GLOBAL FORESTRY SERVICES. Sarawak Audit Checklist / Report STLVS Principles 1-4

Transcription

1 Sarawak Audit Checklist / Report STLVS Principles 1-4 Licensee Ta Ann Plywood Sdn. Bhd. (08737-T) Reference # GFSS a Contact Person Office Address Site Address Mr. Nicholas Ting (Ta Ann Holdings Berhad - Senior General Manager Mr. Ling Tiing Tchin (TAP Reforestation Division - General Manager) Ta Ann Plywood Sdn. Bhd. 1 st Floor No. 6, Lot 9, Jalan Pedada 0A, Sibu, Sarawak, Malaysia. TAP Pasin Camp: Mile 3, Katibas Logging Access Road, Song. TAP Woodley Camp: Mile 4, Tekalit Logging Access Road, Song. nicholas.ting@taann.com.my tiingtchin.ling@taann.com.my Report Date Date of close out Telephone Fax Telephone Fax Approved By 30 October Dr. Kevin T. Grace Statements GFS Statement of Compliance # GFS 00 LVS Issuance Date 01 November 017 Expiration Date 31 October 018 Assessment Details Assessment dates 9 th to 13 th October 017 Scope of Assessment Species GFS Lead Assessor GFS Assessor(s) Others OBJECTIVES: Licence for Planted Forest No (Rejang, Pasin and Woodley Divisions) Acacia mangium, Neolamarckia cadamba, Duabanga moluccana, and Octomeles sumatrana. NA The objective of this checklist is to verify compliance to the Criteria listed in the Sarawak Legality Standard as defined by STLVS Principles 1-4 (Draft 07) for Sarawak dated 1 April 017. Compliance is defined when all applicable criteria are observed to be compliant. A Minor Gap to any indicator does not constitute non-compliance to a criterion. A Major Gap to any applicable indicator does reflect non-compliance to a criterion. Compliance for a criterion where multiple minor gaps are identified in indicators under the criterion may reflect non-compliance to the criterion. All issues identified under this standard shall be considered appropriate to the scale and degree of forestry operations undertaken by the parties under the agreement. Ta Ann Plywood Sdn. Bhd. LPF No Page 1

2 Overview of Licensee Summary Information Organization Information: Ta Ann Holdings Berhad (Ta Ann) is a timber resource-based company based in Sibu, Sarawak, Malaysia. It was founded in the mid 1980 s as a small trading company by the main founders Datuk Amar Abdul Hamed Bin Haji Sepawi, Datuk Wahab Bin Haji Dolah and Dato Wong Kuo Hea, starting as a forest concession licensee which included timber harvesting operations, shipping operations and downstream wood-based industries. Ta Ann Holdings Berhad was incorporated as a public limited company in February 1997 and listed on the main board of Bursa Malaysia (Kuala Lumpur Stock Exchange) on 3 rd November The principal activities of Ta Ann Holdings Berhad are centred around sustainable harvesting of timber resources and value adding downstream activities such as the manufacturing of veneer, plywood, coated plywood, eco plywood, laminated veneer lumber and pachinko plywood, sawn timber and laminated moulding products. Ta Ann is one of the pioneers in reforestation in Sarawak and actively operates its reforestation programmes on which the Group places a strong emphasis. Due the commitment to ensure sustainability of its forest resources, Ta Ann has embarked on research and development programmes to produce improved tree planting material of Acacia mangium, Superbulk and Acacia hybrid, which return higher quality and yield for veneer production. Currently Ta Ann s plan to gradually shift to plantation-based resources is based on using local timber species such as Kelampayan (Neolamarckia cadamba) planted in system termed ZEBRA Planting which involves planting operations conducted at about 50 m intervals following the terrain contour alignment. Ta Ann emphasises on environmentally friendly forestry practices to meet the needs of its customers who are becoming increasingly environmentally conscious. Due diligence surveys are carried out by independent consultants prior to commencement of ground operations to ensure that areas known as High Conservation Value are protected. Ta Ann through its subsidiary companies operates five natural forest concession areas with the following Forest Timber Licenses (FTL) area sizes, comprising a total of 415,36 ha: 1. FTL No. T/ ,69 ha operated under Pasin Sdn. Bhd. (revised on nd May 01). FTL No. T/ ,856 ha operated under Woodley Sdn. Bhd. (revised on nd May 01) 3. FTL No. T/ ,909 ha operated under Raplex Sdn. Bhd. (revised on 3 rd May 017) 4. FTL No. T/ ,756 ha operated under Tanjong Manis Holdings Sdn. Bhd. (revised on 9 th May 017) 5. FTL No. T/034 3,03 ha operated under Borlin Sdn. Bhd. In addition, three Licenses for Planted Forests (LPF) comprising a total of 308,935* ha were issued to Ta Ann by the Sarawak State Government. Note*: FTL No. T/3135 and T/3346 concessions will be progressively revised to resolve the overlapping issue with the converted areas under LPF No LPF No ,703 ha was issued in November 1997 and operated under Zumida Sdn. Bhd. Ta Ann Plywood Sdn. Bhd. LPF No Page

