Where are the trees?
SMG/APP’s new forest policy kicks in only after company hascompleted its planned deforestation in Riau, Sumatra

Investigative Report
Eyes on the Forest
Published in April 2013
Eyes on the Forest (EoF) is a coalition of environmental NGOs in Riau, Sumatra:
Friends of the Earth “Walhi” Riau Office, Jikalahari "Riau Forest Rescue Network" and WWF-Indonesia, Riau Program.
EoF monitors the status of the remaining natural forests in Sumatra's Province of Riau anddisseminates the information worldwide.
For more news on Eyes on the Forest, go to: http://www.eyesontheforest.or.id
For photos and maps, go to: http://maps.eyesontheforest.or.id
Email: editor(at)eyesontheforest.or.id

Front cover
Photo: Sumatran tiger forest cleared inside APP’s self-declared “Senepis Tiger Sanctuary”
inside the concession of PT. Suntara Gajapati, a wood supplier of SMG/APP in Riau Province.
The cleared forest stood on protected peat of more than 4 meters depth. CITES-protected
Ramin trees (Gonystylus sp.) remain standing. Photo taken by Eyes on the Forest at
2o0'52.39"N, 101o8’16.15”E on 11 January 2013.

Summary
In February 2013, Sinar Mas Group’s Asia Pulp & Paper (SMG/APP) published a “forest
conservation policy (FCP)” announcing “an end to the clearing of natural forest across its
entire supply chain in Indonesia”.
In response, Eyes on the Forest (EoF) assessed the policy’s conservation benefit on forests,
wildlife and peat soils in Riau. Since SMG/APP has not provided detailed data to civil society
organizations, EoF combined publicly available data with information collected over many
years of field investigations for its analysis.
EoF identified 21 pulpwood plantation supplier companies for SMG/APP in Riau. Theirconcessions covered 929,204 ha and had 188,634 ha of natural forest remaining in 2012.
89% of the remaining forest should not be cleared as it is protected by law, an extra 8% is
protected by APP’s own previous commitments. The company’s new policy at most protects
an additional 5,171 ha. These forests are small fragments scattered across several
concessions, possibly too small to make a meaningful contribution to ecosystemconservation or even to survive.
EoF also assessed the legality and impact of almost three decades of natural forest pulping
by SMG/APP on forests, wildlife and peat soils in Riau. SMG/APP suppliers’ concessions lost
683,281 ha of natural forest between 1985 and 2012. Of that, 77% was lost in legallyquestionable ways as these forests had been protected by the TGHK spatial plan, the >3mpeat depth limit, and/or the 10% minimum concession forest cover limit. 83% was lost in
Sumatran tiger and elephant habitats, 77% was lost on peat.
The policy does not cover the restoration of these “protected yet lost” forests, forests inhabitat of critically endangered species, or the rehabilitation of the peat soils, many of which
continue to cause carbon emissions as they are constantly being drained to maintain andharvest acacia plantations. At the same time, SMG/APP commissioned much advertised High
Conservation Value assessments for concessions in which planned deforestation had been
completed and practically all remaining forest was already protected. Without restorationcommitment, these assessments carry little if any value.
Despite previous public commitments by APP to become a 100% plantation wood company
by 2004, 2007 and 2009, the annual average speed of forest loss in suppliers’ concessions
did not slow down significantly between 1995 and 2011. The exception was between 2007
and 2009, when a province-wide police investigation into alleged illegal logging by the pulp
& paper industry, including SMG/APP suppliers, caused a quasi-moratorium of forest
clearance in Riau. Forest loss dramatically slowed from 2011, indicating SMG/APP’s suppliers
had almost exhausted their available natural forest supplies before the policy announcement.
A recent analysis of government wood supply data up to this year by Indonesian CSO
Greenomics concluded that APP announced its FCP after their suppliers ran out of forests topulp in Riau and two other provinces in Sumatra.
In conclusion, SMG/APP’s FCP has come too late for the tropical ecosystems damaged in the
suppliers’ concessions in Sumatra. Combined with the lack of a restoration commitment, theconservation benefits of the policy for the company’s main operational area Sumatra areminimal. The same may also be true for areas controlled by SMG/APP suppliers in Kalimantan.
This still needs to be thoroughly evaluated. The process is delayed because detailed datafrom the company are not available.
The policy also lacks another essential commitment. It allows MTH to be delivered to
SMG/APP mills indefinitely, creating a loophole that suppliers may utilize to feed wood into
the mills from new deforestation in violation of the policy. Historically, various suppliers have

1 | EoF (April 2013) Where are the trees?

delivered very large volumes of MTH from legally questionable clearance and potential High
Conservation Value Forests to SMG/APP mills. Recent news that two APP suppliers in West
Kalimantan violated the company’s moratorium vindicates concerns that MTH harvested inviolation of the FCP may be “laundered” into pulp mills.
EoF calls on SMG/APP to restore selected peatlands and forests lost in protected, High
Carbon Stock and High Conservation Value areas in suppliers’ concessions; stop accepting all
tropical forest fiber at all mills by 5 May 2013; mitigate the damages their roads and canals
cause to surrounding natural forests, peat soils and wildlife; and provide detailed information
on existing and new concession areas and mill expansion plans in Indonesia to allow truly
independent monitoring and evaluation of conservation benefits of the FCP.
EoF recommends that APP buyers and other business partners not buy SMG/APP’s products
and support their business until truly independent monitoring has confirmed that thecompany has met the above calls and successfully implemented them.

2 | EoF (April 2013) Where are the trees?

