The truth behind APP’s greenwash

Investigative Report
Eyes on the Forest
Published November 2011
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.
More news on Eyes on the Forest, go to: http://www.eyesontheforest.or.id
Email: eof@eyesontheforest.or.id

01. BackgroundIn 1984, the Sinar Mas Group’s Asia Pulp & Paper (SMG/APP), headquartered in Shanghai,
China, started to operate its first pulp mill in Riau Province in Sumatra1. The mill, Indah Kiat
Pulp & Paper, was Indonesia’s first ‘mega pulp mill’ with a 105,000 tons-per-year production
capacity. In 1994, APP opened its second pulp mill, Lontar Papyrus Pulp & Paper Industry, inneighboring Jambi Province. Both mills exclusively pulped mixed tropical hardwood(MTH) from clearance of natural forests. Both mills continued to expand.
That is why since 1999, customers, creditors, scientists, and civil society have been callingon SMG/APP to not use wood from natural forests to produce its pulp and paper2, 3, 4, 5, 6, 7
and implement two main policies:
1. Operation according to the Forest Stewardship Council’s “Principle 9. Maintenance of High
Conservation Value Forests (HCVFs) defined as environmental and social values that areconsidered to be of outstanding significance or critical importance8” 1.
2. No expansion of pulp production capacities or building of new pulp mills until sufficient
responsible and sustainable plantations have been established in already-deforested
areas.
SMG/APP has refused to commit to these requests and is continuing to expand its
pulp capacity, to pulp natural tropical forests, and to drain peat soils as documented
in detail by Eyes on the Forest and many other organizations. By 2010, SMG/APP’s total pulp
production capacity in Sumatra had grown to at least 2.7 million tons per year. In addition,
SMG/APP had added an additional 1 million ton per year pulp mill in China in 2005 9 .
SMG/APP does not have a sufficient plantation supply to feed any of its mills, but isplanning to build at least two new pulp mills in Indonesia soon.
While SMG/APP has been operating in Riau and Jambi provinces, the provinces’ andSumatra’s natural forest cover has shrunk to less than 30% of the island’s land mass; theisland’s tigers, elephants and orangutans have come ever closer to extinction throughintensifying human-wildlife conflicts and poaching pressure brought about by theirincreasing loss of natural forest habitat; and more and more deep peatlands have been
drained, emitting the carbon stocks they had stored over thousands of years 10 . With
Sumatra’s accessible natural forest almost finished APP has now begun targeting the naturalforests and peatlands of Kalimantan and Papua.
The devastation caused by the Sinar Mas Group’s paper company has led to intense global
critique by civil society and customers. SMG/APP’s response has been classic, it continued
business as usual but put vast resources into a global green-washing campaign - financed by
the deforestation of Sumatra.
In 2006, SMG/APP published a full page advertisement “APP’s Commitment: Conservation
Beyond Compliance” in the New York and London Times – its first big global PR action –falsely portraying itself as a responsible forest and wildlife protection company. A WWF
Indonesia point by point rebuttal detailed the company’s misstatements11.
Today, five years later, APP continues repeating the same false statements together withsome new twists, all trying to hide the ultimate foundation of the Sinar Mas Group/APP’s
operations: the continuing destruction of natural tropical forest and drainage of peat soils.
APP’s PR effort today is bigger and with more aggressive use of the media than ever before.
APP has recruited a wide variety of publicists, individuals and supposedly independent NGOs
to flack its allegedly green practices, including, Cohn & Wolfe12, Environmental Resource
Management13, Alan Oxley and his World Growth and ITS Global14, 15, 16, Mazars17, Carbon
Conservation18, Patrick Moore and his Greenspirit Strategies19, Bastoni and his Sumatran1

In practice, this is to commission prior to any clearing of natural forest an independent and transparent
assessment with the “HCVF Toolkit for Indonesia1” to identify High Conservation Value Forests, and toprotect and maintain all of them.
1Tiger Conservation Foundation (YPHS)20, the Indonesian Pulp & Paper Association (APKI)21
and Allyn Media22. It runs its commercials globally on CNN, Sky TV and other international
broadcasting channels.
In this report, Eyes on the Forest investigates APP’s PR claims. Has there been any
improvement of SMG/APP’s practices on the ground? Has there been a reduction of thecompany’s impact on the world’s most diverse natural tropical forests,
forest wildlife, and theworld’s climate?
The answer is a straightforward:
orward: No. SMG/APP continues draining deep peat soils andclearing natural forests and its negative impact is increasing with the scale of its
operations.
We hope the report will help governments, companies and consumers understand some ofthe on-the-groundound realities that contradict APP’s
APP s PR messaging, and join the many
responsible companies who have chosen to disengage from SMG/APP to not become a part ofthe problem and contribute to the demise of some of the world’s most diverse natural tropicalforests, the extinction of their wildlife, and the dramatic impact on climate change.
The facts are there, in the open,
open for everybody to see and for everyone to check. Come andvisit Sumatra – and if you decide to go up in one of SMG/APP’s helicopters make sure
sur you are
the one to tell the pilot where to go…

Collection of recent APP advertisements published online, on TV, and as hard copy
in various countries in 2011. Clockwise from top left, “APP“
CARES
www.asiapulppaper.com” trademark registeredregisterin the US in 2010 23 ; APP’s “Letter to
Stakeholders: Getting the Facts Down on Paper”
Paper in 201024; “Open Letter to WWF” posted at
APP’s “Rainforest Realities” website on 9 May 201125; “APP - Reforestation” TV commercial26
aired on TV in countries such as Germany, France,, the Netherlands this year;
year one of APP’s“Letter to Stakeholders”; “Declaration of APP” published on the South China Morning Post on
31 August 2011; and APP advertisement
vertisement published in a newspaper in the Netherlands on 31
March 2011 (the same ad was published in Italy, France, the US, etc.)..

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2. What Customers Should Know about SMG/APP
2.1. SMG/APP continues its large-scale natural forest destruction
unabated
In 2011, SMG/APP pledged to its customers “to source 100 percent of its pulpwood supply
from sustainable plantation stock by the end of 201527, 28”.
With this pledge, the SMG/APP confirmed the undeniable fact that the company continues its
indiscriminate, large scale natural tropical forest clearance in Sumatra. Civil society has been
documenting the many resulting problems, including serious biodiversity loss and vast
greenhousegasemissions,overtheyears,
amongothersat29
http://www.eyesontheForest.or.id .
Eyes on the Forest estimates that by 2010, SMG/APP had caused the loss of two
million hectares of natural forest in Riau and in Jambi. Eyes of the Forest based thisestimate on SMG/APP’s own data30, reports by researchers31 and NGOs (see Appendix 1).

2.2. SMG/APP has repeatedly demonstrated that its “commitments” tosustainability cannot be trusted
In the 1990s, APP’s Indah Kiat mill repeatedly stated that plantations would supply“substantially all” of the mill’s wood requirements by 200432.
After defaulting on its commitment in early 2004, APP advanced its “100% plantation”
deadline to 200733.
After defaulting yet again in 2007, APP further advanced its “100% plantation” deadline to200934.
By 2009, APP once again had broken its promise to its buyers. This year, 2011, the company
once again advanced its “100% plantation” deadline to 201535.
Eyes on the Forest does not believe that SMG/APP will meet its 2015 deadline. The
company will have to continue clearing natural forest because it needs to supply
not only its existing but also the at least two new pulp mills it has been advertising.
SMG/APP does not have a sustainable plantation wood supply for its existing pulp mills due
to historically poor plantation development and too high a reliance on plantations located onpeat soils and in community conflict areas36, 37, 38. Scientists have pointed out that plantation
development on peat is considered highly unsustainable39, 40, 41: the continuing drainage ofthe peat will lead to its collapse after only a few rotations and – if the peat is located near thecoast as in Sumatra - the concessions will flood with seawater. Eyes on the Forest calculates
that 77% (almost 760,000 ha) of all of SMG/APP wood suppliers’ concession areas in Riau
alone are on peat. SMG/APP wood suppliers have many more concessions on peat outside of
Riau. All of them, not too long into the future, will stop supplying wood to the company.
In early 2011, Bisnis Indonesia reported that SMG/APP will develop 500,000 hectares of
pulpwood plantations in Papua and two new pulp mills in South Sumatra and East Kalimantan
with an annual pulp production capacity of 2 million tons each by 201742, 43. Yet, SMG/APP
has not demonstrated the existence of sustainable plantation wood supplies for the new mills.
More and more natural forests will be cut to operate them.

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2.3.

SMG/APP causes devastating loss of biodiversity

Eyes of the Forest analyzed government concession data and EoF’s own remote sensing
analysis and field investigations of almost 1.2 million hectares of SMG/APP associatedconcessions in its mostly Riau study area (Map 1) covering close to 940,000 hectares of HTI (industrial timber plantation) concessions and around45,000 hectares of a HPH selective logging concession that allows clear-cutting (PT.
Mutiara Sabuk Khatulistiwa) in Riau which supplied or may supply MTH to APP’s Indah
Kiat pulp mill; and almost 200,000 hectares of HTI concessions in the Bukit Tigapuluh landscape in Jambi44
which supplied or may supply MTH to APP’s Lontar Papyrus pulp mill.

Map 1. SMG/APP associated concessions, natural forest remaining in 2008/2009 and naturalforest lost since 1995 in the Eyes on the Forest study area.

Between 1995, when SMG/APP wood suppliers started to obtain concession licenses, and2008/2009, the last year for which Eyes on the Forest analyzed these data (Map 2, Appendix
2) 45, SMG/APP wood suppliers caused the destruction of around 320,000 ha and 355,000 ha of critically endangered
and endangered forest types, respectively.
 caused the destruction of around 550,000 ha of tiger, 240,000 ha of elephant and 1,500
ha of orangutan range forests. IUCN lists all three species as critically endangered46.
SMG/APP operations in its known concessions in the study area still threaten
 around 100,000 ha critically endangered and 210,000 ha endangered forest types, and around 320,000 ha tiger, 120,000 ha elephant and 2,000 ha orangutan range forest.
Yet this is only part of the story. APP states that “APP’s pulpwood suppliers manage 2.5
million hectares of gross land47”. That is more than double the area Eyes on the Forest
analyzed for this report. In addition, SMG/APP has been pulping MTH from outside the land
they manage. The impact of this company and it’s destruction of natural tropicalforests is thus much higher than reported here based on a limited study area.

4Map 2. SMG/APP concessions and natural forest loss between the mid-1990s and 2008/2009 shown with area’s distinct sectors of
eco-floristic diversity and their respective extinction risk48 (left) and ranges of Sumatran tigers, elephants and orangutans (right).

5SMG/APP wood suppliers have been clearcutting seven out of the existing eight natural forest
landscapes in Riau province (Map 1 & 2).
Tesso Nilo is the last remaining block of a critically endangered dry lowland forest type,which lost more than 90% of its original coverage on the island since 198549. It has one of theworld’s highest levels of vascular plant diversity50 and is home to Sumatra’s endangered
tigers and elephants and many other species51. SMG/APP has been sourcing tropical timberfrom its own concession and third parties including illegal loggers (in 200352) operating inthis area. Despite the highly threatened status of this natural forest and its wildlife SMG/APP
is continuing to clear even the last available natural forest in their Tesso Nilo concessions,threatening their critically endangered resident tigers53.
Libo includes a critically endangered fresh water swamp and endangered peat swamp forest,
now highly fragmented due to rampant natural forest clearance by SMG/APP, APRIL and oilpalm plantation developers. It is habitat of Sumatran tigers and elephants, both highly
threatened by human-wildlife conflicts54.
Senepis, Giam Siak Kecil, Kampar and Kerumutan are critically endangered fresh water
swamp and endangered peat swamp forest blocks that have been devastated by SMG/APP
peat soil drainage and natural forest clearance55. They are habitat of Sumatran tigers andcontain the CITES protected ramin and other endangered fauna and flora. In 2011, SMG/APP
continued to source MTH from Senepis, Kerumutan and Kampar (see Chapter 3).
Bukit Tigapuluh includes a critically endangered dry lowland forest type which has lostaround 80% of its original cover on the island since 198556. International scientists consider
it one of the world’s top 20 landscapes essential for the survival of the tiger57, and theGovernment of Indonesia considers it a top tiger conservation priority58. The forests arehabitat of two of the largest remaining herds of the Sumatran elephant and of the only
successfully reintroduced population of the Sumatran orangutan. From February to April
2011, motion-triggered cameras set up by the Ministry of Forestry and WWF in a
20,000-hectare forest block in this landscape recorded 12 individual tigers, including two
mothers with at least four cubs59. SMG/APP has been systematically targeting the goodnatural forests of this area for pulp production60, 61, 62. A historical analysis of deforestation
around this “12-Tiger Forest” between 2000 and 7 May 2011 reveals the rapid shrinking ofavailable forest habitat due to natural forest clearance by SMG/APP and their competitor
APRIL. Huge encroachment was caused by SMG/APP’s massive logging highway cut throughthe landscapes’ standing forests (Map 3). Both of which have compressed the area’s tiger
population into the remaining small patches of natural forest (see Chapter 3).

