ITS Global Greenpeace Audit Report

Audit of ‘How Sinar Mas is Pulping the Planet’ September 2010
Audit of ‘How Sinar Mas is Pulping the Planet’
Report for Asia Pulp & Paper (APP) by ITS Global
September 2010
www.itsglobal.net Page 1
ITS GLOBAL
International Trade Strategies Pty Ltd, trading as ITS Global

Level 26, 35 Collins Street, Melbourne, 3000
Tel: (61) 3 9654 8323
Fax: (61) 3 9654 4922
http://www.itsglobal.net
Commercial-in-confidence. The views expressed in this publication are those of its authors. The consultant takes no
liability for commercial decisions taken on the basis of information in this report. The information is accurate to the
best of the consultant’s knowledge, however the consultant advises that no decision with commercial implications
which depends upon government law or regulation or executive discretion should be taken by any person or entity
without that party’s having secured direct advice from the government agency concerned in writing.
Executive Summary
International campaign organisation Greenpeace published a report in July 2010, „How

Sinar Mas is Pulping the Planet‟. Its subject is primarily the conduct of Asia Pulp &
Paper (APP), an Indonesia-based pulp and paper company.
This independent audit from ITS global shows the leading allegation Greenpeace makes
against APP – that it secretly planned a massive expansion of its land use in Indonesia –
is based on a fiction. An examination of the evidence used to support this claim shows it
to be false.
In total, the Greenpeace report makes 72 claims against APP. It cites over 300 footnotes
and around 100 references. This evidence was systematically examined, and it does not
support the claims. Quotes are provided from documents in which they do not exist;
maps are provided which mark out concessions that do not exist, material with high
margins of error is treated as if there is none. Most of the leading claims are misleading,
speculative or based on distortions of the facts.
ITS Global commissioned two independent academic experts, one in forestry and
economics, and the other in agricultural science to review Greenpeace‟s claims. Both
describe the Greenpeace report as „highly misleading‟.
This report recommends that any information from Greenpeace be treated with the
utmost caution by customers or stakeholders that are attempting to gain an impartial,
non-politicised view of the market they are engaging with.
The audit of Greenpeace‟s claims shows that their two major claims related to the
company‟s expansion and its greenhouse gas emissions are not defensible:
Expansion
Greenpeace claims APP secretly planned to expand its concessions by 900,000 hectares
between 2007 and 2009. The source is an in-house APP document which Greenpeace
will not reveal. There is no evidence it was or is company policy. The public record
confirms this. Between 2007 and 2009 APP‟s supplier concession areas increased by just
over 25,000 ha.
To support its case, Greenpeace has produced maps marking out APP‟s concession
areas. They show four concessions that do not exist.
Greenhouse Gas Emissions
Greenpeace asserts APP is playing a major role in expanding greenhouse gas emissions
when Indonesia is already the world‟s third largest emitter. Greenpeace further alleges
that APP is engaging in extensive forestry on peatlands and contravening Indonesian law.
A review of the evidence shows these claims to be either groundless or seriously in error.
Greenpeace bases its peatlands claims against APP on a series of maps which, the author
admits and Greenpeace disregards, have significant margins of error (up to 31 percent).
Experts at Indonesia‟s leading agricultural university rate the margin of error as high as
90 percent.
Consequently, Greenpeace‟s contention that APP is a major contributor to Greenhouse

gas emissions is not legitimate. Nor is its claim Indonesian Government agencies show
Indonesia is the third largest emitter in the world. It ignores that the Indonesian
Government formally wrote to the United Nations stating that this was not correct. The
Indonesian government is not a „climate change denier‟. It has made a larger
commitment than any other developing country – and most developed nations – to
reduce emissions.
Credibility of the Greenpeace Report
Greenpeace has indicated that it is using the „Pulping the Planet‟ report to lobby APP‟s
customers to cease purchasing paper products from the company. In doing so,
Greenpeace is adopting tactics that suggest it considers itself beyond reproach.
Within the business world, actions that deceive or pass on false information to customers
and shareholders are held to account. Greenpeace is attempting to engage the business
world in relation to Asia Pulp & Paper and on a number of other fronts, yet its
communications are accountable to no-one.
Greenpeace states publicly that it is a campaigning organisation, not a conservation

organisation or research organisation. In this regard it must be acknowledged that its
views are political – and therefore partial. „Pulping the Planet‟ is a clear example of the
highly politicised nature of its public work.
This audit report indicates that the information Greenpeace is supplying to the market
and general public is both inaccurate and misleading. This report recommends that any
information from Greenpeace be treated with the utmost caution by customers or
stakeholders that are attempting to gain an impartial, non-politicised view of the market
they are engaging with. Not to do so presents a substantial business risk for corporations
that are seeking to make the most of opportunities in high-growth emerging economies
such as China and Indonesia, and in fragile markets in the developed world.
Table of contents
Executive Summary 3
Acronyms 6
1. Introduction 7
2. General Claims and Evidence Used in The 8

Greenpeace Report
3. Key claims of the Greenpeace Report 13
4. Methodology 17
Annex I: Pulping the Planet Analysis 19
Annex II: Greenpeace Maps Analysis 78
Annex III: Reviewer Statements and Qualifications 83
References 85
Acronyms
APP Asia Pulp & Paper

ADB Asian Development Bank
ASEAN Association of Southeast Asian Nations
CIFOR Center for International Forestry Research
CVF Conservation Value Forest
EIA Environmental Impact Assessment
ENGO Environmental non-government organisations
EOF Eyes on the Forest
FAO Food and Agriculture Organization of the United Nations
FOE Friends of the Earth
GDP Gross Domestic Product
ha Hectares
HTI Hutan Tanaman Industri (industrial timber plantation)
HRW Human Rights Watch
IKPP Indah Kiat Pulp & Paper
LEI Lembaga Ekolabel Indonesia (Indonesian Ecolabelling Institute)
LPPP Lontar Papyrus Pulp & Paper
MAI Mean Annual Increment
3
m Cubic metres
MT Metric tonne
MTH Mixed Tropical Hardwood
OFC Offshore Financial Centre
PT AA PT Arara Abadi
PT TMA PT Tebo Multi Agro
PT WKS PT Wira Karya Sakri
SMG Sinar Mas Group
WRI World Resources Institute
WWF World Wide Fund for Nature
WWFI WWF Indonesia
1. Introduction
ITS Global was commissioned by Asia Pulp & Paper (APP) to assess the validity and
accuracy of the claims made in the report authored by Greenpeace in 2010, „How Sinar
Mas is Pulping the Planet‟1 („the Report‟) based on the evidence cited in the report.
The following audit assesses the claims against the evidence cited in the Greenpeace
Report. It is thus an assessment of the objectivity and accuracy of the Greenpeace claims
made against the company.
The audit focuses on the claims made against APP, with lesser discussion of claims
against other companies such as PT Sinar Mas Agro-Resources and Technology (PT
SMART).
The audit was reviewed by two external reviewers that are sufficiently qualified in
ecology, agricultural science and forestry to review the audit.
1
Greenpeace (2010). How Sinar Mas is Pulping the Planet. Greenpeace Netherlands. Amsterdam
2. General Claims and Evidence Used in The Greenpeace Report
2.1 The broad claims of the Greenpeace Report
The Greenpeace Report attempts to demonstrate that APP and its supplier companies
are:
- Accelerating climate change;

- Destroying biodiversity;
- Causing deforestation;
- Breaking the law;
- Engaged in poor governance practices;
- Engaged in poor corporate social responsibility (CSR) activities;
- Engaged in nepotism;
- Of questionable reputation.
In addition, corporate information on the company -- such as levels of debt, size of

operations -- is presented.
In order to demonstrate the above practices, the Greenpeace Report describes the
behaviour and performance of a number of actors. They are:
- The Indonesian Government (generally);

- The pulp and palm industries;
- The Sinar Mas Group (including PT SMART)
- Asia Pulp and Paper;
- The Widjaja Family (the founders and shareholders of APP‟s business
operations).
The data are presented as both direct and indirect claims against APP, using a range of
evidence.
An analysis of the individual items based on footnotes (see Methodology) demonstrates a

total of 299 datum or claims in the report text. The subject matter can be broken down
as follows:
Table 2.1
Thematic Total claims
Corporate 63
Deforestation 56
Corporate Social Responsibility (CSR) 42
Biodiversity 35
Climate 33
Reputation 33
Governance 16
The Widjaja Family 8
Of the 299 items, 133 are claims made directly against the Sinar Mas Group. Of these
133 items, 109 are claims made directly at APP. The remainder are claims made at the
pulp and palm oil sectors more generally (3), at PT SMART (17), and at the Wijaja
Family (4).
Of these 109 claims, 36 are repeated elsewhere in the document; leaving a total of 73
direct claims against APP out of 299 items.
2.2 Evidence used in the Greenpeace report
The Greenpeace report draws on a broad range of sources. Sources were analysed for all
296 datum within the text, with the exception of repeat claims (56 in total), leaving a total
of 240 datum to be checked.
Use of sources is highly flawed. A breakdown showed flaws on 102 occasions, as follows:
Table 2.2
Use of data Occasions
Selective 36
Incorrect 31
Misleading 19
Speculative 13
Nonexistent 3
In addition, Greenpeace presents a map on page 14 of the report, which purports to

represent the existing planned concessions of APP‟s supplier companies, location of
existing forest areas, existing peat areas, and tiger habitat areas in the provinces of Riau,
Jambi and Sumatera Selatan (South Sumatra).
Comparison of current forest concession maps from the Indonesian Ministry of Forestry
(which Greenpeace claims to source) and the Greenpeace maps demonstrates major
flaws. Specifically, errors by Greenpeace demarcate:
- 4 areas as existing forest concessions belonging to APP that are non-existent

(non-existent data);
- 11 areas as „planned‟ APP forest concessions that belong to other forest
companies (speculative data);
- 4 areas as planned APP forest concessions that are existing forest concessions
(incorrect data).
Examples of the misuse of data are presented below.
2.2.1 Non-existent data
On two occasions the report makes claims regarding statements from other
organisations.
“In 2008, the Rainforest Alliance‟s Smart Wood programme withdrew

cooperation with APP, stating that: “It is the decision of Rainforest Alliance that
we do not wish to be used by APP again in order to mislead the public and the
consumers.”
The text quoted by Greenpeace does not appear in the source document.2
“In 2007, the FSC dissociated itself from APP and revoked its chain of custody
certificate: “…the FSC Board of Directors decided that FSC should not allow
any association of its name with APP or any company in which APP is a
majority shareholder, unless APP completely and immediately stops converting
natural forests and provides documented evidence of that cessation.”
The cited document3 does not contain the quoted text. The text from 'unless APP ...' is
not part of the original document. FSC did not revoke the chain of custody certificate; it
simply prevented APP from using the FSC logo or name in any of its communications.
2.2.2 Speculative data
The Greenpeace Report states:
Sinar Mas was aiming to expand its concessions by 900,000 hectares between 2007
and 2009. In 2006, over half of this area was still forested and a quarter of it was
peatland. Thirty of the new concessions encroached into some of the last forest
refuges for the critically endangered Sumatran Tiger. A dozen of them – covering
at least 130,000 hectares – overlapped peatland which is more than three metres
deep.
The Greenpeace Report relies upon a „Confidential Sinar Mas‟ document to make these
assertions, which are a speculation on activity that was ultimately not undertaken by the
company. During the period referred to, APP‟s pulpwood supplier‟s concession areas
increased marginally, by approximately 1 per cent – significantly short of the 900,000ha
that Greenpeace claims.4
2
Rainforest Alliance (2007) ‘Rainforest Alliance Public Statement, Termination of Contract to Verify
High Conservation Value Forests (HCVF) for APP in Sumatra, Indonesia’, January 2007
www.rainforest-alliance.org/forestry/documents/app.pdf
3
Forest Stewardship Council (FSC) (2007) ‘Forest Stewardship Council dissociates with Asia Pulp and
Paper’, Forest Stewardship Council Press Release, December 2007
4
At the end of March 2010, concession areas were 2,519,956 ha. In the middle of 2007, total
concession areas controlled by APP suppliers were 2,494,417 -- approximately 25,539 ha less than
currently.. It should also be noted that the Indonesian government statistics on APP supplier
concessions also differ from Greenpeace estimates; official Department of Forestry documentation
states that concession areas are 2,309,511 ha. (Cf. Ministry of Forestry (2010). Laporan Perkembangan
Pemanfaatan dan Penggunaan Hutan Produksi Triwulan I (Januari - Maret 2010). Ministry of Forestry,
Jakarta, Indonesia). The assessment in this report is based on the concession licenses: SK Menhut No. :
743/Kpts-II/1996, 25 November 1996; SK Menhut No. : 542/Kpts-II/1997, 25 Agustus 1997; SK
Menhutbun No. : 244/Kpts-II/2000, 22 Agustus 2000; Surat Menhutbun No. : SK.19/Menhut-II/2007, 5
Januari 2007; SK Menhut No. : SK.102/Menhut-II/2006, 11 April 2006; SK. Menhut No. : 366/ Kpts-
II/2003, 30 Oktober 2003; SK. Menhut No. : 365/Kpts-II/2003, 30 Oktober 2003; Surat Menhutbun
No. : 803/Menhutbun-VI/1999, 22 Juli 1999; SK Menhut No. : SK.101/Menhut-II/2006 11 April 2006;
SK Menhut No. : SK.18/MENHUT-II/2007, 5 januari 2007; SK Menhut No. : SK.207/MENHUT-
II/2006, 8 Juni 2006; SK Menhut No. : SK.104/Menhut-II/2006, 11 April 2006; SK Menhut No. : SK.
249/Kpts-II/1998, 27 Pebruari 1998; SK Menhut No. : SK.20/Menhut-II/2007, 5 Januari 2007; SK
Menhut No. : SK.554/Menhut-II/2006, 22 Desember 2006; SK Menhut No. : SK.553/Menhut-II/2006,
22 Desember 2006; SK Menhut No. : SK.555/Menhut-II/2006, 22 Desember 2006; SK Menhut No.:
SK.552/Menhut-II/2006, 22 Desember 2006; SK Menhut No. : 109/Kpts-II/2000, 29 Desember 2000;
SK Menhut No. : 71/Kpts-II/2001, 15 Maret 2001; SK Menhut No. : SK.122/Menhut-II/2007, 2 April
2007; SK Menhut No. 346/Menhut-II/2004, 10 September 2004; SK Menhut No. 68/Menhut-II/2004, 9
Maret 2004; SK Menhut No. : SK.401/Menhut-II/2006, 19 Juli 2006; SK Menhut No. : SK.
2.2.3 Misleading data
“[In 2009] the Ministry of Forestry authorised the company to produce over
360,000m³ of rainforest logs (i.e. Mixed Tropical Hardwood or MTH) and around
only 5,000m³ of acacia pulpwood (PT Artelindo Wiratama could, therefore, have
supplied a maximum of 5,000m³ of acacia pulpwood to PT Indah Kiat. However,
recent Greenpeace investigations including aerial images taken in March and April
2010, as well as Ministry of Forestry land cover maps show that the company had
not yet established any harvestable acacia plantations. The only acacia plantations
Greenpeace Southeast Asia investigators could find in March-April 2010 were
areas of six month-old acacia plantations.”
The statement misleadingly implies wrongdoing. Greenpeace attempts to assert that APP
could or should have supplied the approved quantity of plantation forest timber, but
instead supplied timber sourced from natural forests, and that it should have established
forest plantations by the time of writing. Yet the Greenpeace documents cited indicate
that the timber harvested was within the limits of its legal, government-approved annual
workplan. APP supplied around 12% of the quantity of timber that had been approved
by the workplan and is still in the process of establishing the plantations.
2.3.4 Incorrect use of data
“According to recent government estimates, Indonesia ranks as the world‟s third

largest GHG emitter”
The Greenpeace Report makes this claim citing various estimates of Indonesia‟s
emissions with the following footnote:
According to recent estimates published by various governments, Indonesia‟s

emissions (2005) are higher than Brazil‟s (2005), Russia‟s (2005) and India‟s (2005),
but lower than USA‟s (2005) and China‟s (2004): No 1: USA 6.18 GtCO2 in 2005.
Source: EPA 2010: 14 No 2: China 5.6 GtCO2 in 2004. Source: Government of
China (2007) No 3: Indonesia 2.25 GtCO2 in 2005. (See endnote 5) No 4: Brazil
~2.2GtCO2 in 2005: Source: MCT (2009): 19 No 5: Russia ~ 2.0 GtCO2 in 2005.
Source: UNFCCC (2009): 1 No 6: India ~ 1.6GtCO2. Source: Ministry of
Environment and Forests (2009): 53
The Report cites data that uses different methodologies that have not been standardized.
This is a grossly inaccurate misuse of data. Looking at the Climate Analysis Indicators
and Tools (2010) from the independent World Resources Institute, Indonesia ranked
fifth in terms of emissions, behind USA, China, EU and Brazil, for the year Greenpeace
cites. The WRI also indicates that Indonesia is ranked 57th in terms of per capita
emissions. Excluding land-use emissions for that year, Indonesia ranks 13th.
347/Menhut-II/2004, 10 September 2004; SK Menhut No. : SK. 29/Menhut-II/2006, 13 Pebruari 2006;