Introduction
The Sinar Mas Group’s Asia Pulp & Paper (SMG/APP) published its “Forest Conservation Policy”(FCP) on 5 February 2013 announcing “an end to the clearing of natural forest across its
entire supply chain in Indonesia, with immediate effect”1.
Eyes on the Forest (EoF) welcomes that announcement in principal. But what does it actuallymean?
If implemented – as many similar announcements in the past have not been2 – SMG/APP’s
expansion should not harm any more Indonesian forests, at least not directly. But how soonand by how much will the company expand its operations? SMG/APP appears to have been
grabbing land faster than anybody else in the industry. Apparently enough land that thecompany announced it has enough plantation supply for its yet to be built new super mill inSouth Sumatra 3 . Will there be even further expansion? Or has the company reachedsaturation and had decided to consolidate its assets and work with what it has to maximize
productivity of its plantations?
What does the FCP actually mean for the vast stretches of land the company controls either
directly or through supply partnerships, for the ecosystems impacted by SMG/APP’s almost
three decades of pulping in Sumatra, Indonesia?
The company has not provided many answers. During several SMG/APP “socialization”
meetings on the FCP, the company did not provide details, nor GIS data, on the status of
natural forest cover in its suppliers’ concessions or its corporate expansion plans.
Upon closer review, the FCP also lacks several essential commitments. SMG/APP did notcommit to stop pulping mixed tropical hardwood fiber (MTH). Its mills can receive MTH
indefinitely, creating a loophole suppliers may utilize to feed wood into the mills from new
deforestation in violation of the FCP. SMG/APP did not commit to protect remaining forestsfrom outside forces or to undo the long-term negative impacts company practices have hadon peat soils, forests and biodiversity. Poachers and encroachers can continue to enterremaining forests via the company’s logging corridors. Drainage canals will continue to dry
up peat soil and cause carbon emissions4, 5. Wildlife will continue to lack essential habitats
like migration corridors and safe retreats.
EoF has been tracking SMG/APP for many years and today(1)
reports on the impact the operations of SMG/APP’s suppliers in Riau, Sumatra have
had on forests, wildlife and peat soils,(2)
identifies potential legal issues of past operations like compliance with the province’s
spatial plan, development of deep peat soils and minimum forest cover requirements,and(3)
evaluates the conservation benefits of the FCP for the forests of Riau, the epicenter of
SMG/APP’s pulp production for almost three decades.
Analyseswere
also
publishedon
EoF’s
interactive
on-line
GIS(http://maps.eyesontheforest.or.id), which is utilizing Google Earth’s Maps Engine platform
to allow stakeholders evaluate some aspects of SMG/APP’s new forest policy themselves andmonitor its implementation.
EoF will update its database regularly as information from other provinces and new details
about existing concessions becomes available.

3 | EoF (April 2013) Where are the trees?

Methods
Due to the lack of company supplied data, EoF combined publicly available data withinformation collected over many years of field investigations6 for this analysis.
EoF identified the companies and their respective concession blocks from which logs havebeen supplied to SMG/APP’s mills in the past based on company information released since
operations began and EoF investigations. Companies may own several concessions and eachconcession may consist of several distinct blocks (concession blocks). The concession blocks
were mapped on EoF’s web GIS (http://maps.eyesontheforest.or.id) and hyperlinked to
relevant reports.
For each concession, EoF calculated










Lost and remaining natural forest cover between 1985 and 2012 based on visualinterpretation of Landsat images7 and existing scientific data8. EoF used its published2012 forest cover for the analysis (http://maps.eyesontheforest.or.id). The satellite
images on which the 2012 analysis was based were taken months before 1 February
2013, the date when SMG/APP’s moratorium on all forest clearance started. EoF thus
likely underestimated deforestation in concession blocks that were being cleared until
the date of the moratorium. Because of that, EoF conducted one spot check of SMG/APP’s
PT Suntara Gajapati concession using satellite images taken in 2013. EoF alleges thatclearing of forest below a 10% total coverage in any given concession block is illegal as
HTI concessions are required by law to protect a minimum 10% forest coverage as“conservation area”9.
Lost and remaining elephant and tiger habitat based on “original” Sumatran elephant10
and tiger11 distribution ranges identified by scientists and compiled by EoF. They areboth “Critically Endangered” according to IUCN 12 and represent “High Conservation
Value 1.2”13. Scientists published the first comprehensive map of tiger ranges only 12
years after SMG/APP started its operations. EoF thus likely underestimated thecompany’s impact on tiger habitat.
Lost and remaining peat forest based on published information on peat distribution anddepth 14 , 15 . EoF alleges that natural forest on peat more than 3 meters deep areprotected, their clearing has been legally highly controversial16, 17. EoF used the only
peat depth data set available for Riau, applying its two depth classes 2-4 meters and >4
meters as criteria for this analysis.
Lost and remaining protected forests based on Riau’s active TGHK spatial plan (Forest
Land Use Agreement, Ministry of Forestry 1986)18. EoF alleges that natural forest zonedby the TGHK as “Natural Forest Reserve & Tourism (HSA-W)”, “Protection Forest (HL)”and “Limited Production Forest (HPT)” are protected from clear-cutting and clearance ofsuch forest has been illegal19.
Lost and remaining protected forests based on SMG/APP’s previous conservationcommitments, including protection of High Conservation Value Forests the company
committed to in 2004 20 , 21 , 22 , 23 , and protection of forests in UNESCO Giam Siak
Kecil-Bukit Batu Biosphere Reserve 24 , Senepis Tiger Sanctuary 25 , 26 , 27 , 28 , 29 andKampar Carbon Reserve 30 , 31 , 32 . EoF assumed that any clearing of such forests
constitutes a violation of corporate commitments.

EoF then estimated the FCP’s conservation benefit for forests in SMG/APP suppliers’
concession blocks in Riau: how much natural forest would it save that was not alreadyprotected by law and / or by conservation commitments SMG/APP had made in the past.

4 | EoF (April 2013) Where are the trees?

Results
1. SMG/APP supplier companies and their concession blocks
EoF identified 47 concession blocks, with a total mapped area of 929,204 ha, owned by 21companies who have supplied wood to SMG/APP in Riau province alone (Appendix 1,“Pulpwood concessions (HTI): APP” at http://maps.eyesontheforest.or.id). Following, in part,
SMG/APP’s terminology, EoF grouped these companies into four categories:
A. Five companies, publicly declared by SMG/APP as its “own” suppliers33, 34, owned a total
mapped area35 of 509,564 ha. For these concessions, APP had issued a “forest clearance
moratorium” on 5 June 2012 after completing forest clearance operations36, 37. [PT. Arara
Abadi, PT. Riau Abadi Lestari, PT. Satria Perkasa Agung, PT. Satria Perkasa Agung
Serapung and PT. Satria Perkasa Agung & KTH Sinar Merawang.]
B. Six companies, publicly declared by SMG/APP as its “independent” suppliers38, owned atotal mapped area of 183,993 ha. For these concessions, APP had issued a “forest
clearance moratorium” on 1 February 2013. [PT. Balai Kayang Mandiri, PT. Bina Duta
Laksana, PT. Riau Indo Agropalma, PT. Ruas Utama Jaya, PT. Suntara Gajapati and PT.
Mutiara Sabuk Khatulistiwa. The last company only has a “selective logging concession”
license. With or without the moratorium, large scale forest clearance and plantation
development should not happen.]
C. Six companies, publicly identified by SMG/APP as “independent” suppliers39, owned atotal mapped area of 175,493 ha. APP called these concessions “full HTI”, implying they
already completed natural forest clearance operation and are only operating inestablished plantation areas. [PT. Bina Daya Bentala, PT. Bukit Batu Hutani Alam, PT.
Mitra Hutani Jaya, PT. Perawang Sukses Perkasa Industri, PT. Rimba Mandau Lestari and
PT. Sakato Pratama Makmur.]D. Four companies, for which SMG/APP provides no association information but which had
been identified by Eyes on the Forest investigators as wood suppliers to APP, owned atotal mapped area of 60,154 ha. [This category includes PT. Artelindo Wiratama who has
been clearing Sumatran tiger forest in Bukit Tigapuluh for years to supply MTH to APP40,
41, PT. Dexter Timber Perkasa Indonesia who self-declares as “Sinar Mas Group”42, PT.
Putra Riau Perkasa which APP declared as “Kampar Carbon Reserve43” and PT. Inhil
Hutani Pratama who was identified as APP supplier by the Riau Provincial police44.]
The above companies were not the only suppliers of MTH to SMG/APP’s PT. Indah Kiat Pulp &Paper (IKPP) mill in Riau in the past. MTH supplies from “unrecognized suppliers” without
industrial timber plantation concessions (HTI) have been significant. EoF estimates that IKPP
alone pulped about 1.4 million ha of forest by 201045, much more than the total concession
area of the “recognized and identified HTI suppliers” in Riau above. That included supplies
from clearing natural forests for oil palm plantation development, infrastructure or othernon-forestry activities. Origin, legality and environmental impact of these supplies have beenmuch more difficult to identify, trace and ultimately control46, 47, 48.

