TFT Verification Report- BHM, SBA, BAP

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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 1 st 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 FCPJoint 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 1 st February 2013 and 31 st 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 wereobtained 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 relevantdocuments, 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 23 rd to 27 th July 2013 using the following

    steps:

    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).

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

    Districts.

    Conducted field observations in the 23 compartments where the potential

    forest moratorium breaches within the No Go areas had occurred.

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

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

    August 2013 and which was completed on the 22 nd August. The findingswere 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 breachof 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 1 st February 2013.

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    Appendix 1. Summary result of the pre-assessments to identifyHCS/HCV/peatland areas

    Methodology

    Pre-assessments to identify of HCS/HCV/peatland areas were deployed in BAP, BMHand SBA, which focused on the areas planned to be developed during 2013(the RKT2013 operational compartments). The company requested that these pre-assessmentsbe undertaken to facilitate plantation development in low risk areas in order to meet itssuppliers plantation forecasts for its proposed new pulp mill being built in SouthSumatra. Pre-assessments are not being applied elsewhere to any other of APP ssuppliers.

    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 33,896PT. Sebangun Bumi Andalas (SBA) 135,689 8,147PT. Bumi Andalas Permai (BAP) 194,589 17,717Total 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 & PhysicalDesk 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 / 4-5February 2013)

    RKT 2013 SBA, BAP, BMH

    Ground Survey (TFT-SMF / 2529 February 2013)

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

    EcologyDesk Study Ecosystem typeSumatra 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 ofBiodiversity

    Survey of Ecology (TFT-SMF) in

    o 34 Fauna identification transectlane

    o 9 Plots of Vegetationidentification

    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)

    SocialDesk Study OKI statistical data (OKI Dalam

    Angka)BPS OKI

    Land conflict map BAP, SBA, BMHInterview &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 DocumentsDesk 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 anIntegrated and Wise manner

    Proceeding in the Role ofScience and Technology (Iptek)in Supporting the Development ofPlantation Forests and Welfare ofthe 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 RKT2013 (Ha)

    Extent of theAerial SurveyObservation(Ha)

    % of theobservation

    BMH 33,896 16,034 47.3SBA 8,147 5,463 66.7BAP 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 ofScrub onRKT 2013

    (ha)

    Intensityof the

    sampling(%)

    PlotPlan

    PlotRealization

    PlotRemarks

    SBA 4,034 0.025 20 18 2 plots werealreadycleared;4 plots carboncontain over35 tons/ha and14 plot carboncontain below35 tons/ha;No indicationof peatexistence inthese plots

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    HTI

    Extent ofScrub onRKT 2013

    (ha)

    Intensityof the

    sampling(%)

    PlotPlan

    PlotRealization

    PlotRemarks

    BMH 27,754 0.010 56 56 4 plots carbon

    contain over35 tons/ha and52 plot carboncontain below35 tons/ha;No indicationof peatexistence inthese plots

    BAP 12,515 0.025 63 60 3 plots werealready

    cleared; 4plots carboncontain over35 tons/ha and56 plotscarbon containbelow 35tons/ha;No indicationof peatexistence in

    these plotsTotal 44,303 139 134 12 plotscarbon containover 35tons/ha and122 plotscarbon containbelow 35tons/ha;No indicationof peat

    existence inthese 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 (excludingpeatland) is illustrated below

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    In the preliminary HCS assessment 134 random plots were established in the RKT 2013areas 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)DistrictTotal

    District DistrictKL SH ST KL SH ST KL SH ST

    Gelam 64 45 40 149 5 5 5 29 13 13Jambu-jambu 7 7 6 30Jelutung 2 2 6 6Mate Ketam 1 1 9 9Pulai 3 40 35 78 20 9 5 21 1 9 30Rengas 4 4 5 13Terentang 31 31 7 30Grand 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 smalltrees, scrub, or grass remaining. It separates vegetation into six different classes(stratification) through the combination of analyzing satellite images and field plots. TheIndonesian descriptions of these are: High Density Forest (HK3), Medium DensityForest (HK2), Low Density Forest (HK1), Old Scrub (BT) 3, Young Scrub (BM), andCleared/Open Land (LT).

