cw-11 controlled wood forest management master report …

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Certified by: RA-Cert Headquarters 65 Millet St. Suite 201 Richmond, VT 05477 USA Tel: 802-923-3737 Fax: 802-434-3116 www.rainforest-alliance.org Contact person: Gabriel Bolton [email protected] Audit Managed by: Asia-Pacific Regional Office Jl. Tantular Barat No. 88 Denpasar, Bali, Indonesia, 80114 Tel: +62 361 472 3499 Fax: +62 361 472 3498 Contact person: Indu Bikal Sapkota Medita Hermawan Email: [email protected] [email protected] CW-11 May 2017 Forest Management Controlled Wood Assessment Report for: PT. Riau Abadi Lestari in Riau, Indonesia Auditors: Gabriel Bolton Titiek Setyawati Yudi Iskandarsyah Pratama Kurniaji Audit Dates: 15 - 18 August 2017 Report Finalized: 11 January 2018 Forest Management Enterprise information: Primary contact: M. Syarif Hidayat Address: Jl. Tengku Umar No 51 A Pekanbaru Phone / Fax: (0761) 9000200 (ext. 2721) Webpage: Contract signer: Didi Harsa

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Certified by:

RA-Cert Headquarters 65 Millet St. Suite 201

Richmond, VT 05477 USA Tel: 802-923-3737 Fax: 802-434-3116

www.rainforest-alliance.org Contact person: Gabriel Bolton

[email protected]

Audit Managed by:

Asia-Pacific Regional Office

Jl. Tantular Barat No. 88 Denpasar, Bali, Indonesia, 80114

Tel: +62 361 472 3499 Fax: +62 361 472 3498

Contact person: Indu Bikal Sapkota Medita Hermawan

Email: [email protected] [email protected]

CW-11 May 2017

Forest Management

Controlled Wood

Assessment Report for:

PT. Riau Abadi Lestari in

Riau, Indonesia

Auditors: Gabriel Bolton Titiek Setyawati Yudi Iskandarsyah Pratama Kurniaji

Audit Dates: 15 - 18 August 2017 Report Finalized: 11 January 2018

Forest Management Enterprise information: Primary contact: M. Syarif Hidayat Address: Jl. Tengku Umar No 51 A

Pekanbaru Phone / Fax: (0761) 9000200 (ext. 2721) Webpage: Contract signer: Didi Harsa

CW-11 CW-FM Master Report 1 May 2017 Page 2 of 24

TABLE OF CONTENTS

Glossary of terms ............................................................................................................................................ 3

1. INTRODUCTION .................................................................................................................................... 4

2. AUDIT CONCLUSIONS ........................................................................................................................ 5

2.1. AUDITOR RECOMMENDATION .......................................................................................................... 5 2.2. NEW NONCONFORMITY REPORTS ISSUED AS A RESULT OF THIS AUDIT ....................................... 7 2.3. OBSERVATIONS ............................................................................................................................. 16 2.4. ACTIONS TAKEN BY COMPANY AFTER THE AUDIT AND PRIOR TO REPORT FINALIZATION .......... 16

3. AUDIT PROCESS ................................................................................................................................ 18

3.1. AUDIT SCHEDULE/ITINERARY ........................................................................................................ 18 3.2. AUDIT TEAM AND QUALIFICATIONS ................................................................................................ 18 3.3. AUDIT DETAIL ................................................................................................................................. 20

4. STAKEHOLDER CONSULTATION .................................................................................................. 21

4.1. STAKEHOLDER CONSULTATION PROCESS .................................................................................... 21 4.2. STAKEHOLDER COMMENTS RECEIVED .......................................................................................... 21

CW-11 CW-FM Master Report 1 May 2017 Page 3 of 24

Glossary of terms

Bahasa term English term

AMDAL (Analisa Mengenai Dampak Lingkungan) Environmental impact assessment

BKSDA (Balai Konservasi Sumber Daya Alam) Nature Conservation Agency; Indonesia

BPJS Kesehatan Mandatory social security program for health

BPJS Ketenagakerjaan Mandatory social security program for manpower

Desa Village

DPSL (Daerah Perlindungan Satwa Liar) Wildlife protection area

HTI (Hutan Tanaman Industri) Plantation

ISFMP Integrated Sustainable Forest Management Plan

IUPHHK Forest Concession License

LHC (Laporan Hasil Cruising) Cruising report

LHP (Laporan Hasil Produksi) Production report

NPWP (Nomor Pokok Wajib Pajak) Valid Tax Identity Number

PBB Land and building tax

PHPL certification Mandatory national scheme of sustainable forest management

PHTPK (Pengelolaah Hutan Tanaman Pola Kemitraan)

Plantation Forest Management with Partnership Pattern

PKB (Perjanjian Kerja Bersama) Joint Work Agreement (between worker union and the FME)

Pos Faktur Log administration Post

PSDH Forest product fee

RKL (Rencana Pengelolaan Lingkungan) Environment Management Plan

RKT (Rencana Kerja Tahunan) Annual working plan

RKU (Rencana Kerja Usaha) 10 years working plan

RPL (Rencana Pemantauan Lingkungan) Environment Monitoring Plan

SIPUHH (Sistem Informasi Penataan Usaha Hasil Hutan) Forest Product Information System

SIUP (Surat Ijin Usaha Perdagangan) Trading Business License

SKSHHK (Surat Keterangan Sah Hasil Hutan Kayu) Mandatory Log Transport Document

SP (Serikat Pekerja) Worker Union

SVLK Mandatory certification on Timber Legality Assurance System

Tanaman Kehidupan Livelihood Plantation (Mandatory for every concessions license 20% at minimum of total area)

TDP Company Registration Certificate

TPK (Tempat Penimbunan Kayu) Log yard

TPK Antara Log yard transit

TPN (Tempat Penimbunan Sementara) Log landing yard

TPS Temporary Hazardous Chemical Waste Storage

CW-11 CW-FM Master Report 1 May 2017 Page 4 of 24

1. INTRODUCTION

As a part of Asia Pulp & Paper Group’s (APP) preparation to meet the Forest Stewardship Council’s (FSC) conditionally approved “Roadmap towards ending the Disassociation from APP1” requirements, APP will undertake assessments on APP’s own and a selection of supplier concessions in Indonesia. This will be one of fifteen assessments that will inform APP where its strengths and weaknesses lie in relation to the FSC Controlled Wood Standard for Forest Management Enterprises – FSC-STD-30-010 version 2-0. These assessments are not a formal part of the Roadmap. No certificates will be issued because of these audits2. This report presents the findings of an independent evaluation conducted by a team of specialists representing the RA-Cert Program of the Rainforest Alliance. The purpose of the evaluation was to evaluate the FMEs level of conformance to the Forest Stewardship Council (FSC) Controlled Wood requirements as defined in the FSC Controlled Wood Standard for Forest Management Enterprises (FSC-STD-30-010, version 2-0). The intent of this standard is to allow forest management enterprises to supply FSC Controlled Wood to FSC chain-of-custody certified operations for mixing with FSC certified materials in production of FSC mixed products. Conformance with the specified controlled wood standard allows forest management enterprises (FME) to demonstrate that the wood they supply has been controlled to avoid wood from the five controversial categories defined by FSC. Controversial categories include wood that is: 1) illegally harvested, 2) harvested in violation of traditional and civil rights, 3) harvested in forest management units in which high conservation values are threatened by management activities, 4) harvested in areas in which forests are being converted to plantations or non-forest use or 5) harvested from forests in which genetically modified tress are planted. FSC-STD-30-010 provides the basic requirements at the forest management unit level to demonstrate that wood from the FME’s forest area(s) is controlled. Products from verified controlled sources can be used by manufacturers mixing FSC-certified wood and controlled wood.

