MTCS Certified Deforestation

Transcription

MTCS Certified Deforestation
MTCS Certified Deforestation
An illustration of the misleading sustainablility claims made under the Malaysian Timber Certification System by use of publicly
available satellite imagery
October 2015
Aidenvironment Asia
Jalan Burangrang 18
16153 Bogor, Indonesia
www.aidenvironment.org
MTCS Certified deforestation
Executive summary
Ever since the foundation of its predecessor some 18 years ago, the Malaysian Timber Certification Scheme (MTCS) has been unable to
present to its stakeholders credible maps of the tropical forest that claims to certify as being under sustainable management.
Non-industry stakeholders in Malaysia and elsewhere therefore resort to other means of verification to determine whether sustainability
claims made under the MTCS label are truthful. For this study, a digitalized map of permanent forest reserves (dated 2006) was used as
baseline, adjusted according to scantily available data on changes in forest use and allocation. Free-of-charge software (Google Earth Pro)
was subsequently used to determine where deforestation occurred over the past five years.
This study presents over 30 cases of tropical deforestation in Peninsula Malaysia, which, according to accredited certification bodies, are
part of the MTCS certified forest. Most of the cases are not identified or justified in MTCS audit and/or surveillance reports. In fact, because
the accredited auditors do not use geo-spatial data in their assessments, they certify deforestation as “sustainable”.
Even without advanced geo-spatial data sources and software, this study offers credible grounds to argue that several - if not most - MTCScertified management units had already reached their limit of “allowable deforestation” (5% per 6 years) by mid-2015. This threshold was
introduced in February 2011 by the previous Dutch state secretary Atsma, whom bartered with MTCC to accept this limit in exchange for a
two-year conditional acceptance of the scheme on the Dutch government contract market.
At present, the Dutch state secretaries Dijksma and Manshold propose to fully accept MTCS as a credible guarantee of sustainable forestry.
Such acceptance would defy the reality seen by the public in Malaysia and a global audience who has access to ever more up-t0-date and
detailed satellite imagery, free-of-charge, worldwide.
MTCS Certified deforestation
Contents
Executive summary ......................................................................................................................................................................................... 3
1.
1.1
1.2
1.3
1.4
1.5
1.6
1.7
Kedah .......................................................................................................................................................................................................6
Overview ..............................................................................................................................................................................................................................................6
Bukit Perangin PRF ............................................................................................................................................................................................................................ 8
Gunung Inas PRF ................................................................................................................................................................................................................................9
Pedu and Chebar Besar PRF ............................................................................................................................................................................................................. 12
Gunung Bongsu ................................................................................................................................................................................................................................. 14
Chebar Besar PRF ............................................................................................................................................................................................................................. 15
Koi Moi PRF ...................................................................................................................................................................................................................................... 16
2. Kelantan ................................................................................................................................................................................................. 18
2.1
Overview ............................................................................................................................................................................................................................................ 18
2.2 Sungai Durian PRF........................................................................................................................................................................................................................... 20
2.3 Gunung Rabung PRF ........................................................................................................................................................................................................................ 21
2.4 Ulu Sat PRF .......................................................................................................................................................................................................................................22
3. Terengganu ............................................................................................................................................................................................ 24
3.1
Overview ............................................................................................................................................................................................................................................24
3.2 Besul PRF ..........................................................................................................................................................................................................................................24
3.3 Gunung Tebu PRF ............................................................................................................................................................................................................................. 25
3.4 Hulu Setiu PRF ................................................................................................................................................................................................................................. 28
3.5 Mercang PRF .................................................................................................................................................................................................................................... 30
4. Perak ...................................................................................................................................................................................................... 32
4.1
Overview ............................................................................................................................................................................................................................................32
4.2 Belukar Semang PRF ........................................................................................................................................................................................................................32
4.3 Kenderong PRF .................................................................................................................................................................................................................................33
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4.4
Kledang Saiong PRF ..........................................................................................................................................................................................................................34
5.