    For the purpose of this study, a provisional threshold for HCS forest of greater than 35tC/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 classifiedinto 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

    HTIDeveloped

    (Ha)

    NonHCS/HCV/pea

    tland(Ha)

    HCS/HCV/peatland(Ha)

    Require FurtherCheck* (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 23 rd to the 27 th of July 2013, it wasconcluded that, of the 431.1 Ha cleared for development within the No Go areas, therewere 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 ClearingStatus RemarksDate

    startedDate

    completed

    1 KL I1050 SBA KL 23.10 01.02.2013 05.02.2013 Potential HCS

    Potential

    MoratoriumBreach

    2 KL F5150 SBA KL 23.60 07.02.2013 12.02.2013 Potential HCS

    PotentialMoratorium

    Breach

    3 KL F5160 SBA KL 23.50 07.02.2013 12.02.2013 Potential HCS

    PotentialMoratorium

    Breach

    4 KL I1060 SBA KL 23.90 01.02.2013 05.02.2013 Potential HCS

    PotentialMoratorium

    Breach

    5 SHC 2010 BAP SH 20.70 20.01.2013 10.02.2013 Potential HCS

    PotentialMoratorium

    Breach

    6 SHC 1210 BAP SH 18.30 20.01.2013

    10.02.2013

    Potential HCS

    PotentialMoratorium

    Breach

    7 SHC 1220 BAP SH 20.60 20.01.2013

    10.02.2013

    Potential HCS

    PotentialMoratorium

    Breach

    8 STE 4200 BMH ST 22.10 21.01.2013 15.02.2013 Potential HCS

    PotentialMoratorium

    Breach

    9 STF 2110 BMH ST 24.90 20.01.2013 15.02.2013 Potential HCS

    PotentialMoratorium

    Breach

    10 STF 2100 BMH ST 22.70 20.01.2013 16.02.2013 Potential HCS

    PotentialMoratorium

    Breach

    11 STE 4100 BMH ST 23.00 04.03.2013 15.03.2013 Potential HCSPotentialMoratoriumBreach

    12 STF 1090 BMH ST 24.20 02.03.2013 13.03.2013 RFC

    PotentialMoratorium

    Breach

    13 STF 1020 BMH ST 23.40 02.03.2013 13.03.2013 RFC

    PotentialMoratorium

    Breach

    14 STF 2220 BMH ST 24.50 11.02.2013 23.02.2013 Potential HCSPotential

    Moratorium

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    No Compartment HTI DistrictRKT

    Land ClearingStatus RemarksDate

    startedDate

    completedBreach

    15 STF 2190 BMH ST 23.10 13.02.2013 24.02.2013 RFC

    PotentialMoratorium

    Breach

    16 STF 2210 BMH ST 24.50 04.03.2013 16.03.2013 Potential HCS

    PotentialMoratorium

    Breach

    17 STF 2200 BMH ST 23.10 02.03.2013 13.03.2013 Potential HCS

    PotentialMoratorium

    Breach

    18 STF 2120 BMH ST 24.50 10.02.2013 22.02.2013 RFC

    PotentialMoratorium

    Breach

    19 STE 4110 BMH ST 26.40 04.03.2013 17.03.2013 Potential HCS

    PotentialMoratorium

    Breach

    20 STD 3240 BMH ST 22.10 12.02.2013 22.02.2013 RFC

    Potential

    MoratoriumBreach

    21 STD 4040 BMH ST 20.80 12.02.2013 21.03.2013 RFC

    PotentialMoratorium

    Breach

    22 STD 4170 BMH ST 22.80 12.02.2013 23.02.2013 RFC

    PotentialMoratorium

    Breach

    23 STD 4240 BMH ST 22.40 12.02.2013 25.02.2013 Potential HCS

    PotentialMoratorium

    Breach

    Total area (Ha) 528.20Total area cleared after 31 Jan2013 (Ha) 431.10

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

    a. SBA

    Kuala Lumpur (KL) DistrictLand development occurred in four compartments in the SBA Kuala LumpurDistrict, 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) DistrictNo 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 TigaDistrict, which were inside the designated No Go areas. The wood from theclearing of the 63.47 Ha HCS area was not sent to APP s mills.

    c. BAP

    Simpang Heran (SH) DistrictLand development occurred in 3 compartments of the BMH Simpang HeranDistrict, 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 andAPP Operational data (field and Head office)

    Following the field verification on the 23 rd to the 27 th of July 2013, it was concluded thatan 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 toverify how much of the 431.1 Ha area should have been classified as HCS and/orpotential HCV (including peatland areas).

