## Greenhouse Gas Emissions from Palm Oil P roduction

Literature review and proposals from the RSPO Working Group on Greenhouse Gases

Final report

November 2009

Document prepared by:

# Table of contents

1 Introduction ......................................

................................................... .......................... 4

2 GHG emissions of palm oil production – literature r eview .......................................... 6
2.1 Introduction ......................................

................................................... .......................... 6
2.1.1 Scope of the literature review ....................

................................................... ................ 6
2.1.2 Methodology .......................................

................................................... ....................... 6
2.2 Results -qualitatively ............................

................................................... ..................... 7
2.2.1 Type of documents .................................

................................................... ................... 7
2.2.2 Categories of emissions ...........................

................................................... .................. 7
2.2.3 Units of calculation ..............................

................................................... ...................... 8
2.3 Emissions arising from operations during oil palm g rowing and FFB processing ....... 8
2.3.1 Emissions related to the use of fossil fuels for pl antation internal transport and

machinery .........................................

................................................... ......................... 9
2.3.2 Emissions related to the use of artificial fertiliz ers ............................................... ........ 9
2.3.3 Emissions related to the use of fuels in the palm o il mill, and the use palm oil mill byproducts (excluding POME) .........................

................................................... ........... 10
2.3.4 Emissions from POME ...............................

................................................... ............. 11
2.4 Emissions arising from changes in carbon stocks....

................................................... 13
2.4.1 General ...........................................

................................................... .......................... 13
2.4.2 Emissions from removal of aboveground and belowgrou nd biomass ........................ 13
2.4.2.1 Forest ............................................

................................................... ........................... 13
2.4.2.2 Grassland .........................................

................................................... ........................ 14
2.4.2.3 Emission from biomass decomposition ...............

................................................... .... 14
2.4.2.4 Emissions from biomass burning ....................

................................................... ......... 15
2.4.2.5 Carbon stocks on other forest landscapes ..........

................................................... ...... 15
2.4.3 Avoided emission through accumulation of biomass at palm oil plantations ............. 16
2.4.4 Emissions from peat decomposition .................

................................................... ....... 18 2.4.5 Net changes in carbon stocks .....................

................................................... ............. 20 2.4.5.1 Carbon stock balances .............................

................................................... ................ 20 2.4.5.2 Carbon payback times ..............................

................................................... ................ 21 2.5 Overall emission of palm oil production ...........

................................................... ...... 22 2.5.1 The OPCABSIM model ................................

................................................... ........... 22 2.5.2 Summary of emissions from palm oil production .....

.................................................. 24 2.5.3 GHG emissions from further transport and refinery .

.................................................. 25
2.6 Summary of conclusions ............................

................................................... .............. 26

3 Proposals by the GHG Working Group ................

................................................... ... 27
3.1 Introduction ......................................

................................................... ........................ 27
3.2 Developing a framework to reduce GHG emissions from palm oil production ......... 27
3.2.1 Literature study findings on carbon stocks (excludi ng peat) ...................................... 28
3.2.2 Literature study findings on peat .................

................................................... ............ 28
3.2.3 Developing a standard for the carbon intensity of p alm oil ........................................ 29
3.3 Proposals for amendments of RSPO Principles & Crite ria ........................................ 30
3.3.1 Plans to reduce GHG emissions .....................

................................................... .......... 30
3.3.2 Fossil fuel use ...................................

................................................... ....................... 313.3.3 Fertiliser use ....................................

................................................... ......................... 31

3.3.4 Palm oil mill residues ............................

................................................... .................. 32 3.3.5 POME ..............................................

................................................... ........................ 33
3.3.6 Water management on plantations on peat ...........

................................................... ... 33
3.4 Other conclusions recommendations .................

................................................... ...... 34 3.5 Procedural aspects ................................

................................................... ................... 35

4 References ........................................

................................................... ........................ 364



## 1 Introduction

When the RSPO Principles & Criteria were first agre ed in 2005, greenhouse gas (GHG) emissions from palm oil production were not a subje ct of particular attention within RSPO. Since then, a number of developments have changed t his.

Firstly, the attention for climate change in genera l has increased, and more specifically the contribution of certain land use (changes) to clima te change. A report by Delft Hydraulics [9], quantifying GHG emissions from peatlands in Indones ia, has put particular focus on the (perceived) contribution of the palm oil industry t o climate change.

Secondly, there is an increasing demand for GHG emi ssion information of products placed on the market. For example, European governments under the Renewable Energy Directive request GHG emission information of biofuels placed on the market, while international retailers are increasingly studying the ‘carbon foo tprint’ of the ingredients they use in food and cosmetics. In 2005, these developments were just ab out to start.

Thirdly, it has become increasingly apparent that t here is a relation between the two foregoing developments: additional palm oil demand, i.a. driv en by new biofuel markets, increases pressure on land for extension of plantation acrea ge, which may (indirectly) result in additional GHG emissions from land use change.

Given these recent and ongoing developments, RSPO h as concluded that sustainability of palm oil production can only be claimed when explicit co nsideration has been given to aspects of greenhouse gas emissions. GHG emissions shall get a clear position in the RSPO Principles &

Criteria. **The central question is: how and to what extent?**

To provide an answer to this question, RSPO in Marc h 2009 have established a Working Group on Greenhouse Gases (WG-GHG), for which Brinkmann C onsultancy was appointed as independent facilitator. The Terms of Reference of the Working Group have been included in Appendix I. The composition of the Working Group ha s been detailed in Appendix II.

Procedure followed by the GHG-WG Between March and May 2009, Brinkmann Consultancy e xecuted an extensive literature study on GHG emissions from palm oil production. Working Group members from all RSPO constituencies provided input to this study. The re sults of this study have formed the basis for
further discussions in the GHG-WG.

In May 2009, the GHG-WG held its first meeting. The GHG-WG’s preliminary proposals arising from this meeting, were summarized in the report ‘G reenhouse gas emissions from palm oil production – literature review and recommendations for amendment of RSPO Principles & Criteria’, dated 6 July 2009. This document was the n published on the RSPO website for a consultation period of 60 days (10 July – 10 Septem ber 2009), although there were some objections particularly from producers’ representat ives in the GHG-WG.5

During the 60 days consultation period, some 25 sta keholders –both RSPO members and nonRSPO members- presented their views through written submissions (available on www.rspo.org). In addition, two well-attended stake holder meetings were held in Jakarta (7 September 2009) and Sibu, Sarawak (9 September 2009 ). The inputs received during the public consultation were reviewed by the GHG-WG during its second meeting on 10 and 11 May

2009.

During its second meeting, the Working Group again discussed the literature review. Most GHG-WG members felt that the literature was compreh ensive and provided an objective overview of the issues pertaining to GHG emissions from the production and processing of palm oil. However, a group of stakeholders led by G APKI and MPOA expressed their opinion
that further work was needed. Also during the second meeting, the GHG-WG discusse d several proposals to the Executive Board, which have been summarized in this report. T hese proposals supersede the (preliminary) proposals summarized in the public co nsultation document of 6 July 2009.

After the public consultation meeting in Jakarta, I ndonesian producers felt that their ability to respond to the public consultation document had bee n seriously hindered by the absence of a translated version, and also because translation ha d not been available during (the first part of) the consultation meeting. The president of the Executive Board then decided t o extend the consultation period with a period of 20 days, until 30 September 2009. Due to time constraints, views submitted during the extended period of public consultation were not reviewed by the GHG-WG within its current mandate, but were directly submitted to th e Executive Board. The Executive Board, on the basis of the GHG-WG’s proposals and the additio nal input to the public consultation, will in October/November 2009 decide on further steps.