5.1
5.2
5.3
5.4
5.5
5.6
5.7
5.8
5.9
5.10
5.11
5.12
5.13
5.14
Pahang ................................................................................................................................................................................................... 36
Overview ............................................................................................................................................................................................................................................36
Berkelah Jerantut PRF ...................................................................................................................................................................................................................... 37
Kelau PRF ......................................................................................................................................................................................................................................... 38
Lakum (Temerloh) PRF ....................................................................................................................................................................................................................39
Berkelah (Kuantan) PRF ...................................................................................................................................................................................................................39
Lesong PRF........................................................................................................................................................................................................................................42
Ibam PRF ...........................................................................................................................................................................................................................................43
Tasik Bera PRF ................................................................................................................................................................................................................................. 44
Lepar PRF ......................................................................................................................................................................................................................................... 46
Chini (Temerloh) PRF .................................................................................................................................................................................................................... 47
Ibam (Temerloh) PRF .................................................................................................................................................................................................................... 48
Kemasul (Temerloh) PRF .............................................................................................................................................................................................................. 49
Sungai Kuak PRF ............................................................................................................................................................................................................................ 51
Som PRF .......................................................................................................................................................................................................................................... 52
6. Negeri Sembilan ..................................................................................................................................................................................... 53
6.1
Overview ............................................................................................................................................................................................................................................ 53
6.2 Triang PRF ........................................................................................................................................................................................................................................ 53
6.3 Kenaboi PRF ...................................................................................................................................................................................................................................... 54
6.4 Pasoh PRF ......................................................................................................................................................................................................................................... 55
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1.
Kedah
1.1
Overview
1
In its audit report for Kedah (created 16 April 2014), SIRIM claims: “with regard to [MTCS] Criterion 6.10, there had been no new issue related to conversion of
the natural forest to forest plantations/non-forest land use.” This statement is not a truthful representation of the situation on the ground.
According to SIRIM’s first audit report (September 2012), the Forest Management Unit (FMU) of Kedah stretched 307,046 hectare (ha). However, as the forestry
department decided to exclude 7,000 ha from the forest reserves certified under MTCS M&C (Natural Forest): Gunung Inas (compartments 4,5,6,7,8,9 & 10),
Pedu (compartments 48 & 50) and Rimba Telui (compartment 1) and Bukit Perangin (compartments 27 & 28), the certified Kedah FMU covers 300,046 ha as of
October 2013. In so far could be ascertained, 3,600 ha of this “Planted Forest” area was already cleared by early 2011.
Based on maps presented by SIRIM in its audit reports, the area to be excluded from the scope of natural forest certification in Kedah is not 7,000 ha but 16,200
2
ha (the total of “Planted Forest” projects as shown on maps in the audit reports). Unless the Planted Forest projects were demonstrably reduced in size, the
certified area should be 290,846 ha.
Secondly, SIRIM did not consider other forestland clearings, some 3,000 ha in total since early 2011, not including clearings in “Planted Forests”. The disparity
between the size of the Planted Forest on map (16,200 ha) and the area reported by the Kedah Forestry Department (7,000 ha) remains unexplained. Taking
19,200 ha as that which should be deducted from the FMU (307,046 ha), 6.3% of the FMU has been cleared since early 2011 or is set for clearance, based on
3
SIRIM’s maps. This implies that Kedah already exceeds MTCC’s “allowable deforestation threshold” of 5% clearance in 6 years by 1.3%.
In 2010, SIRIM’s audit report stated that nine forest areas of 35,567 ha had been proposed for gazettement as PRF, in addition to the earlier cited sized of the FMU
(307,046 ha). It is not clarified where these proposed areas are located. The auditor’s latest report (April 2014) does not show or suggest that these areas have been
1
2
3
SIRIM is one of only two certification bodies accredited to conduct forest management audits under the MTCS. SIRIM is a government agency, whom is accredited by another government
Planted forests are forestry plantations that are initially developed at the expense of natural forests previously subject to selective harvesting.
This study uses February 2011 as the primary reference point as this was the time when State Secretary Atsma brokered his agreement with MTCC. In some cases raised in this report,
reference is made to the best imagery available date prior to that time when imagery for early 2011 was not available.
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added to the FMU. However, three forest reserves shown in SIRIM’s 2010 map, measuring 16,250 ha in total, appear to be de-gazetted (see below). The SIRIM
audits did not account for these degazettements when re-auditing the state in 2012.
Left: de-gazetted forest reserves in Kedah (white boundaries)
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and remaining forest reserves (red boundaries ).