The scope of this evaluation is for the FME PT. Riau Abadi Lestari, located in Riau, Indonesia, with a total area of ±12,000 ha (Ministry of Forestry Decree No. 542/Kpts-II/1997).

1Further information about the Roadmap process can be found at https://ic.fsc.org/en/what-is-fsc/what-we-do/dispute-resolution/current-cases/asia-pulp-and-paper-app 2The issuance of FSC certificates will depend on the decision by the FSC Board to end the disassociation from APP and the subsequent demonstration of compliance by APP and its suppliers with the applicable FSC standards as part of a new, formal certification process.

CW-11 CW-FM Master Report 1 May 2017 Page 5 of 24

2. AUDIT CONCLUSIONS

2.1. Auditor Recommendation

Controlled Wood Category Conformance

1. Illegally harvested wood Yes No

2. Wood harvested in violation of traditional and civil rights Yes No

3. Wood harvested from forest areas where high conservation values are threatened by forest management activities

Yes No

4. Wood harvested from areas being converted from forests and other wooded ecosystems to plantations or non- forest uses

Yes No

5. Wood harvested from genetically modified trees Yes No

Based on Company’s conformance with RA-Cert/FSC requirements, the auditor

makes the following recommendation:

Level of Conformance to FSC Controlled Wood Requirements:

Minor NCRs and Major NCRs issued

FME’s management system, if implemented as described, is capable of ensuring conformance with all the requirements of the FSC Controlled Wood standard over the whole forest area covered by the scope of the evaluation

Yes No

Comments: The FME has a robust documented management system that covers all of the requirements of the FSC CW-FM standard. If implemented as documented the FME would be in conformance with the requirements of FSC-STD-30-010. However, the status of the concession and past land use history prohibits full implementation of the documented managements systems and conformance. See further details below related to Trans Migration concession and overlapping tenure.

The FME has demonstrated, subject to correction of the identified non-conformances, that their management system is being consistently implemented over the whole forest area covered by the scope of the certificate.

Yes No

Comments: Subject to the correction of identified non-conformances the FME has demonstrated the implementation of their management systems over the forest area covered by the scope of this evaluation. See below related to management of conflict areas which covers most the area of the FMU.

Issues have been identified during the evaluation as controversial or hard to evaluate.

Yes No

Comments: 1. Land conflict issue

The FME has long history of tenurial conflict ever since the issuance of their license for managing the industrial timber plantation. In Laporan Utama Analisa Dampak Lingkungan Hak Pengusahaan Hutan Tanaman Industri Transmigrasi,

CW-11 CW-FM Master Report 1 May 2017 Page 6 of 24

PT Riau Abadi Lestari, Kabupaten Dati II Bengkalis, Propinsi Dati I Riau, Juni 1996, it was clearly stated that the concession is a plantation business run in combination with the transmigration area. The FME was granted a concession license from Ministry of Forestry Decree No. 542/Kpts-II/1997, dated August 25th 1997 to manage degraded forest area of 12,000 Ha in Kampar, Siak and Bengkalis District, in Riau Province for timber industry. The area was part of PT Arara Abadi land reserved (areal cadangan) in three units (Sindotim, Mandiangin and Tasik Serai). The combination of timber plantation and transmigration program was aimed at providing opportunity for communities to work at the plantation while at the same time get profit sharing from the company’s timber production for the areas under collaboration scheme. The transmigration program was established in all three areas. According to the company record, during the first rotation period (1997-2007) there were acacia and rubber plantations. However, with the increasing social conflicts over land with communities, the plantation areas were reduced. There were also requests from the transmigration areas to change the species to palm oil which is not possible under forest zone designation. The communities included within the transmigration areas demanded that the company release the land to them, but it was beyond the company’s authority to do so. The transmigrants requested that the company establish 1800 ha of oil palm plantation (600 ha for each site, sindotim, mandi angin and tasik serai). In the end, however, the transmigrants were supported by the local government to develop the oil palm plantations. The area has been occupied by transmigration community and other communities even before 1996 and has continued to this day. They have built a school building, hospital, market, local authority offices including plantation for livelihood (rubber, oil palm, vegetables, and others). The transmigration program in this area was launched since the issuance of President Instruction No 1 year 1986 until 1996 where the government provide Kredit Lunak Bank Indonesia (KLBI) or Indonesian Bank Soft Loan scheme for investor. Land conflicts between company and local community has been escalating from the time the company began operations resulting in the reduction of areas that are plantable. Currently, about 60% of the RAL concession area is as identified as being under conflict and only 40% is under company management. Some of the community members that have made land claims have successfully obtained land title under private ownership from National Land Titling Agency (BPN). A series of conflict resolution sessions have been facilitated by the local authority and yet land conflict remains a hot issue at the time of audit. The lack of management control on the conflict areas prevents RAL from being able to demonstrate conformance across the entire FMU as oil palm plantation establishment is not an allowable land use under their industrial plantation concession issued by the MoE&F.

2. Peat issue

The FME was granted concession license from Ministry of Forestry Decree No. 542/Kpts-II/1997, dated August 25th 1997 to manage degraded forest area of 12,000 Ha in Kampar, Siak and Bengkalis District, in Riau Province for timber industry. The FME has also carried out an Environmental Impact Analysis that was approved by the AMDAL commission of Ministry of Forestry through letter No.199/DJ-VI/AMDAL dated on 25 June 1996. Based on the AMDAL and HCV documents, nearly all the area of the concession falls under peat land category

CW-11 CW-FM Master Report 1 May 2017 Page 7 of 24

with various depth of peat. The concession covers mostly peat ecosystem, thus Acacia crassicarpa and Eucalyptus sp. are recommended for planting in the concession as these species are most suitable for peat land ecosystem. Approved management plan also contains silviculture system for peat land including canalization. Thus, the FME has legal authority to harvest logs for the pulp and paper industry (to PT Indah Kiat Pulp and Paper) from the peat land area. In 2017, the government issued the “Peraturan Menteri Lingkungan Hidup dan