3 . LPF No ,316 ha operated under Ta Ann Plywood Sdn. Bhd. (revised on 9 May 017) 3. LPF No ,747 ha was issued in October 005 (revised on 8 th July 015) operated under Ta Ann Plywood Sdn. Bhd and further revised down to 10,799 ha in May 017. Ta Ann Plywood Sdn. Bhd., a 100 % subsidiary of Ta Ann Holdings Berhad is the licensed holder for LPF No and had engaged Hariwood Sdn. Bhd as the logging contractor to conduct forest plantation activities which includes planting, felling, extracting, and transporting of planted logs in the LPF No area. Key regulations: The legal framework is provided in the following laws (ordinances), rules and regulations: - Statement of Forest Policy (1954) - Forest Ordinance (015) - Forest Rules (1954) - National Parks Ordinance (1956) - National Parks and Nature Reserves Ordinance (1998) - Wildlife Protection Ordinance (1958) - Sarawak Timber Industry Development Corporation Ordinance (1973) - Sarawak Timber Industry (Registration) Regulations (008) - Sarawak Forestry Cooperation Ordinance (1995) - State of Sarawak Forest Timber License (FTL) - Inter-agency Standard Operating Procedures (SOPs) for Performance of Forestry Functions in Sarawak (Ministry of Resource Planning and Environment, 01) - Minimum Wages (Amendment) (No.3) Order Sarawak Labour Ordinance (Cap.76) - Employment Act 1955 Description & Licenses: The LPF No area is located in the Song District of Kapit Division, Sarawak. For descriptive, administrative and managerial purposes, the licensed area had been divided into four management units/divisions designated as Rejang, Woodley, Pasin, and Naman. The license for LPF/0010 was issued on the 8 th December 1998 for a period of 60 years, expiring on the 7 th of December 058. The Licensee had allocated the Naman Division for oil palm plantation and the remaining three divisions (Rejang, Woodley, and Pasin) for tree plantation. The scope of LPF No STLVS assessment will only cover the Rejang, Woodley, and Pasin divisions. Ta Ann Plywood Sdn. Bhd. holds the License for Planted Forest No granted by the Forest Department Sarawak (FDS) to conduct forest plantation operations within a licensed area of 69,316 ha. Management / Land Tenure: The license tenure based on the License for Planted Forest No was issued and approved to Ta Ann Plywood Sdn. Bhd. on 8 th December 1998 for a period of 60 years (Ref. #: WPO/P/106-4) which covers an area of 10,881 ha. The LPF No was revised on 3 rd March 008 [Ref. #: WPO/P/106 Ta Ann Plywood Sdn. Bhd. LPF No Page 3