4
The reference map of forest reserves (red boundaries throughout this report) used for this study is not perfectly geo-referenced. By lack of access to alternative, the case studies raised in this
report take this bias into account.
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1.2
Bukit Perangin PRF
Based on the forestland designation map of 2010 presented by SIRIM, Bukit Perangin forest reserve (red boundary) comprises permanent forest (green), some of
which is designated as water catchment forest (blue) and some other functions (red and brown). In 2013, SIRIM only presented a low-resolution map of the MTCS
certified forest reserve, with barely readable coupe numbers:
The map shows only one coupe allocated as “Planted Forest” of approximately 440 ha (orange-brown in the map above right). As of February 2015 the area
allocated for “Planted Forest” had not yet been cleared (blue polygon, below). However, at least 1,100 ha was cleared elsewhere in the forest reserve between
November 2012 and early 2015, among other part of a designated soil conservation area:
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1.3
Gunung Inas PRF
In 2010, SIRIM’s forestland designation map showed Gunung Inas PRF comprises permanent forest (green), water catchment forest (blue) and forest >1,000m
above sea level (pink). In its audit report (created 16 April 2014), the status of over 14,000 ha of the reserve was altered from production forest, water catchment
forest and forest 1,000m above sea level to “Planted Forest” (orange brown, see image below, right):
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As of February 2013, logging roads had already reached less than a kilometer away from the high altitude area of 1,000m a.s.l. Forest clearing of 2,150 ha is
shown for early 2011 (left) and early 2015 (right), below:
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1.4
Pedu and Chebar Besar PRF
Between February 2011 and October 2012, some 270 ha of lowland forest, designated as water catchment forest and certified by MTCS, was cleared right at the
edge of the Pedu water reservoir. In its 2013 audit report, SIRIM flatly accepted the Forestry Department’s proposal to designate ~420 ha to “Planted Forest” post
hoc:
During a filed visit to the Pedu forest reserve in June 2014, it was observed that no efforts were made to restore the area opened up by a state government linked
company. In fact, the area was being burnt for rubber planting (not all ‘haze’ comes from Indonesia!). Travellers that pass the new JKR highway that cuts through
the forest reserve are seriously exposed to risk of landslides:
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The MTCS standard C. 6.10 requires that “Forest conversion to plantations or non-forest land uses (…) does not occur on high conservation value forest areas”.
However, close to the clearance discussed just above, some 30 ha of HCV forest in the Pedu PRF were cleared between April 2011 and May 2012. SIRIM’s 2013
audit report (created 16 April 2014) does not mention the non-compliance:
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1.5
Gunung Bongsu
The Kedah Forestry Department does not appear to exercise effective control over the forest reserves and consequently over 200 ha of forest reserve were lost to
local farmers between February 2010 and February 2013. The SIRIM audit reports do not mention this loss.
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1.6
Chebar Besar PRF
To the south of Pedu, ~1,200 ha of forest was lost in Chebar Besar PRF. The land clearing for rubber plantations commenced mid 2000s (below, left: image for
February 2011 and the situation in December 2014):
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1.7
Koi Moi PRF
Similar to the previous case, the Koi Moi forest reserve that borders Thailand lost 517 ha from mid 2000s onwards (March 2007, below – left and February 2015,
right):
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2.
Kelantan
2.1
Overview
According to SIRIM’s public summary audit report of May 2012, Kelantan’s FMU covered 623,849 ha. In the same month, the auditor created another audit report
that declared the FMU to cover 424,497 ha, a reduction of 199,352 ha (32%). The reason was that the state had embarked on a massive rubber plantation
programme within its FMU. By doing so, the Kelantan Forestry Department completely overhauled its MTCS-certified 2006-2017 forest management plan. Rather
than withdrawing the MTCS-certificate because of evident non-compliance with the MTCS standard, the auditor and MTCC decided to excise the plantation
project area from the scope of the certificate, granting “a general pardon” to the forest manager.
SIRIM’s latest audit report states that land clearing in the plantation project areas has been stopped. This is confirmed by this study, although available satellite
imagery is incomplete. SIRIM also states that “With regard to Criterion 6.10, there had been no new conversion of the PRF to forest plantations/non-forest land
use. Further below, however, we demonstrate that there have still been forest clearances for plantations inside the remaining FMU certified under MTCS (natural
forest).
