PT. Sebangun Bumi Andalas

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VERIFICATION REPORT RELATED TO BREACHES OF APP’S NATURAL FOREST CLEARANCE MORATORIUM IN PT. BUMI ANDALAS PERMAI,

PT. SEBANGUN BUMI ANDALAS, AND PT. BUMI MEKAR HIJAU SOUTH SUMATRA

FCP Implementation Team

11 SEPTEMBER 2013

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1. BACKGROUND

On February 1st 2013, APP made the commitment to immediately stop natural forest

conversion within all of its supply chain. APP is using High Carbon Stock (HCS) to

identify areas of natural forest, and High Conservation Value (HCV) assessments to

identify other areas for protection. The result of the HCS & HCV assessments will

guide the forest managers of APP pulpwood suppliers of which areas they can develop

into plantations and those areas they need to maintain as natural forest and HCVs.

The FCP Implementation Team - comprised of TFT and APP staff - regularly monitors

the implementation of the moratorium on all of APP’s pulpwood suppliers’ areas. A

recent audit of all concessions brought the following cases to the attention of the FCP

Joint Steering Committee (JSC) and identified moratorium breaches totaling an area of

69.45 ha of HCS forest within three of APP’s suppliers’ concessions in South Sumatra:

PT. Bumi Mekar Hijau (BMH) – 63.47 ha

PT. Sebangun Bumi Andalas (SBA) – 3.49ha

PT. Bumi Andalas Permai (BAP) – 2.49ha

2. PRE-ASSESSMENTS TO IDENTIFY HCS/HCV/PEATLAND AREAS WITHIN BAP, SBA AND BMH RKT 2013 COMPARTMENTS

The FCP Joint Steering Committee decided to prioritise pre-assessments to identify

HCS/HCV/peatland areas in specific zones that were due to be developed in 2013 (i.e.

the RKT 2013 operational compartments) within BAP, SBA and BMH.

APP requested that these pre-assessments were carried out in South Sumatra to

identify ‘low risk’ areas for ongoing plantation development in order to meet its fibre

forecasts. This process would allow limited land preparation activities to proceed on low

risk areas: that is, areas identified as without conservation values including forests (non-

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HCS), peatland and other important areas (i.e. non-HCV). The pre-assessments would

allow plantation development to proceed while still allowing APP to fulfil its FCP

commitments. This pre-assessment stage is only being applied to RKT areas within

these three companies in South Sumatra. Full HCS and HCV (including peatland)

assessments are currently being conducted in the rest of the areas within these same

concessions. Pre-assessments are only being undertaken in South Sumatra and not

elsewhere by any other APP’s suppliers.

Three operational maps were generated for the pre-assessment stage designating

specific operational RKT 2013 compartments into three broad categories:

a. ALREADY DEVELOPED: - Developed: Compartments whereby HTI had already been established

(plantation and canal/other infrastructures).

b. NO GO AREAS: - Potential HCS/HCV/peatland: Compartments that potentially contained

above ground carbon stocks of more than 35 ton/Ha or strata Old

Scrub/BT and Forest Cover/HK and/or potential HCV, including peatland

areas. These compartments were then considered as “No Go” areas.

- Require further check (RFC): Compartments that could not be classified

accurately as inconsistencies between the principle data sources; aerial

survey, field measurement, and Spot 5 analysis were identified and

therefore a more intensive evaluation and field check would need to be

conducted prior to any operations. These compartments were then

considered as part of the “No Go” areas.

c. GO AREAS: - Non-HCS/non-HCV/non-peatland: compartments that contained above

ground carbon stocks of less than 35 ton/Ha (or strata classified as Open

Land/LT and Young Scrub/BM) and no potential HCV, including peatland

areas. These compartments were then considered as “Go” areas. The

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extent of this area is 14,600 Ha, of which 6,623 Ha had been developed

between 1st February 2013 and 31st July 2013.

Pre-assessments to identify HCS/HCV/peatland areas were conducted for all three

companies between 29 January and 8 February 2013. The methodology used for the

pre-assessment is described in Appendix1.

3. POTENTIAL BREACHES OF THE DESIGNATED “NO GO” AREAS OF 2013 RKT COMPARTMENTS IN BAP, SBA AND BMH

Based on the updated Planting Realization Map of the three HTI companies that were

obtained by the FCP Implementation Team on 15 July 2013, land preparation and

planting activities had occurred inside the designated “No Go” areas. Of the total 489

compartments located inside the “No Go”, 23 were affected. The profile of these 23

compartments can be seen in Appendix 2.

With this finding, the FCP JSC immediately instructed the FCP Implementation Team to

conduct a document review and field verification on the alleged cutting of potential

HCV/HCS/peatland areas within compartments designated as “No Go”.

4. VERIFICATION STEPS TAKEN BY THE FCP IMPLEMENTATION TEAM

The following steps were taken in relation to the potential forest moratorium breaches

within the “No Go” areas in the 23 compartments in BAP, SBA, and BMH:

a. A preliminary evaluation was conducted in APP’s Office in Jakarta on relevant

documents, data, and maps against the original recommendations of the

HCS/HCV/peatland pre-assessment.

b. APP/TFT formed a Field Verification Team (FVT) that was sent to BAP, SBA, and

BMH where the breaches occurred (see Appendix 5).

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c. The FVT conducted a field visit from the 23rd to 27th July 2013 using the following

steps:

Ø Reviewed relevant documents in the Region of Palembang and in the 4

Districts (Simpang Tiga District, Kuala Lumpur District, Sungai Ketupak

District, and Simpang Heran District).

Ø Interviewed relevant parties in the Region of Palembang and in the 4

Districts.

Ø Conducted field observations in the 23 compartments where the potential

forest moratorium breaches within the “No Go” areas had occurred.

Ø Conducted a two-stage data reconciliation process with all the relevant

resource persons in the APP Office in Jakarta that commenced on the 1st

August 2013 and which was completed on the 22nd August. The findings

were reported to the FCP JSC.

5. CONCLUSION OF THE FIELD VERIFICATION TEAM

Based on the result of the verification process and accompanying field data the FVT

concluded:

1. Within BAP, SBA and BMH RKT, potential forest moratorium breaches occurred

after 1 February 2013 in RKT compartments (2013) inside the designated “No

Go” areas. The total area developed was 431.1 Ha and took place in 23

compartments (Appendix2).

2. A first stage of data reconciliation (alignment of field verification data and APP

operational data (Appendix 3) concluded that:

a. With respect to HCV, these 23 compartments were cross checked in

relation to potential HCV areas identified during the pre-assessments

(HCS/HCV/peatland) in February 2013 – there was no overlap. Therefore,

none of the 23 compartments above were assessed to contain HCV and

all further verification would focus on identifying potential HCS.