Photos 1 & 2. Two tiger cubs playing with a dry leaf (left) and a mother tiger with two cubs
(right)63.

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Map 3. Deforestation in Bukit Tigapuluh’s “12-Tiger Forest” area between 2000 and 2011 based on Landsat and SPOT satellite images,
shown with concessions of SMG/APP and APRIL and SMG/APP’s logging road.
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2.4. SMG/APP releases huge amounts of carbon into the atmosphereand reports the opposite
Between the mid-1990s and 2008/2009 (Map 4), SMG/APP wood suppliers in the study area
 caused destruction of around 370,000 ha of natural tropical forests with rather closed
canopy (canopy closure of 70-100%) and 210,000 ha with medium open canopy(40-70%), together comprising 85% of all forest loss in their concessions (Map 4, left).
 caused destruction of around 80,000 ha and 170,000 ha of natural tropical forests on 2-4
meter deep peat and on more than 4 meter deep peat, respectively, draining peat soils
at least in these areas and maybe more (Map 4, right). Clearance of natural forest on
peat more than 3 meters deep violates several Government regulations (see Chapter 3,
Example 3).
Full product lifecycle carbon emission calculations of SMG/APP products, including emissions
from natural forest loss and peat drainage, found the carbon footprint of APP’s paper
production in Sumatra to be in the range of 16 – 21 tons of CO2e per ton of paper64,
550 – 700 times higher than the 0.03 tons published by APP paid consultant
Environmental Resource Management65 and about 10 times the carbon footprintof the pulp & paper sector in North America66. The study further concluded that the
total emissions of APP’s Indonesian pulp and paper mills and forest concessions
was 67 – 86 million tons of CO2e, ranking the Sinar Mas Group’s APP company
ahead of the 2006 emissions of 165 countries around the world67.
Since 2000, SMG/APP’s wood supply has come mainly from natural forest clearance in peatareas68, such as the Senepis, Libo, Giam Siak Kecil, Kampar and Kerumutan landscapes,
containing very deep peat with more than 5,000 tons per hectare of carbon. The rapid
draining of Riau’s peat lands by the paper industry to enable clearance of their natural forests
causes the peat soil to oxidize and emit the carbon it has stored over thousands of years.
SMG/APP’s draining of Riau’s deep peat and its pulping of Riau’s natural forests are the twomost significant reasons for this province’s position as the number one carbon emitter inIndonesia69.
Sumatra island is the absolute leader in LULUCF (Land Use, Land Use Change and Forestry)
associated CO2 emissions in Indonesia with 1.22 gigatons per year70, of which Riau accounts
for around 60 percent71. Much of the emissions are generated by SMG/APP and its competitor
APRIL’s “Mega Pulp Project” which has steadily and quietly invaded the island’s peat lands,
mainly in Riau but also in other provinces since the 2000s. Already totaling 2.2 million
hectares of concessions today, on much deeper peat, with faster drainage and continuously
expanding, Sumatra’s “Mega Pulp Project” is an ongoing climate disaster, far worse thanCentral Kalimantan’s infamous and long defunct, “ex Mega Rice Project”72.
Between 1990 and 2007, Riau lost more than 4 million hectares of natural forest, 44% on
peat. Riau’s average annual CO2 emissions from natural forest loss and peat drainage were
estimated at 0.22 gigatons, one quarter (24 percent) of the collective annual greenhouse gas
emissions reduction target of all Annex I countries in the Kyoto commitment period of
2008-201273.
Eyes on the Forest74 estimated that SMG/APP and APRIL had up to 800,000 hectares (31%)
of Riau’s last remaining natural forests standing in their concessions in 2008/2009, mostly
on deep peat. If they clear these forests and drain their carbon-rich peat soils to develop
pulpwood plantations, they might increase Riau’s annual emissions by 15 percent (comparedwith historical levels75) to almost 0.5 gigatons/year76 - at a time when President Yudhoyono
has pledged to reduce Indonesia’s emissions by 26 percent (0.75 gigatons) and the National
Strategy for REDD+ targets 0.4 gigatons reduction from the whole forestry sector77.

8

Map 4. SMG/APP wood suppliers’ concessions and natural forest loss between mid-1990s and 2008/2009, in relation to canopy density78(left) and soil type – non peat soil or peat soil of different depth79.
9

3. APP cares?
APP’s rosy advertisements, press releases and blogs are flooding the global market place.
APP tells you:
 “We at APP take our responsibilities as overseers of the environment very seriously80”.
 “APP has always adopted as its mission to maintain sustainability in its operation81”.
 “APP cares82”.
As this PR campaign is being rolled out across the globe, SMG/APP has been busy
establishing strong marketing networks in many countries and new markets. The company ispreparing to flood the world with ever more climate-changing deforestation products.
What does APP really care about? Keep pulping as much natural forest as possible and haveas many customers as possible pay for it through their fake conservation commitments,
advertisements and partnerships.
WWF-Indonesia83, the Forest Stewardship Council84, the Rainforest Alliance85, and many
former customers stopped their businesses with APP when they concluded that constructive
engagement of APP to save natural forest is impossible and that any continuing engagement
would provide the company with an excuse to continue pulping Indonesia forests anddestroying its peatlands (Box 1).

Box 1. Companies who have cut off business ties with APP.
Increasing numbers of corporate customers have concluded that SMG/APP’s
environmentally destructive practices, especially the deforestation it causes, areincompatible with their own corporate values and have made public commitments tocease business ties with APP: Office Depot86, Staples87,Kraft88, United Stationers89,
Target90, Mattel91 and Hasbro92 (USA); Idisa Papel (Spain)93; Metro Group94, KiK95,
Adidas 96 , Montblanc 97 and Tchibo 98 (Germany); Woolworths 99 , Coles 100 andMetcash 101 (Australia); The Warehouse 102 (New Zealand); Robert Horne Group 103 ,Tesco 104 , Sainsbury 105 and Marks & Spencer 106 (UK); Nestlé 107 (Switzerland);
Unilever 108 (Netherlands); Ricoh and Fuji Xerox 109 (Japan); Zhejiang Hotels
Association 110 (China); Gucci Group 111 , Cartamundi 112 (Italy); Lego 113 (Denmark);
Leclerc114 (France). Carrefour115 (France) has recently confirmed that they will stopbuying paper from APP for their own brand products.

Until SMG/APP’s owners not only commit, but have proven through independent verification
by civil society groups, that they have stopped all clearing of natural forest within their entire
range of operations, Eyes on the Forest recommends consumers to never believe thegreenwashing of SMG/APP and their marketing partners who are simply trying to befog andconfuse with simple tactics:
1. They exploit your credulity, lack of knowledge or inexperience on Indonesia to mislead
you to think that the issues raised by civil society are untrue.
2. They highlight irrelevant commitments, achievements, efforts and merits to switch
your attention from the crucial information which would influence your purchasing
decision: that SMG/APP continues to cause indiscriminate and large scale peat
clearance and natural forest clearance in Sumatra and is now beginning to do thesame in Borneo and Papua.
On 28 October 2011, the Dutch Advertising Code Commission ruled that APP’s TV and paper
adverts that attempt to position APP as a company that cares about the environment are
misleading the public116. They are shown in the Background Chapter above.

10

Example 1. APP misleads you to think that they are a tiger protection company.
APP writes:“we support programs for the preservation of the 106,000 hectares Senepis tiger reserve,
the 10,000 hectares Taman Raja park, the 172,000 hectares Giam Siak Kecil reserve,
recognized by UNESCO Man and Biosphere Programme, and the Kutai orangutan
program.117”“You only saved one tiger, people told me. It’s not true. Since I joined this company in2004, we have succeeded to secure several Sumatran Tiger conservation habitats. Firstwas the Senepis tiger sanctuary in Dumai, Riau. Second was the UNESCO approved Giam
Siak Kecil Biosphere Reserve. Third was the Taman Raja Nature Reserve in Jambi. Fourth
was the Kampar conservation area. Next? You just need to wait and see.118”
Fact is:Most of the project areas they claim to protect had already been protected by law
or managed by somebody else, therefore SMG/APP adds no additional
conservation benefit for tiger. APP has pulped more tiger habitat EVERY year
than the combined acreage of its actual, legally-required set-asides in theseconcessions. Their wood suppliers have cleared much of the forest of theoriginally government proposed Senepis National Park for tiger conservation,
have begun clearing even the tiny forest block SMG/APP committed to protect
inside its own proposed “Senepis Tiger Sanctuary”, and have drained andclearcut peatland forest inside the UNESCO Reserve.

For years, APP has been highlighting the same “projects” to divert attention from its
large-scale tiger forest destruction in Sumatra, in the landscapes in which these “projects”
are located and even in the “project” areas themselves.
NGOs have shown that SMG/APP does not care about tigers and the “projects” they
advertise.
 APP’s real contribution to the “projects” and the value of the “projects” themselves forconservation are seriously questionable since most of these areas are either alreadylegally protected or managed by other companies.
 SMG/APP wood suppliers have been clearing so much natural forest in Senepis, Giam Siak
Kecil, Kampar and Bukit Tigapuluh (where Taman Raja is located) that it threatens theviability of these entire ecosystems and their biodiversity, as well as their own projects
inside them and tigers they claim to protect.
In Riau and Jambi, Government-required macro/micro-delineation documents and work
plans of 31 wood suppliers of APP and APRIL covering 1.52 million hectares showed that only
50,709 hectares were zoned as government-required “Wildlife Protection Zones”, and of that
forest, only 3,850 hectares were designated by APP specifically for tiger conservation in
Senepis 119 . In contrast, our study found that SMG/APP wood suppliers have destroyed
550,000 hectares of tiger forests between 1995 and 2008/2009 in our study area only andlikely caused more tiger forest loss outside these areas.
SMG/APP promotes tiger translocations as one of its conservation achievements120 121. In
reality, APP does nothing more than financing of the removal of tigers after the company’s
destruction of their habitat has pushed them into conflict with people, none of which would
have happened if the company had conserved these tiger forests122.
In Senepis (Map 5), SMG/APP has been sourcing natural forest wood from five11

concessions123. In 2004, Riau’s Forestry Agency supported by Riau’s Governor proposed a
National Park for tiger conservation in Senepis that included a concession of SMG/APP’s wood
supplier PT. Suntara Gajapati (SG) 124 . A WWF 125 investigation revealed how SMG/APP
appears to have prevented tiger habitat from being protected in the proposed Senepis
National Park. The national park concept suddenly disappeared. Instead, APP began
advertising its own alternate 106,081-hectare “Senepis Tiger Sanctuary”126. Mysteriously,
the area to be protected had largely moved out of the PT. Suntara Gajapati concession into
the concession of an unrelated company, PT. Diamond Raya Timber, whose FSC-certified
operations already fully protected this tiger forest. In 2011, a Greenomics127 investigation
showed that the government-required macro/micro delineation and work plan of SMG/APP’s
PT. Suntara Gajapati had actually only allocated 3,850 hectares, less than 4%, to APP’s tiger
sanctuary. Rather than contributing to tiger habitat protection by having its SG concession
declared a tiger national park, APP’s wood suppliers systematically eradicated the Senepis
tiger habitat in SG and another supplier PT. Ruas Utama Jaya (RUJ) concessions by clearing
natural forest on contiguous deep peat of more than 4 meters. By June 2011, RUJ had
even begun clearing the tiny block of natural forest (less than 5,000 ha) APP had
set aside for its own “Senepis Tiger Sanctuary” (Map 5 and Photos 3-5).

Map 5. APP’s self-declared Senepis tiger sanctuary and SMG/APP history of clearing naturalforest on deep peat.

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Photos 3-5. Peat draining and large-scale clearance of natural forest by APP wood supplier
PT. Ruas Utama Jaya inside APP’s Senepis Tiger Sanctuary in June and October 2011. Arrows
next to photo numbers in map (top right) indicate directions photos were taken.