The case of Kelantan’s rubber plantations has already been well documented. However, what has been disregarded is that none of the MTCS audit reports
verify forest managers’ compliance with forestland designations. In the case of Kelantan, a major change in designation was overlooked by SIRIM. In
its 2013 audit report, SIRIM did not note or question the massive change in forestland designation that brought back some 200,000 ha of protected water
catchment forest (‘tadahan air’) identified in the 2006-2017 FMP (below, left) into the category of production forest (category dark green - below, right; map from
2013 audit report). The rationale for identifying new water catchment areas (light blue, below – right) is not considered by SIRIM. This demonstrates, once again,
that the MTCS auditors use maps as mere illustrations and make no use of the wealth of information contained in the maps that they have access to during their
audits. Consequently, major changes in forest use allocations that directly affect sustainable management are completely disregarded by MTCS
auditors.
SIRIM’s maps suggest that there have been several forestland excisions and also some new forestland allocations in Kelantan, but its 2013 report does not explain
how these decisions came about. The net gain/loss is approximately 7,000 ha loss. Add to this 960 ha of identified natural forest clearance outside the plantation
projects since early 2011, then Kelantan has already accumulated another 1.9% of “allowable deforestation” within MTCS’ 5% threshold since it was granted a
‘general pardon’ for slashing one-third of its MTCS-certified natural forest and for having completely overhauled its forestland use designation without
consequence.
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2.2
Sungai Durian PRF
Evident deforestation (>500 ha) occurred inside Sugai Durian forest reserve (natural forest) after February 2012. “Planted Forest” projects of Kelantan shown in
purple. Image on right: July 2014, clearing polygon also based on image of May 2015:
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2.3
Gunung Rabung PRF
Over 400 ha was cleared in one location in Gunung Rabung between April 2009 (below, left) and October 2012 (right):
Another 30 ha was cleared in one location in Gunung Rabung between August 2011 and February 2013:
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2.4
Ulu Sat PRF
Ulu Sat forest reserve lost 30 ha of due to deforestation between June 2012 and July 2014:
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3.
Terengganu
3.1
Overview
According to SGS [MY] in 2011, Terengganu’s MTCS-certified FMU measured 521,582 ha. In March 2014, the certified FMU (natural forest only) reportedly held
516,696 ha, whilst in February 2015, the certified area was 514,143 ha. The difference between 2011 and 2015 is thus 7,439 ha, or 1.4% of the FMU in 2011. This
does not correspond with the changes reported:
•
•
•
Partial conversion of Merchang PRF into tree plantations: 3,860 ha
Flooding of natural forest in Tembat and Pertuang PRFs: 18,686 ha
Iron mine in Besul PRF (Extension): 2,553 ha.
These three projects cover 25,099 ha in total. They represent 4.9% of the total certified FMU in 2011. In other words, SGS’ data show that Terengganu is close to
reaching MTCS’ 5% ‘allowable deforestation threshold. Comparison of the FMU maps of 2011, 2012 and (undated, 2015 audit report) shows no new forest reserve
gazettements. Meanwhile, SGS did not disclose the apparent excisions of parts of the Rasau Kertih (>3,100 ha), Hulu Setiu (4,200 ha) and Belara (>7,500 ha)
forest reserves (14,800 ha in total). Adding the 800 ha clearance in Gunung Tebu (see below).
Thus, compared to the MTSC-certificate issued in 2011, some 40,699 ha of forestland must be excluded, resulting in 480,883 ha. The reduction (7.8%) of passes
the MTCS 5%-threshold by 2.8%.
3.2
Besul PRF
SGS excluded 2,553 ha from the scope of its MTCS-certification in view of a planned iron mine in Compartment 6 from Besul (Extension). The maps presented to
not clarify where this Compartment is located. SGS issued a Minor CAR for the lack of justification for this mine, as required by MTCS.
