35 tons of aboveground biomass is increasingly the number used to define high conservation value forest for greener palm oil initiatives. Image from Greenpace.
It was just after lunch, Monday, November 8th 2010 when it all began. At the time, it was innocent enough; there were certainly no ill
intentions. Yet, looking back, I now see it as the moment that kicked off the polarizing debate that today splits the palm oil industry and
that drowns out much needed sensible discussion around how forest protection and palm oil expansion might go hand in hand. The debate, with all its spin
and tension, has become the focus rather than that more important, bigger question.
I was in a meeting room in the Crowne Plaza hotel in Jakarta with folk from Golden Agri-Resources (GAR) and Greenpeace. We were meeting for the second time
in three days and we were struggling together to define “forest”.
On March 17th 2010, Greenpeace had released its now famous Orangutan finger/Kit Kat video attacking Nestlé for buying palm oil from GAR. On May
17th, 2010, two short, intense months later and as a follow up to its Chairman’s December 2009 commitment that no Nestlé product would be linked
to deforestation, Nestlé announced new No Deforestation Responsible Sourcing Guidelines (RSGs) and its partnership with TFT. The RSGs committed Nestlé to
buying palm oil only from suppliers who were legally compliant, who respected communities’ Free Prior and Informed Consent and who were protecting
peatlands, High Conservation Value (HCV) forests and High Carbon Stock (HCS) forests. Nestlé’s move was ground breaking and it invited its suppliers to
Singapore in the week of May 24th to meet its Procurement team and TFT to discuss RSG implementation.
Conversion of rainforest in Malaysia for oil palm plantations. Photos taken by Rhett Butler.
Though GAR was no longer a direct supplier (Nestlé had delisted GAR on March 18th), their representatives joined meetings with Nestlé and TFT to
discuss the RSGs.
GAR’s response was poignant and suggestive of what was to come.
They said that they believed they were acting legally, that they had a FPIC process but accepted it could be improved. They were already implementing the
RSPO New Planting Procedures so yes, they were conducting HCV assessments in advance of all developments. They had in fact committed to no peatland
development on February 4th, 2010 but yes, were still establishing procedures to implement the commitment. They thus believed that they were
well advanced in achieving four of the five RSGs, “but what is this HCS forest concept?”
Tough question and one for which we didn’t have an immediate, clear answer. What is HCS and where had the HCS concept come from?
Here’s a quick history…
Rainforest clearing for palm oil production in Malaysia.
When the Indonesian government says it wants another seven million hectares of palm oil plantations established in the not-too-distant future, there are
two distinct initial reactions:
“Terrific!” from the palm oil industry interested in seeing their businesses expand.
“Oh NO!!!” from NGOs worried that new plantations will come at the expense of forests where so much has already been lost.
“Don’t worry, they’ll only be established on degraded land” comes the reassuring response. Initial relief from NGOs soon becomes “OK, but what do you mean
by degraded land?” which is where things go somewhat awry.
There is no clear definition of “degraded” land in most countries’ laws. When seeking to explain “degraded”, folk speak about “secondary” or “logged over”
forest but then we’re left to wonder “how logged over?” and “what do you mean by secondary?”
THAT is the question we were struggling with that November 2010 afternoon in the Crowne Plaza. Where was the line we could together clearly and credibly
say separates forests that should be conserved from degraded land that could be developed into oil palm plantations? Wherever the line was defined, we
needed an approach to locating it in the field that was relatively straightforward; no PhD level research definition would do; we needed something
pragmatic, easily measured and scientifically credible. And beyond that, while we were discussing a process for GAR’s plantations, we were mindful that
whatever we developed had to be applicable and acceptable to the broader industry.
Oil palm plantation in Borneo.
Back in September 2010, GAR staff and I had engaged in a similar exploration. We had tortured ourselves looking at various “forest” definitions and found
none helpful, least of all the FAO definition that would have seen most parks in Jakarta defined as a forest, certainly much of Singapore. Our goal in
those early discussions was to find a balance between the need to conserve forests in landscapes where so much forest had been lost and the
need to create jobs, services and much needed development.
Our struggle led to us writing a paper we had called “GAR/SMART Sustainability Leadership Road Map”. We had shared it with Greenpeace in early October
2010. Subsequent back and forth discussion had brought us together on Friday November 5th and then again in that meeting room in the Crowne
Plaza that Monday November 8th.