    With respect to HCV These 23 compartments representing 431.1 Ha werecrosschecked in relation to potential HCV areas identified during the pre-assessments(HCS/HCV/peatland) in February 2013. There was no overlap. Therefore, none of the23 compartments above were assessed to contain HCV and all further verification couldfocus on identifying potential HCS.

    With respect to HCS, the verification analysis output detailed below revealed that of the431.1 Ha, an initial maximum of 72 Ha could be estimated as HCS. This estimate wouldbe further checked through a stage 2 data reconciliation (Comparative Spatial Analysiswith 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 potentialHCS.)

    Compartment

    Landarea

    StatusDate

    of LC I

    Dateof LC

    II

    Visual SpotAnalysisDec 2012

    HCS Plot Feb2013

    Photo 2013 Remarks

    Areaclearedafter 1

    February2013 (Ha)

    SHC2010

    20.7 RFC 20 Jan2013

    06 Feb2013

    From BT-LT;BT 30% LT

    70%

    Plot groundcheck no 23; 0

    ton carbon/Ha(tC/Ha)

    Photo of groundcheck: all

    directions arealready LandClearing (LC).There is alreadya tertiary canal inthe south

    Compartment withLT-BT condition and

    60% is already LCprior to 1 February2013

    6.7

    SHC1210

    18.3 PotentialHCS

    20 Jan2013

    06 Feb2013

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

    NA Aerial Photocould not beused because itdoes notdescribe thiscompartment

    Around 70% of thiscompartment wasalready clearedprior to 1 February2013 and 30% of itwas cleared after 1February 2013

    5.2

    SHC1220

    20.6 PotentialHCS

    20 Jan2013

    06 Feb2013

    35% LT theremaining65% BM-BT

    NA Aerial Photocould not beused because itdoes notdescribe thiscompartment

    More or less, 80%of this compartmentwas already clearedprior to 1 February2013 and 20% of itwas cleared after 1February 2013

    3.6

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    Compartment

    Landarea

    StatusDate

    of LC I

    Dateof LC

    II

    Visual SpotAnalysisDec 2012

    HCS Plot Feb2013

    Photo 2013 Remarks

    Areaclearedafter 1

    February2013 (Ha)

    KL I1050 23.1 PotentialHCS

    01 Feb2013

    60% LT-40% BM

    There is a plotwith a distanceof approx. 750 Mwith a same

    appearance aswith the carboncontent below35tC/Ha

    Photo indicate avariation of BM-BT with BMvegetation

    domination

    23.1

    KLF5150

    23.6 PotentialHCS

    07 Feb2013

    20% LT-80% BM

    There is a plotwith a distanceof approx. 250 Mwith a sameappearance aswith the carboncontentbelow15tC/Ha

    NA 23.6

    KLF5160

    23.5 PotentialHCS

    07 Feb2013

    40% LT -60% BM

    There are 3 plotswith a sameappearance aswith the carboncontentbelo15tC/Ha

    3 photos in everyplot indicatesvegetation that isdominated byprumpung andgelam seedlings

    23.5

    KL I1060 23.9 PotentialHCS

    01 Feb2013

    10% LT -90% BM

    There is a plotwith a distanceof approximately250 M with asameappearance aswith the carbon

    NA 23.9

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    Compartment

    Landarea

    StatusDate

    of LC I

    Dateof LC

    II

    Visual SpotAnalysisDec 2012

    HCS Plot Feb2013

    Photo 2013 Remarks

    Areaclearedafter 1

    February2013 (Ha)

    content below35tC/Ha

    STE4200

    22.1PotentialHCS

    21 Jan2013

    10 Feb2013

    10% LT -70% BM -20% BT

    NA NA7.1

    STF2110

    24.9PotentialHCS

    20 Jan2013

    11 Feb2013

    90% LT -10% BM

    NA NA4.9

    STF2100

    22.7PotentialHCS

    20 Jan2013

    12 Feb2013

    50% LT -50% BM

    NA NA4.7

    STE4100

    23PotentialHCS

    04 Mar2013

    40% BT -60% BM

    NA NA23

    STF1090

    24.2 RFC 02 Mar2013

    100% LT There is a plot(no 50) with adistance of 500

    M from thecompartment

    Photo groundcheck indicatesvegetation of

    open land in theform of bushes

    24.2

    STF1020

    23.4 RFC 02 Mar2013

    100% LT There is a plot(no 50) with adistance of 200M from thecompartment

    Photo groundcheck indicatesvegetation ofopen land in theform of bushes

    23.4

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    Compartment

    Landarea

    StatusDate

    of LC I

    Dateof LC

    II

    Visual SpotAnalysisDec 2012

    HCS Plot Feb2013

    Photo 2013 Remarks

    Areaclearedafter 1

    February2013 (Ha)

