on the forest, and requested to seriously implement the planting of medicinal plants under the forest canopy in accordance with the cooperation and association plan approved by competent authorities.
To verify the content reported by Nghe An Newspaper, on November 5, 2024, Ky Son Forest Protection Department presided over and coordinated with Mobile Forest Protection Team No. 1 and related units to conduct on-site inspections of the cooperation and association areas.
Through inspection, it was determined that there were 4 temporary camps set up by workers in the cooperative area. The total area within the medicinal plant protection fence is 3.6 hectares, at lot 8, section 8, sub-area 490; of which construction has been carried out at the site including 2 areas with an area of 9183m2.2Zone 1 has an area of 4993m2, including 100 Ngoc Linh ginseng beds (total area of the beds is 2110m2). Zone 2 has an area of 4190 m2, including 30 Ngoc Linh ginseng beds and 9 Kim Tuyen orchid beds (total area of the beds is 552m2)2).
Regarding the treatment of the ground cover to create Ngoc Linh ginseng beds, the company cleared some scattered bamboo roots and dry branches, rotten trees to create a flat surface, then used materials including hard plastic nets, meters, coconut fiber, and a little forest soil to build the beds. For the beds for growing Kim Tuyen orchids, the company cleaned, raked, and tilled the soil to make beds (total area 25.5m2).
Upon inspection, there were no signs of sawing or cutting of standing trees in the medicinal plant growing area. However, the inspection team noted that there was raking and clearing of old bamboo stumps scattered near the ginseng planting beds; and covering the Ngoc Linh ginseng planting beds with plastic. At the same time, it was determined that there were rotten trees that had fallen and been sawed around the ginseng planting beds, but the time of falling and sawing could not be determined.
Forest fire prevention and fighting work has not been ensured according to regulations. Specifically, workers working in the forest have not been equipped with specialized forest fire prevention and fighting tools; there are no solutions to prevent fires from spreading between plots, sections and neighboring sub-areas in the cooperation and association area; there are no specific regulations and rules on forest fire prevention and fighting.
After inspecting the scene, Ky Son Forest Protection Department worked with Ngoc Linh Ginseng Pharmaceutical Group Joint Stock Company and concluded: “There was digging and hoeing under the forest canopy to plant Kim Tuyen orchids and clearing some scattered bamboo roots in the area. This is not consistent with the technical design documents approved in Decision No. 90/QD-BQL dated August 29, 2023 of the Ky Son Protective Forest Management Board. There was an impact on the forest land around the medicinal plant beds such as digging old bamboo roots and covering them with plastic under the forest canopy. Forest fire prevention and fighting in the cooperative area has not been ensured according to regulations”.
Accordingly, it is recommended that Ngoc Linh Ginseng Pharmaceutical Joint Stock Company temporarily suspend new activities until receiving comments from competent authorities; promptly accept and remedy to have the least impact on the forest environment; coordinate with the Ky Son Protective Forest Management Board to review, supplement and complete technical design documents in accordance with regulations.
Is the conclusion correct and sufficient?
Studying Document No. 74/BC-KL, although Ky Son Forest Protection Department pointed out a number of shortcomings, violations and temporarily suspended the operations of Ngoc Linh Ginseng Pharmaceutical Joint Stock Company, there are still contents that need to be clarified.
Specifically, the report of Ky Son Forest Protection Department has not yet assessed the current status of 3.6 hectares of protective forest within the fence protecting medicinal plants, whether it is wrong or different from the previous status. In our opinion, this is something that needs to be clarified, and there is absolutely a basis for clarification.
Because in the records and related documents, there is a report on the results of the investigation of the current status of natural forests to serve the construction of the "Project of cooperation and association in planting non-timber forest products and medicinal herbs under the forest canopy of Ngoc Linh Ginseng Pharmaceutical Group Joint Stock Company at the Ky Son Protective Forest Management Board, Ky Son district, Nghe An province" implemented by the North Central Forest Planning and Investigation Sub-Institute and completed in March 2023.
In this document, the North Central Forest Planning and Investigation Institute organized a fairly specific survey and investigation of the current status of forest types within the scope of plot 8, sub-area 490. In particular, the mixed wood-bamboo forest (where Ngoc Linh ginseng and Kim Tuyen orchids were planted) was assessed to have a complex structure; the main plant components were myrtle, dung, khao, chestnut, mandarin orange... mixed with bamboo. The reserve of the mixed wood-bamboo forest was even specifically determined, specifically each hectare has 231.5m3wood and 5,133 bamboo trees.
Furthermore, in the cooperation and association plan for growing medicinal herbs under the forest canopy at the Ky Son Protective Forest Management Board approved by the Department of Agriculture and Rural Development in Decision 512/QD-SNN-QLKTKHCN, it is clearly stated that the total area of mixed wood-bamboo forest in block 8, sub-zone 490 is 6.6 hectares. Ngoc Linh Ginseng Pharmaceutical Group Joint Stock Company fenced off 3.6 hectares to carry out construction on an area of 0.9183 hectares. Thus, 3 hectares of mixed wood-bamboo forest remain intact so that the Ky Son Forest Protection Department can compare and assess the differences.
Regarding the conclusion of Ky Son Forest Protection Department: "There was a raking and clearing of some scattered bamboo roots in the area"; "There was an impact on the forest land around the medicinal plant beds such as raking and clearing old bamboo roots", in our opinion (PV) is not accurate.