5 | EoF (April 2013) Where are the trees?

2. Status Quo: Deforestation of SMG/APP suppliers’ concession blocks
Details of this analysis are available online at http://maps.eyesontheforest.or.id(“Concession deforestation” layers). In summary, in Riau Province, SMG/APP suppliers lost a
total of 683,281 ha of natural forest in their concessions since the company began pulping in
1984. EoF analyzed which of the often overlapping categories contributed to how much of thetotal forest loss:
•

•
•
•

•

•

569,920 ha (83%) were lost inside the ranges of Sumatran tigers and elephants (Map 1,“Concession deforestation: wildlife ranges” at http://maps.eyesontheforest.or.id).
Historical data on elephant ranges since 1985 show declines in herd and range size in the
Senepis, Libo, Giam Siak Kecil and Bukit Tigapuluh areas where APP suppliers have beenclearing natural forest (Map 2)49. Human and tiger conflicts, likely due to the loss of forest
habitat, have been rampant resulting in the loss of lives on both sides50.
17,254 ha (3%) were lost in HCVF blocks which APP promised to protect in 2004.
1,714 ha (0.3%) were lost inside “Senepis Tiger Sanctuary”.
170,382 ha (25%) were lost inside UNESCO Giam Siak Kecil-Bukit Batu Biosphere
Reserve, 3,255 ha in the core area, 7,081 ha in the transition area and the rest in thebuffer zone.
525,722 ha (77%) were lost on peat soil (Map 3, “Concession deforestation: peat soils” at
http://maps.eyesontheforest.or.id). These deforested peat soil continues to emit
greenhouse gas every day, especially under pulpwood plantation management.
525,856 ha (77%) were lost in three legally questionable ways, which overlap in part:o 301,084 ha (44%) were lost on peat soil 2-4 and >4m deep even though clearing offorest on peat >3m deep has historically been legally highly controversial (Map 3,“Concession deforestation: peat soils” at http://maps.eyesontheforest.or.id).
o 247,401 ha (36%) were forests lost even though they were legally protected by the
TGHK spatial plan as HSA-W, HL and/or HPT zones (Map 4, “Concession deforestation:
land use plan” at http://maps.eyesontheforest.or.id).
o 27,496 ha (4%) were lost bringing the respective concession blocks’ forest cover
below the legally required 10% forest cover limit51.

SMG/APP has a long history of broken promises about the year it would exclusively rely onplantation fiber: APP has been pulping natural forest fiber until today, long beyond the 200452,
200753 and 200954 target years it had promised (Figure 1).

871,915 ha in 1985
(94% of the total
concession area)
683,281 ha

188,634 ha in 2012(20% of the total
concession area)
after the loss of
683,281 ha (78%)

Figure 1.—Decline of natural forest cover inside APP suppliers’ concessions after APP started
to produce pulp in 1984.

6 | EoF (April 2013) Where are the trees?

Our analysis shows that the annual average speed of forest loss in suppliers’ concessions did
not decline significantly between 1995 and 2011. The exception is between 2007 and 2009,
when a province-wide police investigation into alleged illegal logging by the pulp & paperindustry, including SMG/APP suppliers, caused a quasi-moratorium of forest clearance in
Riau55, 56. After high forest losses until 2011, forest loss dramatically slowed from 2011 to
the same rate as during the moratorium. Finding that most of the forest remaining in 2012
was protected by law or by APP’s previous commitments (next chapter), EoF concludes that
APP’s suppliers in Riau had exhausted the natural forest available to them before the FCP
announcement.
Greenomics analyzed official data by the Ministry of Forestry on the volume of natural forest
wood supplies to APP mills up to 2013. The company’s so-called group B suppliers in Riau,
Jambi and South Sumatra falling under APP’s 1 February 2013 clearance moratorium all had
exhausted their natural forest before the policy announcement57. Greenomics concluded “Itwould appear that commitment to the New APP Forest Conservation Policy was delayed until
the clearance of natural forest and forest peatland for the development of pulpwood
plantations had been completed.”

Map 1.—Forest lost and forest remaining inside the ranges of Sumatran tigers and elephantsoverlapping with SMG/APP suppliers’ concessions.

7 | EoF (April 2013) Where are the trees?

Senepis
Giam Siak Kecil
Libo

Bukit
Tigapuluh

Map 2.—Elephant ranges in Riau between 1985 and 2007 from WWF Indonesia (2008).

Map 3.—Forest lost and forest remaining on top of peat of various depths inside SMG/APP
suppliers’ concessions.

8 | EoF (April 2013) Where are the trees?

Map 4.—Forest lost and forest remaining inside zones of government’s TGHK spatial planthat protect natural forest from clearing, overlapping with SMG/APP suppliers’ concessions.