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b. With respect to HCS, the verification analysis output revealed that of the

431.1 Ha, a maximum area of 72 Ha could provisionally be considered as

HCS and therefore in breach of the forest moratorium. This estimate

would be further analysed in a second stage of verification to establish a

more accurate figure.

3. Following stage 1, whereby field verification data and APP Operational data (field

and head office) were reconciled, a second stage comparative spatial analysis

was implemented (Appendix 4) to both double check the output of the first stage

and to strengthen the overall result through the inclusion of plot data generated in

the full HCS assessment implemented in June/July 2013. Based on the analysis

of spatial mapping data and field data, it can be concluded that the total HCS

area cleared after 1 February 2013 is 69.45 Ha. This is an unacceptable breach

of APP’s natural forest clearance moratorium and its FCP.

4. This 69.45 Ha of HCS was cleared despite the FCP Implementation Team “RKT

2013 Recommendation Map” and Moratorium Protocol being distributed to all

regional and district managers. Land preparation activities took place within the

compartments designated as “No Go” areas because of a lack of understanding

by the district managers of the pre-assessment objectives and the ongoing

HCV/HCS assessment work being carried out in the “No Go” areas. Further,

there wasn’t a clear and comprehensive protocol and sign off process in place

between the regional and district managers related to “No Go” and “Go” areas.

5. If the pulpwood suppliers’ operational teams had been provided a robust

checklist of actions and documents requiring formal sign-off and on-going

monitoring and supervision, this incident would have been avoided.

6. None of the wood cleared from the 69.45 Ha of HCS was sent to APP’s mills.

6. ACTIONS BEING TAKEN TO STRENGTHEN APP’S MORATORIUM AND

IMPLEMENTATION OF ITS FCP

As a result of these breaches of the forest moratorium in the “No Go” areas, the

following steps are being taken:

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a. The FCP Implementation Team is developing clear procedures which include:

I. A sign off process illustrating how the HCS and HCV recommendations and

associated final “Go” and “No Go” maps generated are to be used by

operational staff, as part of their operational planning.

II. A checklist to accompany the sign off process to ensure that there is formal

signoff at each stage of the process.

b. These procedures will apply to all future land development processes across

APP’s entire supply base

c. Retraining: All relevant APP and pulpwood supplier operation staff will be

recalled for re-briefing to ensure there is a clear understanding of the signoff

procedures and operationalisation of the recommendations in accordance with

APP’s FCP.

d. Monitoring:

I. Updated Planting Realization Maps to be sent monthly to the FCP

implementation team.

II. Random field checks are to be conducted by the FCP implementation team

every three months.

e. Restoration: TFT recommends that APP restore or compensate for the

equivalent HCS area of what was cleared since 1st February 2013.

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Appendix 1. Summary result of the pre-assessments to identify HCS/HCV/peatland areas Methodology Pre-assessments to identify of HCS/HCV/peatland areas were deployed in BAP, BMH and SBA, which focused on the areas planned to be developed during 2013(the RKT 2013 operational compartments). The company requested that these pre-assessments be undertaken to facilitate plantation development in ‘low risk’ areas in order to meet its suppliers’ plantation forecasts for its proposed new pulp mill being built in South Sumatra. Pre-assessments are not being applied elsewhere to any other of APP’s suppliers. Full HCS and HCV (including peatland) assessments are currently being deployed over all areas of these three companies. Scope Block RKT 2013 HTI concession:

1. PT. Bumi Mekar Hijau (BMH)

2. PT. Sebangun Bumi Andalas (SBA)

3. PT. Bumi Andalas Permai (BAP)

Data on the extent of each concession are as follows:

Name of Company Total Extent (Ha)

Extent of RKT 2013 (Ha)

PT. Bumi Mekar Hijau (BMH) 253,612 33,896 PT. Sebangun Bumi Andalas (SBA) 135,689 8,147 PT. Bumi Andalas Permai (BAP) 194,589 17,717 Total 583,891 59,760

Source: Layout and spatial analysis of 2013RKT compartments Method

1. Desk Study

• Map of land cover

• Map of SPOT 5 and its interpretation

• Progress of the HTI activity (land clearing, plantation, etc.)

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2. Analysis of Secondary Data

3. Aerial Survey

4. Carbon Stock Measurement (above ground biomass)

5. Consultation with selected stakeholders

6. Biodiversity Survey (HCV 1, 2, & 3)

Desk Study and Its Analysis

The secondary data used in the formulation of the field data collection plan and its

further analysis can be seen in table below

Secondary data for the data collection plan and analysis result

Stages Data Source

Basemap & Physical Desk Study • Land Cover SPOT - 2012 (SMF)

Landsat 2010 (Kemenhut) • Water catchment area (DAS) RLPS Kemenhut (2010) • Land System RePPProT (1990) • Basemap (river, road) PDTK – Kemenhut

Field Survey • Aerial Survey (TFT-SMF / 4-5 February 2013)

RKT 2013 SBA, BAP, BMH

• Ground Survey (TFT-SMF / 25 – 29 February 2013)

District Jelutung, Bagan Rame, Simpang Heran (HTI, Peat, SS, BZ)

Ecology Desk Study • Ecosystem type

Sumatra Eco region Map - WWF • Habitat of Sumatran Elephant • Habitat of Sumatran Tiger • Important Bird Area Birdlife • Peat land Wetlands (2003)

RePPPRot (1990) SMF Operational map

Desk Study & Field Check

• Elephant Encounter Location SMF monitoring table and map

Survey of Biodiversity

• Survey of Ecology (TFT-SMF) in

o 34 Fauna identification transect lane

o 9 Plots of Vegetation identification 23 Feb – 7 March

Location: • Simpang Heran (HK,BZ,SS,BT) • Air Sugihan (BM) • Sungai Jelutung (BT, DPSL) • Sungai Beyuku (HTI) • Sungai Penyabungan (DPSL,BM,

KPPN) • Padang Sugihan (HK, BT) • Kuala Lumpur (KPPN, BM) • Teluk Pulai (HTI, BZ) • Tanjung Jati (BT, HK) • Tanjung Kait (LT, SS)

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Stages Data Source

• Sungai Ketupak (BR, HTI) • Sungai Serdang (BT) • Sungai Gebang (Karet, BM, LT,

BM, HTI, LT) Social Desk Study • OKI statistical data (OKI Dalam

Angka) BPS OKI

• Land conflict map BAP, SBA, BMH Interview & FGD

• Interview & FGD (TFT-SMF) 23 Feb – 7 March 2013

Location: • Banyu Biru Village • Jadi Mulya Village • Kuala 12 Village • Lebong Gajah Village • Simpang Tiga Jaya (S. Pedada)

