Peat Regulation by Greenpeace Indonesia

Protecting Indonesia’s peatlands How the new regulation is a flawed initiative 10 March 2014 _____________________________________________________________________ Why peatland protection is important Tropical peatland forests represent a unique ecosystem. Any change to the natural balance between water, soil and vegetation will result in greenhouse gas (GHG) emissions. Peatlands are formed when waterlogging delays the decay of organic material – mostly vegetation – and collects over thousands of years. It is estimated that peatlands globally hold 20-35% of the i ii world's terrestrial carbon . Indonesia’s peatlands store almost 60 billion tonnes of carbon , nearly iii six times more than all the carbon humans emitted in 2011 . When peatlands are drained, the stored carbon reacts with oxygen in the air to release carbon dioxide into the atmosphere. The dry peat also becomes highly flammable, increasing the risk of large-scale and long-term smouldering underground fires. Consequently, as new Greenpeace iv map analysis shows, almost 76 per cent of recent fire hotspots in Indonesia are on peatland . More than 86 per cent of the fire hotspots occurring in the area protected by the moratorium are v on peatland , despite the moratorium’s stated goal to temporarily halt new land clearance in these vi areas . Indonesia's peatlands cover less than 0.1 per cent of the Earth's surface but through draining and vii fires are already responsible for 4 per cent of global GHG emissions every year , making Indonesia one of the top global carbon emitters. Peatlands should not only be protected to eliminate an important source of climate-changing GHG emissions. Peatland forests largely overlap with critical wildlife habitat of endangered species like viii the Sumatran tiger and the orang-utan . ix

The main drivers of peatland destruction in Indonesia are palm oil and pulp plantations , draining the areas and making them prone to fires. Mapping evidence shows the extent to which the plantation sector is undermining the Indonesian government’s climate commitments through continued forest and peatland destruction. Almost 5.5 million hectares of oil palm and pulp concessions across Indonesia overlap with peatlands and around 50 per cent of recent fire x hotspots on peatland are inside those concessions .

The origins of the Peat Regulation (RPP Gambut) xi

Five years ago, the Indonesian Parliament passed Law No. 32 of 2009 dated October 3, 2009 regarding Environmental Protection and Management, commonly known as the ‘Environmental Law’. This law was an important step forward to improve ecosystem management and protection in Indonesia. To render this law effective however, the government still needs to adopt xii implementing regulations on several aspects . The Regulation on the Protection and Management of Peatland Ecosystems, the Peat Regulation in short, is the first of these regulations about to be effectively approved by the Indonesian government and President Yudhoyono, whose services have played a major role in driving the process forward. The Environmental Law and the Peat Regulation do not come out of the blue. They should be seen in the context of the President’s 2009 commitments to reduce GHG emissions by more than 26 percent by 2020 and up to 41 percent with international assistance, compared to business as xiii usual . 85 per cent of Indonesia’s greenhouse gas emissions come from land-use activities, xiv around half of this peat-related . The action plan that followed directly from President Yudhoyono’s GHG emissions reduction xv commitment was the National Greenhouse Gas Emission Reduction Action Plan in 2011 . It imposes a range of essential activities to be undertaken to achieve peatland protection, from surveys and data collection, inventory and mapping over criteria for protecting peat domes and

provincial-level master plans for peat protection to sustainable peat ecosystem management. Both horizontally and vertically, several government bodies are responsible for delivering the peat-related aspects of the action plan: the Ministry of Environment, the Ministry of Public Works, BAPPENAS, and provincial institutions. xvi

The new Peat Regulation adopts a similar approach and explicitly regroups the GHG Emission Reduction Action Plan’s deliverables into a mandate for the Ministry of Environment to develop a Peatland Ecosystem Protection and Management Plan that aligns national and local policies. It also specifies criteria for determining which peatland ecosystems should be protected and which ones can be cultivated. While this is a step forward to achieve policy coherency, the new regulation omits critical deliverables from other government policies and strategies, does not include all relevant political actors and its criteria are too weak.