3. Status Quo: Forest remaining in SMG/APP suppliers’ concession blocks
Details of this analysis are available online at http://maps.eyesontheforest.or.id(“Concession deforestation” layers). In summary, SMG/APP suppliers’ concessions had atotal of 188,634 hectares of natural forest remaining, with an average forest cover of 20%.
Only 6,673 hectares of the 188,634 hectares could still be cleared because they are notprotected by law or previous commitments made by the company (Figure 2, Map 5, Appendix
1).
The rest, 97% of the forest remaining in 2012, should not be cleared because of legal
protection (89%) and corporate conservation commitments (8%). Several of these
protection categories apply for the same forest block. The summary below lists how muchforest falls into each category:
•

•

•
•

42,934 ha (23%) should not be cleared because they are zoned for protection (HSA-W
and HL) and for selective logging (HPT) by government’s TGHK spatial plan (Map 4,“Concession deforestation: land use plan” at http://maps.eyesontheforest.or.id).
140,721 ha (75%) should not be cleared because they are on peat 2-4 and >4m deep
(legal limit >3m depth) (Map 3, “Concession deforestation: peat soils” at
http://maps.eyesontheforest.or.id).
65,424 ha (35%) should not be cleared because they are protected by the 10% minimum
forest cover limit.
107,308 ha (48%) should not be cleared because they had been protected by earlier
company commitments.

EoF so far has only analyzed satellite images taken many months before 1 February 2013,
9 | EoF (April 2013) Where are the trees?

the date for which SMG/APP issued its moratorium. However, one spot check of satellite
images in 2013 revealed that, by the onset of SMG/APP’s moratorium, SMG/APP supplier PT.
Suntara Gajapati had already cleared the 1,502 hectares of forest it could clear without
infringing legal issues and previous corporate conservation commitments58. In conclusion, at
most 5,171 hectares remain in SMG/APP’s Riau concessions that benefit from the company’s
new FCP. These forests are small, scattered fragments in several concessions, possibly too
small to make a meaningful contribution to ecosystem conservation or even to survive(Appendix 1). They are also so small that they are difficult to show in Map 5.

Update: 1,502 hacleared since2012. FCP protects
at most 5,171 ha.

Figure 2.—Percentage of forest lost and remaining in SMG/APP suppliers’ concessions in
Riau, Sumatra. Any given block of lost and remaining forest may fall into several of the listed
categories but here is only listed once to avoid double counting. For example a forest clearedin violation of an APP commitment on deep peat inside a zone protected by the TGHK spatialplan is only listed as forest lost in the TGHK category.

10 | EoF (April 2013) Where are the trees?

Map 5. Forest remaining in SMG/APP suppliers’ concessions that is legally protected,
protected by previous company commitments, or available for clearance.

Photo 1.—Mixed Tropical Hardwood cleared before the 1 February 2013 moratorium in PT.
Ruas Utama Jaya in APP’s self-declared “Senepis Tiger Sanctuary”, waiting to be transported
to APP’s pulp mill. Photo taken by Eyes on the Forest at 1o51'35.48"N, 101o3'14.39"E on 14
January 2013.

11 | EoF (April 2013) Where are the trees?

Conclusions
EoF’s analysis finds that







89% of the natural forest remaining in 2012 inside SMG/APP suppliers’ 929,204 hectares
Riau concession empire was already protected by law and an extra 8% protected by
APP’s previous conservation commitments. The FCP protects an additional 5,171
hectares at most.
77% of the natural forest lost between 1985 and 2012 inside SMG/APP suppliers’
concessions occurred in legally questionable ways as these forests had been protectedby the TGHK spatial plan, the >3m peat depth limit, and/or the 10% minimum
concession forest cover limit.
83% of the natural forest lost between 1985 and 2012 inside SMG/APP suppliers’
concessions had been habitats of Critically Endangered Sumatran elephants and tigers.
77% of the natural forest lost between 1985 and 2012 inside SMG/APP suppliers’
concessions occurred on peat soil, which continue to cause carbon emissions from being
drained to maintain and harvest acacia plantations.

EoF’s analysis showed that the policy was announced only after APP suppliers had exhausted
the forests they could clear, and without committing to the restoration of “protected yet lost”
forests, forests in habitat of critically endangered species, or the rehabilitation of peat soils.
SMG/APP commissioned its much advertised High Conservation Value assessments forconcessions which had already completed their planned deforestation and in which almost all
remaining forest was already protected. Without restoration commitment, theseassessments carry little if any value.
A recent study by Greenomics concluded that APP released its FCP only after their suppliers
had run out of forests to clear also in other provinces in Sumatra. The same may be true forareas controlled by SMG/APP suppliers in Kalimantan. But potential benefits of the FCP for
Kalimantan concessions have not yet been independently evaluated. A lack of detailed
company data has delayed such an analysis.
Lack of transparency also is hindering truly independent monitoring of the current FCP’s
implementation. SMG/APP announced an internal monitoring program on theimplementation of its FCP and wrote “APP will welcome independent 3rd party observers toverify the implementation”59. Yet, so far the monitoring is conducted only internally without
independent CSOs’ participation as there is not yet an agreed protocol for “independent
observation” to provide CSOs the unconditional access and data necessary to implement atruly independent monitoring program60.
The policy also lacks another essential commitment. It continues to allow MTH to bedelivered to SMG/APP mills indefinitely, creating a loophole that suppliers used to “very open
mill gates” may try to exploit. As this analysis and many previous EoF investigative reports
have shown, SMG/APP suppliers have delivered very large volumes of MTH from legallyquestionable clearance and potential high conservation value forests to the company’s pulp
mills for many years. There may be suppliers who try to deliver MTH from new deforestationsites instead of only FCP-allowed MTH supplies, such as those cut before 1 February 2013 orcleared “from land which is not forest, such as scrub land61”, non High Conservation Value(HCV) and non High Carbon Stock (HCS). “Business as usual” may prevail. CSOs in West
Kalimantan recently found canal building and logging activities in the concessions of APP
suppliers under moratorium62.
The fact that SMG/APP announced its policy only after their suppliers finished their planned
deforestation in Sumatra, continues to accept tropical forest fiber, and has not committed to
repair the damage the company’s long history of clearance of Indonesia’s forests has caused,
12 | EoF (April 2013) Where are the trees?

indicates that the company has no interest in conserving the country’s natural resources.

