Both ENDS’ response to the Indonesian Sustainable Palm Oil National Action Plan
On 30 September 2017 Both ENDS submitted a position statement on the draft Indonesian Sustainable Palm Oil National Action Plan. The draft National Action Plan purports to represent a blue print for improving the sustainability of the Indonesian palm oil industry. However, Both ENDS has significant concerns about the logic, rationale and purpose behind the draft National Action Plan and its legitimacy as a benchmark for a sustainable palm oil industry.
As the world's largest producer and exporter of palm oil, Indonesia has a national interest in improving the sustainability of this important globally-traded commodity. With global demand for palm oil still rising, and Indonesia's government goal of doubling palm oil production by 2020, there is an obvious risk that the social and environmental controversies associated with palm oil production in Indonesia will also continue and multiply.
In order to address the range of negative social and environmental impacts for which palm oil has become known, the Indonesian Sustainable Palm Oil Forum (Forum Kelapa Sawit Berkelanjutan Indonesia - "FoKSBI") has drafted the Indonesian Sustainable Palm Oil National Action Plan (NAP) in July 2017.
FoKSBI, intended to provide a forum for multi-stakeholder dialogue, is primarily comprised of representatives from the Indonesian government and palm oil industry, with some representatives from 'development partners' (such as USAID, the German and Norwegian Embassies, the Round Table for Sustainable Palm Oil) and some Indonesian NGOs.
The draft National Action Plan
In general, the draft NAP identifies a number of cross-cutting issues, as well as a range of governance, law enforcement, regulatory, transparency, environmental and certification challenges. There is a prominent focus on measures to increase the coordination, management and productivity of smallholders, and various measures related to improving monitoring, documentation and planning of palm oil plantations through better coordination of government authorities.
While the draft NAP includes some positive and laudable actions, e.g. measures to resolve land conflicts faster, to ensure existing laws are obeyed by palm oil plantation operators, and to combat corruption and misconduct in the industry, the balance of the actions proposed in the draft NAP fails to present a legitimate plan for a genuinely sustainable palm oil industry.
Instead, the actions set out in the draft NAP appear designed to boost the productivity, efficiency and profitability of large industry players, and to further integrate the palm oil industry in Indonesia's economic, environmental, agricultural and energy policies and infrastructure. Reading between the lines, the driving concern seems to be achieving the Indonesian government's ambition of having at least 70% of Indonesian palm oil certified under its domestic Indonesian Sustainable Palm Oil ("ISPO") standard and protecting the palm oil industry from international market forces and more onerous foreign sustainability standards (like the RSPO).
Both ENDS' reaction
As an international NGO that works closely with local Indonesian civil society organisations on the human rights, social, environmental, cultural and economic impacts of the palm oil industry, Both ENDS felt compelled to submit a position statement on the draft NAP raising our concerns.
While supporting the multi-stakeholder dialogue process, Both ENDS has significant reservations about the draft NAP and the version of 'sustainability' it presents. In summary, Both ENDS' main concerns are that the draft NAP:
- Insufficiently addresses the industry's core sustainability issues, such as illegal forest clearing and forest fires, peat land degradation, land grabbing, community displacement, watershed degradation, labour rights violations etc;
- Has a misguided emphasis on growth and productivity as means to improving industry sustainability;
- Makes no reference to existing international best-practice or sustainability standards adopted by the international community;
- Lacks any measures to facilitate plantation closure, restoration and reforestation;
- Presents a contradictory conservation policy and no clear conservation goals;
- Fails to address the impacts and influence of large-scale producers, millers, refiners and traders; and
- Poorly represents the interests of non-commercial industry stakeholders.
Both ENDS' full submission can be found below.
FoKSBI has indicated that it hopes to finalise the draft NAP by the end of 2017. Both ENDS has urged FoKSBI to postpone finalizing the draft NAP so that it can be revised, with input from Indonesian and international civil society. If the draft NAP is finalised in its current form, it will represent a huge missed opportunity to bring industry participants, government, and civil society groups together around the goal of resolving the negative impacts of reckless palm oil production.