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a study conducted by

The Tropical Forest Foundation-Indonesia

for

FSC Global Development GmbH

August 29, 2016

REGARDING REDUCED IMPACT LOGGING, SUSTAINABILITY,

AND

FOREST STEWARDSHIP COUNCIL CERTIFICATION

Summary and Recommendations

The increased prominence of FSC certification activities in Indonesia, has prompted the FSC to pose a number of questions related to the adoption and relevance of reduced impact logging, the response of the Indonesian forests to logging activities, and the potential for alternative logging technologies. A full answer to these questions will require field data collection, however, in this desk study, the Tropical Forest Foundation, provides an overview based on more than 16 years working with the forest concession industry in Indonesia A discussion of the issues underlying the basic questions posed by the FSC suggests further studies which could be implemented to bring greater clarity to the preliminary answers presented here. First of all, an audit against the RIL standard should be conducted on all FSC certified concessions. This should be followed by a training workshop for all certifying bodies and lead auditors operating in Indonesia, to ensure a uniform perception of both the RIL standard and the related FSC criteria and indicators. As the FSC certified concessions increase, there is a growing sense that diverging interpretations in how different certifying bodies and auditors evaluate logging activities and logging impact, places the credibility of the FSC certification at risk. On the question of response of the forest to logging; too little is understood about growth rates. Considerable data is being collected by individual forest concession. This data needs to be collated and analyzed to provide a robust basis on which FSC auditors can make their evaluations during a certification assessment.

1 Introduction

The Tropical Forest Foundation (TFF) established a presence in Indonesia in January 2000 with a self-appointed mandate to promote the adoption of reduced impact logging (RIL) as a more sustainable management strategy in the tropical forests of Southeast Asia. More than sixteen years later, the TFF name has become widely synonymous with RIL, but that is by no means the only achievement of the TFF-Indonesia. In January, 2010, TFF became the first organization to actively support the certification goals of The Borneo Initiative (TBI) and has since then, directly assisted 10 concessions managing over 1.3 million hectares of forest in Indonesia and Papua New Guinea to achieve FSC certification under TBI’s certification support program. TBI’s extraordinary success as a certification support program in Indonesia and, TFF’s achievements under this program, has caught the attention of the Forest Stewardship

Council (FSC) and prompted questions related to the promotion and adoption of the RIL management strategy as it relates to sustainable forest management and the progression to FSC certification.

2 Terms of Reference

The terms of reference for this paper relate to questions about the adoption of reduced impact logging (RIL) as a management strategy and how this relates to forest certification. Specifically, this paper will elaborate answers to the following questions that have been put forward by the FSC.

1. Is RIL really being adopted in FSC certified concessions? 2. How does the Indonesian forest respond to logging? 3. Is there an opportunity for improving current harvesting practices?

A comprehensive answer to these questions will require substantial further field data collection not mandated under this study, consequently, this paper will elaborate on these questions based on information collected during the years of TFFs work in Indonesia.

3 Adoption of RIL as a management strategy.

The idea that the forest concession system in the tropical forests is little more than an unsustainable logging operation, has some merit. Concerns regarding the sustainability of logging in the tropical forest, is a significant part of the rationale for promoting and adopting practices which are less destructive, hence the concept of RIL which should be considered as a precondition for FSC certification.

3.1 Defining RIL

The concept of RIL evolved in the late 1980s around the recognition that conventional regulatory frameworks and practices in tropical selection harvesting systems, often result in unsustainably high levels of forest degradation. The origin of TFF and its focus on RIL, can be traced to a 1989 Smithsonian Tropical Forestry Workshop where various industry, conservation, and scientific institutions proposed the establishment of a training institution to combat the negative publicity of an NGO led campaign to boycott the importation of tropical timber products to North America. This coming together of concerned organizations, led directly to the creation of TFF’s first regional program in Brazil in 1990. The Brazilian organization1 was established to promote, train, and research improvements in forest operations built around the concept of RIL. The Brazilian program of TFF began training improved harvesting techniques and has evolved into an extensive program of training in sustainable forest management as it expanded its outreach to all sectors of the Brazilian forestry community.

1 Fundacao Floresta Tropical (FFT)

In Southeast Asia, the first attempt to study and define RIL, was undertaken by CIFOR2 with the publication of a set of guidelines3 in 1998 (Sist, et al 1998). These guidelines were primarily intended to define how CIFOR was going to implement an ITTO funded, comparative study of RIL in the Inhutani II concession in Malinau, East Kalimantan. Although widely cited as reference for RIL, the guidelines never received much attention from the concession industry in Indonesia due to their general nature. TFF established a presence in Indonesia in January, 2000, through a Memorandum of Understanding with CIFOR and APHI4. During its first year of building up a training program in Indonesia, TFF also co-organized and co-sponsored the first international conference on RIL held in Kuching, Sarawak in late February 2002 (FAO-APFC, 20025). It soon became apparent that a clearer definition of RIL was needed to guide TFFs programs which had expanded into Brazil, Indonesia, Guyana, and Gabon. After two years of intensive consultation with leading researchers and TFFs regional programs, TFF-International released a generic standard6 for RIL which was intended to be a quality reference for timber harvesting procedures and techniques in natural tropical forests. Simultaneously, TFF-Indonesia, developed a country specific standard for RIL and a series of five technical manuals to guide the training and adoption of RIL in Indonesia. These manuals are the reference texts which define TFFs definition of RIL in the context of the Indonesian regulatory framework. The manuals7 are the ‘textbooks’ for TFFs training program and are provided to participants of the appropriate training modules as reference material.

2 Center for International Forest Research, a member of the CGIAR group of research institutions. 3 Plinio Sist, Dennis Dykstra, Rober Fimbel, 1998, “Reduced-Impact Logging Guidelines for Lowland and Hill Dipterocarp Forests in Indonesia”. 4 APHI (Association of Indonesian Forest Concession Holders) 5 FAO-APFC, 2002, “Applying Reduced Impact Logging to Advance Sustainable Forest Management”, a publication of FAO-APFC International Conference Proceedings, 26 February to 1 March, 2001. 6 “Tropical Forest Foundation Standard for Reduced Impact Logging”, TFF-STD-RIL-2006, published June 28, 2007; revised October 19, 2007 (V.1.1) 7 The ‘procedures’ manuals for RIL in Indonesia, can be downloaded as PDF files from www.tff-indonesia.org in English and Bahasa Indonesia. Hard copies can be purchased from TFF-Indonesia.