Eyes on the Forest Recommendations for SMG/APP
Addressing the issues outlined in this report could make SMG/APP’s new FCP truly thebreakthrough forest and peat conservation Indonesia needs so badly. For that the company
would need to:
1. Restore selected peatlands and forests lost in protected (according to TGHK, >3m peat,
10% forest minimum), High Carbon Stock and High Conservation Value areas insuppliers’ concessions.
2. Stop accepting all tropical forest fiber at all mills by 5 May 2013, the date of the firstquarterly report on the new FCP to close all potential loopholes for abuse and make themonitoring of full implementation of the new FCP straightforward and without doubt.
3. Mitigate the damage infrastructure like roads and canals cause to surrounding naturalforests and wildlife.
4. Provide detailed information on all existing and past suppliers’ concessions including
information on concession boundaries, land cover, High Conservation Value (HCV) andHigh Carbon Stock (HCS) areas identified by SMG/APP contractors, and provide civilsociety with access to all concessions and facilities to allow truly independent
stakeholder monitoring of the FCP.
5. Provide information on new concession areas and mill expansion plans in Indonesia toallow CSOs to independently evaluate future conservation benefits of the FCP.

Eyes on the Forest recommendation to APP buyers and other business
partners
Do not buy SMG/APP’s products until truly independent monitoring by EoF has confirmed thatthe company• has committed to restore selected forests and rehabilitate peat soils it cleared ordamaged in the past in HCV, HCS and protected areas in its concession,• has stopped accepting tropical forest wood at all mills,• has provided CSOs with all the data necessary for truly independent monitoring, and• has demonstrated a proven track record of successful implementation of the above andits improved forest conservation policy for a period of time.

END
For further information, please contact:
Eyes on the Forest Editor
Email: editor(at)eyesontheforest.or.id

13 | EoF (April 2013) Where are the trees?

ID

Group

Appendix 1. SMG/APP suppliers in Riau Province, Sumatra

Relationshipto SMG/APP

GIS area
Company nameNatural forest
remaining in
mid 2012

Small natural forest blocks
remaining in 2012 whichmight benefit from FCP.
(% total
forest)

(ha)

(ha)

(%)

(ha)

PT. Arara Abadi - Beringin
PT. Arara Abadi - Minas
PT. Arara Abadi - Minas
PT. Arara Abadi - Pelalawan
PT. Arara Abadi - Sedinginan
PT. Arara Abadi - Sedinginan
PT. Arara Abadi - Minas
PT. Arara Abadi - Pelalawan
PT. Arara Abadi - Pelalawan
PT. Arara Abadi - Duri
PT. Arara Abadi - Beringin
PT. Arara Abadi - Nilo
PT. Arara Abadi - Duri
PT. Arara Abadi - Pulau Muda
PT. Arara Abadi - Siak
PT. Riau Abadi Lestari
PT. Riau Abadi Lestari
PT. Riau Abadi Lestari
PT. Satria Perkasa Agung
PT. Satria Perkasa Agung - ex. HPHTI PT.
Intipalma

9,542
8,655
3,552
848
7,192
3,623
14,77923,52428,99357,81815,857
26,43988,88528,21844,963
6,259
4,139
5,434
13,475

0
0
0
7
47
94
131
688
960
1,659
1,785
2,510
3,766
6,654
7,195
0
0
0
730

0%
0%
0%
1%
1%
3%
1%
3%
3%
3%
11%
9%
4%
24%
16%
0%
0%
0%
5%

0
0
0
0
0
0
0
0
0
0
3
0
0
230
1,519
0
0
0
0

0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
3%
21%
0%

33,841

816

2%

0

0%

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19

A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A

"Own"
"Own"
"Own"
"Own"
"Own"
"Own"
"Own"
"Own"
"Own"
"Own"
"Own"
"Own"
"Own"
"Own"
"Own"
"Own"
"Own"
"Own"
"Own"

20

A

"Own"

21

A

"Own"

PT. Satria Perkasa Agung - Serapung

11,867

2,900

24%

21

1%

22

A

"Own"

PT. Satria Perkasa Agung & KTH. Sinar
Merawang - Pulau Muda

9,885

3,193

32%

0

0%

23

A

"Own"

PT. Satria Perkasa Agung - Pulau Muda

40,581

14,229

35%

54

0%

24

A

"Own"

PT. Satria Perkasa Agung

21,197

21,197

100%

0

0%

25

B

"Independent"

PT. Balai Kayang Mandiri

6,031

235

4%

0

0%

26

B

"Independent"

PT. Balai Kayang Mandiri

8,829

4,313

49%

0

0%

27

B

"Independent"

PT. Balai Kayang Mandiri

6,352

6,352

100%

311

5%

28

B

"Independent"

PT. Bina Duta Laksana

29,200

8,253

28%

213

3%

29

B

"Independent"

PT. Mutiara Sabuk Khatulistiwa

44,31425,694

58%

327

1%

30

B

"Independent"

PT. Riau Indo Agropalma

9,704

2,842

29%

1,104

39%

31

B

"Independent"

PT. Ruas Utama Jaya

16,161

743

5%

0

0%

32

B

"Independent"

PT. Ruas Utama Jaya

28,612

5,835

20%

697

12%

33

B

"Independent"

PT. Suntara Gajapati

34,7908,970

26%1,502*

17%

34

C"Independent"

PT. Bina Daya Bentala

20,386

1,849

9%

0

0%

35

C

"Independent"

PT. Bukit Batu Hutani Alam

33,057

6,200

19%

0

0%

14 | EoF (April 2013) Where are the trees?

36

C"Independent"

PT. Mitra Hutani Jaya

9,672

2,283

24%

396

17%

37
38
39
40

C
C
C
C

"Independent""Independent""Independent""Independent"

PT. Perawang Sukses Perkasa Industri
PT. Perawang Sukses Perkasa Industri
PT. Perawang Sukses Perkasa Industri
PT. Perawang Sukses Perkasa Industri

6,848
7,520
23,08424,540

531
0
40
2,924

8%
0%
0%
12%

0
0
0
296

0%
0%
10%

41

C

"Independent"

PT. Rimba Mandau Lestari

5,604

261

5%

0

0%

42

C

"Independent"

PT. Sakato Pratama Makmur

21,895

4,414

20%

0

0%

43

C

"Independent"

PT. Sakato Pratama Makmur

22,888

10,071

44%

0

0%

44

D

"Independent"

PT. Artelindo Wiratama

10,232

2,076

20%

0

0%

45
46

D
D

"Independent""Independent"

PT. Dexter Timber Perkasa Indonesia
PT. Inhil Hutani Pratama

21,767
11,561

8,738
856

40%
7%

0
0

0%
0%

47

D

"Independent"

PT. Putra Riau Perkasa

16,594

16,594

100%

0

0%

929,204

188,635

20%

6,672

3.5%

Total area

* This forest block no longer exists. PT Suntara Gajapati cleared it before the moratorium deadline of 1 February 2013.

15 | EoF (April 2013) Where are the trees?