SGS did not identify an old (<2008) oil palm encroachment of approximately 80 ha of in the MTCS and FSC-certified Besul forest reserve was converted into oil
palm (bottom left). According to SGS’s maps in its MTCS audit 2014 and 2015 reports, the area remains part of the Besul permanent reserved forest (bottom
right):
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3.3
Gunung Tebu PRF
Between August 2003 (bottom left) and August 2013 (bottom right), more than 800ha of Gunung Tebu forest reserve was cleared, in part after February 2011:
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Not even a riparian buffer zone besides the 15-30m-wide river was spared:
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Yet, according to SGS’s March 2014 audit report (bottom left), the area cleared remains categorized as water catchment forest (below, left) and forest reserve (SGS,
February 2015: below, right):
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3.4
Hulu Setiu PRF
SGS’ maps show that ~5,450ha from the Hulu Setiu PRF was excised. Some 3,600 ha of the forest reserve was cleared, 3,350 ha of which was cleared between May
2012 (image below, left) and August 2013 (image below, right):
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In April 2014, villagers in the region complained about a group of 12-14 elephants ransacking their rubber and oil palm crops since three years. The human5
wildlife conflict is caused by the logging activity in Ulu Setiu.
5
“Penduduk enam kampung kecewa”. Sinar Harian, 24 April 2014.
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3.5
Mercang PRF
SGS reported the scheduled partial conversion of Mercang PRF into tree plantations in its March 2014 report but the same report presented a map (bottom, left)
that did not show the area excluded (3,860 ha). The appropriate map was presented only in February 2015 (bottom, right):
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4.
Perak
4.1
Overview
Perak has an MTCS-certified FMU of 991,436 ha (October 2012), a figure very similar to an earlier audit by SIRIM which tagged the FMU at 991,433 ha in July
2010.
Due to a stakeholder comment, SIRIM stated in its 2013 audit report that Chikus forest reserve (~2,000 ha) was degazetted but the assessor did not adjust the
certified FMU accordingly. Similarly, SIRIM still has to account for the 2,200 ha clearance of Kledang Saiong (Kinta-Majong), which is consistently showing on
maps as part of Perak’s MTCS-certified FMU, even though this area was deforested for plantations prior to May 2011. Additionally, it was found that at least 1,390
ha of natural forest was cleared since early 2011 that SIRIM did not report. Instead it stated in its latest audit report:
“With regard to Criterion 6.10, there has been no conversion of the natural forest to forest plantations or non-forest land uses in the FMU since the previous
recertification audit.”
In reality, Perak’s natural forest FMU was reduced by at least 5,590 ha. This represents 0.6% of Perak’s FMU. MTCC assessor SIRIM failed to account for most of
this loss.
4.2
Belukar Semang PRF
Several sites of deforestation in Belukar Semang were identified, one of which is nearly 670 ha large. They were created between February 2014 and February
2015 but left unidentified by SIRIM:
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4.3
Kenderong PRF
A new highway between Balingan and Gerik triggered new logging operations and also deforestation. A large portion of forest clearance took place in State land
but some 270 ha was lost inside Kenderong PRF between May 2009 and February 2015:
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4.4
Kledang Saiong PRF
Some 450 ha of natural forest was converted to other land use just off Kuala Kansar starting after August 2010 (below, left). Situation as of January 2015, right
below (also note the intensity of selective logging in the surroundings):
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5.
Pahang
5.1
Overview
SGS’ statement (August 2012) that: “There is no conversion occur in the PRF of the Pahang FMU” is demonstrably false and misleading.
According to SGS, in 2010, Pahang’s MTCS-certified area was 1,562,496 ha. In its later audit report (August 2012), Pahang’s certified FMU (natural forest) had
6
been reduced to 1,524,827 ha, to exclude 38,075 ha for plantations in Kemasul (24,043 ha is Kemasul) and Lesong and Remen Chereh PRF (14,032 ha). In
February 2015, SGS reduced the certified area further, to 1,503,314 ha, excluding in total 59,588 ha. Thus, an additional 21,513 ha of natural forest loss for
plantations was taken off the certified area by SGS:
The auditor SGS notes that these conversions have not yet been justified from a sustainability point of view. In view of
forest canopy cover in the largest project areas (Yong, Gunung Benom and Bencah), as seen on satellite imagery, it is
obvious that these plantation projects are not afforestation or forest restoration projects. The forests in these reserves
appear well-stocked with natural forest species.