About this document This document comprises two main elements: Chapter 2 includes the results of the literature review on GHG emissions from palm oil production, e xecuted by Brinkmann Consultancy with inputs from the GHG-WG. Chapter 3 includes the GHG- WG’s proposals to the RSPO Executive
Board.

N.B. As stated above, the proposals outlined in thi s document supersede the draft proposals outlined in the document ‘Greenhouse gas emissions from palm oil production – literature review and proposals for amendment of RSPO Principl es & Criteria’, dated 6 July 2009.6



## 2 GHG emissions of palm oil production –

literature review

2.1 Introduction

2.1.1 Scope of the literature review
Numerous studies have looked into GHG emissions rel ated to the development and operations of oil palm plantations, processing of fresh fruit bunches at palm oil mills, as well as further transport, processing and end-uses of palm oil and palm oil derived products. In the framework of the GHG Working Group, a significant n umber of studies have been reviewed (Refer to Chapter 4 ‘Reference list’).

**The primary objective of the literature review has been to identify major categories of GHG**  **emissions during palm oil production, specify order s of magnitude for these emissions, and**  **highlight any (scientific) (un-)certainties as rega rds the (level of) GHG emissions from palm oil**  **production. The literature review is meant to provi de a solid, objective basis for discussions on**  **how to include GHG emissions in the framework of RS PO Principles & Criteria.** 

As RSPO Principles & Criteria focus primarily on pa lm oil production (and do not cover sustainability aspects of further downstream transp ort and processing of palm oil products)
the literature review has concentrated on GHG emiss ions related to growing oil palms, and processing of FFB in palm oil mills. GHG effects of further downstream transport and processing of palm oil products have not been consi dered, neither has a full LCA (methodology) for certain end-products been develop ed.

Both GHG emissions related to operations of existin g plantations, as well as emissions related to land use change when developing new plantations, have been considered (refer to 2.2.2 for more details).

2.1.2 Methodology GHG Working Group members have submitted publicatio ns which they thought would be
relevant in the framework of the literature review. Additional literature has been collected by Brinkmann Consultancy through internet search and v ia scientific libraries.

The literature collected and reviewed does not prov ide full coverage of all existing, potentially relevant, publications. However, the author believe s that the review covers all relevant issues in relation to GHG emissions from palm oil producti on, and is a good representation of the different scientific opinions on the subject. As stated in Chapter 1, most GHG-WG members felt th at the literature was comprehensive and provided an objective overview of the issues pertai ning to GHG emissions from the production of palm oil. However, a group of stakeholders led b y GAPKI and MPOA expressed their opinion
that further work was needed.

The main findings of the literature review have bee n summarized in this Chapter.7

2.2 Results -qualitatively

2.2.1 Type of documents The documents reviewed vary considerably in scope a nd size, and can be categorized as
follows:

• Life Cycle Assessments (LCA), to assess the GHG eff ects of a specific palm oil application, e.g. a well-to-wheel analysis for palm oil biodiesel (Refer e.g. to [33]). This
includes also studies which have been carried out f or the development of ‘CO 2 -tools’ by various European governments (Refer e.g. to [8], [27], [59], [41]);

• Studies which focus primarily on changes in carbon stocks, when palm oil plantations replace other land uses (Refer e.g. to [9], [22] an d [33]);

• Studies which focus on environmental impacts, inclu ding GHG emissions, of operations at oil palm plantations and palm oil mills (Refer e .g. to [64]);

• Other studies (Refer e.g. to [19] and [20]).

Studies have been executed by scientists and resear chers from various universities, research institutions and consultancy firms, primarily in So uth-East Asia and Europe. In addition, plantation industries, downstream palm oil processo rs/users, NGOs and governments, have commissioned and/or executed studies.

2.2.2 Categories of emissions In literature, GHG emissions from palm oil producti on have generally been categorised as follows [3], [41], [44]:

1. Emissions arising from operations during oil palm g rowing and FFB processing, or more precisely:
1a.Emissions related to the use of fossil fuels for plantation internal transport and machinery; 1b. Emissions related to the use of fertilizers; 1c. Emissions related to the use of fuels in the pa lm oil mill, and the use of palm oil mill by-products; 1d. Emissions from Palm Oil Mill Effluent (POME).

2. Emissions arising from changes in carbon stocks, du ring the development of new plantations, and during the operations of plantatio ns. This includes in particular changes in aboveground and underground biomass and soil organic matter (including peat).

The first category, emissions from operations, is d iscussed in Section 2.3. The second category, emissions from changes in carbon stocks, is discuss ed in Section 2.4.

In addition to the above specified categories of em issions, ‘GHG emissions from indirect land use change’ are regularly debated in the public dom ain, particularly in relation to biofuels (refer to Box 1 below). The GHG-WG has acknowledge d the relevance of this category of GHG emissions, but has concluded that there is still sc ientific lack of clarity how GHG emissions from indirect land use change can be quantified, and how they can be dealt with in the framework of a biomass sustainability certification scheme su ch as RSPO. As the focus here is on emissions8

which can directly be attributed to the RSPO unit o f verification, GHG emissions from indirect
land use have not been studied in detail. The GHG-WG recommends that RSPO will closely follow developments in science and policies towards measuring and attributing GHG emissions fro m indirect land use change, and
reconsider the issue once conclusions have been rea ched.

Box 1 GHG emissions from indirect land use change Indirect land use change occurs if the use of palm oil from an established plantation for biofuel purp oses leads to an establishment of new plantations on agr icultural land. The crops cultivated on that land a re ‘outcompeted’ and subsequently displaced to other a reas, i.e. ‘leaking’ from agricultural land into natural forests, for example. This indirect land us e change may result in significant GHG emissions, a s a result of changes in carbon stocks.

Policy makers are investigating possibilities to qu antify GHG emissions from indirect land use change, and how these shall be included in carbon balance/L CA methodologies. For example, the EU in Article 19.5 of the Renewable Energy Directive [12] states that: **‘The Commission shall, by 31 December 2010, submit a report to the European Parliament and to t**  **he Council reviewing the impact of indirect land-us e**  **change on greenhouse gas emissions and addressing w ays to minimize that impact. The report shall, if**  **appropriate, be accompanied by a proposal, based on the best available scientific evidence, containing**  **a concrete methodology for emissions from carbon stoc**  **k changes caused by indirect land-use changes, ensuring compliance with this Directive, in particu**  **lar Article 17 (2).’**

2.2.3 Units of calculation In literature, GHG emissions from palm oil producti on are either expressed ‘per hectare’ or ‘per tonne CPO/FFB’. A ‘per hectare’ basis is gener ally applied for emissions related to land use change and/or change in carbon stocks. A ‘per tonne CPO/FFB’ basis is generally applied for emissions related to operations at the plantation a nd mill.

In the literature review, both expressions have bee n quoted. However, for the purpose of comparing orders of magnitude, emissions ‘per hecta re’ have also been converted to a ‘per tonne CPO/FFB’ basis. For this conversion, a yield range of 3.2 - 4 tonnes CPO/ha*yr has been applied.