    STF2220

    24.5 PotentialHCS

    11 Feb2013

    20% LT -80% BM

    There is a plot(no 48 the fieldphysical is 35)with a distance

    of 100 M fromthe compartmentwith a carbonvalue of 8 tC/Ha

    Photo groundcheck indicatesprumpung andgelam

    24.5

    STF2190

    23.1 RFC 13 Feb2013

    10% LT -90% BM

    There is a plot(no 48 the fieldphysical is 35)with a distanceof 100 M fromthe compartmentwith a carbonvalue of 8 tC/Ha

    Photo groundcheck indicatesprumpung andgelam

    23.1

    STF2210

    24.5 PotentialHCS

    04 Mar2013

    20% LT -80% BM

    NA Aerial Photoconfirmsdominant LT

    24.5

    STF2200

    23.1PotentialHCS

    02 Mar2013

    60% LT -40% BM

    NA NA23.1

    STF2120

    24.5 RFC10 Feb2013

    70% LT -30% BM

    NA NA24.5

    STE4110

    26.4PotentialHCS

    04 Mar2013

    20% BT -80% BM

    NA NA26.4

    STD3240

    22.1 RFC 12 Feb2013

    70% LT -30% BM

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

    NA 22.1

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    Compartment

    Landarea

    StatusDate

    of LC I

    Dateof LC

    II

    Visual SpotAnalysisDec 2012

    HCS Plot Feb2013

    Photo 2013 Remarks

    Areaclearedafter 1

    February2013 (Ha)

    compartmentwith a carbonvalue of 11tC/Ha

    STD4040

    20.8 RFC 12 Feb2013

    70% LT -30% BM

    There is a plot(no 42) with adistance of 200M from thecompartmentwith a carbonvalue of 11tC/Ha

    Aerial Photoconfirmsdominant landpreparation

    20.8

    STD4170

    22.8 RFC 12 Feb2013

    10% LT -90% BM

    NA Aerial Photoindicates BM andLT

    22.8

    STD4240

    22.4 PotentialHCS

    12 Feb2013

    100% BM NA Aerial Photoindicates BM

    22.4

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    Appendix4.Stage 2 data reconciliation (Comparative Spatial Analysis withadditional reference to Full HCS Assessment Plots)

    Following Stage 1 whereby field verification data and APP Operational data (field and headoffice) were reconciled, a second stage comparative spatial analysis was implemented to bothdouble check the output of the first stage and to strengthen the overall result through theinclusion 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 5images and a supervised classification of strata and HCS measurement plots over the 23compartments.HCS measurement plots from the preliminary HCS assessment were used astraining samples for the exercise.

    The following flow diagram illustrates the steps taken during the spatial analysisPicture 1. Spatial Analysis Method

    Training sampleclassification ofpreliminary HCS plotvalues (Feb 2013):

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

    (IndependentTraining

    Digital SPOT image Calculate statisticaldescriptions

    Classify data intocategories

    Verify HCS fullassessment plots

    Final data classification

    Breach of HCS area

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

    Old Scrub /Forest Density01

    1 54-BMH ST 59.58 Training Sample2 55-BMH ST 36.753 39-BMH ST 71.194 51-BAP SH 51.085 2-SBA KL 44.7 Corresponding

    HCS Plots6 17-SBA KL 73.857 32-SBA KL 45.418 41-SBA KL 112.689 47-BMH ST 82.2210 48-BMH ST 157.2811 52-BMH ST 107.3412 56-BMH ST 61.4113 58-BMH ST 93.0414 64-BMH ST 36.215 65-BMH ST 59.616 72-BMH ST 59.4517 109-BMH ST 127.8218 127-SBA KL 35.2219 66-BAP SH 75.7720 68-BAP SH 158.34

