The High Conservation Value Resource Network. Technical Panel Peer Review of

Transcription

1 The High Conservation Value Resource Network Technical Panel Peer Review of High Conservation Value Forest Assessment of Forest Management Unit 23 & 24, Kalabakan, Sabah November

2 Contents Disclaimer... 2 Introduction... 3 Methodology... 4 General Recommendations... 4 Summary of Findings... 5 Summary Tables... 8 Full Review Disclaimer This review was conducted by the High Conservation Value Resource Network (HCVRN) Technical Panel according to the guidelines set out and approved by the HCVRN, in line with the HCVRN Charter, and is conducted in good faith on the basis of information provided by the review team. The HCVRN Technical Panel and the HCVRN can take no responsibility for the accuracy of information provided by WWF Malaysia and cannot be held liable in any way for any damage or loss resulting from the use or interpretation of this review by WWF-Malaysia, Rakyat Berjaya Sdn Bhd, or any third party. The opinions expressed in this review are those of the HCVRN Technical Panel and do not necessarily represent the views of the HCVRN or its Steering Group members. 2

3 Introduction This document is a High Conservation Value Resource Network (HCVRN) peer review of the report High Conservation Value Forest Assessment of Forest Management Unit 23 & 24, Kalabakan, Sabah prepared by Anna Wong and team from November 4 to December 17 th, The peer review was carried out following a voluntary request from WWF-Malaysia. It required a full review by 2 primary reviewers from the HCVRN Technical Panel with specific and relevant expertise. Each of the reviewers assessed the document independently and submitted their comments to a lead reviewer. The lead reviewer was in charge of compiling the results and producing a comprehensive peer review report. The report assesses various aspects of the HCV Assessment in question and records findings for each section in one of three categories: No issues - Indicates that the information provided is adequate; Minor issues - Indicates that the section topic has been addressed but that there is scope for improvement e.g. in the use or interpretation of data; Major issues - Indicates that there has been a systematic failure to address the topic, or that the use or interpretation of data is wholly inadequate or inappropriate. Where several subsections contribute to the overall finding (i.e. sections 4, 5, 6, 7 of the review), the highest (most serious) category of findings in the subsections is assigned to the overall finding (e.g. if the issues for section 5 are assessed as follows: 5.1: -none; 5.2: -major; 5.3: -minor, then the overall finding for section 5 is: -major). The peer review is structured as follows: General Findings - Provides an overall evaluation of the HCVF Assessment in question, clearly describing the strengths and weaknesses of the Assessment, and highlighting any issues which need further investigation or resolution. This section also includes other concerns identified during the review process which are strictly outside the remit of the peer review. Summary of Findings - This section shows the Summary Tables for Checklists A, B and C for rapid reference to the issues identified in the full review. Full Review - This section shows the Checklists A, B and C, as appropriate, that were utilized by the reviewers to assess the adequacy of the Assessment in question. 3

4 Methodology For the purposes of conducting this review the HCVRN Technical Panel followed the guidance set by the document: Reviewing High Conservation Value Reports: HCV Resource Network Guidance for Peer Reviews of HCV Assessment Reports (Version 2.1, September 2010). This document provides guidance and standard templates for conducting a peer review of an HCV assessment report, based on the guiding principles of the HCVRN as described in the Network s Charter. For further details of the Technical Panel Peer Review Process please refer to the HCVRN website. General Recommendations The following recommendations can improve the HCV Assessment report and can support in the appropriate identification, management and monitoring of High Conservation Values: 1. The reporting can be improved by following the Good practice guidelines for High Conservation Value Assessments: A Practical Guide for Practitioners and Auditors, which provides valuable advice on the creation of a suitable HCV Assessment report. 2. Additional guidance on the production of high quality HCV Assessment reports can be obtained by evaluating previous reports. These reports can be obtained at the HCV Resource Network webpage. 4

5 Summary of Findings The assessment area covered by the report contains HCVs of the highest order of global significance, particularly as they relate to HCVs 1, 2 & 3. For this reason, a high standard for data collection, analysis and interpretation is required for making decisions regarding delineation of HCVF, HCV management areas (HCVMA) and the management prescriptions that would maintain and enhance these values. Consequently, the technical panel peer review concludes that major revision is required for the assessment report to adequately address the issues covered in the accompanying tables of the full review (Checklist C). Although these required revisions are extensive, we believe the assessment team and authors of the report have the expertise to accomplish this revision, for the report is clearly written and there is good understanding of the HCVs. However, much work needs to be done involving mapping and GIS work, and this expertise in producing and interpreting maps relevant to mapping the distribution of HCVs and their HCVMAs is critical for a successful revision. Below we briefly summarize the major issues. However, for a complete discussion of the issues, and for many others not summarized here, refer to the full review provided in Checklist C. Evaluation of the report and review of management prescriptions is severely hindered by the lack of background information on past, current and future management operations within the assessment areas of FMUs 23 & 24. The current status of the area must be described and mapped by forest cover and condition, and logging or other land use history. The future land use status for the area is unclear and must be explicitly detailed in terms of intended operations throughout the FMUs that will change the condition of its vegetation. Where are logging or other operations to be conducted and under what detailed plan of operations? Are some areas scheduled for some status other than natural forest under SFM? See detailed comments under C2 of the peer review, although these uncertainties restrict evaluation of several other questions about HCV management. Maps and GIS analysis of critical data are missing and therefore cannot be applied to make HCV assessments (see C2, C3, C4, C5 & C6). These include: a) The detailed remote sensing images that would detail forest land use history and current vegetative condition within the FMUs; b) Maps of current forest condition by forest or ecosystem type, forest structural condition reflecting logging history, and topography; c) Maps of biophysical features such as geology, soils and slope; d) Maps of watersheds, rivers and streams and; e) Maps of current forest use by villagers. Some of these maps are required for just the FMUs of the assessment area, but others should include the greater landscape extending beyond the FMUs. These maps are the basis for determining various scenarios for maintaining and enhancing different HCVs, and are not possible to evaluate without them. Maps are required that show the spatial distribution of each of the HCVs across the assessment area, and further, that show the HCVMA that will be managed in various ways from full protection to 5