2.3 Emissions arising from operations during oil pa lm growing and FFB

processing

This section discusses emissions arising from opera tions during oil palm growing and FFB processing:

• Emissions related to the use of fossil fuels for pl antation internal transport and machinery (2.3.1);

• Emissions related to the use of fertilizers (2.3.2) ;

• Emissions related to the use of fuels in the palm o il mill, and the use of palm oil mill byproducts (2.3.3);

• Emissions from Palm Oil Mill Effluent (2.3.4).9

2.3.1 Emissions related to the use of fossil fuels for plantation internal transport and

machinery Fossil fuel use comprises mainly diesel consumption in agricultural machinery used in nursery, maintenance, harvesting, collection procedures, mil ling, and other estate internal transport.

Studies vary in the assumptions of how much diesel is required per hectare or per tonne of product.

Nikander [41] has estimated diesel consumption at 5 8-70 liters per hectare per year, and CO 2 - eq emissions at 3.1 kg CO 2 -eq per liter diesel, equaling 180-217 kg CO 2 -eq/ha*yr.

Damen and Faaij [7] have assumed that all transport within the plantation takes place with 5 tonnes capacity trucks, with a diesel consumption o f 1.8 MJ/tkm, and an average distance from harvesting to mill of 10 km (20 ton CO 2 -eq/TJ diesel). At their assumed FFB yield of 20 tonnes/ha this leads to a CO 2 -eq emission of 36 kg CO 2 -eq/ha*yr. This figure only covers FFB transport from harvest to mill.

Wood and Corley [61] have estimated energy use for vehicles and machinery at 4.7 GJ/ha*yr. Assuming a specific emission of 0.086 kg CO 2 -eq/MJ diesel, this would however result in an annual emission of 404 kg CO 2 -eq/ha*yr.

ERIA [11] have estimated diesel consumption at the plantation stage at 33 liter/ha*yr, for transport from plantation to mill at 1.5 liter per tonne FFB, and at the palm oil mill at 0.45 litre/tonne FFB. The study has assumed an average F FB yield of 19 tonne FFB/ha*yr, so that the overall diesel consumption equals 70 liters per hectare per year. The study has quoted a specific emission of 3.208 kg CO 2 -eq/ton diesel, resulting in an emission of 225 kg CO 2 - eq/ha*yr.

Conclusion: Based on the literature review, GHG emi ssions related to the use of diesel plantation internal transport and machinery, are in the order of 180-404 kg CO 2 -eq/ha*yr. Based on a yield range of 3.2-4 tonne CPO/ha*yr, GH G emissions per tonne of CPO are in the order of 45-125 kg CO 2 .

2.3.2 Emissions related to the use of artificial fe rtilizers Common palm oil fertilizer inputs comprise nitrogen fertilizers (either ammonium nitrate, ammonium sulphate, urea and/or ammonium chloride), phosphate rock (P 2 O 5 ), potassium chloride (K 2 O) and kieserite (MgO). Literature references on qu antities of fertilizer inputs have
been summarized in Table 2.1.

**Table 2.1 Fertiliser inputs in oil palm plantation s, according to various studies.**  Input Damen and Faaij [7] Corley [5] Nikander [41] ERIA [11] Ammonium nitrate (kg N/ha/yr) 100 - 96-100 93 Ammonium sulphate (kg N/ha/yr) -- 88.2 - - Phosphate rock (kg P 2 O 5 /ha/yr) 45 34.6 28-45 114 Potassium chloride (kg K 2 O/ha/yr) 205 252.0 172-205 200 Kieserite (kg MgO/ha/yr) 50 39.2 33-48 27

In the framework of a LCA study [4], Chen has calcu lated fertilizer inputs on a per tonne CPO basis. His figures are – converted to a per ha basi s- in the same order of magnitude as the figures specified in Table 2.1.10

GHG emissions related to the use of fertilizers in palm oil plantations comprise of two elements [7], [10], [11] [41], [44]:

• Emissions which occur during the production and (in ternational) transport of fertilizers, in particular due to the use of fossil fuels. Emissions vary between the type of fertilizers, as well as country and mode of prod uction;

• N 2 O emissions which occur during the application of n itrogen fertilizer. According to IPCC guidelines [27] 1% N 2 O-N of total N applied is emitted during fertilizer application. The Global Warming Potential of N 2 O is 296 times stronger than CO 2 .

Nikander [41] has estimated overall greenhouse gas emissions from fertilizer and pesticide use between 1,086 and 1,500 kg CO 2 -eq/ha*yr. N 2 O emissions during application of nitrogen fertilizer have been calculated at 616 kg CO 2 -eq/ha*yr, which amounts to 40-60% of total
fertilizer related GHG emissions.

Wijbrans and Van Zutphen [59] have estimated total GHG emissions related to the use of chemical fertilizers at 1,409 kg CO 2 -eq/ha*yr.

The default value of the greenhouse gas calculator of the UK Renewable Fuels Agency [44] is also in the range of 1,000 - 1,500 kg CO 2 -eq/ha/yr, whereby the exact value depends on the assumptions made as regards exact quantities and ty pe of fertilizers.

ERIA [11] have estimated that overall CO 2 -eq emissions related to the use of the fertilizer mix equal 17.3 kg CO 2 -eq/tonne FFB or, at 19 tonnes FFB/ha*yr, 330 kg CO 2 -eq/ha*yr. From the study, it is not clear why this value is so much lo wer than those from other references.

Wahid et al. [56] have estimated energy use by fert ilizers at 10.25 GJ/ha*yr, but do not specify what this figure exactly includes (production, tran sport, etc.).

N.B. GHG emissions resulting from the production of pesticides used in palm oil plantations, is generally considered negligible in comparison to th e GHG emissions from fertilizers (ref e.g. [38]).

Conclusion: Based on the literature review, GHG emi ssions related to the use of artificial fertilizers and pesticides, are in the order of 1,0 00-1.500 kg CO 2 -eq/ha/yr. Based on average yields (3.2-4 tonnes CPO/ha*yr), GHG emissions per tonne of CPO are in the order of 250 – 470 kg CO 2 -eq/tonne.

2.3.3 Emissions related to the use of fuels in the palm oil mill, and the use palm oil mill

by-products (excluding POME) The milling process requires steam, which is gener ated in boilers generally fuelled by fiber and shell. As these are both biomass streams, and boile r GHG emissions other than CO 2 are considered negligible, the energy generation proces s is CO 2 -neutral, and largely independent
from fossil fuels.

Another solid residue from the palm oil mill are e mpty fruit bunches (EFB). These can be used as mulch in the plantation, be composted or landfil led, or utilized as a biofuel, each of which has specific GHG emission characteristics. Application as mulch is currently common practice. Application as mulch has the potential to contribute to GHG emission reduction, as it may red uce the need for artificial fertilizers,11

improve carbon sequestration in the soil and soil o rganic matter. However, no quantitative
data on GHG effects are available. Like in various studies (e.g. [11], [41], [51]) it is concluded here that application of mulch is carbon neutral. Landfilling of EFB leads to methane emissions, as a result of anaerobic decomposition processes [43].

GHG emissions of further transport and treatment of palm kernels are not considered here. In LCA methodologies, generally part of the GHG emissi ons are attributed to by-products produced, refer to Box 2 below. However, as no full LCA is developed, this is considered less
relevant here.

Box 2. Allocation of emissions to by-products The production of Crude Palm Oil involves generatio n of by-products (PKO, PKM) and residues. In LCA methodologies, it is common to allocate the overall emissions associated with the production of the main product (CPO), between the main product and th e by-products. Various allocation methods exist, including:

1. **Allocation by market prices** , i.e. allocation of the emissions proportional to the market prices of the main product and the by-products;

2. **Allocation by energy content** , i.e. allocation of the emissions proportional to the total energy content of the main product and the by-products;

3. **System expansion** . The by-products are included in the project bound ary. For each by-product, the baseline production processes are identified. Respe ctively, the emissions associated with the producti on of the by-products in the absence of the activity a re included in the baseline emissions.