    Young Scrub /Old Scrub

    1 52-BAP SH 26.48 Training Sample2 42-BMH ST 11.233 43-BMH ST 18.184 13-SBA KL 24.08

    CorrespondingHCS Plots

    5 45-SBA KL 31.746 50-BMH ST 28.587 60-SBA KL 26.198 69-BMH ST 24.659 106-BMH ST 12.97

    Young Scrub 1 51-BMH ST 3.39 Training Sample2 7-SBA KL 4.283 48-BMH SK 8.054 14-SBA KL 5.19

    CorrespondingHCS Plots

    5 39-BMH ST 9.896 51-BMH ST 1.267 67-BMH ST 5.758 82-BMH ST 9.46

    Class LT 1 23-BAP SH 0 Training Sample2 25-BAP SH 03 24-BAP SH 04 50-BAP ST 05 16-SBA KL 0

    CorrespondingHCS Plots

    6 18-SBA KL 07 34-SBA KL 0

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    Class No Id Plot Location Ton C/Ha Note8 44-SBA KL 09 107-SBA KL 010 108-SBA KL 011 129-SBA KL 012 130-SBA KL 013 49-BAP SH 014 49-BAP SH 015 54-BAP SH 016 55-BAP SH 017 118-BAP SH 018 134-BAP SH 019 135-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 be88.38Ha (Table 7). Through further portioning between the verification and consolidation dataand spatial data analysis (Table 8) it can be concluded that the final HCS area cleared after the1 st of February 2013 is 69.45 Ha.

    Land cover distribution of each compartment in questionDistrict/

    CompartmentWater 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

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    District/Compartment

    Water LT Class Veg 1 Class Veg 2Class 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 scrubClass Veg 2 young scrub-old scrubClass Veg 3 old scrub-forest density1 (>35 tC/Ha)

    Proportional calculation of each compartment in question

    Compartment DistrictSpatial

    AnalysesArea 1

    RKTArea 2

    Verificationand

    ConsolidationHCS area 3

    SpatialAnalyses

    HCS area 4

    EstimatedProportion

    of HCSarea 5

    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

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    Compartment DistrictSpatial

    AnalysesArea 1

    RKTArea 2

    Verificationand

    ConsolidationHCS area 3

    SpatialAnalyses

    HCS area 4

    EstimatedProportion

    of HCSarea 5

    STF 2110 ST 25.35 24.9 4.9 0.39 0.08

    STF 2100 ST 24.37 22.7 4.7 0.31 0.06STE 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 18.77Total 542.96 528.2 431.1 88.38 69.45

    Remarks:1: Compartment area based on the spatial data2: Compartment area based on the RKT document3: Area prepared after 1 February 2013 based on the verification and consolidation

    4: Area prepared after 1 February 2013 based on the spatial data5: 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 utilizingdifferent carbon calculation algorithms in the conversion process. The resulting outputs wereconsiderably different whereby a compartment designated as HCS under one algorithmicconversion could swing to non-HCS under a second algorithm. For the purposes of thisverification 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 appropriatealgorithm for use in the HCS studies.

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

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

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

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

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    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 23 rd to the 27 th of July 2013.The FieldVerification 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 FVTaccompanied by staff from each District conducted the document reviews.

    Following the natural forest clearance moratorium commitment made by the APP on the31 st of January 2013, the FOD (Head of the Region) of Palembang sent an InternalOffice Memo No. Reg: FOD-2013-I-005 and the Moratorium Protocol to forest operatorsin all Districts and Supporting Departments through email. The FOD also requestedforest operators/contractors in all Districts to stop all operational activity of new landpreparation.

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

    a. SBA

    1. Kuala Lumpur District

    A verification process was conducted on the following documents related to theland 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 toSK.093/SBAWI/XII/2012 dated on the 10 th of December 2012. RKT 2013 is validfrom the 1 st of January 2013 until the 31 st of December 2013, a total land area of2,606 Ha.