Village • Simpang Tiga Sakti Village • Srijaya Baru Village • Sungai Batang Village • Tulung Seluang Village • 3 Penyabungan Hamlet, Riding

Village • Bagan Rame Hamlet • Parit 26 Hamlet • Sungai Janun Hamlet • Sungai Kong Hamlet

Legal Documents Desk Study • Macro Delineation

BAP, SBA, BMH • RKU • LHP Gelam • LHP Karbon • RKL & RLP 2012 • LITBANGHUT reports • LHP Cultivation of Gelam species • LHP 2012 Peat Carbon • LHP 2011 Peat Emission • LHP Rehabilitation Technology of

Peat Swamp Forest • Proceeding in the management of

Forests and Swamp Lands in an Integrated and Wise manner

• Proceeding in the Role of Science and Technology (Iptek) in Supporting the Development of Plantation Forests and Welfare of the Community

Balitbanghut

• RKT Block BAP, SBA, BMH

Based on the secondary data analysis, the data collection in the field was obtained from

the following activities:

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Aerial Survey The aerial survey covered 56% of the total area within the RKT 2013 of all the 3

companies. The scope of the observation on each concession is presented in table

below.

Scope of the observation of the “Aerial Survey” activity

HTI Extent of RKT 2013 (Ha)

Extent of the Aerial Survey Observation (Ha)

% of the observation

BMH 33,896 16,034 47.3 SBA 8,147 5,463 66.7 BAP 17,717 12,100 68.3 Total 59,760 33,597 56.2

Carbon Stock Measurement The HCS plots were randomly deployed with the intensity of sampling from 0.01% to

0.025% detailed in the table below. These randomly deployed HCS plots only targeted

non-peat areas as defined through available peat maps as these areas were

automatically categorized as “No Go”.

Number of HCS measurement plot on each HTI Concession

HTI Extent of Scrub on RKT 2013

(ha)

Intensity of the

sampling (%)

Plot Plan ∑

Plot Realization

∑ Plot Remarks

SBA 4,034 0.025 20 18 2 plots were already cleared; 4 plots carbon contain over 35 tons/ha and 14 plot carbon contain below 35 tons/ha; No indication of peat existence in these plots

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HTI Extent of Scrub on RKT 2013

(ha)

Intensity of the

sampling (%)

Plot Plan ∑

Plot Realization

∑ Plot Remarks

BMH 27,754 0.010 56 56 4 plots carbon contain over 35 tons/ha and 52 plot carbon contain below 35 tons/ha; No indication of peat existence in these plots

BAP 12,515 0.025 63 60 3 plots were already cleared; 4 plots carbon contain over 35 tons/ha and 56 plots carbon contain below 35 tons/ha; No indication of peat existence in these plots

Total 44,303 139 134 12 plots carbon contain over 35 tons/ha and 122 plots carbon contain below 35 tons/ha; No indication of peat existence in these plots

The maps below show the plots location and flight paths.

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Consultation with selected stakeholders

The consultation was only conducted at the village/hamlet level. This was conducted

because the village/hamlet would mostly have interest in the HTI concession areas and

therefore engage in the process. The consultation process was conducted through

interviews and Focus Group Discussions (FGD) in the fourteen villages/hamlets.

The pre-assessment process for the identification of HCV and HCS areas (excluding peatland) is illustrated below

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In the preliminary HCS assessment 134 random plots were established in the RKT 2013 areas with a sample intensity of 0.01% to 0.025%. The summary of these sample plots is tabulated below.

Summary of the Sample Plot of Preliminary Assessment

Species Total Tree Min DBH (cm) Max DBH (cm)

District Total District District KL SH ST KL SH ST KL SH ST

Gelam 64 45 40 149 5 5 5 29 13 13 Jambu-jambu 7 7 6 30 Jelutung 2 2 6 6 Mate Ketam 1 1 9 9 Pulai 3 40 35 78 20 9 5 21 1 9 30 Rengas 4 4 5 13 Terentang 31 31 7 30 Grand Total 71 95 119 285

Remarks:

- Min DBH : Smallest tree diameter found in the sample plot - Max DBH : Largest tree diameter found in the sample plot - KL : Kuala Lumpur - SH : Simpang Heran - ST : Simpang Tiga

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The HCS approach distinguishes natural forest from degraded lands with only small trees, scrub, or grass remaining. It separates vegetation into six different classes (stratification) through the combination of analyzing satellite images and field plots. The Indonesian descriptions of these are: High Density Forest (HK3), Medium Density Forest (HK2), Low Density Forest (HK1), Old Scrub (BT) 3, Young Scrub (BM), and Cleared/Open Land (LT). For the purpose of this study, a provisional threshold for HCS forest of greater than 35 tC/Ha of above ground biomass (AGB) was set. As a result of the pre-assessments (HCS/HCV/peatland), specific operational RKT 2013 compartments could be classified into three broad categories:

1. ALREADY DEVELOPED: - Developed: Compartments whereby HTI had already been established

(plantation and canal/other infrastructures).

2. NO GO AREAS:

- Potential HCS/HCV/peatland: Compartments that potentially contained

above ground carbon stocks of more than 35 ton/Ha or strata Young

Scrub/BT and Forest Cover/HK and/or potential HCV, including peatland

areas. These compartments were then considered as “No Go” areas.

- Require further check (RFC): Compartments that could not be classified

accurately as inconsistencies between the principle data sources (aerial

survey, field measurement, and Spot 5 analysis) were identified and

therefore a more intensive evaluation and field check would need to be

conducted prior to any operations. A precautionary approach was taken

whereby these compartments were classified as “Require further check”

and therefore “No Go” areas.

3. GO AREAS: - Non-HCS/ non-HCV/ non-peatland: compartments that contained above

ground carbon stocks of less than 35 ton/Ha (or strata classified as Open

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Land/LT and Young Scrub/BM) and no potential HCV, including peatland

areas. These compartments were then considered as “Go” areas.

Summary of Preliminary Assessment HCS/HCV/peat result for the three HTI

HTI Developed (Ha)

Non HCS/HCV/pea

tland (Ha)

HCS/HCV/peatland (Ha)

Require Further Check* (Ha)

Total (Ha)

BAP 5,907 3,561 5,193 3,055 17,717

BMH 7,931 9,763 13,182 3,020 33,896 SBA 2,635 1,283 1,427 2,803 8,147

Grand Total 16,473 14,607 19,802 8,878 59,760 Overlaid maps of HCV/Peat and HCS for the three HTI are below.