The Indonesian government’s diffuse peatland protection and management policies During the past years, another set of strategic documents has been developed with an explicit mandate for different government bodies to work on a range of critical aspects to reduce emissions from peat degradation and to halt conversion of peatlands, next to the trajectory set in motion by the adoption of the Environmental Law and the National GHG Emission Reduction Action Plan. Although this second cluster of strategies and action plans also bears a direct relationship with President Yudhoyono’s GHG emission reduction commitments, it runs along a parallel trajectory set in motion by the bilateral REDD+ Partnership between Indonesia and Norway that was xvii concluded in 2010 with the signature of a Letter of Intent (LoI) . Two critical deliverables of the LoI are the development of an encompassing national REDD+ strategy and the establishment of a REDD+ Agency to oversee the development and implementation of all REDD+ related actions. Indonesia published its National REDD+ Strategy in 2012. The strategy includes an explicit mission to enhance peatland management institutions, improve relevant laws and regulations and improve capacity to manage peatland resources with an explicit mandate for the REDD+ Agency to improve peatland management through various measures including the implementation of the xviii moratorium . The Agency also received the mandate to prepare mechanisms and regulations to reclassify peatlands as permanent forests including facilitating land swaps and reviewing existing concessions. On top of that, integrated cross-sector landscape management systems are explicitly referred to as a key approach to improve the effectiveness of sustainable landscape management as well as conservation and land rehabilitation. An inventory of peatlands, an evaluation of their condition, research of exploitation permits and taking steps towards rehabilitation are all part of this approach. The overlaps with the mandate of the Ministry of Environment in the new Peat Regulation are obvious, especially because accelerating the implementation of the Environmental Law is cited as an explicit mandate for the REDD+ Agency. What is also obvious however is the omission in the new Peat Regulation of critical deliverables to halt disintegration of peatlands that are included in the National REDD+ Strategy: rehabilitation and restoration of peat ecosystems, a review of concessions, facilitating land swaps and the establishment of a database of degraded land. xix

The REDD+ Agency itself was only formally established in August 2013 . Its mandate explicitly refers to its coordinating role regarding REDD+ relevant matters but doesn’t empower the institution to impose actions on relevant ministries and does not involve the Ministry of Agriculture which is responsible for issuing agriculture plantation permits such as palm oil. The President’s choice not to give the Agency a strong mandate leaves the country without the coordinating body that would be required to tackle drivers of peat destruction and deforestation in an integrated way. The parallel mandate of the Peat Regulation for the Minister of Environment to develop a partial peat action plan confuses matters even further.

Why the new regulation will not save peatlands The overlap of mandates and responsibilities of different actors involved and the lack of involvement of key players such as the Ministry of Agriculture have led to a partial and diffuse approach to peatland management and protection with no coherent government action plan that integrates all relevant actions to effectively address the drivers of peat destruction. The Peat Regulation will perpetuate that problem. The lack of a holistic approach to peat ecosystems and landscapes and to addressing the drivers of peat destruction becomes very apparent in the weak criteria of the Peat Regulation to distinguish between peatland ecosystems that should be protected and those that can be cultivated. Shallow peatlands with a depth of less than one meter simply remain unprotected, without any consideration of the fact that these areas are often part of larger peat domes. These peat domes are at great risk of collapse when their fringes are degraded and should be entirely protected. The regulation also overlooks the fact that many hectares of peatland are located in existing concessions. It does nothing to protect these areas and neither does it consider a solution to deal with the many hectares of peatland covered by existing plantations from the perspective of the landscape approach that the National REDD+ Strategy promotes. In short, this regulation will not stop further disintegration of Indonesiaâ&#x20AC;&#x2122;s peatlands. The need for a coherent government approach is nevertheless obvious. The recent wave of peatland fires in Sumatra and Kalimantan are a case in point for what will continue to happen xx under a business as usual approach . A range of existing laws and regulations that partially protect peatland is simply not enforced: the 1990 Presidential Instruction on the management of xxi xxii protected areas including the protection of deep peat , the prohibition of burning to clear land , xxiii the renewed moratorium and various Ministry of Forestry decrees and regulations establishing national parks and protected forest areas. Adding a new regulation with another partial action plan into the mix is in and of itself not a solution.