4. **Attributing all emissions to the main product** . As a conservative approach, all emissions from production process are accounted as project emissio ns where the main product is produced.

In this document, GHG emissions are expressed per t onne CPO, without allocating overall emissions between main product and by-products. As in method 4 above, this is a conservative approach, ignoring the fact that besides CPO other useful products are produced.

Conclusion: Efficient re-use of palm oil mill by-pr oducts and residues saves significant quantities of fossil fuels. Based on the literature review, it is assumed that no net GHG emissions arise from the use of fuels in palm oil m ills, and from the useful application of the palm oil mill by-products and residues.

2.3.4 Emissions from POME During the milling process, wastewater is produced, which is generally referred to as palm oil mill effluent (POME). The wastewater is heavily pol luted with biodegradable organic material, typically up to 80,000 mg/l COD, and needs treatmen t prior to discharge.

The most common POME treatment system consists of a pond or lagoon treatment system. The naturally available oxygen in this system is ge nerally insufficient to cater for all aerobic decomposition of the organic material in the wastew ater. As a result, the decomposition turns anaerobic, resulting in the production of biogas, w hich dissolves from the ponds into the atmosphere. POME derived biogas consists for a sig nificant part of methane (CH 4 ), which represents a substantial GHG emission source. Most studies indicate a typical methane content in biogas of 65% (e.g. [56], [8], [44]). Ya cob et al. ([63] and [64]), however, have measured lower methane contents (54% on average), w hich they attributed to the large variation in chemical properties of POME, and to th e lack of operational control of the tanks.

Wijbrans and Van Zutphen [59] have calculated that the POME methane release equals 9 kg/tonne FFB (at 0.7 m 3 POME/tonne FFB, 28 m 3 biogas/m 3 POME and 65% CH 4 in the biogas).12

This results in considerable extra GHG emissions of 190 kg CO 2 -eq per tonne FFB. The figure of

28 m 3 CH 4 / m 3 POME has also been mentioned by others as a ‘commo n practice’ figure (e.g.[8] and [44]).

Nikander [41] has used a POME emissions range of 2, 500 - 3,800 kg CO 2 -eq/ha*yr.

ERIA [11] has specified a POME generation rate of 0 .7m 3 /tonne FFB, 28 m 3 of biogas/tonne of POME (with 65% CH 4 ), and 19 tonne FFB/ha/yr.

Yacob et al. ([63] and [64]) have calculated a meth ane emission of 5.5 kg CH 4 /tonne POME discharged, equaling, some 9 m 3 CH 4 /tonne POME. This figure is significantly lower tha n all other data found in the literature review, and can most likely be attributed to the specific lay out of the treatment system monitored.

In recent years, palm oil mills have applied variou s technologies to improve the treatment of POME, while also reducing methane emissions. These include technologies for biogas capture, which is subsequently flared, or in some cases con verted to electricity/heat for local use. Flaring of biogas, or conversion of biogas to elect ricity and/or heat, results in conversion of
methane to CO 2 , which is biogenic: consequently, GHG emissions ar e reduced with a factor 23. Biogas capture technologies are eligible as CDM pro ject, thus having the potential of generating significant revenues through the sale of carbon credits. The efficiency of GHG emission reduction through biogas capture varies wi dely ([63] and [64]).

Another option for improved POME treatment is to co -compost the material with EFBs, thus generating a high quality compost with valuable C:N ratio, while also significantly reducing POME discharge. Schuchardt et al. ([48] and [50]) h ave demonstrated that this technology has the potentially to significantly reduce POME quanti ties, while Lord et al. [35] managed to achieve a zero discharge of POME.

Other technologies which contribute to reducing met hane emissions from POME include decanters prior to pond treatment, thus removing a significant amount of suspended solids, as well as denitrification technologies. No literature data have been found on the practical applications and the efficiency of these technologi es.

Conclusion: Based on the literature review, GHG emi ssions from POME, are in the order of 2,500 – 4,000 kg CO 2 -eq per ha*yr, or 625 – 1,467 kg CO 2 -eq per tonne CPO (based on a yield range of 3.2-4 tonnes CPO/ha). Various technologies have the potential to signific antly reduce methane emissions from POME, including biogas capture, decanters, co-compo sting with EFB, and denitrification. Emission reduction efficiencies for biogas capture technologies vary considerably in practice. For other technologies, no quantitative data on emi ssion reduction efficiency have been
found.13

2.4 Emissions arising from changes in carbon stocks

2.4.1 General This Section reviews emissions arising from changes in carbon stocks, during the development of a new plantation, and during the operations of a plantation. These emissions are in particular related to changes in aboveground and un derground biomass, as well as soil organic matter (including peat).

Establishing and operating palm oil plantations may have three different impacts upon aboveground and belowground carbon stocks, namely [ 27], [19]:

• The establishment of a plantation leads to the remo val of originally present aboveground and belowground biomass, e.g. forest, g rassland;

• A palm plantation stores carbon through the growth of oil palms;

• Establishing and operating oil palm plantations on peat requires ongoing drainage, thus causing ongoing peat oxidation.

These impacts are discussed separately in Section 2 .4.2-2.4.4. Section 2.4.5 discusses the overall effects of palm oil plantations on carbon s tocks.

2.4.2 Emissions from removal of aboveground and bel owground biomass This section discusses greenhouse gas emissions whi ch arise when original biomass present on land, is removed to make way for a new oil palm pl antation.

The GHG emission which results from changes in abov eground and underground biomass, depends on the original biomass stock present on th e land, as well as the question whether original biomass is removed through decomposition, or through burning.

Available literature data concentrate on biomass of intact forests and grasslands. Very limited
data have been found on biomass stock of other land cover types typical for areas where oil palm is developed, such as degraded forests, logged over forests, shrub land, etc. Below, first the typical biomass stock for intact f orests and grasslands present in areas suitable for oil palm development are discussed (Section 2.4 .2.1 and 2.4.2.2). Secondly, GHG emissions from the removal of these biomass stocks, either th rough decomposition or burning, are discussed (Section 2.4.2.3 and 2.4.2.4). Finally, l iterature data on carbon stocks from other landscapes have been summarized (Section 2.4.2.5).

**N.B. Literature data concentrate on intact primary forests and grasslands. In reality, palm oil in**  **many cases is established on forest lands that have been logged at least once or have been**  **degraded through intensive shifting cultivation or fire. The literature references on carbon**  **stocks quoted here will in many cases be too high, and effectively represent a worst-case**  **scenario. Equally, grasslands may in reality have l ower carbon stocks than quoted here, in**  **particular when these grassland are fire dominated.**

2.4.2.1 Forest The quantity of biomass in intact tropical rain for ests varies greatly in response to the local environment, whereby the biomass of tropical lowlan d forests is usually higher than that of upland forests. Germer and Sauerborn [15] have done an extensive review of available data for above ground biomass quantities, and derive a mean value of 295 +/- 152 tonnes/ha for14

intact tropical lowland forests. This is in line wi th the IPCC [29] default values for above ground biomass of 225 tonnes/ha in continental Asia, and 2 75 tonnes/ha in insular Asia.