    Land allocation in SBA according to the approved 2013 RKT

    Company District Land Area Remarks Lay out (Ha)(Ha) TP TU TK KL

    SBAKualaLumpur

    30,754Plan 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 is8,353.23 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 8 th of February 2013, despite the distribution of the RKT 2013Recommendation Map and Moratorium Protocol being sent to the Kuala

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    Lumpur District operator, land preparation activity continued in thecompartments inside the No Go areas, namely; KL F5150 and KL F5160 underthe 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 1 st of February 2013 isavailable in the District in the form of a Daily Activity Report. In this report, therealization of the land preparation, the name of the contractor for the landpreparation, unit code, daily planting report, and planting contractor are listed.

    Report of land preparation in SBA and its breachstatus

    No CompartmentLandArea(Ha)

    Mechanical LC Recommendationmap

    RemarksDate Started Date Ended

    1 KL I1050 23.1 01.02.2013 05.02.2013 HCS Potential

    PotentialMoratorium

    Breach

    2 KL I5150 23.6 07.02.2013 12.02.2013

    HCS Potential PotentialMoratorium

    Breach

    3 KL I5160 23.5 07.02.2013 12.02.2013

    HCS Potential PotentialMoratorium

    Breach

    4 KL I1060 23.9 01.02.2013 05.02.2013 HCS Potential

    PotentialMoratorium

    Breach

    Date of planting of each compartment in question in SBA

    No

    CompartmentLandArea(Ha)

    PlantingRemarks

    Date Started Date Ended

    1 KL I1050 23.1 01.06.2013 06.06.2013 n/a2 KL I5150 23.6 01.06.2013 08.06.2013 n/a3 KL I5160 23.5 01.06.2013 09.06.2013 n/a4 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 preparationactivity in SBA. In accordance with the result of the preliminary assessment only

    non-commercial small diameter trees dominated by pioneer species wereproduced as a result of the land preparation (see Appendix 1).

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

    b. BMH

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    A verification procedure was conducted on the following documents related to theland 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 throughSK.101/BMH/XII/2012. RKT 2013 is valid from the 1 st of January 2013 until the31 st of December 2013 in a land area of 4,517 Ha.

    The BMH RKT 2013 Document details the work plan for all the Districts asfollows:

    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 DistrictLandArea Remarks Lay Out (Ha)

    (Ha) TP TU TK KL

    BMH SungaiKetupak

    43.536 Plan 26,970 6,715 3,295 4,416Realization 9,363 0 0 0

    Simpang 28.491 Plan 28,491 497 1,310 1,179Tiga Realization 9,244 0 0 0

    1. Sungai Ketupak District

    v Land preparation documentBased on the land preparation document for the Sungai Ketupak Districk onlyone compartment, SKJ 3030 was cleared and this was completed prior to the 1 st of February 2013.

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

    No Compartment Area Mechanical LC Remarks

    (Ha) DateStarted Date Ended

    1. SKJ 3030 22.9 14.01.2013 27.01.2013 Potential

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    MoratoriumBreach

    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 8 th of February 2013, despite the distribution of the RKT 2013Recommendation Map and Moratorium Protocol being sent to the SimpangTiga District operator, land preparation activity continued in 16 compartmentsinside the No Go areas, under the work contract (Work Order/SPK) with theland preparation contractor.

    v Document on the land preparationThe document on the land preparation activity is available for Simpang TigaDistrict.