4 (VII)-10] to cover an area of 108,15 ha covering Naman (13,145 ha), Woodley (18,43 ha), Pasin (54,393 ha) and Rejang (,164 ha) forest areas. The LPF No was revised again to exclude NCR land on 1 st September 015 [Ref. #: WPO/P/106 (XI)-30] to cover an area of 107,485 ha. The LPF No was revised again on 9 th May 017 [Ref. #: WPO/P/106 (XII)-15] to cover an area of 69,316 ha. Management Planning (FMP / GP): License for Planted Forest No is divided into 4 smaller management areas which are Rejang, Woodley, Pasin, and Naman and the license was issued by the Director of the Forest Department Sarawak. Management Plan or Tree Planting Plan (TPP) period and expiry date is identical with the License for Planted Forest No. 0010, i.e. from 8 th December 1998 to 7th December 058. The revised Tree Planting Plan (TPP) was approved on 3 rd March 008 by FDS [Ref. #: WPO/P/106(V)-56] which covers 69,316 ha of the licensed concession with a net operable area of 4,01 ha. Tree Planting Plan (TPP) only covers the tree plantation divisions (Rejang, Woodley, and Pasin). Operational activities: Hariwood Sdn. Bhd. is a registered logging contractor for LPF No Hariwood Sdn. Bhd. is engaged by the licensee as the contractor to conduct forest plantation activities, which includes planting, felling, extracting, and transporting of planted logs in the LPF No area. Currently, active Coupes with valid Permit to Harvest Coupe (PHC) are Coupes 04E and 03E of Rejang Division and 04B of Woodley Division. There is no cutting limit imposed on the standing timber from the planted forest. Area Division Total Area Woodley Pasin Area Rejang Area Naman Area (ha) Area (ha) (ha) (ha) (ha) ITP (Actual) 6,031 10,95 6,080-3,063 ITP , ,583 (Dispute) Plantable OP - - 1,761 10,980 1,741 NCR (Apis) Settlement Area Terrain Unplantanble 59 1, ,786 Class IV Buffer Zone,844 10,415 8, ,788 Conservatio n Area ,111 96,49 Dam Total 9,574 4,744,007 1,991 69,316 Environmental Context The current vegetation in the Rejang, Woodley, and Pasin divisions are predominantly logged-over remnant hill Mixed Dipterocarp Forest (MDF) with small stretches of virgin forest in Pasin Division along the Sarawak / Indonesian border. The remnant vegetation varies in structure and species composition depending on the terrain conditions and the intensity of the previous and on-going timber harvesting. As for the Pasin Division, there are vast areas of shifting agriculture in the northern part with isolated kerangas towards the south. These areas, kerangas, and Terrain Class IV are excluded as un-plantable areas. Ta Ann Plywood Sdn. Bhd. LPF No Page 4

5 The Woodley Division is drained by three main systems, which are Sg. Lajan Besat to the north, Sg. Sebatu to the west and Sg. Lanang to the south. The eastern portion of Woodley Division drains into Sg. Mukoh and Sg. Tekalit and eventually to Sg. Katibas. Streams in the eastern side of Rejang Division drain into Sg. Matalau. In the western region, streams flowing northwards drain into Sg. Matalau while those flowing southwards drain into Sg. Laup and Sg. Nging. According to the EIA, several protected mammals were identified with the licensed area, including the orang utan, generally located to areas adjacent to the Lanjak Entimau Wildlife Sanctuary and the Indonesian border. Other totally protected mammals are the Bornean gibbon, Hose s langur, maroon langur, clouded leopard, western tarsier, slow loris and giant squirrel. Among the totally protected birds are six species of hornbills. The other two protected birds are the Argus pheasant and Bulwer s pheasant. Other mammals found in the licensed areas, which are not protected are leopard cats, barking deers, sambar deers, flying squirrels, green lizards, rats, bats, tree squirrels, pigmy squirrels, flying squirrels, civet cats, mongooses, wild boars and mouse deer. Non-protected birds found in the licensed areas included green pigeons, doves, blue-naped parrots, cougals, barbets, broadbills, bulbuls, sunbirds, flycatchers, shamas, magpie robins, sparrows, munias, spider hunters and drongos. Environmental Impact Assessment: EIA for the licensed area titled Environmental Impact Assessment For Tree Planting under Licence for Planted Forests No in the Sibu and Kapit Divisions, Sarawak was conducted by a registered environmental consultant firm; Plantacia Sdn. Bhd and submitted to the Natural Resources and Environment Board (NREB) and was subsequently approved in 10 th December Details of the EIA report are shown in the table below. Project name Environmental Impact Assessment For Tree Planting under Licence for Planted Forests No in the Sibu and Kapit Divisions, Sarawak Registered EIA Consultant Plantacia Sdn. Bhd. NREB Reference No. (8) NREB/6-11/64 Date of Approval 10 th December 1999 Social context Social Assessment: In 01, Ta Ann hired Ecosol Consultancy Sdn. Bhd. to conduct a separate Social Impact Assessment apart from the EIA that included an evaluation of settlements, which were identified as associated with the LPF No area, which covered an area of 108,15 ha. There were 63 villages located within a 3-km radius of the LPF No but only 7 villages were visited and surveyed. Since the LPF No was revised on 9 th May 017 to cover an area of 69,316 ha, all the longhouses were no longer located within the licensed area. Ta Ann Plywood Sdn. Bhd. LPF No Page 5