13In 2009, Eyes on the Forest reported that most violent incidents between people and tigers
in Riau Province since 1997 had occurred near forested areas being cleared by SMG/APP. The
analysis, based on published human-tiger conflict data, found that at least 147 of 245 or
60% of all conflicts in Riau, resulting in 27 human deaths (49%) and 8 tiger deaths (53%),
occurred in the Senepis area alone128. But not only tigers suffered from SMG/APP’s relentlessdestruction of their habitat. All of SMG/APP’s forest clearance was preceded by draining of
the peat these forests stood on, putting the viability and sustainability of this entire peat
ecosystem in question and releasing vast amounts of greenhouse gas emissions.
Bukit Tigapuluh – KKI Warsi, Eyes on the Forest and other local NGOs working in thislandscape showed how SMG/APP has been systematically targeting the good natural forestsof this Global Priority Tiger Conservation Landscape129, 130, 131, 132 and estimated that APP
has caused the loss of more than 75,000 hectares of its natural forest since 2004133. In 2009,
APP announced its “Taman Raja Nature Reserve” covering less than 7,000 hectares offorest134. NGOs showed that most of the forest in the “Taman Raja Nature Reserve” could nothave been cleared anyway according to Indonesian law135, 136 and that the reserve cannot
function as “wildlife corridor” as APP claims because the company has pulped the naturalforest around most of it.
UNESCO Giam Siak Kecil Biosphere Reserve, which SMG/APP portrays as its “conservation
flagship program 137 ”, had already been protected before APP’s announcement with nopermission to drain its deep peat soils and clear its forests by local land use plan and various
regulations. SMG/APP’s partner companies started to illegally clear natural peatland forest inwhat today is the reserve’s buffer zone before 2000 without proper licenses from the Ministryof Forestry138. Based on extensive on-the-ground investigations and satellite analysis, Eyeson the Forest139 summarized how APP continued to destroy the Giam Siak Kecil ecosystemeven after the UNESCO Biosphere Reserve was declared in 2009, by draining its deep peatsoils and clearing its forests and contributing to huge, ever-increasing carbon emissions in
the process. Some of the forest clearance has been conducted without proper licenses and as
a result of corruption, as evidenced by the local officials who went to jail for issuing illegal
licenses 140 . Greenomics 141 states “the said Biosphere Reserve is nothing more than alandscape in the midst of massive forest clearance by APP’s pulpwood plantation suppliers”.
In Kampar, SMG/APP has drained deep peat soils and cleared natural forest in thislandscape since the late 1990s. In 2010, APP and their partner Carbon Conservation began“selling” their tiny “Kampar Carbon Reserve” project 142 , marketing it also as a tiger
conservation project. Eyes on the Forest and Greenomics reported that the project should
not earn any carbon credits since the area has already been protected by law because of itsvery deep peat soils (no additionality) and that SMG/APP is clearing forest and draining peatin this contiguous ecosystem (huge leakage), emitting large amounts of carbon143.

Example 2. APP misleads you to think that APP does not use wood from naturalforest with High Conservation Values to make its products.
APP writes1:“APP’s fibre suppliers operate pulpwood plantations according to legal concessions grantedby the Government of Indonesia on land identified as being the lowest-value forested
areas in the country, comprised largely of what it categorises as degraded orwasteland.144”“Rather than burn the wood residues which would result in an increase in carbon emissions
or leave the residues on the forest floor potentially risking disease outbreaks in the forests,
1

Underlines in APP quotes are by Eyes on the Forest.
14

the Government requires that they be used productively such as to produce pulp andpaper.145”“Prior to plantation development the land is subjected to several ecological and social
assessments to ensure that any areas of high conservation values are identified andprotected.146”“We monitor closely the supply chain for the pulp and paper production, to ensure no
pulpwood from high conservation value areas (HCV) as defined by the Government ofIndonesia is used in any of APP’s products.”147
Fact is:APP uses wood from clearance of good, dense tropical forest in Sumatra, withHigh Conservation Values as defined by Forest Stewardship Council, such as
critically endangered Sumatran tiger and endangered dry lowland and peatland
forests, and identified by independent assessors based on the multi-stakeholder
endorsed Indonesia HCV Toolkit.

APP never defines what it means by “lowest-value forest areas”, “degraded” or “wasteland”.
The company wants customers to imagine that their wood suppliers are only harvesting what
they call “wood residues” in very open areas with very few trees or with the “wood residues”
already lying on the ground when their wood suppliers arrive there.
In reality, our satellite image and field investigations have consistently shown that SMG/APP
wood suppliers are clearing good, dense natural forests with HCVs (Map 2, 3 and 4)148, 149,
150, 151, 152, 153, 154. Even SMG/APP wood suppliers’ own annual cutting plans (called RKT),
based on company data submitted to Government, show high tree densities with an average
official timber volume of 82 m3/hectare in 2009 (between 31 and 152 m3/ha) and 95 m3/ha
in 2010 (between 31 and 164 m3/ha)155.
To set the record straight: SMG/APP’s so-called “wood residues” were tropicalforests before the company’s wood suppliers flattened them.
What APP does not tell you is that the Indonesian government recognizes only very few areas
as “primary forest” in its official map of Sumatra and most are inside conservation areas andareas with steep slopes. Majority of the natural forest that has once been zoned as a selective
logging concession is called “secondary forest”, “degraded forest” or “logged over forests”
without any strict definition. These are all mostly unprotected dry natural lowland andpeatland forests with often dense canopies where only some large-diameter trees had
selectively been harvested in the past. They are still very rich in biodiversity and carbon156
yet but under the current laws and regulations the Government can issue pulpwood
concession licenses and allow them to be cleared.
To set the record straight: the Government of Indonesia allows the clearing ofdense tropical forests with high biodiversity values for conversion to pulpwood
plantations. To operate sustainably companies have to voluntarily protect High
Conservation Value Forests.
What APP does not tell you is that the company refuses to have its natural forests
independently and transparently assessed using the globally adopted definition of HCVF by
the Forest Stewardship Council through the application of the Indonesia HCV Toolkit. APP
uses the much the same words such as “high conservation value areas (HCV) as defined by
the Government of Indonesia” and application of legally required “ecological and social
assessments”. But these simply mean forest assessments based on government required
called AMDAL and macro-micro delineation whose applications on the ground have failed
time and again to protect High Conservation Value Forests.

15

In 2004, after urging by customers and NGOs, SMG/APP commissioned the Rainforest
Alliance’s SmartWood Program (RA) to identify HCVFs in three of its Forest Management
Units based on the Indonesia HCV Toolkit. When identified, SMG/APP committed to protect
and maintain all the HCVs. Yet, a time series analysis of historical satellite images revealed
that the company has been clearing these independently and transparently identified HCVFs(yellow hatchet outlined areas in Map 6 and 7). All are forests standing on peat soils deeper
than 4 meters, protected by law.
To set the record straight: SMG/APP is not protecting transparently andindependently identified HCVF but has been destroying them to produce its
paper157, 158.

Map 6. Clearance of Rainforest Alliance identified HCVF and other natural forest on deep
peat in Kerumutan.

Map 7. Clearance of Rainforest Alliance identified HCVF and other natural forest on deep
peat in Kampar.
16

Example 3. APP misleads you to think that APP follows all relevant laws andregulations and that ensures them to be sustainable and pro conservation.
APP writes:“APP has always strictly complied with relevant laws and regulations in order to ensure that
all of our pulp and paper products originated from legal and sustainably managed forests.
159”“For the Indonesian pulp and paper industry, sustainable forest management andconservation begins with strictly adhering to government of Indonesia spatial planning andplantation development regulations as well as Sustainable Forestry Management
certification requirements. These standards define requirements for preserving High
Conservation Value Forest, restrictions for development on peatland, and community
engagement in the plantation development process.160”“APP has a policy to embrace all credible certification standards which are relevant to andin support of Indonesia’s policies, law and regulations and we will always strive to meet thehighest standards that are expected by our customers and partners worldwide. We willcontinue to apply standards and principles from other globally recognized certifications,
including international TLTV, ecolabelling and PEFC 161”.
Fact is:Numerous field investigations and analysis indicate that SMG/APP does notcomply with all relevant laws and regulations and that clearance of natural forest
is a legal option in Indonesia which SMG/APP continues to employ.

Legality is a minimum requirement for all customers. Many customers require more thanlegal compliance, for example, insisting on sustainability, conservation and zerodeforestation. Yet even APP’s claim that it has “always strictly complied with relevant laws
and regulations” is not true.
What APP does not tell you is that: Many of SMG/APP’s concessions have violated Government “restrictions for developmenton peatland” by clearing natural forest on deep peat of more than 3 meters 162 , inviolation of Presidential Decree Number 32/1990 on Management of Protected Area, Act
Number 5 of 1990 on Conservation of Living Resources and Their Ecosystems163, Law
Number 26/2007 on Spatial Planning 164 , the currently active national spatial plan
enacted by Government Regulation Number 26/2008 on National Spatial Planning165.
 A 2009 audit report by the Indonesian State Audit Board (BPK-RI) concluded that
SMG/APP wood suppliers cleared natural forest based on pulpwood plantation licenses
and annual cutting licenses issued in violation of regulations166.
 The Government of Indonesia jailed two government officials (Tengku Azmun Jaafar andAsral Rachman) for corruption when issuing licenses to APP’s wood suppliers167, twomore were detained (Arwin A.S and Syuhada Tasman)168 and another one is currently
under investigation by Indonesia’s Corruption Eradication Commission (Burhanudin
Husein)169. With these licenses obtained through corrupt practices, SMG/APP cleared
natural forest to supply its pulp mills and produce the paper it sells around the world170,
171, 172, 173, 174.
 Recent changes in forestry laws and regulations allow clearance of any natural forest, incontradiction of pro-sustainability and pro-conservation laws and regulations such as
those related to peat development and that their suppliers are exploiting thesecontradictions to cut as much natural forest as possible 175 . A truly responsible andsustainable and pro-conservation company would rather respect the aspirations andintentions of these laws and regulations and protect these forests. Under such17

circumstance, legality does not constitute sustainability or conservation.
APP highlights its commitment to legality by implementing the “Timber Legality &Traceability Verification (TLTV)” service developed by SGS and by adopting “Sistem Verifikasi
Legalitas Kayu (SVLK, Indonesia’s national timber legality and verification system)” 176, 177.
However, as “legality” in practice does not guarantee “sustainable forest management” nor“conservation”, APP has no basis to say: “foreign countries importing wood-based products
from Indonesia should have complete confidence that Indonesian products certified under
SVLK guidelines adhere to the highest standards for wood legality and support SFM principles.
These standards should be accepted and considered equal to those legal requirements
created by countries with the intention to protect their own natural forests and mandate
sustainable plantation forestry practices”178.
What APP does not tell you is that the world’s most credible forestry certification standard,
the Forest Stewardship Council (FSC), dissociated itself from Asia Pulp & Paper in 2007. The
FSC Board of Directors stated “The FSC Board of Directors decided that association with APP
would threaten the good will and faith invested in the name Forest Stewardship Council. [...]
There is substantial publicly available information that suggests that APP, a Sinar Mas
subsidiary, is associated with destructive forestry practices. Reports from WWF, Greenpeace,
Eyes on the Forest and many other independent sources suggest that APP is actively
conducting forestry practices contrary to FSC Principles and Criteria.”179
As a result, today, APP has no independent, credible third party certification to demonstrate
their sustainability.
Certification bodies frequently quoted by APP -- the Indonesian Ecolabel Institute (LEI), theProgram for the Endorsement of Forest Certification (PEFC), EU Ecolabel and the Indonesian
government’s Sustainable Production Forest Management (Pengelolaan Hutan Produksi
Lestari/PHPL) standards 180 , 181 -- do not ensure sustainability. Neither of them havestandards comprehensive enough to validate182, 183, 184:
1. whether SMG/APP is/was involved in HCVF and peat destruction in the concessions inquestion, and
2. Whether the overall sustainability, environmental record and the large-scale
environmental and social problems the whole SMG/APP corporate group cause beyond
the few small concessions they certify.