Between 2006 and 2011, Pahang added approximately 113,000 ha new forest reserves to its FMU. From 2011 onward,
~15,700 ha was added (~8,700 in Nenasi extension and 7,000 in Remen Chereh). Net forest loss in Pahang after early 2011
would be ~44,000 if planned conversion is compensated with newly gazetted reserves. This puts Pahang at 2.8% of its
certifiable deforestation threshold of 5% of the FMU.
However, there are countless cases of forest reserve clearances in Pahang, many of them dating from after early 2011, that
the MTCS auditor did not take into account. Disregarding encroachments prior to 2011, at least 10,280 ha of forest
clearance took place in Pahang’s forest reserves since early 2011 that SGS had not identified or discussed. Furthermore, the
Kemasul forest reserves must be excluded from the scope of the M&C (Natural Forest) assessment, estimated at another
~20,000 ha.
6
Figures do not add up.
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Adding reported and unreported forest reserve clearances for Pahang since early 2011, the state has already reached 4.8% of the allowable deforestation threshold
of 5%.
5.2
Berkelah Jerantut PRF
Unobserved by SGS, Berkelah (Jerantut) saw 1,155 ha of the reserve heavily logged and degraded by March 2014, most likely in preparation for clearing for oil
palm, which surrounds the forest reserve in the locality:
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5.3
Kelau PRF
Kelau PRF lost 730 ha since ten years as result of de-gazettement in two sites. The northern clearing (250ha) was fully cleared after May 2012. The southern
clearing had been fully converted to an oil palm plantation and workers’ housing by July 2014. Smallholder oil palm and rubber have encroached in other parts of
the forest reserve for many years. SGS’s maps (June 2012 and an undated newer map) show that these two sites had been degazetted from the forest reserve:
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5.4
Lakum (Temerloh) PRF
By September 2012, forest clearing had already commenced in Lakum (Temerloh) forest reserve (below, left). By July 2014, some 1,675 ha had been fully cleared
(below, right). The clearing is surrounded by oil palm, the most likely land use in said clearing. According to SGS’ audit reports and maps, the clearing is still part
of the MTCS certified natural forest.
5.5
Berkelah (Kuantan) PRF
Over 2,700 ha of Berkelah Kuantan PRF was cleared over the past 10-15 years, mostly in recent years. In its assessment reports, SGS did not identify the natural
forest clearings:
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Site 1 (August 2011 – March 2014):
Site 2 (2011 – September 2014), below:
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Berkelah Kuantan PRF appears one of the worst managed forest reserves in Pahang. Several of its hilltops have since long been denuded suggesting that the area is
unsuitable for forestry but heavy logging continues in other parts of the reserve (images below: March 2014):
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5.6
Lesong PRF
SGS reported that (part of) Lesong PRF is scheduled for conversion into tree plantations. The auditor did not identify an encroachment (>~50ha) in the reserve
that occurred between June 2010 (below, left) and September 2014 (below, right), very likely for oil palm as this crop surrounds the reserve in this locality:
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5.7
Ibam PRF
Ibam is divided in three reserves (Temerloh, Rompin and Kuantan). By January 2012, these reserves had lost at least 2,100 ha due to various small conversions
(white lines) for mining, housing and plantations:
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5.8
Tasik Bera PRF
Tasik Bera, partially a RAMSAR site since the 1970s, is a relatively new forest reserve (2007). It is known for its seasonal wetlands and also for its countless
“encroachments”. Many of these were in fact illegal agricultural lots prior to the gazetttement of the forest reserve. Nearly one-third (11,000ha) of the reserve is
affected by agriculture. The transfer of management responsibility from the Wildlife Department to the MTCS-certified Forestry Department has made no
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difference: there are still new forest clearings in the forest reserve, among which a ‘brand new’ clearing (50ha) created between March 2014 and March 2015
(below, right):
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5.9
Lepar PRF
There are two encroachments in Lepar PRF (700 ha). The largest has been planted with rubber prior to 2011 and was replanted with rubber thereafter. A new
clearing of 200 ha was created between January and August 2012 further south. The auditor for MTCC did not observe the encroachments.