6 According to the SIA, certain areas within the licensed area are subjected to NCR claims by the local people based on their shifting cultivation areas or native farmlands and forest areas associated with resource use such as hunting, fishing and gathering of Non-Timber Forest Products (NTFP). The Shifting Agricultural (SA) areas as in the previous LPF No license document and SIA report have been excluded out from the current revision for LPF No Current Records of LPF No Longhouse Communities and Agreements: Race Iban Iban Iban Village Name Rumah Demang, Rumah Tugang, Rumah Baro Dapong Anak Nuing Rumah Joslee Village Location Outside of LPF No Outside of LPF No Outside of LPF No Area Claimed/ Coupe(s) 0E, part of 03E, part of 04E, part of 05E, and part of 06E Part of TAP Pasin Camp and nursery Area Claimed (Ha) 13E 1,300 Date of Valid Agreement 4,11 nd March th October st April 014 till the salvage logging operation ends Social Monitoring: Ta Ann has a system to establish formal agreements with each longhouse community for compensation for resource use within areas claimed by each longhouse. Agreements are reached through negotiations and discussions as operations progresses, coupe by coupe basis under each management division. Once a deal has been reached, provisions are then laid out in a formal written agreement. The agreement is then read and interpreted to all parties involved to declare that they have fully understood and agreed to the agreement provisions before signing. Current payments / compensations are based on volume of extracted planted timber within the claimed areas after local communities has finalized and resolved any conflicting land claims which can be dynamic. Scope of Assessment The scope of the evaluation is to verify compliance of LPF No. 0010, Ta Ann Plywood Sdn. Bhd. with the STLVS P1-4 Standard (Draft 07) 1 April 017. Site evaluation to verify and report the level of compliance by Hariwood Sdn. Bhd. to the standard in respect to each of the criteria within this report. Compliance is defined when the auditee demonstrates that the indicators consist of only minor gaps or no gaps against any applicable criteria of the standard. Non-compliance to the Sarawak Legality Standard occurs when the auditee does not demonstrate adequate compliance to a criterion. Ta Ann Plywood Sdn. Bhd. LPF No Page 6

7 Itinerary of Assessment Date Activities GFS Staff Mandays 9 th October 017 Monday 10 th October 017 Tuesday 11 th October 017 Wednesday 1 th October 017 Thursday Opening meeting followed by document review at Ta Ann Plywood Sdn. Bhd. office. Overnight at Sibu. Travel from Sibu to Rejang Division (LPF No. 0010). Visited Rumah Demang for longhouse interview session. Site visit to verify: i) Common licensed boundary between LPF No and FTL No. T/3409. ii) Replanting activity at Coupe 04E Block 9A of Rejang Division. iii) Common licensed boundary between LPF No and FTL No. T/3135. iv) Site visit to TAP Pasin camp in LPF No Assessment of generator set storage area, nursery, workshop, lubricant storage, scheduled wastes storage area, waste disposal pit, fuel depot and workers quarters. Overnight at TAP Pasin camp. Site visit to verify: i) Coupe 0C Block 19A of Pasin Division. ii) Conservation belts/buffer zones in Coupe 04E Blocks 1A, 7A, and 9A of Rejang Division. iii) Conservation belts/ buffer zones in Coupe 03E Blocks A,4A,5A,6A, and 7A of Rejang Division. iv) Current harvesting of planted forest in Block 9A and 10A, Coupe 03E of Rejang Division. v) Stream buffer zones in Coupe 4E and 3E of Rejang Division. vi) Visited Rumah Joslee for longhouse interview session. vii) Log inspection and document review at Sg. Manari log pond. Travel to Song and overnight in Song. Site visit to verify: i) Log inspection and document review at Ng. Lajan log pond. ii) Visited Ta Ann manned guard post controlling access to FTL No. T/3346 and LPF No iii) Common licensed boundary between LPF No and FTL No. T/3346. iv) Conservation belts/ buffer zones in Coupe. 04B Blocks 1A and 11A of Woodley Division. v) Stream buffer zones in Coupe 01B Woodley Division. vi) Site visit to TAP Woodley camp in LPF No Assessment of generator set storage area, nursery, workshop, lubricant storage, scheduled wastes storage area, waste disposal Ta Ann Plywood Sdn. Bhd. LPF No Page 7

