VERIFICATION REPORT RELATED TO BREACHES OF APPS 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

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 APPs 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 APPs 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 (non1

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 APPs 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 APPs 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: 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 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.

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 APPs 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 wasnt 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 APPs mills.

6. ACTIONS BEING TAKEN TO STRENGTHEN APPS 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 APPs 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 APPs 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.

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 APPs 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:
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 Name of Company Total (Ha) Extent

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 Basemap & Physical Desk Study Land Cover Ecology Desk Study Water catchment area (DAS) Land System Basemap (river, road) Aerial Survey (TFT-SMF / 4-5 February 2013) Ground Survey (TFT-SMF / 25 29 February 2013) Ecosystem type Habitat of Sumatran Elephant Habitat of Sumatran Tiger Important Bird Area Peat land Data Source SPOT - 2012 (SMF) Landsat 2010 (Kemenhut) RLPS Kemenhut (2010) RePPProT (1990) PDTK Kemenhut RKT 2013 SBA, BAP, BMH District Jelutung, Bagan Rame, Simpang Heran (HTI, Peat, SS, BZ)

Field Survey

Sumatra Eco region Map - WWF Birdlife Wetlands (2003) RePPPRot (1990) SMF Operational map SMF monitoring table and map 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)

Desk Study & Field Check Survey of Biodiversity

Elephant Encounter Location Survey of Ecology (TFT-SMF) in o 34 Fauna identification transect lane o 9 Plots of Vegetation identification 23 Feb 7 March

Stages

Data

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

Social Desk Study

Interview & FGD

OKI statistical data (OKI Dalam Angka) Land conflict map Interview & FGD (TFT-SMF) 23 Feb 7 March 2013

BPS OKI BAP, SBA, BMH 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 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 RKT Block

BAP, SBA, BMH

Balitbanghut

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 BMH SBA BAP Total 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. Extent of RKT 2013 (Ha) 33,896 8,147 17,717 59,760 Extent of the Aerial Survey % of the Observation observation (Ha) 16,034 47.3 5,463 66.7 12,100 68.3 33,597 56.2

Number of HCS measurement plot on each HTI Concession Extent of Scrub on RKT 2013 (ha) 4,034 Intensity of the sampling (%) 0.025 Plot Plan 20 Plot Realization Plot 18

HTI SBA

Remarks 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
10

HTI BMH

Extent of Scrub on RKT 2013 (ha) 27,754

Intensity of the sampling (%) 0.010

Plot Plan 56

Plot Realization Plot 56

Remarks 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 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 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

BAP

12,515

0.025

63

60

Total

44,303

139

134

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 Total Tree Min DBH (cm) Species District District Total KL SH ST KL SH ST Gelam 64 45 40 149 5 5 5 Jambu-jambu 7 7 6 Jelutung 2 2 6 Mate Ketam 1 1 9 Pulai 3 40 35 78 20 9 5 Rengas 4 4 5 Terentang 31 31 7 Grand Total 71 95 119 285

Max DBH (cm) District KL SH ST 29 13 13 30 6 9 21 19 30 13 30

Remarks: - Min DBH - Max DBH - KL - SH - ST

: Smallest tree diameter found in the sample plot : Largest tree diameter found in the sample plot : Kuala Lumpur : Simpang Heran : 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 Non HCS/HCV/pea Developed HCS/HCV/pea Require Further HTI tland (Ha) tland Check* (Ha) (Ha) (Ha) BAP BMH SBA Grand Total 5,907 7,931 2,635 16,473 3,561 9,763 1,283 14,607 5,193 13,182 1,427 19,802 3,055 3,020 2,803 8,878

Total (Ha) 17,717 33,896 8,147 59,760

Overlaid maps of HCV/Peat and HCS for the three HTI are below.

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20

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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
Land Clearing No Compartment HTI District RKT Date started Date completed Status Remarks Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium

KL I1050

SBA

KL

23.10

01.02.2013

05.02.2013

Potential HCS

KL F5150

SBA

KL

23.60

07.02.2013

12.02.2013

Potential HCS

KL F5160

SBA

KL

23.50

07.02.2013

12.02.2013

Potential HCS

KL I1060

SBA

KL

23.90

01.02.2013

05.02.2013

Potential HCS

SHC 2010

BAP

SH

20.70

20.01.2013

10.02.2013 10.02.2013

Potential HCS

SHC 1210

BAP

SH

18.30

20.01.2013 10.02.2013

Potential HCS

SHC 1220

BAP

SH

20.60

20.01.2013

Potential HCS

STE 4200

BMH

ST

22.10

21.01.2013

15.02.2013

Potential HCS

STF 2110

BMH

ST

24.90

20.01.2013

15.02.2013

Potential HCS

10

STF 2100

BMH

ST

22.70

20.01.2013

16.02.2013

Potential HCS

11

STE 4100

BMH

ST

23.00

04.03.2013

15.03.2013

Potential HCS

12

STF 1090

BMH

ST

24.20

02.03.2013

13.03.2013

RFC

13 14

STF 1020 STF 2220

BMH BMH

ST ST

23.40 24.50

02.03.2013 11.02.2013

13.03.2013 23.02.2013

RFC Potential HCS

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Land Clearing No Compartment HTI District RKT Date started Date completed Status Remarks Breach Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach

15

STF 2190

BMH

ST

23.10

13.02.2013

24.02.2013

RFC

16

STF 2210

BMH

ST

24.50

04.03.2013

16.03.2013

Potential HCS

17

STF 2200

BMH

ST

23.10

02.03.2013

13.03.2013

Potential HCS

18

STF 2120

BMH

ST

24.50

10.02.2013

22.02.2013

RFC

19

STE 4110

BMH

ST

26.40

04.03.2013

17.03.2013

Potential HCS

20

STD 3240

BMH

ST

22.10

12.02.2013

22.02.2013

RFC

21

STD 4040

BMH

ST

20.80

12.02.2013

21.03.2013

RFC

22

STD 4170

BMH

ST

22.80

12.02.2013

23.02.2013

RFC

23

STD 4240

BMH

ST

22.40 528.20 431.10

12.02.2013

25.02.2013

Potential HCS

Total area (Ha) Total area cleared after 31 Jan 2013 (Ha)

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 APPs 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 APPs 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 APPs 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.) Area Date Visual Spot cleared Compart Land Date HCS Plot Feb Status of LC Analysis Photo 2013 Remarks after 1 ment area of LC I 2013 II Dec 2012 February 2013 (Ha) SHC 20.7 RFC 20 Jan 06 Feb From BT-LT; Plot ground Photo of ground Compartment with 6.7 2010 2013 2013 BT 30% LT check no 23; 0 check: all LT-BT condition and 70% ton carbon/Ha directions are 60% is already LC (tC/Ha) already Land prior to 1 February Clearing (LC). 2013 There is already a tertiary canal in the south SHC 18.3 Potential 20 Jan 06 Feb From BM-BT; NA Aerial Photo Around 70% of this 5.2 1210 HCS 2013 2013 with 25% LT could not be compartment was - 75% BM used because it already cleared and BT does not prior to 1 February describe this 2013 and 30% of it compartment was cleared after 1 February 2013 SHC 20.6 Potential 20 Jan 06 Feb 35% LT the NA Aerial Photo More or less, 80% 3.6 1220 HCS 2013 2013 remaining could not be of this compartment 65% BM-BT used because it was already cleared does not prior to 1 February describe this 2013 and 20% of it compartment was cleared after 1 February 2013

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Compart ment KL I1050

Land area 23.1

Status

Date of LC I 01 Feb 2013

Date of LC II

Visual Spot Analysis Dec 2012 60% LT40% BM

HCS Plot Feb 2013 There is a plot with a distance of approx. 750 M with a same appearance as with the carbon content below 35tC/Ha There is a plot with a distance of approx. 250 M with a same appearance as with the carbon content below15tC/Ha There are 3 plots with a same appearance as with the carbon content belo15tC/Ha There is a plot with a distance of approximately 250 M with a same appearance as with the carbon

Photo 2013

Remarks

Potential HCS

Photo indicate a variation of BMBT with BM vegetation domination

Area cleared after 1 February 2013 (Ha) 23.1

KL F5150

23.6

Potential HCS

07 Feb 2013

20% LT80% BM

NA

23.6

KL F5160

23.5

Potential HCS

07 Feb 2013

40% LT 60% BM

KL I1060

23.9

Potential HCS

01 Feb 2013

10% LT 90% BM

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

23.5

23.9

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Compart ment

Land area

Status

Date of LC I

Date of LC II

Visual Spot Analysis Dec 2012

HCS Plot Feb 2013 content below 35tC/Ha

Photo 2013

Remarks

Area cleared after 1 February 2013 (Ha)