6 specific logging prescriptions to safeguard these critical HCVs. This is perhaps not surprising given lack of some critical data and analysis highlighted in pt. 2 above. The full identification and spatial distributions of HCVs, especially HCVs 1-3 but also perhaps HCV6, needs to be carefully interpreted based on limited data collection methods, which need more detailed explanations. Biodiversity surveys were conducted over short periods and at a small number of sites, and it is critical that the precautionary principle is applied to not overextend these data. This applies especially to the lists of endangered and endemic species that are undoubtedly or likely to occur within the forests of the FMUs, but will be missed in surveys limited in time or space. It also applies to generalizations about species distributions without better data classifying areas by habitat type and condition. Management and monitoring prescriptions are not detailed in a way that can be operationalized or justified in terms of how they maintain or enhance the identified HCVs that occur within the two FMUs. As mentioned above, a critical first step is to determine management areas that would maintain the populations and habitat quality for HCVs 1, 2 & 3. The consultation process has to be expanded so that the full range of stakeholders can be consulted in the review of the revised report and on further data collection and management and monitoring decisions. Finally, but most importantly, is the significance of this assessment area for global biodiversity conservation under HCV2 (see especially C5.2 for detailed discussion, but also C3 and C6). As the best and last remaining large landscape of mineral soil (non-peaty) lowland forest in all of Borneo, this landscape in the lowlands of eastern Sabah represents the best and probably the only place where the full diversity of lowland plant and animal species can be conserved. This diversity is among the world s highest, and is restricted to mineral soils in upland, non-swampy lowland and hill forest especially below 500m, increasing towards the lower elevations of this range. The great proportion of this diversity is of rare species existing at low densities, thereby requiring very large areas to maintain the sufficiently large population sizes over the long term that minimize the risk of extinction. These species include many species of special conservation status, such as clouded leopard and helmeted hornbill. But most important are the endemic elephant subspecies limited to this specific landscape, and the subspecies of orangutan endemic to eastern Borneo, but with the great majority of its population in this landscape. The assessment area sits centrally within this landscape, linking protected forest and permanent forest reserves to its west, east and north. This argues emphatically that as much as possible of the area of these FMUs be maintained as forest habitat supporting this species and ecosystem biodiversity. Forest in excellent condition can serve as small protected areas within the FMUs while most is placed under SFM for ecologically sustainable, low impact timber extraction under natural forest management, finding an acceptable balance between selective logging and timber production and biodiversity conservation. Areas of forest degraded by previous logging, but within the spatial matrix of this landscape scale forest, should be allowed to recover to improved forest cover and habitat condition before 6

7 eventually entering SFM. If protected from fire, natural processes of forest succession should costeffectively improve overall average habitat quality over time, even while supporting SFM for timber extraction. Full assessment of these possibilities and scenarios of course requires maps and data detailed under the points above and in the full peer review. We suggest the following resources might be helpful in revising the report: Good practice guidelines for High Conservation Value assessments: A practical guide for practitioners and auditors, Christopher Stewart, Perpetua George, Tim Rayden and Ruth Nussbaum: 2008, ProForest /. Assessment, Management & Monitoring of High Conservation Values: A practical guide for forest managers, Tim Rayden: 2008, ProForest. Practitioners guide to managing High Conservation Value Forest in Indonesia: a case study from East Kalimantan. Meijaard, E., Stanley, S.A., Pollard E. H. B., A. Gouyon, and G. Paoli (2006). The Nature Conservancy, Samarinda, Indonesia /HCVF_Kalimantan.pdf. 7