Kehutanan Republik Indonesia Nomor P.17/Menlhk/Setjen/Kum.1/2/2017

tentang Perubahan Atas Peraturan Menteri Lingkungan Hidup Dan Kehutanan

Nomor P.12/Menlhk-Ii/2015 Tentang Pembangunan Hutan Tanaman Industri” and one new clause (15 g) made a stipulation that the Peat Ecosystem subject to protection measures is all peat that occurs within plantation concession after overlaying the RKUPHHK-HTI and Peat Ecosystem Function Map issued by the Ministry of Environment and Forestry. Thus, the concession now has an obligation to revise their RKU using Peat Ecosystem Function Map with scale of 1:250.000. In the case of PT RAL, if the concession contains peat under the protection category covering an area of more than 40% of their concession then the company is eligible for a land swap. According to article 8 (g) a plantation concession having more than 40% of their areas fall under Peat Ecosystem for Protection Function can apply for land swap, which will be arranged by Ministerial Regulation. There is also clause stating that after overlaying the KHG (Peat Hydrological Areas) map the existing plantation on peat that also falls under Protection Function can be harvested for 1 rotation (cycle) and it cannot be replanted. It must be allocated as Area for Peat Ecosystem Protected Functions in the layout of IUPHHK- HTI. In other words, any plantation area that is located within the mapped Peat Hydrological area (KHG) map will not be eligible for replanting after current stand is harvested. Currently, PT RAL is in the process of revising their RKU following the P.17/2017. Until they receive RKU approval, the FME is required to stop their forest operation on peat land (no planting and no land clearance) and continue to protect the peat land. Areas that fall under cultivation function (regardless of the depth of the peat) can be managed for plantation.

2.2. New nonconformity reports issued as a result of this audit

NCR#: 01/17 NC Classification: Major Minor X

Standard & Requirement: FSC-STD-30-010 (Version 2-0) EN

Report Section: Appendix II – 1.3 Quality system requirements

Description of Nonconformance and Related Evidence:

1.3 All interviewed staff shall be aware of their responsibilities and shall have sufficient overview of the controlled wood requirements to ensure their fulfillment.

Overall staff and forest workers interviewed during the audit were knowledgeable about their job responsibilities, however, gaps exist in their knowledge of Controlled Wood requirements. This contributed to the nonconformances identified during the audit. Examples include:

1. Insufficient knowledge of monitoring and protection requirements related to HCVs.

CW-11 CW-FM Master Report 1 May 2017 Page 8 of 24

2. Insufficient knowledge of health and safety SOPs related to chemical use (requirement for showering and changing facilities onsite for workers applying chemicals), requirement for FME to ensure workers are provided required PPEs at no cost.

Corrective Action Request: Organization shall implement corrective actions to demonstrate conformance with the requirement(s) referenced above. Note: Effective corrective actions focus on addressing the specific occurrence described in evidence above, as well as the root cause to eliminate and prevent recurrence of the nonconformance.

Timeline for Conformance: Not Applicable

Evidence Provided by Organization:

• BA Sosialisasi Role Charter

• BA Training HCV HCS

• Materi Sosialisasi P3K Kasus Keracunan

• Materi-Buku Saku HCV

• Rencana dan realisasi tranning

• sosialisasai APD

Findings for Evaluation of Evidence:

After the onsite closing meeting and prior to report finalization PT RAL conducted training for applicable staff on:

1. Staff roles and responsibilities as defined in role charters, 2. General HCV training 3. Training on first aid procedures for exposure to chemicals 4. Training on PPE procedures.

Evidence of the training events was provided, e.g., sign in sheets, photos of training, etc. However, except for HCVs and first aid training for chemical exposure the evidence provided did not detail the content of the training provided. Also, the HCV training provided was generic and did not detail specific management, monitoring and protection measures for HCVs that occur on the FMU. Onsite evaluation is required to verify effectiveness of the training provided to ensure all staff are aware of their responsibilities and shall have sufficient overview of the controlled wood requirements to ensure their fulfillment.

NCR Status: OPEN

Comments (optional):

NCR Evaluation:

Evaluation Method: Onsite Estimated Level of Effort: 1 day

Auditor Specialty: General

MAJOR NCR#: 02/17 NC Classification: Major Minor X

Standard & Requirement: FSC-STD-30-010 (Version 2-0) EN, 1.3 a) – d)

Report Section: Appendix II; 4.1

Description of Nonconformance and Related Evidence:

4.1. FME shall develop and implement procedures for stakeholder consultation as defined in this standard and include at least the following (1.3 a-d):

a) key stakeholders shall be identified and invited to participate in the consultation with sufficient prior notice;

b) excluded groups shall be given particular attention when identifying interested or affected parties; c) the consultation process shall be opened to parties claiming an interest in or affected by

implementation of this standard; d) all identified parties shall be provided with access to sufficient information

CW-11 CW-FM Master Report 1 May 2017 Page 9 of 24

The FME has developed a standard operating procedure (SOP) for stakeholder consultation number SOP-RAL-G2-011 dated June 1, 2017. The SOP, as explained in the procedure, is required to be implemented by forest management staff in order to make sure that the consultation process is effective and integrated. The SOP also requires key stakeholders to be identified and given the opportunity to provide input with sufficient prior notice. Invitations should be sent out to participants at least 7 days before the event while the material documents for consultation should be sent at the latest 3 days in advance. For identifying stakeholders and getting their involvement, the FME has also developed an SOP for mapping and involving stakeholder participation (Pemetaan dan Pelibatan Pemangku Kepentingan) SOP-RAL-G2-010. The FME has identified stakeholders at different levels and maintains a list of stakeholders in all three districts (Siak, Kampar and Bengkalis) where the FME areas are located. However, the list of stakeholders provided to the auditors during assessment was two years old and had not been updated in the field office. Some key stakeholders had been left off the list such as the head of provincial environmental and forestry office. There was also an occasion where the invitation letter for a socialization meeting about the FME annual work plan was sent out just one day before the meeting took place, and not all key stakeholders were invited to the meeting.

Corrective Action Request: Organization shall implement corrective actions to demonstrate conformance with the requirement(s) referenced above. Note: Effective corrective actions focus on addressing the specific occurrence described in evidence above, as well as the root cause to eliminate and prevent recurrence of the nonconformance.

Timeline for Conformance: Not Applicable

Evidence Provided by Organization:

• BA Sosialisasi program DMPA di Desa Bencah Kelubi (Report of dissemination of fire care village program in Bencah Kelubi Village.

• The FME’s latest stakeholder list dated September 2017.

Findings for Evaluation of Evidence:

After the onsite closing meeting and prior to report finalization PT RAL provided evidence of dissemination on DMPA program and latest stakeholder list. The stakeholder list contains information for each unit of the FME. Since many of the stakeholders in the list have no cell phone number listed, this need to be verified in the field. Inaddition, the FME did not provide any evidence regarding the stakeholder invitation timeline. Therefore, this NCR remains open.