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Appendix 2. Field verification Result Following the field verification conducted on the 23rd to the 27th of July 2013, it was concluded that, of the 431.1 Ha cleared for development within the ‘No Go’ areas, there were potential forest moratorium breaches in 23 compartments of the RKT areas: BMH: Simpang Tiga District (16 compartments) SBA: Kuala Lumpur District (4 compartments) BAP: Simpang Heran District (3 compartments)

The profile of the 23 compartments and their locations

No Compartment HTI District RKT

Land Clearing Status Remarks Date

started Date

completed

1 KL I1050 SBA KL 23.10 01.02.2013 05.02.2013 Potential HCS

Potential Moratorium

Breach

2 KL F5150 SBA KL 23.60 07.02.2013 12.02.2013 Potential HCS


Breach

3 KL F5160 SBA KL 23.50 07.02.2013 12.02.2013 Potential HCS


Breach

4 KL I1060 SBA KL 23.90 01.02.2013 05.02.2013 Potential HCS


Breach

5 SHC 2010 BAP SH 20.70 20.01.2013 10.02.2013 Potential HCS


Breach

6 SHC 1210 BAP SH 18.30 20.01.2013

10.02.2013

Potential HCS


Breach

7 SHC 1220 BAP SH 20.60 20.01.2013

10.02.2013

Potential HCS


Breach

8 STE 4200 BMH ST 22.10 21.01.2013 15.02.2013 Potential HCS


Breach

9 STF 2110 BMH ST 24.90 20.01.2013 15.02.2013 Potential HCS


Breach



Breach



Breach

12 STF 1090 BMH ST 24.20 02.03.2013 13.03.2013 RFC


Breach

13 STF 1020 BMH ST 23.40 02.03.2013 13.03.2013 RFC


Breach

14 STF 2220 BMH ST 24.50 11.02.2013 23.02.2013 Potential HCS Potential

Moratorium

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No Compartment HTI District RKT

Land Clearing Status Remarks Date

started Date

completed Breach

15 STF 2190 BMH ST 23.10 13.02.2013 24.02.2013 RFC


Breach



Breach



Breach

18 STF 2120 BMH ST 24.50 10.02.2013 22.02.2013 RFC


Breach



Breach

20 STD 3240 BMH ST 22.10 12.02.2013 22.02.2013 RFC


Breach

21 STD 4040 BMH ST 20.80 12.02.2013 21.03.2013 RFC


Breach

22 STD 4170 BMH ST 22.80 12.02.2013 23.02.2013 RFC


Breach

23 STD 4240 BMH ST 22.40 12.02.2013 25.02.2013 Potential HCS


Breach

Total area (Ha) 528.20

Total area cleared after 31 Jan 2013 (Ha) 431.10

The details on the number of compartments per district where land preparation was conducted after the moratorium are as follows:

a. SBA

Kuala Lumpur (KL) District Land development occurred in four compartments in the SBA Kuala Lumpur District, which were inside designated “No Go” areas. The wood from the clearing of the 3.49 Ha HCS area was not sent to APP’s mills.

b. BMH 1. Sungai Ketupak (SK) District

No breach occurred in BMH Sungai Ketupak District. 2. Simpang Tiga (ST) District

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Land development occurred in 16 compartments of the BMH Simpang Tiga District, which were inside the designated “No Go” areas. The wood from the clearing of the 63.47 Ha HCS area was not sent to APP’s mills.

c. BAP

Simpang Heran (SH) District Land development occurred in 3 compartments of the BMH Simpang Heran District, which were inside the designated “No Go” areas. The wood from the clearing of the 2.49 Ha HCS area was not sent to APP’s mills.

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Appendix 3. Stage 1 of data reconciliation: Alignment of field verification data and APP Operational data (field and Head office) Following the field verification on the 23rd to the 27th of July 2013, it was concluded that an area of 431.1 Ha had been developed within 23 compartments of the “No Go” areas. A field verification and APP operation data reconciliation (Stage 1) was required to verify how much of the 431.1 Ha area should have been classified as HCS and/or potential HCV (including peatland areas). With respect to HCV – These 23 compartments representing 431.1 Ha were crosschecked in relation to potential HCV areas identified during the pre-assessments (HCS/HCV/peatland) in February 2013. There was no overlap. Therefore, none of the 23 compartments above were assessed to contain HCV and all further verification could focus on identifying potential HCS. With respect to HCS, the verification analysis output detailed below revealed that of the 431.1 Ha, an initial maximum of 72 Ha could be estimated as HCS. This estimate would be further checked through a stage 2 data reconciliation (Comparative Spatial Analysis with additional reference to Full HCS Assessment Plots).

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Result of the data reconciliation between the FVT and APP team (note: the compartments earmarked red are those containing potential HCS.)

Compartment

Land area Status Date

of LC I

Date of LC

II

Visual Spot Analysis Dec 2012

HCS Plot Feb 2013 Photo 2013 Remarks

Area cleared after 1

February 2013 (Ha)

SHC 2010

20.7 RFC 20 Jan 2013

06 Feb 2013

From BT-LT; BT 30% LT 70%

Plot ground check no 23; 0 ton carbon/Ha (tC/Ha)

Photo of ground check: all directions are already Land Clearing (LC). There is already a tertiary canal in the south

Compartment with LT-BT condition and 60% is already LC prior to 1 February 2013

6.7

SHC 1210

18.3 Potential HCS

20 Jan 2013

06 Feb 2013

From BM-BT; with 25% LT - 75% BM and BT

NA Aerial Photo could not be used because it does not describe this compartment

Around 70% of this compartment was already cleared prior to 1 February 2013 and 30% of it was cleared after 1 February 2013

5.2

SHC 1220

20.6 Potential HCS

20 Jan 2013

06 Feb 2013

35% LT the remaining 65% BM-BT

NA Aerial Photo could not be used because it does not describe this compartment

More or less, 80% of this compartment was already cleared prior to 1 February 2013 and 20% of it was cleared after 1 February 2013

3.6

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Compartment


of LC I

Date of LC

II




February 2013 (Ha)

KL I1050 23.1 Potential HCS

01 Feb 2013

60% LT- 40% BM

There is a plot with a distance of approx. 750 M with a same appearance as with the carbon content below 35tC/Ha

Photo indicate a variation of BM-BT with BM vegetation domination

23.1

KL F5150

23.6 Potential HCS

07 Feb 2013

20% LT- 80% BM

There is a plot with a distance of approx. 250 M with a same appearance as with the carbon content below15tC/Ha

NA 23.6

KL F5160

23.5 Potential HCS

07 Feb 2013

40% LT - 60% BM

There are 3 plots with a same appearance as with the carbon content belo15tC/Ha

3 photos in every plot indicates vegetation that is dominated by prumpung and gelam seedlings