The TFF procedures manuals define RIL and serve as training texts and reference materials for practitioners of RIL.

3.2 Indonesia criteria and indicators of RIL

TFF’s Indonesian standard for RIL is rooted in the principles developed at the international level and grounded in Indonesia’s forest regulations that a forest concession must adhere to as a condition of its license.

Development of the Indonesian standard and the defining criteria and indicators (C & I), presented a substantial challenge for TFF. Initial thoughts on setting benchmark values for impact parameters had to be abandoned when it became obvious that forest management situations in Indonesia contained too many variables thus resulting in an unmanageable variety of outcomes. Instead, it was acknowledged that RIL should minimize impact while at the same time optimizing profitability within the constraints of the forest regulations. Consequently, a series of easy to evaluate proxy indicators were incorporated into the C&I. These indicators were selected as being preconditions for minimizing impact regardless of the individual site condition or management configuration.

TFF’s message to forest concessions has been both simple and clear: adoption of RIL is cost effective, it save money, and it reduces impact.

Initially, TFF cited the example of TFFs Brazilian program, Fundacao Floresta Tropical (FFT) which clearly demonstrated major cost savings that could be gained through the adoption of RIL (Holmes, et al)8. As TFFs training program in Indonesia evolved, controlled studies, which compared selected financial and impact parameters of conventional versus RIL logging systems, were increasingly being integrated into the TFF-Indonesia training program. The financial advantages of selected operational trials have been published in

8 Holmes, Thomas P., Geoffrey M. Blate, Johan C. Zweede, et al, “Financial Costs and Benefits of Reduced Impact Logging in the Eastern Amazon”

RIL Training Program

Module#1 Contour and Tree Position Mapping. Starts with forest inventory required by MoEF regulation and teaches field and office procedures for contour and tree position mapping based on ground surveys. Includes use of GPS, GIS, manual and computer assisted mapping, etc. Requires concession staff to continue mapping +/- 100 ha area as a basis for the second training input.

Module#2 RIL Planning and Operations. Once the operational area maps produced as an output of the Module#1 have been determined to be of sufficient accuracy, the second training can begin. This teaches the basics of planning, interpretation and use of maps for the creation of a detailed logging plan, and then goes on to initiate logging activities in the study area. Development of operational, environmental, and utilization standards is crucial. Concession company is required to complete logging according to the RIL standard. This module can also be expanded to include an operational research trial.

Module#3 Deactivation, monitoring, evaluation and

management considerations for RIL An evaluation is carried out in the area logged as a follow-up to Module#2. This can be of varied complexity depending on the objectives of the entire training program. Management considerations are crucial and focus on the establishment of standard operating procedures, delegation of responsibility, and the institutionalization of job functions to ensure adoption of all aspects of the RIL system.

Roads Module Provided on special request for concessions wishing to improve road system planning, location, construction, and maintenance of forest roads and related forest engineering functions.

various TFF “Reduced Impact Logging and Certification” newsletter and can be downloaded from www.tff-indonesia.org. This approach has proven successful not only in convincing individual concessions to adopt RIL as a management strategy but also at pulling in an ever expanding request for RIL training from concessions across Indonesia. The RIL standard (Appendix I) developed by TFF-Indonesia, consists of 13 criteria and 33 indicators which are designed to cover all aspects of a selective logging operation. This standard is used to define the elements of an RIL management system and is used to evaluate performance, identify training needs, and monitor progress of a company which is in the process of adopting RIL. Indicators are evaluated using a score of 0 to 5. Although all indicators are required, some are considered more important than others and have been assigned a weight between one and five with the higher value being the most significant. The result of this evaluation is a score which measures RIL adoption of the standard expressed as a percent of the total maximum possible score (Appendix II).

3.3 RIL and FSC certification

TFF-Indonesia’s client base in the forest concession industry, has consistently numbered between 30 to 40 with new concessions joining TFFs program while others dropped out or graduated out of the training program. Availability of funding to conduct RIL training, has always been the primary constraint for a wider engagement with the industry.

Forest concessions have tended to be “NGO shy”; some because they wish to avoid scrutiny of their poor social or environmental performance and others because they have been unfairly attached by overly zealous NGOs. It has been TFFs consistent experience that a RIL training program which conveys benefit to the management of a concession, builds trust and confidence and leads to broad-based improvements in the way the concession company manages its forest.

As world markets have increasingly focused on issues of legality and sustainability, particularly aimed at tropical timber concessions, export industries began to realize the advantages of active engagements with the NGO community on issues of legality verification and forest certification. This ‘market’ pressure has been particularly effective in stimulating change since the Indonesian forest industry is built primarily on export to global markets.

TFFs first venture into direct certification assistance activities began in 2003 in partnership with Form International, a Dutch consulting company. TFF provided guidance, training, and management assistance to two forest concessions in Central Kalimantan under a project titled ‘Improved Sourcing of Certified Timber Products’ funded by the Dutch Government. The project proved highly successful with the two companies9 achieving FSC certification in 2005 and 2007. Both companies had undergone comprehensive RIL training by TFF prior to this engagement and both companies continue to request RIL audits by TFF on an annual basis as a way of keeping concession staff focused on the challenges of maintaining the FSC certification.

9 PT Erna Djuliawati – 184,206 ha and PT Sari Bumi Kusuma – 147,600 ha.

The relationship between RIL and certification is an issue which has been posed as a direct question by the FSC. TFF explored this relationship in an article published in the “Reduced Impact Logging and Certification Newsletter in December 201110 and found that out of the 22 forest concessions that had undergone RIL training by TFF, 17 (78%) had gone on to pursue FSC certification. In a 2003 paper11 delivered at a ‘Certification Watch’ conference in Quebec Canada, TFF presented a paper which referenced the specific criteria and indicators in the FSC standard and how they directly pertained to TFFs RIL standard. Although the FSC standard has undergone some revisions, the linkages between the RIL concept and the FSC standard, remains unequivocally valid.

