also were required to file fourteen monthly reports and four quarterly reports submitted to the 

various MoFr agencies (NRMP Report No. 51).  

Not only is there a tremendous reporting demand on concessionaires by Government officials, 

but concessionaires are also subject to widely varying interpretations of these regulations and 

practices by provincial and local government officials.  Government authorities from each region 

apply different implementation standards and sanctions for the same TPTI parameter.  Multiple 

visits by different forestry officials provide mixed messages to the concessionaire.  The result is 

a high level of uncertainty for the concessionaire and a severe reduction in the effectiveness of 

the avoidance role of sanctions.  As the current prescriptive approach identifies loopholes, it fills 

these with more requirements, reflecting concern about the future of Indonesia's natural forests.  

Inspection resources remain the same, and existing resources are used only to verify reporting 

procedures and not to evaluate actual forest management (NRMP Report No. 51). 

While the current regulatory requirements faced by concessionaires are confusing and 

ambiguous, they may prove to be insurmountable if extended to community forests.  How could 

community forest managers negotiate the present array of regulations for natural production 

forests?  These communities currently face tremendous obstacles before they can officially 

benefit from formally recognized forest timber utilization (NRMP Report No. 51).  Successful 

forest certification by an independent agency, which thereby qualifies the concessionaire for de 

bureaucratization and deregulation ((NRMP Reports No's. 46 and 77). 

Illegal logging at abandoned HPH's and protected forests thrives in such a circuitous and 

bureaucratic environment.  In West Kalimantan, illegal logging is controlled by business people, 

government civil servants and HPH concession officials who hire local villagers to fell and 

transport logs to loading ports.  Local community involvement is solicited through third parties, 

who often garner unofficial clearance letters from local level or higher officials.  Illegal logging 

continues relatively uninfluenced by existing sanctions. The interaction of increased sawn timber 

taxes and significant increases in domestic demand for logs has shifted the illegal log market by 

changing the demand for logs before adequate controls at ports were established.  It has been 

inferred from field observations that Illegal logging may be filling the demand for domestic 

construction timber. The volume and type of illegal timber are not factored into provincial 

planning processes or statistics. 

Concerns about deforestation are driven both two factions.  Conservationists often view logging 

and current forest practices as the major threat to biological resources and diversity.  Foresters 

view the deforested areas as a loss to forest production. Inappropriate management 

prescriptions to these issues contribute to concerns about continued deforestation. Reduction of 

available forest land reflects the inability of forest revenues to overcome production costs (e.g., 

establishing property rights, forest management activities, returns from alternative land uses).  

These prices and costs determine land uses. Policies may have greater impact on cost 

thresholds of alternative land uses than do the prices. 

The present regulatory system results in significant production costs.  For example, the approval 

process for the AAC can require a year, creating uncertainty and encouraging poor planning by 

the concessionaire.  Delays affect the construction of logging roads, for example, and often 

result in their use before completion; this, in turn, results in increased costs and soil erosion.  

Another observed example was delayed arrival of the MoFr inspector who authorizes the 

production report (LHP).  This delay can halt the river transport of several hundred cubic meters 

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