The reason for this assessment is because the images, clips, and audio tapes we have (used in part in the series of articles "Clarifying the negative impacts of Ngoc Linh ginseng planting on Puxailaileng protective forest") prove that workers of Ngoc Linh Ginseng Pharmaceutical Joint Stock Company cut and dug up fresh bamboo bushes in the protective forest to create a surface for planting Ngoc Linh ginseng; there are even images and clips recording the scene of the company's leaders in front of a mess of bamboo bushes that have been cut, dug up, and brought up from the forest floor.
In addition, from November to December 2023, the act of clearing and digging bamboo bushes in the protective forest of Ngoc Linh Ginseng Pharmaceutical Joint Stock Company was discovered and recorded twice by the People's Committee of Na Ngoi Commune and local forest rangers. Compared with our actual scene on October 21, 2024 (with the participation of Mr. Ho Ba Xenh - Forest Ranger of Na Ngoi Commune), the above documents are authentic evidence. Ky Son Forest Ranger Department can use them, along with the on-site inspection on November 5, 2024, to draw a clearer conclusion about the actions of Ngoc Linh Ginseng Pharmaceutical Joint Stock Company affecting the protective forest!
In addition, in Report No. 74/BC-KL, there is no assessment of whether the protective nature of the forest within the 3.6ha protection fence has been reduced or not? This is really very important content, helping competent state management agencies make accurate decisions on the cooperation and association of medicinal plant cultivation under the forest canopy of Ngoc Linh Ginseng Pharmaceutical Group Joint Stock Company with the Ky Son Protective Forest Management Board. Because the cultivation of Ngoc Linh ginseng according to the concentrated model, including 130 beds with plastic roofs with a total area of 0.9183ha, has occupied more than 1/4 of the 3.6ha protective forest area. This 0.9183ha area has become a Ngoc Linh ginseng garden, there will be no more opportunity for forest regeneration and forest development.
“The land preparation process must be carried out in a way that has the least impact on the forest environment. Therefore, the medicinal plants planted in the project are all done in a nearly natural way, the plants are planted in holes with a diameter of about 10cm, at a density appropriate to each type of plant, without plowing or making ridges in the forest to plant medicinal plants.” (Technical design documents for growing medicinal plants under the forest canopy - Approved by Ky Son Protective Forest Management Board in Decision No. 90/QD-BQL dated August 29, 2023).
It is necessary to strictly implement the provisions of the law.
In Report No. 74/BC-KL, Ky Son Forest Protection Department mentioned the opinion of Ngoc Linh Ginseng Pharmaceutical Joint Stock Company with the following content: “Through working, Ngoc Linh Ginseng Pharmaceutical Joint Stock Company acknowledged that there were certain impacts on the forest ecosystem in the process of growing medicinal herbs. Specifically, in the stages of handling the ground cover, preparing the soil, and covering the beds with plastic to care for Ngoc Linh ginseng plants. However, the company affirmed that such impacts must be made to grow Ngoc Linh ginseng...”; “recommend considering, reviewing, and adjusting the technical design documents to suit the actual conditions of the medicinal herb growing area”.
Therefore, recently we (PV) have been studying the implementation of the program of growing medicinal herbs under the forest canopy in the province. Then we learned that in the mountainous districts of Con Cuong, Tuong Duong, Que Phong... there have been a number of models of growing medicinal herbs under the forest canopy that have achieved positive results. And we know that Associate Professor, Dr. Dao Thi Minh Chau - Deputy Director of the Center for Environment and Biological Resources is one of the pioneers, closely associated with the Department of Science and Technology of Nghe An, the Global Environment Fund, to organize the implementation.
According to Associate Professor, Dr. Dao Thi Minh Chau, projects and programs for planting medicinal plants under the forest canopy are currently being implemented within the production forest area. However, before implementation, the current status of vegetation under the forest canopy is carefully surveyed to determine the medicinal plant species to be planted that are suitable for ecological conditions, help them grow well, increase forest cover, and do not change the structure of the forest ecosystem. Associate Professor, Dr. Dao Thi Minh Chau said that she does not agree with clearing forests to the extent of changing the structure and function of the forest to grow medicinal plants. Especially with protective forests, because major interventions will change ecological conditions, change forest structure, and reduce the function of regulating water resources, limiting floods, and preventing erosion...
At the same time, Associate Professor, Dr. Dao Thi Minh Chau recommended: “In the forest ecosystem, there are not only plants and animals but also bacteria, land, water and atmosphere. All of these components combine to create a complex but balanced living environment, in which each element contributes to the existence and development of the system. Planting medicinal plants under the forest canopy is necessary for us to achieve two goals at the same time, including creating livelihoods for people to better manage forests and conserve biodiversity. Therefore, the implementation of the project of planting medicinal plants under the forest canopy should be carried out by planting under the canopy of other tree species, this species depends on other species and vice versa, the planting density should be moderate so as not to occupy the space of other species in the common ecosystem, creating conditions for the whole ecosystem to develop together”.
The discussions of Associate Professor, Dr. Dao Thi Minh Chau on growing medicinal herbs under the forest canopy are in line with the provisions of the Forestry Law and Decree 156/ND-CP of the Government. Specifically, Point 2, Article 25 (forestry, agricultural and fishery production in protective forests), Decree 156/ND-CP stipulates: "Forest owners, stable contractors are households, individuals, and residential communities that are allowed to intercrop agricultural crops, non-timber forest products, raise livestock and raise aquatic animals under the protective forest canopy, but must not reduce the forest area, quality, affect forest regeneration and the protective capacity of the forest".
Therefore, with what has been reflected in the series of articles "Clarifying the negative impacts of Ngoc Linh ginseng planting on Puxailaileng protective forest" and the above content, we request that the authorities accurately assess the negative impacts on the protective forest of plot 8, sub-area 490, belonging to the Puxailaileng "nature reserve", and promptly and strictly rectify them according to the law!