SK Menhut No. : 337/Menhut-II/2004, 7 September 2004; SK Menhut No. : 417/Menhut-II/2004, 10
Oktober 2004; SK Menhut No. : 339/Menhut-II/2004, 7 September 2004; SK Menhut No. :
SK.90/Menhut-II/2007, 22 Maret 2007; SK Menhut No. : SK.79/Menhut-II/2009, 5 Maret 2009; SK
Menhut No. : 750/Kpts-II/1996, 2 Desember 1996; SK Menhut No. : SK.332/Menhut-II/2007, 17
September 2007; SK Menhut No. : SK.179/Menhut-II/2007, 1 Mei 2007; SK. Menhut No. : 156/Kpts-
II/1996, 8 April 1996; SK. Menhut No. : SK.87/MENHUT-II/2007, 22 Maret 2007
Greenpeace also ignores the Indonesian Government‟s Second National Communication

under the United Nations Framework Convention on Climate Change in November
2009, which soundly dismissed the calculations leading to the conclusion that it is the
world‟s third largest emitter of greenhouse gases.5
2.3.5 Selective data
“The Red List reports that the Sumatran tiger is losing up to six percent of
its forested habitat per year, “due to expansion of oil palm plantations and
planting of Acacia plantations.”
The data cited is incomplete. The full entry for the Sumatran tiger notes that more than
three quarters of tiger deaths are due to poaching. The full entry states:
"The Sumatran tiger is declining due to high rates of habitat loss (3.2-5.9%/yr;
Achard et al. 2002, FWI/GFW 2001, Uryu et al. 2007) and fragmentation, which
also occur, to a lesser extent, inside protected areas (Gaveau et al. 2007, Kinnaird
et al. 2003, Linkie et al. 2003, 2004, 2006). There are high levels of human-tiger
conflict (Nyhus and Tilson 2004, Browne and Martyr 2007), as well as illegal trade
in tiger parts (Nowell 2000, Nowell 2007). From 1998-2002 at least 51 tigers per
year were killed, with 76% for purposes of trade and 15% out of human-tiger
conflict (Shepherd and Magnus 2004). Ng and Nemora (2007) found the parts of
at least 23 tigers for sale in market surveys around the island."
Moreover, the data cited does not give a full account of land use change and its
drivers in Indonesia. By way of example, current total plantation forestry
concessions in Indonesia total 8.7 million ha. Natural forest concessions exceed
25 million ha. Smallholder palm accounts for 14.2 million ha. Commercial palm
estates exceed 25 million ha. Total harvested agricultural land (excluding palm) is
19.7 million ha, and has expanded by 1.34 million between 2007-2009.6 Tiger
habitat loss is as much to do with fragmentation – a function of spatial planning –
as it is to do with area lost – noted in the cited source.
5Republic of Indonesia (2009). Draft Second National Communication under the United Nations
Framework Convention on Climate Change: Summary for Policymakers. Jakarta 2009
6
Ministry of Forestry (2010). Laporan Perkembangan Pemanfaatan dan Penggunaan Hutan Produksi
Triwulan I (Januari - Maret 2010) and BPS (2009). Perkembangan Beberapa Indikator Utama.
Sosial-Ekonomi Indonesia: Trends of the Selected Socio-Economic Indicators of Indonesia Oktober
Katalog BPS: 3101015
3. Key claims of the Greenpeace Report
3.1 Greenpeace’s key claims
The Greenpeace Report makes two key claims.
3.1.1 Expansion concessions
It purports to document plans by APP to significantly expand its operations through the
acquisition of further forested areas. The fibre sourced from these areas, as either natural
forest fibre or plantation forest fibre, would be used as feedstock for its two pulp mills
on Sumatra, Indah Kiat Pulp and Paper (IKPP) and Lontar Papyrus Pulp and Paper
(LPPP).
The Greenpeace Report defines these areas as „expansion concessions‟ or „expansion

areas‟.
3.1.2 Plantations on peat lands
It claims to have found evidence of wrongdoing by the company with regards to the
establishment of plantation concessions or of clearing of natural forest on areas of peat
with a depth greater than 3 metres.
An Indonesian Presidential Decree states that areas with a peat depth greater than three
metres should be designated as protected areas.
The relatively high organic matter content of peat soils and the increased rate of
oxidation once disturbed provides a basis for Greenpeace to make further claims that the
company is directly responsible for increased carbon emissions.
3.2 Evidence supporting the major claims
Few, if any, of the claims are supported by the evidence used. In the cases where the
evidence does appear to support the Greenpeace case, the evidence itself is questionable,
or is disputed among academic circles.
There are three such key pieces of evidence:
3.2.1 ‘Confidential Sinar Mas document, copy held by Greenpeace International’
Greenpeace claims APP secretly planned to expand its concessions by 900,000 hectares
between 2007 and 2009. The source is an in-house APP document which Greenpeace
will not reveal. There is no evidence it was or is company policy. The public record
confirms this. Between 2007 and 2009 APP‟s supplier concession areas increased by just
over 25,000 ha. ITS Global does not question the existence of the document despite
Greenpeace‟s unwillingness to release it publicly.
Closer inspection of the Greenpeace Report and a follow up document by Greenpeace

indicates that the source was a presentation during an internal management meeting in
2007. It was not approved nor implemented by Sinar Mas management. All claims
derived from the document must therefore be considered at best speculative and at least
of no consequence.7
3.2.2 Wahyunto, S. Ritung & Subagjo H (2003) ‘Peta Luas Sebaran Lahan Gambut dan
Kandungan Karbon di Pulau Sumatera (Maps of Area of Peatland Distribution and Carbon Content
in Sumatra), 1990-2002’, Wetlands International - Indonesia Programme and Wildlife Habitat
Canada (WHC)
Greenpeace‟s claim that APP has been undertaking activity on „deep peat‟ of a depth
greater than 3 metres relies upon the overlay of a map contained within the „Confidential
document‟ and maps produced by Wahyunto, et. al.
The maps used, which were published by Wetlands International, contain significant
error margins, as much as 31 per cent as admitted by the author. 8 The margin for error
associated with the methodology are described by a soil hydrologist from a leading
Indonesian University as high as 90 per cent. 9
Given such a high margin for error – 90 per cent – Greenpeace has no basis for the
allegations it makes concerning „deap peat‟.
3.2.3 Presidential Decree 32 of 1990’
Presidential Decree 32 of 1990 states that „peat soil with 3 meters thickness or more,
existing in the upstream river and swamp‟ is to be classified as a „protected zone‟. The
Decree prohibits cultivation activities in protected zones, except those „not disturbing the
protection function‟. The protection function of peat zones is defined as „controlling the
territorial hydrology, functioning as a water binder and prevention of flood as well as
protecting the specific ecosystem in the zone concerned‟. The Decree 32/1990 provides
authorities to the local governments to determine the protected zones, but retains
management functions with the National Government. Article 38 of the Decree states
that cultivation activity - and even mining - may take place in protected zones, if the
activity is managed in such a way that the protection function of the zone is maintained
and that the activity is regulated by the relevant Minister.
The blanket illegality of the 'three metre rule' is therefore not clear-cut. The conditions of
the decree permit any number of industrial activities within peatland areas, including
mining, forestry and agriculture.
The Decree itself overlaps with a number of other spatial planning laws. The Decree is
significantly different to Agricultural guidelines, which identify that areas with up to 76
cm deep peat are suitable for conversion to agriculture. Similarly, Provincial Spatial
Planning (Rencana Umum Tata Ruang Wilayah Propinsi, RUTRW) issued in 1992
7
Ministry OF FORESTRY (2006). STRATEGIC PLAN OF THE MINISTRY OF FORESTRY 2005-
2009 (REVISED), Jakarta, August 2006 Published by : Centre of Forestry Planning and Statistics
Forestry Planning Agency; Manggala Wanabakti Building, Block VII, 5 Floor; Jl. Gatot Subroto
Jakarta, 10270.
8
Wahyunto and I Nyoman N. Suryadiputra. 2008. Peatland Distribution in Sumatra and Kalimantan-
explanation of its data sets including source of information, accuracy, data constraints and gaps.
Wetlands International – Indonesia Programme. Bogor. xiii + 52.
9
Professor Budi Setiawan, Bogor Agricultural Institute, personal communication.
indicates the delineation of all peat swamp areas to fall under the status of Protected
Areas. There is, in other words, a need for institutional rationalisation of spatial planning
laws; moreover, there is a further need for implementing regulations once rationalisation
has taken place.10 Current legislative overlaps prevent the Decree from being used in
spatial planning implementation.11
3.3 Gross inaccuracies in the major claims
Notwithstanding the problems with the evidence used in the Greenpeace Report, there
are also significant problems with the way the evidence is applied. In particular, a map in
the report (p. 14) claims to indicate Sinar Mas‟ existing forestry concessions and the
location of its hypothetical „expansion concessions‟. This is based, according to the
Greenpeace report on the „Confidential Document‟ and concession maps released by the
Indonesian Ministry of Forestry.
The Greenpeace Report map demarcates four areas that it claims are „Sinar Mas‟ Existing
Concessions‟. However, the Ministry of Forestry map indicates that these areas are not
forestry concessions of any description. The map also demarcates 11 existing concessions
are „Sinar Mas Expansion Targets‟, which have been allocated to different companies.
It also demarcates four concessions as „Targets‟ that are, in fact, existing concessions that
are licensed to APP suppliers. The below image is included in a large format in Annex II.
10
Ministry of Forestry / IFCA (2009). REDDI: Reducing Emissions from Deforestation and Forest
Degradtion in Indonesia -- REDD Methodology and Strategies.
11
MoFor 2008, IFCA 2007 Consolidation Report : Reducing Emissions from Deforestation and Forest
Degradation in Indonesia, Published by FORDA Indonesia
4. Methodology
4.1 Text Analysis
The allegations made against APP in the Greenpeace Report were split into individual
items using Greenpeace‟s extensive footnoting. These are presented in Annex I, along
with the cited evidence, an assessment of the evidence, an assessment of the use of data
and an overall assessment of the claim. Where deemed necessary the authors have
introduced a counterpoint and cited response sources.
The 305 individual items were broken down by thematic area, based on the Greenpeace
text. This was based on the general contentions of the report that APP is:
- Damaging the climate (Climate)

- Destroying biodiversity (Biodiversity);
- Undertaking deforestation (Deforestation);
- Breaking the law (Illegal conduct);
- Demonstrating poor governance (Family and Governance);
- Engage in poor corporate social responsibility activities (CSR);
- Has a poor reputation (Reputation);
- Is a large company (Corporate).
The datum were then assessed as to whether they are a direct or indirect claim against the
Sinar Mas Group. For example, a claim about Indonesia‟s emissions more generally is not
a direct claim, but a claim about APP‟s management of forest concessions is.
The datum were then assessed to distinguish the subject of the claim, e.g. whether it is
APP specifically being named or PT SMART.
The data sources were then checked to assess whether the claim is supported by the cited
source. The use of data was subdivided as follows:
Non-existent – no supporting data found within the Greenpeace claims;
Speculative -- the claim is being made against events that are yet to take place or
are hypothetical;
Misleading – the data is cited in a way that is unclear or could easily be

misinterpreted;
Incorrect – the claim is not supported by the cited data;
Selective – the source cited contains relevant additional data that does not
support the Greenpeace claim, or there is publicly available data that supports a
credible alternative viewpoint.
4.2 Map analysis
The Greenpeace map was overlaid with gazetted concession areas utilising the two
commercial forestry concession licenses in Indonesia:
- Izin Usaha Pemanfaatan Hasil Hutan Kayu – Hutan Tanaman Industri

(IUPHHK-HTI – plantation forestry concession)
- Izin Usaha Pemanfaatan Hasil Hutan Kayu – Hutan Alam (IUPHHK-HA –

selective forestry concession)
The maps used were:
Direktorat Inventarisasi Dan Pemantauan Sumber Daya Hutan Dan Direktorat Jenderal
Planologi Kehutanan Departemen Kehutanan (2009) Peta Pemanfaatan Dan Perubahan
Peruntukan Kawasan Hutan, Provinsi Riau, Provinsi Jambi, Provinsi Sumatera Selatan.
Maps were downloaded in Adobe PDF format; concession areas were extracted using
Adobe Creative Suite (CS5) software.
Concession areas were scaled accordingly and overlaid on the Greenpeace map along
with the accompanying data relating to companies operating concessions. Extraneous
Greenpeace data that could be isolated (tiger habitat information, pulp mill locations) was
removed. Licence numbers and approval dates were extracted from Ministry of Forestry
(2010). Laporan Perkembangan Pemanfaatan dan Penggunaan Hutan Produksi Triwulan I (Januari
- Maret 2010). Ministry of Forestry, Jakarta, Indonesia. They have been included in the
Annex.
4.3 Independent Review
The audit was assessed by independent reviewers. Their statements and qualifications can
be viewed in Annex III.
Annex I: ‘Pulping the Planet Analysis’

See explanatory notes below.12
FN REPORT TEXT AND SOURCE RESPONSE TO DATA COUNTERPOINT / SOURCE DATA USE /
REPEAT
1 Tropical forest destruction is responsible for around 20 per cent of The UNFCCC 'Summary for Policymakers' Incorrect
CL global greenhouse gas (GHG) emissions..1 document cited does not assert this 20 per
1 UNFCCC 2007: Figure SPM.1; NCCC (2009a). cent figure; the detailed section of the AR4
report cites disagreement among experts as to
the extent of emissions from tropical forests.
In addition, the NCCC press release cited does
not contain any such information
2 Ending deforestation will not only preserve biodiversity but it must The document cited is a proposal to GEF but it Selective
CL be a central part of a global strategy to tackle climate change. is not available through the GEF website,
Peatlands are perhaps the world’s most critical carbon stores and a suggesting the findings are not agreed nor
key defence against climate change; they store somewhere adopted.
between a fifth and a third of the total carbon contained in the
terrestrial biosphere, including all soils and vegetation.2
2 UNEP (2002)
3 There are about 22.5 million hectares of peatlands in Indonesia3
CL 3 Hooijer et al (2006): 6
4 The vast majority of which are on the Indonesian island of The assertion that the 'vast majority' of Incorrect
CL Sumatra.4 peatlands is not supported by the document.
4 Hooijer et al (2006): 6 Page 9 of the document indicates that Papua
has a greater peat area than Sumatra. There
are also very significant areas in Kalimantan.
12
Explanatory notes: (1) The codification for themes in the footnote (FN) column is as follows: CL (Climate), DF (Deforestation), BD (Biodiversity), FA (Family), CO
(Corporate), CS (Corporate Social Responsibility). SC (Social Conflict), IL (Illegal conduct), RE (Reputation). (2) Claims made directly against APP are shaded.
REPEAT
5 The destruction of rainforests and carbon-rich peatlands5 The first source is not included in the The World Resources Institute Database indicates Incorrect
CL 5 Indonesia’s deforestation-related – including peatland – bibliography and cannot be verified. However, that Indonesia's land-use change emissions for
emissions were 1.88 GtCO2 in 2005. Source: DNPI (2008a). An an additional cited source (NCCC 2008b) that year were 1.459GtCO2 [1]. While there are
additional 0.36 GtCO2 are peat emissions that were classified as contains the figure of 1.87GtCO2. The problems with the WRI data that have been
‘non-commercial’ and should be included in Indonesia’s total , as Greenpeace figure conflates non-deforestation documented [2], the data is freely available and
they result from ongoing peatland emissions (‘Restoration of 5 and deforestation emissions on peat soils. often used by NGOs in determining emissions.
million ha of non-commercially used peatland could result in a According to the document cited, Indonesia's [1] Climate Analysis Indicators Tool (CAIT) Version
further reduction of 360 MtCO2e’). Source: NCCC (2009b). Fact total deforestation emissions from 7.0. (Washington, DC: World Resources Institute,
sheet: 2 deforestation on forests and peatlands are 2010).
0.78GtCO2: one-third of the Greenpeace [2] van der Werf, G.R., D.C. Morton, R.S. DeFries,
figure, and less than 9% of global deforestation J.G.J. Olivier, P.S. Kasibhatla, R.B. Jackson, G.J.
emissions. Including forest degradation Collatz, and J.T. Randerson. 2009. CO2 emissions
emissions takes the figure to 1.022GtCO2. from forest loss. Nature Geoscience 2: 737–38.
Additionally, the figure Greenpeace cites
confuses existing emissions with projected
emissions savings and/or offsets in the cited
document; this is not specified by Greenpeace.
6 is the key reason why Indonesia accounts for around a quarter of The assumption Greenpeace uses in its Incorrect
CL all GHG emissions caused by deforestation.6 calculation is incorrect (see fn5).
6 2.26 (1.88 + 0.36) GtCO2 / 8.88GtCO2 = 25%. Global
deforestation-related – including peatland – emissions in 2004
(latest year available) were 8.88GtCO2. Source: UNFCCC 2007:
Figure SPM.1; (NCCC 2009a). Also see endnote 5
7 According to recent government estimates, Indonesia ranks as the The conclusion cites data that uses different Climate Analysis Indicators and Tools (2010) for Incorrect
CL world’s third largest GHG emitter.7 methodologies that have not been the year Greenpeace cites indicates that
7 According to recent estimates published by various standardized accordingly, which is a misuse of Indonesia ranked fifth in terms of emissions,
governments, Indonesia’s emissions (2005) are higher than data. behind USA, China, EU and Brazil. The source also
Brazil’s (2005), Russia’s (2005) and India’s (2005), but lower than indicates that Indonesia is ranked 57th in terms of
USA’s (2005) and China’s (2004): No 1: USA 6.18 GtCO2 in 2005. per capita emissions. Excluding land-use
Source: EPA 2010: 14 No 2: China 5.6 GtCO2 in 2004. Source: emissions for that year Indonesia ranks 13th.
Government of China (2007) No 3: Indonesia 2.25 GtCO2 in 2005. Climate Analysis Indicators Tool (CAIT) Version 7.0.
(See endnote 5) No 4: Brazil ~2.2GtCO2 in 2005: Source: MCT (Washington, DC: World Resources Institute,
(2009): 19 No 5: Russia ~ 2.0 GtCO2 in 2005. Source: UNFCCC 2010).
(2009): 1 No 6: India ~ 1.6GtCO2. Source: Ministry of Environment
and Forests (2009): 53
REPEAT
8 The palm oil and pulp and paper industries are two of the major The report cited does not assess the drivers of Causes of deforestation in Indonesia are Incorrect
CL drivers of these escalating emissions.8 deforestation in Indonesia; nor does it name numerous: the conversion of forestlands to
8 MoFor (2008) XV, XXI either the pulp or palm as a major driver -- the agriculture for smallholders or otherwise; the
methodology of the paper distinguishes clearfelling of timber (illegally or otherwise) for
between planned/unplanned deforestation, sawnwood or roundwood; rapid urban
not the individual proximate causes. There are development; transmigration.[1] A number of
a number of contributors to forest loss in studies cite population pressure as one of the
Indonesia (see counterpoint); technological causes of deforestation[2];
improvements and increased knowledge on [1] For an overview of related literature, see
deforestation ultimately improve forest and Sunderlin, W.D. and Kesosudamo, I.A.Y. (1996).
land management. Rates and Causes of Deforestation in lndonesia:
Towards a Resolution of the Ambiguities. Center
For International Forestry Research Occasional
Paper No. 9.
http://www.cifor.cgiar.org/publications/pdf_files/
OccPapers/OP-09n.pdf. [2] Scotland, N. (2000).
Indonesia Country Paper on Illegal Logging.
Prepared for the World Bank-WWF Workshop on
Control of Illegal Logging in East Asia Jakarta, 28
August 2000, p.1. Department for International
Development and WWF. Murdiyarso, D.,
Puntodewo, A., Widayati, A. and van Noordwijk,
M. (2006). Determination of eligible lands for A/R
CDM project activities and of priority districts for
project development support in Indonesia. Center
for International Forestry Research, Bogor,
Indonesia.
9 The destruction of Indonesia’s forests and peatlands also has a The Chundawat article only assesses tiger Selective
BD devastating impact on biodiversity. The endangered orang-utan populations, not orang-utan populations
and the Sumatran tiger are just two of the species under threat of
extinction,9
9 Chundawat et al (2008)
10 in part due to the loss of natural forest habitat.10 There are two problems with the way this data Orang-utan species have been found to survive Misleading
BD 10 UNEP (2007): 9; Chundawat et al (2008) is sourced. I. Orang-utan populations in well within an acacia forest plantation complex. A
Indonesia are split between two sub-species -- study conducted by The Nature Conservancy and
REPEAT
the Borneo and Sumatran subspecies. The USAID's OCSP program found populations of close
critically endangered Sumatran orang-utan is to 5,000 individuals within an acacia plantation
not under threat from pulp and paper complex. The study recommended that "Acacia
plantations. The Borneo subspecies has plantation concessions should be considered in
actually adapted to well to acacia plantations future orangutan conservation strategies, given
in Indonesia (see counterpoint). II. The IUCN the large population of orangutans they host." [2]
data sourced for tiger species more broadly -- [1] Linkie, M., Wibisono, H.T., Martyr, D.J. &
and not the Sumatran subspecies. The IUCN Sunarto, S. 2008. Panthera tigris ssp. sumatrae. In:
data for the Sumatran subspecies states: "The IUCN 2010. IUCN Red List of Threatened Species.
Sumatran tiger is declining due to high rates of Version 2010.2. <www.iucnredlist.org>.
habitat loss (3.2-5.9%/yr; Achard et al. 2002, Downloaded on 12 August 2010.
FWI/GFW 2001, Uryu et al. 2007) and [2] Guillaume Albar M2 BGAE-IEGB Under
fragmentation, which also occur, to a lesser supervision of Erik Meijaard. "Study of orangutan
extent, inside protected areas (Gaveau et al. (Pongo pygmaeus morio) densities and distribution
2007, Kinnaird et al. 2003, Linkie et al. 2003, in Acacia mangium plantation concessions in East
2004, 2006). There are high levels of human- Kalimantan, Indonesian Borneo." OCSP, The Nature
tiger conflict (Nyhus and Tilson 2004, Browne Conservancy, University Montpellier.
and Martyr 2007), as well as illegal trade in
tiger parts (Nowell 2000, Nowell 2007). From
1998-2002 at least 51 tigers per year were
killed, with 76% for purposes of trade and 15%
out of human-tiger conflict (Shepherd and
Magnus 2004). Ng and Nemora (2007) found
the parts of at least 23 tigers for sale in market
surveys around the island." [1] Care must be
taken to minimise fragmentation of habitat,
but the nature of spatial planning in Indonesia
does not always make this feasible.
11 Controlled by the Indonesian Widjaja family,11
FA 11 See eg Studwell (2007): 164-167
REPEAT
12 the Sinar Mas group is one of the largest conglomerates in The source is a Greenpeace report and cannot Rainforest destruction' is a term used by Partial
DF Indonesia engaged in clearing rainforests and destroying be considered impartial or accurate; this is an Greenpeace for land-use change, as recognised by
peatlands.12 associative or circumstantial conclusion rather governments and intergovernmental
12 See eg Greenpeace International (2008a,b) than a careful calculation. organisations. The reasons for land-use change in
a developing country context are myriad; the
primary is the conversion of land for fuel and
food. It has also been noted by CIFOR and FAO [2]
-- the world's two leading forestry research
organisations -- that causes of deforestation are
often outside of the forest sector external to the
operation of the forest industry with quite
independent causes and drivers.
[1] Seymour, Frances. Speech presented at United
Nations Food and Agriculture Organisation
Committee on Forestry Meeting 19, Rome, Italy,
March 17, 2009.
http://www.fao.org/forestry/media/17189/0/0/.
[2] Jan Heino (2008). Statement by Jan Heino
Assistant Director-General, FAO Forestry
Department on behalf of the Collaborative
Partnership on Forests (CPF); Forest Day 2 6
December 2008, Poznan, Poland.
13 The group also has significant interests in coal mining, amongst
CO other sectors.13
13 e.g. Sinar Mas Group website: www.sinarmas.com
14 According to Globe Asia magazine, the Indonesian tycoon that
FA founded Sinar Mas, Eka Tjipta Widjaja, is considered to be the
second richest person in Indonesia, with a fortune worth USD 4
billion.14
14 Globe Asia (2010)
15 Sinar Mas palm oil and paper is used in a range of products sold in The source is a Greenpeace report and cannot Partial
CO stores and supermarkets around the world, from toilet paper and be considered impartial or accurate
luxury shopping bags to chocolate bars and doughnuts.15
15 Greenpeace International investigations 2009/2010. See also
GAR (2009a)
REPEAT
16 Between November 2007 and April 2010, Greenpeace released a I. The source is a Greenpeace report and According to the most recent FAO data, Indonesia Misleading
DF series of investigative reports on Sinar Mas16 and other key cannot be considered impartial or accurate. II. has 94,432 million ha of forests -- more than 50
players in the Indonesian palm oil sector. They revealed that Sinar The term 'remaining' implies that loss of these per cent of all land cover. Of this forest, 40 per
Mas was expanding its operations and encroaching on Indonesia’s areas is imminent, which is incorrect, and can cent has been set aside for protection and
remaining rainforests and peatlands. be considered emotive language. conservation purposes -- an area roughly equal to
16 Greenpeace International (2007); Greenpeace International Germany or Japan [1].
(2008a, b) Greenpeace UK (2009); Greenpeace International FAO (2010). GLOBAL FOREST RESOURCES
(2010a) ASSESSMENT 2010 COUNTRY REPORT INDONESIA.
FAO 2010/95. Rome, 2010
17 As a result, a growing number of international consumer