23.5

KL I1060 23.9 Potential HCS

01 Feb 2013

10% LT - 90% BM

There is a plot with a distance of approximately 250 M with a same appearance as with the carbon

NA 23.9

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Compartment


of LC I

Date of LC

II




February 2013 (Ha)

content below 35tC/Ha

STE 4200 22.1

Potential HCS

21 Jan 2013

10 Feb 2013

10% LT - 70% BM - 20% BT

NA NA 7.1

STF 2110

24.9 Potential HCS

20 Jan 2013

11 Feb 2013

90% LT - 10% BM

NA NA 4.9

STF 2100 22.7

Potential HCS

20 Jan 2013

12 Feb 2013

50% LT - 50% BM NA NA

4.7

STE 4100

23 Potential HCS

04 Mar 2013

40% BT - 60% BM

NA NA 23

STF 1090

24.2 RFC 02 Mar 2013

100% LT There is a plot (no 50) with a distance of 500 M from the compartment

Photo ground check indicates vegetation of open land in the form of bushes

24.2

STF 1020

23.4 RFC 02 Mar 2013

100% LT There is a plot (no 50) with a distance of 200 M from the compartment

Photo ground check indicates vegetation of open land in the form of bushes

23.4

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Compartment


of LC I

Date of LC

II




February 2013 (Ha)

STF 2220

24.5 Potential HCS

11 Feb 2013

20% LT - 80% BM

There is a plot (no 48 – the field physical is 35) with a distance of 100 M from the compartment with a carbon value of 8 tC/Ha

Photo ground check indicates prumpung and gelam

24.5

STF 2190

23.1 RFC 13 Feb 2013

10% LT - 90% BM

There is a plot (no 48 – the field physical is 35) with a distance of 100 M from the compartment with a carbon value of 8 tC/Ha

Photo ground check indicates prumpung and gelam

23.1

STF 2210

24.5 Potential HCS

04 Mar 2013

20% LT - 80% BM

NA Aerial Photo confirms dominant LT

24.5

STF 2200 23.1

Potential HCS

02 Mar 2013

60% LT - 40% BM NA NA

23.1

STF 2120

24.5 RFC 10 Feb 2013

70% LT - 30% BM

NA NA 24.5

STE 4110 26.4

Potential HCS

04 Mar 2013

20% BT - 80% BM NA NA

26.4

STD 3240

22.1 RFC 12 Feb 2013

70% LT - 30% BM

There is a plot (no 42) with a distance of 200 M from the

NA 22.1

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Compartment


of LC I

Date of LC

II




February 2013 (Ha)

compartment with a carbon value of 11tC/Ha

STD 4040

20.8 RFC 12 Feb 2013

70% LT - 30% BM

There is a plot (no 42) with a distance of 200 M from the compartment with a carbon value of 11 tC/Ha

Aerial Photo confirms dominant land preparation

20.8

STD 4170

22.8 RFC 12 Feb 2013

10% LT - 90% BM

NA Aerial Photo indicates BM and LT

22.8

STD 4240

22.4 Potential HCS

12 Feb 2013

100% BM NA Aerial Photo indicates BM

22.4

31

Appendix4.Stage 2 data reconciliation (Comparative Spatial Analysis with additional reference to Full HCS Assessment Plots) Following Stage 1 whereby field verification data and APP Operational data (field and head office) were reconciled, a second stage comparative spatial analysis was implemented to both double check the output of the first stage and to strengthen the overall result through the inclusion of plot data generated in the full HCS assessment implemented in June/July 2013. The Comparative Spatial Analysis is based on a land cover analysis using updated SPOT 5 images and a supervised classification of strata and HCS measurement plots over the 23 compartments.HCS measurement plots from the preliminary HCS assessment were used as training samples for the exercise. The following flow diagram illustrates the steps taken during the spatial analysis

Picture 1. Spatial Analysis Method

Training sample classification of preliminary HCS plot values (Feb 2013):

1. > 35 (4 plots) 2. 10 – 35 (3) 3. 0 – 10 (3) 4. < 0 (4) 5. Water

(Independent Training

Digital SPOT image Calculate statistical descriptions

Classify data into categories

Verify HCS full assessment plots

Final data classification

Breach of HCS area

32

Training sample summary of carbon values Class No Id Plot Location Ton C/Ha Note

Old Scrub / Forest Density 01

1 54-BMH ST 59.58 Training Sample 2 55-BMH ST 36.75 3 39-BMH ST 71.19 4 51-BAP SH 51.08 5 2-SBA KL 44.7 Corresponding

HCS Plots 6 17-SBA KL 73.85 7 32-SBA KL 45.41 8 41-SBA KL 112.68 9 47-BMH ST 82.22 10 48-BMH ST 157.28 11 52-BMH ST 107.34 12 56-BMH ST 61.41 13 58-BMH ST 93.04 14 64-BMH ST 36.2 15 65-BMH ST 59.6 16 72-BMH ST 59.45 17 109-BMH ST 127.82 18 127-SBA KL 35.22 19 66-BAP SH 75.77 20 68-BAP SH 158.34

Young Scrub / Old Scrub

1 52-BAP SH 26.48 Training Sample 2 42-BMH ST 11.23 3 43-BMH ST 18.18 4 13-SBA KL 24.08

Corresponding HCS Plots

5 45-SBA KL 31.74 6 50-BMH ST 28.58 7 60-SBA KL 26.19 8 69-BMH ST 24.65 9 106-BMH ST 12.97

Young Scrub 1 51-BMH ST 3.39 Training Sample 2 7-SBA KL 4.28 3 48-BMH SK 8.05 4 14-SBA KL 5.19


5 39-BMH ST 9.89 6 51-BMH ST 1.26 7 67-BMH ST 5.75 8 82-BMH ST 9.46

Class LT 1 23-BAP SH 0 Training Sample

2 25-BAP SH 0 3 24-BAP SH 0 4 50-BAP ST 0 5 16-SBA KL 0


6 18-SBA KL 0 7 34-SBA KL 0

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Class No Id Plot Location Ton C/Ha Note 8 44-SBA KL 0 9 107-SBA KL 0 10 108-SBA KL 0 11 129-SBA KL 0 12 130-SBA KL 0 13 49-BAP SH 0 14 49-BAP SH 0 15 54-BAP SH 0 16 55-BAP SH 0 17 118-BAP SH 0 18 134-BAP SH 0 19 135-BAP SH 0

Water Use 5 independent training samples (at the canals)

Based on the Supervised Classification, the total area containing HCS was estimated to be 88.38Ha (Table 7). Through further portioning between the verification and consolidation data and spatial data analysis (Table 8) it can be concluded that the final HCS area cleared after the 1stof February 2013 is 69.45 Ha.