STE 4200 STF 2110 STF 2100 STE 4100 STF 1090

22.1 24.9 22.7 23 24.2

Potential HCS Potential HCS Potential HCS Potential HCS RFC

21 Jan 2013 20 Jan 2013 20 Jan 2013 04 Mar 2013 02 Mar 2013

10 Feb 2013 11 Feb 2013 12 Feb 2013

10% LT 70% BM 20% BT 90% LT 10% BM 50% LT 50% BM 40% BT 60% BM 100% LT

7.1 NA NA NA NA There is a plot (no 50) with a distance of 500 M from the compartment There is a plot (no 50) with a distance of 200 M from the compartment NA NA NA NA Photo ground check indicates vegetation of open land in the form of bushes Photo ground check indicates vegetation of open land in the form of bushes 4.9 4.7 23 24.2

STF 1020

23.4

RFC

02 Mar 2013

100% LT

23.4

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Compart ment STF 2220

Land area 24.5

Status

Date of LC I 11 Feb 2013

Date of LC II

Visual Spot Analysis Dec 2012 20% LT 80% BM

HCS Plot Feb 2013 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 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 NA

Photo 2013

Remarks

Potential HCS

Photo ground check indicates prumpung and gelam

Area cleared after 1 February 2013 (Ha) 24.5

STF 2190

23.1

RFC

13 Feb 2013

10% LT 90% BM

Photo ground check indicates prumpung and gelam

23.1

STF 2210 STF 2200 STF 2120 STE 4110 STD 3240

24.5

Potential HCS Potential HCS RFC Potential HCS RFC

04 Mar 2013 02 Mar 2013 10 Feb 2013 04 Mar 2013 12 Feb 2013

20% LT 80% BM 60% LT 40% BM 70% LT 30% BM 20% BT 80% BM 70% LT 30% BM

Aerial Photo confirms dominant LT NA NA NA NA

24.5

23.1 24.5 26.4 22.1

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

23.1 24.5 26.4 22.1

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Compart ment

Land area

Status

Date of LC I

Date of LC II

Visual Spot Analysis Dec 2012

HCS Plot Feb 2013 compartment with a carbon value of 11tC/Ha

Photo 2013

Remarks

Area cleared after 1 February 2013 (Ha)

STD 4040

20.8

RFC

12 Feb 2013

70% LT 30% BM

STD 4170 STD 4240

22.8

RFC

12 Feb 2013 12 Feb 2013

10% LT 90% BM 100% BM

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

Aerial Photo confirms dominant land preparation

20.8

22.4

Potential HCS

NA

Aerial Photo indicates BM and LT Aerial Photo indicates BM

22.8

22.4

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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 Digital SPOT image Training sample classification of preliminary HCS plot values (Feb 2013): 1. 2. 3. 4. 5. > 35 (4 plots) 10 35 (3) 0 10 (3) < 0 (4) Water (Independent Training Calculate statistical descriptions

Classify data into categories

Verify HCS full assessment plots

Final data classification

Breach of HCS area

31

Training sample summary of carbon values Class No Id Plot Location 54-BMH ST Old Scrub / 1 Forest Density 2 55-BMH ST 01 3 39-BMH ST 4 51-BAP SH 5 2-SBA KL 6 17-SBA KL 7 32-SBA KL 8 41-SBA KL 9 47-BMH ST 10 48-BMH ST 11 52-BMH ST 12 56-BMH ST 13 58-BMH ST 14 64-BMH ST 15 65-BMH ST 16 72-BMH ST 17 109-BMH ST 18 127-SBA KL 19 66-BAP SH 20 68-BAP SH 52-BAP SH Young Scrub / 1 Old Scrub 2 42-BMH ST 3 43-BMH ST 4 13-SBA KL 5 45-SBA KL 6 50-BMH ST 7 60-SBA KL 8 69-BMH ST 9 106-BMH ST Young Scrub 1 51-BMH ST 2 7-SBA KL 3 48-BMH SK 4 14-SBA KL 5 39-BMH ST 6 51-BMH ST 7 67-BMH ST 8 82-BMH ST 1 23-BAP SH Class LT 2 25-BAP SH 3 24-BAP SH 4 50-BAP ST 5 16-SBA KL 6 18-SBA KL 7 34-SBA KL

Ton C/Ha 59.58 36.75 71.19 51.08 44.7 73.85 45.41 112.68 82.22 157.28 107.34 61.41 93.04 36.2 59.6 59.45 127.82 35.22 75.77 158.34 26.48 11.23 18.18 24.08 31.74 28.58 26.19 24.65 12.97 3.39 4.28 8.05 5.19 9.89 1.26 5.75 9.46 0 0 0 0 0 0 0