RE companies, including Unilever,17
17 Unilever (2009)
18 Kraft18
RE 18 Kraft Foods (2010)
19 and Nestlé,19
RE 19 Nestlé (2010)
20 suspended multimillion dollar palm oil contracts with Sinar Mas.20
RE 20 GAR (2009b)
21 Asia Pulp and Paper (APP), is Indonesia’s largest pulp and paper
CO producer.21
21 APP (2009b): 21; APP’s main rival in Indonesia is APRIL, which
has an annual capacity of 2.6 million tonnes of pulp and 0.75
million tonnes of paper. Source: APRIL (2009)
22 With its expansion into China in 1992,22 and, in 2008,
CO 22 APP China, Chairman’s Address www.app.com.cn/english/
aboutus_chairman.html viewed 8 June 2010
23 it became the fourth largest worldwide23
CO 23 RISI (2009b). RISI does not include APP or APRIL in this
ranking, as neither company publishes reliable figures on its
paper and paperboard (P&B) production. Greenpeace
International estimates APP’s global P&B production to have
been 10 million tonnes in 2007
24 it ranked as the world’s fifth largest tissue producer.24
CO
REPEAT
24 Tissue World (2008)
25 The group has recently set up new sales networks in the US,25
CO 25 Eagle Ridge Paper, USA. Source: RISI (2009a)
26 the UK26
CO 26 Arco Paper website refers its APP mills in China as ‘Our mills
at Gold East, Gold Huasheng and Ningbo Zhonghua.’ Source:
http://arcopaper.com/About__our_products.html;
27 and Spain,27
CO 27 Pers. Comm. with paper industry contact
28 and expanded its production capacities in Australia,28
CO 28 Solaris Paper (2010)
29 Canada,29
CO 29 Gazette (2010); Reuters (2010)
30 China30
CO 30 Chang 2010
31 and the US.31
CO 31 Associated Press (2010)
32 According to mapping analysis conducted by the World Wildlife The statement is taken from a press release, Incorrect
DF Fund (WWF), APP’s two pulp mills in Sumatra cause more loss of which has no methodology for the statement
rainforest than any other company on the island.32 and does not indicate mapping has taken place
32 WWF 2009 and is therefore unverifiable.
33 Over the last five years, APP has repeatedly claimed that it is on a
CS responsible ‘path toward sustainability’ and will soon have no need
to pulp Indonesian forests to meet its fibre requirements. Written
for its customers and other stakeholders, its ‘sustainability’ reports
have proclaimed: … will be fully reliant on renewable, plantation-
grown fibre from socially, environmentally and legally responsible
sources.”33
33 APP (2004): ii
34 “the current 623,409 hectares of plantation forests will more than
CS adequately provide the fibre requirements for APP’s two pulp mills
in Sumatra by end of 2009.”34
34 APP (2007): 58
REPEAT
35 APP has recently released a series of adverts entitled “APP Cares”
CS 35 Newsmaker (2010); Youtube website www.youtube.com/wa
tch?v=rEyduROW8Sk&feature=related
36 environmental message to the world”.36
CS 36 ProPrint (2009)
37 The adverts, broadcast on CNN International37
CS 37 Newsmaker (2010)
38 and published in The Times (UK),38
CS 38 The Times (2010)
39 amongst other media outlets, aim to highlight APP’s efforts to
CS conserve the environment, protect biodiversity, alleviate poverty
and mitigate climate change.39
39 Newsmaker (2010); Youtube website www.youtube.com/wa
40 How Sinar Mas is Pulping the Planet provides new evidence which It is impossible to assess the veracity of the That Greenpeace has chosen not to publicly Speculative
DF shows that APP never intended to source its pulpwood from document as it has not been made public by release this document through an anonymous
plantations alone after 2009, in spite of the promise it made to its Greenpeace. However, Greenpeace's website -- such as the widely used Wikileaks --
customers and other stakeholders. A confidential document subsequent report, 'Expanding the Empires', indicates a hesitation in revealing the full context
written by Sinar Mas in 2007,40 contained pictures of the document and of the document. Further, the Indonesian
40 Confidential Sinar Mas document, copy held by Greenpeace indicated that the report was an internal Government in 2005 called for a significant
International presentation. The auditor does not dispute the expansion of the Indonesian pulp and paper
provenance of the document but, on balance industry, calling on the sector to expand its
of probabilities, must assume this was not a concession areas by 5 million ha. [2]
management commitment, based on the Chen Kuan-Cheng (2008). The Ethnic Chinese Style
decrease in forest area under the company’s of Corporate Innovation. PICMET Proceedings, 27-
control. The document was shown as a 'Skill 31 July, Cape Town, South Africa, 2008. [2]
Development Activity' presented at the Sinar MINISTRY OF FORESTRY (2006). STRATEGIC PLAN
Mas Management by Olympic System (MBOS) OF THE MINISTRY OF FORESTRY 2005-2009
conference in 2007. This context is significant (REVISED), Jakarta, August 2006 Published by :
in that the MBOS Conference is a competitive Centre of Forestry Planning and Statistics Forestry
management system that encourages small Planning Agency; Manggala Wanabakti Building,
teams within business units to propose ideas Block VII, 5 Floor; Jl. Gatot Subroto Jakarta, 10270.
that achieve a clearly defined goal (e.g. 20 per
cent ROI) [1]. The Conference presents these
ideas in a competitive environment; the
REPEAT
presentation of an idea does not necessarily
entail its adoption or implementation. Any
interpretation of the document as being an
adopted or implemented plan is therefore
speculative; this assertion is further supported
in the claims below.
41 and held by Greenpeace International, shows that the group was The Greenpeace statement effectively makes In response to I. At the end of March 2010, Speculative
DF implementing plans to acquire new forest areas through its ‘Area two speculative claims based on the concession areas were 2,519,956 ha. During 2007,
Development Project for Supporting Mill License Capacity’. … to document: I. APP was intending to expand its total concession areas controlled by APP were
government” (i.e. used to lobby government) in order to gain concession areas between 2007 and 2009, 2,494,417 -- approximately 25,539 ha less than
approval for a massive increase of the group’s existing licensed approximately by an area of 900,000ha, currently. In response to II. APP's pulp capacity in
pulping capacity and landbanks (i.e. new forest areas to clear for referring to these areas as 'expansion Indonesia has not changed since the beginning of
plantation development).41 concessions', based on a map contained within 2007; this is indicated in other documentation
41 Confidential Sinar Mas document, copy held by Greenpeace the document; II. APP was intending to cited by Greenpeace throughout the report.
International increase its pulp capacity in the same period. [1] Ministry of Forestry (2010). Laporan
Perkembangan Pemanfaatan dan Penggunaan
Hutan Produksi Triwulan I (Januari - Maret 2010).
Ministry of Forestry, Jakarta, Indonesia. [2] Based
on the concession licenses for: PT Arara Abadi, SK
Menhut No. : 743/Kpts-II/1996, 25 November
1996; PT Riau Abadi Lestari, SK Menhut No. :
542/Kpts-II/1997, 25 Agustus 1997; PT Satria
Perkasa Agung, SK Menhutbun No. : 244/Kpts-
II/2000, 22 Agustus 2000; PT Satria Perkasa Agung
- KTH Sinar Merawang (partnership) Surat
Menhutbun No. : 634/Menhutbun-VI/1999, 16 Juni
1999; PT Satria Perkasa Agung - (Serapung) SK
Menhut No. : SK.102/Menhut-II/2006, 11 April
2006; PT Sekato Pratama Makmur, SK. Menhut No.
: 366/ Kpts-II/2003, 30 Oktober 2003; PT Bukit
Batu Hutani Alam, SK. Menhut No. : 365/Kpts-
II/2003, 30 Oktober 2003; PT Dexter Timber PI. -
KTH Wana Jaya (partnership), Surat Menhutbun
No. : 803/Menhutbun-VI/1999, 22 Juli 1999; PT
Mitra Hutani Jaya, SK Menhut No. :
REPEAT
SK.101/Menhut-II/2006, 11 April 2006; PT Ruas
Utama Jaya, SK Menhut No. : SK.46/MENHUT-
II/2006, 6 Maret 2006; PT Bina Duta Laksana, SK
Menhut No. : SK.207/MENHUT-II/2006, 8 Juni
2006; PT Putra Riau Perkasa, SK Menhut No. :
SK.104/Menhut-II/2006, 11 April 2006; PT
Perawang Sukses Perkasa Industri; SK Menhut No. :
SK. 249/Kpts-II/1998, 27 Pebruari 1998; PT Rimba
Rokan Perkasa, SK Menhut No. : SK.554/Menhut-
II/2006, 22 Desember 2006; PT Prima Bangun
Sukses, SK Menhut No. : SK.553/Menhut-II/2006,
22 Desember 2006; PT Bina Daya Bentala, SK
Menhut No. : SK.555/Menhut-II/2006, 22
Desember 2006; PT Rimba Mandau Lestari, SK
Menhut No. : SK.552/Menhut-II/2006, 22
Desember 2006; PT Mutiara Sabuk Khatulistiwa, SK
Menhut No. : 109/Kpts-II/2000, 29 Desember
2000; PT Suntara Gajapati, SK Menhut No. :
71/Kpts-II/2001, 15 Maret 2001; PT Wirakarya
Sakti, SK Menhut No. 346/Menhut-II/2004, 10
September 2004; PT Rimba Hutani Mas, SK
Menhut No. 68/Menhut-II/2004, 9 Maret 2004; PT
Tebo Multi Agro SK Menhut No. : SK.401/Menhut-
II/2006, 19 Juli 2006; PT Sebangun Bumi Andalas,
SK Menhut No. : SK. 347/Menhut-II/2004, 10
September 2004; PT Sumber Hijau Permai, SK
Menhut No. : SK. 29/Menhut-II/2006, 13 Pebruari
2006; PT Bumi Persada Permai SK Menhut No. :
337/Menhut-II/2004, 7 September 2004; PT Bumi
Mekar Hijau, SK Menhut No. : 417/Menhut-
II/2004, 10 Oktober 2004; PT Bumi Andalas Permai,
SK Menhut No. : 339/Menhut-II/2004, 7
September 2004; PT Finnantara Intiga, SK Menhut
No. : 750/Kpts-II/1996, 2 Desember 1996; PT Surya
Hutani Jaya, SK. Menhut No. : 156/Kpts-II/1996, 8
REPEAT
April 1996. The three concessions approved in
2007 were: PT Acacia Andalan Utama, SK. Menhut
No. : SK.87/MENHUT-II/2007, 22 Maret 2007; PT
Balai Kayang Mandiri, SK Menhut No. :
SK.20/Menhut-II/2007, 5 Januari 2007; PT
Artelindo Wiratama, SK Menhut No. :
SK.122/Menhut-II/2007, 2 April 2007
42 While the overall capacity of its two pulp mills in Sumatra was 2.6 See responses to fn 40-41 Speculative
CO million tonnes per year in 2006 42
42 Confidential Sinar Mas document, copy held by Greenpeace
International
43 the Sinar Mas document indicates that APP was proposing to raise See responses to fn 40-41. While the claim is In addition to the speculative nature of the claim, Speculative
CO that to 17.5 million tonnes per year,43 a sevenfold increase in speculative, there is the additional possibility the logistical assumptions behind the claim are so
APP’s pulp capacity in Indonesia. that the Greenpeace reading of the 17.5 ridiculous as to make the claim unbelievable. The
43 Confidential Sinar Mas document, copy held by Greenpeace million figure mistakes pulp output for log pulp production capacity of the entire nation of
International input. Based on this revision, speculated pulp Canada -- one of the world's largest pulp
output would be increased by 3.89Mt/yr – a 50 producers -- is approximately 20 million mty;
per cent increase. This is a much more Greenpeace is proposing that APP would
plausible result, but does not, however, alter effectively have the equivalent pulp capacity of
the speculative nature of the claim. Canada; third, the rough benchmark for the cost
of installing pulp capacity is US$1000/tonne --
such an expansion would require an investment
of USD17.5 billion, significantly larger than total
annual FDI in Indonesia.
44 Pulping the Planet reveals – from analysis of Indonesian See responses to fn 40-41. In addition, the Speculative
DF Government and confidential Sinar Mas maps and data, as well as statement implies that Sinar Mas was
on-the-ground investigations – that APP continues to acquire and intending to acquire this area and clear cut the
destroy rainforest and peatland to feed its two pulp mills in existing forest within these concessions. Given
Sumatra. In the Sumatran provinces of Riau and Jambi alone: Sinar that it appears APP’s supplier never intended
Mas was aiming to expand its concessions by 900,000 hectares to do so, nor that any of these plans
between 2007 and 2009. In 2006, over half of this area was still eventuated, the claim is both speculative and
forested44 incorrect.
44 Confidential Sinar Mas maps (copy held by Greenpeace
International) overlayed MoFor (2009d) Landcover 2006 map
REPEAT
45 and a quarter of it was peatland.45 See responses to fn 40-41 and above. The data [1] Wahyunto and I Nyoman N. Suryadiputra. Speculative
DF 45 Confidential Sinar Mas maps (copy held by Greenpeace cited contains the following problems. I. The 2008. Peatland Distribution in Sumatra and
International) overlayed with maps from Wahyunto, S. Ritung & maps used, which were published by Wetlands Kalimantan-explanation of its data sets including
Subagjo, H. (2003) International, contain significant error margins, source of information, accuracy, data constraints
as much as 31 per cent as admitted by the and gaps. Wetlands International – Indonesia
author. [1] The margin for error associated Programme. Bogor. xiii + 52. [2] Professor Budi
with the methodology are described by one Setiawan, Bogor Agricultural Institute, personal
Indonesian soil hydrologist as high as 90 per communication. [3] BSI-CUC (2010). Verifying
cent. [2] This is supported by the recent Greenpeace Claims Case: SMART
investigation of Greenpeace claims against
Sinar Mas' agricultural operation (PT SMART),
which found that the Greenpeace claims of
planting on deep peat (based on FFI field
assessments that have a more stringent
methodology than that used by Wahyunto et
al) were for the most part incorrect [3].
46 Thirty of the new concessions encroached into some of the last See responses to fn 40-41, 44, 45. In addition, Speculative
DF forest refuges for the critically endangered Sumatran Tiger.46 the Greenpeace use of data is a simplistic use
46 Confidential Sinar Mas maps (copy held by Greenpeace of the methodology and purpose of the
International) overlayed with maps from Dinnerstein et al. (2006) Dinnerstein et. al maps, which set out a
strategy for conservation priorities, rather than
being a current account of tiger range.
47 A dozen of them – covering at least 130,000 hectares – overlapped See responses to fn 40-41, 44, 45 Speculative
IL peatland which is more than three metres deep.47 .
International) overlayed with maps from Wahyunto, S. Ritung &
Subagjo, H. (2003)
REPEAT
48 It is illegal to destroy peatland over three metres deep under The use of the Greenpeace sentence is The authors of the report are oblivious and to the Speculative
IL Indonesian law.48 misleading, notwithstanding the inaccuracies political history of land-use planning in Indonesia.
48 Government of Indonesia (1990) in both the data cited by Greenpeace and The decree referred to was rarely honoured
Greenpeace accusations against PT SMART during the term of its creator, President Suharto.
(see above). The blanket illegality of the 'three The clearest example of this was the institution of
metre rule' is not clear-cut. I. The conditions of the 1 million acre Peat lands development Project
the decree permit any number of industrial (Proyek Pengembangan Lahan Gambut PPLG),
activities within peatland areas, including based on Presidential decrees No. 83/1995 and
mining, forestry and agriculture. Presidential 74/1998. Vast sections of this project were on
Decree 32 of 1990 states that ‘peat soil with 3 peat with depths greater than 3 meters according
meters thickness or more, existing in the to Wahyunto et. al. Further, many of the spatial
upstream river and swamp’ is classified as a planning laws created during this period have no
‘protected zone’. The Decree prohibits implementing regulation or even possible
cultivation activities in protected zones, except sanctions for non-complaiance. [3]
those ‘not disturbing the protection function’.
The protection function of peat zones is [1] Ministry of Forestry / IFCA (2009). REDDI:
defined as ‘controlling the territorial Reducing Emissions from Deforestation and
hydrology, functioning as a water binder and Forest Degradation in Indonesia -- REDD
prevention of flood as well as protecting the Methodology and Strategies.
specific ecosystem in the zone concerned’. The [2] MoFor 2008, IFCA 2007 Consolidation Report :
Presidential Decree 32/1990 provides Reducing Emissions from Deforestation and
authorities to the local governments to Forest Degradation in Indonesia, Published by
determine the protected zones, but retains FORDA Indonesia
management functions with the National [3] Effendi, E. 2002. Rationalizing the facts: Forest
Government. Article 38 of the Decree states Zone rationalization in the context of local spatial
that cultivation activity - and even mining - planning and development programs. Paper for
may take place in protected zones, if the the World Bank. Jakarta, Indonesia.
activity is managed in such a way that the
protection function of the zone is maintained
and that the activity is regulated by the
relevant Minister. II. The Decree itself overlaps
with a number of other spatial planning laws.
The Decree is significantly different to
Agricultural guidelines, which identify that
areas with up to 76 cm deep peat are suitable
REPEAT
for conversion to agriculture. Similarly,
Provincial Spatial Planning (Rencana Umum
Tata Ruang Wilayah Propinsi, RUTRW) issued in
1992 indicates the delineation of all peat
swamp areas to fall under the status of
Protected Areas. There is, in other words, a
need for institutional rationalisation of spatial
planning laws; moreover, there is a further
need for implementing regulations once
rationalisation has taken place. [1] Current
legislative overlaps prevent the Decree from
being used in spatial planning implementation.
[2]
49 … Mas’ 900,000 hectares of expansion concessions had either been Regarding 'expansion concessions', see Misleading
DF approved by the Indonesian government or were in the process of responses to fn 40-41, 44, 45; regarding the
being acquired.49 acquisition of '75,000ha' see fn50
49 75,000 hectares had already been fully acquired or taken over
from other companies and had been approved by the Indonesia
government. The remaining 385,000 hectares concessions were in
acquisition. Source: Confidential Sinar Mas document, copy held
by Greenpeace International
REPEAT
50 Greenpeace recently carried out an on-the-ground investigation The source for assertion that APP has acquired The statement is also misleading because of the Selective
DF into two key rainforest areas in Sumatra. Sinar Mas has recently new concessions is incorrect; the statement use of the term 'Bukit Tigapuluh Forest
acquired new concessions in the Bukit Tigapuluh Forest Landscape says that an APP supplier has applied to Landscape', which is a term that has no basis in
in Central Sumatra, one of the last refuges for the critically develop a pulpwood plantation. The plantation law; it has been conflated with the Bukit
endangered Sumatran tiger.50 development -- which was approved -- was Tigapuluh National Park by a number of campaign
50 WWF et al. (2008); APP (2009a); see also Chundawat et al within existing gazetted concession areas. [1] groups including WWF. In 2008, WWF Indonesia
(2008) accused PT Wira Karya Sakri (PT WKS, an SMF
company operating in Jambi province) of illegal
logging in the Bukit Tigapuluh National Park . In
response, APP commissioned a British-based
consultancy Oxford Index (www.oxindex.com) to
conduct an independent inquiry into the claims.
Following an on-ground investigation (which
included discussions with NGOs, APP and APP’s
fibre suppliers, and examination of documents
and concession areas), Oxford Index found that
PT WKS did not engage in logging in the Bukit
Tigapuluh National Park. Areas pointed out by
WWF Indonesia as those outside WKS
concessions were in fact within PT WKS
concessions. Oxford Index also observed that
WWFI misattributed the term “national park” to
the whole of Bukit Tigapuluh Forest Landscape
area . Additional errors in their reporting of APP's
conduct were also conceded by WWF in the
findings. [2]
[1] The former concessions were: PT. Dalek Hutani
Esa, 586/Kpts-VI/1999 (approved 29-07-1999;
52,480ha) and PT. Hatma Hutani, 593/Kpts-
VI/1999 (26-02-1998, 41.000ha); the revised
concession area was 43,600ha -- less than half the
original concession areas. [2] Oxford Index (2008)
REPEAT
51 It is also targeting the Kerumutan Peat Swamp forest for further The use of the term 'targeting' is speculative; Speculative
DF expansion; this is another important tiger habitat and area of the author assumes this is based on the
carbon-rich peatland.51 'expansion concessions' referred to earlier in
51 IUCN. Kerumutan peat swamp forest ecosystem protection the text, in turn based upon a speculative and
initiative in Riau. http://nciucn.nl/projecten/kerumutan_ non-emergent claim on APP's expansion plans.
peat_swamp_forest_ecossytem_protection_initiative_in_riau/ Further, the source cited states: “The main
problems in KWR are illegal logging, poaching,
forest fires and an access road to the pulp and
paper industries in bufferzone that provides
access to illegal loggers and poachers, and the
planning by the provincial government to build
a highway to connect regencies near the KWR.
In the project area the government tends to
change the forests in the peat swamp area
from logging concession allotment to both oil
palm and pulp & paper industry. Beside the
government policy, communities conduct
illegal logging in these areas, after which they
plant it with oil palm. Logging companies have
apparently gone bankrupt, so all illegal logging
is done by local communities.”
52 Some international companies, such as Staples,52 Staples paper procurement policy shifted to Staples (2010). Staples Inc. Sustainable Paper Selective
RE 52 Staples (2009) mandate fiber under FSC certification (first Procurement Policy, last revised January 28 2010
preference); or, alternatively PEFC
requirements. Indonesia has no certified FSC
pulpwood forests, nor has its national
certification scheme (Lembaga Ekolabel
Indonesia, LEI) been put forward for
assessment under the PEFC system. Staples'
procurement policy would, therefore
automatically exclude APP's fiber supply.
53 Office Depot53
RE 53 Office Depot (2009)
REPEAT
54 and Woolworths (Australia),54 Woolworths altered its procurement policy to [1] See Woolworths (2009). Corporate Selective
RE 54 ABC (2008) require the purchase of paper certified under Sustainability Report.
either FSC or PEFC sustainable forest
management standards; this was a result of
pressure from the Australian Construction
Forestry Mining and Energy Union [1]
55 have stopped buying or selling paper products connected to APP.
RE However, recent research by Greenpeace shows that many other
international companies continue to do so. These include: French
supermarket chain Carrefour (e.g. in Indonesia, China);55
55 Greenpeace China investigations 2010
56 US supermarket chain Walmart (in China);56
RE 56 Greenpeace China investigations 2010
57 French supermarket chain Auchan (in China);57
RE 57 Greenpeace China investigations 2010
58 British supermarket chain Tesco (in China);58
RE 58 Tesco stocks various APP China brand products in its retail
outlets in China. Greenpeace China investigations 2010
59 British retail group WH Smith (in the UK);59
RE 59 WH Smith stocks various stationary products of APP-related
company Collins (Nippecraft)
60 US information technology multinational Hewlett Packard (in
RE Brazil);60
60 APP Brasil (2008)
61 US fast-food chain Kentucky Fried Chicken (in China);61
RE 61 Greenpeace China investigations 2010; see also Ningbo Asia
Paper website, Products www.nbasia.com.cn/en-products.asp
62 Dutch Office supplies company Corporate Express;62
RE 62 Corporate Express (2010)
REPEAT
63 and Australian global paper merchant PaperlinX (e.g. in Australia
RE and the UK).63
63 PrintWeek (2009); See also Spicers Global products www.
spicers.com.au/index.asp?menuid=100.030.080&artid=232
(viewed 8 June 2010). Sinar Royal and Sapphire are Sinar Mas
brands. PaperlinX operates worldwide through subsidiaries
including PaperCo, Robert Thorne & Howard Smith (all UK),
Papernet (AT), Deutsche Papier (DE), Polyedra (IT), Spicers Paper
(HK, MY, SG, AUS, CDN, US), Paperpoint (AUS), Coast Paper (CDN)
and many others
64 Other international companies including Kimberly Clark, Kraft, The implication of the Greenpeace statement [1] Kimberley Clark Australia (2010). Kimberly- Incorrect
CS Nestlé and Unilever, are in the process of implementing global is that these companies source from APP; at Clark is not supplied by Sinar Mas or Asia Pulp and
sustainability policies for pulp and paper. These policies will least one of the companies, Kimberley Clark, Paper, 23 July 2010.
exclude paper products from APP unless it makes substantial does not. The company released a clarifying http://www.kca.com.au/news/news82.html
improvements to the sustainability of it’s *sic+ fibre supplies.64 statement following the reporting of
64 Kraft, Nestlé and Unilever pers. comms. with Greenpeace UK; Greenpeace claims in the Australian media [1].
Kimberly Clark pers. comm. with Greenpeace USA
65 APP China’s Gold East Paper mill is the single largest export
CO destination from APP Indonesia’s Riau-based pulp mill, PT Indah
Kiat.65
65 Confidential 2009 trade data, copy held by Greenpeace
International
66 Customers of Gold East’s Paper include many international and
CO high-profile magazines and books including Chinese National
Geographic; CNN Traveller; COSMO (published by National
Geographic); Cosmo Girl (published by Cosmopolitan); ELLE;
Esquire; and Marie Claire.66
66 See APP Print Awards 2007-2009
www.sinarmasprintawards.com/ Application requirement: ‘At
least 70% of paper used in entries must be Gold East Paper or
Gold Huasheng Paper’s product.’
REPEAT
67 Some international companies, including Kraft, Nestlé and
CO Unilever, have also stopped buying palm oil from Sinar Mas.
However the following companies, listed as customers of Sinar
Mas’ palm oil division in June 2009, have not yet made similar
commitments:67
67 GAR (2009a):13
68 Campbell Soup Company (US); Burger King (US); Dunkin Donuts
CO (US); Pizza Hut (US); and Shiseido (Japan). Two of the largest palm
oil traders in the world – Cargill (US) and Wilmar (Singapore) – are
still buying from Sinar Mas and trading to a variety of their global
customers.68
68 Confidential 2010 trade data, copy held by Greenpeace
International
69 In addition, the French supermarket chain, Carrefour, is still selling
CO Sinar Mas branded palm oil products in Indonesia.69
69 e.g. Carrefour (Indonesia) Java catalogue for Bali, Java and
Makassar, 7-20 April 2010.
70 Peatlands are perhaps the world’s most critical carbon stores and a Repeat
CL key defence against climate change. Covering just 3% of the earth’s
land surface,70
70 Hooijer et al (2006): 1
71 they store somewhere between a fifth and a third of the total See fn2 Repeat
CL carbon contained in the terrestrial biosphere, including all soils and
vegetation.71
71 UNEP (2002)
72 There are about 22.5 million hectares … 72 See fn3 Repeat
73 the vast majority of which are on the … 73 See fn4 Repeat
74 Some of these are up to 15 metres deep; some of the deepest in See fn2 Repeat
CL the world.74
74 UNEP (2002)
REPEAT
75 Sumatra’s peat swamp forests not only provide habitat for The first part of the statement is a repeat of Incorrect
CL endangered species such as the Sumatran tiger, they are also of earlier claims; the second assertion is not
critical importance in mitigating climate change. The clearing and supported by the cited source, which assesses
draining of peatlands is the key reason why Indonesia is the peat oxidation levels over a 25-year time
world’s third largest GHG emitter.. As peat dries out and oxidises, horizon.
it degrades and emits GHG for up to 150 years.75
75 Germer and Sauerborn (2007)
76 In 2006, Sinar Mas controlled over 400,000 hectares of oil palm The data cited is a Greenpeace report and Selective
CL and cannot be considered impartial.
acacia pulpwood concessions on peatlands in the Sumatran Notwithstanding this, the data cited within the
province of Riau alone. This area of peat is projected to emit source is from Wahyuanto (2006), also cited
approximately 2.3 billion tonnes of GHG emissions over 150 years within the current Greenpeace report. See
– more than twice the annual emissions from Germany.76 response to fn 46.
76 Greenpeace International (2008b): 51
77 Tropical forest destruction is responsible for around 20 per cent of See fn1 Repeat
CL global published by the International Union for greenhouse gas
(GHG) emissions.77
77 UNFCCC 2007: Figure SPM.1; NCCC (2009a).
78 Ending deforestation will not only preserve biodiversity but it must See fn5 Repeat
CL be a central part of a global strategy to tackle climate change. The
destruction of rainforests and carbon-rich peatlands78
78 Indonesia’s deforestation-related – including peatland –
emissions were 1.88 GtCO2 in 2005. Source: NCCC (2009a). An
additional 0.36 GtCO2 are peat emissions that were classified as
‘non-commercial’ and should be included in Indonesia’s total , as
they result from ongoing peatland emissions (‘Restoration of 5
million ha of non-commercially used peatland could result in a
further reduction of 360 MtCO2e’). Source: NCCC (2009b). Fact
sheet: 2
REPEAT
79 is the key reason why Indonesia accounts for around a quarter of See fn5 Repeat
CL all GHG emissions caused by deforestation.79
79 2.26 (1.88 + 0.36) GtCO2 / 8.88GtCO2 = 25%. Global
deforestation-related – including peatland – emissions in 2004
(latest year available) were 8.88GtCO2. Source: UNFCCC 2007:
Figure SPM.1; NCCC (2009a). Also see endnote 5
80 According to recent government estimates, Indonesia ranks as the See fn7 Repeat
CL world’s third largest GHG emitter.80
80 According to recent estimates published by various
governments, Indonesia’s emissions (2005) are higher than
Brazil’s (2005), Russia’s (2005) and India’s (2005), but lower than
USA’s (2005) and China’s (2004): No 1: USA 6.18 GtCO2 in 2005.
Source: EPA 2010: 14 No 2: China 5.6 GtCO2 in 2004. Source:
Government of China (2007) No 3: Indonesia 2.25 GtCO2 in 2005.
(See endnote 5) No 4: Brazil ~2.2GtCO2 in 2005: Source: MCT
(2009): 19 No 5: Russia ~ 2.0 GtCO2 in 2005. Source: UNFCCC
(2009): 1/ No 6: India ~ 1.6GtCO2. Source: Ministry of
Environment and Forests (2009): 53
81 The Indonesian Government admits responsibility for at least 5 per
CL cent of global GHG emissions, 80 per cent of which is related to
natural forest loss and peatland degradation.81
81 NCCC (2009a)
82 The government has also identified palm oil and pulp and paper as See fn8 Repeat
CL two of the major drivers of deforestation and escalating GHG
emissions.82
82 MoFor (2008) XV, XXI
83 A report published by the United Nations Environment Programme The claim within the report cited does not cite Speculative
DF (UNEP) in 2007 warned that, if current rates of deforestation a source, nor provide a methodology for the
continue unabated, 98 per cent of Indonesia’s lowland rainforests prediction. A similar claim within the same
could be destroyed by 2022.83 report regarding the loss of forests in Borneo is
83 UNEP (2007): 7 attributed to WWF, but this is not cited to a
specific source.
84 Most of Indonesia’s peatland forests are lowland rainforests. 84
DF 84 There are some peatlands in the central highlands area of
Papua, Indonesia
REPEAT
85 Greenpeace documented Sinar Mas in the act of clearing See fn9 regarding the data cited in relation to [1] PT Artelindo Wiratama, SK Menhut No. : Repeat
DF rainforests and destroying peatland in these areas. The biodiversity. Additionally, phrases 'the act of SK.122/Menhut-II/2007, 2 April 2007; [2] RKT
destruction of Indonesia’s forests and peatlands also has a clearing rainforests' and 'destroying peatlands' 15/BPHT-3/2009, dated April 15 2009; [3] [3] 1)
devastating impact on biodiversity. The endangered orang-utan imply wrongdoing. The activity referred to Eksekutif DATA STRATEGIS KEHUTANAN 2007,
and the Sumatran tiger are just two of the species under threat of later in the document (p.16) is within the DEPARTEMEN KEHUTANAN, Direktorat Jenderal
extinction,85 boundaries of the Sinar Mas/PT Artelindo Bina Produksi Kehutanan (BPK) 2008; 2) Statistik
85 Chundawat et al (2008); UNEP (2007) Wiratama concession [1] and subject to a Kehutanan Indonesia 2006, 2007, Departemen
government-approved annual working plan [2]. Kehutanan; 3) Keputusan Menteri Kehutanan
Plantation clearing activities are also subject to tentang Penunjukkan Kawasan Hutan dan
planning and AMDAL assessment for Perairan; 4) Tata Guna Hutan Kesepakatan, 1984
conservation value [3] [4] as well as Macro- [4] [2] RI Ministry of Forestry Decree
and Micro-Delineation for the existing SK.101/Menhut-II/2004 and Government
landscapes to ensure that high conservation Regulation No. 34/2002 [5] RI Ministry of Forestry
value areas remain protected[5]. See also Decree SK.101/Menhut-II/2004 and Interpretation
fn10, 11, 76. Ministry of Forestry S.06/MENHUT-VI/2006
regarding acceleration of the development of
estate forest to accommodate the raw material
requirement for the pulp and paper industry,
http://www.eu-
flegt.org/images/reference/law/2004%20SK%20M
enhut%20No101%20eng.htm
86 in part due to the loss of natural forest habitat.86 See also fn10, 11, 76. Repeat
DF 86 UNEP (2007): 9; Chundawat et al (2008)
87 The Red List of Endangered Species, published by the International Repeat
BD Union for Conservation of Nature (IUCN),87
88 classifies the Borneo orang-utan (Pongo pygmaeus) The use of this data is misleading. Sumatran Selective
BD as ‘endangered’ and the Sumatran orang-utans are endemic to Aceh in Sumatra;
orang-utan (Pongo abelii) as ‘critically there are no APP pulp and paper operations
endangered. Recent estimates indicate that there are between there. Similarly, orang-utans have been
45,000 and 69,000 Sumatran, orang-utans left in the wild.88 documented as adapting well within buffer
88 UNEP (2007): 9 zones of acacia plantations.
89 The Red List classifies the Sumatran tiger (Panthera tigris
BD sumatrae) as ‘critically endangered’.89
REPEAT
90 Recent estimates indicate that there are only 400-500 left in the
BD wild.90
91 In the Sumatran province of Riau, which has the highest rates of The interpretation of the data is incorrect; the Incorrect
BD deforestation,91 table cited does not mention rates of
91 See e.g. MoFor (2009a): table I.1.4. deforestation, only gross deforestation. On the
table cited, East Kalimantan had significantly
higher gross deforestation
92 the number of tigers has declined by 70 per cent in the last 25 The use of this data is selective; WWF has also [1]
BD years.92 reported that 80 per cent of tiger deaths are http://wwf.panda.org/what_we_do/endangered_s
92 Uryu et al. (2008) due to poaching [1]; this number has been pecies/tigers/about_tigers/sumatran_tiger/threats
specified more clearly as 76 per cent -- see /poaching/
data and sources below
93 The Red List reports that the Sumatran tiger is losing up to six The data cited is incomplete. The full entry Selective
BD percent of its forested habitat per year, “due to expansion of oil notes that more than three quarters of tiger
palm plantations and planting of Acacia plantations.” 93 deaths are due to poaching. The full entry
93 Chundawat et al (2008) states: "The Sumatran tiger is declining due to
high rates of habitat loss (3.2-5.9%/yr; Achard
et al. 2002, FWI/GFW 2001, Uryu et al. 2007)
and fragmentation, which also occur, to a
lesser extent, inside protected areas (Gaveau
et al. 2007, Kinnaird et al. 2003, Linkie et al.
2003, 2004, 2006). There are high levels of
human-tiger conflict (Nyhus and Tilson 2004,
Browne and Martyr 2007), as well as illegal
trade in tiger parts (Nowell 2000, Nowell
2007). From 1998-2002 at least 51 tigers per
year were killed, with 76% for purposes of
trade and 15% out of human-tiger conflict
(Shepherd and Magnus 2004). Ng and Nemora
(2007) found the parts of at least 23 tigers for
sale in market surveys around the island."
REPEAT
94 If this loss is not stopped, the critically endangered Sumatran tiger The cited source does not account for the The species cited were lost due primarily to Incorrect
BD could well follow other species of tiger in Indonesia – the Javan extinction of these subspecies. population pressures. [1]
tiger (Panthera tigris sondaica) and the Bali tiger (Panthera tigris Seidensticker, J. (1986) Large Carnivores and the
balica) – into extinction.94 Consequences of Habitat Insularization: Ecology
94 Chundawat et al (2008) and Conservation of Tigers in Indonesia and
Bangladesh. Pp 1-42 In: Miller, S.D., Everett, D.D.
(eds.) Cats of the world: biology, conservation and
management. National Wildlife Federation,
Washington DC.
95 In Sumatra, the expansion of pulp plantations into rainforest is The document cited relates to an area that Selective
SC destroying the natural resources that indigenous communities APP’s pulpwood supllier does not operate in;
depend on for their livelihoods, including the Teluk Meranti95 the company is mentioned only in passing in
95 FPP (2009) the referred document. This source is
therefore irrelevant.
96 and Talang Mamak communities96 The document cited is a press release; the Both the Orang Rimba and Talang Mamak tribes Selective
SC 96 WWF (2009b) evidence is a quote from a local environmental are present in the Bukit Tigapuluh National Park,
campaigner and cannot be considered with populations of 364 and 6,000 respectively.
authoritative or accurate. This is distinct from the ‘Forest Landscape’
referred to by WWF.
97 in Riau province and the Orang Rimba community in Jambi The document cited is a press release Both the Orang Rimba and Talang Mamak tribes Selective
SC province.97 regarding the construction of a road by the are present in the Bukit Tigapuluh National Park,
97 EoF (2009) provincial government; it does not refer to the with populations of 364 and 6,000 respectively.
expansion of concession and/or plantation This is distinct from the ‘Forest Landscape’
areas. referred to by WWF.
98 In 2006, Sinar Mas controlled over 400,000 hectares of oil palm See fn76 Selective
CL and acacia pulpwood concessions on peatlands in the Sumatran
province of Riau alone. This area of peat is projected to emit
approximately 2.3 billion tonnes of GHG emissions over 150 years
– more than twice the annual emissions from Germany.”
98 Greenpeace International (2008b): 51
99 Founded by Eka Tjipta Widjaja in the 1970s,99
FA 99 APP website. History & Overview www.asiapulppaper.com/
100 the Sinar Mas group (SMG) has established itself as a dominant
CO global player in the pulp and paper and palm oil sectors.100
REPEAT
100 eg Sinar Mas Group website: www.sinarmas.com
101 The group now has significant interests in coal mining, property
CO development, banking and finance.101
101 eg Sinar Mas Group website: www.sinarmas.com
102 According to Globe Asia magazine, the Indonesian tycoon, Eka
FA Tjipta Widjaja is now considered to be the second richest person in
Indonesia, with a fortune worth USD 4 billion.102
102 Globe Asia (2010)
103 The Widjaja family maintains control of the Sinar Mas group The implication is that the use of offshore Misleading
GV though a complex network of offshore holding and trust finance centres is somehow deceptive or
companies.103 opaque, when in fact the opposite is true. The
103 eg GAR (2010a): 44 – main section; GAR (2010a): 26 – use of OFCs is a conventional business practice
Financial Statement section; Thomson Reuters (2010) for a number of reasons; moreover, the use of
OFCs is actively promoted by both the US and
UK governments.
104 According to Joe Studwell, author of Asian Godfathers, the The assertion is that the family's business Selective
GV Widjajas are masters of the ‘godfather arts’; they pyramid practices are opaque. This could be regarded
companies and practice opaque interplay between private and as an assertion that is culturally insensitive,
public businesses.104 bordering on racist. Company structures
104 Studwell (2007): 164-167 throughout Asia and South-East Asia have been
well-documented as being significantly
different from Western corporate structures,
and that the principles of governance differ
significantly between the two.
105 For example, Sinar Mas’s palm oil business is largely controlled This is counterintuitive to the assertion that Incorrect
GV through Golden Agri Resources (GAR), a Sinar Mas company listed the company's business practices are opaque;
on the Singapore Exchange.105 all information cited was in publicly available
105 GAR (2010a): 44 – main section company documents, e.g. Annual reports.
106 The company is incorporated in the tax haven of the Republic of This is counterintuitive to the assertion that Incorrect
GV Mauritius, through the registered office of Multiconsult Ltd.106 the company's business practices are opaque;
106 GAR (2010a): 44 – main section all information cited was in publicly available
company documents, e.g. Annual reports.
REPEAT
107 The Widjajas own almost 50 per cent of GAR through the ‘Widjaja This is counterintuitive to the assertion that Incorrect
GV Family Trust (2)’ account, which controls Flambo International Ltd, the company's business practices are opaque;
an offshore corporate trust account in the British Virgin Islands. all information cited was in publicly available
This in turn controls Massingham Ltd, another offshore corporate company documents, e.g. Annual reports.
trust account in Singapore, which is major shareholder in GAR.107
107 GAR (2010a): 44 – main section; GAR (2010a): 26 – Financial
Statement section; Thomson Reuters (2010)
108 The Widjaja family is probably best known for escaping the Asian
GV financial crisis of the 1990s.108
108 Forbes (2009)
109 The APP group, considered the Widjaja ‘family treasure’,109
GV 109 Forbes (2009)
110 defaulted on nearly USD 14 billion in debt.110 The source cited indicates that the Selective
GV 110 eg Ex-Im Bank (2003); Davis (2004): 3; Forbes (2009) complexities of the case are much more
significant than the Greenpeace statement
reveals, and that many of the company's
financial problems can be directly traced to the
Asian financial crisis of 1997.
111 Although APP was technically bankrupt, the Widjaja family See above. To imply that government support for debt Selective
GV succeeded, with support from the Indonesian Government,111 restructuring during a time of financial harship is
111 Davis (2004): 3 somehow unscrupulous would pose similar
questions for a number of government-assisted
debt restructurings taking place in the United
States.
112 In restructuring approximately USD 6.5
GV billion of the original debt billion of the original debt.112
112 White & Case (2003)
113 This was the largest ever restructuring in Southeast Asia.113
GV 113 Shearman and Sterling (2005)
114 The final restructuring agreement meant that the Widjajas The Greenpeace statement implies that there Selective
GV managed to keep control of APP114 was impropriety in the debt restructuring;
114 White & Case (2003) however, as other documents cited by
Greenpeace demonstrate, the restructuring
process was a negotiation process between
debtors and creditors.
REPEAT
115 and would only have to start paying the bulk of the debt between See above Selective
GV 2015 and 2025.115
115 Indah Kiat (2009): 44-45; Tjiwi Kimia (2009): 45-49
116 At the end of 2009, APP’s Indonesian mills still owed at least USD See above Selective
GV 4.2 billion of the restructured debt.116
116 Indah Kiat (2009): 44-45; Tjiwi Kimia (2009): 45-49
117 In October 2007, APP China owed approximately USD 1 billion to See above Selective
GV overseas private banks as well as government export credit
agencies.117
117 Debtwire (2008)
118 The APP group is now run by one of Eka Widjaja’s sons, Teguh
FA Ganda Widjaja. In 2008, Pulp & Paper International magazine rated
him the most powerful man in the pulp and paper sector
worldwide.118
118 RISI (2008)
119 With a total pulp and paper capacity of over 7 million tonnes per
CO year,119
119 APP (2009b): 21
120 the group is now Indonesia’s largest pulp and paper producer Repeat
CO and,120
120 APP’s main rival in Indonesia is APRIL, which has an annual
capacity of 2.6 million tonnes of pulp and 0.75 million tonnes of
paper. Source: APRIL (2009)
121 together with its production capacities in China, is the fourth
CO largest worldwide.121
121 RISI (2009b) RISI does not include APP nor APRIL in this
ranking, as neither companies publishes reliable figures on their
paper and paperboard (P&B) production. Greenpeace
International estimates APP’s global P&B production to have
been 10 million tonnes in 2007 (4.5 million in Indonesia and
around 5.5 million in China. Source: APP (2009b); APP China
website www.app.com.cn
122 Its pulp mill PT Indah 122 APP (2009b): 21
CO Kiat is one of the
largest mills in the
REPEAT
world, producing
nearly two million
tonnes of pulp per
year.122
123 Following a massive expansion of its tissue production in the last
CO few years, in 2008 the APP group became the fifth largest tissue
producer worldwide.123
123 Tissue World (2008)
124 More recently, it has set up new sales networks in the US,124
CO 124 Eagle Ridger Paper, USA: Source: RISI (2009a)
125 UK125
CO 125 Arco Paper refers to APP mills in China as ‘Our mills at Gold
East, Gold Huasheng and Ningbo Zhonghua.’ Source:
http://arcopaper.com/About__our_products.html;
126 and Spain,126
CO 126 Pers. Comm. with paper industry contact
127 and expanded its production capacities in Australia,127
CO 127 Solaris Paper (2010)
128 Canada,128
CO 128 Gazette (2010); Reuters (2010)
129 China129
CO 129 Chang 2010
130 and the US.130
CO 130 Associated Press (2010)
131 Part of Sinar Mas’ expansion strategy has been to establish itself as
CO a key player in the tissue paper markets of North America,131
131 Associated Press (2010)
132 Europe132
CO 132 APP China increased its tissue products exports to Europe
from almost zero in 2008 to over 7,000 tonnes in 2009, over half
of this going to the UK, with Spain, Belgium and France being
further important markets. Source: CTI (2010)
REPEAT
133 and Australia.133
CO 133 Solaris Paper (2010), ABC (2010) Note: From 2008 to 2009,
Australian tissue products imports from APP China alone more
than doubled in volume. Source: CTI (2010)
134 Sinar Mas affiliated companies, such as Solaris and Mercury,
CO market both APP branded products (Livi, Paseo), and manufacture
own label products for retailers.134
134 see company web-sites http://www.solarispaper.com.au/;
http://www.solarispaper.com/; http://www.mercurypaper.com/
135 These products include facial and toilet tissue, paper napkins and
CO towels.135
135 see company web-sites http://www.solarispaper.com.au/;
http://www.solarispaper.com/; http://www.mercurypaper.com/
136 In China, APP recently set up the world’s largest paper machine at
CO its Hainan Jinhai Pulp & Paper mill, where it expects to produce
almost 1.5 million tonnes of coated fine paper per year136
136 Chang (2010)
137 for products such as magazines and brochures. APP now claims to
CO be the largest producer of pulp, paper and tissue products in
China.137
137 APP China website. Chairman’s address www.app.com.cn
viewed 8 June 2010
138 By the end of 2007, Sinar Mas Forestry – APP’s “exclusive supplier”
CO in Indonesia138
138 APP (2009b): 2
139 controlled at least 2.4 million hectares of concessions for The statement effectively asserts that APP's [1] Romain Pirard and Christian Cossalter (2006). Incorrect
DF conversion into pulpwood plantations.139 supplier’s entire concession areas are Revival of Industrial Forest Plantations in
139 Of these, 1.9 million hectares are in the Sumatran provinces converted into plantations. This is incorrect. Indonesia’s Kalimantan Provinces
of Riau, Jambi and South Sumatra, and 0.5 million hectares are in Plantable areas – the ground area that can be Will they help eliminate fiber shortfalls at
East and West Kalimantan. APP claims to have set aside 962,000 planted with plantation species -- vary Sumatran pulp mills or feed the China market?
hectares of these 2.4 million for conservation purposes. Source: significantly from concession to concession for CIFOR, Bogor, Indonsia.
APP (2009b) a number of reasons, such as slope, soil
quality, local community presence,
conservation value. For example, the Surya
Hutani Jaya HTI concession (SK Menhut 156)
REPEAT
had a plantable area of less than 50 per cent
following submission of workplans. [1] See also
fn51.
140 Over a quarter of these concessions were still forested in 2006 140 See above Incorrect
DF 140 Greenpeace International mapping analysis based on MoFor
(2009d) Landcover 2006 maps.
141 Almost half of the area established with pulpwood plantations is The cited document cannot be used to reach Incorrect
DF located on peatland.141 this conclusion; the MoFor Landcover maps do
141 Total area of established pulpwood plantations in 2006 was not provide detail establishment of plantations
427,000 hectares. Greenpeace International mapping analysis
based on MoFor (2009d) Landcover 2006 maps.
142 Over 50,000 hectares of plantations is on peat deeper than three The cited document cannot be used to reach Repeat
DF metres.142 this conclusion; the MoFor Landcover maps do
142 Greenpeace International mapping analysis based on MoFor not provide detail of peatland or peat depth.
(2009d) Landcover 2006 maps. Notwithstanding this, the peat data relied
upon by Greenpeace has significant problems
as outlined elsewhere in this document.
143 It is illegal to destroy peatland over three metres deep under See fn 48 Repeat
IL Indonesian law.143
143 Government of Indonesia (1990)
144 According to mapping analysis conducted by the World Wildlife See fn32 Repeat
DF Fund (WWF), APP’s two pulp mills in Sumatra are responsible for
more loss of rainforest on the island than any other company.144
144 WWF (2009)
145 Since APP began operations there in the 1980s, the company is See fn32 Repeat
DF estimated to have pulped more than one million hectares of
rainforest (an area a third the size of Belgium)145
145 US Central Intelligence Agency (2010)
146 in the Sumatran provinces of Riau and Jambi alone.146 See fn 32 Repeat
DF 146 WWF (2009)
REPEAT
147 While APP is one of the biggest producers of pulp and paper in the
CO world, Sinar Mas is also a key player in the palm oil industry within
Indonesia.147
147 GAR (2010a): 11
148 Franky Oesman Widjaja, Eka’s son and Teguh’s younger brother, is
FA the CEO of Golden Agri Resources (GAR), a parent holding
company for all Sinar Mas’ palm oil interests.148
148 GAR (2010a): 12
149 Through GAR subsidiaries, such as PT SMART, Sinar Mas is
CO Indonesia’s biggest palm oil producer, responsible for 10 per cent
of the country’s palm oil production.149
149 Greenpeace International (2008b)
150 In 2009, GAR controlled 427,000 hectares of palm oil
CO plantations.150
150 GAR (2010a): 16
151 PT SMART, a member of the Roundtable on Sustainable Palm Oil
CO (RSPO), 151
151 See RSPO website www.rspo.org/?q=membersearch
152 has been involved in large-scale and often illegal clearing of forests
IL and peatlands in Kalimantan and Sumatra.152
152 See eg Greenpeace International 2009; Greenpeace
International (2010a, b); EoF (2010)
153 It has been aggressively trying to increase the size of its concession
DF areas for future oil palm development by over one million
hectares.153
153 GAR (2008): 9
154 Unilever, the global consumer goods giant, decided to suspend its
RE €30 million palm oil contract with the company in December
2009.154
154 Unilever (2009); PT SMART (2009)
155 This followed the publication of the Greenpeace reports Burning
RE up Borneo155
155 Greenpeace International (2008a)
REPEAT
156 and Illegal Forest Clearance and RSPO Greenwash: case studies of
RE Sinar Mas.156
156 Greenpeace International (2009)
157 In March 2010, major food producers including Kraft,157
RE 157 Kraft Foods (2010)
158 Mars158
RE 158 Email from Mars to Greenpeace UK, March 2010
159 and Nestlé159
RE 159 Nestlé (2010)
160 also suspended their contracts. Growing pressure on Sinar Mas
RE from its customers160
160 Unilever (2009)
161 has forced it to re-evaluate its environmental policies.161
RE 161 e.g. PT SMART (2009): 1; PT SMART (2010): 1
162 In February 2010, the palm oil arm of the company announced
RE that it would stop clearing all peatlands, primary forests and other
High Conservation Value (HCV) forests.162
162 PT SMART (2010): 1
163 An investigation by Greenpeace in March and April 2010 revealed
RE that the company was already violating these commitments and
was continuing to clear areas of peatland and HCV forest in West
and Central Kalimantan.163
163 Greenpeace International (2010b)
164 Sinar Mas’ mining division is headed by Fuganto Widjaja,164
FA 164 Crest Capital (2010)
165 a grandson of Eka
FA Tjipta Widjaja.165
166 In 2009, Sinar Mas started to expand into coal mining though PT
CO Dian Swastatika Sentosa (DSS).166
166 DSS website www.dss.co.id/business/coal-mining.html
viewed 4 June 2010
167 Sinar Mas aims to further expand in the coal sector by “integrated
CO explorations” as well as by “acquiring other mining
companies”.167
REPEAT
167 DSS (2010):14
168 In December 2009, DSS was listed on the Jakarta Stock Exchange
CO in order to raise funds of around USD 16 million for further
expansion.168
168 DSS (2010):10
169 DSS now operates through four coal mining and exploration
CO companies and holds a total of five mining licences in Riau, Jambi,
South Sumatra and South Kalimantan,169
169 DSS website www.dss.co.id/business/coal-mining.html
viewed 4 June 2010
170 with estimated coal reserves amounting to 160 million tonnes.170
CO 170 DSS (2010): 16
171 Some of the coal feeds the high energy requirements of Sinar Mas’
CO pulp and paper mills PT Indah Kiat (in Riau, Sumatra) and PT Pabrik
Kertas Tjiwi Kimia (on Java).171
171 Investor Daily (2009)
172 In 2008, APP hired a “very reputable risk management and PR firm,
CO Weber Shandwick to further convey [its] environmental message
to the world.”172
172 ProPrint (2009)
173 The same year, Weber Shandwick proclaimed that “companies
CO have awakened to the fact that corporate responsibility and
reputation go hand in hand.”173
173 Weber Chandwick (2008)
174 In 2009, Sinar Mas launched a major global advertising campaign
CS which was broadcast on CNN International174
174 Newsmaker (2010)
175 and published in The Times (UK), 175
CS 175 The Times (2010)
176 among other media outlets, in an attempt to promote its green
CS credentials.176
176 NewsMaker 2010)
REPEAT
177 The adverts, which used the slogan “APP: Building a sustainable
CS future today”, aim to highlight APP’s efforts to conserve the
environment, protect biodiversity, alleviate poverty and mitigate
climate changee.177
177 Newsmaker (2010); Youtube website www.youtube.com/wa
178 Aida Greenbury, APP’s Director of Sustainability and Stakeholder
CS Outreach, stated:178 "let there be no doubt: while APP wishes to
be a world leader in the pulp and paper-making industry, we will
do so in a responsible and sustainable manner. We are on a path
toward sustainability and will not be deterred.”
178 Newsmaker (2010)
179 Over the last five years, APP has repeatedly claimed that it is on
CS the responsible ‘path toward sustainability’ and will soon no longer
need to pulp Indonesian forests to meet its fibre requirements.179
179 eg APP (2004): ii
180 Written for its customers and other stakeholders, APP’s 2004
CS Sustainability Action Plan, referred to the group’s commitment to
become sustainable in plantation-grown fibre by 2007: “This
means that, after this date [2007], APP/SMG will be fully reliant on
renewable, plantation-grown fibre from socially, environmentally
and legally responsible sources.”180
180 APP (2004): ii
181 Published in May 2007, APP’s 2005-2006 environmental report – The document cited demonstrates that APP Selective
DF also written for its customers and other stakeholders – showed was transparent about its efforts to meet this
that it would fail to meet the 2007 target and could, in theory, now target, subject to government policy and
only meet it at the end of 2009:181 regulations; the Greenpeace claim implies
181 APP (2007): 58 wrongdoing.
REPEAT
182 It is forecast that, with current pulp-mill capacity requiring 16 See responses to fn 40-41, 44, 45. Greenpeace Repeat
DF million cubic meters of pulpwood per year at an average mean is asserting that the statements made by APP
annual increment of 25 m3/ha/yr, the current 623,409 hectares of over the past two years relating to sourcing
plantation were meaningless, based on its assumptions
forests will more than adequately provide the fibre requirements relating to the MBOS document.
for APP’s two pulp mills in Sumatra by end of 2009.” (emphasis
added by Greenpeace.) A confidential 2007 Sinar Mas document,
held by Greenpeace International, shows that, despite its claim,
APP never intended to source its pulpwood exclusively from
plantations alone after its 2009 deadline, in spite of its assurance
to its customers and other stakeholders. In fact, it was planning to
maintain its reliance on rainforest logs (i.e. Mixed Tropical
Hardwood or MTH).182
International
183 The document reveals that Sinar Mas was starting to implement See responses to fn 40-41, 44, 45. Repeat
DF plans to acquire new forest areas through its ‘Area Development
Plan for Supporting Mill License Capacity’. The Project would be
“exposed to government” (i.e. used to lobby government) in order
to gain approval for a massive increase of its existing licensed
pulping capacity and landbanks (i.e. new forest areas to clear for
plantation development).183
International
184 While the overall capacity of its two pulp mills in Sumatra was 2.6 See responses to fn 40-41, 44, 45. Repeat
DF million tonnes per year in 2006,184 the Sinar Mas document
indicates that APP was
International
185 proposing to raise that to 17.5 million tonnes per year,185 See responses to fn 40-41, 44, 45. Repeat
DF 185 Confidential Sinar Mas document, copy held by Greenpeace
International
REPEAT
186 a sevenfold increase in its pulp capacity in Indonesia, involving:186 See responses to fn 40-41, 44, 45. Repeat
DF Increased pulp capacity at two existing mills in Sumatra, PT Indah
Kiat and PT Lontar Papyrus (from 2.6 to 7.5 million tonnes per
year);
One new pulp mill in South Sumatra (2 million tonnes per year);
Two new pulp mills in Kalimantan (with a total capacity of 8 million
tonnes per year).
International
187 As the Sinar Mas document sets out,187 in order to supply the See responses to fn 40-41, 44, 45. Repeat
DF increased pulp mill capacity, the company would need to massively
expand its pulpwood concession area.
International
188 In 2007, the company acquired 0.57 million hectares and obtained See responses to fn 40-41, 44, 45. The claim is, Incorrect
DF initial permits for a further 0.75 million hectares.188 however, grossly inaccurate. APP’s supplier
188 Confidential Sinar Mas document, copy held by Greenpeace companies gained three licenses in 2007,
International totalling 256,280ha. This is less than half the
area stated by Greenpeace. No concessions
were approved for the company in 2008 and
only one concession was approved ni 2009 at
24,050ha. These concession approval
ocuments are publicly available online through
the Ministry of Forestry
189 In total, this means an expansion of 1.3 million hectares during See above Incorrect
DF 2007.189
International
190 Sinar Mas estimates that 70 per cent of the total expansion area See responses to fn 40-41, 44, 45. Incorrect
DF would be available for development, of which it would deforest
460,000 hectares generating 23 million tonnes of rainforest logs
(i.e. Mixed Tropical Hardwood or MTH).190
International
REPEAT
191 For 2009-2010, APP declared to Greenpeace191 that only 10
DF percent of its current pulp production capacity is met through
sourcing rainforest logs (i.e. Mixed Tropical Hardwood or MTH).
191 APP (2010): 2
192 The total 2007 expansion area of expansion of 1.3 million hectares See responses to fn 40-41, 44, 45. Repeat
DF would therefore facilitate APP’s continued reliance on rainforest
logs for a further 20 years.192
International
193 However, Sinar Mas had not finished acquiring new forested areas See fn41. Further, the cited source does not Repeat
DF by the end of 2007. Greenpeace analysis, based on the latest support this conclusion. In the period cited by
pulpwood concession statistics released by the Ministry of Greenpeace, approximately 819,000ha of new
Forestry, shows that between 2008 and early 2010 Sinar Mas pulpwood concessions were approved on
acquired at least another 116,000 hectares of forested Sumatra along (Riau, Jambi and South Sumatra
concessions.193 provinces); a further 569,000ha of pulpwood
193 Greenpeace International analysis based on the latest concessions were approved in Indonesian
concession statistics released by the Ministry of Forestry, Borneo. None of these new approvals are
Indonesia (MoFor (2010b) documented by management group within the
document, only individual company, with a
total given for management groups APP and
RAPP, based on net concession areas.
194 By the first quarter of 2010, Greenpeace estimates that Sinar Mas See responses to fn 40-41, 44, 45. Repeat
DF controlled 2.9 million hectares of partially forested
concessions,194
194 MoFor (2010b)
195 some in areas of tiger habitat and carbon-rich peatlands. Repeat
DF 195 Greenpeace International mapping analysis used in this
report
REPEAT
196 However, APP is in the process of acquiring even more The document cited lists applications for 78 Selective
DF concessions, which suggests that it uses or plans to use a higher concessions by a number of different
percentage of rainforest logs (i.e. Mixed Tropical Hardwood or companies. The application is by PT Rimba
MTH) in its paper products.196 Hutani Mas for 52,000ha, which was previously
196 MoFor (2010a) approved (Approvals listed: SK. Pencad No.
SK.461/Menhut-VI/2008 tanggal 12 Desember
2008 Nomor SP1 : No. S.777/Menhut-VI/2008
tanggal 12 Desember 2008 SP2 : Nomor :
.383/Menhut-
VI/2009, tanggal 22 Mei 2009).
197 Whilst Sinar Mas has successfully achieved a substantial increase in This statement is completely speculative; it is Speculative
CO its pulpwood concession areas, as set out in its internal document, based on an incorrect assumption regarding
it has not made any formal announcements that it plans to the expansion of concession areas.
increase its pulp mill capacity in Indonesia. It would require a
minimum investment of USD 19 billion to fund its intended
increase in pulp capacity.197
197 Sinar Mas’ latest newly built pulp mill, Hainan Pulp & Paper,
with a capacity of one million tonnes of bleached hardwood pulp,
required an investement of USD 1.275 billion in 2005. Source:
Solaris Paper website www.solarispaper.com/mills. php. Solaris
Paper is a Sinar Mas group affiliate.
198 As indicated above, APP still bears a debt of over USD 5 billion,
GV most of which is due for repayment between 2015 and 2025.198
198 Indah Kiat (2009): 44-45;Tjiwi Kimia (2009): 45-49
199 It is therefore plausible that, although the Sinar Mas document This claim is both speculative and based on Speculative
DF discusses an expansion to 17.5 million tonnes of pulp capacity per incorrect assumptions
year, the company might have had other intentions when
presenting its ‘Area Development Plan for Supporting Mill License
Capacity’ to the Indonesian Government. It raises the question as
to whether Sinar Mas ever seriously planned to develop build an
additional 15 million tonnes of pulping capacity, or whether it
actually only ever intended to acquire new forested concessions in
order to maintain APP’s long-term reliance on rainforest logs (i.e.
Mixed Tropical Hardwood or MTH).
No citation
REPEAT
200 In several APP documents and communications, the group The Greenpeace claim implies that APP is being Misleading
CS proclaims that its suppliers “only develop least valuable degraded dishonest in its public/CSR communications. In
forests and denuded [barren] wasteland 199... and prior to any response to the claims see fn85 regarding
development these areas are subjected to several independent AMDAL assessments.
ecological and social assessments in order to protect any high
conservation value that might exist.”200
199 APP Myths and Realities: www.app-mythsandrealities.com;
200 APP Myths and Realities: www.app-mythsandrealities.com
201 APP clearly wants to communicate that it has no interest in The Greenpeace claim implies that APP is being See Guillaiam (op. cit) and Daniel Piottoa, Florencia Misleading
CS developing rainforests that are important for critically endangered dishonest in its public/CSR communications. In Montagnini, Luis Ugaldea and Markku Kanninena.
species (e.g. tiger habitat) or for climate mitigation (e.g. carbon- response to the claims: see response sources “Performance of forest plantations in small and
rich peatlands). APP also suggests that the rainforests it ‘develops’ (right). medium-sized farms in the Atlantic lowlands of
into plantations actually benefit biodiversity and the climate: • Costa Rica”. Forest Ecology and Management.
“…pulpwood plantations indeed help to protect biodiversity…. The Volume 175, Issues 1-3, 3 March 2003, Pages 195-
lower value land developed into pulpwood plantations play 204.
important roles as a buffer or security zone to protect the integrity
of high value natural forests within and surrounding the
plantations”.’201
201 APP China (2009)
202 “The mixed residue material generated from the development of The Greenpeace claim implies that APP is being The use of forest residues in pulp production is Misleading
CS wasteland and low value or degraded forest is allocated for the dishonest in its public/CSR communications. permitted under IPK permits and TPTI permits, as
pulp industry by the government as the most environmentally well as condoned by the Indonesian Government.
friendly option202 See source for full summary of the use of forest
202 APP China (2009) residues in Indonesian forest product production.
Asian Development Bank and National
Development Planning Agency (BAPPENAS) (1998).
PLANNING FOR FIRE PREVENTION AND DROUGHT
MANAGEMENT PROJECT. Asian Development Bank
TA 2999-INO July 1998 – March 1999; Logging
Residue and Policy Implications WORKING PAPER
4. Jakarta, February 1998
REPEAT
203 as opposed to leaving it on the ground or burning it, which will See above See above Misleading
CS create forest fires and the release of methane into the atmosphere
and lead to forest disease outbreaks”.203 APP wants its customers
to believe that the ‘mixed residue material’ (Mixed Tropical
Hardwood, MTH) it uses in its pulp mills is simply wood-waste that
is lying on the ground in the areas it develops.
203 RISI (2010)
204 However, Greenpeace investigations show that Sinar Mas See response to fn40-46 Repeat
DF continues to acquire and destroy forested tiger habitat, and
continues to clear carbon-rich peatlands to feed its Sumatran pulp
mills. In the Sumatran provinces of Riau and Jambi alone, Sinar
Mas was aiming to expand its concessions by 900,000 hectares
between 2007 and 2009. In 2006, over half of this area was still
forested and a quarter of it was peatland.204
International) overlayed MoFor (2009d) Landcover 2006 map
205 Thirty of the new concessions encroached into some of the last See response to fn40-46 Repeat
DF forest refuges for the critically endangered Sumatran Tiger.205
International) overlayed with maps from Dinnerstein et al. (2006)
206 A dozen of them – covering at least 130,000 hectares – overlapped See response to fn40-46 Repeat
DF peatland which is more than three metres deep.206
International) overlayed with maps from Wahyunto, S. Ritung &
Subagjo, H. (2003)
207 It is illegal to destroy peatland over three metres deep under See response to fn40-46 Repeat
DF Indonesian law.207
208 By the end of 2007, over half of Sinar Mas’ 900,000 hectares of See response to fn40-46. The phrases "in Incorrect
DF expansion concessions had either been approved by the acquisition" or "in the process of being
Indonesian government or were in the process of being acquired" is not supported by government
acquired.208 documentation or the change in size of Sinar
208 75,000 hectares had already been fully acquired or taken Mas concessions during the period.
over from other companies and approved by the Indonesia
REPEAT
government. The remaining 385,000 hectares concessions were in
acquisition. Source: Confidential Sinar Mas document, copy held
by Greenpeace International
209 Sinar Mas’ expansion concessions encroach into the Bukit See response to fn40-46. The claim is made Incorrect
BD Tigapuluh Forest Landscape in Central Sumatra, one of the last based on the speculative 'expansion
refuges for the critically endangered Sumatran tiger.209 concessions' -- which is an incorrect
209 WWF et al. (2008); APP (2009a); see also Chundawat et al assumption
(2008)
210 Sinar Mas planned to expand into 210,000 hectares in this See response to fn40-46. The claim is made Incorrect
BD area.210 based on the speculative 'expansion
210 Confidential Sinar Mas document, copy held by Greenpeace concessions' -- which is an incorrect
International assumption
211 In 2007, Sinar Mas acquired concessions covering 36,000 hectares The citation is incorrect. PT Artelindo [1] 122/Menhut-II/2007; 22/04/2007 [2] Incorrect
DF in the region through PT Artelindo Wiratama (Riau Province) and Wiratama (Riau) was approved in 2007 401/Menhut-II/2006, 19/07/2006
PT Tebo Multi Agro (Jambi Province).211 covering 10,740ha; Tebo Multi was approved
211 Confidential Sinar Mas document, copy held by Greenpeace in 2006 covering 19,770ha. Moreover, the size
International; MoFor (2009c); see also WWF et al. (2008) of the two concessions combined ia 30,510ha.
212 Other expansion concessions encroach into the Kerumutan Peat See response to fn40-46. The claim is made Incorrect
BD Swamp forest located in the province of Riau, another important based on the speculative 'expansion
forested tiger habitat.212 This is also an area of deep peat. concessions' -- which is an incorrect
212 IUCN. Kerumutan peat swamp forest ecosytem protection assumption
initiative in Riau. http://nciucn.nl/projecten/kerumutan_
peat_swamp_forest_ecossytem_protection_initiative_in_ riau/
213 In 2006, Sinar Mas acquired a concession area covering 30,180 The Greenpeace reading of the data is PT.Bina Duta Laksana; 207/Menhut-II/2006; Incorrect
DF hectares through PT Bina Duta Laksana,213 incorrect. The concession licence was 08/06/2006; 28.890 ha
213 MoFor (2009b,c) approved in 2006 and covers an area of
28,890ha.
214 and targeted a further 41,000 hectares through the acquisition of This is incorrect. The MKS concession was SK Menhut No. : 109/Kpts-II/2000, 29 Desember Incorrect
BD the neighbouring selective logging concession, PT Mutiara Sabuk approved in 2000. 2000
Khatulistiwa.214
International
REPEAT
215 This map combines several sets of data: the Sinar Mas pulpwood The maps are inaccurate and cite data that is See Annex II Nonexisten
BD concession boundaries, which are based on concessions maps non-existent . Of the 60 areas on the map that t
recently made available by the Indonesian Ministry of Forestry; Greenpeace says are Sinar Mas 'expansion
confidential Sinar Mas documents held by Greenpeace; and targets', 41 of are concessions belonging to
Greenpeace analysis of concession documentation.215 other companies. The remaining 19 are not
215 Confidential Sinar Mas document, copy held by Greenpeace forest gazetted as forestry concessions.
International Moreover, the Sinar Mas 'existing concessions'
are in incorrect in a number of instances.
216 Natural forest cover is based on 2006 maps recently made The use of the forest cover maps from 2006 is See Annex II Selective
BD available by the Indonesian Ministry of Forestry. 216 selective. The Ministry of Forestry maps
216 MoFor (2009d) contain a broader range of data, including
forested area on mineral soils; the Greenpeace
maps appear to indicate that tiger habitat is
the only remaining source of natural forest
timber (posed by the question, "Tiger habitat
or APP's mixed wood residues?"). Further, the
maps also imply that APP’s supplier companies
are the only forest operator on the island of
Sumatra.
217 Peatland distribution is based on maps published by Wetlands The data cited contains the following See Annex II Repeat
BD International. 217 problems. I. The maps used, which were
217 Wahyunto, S. Ritung & Subagjo, H. (2003) published by Wetlands International, contain
significant error margins, as much as 31 per
cent. Moreover, the methodology and
assessment used by Wahyunto, et al for the
assessment has been described by Bogor
Agricultural University researchers as
'scientifically unacceptable'; the margin for
error associated with the methodology are
described by one researcher as high as 90 per
cent.
REPEAT
218 Sumatran tiger habitat distribution is based on maps compiled by The WWF maps for tiger distribution cited See Annex II Repeat
BD WWF.218 were compiled in 1996, almost 15 years ago.
218 Sumatra Important Ecosystem with Tiger Distribution map These distributions differ considerably from
From research data of conservation Institutions: (Wildlife the habitat maps in another cited source
Conservation Society (WCS), Fauna and Flora International (FFI), (Dinnerstein 2006)
Yayasan Badak Indonesia (YABI), World Wildlife Fund (WWF),
Zoological Society of London (ZSL) and Leuser International
Foundation (LIF). Source: Roosita and Sulistyawan (2010) and
WWF/SaveSumatra.org www.
savesumatra.org/index.php/newspublications/map/0/
Species%20Distribution%20 Map downloaded May 2010
219 Priority Tiger Conservation Landscapes are based on maps See Annex II Repeat
BD published by the Save the Tiger Fund.219
219 Maps from Dinnerstein et al. (2006)
220 Spanning over half a million hectares, the Bukit Tigapuluh Forest See footnote 51. The 'Bukit Tigapuluh Forest In 2008, WWF Indonesia accused PT Wira Karya
BD Landscape in Central Sumatra is one of the last refuges for the Landscape' is a term that has no legal meaning Sakri (PT WKS, an SMF company operating in
critically endangered Sumatran tiger.220 and is not a gazetted area. Jambi province) of illegal logging in the Bukit
220 WWF et al. (2008); see also Chundawat et al (2008) Tigapuluh National Park[1]. In response, APP
commissioned a British-based consultancy Oxford
Index (www.oxindex.com) to conduct an
independent inquiry into the claims. Following an
on-ground investigation (which included
discussions with NGOs, APP and APP’s fibre
suppliers, and examination of documents and
concession areas), Oxford Index found that PT
WKS did not engage in logging in the Bukit
Tigapuluh National Park. Areas pointed out by
WWF Indonesia as those outside WKS
concessions were in fact within PT WKS
concessions. Oxford Index also observed that
WWFI misattributed the term “national park” to
the whole of Bukit Tigapuluh Forest Landscape
area[2].
REPEAT
221 It has been designated one of the twenty highest global priority See footnote 51. The 'Bukit Tigapuluh Forest
BD landscapes for conserving tigers.221 Landscape' is a term that has no legal meaning
221 Global Priority Tiger Conservation Landscapes are habitats and is not a gazetted area.
that can support at least 100 tigers and where there is evidence
of breeding. Source: Dinerstein et al. (2006)
222 Of this landscape, 144,000 hectares are designated as the Bukit See footnote 51. The 'Bukit Tigapuluh Forest
BD Tigapuluh National Park.222 Landscape' is a term that has no legal meaning
222 MoFor website. Bukit Tiga Puluh National Park www. and is not a gazetted area.
dephut.go.id/INFORMASI/TN%20INDO-ENGLISH/bukit30_
NP.htm
223 Bukit Tigapuluh is the island’s largest lowland rainforest region,223 See footnote 51. The 'Bukit Tigapuluh Forest
BD 223 FZS website. Biodiversity, Frankfurt Zoological Society Landscape' is a term that has no legal meaning
www.orangutan-lifeboat.de and is not a gazetted area.
224 hosting incredible biodiversity:224 See footnote 51. The 'Bukit Tigapuluh Forest
BD 224 WARSI website. Bukit Tigapuluh National Park www.warsi. Landscape' is a term that has no legal meaning
or.id/Forest/forest_tnbt.htm and is not a gazetted area.
225 660 plant species, 200 species of birds and 60 mammal species, See footnote 51. The 'Bukit Tigapuluh Forest
BD including the highly endangered clouded leopard (Neofelic Landscape' is a term that has no legal meaning
nebulosa), Malayan tapir (Tapirus indicus) and elephant (Elephas and is not a gazetted area.
maximus). Bukit Tigapuluh has the only reintroduction project for
the Sumatran orang-utan; over 100 have been released into the
wild.225
225 Perth Zoo website www.perthzoo.wa.gov.au/Conservation--
Research/Projects-in-the-Wild/Sumatran-Orangutan-Pilot-
Project/; GRASP (2009)
REPEAT
226 The re-established orang-utan population now inhabits large parts The Greenpeace statement misattributes a [1] VIII.10. DAFTAR PROYEK/ PROGRAM KERJA Selective
BD of the Bukit Tigapuluh landscape, especially in the southern buffer conflicting set of priorities within the SAMA LUAR NEGERI (KLN) DI LINGKUP
zone.226 Indonesian Government to Sinar Mas. The DEPARTEMEN KEHUTANAN TAHUN 2006; Ministry
Directorate General of Conservation within the of Forestyr and Frankfurt Zoological Society (2009).
Indonesian Ministry of Forestry supported an The Bukit Tigapuluh Ecosystem Conservation
orang-utan reintroduction program under the Implementation Plan. [2] PT. Dalek Hutani Esa,
auspices of Frankfurt Zoological Society; this 586/Kpts-VI/1999 (approved 29-07-1999;
program commenced in 2001 and finished in 52,480ha) and PT. Hatma Hutani, 593/Kpts-
2009 [1]. The inactive concessions [2] were VI/1999 (26-02-1998, 41.000ha); [3] PT.RIMBA
approved for reactivation under the company HUTANI MAS SK.461/Menhut-VI/2008 tanggal 12
PT RImba Hutani Mas [3]. Desember 2008
227 The area is also home to Orang Rimba forest-dwelling tribal See fn95-97 Repeat
SC communities. These communities face increasing abuse and
marginalisation as a result of rapid deforestation.227
227 WARSI website www.warsi.or.id/Forest/forest_tnbt.htm
228 As one Orang Rimba leader stated:228 “One day [the company] See fn95-97 Repeat
SC came and told us to leave, we were pushed out. They cut down our
homes and the forests. We no longer have the forest to live. We
don’t have food or protection.”
228 ABC News (2009)
229 Despite the social and ecological importance of this area, APP and See fn41-46; this is a speculative claim. See Speculative
BD its pulpwood suppliers are associated with ten licensed or footnote 51. The 'Bukit Tigapuluh Forest
proposed pulpwood concessions that encroach into the Bukit Landscape' is a term that has no legal meaning
Tigapuluh Forest Landscape in Riau and Jambi. According to WWF, and is not a gazetted area.
these pulpwood concessions cover 358,047 hectares, half of which
are in the landscape’s natural forest.229
229 WWF et al. (2008)
230 One of Sinar Mas’ pulpwood concession holders in the area is PT
BD Artelindo Wiratama.230
230 WWF et al. (2008)
REPEAT
231 The PT Artelindo Wiratama concession area is of critical The data source cited does not mention Incorrect
BD importance for the Sumatran tiger because it forms a corridor for 'Rimbang Baling'.
migration between Bukit Tigapuluh National Park and the Rimbang
Baling nature reserve to the northwest, in Riau province.231
231 WWF et al. (2008)
232 As such, according to WWF, “the natural forest being converted This phrase in the cited document is used in Incorrect
BD should tentatively be considered High Conservation Value Forest.” reference to two other concessions in the
232 document, Wira Karya Sakti and Tebo Multi
232 WWF et al. (2008) Agro; HCVF is not specified in relation to the
Artelindo concession.
233 In its disclosure of raw material suppliers to the Ministry of
CO Forests, PT Indah Kiat listed PT Artelindo Wiratama as supplying
almost 42,000m³ of pulpwood in 2009.233
233 Ministry of Forestry document 2010, copy held by
Greenpeace International
234 In the same year, the Ministry of Forestry authorised the company This document is publicly available. In this Selective
DF to produce over 360,000m³ of rainforest logs (i.e. Mixed Tropical section, Greenpeace is attempting to assert
Hardwood or MTH) and around only 5,000m³ of acacia pulpwood that APP could have supplied plantation forest
(i.e. from plantations).234 timber, but instead supplied timber sourced
234 Around 60% of which has with a diameter greater than 30cm. from natural forests, and that it should have
Source: Ministry of Forestry document 2010, copy held by established forest plantations at the time of
Greenpeace International writing, or not at all. The statement implies
wrongdoing, but the Greenpeace documents
cited indicate that the timber harvested was
within the limits of its legal, government-
approved annual workplan.
235 PT Artelindo Wiratama could, therefore, have supplied a maximum The speculative Greenpeace statement implies Misleading
DF of 5,000m³ of acacia pulpwood to PT Indah Kiat. However, recent that the company had clearcut the concession,
Greenpeace investigations including aerial images taken in March supplied 360,000m3 of timber, and had no
and April 2010, as well as Ministry of Forestry land cover maps,235 intention of establishing a pulpwood
235 MoFor (2009d); MoFor (2006) plantation. Yet it had supplied around 12% of
this quantity and is still in the process of
establishing the plantations.
REPEAT
236 show that the company had not yet established any harvestable See above Misleading
DF acacia plantations.236
236 The only acacia plantations Greenpeace Southeast Asia
investigators could find in March-April 2010 were areas of six
month-old acacia plantations
237 Instead, PT Artelindo Wiratama continues to clear rainforests in See above [1] PERKEMBANGAN PRODUKSI KAYU BULAT/KAYU Misleading
DF the area.237 On the ground investigations by Greenpeace in March BULAT KECIL IPK PROPINSI RIAU; [2] DAFTAR
2009 show that the logs from this concession were transported by PENYAMPAIAN RENCANA PEMENUHAN BAHAN
truck to APP’s PT Indah Kiat mill in Perawang, Riau Province. BAKU INDUSTRI (RPBBI) TAHUN 2009 INDUSTRI
237 Greenpeace Southeast Asia investigations (2010) KAPASITAS > 6000 M3/TAHUN PROVINSI RIAU,
KEPULAUAN RIAU DAN SUMATERA BARAT S.D.
BULAN DESEMBER 2009
238 Covering 1.3 million hectares, the Kerumutan Peat Swamp Forest is "Kerumutan Peat Swamp Forest" -- like Bukit Misleading
BD one of the most critically threatened landscapes in the Province of Tigapuluh Forest Landscape -- has no legal
Riau.238 meaning.
238 Greenpeace Southeast Asia investigations (2010)
239 It has been designated one of the regional priority landscapes for See above Misleading
BD conserving tigers.239
239 IUCN. Kerumutan peat swamp forest ecosytem protection
240 A conservation initiative aims to formally protect less than 10 per This use of data is selective. There is already a The wildlife reserve is shared by Pelalawan and Selective
BD cent of the area, consisting of a core area of 93,000 hectares, as a 120,000 ha reserve in the area that was Indragiri Hulu, which presents a number of
Kerumutan Wildlife Reserve and a further 52,000 hectares as a declared in 1976; it extends between the adminsitrative problems. A full case study of the
Peat Swamp Protection Area.240 Indragiri and Kampar Rivers, due north of problems within the area was completed by
240 Global Priority Tiger Conservation Landscapes are habitats Rengat. It is bordered on all sides by former CIFOR in 2001.
that can support at least 100 tigers and where there is evidence logging concessions. Lesley Potter and Simon Badcock (2001). The
of breeding. Source: Dinerstein et al. (2006) Effects of Indonesia’s Decentralisation on Forests
and Estate Crops in Riau Province: Case Studies of
the Original Districts of Kampar and Indragiri Hulu.
CIFOR, Bogor, Indonesia.
REPEAT
241 Ninety percent of the area has been designated for plantation See above Selective
BD development,241 of which Sinar Mas now controls 104,000
hectares under pulpwood concessions.
At this point in the report footnotes become misaligned.
242 One of Sinar Mas’ pulpwood concession holders in the area is PT In response to the claim: Ministry of Forestry Incorrect
BD Bina Duta Laksana.242 documents state clearly that the concession
243 MoFor (2009) area is 28,890ha
243 This concession covers more than 30,000 hectares and is, See fn 45 Repeat
IL according to maps developed by Wetlands International, mostly
located on peatland deeper than three metres;243
244 Wahyunto and Subagjo H (2003)
244 it is illegal to destroy peatland of that depth to establish a See fn 48 Repeat
IL plantation under Indonesian law.244
245 In their disclosure of raw material suppliers to the Ministry of The Greenpeace statement implies a BDL approval permit: SK. 04/BPHT-3/2009, 27 Selective
DF Forests, PT Indah Kiat listed PT Bina Duta Laksana as supplying over substantial clearance within the concession, or March 2009; MKS RKT: Kpts/522.2/Pemhut/3591
80,000m³ of pulpwood in 2009. The neighbouring concession, PT that it was engaged in wrongdoing. According
Mutiara Sabuk Khatulistiwa, was listed as supplying almost to its annual workplan, BDL was approved to
99,000m3.245 supply more that 360,000m3 of natural forest
246 Ministry of Forestry 2010 document, copy held by timber within the period across an area of
Greenpeace International 4150ha. Activity in both concessions is
sanctioned under the annual workplan (RTK).
246 Ministry of Forestry maps for 2003 and 2006 246 show that neither This is selective use of data; APP had its SK. 04/BPHT-3/2009, 27 March 2009 Selective
DF company had established any pulpwood plantations in these areas. concession approved for BDL in 2006. There is
Assuming that these maps were accurate, the pulpwood supplied therefore no reason to assume for it to have
from these concessions was 100 per cent rainforest logs (i.e. Mixed established any operations on this land prior to
Tropical Hardwood or MTH). this time.
247 MoFor (2009d); MoFor (2006)
REPEAT
247 An investigation by Greenpeace in September 2009 shows that See response to fn 245 Selective
DF Sinar Mas was clearing in PT Bina Duta Laksana and transporting
logs by barge to APP’s PT Indah Kiat mill in Perawang, Riau
Province.247
248 Greenpeace Southeast Asia investigations, September 2009
248 In April 2010, Greenpeace documented ongoing clearing in PT Bina See response to fn 245 Selective
DF Duta Laksana.248
249 Greenpeace Southeast Asia investigations 2010; 250 APP
(2008): 1
249 Knowing that a growing number of customers are seeking products
CS certified as not coming from illegal or controversial sources,249
250 APP (2008): 1
250 APP has had a number of its mills’ chains of custody certified
CS under the Programme for the Endorsement of Forest Certification
(PEFC) scheme.250
251 APP (2010): 3;
251 To bear the PEFC logo, a product must contain 70 per cent
CS minimum of PEFC-certified virgin fibre, and the remaining material
in the product must come from ‘verified non-controversial
sources’. However, as there are no PEFC-certified forests or
plantations in Indonesia,251 any production of PEFC products by
APP involves the import of PEFC certified pulp from other
countries.
252 PEFC website. www.pefc.org/index.php/certification-
services/find-certified viewed 6 June 2010
252 This pulp is then mixed with ‘verified non-controversial
CS material’252 (i.e. non-certified timber) from a number of
concessions in Sumatra.
253 APP (2008):2
REPEAT
253 Serious questions remain as to how any such timber produced by This statement is misleading. The PEFC system Ben Gunneberg (2010). Letter to Andy Tait, Misleading
CS APP companies can be classified as ‘non-controversial’. The of certification is a risk management system Greenpeace, dated March 10 2010; Letter to Andy
company claims that its pulp mills in Sumatra, PT Indah Kiat and PT that verifies a percentage of material as 'non- Tait, Greenpeace, April 22, 2010; Letter to Andy
Lontar Papyrus, have introduced:253 controversial'. It is a risk management system Tait, Greenpeace, July 2 2010; Greenpeace, July 9
254 APP (2008): 2 that is similar to FSC's 'Controlled Wood' 2010
standard. It does not purport to certify the
remaining 30 per cent under this standard.
The rather simple nature of this certification
system was explained in detail to Greenpeace
by PEFC Chief Executive Ben Gunneberg,
however, these explanations were ignored by
Greenpeace. Moreover, there was a clear call
by PEFC for Greenpeace to use the formal
dispute resolution system via PEFC
certification. To the author's knowledge this is
yet to take place.
254 “PEFC procedures for avoidance of raw material from controversial This statement is incorrect, and based upon a SGS (2010). Letter to CFMEU. Wednesday, 11 Incorrect
CS sources...verified by an independent third party certification body complaint made to PEFC by the CFMEU February 2009
in order to provide confidence that no illegal or controversial wood (Construction Forest Mining and Electrical
enters the mills’ fibre supply chain.” (APP Stakeholder Update, May Union, based in Australia). The complaint was
2008) The reality is that none of the raw materials entering these not upheld by PEFC and/or SGS, the auditor in
mills had been officially verified under PEFC rules. In fact, at the question.
time that this statement was written, neither of the mills even had
PEFC Chain of Custody certification.254
255 Greenpeace UK communication with SGS, 18 June 2010
255 Following correspondence with Greenpeace, PEFC confirmed that See above Selective
CS APP has been asked to “modify the statement to avoid any
potential misinterpretation”.255
256 PEFC letter to Greenpeace UK, 9 March 2010
REPEAT
256 Elsewhere, APP has claimed that these two mills “have been The statement was subsequently altered Correct
CS verified by an independent third-party certification body in order following the Greenpeace correspondence.
to provide confidence that no illegal or controversial wood enters
the mills’ fibre supply chain.”256 (This text appears above two
images of audit certificates for these mills, issued by SGS auditors.)
257 APP website www.app-mythsandrealities.com
257 Asked by Greenpeace for details of this verification, an SGS auditor See above. This statement is misleading. The The mills do, however, have current and valid Misleading
CS replied:257 “I cannot confirm that SGS has actually done an audit auditor cannot confirm that all the material certificates for TLTV from SGS.
at the mills to confirm that all material received at these mills is entering the mills has been audited; but this is SGS-TLTV / LP VLO 0005; SGS-TLTV / LP VLO 0006
covered by the SGS verifications.” (SGS’ emphasis) not what the TLTV or CoC assessments are
258 SGS email to Greenpeace UK, 23 April 2010 supposed to do; they are only supposed to
audit a percentage of the material, not 100 per
cent of it.
258 SGS has more recently confirmed to Greenpeace that no such audit See above Misleading
CS has taken place. 258
259 Greenpeace UK communication with SGS, 18 June 2010
259 In 2009, according to Ministry of Forestry data,259 PT Indah Kiat See above Misleading
CS continued to receive rainforest logs (i.e. MTH). As shown above,
Greenpeace investigations illustrate that the company continues to
source rainforest logs from tiger habitat and peatland forests, both
considered highly controversial
260 Ministry of Forestry document 2009, copy held by
Greenpeace International
260 . In addition, acacia logs were supplied to PT Indah Kiat from See fn 45 Misleading
IL plantations that were established on peat deeper than three
metres,260
261 Wahyunto et al (2003)
261 which is illegal under Indonesian law.261 See fn 48 Repeat
IL 262 Government of Indonesia (1990)
262 As of 2006, 213,000 hectares of acacia plantations inside Sinar See fn 45 Repeat
DF Mas-controlled concessions were located on peatlands, with at
least 50,000 hectares located on peatland deeper than three
metres.262
263 Greenpeace International analysis based on the Ministry of
REPEAT
Forestry’s 2006 land cover map and concession data released by
the same Ministry in 2010.
263 While APP is actively trying to convince potential customers of its See fn53 Repeat
RE sustainability credentials, several large multinational companies
have already severed ties with APP after it was unable to address
their concerns. Office supplies retailer, Staples, sourced about 9
per cent of its total paper supply from APP.263
264 WSJ (2008)
264 Following allegations against the company, Staples chose the route See fn53 Repeat
RE of positive engagement, trying to encourage APP to change. In
2008, it severed all contracts with the group, claiming that
“engagement was not possible anymore” and that to remain a
customer of APP would be “at great peril to our brand”.264
265 WSJ (2008)
265 Along with Staples,265 See fn53 Repeat
RE 266 Staples (2009)
266 other well known brands and global players such as: Office See fn54 Repeat
RE Depot;266
267 Office Depot (2009)
267 Woolworths (Australia);267 See fn54 Repeat
RE 268 ABC (2008)
REPEAT
268 Franklin Covey; Fuji Xerox; Ricoh; Target; Unisource; H&M; and The statement from which this is sourced is not Selective
RE Gucci have all decided to stop buying from APP.268 footnoted, and despite searches of public
269 RAN (2009a); RAN (2009b) information could not find adequate evidence
that a large proportion of the companies cited
had in fact chosen to cease business with APP
on environmental grounds. Some companies
named have implemented FSC purchasing
policies that exclude non-FSC paper rather
than non-APP paper. For example, Fuji Xerox –
in 2007 undertook to switch to a 40 per cent
FSC-certified supply chain, and consequently
reduced its non-FSC suppliers. It was able to
secure 40 per cent in 2007, but due to changes
in FSC’s certification rules it has since only
been able to meet a 17 per cent target; Ricoh
undertook a commitment to use FSC-certified
and recycled paper in 2002.
269 Other international companies including Kimberly Clark, Kraft, See fn54 Repeat
RE Nestlé and Unilever, are in the process of implementing global
sustainability policies for pulp and paper. These policies will
exclude paper products from APP unless it makes substantial
improvements to the sustainability of it’s fibre supplies.269
270 Kraft, Nestlé and Unilever pers. comms. with Greenpeace UK;
Kimberly Clark pers. comm. with Greenpeace USA
REPEAT
270 Meanwhile a number of international non-governmental An agreement was signed between the *1+ “Letter of Intent between WWF Indonesia, Asia Selective
CS organisations have also dropped working relationships with APP. organisations in August 2003. This 'Letter of Pulp and Paper Co. Ltd. and its fiber suppliers, the
These include WWF, the certification body Rainforest Alliance Intent'[1] specified certain a number of actions Sinar Mas Group forestry companies”, 13 February
Smart Wood (US) and the international forest certification body and conservation activities that would be 2003.
the Forest Stewardship Council (FSC). In 2004, WWF ended its undertaken by APP and WWF. The centrepiece http://www.wwf.or.id/attachments/Letter%20of%
partnership agreement with APP after the group refused to stop of the Letter was the commitment to develop 20Intent-Final.pdf.
converting natural forest to plantations:“ In APP’s assessment, it an Action Plan, which would develop time-
sees any forest as ‘degraded’ and ready for conversion to bound commitments to:
plantation…APP was asked to redo their assessment. WWF said i. achieve a Sustainable Wood Supply;
APP has been doing a lot of logging in good forest, so why not ii. document its conservation policy, which
suspend all logging operations in native forest. The company said protects any remaining high conservation value
‘not possible’”. 270 forests under the management of SMG and its
271 WWF Indonesia’s Nazeer Foead quoted on www. suppliers in Riau and Jambi provinces;
climatechangecorp.com/content.asp?ContentID=5218 iii. ensure upgraded chain of custody to
guarantee all suppliers are fully legal compliant
and eliminating any wood deliveries that are of
doubtful legality;
iv. resolve legitimate social conflicts with local
communities. The deadline for the completion
of the Action Plan was January 31, 2004.
However, the negotiation process between
APP and WWF disintegrated. WWF withdrew
its support for the final version of the Action
Plan in mid-February 2004.
REPEAT
271 • Since then, WWF has been calling on companies to demand that On the day that the Letter of Intent between [1] APP account of events. This type of response Selective
CS APP stop its unsustainable practices.271 APP and WWF expired (February 19, 2004), from WWF is not unusual. For example, when
272 WWF (2008) WWF re-commenced its campaign against APP. negotiations between Indonesian forestry
A lobbying campaign directed at APP company Asia Pacific Resource International
customers took place over the following four Limited (APRIL) and WWF fell apart in 2001, WWF
months. [1] The campaign stated that APP's immediately campaigned APRIL's customers and
timber should generally be considered illegal, requested CNN to air a story on the company. See
despite it being based on unproved allegations Steve Stecklow (2006). 'Environmentalists, Loggers
of the legality of timber from one supplier, and Near Deal on Asian Rainforest'. Wall Street Journal,
a disagreement over the legal authority of February 23, 2006
logging rights. The campaign has continued in
the four years since then. WWF has continued
to accuse APP of illegal logging, despite the
latter implementing legality verification audits
by Society General du Surveillance (SGS) for a
number of its suppliers, giving it the right to
apply FSC logos which verified the fact.
272 In 2008, the Rainforest Alliance’s Smart Wood programme The cited document does not contain the Nonexisten
CS withdrew cooperation with APP, stating that:272 “It is the decision quoted text. t
of Rainforest Alliance that we do not wish to be used by APP again
in order to mislead the public and the consumers.”
273 Rainforest Alliance (2007)
273 In 2007, the FSC dissociated itself from APP and revoked its chain The cited document does not contain the Nonexisten
CS of custody certificate:273 ”…the FSC Board of Directors decided quoted text. The text from 'unless APP ...' is t
that FSC should not allow any association of its name with APP or not part of the original document. FSC did not
any company in which APP is a majority shareholder, unless APP revoke the chain of custody certificate; it
completely and immediately stops converting natural forests and simply prevented APP from using the FSC logo
provides documented evidence of that cessation.” or name in any of its communications.
274 FSC (2007)
274 Footnotes 274-277 have no text
275 Confidential 2009 trade data, copy held by Greenpeace
International
275 276 Confidential 2009 trade data, copy held by Greenpeace
International
REPEAT
276 277 In 2008 Gold East Paper produced 2.2 million tonnes of
coated fine paper. Source: Gold East Paper (2009). Chinese total
production amounted to 4.6 million tonnes in the same year.
Source: China Paper Association (2008)
277 278 CTI (2010)