Land cover distribution of each compartment in question District/

Compartment Water LT Class Veg 1 Class Veg 2 Class Veg 3 (>35 t/c/Ha) Total

Kuala Lumpur 4.57

16.15

58.95

17.04

3.48 100.20

KLF5150 1.52

5.37

13.35

4.15

0.27 24.66

KLF5160 2.69 4.61

14.05

4.25 0.05 25.66

KLI1050 0.19

4.45

14.98

3.56

1.05 24.24

KLI1060 0.17 1.72

16.56

5.07

2.12 25.64

Simpang Heran 1.16

14.19

19.11

20.31

12.17 66.93

SHC1210 0.43

1.20

7.31

10.04

2.23 21.22

SHC1220 0.21

0.19

7.44

7.47

8.92 24.23

SHC2010 0.51

12.79

4.35

2.81

1.01 21.48

Simpang Tiga 16.47

49.24 183.56

69.22 72.72 391.22

STD3240 0.87

2.45

15.30

4.47

2.16 25.25 STD4040

0.03 0.83 16.18 6.85 0.74

24.63

STD4170 0.05 0.62 4.71

7.03 13.42 25.83

34

District/ Compartment Water LT Class Veg 1 Class Veg 2 Class Veg 3

(>35 t/c/Ha) Total

STD4240

0.04

2.76

1.90

18.77 23.48

STE4100

1.05

5.38

7.46

15.22 29.10

STE4110

3.31

6.49

4.15

7.45 21.39

STE4200 0.03

3.20

7.86

3.07

12.74 26.90

STF1090 4.86

2.55

11.97

0.07 19.45 STF2100 0.97 3.90 13.44 5.84 0.31 24.46

STF2110 1.05

2.03

19.57

2.14

0.39 25.19

STF2120 0.31

1.21

16.77

4.47

0.35 23.11

STF2190 0.08

4.42

13.56

8.00

0.37 26.43

STF2200 2.50

7.32

12.86

6.03

0.25 28.96

STF2210 0.05

7.24

8.06

6.11

0.34 21.80

STF2220 0.11

2.33

15.92

1.24

0.17 19.78

STF4020 5.55

6.75

12.73

0.38

0.04 25.46

22.20

79.58

261.61

106.57

88.38 558.34 Remarks: Class Veg 1 young scrub Class Veg 2 young scrub-old scrub Class Veg 3 old scrub-forest density1 (>35 tC/Ha) Proportional calculation of each compartment in question

Compartment District Spatial

Analyses Area1

RKT Area2

Verification and

Consolidation HCS area3

Spatial Analyses

HCS area 4

Estimated Proportion

of HCS area5

SHC 2010 SH 20.58 20.7 6.7 1.01 0.33 SHC 1210 SH 20.82 18.3 5.2 2.12 0.60 SHC 1220 SH 24.57 20.6 3.6 8.92 1.56 KL I1050 KL 23.05 23.1 23.1 1.05 1.05 KL F5150 KL 25.68 23.6 23.6 0.27 0.27 KL F5160 KL 24.63 23.5 23.5 0.05 0.05 KL I1060 KL 23.86 23.9 23.9 2.12 2.12 STE 4200 ST 26.29 22.1 7.1 12.74 4.09

35

Compartment District Spatial

Analyses Area1

RKT Area2

Verification and

Consolidation HCS area3

Spatial Analyses

HCS area 4

Estimated Proportion

of HCS area5

STF 2110 ST 25.35 24.9 4.9 0.39 0.08 STF 2100 ST 24.37 22.7 4.7 0.31 0.06 STE 4100 ST 28.72 23.0 23.0 15.22 15.22 STF 1090 ST 18.71 24.2 24.2 0 0 STF 1020 ST 15.73 23.4 23.4 0 0 STF 2220 ST 20.35 24.5 24.5 0.17 0.17 STF 2190 ST 25.43 23.1 23.1 0.37 0.37 STF 2210 ST 22.30 24.5 24.5 0.34 0.34 STF 2200 ST 27.99 23.1 23.1 0.25 0.25 STF 2120 ST 23.08 24.5 24.5 0.35 0.35 STE 4110 ST 20.72 26.4 26.4 7.45 7.45 STD 3240 ST 25.95 22.1 22.1 2.16 2.16 STD 4040 ST 23.83 20.8 20.8 0.74 0.74 STD 4170 ST 26.26 22.8 22.8 13.42 13.42 STD 4240 ST 24.69 22.4 22.4 18.77 18.77

Total 542.96 528.2 431.1 88.38 69.45 Remarks: 1: Compartment area based on the spatial data 2: Compartment area based on the RKT document 3: Area prepared after 1 February 2013 based on the verification and consolidation 4: Area prepared after 1 February 2013 based on the spatial data 5: Area prepared after 1 February 2013 based on the proportion between 3 and 4

It is important to note that the team ran a number of simulations to assess the impact of utilizing different carbon calculation algorithms in the conversion process. The resulting outputs were considerably different whereby a compartment designated as HCS under one algorithmic conversion could swing to non-HCS under a second algorithm. For the purposes of this verification a precautionary approach was taken whereby the most conservative algorithm (overestimating carbon values) was selected to yield the final value of 69.45 Ha. As part of APPs on-going HCS assessment work an independent organisation(George Kuru, Ata Marie Group Ltd) has been recruited to support the team to evaluate the most appropriate algorithm for use in the HCS studies.

The carbon algorithms used included: Secondary Peat Swamp Forest (Sumsel) : Ln B = LN 0.206 + 2.45 LN D Scrub Peat Swamp Forest (Disertasi Susi - 2012) : B=0.098 D^2.35 LOA Peat Swamp Forest (Sumsel) (Skripsi - No. 74 -Forda) : B=0.1531 D^2.40 LOA Peat Swamp Forest (Kalteng) (Skripsi - No. 34 -Forda) : B=0.1066 D^2.486

36

SPOT image interpretation on the area cleared after 1 February 2013 at Simpang Tiga District of BMH

37

SPOT image interpretation on the area cleared after 1 February 2013 at Simpang Heran District of BAP

38

SPOT image interpretation on the area cleared after 1 February 2013 at Kuala Lumpur District of SBA

39

Appendix 5. Field Verification related to the alleged breach in South Sumatra A. Implementation of the Verification

1. Date and Implementers of the Verification The verification was conducted from the 23rd to the 27th of July 2013.The Field Verification Team was comprised of:

- Yudi Purnomo (TFT) - Abidin Lakadimu (TFT) - Ihwan Rafina (TFT)

The Supplier Resource Team was comprised of:

- Baron Y. Setiawan (PMD Region of Palembang) - Muhammad Rozi (PMD Region of Palembang) - Iyus Yusuf (PMD Region of Palembang) - Sudadi (PMD Region of Palembang) - Kgs. M. Iqbal (PMD Region of Palembang) - Iwan Zalkashi (DM Simpang Tiga) - Madenin (PSD Simpang Tiga) - Rahmat Muda Kelana Madenin (Project Leader I Simpang Tiga District) - Alpison (Project Leader of Simpang Heran District) - Hendri (PSD Kuala Lumpur) - M. Fahmi (PH Kuala Lumpur District) - Ruli Kurniawan (DM Sungai Ketupak) - Rudi Susanto (PSD Sungai Ketupak) - Supriansyah (PTU Sungai Ketupak)

2. Document Verification

A document review was conducted to understand the chronology of events. The FVT accompanied by staff from each District conducted the document reviews.