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5.10
Chini (Temerloh) PRF
Between March 2014 and March 2015, some 500 ha of Chini (Temerloh) PRF were fully cleared in several localities, likely for oil palm, which borders the forest
reserve. The encroachments were not identified by SGS:
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5.11
Ibam (Temerloh) PRF
Again, unnoticed by the MTCS-auditor, Ibam (Temerloh) reserve lost 140 ha, likely due to oil palm encroachment, between March 2014 (bottom, left) and March
2015 (bottom, right):
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5.12
Kemasul (Temerloh) PRF
Kemasul PRF has two sub-units: Bentong and Temerloh, and both have extensions. Jointly they measure about 47,000 ha. By July 2015, the bulk of these reserves
had been cleared, apparently for rubber. SGS (February 2014) excluded 24,043 ha from the MTCS (Natural Forest) certificate and another 443 ha was excluded in
its 2015 report. The question arises whether SGS has now accounted for all natural forest loss in the Kemasul forest reserves. Unless there is evidence that natural
forest will be set aside for selective logging, we forecast that another ~20,000 ha from the Kemasul reserves will (have to) be excluded from the MTCS
certificate.
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5.13
Sungai Kuak PRF
Over 1,000 ha in Sungai Kuak forest reserve was lost between May 2010 and March 2014:
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5.14
Som PRF
About 780 ha of Som forest reserve was cleared between February 2010 and February 2015:
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6.
Negeri Sembilan
6.1
Overview
According to SIRIM’s audit report of 2011, the Negeri Sembilan FMU covered 155,531 ha, which was slightly revised to 154,577 ha in 2012 due to digitalization of
maps at federal level. The auditor states in its 2012 report and 2013 surveillance report: “With regard to the implementation of the instruction related to Criterion
6.10, there has been no new conversion of the natural forest to forest plantations or non-forest land use since the second surveillance audit in 2011.”
The natural forest conversions taking place in the state after early 2011 are estimated at 3,500 ha (and ongoing). This loss represents 2.3% of the certified FMU,
which is still below MTCC’s “allowable deforestation” threshold but SIRIM has not yet account for this forest loss.
6.2
Triang PRF
At least 3,700 ha of Triang forest reserve was been cleared by February 2014 (below, left), of which at least 1,700 ha after May 2011 (below, right):
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MTCS Certified deforestation
6.3
Kenaboi PRF
By February 2014 (right image below), at least 4,400 ha of natural forest was cleared in Kenaboi forest reserve, likely starting early 2011, of which 1,000 ha was
cleared after May 2011 (left image below):
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MTCS Certified deforestation
6.4
Pasoh PRF
The globally renown Forest Research Institute Malaysia (FRIM) lost 900 ha of its research site to conversion, 800 ha of which was cleared after May 2012:
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MTCS Certified deforestation
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MTCS Certified deforestation
Disclaimer
The digitized baseline map for forest reserves in Peninsula Malaysia used in this analysis dates from 2006. The map contains about 460 forest reserve units. The
base map is not perfectly geo-referenced. This bias is taken into account in the analysis. Figures presented should be considered reasonably reliable in the number
of ‘000. Maps presented in the various SIRIM and SGS audit reports were used to verify and update the 10-year old map, where possible: MTCS certifiers
continue to publish maps that are unnecessarily out-of-date, often have unreadable legends and typically do not reflect the true area certified under MTCS M&C
(natural forest).
The analysis focused on forest clearance from February 2011 onward, considering that it was then that State Secretary Atsma first reached agreement with MTCC
regarding forest clearance in MTCS-certified forest reserves. For clarity’s sake, the analysis disregards the moment when the certified management unit may have
been certified under MTCS’ standard.
Although the term Forest Management Unit (FMU) is occasionally used in this report, it is important to note that it remains vague at best what comprises an FMU
in Peninsula Malaysia.
The analysis did not:
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Map out all deforestation inside forest reserves because high-resolution satellite imagery for February 2011 to present was not available for all sites. The
figures presented underestimate of actual deforestation;
Measure selective logging;
Include forest conversion that evidently took place before February 2011;
Measure all of the numerous small-scale encroachments by local farmers and plantation companies within forest reserve boundaries;
Consider very small forest reserves;
Measure mining pits, highways and electricity lines inside forest reserves;
Weigh in forest reserve excision and/or de-gazettement when maps and reports produced by accredited assessors shed no light on such developments;
Cover Selangor and corporate owned FMUs in Sabah and Sarawak.
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