Example 4. APP misleads you to think that APP cares about the world’s climate.
APP writes:“We also must recognize that private industry is equally responsible for using the
moratorium period to assess and advance internal sustainable forestry management
practices and programs.185”“Bottom line is that it’s not enough to just say we support the moratorium. What mattersmost are actions. […] While Asia Pulp & Paper will take action to emerge from themoratorium a healthier business with a clear and definitive vision for the future of oursustainable forestry management, manufacturing, conservation and social investment
programs. 186”
“Much of Indonesia consists of unimproved land. Afforestation is a possibility that makes
wild land into de facto CO2 capture and storage areas. Indonesia is a fantastic place toplant trees. APP pulp suppliers plant more than 200 million trees per year.187”
Fact is:18

APP first destroys millions of old trees of hundreds of different species to plant
young trees of one species and then cuts every planted tree 5-7 years later. Net
out: big emissions - no sequestration. Even more devastating for the climate,
SMG/APP continuously drains very carbon rich peat soils to destroy their forestsand plant its monocultures, releasing millions of tons of carbon into theatmosphere that affect the world’s climate (See also Chapter 2.3.).

The Indonesian moratorium on deforestation is in fact only a moratorium of the issuance of
new licenses in so-called primary forests and peatlands for which no permit has ever been
issued188, 189, 190, 191. This means only very few forests in Sumatra are protected by themoratorium with basically no impact on SMG/APP (Map 8). With very few exceptions, thegroup will continue its destruction of natural forest and draining of peat soils in their existing
concessions. APP can even obtain licenses to cut down natural forests that are still available
and not covered by the moratorium (Map 8).

Map 8. SMG/APP and RGE/APRIL wood supplier concessions and Barito Pacific concessions,natural forest remaining in 2008/2009 and moratorium areas (where new permits would not
be issued during the moratorium) based on the Ministry of Forestry SK. 323/Menhut-II/2011
on 17 June 2011192. No natural forest inside known SMG/APP affiliated concessions in the
study area is protected by the moratorium.

19

In fact, none of the activities APP has been advertising (afforestation, research, etc.) as“responsible for using the moratorium period” includes a stoppage of the drainage of peatsoils, of the clearance of natural forest and of pulping MTH in its mills. Yet these are the most
crucial activities needed for valid REDD efforts to have any meaning in Indonesia at all.
APP has dramatically misled the public to think the company’s operations are carbon neutral.
A contractor, Environmental Resources Management (ERM) in the UK helped APP advertise a“near zero carbon footprint” based on an incomplete set of assumptions that omitted thecompany’s most crucial greenhouse gas releases193, 194.
ERM and APP intentionally ignored the huge emissions caused by SMG/APP’s clearance of
natural forests for its pulp production and, most of all, the vast emissions the company’s
continuing drainage of the peat soils for their plantations cause every year. Instead, mocking
customers, investors and the Government agencies who issued the licenses, APP even added
the carbon sequestration of the very plantations which cause all these huge emissions toimprove its carbon foot print calculation195 (see also Chapter 2.3). Replacing tropical forests
with monocultures in five- to seven- year rotations to produce pulp & paper which are soon
discarded to emit their sequestered carbon is far from any valid definition of what
“afforestation” projects are for climate change mitigation.

20

4. Eyes on the Forest Calls on SMG/APPIn April 2011, APP announced that, in partnership with Carbon Conservation, it is crafting“Vision 2020, a roadmap to guide sustainability principles, goals and program execution
across all aspects of the company's Indonesian operations from today to the year 2020.196”
SMG/APP has invited civil society to contribute. Eyes on the Forest offers this report as its
contribution to the effort with a simple conclusion:
SMG/APP’s Vision 2020 will be executed in landscapes free of forests and full of
collapsed peat domes unless the company immediately stops all deforestation,peat drainage and expansion of pulping capacity without existing sustainably built
plantations.
The announcement of yet another sustainability plan is nothing new for SMG/APP.
Announcements like this have come and gone, designed and disseminated with the simple
objective of keeping its customers and investors happy while giving the company ever moretime to drain peat soils and clear forests.
In 2003, SMG/APP commissioned a “sustainable wood supply assessment & planning” fromtwo consultancy companies 197 , signed a Letter of Intent with WWF 198 , and eventually
produced a “sustainability action plan” in 2004. After reviewing the document, WWF ended
its engagement with SMG/APP. The assumptions were beyond belief, to a point where eventhe consulting firm could not stand by them and APP had to publish its own analysis. It
insisted on having to cut an additional 180,000 hectares of natural forest “to becomesustainable” while failing to commit to protect High Conservation Value Forests 199 . As
predicted, the company never implemented its own plan and has cleared much more than
the announced 180,000 hectares of forest since. And it will continue doing so, because thebrand new self-imposed deadline for MTH-free operations is a convenient four years away.
Can any business partner really afford to take APP’s announcement of a sustainability
contract with “Carbon Conservation” serious?
Eyes on the Forest calls on the Sinar Mas Group’s Asia Pulp & Paper company tostop clearing natural forest in Sumatra, all other Indonesian islands andthroughout the world today and commit to the calls by NGOs listed in Box 1.
Eyes on the Forest calls on customers and other business partners to not trust
SMG/APP’s public relations claims. Sumatra’s forests and species are at the 11th
hour. Responsible paper and pulp purchasers should not contribute to their demise.
Join the growing list of other responsible companies that have stopped sourcing
from APP.

Box 2. Calls to Indonesian pulp and paper companies, endorsed by morethan 400 Indonesian NGOs in 2010 200, 201
1. An immediate halt on all further logging, clearing and conversion of naturalforests across all operations in Indonesia and a halt on all sourcing of mixed
tropical hardwood fiber until areas of High Conservation Value and high carbon
value have been identified and protected, and areas suitable for fiber production
have been agreed upon by government, industry, civil society organizations,and affected indigenous peoples and forest dependent communities.
2. A timebound plan for the restoration of peat lands and key ecological areas
affected by roads, canals, logging, wood transportation and plantations isagreed by government, industry, civil society and affected communities, and is21

being implemented.
3. Negotiated agreements with indigenous communities affected by planned orexisting pulp operations based on the right of indigenous peoples to give or
withhold their free, prior and informed consent to developments that may affecttheir customary territories are established. Negotiated settlements and faircompensation for lands with non indigenous communities must also beestablished. Safeguards for pulpwood plantation and pulp and paper mill
workers’ rights including for example, adequate wages, healthy working
conditions, training, and insurance, are also established.
4. A commitment that any new or expanded pulp and paper mill capacity is totally
mercury-free and chlorine-free.
5. A halt on any additional pulp or paper production capacity or expansion and anaudit of existing fiber production capacity to verify that additional natural forest
fiber (MTH) is not required for existing or expanded operation and is consistent
with the above conditions.
6. The employment of an independent third party, acceptable to independent civilsociety groups in Indonesia, to monitor implementation and continued
adherence to the above conditions and report regularly to the public on its
findings.

END
For further information, please contact:
Eyes on the Forest Editor
Afdhal Mahyuddin
Email: eof@eyesontheforest.or.id

22

Appendix 1. Area estimate of natural forest cleared to supply IKPP and LPPP.
1. Parameters used to calculate size of forest needed for production of known amounts of pulp
Parameter

Value

1. From air dry ton (adt) pulp to green metric ton (gmt) mixed tropical hardwood (MTH, obtained by clearance of natural forest) wood weight (Jaakko Poyry
1998, quoted by Barr 2001)
3
2. From MTH wood weight (gmt) to MTH wood volume (m ) at pulp mill gate (APP 2004)
3. From MTH wood volume at pulp mill gate to MTH standing wood volume in natural forest (taking into account harvest, transport and chipping losses)(AMEC, quoted in APP 2004)
4. Average MTH standing wood volume harvestable per hectare of natural forest (m3/ha) as the average volumes listed in RKT 2009 and 2010 issued to
SMG/APP wood suppliers (Eyes on the Forest July 2010 and November 2010).

4.83
1.142
1.235
89

2. Estimate of deforestation caused by operation of SMG/APP's Indah Kiat Pulp & Paper (IKPP) mill in Riau Province, Sumatra
Comment: Forest clearance for which the IKPP mill was responsible is likely higher than calculated here. We only calculated forest clearance based on data for Riau province, yet
the mill also received fiber from other provinces. None of the data taken from APP publications could be verified and may thus not be correct.
Production[A] Natural[B] Pulp[C] % MTH in [D] Reference and notesYearforest pulped production
mill fiber(ha)capacity or actual
supplyproduction (bold)(ton/year)[A] Forest clearance calculated based on pulp production and MTH content using above parameter values.
1984-1987

32,329105,000

100%[B] Pirard & Cossalter (2006)[C] SMG/APP began operations in 1984 and did not have plantations ready for harvest by 1987.

1988

7,436

105,000

92%

1989-1990

16,996

120,000

92%

1991-1996

174,205

410,000

92%

1997-1998

203,239

1,435,000

92%

1999

104,683

1,700,000

80%[A] Forest clearance calculated based on pulp production and MTH content using above parameter values.
[B] "Since 1989, Indah Kiat has expanded its pulp production capacity from 120,000 tonnes to 1.7 million
tonnes per annum" (PT Indah Kiat 1999, quoted by Barr 2000). "Between 1991 and 1999, the group’s pulp
processing capacity grew from 410,000 tonnes to 2.3 million tonnes per annum" (Ausnewz 1999, quoted byBarr 2000). "the original market pulp line has been modernized, new lines were added in 1989, 1995 and1997" (AMEC 2001) 1997 data was taken from U.S. & Foreign Commercial Service and U.S. Department ofState (1999).
3[C] "Of the 100 million m of wood estimated to have been consumed by the pulp industry during 1988-1999,
only eight percent was harvested from plantations" (Indonesian Pulp and Paper Association 1997 andJaakko Poyry 1998, quoted by Barr 2000) "The acacia wood harvested in 1999 accounted for 20 percent of
the fiber consumed by Indah Kiat that year." (Barr 2000)

2000 - 2004

569,598

1,850,000

80%

2005

89,052

1,866,006

62%

2006

87,351

1,907,282

60%

2007

11,347

1,842,755

8%

2008

-

2,000,000

0%

2009

56,6592010

46,151TOTAL

1,399,044

2,000,000

2,000,000[A] Forest clearance calculated based on pulp production and MTH content using above parameter values.
[B] APP (2004) - not verified company information that may not be correct!
[C] "Asia Pulp & Paper Company Ltd. (APP), the holding company of IKPP recently reported that plantationgrown wood accounted for 20 percent of the overall mill supply in 2003 and 2004 and 35 percent in 2005."(Cossalter 2006) - not verified company information that may not be correct!
[A] Forest clearance calculated based on pulp production and MTH content using above parameter values.
[B] APP (2008). APP (2009) - not verified company information that may not be correct!
[C] For 2005-2007, we used average number of MTH content for each year found in literature. APP (2009)
wrote 59% for 2005, 49% for 2006 and 8% for 2007. Cossalter (2006) wrote 65% in 2005. WWF Indonesia(June 2006) wrote 70% for 2006. The MTH figure given by APP for 2007 is low and we estimate zero
percent for 2008 because APP could only use MTH on its log yard, could not transport MTH, and had to relyon plantation fibre brought in by boat from other provinces during 2007 and 2008 while APP wood suppliers
were being investigated by the police for illegal logging and all MTH transport was prohibited. However,reports exist that many barges with MTH landed at the SMG/APP dock during the police investigation.

37%[A] Government permits allowed SMG/APP wood suppliers to clear 56,659 hectares of natural forest in Riau
(Eyes on the Forest July 2010). Forest clearance this year is likely higher as permits issued for otherprovinces to supply IKPP were not considered.
[B] APP (2008) - not verified company information that may not be correct!
[C] MTH calculated based on forest clearance and pulp production using above parameter values. MTH
content is likely higher because forest clearance is likely higher.

30%[A] Government permits allowed SMG/APP wood suppliers to clear 41,789 hectares of natural forest in Riau
(Eyes on the Forest November 2010). In addition, SMG/APP were allowed to clear 4,362 hectares based on"self approved RKT" in Riau. Forest clearance this year is likely higher as permits issued for otherprovinces were not considered.
[B] APP (2008) - not verified company information that may not be correct!
[C] MTH calculated based on forest clearance and pulp production using above parameter values. MTH
content is likely higher because forest clearance is likely higher.

23

3. Estimate of deforestation caused by operation of SMG/APP's Lontar Papyrus Pulp & Paper pulp mill in Jambi Province, Sumatra
Comment: None of the data taken from APP publications could be verified and may thus not be correct.
[B] Pulp[C] % MTH in [D] Reference and notes[A] Natural
mill fiber
forest pulped production
Production
capacity or actual
supply(ha)Yearproduction (blue)(ton/year)

1994-1999

307,121665,000

100%[A] Forest clearance calculated based on pulp production and MTH content using above parameter values.
[B] This mill started its pulp production in 1994. Production figure is based on P.T. Data Consult (May 25,2005).
[C] Eyes on the Forest assumes SMG/APP did not have plantations ready for harvest by until 1999.