Following the natural forest clearance moratorium commitment made by the APP on the 31st of January 2013, the FOD (Head of the Region) of Palembang sent an Internal Office Memo No. Reg: FOD-2013-I-005 and the Moratorium Protocol to forest operators in all Districts and Supporting Departments through email. The FOD also requested forest operators/contractors in all Districts to stop all operational activity of new land preparation.

40

After the HCS/HCV/peat preliminary assessment, the Planning Department in the Office of the Region of Palembang developed an operational map named “RKT 2013 Recommendation Map” based on The FCP Implementation Team Map illustrating the result of the HCV and HCS preliminary assessment on RKT 2013 and associated “Go” and “No Go” areas. This “RKT 2013 Recommendation Map” was sent to forest operators in all the Districts on the 8th of February 2013 through email.

a. SBA

1. Kuala Lumpur District

A verification process was conducted on the following documents related to the land preparation in operational areas subject to the pre-assessments(HCS/HCV/peatland) on RKT 2013.

v RKT

RKT 2013 was approved by the SBA Chief Director according to SK.093/SBAWI/XII/2012 dated on the 10th of December 2012. RKT 2013 is valid from the 1st of January 2013 until the 31st of December 2013, a total land area of 2,606 Ha. Land allocation in SBA according to the approved 2013 RKT

Company District Land Area

Remarks Lay out (Ha)

(Ha) TP TU TK KL

SBA Kuala Lumpur 30,754

Plan 13,505 6,848 4,397 4,278

Realization 5,036 0 0 0

In the SBA RKT 2013 document, the activity plan for all districts include the following:

• The land preparation plan on bare land, including former harvested areas is

8,353.23 Ha. • The planting plan on bare land, including former harvested areas in the areas:

- Main Plants : 7,869 Ha - Indigenous Species Plants : 100 Ha - Livelihood Plants : 400 Ha

v On the 8th of February 2013, despite the distribution of the “RKT 2013 Recommendation Map” and Moratorium Protocol being sent to the Kuala

41

Lumpur District operator, land preparation activity continued in the compartments inside the “No Go” areas, namely; KL F5150 and KL F5160 under the work contract (Work Order/SPK) with the land preparation contractor.

v Document for land preparation and planting. The document for land preparation and planting after the 1st of February 2013 is available in the District in the form of a Daily Activity Report. In this report, the realization of the land preparation, the name of the contractor for the land preparation, unit code, daily planting report, and planting contractor are listed. Report of land preparation in SBA and its breachstatus

No Compartment Land Area (Ha)

Mechanical LC Recommendation map Remarks

Date Started Date Ended

1 KL I1050 23.1 01.02.2013 05.02.2013 HCS Potential


Breach

2 KL I5150 23.6 07.02.2013 12.02.2013

HCS Potential Potential Moratorium

Breach

3 KL I5160 23.5 07.02.2013 12.02.2013

HCS Potential Potential Moratorium

Breach

4 KL I1060 23.9 01.02.2013 05.02.2013 HCS Potential


Breach Date of planting of each compartment in question in SBA

No Compartment

Land Area (Ha)

Planting Remarks

Date Started Date Ended 1 KL I1050 23.1 01.06.2013 06.06.2013 n/a 2 KL I5150 23.6 01.06.2013 08.06.2013 n/a 3 KL I5160 23.5 01.06.2013 09.06.2013 n/a 4 KL I1060 23.9 18.06.2013 22.06.2013 n/a

v There was no utilization of the natural forest wood from the land preparation

activity in SBA. In accordance with the result of the preliminary assessment only non-commercial small diameter trees dominated by pioneer species were produced as a result of the land preparation (see Appendix 1).

v The District did not update the realization of the land preparation. No procedure regulates the implementation of such periodic updating.

b. BMH

42

A verification procedure was conducted on the following documents related to the land preparation in operational areas subject to the pre-assessment (HCS/HCV/peatland) on RKT 2013: v RKT

The self-approval of RKT 2013 signed by the BMH Chief Director through SK.101/BMH/XII/2012. RKT 2013 is valid from the 1st of January 2013 until the 31st of December 2013 in a land area of 4,517 Ha. The BMH RKT 2013 Document details the work plan for all the Districts as follows: • The land preparation plan on bare land, including former harvested areas, is

32,581 Ha. • The planting plan in vacant lots, including former harvested areas are:

- Main Plants : 31,761 Ha - Indigenous Species Plants : 120 Ha - Livelihood Plants : 700 Ha

Land allocation of BMH according to the approved 2013 RKT

HTI District Land Area Remarks Lay Out (Ha) (Ha) TP TU TK KL

BMH Sungai Ketupak 43.536

Plan 26,970 6,715 3,295 4,416


Simpang 28.491 Plan 28,491 497 1,310 1,179

Tiga


1. Sungai Ketupak District

v Land preparation document

Based on the land preparation document for the Sungai Ketupak Districk only one compartment, SKJ 3030 was cleared and this was completed prior to the 1st of February 2013.

Report of land preparation in Sungai Ketupak District (BMH) and its breachstatus

No Compartment Area Mechanical LC Remarks

(Ha) Date Started Date Ended

1. SKJ 3030 22.9 14.01.2013 27.01.2013 Potential

43

Moratorium Breach

v The District did not update the realization of the land preparation. No procedure

regulates the implementation of such updating.

