In February, Asia Pulp & Paper, one the world’s largest paper producers, announced a forest conservation policy that would effectively exclude fiber sourced through conversion of rainforests and peatlands. The announcement however was met by skepticism by many in the environmental movement due to APP’s failures to abide by previous commitments to avoid rainforest logging.
Yet APP’s February announcement was notable for a few reasons. First, Greenpeace, APP’s chief environmental agitator over the past four years, said it had enough confidence in the policy to suspend its campaign against APP. Second, the highest levels of APP’s management were involved in pushing the policy forward, which they said was important for the forestry’s giant’s core business, rather than just an exercise in Corporate Social Responsibility (CSR). Third, the forest conservation policy would be implemented by The Forest Trust (TFT), an increasingly prominent conservation group that works with companies to clean up their supply chains. And finally, the announcement was accompanied by shift in messaging from APP: from the combative tone of earlier statements to something more deferential and inclusive. The change caught some of APP’s fiercest critics off-guard.
As a close observer of APP over the past several years, I’ve been keen to see what happens with the forest policy. Accordingly, I have sent a lot of questions to various stakeholders in Indonesia’s forestry sector, ranging from local activists, to international NGOs, to auditors, to officials within the Ministry of Forestry, to APP itself. Much of the research I’ve garnered through this process has ended up in my reporting on the policy, but information continues to come into my inbox. For example, over the weekend, Aida Greenbury, Managing Director of Sustainability at APP, replied to some of my questions in a comprehensive response. Given the extent of her message, I’ve included the full text below.
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APP’s new Forest Conservation Policy – Questions Answered Aida Greenbury, Managing Director, Sustainability, Asia Pulp and Paper Group (APP) In February of this year, we made a commitment to no deforestation throughout our supply chain. This and our other commitments to support responsible forest management can be found in our Forest Conservation Policy (FCP) – a piece of work that we hope will set a new benchmark for sustainability in our sector. Our plan has understandably come under much scrutiny from people and organizations who care about the rainforests. As such, while we have received a great deal of support for our commitments, three months into the implementation of the policy, we have also received many questions, challenges and concerns from a variety of stakeholders. We welcome this interest in our work, indeed our policy includes a commitment to complete openness and to responding quickly to issues that are raised.
Of the questions we have received, we have noticed a number of recurring themes, and to ensure as many people as possible understand the challenges we face, I thought it would be helpful to address each of these themes below. These are, of course, not the only issues we are addressing. We continue to work hard to implement our ambitious goals, and our partner The Forest Trust (TFT) is providing monthly progress updates. We continue to engage directly with our critics in the hope that we can work together on current and future issues. We also invite any interested organizations to get in touch if they would like to take part in any of our third party observer programs. We never expected this to be easy, but we are absolutely determined to succeed.
Question: Mixed Topical Hardwood (MTH) in our supply chain Some groups have asked for a clearer explanation of how Mixed Tropical Hardwood (MTH) felled prior to the moratorium on February 1st 2013 will be processed, what monitoring is being undertaken and when we will be certain that it has cleared through the system. Answer: Our partner, The Forest Trust (TFT), has developed an extremely thorough inventory monitoring process for precisely this purpose, after consultation with NGOs, and they, along with the APP team on the ground, are implementing it now. The process requires the teams to identify and log the boundary of natural forest area in the concession, the quantity of MTH logs in the blocks where natural forest clearing took place prior to the moratorium, and the machinery that was there at the time. The same information is then also gathered at the key stages of transport along the supply chain – at log handling points, then the transit log yards, and finally at the mill gate. We monitor MTH movement through the chain, while also ensuring that boundaries where clearance last took place remain intact. No MTH logs can be received by any of the pulp mills unless they have been through the monitoring process. We will publish this data and progress in our reports, and we would like to invite any NGO interested in this issue to join monitoring trips to check the implementation of the process. Our target date for ensuring all MTH is out of our supply chain is August this year. We have been challenged on this, with requests that it should be completed sooner, and we are fully aware of NGO concerns in this area. We are working hard to complete this work as soon as possible and TFT will report on progress through their monthly reports. The challenges are largely logistical ones regarding contractor availability, infrastructure and variable weather conditions.