8 Summary Tables The following summary tables highlight the major strengths and weaknesses found in the reviewed HCV Assessment report. These tables are completed by the reviewers after completing the full reporting tables that can be found in the next section of this document. Checklists A & B - Should be used wherever the HCV framework is used to support responsible management decisions outside of the context of a credible multi-stakeholder certification scheme for responsible natural resource management. Checklist C - Sections 6.3. and 8.1. (conversion issues) always apply if any conversion of natural or traditionally-managed areas is planned as part of the operations under review. Section 8.2. (other conservation values) always applies for applications outside of the context of a relevant multi-stakeholder certification scheme. If these conditions do not apply, sections 6.3 and 8 may be omitted from the review. Summary Checklist C: HCV identification, management and monitoring Project name: TP Peer Review Report of HCVF Assessment Report of FMU Unit 23 & 24, Kalabakan, Sabah Reviewers: HCVRN Technical Panel Date of review: July- November 2012 Description of document content: Issues identified C1. Executive summary of the document Overall Executive summary C2. Scope of the assessment Overall Scope C3. Wider landscape context and significance of the assessed area Overall Landscape context 8

9 C4. HCV assessment process including consultation process Overall HCV assessment process 4.1.Composition and qualifications of assessment team 4.2. Data sources and data collection methodologies 4.3. Consultation processes C5. Identification, location and status of each HCV Overall HCV identification 5.1. Addressing all six HCVs 5.2. Data quality 5.3. Reference to HCV toolkits 5.4. Decision on HCV status 5.5. Mapping decisions C6. Management of HCVs Overall HCV management 6.1. Assessment of threats or risks to each HCV 9

10 6.2. Are HCV management plans adequate? 6.3. Protection of HCVs from conversion N/A C7. Monitoring of HCVs Overall HCV monitoring 7.1 Are monitoring plans clearly described? 7.2 Are monitoring plans adequate? 7.3 Are there plans for a regular review of data? C8. Responsible management of other conservation values Overall: responsible management N/A 8.1. Conversion of non-hcv ecosystems N/A 8.2. Responsible management of other values N/A 10

11 Full Review This section shows the full review that was consolidated by the lead reviewer. It includes the comments and suggestions made by the other reviewers involved. In accordance with the HCVRN peer review guidance, this peer review does not include an assessment of issues in Checklists A & B, it only includes an assessment of issues in Checklist C. Checklist C: HCV identification, management and monitoring Project name: TP Peer Review Report of HCVF Assessment Report of FMU Unit 23 & 24, Kalabakan, Sabah Reviewers: HCVRN Technical Panel Date of review: July- November 2012 Description of document content: Issues identified C1. Executive summary of the document Overall Executive summary a) Are the key findings clearly presented and summarised? b) Does the summary accurately reflect the findings and recommendations of the main document? c) If no summary exists, is it still possible to use the document easily? C1. Reviewer comments: The key findings of the assessment are clearly presented and are in accordance with the recommendations of the main document. It is well written and organized, as is the main text. One major shortcoming is that it does not include a map of HCVF or HCV management areas (HCVMA). It is therefore hard to visualize how HCVs are maintained and protected without seeing how the FMUs are zoned by land use or various forms of management. The executive summary should briefly state the management aims of the assessment area, detailing both its history and current status of the forests, and what the forest conditions will be like under the management plan. The limitations of the surveys underlying the report should be mentioned, including where 11

12 further data are needed to complete mapping of HCVs and designation of HCVF. Note that the page numbers for tables and figures are inaccurate. C2. Scope of the assessment Overall Scope a) Is the assessment area and surrounding landscape clearly defined? b) Is there a basic summary of the company and its operations in the area? c) Are the impact and scale of proposed operations adequately described? d) Did exploitation of any kind (especially clearance) take place prior to the assessment, and if so, how are such areas treated? e) Is the purpose of the HCV assessment clear? C2. Reviewer comments: a) Yes/No: The assessment area comprises two contiguous FMUs that total 159,000 ha of mostly logged over lowland dipterocarp forest. These FMUs are adequately delineated in the text and clearly shown on figures 2 & 4. Figure 4 is useful as it shows land use in the adjacent areas to the south owned/managed by Yayasan Sabah. It would be useful if the land use plan for areas to the east and northern borders were also shown. Maps showing a combination of topography and land cover are needed for the FMU and the region surrounding the FMUs (see C3a below also). This map should show both natural forest types broken into classes of forest cover indicating extent of logging damage. b) No: There is no summary of the company and its plan of operations-- only that the plan is to re-log the FMUs. Are their ongoing operations? A timeline is needed of past and future operations, what a map that illustrates this plan, if possible. c) No: There is no description of the scale and impact of the planned logging operations. There is no explicit statement that the forest is to be placed under SFM and that RIL is to be implemented to limit damage to the residual stand. Is sustained yield a goal of the management? The scale of logging in the different slope classes is not defined. The species to be harvested, density of trees taken, and other management and silvicultural protocols that might influence HCVs should be summarized. d) Yes, logging was carried out in these FMUs but no details or maps are provided 12