TFF uses the RIL C&I auditing tool to establish the adoption baseline and define training needs for companies that request RIL training support. The auditing tool is then used to monitor progress, usually within the context of a funded training program. TFF does not normally conduct the RIL audit and scoring with concessions that have achieved FSC certification unless the concessions specifically request it. Table 1 has been compiled for natural forest concessions which are either FSC certified or engaged in TBI’s certification support program. This is a partial list of concessions which are FSC certified or ‘on-the-road’ to certification. Not included in this list are small community run or Perhum Perhutani management units (mostly teak plantations) or swamp forest and mangrove concessions. Of these 22 certified concessions managing 2,626,427 ha of dryland forest, only 4 have never received RIL training. When conducting an RIL audit, TFF considers 80% adoption as a ‘passing grade’. Since TFF does not conduct RIL audits routinely, it is not possible from this table to fully evaluate the extent of RIL adoption by certified forest concessions. To evaluate this relationship more effectively would require RIL audits of all FSC certified concessions. Collaborative information suggests that the logging standards in perhaps four or five of the certified concessions would not receive a passing grade if audited against the RIL standard.

10 “RIL and Certification” published in Vol. 15, December 2011 of TFFs ‘Reduced Impact Logging and Certification Newsletter’. 11 Klassen, A.W., 2003, “Reduced Impact Logging and Certification”, Certification Watch, Quebec City, Canada.

Table 1 Natural Forest Concessions FSC Certified or engaged in the certification process (not including plantation or community managed units)

12 SILIN is the acronym for ‘intensive silvicultue with line planting’.

Company

Area

(ha)

Location

Most

Recent

RIL Audit

RIL

Adoption

Score (%)

Year FSC

Certified

Comments

A score of 80% or better is considered by TFF as ‘substantial’ adoption of RIL. A score of 23% is considered minimum compliance with MoEF regulations.

RIL Training

PT Erna Djuliawati 184,206 C. Kalimantan 2016 98.2 2005 TFF - SILIN12 Yes

PT SBK (Katingan) 147,600 C Kalimantan 2015 93.1 2007 TFF - SILIN Yes

PT Intraca Wood 145,110 N. Kalimantan No audit - 2012

Previous suspension for poor logging; second pass

No

PT Sarmiento Parakanca T. 216,580 C. Kalimantan 2015 88.4 2011 TFF - SILIN Yes

PT Suka Jaya Makmur 171,340 W. Kalimantan 2009 70.0 2010 TFF - half SILIN Yes

PT Roda Mas Timber 69,620 E. Kalimantan No recent audit

- 2012 TFF - first and second pass Yes

PT Belayan River T. 97,500 E. Kalimantan No recent audit

- 2011 TFF - first pass Yes

PT Narkata River T. 41,540 E. Kalimantan No recent audit

- 2011 TFF - second pass Yes

PT Indexim Utama 52,480 C. Kalimantan 2015 94.2 2013 TFF - second pass Yes

PT Gema Hutani Lestari 148,450 S. Maluku No recent audit

- 2013 TFF - second pass Yes

PT Dwima Jaya Utama 127,300 C. Kalimantan 2016 84.0 2012 First pass Yes

PT Telegabakti Persada 63,405 N. Maluku No recent audit

- 2016 TFF - first pass Yes

PT Bina Balanta Utama 298,710 Papua 2014 39.5 2016 TFF – first pass Yes

PT Kemakmuran Berka T. 82,810 E. Kalimantan No audit - 2012 First pass No

PT Ratah Timber 97,216 E. Kalimantan No audit - 2013 Second Yes

PT Carus Indonesia 72,100 C. Kalimantan 2016 82.0 2014 First pass Yes

PT Intracawood 145,110 N. Kalimantan No audit - 2012 Second pass No

PT Gunung Gajah Abadi 74,980 E. Kalimantan No audit - 2015 First and second pass No

PT Wijaya Santosa 130,755 Papua No audit - 2016 First pass No

PT Wanasokan Hasalindo 49,000 W. Kalimantan 2014 77.3 2013/CW

First and second pass Yes

PT Sari Bumi Kusuma Delang 41,445 W. Kalimantan 2014 63.6 2013/CW

Second pass Yes

PT Wapoga Mutiara 169,170 Papua 2014 23.8 2016/CW

First pass Yes

Totals 2,626,427

Natural forest concessions implementing certification action plan

PT Rizki Kasida Reana 55,150 E. Kalimantan No audit - -

These natural forest concessions are enrolled in the TBI certification support program.

No PT. Inhutani I – Meraang 70,700 E. Kalimantan No audit - - No PT Wanabhakti Persada 44,402 E. Kalimantan No audit - - No PT Aditya Kirana Mandiri 42,700 E. Kalimantan No audit - - No PT Utama Damar Indah 49,250 E. Kalimantan No audit - - No PT Karya Lestari 49,123 E. Kalimantan No audit - - No PT Inhutani II – Malinau 29,040 N. Kalimantan 2015 32.0 - Yes Yes PT Graha Sentosa Permai 44,970 C. Kalimantan 2014 10.4 - Yes PT Hanurata 234,470 W. Papua No audit - - Yes PT Multi Wahana Wijaya 107,740 W. Papua No audit - - No PT Mitra Pembagunan G. 83,950 W. Papua No audit - - No PT ASCO Prima Nusantara 171,270 Papua No audit - - No PT Sumalindo Lestari IV 63,550 E. Kalimantan 2015 35.0 - Yes

3.4 FSC understanding of RIL

Currently there are six FSC accredited certifying bodies operating in Indonesia. Although all are to varying degrees, acquainted with the RIL standard, individual auditors may not be or, may often lack the practical experience to accurately evaluate the physical attributes of a logging operation. The result may be a passing grade for certification which is not consistent with FSC or RIL norms. Through the adoption of the Harmonized FSC-STD-IDN-01-01, FSC has gone a long way to ensuring uniform evaluation and reporting. However, there is still a pressing need to more formally acquaint FSC certifying bodies and the individual auditors which they recruit, with the RIL standard and how it relates to the principles, criteria, and indicators of the FSC standard, particularly as it pertains to evaluation of logging impact. This could be easily accomplished with a RIL familiarization workshop which would not only look at the RIL standard, but also cover evaluation of the physical aspects of a forest harvesting operation. Failure to ensure uniformity in the way auditors and CBs evaluate a logging operation will ultimately lead to a weakening of the FSC standard.

3.5 Ministry of Environment and Forests view on RIL

A positive outcome of the MoE engagement in the FLEGT13 legality verification process, has been the decision to adopt a mandatory certification requirement for all natural forest concessions14. This requirement, is implemented under the authority of, KAN15, an independent Government standards setting body, which has developed an accreditation system under which qualifying consulting groups conduct audits against the MoEF sustainable forest management standard. Although the ownership of the sustainable forest management standard resides with the MoEF, the responsibility of overseeing and implementing the auditing process falls under the jurisdiction of KAN and it’s accredited auditing firms. This concept is structured similarly to independent certification schemes such as the FSC and should provide a sound basis of supervising the performance of forest concessions. Concession companies pay for the audit and are rated as “poor”, “average” or “good” by the certifying body. Sanctions can be applied to the annual harvesting approvals if the score is “poor”. An “average” score will require that all approvals of annual cutting permits are processed and approved by the Provincial Dinas Kehutanan, while a score of “good” will entitle the concession to a ‘self approval’ process which applies to the approval of the 100% inventory, the annual cutting permit approval process, and the filing of the bi-monthly production reports.