278 Recent research by Greenpeace shows that many other
CS international companies are still buying or selling paper products
sourced from APP. These include: French supermarket chain
Carrefour(eg in Indonesia, China); US supermarket chain Walmart
(in China);278
279 French supermarket chain Auchan (in China);279
CS 280 Greenpeace China investigations 2010
280 British supermarket chain Tesco (in China);280
CS 281 Tesco stocks various APP China brand products in its retail
outlets in China. Greenpeace China investigations 2010
281 British retail group WH Smith (in the UK);281
CS 282 WH Smith stocks various stationary products of APP-related
company Collins (Nippecraft) 283 APP Brasil (2008)
282 US information technology multinational Hewlett Packard (in
CS Brazil);282
283 APP Brasil (2008)
283 US fast-food chain Kentucky Fried Chicken (in China);283
CS 284 Greenpeace China investigations 2010; see also Ningbo Asia
Paper website, Products www.nbasia.com.cn/en-products. asp
284 U Dutch Office supplies company Corporate Express;284
CS 285 Corporate Express (2010)
REPEAT
285 and Australian global paper merchant PaperlinX (e.g. in Australia
CS and the UK).285
286 PrintWeek 2009. See also Spicers Global products www.
spicers.com.au/index.asp?menuid=100.030.080&art id=232
(viewed 8 June 2010). Sinar Royal and Sapphire are Sinar Mas
brands. PaperlinX operates worldwide through subsidiaries
including PaperCo, Robert Thorne & Howard Smith (all UK),
Papernet (AT), Deutsche Papier (DE), Polyedra (IT), Spicers Paper
(HK, MY, SG, AUS, CDN, US), Paperpoint (AUS), Coast Paper (CDN)
and many others
286 In October 2009, Greenpeace tested286 paper products from APP’s No methodology has been made available. Selective
DF Gold East Paper mill in China to see if they were made using fibre However, as demonstrated above, the data on
from tropical rainforests or plantations. The tests were carried out the use of MTH is on the public record.
through an independent laboratory. Out of the five papers tested,
four proved positive for rainforest fibre (i.e. Mixed Tropical
Hardwood or MTH).
287 APP China’s Gold East Paper mill accounts for almost half of
CO China’s coated fine paper production.287
288 In 2008 Gold East Paper produced 2.2 million tonnes of
coated fine paper. Source: Gold East Paper (2009). Chinese total
production amounted to 4.6 million tonnes in the same year.
Source: China Paper Association (2008)
288 It exports to over two dozen countries288
CO 289 CTI (2010)
289 and is the single largest export destination from APP’s Riau-based
CO pulp mill, PT Indah Kiat.289
International
290 Customers of the mill’s paper include many highprofile magazines
CO and books including as Chinese National Geographic; CNN
Traveller; COSMO (published by National Geographic); Cosmo Girl
(published by Cosmopolitan); ELLE; Esquire; and Marie Claire.290
291 See APP Print Awards 2007-2009 www.
sinarmasprintawards.com/ Application requirement: ‘At least
REPEAT
70% of paper used in entries must be Gold East Paper or Gold
Huasheng Paper’s product.’
291 Some international companies – such as Kraft, Nestlé and Unilever Repeat
CO – have stopped buying palm oil from Sinar Mas. However the
following companies, listed as customers of Sinar Mas’ palm oil
division in June 2009, 291 have not yet made similar
commitments:291 • Campbell Soup Company (US); Burger King
(US); Dunkin Donuts; Pizza Hut (US); and Shiseido (Japan).
292 GAR (2009a):13
292 • Two of the largest palm oil traders in the world – Cargill (US) and Repeat
CO Wilmar (Singapore) – are still buying from Sinar Mas and trading to
a variety of their customers.292
International
293 In addition, the French supermarket chain Carrefour, is still selling Repeat
CO Sinar Mas own brands of palm oil products in its stores in
Indonesia.293
294 eg Carrefour (Indonesia) Java catalogue for Bali, Java and
Makassar, 7-20 April 2010.
294 In a letter to Greenpeace International in January 2010,294 APP
CL claims that it “supports President Susilo Bambang Yudhoyono’s
pledge to reduce carbon emissions by 26% by 2020 [and is]
committed to making its carbon footprint as small as possible.”
295 APP (2010): 3
REPEAT
295 In September 2009, Indonesian President Susilo Bambang
CL Yudhoyono announced its climate change targets to G-20 leaders,
stating that Indonesia will:295 “reduce *its GHG+ emissions by 26%
by 2020 from BAU (Business As Usual). With international support,
we are confident that we can reduce emissions by as much as 41%.
This target is entirely achievable because most of our emissions
come from forest-related issues, such as forest fires and
deforestation.” (emphasis added by Greenpeace)
296 President Susilo Bambang Yudhoyono (2009a)
296 President Yudhoyono’s targets could lead to substantial reductions