Lagging behind global dynamics to halt peat destruction Meanwhile, a growing number of actors are engaging to eradicate peat destruction from global commodity supply chains. On the producer side, companies like Golden Agri Resources xxiv xxv xxvi (GAR) , Asia Pulp & Paper (APP) , Wilmar and the members of the Palm Oil Innovation xxvii Group have explicitly committed to stop peat clearance for the establishment of plantations. Those with a large amount of hectares of existing plantations on peatland are exploring and investigating solutions to mitigate the impacts. While still in need of much support, local communities are also increasingly tapping into global palm oil supply chain dynamics, by striving for Roundtable on Sustainable Palm Oil (RSPO) xxviii certification and developing good peat and forest governance practices . xxix

At the consumer end of the spectrum, an increasing amount of brands are engaging to ban palm oil from forest and peatland destruction from their supply chains and to work with their suppliers in order to achieve these goals. Consumer country governments are also developing initiatives to reduce peatland and forest xxx destruction in global supply chains, ranging from exploring public-private partnerships to xxxi measuring their global forest footprint . The Indonesian government has put in place policies and measures to halt peatland disintegration, but it has mainly done so from the perspective of REDD+ and reducing GHG emissions. A complementary global supply chain approach to address the most important drivers of deforestation has not yet been adopted by the government whereas its potential to help achieve the governmentâ&#x20AC;&#x2122;s GHG emission reduction goals is growing as more companies adopt similar engagements. Individual companiesâ&#x20AC;&#x2122; policies and their implementing methodologies should be integrated with government policy instead of existing alongside it. Moreover, corporate actors need government input and support to successfully implement their policies in the form of incentives for good practice; law development, enforcement and good governance to establish a level playing field for the entire sector, and an adequate regulatory

framework that enables the implementation of No Deforestation and Forest Conservation policies. Peat landscapes and wildlife habitat exceed concession boundaries. Integrated solutions at government level are necessary to enhance positive impacts of corporate peat protection and restoration initiatives.

Conclusions and recommendations President Yudhoyono’s new Peat Regulation will not improve the dire state of Indonesia’s peatlands and peat forests. It fails to protect all peatlands, including shallow peat and peat areas within existing concessions. A coherent action plan to protect and restore peatlands is missing, with many useful deliverables spread across parallel policy trajectories under different coordinating agencies. Meanwhile, corporate actors are already implementing policies to stop peat clearance. The Indonesian government should match their level of ambition and create an enabling framework for these initiatives to succeed. President Yudhoyono must refrain from signing the current draft Peat Regulation and instruct his government to: -‐

Revise the draft Peat Regulation to protect all peatlands;

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Develop a coherent peat action plan building on deliverables of all existing government action plans with a focus on integrated landscape level solutions. A government action plan also needs to include relevant private sector and communitydriven initiatives;

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Enforce the moratorium and ensure that new oil palm, pulp and other plantations are developed on low-carbon land;

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Review existing concession permits. Crack down on illegality, including failure to follow due process in licensing and failure to respect peatland regulations or prohibition of burning. Revoke the concessions of persistent offenders as well as those obtained in violation of legislation;

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Create a national public register of all concession types – including selective logging, xxxii palm oil, pulp and coal – and publish the One Map . Develop an independent national deforestation monitoring system to bring greater transparency to the process, ensure effective monitoring and enforcement, and empower local communities and other stakeholders. This would enable stakeholders to monitor the impact of operations, expose and make accountable those responsible for environmental destruction such as fires and illegal peat drainage and improve governance by enhancing enforcement efforts against those responsible for violations;

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Develop a database of degraded lands to allow for an effective land swap process, enabling legal concessions in forest and peatland areas to be exchanged for xxxiii concessions in low carbon value areas unencumbered with social, environmental or economic concerns.

For more information, contact: yuyun.indradi@greenpeace.org Greenpeace International Ottho Heldringstraat 5 1066 AZ Amsterdam The Netherlands Tel: +31 20 7182000 greenpeace.org

Appendix 1

FIRE HOTSPOTS IN FEBRUARY 2014 IN PEAT LAND AND MORATORIUM AREAS 100°0'0"E

110°0'0"E

120°0'0"E

130°0'0"E

140°0'0"E

Sou

Chi

Sea

5°0'0"N

PH I LIP P I NE S

MA LAY S IA MA LAY S IA

C el ebes Sea

0°0'0"

rim

0°0'0"