NCR Status: OPEN

Comments (optional):

NCR Evaluation:

Evaluation Method: Onsite Estimated Level of Effort: 1 day

Auditor Specialty: Lead and social auditor

MAJOR NCR#: 03/17 NC Classification: Major X Minor

Standard & Requirement: FSC-STD-30-010, version 2-0; Section 3, Table 1b & FSC-ADV-30-010-1: 1. Legal rights to harvest 1.4)

Report Section: Appendix II, 5.1.6

Description of Nonconformance and Related Evidence:

5.1.6 Evidence shall demonstrate that the FME is following the prescriptions of the management plan and is implementing the management plan in the field. (Section 3, Table 1b & FSC-ADV-30-010-1: 1. Legal rights to harvest 1.4)

Findings:

Based on interviews and field visits in the three regions, the audit team found that the FME has not fully followed the prescription as set out in the management plan (ISFMP and RKU) across the entire FMU.

CW-11 CW-FM Master Report 1 May 2017 Page 10 of 24

Approved management activities are only implemented in their plantation areas which currently covers less than 50% of the concesssion area. Most of the concession area is under land conflict with community. Field visit in Mandi Angin indicated that there was no monitoring of riparian, buffer zone and HCV areas since most of these areas have been almost entirely converted to oil palm plantations. Mandi Angin river and its tributaries as well as many of the water courses located in the other two units have no natural forest buffer. This is not in compliance with the government regulation Peraturan Pemerintah Republik Indonesia Nomor 38 Tahun 2011 tentang Sungai (Government Regulation regarding River) and Peraturan Menteri Pekerjaan Umum dan Perumahan Rakyat Republik Indonesia Nomor 28/PRT/M/2015 Tentang Penetapan Garis Sempadan Sungai Dan Garis Sempadan Danau (Ministry Regulation concerning stipulation on river line or buffer for river and lake). The auditors also observed recent opening (active conversion) of peat swamp for oil palm plantation along the Mandi Angin river and in protected areas in the other two units, indicating that there are no protection measures being successfully implemented for these areas.

Additionally, under the Section VIII-5-yr management plan (periode 2016-2020), sub section 8.2.2, the FME is required to manage the protection area including Buffer Zone of Tahura Sultan Syarief Kasim (SSK) II (NKT 1.1, 1.2 and 1.3), wildlife corridor or DPSL/Daerah Perlintasan Satwa Liar (NKT 1.1., 1.2, 1.3, 4.1 and 4.2), KPPN or germ plasm conservation area (NKT 1.1., 1.2, 1.3, 3, 4.1 and 4.2) and river or riparian buffer zone (HCS and all HCVs). Mandiangin region contain NKT 1.1., 1.2, 1.3, 3, 4.1 and 4.2, however monitoring of HCVs is lacking. There was no boundary marking on ground, no collaborative management for riparian management, no biophysical identification and monitoring and no monitoring done by the FME as prescribed under the ISFMP.

Corrective Action Request: Organization shall implement corrective actions to demonstrate conformance with the requirement(s) referenced above. Note: Effective corrective actions focus on addressing the specific occurrence described in evidence above, as well as the root cause to eliminate and prevent recurrence of the nonconformance.

Timeline for Conformance: Not Applicable

Evidence Provided by Organization:

• BA Musyawarah pengelolaan pengelolaan kawasan konservasi di Kampung Mandiangin (Evidence of a meeting on management of conservation area in Mandiangin village)

• Laporan Kegiatan identifikasi tutupan lahan PT RAL 2017. ( Report of land cover identification in PT RAL 2017)

• Hasil pemetaan konflik PT RAKA (PT RAKA conflict mapping result)

• Peta Penutupan lahan PT RAL skala 1:50.000 yang belum ditandatangani. (Unsigned map of PT RAL land cover)

Findings for Evaluation of Evidence:

After the onsite closing meeting and prior to report finalization PT RAL provided evidences on land cover map and PT RAKA conflict assessment. Based on reviewed evidences, it is clear that the FME has started to monitor the land cover and evaluating conflicts. However, the FME is not consistent in its evidences, in report provided mention that the source is Landsat 8 2017 however, the result showing land cover 2016. Moreover, the FME did not provided evidence that the management plan has been implemented throughout the FMU. The evidence of meeting was provided with photo and attendance list but without result of the meeting. The conflict assessment report contains latest action recorded was in 2015. It is clear that the non-conformance has not been addressed and NCR remains open.

NCR Status: OPEN

Comments (optional):

NCR Evaluation:

Evaluation Method: Onsite Estimated Level of Effort: 1 day

CW-11 CW-FM Master Report 1 May 2017 Page 11 of 24

Auditor Specialty: Forestry

MAJOR NCR#: 04/17 NC Classification: Major X Minor

Standard & Requirement: FSC-STD-30-010, version 2-0; FSC-ADV-30-010-1: 3. Timber Harvesting Activities, 3.4 Health & Safety

Report Section: Appendix II, 5.1.11

Description of Nonconformance and Related Evidence:

5.1.11 FME shall provide evidence that legally required occupational health and safety laws applicable to workers involved in forest operations are considered for the following (FSC-ADV-30-010-1: 3. Timber Harvesting Activities, 3.4 Health & Safety):

a. proper personal protective equipment; b. safe and proper felling and transport practice; c. establishment of protections zones around harvest sites; d. safety requirements for machinery used, and;

e. safety requirements in relation to chemical usage,

Findings:

The FME has developed a number of procedures to ensure the health and safety of their staff and workers during forest operation such as the following:

1. Proper personal protective equipment (SOP –RAL-S1-006). Based on the field visit observations, workers in the Tasik Serai and Sindotim properly wore PPE as prescribed under the SOP

2. Safe and proper felling and transport practice is prescribed in detail under SOP RAL-P4-001 concerning harvesting in dry land, while SOP-RAL-P4-002, is deals with harvesting in wetland. No active harvesting was observed during field visit.

3. SOP-RAL-P4-002 Harvesting Guideline – contain PPE, establishment of protections zones around harvest sites, safety requirements for using machinery and the use of chemicals.

With regard to safety requirement in relation to chemical usage, the FME has SOP-RAL-P3-001 concerning PPE for herbicide application.in dry land and wet land for Acacia and Eucalyptus plantations. Section 6.13.3 under this SOP prescribed that workers dealing with chemical not bring their used PPE to wash at home. Based on an interview with the herbicide worker in Sindotim region, they bring their used PPE and wash them at home. This is inconsistent with the SOP. The auditor also verified that there was no proper place to wash the used PPE on site. The current SOP prohibits washing at home, but there were no procedures available to facilitate cleaning and washing used PPE at a company facility. Moreover, contracted workers interviewed in the field informed the audit team that they are required to replace any lost or damaged PPEs at their own cost.

Inspection of first aid kits in Sindotim and Tasik Serai region found that they do not include the required contents per national regulation (Peraturan Menteri Tenaga Kerja Dan Transmigrasi Republik Indonesia Nomor : Per.15/Men/Viii/2008 Tentang Pertolongan Pertama Pada Kecelakaan Di Tempat Kerja).