References
1

Asia Pulp & Paper (5 February 2013) Asia Pulp & Paper Group (APP) Commits to an Immediate Halt to All Natural Forest
Clearance.
http://www.rainforestrealities.com/newsroom/press-releases/app-commits-to-an-immediate-halt-to-all-natural-forestclearance/
2

EoF (14 December 2011) The truth behind APP's greenwash.
http://eyesontheforest.or.id/attach/EoF%20%2814Dec11%29%20The%20truth%20behind%20APPs%20greenwash%
20HR.pdf
3

Podium discussion at APP announcement of new forest policy, 5 February 2013, Jakarta.

4

Miettinen, J., Hooijer, A., Shi, C., Tollenaar, D., Vernimmen, R., Liew, S.C., Malins, C. & S.E. Page (2012) Extent ofindustrial plantations on Southeast Asian peatlands in 2010 with analysis of historical expansion and future projections.
GCB Bioenergy, 4: 908–918. doi: 10.1111/j.1757-1707.2012.01172.x

5

Hooijer, A., S. Page, Jauhiainen, J., W.A. Lee, X.X. Lu, A. Idris & G. Anshari (2012) Subsidence and carbon loss in drained
tropical peatlands. Biogeosciences, 9, 1053-1071, doi:10.5194/bg-9-1053-2012, 2012.
http://www.biogeosciences-discuss.net/8/9311/2011/bgd-8-9311-2011.pdf
6

http://www.eyesontheforest.or.id/index.php?page=content&cid=57Laumonier, Y., Uryu, Y., Stüwe, M., Budiman, A., Setiabudi, B. & O. Hadian (2010) Eco-floristic sectors and deforestation
threats in Sumatra: identifying new conservation area network priorities for ecosystem-based land use planning.
Biodiversity Conservation 19 (4): 1153-1174. http://www.springerlink.com/content/c77376k574051178/fulltext.pdf
8Laumonier, Y. (1997) The Vegetation and Physiography of Sumatra. Kluwer Academic Publishers.
http://books.google.co.id/books/about/The_vegetation_and_physiography_of_Sumat.html?id=lOclIZ9hyCYC&redir_esc=y Laumonier, Y., Purnajaya, P. and S. Setiabudi (1987). International Map of the Vegetation. “Northern Sumatra”.
1:1.000.000. Institut de la Carte Internationale de la Végétation, Toulouse, France and SEAMEO-BIOTROP, Bogor,
Indonesia. http://eusoils.jrc.ec.europa.eu/esdb_archive/eudasm/asia/images/maps/download/ID2014_3TO.jpg
Laumonier, Y., Purnajaya and Setiabudi (1986) International Map of the Vegetation. “Central Sumatra”. 1:1.000.000.
Institut de la Carte Internationale de la Végétation, Toulouse, France and SEAMEO-BIOTROP, Bogor, Indonesia.
http://eusoils.jrc.ec.europa.eu/esdb_archive/eudasm/asia/images/maps/download/ID2014_2TO.jpg
Laumonier, Y. (1983) International Map of the Vegetation. “Southern Sumatra”. 1:1.000.000. Institut de la Carte
Internationale de la Végétation, Toulouse, France and SEAMEO-BIOTROP, Bogor, Indonesia.
http://eusoils.jrc.ec.europa.eu/esdb_archive/eudasm/asia/images/maps/download/ID2014_1TO.jpg
Laumonier, Y. (1990) Search for phytogeographic provinces in Sumatra. In: Baas, P., Kalkman, K. & R. Geesink (Eds) The
plant diversity of Malaysia. Kluwer Academic Publishers, Dordrecht, pp 193–211. Laumonier et al. (2010). WWF Indonesia(2010) Sumatra’s Forests, their Wildlife and the Climate. Windows in Time: 1985, 1990, 2000 and 2009.
http://awsassets.wwf.or.id/downloads/wwf_indonesia__2010__sumatran_forests_wildlife_climate_report_for_dkn___b
appenas.pdf Natural forest cover map since 2009 also generated with the same methodology.
9

Keputusan Menteri Kehutanan Nomor: 70/Kpts-II/95 Tentang Pengaturan Tata Ruang Hutan Tanaman Industri(http://www.dephut.go.id/files/70_95_ind.pdf) in conjunction with Keputusan Menteri Kehutanan Nomor:
246/Kpts-II/1996 Tentang Perubahan Keputusan Menteri Kehutanan Nomor 70/KPTS-II/1995 Tentang Pengaturan Tata
Ruang Hutan Tanaman Industri (http://www.dephut.go.id/files/246_96.pdf), in conjunction with Peraturan Menteri
Kehutanan Nomor: P.21/Menhut-II/2006 Tentang Perubahan Keputusan Menteri Kehutanan Nomor 246/Kpts-II/1996
Tentang Perubahan Keputusan Menteri Kehutanan Nomor 70/KptsII/1995 Tentang Pengaturan Tata Ruang Hutan
Tanaman Industri (http://www.dephut.go.id/index.php?q=id/node/1948)
10

Blouch, R.A. & Haryanto. (1984) Elephants in Southern Sumatra IUCN/WWF Report No: 3., Project 3033. Bogor.
Mapped in Santiapillai, C. & Jackson, P. 1990. The Asian Elephant: An Action Plan for its Conservation. IUCN, Gland,
Switzerland. Blouch, R. A. & Simbolon, K. (1985) Elephants in Northern Sumatra. IUCN/WWF Report No: 9., Project 3033.
Bogor. Mapped in Santiapillai & Ramono (1990)
11

Wikramanayake, E.D., Dinerstein, E., Robinson, J.G., Karanth, U., Rabinowitz, A., Olson, D., Mathew, T., Hedao, P.,
Conner, M., Hemley, G. and D. Bolze (1998) An Ecology-Based Method for Defining Priorities for Large Mammal
Conservation: The Tiger as Case Study. https://secure.worldwildlife.org/science/pubs/AnEcologyBasedMethod.pdf
12

The IUCN Red List of Threatened Species. http://www.iucnredlist.org/

13

The Consortium for Revision of the HCV Toolkit for Indonesia (2009) Guidelines for the Identification of High
Conservation Values in Indonesia (HCV Toolkit – Indonesia)
http://www.hcvnetwork.org/resources/national-hcv-interpretations/Toolkit%20HCVF%20English%20version_final-26Ja
n10.pdf
14

Laumonier, Y. (1997)16 | EoF (April 2013) Where are the trees?