2000 - 2004

221,681

720,000

80%[A] Forest clearance calculated based on pulp production and MTH content using above parameter values.
[B] APP (2004) - not verified company information that may not be correct!
[C] Cossalter (2006) as for IKPP in 2003 and 2004.

2005

30,674

642,753

62%[A] Forest clearance calculated based on pulp production and average 62% MTH content using above
parameter values[B] APP (2009) - not verified company information that may not be correct!
[C] We used average of 59% by APP (2009) and 65% by Cossalter (2006).

2006

28,168

677,682

54%[A] Forest clearance calculated based on pulp production and MTH content using above parameter values[B] [C] APP (2009) - not verified company information that may not be correct!
[A] Forest clearance calculated based on pulp production and 100% MTH content using above parametervalues.
[B] APP (2009) - not verified company information that may not be correct!
[C] APP (2009) writes "The percentage of plantation pulpwood used at Lontar decreased in 2007 due to theneed to meet increased demand for plantation pulpwood at the Indah Kiat Perawang mill in Riau", but also
writes that Lontar Papyrus' Mixed Tropical Hardwood Pulpwood was 58% . Eyes on the Forest suspects thatall plantation wood from Jambi concessions were used to supply Indah Kiat mill in Jambi during the police
embargo on all MTH transport there, hence estimates 100% MTH supply for LPPP. Not verified company
information that may not be correct!

2007

51,886

674,081

100%

2008

55,420720,000

100%

2009
2010

?
?

720,000
720,000

TOTAL
PULPED[A] Forest clearance calculated based on pulp production and MTH content using above parameter values.
[B] APP (2004) - not verified company information that may not be correct!
[C] Eyes on the Forest believes that all plantation wood from Jambi concessions were used to supply Indah
Kiat mill in Jambi, hence estimates 100% MTH supply for LPPP.
? [B] APP (2004) - not verified company information that may not be correct!
? [B] APP (2004) - not verified company information that may not be correct!

694,951

24

Appendix 2. Data used for the analysis in Chapter 2
The “study area” analysed for this report included Riau province and the part of Jambi
province that surrounds Bukit Tigapuluh national park. Our analysis in Chapter 2 used thefollowing data sets.
1. Concessions
Data on pulpwood (HTI) concessions and selective logging (HPH) concessions were obtained
from the Ministry of Forestry (2011) and Riau Forestry Agency (2006, 2011).
2. Natural forest cover
Natural forest was defined as original natural (as opposed to anthropogenic) vegetation
dominated by trees with a crown cover of more than 10%. Plantations were not considered
forests. Forests were defined exclusively as “natural forests” as it is those who havegenerated and still represent the country’s wealth of biodiversity, provide many of its
environmental services and social values, and host its huge carbon stocks. Natural forest
areas were delineated by visual interpretation of Landsat and other optical remote sensing
data. Time series analysis of natural forest cover used the following data: Natural forest delineated by Setiabudi, WWF Indonesia (see WWF Indonesia 2008) for1995 Natural forest delineated by Laumonier, Setiabudi, WWF Indonesia et al. (see WWF
Indonesia 2010) for 2008/9.
3. Floristic diversity: eco-floristic sectors
Analysis of natural forest cover in eco-floristic sectors in 1995 and 2008/9 and their
extinction risk category was based on Laumonier (1983) 202, Laumonier et al. (1986)203,
Laumonier et al. (1987)204, Laumonier (1990)205, Laumonier (1997)206, Laumonier et al.
(2010)207 and WWF Indonesia (2010).
4. Faunal diversity: Tiger, Elephant and Orangutan ranges•••

Sumatran tiger distribution 1996/2005 was based on Wikramanayake et al. (1998,
labeled Tiger Conservation Units) 208 and Sanderson et al. (2006, labeled Tiger
Conservation Landscapes)209.
Sumatran elephant distribution 1985 was based on Blouch & Symbolon (1985)210.
Sumatran orangutan distribution 2005-2010 was mapped by Frankfurt ZoologicalSociety211.

5. Peat soil
Peat soil area and depth 2002 was based on Wahyunto et al. (2003) 212 and the threepeat-related eco-floristic sectors "Peat Swamp Forest", "Mixed Peat Swamps" and "Peat
Swamps" (see above under data set 2).
6. Natural forest canopy density
Three classes of forest canopy density were distinguished by visual interpretation of Landsat
images based on WWF Indonesia (2008).
7. Basic data•

Sumatra’s provincial boundary data follow Government of Indonesia’s Bakosurtanal(2008).
25

•Presidential Moratorium Map was based on the Ministry of Forestry SK.
323/Menhut-II/2011
dated
17
June
2011
(for
the
text,
see
http://appgis.dephut.go.id/appgis/moratorium/SK_323_MENHUT.pdf; for the Ministryof Forestry map, see http://appgis.dephut.go.id/appgis/petamoratorium.html). The
shape file was published by Presidential Working Unit of Supervision and Control ofDevelopment (Unit Kerja Presiden Bidang Pengawasan & Pengendalian Pembangunan)
at:
http://dev.ukp.go.id/web/informasi-publik/cat_view/20-geospasial (downloaded on 29
September 2011).

References
1

Pirard, R. & Cossalter, C. (2006) The Revival of Industrial Forest Plantations in Indonesia's Kalimantan
Provinces. Will they help eliminated fiber shortfalls at Sumatran pulp mills or feed the China market?
CIFOR Working Paper No. 37.

2

Brown, D. W. (1999) Addicted to Rent: Corporate and Spatial Distribution of Forest Resources inIndonesia; Implications for Forest Sustainability and Government Policy.” DFID/Indonesia-UK Tropical
Forest Management Program Report No. PFM/EC/99/06.
3
Barr, C. (2000) Profits on Paper: The Political Economy of Fiber, Finance, and Debt in Indonesia's Pulp andPaper Industries. CIFOR.
http://siteresources.worldbank.org/INTINDONESIA/FLEG/20171586/Chriss_Bar.pdf
4
Potter, L. & Badcok, S. (2001) Case Study 6: The effects of Indonesia's decentralisation on forests andestate crops: case study of Riau province, the original districts of Kampar and Indragiri Hulu. CIFOR Reports
on Decentralisation and Forests in Indonesia.
http://www.cifor.cgiar.org/Publications/DocumentDownloader?a=d&p=¥publications¥pdf_files¥Books¥Cas
es%206-7.pdf
5Friends of the Earth (May 2001) Report: Paper Tiger, Hidden Dragons: The responsibility of international
financial institutions for Indonesian forest destruction, social conflict and the financial crisis of Asia Pulp &Paper. http://www.foe.co.uk/resource/reports/paper_tiger_hidden_dragons.pdf
6Barr, C. (2001) Banking on sustainability: structural adjustment and forestry reform in post-Suharto
Indonesia. WWF Macroeconomics for Sustainable Development Program Office & CIFOR.
http://www.cifor.cgiar.org/Publications/DocumentDownloader?a=d&p=¥publications¥pdf_files¥Books¥cba
rr¥Banking.pdf
7
WWF Germany (2003) Elephant Forests on Sale. Rain forest loss in the Sumatran Tesso Nilo region and therole of European banks and markets.
8
9

Forest Stewardship Council. FSC Principles and Criteria. http://www.fsc.org/1093.html
APP China website. http://www.app.com.cn/english/aboutus_development.html

10

WWF Indonesia (2010) Sumatra's Forests, their Wildlife and the Climate - Windows in Time: 1985,
1990, 2000, and 2009. A quantitative assessment of some of Sumatra's natural resources submitted astechnical report by invitation to the National Forestry Council (DKN) and the National Development
Planning Agency (BAPPENAS) of Indonesia. Full report for download:
http://assets.wwfid.panda.org/downloads/wwf_indonesia__2010__sumatran_forests_wildlife_climate_r
eport_for_dkn___bappenas.pdf Online summary:
http://www.savesumatra.org/index.php/wherewework/detail/Sumatra
11

WWF Indonesia (October 2006) Monitoring Brief October 2006: Asia Pulp & Paper (APP). Hiding
Destruction behind False Advertisements: APP continues to ignore calls for conservation beyond “legal
compliance”, and even fails on the latter.
http://www.wwf.or.jp/activity/forest/lib/APP_Oct06_MonitoringRpt.pdf
12PRWeek (30 September 2010) Asian Pulp & Paper Drafts In Cohn & Wolfe To Fight Greenpeace
Accusations.
http://www.prweek.com/news/1031982/Asian-Pulp---Paper-drafts-Cohn---Wolfe-fight-Greenpeace-accus
ations/13

Environmental Resource Management (2008) Asia Pulp & Paper- Indonesia: Executive Summary of
APP’s Carbon Footprint Assessment. www.cathaybr.com/pdf/APP_CarbonFootPrint.pdf

26

14

Laurance, W. et al. (25 October 2010) An Open Letter about Scientific Credibility and the Conservation of
Tropical Forests.
http://www.eyesontheforest.or.id/attach/Leading%20scientists%20%2825Oct10%29%20Open%20letter%20to%20ITS-WGI-Oxley.pdf
15
Mongabay.com (1 November 2010) Nobel Prize winner, anti-poverty group, scientists fire back at logging
lobbyist. http://news.mongabay.com/2010/1101-oxley_maathai.html
16
The New York Times (30 March 2011) Odd Alliance: Business Lobby and Tea Party.
http://www.nytimes.com/2011/03/31/us/politics/31liberty.html
17

Asia Pulp & Paper (11 August 2010) Letter to Stakeholders. Getting the Facts Down on Paper.
http://www.asiapulppaper.com/portal/app_portal.nsf/Web-MenuPage/25789CB95E09B9F54725777C00
23C42A/$FILE/Mazars.pdf
18

Asia Pulp & Paper (5 April 2011) Asia Pulp & Paper Group Partners with Carbon Conservation on Vision
2020: A Roadmap to Global Leadership in Sustainable Pulp and Paper Production.
http://www.csrwire.com/press_releases/31948-Asia-Pulp-Paper-Group-Partners-with-Carbon-Conserva
tion-on-Vision-2020-A-Roadmap-to-Global-Leadership-in-Sustainable-Pulp-and-Paper-Production
19
The Guardian George Monbiot’s Blog (2 December 2010) Why is a former Greenpeace activist siding withIndonesia’s logging industry?
http://www.guardian.co.uk/environment/georgemonbiot/2010/dec/02/sumatra-rainforest-destruction-pat
rick-moore
20
Greenbury, A. (3 August 2011) Help Us Save the Sumatran Tiger.
http://www.rainforestrealities.com/2011/08/03/help-us-save-the-sumatran-tiger/
21

Indonesian Pulp & Paper Association (9 June 2011) APKI Speaks Out Against Greenpeace Attacks.
http://www.rainforestrealities.com/2011/06/09/apki-speaks-out-against-greenpeace-attacks/
22

Ally Media (2011) Asia Pulp & Paper – Reforestation.
http://www.youtube.com/watch?v=qbXLhkWehgE
2324

http://www.trademarkia.com/app-cares-wwwasiapulppapercom-77947823.html
Asia Pulp & Paper (11 August 2010)25

http://www.rainforestrealities.com/2011/05/09/open-letter-to-wwf/

26

Ally Media (2011)27

Asia Pulp & Paper (22 February 2011) Asia Pulp & Paper Lays Out Key Milestones On Path to 100 Percent
Pulpwood Supply Certification.
http://www.businesswire.com/news/home/20110222007673/en/Asia-Pulp-Paper-Lays-Key-MilestonesPath
27

Greenbury (3 August 2011)