CL in Indonesia’s GHG emissions:296 26 per cent target: predicted
2020 emissions would need to be cut to around 90 per cent of
Indonesia’s 2005 emissions (i.e. equivalent to a reduction of
163MtCO2 on 2005 annual emissions). 41 per cent target:
predicted 2020 emissions would need to be cut to nearly 75 per
cent of Indonesia’s 2005 emissions (i.e. equivalent to a reduction
of 586MtCO2 on 2005 annual emissions).
297 2005 emissions (2,250MtCO2) and BAU 2020 emissions
(2,820MtCO2): 26% reduction on BAU 2020 is 733 MtCO2, or an
equivalent reduction of 163MtCO2 on 2005 annual emissions;
415 reduction on BAU 2020 is 1,156MTCO2, or an equivalent
reduction of 586MTCO2 on 2005 emissions: Source: NCCC (2009a)
297 As 80 per cent of Indonesia’s GHG emissions are mostly from the
CL conversion of rainforests and peatlands,297
298 NCCC (2009a)
298 these “forest-related” emissions would have to be severely cut in
CL order to meet President Yudhoyono’s targets as described
above.298
299 NCCC (2008a)
299 In May 2010, as a first step to achieving its targets, President
CL Yudhoyono announced a two year moratorium on the granting of
any “new concessions on conversion of natural forests and
peatlands into plantations”.299
300 Government of Norway (2010).
REPEAT
300 This was part of a USD 1 billion ‘cooperation agreement’ between
CL the Norwegian and Indonesian Governments.300
301 Government of Norway (2010).
301 The moratorium does not apply to the conversion of natural
CL forests and peatlands within existing concessions, so does not
affect the hundreds of thousands of hectares of forested
concessions that Sinar Mas has already acquired but which have
not yet been converted. This includes the forested concessions
that Sinar Mas controls for both pulp and oil palm plantations.301
302 EoF (2010); Greenpeace International (2007); Greenpeace
International (2008a); Greenpeace International (2008b);
Greenpeace UK (2009); Greenpeace International (2010a);
Greenpeace International (2010b)
302 Of the pulpwood concessions Sinar Mas acquired since 2007, Repeat
CL around 30,000 hectares are located on peatland areas over three
metres deep, and therefore illegal to destroy, and over 100,000
hectares are located on peatland less than three metres deep.302
303 Greenpeace International mapping analysis is based on the
Wetlands International peat distribution maps and concession
data released by the Ministry of Forestry in 2010
303 APP is continuing to expand its pulp and palm oil operations into Repeat
CL Indonesia’s remaining rainforests and carbon-rich peatlands. At
the same time, annual emissions from peatlands are forecast to
increase by 20 per cent due to the “continued conversion of
peatland.”303
304 NCCC (2008b)
304 It is therefore clear that if APP continues business as usual it will The Government has made an initial Misleading
CL undermine the government’s aims to reduce its contribution to commitment; yet there is no plan of
global climate change. implementation. To say that APP is
305 Forested areas are defined as greater than 10 per cent undermining these commitments is akin to
canopy cover stating that all industry in Indonesia is doing
the same. APP has also initiated several carbon
reduction activities, such as the publicly
available carbon footprint monitoring, CDM
programs, conservation forest carbon
REPEAT
assessment & REDD programs and plantation
carbon impact assessments.
Annex II: Greenpeace Maps Analysis
PROVINCE DEFINITION ON OFFICAL HELD BY LICENCE Affiliated LOCATION IF ASSESSMENT