13 Forest Law Enforcement , Governance, and Trade is a program initiated by the European Union. 14 Pengelolaan Hutan Produksi Lestari. Most recent regulations concerning performance of sustainable forest management and timber legality set out in P.30/MenLHK/Setjen/PHPL,3/3/2016. 15 Komite Akreditasi National

Oversight of this process is left largely to the NGO community. It has been frequently observed that actual field performance by a forest concession bears little relationship to the final audit evaluation. Failure to implement regulatory requirements such as the 100% inventory or ‘reduced impact logging’ in part or in whole, frequently results in a score of ‘good’. Such inconsistencies, if not corrected, risk undermining the credibility of the entire PHPL system. Reduced Impact Logging (RIL) is directly referred to in the regulation defining the PHPL standard. Four indicators mention RIL, however, the reference is of a very general nature and lacks definition or implementation guidelines, hence concession companies do not know what is required of them and KAN accredited auditors have no technical guidance on how to evaluate compliance with the indicators at the field level. Although the MoEF has paid ‘lip service’ to the concept of RIL as a necessary part of sustainable forest management, the lack of clarity in the Ministry’s guidelines and auditing protocols, adds little to larger efforts to promote adoption of RIL practices.

3.5 RIL and Carbon

While forest certification has provided a well understood, clear market related additional incentive for companies to adopt RIL practices, climate change considerations still have not had an impact on influencing concessions behavior. However, there are indications that this could change in the near future. The Nature Conservancy (TNC) has developed base line CO2 emission levels for the logging activities of timber concessions in East Kalimantan. A baseline study16 of nine concessions was used to establish baseline emission levels for a ‘business as usual’ scenario. A methodology for sampling and calculating emissions has been developed and has now been approved under the Verified Carbon Standard (VCS). This methodology17,18 is about to be field tested at an operational scale for companies that are adopting the TFF standard for RIL. If successful, additional carbon retention due to adoption of RIL, could then be used as carbon credits to be sold on the voluntary carbon market or to be used in national or regional accounting of emission reductions. TFF will be the implementer in the first two major field trials of this methodology beginning in the last quarter of 2016.

4 Forest response to logging. The Dipterocarp forests of SE Asia are widely considered to be the most resilient and easy to manage tropical rain forests of the world. 16 Bronson Griscom, Peter Ellis, Francis Putz, 2014, “Carbon emissions performance of commercial logging in East Kalimantan, Indonesia”, Global Change Biology (2014) 20, 923-937. 17 The Nature Conservancy & TerraCorbon, 2016, “Methodology for improved forest management through reduced impact logging”, VCS Methodology VM0035. 18 The Nature Conservancy & TerraCorbon, 2016, “Performance Method for Reduced Impact Logging in East and North Kalimantan,” VCS Module VMD0047.

4.1 Characteristics of the forest and landscape

Two broad categories of forest lands exist in Indonesia: swamp forest and dryland forest. Discussions regarding regeneration, sustainability, and logging technology refer to the dryland forest category.

4.2 Logging impact

Tractor logging produces high levels of impact, particularly if not carefully planned and controlled. A crawler tractor pushing its way through the forest destroys everything in its path including regeneration. In developing its RIL standard and training program, TFF places a great deal of emphasis on the need for good planning of the extraction network and tight control of the extraction process. In an comparative RIL study in 199619 in the timber concession of PT Sari Bumi Kusuma, it was found that soil disturbance in the control area was 6.4% of the total area logged versus 4.2% in the RIL area even though a higher volume per hectare was extracted from the RIL area. The comparative research conducted by CIFOR20 in 1997/98 found that skid area in the conventional logging area was 18.6 m2/m3 extracted versus 8.6 m2/m3 extracted in the RIL area, a result consistent with other similar studies elsewhere. Over the years, TFF has conducted comparative studies in RIL in partnership with collaborating forest concessions. Soil disturbance was one of the main impact parameters used to compare RIL with conventional logging. The results were consistently in line with the findings of the CIFOR study and the earlier study in PT Sari Bumi Kusuma. Many of these studies are highlighted in the TFF RIL and Certification Newsletters which are posted on the TFF website, www.tff-indonesia.org. Logging intensity under the Indonesian selection system (TPTI21) normalyl resulted in a felling intensity of 5 to 7 trees per hectare while the minimum diameter limits were set at 50 and 60 cm for production forest and limited production forest respectively. In 2009, the Ministry reduced the minim felling diameter to 40 and 50 cm. Independent logging concessions still tend to harvest to the higher diameter limit since the open log market discounts the value of smaller diameter logs, sometimes below production cost. However, vertically integrated companies have increased their felling intensity, often harvesting 15 or more trees per hectare.

4.3 Regeneration and growth

19 “Report on an Operational Logging Trial and the Evaluation of the Harvested Stand”, A.W. Klassen, 1996, NRMP Report No.70, ARD/USAID. 20 “Reduced-Impact Logging in Indonesian Borneo: Some Results Confirming the Need for New Silvicultural Prescriptions”, Plinio Sist, Douglas Sheil, Kuswaa Kartawinata, and Hari Priyadi, 2002, Technical Report Phase 1 1997-2006, ITTO Project PD12/97. 21 Tebang Pilih Tanam Indonesia.