We had spent the morning discussing general GAR plantation development operations and GAR’s readiness to protect forests within its license areas. Yet, as
the afternoon emerged from a constructive lunchtime discussion, our lack of common understanding around how to define the “forest” that should be protected
and the “degraded” land that could be cleared was holding us back.
As we grappled with the issue, I stood up and wrote a large “35” on the flip chart. There was silence. “What’s that then?” the participants wondered.
“Well,” I explained:
- The RSPO’s Greenhouse Gas (GHG) Working Group was considering using a figure of 35tC/hectare of above ground biomass to define the threshold between
forest and non-forest;
- The Indonesian Government’s own Climate Change Unit, reporting directly to the President and operating with support from the Norwegian government, was
also looking at a figure of 35-40tC/ha to define the forest/non-forest threshold;
- Wetlands International had conducted research that suggested a 35-40tC/ha threshold;
- Independent researchers had studied forest conditions in Kalimantan and had defined the threshold between truly degraded land and secondary forest as
- Greenpeace’s own internal discussions and investigations had looked at all the global research on this issue and had concluded that there was sufficient
evidence in support of a threshold in the 35-40tC/ha range.
So…we have many respected sources – the Indonesian government, the RSPO’s GHG Working Group scientists, NGO and independent research – all pointing at this
figure of 35-40tC/ha of above- ground biomass as the threshold that might define the transition from forest to non-forest, degraded land.
Both Greenpeace and GAR volunteered further information based on their own experience and knowledge of what information was out there and we agreed that
while this threshold seemed to have some consensus about it, none of us, in practice, knew what a forest of 35tC/ha looked like. How dense was it? Were
there big trees present? How easily could it be identified in the field? We had no answers but given the consensus among respected sources that was
building around the number, we felt it warranted further investigation.
Secondary rainforest, like this tract in Sumatra, is often cleared by palm oil companies who justify clearing by noting that the forest isn’t “pristine”. Scientists argue that such forests still retain considerable ecological value, in addition to storing substantial amounts of carbon.
A key question emerged from Greenpeace: “If the accepted threshold is 35tC/ha above- ground biomass and field work reveals that 70% of a given concession
is off-limits, what will GAR do? Throw the 35tC/ha threshold out the window and develop anyhow OR respect the threshold and protect the forested areas?”
There was little point in further discussion if GAR adopted the first approach, yet everyone understood that there were legal as well as business
implications of adopting the second. Discussions were adjourned so that GAR could discuss the situation internally, with its leaders. Twenty-four hours
later, GAR responded that it would indeed follow the second approach – it would respect the threshold – provided that others in the industry did likewise
and that doing so did not violate Indonesian law. It was understood that current Indonesian laws would prohibit such conservation practices so there was a
commitment from GAR to take a leadership role in speaking to the various Indonesian Government ministries to explore what might be possible to allow such
forest set-aside and protection. Good.
The next challenge really was to get out into the field and start gathering data to get a clearer idea of what a forest of 35tC/ha looked like and whether
protecting it was economically, ecologically and socially feasible. A forest inventory team comprising GAR, TFT and Greenpeace staff headed to Kalimantan
in the week of November 15th and measured a number of plots within a range of forests, covering a diversity of densities, species and ecological
condition; from severely degraded to high density forest areas. There was no strong scientific basis for this initial one week measurement; it was a first
“look-see”. The results and subsequent photos started to give us an idea of what we were talking about and in the subsequent months, plans were made for a
proper, scientifically valid forest inventory to collate solid, credible data to provide a clear picture of the above- ground biomass measurements in a
range of forest densities and how much of each remained in GAR’s concessions in those areas awaiting possible development.
We were making progress.
Oil palm plantation and forest in Costa Rica.
In order to give this progress some framework, GAR released its Forest Conservation Policy (FCP) on February 9th 2011.
There had been much discussion within GAR and between GAR, TFT, Greenpeace and palm oil industry stakeholders around what the FCP might contain. In the
end, and this is where the events of November 8th 2010 really made an impact, the FCP noted, for High Carbon Stock forests, the
4. High Carbon Stock (“HCS”) Forests
4.1 For the purposes of this policy, we commit to leading the investigation and to promoting the adoption of this new HCS concept, across the palm oil
4.2 We recognize that to conserve the HCS:
the Government of Indonesia plays a critical role particularly with respect to adopting new regulations and enacting relevant legislation so as to
enable the transformation of the palm oil industry (including establishing and implementing a land swap process);
- key players in the Indonesian palm oil industry should address the conservation policy with respect to HCS; and
civil society organizations, local and indigenous communities and other stakeholders must engage in the process to transform the palm oil industry.