15

Wahyunto, S. Ritung dan H. Subagjo (2003). Peta Luas Sebaran Lahan Gambut dan Kandungan Karbon di Pulau
Sumatera / Maps of Area of Peatland Distribution and Carbon Content in Sumatera, 1990 – 2002. Wetlands International- Indonesia Programme & Wildlife Habitat Canada (WHC).
http://www.wetlands.or.id/PDF/buku/Atlas%20Sebaran%20Gambut%20Sumatera.pdf
16

Presidential Decree Number 32/1990 on Management of Protected Area, in conjunction with Act of the Republic ofIndonesia No. 5 of 1990 Concerning Conservation of Living Resources and Their Ecosystems(http://faolex.fao.org/docs/pdf/ins3867.pdf), in conjunction with Law (UNDANG-UNDANG REPUBLIK INDONESIA) Nomor
26 Tahun 2007 on Spatial Planning (http://landspatial.bappenas.go.id/peraturan/the_file/UU_No26_2007.pdf), in
conjunction with Government Regulation (PERATURAN PEMERINTAH REPUBLIK INDONESIA) Nomor 26 Tahun 2008 on
National Spatial Planning (http://www.bkprn.org/v2/peraturan/file/PP_26_Tahun_2008.pdf)
17

Wetlands International (2011) Peatlands in Indonesia’s National REDD+ Strategy.
http://www.wetlands.org/LinkClick.aspx?fileticket=9Nesl6BCI1U%3D&tabid=56 See discussion on Presidential Decree
32/1990 in page 26.
18

Surat Keputusan Menteri Kehutanan Nomor: 173/Kpts-II/1986 tanggal 06 Juni 1986 tentang Penunjukan Areal Hutan
di Wilayah Provinsi Dati I Riau Sebagai Kawasan Hutan (Tata Guna Hutan Kesepakatan/TGHK). Map of TGHK (Forest Land
Use Agreement) published by the Ministry of Forestry can be downloaded at:
http://www.dephut.go.id/halaman/Peta%20Tematik/Tghk/TGRIAU.GIF
19Undang-Undang Republic Indonesia Nomor 41 Tahun 1999 tentang Kehutanan Dengan Rahmat Tuhan Yang Maha Esa.
http://www.dephut.go.id/INFORMASI/UNDANG2/uu/41_99.htm Putusan Nomor 45/PUU-IX/2011 Demi Keadilan
Berdasarkan
Kehutanan
Yang
Maha
Esa
Mahkamah
Konstitusi
Republic
Indonesia.
http://www.mahkamahkonstitusi.go.id/index.php?page=download.Putusan&id=1015
20

Rainforest Alliance SmartWood Program (2004) High Conservation Value Forest (HCVF) Assessment Report for: Asia
Pulp & Paper/Sinar Mas Group (Pulau Muda District)
http://eyesontheforest.or.id/attach/SmartWoodHCVFAssReport.PMuda.Final1Oct04.pdf
21

Rainforest Alliance SmartWood Program (2005) High Conservation Value Forest (HCVF) Assessment Report for;
Serapung Unit PT Arara Abadi, Asia Pulp & Paper/Sinar Mas Group. http://eyesontheforest.or.id/attach/HCVFserapung.pdf

22

Rainforest Alliance SmartWood Program (2005) High Conservation Value Forest (HCVF) Assessment Report for; Siak
District PT Arara Abadi, Asia Pulp & Paper/Sinar Mas Group. http://eyesontheforest.or.id/attach/HCVFserapung.pdf
http://eyesontheforest.or.id/attach/Siak.Full.pdf
23

Eyes on the Forest (2012) APP; default on environmental covenant.
http://eyesontheforest.or.id/attach/EoF%20%28Mar12%29%20APP%20default%20on%20environmental%20covenant%20report%20FINALS.pdf
24

Asia Pulp & Paper: Industry preserves globally recognized conservation site.
http://www.rainforestrealities.com/articles/industry-preserves-globally-recognized-conservation-site/ (information as of
9 March 2013)
25

PT. Suntara Gajapati letter, 22 June 2006 and associated documents.
http://www.eyesontheforest.or.id/attach/APPSMG_Sancuarymap_Jun2006_20111216081202.rar
26

EoF (14 December 2011)27

WWF (14 December 2011) Massive APP greenwash campaign is mostly hogwash, finds new report.
http://wwf.panda.org/what_we_do/how_we_work/conservation/forests/forests2/asian_pulp_and_paper/?202809/Mass
ive-APP-greenwash-campaign-is-mostly-hogwash-finds-new-report28

WWF (16 December 2011) Document pulps APP’s tiger sanctuary claims.
http://wwf.panda.org/wwf_news/?202873/Documents-pulp-APPs-tiger-sanctuary-claims
29

Greenomics (December 2011) EoF Report: Fact or Fiction?
http://www.greenomics.org/docs/Report_201112_EoF_Report.pdf
30

Asia Pulp & Paper (3 October 2010) Carbon Conservation and APP Introduce the World's First Pulpwood Plantation to
Carbon Reserve REDD-Plus Initiative.
http://www.businesswire.com/news/home/20101003005120/en/Carbon-Conservation-APPIntroduce-Worl
31

Greenomics (23 November 2010) Pulling the wool over the public's eyes: APP deceives public over "Kampar Carbon
Reserve" project. http://www.greenomics.org/docs/Report_201011_APPdeceivespublicovercarbonproject.pdf

32

EoF (14 December 2011)33

APP says: “First are APP-owned pulpwood plantation concessions. These are pulpwood supplier companies in which APP
has equity stakes. There are six APP-owned pulpwood plantation companies that hold pulpwood plantation concession
licenses in Indonesia. These concessions are located in Sumatra and Kalimantan, covering over one million hectares gross

17 | EoF (April 2013) Where are the trees?

in total. Second is APP independent wood suppliers. These are independent companies that hold pulpwood plantation
concession licenses in Indonesia. APP has no ownership share in these companies. The companies have long-term
contractual agreements to supply APP mills with pulpwood. Currently there are approximately 30 independent companies
supplying pulpwood to APP mills.” in Asia Pulp & Paper (23 May 2012a) High Conservation Values cover more than ‘Natural
Forest’.https://www.rainforestrealities.com/2012/05/23/high-conservation-values-cover-more-than-%E2%80%98natur
al-forest%E2%80%99/.
34

Sinarmas Forestry website, "History" - http://us.sinarmasforestry.com/about_history.asp?menu=135“Mapped area” is the concession area published by the Indonesian Ministry of Forestry’s official GIS concession
information used for this analysis. It is not necessarily the same as the area specified in concession license documents.
36

Greenomics (2012) Why the Indonesian Ministry of Forestry Recommends that Asia Pulp & Paper revise its “APP
Sustainability Roadmap 2020 and beyond”.
http://www.greenomics.org/docs/Report_201210_Greenomics_MOF_Recommendation_to_APP.pdf
37