The belowground biomass is a function of the aboveg round biomass, whereby the ratio between the two may vary depending on local circums tances. On the basis of a large number of literature sources, Germer and Sauerborn [15] ha ve derived a mean ratio of 0.18 between aboveground and underground biomass, which is sligh tly higher than the IPPC [29] default value. Based on the ratio of 0.18, they calculated a mean value for belowground biomass of 47 +/- 26 tonnes/ha.

Based on the above figures, Germer and Sauerborn [1 5] have calculated the total above and belowground biomass of tropical lowland forests to be 342 +/- 178 tonnes/ha. Based on their assumption that the carbon content of biomass is 50 %, which is also in line with the IPPC default value, this equals a carbon stock of 171 +/ -89 tonnes/ha.

2.4.2.2 Grassland The grassland biomass is determined by the floristi c composition, precipitation, soil properties, fire, wildlife and other factors. The IPCC [29] def ault value for above ground biomass on tropical savanna ranges from 4.9 tonnes/ha to 6.6 t onnes/ha, whereby a savanna is defined as ‘vegetation formations with a predominantly continu ous grass cover’. A review of literature on typical Imperata grasslan d in oil palm growing regions reveals an average value for aboveground biomass of 11.2 +/-7. 3 tonnes/ha, which is higher than the IPCC range [15]. It is hypothesized that this diffe rence in biomass reflects the usually high soil fertility and favorable rainfall in areas suitable for palm oil production.

No default values for grassland belowground (root) biomass is given in the IPCC reference manual and studies published on grassland root biom ass in humid tropics are limited. Germer and Sauerborn [15] have calculated a value for gras sland belowground biomass of 15.5 +/-10.1 tonnes/ha.

Germer and Sauerborn [15] have concluded, on the ba sis of available data, that the biomass of grassland (aboveground and belowground) in oil palm suitable environments is 26.7 +/- 17.4 tonnes/ha. Based on their assumption that the carbo n content of biomass in grassland is 43%, this equals a carbon stock of 11.5 +/- 7.5 tonnes/h a.

2.4.2.3 Emission from biomass decomposition Oil palm plantation establishment requires the remo val of the existing forest or grassland plant cover. After clearing, the biomass is, if not burne d, broken down by termites, insects and micro-organisms. Decomposition emits the carbon con tained in the biomass into the atmosphere as CO 2 . A fraction of the carbon is released as methane t hrough the activity of termites. Due to the uncertainty of the effect of c learing on termite populations and associated methane release, no guidance on calculat ion of this component in included in the IPCC methodology [29].
The CO 2 released by decomposition is estimated as a direct function of biomass volume and carbon content. IPCC [29] have estimated a carbon c ontent of 50% for all carbon stocks. For Imperata cylindrica grassland, additional research has provided a figure of 43% [15].

Decomposition of cleared aboveground biomass and ro ot biomass is a long process. After cutting the vegetation there is an initial rapid lo ss of easily decomposable root biomass, leaving behind a large fraction of resistant materi al. Germer and Sauerborn [15] have indicated15

that exact figures on timelines and percentages dec omposed are unknown. However, they assume a complete decay of biomass within a timefra me of 25 years, leading to a total emission from biomass decomposition of 42.0 +/- 27. 4 tonnes CO 2 -eq/ha grassland, and 627 +/-326.3 tonnes CO 2 -eq/ha of primary forest. These emission figures ar e equivalent to the removal of a carbon stock of 11.5 +/- 6.7 tonnes C/ ha of grassland, and 171 +/- 89 tonnes C/ha of primary forest.

2.4.2.4 Emissions from biomass burning Emissions from burning the cleared vegetation depen d on the degree of combustion that is achieved, i.e. the proportion of biomass consumed b y fire. The IPCC guidelines [29] have
stated a default combustion fraction of 50% for cl eared forest biomass, while the guidelines also recommend to adjust the value to actual local conditions. Germer and Sauerborn [15] have indicated that as a result of repeated burning , some 40% of the carbon contained in above ground biomass from forest clearing enters th e atmosphere through combustion, while the rest is released through decomposition, and als o some of the remainder is converted into
charcoal.

Grassland aboveground consists mainly of inflammabl e material, which admits a higher combustion fraction than in forest clearings. The I PCC [29] has recommended general default values in the range from 80% to 85%, if detailed lo cal information is not available.

Germer and Sauerborn [15] have calculated total emi ssions of aboveground biomass burning and the decay of unburned above and belowground bio mass to be 43.5 +/- 28.3 tonnes CO 2 -eq per hectare of grassland, and 648.0 +/- 337.2 tonne s CO 2 -eq per hectare of primary forest. These emission figures are equivalent to the remova l of a carbon stock of 11.8 +/- 7.7 tonnes C/ha of grassland, and 176 +/-92 tonnes C/ha of pri mary forest.

Conclusion: Based on the literature review, GHG emi ssions from removal of aboveground and underground biomass in intact primary forests a re in the order of 635 +/- 330 tonne

CO 2 -eq/ha. GHG emissions from removal of aboveground a nd underground biomass in tropical grasslands are in the order of 43 +/-28 to nne CO 2 -eq/ha. These figures equal a carbon stock change of 171 +/ - 89 tonnes Carbon/ha for intact primary forests, and 11.5 +/- 7.5 tonnes Carbon/ha for gras slands.

2.4.2.5 Carbon stocks on other forest landscapes Morel [39] has summarized data of above ground carb on stocks of different forested land covers in Sabah. She found aboveground carbon stock s of unlogged forest to be around 278 tonnes C/ha, and aboveground carbon stocks of logge d forest in the range of 101 – 158 tonnes C/ha, depending on the year of logging. The Sabah F orest Research Centre measured aboveground carbon values ranging from 51 to 84 ton nes C/ha, for high to low disturbed
forests.

Morel [39] has also quoted a range of biomass value s reported in literature for a number of forested land cover types across Malaysia and Indon esia. These have been summarized in
Table 2.2 below.16

**Table 2.2 Carbon values reported for a number of fo rested land cover types [39].** 
Forest Type Tonnes carbon/ha Peninsular Malaysia Logged hill 90
Forest fallow 70 Freshwater swamp 110 Disturbed freshwater swamp 142.5

Borneo – Sarawak Mixed diterocarps-dense stocking (flat to undulatin g) 162.5-192.5 Mixed dipterocarps –dense stocking (mountainous) 33 0-405
Borneo – Sabah Lowland Dipterocarp (logged and unlogged) 32-323.9

Borneo – Kalimantan Fallows (range of years since cleared) 13-25.5

Conclusion: The carbon stocks of logged over forest s, and forests with various levels of disturbance, show large variations and generally ap pear to be in between the ‘extreme’ values of undisturbed primary forests and grassland s, as highlighted in the previous sections.

2.4.3 Avoided emission through accumulation of biom ass at palm oil plantations Biomass at oil palm plantations can be categorized as follows:

• Aboveground biomass, i.e. the oil palm trees exclud ing roots;

• Belowground biomass, i.e. the oil palm tree roots;

• Litter from oil palm trees and other vegetation;

• Biomass of ground cover vegetation.

According to [15], the typical biomass accumulation in tree plantations follows a curve of quick initial growth and thereafter a minor increase. A l inear equation to calculate the carbon stocks as provided in ‘Good Practice Guidance for and use, land use change and forestry’ by the IPCC
tends to underestimate actual values.