Ka at a ra

Sulawesi

Maluku

Papua

Java Sea

5°0'0"S

Kalimantan

Sumatra

Banda Sea

Java

Bali

Nusa Tenggara

Arafur u S ea

120

240

480

720

960 Km

10°0'0"S

EAST TIMOR

100°0'0"E

AU S TR A LI A 110°0'0"E

120°0'0"E

130°0'0"E

140°0'0"E

Legend: FIRE HOTSPOTS, Feb 1st - March 2nd 2014 : NATIONAL BOUNDARY COASTLINE PEAT (20.6 MILLIONS HA) IN MORATORIUM AREA IS 11.21 MILLIONS HA

1- Total of FHS in Indonesia : 11.288 2- FHS on peat land area : 8.542 or 75.7 % from total FHS 3- FHS on Moratorium area : 3.758 or 33,3% from total FHS 4- FHS on peat land inside Moratorium area : 3.247 or 86,4% from FHS in Moratorium area

MORATORIUM REV.5 : PEAT (5.47 MILLIONS HA) PRIMARY FOREST (59.14 MILLIONS HA)

Map projections using World Mercator with parameters : Central_Meridian: 117.0 Standard_Parallel_1: -2.5

Data sources : 1. Indonesia Peat Land provided by Wetlands International 2006, updated on 2014 in locations: Central Kalimantan, Jambi, and South Sumatera 2. Fire Hotspot provided by NASA, digital data downloaded from website: http://earthdata.nasa.gov/data/near-real-time-data/firms/active-fire-data 3. Moratorium Area provided by Planology Directorate, Ministry of Forestry, Indonesia 2013, digital data downloaded from website: http://www.ukp.go.id/informasi-publik/cat_view/20-geospasial

Analysis and map produced by Greenpeace Indonesia, March 2014

Appendix 2

FIRE HOTSPOTS IN FEBRUARY 2014 IN PEAT LAND AND CONCESSIONS AREAS 100°0'0"E

110°0'0"E

120°0'0"E

130°0'0"E

140°0'0"E

Sou

Chi

Sea

5°0'0"N

P H ILIP P IN E S

MA LAY S IA MA LAY S IA

Celebes Sea

0°0'0"

Ka m at a ra

Sulawesi

Maluku

Papua

Java Sea

5°0'0"S

ra i

Kalimantan

Sumatra

Banda Sea

Java

Bali

Nusa Tenggara

Arafuru Sea

120

240

480

720

960 Km

10°0'0"S

EAST TIMOR

100°0'0"E

AU S TR A LIA 110°0'0"E

120°0'0"E

130°0'0"E

140°0'0"E

Legend: NATIONAL BOUNDARY COASTLINE PEAT (20.6 MILLIONS HA) CONCESSIONS : HTI Concession (12.34 millions Ha) 2.78 millions Ha in Peat Area Palm Oil Concession (15.26 millions Ha) 2.68 millions Ha in Peat Area

Map projections using World Mercator with parameters : Central_Meridian: 117.0 Standard_Parallel_1: -2.5

FIRE HOTSPOTS, Feb 1st - March 2nd 2014 : 1- Total of FHS in Indonesia : 11.288 2- FHS on peat land area : 8.542 or 75.7 % from total FHS 3- FHS on peat land inside Palm Oil concessions : 2.160 or 25,3% from FHS in whole peat land 4- FHS on peat land inside Pulp & paper concessions : 2.387 or 27,9% from FHS in whole peat land 5- FHS on peat land inside the concessions : 4.150 or 48.6% from FHS in whole peat land Data sources : 1. Indonesia Peat Land provided by Wetlands International 2006, updated on 2014 in locations: Central Kalimantan, Jambi, and South Sumatera 2. Fire Hotspot provided by NASA, digital data downloaded from website: http://earthdata.nasa.gov/data/near-real-time-data/firms/active-fire-data 3. HTI Concession MoFor (2010) HTI concession maps, provided by the Planning Department of the Ministry of Forestry, Indonesia, downloaded September 2010 (http://appgis.dephut.go.id/appgis/kml.aspx ). Updated with 1) MoFor (2010) Pemanfaatan Hutan, Data dan Informasi, 2010, MoFor , November 2010, www.dephut.go.id/files/Buku_pemanfaatan_2010.pdf and 2) MoF (2011), online WebGis Kehutanan, online interactive map http://webgis.dephut.go.id/ditplanjs/index.html accessed May 12 2011 4. Palm Oil Concession Greenpeace (2013) based on agriculture plantations maps, provided by the Planning Department of the Ministry of Forestry, Indonesia, downloaded on July 29, 2010 (appgis.dephut.go.id/appgis/kml.aspx), supplemented and updated by Greenpeace in Riau and Kalimantan with data gathered from provincial planning agencies (BAPEDA) and various plantation companies.

