- -article 33 paragraph (3) of the 1945 constitution of the republic of indonesia affirms that the earth, water, and natural resources contained therein are controlled by the state and used for the greatest prosperity of the people, including in the management of forest areas. the utilization of production forest areas for development purposes outside of forestry activities is made possible through the forest area use approval (persetujuan penggunaan kawasan hutan/ppkh) mechanism as regulated in government regulation number 23 of 2021 concerning the administration of forestry, which replaced the forest area borrow-to-use permit (izin pinjam pakai kawasan hutan/ippkh) regime, while its technical provisions are regulated in regulation of the minister of environment and forestry number 7 of 2021. the research problems in this study are how the suitability of forest area use for development purposes under government regulation number 23 of 2021 applies to burial grounds, and how the obligations of ppkh holders for burial grounds are implemented for the purposes of conservation activities and the sustainability of production forests. the research method used is normative juridical, of a descriptive-analytical nature, sourced from secondary data and supported by primary data in the form of an interview with a first expert spatial planning officer in the spatial planning division of the karawang regency public works and public housing office (dinas pupr). the research data were analyzed qualitatively, with conclusions drawn using deductive reasoning. the results of the research indicate that the development plan for bhayangkara memorial hill is in principle consistent with article 91 paragraph (2) of government regulation number 23 of 2021 in conjunction with article 369 paragraph (2) letter g of ministerial regulation number 7 of 2021, which classifies religious activities (burial grounds) as strategic activities eligible for ppkh with exemption from non-tax state revenue (pnbp), compensation, and watershed rehabilitation obligations. however, it has not yet been fully compliant procedurally, as only an ippkh (decree no. sk.462/menlhk/setjen/pla.0/12/2020) has been obtained, while the non-business spatial utilization activity suitability (kkpr), building approval (pbg), and environmental documents have not yet been secured. the normative framework governing the obligations of ppkh holders is consistent with article 91 paragraph (1) of government regulation number 23 of 2021 and is formulated in the fourth ruling (amar keempat) of decree sk.462/2020, although full implementation remains prospective since physical construction has not yet commenced. the cause of the unresolved licensing process lies in the overlapping authority between the central and regional governments, as well as regulatory obstacles in the form of a licensing moratorium at the provincial level, which narrows the room for maneuver available to the applicant in the field