The amount of carbon bound in oil palm plantation b iomass is primarily a function of palm growth and the understorey. Published values on the quantity of above ground biomass on oil palm plantations range from 50 tonnes/ha to over 10 0 tonnes/ha towards the end of the plantations economical live span after 20-25 years. The root biomass of oil palm increases with the abo veground biomass increase, while its maximum volume depends strongly on soil properties and water availability. Germer and Sauerborn [15] have calculated a time-averaged oil palm root biomass of 20 +/- 5 tonnes/ha. Biomass of ground cover vegetation decreases with p alm growth and heavier shade. Germer and Sauerborn [15] have calculated a time-averaged total ground cover biomass of 2.5 +/- 1.0 tonnes/ha (assuming a fast ground cover establishme nt with a maximum of 10 tonnes/ha and a linear biomass loss through increased shading to 1 tonne/ha at canopy closure at 5 years after planting).

Based on the above figures, Germer and Sauerborn [1 5] have calculated a time-averaged total quantity of (above and belowground) biomass in an o il palm plantation of 82.5 +/- 26 tonne/ha. Considering a carbon content of 40.4% fo r oil palm biomass (Syahrinudin, 2005, in [15]) and of 50% for remaining vegetation, both pal ms and understorey together fix a time averaged quantity 35.3 +/- 11.0 tonne carbon/ hecta re within the economic lifespan of oil palm (equaling 129.3 +/- 40.3 tonne CO 2 -eq/hectare).17

In Figure 1, taken from [15], biomass data from 51 oil palm fields were plotted. Integration of the fitted equation returns a time averaged oil pal m **aboveground** biomass of 60 +/- 20 tonnes biomass/ha for 25 years after planting, where the s tandard deviation is an estimation taking the large variation of the plotted data into accoun t.

**Figure 1. Increase in biomass (tonnes/ha) as a func tion of palm age [13].** 

Henson [22] has also quantified carbon sequestratio n of oil palms in Malaysia. The mean carbon sequestration of an oil palm stand with a 25 year life was found to total 2.09 tonnes carbon/ha/yr (equaling 7.66 tonnes of CO 2 -eq), with the oil palms accounting for 80% of the mean carbon storage by the system (and ground cover , litter, and palm products accounting for the remainder 20%). The total carbon accumulate d by the palms at the end of the cycle comes to 44 tonnes C/ha. The time averaged in situ standing plantation carbon stock over 30 years was calculated to be 35.4 tonnes/ha, which is similar to the 25 year mean value of 35.3 tonnes carbon/ha for oil palm and understorey deter mined by Germer and Sauerborn [15], and with a later value by Henson [23] namely 35.87 tonne carbon/ha. Henson has indicated that this figure includes litter in plantations, ho wever that the quantity is generally limited compared to the overall figure (also refer to Table 5 in [25]. In addition to the above quantified carbon sequestr ation Henson ([22] and [25]) has identified and quantified other sources of carbon sequestratio n, including harvested wood products during forest conversion, residues left after palm tree or forest clearing, mill by-product energy generation and mill by-product fertiliser substitut ion. The potential carbon sequestration has been calculated at 0.615 tonnes/ha*yr. In carbon ac counting methodologies [30], only the carbon contained in wood products can be counted as ‘sequestered’, as for the other sources
it is assumed that it will be released within a rel atively short timeframe (due to consumption or end of life of products).

Morel [39], on the basis of field measurements at o il palm plantings in Sabah, calculated a weighed averaged value of 24.2 tonnes carbon/ha for aboveground biomass, assuming a 25 year planting period. Syahranudin [49] found a value of 84.6 tonnes carbo n/ha for 30 years palm oil plantings, of which 62.8 tonnes C/ha was aboveground biomass, and 21.8 tonnes C/ha was underground biomass. Jiwan and Saharjo [31] found an abovegroun d carbon stock of approximately 4018

tonnes/ha, for a 25 year oil palm plantings in East Kalimantan. Both studies have not calculated time averaged carbon stocks on oil palm plantings.

The time averaged carbon stock of approx. 35 tonnes C/ha, as calculated by various authors using different approaches (see above) is lower tha n the figure of 55 tonnes C/ha, used by the
IPCC as default value. No references have been foun d as to how the IPCC figure has been
derived.

Conclusion: Based on the literature review, the tim e averaged carbon stock in an oil palm plantation appears to be in the order of 35 tonnes carbon/ha, calculated over a 25-30 years standing period. Some literature sources quote high er time averaged figures, while others quote lower figures. With multiple planting cycles, the time averaged standing stock is expected to remain close to 35 tonnes/ha, as biomas s is removed prior to re-planting.

2.4.4 Emissions from peat decomposition In the past few years, CO 2 emissions from drained peatlands in South-East Asi a have been the subject of a fierce debate, which included in parti cular also the perceived contribution of the palm oil sector. This section summarises scientific certainties and uncertainties as they appear
from reviewed international literature.

Box 3. Definitions of peat There is not one single, agreed definition for peat . M. Mohamed et al. [38] provide the following guidance:

‘ **Peat in strict definition usually refers to the acc umulation of a purely one hundred percent organic**  **material and the distinction between soil and veget ative accumulation is not clear (Andriesse, 1992).**  **Over the years, ‘peat’ has been alternately referre d to as ‘organic soils’ and Histosoils. Tie (1979)**  **refers to peat as organic soils on the basis of the mass c**  **omposition i.e. soils that contain at least 65% org anic**  **matter or conversely, less than 35% mineral conten t. The more recent definition of organic soils as**  **adopted by the Soil Division of Sarawak is based on profile partition, i.e. soils that have 50 cm or m**  **ore organic soil matter within 100 cm or more than twic**  **e that of mineral soil materials overlying bedrock within 50 cm (Teng, 1996). On the other hand, USDA**  **defines a soil type as organic soils (or Histosols) if**  **more than half of the upper 80 cm of the soil is or ganic or if organic soil material of any thickness**  **rests on rock or on fragmented material having interstice**  **s filled with organic materials (Soil Survey Staff, 1998)**  ’.

Wetlands International ( www.wetlands.org ) provides the following definition: ‘Peat is dead organic material that has been formed on the spot. Peat con sists of 90% water and 10% plant matter. Peat is formed under conditions where dead plant material i s conserved for thousands of years due to a combination of permanent water saturation, low oxyg en levels and a high level of acidity. Areas with peat soils are called peatlands’.

And the Peat Society ( www.peatsociety.org ) provides the following definition: ‘ **Peat is sedentarily accumulated material consisting of at least 30% (dr**  **y mass) of dead organic material. A peatland is an area with or without vegetation with a naturally ac**  **cumulated peat layer at the surface** ’.

Experts agree that in their natural state, tropical peatlands sequester carbon by accumulation in peat and biomass (e.g. [22], [15] and [54]). Dra inage and degradation of primary peat forests results in carbon losses mainly through increased d ecomposition of the peat. Conversion of peatlands to oil palm plantations requires drainage of 60-80 cm below soil surface which thus enhances peat decomposition.

CO 2 -emissions increase with drainage depth, with a fig ure of 9 tonnes of additional CO 2 emission for every extra 10 cm drainage depth quote d by various authors (e.g. [61]). Given the19

range in data available for overall emissions (see below), this figure is unlikely to be very
robust.

Conclusion: Experts agree that in their natural sta te, tropical peatlands sequester carbon by accumulation in peat and biomass. Drainage and degr adation of primary peat forests results in carbon losses mainly through increased decomposi tion of the peat. Conversion of peatlands to oil palm plantations requires drainage of 60-80 cm below soil surface which thus enhances peat decomposition. CO 2 -emissions increase with drainage depth.

