Simplifying institutional requirements 
  
Reducing natural forest undervaluation 
  
Reducing uncertainties of resource allocation rights.  
2.4  Lessons Learned: Simplifying Institutional Requirements   
2.4.1  Planning Processes  
The current regulatory framework for managing natural forests (e.g., TPTI) is highly prescriptive 
and indirect.  Forest practice regulations focus on issuing licenses, permits, and approvals for 
prescribed requirements (e.g., road construction, equipment types, personnel qualifications, 
programs for research and development, financial reporting, and timber harvest limits).  Only a 
few regulatory requirements focus directly on the impact of logging activities. Instead, the 
overwhelming majority of regulations prescribe what forest managers should do rather than 
what should be achieved (e.g., stipulations about machinery used and staffing qualifications) 
and therefore provide little assurance that impacts on the forest ecosystem are within 
acceptable pre determined limits. 
The failure of this prescriptive approach is evident from examining, for example, the production 
forests in West Kalimantan.  During 1992, field surveys of 35% of the active HPH's with reviews 
of all 72 HPH's in West Kalimantan were conducted to assess harvest levels and standing stock 
management (Curran 1992). These active HPH's reported productivity levels at least 25% 
above the forestry department s predicted average commercial volume for the province.  
Furthermore, the total area of HPH production forest available in West Kalimantan for timber 
extraction in 1994/95 was only 69% of the original production forest area allocated to 
concessions.  The rate of West Kalimantan timber extraction was unsustainable.  Rather, 
extraction proved to be unprofitable on the 30% of the concession's land that was converted to 
non production forest status.  A case in point was a 200,000 hectare concession that ceased 
activity after its 20 year lease and was found to have a residual timber stock less than 20 m
3
 per 
hectare over the entire concession area.  At this level of stocking, the land classification shifted 
from forested to unproductive land. 
Even in the best of cases, ineffective standing stock management was observed among all the 
HPH's surveyed in West Kalimantan.  The applied silvicultural techniques did not improve the 
quality of the remaining stand.  The major contributing factor was the discrepancy among TPTI 
theory, ecology and field practice.  First, HPH staff and bureaucrats had a poor conceptual 
understanding of the TPTI objectives and practices. This insufficient understanding exacerbated 
the impacts of a rigid regulatory system applied by forestry officials.  Secondly, the differing 
focus of HPH staff and forest officials when evaluating TPTI compliance lead to vastly different 
interpretations of outcome. For example, HPH staff tended to focus on forest management, 
while forestry officials focused on post harvest treatment. Forestry officials base their 
determination of the acceptable level of TPTI implementation on area covered rather than on 
actual effects of these practices on the timber stand.  Conversely, HPH staff base their 
performance on the ability to extract the volume of timber demanded by downstream 
processing.   
37 
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