Question: Natural Forest Clearance We have been asked on several occasions if it is the case that natural forest can still be cleared if it does not meet High Conservation Value (HCV) or High Carbon Stock (HCS) criteria. Answer: The short answer is no. Under no circumstance can natural forest be cleared under the new policy. To achieve identification and therefore protection, we are using HCV assessment and HCS classification. This is more complex than simply dividing land into one type or another, as there are in fact six classifications, which are identified using both field work and satellite analysis. In descending order of value they are high density forest, medium density forest, low density forest, old scrub, and young scrub and cleared or open land. The first four currently fall into the HCS classification. Prior to the completion of our HCS study, it is only the last two that are available for clearance or usage by APP and its suppliers, and then only when HCV and peat land assessments have been completed.
Question: Openness We are frequently asked about transparency and the role of third party NGOs in monitoring and auditing the Forest Conservation Policy (FCP). Answer: We are absolutely committed to being as transparent as possible and are working with many interested organizations to ensure they are satisfied that we are operating to the highest possible standard. We have carried out a number of initiatives in this regard. Firstly, NGOs and academics together with TFT have flown over our suppliers’ concessions in Riau and South Sumatra province to monitor progress. Additional ground checks are planned for the end of May 2013. Secondly, we are developing what we believe will be an industry-leading online dashboard, which will enable those interested to review detailed progress on the ground, and see what issues and challenges have arisen, and how they are being dealt with. We hope to launch a pilot version of this at www.asiapulppaper.com in June 2013. Thirdly, we have held a series of events in Indonesia for interested parties, to explain the policy and to invite feedback and further inputs. There have been seven so far, with over 50 participants from civil society, the academic community and NGOs. We also intend to invite independent auditors to monitor the implementation of our HCV management plans, to help ensure HCV areas are maintained, protected and enhanced over the long term.
Question: Suppliers We are asked how we are dealing with the provision of detailed information to NGOs for monitoring all suppliers and concession boundaries and existing land cover. Answer: There are a series of protocol documents covering a range of issues on the implementation of the policy that will be made publicly available, along with information on concessions, moratorium boundaries, progress reports and so forth. Other far more detailed information is being made available to NGO observers who participate in the monitoring program and to others with specific requests. Drafts of these protocols have been shared and discussed with NGOs during our discussion events. Now we are incorporating their input into the draft protocols, then we will make them available on the APP website. It is important to note that all FCP protocols are working documents and will be revised regularly, based on stakeholders’ input. To date, 15 NGOs have agreed to take part in our Independent Observer programs and several others are interested in participating in the social conflict resolution and Free, Prior and Informed Consent (FPIC) pilot projects as well as the peatland assessment.
Question: Quantity of protected forest A regular issue of concern is the question of exactly how much natural forest will be saved as a result of the new policy. The observation has often been made that because APP has already cleared enough forest in the past there is nothing of consequence left to save. Answer: Our new policy will lead to substantial areas of natural forest being conserved across our supplier concessions in Indonesia. In addition, it is important to note that the FCP will apply to any new concessions that may supply us in the future. We have said publicly that we will share information relating to the forest stratification analysis and monitoring process, following the completion of the HCS study currently being carried out by the joint APP/TFT team. To ensure that this information is accurate, we will wait until we have all the evidence necessary to support any claims we might make about conserved natural forest. As ever, evidence will be available to stakeholders and any other parties who are interested.
Question: Restoration There is no apparent APP commitment to restoration of forest land previously cleared. Answer: We recognize how important restoration and other connected measures can be to ensure the long term protection of Indonesia’s natural forests in the areas where APP and our suppliers operate. We plan to work with stakeholders on how best to move forward on this topic. Most importantly, we are committed to HCVF principles and will adhere to any recommendations that might come out of the HCV assessment currently taking place. These recommendations may include restoration of natural or plantation forest. As soon as we have all of the information necessary, we will create a HCV management plan, which will consider environmental, social and economic aspects of sustainability. The plan will be developed in consultation with APP employees, civil society, government, company, community and others. We currently are at the start of a long and complex journey during which we must:
However, even when we have completed all of this, there will still be a long road with many challenges ahead. Our objectives remain the same: no deforestation and forest stewardship in our supply chain. And we can’t achieve this without the support from the NGO community and our stakeholders.
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