Note Training Sample

Corresponding HCS Plots

Training Sample

Corresponding HCS Plots

Training Sample

Corresponding HCS Plots

Training Sample

Corresponding HCS Plots

32

Class

No 8 9 10 11 12 13 14 15 16 17 18 19

Id Plot 44-SBA 107-SBA 108-SBA 129-SBA 130-SBA 49-BAP

Water

Location Ton C/Ha KL 0 KL 0 KL 0 KL 0 KL 0 SH 0 SH 0 49-BAP SH 0 54-BAP SH 0 55-BAP SH 0 118-BAP SH 0 134-BAP SH 0 135-BAP Use 5 independent training samples (at the canals)

Note

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/ Water LT Class Veg 1 Class Veg 2 Compartment Kuala Lumpur KLF5150 KLF5160 KLI1050 KLI1060 Simpang Heran SHC1210 SHC1220 SHC2010 Simpang Tiga STD3240 STD4040 STD4170 4.57 1.52 2.69 0.19 0.17 1.16 0.43 0.21 0.51 16.47 0.87 0.03 0.05 16.15 5.37 4.61 4.45 1.72 14.19 1.20 0.19 12.79 49.24 2.45 0.83 0.62 58.95 13.35 14.05 14.98 16.56 19.11 7.31 7.44 4.35 183.56 15.30 16.18 4.71 17.04 4.15 4.25 3.56 5.07 20.31 10.04 7.47 2.81 69.22 4.47 6.85 7.03

Class Veg 3 (>35 t/c/Ha) 3.48 0.27 0.05 1.05 2.12 12.17 2.23 8.92 1.01 72.72 2.16 0.74 13.42

Total 100.20 24.66 25.66 24.24 25.64 66.93 21.22 24.23 21.48 391.22 25.25 24.63 25.83

33

District/ Compartment STD4240 STE4100 STE4110 STE4200 STF1090 STF2100 STF2110 STF2120 STF2190 STF2200 STF2210 STF2220 STF4020

Water

LT 0.04 1.05 3.31

Class Veg 1 2.76 5.38 6.49 7.86 11.97 13.44 19.57 16.77 13.56 12.86 8.06 15.92 12.73 261.61

Class Veg 2 1.90 7.46 4.15 3.07 0.07 5.84 2.14 4.47 8.00 6.03 6.11 1.24 0.38 106.57

Class Veg 3 (>35 t/c/Ha) 18.77 15.22 7.45 12.74

Total 23.48 29.10 21.39 26.90 19.45

0.03 4.86 0.97 1.05 0.31 0.08 2.50 0.05 0.11 5.55 22.20

3.20 2.55 3.90 2.03 1.21 4.42 7.32 7.24 2.33 6.75 79.58

0.31 0.39 0.35 0.37 0.25 0.34 0.17 0.04 88.38

24.46 25.19 23.11 26.43 28.96 21.80 19.78 25.46 558.34

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 Spatial Analyses 1 Area 20.58 20.82 24.57 23.05 25.68 24.63 23.86 26.29 RKT Area2 20.7 18.3 20.6 23.1 23.6 23.5 23.9 22.1 Verification and Consolidation 3 HCS area 6.7 5.2 3.6 23.1 23.6 23.5 23.9 7.1 Spatial Analyses 4 HCS area 1.01 2.12 8.92 1.05 0.27 0.05 2.12 12.74 Estimated Proportion of HCS 5 area 0.33 0.60 1.56 1.05 0.27 0.05 2.12 4.09

Compartment

District

SHC 2010 SHC 1210 SHC 1220 KL I1050 KL F5150 KL F5160 KL I1060 STE 4200

SH SH SH KL KL KL KL ST

34

Compartment

District

Spatial Analyses Area1 25.35 24.37 28.72 18.71 15.73 20.35 25.43 22.30 27.99 23.08 20.72 25.95 23.83 26.26 24.69 542.96

RKT Area2 24.9 22.7 23.0 24.2 23.4 24.5 23.1 24.5 23.1 24.5 26.4 22.1 20.8 22.8 22.4 528.2

Verification and Consolidation HCS area3 4.9 4.7 23.0 24.2 23.4 24.5 23.1 24.5 23.1 24.5 26.4 22.1 20.8 22.8 22.4 431.1

Spatial Analyses HCS area 4 0.39 0.31 15.22 0 0 0.17 0.37 0.34 0.25 0.35 7.45 2.16 0.74 13.42 18.77 88.38

Estimated Proportion of HCS area5 0.08 0.06 15.22 0 0 0.17 0.37 0.34 0.25 0.35 7.45 2.16 0.74 13.42 18.77 69.45

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 STD 4240

ST ST ST ST ST ST ST ST ST ST ST ST ST ST ST Total

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

35

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

36

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

37

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

38

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.