    Report of land preparation in Simpang Tiga District (BMH) and its breach status

    NoCompartment

    Area Mechanical LC IRemarks

    (Ha) Date started Date ended Status

    1 STE 4200 22.1 21.01.2013 15.02.2013 Potential HCSPotentialMoratorium Breach

    2 STF 2110 24.9 20.01.2013 15.02.2013Potential HCS Potential

    Moratorium Breach

    3 STF 2100 22.7 20.01.2013 16.02.2013 Potential HCS PotentialMoratorium Breach

    4 STE 4100 23.0 04.03.2013 15.03.2013Potential HCS Potential

    Moratorium Breach

    5 STF 1090 24.2 02.03.2013 13.03.2013Potential HCS Potential

    Moratorium Breach

    6 STF 1020 23.4 02.03.2013 13.03.2013Potential HCS Potential

    Moratorium Breach

    7 STF 2220 24.5 11.02.2013 23.02.2013Potential HCS Potential

    Moratorium Breach

    8 STF 2190 23.1 13.02.2013 24.02.2013Potential HCS Potential

    Moratorium Breach

    9 STF 2210 24.5 04.03.2013 16.03.2013Potential HCS Potential

    Moratorium Breach

    10 STF 2200 23.1 02.03.2013 13.03.2013Potential HCS Potential

    Moratorium Breach

    11 STF 2120 24.5 10.02.2013 22.02.2013Potential HCS Potential

    Moratorium Breach

    12 STE 4110 26.4 04.03.2013 17.03.2013Potential HCS Potential

    Moratorium Breach

    13 STD 3240 22.1 12.02.2013 22.02.2013Potential HCS Potential

    Moratorium Breach

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    NoCompartment

    Area Mechanical LC IRemarks

    (Ha) Date started Date ended Status

    14 STD 4040 20.8 12.02.2013 21.03.2013Potential HCS Potential

    Moratorium Breach

    15 STD 4170 22.8 12.02.2013 23.02.2013

    Potential HCS Potential

    Moratorium Breach

    16 STD 4240 22.4 12.02.2013 25.02.2013Potential HCS Potential

    Moratorium Breach

    v There is no utilization of the natural forest wood from the land preparationactivity in the Simpang Tiga District. According to the result of the preliminaryassessment, 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 theland 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 stipulatedin the SK No. 101/BAP-XII/2012 (dated 10 th of December 2012). The RKT 2013is valid from the 1 st of January 2013 until the 31 st of December 2013 for a totalland area of 5,651 Ha.

    Land allocation of BAP according to the approved 2013 RKT

    HTI DistrictLand Area

    RemarksLay out (Ha)

    (Ha) TP HTI District (Ha)

    BAP SimpangHeran

    35,289 Planned 19,671BAP

    Simpang

    Heran35,289

    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:

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

    v Land preparation DocumentThe document for land preparation and planting after the 1 st of February 2013 isavailable 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)

    Datestarted

    Dateended

    Datestarted Date ended

    Status

    1

    SHC

    2010 20.7 20.01.2013 31.01.2013 06.02.2013 10.02.2013 Potential HCS

    PotentialMoratorium

    Breach

    2SHC1210 18.3 20.01.2013 31.01.2013 06.02.2013 10.02.2013

    Potential HCS PotentialMoratorium

    Breach

    3SHC1220 20.6 20.01.2013 31.01.2013 06.02.2013 10.02.2013

    Potential HCS PotentialMoratorium

    Breach

    v On the 8 th of February 2013, despite the distribution of the RKT 2013Recommendation Map and Moratorium Protocol being sent to the SimpangHeran District, land preparation activity continued in three compartments inside

    the No Go areas, under the agreement (Work Order/SPK) with the landpreparation 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 preliminaryassessment, 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

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

    The map below indicates the location of the compartments were the potential forestmoratorium 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 1 st of February 2013 occurredin four compartments inside the No Go areas. (KL I1050, KL I1060, KL I5150and KL I5160). The land preparation occurred from the 1 st of February 2013 untilthe 12 th of February 2013

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

    Lokasipengambilanphoto

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    Planted compartments in question in SBA

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    b. BMH

    1. Sungai Ketupak District

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

    The map below indicates the location of the compartments were the potential forestmoratorium 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 1 st of February 2013 did not

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

    February 2013 (from the 14 th of January 2013 to the 27 th 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 ofphotographs

    (shown below)

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    Planted compartments in question in Sungai Ketupak District (BMH)

    2. Simpang Tiga

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

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

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    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 occurredin the sixteen compartments inside the No Go area, (STE 4200, STF 2110, STF2100, STE 4100, STF 1090, STF 1020, STF 2220, STF 2190, STF 2210, STF2200, STF 2120, STE 4110, STD 3240, STD 4040, STD 4170, and STD 4240)

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

    v The pictures below show the land preparation realization in compartmentSTD4160.

    Location ofphotographs(shown below)

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    Planted compartments in question in Simpang Tiga District (BMH)

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    c. BAP

    1. Simpang Heran District

    The field verification was conducted on the 26 th of July 2013.

    The map below indicates the location of the compartments where the potential forestmoratorium 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 1 st of February 2013

    occurred in the three compartments inside the No Go (SHC 2010, SHC1210 and SHC 1220). The land was cleared on the 20 th to the 31 st ofJanuary 2013, and then following a brief pause in clearance activities wereresumed on the 6 thtothe 10 th of February 2013.

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

    Location ofphotographs(shown below)

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    Planted compartments in question in BAP