13 critical to assessing when operations occurred. The extent of this logging, in terms of species harvested, dbh limits, methods of harvesting and damage to forest structure needs to be summarized. A forest cover map where this logging occurred. It is not possible to assess the relative conservation value of different forest area without this overlay of forest type, elevation and current forest status by recovery from prior logging damage. The designation of important HCVF from the HCVs requires assessment of remaining forest status through proper mapping. e) No, the purpose of the assessment is not clear. Although the main objective of the report is to conduct a full HCVF assessment for these two FMUs, it is not clear why this is being conducted. No mention is made that this is part of an FSC assessment, and that the clients seek to harvest certified timber or other wood products. It is also unclear what the long-term management objectives are. What is the longer-term plan for the FMU? These FMUs are in the heart of an important lowland forest conservation landscape (see C3 below), and should be maintained as a permanent forest reserve under SFM, as the Sabah Forest Department has indicated it is committed to follow. If this commitment includes these two FMUs, this should be made explicit in the report. It is worrisome that Figure 1 contradicts Figure 4 in that the areas designated as oil palm plantation and TPI conversion plantation are shown as Class II Commercial Forest Reserve, and part of the permanent forest estate in Figure 1. What is to prevent Yayasan Sabah from converting FMUs 23 & 24 to oil palm or other plantation with no biodiversity HCVs following this new round of logging? C3. Wider landscape context and significance of the assessed area Overall Landscape context a) Is the wider landscape convincingly and adequately described? b) Are the key social and biological features of the wider landscape clearly described? C3. Reviewer comments: The landscape context can be presented mostly as part of an introductory chapter or when evaluating the presence and mapping of specific HCVs. When relevant landscape-scale maps are presented under HCV findings, it is useful to reference these maps in the introductory chapter. a) No: The context of the wider landscape beyond the FMU should be described and mapped more completely. To assess the physiographic context of the FMU relevant to HCVs 1-3, it is important to show a regional map of forest cover and indicating 13

14 how extensive the forest types are in the general region, including the two protected areas. The typology of forest types should be specific for elevation distinctions, geology and soil types, and drainage (various types of swamp forest). The single paragraph defining forest ecosystems under section 3.0 of the Introduction is inadequate to properly describe the diversity of ecosystems and forest types under different combinations of soils, geology, and elevation. Maps of the original natural vegetation in the FMUs and surrounding landscape should be presented along with a current map of forest/vegetation cover showing a typology of prior logging damage, fire, etc. Information about forest cover, forest types and land use status is important to understand relationships between the FMUs and the landscape-level forest (HCV2) and corridors important for dispersal and movements of plants and animals and the threats to remaining forested areas. The map following pg. 80 under HCV2 is inadequate because it does not include the status of areas bordering the north side of these FMUs and does not show existing forest cover. (Note also that important information on pg. 16 cannot be read because the right margin is cut off.) b) No: The biogeographic status of this northeast Bornean region (e.g., following MacKinnon) should be described and mapped, because this will enable analysis of how well protected any endemic species and subspecies are within the region, as well as its unique species assemblages. This is not summarized under HCV 1.3, as only Borneo-wide endemism is discussed. We need to be able to evaluate the relative importance of the forests within the FMUs compared to other areas with similar mosaics of forest types and ecosystems. The maps indicated under C3a above are critical to this evaluation. No: The social features or the wider landscape are not described or delineated. Four villages were surveyed, but these were apparently selected because they were near flora and fauna assessment sites (pg. 16), or do these comprise all the relevant villages? Locations of human settlements and forest use areas are not mapped for the FMUs and the adjacent areas either in the Introduction or under HCV5 & HCV6 findings. This topic needs to be included in the Introduction. C4. HCV assessment process including consultation process Overall HCV assessment process For each of the sub-topics, was the process or effort proportionate and adequate relative to the likely impact and scale of operations? 14

15 4.1.Composition and qualifications of the assessment team a) Did the team include or have adequate access to relevant expertise to assess biological and social values? 4.1. Reviewer comments: The assessment team represents most areas of expertise and experience needed to assess the FMU for HCVs. However, it would be good to include a sentence or two for each member about their relevant expertise. Some of the shortcomings noted in the landscape context and HCV findings indicate a need for a tropical forest conservation biologist/ecologist, although this might be within the expertise of team members. For instance, HCV2 & HCV3 require more expertise to classify forest into many more than two broad types and discuss need for landscape scale forests. Additionally, an expert on HCV4 is needed, or should be identified in the table of expertise. In fact, it would be good to include in the table of the survey teams who had responsibility for which HCVs. The HCV findings, landscape context and management recommendations are not supported or illustrated by relevant maps and GIS analysis. Data are not presented on the areas covered by the HCVs or by forest types, as defined by soils, elevation or logging damage. This might indicate that a GIS specialist was not available throughout the assessment planning and report writing processes Data sources and data collection methodologies a) Are data sources and data collection methodologies clearly described or referenced and summarised (and presented in annexes if appropriate), and are they adequate to identify HCVs? b) Were reasonable efforts made to fill gaps in the data, proportionate to the impact and scale of the operations? 4.2. Reviewer comments: a) No: In general, desktop resources, prior studies and databases are well integrated into evaluating HCVs. As indicated in C3 above, GIS analysis of forest cover, forest type, elevation and soils are not integrated. In addition, given the relatively low sampling effort for fauna and difficulty in concluding absence, the precautionary principle should be invoked in compiling lists of species under HCVs 1.2 & 1.3. In addition, field methodologies for HCVs 1.1, 1.3, 2 & 3 are not adequately described: Figure 4 shows the general location of these survey sites, but does not characterize the sites. 15