28

Asia Pulp & Paper (5 April 2011)29

See many reports available at http://www.eyesontheforest.or.id andhttp://www.savesumatra.org/index.php/link
30
AMEC (2001) APP Pulp Mills & Sinar Mas Group Forestry Companies. Environmental Compliance & Wood
Supply Audit Main Report. Asia Pulp & Paper (2004) APP Sustainability Action Plan. Asia Pulp & Paper (2008)
Our Mills.
http://www.asiapulppaper.com/portal/APP_Portal.nsf/Web-MenuPage/B65C5196BF3DD73A4725761C002F
65A4/$FILE/Our%20Mills.pdf Asia Pulp & Paper (2009) 2007 Growing a Sustainable Future. Environmental
and Social Sustainability Report for Indonesia. See other sources in the table.
31
U.S. & Foreign Commercial Service and U.S. Department of State (1999). Indonesia – Pulp and Paper –ISA981101 USDOC, International Trade Administration. http://ita.doc.gov/td/forestprod/indonesia.htm
Barr (2000). P.T. Data Consult (May 25, 2005) Indonesia feared to become net importer of pulp. (INDUSTRY),
published in Indonesian Commercial Newsletter.
http://www.thefreelibrary.com/1.+Indonesia+feared+to+become+net+importer+of+pulp.-a0141997821
Pirard & Cossalter (2006). Cossalter, C. (2006) APP and APRIL’s commitments for Sustainable pulpwood
plantations. Where do we stand? Draft.
http://environment.yale.edu/tfd/uploads/APP__APRIL_25_November_2006.pdf
32Barr (2000)
33

Asia Pulp & Paper (2004)

34

Asia Pulp & Paper (May 2007) APP 2005/06 Environment Report.
http://www.asiapulppaper.com/portal/APP_Portal.nsf/Web-MenuPage/1B2BBDDE7FB9B64C4725739B0
0232E6A/$FILE/SR1.PDF

27

35

Asia Pulp & Paper (22 February 2011)
Riley, J. (19 Aprli 2008) Peat, Pulp & Paper: Climate Impact of Pulp Tree Plantations on Peatland inIndonesia. http://www.environmentalpaper.org/documents/Jack%20Rieley.pdf Rieley & Page (2008)
37
Barr, C. (10 April 2008) Indonesia’ s Pulp & Paper Industry: Overview of Risks and Opportunities.
http://www.environmentalpaper.org/documents/Chris%20Barr%20-%20CIFOR.pdf
38
Obidzinski, K & Dermawan, A. (30 May 2011) CIFOR Forest blog: New round of pulp and paper expansion
in Indonesia: What do we know and what do we need to know?
http://blog.cifor.org/2905/new-round-of-pulp-and-paper-expansion-in-indonesia-what-do-we-know-andwhat-do-we-need-to-know/
36

39

Rieley, J.O. & S.E. Page (2008) Carbon Budgets under Different Land Uses on Tropical Peatland. Included
in: Rieley, J.O., Banks, C.J. and Page, S.E. (2008) Future of Tropical Peatlands in Southeat Asia as Carbon
Pools and Sinks. Papers Presented at the Special Session on Tropical Peatlands at the 13th International Peat
Congress, Tullamore, Ireland, 10th June 2008, CARBOPEAT Partnership, International Peat Society andUniversity of Leicester, United Kingdom.
http://www.geog.le.ac.uk/carbopeat/media/pdf/tullamorepapers/ipc_tropical_peat_special_session.pdf
40
Barr (10 April 2008)
41
WWF Indonesia (2010)
42

Bisnis Indonesia (24 April 2011) Konglomerat Kembangkan Investasi HTI Di Kalimantan Dan Papua.
http://www.bisnis.com/articles/konglomerat-kembangkan-investasi-hti-di-kalimantan-dan-papua
43
Obidzinski & Dermawan (30 May 2011)
44
KKI Warsi, Frankfurt Zoological Society, Eyes on the Forest and WWF-Indonesia (14 December 2010a)
Press Release: Once-Untouched Haven for Tigers, Orangutans, Elephants Being Systematically Targeted by
APP/SMG. Sumatran Forest is Last Home of the Indigenous Orang Rimba and Talang Mamak.
http://www.wwf.or.id/en/news_facts/press_release/?21160/Once-Untouched-Haven-for-Tigers-Orangutans-Elephants-Being-Systematically-Targeted-by-APPSMG KKI Warsi, Frankfurt Zoological Society, Eyes on
the Forest and WWF-Indonesia (14 December 2010b) Report: Last Chance to Save Bukit Tigapuluh.
Sumatran tigers, elephants, orangutans and indigenous tribes face local extinction, along with forest.
http://www.wwf.or.id/btp_report_dec10_pdf
45Laumonier, Y., Uryu, Y., Stwe, M., Budiman, A., Setiabudi, B. & O. Hadian. (2010) Eco-floristic sectors anddeforestation threats in Sumatra: indentifying new conservation area network priorities forecosystem-based land use planning. Biodiversity Conservation (2010) 19: 1153-1174.
http://www.springerlink.com/content/c77376k574051178/fulltext.pdf See also WWF Indonesia (2010).
46

IUCN, The International Union for Conservation of Nature and Natural Resources lists Sumatran tiger(Panthera tigris ssp. sumatrae), Sumatran elephant (Elephas maximus ssp. sumatranus) and Sumatranorangutan (Pongo abelii) as critically endangered. Linkie, M., Wibisono, H.T., Martyr, D.J. & Sunarto, S.
2008. Panthera tigris ssp. sumatrae. In: IUCN 2011. IUCN Red List of Threatened Species. Version 2011.2.
<http://www.iucnredlist.org/apps/redlist/details/15966/0, downloaded on 14 November 2011> Gopala, A.,
Hadian, O., Sunarto, ., Sitompul, A., Williams, A., Leimgruber, P., Chambliss, S.E. & Gunaryadi, D. 2011.
Elephas maximus ssp. sumatranus. In: IUCN 2011. IUCN Red List of Threatened Species. Version 2011.2.
<http://www.iucnredlist.org/apps/redlist/details/199856/0, downloaded on 14 November 2011> Singleton, I.,
Wich, S.A. & Griffiths, M. 2008. Pongo abelii. In: IUCN 2011. IUCN Red List of Threatened Species.
Version 2011.2. <http://www.iucnredlist.org/apps/redlist/details/39780/0, downloaded on
14 November 2011>47

Greenbury, A. (31 January 2011) Asia Pulp and Paper: why activists are wrong over destructive logging
allegations. Published at The Ecologist.
48
Laumonier et al. (2010). WWF Indonesia (2010)49
Laumonier et al. (2010). WWF Indonesia (2010).
50
Gillison, A.N. (2001) Vegetation Survey and Habitat Assessment of the Tesso Nilo Forest Complex.
Pekanbaru, Riau Province, Sumatra, Indonesia (27 October – 10 November 2001). WWF Technical Report,
WWF, Washington, DC, USA.
51
Prawiradilaga, D. M. et al. (2003) Survey Report on Biodiversity of Tesso Nilo. May – August 2003.
Indonesian Research Centre for Biology-LIPI & WWF Indonesia.
52
WWF Indonesia (16 June 2004) Monitoring of Illegal Logging Operations in Riau, Sumatra. Deliveries ofIllegally 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.wwf.or.id/attachments/Monitoring_of_Illegal_Logging.pdf
53
Greenpeace (25 July 2011) Endangered Sumatran tiger dies in trap on APP concession in Indonesia.

28http://www.greenpeace.org/international/en/news/Blogs/makingwaves/endangered-sumatran-tiger-dies-i
n-trap-on-app/blog/35859/
54
For example, see Eyes on the Forest (4 April 2006) Interactive Map on Elephant Distribution and Conflictin Riau, Sumatra. WWF Indonesia (2006) Riau’s Elephants: The 2006 Tragedy.
http://www.wwf.or.id/en/about_wwf/whatwedo/forest_species/where_we_work/tessonilobukittigapuluh/f
ocal_species/elephants/elephant_tragedy/ Eyes on the Forest (18 April 2006) Forests to Paper, Forests toPalm Oil and No Place to Live for Riau’s Elephants.
http://www.wwf.or.jp/activities/upfiles/EoFElephant18Apr06_.pdf
55

For example, see: Eyes on the Forest (30 November 2010) EoF calls on SMG/APP and APRIL to keep
their promises: Stop conversion of natural forest and drainage of peat to produce pulp, stop violation of
the country’s climate commitments.
http://eyesontheforest.or.id/attach/EoF%20%2830Nov10%29%20Riau%20RKT%202010%20natural%
20forest%20and%20peat%20conversion%20EN%20FINAL.pdf Eyes on the Forest (8 July 2010)
Investigative Report: Business as Usual in Riau, Sumatra: Pulp Industry Continues Clearance of Natural
Forest.
http://eyesontheforest.or.id/attach/EoF_Report_July2010_pulp_industry_continues_clearance%20B.pdf
Eyes on the Forest (April 2010) Investigative Report December 2009. Two Asia Pulp & Paper / Sinar Mas
Group associated companies continue clearcutting of deep peatland forest of Kerumutan in Riau Province,
Sumatra, threatening peatland forest ecosystems, Sumatra tiger and global climate.
http://eyesontheforest.or.id/attach/EoF_Investigative_Report_April2010_APP_Kerumutan.pdf Eyes on
the Forest (27 July 2009) Fires in APP/Sinar Mas Concessions Add to Region’s Haze Woes, Threaten New
UN Biosphere Reserve.
http://eyesontheforest.or.id/attach/EoF_PR_Fire_hotspot_final_27_July_2009.pdf Eyes on the Forest(26 March 2008) Eyes on the Forest to Asia Pulp & Paper: Cease all destruction of one of the world’s
largest tropical peatland forests – Kampar peninsula in Riau, Sumatra, Indonesia.
http://eyesontheforest.or.id/attach/Investigative%20Report%20english%20version%20march%20200
8.pdf
56
Laumonier et al. (2010). WWF Indonesia (2010).
57
Sanderson, E., J. Forrest, C. Loucks, J. Ginsberg, E. Dinerstein, J. Seidensticker, P. Leimgruber, M.
Songer, A. Heydlauff, T. O’Brien, G. Bryja, S. Klenzendorf, and E. Wikramanayake. 2006. Setting Priorities
for the Conservation and Recovery of Wild Tigers: 2005-2015. WCS, WWF, Smithsonian, and NFWF-STF.
58
The Jakarta Globe (24 November 2010) Indonesia Joins World Forum Vowing to Save Tigers.
http://www.thejakartaglobe.com/nvironment/indonesia-joins-world-forum-vowing-to-save-tigers/408341
59
WWF Indonesia (10 May 2011) WWF captures Sumatran Tiger Triplets in forest under imminent threat ofclearing. http://www.wwf.or.id/index.cfm?uNewsID=22341&uLangID=160
KKI Warsi, Frankfurt Zoological Society, Zoological Society of London, PKHS & WWF Indonesia (8 January
2008a) Joint Press Release: APP Forest Clearing Threatens Lives of Local Communities and Endangered
Species.
http://www.wwf.or.id/en/news_facts/press_release/?2642/Forest-Clearing-In-Bukit-Tigapuluh-ThreatensLives-Of-Local-Communities-And-Endangered-Species KKI Warsi, Frankfurt Zoological Society, ZoologicalSociety of London, PKHS & WWF Indonesia (8 January 2008b) Joint Report: Asia Pulp and Paper (APP)
Threatens Bukit Tigapuluh Landscape.
http://rafflesia.wwf.or.id/library/attachment/pdf/BTp_Investigation_Jan%202008_draft_FINAL.pdf
61
KKI Warsi et al. (14 December 2010a). KKI Warsi et al. (14 December 2010b)
62
WWF and Google Earth (9 May 2011) Video: Saving Bukit Tigapuluh.
http://www.youtube.com/watch?v=qsg6N9p0Vy063
WWF Indonesia (10 May 2011) WWF captures Sumatran Tiger Triplets in forest under imminent threat ofclearing. http://www.wwf.or.id/index.cfm?uNewsID=22341&uLangID=1
64
Rainforest Action Network and Japan Tropical Forest Action Network (October 2010) Asia Pulp & Paper’s
Hidden Emissions: Calculating the Real Carbon Footprint of APP’s Paper.
http://ran.org/sites/default/files/app_hidden_emissions.pdf
65
Environmental Resource Management (2008)
66
Worrell et al. 2001, quoted by Environmental Resource Management (2008)
67
Rainforest Action Network and Japan Tropical Forest Action Network (October 2010)
68
WWF Indonesia (2008) Deforestation, Forest Degradation, Biodiversity Loss and CO2 Emissions in Riau,
Sumatra, Indonesia. WWF Indonesia Technical Report, Jakarta, Indonesia.
http://www.worldwildlife.org/who/media/press/2008/WWFPresitem7596.html
69
WWF Indonesia (2008). WWF Indonesia (2010). Eyes on the Forest (16 March 2011) Press Release: EoF