Eyes on the Forest (26 July 2012) SMG/APP: The Pulping Continues. Sustainability roadmap without teeth does not end
mills’ pulping of Indonesia’s rainforests.
http://eyesontheforest.or.id/attach/EoF%20%2826Jul12%29%20SMG%20APP%20The%20Pulping%20Continues%20F
INAL.pdf
38

SMG/APP Forest Conservation Policy consultation meeting with NGOs in Jakarta, Riau and other provinces during
February and March 2013.
39

SMG/APP Forest Conservation Policy consultation meeting with NGOs in Jakarta, Riau and other provinces during
February and March 2013.
40

KKI Warsi et al. (2008) APP threatens Bukit Tigpauluh Landscape.
http://eyesontheforest.or.id/attach/KKIWARSI%20FZS%20ZSL%20YPKHS%20WWF%20Indonesia%20%288Jan2008%29%20APP%20Threatens%20Bukit%20Tigapuluh%20Landscape.pdf
41

KKI Warsi et al. (2010) Last chance to save Bukit Tigapuluh.
http://eyesontheforest.or.id/attach/Warsi%20FZS%20EoF%20WWF%20%2814Dec2010%29%20Last%20chance%20t
o%20save%20Bukit%20Tigapuluh.pdf
42Facebook page of PT. Dexter Timber Perkasa Indonesia, Sinar Mas Group.
http://www.hs.facebook.com/pages/PTDEXTER-TIMBER-PERKASA-INDONESIA-Sinar-Mas-Group/115670725145119
43

Asia Pulp & Paper (3 October 2010)44

EoF (11 Feb 2009) Police urged to resume logging cases.
http://www.eyesontheforest.or.id/?page=news&action=view&id=213
45

Eyes on the Forest (14 December 2011)46

WWF Indonesia (16 June 2004) Monitoring of Illegal Logging Operations in Riau, Sumatra: Deliveries of Illegally Cut
Wood from Proposed Tesso Nilo National Park to APP's Indah Kiat Pulp and Paper Mill in August 2003 and April 2004.
http://www.savesumatra.org/app/webroot/upload/report/WWF_%2816Jun04%29_Deliveries_o_illegally_cut_wood_fro
m_proposed_TNNP_to_APP.pdf
47

WWF Indonesia (8 June 2004) Legality of Timber Consumed by Asia Pulp and Paper's Mills in Indonesia, January October 2003. http://www.illegal-logging.info/uploads/Legality_of_Timber_WWF_Indonesia.pdf
48

Barr, C. (2000) Profits on Paper: The Political-Economy of Fiber, Finance, and Debt in Indonesia’s Pulp and Paper
Industries. http://siteresources.worldbank.org/INTINDONESIA/FLEG/20171586/Chriss_Bar.pdf
49

WWF-Indonesia (2008) Deforestation, Forest Degradation, Biodiversity Loss and CO2 Emissions in Riau, Sumatra,Indonesia. One Indonesian Province’s Forest and Peat Soil Carbon Loss over a Quarter Century and its Plans for the Future.
http://assets.panda.org/downloads/riau_co2_report__wwf_id_27feb08_en_lr_.pdf
50Eyes on the Forest (10 January 2013) SMG/APP deforestation and deadly human tiger conflict.
http://eyesontheforest.or.id/attach/EoF%20%2810Jan13%29%20SMG%20APP%20deforestation%20and%20deadly%
20human%20tiger%20conflict_FINAL.pdf
51

Keputusan Menteri Kehutanan Nomor: 70/Kpts-II/95 Tentang Pengaturan Tata Ruang Hutan Tanaman Industri(http://www.dephut.go.id/files/70_95_ind.pdf) in conjunction with Keputusan Menteri Kehutanan Nomor:
246/Kpts-II/1996 Tentang Perubahan Keputusan Menteri Kehutanan Nomor 70/KPTS-II/1995 Tentang Pengaturan Tata
Ruang Hutan Tanaman Industri (http://www.dephut.go.id/files/246_96.pdf), in conjunction with Peraturan Menteri
Kehutanan Nomor: P.21/Menhut-II/2006 Tentang Perubahan Keputusan Menteri Kehutanan Nomor 246/Kpts-II/1996
Tentang Perubahan Keputusan Menteri Kehutanan Nomor 70/KptsII/1995 Tentang Pengaturan Tata Ruang Hutan
Tanaman Industri (http://www.dephut.go.id/index.php?q=id/node/1948).

18 | EoF (April 2013) Where are the trees?

52

Barr, C. (2000) Profits on Paper: The Political Economy of Fiber, Finance, and Debt in Indonesia's Pulp and Paper
Industries. CIFOR. http://siteresources.worldbank.org/INTINDONESIA/FLEG/20171586/Chriss_Bar.pdf
53

Asia Pulp & Paper (2004) APP Sustainability Action Plan.

54

Asia Pulp & Paper (May 2007) APP 2005/06 Environment Report.
http://www.asiapulppaper.com/portal/APP_Portal.nsf/Web-MenuPage/1B2BBDDE7FB9B64C4725739B00232E6A/$FILE/SR1.PDF
55

The Jakarta Globe (16 May 2011a) Special Report: How a $115b Illegal Logging Probe Was Felled.
http://www.thejakartaglobe.com/nvironment/special-report-how-a-115b-illegal-logging-probe-was-felled/441679
56

The Jakarta Globe (16 May 2011b) A Timeline of the Riau Investigation.
www.thejakartaglobe.com/nvironment/a-timeline-of-the-riau-investigation/441823
57

Greenomics (18 March 2013) APP’s artful deception. After pulping its remaining forests, APP positions itself as aconservation leader with new policy.
http://www.greenomics.org/docs/APP%27s_artful_deception_with_new_policy_201303.pdf
58

See also Greenomics (18 March 2013)

59

Asia Pulp & Paper (5 February 2013).

60

SMG/APP Forest Conservation Policy consultation meeting with NGOs in Jakarta, Riau and other provinces during
February and March 2013.
61

Asia Pulp & Paper (5 February 2013).

62

Kalimantan Forest Monitoring NGOs (26 March 2013) Kalimantan Forest Monitoring NGOs: APP suppliers’ continued

natural forest clearance and peat canal development shed doubt on APP’s forest conservation commitment.
http://www.eyesontheforest.or.id/attach/Joint%20Press%20Release_APP%20FCP%20Violation%20in%20West%20Kali
mantan_260313_English_20130326090349.pdf

19 | EoF (April 2013) Where are the trees?