16 A table should be added that lists the survey locations by forest type and condition, and elevation. The sample sizes for faunal surveys are unclear; the Methods (pg. 9) merely state that line transects. were used in forest blocks of randomly selected sites. Were each of the 3-5 km transects sampled once for both diurnal and nocturnal fauna? What is meant by random? I think the sites were sampled at places within the FMUs that allowed access, rather than random. Similar details should be provided for the flora surveys. What was the sample area (line transect length x width) at each study site? Give at least an approximation. Most important, did the surveys cover a range of forest types, logging disturbance states, and elevation? What types were not sampled? Methods are not further clarified under the HCV findings. Description of transect survey methods, total sampling effort, the area over which these surveys were conducted, and other relevant details should be reported so the adequacy of coverage and its representativeness can be evaluated. The rationale for these survey methods, including if stratification was by different forest habitat should be discussed. In general, an argument or rationale for the adequacy of the field sampling design for assessing each HCV should be presented. Field data collection methods for HCV5 and 6 relied on questionnaire-based interviews with people from four villages, apparently based on their accessibility by road. Please compare these four villages with others that were not sampled (unless these were the only four). Please clarify if villagers were truly randomly selected (for instance, with each assigned a number that is then randomly drawn with equal probability), or based on who was available. b) Unclear: Unclear what biases in sampling distribution for fauna, flora or villages might be in need of adjustment or weighting of data Consultation processes a) Was there an appropriate consultation process for Identification of HCVs Management of HCVs Monitoring of HCVs b) Were appropriate existing initiatives engaged wherever possible (including existing local or international social, ecological or biological conservation initiatives)? 4.3. Reviewer comments: a) No: Consultations were held September 28, 2010 in the Sabah Forestry Department Head Office with WWF (Ms. Ivy Wong Ling Ling), SFD Deputy Director (Mr. Fred Kugan & Dr. Robert Ong) and the team leader (Anna Wong). On end of October 2010 another meeting selected 16

17 sites in the two FMUs for the HCVF assessment field sampling. The meeting included SFD, Tawau District Forestry Officer (Mr. Ismaili) and Yayasan Sabah Tawau Regional Manager, Tawau District (Mr Gregory) and the team leader (Anna Wong). However, no further stakeholder consultations to review findings, or management and monitoring of HCVs is mentioned. One was apparently scheduled after the 2 nd draft of the report (pg. 9) but this process is not described, nor is it clear if it took place. A public discussion of the report should take place, inviting community representatives, government officials (including the Wildlife Dept.), and members of NGOs, especially those involved in conservation of biodiversity. It is not clear that a concerted effort has been made to include local communities in the consultation process, particularly with respect to the identification of HCVs and their management. b) No: no reference is made to global conservation assessments of this area, and surprisingly, management plans for wildlife species in Sabah are not referenced. These include both orangutan and elephant action plans, for instance. A wider set of national and international conservation groups should be invited to discuss the report. C5. Identification, location and status of each HCV Overall HCV identification For all HCVs, are the following points addressed, and was the process or effort proportionate and adequate relative to the likely impact and scale of operations? 5.1. Addressing all six HCVs a) Are all six HCVs addressed in the report? b) If one or more HCVs are not addressed, is there adequate justification for not doing so (e.g. the HCV is absent beyond reasonable doubt)? 5.1. Reviewer comments: a) yes, the report addresses all six HCVs Data quality c) Are data detailed, recent and complete enough to make informed decisions on presence/status/location of the HCV? d) Is the precautionary principle appropriately invoked in the use of data? 17

18 e) Were maps, reports and other previously existing data up to date and adequate? f) Is there an understanding of the spatial accuracy of the data used? g) Should further data be collected before decisions are made? 5.2. Reviewer comments: HCV1.1: Data needed are straightforward and adequate. HCV1.2 & 1.3: c) No: Data are adequate to confirm presence of these HCVs in terms of their presence at different survey sites of the FMU, but there is no attempt to discuss the distribution of these values across the different areas of the FMUs. This requires maps of forest cover, natural forest type and forest condition. An interpretation must be provided from mapping these forest habitat types and conditions regarding the most valuable areas for biodiversity conservation, including endangered species. This mapping should highlight the very valuable and least disturbed lowland MDF areas. The presentation of these data should be revised, so that the main body of the report focuses on summarizing results and interpretations for distribution, management of monitoring of these HCVs. The main text does not need to report location of every individual noted at every survey site. Instead, place these in an appendix and provide tables of species (rows) x survey sites (columns). Also provide a table that lists the attributes of each sampling site by forest type, forest condition (previous logging damage), elevation and sampling effort. It is not possible to draw conclusions about the relative density of endangered species (e.g., bottom pg. 27) given that the mean values between sites cannot be compared statistically. Are differences between samples such as Fig. 6 due to sampling effort, habitat condition or forest type? Given the short period and limited areas of direct faunal surveys, it is a pity that careful interviews with flip charts of mammal and bird species were not conducted with local villagers who use the forest. These can add to the list of rare species that are likely or possibly present, as well as ones who are likely absent. d) No: Although there is no problem with identifications of flora and fauna species, the precautionary principle needs to be invoked, recognizing that surveys very limited in space and time cannot begin to record the many rare endangered species that reside in eastern Bornean lowland and hill MDF. The list of species from samples should be augmented with another list of species known to occur in these forest types and biogeographical region, in accordance with the precautionary principle. Desk research of available databases would complete this list. e-f) No: The location and spatial distributions of these HCVs is unclear. The list of species 18

