The issuance of land patents to tillers is based on vested rights (i.e., 30 years occupation of the land) where lands from the public domain are distributed (no land valuation or amortization). No support services have reportedly been provided to beneficiaries of land patents, because according to the DENR, these lands become private property once they are transferred. Meanwhile, no program-wide impact studies have been done on CARP in public lands, as most of the impact studies on CARP have focused solely on the work of DAR. Upon review, the CARP targets for public lands appear to have been set too low, and there is greater scope for further improving tenure security in public lands. The final forest line has not yet been fully delineated, and vast tracts of public lands remain unclassified. But in the absence of a CARP program framework in public lands, there is a danger that tenure reforms for the estimated 22 million forest dwellers might be overlooked by the bureaucracy. While CARP in public lands is now considered “completed”, questions arise on the future tenure of forest dwellers and users. Since 2013, there has been a moratorium on the issuance of new tenure instruments in forests, leaving about half of the 500 thousand ISF/CSC holders without legal tenure, and many forest areas under open access. Also, many of the CBFM Agreements have expired after their 25-year leases and have not been renewed. And without tenure rights, there is little incentive for people to preserve and sustainably manage land, forests and biodiversity. With the passage of the Expanded National Integrated Protected Areas System (E-NIPAS) Law in 2018, a moratorium has also been declared on the issuance and renewal of tenure instruments (as well as concessions, licenses, permits, etc.) within the protected areas, until the management plan for each protected area is put into effect. The government wants to close all “open access” areas in forest lands by 2020. While this objective is driven by the need to protect, conserve and sustainably manage the country’s forests, the question is whether equal importance will be given to improving the tenure security and livelihood of forest dwellers. 28 Status of Land and Resource Tenure Reform in the Philippines 2018