4.3 GAR will conduct fieldwork in collaboration with TFT and other stakeholders in the first half of 2011. During such fieldwork, a provisional
definition of exceeding 35tC/ha will be used as HCS forest definition. We will share the results of this fieldwork when finalised. The provisional 35
tC/ha definition may change as applicable to the industry, and as a result of the fieldwork and after consultations with stakeholders.”
(Source: Golden Agri Resources Forest Conservation Policy, Feb 9th, 2011)
What a difference a number makes!
New clearing for an palm plantation in Sumatra.
We set an above-ground biomass exceeding 35tC/ha as a provisional definition of HCS forest (Oxford Dictionaries definition of provisional : Arranged or existing for the present, possibly to be changed later). HCS estimates only around half of the actual carbon present above and below
ground, so this was taken into account in setting the threshold at 35. We couldn’t have known it at the time, but our subsequent field measurements
revealed that there are six clearly defined ecological strata in the lands we were measuring for above- ground biomass and that while we have accurate
measurements of their above- ground biomass, the actual biomass is less important than their ecological condition as high, medium, low density or
regenerating forest (old scrub), and as young, recently cleared scrubland, or as bare ground, grassy areas.
Our locally and internationally peer- reviewed scientific research revealed that the threshold between regenerating forest and recently cleared scrubland,
between forest and non-forest, isn’t exactly 35 tC/ha. Instead the average above- ground carbon value was 27tC/ha for non-forest and 60tC/ha and above for
forests. If we looked at the mid-point between these 27tC/ha strata and the 60tC/ha, it is around 35-40tC/ha – so we were reassured that we were on the
right track. We’ve since learned by measuring forests in other countries that this carbon value might be different elsewhere and it shouldn’t be taken as a
standard throughout the world.
Really, the key thing we’ve learned is that while the average above-ground carbon value per hectare is an important measure, it really is just a proxy, a
way to identify the ecological condition of the forest and it is more important that the stratification of the land cover is performed accurately to
identify the changes between land cover types that are considered forest (regenerating forest and above) and those that are non-forest (scrub and below).
Leading into our field research, we certainly didn’t know for sure what a forest of 35tC/ha above ground biomass looked like. We used our best judgement
and the best information we had available at the time. This is why GAR’s policy notes, “ during such fieldwork, a provisional definition of exceeding 35tC/ha will be used as HCS forest definition”. Yet, even though it was noted as provisional those in the industry opposed to the whole “No deforestation” idea have seized upon “35” as a fixed ‘holy grail’ way of defining forest.
By being open and transparent about our thinking, we have given a stick to those folk who want no constraints on forest clearance beyond the weak
provisions of the RSPO that do not protect secondary forests.
Canopy of an palm plantation in Sumatra.
Some in the industry, worried that a HCS, forest/non-forest threshold set at 35tC/ha will mean no more development but at the same time remaining
completely uninformed by the multi-stakeholder work done by GAR, TFT and Greenpeace, have embarked on an aggressive smear campaign against that number –
35. In doing so, they have sown fear and panic that has led to complete rejection by many of any discussion around HCS forest conservation. It hasn’t
mattered that Brand Palm Oil has a problem because of its link to deforestation and that HCS forest conservation is an industry- led, scientifically
validated, truly multi-stakeholder initiative to find a solution. It hasn’t mattered that those campaigning against the HCS concept know little if anything
of what the forest strata look like. Like us back in November 2010 before we conducted our research, most in the industry know very little about HCS. The
difference is that we went out into the concessions to learn but most in the industry have only “heard” from those waging the campaigns against HCS that it
means 35tC/ha, set in concrete, no opportunity for discussion, that it’s been developed by NGOs without any scientific basis as a way of destroying the
palm oil industry, that it is being pushed by racists who don’t want to see countries developing, that it is some sort of trade barrier, that ultimately,
it simply means no development; that it’s bad, evil, big time. Few have taken any steps to actually look at whether that is the case.