29

coalition urges APP and APRIL not to clear 800,000 hectares of natural forests in their concessions.
http://eyesontheforest.or.id/?page=news&action=view&id=326 Eyes on the Forest (15 March 2011)
Impacts of the LoI moratorium on Sumatra's natural forest and peat - an analysis of Riau, Sumatra's
deforestation hotspot. Submitted to Dr. Ir. Kuntoro Mangkusubroto, Kepala Unit Kerja Presiden bidang
Pengawasan dan Pengendalian Pembangunan (UKP4).
http://eyesontheforest.or.id/attach/EoF%20%2815Mar11%29%20Impacts%20of%20LoI%20moratorium%20on%20Sumatra%20and%20Riau%20EN%20Submitted.pdf
70
The Ministry of Forestry, Republic of Indonesia (2007) Reducing Emissions from Deforestation and Forest
Degradation in Indonesia. REDD Methodology and Strategies Summary for Policy Makers.
http://www.dephut.go.id/INFORMASI/LITBANG/IFCA/Summary%204%20policy%20makers_final.pdf
71
WWF Indonesia (2008)
72

WWF Indonesia (2010)
WWF Indonesia (2008)
74
Eyes on the Forest (16 March 2011). Eyes on the Forest (15 March 2011)
75
Riau’s reference emission level was around 425 megatons according to the National REDD+ Strategy
Draft 1 Revised, available at
http://www.un.or.id/sites/default/files/COMPLETEStranas1RevisedEng%20final%20version.pdf
76
If we assume 86 ton CO2/ha/year of peat emissions from pulpwood plantation on peat,
based on Hooijer et al. (2010) http://www.biogeosciences.net/7/1505/2010/bg-7-1505-2010.pdf, annual
CO2 emissions from these areas could be 61 megatons/year.
77
Eyes on the Forest (15 March 2011).
78
WWF Indonesia (2008)
79
Wahyunto et al. (2003)
73

80

Asia Pulp & Paper (31 March 2011) Advertisement on a Dutch newspaper, De Groene Amsterdammer.
The same advertisement was used in the US and various countries in Europe this year.

81

Asia Pulp & Paper (31 August 2011) Advertisement in a Hong Kong newspaper, the South China
Morning Post.

82

Asia Pulp & Paper (31 March 2011)
WWF (20 February 2004) Time is running out for
APP. http://assets.wwfid.panda.org/downloads/time_is_running_out_4_app.pdf WWF US (20 February2004) WWF Calls on U.S. Retailers to Demand Paper Giant APP Stop Unsustainable Logging.
http://www.worldwildlife.org/who/media/press/2004/WWFPresitem691.html
83

84

Forest Stewardship Council (December 2007) Forest Stewardship Council dissociates with Asia Pulp
and Paper.
http://www.fsc.org/fileadmin/web-data/public/document_center/Stakeholder_updates/FSC_dissociates_with_APP-EN.pdf
85

Rainforest Alliance Public Statement (January 2007) Statement: Termination of Contract to Verify High
Conservation Value Forests (HCVF) for APP in Sumatra, Indonesia.
http://www.rainforest-alliance.org/forestry/documents/app.pdf
86
Office Depot (2011) Office Depot’s industry-leading Global Environmental Strategy.
http://www.officedepot.cc/environment/downloads/2011-environmental-overview.PDF
87
The Wall Street Journal (7 February 2008) Green-Minded Staples Ends Ties With Asia Pulp & Paper.
88
The Jakarta Globe (6 July 2010) Carrefour and Kraft Add To Sinar Mas Group’s Woes.
http://www.thejakartaglobe.com/business/carrefour-and-kraft-add-to-sinar-mas-groups-woes/384511
89
Forest Ethics (2009) Green Grades 2009. A Report Card on the Paper Practices of the Office Supply Sector.
Summary of United Stationers.
http://www.forestethics.ca/downloads/Green-Grades-UnitedStationers-Summary-09.pdf
90
Forest Ethics (2009) Green Grades 2009. A Report Card on the Paper Practices of the Office Supply Sector.
Summary of Target. http://www.forestethics.org/downloads/Green-Grades-Target-Summary-09.pdf
91Southern California Public Radio (5 October 11) Mattel breaks up with Asia Pulp and Paper afterGreenpeace’s Barbie-based campaign [UPDATE].
http://www.scpr.org/news/2011/10/05/29262/mattel-breaks-asia-pulp-and-paper-after-greenpeace/
Greenpeace (5 October 2011) Success: Barbie and Mattel drop deforestation!
http://www.greenpeace.org/international/en/news/Blogs/makingwaves/success-barbie-and-mattel-dropdeforestation/blog/37176/
92
Greenpeace (2 November 2011) Toy giant Hasbro latest to introduce tough paper policy following
Greenpeace investigation.

30

http://www.greenpeace.org/usa/en/media-center/news-releases/Hasbro-latest-company-to-drop-rainfore
st-packaging1/
93
Greenpeace (21 May 2007) El mercado español cierra las puertas al papel procedente de la destrucción delos bosques de Indonesia. http://www.greenpeace.org/espana/es/news/el-mercado-espa-ol-cierra-las/
94
RobinWood (25 August 2004) ROBIN WOOD überzeugt Metro: Handelskonzern will auf Papier aus
Regenwaldzerstörung verzichten. http://www.robinwood.de/german/presse/040825.htm
95
RobinWood (31 May 2011) Papiergiant APP verliert weiteren Kunden in Europa. KiK verzichtet auf
Schreibpapier aus Indonesian. http://www.robinwood.de/Newsdetails.13+M52f2807ec82.0.html
96
Greenpeace (30 January 2011) Asia Pulp and Paper Awarded Golden Chainsaw. Greenpeace accusescompany of being one of worst rainforest destroyers in Indonesia.
http://www.greenpeace.org/international/en/press/releases/Asia-Pulp-and-Paper-Awarded-Golden-Chainsaw/
97
Greenpeace (2 November 2011)
98
Greenpeace (2 November 2011)
99
PrintWeek (8 August 2008) APP defiant despite losing Woolworths contract over environmental
allegations.
http://www.printweek.com/news/838307/APP-defiant-despite-losing-Woolworths-contract-environmentalallegations
100
The Sydney Morning Herald (25 August 2011) IGA dumps toilet paper product.
http://news.smh.com.au/breaking-news-national/iga-dumps-toilet-paper-product-20110825-1jats.html
101

Metcash Limited (23 August 2011) IGA Paper Products Sources from Indonesia.
http://www.metcash.com/our-responsibility/in-the-news
102
Greenpeace (2 November 2011)
103
PrintWeek (1 March 2002) APP shunned until it becomes green.
http://www.printweek.com/news/426984/APP-shunned-until-becomes-green/
104
The Guardian George Monbiot’s Blog (2 December 2010)
105
Greenpeace (30 January 2011)
106
Greenpeace (30 January 2011)107
Greenpeace (June 2011) Sinar Mas under Investigation. How APP is Toying with Extinction.
http://www.greenpeace.org/international/Global/international/photos/forests/2011/app/sections/ToyingW
ithExtinction_Full.pdf
108Greenpeace (June 2011)
109
WWF Indonesia (20 October 2006) APP Hides Destruction Behind False Advertisements.
http://www.wwf.or.id/en/news_facts/press_release/?7460/APP-Hides-Destruction-Behind-False-Advertise
ments
110
Greenpeace (22 February 2005) Victory for public environmental action as APP withdraws lawsuit.
http://www.greenpeace.org/eastasia/press/releases/forests/2005/victory-for-public-environment/
111
Mongabay.com (3 November 2009) Gucci drops APP in pledge to save rainforests.
http://news.mongabay.com/2009/1103-hance-gucci.html
112
Greenpeace (2 November 2011)113

Ourfutureplanet (16 August 2011) Lego banishes Asia Pulp & Paper due to deforestation link.
http://www.ourfutureplanet.org/news/607-lego-banishes-asia-pulp-a-paper-due-to-deforestation-link
114
GraphiLine.com (21 December 2010) Carrefour et Leclerc déréférencent le papetier Asia Pulp and Paper(APP).
http://www.graphiline.com/article/13816/Carrefour-et-Leclerc-dereferencent-le-papetier-Asia-Pulp-and-P
aper-(APP)115
The Jakarta Globe (6 July 2010)
116
Greenpeace (7 November 2011) Indonesian Rain forest Destroyer Asia Pulp and Paper Loses MoreContracts.
http://www.greenpeace.nl/press/Persberichten-2011/Reclame-Code-Commissie-reclames-APP-misleidend/
117

Asia Pulp & Paper (31 March 2011)
Greenbury (3 August 2011)
119
Greenomics (18 May 2011)
120
Asia Pulp & Paper (26 October 2011) Sumatran Tiger Conservation Foundation Rescues Another
Endangered Tiger, Begins Relocation Process.
http://www.businesswire.com/news/home/20111026007036/en/Sumatran-Tiger-Conservation-Foundatio
118

31

n-Rescues-Endangered-Tiger
121

Greenbury (3 August 2011)
Eyes on the Forest (28 October 2011) APP’s tiger capture questioned.
http://www.eyesontheforest.or.id/?page=news&action=view&id=499
123
For example, see Eyes on the Forest (May 2011) Investigative Report. PT Suntara Gaja Pati and PT Ruas
Utama Jaya, two affiliated companies to APP/SMG, continue clearcutting of Senepis Sumatran tiger forest,
where the group contributes only less than 15 percent area for Senepis Buluhala Sumatran tiger
conservation.
http://www.eyesontheforest.or.id/attach/Investigative%20Report%20PT%20SGP%20PT%20RUJ%20Sen
epis_May%202011.pdf
124
Riau Forestry Agency Letter No. 522.1/PR/7518 on 23 August 2004. Riau Governor Letter No.
500/EKBANG/63.18 on 18 October 2004.
125
For example, see WWF Indonesia (October 2006)
126
PT Suntara Gajapati Letter Number: 022/SG/VI/2006, dated 22 June 2006.
127
Greenomics (18 May 2011)
128
Eyes on the Forest (17 March 2009) Press release: Forest clearing by Giant APP/Sinar Mas linked to 12
years of Sumatran tiger, human fatalities.
http://eyesontheforest.or.id/attach/EoFRiauTigerConflictPR_17Mar09.pdf Map
http://eyesontheforest.or.id/attach/EoF%20MAP%20for%20%20PR%20on%20APP%20and%20tiger%20
conflicts_17Mar09.pdf
129
KKI Warsi et al. (8 January 2008a). KKI Warsi et al. (8 January 2008b).
130
KKI Warsi et al. (14 December 2010a). KKI Warsi et al. (14 December 2010b).
131
WWF Indonesia (9 May 2011) WWF captures Sumatran tiger triplets in forest under imminent threat ofclearing.
http://www.wwf.or.id/en/?22341/Video-otomatis-WWF-merekam-induk-dan-anak-harimau-di-habitat-yan
g-terancam
132
WWF and Google Earth (9 May 2011) Video: Saving Bukit Tigapuluh.
http://www.youtube.com/watch?v=qsg6N9p0Vy0
133
KKI Warsi et al. (14 December 2010a). KKI Warsi et al. (14 December 2010b).
134
Asia Pulp & Paper (27 July 2009) APP supports creation of new Taman Raja Nature Reserve in Indonesia.
135
KKI Warsi et al. (14 December 2010b)
136
Greenomics (November 2011) Reasons behind Asia Pulp and Paper’s Taman Raja & Kampar Carbon
Reserves. http://www.greenomics.org/docs/Report_201111_Reasons_Behind_APP's_Reserves.pdf
137
Asia Pulp & Paper CNN International Advertorials (December 2009) “Conservation”.
http://www.youtube.com/watch?v=rEyduROW8Sk
138
Eyes on the Forest (30 November 2010). WWF Indonesia (October 2006)
139
Eyes on the Forest (30 November 2010). Also see other Eyes on the Forest reports at
http://www.eyesontheforest.or.id
140
Eyes on the Forest (10 November 2010) EoF News: More Riau official sentenced for forestry
graft case. http://eyesontheforest.or.id/?page=news&action=view&id=304
141
Greenomics (18 May 2011)
142
Business Wire (3 December 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
d%E2%80%99s-Pulpwood-Plantation
143
Eyes on the Forest (30 November 2010). Greenomics (23 November 2010) Pulling the wool over the
public’s eyes: Asia Pulp & Paper deceives public over “Kampar Carbon Reserve” project.
http://www.greenomics.org/docs/Report_201011_APPdeceivespublicovercarbonproject.pdf Greenomics(November 2011)
122

144

http://www.asiapulppaper.com “Tackling Climate Change” under Sustainability & CSR section, viewed
on 3 August 2010.
145

Asia Pulp & Paper (31 August 2011)146

http://www.asiapulppaper.com “Tackling Climate Change” under Sustainability & CSR section, viewed
on 3 August 2010.
147

Asia Pulp & Paper (31 August 2011)

148

WWF Indonesia (October 2006)

149

WWF Indonesia (2008)

32

150

Eyes on the Forest (April 2010)151

Eyes on the Forest (8 July 2010)

152

Eyes on the Forest (30 November 2010)

153

KKI Warsi et al. (14 December 2010a). KKI Warsi et al. (14 December 2010b).