When Indonesia began the process of industrializing its natural forest estate, very little was known about increment and growth requirements of most of the Indonesian species. One of the most basic assumptions underpinning policies for regulating the annual harvest, was the assumption that trees in the natural forest will put on an average increment of 1 cm per year and that the forest will accrue a net additional volume of 1 cu.m. per hectare per year. To verify the validity of this assumption, forest concessions were required to establish a six hectare series of clustered permanent sample plots for every five year logging block. These series of permanent sample plots were usually located in areas where little disturbance had occurred and were consequently ill suited for monitoring forest response to logging. Annual measurements had to be made by the concession and the data had to be submitted to Litbang22 for processing. Most of this data remains ‘unprocessed’. Forest concession companies who have pursued FSC certification have been forced to do their own basic analysis of their permanent sample plot data to justify their rate of harvest and a few researchers have examined some of the Libbang data. When taken as an aggregate of all species, growth data has usually averaged under the assumed 1 cm. per year, however, it has also been noted that some of the major commercial species have growth rates double the assumed average. The forests of Sumatera, Kalimantan and parts of Maluku and Sulawesi are dominated by species belonging to the Dipterocarpacea family while the forests of Papua have a totally different species mix. Dipterocarps produce abundant winged seeds every 5 to 6 years in a large-scale fruiting referred to as a ‘mast’. Regeneration on the forest floor is usually abundant but does not grow well until a disturbance opens the canopy. Established regeneration responds quickly to light with growth

increments of one to two meters in height within four to five months of logging. The growing interest in forest certification has also brought about the need to find more definitive answers on how the forest responds to logging. As a certification coach for many of the currently FSC certified concessions, TFF has encouraged forest concessions to establish

permanent sample plots randomly located in recently logged areas which are more

22 Penelitian dan Pengembangan (Litbang), Research and Development Department of the MoEF

New Meranti regeneration following a periodic ‘mast’ of the Dipterocarp forest.

Dense regeneration of Meranti sp. showing >1.5 meters of growth four months after logging in the Belayan River Timber concession, E. Kalimantan

A 19 year old stand of white and red Meranti in the SBK concession, Central Kalimantan.

representative of the logged over condition. Although substantial data is now available, it is still in the hands of the individual concession companies and would benefit from a consolidation and analysis. Analyzing such data across a selection of concessions and forest conditions, should be a priority of the FSC certification system. An analysis of the SILIN system practiced in the concession of PT Sari Bumi Kusuma is the subject of a recently completed PhD study by Indonesian researcher Ruslandi. Data suggests that growth rates exceed 2 cm per hectare for the planted and natural regeneration. A summary of the study will be available soon.

4.4 Silvicultural models and their implications.

With the introduction of alternative silvicultural systems in 2009, diameter limits were reduced to 40 and 50 cm for the two main forest categories, and the rotation cycle was shortened to 30 years. The TPTI system23 was reduced to 7 steps by eliminating most of the post harvesting requirements. The scientific validity for the fundamental changes to diameter limits and rotation cycle have not been verified but were instituted primarily to augment a shrinking log supply as concession areas were reduced with each license renewal

and with unauthorized occupation of forest land steadily undermined the productive forest area. Experiments with systematic enrichment planting were institutionalized under an intensive silviculture system (SILIN) which required line planting after harvesting. Concession licenses were granted for 50 to 70 years on the assumption that planted stock could be harvested in 25 years. Five major concessions have taken up this challenge and are implementing this silivicultural system systematically, even though the financial benefits are not yet proven.

A preliminary investigation24 into this system conducted by TFF in five concessions found that the establishment and maintenance costs of this systematic enrichment planting averaged over US$20 per cubic meter logged if these costs were to be written off directly as a logging cost. Although the enrichment planting was still relatively new at the time of the study, preliminary survival and growth information suggested that as little as 10% of the planted stock could be of harvestable diameter at the prescribed rotation age of 25 years.

23 Indonesia’s selective logging and administrative system 24 “Can we harvest this tree in 23 years?”, an article on a preliminary revies of the SILIN system published in the RIL & Certification Newsletter, vol.14, July 2011.

Four year old plantation of red meranti under the intensive silviculture line planting system (SILIN).

4.5 A question of sustainability

The question, “How does the Indonesian forest respond to logging?”, raises the broader issue of sustainability. When considering this question in its most simplistic sense with the benefit of more than 20 years of personal observations, the answer is that the Indonesian Dipterocarp forest respond very well to logging. Many of the main commercial species belonging to the ‘Meranti’ commercial groups of species, are early to mid-succession species. Regeneration is abundant on the forest floor and responds quickly to the introduction of light following site disturbing activities. Sapling and pole size trees are abundant and respond vigorously to logging. The situation is quite different in the forests of Papua and West Papua Province. The high cost of operating in this region and the largely unproven nature of many of the species, results in a harvest of relatively few species. Many concessions in this region harvest only Merbau, a slow growing climax species highly valued in world markets. As a result of this singular focus on Merbau, only two or three trees may be harvested per hectare and seldom more than five. The problem with Merbau, however, is that through much of its Indonesian range, regeneration, sapling and pole size trees are almost absent from the stand. Very few growth studies have been done for Merbau and none in Indonesia. What data is available suggests that an appropriate cutting cycle could be somewhere between 70 to 100 years, not the 30 years assumed under Ministry regulations. This is clearly an issue of sustainability for this particular species.

5 Improving current harvesting practices.

In a discussion of current harvesting practices, reference is made to dryland selective logging as opposed to logging in swamp forests where a miniature rail system is usually deployed. In dryland logging, the extraction technology of choice has traditionally been the crawler tractor, typically the Caterpillar D7G model or the Komatsu equivalent. These are heavy machines designed for pushing. Their destructive impact on the forest, if not very carefully planned, can be massive. In the ‘business-as-usual’ model, forest managers typically leave the planning of actual extraction activities, to the discretion of the tractor operator within demarcated logging blocks, usually +/-100 hectares. Planning of skid trails is entirely in the hands of the man who operates the crawler tractor. The most successful aspect of TFFs RIL training program, is to empower competent staff to conduct detailed planning of the extract system, thus removing the important function from the hands of a tractor operator. TFF has also worked to promote the adoption of alternative extraction technologies which could be used to reduce impact. The following options have been tried in Indonesia and show varying degrees of promise.