Analysis and map produced by Greenpeace Indonesia, March 2014

Appendix 3

FIRE HOTSPOTS IN FEBRUARY 2014 IN PEAT LAND AND SPECIES HABITATS 100°0'0"E

110°0'0"E

120°0'0"E

130°0'0"E

140°0'0"E

Sou

Chi

Sea

5°0'0"N

P H ILIP P IN E S

MA LAY S IA MA LAY S IA

Celebes Sea

0°0'0"

Ka m at a ra

Sulawesi

Maluku

Papua

Java Sea

5°0'0"S

ra i

Kalimantan

Sumatra

Banda Sea

Java

Bali

Nusa Tenggara

Arafuru Sea

120

240

480

720

960 Km

10°0'0"S

EAST TIMOR

100°0'0"E

AU S TR A LIA 110°0'0"E

120°0'0"E

130°0'0"E

140°0'0"E

Legend: NATIONAL BOUNDARY COASTLINE PEAT (20.6 MILLIONS HA)

FIRE HOTSPOTS, Feb 1st - March 2nd 2014 : 1- Total of FHS on Indonesia : 11.288 2- FHS on peat land area : 8.542 or 75.7 % from total FHS 3- FHS on peat land inside Tiger habitat : 4.386 or 38,9% from total FHS 5- FHS on peat land inside Orangutan habitat : 120 or 1,1% from total FHS

TIGER HABITAT (20.9 MILLIONS HA) There are 3.92 millions ha of peat in this area ORANGUTAN HABITAT (11.11 MILLIONS HA) There are 2.56 millions ha of peat in this area

Map projections using World Mercator with parameters : Central_Meridian: 117.0 Standard_Parallel_1: -2.5

Data sources : 1. Indonesia Peat Land provided by Wetlands International 2006, updated on 2014 in locations: Central Kalimantan, Jambi, and South Sumatera 2. Fire Hotspot provided by NASA, digital data downloaded from website: http://earthdata.nasa.gov/data/near-real-time-data/firms/active-fire-data 3. Tiger Habitat provided by World Wildlife Fund (WWF), May 2010, digital data downloaded from website: http://www.savesumatra.org/index.php/newspublications/map/0/Species%20Distribution%20Map 4. provided by Wich et al (2008) Distribution and conservation status of the orang-utan (Pongo spp.) on Borneo and Sumatra