The database of CO 2 -emission values from drainage and fire is still po or. Most published CO 2 emission data for both intact and damaged peatlands stem from closed chamber measurements of total (soil) respiration. These mea surements cover not only heterotrophic but also autotrophic emissions from the living root s and low vegetation. With the possible exception of some of the measurements of Vasander a nd Jauhiainen [54] and Melling et al. [36], none of the numerous soil respiration studies from tropical peat soils convincingly manages to exclude autotrophic (root) respiration o r short term litter turnover. As the root respiration component may vary between 6 and 67% of the total CO 2 emission from peat soils, these studies are inadequate for determining net em issions from peat oxidation.

Melling et al. [36] have attempted to exclude root respiration by ‘trenching’, i.e. inserting a cylinder into the peat severing roots well before f lux measurements and – without indication of drainage depth- arrive at heterotrophic soil flu x rates from a 5 year old oil palm plantation of 3.4 – 4.1 kg CO 2 /m 2 *yr. The measurement method (chamber design and sam pling method)
tends to underestimate CO 2 fluxes by 15-20% [36] or more, however, which mean s that the actual flux may amount to more than 4.9 kg CO 2 /m 2 *yr.

Other, longer term lifecycle analyses also all arri ve at clearly negative values for CO 2 emissions from peat degradation, e.g. 1.8 kg CO 2 /m 2 *yr [15], 3.7-5.5 kg CO 2 /m 2 *annum [43], 3.9 kg

CO 2 /m 2 *yr [58], and 5.5-7.3 kg CO 2 /m 2 *yr [13]. Muruyama and Bakar [44] have estimated a

CO 2 -emissions of oil palm plantations on peat of 54 to nnes CO 2 -eq/ha*yr, at 80 cm drainage depth.

Henson [22] has concluded that there is still great uncertainty concerning the magnitude of peat soil carbon emissions and their relationship t o drainage intensity and peat subsidence. He cites values of 7.2 tonnes carbon ha/yr [61] and 9. 17 tonnes carbon/ha/yr [36]. This equals emissions of approximately 25 to 35 tonnes CO 2 -eq/ha*yr.

Conclusion: There is a large variety of quantitativ e data on CO 2 -emissions from drained peatlands, while not all measurement methods applie d are reliable in terms of quantifying emission from peat oxidation. Literature data vary between 18 – 73 tonnes CO 2 /ha*yr (4.9- 19.9 tonnes carbon/ha*yr). Based on a yield range of 3.2 to 4 tonnes CPO/ha, t his would lead to emissions of 4.5 - 22.8

tonnes CO 2 /tonne CPO. Expressed in quantities of carbon, this range equals 1.2 – 6.2 tonnes carbon/tonne CPO.

In relation to other relevant GHG, in particular N 2 O and methane, the following appears from
literature:

• Nitrous oxide emissions from primary and secondary forest sites vary between -63 μg

N 2 O/m 2 *hour, and 916 μg N 2 O/m 2 *hour, with 90% of the measured values below 125 μg N 2 O/m 2 *hour (reference).

• Methane emissions show a clear relationship to wate r level with values generally low (and often negative) for water levels below -20 cm and higher and more variable at20 higher water levels. Methane emissions from tropica l peat swamps are small due to the recalcitrance of the material. Restoration (rew etting) of drained peat soils is unlikely to lead to methane emissions that negate g ains in the reduction of CO 2 emissions (Wilson et al. [57]).

Conclusion: Carbon sequestration and emission fluxe s in natural peat swamps are some orders of magnitude smaller than the carbon losses from oxidation of drained peat soils.
Methane and N 2 O emissions from both natural peatlands and from oi l palm plantations on peat, are limited.

Vasander and Jauhiainen [54], like a number of othe r authors (e.g [1]) have made an analysis of uncertainties and gaps in current knowledge, com prising both GHG emissions from natural peatlands and from drained peatlands, and urge for additional research to further quantify data, ‘in particular ecosystem-level measurements o f gaseous carbon and other GHG fluxes together with process based studies in order to det ail further true overall carbon balances on undrained, degraded and developed tropical peatland ’. Despite the indicated need for further detailing of existing data, also these authors expl icitly conclude that ‘tropical peat swamp forests form one of the most efficient carbon seque stering ecosystems and important carbon stores and that drained peat ‘results in an abrupt and permanent shift in the ecosystem carbon
balance from sink to source’.

Conclusion: Various authors have indicated the need to further detail data on GHG fluxes in both undisturbed and drained peatlands. However, th is research is not expected to change overall Conclusions 1-3 above, but rather refine an d narrow down the data ranges.

2.4.5 Net changes in carbon stocks

2.4.5.1 Carbon stock balances Based on the figures specified in sections 2.4.1-2. 4.4 above, net carbon stock changes have been calculated for the conversion of intact primar y forest and grassland to a palm oil plantation. For peat, only the carbon stock change caused by peat decomposition **in the first**

**year** has been calculated. Values have been summarized i n Table 2.3.

Again, it needs to be emphasized that in practice o il palm is developed on forest land where in many cases carbon stock values are lower, due to pr evious logging or degradation, and that the figures mentioned are a worst-case scenario.21

**Table 2.3 Carbon stock change (tonnes carbon/ha) fo r plantation replacing grassland and intact primary**  **forest.**

Plantation replacing grassland Plantation replacing

forest on mineral soil Plantation replacing forest on peat soil

Time averaged carbon stock of previous land use 11.5 +/- 7.5 171 +/-89 171 +/- 89

Time averaged carbon stock of oil palm 35 35 35

Carbon stock loss as as result of one year of peat decomposition 2 0 0 4.9 to 19.9 (annually)

Net change in carbon stock +16 to +31 -47 to -225 -52 to -245 (after one year)

**Notes:**

**1 A positive sign indicates a net increase in carbon**  **stock**

2 **Peat decomposition is an continuous process. For il lustration purposes, only the carbon stock change i**  **n the first year has been quantified here. Over a 25**  **year period, the time averaged net change in carbon stock will range from -169 to -723 tonnes**  **(=net loss)**

Henson [22] has examined the carbon balance of oil palm cultivation and palm oil production in Malaysia over the 25 years from 1981 to 2005. He concludes that ‘both the present and
other studies cited have demonstrated that the natu re of land use change leading to oil palm planting is all important in determining whether th e crop constitutes a net sink or source of GHG emissions and whether oil palm cultivation redu ces or increases, the threat of global warming’.

Conclusion: The carbon loss which occurs when tropi cal forest is converted to oil palm plantation, by far exceeds the carbon sequestration during one cycle of oil palm growth (25 years). The overall carbon loss is further enhanced when the oil palm plantation is located on peat. When oil palm plantations replace grasslands, carbon sequestration exceeds carbon loss by conversion of grass lands. In that case, pa lm oil plantations act as a net carbon sink.

2.4.5.2 Carbon payback times The terms ‘carbon payback times’, ‘carbon debt’ or equivalent are mostly used in discussions on the GHG balance (well-to-wheel assessments) of b iofuels. The carbon payback time has been defined as the number of years required for av oided fossil fuel emissions from biofuels to compensate for losses in original carbon stocks dur ing land conversion.