19 from survey data merely indicate some species known to occur at these sampling sites, not their distributions. For instance, given limited sampling throughout these FMUs, is it possible to draw conclusions about the distribution of elephants (pg. 47)? As mentioned above, we do not know the stratification of survey sites by elevation, forest type and condition. What would be ideal are maps showing the possible extent of the populations of these species, based on relative habitat quality for groups of these species. Species groups should be based on population presence and densities in natural forest habitat types and extent of structural damage from prior logging. More field sampling may not be necessary if survey data can be extrapolated with desk research to map the approximate extent of the populations of these species by habitat type. Lack of these data and analysis limits not only necessary mapping of HCVs, but also the management plans for maintaining these HCVs (see below). This may not be possible, and the maps of these HCVs may extend across all areas of the FMUs. A major missing reference that needs to be incorporated into evaluating the effects of logging on species abundances is Meijaard, Sheil, et al. s Life After Logging (we note that the team leader of this assessment is one of the co-authors!). This reference summarizes how different levels of logging disturbance change habitat quality and population densities and viabilities for different species. Management guidelines can then be prescribed to minimize impacts on populations of different key species. Some species are very sensitive to logging disturbance, thereby arguing that areas free from logging and representing patches of natural forest with minimal disturbance be included in HCV 1.2 and 1.3 management areas. HCV1.3 (Note that comments above apply to both HCV1.2 and HCV1.3.) The list of endemic species is highly deficient; for instance, tufted-eared ground squirrels are Bornean endemics. The precautionary principle should be carefully invoked to list endemics likely to be here, although not seen during these limited surveys. In addition, it is useful to note species endemic to this region of Borneo, such as the Bornean pygmy elephant and the unique subspecies of orang-utan (P.p. morio) limited to eastern and north-eastern Borneo. This should also be mentioned in a special biogeography section for better landscape context in the Introduction. These endangered lowland endemics that are of great conservation concern make the future of these forests of global conservation importance. HCV1.4 c-f) Yes/Partial: Migratory bird species were recorded from some of the survey sites. Is there a specific type of habitat used by these species, or does the HCV extend across all forest types of both FMUs? HCV1.4 also defines specific locations that can occur throughout the FMU and it is unreasonable for the survey teams to have mapped every saltlick or fig tree, but are there important areas used by elephants and other large herbivores for mineral resources? It is critical that management and monitoring protocols are in place to search for these and map these in advance of harvesting specific annual blocks. 19

20 The importance of FMUs 23 & 24 as part of a critical, irreplaceable Bornean lowland forest landscape HCV2: The report concludes that HCV2 exists as the 59,000 ha Maliau Basin FR and also as riparian buffers and wildlife corridors to link other forest reserves adjacent to or outside of FMUs 23 & 24. However the key question also asks does any part of the FMU license area exist within or next to a large natural landscape. It is clearly true that the FMUs exist within a large landscape forest and are a key component to this, even if many areas have been logged. I think confusion arises because although in the Malaysian Toolkit, the FMU can be an HCV large landscape, the management recommendations (pg. 9) focus solely on wildlife corridors rather than the need for the FMU to contribute to the larger landscape forest. In fact, these two FMUs are central to the last remaining large block of lowland rainforest not only in Sabah (fig. 1), but in all of Borneo. As mentioned earlier, a map of existing forest cover with elevation contours would indicate the importance of this landscape, which extends east, west and north of these FMUs. It is important here to invoke the Global Toolkit definition for HCV2: Forest area contains or is part of a globally, regionally or nationally significant large landscape forest where significant populations of most if not all naturally occurring wildlife species exist in natural patterns of distribution and abundance (from Malaysian Toolkit). The best chance of sustaining large landscape forests to conserve the rich species diversity of the lowland forests of Borneo, and its many endangered endemic species, is in eastern Sabah--- this large contiguous of lowland and hill forest extending from the Ulu Segama and Kinabatangan forest areas to the east, through Danum Valley and west and north through and beyond Maliau Basin and Imbak Canyon reserves. Further points arguing for maintaining most (if not all) of FMUs 23 & 24 as part of a contiguous large landscape forest (as HCVF under HCV2) is the following: The species richness of Bornean lowland forests is among the greatest in the world. As indicated in the floristic sampling from Maliau Basin mentioned in the report, these forests, when adding up across species restricted to forest types, contain thousands of plant species and probably the full, rich diversity of Bornean lowland animal species. We emphasize that this great species diversity is in lowland forests, with the greatest at lower elevations below 500 m or so. Critical to arguing for the need for very large areas of contiguous forest habitat in Borneo and other tropical forests is the great number of very rare species that live at very low density. This includes many of the species of hornbills, the endemic Tufted-eared Ground Squirrel, many other vertebrates, and many tree species. Most of these are not necessarily wide-ranging or migratory, but require very large areas (500,000 to a million ha) to maintain viable populations (100s-1000s of 20

