levels of waste, concession field staff maintained that waste levels were over estimated within 

the NRMP field site in West Kalimantan.  

Further work undertaken to highlight the economic parameters of logging waste (NRMP Report 

Nos. 44, 71, 72) indicated that the potential benefits from reduced avoidable waste were 

significantly important for both the concession and the GOI.  Based on this, low impact logging 

systems were developed and linked to higher resources extraction levels in a pilot logging trial 

(NRMP Report Nos. 58 and 70).  

Results from this work informed policy discussions within a Tim Kajian framework.  Over an 

extended period, alternative responses to prescriptive regulation of natural forest management 

were promoted.  Workshops were held to discuss the issues with project staff, forestry officials, 

and private sector concessionaires.  During these workshops, an NRMP trainee from a private 

sector company cited his research to highlight the need for increased forest utilization given 

increasing resources scarcity.  Collectively, these initiatives resulted in a changed logging policy 

for this concessionaire.  However, to date, no change to the underlying national policy approach 

has been implemented. 

2.4.3  Compliance and Enforcement of Forestry Regulations  

The critical institutional requirement for prescriptive command and control mechanisms is the 

ability to enforce compliance.  Unfortunately, this is not being achieved in Indonesia.  Before 

1989, no fines were imposed.  With installation of a new Minister of Forestry in 1989, 40% of 

Indonesia's HPH's were temporarily banned for breaching their obligations.  The Minister fined 

187 HPH's for excessive logging, and 114 HPH's were blacklisted for failing to pay replanting 

fees to the MoF Reforestation Fund (Dana Reboisasi, DR).  However, by April 1990 the number 

of concessions increased from 561 in 1989 to 575, indicating that no net loss of concession 

licenses actually occurred as a consequence of non compliance enforcement. 

Curran (1992) assessed the costs and the application of fines in West Kalimantan relative to 

forest extraction levels.  During the period from 1989 to 1992, 97 fines were issued by the West 

Kalimantan  Dinas Kehutanan to forty five of the total 68 HPH's, suggesting that enforcement 

efforts were increased in contrast to the period prior to 1989 when no sanctions were issued on 

concessions in the province.  Despite the apparent increased enforcement of regulations, 

concession compliance in West Kalimantan had not increased significantly.  The criteria for 

applying any of the four types of sanctions were vague, as were the level of fines.  The four 

types of sanctions were: 

Withholding the release or assignment of the new annual work plan, which delays 

production and output.  Indirect costs include loss of river transport options in the dry 

season or unofficial payments to facilitate processing. 

Reduction in the AAC, which reduces the level of productivity. 

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