Corrective Action Request: Organization shall implement corrective actions to demonstrate conformance with the requirement(s) referenced above. Note: Effective corrective actions focus on addressing the specific occurrence described in evidence above, as well as the root cause to eliminate and prevent recurrence of the nonconformance.

Timeline for Conformance: Not Applicable

Evidence Provided by Organization:

• BA Pemasangan shower dan tempat ganti pakaian tenaga kerja di lapangan PT RAL (report on installation of shower facilities)

• BA sosialisasi penggunaan shower dan tempat ganti (evidence on dissemination of the use of shower facilities)

CW-11 CW-FM Master Report 1 May 2017 Page 12 of 24

Findings for Evaluation of Evidence:

After the onsite closing meeting and prior to report finalization PT RAL provided evidences on installation of shower facilities and dissemination of the use of shower facilities. Photos and attendance list were provided. This evidence needs to be verified in the field. In addition, the FME has not provided any evidence related to first aid kits and PPE for workers as raised above. The NCR remains open.

NCR Status: OPEN

Comments (optional):

NCR Evaluation:

Evaluation Method: Onsite audit Estimated Level of Effort: 1 day

Auditor Specialty: Forestry

MAJOR NCR#: 05/17 NC Classification: Major X Minor

Standard & Requirement: STD-30-010 (Version 2-0) EN, Criterion 4.2 and 4.5

Report Section: Appendix II, 5.2.2 & 5.2.4

Description of Nonconformance and Related Evidence:

5.2.2. No conflicts shall exist relating to land tenure or land use rights of traditional or indigenous peoples in the areas managed by the FME (4.2 & FSC-ADV-30-010-1: Third parties’ rights 4.1, 4.2 & 4.3). In case conflicts exist, the FME has agreed a resolution process with relevant parties as specified below in point 5.2.4 (If the FME is SLIMF, but a conflict exists, a resolution process shall be in place and cannot be considered non-applicable).

5.2.4. If there are conflicts relating to land tenure or land use rights of traditional or indigenous peoples, a resolution process shall be established by the FME and evidence regarding following aspects shall be presented by the FME (4.5 & & FSC-ADV-30-010-1: Third parties’ rights 4.1, 4.2 & 4.3):

a) the process genuinely addresses the concerns and is aimed at resolving the disputes b) the process has the support of the parties involved in the dispute c) an interim process for addressing the dispute and for the management of the forest area concerned

has been agreed with parties to the dispute.

Based on document review, the FME has established targets to resolve several conflicts during calendar year 2017. In Mandi Angin, the FME has targeted 3 cases to be resolved. For conflicts in Sindotim unit, the objective would be to monitor the conflicts in the field or 2017 and It is target resolution of the conflicts in 2018. Although the FME has already mapped and completed an analysis of the conflicts, many of which have been ongoing for years, and set out a plan to resolve them, the FME has not presented evidence that affected parties have agreed with the proposed conflict resolution process as required by the criterion, therefore, a major nonconformance was issued.

Corrective Action Request: Organization shall implement corrective actions to demonstrate conformance with the requirement(s) referenced above. Note: Effective corrective actions focus on addressing the specific occurrence described in evidence above, as well as the root cause to eliminate and prevent recurrence of the nonconformance.

Timeline for Conformance: Not Applicable

Evidence Provided by Organization:

• Surat kesepakatan Bersama penyelesaian klaim desa Beringin 2016 (Agreement on dispute resolution in Beringin village 2016)

• Surat PT RAL kepada pihak berkonflik tertanggal 10 Februari 2015 tentang status lahan (FME’s letter to disputant dated 10 February

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2015 on land status)

• Perjanjian ganti rugi tanah dengan salah satu pihak di Minas Barat tertanggal 19 Agustus 2016. (Compensation agreement between FME and a disputant dated 19 august 2016)

Findings for Evaluation of Evidence:

The provided evidences have been reviewed during field audit. The FME has not been able to provide evidences that address issued NCR. Therefore, this NCR remain open.

NCR Status: OPEN

Comments (optional):

NCR Evaluation:

Evaluation Method: Onsite audit Estimated Level of Effort: 1.5 days

Auditor Specialty: Lead and Social auditor

MAJOR NCR#: 06/17 NC Classification: Major X Minor

Standard & Requirement: FSC-STD-30-010, version 2-0 section 5

Report Section: Appendix II, 5.3.1

Description of Nonconformance and Related Evidence:

5.3.1 High conservation values in the FMU shall be identified and precautionary measures shall be taken by the FME to eliminate potential negative impacts to high conservation values present (Annex 2; 5.2).

Findings:

The FME has identified high conservation values through HCV assessments done in 2014 by PT Asia Pacific Consultant Service. The assessments also include precautionary measures that should be taken by the FME to minimize negative impacts of forest operation on the identified values. This is also supported by the development of the HCV and HCS Management and Monitoring Plan in PT RAL plantation area (Document: Rencana Pengelolaan dan Pemantauan HCV–HCS di Areal Hutan Tanaman Industri PT RAL, Propinsi Riau, Sinarmas Forestry, 2016). Precautionary and protection measures are prescribed in detail in the SOP for HCV Management and Monitoring (SOP RAL-E3-012). The SOP contains a matrix to score the magnitude of threats against conservation targets so that the FME can prioritize mitigation actions. The SOP is not being implemented by the FME. The auditor inspected a number of HCVs in all three units and found oil palm plantation along riparian zones and in protected areas that have been mapped and identified as HCV. In some cases, the oil palm plantations occupying the mapped HCV areas, which are visible along main roads, predate the HCV assessment completed in 2014.

Based on the HCV assessment, the FME contains some rare, threatened and endangered wildlife species such as elephant (Elephas maximus) and tiger (Panthera tigris sumatrae). The FME developed a SOP to monitor these species (SOP RAL-E3-004). So far, the monitoring activities was done for the wildlife in general but not specific to elephant and tiger as suggested by BKSDA and under ISFMP. The FME still lacks monitoring especially for HCVs. For example, in Mandi Angin region, the HCV study identified riparian areas and river buffer zones nearby the KPPN, but there was no report for monitoring this protection area. This indicates that the FME did not appropriately take precautionary measure to eliminate potential negative impacts to the identified HCVs.

Corrective Action Request: Organization shall implement corrective actions to demonstrate conformance with the requirement(s) referenced above. Note: Effective corrective actions focus on addressing the specific occurrence described in evidence above, as well as the root cause to eliminate and prevent recurrence of the nonconformance.

Timeline for Conformance: Not Applicable

Evidence Provided by Laporan Skoring Ancaman terhadap HCV (Scoring of threats to HCVs)

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Organization: • Sempadan Sungai Perapakan (Perapakan River Buffer)

• DPSL km 51 (wildlife conservation area km 51) DPSL km 53 (wildlife conservation area km 51)

Findings for Evaluation of Evidence:

During report writing phase, the FME provided additional evidences as mentioned above. The evidence provides scoring of threats of each HCV. However, detail information on the process, date and method used were not available. The evidence has not address the non-conformance.