Analysis and map produced by Greenpeace Indonesia, March 2014

IGBP (1999); Patterson (1999) cited from: Noor, et al 2005. Community-based Approach to Peatland Adaptation and Management in Central Kalimantan, Jambi and South Sumatra, Indonesia. Published in: Mudiyarso D. & H. Herawati (eds) 2005. Carbon forestry: who will benefit. Proceedings of Workshop on Carbon Sequestration and Sustainable Livelihoods, http://www.cifor.org/publications/pdf_files/Books/BMurdiyarso0501.pdf : 128. ii Page, S.E., Rieley, J.O. & Banks, C.J. 2011. Global and regional importance of the tropical peatland carbon pool. Global Change Biology 17: 798–818 iii IPCC (2013) Climate Change 2013: The Physical Science Basis. Working Group I contribution to the IPCC 5th Assessment Report Ch. 6 http://www.ipcc.ch/report/ar5/wg1/#.Um6XYDhFD5o iv See Appendix 1: Fire Hotspots in February 2014 in peatland and moratorium areas. v Ibid. vi President of the Republic of Indonesia 2013. Instruksi Presiden Republik Indonesia Nomor 6 Tahun 2013 Tentang Penundaan Pemberian Izin Baru Dan Penyempurnaan Tata Kelola Hutan Alam Primer Dan Lahan Gambut, http://sipuu.setkab.go.id/PUUdoc/173769/Inpres0062013.pdf. vii Based on emissions from deforestation of 8.52 billion tonnes. IPCC WGIII (2007): 104. Indonesia’s peatland emissions are 1.8Gt/year. Hooijer et al (2006): 29. CIA (2007) gives global land area as 15 billion hectares. IPCC, Working Group III 2007. Climate Change 2007: Mitigation. Contribution of Working Group III to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change Metz B., Davidson O. R., Bosch P. R., Dave R., Meyer L. A. (eds), Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA. Hooijer, A, M Silvius, H Wösten, H and S Page (2006) PEAT-CO2, Assessment of CO2 emissions from drained peatlands in SE Asia Delft Hydraulics report Q3943 7 December 2006 www.wetlands.org/ckpp/publication.aspx?ID=f84f160f-d851-45c6-acc4-d67e78b39699: 29 viii See Appendix 3: Fire hotspots in February 2014 in peatland and species habitat. ix Greenpeace mapping analysis, based on landcover maps for 2009 and 2011, provided to Greenpeace by the Ministry of Forestry, Indonesia, in 2013. x See Appendix 2: Fire hotspots in February 2014 in peatland and concession areas. xi President of the Republic of Indonesia 2009. Undang-undang Republik Indonesia Nomor 32 Tahun 2009 Tentang Perlindungan Dan Pengelolaan Lingkungan Hidup, http://prokum.esdm.go.id/uu/2009/UU%2032%20Tahun%202009%20%28PPLH%29.pdf. xii Another critical aspect of the Environmental Law is the obligation to obtain an Environmental Permit as a precondition for obtaining other business permits. The Ministry of Environment drafted an implementing regulation which has still not been approved. xiii The Jakarta Globe, 22 November 2009. Greenpeace Calls Out SBY to Act on Indonesia’s Emissions, http://www.tffindonesia.org/index.php/en/the-jakarta-globe/170-greenpeace-calls-out-sby-to-act-on-indonesias-emissions. xiv National Council on Climate Change (DNPI) 2010. ‘Setting a course for Indonesia’s green growth’ Press conference presentation 6 September 2010, http://forestclimatecenter.org/files/2010-0906%20Setting%20a%20Course%20for%20Indonesia-s%20Green%20Growth%20%20DNPI%20Press%20Conference%20Presentation.pdf : 5. xv President of the Republic of Indonesia 2011. Presidential Regulation no 61_2011 regarding National Action Plan on GHG Emission Reduction, http://forestclimatecenter.org/files/2011-0920%20Presidential%20Regulation%20No%2061%20on%20The%20National%20Action%20Plan%20for%20Greenhouse%20G as%20Emission%20Reduction.pdf. xvi Government of the Republik of Indonesia 2014. Peraturan Pemerintah Republik Indonesia Nomor X Tahun X Tentang Perlindungan Dan Pengelolaan Ekosistem Gambut, http://jdih.menlh.go.id/pdf/ind/IND-RANC-3-2012-R.PP%20PPEG.pdf. xvii Government of the Kingdom of Norway and Government of the Republic of Indonesia 2010. Letter of Intent on Cooperation on reducing greenhouse gas emissions from deforestation and forest degradation, 26 May 2010. http://www.norway.or.id/PageFiles/404362/Letter_of_Intent_Norway_Indonesia_26_May_2010.pdf. xviii SATGAS REDD+ 2012. REDD+ National Strategy, http://www.unorcid.org/upload/doc_lib/Indonesia%20REDD+%20National%20Strategy.pdf. xix President of the Republic of Indonesia 2013. Peraturan Presiden Republik Indonesia Nomor 62 Tahun 2013 Tentang Badan Pengelola Penurunan Emisi Gas Rumah Kaca Dari Deforestasi, Degradasi Hutan Dan Lahan Gambut, http://www.fordamof.org//files/Perpres_62_20133.pdf. xx Aritonang, M. S. & N. Osman 2014. Disaster relief agency says the worst is yet to come. The Jakarta Post online Headlines, Wed, March 5 2014, http://www.thejakartapost.com/news/2014/03/05/disaster-relief-agency-says-worst-yet-come.html. xxi President of the Republic of Indonesia 1990. Keputusan Presiden No. 32 Tahun 1990 Tentang Pengelolaan Kawasan Lindung, http://www.bplhdjabar.go.id/index.php/dokumen-publikasi/doc_download/337-keppres-no32-tahun-1990-. xxii Burning to clear land is prohibited under Law No. 32/2009 on Environmental Protection and Management (see endnote xi) and Government Regulation No. 4/2001 on the Management of Environmental Degradation and/or Pollution linked to Forest or Land Fires: http://dsdan.go.id/index.php?option=com_rokdownloads&view=file&task=download&id=35%3App-nomor-04-tahun2001&Itemid=2. xxiii President of the Republic of Indonesia 2013. Instruksi Presiden Republik Indonesia Nomor 6 Tahun 2013 Tentang Penundaan Pemberian Izin Baru Dan Penyempurnaan Tata Kelola Hutan Alam Primer Dan Lahan Gambut, http://sipuu.setkab.go.id/PUUdoc/173769/Inpres0062013.pdf.