21 individuals). Unusually rare, low-density umbrella species essential to be maintained in this landscape include felids (including clouded leopard and many smaller cats), elephants, orang-utans and large birds such as helmeted hornbills. Many such species are also keystone species in trophic cascades, through their ecological effects maintaining species diversity as top predators, seed dispersal agents and pollinators. In general maintaining the species assemblage and community integrity of these forests requires maintaining the very rarest, low-density species. The areas of lowland forest in protected areas in Borneo in general, and specifically in Sabah, are too small to provide for the long-term conservation of this richest biodiversity in the lowland forests. For instance, Danum Valley at 43,800 ha, and Maliau Basin, at ha would only provide habitat for 8-10 clouded leopard individuals or helmeted hornbill pairs, if they occur at a density of one per 5 km2. A viable population should include 100s of individuals if possible, to protect against extinction. This large landscape includes the major habitat block of two endangered local Bornean endemics, the Bornean pygmy elephant and the eastern Bornean orang-utan. FMUs 23 & 24 provide habitat for an important % of the total populations (see Sabah Elephant Action Plan, 2011 and Orangutan Action Plan). Finally, but perhaps most important to consider for long-term biodiversity conservation, is the need for large contiguous, and habitat-rich landscape forests to safeguard species from changes that will occur through climate change in the next 20, 50 and 100 years: a) In the short term, we might expect disruption of climate in which eastern Borneo, traditionally experiencing infrequent, ENSO-related damaging drought with accompanying fires, with perhaps more frequent drought and fire episodes. The past years and this ever increasing threat argues for maintaining a buffer of extra habitat that can withstand habitat loss from these and other causes. Over the longer term, climate warming may require colonization of species to other habitats, especially up elevation gradients. Many Bornean species already practice seasonal or supra-annual population migrations timed with changes in food, especially fruit and seed, availability. It is important to maintain contiguity across the forested landscape from eastern to western Borneo to accommodate these possible---if not expected population shifts. For instance, a recent paper argues that the healthy persistence of the Sabah orang-utan population under climate change models of increasing temperature will require maintaining the forest reserves as habitat, and maintaining contiguity between eastern and western forests (Gregory, et al. 2012, Plos 21

22 One 7: 1-10). In conclusion, to maintain and enhance HCV2, it is essential that the remaining natural forests within these FMUs continue to form part of the permanent forest estate over the long term. These forests need not all be strictly protected, and the majority of the forests in the landscape might be placed under SFM management under RIL guidelines imposed to maintain adequate habitat quality. Although some lowland forest species suffer reduced densities from logging, the large area under SFM of natural forest, when combined with the contiguous strictly protected areas, should maintain viable populations. Recent analysis has shown lightly logged forest maintains adequate habitat quality for orang-utans although forests heavily logged or subjected to rapid successive coupes can drive populations locally extinct (Ancrenaz, et al. 2010, Plos One 5:1-11). HCV3: The report states that the FMUs are comprised of Lowland and Hill Mixed Dipterocarp Forest (MDF), and higher elevation heath forest (kerangas) and montane forest. Because the kerangas forest is of low stocking of timber trees and will largely be left unlogged and unconverted, more important is to consider how MDF varies within the FMU. Forest types are not mapped, which is essential for evaluating the distribution of this HCV and others. In addition, the classification in the report is too coarse to distinguish possible rare forest habitats. Note that 12 different forest types occur in the Maliau Basin Conservation Area as stated in the report. More forest types as indicated by soils and geology and by water relations (riparian and swamp forests) should be applied to evaluate the distribution of rare and endangered forest habitats and ecosystems. The data presented in the report are inadequate to identify the critical HCVF areas for management because there is no classification that shows the distribution of prior logging disturbance classes along with these forest types. Relevant data on logging damage & forest type may require analysis of aerial photographs as satellite imagery is likely inadequate to resolve important distinctions between well-structured natural undisturbed or lightly logged forest and MDF that is heavily damaged and mostly covered by Macaranga and other pioneer species. However, note that if sufficient patches of primary tree species exist in a matrix of heavily logged forest, the forest can recover its structure and biodiversity over time through natural succession. Although the report correctly identifies lowland MDF as rare and endangered and a high priority for conservation (pg. 71), strangely there are no management recommendations for maintaining or enhancing lowland forest as HCV3. In justifying and determining HCVF areas for this HCV3, it should be noted that in general, tree and vertebrate biodiversity and population densities in MDF is inversely related to elevation for many species. And there is a well-known pattern that figs and big woody climbers decline in diversity with elevation, as does overall forest productivity. The lower elevation MDF forests are therefore more important for biodiversity conservation and have been most damaged by logging and 22