NCR Status: OPEN

Comments (optional):

NCR Evaluation:

Evaluation Method: Onsite audit Estimated Level of Effort: 2 days

Auditor Specialty: Forester, Social auditor

MAJOR NCR#: 7/17 NC Classification: Major X Minor

Standard & Requirement: FSC-STD-30-010, version 2-0; criterion 5.2.c

Report Section: Appendix II, 5.3.4

Description of Nonconformance and Related Evidence:

5.3.4 FME shall have a list of the high conservation values identified in the FMUs, together with evidence indicating that precautionary measures have been taken to eliminate potential negative impacts to the high conservation values present (5.2 c).

Finding:

The FME has a list of HCVs identified within their concession. They have developed management and monitoring plans to eliminate potential negative impacts to the HCV values. However, there was observations during audit found:

1. Recent land clearance of riparian ecosystem/natural forest to non-forest uses (oil palm plantation) occurred in Mandi Angin river, Mandi Angin region and Tasik Sereh

2. Lack of monitoring for riparian and buffer or the river (HCV 1.1, 1.2, 1.3 and 4.1 and 4.2)

3. No report of community activities that threatening the HCVs (i.e land clearance or natural forest to non-forest uses)

4. Two community cemeteries located in Tasik Serai have not been mapped or had precautionary measures defined to ensure their protection.

These indicate that precautionary measures are not properly taken by the FME to protect and maintain the identified HCVs.

Corrective Action Request: Organization shall implement corrective actions to demonstrate conformance with the requirement(s) referenced above. Note: Effective corrective actions focus on addressing the specific occurrence described in evidence above, as well as the root cause to eliminate and prevent recurrence of the nonconformance.

Timeline for Conformance: Not Applicable

Evidence Provided by Organization:

• BA Musyawarah pengelolaan pengelolaan kawasan konservasi di Kampung Mandiangin (Evidence of a meeting on management of conservation area in Mandiangin village)

• Deskripsi salah satu konflik di Desa Mandiangin (Description of one particular conflict in Mandiangin village)

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Findings for Evaluation of Evidence:

The FME provided evidence of a meeting with stakeholders from Mandi Angin village including picture and attendance list. However, no minutes of the meeting nor any information of the result of the meeting was provided. The description of the conflict has been reviewed before. The evidence provided has not address issued NCR.

NCR Status: OPEN

Comments (optional):

NCR Evaluation:

Evaluation Method: Onsite audit Estimated Level of Effort: 2 days

Auditor Specialty: Forester, Social auditor

MAJOR NCR#: 8/17 NC Classification: Major X Minor

Standard & Requirement: FSC-STD-30-010, version 2-0; criteria 6.1, 6.2 & 6.3

Report Section: Appendix II, 5.4.1, 5.4.2, & 5.4.3

Description of Nonconformance and Related Evidence:

5.4.1. No conversion of natural and semi-natural forests and other wooded ecosystems such as woodlands and savannahs to plantations or non-forest uses shall take place. This shall be supported by records or verifiable evidence (e.g. records of forest area within the management of the FME) (6.2).

5.4.2. Absence of conversion shall be supported by records or verifiable evidence (e.g. records of forest area within the management of the FME) (6.2).

5.4.3. If any forest conversion has occurred, it shall be under at least one of the following circumstances (6.3):

a) conversion entails a very limited portion of the FMU (< 0,5% per year and < 5% in total in long term).

b) conversion shall not occur on high conservation value forest area c conversion shall enable clear, substantial, additional, secure long term environmental and social

benefits across the FMU.

Findings:

The FME has developed Forest Conservation Program and committed not to convert natural forest into plantation or non-forest uses. However, the audit team observed a recent opening of peat swamp for oil palm plantation taking place along the Mandi Angin river indicating that there was no protection against these supposedly conserved area (See 5.1.6). Based on interviews, active convertion from natural forest (peat swamp ecosystem) to non-forest uses (oil palm plantation) was done by the local community, but the FME has no record on this activity. Evidence of active conversion by local communities of natural secondary forest to oil palm plantations was also witnessed in Sindotim (SW corner along river) and Tasik Serai (central part of unit adjacent to 2017 harvest area and along southern boundary west of main road) units. All the observed conversion was occurring in areas mapped as HCV.

Corrective Action Request: Organization shall implement corrective actions to demonstrate conformance with the requirement(s) referenced above. Note: Effective corrective actions focus on addressing the specific occurrence described in evidence above, as well as the root cause to eliminate and prevent recurrence of the nonconformance.

Timeline for Conformance: Not Applicable

Evidence Provided by Organization:

• Musyawarah pengelolaan pengelolaan kawasan konservasi di Kampung Mandiangin (Evidence of a meeting on management of conservation area in Mandiangin village)

• Laporan Patroli Terpadu PT RAL di Kawasan Sungai Tapung Kanan (Report of join monitoring by divisions in PT RAL covering

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Tapung Kanan river (undated))

Findings for Evaluation of Evidence:

The FME provided evidence of a meeting with stakeholders from Mandi Angin village including picture and attendance list. However, no minutes of the meeting nor any information of the results of the meeting were provided. The monitoring report provided was not dated and did not include a clear description of the monitoring process of the results of the monitoring. Based on the evidence provided the NCR remains open

NCR Status: OPEN

Comments (optional):

NCR Evaluation:

Evaluation Method: Onsite audit Estimated Level of Effort: 2 days

Auditor Specialty: Forestry, Ecologist

2.3. Observations

Note: Observations are issued for areas that the auditor sees the potential for improvement in implementing standard requirements or in the quality system; observations may lead to direct non-conformances if not addressed.

OBS 01/17 Reference Standard & Requirement: STD-30-010 (Version 2-0) EN, Criterion 4.3

The audit team found examples of requests made to the FME by local community members that were not documented and responded to in a timely manner;

• a request to normalize the river in Mandi Angin village, and

• a request from community in Mandi Angin to the FME to give access to power grid line to cross the concession areas so that it can reach the village.

This is raised as an observation because the auditor found that in all other cases reviewed the FME documented and responded to requests in a timely manner.

Observation: FME should document the respond to all stakeholder requests or concerns in a timely manner.

2.4. Actions Taken by Company after the audit and prior to report finalization The FME provided below documents as evidences: - Report of training for applicable staff on:

a. Staff roles and responsibilities as defined in role charters, b. General HCV training c. Training on first aid procedures for exposure to chemicals d. Training on PPE procedures.

- BA Sosialisasi program DMPA di Desa Bencah Kelubi (Report of dissemination of fire care village program in Bencah Kelubi Village.