2. Simpang Tiga District v On the 8th of February 2013, despite the distribution of the “RKT 2013

Recommendation Map” and Moratorium Protocol being sent to the Simpang Tiga District operator, land preparation activity continued in 16 compartments inside the “No Go” areas, under the work contract (Work Order/SPK) with the land preparation contractor.

v Document on the land preparation The document on the land preparation activity is available for Simpang Tiga District. Report of land preparation in Simpang Tiga District (BMH) and its breach status

No Compartment

Area Mechanical LC I Remarks (Ha) Date started Date ended Status

1 STE 4200 22.1 21.01.2013 15.02.2013 Potential HCS Potential Moratorium Breach

2 STF 2110 24.9 20.01.2013 15.02.2013 Potential HCS Potential

Moratorium Breach


Moratorium Breach

4 STE 4100 23.0 04.03.2013 15.03.2013 Potential HCS Potential

Moratorium Breach


Moratorium Breach


Moratorium Breach


Moratorium Breach


Moratorium Breach


Moratorium Breach


Moratorium Breach


Moratorium Breach

12 STE 4110 26.4 04.03.2013 17.03.2013 Potential HCS Potential

Moratorium Breach

13 STD 3240 22.1 12.02.2013 22.02.2013 Potential HCS Potential

Moratorium Breach

44

No Compartment

Area Mechanical LC I Remarks (Ha) Date started Date ended Status


Moratorium Breach


Moratorium Breach


Moratorium Breach

v There is no utilization of the natural forest wood from the land preparation

activity in the Simpang Tiga District. According to the result of the preliminary assessment, only non-commercial species can be found in the area (see Appendix 1).

v The District did not update the realization of the land preparation. No procedure regulates the implementation of such periodic updating.

c. BAP

1. Simpang Heran District A verification procedure was conducted on the following documents related to the land preparation in operational areas subject to the pre-assessments (HCS/HCV/peatland) on RKT 2013:

v RKT The self-approval of RKT by BAP signed by the BAP Chief Director as stipulated in the SK No. 101/BAP-XII/2012 (dated 10th of December 2012). The RKT 2013 is valid from the 1st of January 2013 until the 31st of December 2013 for a total land area of 5,651 Ha.

Land allocation of BAP according to the approved 2013 RKT

HTI District Land Area

Remarks Lay out (Ha)

(Ha) TP HTI District (Ha)

BAP Simpang Heran 35,289 Planned 19,671 BAP Simpang

Heran 35,289

Realization 14,276 In the BAP RKT 2013 document, the activity plan in all districts is: • The land preparation plan in bare land, including former harvested area is

18,349.34 Ha (of those, the 3,486 Hais ex-HTI). • The planting plan in vacant lots, including former harvested area are:

45

- Main Plants : 16,549Ha - Indigenous Species Plants : 140 Ha - Livelihood Plants : 1,660 Ha

v Land preparation Document

The document for land preparation and planting after the 1st of February 2013 is available in the District in the form of a Daily Activity Report. Report of land preparation in Simpang Heran District (BAP) and its breachstatus

No Comp Area Mechanical LC I Mechanical LC II

Remarks (Ha) Date

started Date

ended Date

started Date ended Status

1 SHC 2010 20.7 20.01.2013 31.01.2013 06.02.2013 10.02.2013 Potential HCS


Breach

2 SHC 1210 18.3 20.01.2013 31.01.2013 06.02.2013 10.02.2013

Potential HCS Potential Moratorium

Breach

3 SHC 1220 20.6 20.01.2013 31.01.2013 06.02.2013 10.02.2013

Potential HCS Potential Moratorium

Breach

v On the 8th of February 2013, despite the distribution of the “RKT 2013

Recommendation Map” and Moratorium Protocol being sent to the Simpang Heran District, land preparation activity continued in three compartments inside the “No Go” areas, under the agreement (Work Order/SPK) with the land preparation contractor.

v There was no utilization of the natural forest wood from the land preparation activity in the Simpang Heran District. According to the result of the preliminary assessment, only non-commercial species can be found in the area (see Appendix 1).

3. FIELD VERIFICATION

In addition to verification of documents at each company, field verification activity was conducted to verify the information obtained through both interviews and documents. The FVT, accompanied by staff of each District, conducted the field investigation.

a. SBA 1. Kuala Lumpur District

46

This field verification was conducted on the 24th and the 25th of July 2013.

The map below indicates the location of the compartments were the potential forest moratorium breaches were identified:

Location map of compartments in question in Kuala Lumpur District (SBA)

The result of the field verification concluded that: v It was confirmed that the land preparation after the 1st of February 2013 occurred

in four compartments inside the “No Go” areas. (KL I1050, KL I1060, KL I5150 and KL I5160). The land preparation occurred from the 1st of February 2013 until the 12th of February 2013

v All the four compartments were already planted with Acacia spp as seen in the photos below:

Lokasi pengambilan photo

47

Planted compartments in question in SBA

48

b. BMH

1. Sungai Ketupak District

The field verification was conducted on the 25th of July 2013. The map below indicates the location of the compartments were the potential forest moratorium breachas required cross-checking.

Location map of compartments in question in Sungai Ketupak District (BMH) From the field verification the following facts and data were obtained: v It was confirmed that the land preparation after the 1st of February 2013 did not

occur. v The land preparation in compartment SKJ3030 was conducted prior to the 1st of

February 2013 (from the 14th of January 2013 to the 27th of February 2013). Therefore, there were no breaches.

v During the field verification, compartment SKJ3030 was already planted with Acacia spp, as seen in the pictures below.

Location of photographs (shown below)

49

Planted compartments in question in Sungai Ketupak District (BMH)

2. Simpang Tiga

The field verification was conducted on the 24th and the 25th of July 2013.

The map below indicates the location of the compartments were the potential forest moratorium breaches required crosschecking:

50

Location map of compartments in question in Simpang Tiga District (BMH) v It was confirmed that the land preparation after the 1st of February 2013 occurred

in the sixteen compartments inside the “No Go” area, (STE 4200, STF 2110, STF 2100, STE 4100, STF 1090, STF 1020, STF 2220, STF 2190, STF 2210, STF 2200, STF 2120, STE 4110, STD 3240, STD 4040, STD 4170, and STD 4240)

v During the verification, these 16 compartments were already planted with Acacia spp.

v The pictures below show the land preparation realization in compartment STD4160.


51

Planted compartments in question in Simpang Tiga District (BMH)

52

c. BAP

1. Simpang Heran District

The field verification was conducted on the 26th of July 2013. The map below indicates the location of the compartments where the potential forest moratorium breaches required crosschecking:

Location map of compartments in question in Simpang Heran District (BAP)

The following is the result of the field verification:

v It was confirmed that the land preparation after the 1st of February 2013 occurred in the three compartments inside the “No Go” (SHC 2010, SHC 1210 and SHC 1220). The land was cleared on the 20th to the 31st of January 2013, and then following a brief pause in clearance activities were resumed on the 6thtothe 10th of February 2013.

v During the field verification the three compartments were already planted with Acacia spp, as seen in the pictures below.


53

Planted compartments in question in BAP