GREENPEACE MAP STATUS COMPANY to UNDEFINED
Riau Sinar Mas Pulpwood Not a Not applicable Not applicable Not Directly adjacent to PT Non-existent: The area marked
Existing Concession concession applicable Diamond Raya, southern on the Greenpeace map is not a
boundary concession area
Riau Sinar Mas Pulpwood Not a Not applicable Not applicable Not Adjacent to PT Suntara Non-existent: The area marked
Existing Concession concession applicable Gajapati, southern on the Greenpeace map is not a
boundary concession area
Riau Sinar Mas Pulpwood Plantation PT Bina Daya 555/Menhut- APP’s Incorrect: The area marked is an
Expansion Targets concession Bentala II/2006 22-Des-06 supplier existing concession
Riau Sinar Mas Pulpwood Plantation PT.RIMBA ROKAN 554/Menhut- APP”s Incorrect: The area marked is an
Expansion Targets concession PERKASA II/2006 22-Des-06 supplier existing concession
Riau Sinar Mas Pulpwood Not a Not applicable Not applicable Not Adjacent to PT Sekato Non-existent: The area marked
Existing Concession concession applicable Pratama Makmur, on the Greenpeace map is not a
southern boundary concession area
Riau Sinar Mas Pulpwood Not a Not applicable Not applicable Not Directly east of PT. Non-existent: The area marked
Existing Concession concession applicable SATRIA PERKASA on the Greenpeace map is not a
AGUNG concession concession area
Riau Sinar Mas Pulpwood Plantation PT.BALAI KAYANG 20/Menhut- APP’s Incorrect: The area marked is an
Expansion Targets concession MANDIRI II/2007 05-Jan-07 supplier existing concession
Riau Sinar Mas Pulpwood Selective PT SIAK RAYA 202/Menhut- RAPP Speculative: The area marked is
Existing Concession concession TIMBER II/2007 16-Mei-07 an existing concession
belonging to another company
Riau Sinar Mas Pulpwood Selective PT.BHARA INDUK SK 802/Kpts-VI/99 Not APP Speculative: The area marked is
Expansion Targets concession (d/h BRAJATAMA) an existing concession
Jambi Sinar Mas Pulpwood Plantation PT. WANA MUKTI 275/Kpts-II/1998 Not APP Speculative: The area marked is
Expansion Targets concession WISESA 27-Feb-98 an existing concession
Jambi Sinar Mas Pulpwood Plantation PT. MALAKA AGRO 570/Menhut- Not APP Speculative: The area marked is
Expansion Targets concession PERKASA II/2009; 28-Sep- an existing concession
09 belonging to another company