39

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 preassessments(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 Kuala Lumpur Land Area (Ha) SBA 30,754 Plan Realization Remarks TP 13,505 5,036 Lay out (Ha) TU 6,848 0 TK 4,397 0 KL 4,278 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
40

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 Date Started Date Ended Recommendation map Remarks

1 KL I1050

23.1

01.02.2013

05.02.2013

HCS Potential HCS Potential

2 KL I5150

23.6

07.02.2013

12.02.2013 HCS Potential

3 KL I5160

23.5

07.02.2013

12.02.2013

4 KL I1060

23.9

01.02.2013

05.02.2013

HCS Potential

Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach

Date of planting of each compartment in question in SBA

N o Compartment Land Area (Ha) Planting Date Started Date Ended

Remarks

1 2 3 4

KL I1050 KL I5150 KL I5160 KL I1060

23.1 23.6 23.5 23.9

01.06.2013 01.06.2013 01.06.2013 18.06.2013

06.06.2013 08.06.2013 09.06.2013 22.06.2013

n/a n/a n/a 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

41

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 Land Area HTI District Remarks (Ha) BMH Sungai Ketupak Simpang Tiga 43.536 28.491 Plan Realization Plan Realization TP 26,970 9,363 28,491 9,244

Lay Out (Ha) TU 6,715 0 497 0 TK 3,295 0 1,310 0 KL 4,416 0 1,179 0

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
Area No 1. Compartment (Ha) SKJ 3030 22.9 Mechanical LC Date Started 14.01.2013 Date Ended 27.01.2013 Potential Remarks

42

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 Compartm ent 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 Area (Ha) 22.1 24.9 22.7 23.0 24.2 23.4 24.5 23.1 24.5 23.1 24.5 26.4 22.1 Mechanical LC I Date started 21.01.2013 20.01.2013 20.01.2013 04.03.2013 02.03.2013 02.03.2013 11.02.2013 13.02.2013 04.03.2013 02.03.2013 10.02.2013 04.03.2013 12.02.2013 Date ended 15.02.2013 15.02.2013 Potential HCS 3 4 5 6 7 8 9 10 11 12 13 16.02.2013 Potential HCS 15.03.2013 Potential HCS 13.03.2013 Potential HCS 13.03.2013 Potential HCS 23.02.2013 Potential HCS 24.02.2013 Potential HCS 16.03.2013 Potential HCS 13.03.2013 Potential HCS 22.02.2013 Potential HCS 17.03.2013 Potential HCS 22.02.2013 Status Potential HCS Potential HCS Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach Remarks

1 2

43

No

Compartm ent STD 4040 STD 4170 STD 4240

Area (Ha) 20.8 22.8 22.4

Mechanical LC I Date started 12.02.2013 12.02.2013 12.02.2013 Date ended 21.03.2013 Potential HCS 23.02.2013 Potential HCS 25.02.2013 Status Potential HCS

Remarks Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach

14 15 16

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 (Ha) BAP Simpang Heran 35,289 Planned Realization Remarks TP 19,671 14,276 Lay out (Ha) HTI BAP District Simpang Heran (Ha) 35,289

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:
44

- 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
Area No Comp (Ha) SHC 2010 SHC 1210 SHC 1220 Mechanical LC I Date started Date ended Mechanical LC II Date started Remarks Date ended Status Potential Moratorium Breach Potential Moratorium Breach Potential Moratorium Breach

20.7

20.01.2013

31.01.2013

06.02.2013

10.02.2013

Potential HCS Potential HCS

18.3

20.01.2013

31.01.2013

06.02.2013

10.02.2013 Potential HCS

20.6

20.01.2013

31.01.2013

06.02.2013

10.02.2013

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

45

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)

Lokasi pengambilan photo

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:

46

Planted compartments in question in SBA

47

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)

Location of photographs (shown below)

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.

48

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:

49

Location map of compartments in question in Simpang Tiga District (BMH)

Location of photographs (shown below)

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.

50

Planted compartments in question in Simpang Tiga District (BMH)

51

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)

Location of photographs (shown below)

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.
52

Planted compartments in question in BAP

53