- The FME’s latest stakeholder list dated September 2017. - BA Musyawarah pengelolaan pengelolaan kawasan konservasi di Kampung Mandiangin (Evidence

of a meeting on management of conservation area in Mandiangin village) - Laporan Kegiatan identifikasi tutupan lahan PT RAL 2017. ( Report of land cover identification in PT

RAL 2017)

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- Hasil pemetaan konflik PT RAKA (PT RAKA conflict mapping result) - Peta Penutupan lahan PT RAL skala 1:50.000 yang belum ditandatangani. (Unsigned map of PT

RAL land cover) - BA Pemasangan shower dan tempat ganti pakaian tenaga kerja di lapangan PT RAL (report on

installation of shower facilities) - BA sosialisasi penggunaan shower dan tempat ganti (evidence on dissemination of the use of

shower facilities) - Surat kesepakatan Bersama penyelesaian klaim desa Beringin 2016 (Agreement on dispute

resolution in Beringin village 2016) - Surat PT RAL kepada pihak berkonflik tertanggal 10 Februari 2015 tentang status lahan (FME’s

letter to disputant dated 10 February 2015 on land status) - Perjanjian ganti rugi tanah dengan salah satu pihak di Minas Barat tertanggal 19 Agustus 2016.

(Compensation agreement between FME and a disputant dated 19 august 2016) - Laporan Skoring Ancaman terhadap HCV (Scoring of threats to HCVs) - BA Musyawarah pengelolaan pengelolaan kawasan konservasi di Kampung Mandiangin (Evidence

of a meeting on management of conservation area in Mandiangin village) - Deskripsi salah satu konflik di Desa Mandiangin (Description of one particular conflict in Mandiangin

village) - Musyawarah pengelolaan pengelolaan kawasan konservasi di Kampung Mandiangin (Evidence of a

meeting on management of conservation area in Mandiangin village) - Laporan Patroli Terpadu PT RAL di Kawasan Sungai Tapung Kanan (Report of join monitoring by

divisions in PT RAL covering Tapung Kanan river (undated))

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3. AUDIT PROCESS

3.1. Audit schedule/Itinerary

Location Date(s) Activities

Pekanbaru, Riau 14 August 2017 Stakeholder consultation with Government agencies and NGOs.

FME Office 15 August 2017 Opening meeting, document review, FME staff interviews.

Forest concession, Units Sindotim, Mandi Angin and Tasik Serai

16 August 2017 Field inspection, stakeholder consultation with forest workers and local communities

Pekanbaru, Riau 17 August 2017

Indonesia Independence Day

Document review

FME Office and Unit Sindotim 18 August 2017 Document review, field inspection, FME staff interview, inspect worker housing, chemical storage, hazardous waste storage and fuel storage.

Closing meeting

Total number of person days used for the audit:26, of this 4 days for pre-evaluation and preparation 16 days for onsite document review and field inspection 6 stakeholder consultation

3.2. Audit team and qualifications

Name Qualifications

Role /

Audit

Focus

Gabriel Bolton

Gabe has a Bachelors of Science in Forestry from the University of Vermont (1996). He has over 10 years of experience working as a forester in the Northeastern US with 15 years of experience related to forest certification. He has been employed by Rainforest Alliance since 2006 and currently is Rainforest Alliance's global technical expert on forest management certification. Gabe has participated in more than 40 audits and assessments on six continents in addition to completing Rainforest Alliance CoC and FM Lead Assessor Training.

Audit Team Leader

Titiek Setyawati, Ph.D.

Titiek is a senior researcher at Forest Research and Development Agency, Ministry of Environment and Forestry, Indonesia. She has experience working with PT. Sarana Wana Nusa Consult; Alas Kusuma Group; PT. Diamond Raya Timber for SFM certification assistance program; LEI (Lembaga Ekolabel Indonesia); CIFOR (Center for International Forestry Research); SGS for SFM certification and socialization, CITES Working Group for Endangered Plant Species; ITTO-CIFOR Project (froml1996 to now); member team for HCVF ToolKit 2003 Revision, FAO for a drought study, GIZ for Asian Heritage Parks in ASEAN country assessment, FSC for Centralized

Auditor, Forestry/Ecology

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Risk Assessment for HCV 1-3 (biodiversity), UNDP-MoF-GEF project on SCBFWM (Strengthening Community Based Forest and Watershed Management, ITTO-Cendana and Ramin Project, FAO Project for Drought and Community in 2015, GTZ-ACB Project for Asian Heritage Park Assessment in 2014, member of Standard Development Group (SDG) for FSC Sustainable Forest Management National Standard Development, Lead for FSC CNRA (Centralized National Risk Assessment) with Remark Asia, and a number of HCVF studies in Indonesia. She holds PhD from The University of Melbourne, Australia; MSc from Faculty of Forestry, Mississippi State University, USA, and Bachelor degree from Forestry Faculty, Bogor Agriculture Institute. Currently appointed as National Consultant for FAO TCP/FLR Project for Forestry Landscape Restoration for 2017 period. Titiek holds ISO 9001-2008 certificate under IRCA-BSI and has participated in more than 30 audits, (re)assessments, and pre-assessment for Rainforest Alliance since June 2008.

Yudi Iskandarsyah

Yudi earned his forestry degree from Bogor Agricultural University in 1997 and his Master’s degree in environmental management from Yale University in 2003. He has experience as an auditor in forestry, forest products industry and palm oil plantation in environmental and social aspects.

Social Expert

Pratama Bagus Kurniaji

Kurniaji, graduated from Universitas Gadjah Mada with Forest Resource Conservation major. Experienced in FSC FM/CoC assessments and audits in Indonesia, Thailand and Malaysia and conducting Indonesia mandatory forest certification audit (PHPL) as prerequisite aspect auditor. He has completed FSC FM Lead auditor training in 2016, SAN lead auditor training, Trademark Training for certification bodies and FSC Chain of Custody lead auditor training. Experienced in conducting PRA, SIA, social conflict mapping and environmental monitoring for FMUs in Sumatera, Kalimantan and Papua. Previously worked as forestry consultant that assist FMUs to achieve FSC Certification through TBI coaching scheme. Currently work with Rainforest Alliance as Forest Management and Verification service coordinator that manages clients in Asia Pacificl.

Support Auditor/ Translator

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3.3. Audit detail

Overview of Inspection and sampling method used:

FME system documents were selected and reviewed based on their relevance/applicability to the CW-FM requirements. Likewise, the implementation of relevant management activities was the focus of field inspections. Site selection for inspection focused on the ongoing plantation management activities including working conditions as well as protection and monitoring of defined HCVs and natural forest areas. Community areas with identified conflicts were sampled to verify community consultation and conflict resolution processes.

FMUs selected for evaluation and rationale for selection.

PT. Riau Abadi Lesteri (RAL) concession consist of a single FMU containing three units, Sindotim, Mandi Angin and Tasik Serai. All three units where evaluated during this assessment.

Approach to evaluation of management system:

The audit evaluated RAL’s management system through a review of documents and verifying the consistent implementation of these procedures and policies through interviews with staff, communities and other stakeholders and audit observations of implementation and the impacts of management in the field via samples across the FME. The audit also focused on the implementation of management activities in community conflict areas. The forest concession is classified as a trans migration concession. A large portion of the three units are under conflict with transmigrant communities. Oil palm plantations have been established by local communities on 60% of the unit

Additional techniques used for evaluation (e.g. flyover):

The audit team used maps and collector/GPS application with satellite imagery when conducting field visits. A drone was used to flyover remote inaccessible areas to view activities on mapped HCV areas and buffer retention on protected areas.