Jambi Sinar Mas Pulpwood Plantation PT.ARANGAN 660/Kpts-II/1995 Not APP Speculative: The area marked is
Expansion Targets concession HUTANI LESTARI 12-Des-95 an existing concession
Sumatra Sinar Mas Pulpwood Selective PT.BUMI 604/Kpts-II/1997; Not APP Speculative: The area marked is
Selatan Expansion Targets concession PRATAMA USAHA 18-09-1997 an existing concession
JAYA belonging to another company
Sumatra Sinar Mas Pulpwood Plantation PT.PAKERIN 226/Kpts-II/1998 Not APP Speculative: The area marked is
Selatan Expansion Targets concession 01-Feb-98 an existing concession
Sumatra Sinar Mas Pulpwood Plantation PT.CIPTA MAS 70/Menhut- Not APP Speculative: The area marked is
Selatan Expansion Targets concession BUMI SUBUR II/2005 29-Mei-05 an existing concession
Sumatra Sinar Mas Pulpwood Plantation PT. PARAMITRA 378/Menhut- Not APP Speculative: The area marked is
Selatan Expansion Targets concession MULIA LANGGENG II/2009 25-Jun-09 an existing concession
Sumatra Sinar Mas Pulpwood Plantation PT.WAY HIJAU 195/Kpts-V/1992 Not APP Speculative: The area marked is
Selatan Expansion Targets concession HUTANI 01-Apr-92 an existing concession
Sumatra Sinar Mas Pulpwood Selective PT. HARAPAN TIGA 382/Menhut- Not APP Speculative: The area marked is
Selatan Expansion Targets concession PUTRA II/2005 11-Nop- an existing concession
05 belonging to another company
Maps included in the following pages:
1. The Greenpeace Report map (p.14 of the Greenpeace Report) overlaid with
Direktorat Inventarisasi Dan Pemantauan Sumber Daya Hutan Dan Direktorat Jenderal
Planologi Kehutanan Departemen Kehutanan (2009) Peta Pemanfaatan Dan Perubahan
Peruntukan Kawasan Hutan, Provinsi Riau, Provinsi Jambi, Provinsi Sumatera Selatan.
2. The Greenpeace Report map (p.14 of the Greenpeace Report)
3. Direktorat Inventarisasi Dan Pemantauan Sumber Daya Hutan Dan Direktorat