23 converted to non-forest uses throughout Borneo. It is therefore critical to classify the areas within the FMU by elevation zone on a fine scale (50 or 100 m contours) and by prior disturbance. This map can then be used to prioritize areas for careful management to maintain habitat quality and biodiversity, even if largely under SFM. HCV4.1 a-g) No/Partial: Water catchment areas listed under 4.1 are the various class I & VI forest reserves and two others. Others are riparian buffer zones in which the legal requirements for width increase with stream or river width. Although it must be that a significant proportion of the FMUs are steep Class IV terrain, and high levels of sedimentation and chemical pollutants from logging operations can adversely affect downstream water quality, these steep slopes are not identified as HCV4.1 forest. Because topo maps are not provided, and the HCVF for HCV4.1 is not mapped, it is not possible to determine if this HCV has been accurately identified. Also, because villages within, adjacent to and downstream from the water catchment areas of the FMUs are not mapped, it is not possible to verify that water quality for these villages would be adequately safeguarded by these buffers. The report indicates that stream water is used by villages but unclear if this extends to all villages and if all were sampled. The report asserts that riparian buffers had been observed during the previous logging episode(s) but the survey methods providing data for this assertion are not provided. This highlights the need for background information in the Introduction on the history of logging in the FMUs. HCV4.2: Yes, except e-no: Although present as forests with slopes > 25 o, no map is provided showing these areas thereby designated as HCV4.2. The sentence on pg. 76: With the proposed development of 20,000 30,000 ha per year, soil erosion is expected to become a major environmental issue requires clarification, and presumably indicates that SFM is not intended for this area (?). What sort of development? Move this and clarify future plans in the Introduction. HCV4.3: More data and logical arguments are required to conclude that forest buffers from fire are not present. Figure 26 shows that widespread fires during the drought extended to near these FMUs (although the map needs to outline the FMUs on it). Because these forest fires especially penetrate logged over forest, and that these FMUs now have increased risk given logging that occurred since , why are they not under fire risk now? Given expectations that climate change (e.g., temperature increase, and increased severity of ENSO droughts) might increase fire risk, this risk, and the identification of forest areas that might mitigate risk, has to be taken more seriously. It is strange that the fire risk map (fig. 27) shows no risk for areas that have burned during previous drought and fire episodes. What has changed that makes these under lower risk now? HCV5: c, d & g): Yes 23

24 Survey data appear adequate to support the main conclusions that only a small percentage of villagers use nearby forests for hunting and for gathering medicinal plants and firewood. The survey sampling design is of high quality, stratified across the four villages, among men and women, and across knowledgeable age classes. The conclusions have a sound sampling basis for these four villages, which apparently include 8-10 different cultural groups. But again, it is not clear these are the only villages within or adjacent to the FMUs and no map of villages and infrastructure is provided in the introduction to the report. e & f): Data are inadequate to map the locations of HCV 5, and no map is provided. The toolkit recommends identifying and mapping specific locations of forest products through participatory mapping. The report does not indicate this was implemented for the four communities surveyed. HCV6: c-g) adequate: The report asserts that no traditional burial grounds exist within the assessment area as defined by FMUs 23 & 24. Lack of maps identifying locations of HCV 5 and HCV 6 makes it very difficult to understand the landscape context of communities in relation to the FMUs. There is no reference to background data on the many cultural groups in these data that might have guided questionnaires about their cultural practices and sites. Because no background is given for the expertise of any team members in the introduction or the appendix, it is unclear if those identified as social surveyors have expertise in these groups. Murut, Tidong and Bajau are ethnic group with a unique way of life, customs and beliefs. Murut for example, comprise one of the largest indigenous groups in Sabah, including subgroups such as Baukan, Gana', Kalabakan, Okolod, Paluan, Sulangai, Serudung, Tagal, Timugon and the Beaufort and Keningau Murut. Literally "Murut" means "hill people". They inhibit the interior and southeastern parts of Sabah and the territory straddling the Kalimantan and Sarawak borders. They are mostly shifting cultivators and hunters with some riverine fishing. Those of Murut origin speak 15 languages and 21 dialects. The language commonly used and understood by the large majority is Tanggal. Their language is also related to the Kadazandusun languages. Once feared as fearless headhunters and longhouse dwellers, the Murut these days have abandoned much of their age-old traditions especially headhunting. They are also very skilled in hunting with blowpipe. The assessment report s lack of description these and other ethnic groups does not lend confidence that a thorough investigation of their cultural and spiritual connection to forested areas could be accomplished during the interviews Reference to HCV toolkits a) Has a National Interpretation of HCVs been used, or (in the absence of a National Interpretation), have the generic HCVF Toolkit guidelines been appropriately 24