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4. STAKEHOLDER CONSULTATION

4.1. Stakeholder consultation process The purpose of the stakeholder consultation for this evaluation was to ensure that the public is aware of and informed about the assessment process and its objectives and to assist the RA-Cert audit team in identifying potential issues in relation to the operations conformance with the Controlled Wood standard. The table below summarizes the extent of the stakeholder consultation for this Controlled Wood assessment process.

Stakeholder Type Contacted

Stakeholders consulted directly or

provided input (#)

NGOs 6

Local Community members 42

Govt agency 12

Other (university, contractors, etc.)

12

Description of the stakeholder consultation activities and methods Consultation with stakeholder involved email notification and face to face meetings or interviews. Following FSC consultation requirements on July 14, 2017 a stakeholder briefing notice (Bahasa Indonesia and English versions) was sent to stakeholders included on RA's Indonesia list, FSC Indonesia’s’ list and the FME's stakeholder list (provided by APP Jakarta). APP was also asked to distribute the notice to local and regional stakeholders without email addresses. Meetings were set up in Pekanbaru, the provincial capital with government agencies, social and environmental NGOs and research organization. Onsite visits were made to neighboring communities, particularly those that have registered conflicts with the FME.

4.2. Stakeholder comments received

The stakeholder consultation was organized to give stakeholders opportunity to comment the activities of the FME in relation to the five controlled wood categories. The table below summarizes the issues presented by the stakeholders and the response of the assessment team to each comment.

CW Category Stakeholder comment RA-Cert response

1. Illegally harvested wood

PT RAL received mandatory certificate (PHPL and VLK) and eligible for self-approval of their annual harvesting plan (RKT), So far, PT RAL does not have problems with meeting all the government requirement including RKL/RPL

The FME meets almost all legal requirements except failure in meeting requirements under 5.1.5, 5.1.6 and 5.1.11. Maintenance of riparian and river buffer is inadequate and this is inconsistent with the management plan as well as

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(environmental monitoring report) report on time.

not meeting the government requirement. See Major NCRs 03/17 and 04/17.

2. Wood harvested in violation of traditional and civil rights

The community of Mandi Angin and Rantau Bertuah have requested the FME to release the conflict areas from the forest zone status.

The FME does not have the authority to release the land from forestry zone status. It is under the authority of Ministry of Environment and Forestry to change the status of a forest zone.

3. Wood harvested from forest areas where high conservation values are threatened by forest management activities

A significant part of APPs plantations (including RAL) occupy peatlands which are drained for the production of Acacia wood pulp. Drainage of peatlands leads to high GHG emissions, increases fire risk, and drainage leads to peatland subsidence resulting in serious environmental, social and economic consequences. Drainage based plantations on peatlands should be rewetted and used in an environmental and economic sensible way involving communities.

PT RAL mostly located in the peat land and under recent government regulation P 17 year 2017, and therefore the company should revise their RKU based on the maps issued by BRG (Peat Restoration Agency). Peat with depth of >3 meter is considered as deep peat and it shall be protected. Riau has been appointed as one out of four KHG priority at national level. It was admitted that there was no official map being released by BRG and BRG Task Force in Riau has not received the updated peat land distribution map. The current available peat map is 1:250,000 scale and Riau Province has been requesting to BRG for the 1:50,000 map.

- Elephant presence in the peat land are not well managed and monitored (inadequate corridor for elephant).

PT RAL has developed peat land distribution map which is prepared before AMDAL was done in 1996. Field investigation during the audit showed that peat distribution is consistent with the map.

The FME has done some monitoring on tiger and elephant and developed a map for elephant’s track.

The FME also put effort to commit to APP’’s Forest Conservation Plan (FCP) although there are limitations in carrying out the conservation program due to high land conflict. More than half of the Mandi Angin unit is composed of peat land and contain HCVs 1.1, 1.2, 1.3, 3, 4.1, and 4.2. However, the area has high conflict with community. This is the reason why the FME cannot fully control the areas. Community activities threaten the HCVs and control from the FME is lacking. Therefore, Major NCR 06/17 and 7/17 are issued.

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- Communication between BKSDA and concession remain minimum. - Social conflict may escalate due to the issuance of P 17 year 2017 especially to RAL where most area inhabiting by community (originally RAL is Transmigration plantation). - PT RAL shows strong commitment to protect environment but not all recommendations from the stakeholder are considered by the company as stakeholder are only involve during the HCVF identification process. - Continuing fragmentation will disturb elephant corridors on the FMU. - There should be research and development for tiger and elephant involving all relevant stakeholders such as BKSDA and universities (not personal engagement).

4. Wood harvested from areas being converted from forests and other wooded ecosystems to plantations or non- forest uses

PT RAL is inhabited by community from transmigration program which has existed long before the company received a license to manage the area for timber plantation. Community perceives that oil palm business is more profitable than other livelihood plantation such as rubber or staple plants such as Acacia ad Eucalyptus. This is the reason behind massive conversion done by local community residing in and near the concession area.

Through interviews and field observations the audit team found that the FME only implements their environmental management and monitoring program for the area within the concession with timber plantations and not for areas occupied by the communities. During field inspections, the audit team found active conversion of natural forest in Sindotim, Tasik Serai and Mandi Angin regions. See Major NCR 8/17.

5. Wood harvested from genetically modified trees

No comments received

6. FME’s stakeholder consultation process

Feedback from stakeholders from surrounding communities:

1. Communication with the FME is directed to PT Arara Abadi (PT AA). Since 2010 the management of PT RAL has been handled by PT AA.

2. There is no clear response from the FME

The three PT RAL units are surrounded by PT AA. PT AA ha a much larger foot print on and engages with the same stakeholders as PT RAL. As both PT AA and PT RAL are APP owned operations, the audit team found that most stakeholders do not distinguish between them.

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with regard to request or inquiry from community about whether the percentage livelihood plantation can be increased to 20%. There is also no clear response to requests such as to normalize the Mandi Angin river, to get permit from the FME so that the power line from national grid can reach the village that will cross through the FME areas.

3. The community of Mandi Angin and Rantau Bertuah village has expressed their request to the FME to release the conflict areas from the forest zone status.

The FME has already developed SOP on grievance mechanism and also has put information about the mechanism in the villages (in Sindotim and Gelombang Unit) but not yet in Tasik Serai Unit. The response from the FME was made verbally and not documented. The audit team verified that the FME failed to document and respond to a small number of requests made by local communities. See OBS 01/17. Regarding the release of forest zone, the FME informed the audit team that they always inform the communities that the process is beyond the FME authority and that the release can only be authorized by the Ministry of Environment and Forestry.