8 pit, fuel depot and workers quarters. Travel to Sibu and overnight at Sibu. 13 th October 017 Document review and closing meeting at Ta Ann Friday Plywood Sdn. Bhd. office. 14 th October 017 Dr. Kevin Grace Reporting: GFSS Saturday Total 1 Highlights of Assessment (Major Gap = 0 / Minor Gap = 1 / Observation = ) Ta Ann Plywood Sdn. Bhd. has complied with the Sarawak Legality Standard (Principles 1-4) as no noncompliance was identified during the assessment on 9 th 13 th October 017. Principle 1. Right to Harvest: Ta Ann Plywood Sdn. Bhd has demonstrated compliance to the license requirements, EIA requirements and management planning guidelines. Ta Ann Plywood Sdn. Bhd is currently only conducting harvesting operations in Coupes 04E and 03E of Rejang Division and 04B of Woodley Division. Two observations were identified under principle 1: Observation 001 Checklist 1..4: Waste disposal pit of the TAP Pasin Camp was observed without a fence. Observation 00 Checklist 1.3.1: According to the Proposed Tree Planting Plan, section 6.3.: Fire Protection, the Company stated that it will construct fire towers at accessible high spots. However, no fire towers have been built within the concession area. Principle. Forest Operations: Ta Ann Plywood Sdn. Bhd has demonstrated compliance to forestry operation standards, specifically standards pertaining to demarcation of boundaries and areas for protection, implementation of systems to protect the licensed area from encroachment, log transportation, worker safety and health. Boundaries and areas designated for protection such as buffer zones checked on the ground were marked with signs and respective colours as reflected on the map. A gate was erected at the entry leading to the FTL No. T/3346 and LPF No area to protect the licensed area against illegal activities encroachment. Gates were not erected along the main logging road as it was a public road for the use of all the communities and leading to adjacent licensed areas. Nevertheless, forest surveyor teams are responsible for on ground general checking or patrolling within the licensed area while conducting forest surveys. Reports were documented and maintained. There were no reports of illegal activities such as encroachment, illegal logging and poaching reported for the past one year (October 016 to September 017) inside the licensed area. No cutting limit nor log production volume limit was imposed on the harvesting of planted timber in LPF No The harvesting of planted timber is based on clear felling methods. Planted forest harvested logs from LPF No are transported in batches which are weighed using weighbridge at the log pond. Royalty is assessed according to log batches weighed. Related documents on production, royalty payment and transportation were adequately maintained for cross checking and inspection. Ta Ann Plywood Sdn. Bhd. LPF No Page 8

9 Highlights of Assessment Field workers sampled had valid documents and were covered by SOCSO and insurance. All field workers were equipped with PPE. Various types of training were provided to workers and the workers were fully aware of the safety and health procedures. Trainings conducted were documented and maintained. Principle 3. Statutory Charges: Ta Ann Plywood Sdn. Bhd demonstrated compliance to payment of Royalty Fees and other charges as required. Principle 4. Other User Rights: In 01, Ta Ann hired Ecosol Consultancy Sdn. Bhd. to conduct a separate Social Impact Assessment apart from the EIA that included an evaluation of settlements, which were identified as associated with the LPF No area, which covered an area of 108,15 ha. There were 63 villages located within a 3-km radius of the LPF No but only 7 villages were visited and surveyed. Since the LPF No was revised on 9 th May 017 to cover an area of 69,316 ha, all the longhouses were no longer located within the licensed area. According to the SIA, certain areas within the licensed area are subjected to claims by the local people based on their shifting cultivation areas or native farmlands and forest areas associated with resource use such as hunting, fishing and gathering of Non-Timber Forest Products (NTFP). The Shifting Agricultural (SA) areas as in the previous LPF No license document and SIA report have been excluded from the current revision of the licensed area. Ta Ann has a system to establish formal agreements with each longhouse community for compensation for resource use within areas claimed by each longhouse. Agreements are reached through negotiations and discussions as operations progresses, coupe by coupe basis under each management division. Once a deal has been reached, provisions are then laid out in a formal written agreement. The agreement is then read and interpreted to all parties involved to declare that they have fully understood and agreed to the agreement provisions before signing. Current payments / compensations are based on volume basis of extracted planted timber on the claimed areas after local communities has finalized and resolved any conflicting land claims which are dynamic and did not arise during the previous forest operations. There are no longhouses located within the recently revised LPF No concession. However, according to Ta Ann, some of the longhouses have claims over lands within the recently revised LPF No concession. Ta Ann is currently operating in Coupe 04E and 03E of Rejang Division and Coupe 04B of Woodley Division. The longhouse communities from Rumah Demang, Rumah Tugang, and Rumah Baro have claims over land within the Rejang Division. There are no land claims over the area within Coupe 04B of Woodley Division. One minor gap was identified regarding Principle 4. Other User Rights. Gap 001/017 (Minor) Checklist 4.1.: Ta Ann has mapped the land areas that are under dispute as indicated in the revised maps G (Rejang), G3 (Pasin), and G4 (Woodley) for the revised LPF No concession, but particulars of the claimants were lacking. Ta Ann Plywood Sdn. Bhd. LPF No Page 9

