FORMAL REPORT ON ENCROACHMENT AND ENVIRONMENTAL DESTRUCTION BY PACIFIC ELITE
INVESTMENT LIMITED UNDER THE MOMASE LARGE-SCALE INTEGRATED AGRICULTURE PROJECT
Date: 15th / 10/ 2025
Prepared by: Eugene Mondu – Turubu Eco Forestry Development Program Inc.
Submitted to: East Sepik Environment Conservation and Climate Change Office
1. Background
This report highlights serious environmental and social
issues resulting from the ongoing operations of Pacific
Elite Investment Limited under the Momase Large-
Scale Integrated Agriculture Project (MLSIAP). The
company operates under Forest Clearance Authority
(FCA) No. 11-03 and Environmental Permit No. WD-L3
(196) / WE-L3 (150).
The project area covers parts of Turubu LLG (Wewak
District), Angoram LLG (Angoram District), and Sausso
LLG (Yangoru-Saussia District) within East Sepik
Province, with a gross area of 105,400 hectares, of
which 90,000 hectares are deemed suitable for
operation. The Environmental Permit was issued on 5
December 2008, and later amalgamated as EP-L3 (806)
on 19 November 2021, with a term of 25 years.
2. Nature of the Problem
The logging company, operating from Dandan Village, has now encroached into areas beyond agreed
customary boundaries, including lands
where no consent has been granted by
legitimate landowners. These include:
• Wugh Clan (Ward 8, Kamasau Village)
• Ngagam and Wau Clans (Ward 7, Tring
Village)
These encroachments have taken place
without prior consultation, awareness, or
consent from the affected clans and
communities, which violates the principles
of Free, Prior and Informed Consent (FPIC)
under national and international standards.
It is noted that the operations are being
influenced by a few semi-educated local
elites and “paper landowners,” who are supporting the continuation of logging despite widespread
opposition from genuine landowners.
3. Environmental and Social Impacts
Significant environmental destruction and ecological disturbance have already been reported, including:
• Destruction of wildlife habitats, particularly of endangered species such as Tree Kangaroos and
Black Cockatoos.
• Pollution of rivers and creeks, including contamination of drinking water sources at Dandan Care
Centre, where the Kadavar people reside.
• Clearing of forest areas that are part of the proposed extension of the Mojirau Wildlife
Management Area (WMA) — an area recognized for its high biodiversity and importance as a
nesting ground for wildfowl eggs and other species.
• Social tensions and conflicts among landowners due to misinformation and lack of proper
consultation.
4. Governance and Compliance Concerns
4.1 Lack of Environmental Compliance
Monitoring
There is no clarity on whether
Environmental Performance Reports
(EPRs) have been submitted or whether
CEPA has conducted inspections in line
with the Environment Act 2000, Section
82.
4.2 Unlawful Employment
The majority of workers are reportedly
foreign nationals (Asians) without valid
Work Permits, potentially breaching the
Employment of Non-Citizens Act 2007,
Section 6(1).
4.3 No Landowner Awareness or Consent
Most landowners in Turubu LLG are
unaware of the project’s scope or legal
basis, a clear breach of the FPIC principle,
and likely contravening the Forestry Act
1991, Section 90B(2)(a) and Environment
Act 2000, Schedule 2 (Public
Consultation).
4.4 Société Générale de Surveillance (SGS) PNG Ltd.,
Contracted by PNGFA to perform
third-party compliance monitoring,
has not reported breaches or
irregularities despite ongoing
landowner complaints and visible
encroachments. There is no publicly
available SGS verification of FPIC
compliance or of land boundary
observance.
This constitutes a failure of third-
party compliance auditing and
undermines public trust in the
regulatory process.
International Reference:
UNDRIP, Article 32 affirms Indigenous
peoples’ right to Free, Prior and
Informed Consent (FPIC) on matters
affecting their lands and resources.
6. Recommendations
A. Conservation and Environment Protection Authority (CEPA):
• Conduct urgent compliance inspections under the Environment Act 2000
• Confirm whether Environmental Performance Reports (EPRs) have been submitted
• Determine whether permit conditions under EP-L3 (806) are being fulfilled
• If not Terminate the Environmental Permit and Suspend the Operation
B. Papua New Guinea Forest Authority (PNGFA):
• Suspend FCA No. 11-03 pending a judicial review of legality and land acquisition processes
• Ensure all future operations comply with FPIC requirements
C. Department of Labour and Immigration:
• Investigate the employment status of foreign workers and ensure work permit compliance
D. Provincial and District Authorities:
• Facilitate an independent investigation into the social and environmental impacts
• Support inclusive community consultations on land use and project continuation
E. SGS PNG Ltd.
• Disclose monitoring reports for the project to date
• Explain the lack of compliance reporting regarding landowner disputes and encroachments
• Cooperate with any independent investigations or regulatory reviews
7. Conclusion
The situation in Turubu LLG constitutes a serious breach of environmental laws, land rights, and
constitutional protections. Continued operations under FCA No. 11-03 without proper legal and social
safeguards will result in irreversible environmental damage, social unrest, and legal liability.
We therefore strongly recommend that the Government of Papua New Guinea, through CEPA and
PNGFA, immediately halt all operations under FCA No. 11-03 until a full judicial review and compliance
audit is completed.