Unfortunately, the debate around how forest conservation and continued palm oil development might be accommodated together within the landscape has been
It hasn’t mattered that GAR’s policy made it completely clear that the 35tC/ha was provisional. Nothing was ever set in concrete and
even though subsequent peer reviewed, published research revealed the average for regenerating forest to be 60tC/ha above ground, the naysayers were by
then racing away with nightmare stories around 35tC/ha meaning no palm oil development in Africa; around it spelling an end to any development in
What we’ve ended up with is two distinct camps:
- Those including the original proponents and a rapidly growing group of palm oil industry players, brands and NGOs ready to continue to further explore
the HCS concept and consider the work done to date as a valuable, starting contribution. Many consumer companies who seek an end to the brand damaging
deforestation link with palm oil now back this group. This group is initiating a HCS Approach Steering Group process to guide the standardization of the
HCS Approach including considering appropriate thresholds in different regions around the world, as well as overseeing the governance of the HCS Approach.
- And secondly those who reject the work done to date as something they’ve not been involved in, something led by GAR, TFT and Greenpeace and somehow
therefore not credible, and who have embarked on their own research into what HCS might look like. These companies continue to develop plantations under
business as usual while their HCS study unfolds over an unclear time horizon. They have come up with their own manifesto that claims to support no
deforestation but it very clearly isn’t today preventing clearance of potential High Carbon Stock forest – in other words business-as-usual deforestation.
The sad thing is that these two camps remain, for now, split and two different HCS concepts are developing side by side. The hope is that over time, these
two concepts might merge into one but in the meantime, more HCS forest will be destroyed further damaging Brand Palm Oil’s ability to rid itself of the
deforestation legacy that damages the whole industry including those, such as smallholders, the campaigning naysayers are purportedly so worried about.
The real disappointment is not just that part of the industry is closing itself, closing its mind, to what is a living, vibrant and ultimately “good for
the industry” discussion around how to marry forest conservation with palm oil industry development but that it is doing so over a mirage.
Canopy of a tract of secondary forest in Sumatra.
The noise around 35 really is just that, a noisy mirage created by the communications teams of those companies and industry bodies that want no constraints
placed on the amount or ecological condition of land that they can develop.
It’s a shame that our “mistake” of being open and transparent in our thinking has provided an opportunity for mischief and spin. Nonetheless, with more and
more palm oil buyers, traders and growers committing to the HCS concept as defined by the work done to date, those resisting it and fear mongering about
35tC/ha will ultimately need to engage and work harder to understand the whole HCS concept. They’re doing that, slowly, and in isolation from the work done
to date while continuing to clear forests and it remains to be seen if what they produce from their deliberations is credible. But ultimately, today, there
are only two types of companies in the palm oil industry, those who have already committed to protecting forests and developing new plantations under
credible No Deforestation policies underpinned by a strong HCS forest concept and those who will in the future. For the good of Brand Palm Oil, let’s hope
that future is not too distant.
The real hope is that soon, all palm oil industry stakeholders can get together to have a more calm discussion around the real deforestation issue that is
threatening the industry. The purpose in telling this story is to help people understand where the number “35” came from; to help them see that despite the
increasingly aggressive and vitriolic claims about HCS and those proposing it, that the key initial motivation was to find a solution to a big palm oil
industry problem that other approaches, such as the RSPO, had failed to address. No one at the table thought about how they could disadvantage trade and
development in developing countries, no one thought racist thoughts. Everyone involved in those initial HCS discussions and everyone involved in furthering
that initial work today is doing so with an open mind around trying to help Brand Palm Oil move forward. And moving forward is not just about forests and
carbon; it’s also about people. For example, participatory mapping has now become a key part of the HCS Approach, which will continue to evolve in a live
and dynamic way.
Brand Palm Oil does have a serious deforestation problem and the sooner it can stop fretting about a non-existent mirage called “35”, the sooner it might
And P.S. A knowledge exchange network led by the University of York in the UK produced its first science for policy report in May 2014. The report – ‘Change in carbon stocks
arising from land-use conversion to oil palm plantations’ – focuses on identifying low carbon stock land cover types that could be converted to oil palm
production. The report determines that a threshold of 40tC/ha should be used as the threshold to identify low carbon stocks that could be developed. The
report focuses on carbon stocks, not the ecologically important functions of forests, but nonetheless, it’s reassuring to see that such a scientific review
uses the 40tC/ha threshold.