xxiv

Golden Agri Resources 2011. Golden Agri Resources Initiates Industry Engagement for Forest Conservation, 9 February 2011, http://www.goldenagri.com.sg/110209%20Golden%20AgriResources%20Initiates%20Industry%20Engagement%20for%20Forest%20Conservation.pdf. xxv APP 2013. APP’s Forest Conservation Policy, http://www.asiapulppaper.com/system/files/app_forest_conservation_policy_final_english.pdf. xxvi th Wilmar 2013. No Deforestation, No Peat, No Exploitation Policy, December 5 2013, http://www.wilmarinternational.com/wp-content/uploads/2012/11/No-Deforestation-No-Peat-No-Exploitation-Policy.pdf. xxvii th Palm Oil Innovation Group 2013. Palm Oil Innovation Group Charter, 13 November 2013, http://www.greenpeace.org/international/Global/international/photos/forests/2013/Indonesia%20Forests/POIG%20Charter%201 3%20November%202013.pdf. xxviii See e.g. Sawit Watch & Oxfam Novib s.d. Programme Scaling up sustainable palm oil for communities, smallholders and labourers to participate and benefit, http://www.oxfamnovib.nl/Redactie/Downloads/English/SPEF/103%20SpecialProj%20Leaflets%20%20Palmolie%20gewHerdruk%20-%20def%20LoR.pdf. xxix See e.g. Davidson, H. 2014. Greenpeace urges Procter & Gamble to reject harmful palm oil practices. The Guardian Online, 27 February 2014, http://www.theguardian.com/environment/2014/feb/27/greenpeace-urges-procter-gamble-to-reject-harmfulpalm-oil-practices. xxx Tropical Forest Alliance 2013. Tropical Forest Alliance 2020: Reducing Commodity-Driven Deforestation, http://www.tfa2020.com/index.php/objectives. xxxi European Commission 2013. The impact of EU consumption on deforestation: Comprehensive analysis of the impact of EU consumption on deforestation. Final report, http://ec.europa.eu/environment/forests/pdf/1.%20Report%20analysis%20of%20impact.pdf. xxxii One Map is a mapping system that standardises disparate accounts of forest cover, land use and administrative boundaries used by various ministries and local governments – see Anderson, J. 2013. A Conversation with Nirarta “Koni” Samadhi on Indonesia’s forests. WRI Insights 7 May 2013, http://insights.wri.org/news/2013/05/conversation-nirarta-koni-samadhiindonesias-forests#sthash.dh95bKFM.dpuf. xxxiii An appropriate HCS approach that is additional to a robust HCV assessment can be used as a proxy for identifying degraded land that was previously forest. Criteria for degraded lands should include the identification and exclusion of HCS forests and peatland. HCS forest is above the level between naturally regenerating secondary forest and degraded lands that have the vegetation of young scrub or grassland. The HCS approach effectively combines both biodiversity and carbon conservation through the goal of conserving ecologically viable areas of natural forest. See Golden Agri-Resources website ‘High carbon stock forest conservation’ and Greenpeace International 2013. Identifying High Carbon Stock (HCS) forest for protection, March 2013 http://www.greenpeace.org/international/Global/international/briefings/forests/2013/HCS-Briefing2013.pdf.