5.1 Alternative technologies

Caterpillar and Komatsu crawler tractors have long been the favored machines of the Indonesian logging industry. Although designed for earth moving, they are also equipped with powerful winches and are the main extraction machines capable of pulling tree length logs from the felling site to the landing. However, alternative technologies exist and some are gaining more attention due to a variety of factors. Skyline systems The mobile tower yarders built by ‘Skagit’ and ‘Madill’ in the Pacific Northwest of Canada and America, found a ready application in the early days of logging the Dipterocarp forests of the Philippines. However, since these logging machines were primarily designed for clear-cutting, the resulting destruction of the Dipterocarp forests earned them a very unfavorable reputation in neighboring Indonesia. Until a few years ago, one concession in East Kalimantan operated a 120 foot Skagit tower yarder in a live skyline configuration with haul-

back. In this configuration, selective logging is possible but requires high volumes per hectare to make it profitable. In addition, the application of this logging method requires specific topographic conditions and a high level of forest engineering information and skills. Given these challenges, the company has since retired this logging machine. Rubber tyred skidders A few of these machines are in use in Indonesia and are primarily used to

forward logs to landings along well established skid trails. Indonesian soil conditions are too wet; terrain is too steep; and understory vegetation is too thick for these machines to have a widespread application in general logging, however, as new yarding technologies such as the modified excavator come into more common use, expect to see more of these rubber tyred extraction machines for fast forwarding of logs to road side landings. Helicopter logging Helicopter logging has been deployed extensively in Sarawak, primarily to access forest areas which are too steep or too far for a road to extract economically using crawler tractors. Helicopter

Skagit yarder in the Sumalindo II concession, East Kalimantan

A Timberjack skidder with grapple.

A Sikorsky Sky Crane logging in Sarawak

logging is the ultimate, low-impact logging technology and proved very effective in Sarawak. While Indonesia has identical terrain and forest conditions to Sarawak, the economics are quite different. Sarawak still permits log exports while Indonesia has long had a prohibitive export tax in place which effectively prevents the export of logs. While Sarawak can sell logs at prices set on the world market, Indonesia has a log pricing structure which is more akin to an internal transfer price and results in log values approximately half of the world price. With this pricing constraint, helicopter logging in Indonesia remains only a remote possibility. Ground winching (mono-cable) In 2009, two East Kalimantan timber concessions introduced a logging system that had gained some prominence in the illegal logging fraternity in Indonesia during the 2001-2004 period of logging chaos following efforts to decentralize jurisdiction of the forest administration. The technology consisted of a large drum mounted on a metal sled and powered by a low revolution/high torque motor more commonly used on large river boats. The machine was referred as a monocable25 and was used to forward logs to a landing using a single cable. The cost of deploying this technology was extremely low but so was the production. One machine employing a 5 man crew, could extract 3-5 trees to roadside in one day. The very low impact resulting from the use of this extraction technique, elicited an enthusiastic endorsement from proponents of RIL, however, difficulty in finding sufficient laborers, the low rate of production, and technical problems with the machine, brought about a halt in large scale operational application of this technology. Under the right conditions, it could still serve as a effective, low impact extraction machine but it is unlikely to receive serious consideration by the larger timber concession community. Track skidder (Cat 527) In the late 1990’s, Caterpillar developed a crawler tractor specifically designed to pull, rather than to push. The Cat 527 track skidder rapidly gain acceptance in Sarawak but

25 “Innovation in RIL Technology” an article on the monocable published in Reduced Impact Logging and Certification Newsletter, October 2010

Locally manufactured ‘monocable’

The Cat 527 track skidder in an RIL logging trial in West Kalimantan.

Indonesian timber companies remained unconvinced given the cheaper more readily available multi-purpose Caterpillar D7-G and Komatsu tractors. The Cat 527 was first tested in CIFORs RIL research trial in the Inhutani II concession in Malinau in 1997 and then again in 2012 in a comparative RIL trial in the West Kalimantan concession of PT Suka Jaya Makmur. TFF facilitated both of these trials through its collaboration with Caterpillar International. The success and publicity26 of these trials lead directly to some of the first purchases of the Cat 527 track skidder in Indonesia but it wasn’t till 2012 when Caterpillar Indonesia closed its D7-G production line and began manufacturing the 527 in Indonesia, that a greater interest began developing in the 527 track skidder. The Cat 527 has a bright future in Indonesia’s forest concessions. It is faster, more maneuverable, and has a lighter footprint than the D-7G and Komatsu crawler tractors. As forest concessions increasingly enter their second cutting cycle, existing road and skid trail infrastructure and small trees make the 527 skidder a logical choice for large scale operations. Modified excavator The concept of modifying an excavator to become a yarding machine was first turned into an operational reality in 2000 by the Rimbaka company in Malaysia with 18 machines initially deployed in the hill and swamp forests of Pahang state. The results were a dramatic reduction in impact, apparent even to the untrained eye. The ‘Rimbaka Timber Harvester’ is a modified excavator which has been converted into a high-lift, line machine. A winch is mounted beside the cab. The standard excavator arm has been removed and replaced with a boom than can be raised, lowered and extended hydraulically. Attached to the boom is a modified bucket arm which is used as a stabilizing brace when the machine is pulling a particularly heavy log. The boom has a small bucket which

26 “The Caterpillar 527 Track Skidder: A low impact machine with considering”, article published in the RIL & Certification Newsletter, December 2004.

The Rimbaka Timber Harvester being employed in the hill forests of Pahang State, Malaysia

can also be used to build skid trails and to lift and manipulate tree-length logs with ease. The basic machine is a Hyundai 320 excavator. Modifications were made by Hyundai under license to Rimbaka Forestry which maintained distribution rights for the machine. TFF spearheaded a drive to attract use of this technology in Indonesia but the timing was not conducive as the Indonesian forestry sector was just entering its most unstable period with log prices pushed to all-time lows by illegal logging and poorly executed attempts at decentralization. It was also during this time that the Forest Research Institute of Malaysia (FRIM) began developing and testing its own version of the modified excavator. Although the Rimbaka company no longer exists, the FRIM machines are still being used in Malaysia and referred to as the ‘Log Fisher’. TFF maintains links with the Caterpillar which has done its own modification of an excavator into a yarding machine, however, without some demonstration and research trials of this technology, it is unlikely that the conservative logging sector in Indonesia will spontaneously adopt this new technology at a large scale. This development in low-impact extraction technology is probably the most promising innovation that needs to be studied and promoted. The modified excavator is ideally suited for up-hill yarding and the Indonesian forest topography provides ample opportunity for the application of this technology. Work with the Rimbaka and subsequently with the Log Fisher, showed dramatic reductions in logging impact. Winching up to 100 meters is feasible with costs and productivity equal or better than conventional ground based skidding using a crawler tractor.

APPENDIX I

RIL PERFORMANCE CRITERIA & INDICATORS FOR INDONESIA

Management Activity or

Element

Implementation Indicator

Implementation Verifier Audit Observations and Comments

1. A pre-harvesting, operational inventory has been conducted which identifies all trees to be harvested and trees to be protected according to the standards set in the Indonesian TPTI or TPTJ silvicultural and administrative systems.

1.1 Field visits verify that the inventory has been conducted and trees are labeled and numbered according to regulatory requirements.