10 Summary results: (Major Gap = 0 / Minor Gap = 1 / Observations = ) GAPs: Assessment Date GAP # Type Checklist Description 001/017 Minor 4.1. Ta Ann has mapped the land areas that are under dispute as indicated in the revised maps G (Rejang), G3 (Pasin), and G4 (Woodley) for the revised LPF No concession, but particulars of the claimants were lacking. *Note: Major Gap = Non-Compliance / Minor Gap = Minor Gap raised can be upgraded to a Major Gap if not adequately addressed by the date of the next surveillance visit. Status of Outstanding GAPs GAP # Type Checklist Status Description Observations Obs # Checklist Description Waste disposal pit of the TAP Pasin Camp was observed without a fence According to the Proposed Tree Planting Plan, section 6.3.: Fire Protection, the Company stated that it will construct fire towers at accessible high spots. However, no fire towers have been built within the concession area. *Note: Observation raised can be upgraded to a Minor Gap if not adequately addressed by the date of the next surveillance visit. Status of Outstanding GAPs GAP # Type Checklist Status Description October 016: Safety measures to avoid accidental vehicle slip into rivers are inadequate. Placement of warning signs at river crossing points is inconsistent. 008/016 Minor 4..3* Closed 009/016 Minor 4.3.1* Closed October 017: Safety measures to avoid accidental vehicle slip into rivers were observed adequate. Warning signs and bridge signs were observed to be consistently erected at bridge crossings of Sg. Selabi and Sg. Sesega in Coupes 03E and 04E of Rejang Division. October 016: Several buffer zones were disturbed by road upgrading works, due to late placement of buffer zone signs. Prescribed width of stream buffer zone has not always been observed. October 017: Stream buffer zones were randomly checked in Coupes 3E and 4E of Rejang Division and observed to be protected and free from any form of disturbance or Ta Ann Plywood Sdn. Bhd. LPF No Page 10

11 encroachment. Prescribed width of stream buffer zones was also consistently observed. October 016: Dumping of a large number of old tires were observed at Coupe 0C Block 19A1. 010/016 Minor 4.3.4* Closed October 017: The location (GPS coordinates: N 01 o E 11 o ) of the previous tire dumping in Block 19A1 of Coupe 0C was observed to be free of any old tires. *Note: Gaps from previous year 016 report incorporated to the current STLVS P1-4. Highlights of Close out visit (if applicable) Not applicable Dates Recommendations Ta Ann Plywood Sdn. Bhd. has demonstrated compliance with the Sarawak Legality Standard (Principles 1-4) for LPF No and is recommended to receive a GFS Statement of Compliance and STLVS Certificate of Compliance from FDS. Gaps and observations identified in this assessment must be addressed by the next surveillance visit scheduled in October 018. Action required to close the gaps and observations include: Gap 001/017 (Minor) Checklist 4.1.: Ta Ann should ensure details of the local communities that have potential claims over the planted and unplanted areas in the revised LPF No concession are clearly documented. Observation 001 Checklist 1..4: Waste disposal pits should be equipped with proper fence. Observation 00 Checklist 1.3.1: According to the licensee, fire towers are not necessary to monitor fire. Therefore, the licensee should amend the Proposed Tree Planting Plan to not include the need of fire towers. The next surveillance will be scheduled in October 018. End of Summary Report Ta Ann Plywood Sdn. Bhd. LPF No Page 11