154

Also see many Eyes on the Forest and other reports collected at http://www.eyesontheforest.or.id andhttp://www.savesumatra.org/index.php/link
155
Eyes on the Forest (30 November 2010)
156

Mongabay.com (18 November 2010) Scientists call upon Indonesia to recognize value of secondary
forests. http://news.mongabay.com/2010/1118-letter_norway_indonesia.html

157

For example, read Eyes on the Forest (8 July 2010) and Eyes on the Forest (30 November 2010).
Greenomics (18 May 2011) Pulp and Paper Giants Show Abject Lack of Concern for Sumatran Tiger,
Despite Aggressive PR Claims. http://www.greenomics.org/docs/Report_201105_Sumatran_Tiger.pdf
158

159

Asia Pulp & Paper (31 August 2011)

160

Asia Pulp & Paper (22 February 2011)

161

Asia Pulp & Paper (22 February 2011)162

For example, read Eyes on the Forest (April 2010), Eyes on the Forest (8 July 2010), Eyes on theForest (30 November 2010).
163

Act of the Republic of Indonesia No. 5 of 1990 Concerning Conservation of Living Resources and Their
Ecosystems. http://faolex.fao.org/docs/pdf/ins3867.pdf
164

Law (UNDANG-UNDANG REPUBLIK INDONESIA) Nomor 26 Tahun 2007

http://landspatial.bappenas.go.id/peraturan/the_file/UU_No26_2007.pdf
165

Government Regulation (PERATURAN PEMERINTAH REPUBLIK INDONESIA) Nomor 26 Tahun 2008

http://www.bkprn.org/v2/peraturan/file/PP_26_Tahun_2008.pdf
166
Greenomics (18 May 2011)
167
The Jakarta Post (17 September 2008) Pelalawan regent gets 11 years.
http://www.thejakartapost.com/news/2008/09/17/pelalawan-regent-gets-11-years.html The Jakarta Post
(14 February 2011) Supreme Court rejects former regent’s appeal in illegal logging case.
http://www.thejakartapost.com/news/2011/02/14/supreme-court-rejects-former-regent039s-appeal-illeg
al-logging-case.html Eyes on the Forest (10 November 2010) More Riau official sentenced for forestry graft
case. http://www.eyesontheforest.or.id/?page=news&action=view&id=304 The Jakarta Globe (19 May
2011a) A Timeline of the Riau Investigation.
http://www.thejakartaglobe.com/nvironment/a-timeline-of-the-riau-investigation/441823
168
Eyes on the Forest (26 March 2011) Siak District Head detained over forestry corruption charge.
http://www.eyesontheforest.or.id/index.php?page=news&action=view&id=328 The Jakarta Post (13August 2011) Former Siak regent tried for graft.
http://www.thejakartapost.com/news/2011/08/13/former-siak-regent-tried-graft.html Eyes on the Forest(16 August 2011) Siak District Head prosecuted in Riau.
http://eyesontheforest.or.id/?page=news&action=view&id=488
169
detikNews (12 August 2011) Jadi Tersangka Korupsi Sejak 2008, Bupati kampar Diperiksa KPK.
http://us.detiknews.com/read/2011/08/12/105450/1702190/10/jadi-tersangka-korupsi-sejak-2008-bupa
ti-kampar-diperiksa-kpk Riau Pos (12 August 2011) Bupati Kampar diperiksa KPK.
http://www.riaupos.co.id/berita.php?act=full&id=1529&kat=5 PekanbaruExpress.com (14 September2011) KPK periksa dan geledah rumah Bupati Kampar Burhanudin
http://www.pekanbaruexpress.com/korupsi/korupsi/4385-kpk-periksa-dan-geledah-rumah-burhanudin
Nasional inilah.com (15 September 2011) KPK geledah rumah Burhanuddin.
http://nasional.inilah.com/read/detail/1774454/kpk-geledah-rumah-burhanuddin
170
The Jakarta Globe (19 May 2011b) How a $115b Illegal Logging Probe Was Felled. Unanswered Question:
Why the sudden end to an apparently watertight two-year police investigation into 14 pulp and paper
companies' forest clerarance in Riau?
http://www.thejakartaglobe.com/nvironment/special-report-how-a-115b-illegal-logging-probe-was-felled/441679171
The Jakarta Globe (19 May 2011a)
172
The Jakarta Globe (19 May 2011c) KPK Vows to Pursue Logging 'Cold Cases'
http://www.thejakartaglobe.com/news/kpk-vows-to-pursue-logging-cold-cases/441684
173
The Jakarta Post (14 June 2011) Police resume probes into 14 timber firms.

33

http://www.thejakartapost.com/news/2011/06/13/police-resume-probes-14-timber-firms.html
174
See also articles by Eyes on the Forest, for example, Eyes on the Forest (27 July 2005) WWF, Walhi,
Jikalahari: “Logging Moratorium for Companies with Questionable Industrial Timber Plantation Licenses”.
http://www.eyesontheforest.or.id/?page=news&action=view&id=12 Eyes on the Forest (April 2010). Eyeson the Forest (8 July 2010). Eyes on the Forest (30 November 2010).
175
Eyes on the Forest (8 July 2010).
176

Asia Pulp & Paper (22 February 2011)

177

Asia Pulp & Paper (10 March 2011) Asia Pulp & Paper Joins Indonesian Associations Pledging 100
Percent Industry Adherence to National Wood Legality Laws. Indonesian Industry Associations Calls on
Governments Worldwide to Recognize SVLK Certification Standards in National Procurement Policies.
http://eon.businesswire.com/news/eon/20110310005512/en/Asia-Pulp-%26-Paper/APP/Indonesia
178

Asia Pulp & Paper (10 March 2011)179

Forest Stewardship Council (December 2007) Forest Stewardship Council dissociates with Asia Pulp
and Paper.
http://www.fsc.org/fileadmin/web-data/public/document_center/Stakeholder_updates/FSC_dissociates_with_APP-EN.pdf
180

Asia Pulp & Paper (22 February 2011)
Asia Pulp & Paper (16 November 2011) Asia Pulp & Paper in ‘Full Compliance’ with EU Ecolabel. European
Commission report rules that Pindo Deli products meet Ecolabel standards.
182
On criticisms on LEI, see KKI Warsi, FZS Indonesia Program, PKHS, Jikalahari, Walhi Riau, Walhi Jambi
and WWF Riau (19 November 2009) Indonesian NGOs: Even with LEI certification, APP paper products areunsustainable. http://www.wwf.or.id/index.cfm?uNewsID=12980&uLangID=1
183
Climate for Ideas, Forests of the World, Dogwood Alliance, Hnuti DUHA, Les Amis de la Terre, Greenpeace,
Sierra Club of British Columbia, Suomen Luonnonsuojeluliitto, Netherlands Centre for Indigenous Peoples(September 2011) On The Ground 2011 The controversies of PEFC and SFI.
http://www.greenpeace.org/international/Global/international/publications/forests/On%20The%20Groun
d%2017_10_11.pdf
184
FERN (9 April 2010) EU Ecolabel allows forest destruction – the case of Pindo Deli.
http://www.fern.org/sites/fern.org/files/FERN_PindoDeli-final_0.pdf
181

185

Greenbury, A. (20 May 2011) Taking action to make the most of the Moratorium.
http://www.rainforestrealities.com/2011/05/20/taking-action-to-make-the-most-of-the-moratorium/
186

Greenbury (20 May 2011).

187

Asia Pulp & Paper (2011) TV commercial on Dutch TV, STER.
CIFOR Forest Blog (23 May 2011) Indonesia releases Presidential Instructions for logging moratorium.
http://blog.cifor.org/3003/indonesia-releases-presidential-instructions-for-logging-moratorium/
189
Eyes on the Forest (16 March 2011). Eyes on the Forest (15 March 2011).
190
Muhammad Teguh Surya (20 June 2011) Presidential order vs. forest conversion moratorium. Opinion
published by The Jakarta Post.
http://www.thejakartapost.com/news/2011/06/20/presidential-order-vs-forest-conversion-moratorium.ht
ml191
Red-monitor (14 June 2011) NGOs criticize Indonesia’s “moratorium”.
http://www.redd-monitor.org/2011/06/14/ngos-criticise-indonesias-moratorium/192
http://www.dephut.go.id/files/SK.323_MENHUT_2011.pdf
http://appgis.dephut.go.id/appgis/moratorium/SK_323_MENHUT.pdf
193
Environmental Resource Management (2008)
194
Asia Pulp & Paper (11 August 2008) APP Indonesia Releases Results of Carbon Footprint Assessment.
195
Rainforest Action Network and Japan Tropical Forest Action Network (October 2010)
188

196

Asia Pulp & Paper (5 April 2011)
Asia Pulp & Paper (19 June 2002) APP and SMG announce detailed sustainable wood supply assessment& planning project conducted by independent 3rd party.
197

198

WWF Indonesia (19 August 2003) Asia Pulp and Paper Co. Ltd. and its fiber suppliers, the Sinar Mas
Group forestry companies Letter of Intent, Jakarta,
Indonesia. http://assets.wwfid.panda.org/downloads/letter_of_intent_final.pdf
199
WWF (20 February 2004) Time is running out for
APP. http://assets.wwfid.panda.org/downloads/time_is_running_out_4_app.pdf WWF US (20 February2004) WWF Calls on U.S. Retailers to Demand Paper Giant APP Stop Unsustainable Logging.

34http://www.worldwildlife.org/who/media/press/2004/WWFPresitem691.html
200

Eyes on the Forest (10 March 2010) 400 Indonesian NGOs reject APP’s green claims.
http://www.eyesontheforest.or.id/index.php?page=news&action=view&id=269
201

Indonesian NGOs (10 March 2010) An Open Letter to Customers of and Investors in the Indonesian
Pulp and Paper Sector. http://ran.org/sites/default/files/join_id_letter_to_pulp_and_paper_sector.pdf
202
Laumonier, Y. (1983) International Map of the Vegetation. “Southern Sumatra”. 1:1.000.000. Institut dela Carte Internationale de la Végétation, Toulouse, France and SEAMEO-BIOTROP, Bogor, Indonesia.
203
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.
204
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.
205
Laumonier, Y. (1990) Search for phytogeographic provinces in Sumatra. In: Baas P, Kalkman K, Geesink
R (eds) The plant diversity of Malaysia. Kluwer Academic Publishers, Dordrecht, pp 193–211.
206
Laumonier, Y. (1997) The Vegetation and Physiography of Sumatra. Kluwer Academic Publishers.
207
Laumonier et al. (2010). WWF Indonesia (2010).
208
Wikramanayake, E.D., Dinerstein, E., Robinson, J.G., Karanth, U., Rabinowitz, A., Olson, D., Mathew, T.,
Hedao, P., Conner, M., Hemley, G. and Bolze, D. (1998) An Ecology-Based Method for Defining Priorities forLarge Mammal Conservation: The Tiger as Case Study.
209
Sanderson, E., J. Forrest, C. Loucks, J. Ginsberg, E. Dinerstein, J. Seidensticker, P. Leimgruber, M. Songer,
A. Heydlauff, T. O’Brien, G. Bryja, S. Klenzendorf, and E. Wikramanayake. 2006. Setting Priorities for theConservation and Recovery of Wild Tigers: 2005-2015. WCS, WWF, Smithsonian, and NFWF-STF.
210
Blouch & Symbolon (1985) cited in Snatiapillai & Jackson (1990) The Asian Elephant: An Action Plan for
its Conservation. World Conservation Union/ Species Survival Commission Asian Elephant Specialist Group.
Gland, Switzerland.
211
KKI Warsi, Frankfurt Zoological Society, Eyes on the Forest and WWF-Indonesia (14 December 2010b)
212
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).

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