1.1.1 Spot checks should be conducted in multiple locations.

Auditor to insert observations and comments here.

1.2 The Company has written standards for its cruising activities including a clearly stated policy, on which trees are suitable for inclusion in the inventory (see audit notes below).

1.3 Cruising summaries (LHP) are available for the entire area to be harvested.

1.4 Document check should verify that species protected by Indonesian law and CITES protocol are not included in the list of species proposed for harvesting.

AUDIT NOTES:

A 100% inventory is mandatory for Indonesian forest concessions. Requirements and procedures for such an inventory is well documented by the Ministry of Forests (MoF) and available to all companies. MoF regulations detail the inventory, marking, mapping, and reporting procedures for commercial, protected, and future crop trees.

The regulation (SK) on minimum stocking standards for concession license and RKT renewal is not considered legitimate for RIL audit purposes as it is counterproductive to the goals of RIL and contains completely unimplementable expectations.

2. Operational scale contour and tree position maps of adequate accuracy are available for the entire area to be harvested anually.

2.1 The company has acquired appropriate scale contour maps through remote sensing methods or has adopted

suitable ground survey procedures to permit routine contour and tree position mapping.

2.1.1 An appropriate operational map scale is not greater than 1:5,000 with contour

intervals of not more than 5 m.

2.1.2 Minimum information content of the operational contour and tree position maps includes all permanent and seasonal watercourses, contours, roads (existing and planned), block boundaries, physical features which could influence logging planning, and the location of all trees suitable for harvesting.

2.1.3 It is recommended that systematic ground surveys leave behind a recognizable

survey grid which can be used for field orientation.

2.2 Accuracy of the maps must be adequate to permit accurate planning of skid trails according to contours,

location of physical features (streams) and tree location information.

2.2.1 Field checks will verify accuracy of the map. Tree location should be accurate

within a radius of 20m.

AUDIT NOTES: Although contour mapping is recommended under MoF regulation, it is not an enforceable requirement. However, accurate contour maps play a much larger role in RIL planning than tree position maps, consequently,

these indicators and verifiers are important preconditions to RIL implementation and should be subjected to significant audit scrutiny in the field.

3. Forest roads are planned, located, constructed, and maintained so as to minimize the impact on the forest and related values.

3.1 Company specific road standards have been developed to guide the planning, location, construction,

maintenance, and deactivation of forest roads.

3.2 Roads are located and constructed according to company standards.

3.3 Road locations are routinely positioned on operational planning maps prior to commencement of logging

planning and operations.

3.4 Roads are maintained to minimize erosion.

3.5 Roads no longer required for forest management activities, are deactivated so as to prevent erosion and to

safeguard against unauthorized activities.

AUDIT NOTES: Technical guidance on roads is provided in the TFF “Planning, Location, Survey, Construction and Maintenance for Low Impact Forest Roads”

4. Harvesting boundaries are established in the field and shown on the maps according to existing regulatory requirements.

4.1 Procedures for the establishment of logging boundaries are clearly stated.

4.1.1 Random and representative field checks verify the existence of operational

boundaries

4.2 Harvesting boundaries do not conflict with or overlap with protected area boundaries as identified on a

higher order plan, either inside or outside of the concession boundary.

AUDIT NOTES: Boundary demarcation is required under MoF regulations. Procedures are prescribed by the MoF in detail. Both map and field checks will be required to verify compliance.

5. The company is in possession of valid concession license and a valid annual cutting permit (SK RKT)

5.1 Current concession license and annual cutting permit are signed by appropriate authorities.

5.1.1 A document check verifies the existence of valid license documents.

AUDIT NOTES: Possession of a valid concession license and annual cutting permit are part of the legality standard and one of the main pre-conditions for participation in the “ RIL verified” program.

6. Operational scale harvesting plans are prepared showing how the company proposes to carry out harvesting activities.

6. 6.1 Harvesting plans are prepared on the contour and tree position maps.

6.2 The company has developed operational and environmental standards to guide planning and logging

activities

6.2.1 Operational standards include considerations for maximum gradient of skid

trails, soil considerations, location of landings, organization (sub-compartmentalization) considerations, and stream crossing procedures.

6.2.2 Environmental standards include a policy on maximum slope suitable for

ground based logging, riparian buffer zones, stream crossing, considerations for landings, and considerations related to cultural aspects.

6.3 The company has designated capable personnel responsible for carrying out detailed logging planning.

6.3.1 Accurate plans incorporating existing contour and tree position information

as well as planning standards are being routinely prepared.

AUDIT NOTES:

This is an RIL requirement. The only MoF logging planning requirement is the division of the annual harvest area into +/-100 hectare blocks and the planning of the trucking roads two years prior to harvesting. However, the preparation of detailed harvest plans by competent personnel is a key element in the successful adoption of RIL practices.

7. Skid trails and landings are located prior to the commencement of felling activities in accordance with operational and environmental standards.

7.1 The company has designated capable personnel responsible for carrying out detailed skid trail and landing

location.

7.1.1 Field checks confirm that skid trails and landings are being routinely located

according to the logging plan and the standards which have been specified.

7.2 Updated maps have been prepared showing actual location of landings and skid trails where there is a

variation of the original plan.

AUDIT NOTES: Field checking is required to confirm compliance.

8. Skid trails are opened prior to the commencement of felling activities and in accordance with operational and environmental standards

8.1 The purpose and procedure of opening up skid trails is clearly communicated to operational supervisors and

personnel

8.1.1 Foremen in charge of logging activities, have up-to-date and accurate maps

to guide the extraction activities

8.2 Simple technical guidelines exist for opening the skid trails.

8.2.1 Field checks confirm that skid trails and landings are being routinely

opened prior to felling and that skid trails and landings are built according to the specified standards.

AUDIT NOTES:

This is an RIL requirement which seeks to ensure that the benefits of detailed harvest planning is actually passed on to the operational stage. Experience has shown that opening of the skid trails progressively with the logging operation, does not work effectively in the tall timber and broken terrain conditions commonly found in Indonesia, consequently, opening of the planned and located skid trails prior to felling is an important step in the process of implementating an RIL system.

9. Felling and bucking is carried out according to RIL principles and guidelines.

9.1 Fallers have been instructed on simple decision making criteria to guide their efforts at directional felling.

This includes considerations for: personal safety, alignment to skid trail, location of future crop and protected trees, recoverability of the felled tree, and minimizing felling breakage

9.1.1 Do the fallers have a pocket sized card covering basic falling and bucking

considerations?