Jenderal Planologi Kehutanan Departemen Kehutanan (2009) Peta Pemanfaatan Dan
Perubahan Peruntukan Kawasan Hutan, Provinsi Riau, Provinsi Jambi, Provinsi
Sumatera Selatan.
Annex III: Reviewer Statements and Qualifications
Reviewer 1: Dr Neil Byron (dr.neil.byron@gmail.com)

PhD, MA (Econ), BSc (For) (Hons)
Member, Wentworth Group of Concerned Scientists
Adjunct Professor, ANU‟s Crawford School of Economics &
Government and Fenner School of Environment & Society;
Visiting Fellow, University of Melbourne; and Wolfson College, Oxford
University.
Director, Earthwatch Institute Australia
Former Member, IUCN‟s World Commission on Protected Areas
Former Assistant Director General, Center for International Forestry
Research (CIFOR), Bogor, Indonesia
Statement:
The Greenpeace report “Pulping the Planet” purports to be a credible scientific

presentation of facts and evidence, supported by many footnotes and an extensive
Bibliography. However, from my extensive experience in Indonesia and the forestry and
pulp & paper sector internationally, I conclude that the Audit of those claims has been
very thorough and that the Greenpeace report is seriously misleading, due to:
- Misrepresentation of facts;
- Omissions of important contradictory and/or explanatory materials that are

readily available to any serious researcher; and
- Inclusion of much pejorative material that is irrelevant to their claims;
through a mix of incompetence, ignorance and/or design.
Dr R.N Byron, August 26, 2010
Reviewer 2: Dr David F Smith AM (dfsmith@unimelb.edu.aud)

Research Fellow School of Agriculture and Food Sciences, University of
Melbourne
Former Director General of Agriculture (Victoria)
Member of the Order of Australia in 1995
Fellowship of the Australian Institute of Agricultural Science (1984)
Australian Medal of Agricultural Science (2003)
Statement:
20 August 2010.
Statement:
I have examined the report of Greenpeace 'Sinar Mas is Pulping the Planet‟, covering the
operations and conduct of Asia Pulp and Paper (APP), and studied the analysis of that
report.
Unfortunately, the Greenpeace report is misleading with many errors and imprecisions.
In my opinion it is a shabby and careless piece of work. The imprecisions often arise
from their failure to appreciate the nature of land-based field work, where mapping and
boundaries are often problematic because of the very nature of ecosystems. The field
competencies of analysts become very important – easily leading to errors in
conclusions. In this case these have been further compounded by inadequate cross-
checking of the final document.
I believe the audit carried out by ITS Global shows diligence and fairness.
(Dr) David F Smith AM
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Audit of ‘How Sinar Mas is Pulping the Planet’ September 2010

Audit of ‘How Sinar Mas is Pulping the Planet’

Report for Asia Pulp & Paper (APP) by ITS Global

International Trade Strategies Pty Ltd, trading as ITS Global

International campaign organisation Greenpeace published a report in July 2010, „How

Greenhouse Gas Emissions

Consequently, Greenpeace‟s contention that APP is a major contributor to Greenhouse

Credibility of the Greenpeace Report

Greenpeace states publicly that it is a campaigning organisation, not a conservation

2. General Claims and Evidence Used in The 8

Annex I: Pulping the Planet Analysis 19

Annex II: Greenpeace Maps Analysis 78

Annex III: Reviewer Statements and Qualifications 83

APP Asia Pulp & Paper

2. General Claims and Evidence Used in The Greenpeace Report

2.1 The broad claims of the Greenpeace Report

- Accelerating climate change;

In addition, corporate information on the company -- such as levels of debt, size of

- The Indonesian Government (generally);

An analysis of the individual items based on footnotes (see Methodology) demonstrates a

2.2 Evidence used in the Greenpeace report

In addition, Greenpeace presents a map on page 14 of the report, which purports to

- 4 areas as existing forest concessions belonging to APP that are non-existent

Examples of the misuse of data are presented below.

2.2.1 Non-existent data

“In 2008, the Rainforest Alliance‟s Smart Wood programme withdrew

2.2.2 Speculative data

The Greenpeace Report states:

2.2.3 Misleading data

2.3.4 Incorrect use of data

“According to recent government estimates, Indonesia ranks as the world‟s third

According to recent estimates published by various governments, Indonesia‟s

347/Menhut-II/2004, 10 September 2004; SK Menhut No. : SK. 29/Menhut-II/2006, 13 Pebruari 2006;

Greenpeace also ignores the Indonesian Government‟s Second National Communication

2.3.5 Selective data

3. Key claims of the Greenpeace Report

3.1 Greenpeace’s key claims

The Greenpeace Report makes two key claims.

3.1.1 Expansion concessions

The Greenpeace Report defines these areas as „expansion concessions‟ or „expansion

3.1.2 Plantations on peat lands

3.2 Evidence supporting the major claims

There are three such key pieces of evidence:

3.2.1 ‘Confidential Sinar Mas document, copy held by Greenpeace International’

Closer inspection of the Greenpeace Report and a follow up document by Greenpeace

3.2.3 Presidential Decree 32 of 1990’

3.3 Gross inaccuracies in the major claims

4.1 Text Analysis

- Damaging the climate (Climate)

Non-existent – no supporting data found within the Greenpeace claims;

Misleading – the data is cited in a way that is unclear or could easily be

Incorrect – the claim is not supported by the cited data;

4.2 Map analysis

- Izin Usaha Pemanfaatan Hasil Hutan Kayu – Hutan Tanaman Industri

- Izin Usaha Pemanfaatan Hasil Hutan Kayu – Hutan Alam (IUPHHK-HA –

The maps used were:

4.3 Independent Review

Annex I: ‘Pulping the Planet Analysis’

17 As a result, a growing number of international consumer

277 278 CTI (2010)

296 President Yudhoyono’s targets could lead to substantial reductions

Annex II: Greenpeace Maps Analysis

PROVINCE DEFINITION ON OFFICAL HELD BY LICENCE Affiliated LOCATION IF ASSESSMENT

09 belonging to another company