9.2 Fallers are equipped with basic safety equipment and tools appropriate for the implementation of directional

felling.

9.2.1 Fallers are supplied with and use basic safety equipment (hardhats) as well

as appropriate felling aids such as felling wedges.

9.3 The company has a clear, written utilization policy and bucking standards. This policy should specify

maximum tolerable defect, preferred log lengths, and acceptable species.

AUDIT NOTES: For additional technical details, the manual “Operational Considerations for RIL” should be consulted.:

10. Skidding is carried out in such a way as to minimize soil disturbance and damage to the residual stand.

10.1 The company has issued operating instructions to tractor operators which seek to ensure that machines

remain on the skid trails and maximize winching.

10.1.1 If the log is within 20 m of the skid trail, it should be extracted using the winch only unless its position is such that there is no clearance under the log for the cable or if there is an obstacle which would prevent direct winching.

10.2 The tractor operator does not develop new skid trails which are not marked in the field without consulting

with the foreman.

10.2.1 There is no evidence of criss-crossing or duplicate skid trails.

AUDIT NOTES:

This is an RIL requirement dealing with skidding. In the Dipterocarp forest, minimizing soil disturbance is the key to ensuring good regeneration. The forest floor usually has an abundance of seedlings. With the opening of the forest canopy, the existing regeneration grows aggressively. Soil disturbance not only implies destruction of poles and saplings, but also of the seedlings. Soil disturbance/displacement is the single most important factor affecting forest regeneration.

11. The company has a clearly stated policy for deactivating landings and skid trails aimed at minimizing the risk of erosion.

11.1 Deactivation guidelines for skid trails should specify how and under what conditions cross-ditching will be

done.

11.2 Cross-ditching of skid trails is a part of the tractor operator’s normal job description.

11.2.1 Field checks verify that cross-ditching and deactivation of landings is done

according to the company’s standards.

AUDIT NOTES: Field checks are required. Technical guidance is available in the manual, “Operational Considerations for RIL”.

12. Monitoring and post-harvesting evaluation is being carried out with the intention of providing continuous self-evaluation and feed-back to the management on the implementation of RIL practices.

12.1 Monitoring and evaluation activities have been identified as job descriptions and competent personnel

have been instructed to carry out these functions.

12.1.1 These duties may be added on to the job description of the foreman or new

personnel may be appointed as ‘block inspectors’.

12.2 Routine field monitoring is carried out during the logging activities to ensure that RIL objectives are being

achieved

12.3 A post harvesting evaluation procedure has been adopted, which assesses compliance with RIL objectives

and reports to management.

12.3.1 ‘Block reports’ are available. They should cover all aspects of the logging

and deactivation requirements and should also report on utilization matters. An attached map indicating the areas logged is desirable.

AUDIT NOTES: Technical details are provided in the TFF publication, “Operational Considerations for RIL”.

13. Management has put in place appropriate policies, instructions, and personnel to ensure that all sectors of the operation are clear on the need to modify practices to make the adoption of RIL practices an operational reality.

13.1 Company policy and instructions to inventory, planning, and operations personnel, state the objectives of

adopting RIL and clearly inform on individual job responsibilities.

13.1.1 Policy statements and/or standard operating procedures exist which

describe the various elements of the RIL system.

13.1.2 Job descriptions exist which demonstrate the integration of function and

responsibility.

13.2 Personnel have been designated, trained, and adequately instructed to ensure that all RIL activities are

carried out effectively.

AUDIT NOTES: Guidelines for implementation are provided in the TFF manual, “Management Considerations for RIL”.

6

APPENDIX II RIL Scoring Standard

Desired outcome of adoption of an RIL system is to reduce the impact of logging activities for all parameters. The score provides a subjective evaluation of the degree of implementation of each indicator. The weight is a measure of the significance of each indicator in influencing the desired outcome. The weighted score is the product of the score times the weight. A forest management units overall weighted score is expressed as a percent of the maximum possible weighted score. Score: 0 = no indication of any compliance; 5 = full compliance Weight: 1 = minor significance; 5 = very significant in influencing the outcome. A score of 130 is considered minimum compliance with MoEF regulation. A score if 80% or better is considered by TFF to be in substantial compliance with the C&I of RIL.

Ind.

Description

Max. Score (0-5)

Weight

(1-5)

Max. Weighted

Score 1.1 Inventory conducted; trees labeled and numbered 5 5 25 1.2 Written cruising standards 5 1 5 1.3 Cruising summaries (LHC) are available for all of RKT 5 3 15 1.3 Check for Cites species 5 2 10 2.1 Appropriate scale contour maps available – contents 5 5 25 2.2 Accuracy of maps 5 4 20 3.1 Road standards developed 5 2 10 3.2 Roads located and constructed according to standards 5 4 20 3.3 Roads located on operational scale maps 5 3 15 3.4 Roads maintained to minimize erosion 5 3 15 3.5 Unused roads deactivated 5 2 10 4.1 Procedures for establishment of logging boundaries 5 2 10 4.2 Harvest boundaries do not conflict with protected areas 5 4 20 5.1 Valid concession license and valid annual cutting permit 5 5 25 6.1 Harvesting plans prepared on contour/tree maps 5 5 25 6.2 Environmental and operational standards to guide plan 5 4 20 6.3 Capable personnel designated to carry out planning 5 3 15 7.1 Capable personnel to do skid trail location 5 5 25 7.2 Updated maps showing actual location of skid trails 5 3 15 8.1 Operational personnel understand purpose of planning ... 5 4 20 8.2 Technical guidelines for opening skid trails 5 3 15 9.1 Fallers have instructions on felling considerations and safety 5 4 20 9.2 Fallers have basic safety equipment and tools 5 2 10 9.3 Utilization policy / bucking guidelines 5 3 15 10.1 Skidder operators provided with instructions 5 3 15 10.2 Skidder operators do not open skid trails independently 5 3 15 11.1 Deactivation guidelines exist 5 2 10 11.2 Cross-ditching part of tractor operators normal job 5 2 10 12.1 Monitoring and evaluation personal have been instructed 5 4 20 12.2 Routine field monitoring of logging activities 5 4 20 12.3 Post harvesting evaluation to check on RIL compliance 5 3 15 13.1 Policy and instructions to all departments (re. RIL), clear ... 5 5 25 13.2 Personnel designated, trained, and adequately instructed 5 4 20 Actual Score Maximum Potential Score 165 555 Required by MoEF Regulation 130