Gibbs et al. [16] have calculated ‘carbon payback t imes’ for a number of biofuels, including palm oil biodiesel. The study concludes that under current conditions, the expansion of biofuels into productive tropical ecosystems will a lways lead to net carbon emissions for decades to centuries, while expanding into degraded or already cultivated land will provide almost immediate carbon savings. No foreseeable cha nges in agricultural or energy technology will be able to achieve meaningful carbon benefits if crop-based biofuels are produced at the expense of tropical forests. For biodiesel from palm oil, a carbon payback time was calculated for 30-120 years for nonepeat soils in South-East Asia, and more than 900 ye ars for forests on peatlands. The study concluded that degraded lands in Southeast Asia, co uld provide immediate carbon benefits. However, it also notices that growing biofuel crops on these marginal lands may require significantly more land area than other regions due to relatively lower yields, and will likely22

require more energy-intensive management such as in creased fertilizer application to remain productive.

Fargione et al. [13] have also concluded that conve rting native forests to biofuel production results in large carbon debts: ‘converting lowland tropical rainforest in Indonesia and Malaysia to palm biodiesel would result in a biofuel carbon debt of 610 tonne/ha of CO 2 -eq that would take approximately 86 years to repay’.....’Converting tropical peatland rainforest to palm production incurs a similar biofuel carbon debt fro m vegetation, but the required drainage of peatland causes an additional sustained emission of approximately 55 tonnes of CO 2 -eq/ha/yr from oxidative peat decomposition’....’Peatland of av erage depth (3m) could release peatderived CO 2 -eq for about 120 years. Total net carbon released would be approximately 6,000 tonne/ha of CO 2 -eq, taking 840 years to repay’.

Conclusion: Calculations on carbon payback time –th ough solely used for biofuels – reinforce
the conclusion that intact forest conversion for oi l palm plantation leads to very high GHG emissions, which takes decades to centuries to offs et, through replacement of fossil fuels and carbon sequestration by oil palms. Producing on peat results in even longer payback
times.

2.5 Overall emission of palm oil production

2.5.1 The OPCABSIM model In the literature review, only one study has been f ound which specifically models the overall greenhouse emissions of palm oil production. This i s the OPCABSIM model developed by Henson [23]. In his study, he has illustrated the m odel with four calculation examples, which
have been summarized in the box below. From the mod el calculations it appears that the order of magnitude of emissions is comparable to th e results above. Specific emission figures are difficult to assess, as references to specific sources are limited [23].

The examples have been abbreviated as NA, CS, IS an d PS, and can be summarized as follows:

• NA stands for national average oil palm and represe nts the average performing Malaysian crop. It is assumed to grow on mineral so il, to have replaced a previous crop of rubber, is grown without return of mill by-produ cts to the field, and is to be replanted after 25 years

• CS stands for a coastal (soil) site, whereby it was assumed that the previous crop was oil palm

• IS stands for an inland site , low to medium produc tive, with preceding vegetation being grassland.

• PS stands for peat soil.23

**Table 2.4 Four calculations examples with the OPCAB SIM model (Henson, [23], all data are in tonnes**  **Ceq/ha*yr).**

NA CS IS PS

Carbon gains Oil palm -1.628 -2.015 -1.902 -2.021 Includes roots

Ground cover -0.059 -0.048 -0.052 -0.095 Includes cover litter Oil palm litter -0.172 -0.217 -0.185 -0.191 Frond piles etc Mill-by products 0 0 0 0 Assumed not returned Total gains -1.859 -2.280 -2.139 -2.307

Carbon
losses Peat C oxidation 0 0 0 +8.032 Mean rate over 25 yea rs

Plantation inputs +0.333 +0.333 +0.333 +0.392 Base d on fossil fuel use
N2O emission –fertil. +0.166 +0.166 +0.166 +0.176 From N fertiliser N2O emission – peat 0 0 0 +0.148 From peat
Initial biomass loss +2.466 +2.280 +0.199 +3.474 N A: Mature rubber CS: Mature oil palm
IS: Grassland PS: Secondary forest
Total losses +2.965 +2.779 +0.698 +12.222

Carbon
balance +1.105 +0.499 -1.441 +9.915

Off-site budget

items
Carbon gains Mill products and byproducts -0.079 -0.127 -0.125 -0.226 CPO, PKO, kernel cake, EFB, fibre, shell, POME

Carbon
losses CH4 from POME +0.671 +0.900 +0.650 +0.759

On plus
off-site budget

Total
Carbon gains -1.938 -2.407 -2.264 -2.533

Total C
losses +3.636 +3.679 +1.348 +12.981

Carbon
balance +1.698 +1.272 -0.916 +10.448

(NA = national average; CS = coastal site; IS = inl and ; PS = peat soil) Note: a positive sign indicates a net GHG emission24

2.5.2 Summary of emissions from palm oil production Sections 2.3 and 2.4 have quantified relevant GHG e missions from palm oil production, both from operations at plantations and mills, and from changes in carbon stocks. The categories of GHG emissions, and concluded orders of magnitude, a re summarized in the table below

**Table 2.5 GHG emissions from palm oil production, i ncluding emissions from carbon stock changes (all**  **emissions on a kg CO 2**  **-eq/ha and kg CO 2**  **-eq/tonne CPO basis).**

GHG emission
factor Emissions per ha

**(kgCO 2**  **-eq/ha*** **annum)** Emissions per tonne CPO **(kg**

**CO 2**  **-eq/tonne CPO)** Note

1.Operations
1a. fossil fuel use transport & machinery +180 to + 404 +45 to + 125 -

1b. fertilizer

use +1,500 to +2,000 + 250 to + 470 -

1c. fuel of mill
& utilization ofmill byproducts 0 0 -

1d. POME +2,500 to +4,000 + 625 to + 1,467 -

**Total operations**  **+4,180 to +6,225 +920 to + 2,007** -

2.Emissions
from carbon stock change 2a. 25 year
discounted

GHG emission
from
conversion of

grass land/forest +1,700 to + 25,000 +425 to +7,813 Based on a carbon stock change of 11.5 – 171 tonnes C/ha, which is discounted over 25 years and expressed

as CO 2

2b. Annual
carbon sequestration by oil palms - 7,660 -1,915 to -2,393 Henson [22]

2c. Emissions from oil palm
on peat +18,000 to + 73,000 +4,500 to +22,813 -

**Total emissions**
**related to**
**carbon stock change**  **+12,040 to +90,340 +3,010 to + 28,233** -

Total **+16,220 to 96,565 +3,930 to +30,240** - **Note: a positive sign indicates a net GHG emission**

The above calculation clearly indicate that convert ing high biomass carbon stocks to oil palm plantation, i.e. forests and/or peatlands, causes b y far the highest GHG emissions. This confirms the conclusion of most literature, e.g. Za h et al. [67], who in a life cycle assessment of various biofuels (including palm biodiesel), conclu ded that **‘...most of the environmental impacts of biofuels are caused by agricultural cult**  **ivation. In the case of tropical agriculture this**25

**is primarily the slash-and-burning of rainforests w hich sets great quantities of CO**  **2 free, causes**  **air pollution and has severe impacts on biodiversit y’.** 

2.5.3 GHG emissions from further transport and refi nery The previous Sections have focused on quantifying G HG emissions from palm oil production, and have not quantified GHG emissions from further transport, processing etc. To put the GHG emissions from palm oil production in perspective, this Section summarises GHG emissions from further transport and refinery of palm oil.

**Transport** Nikander [41] has calculated GHG emissions related to palm oil transport by ship, from Malaysia to Rotterdam (ship load 40,000 tonnes), an d further to Porvoo (ship load 12,500 tonnes). He estimated total GHG emissions for the 1 7,300 km journey at 106 kg CO 2 -eq/tonne palm oil.

The (conservative) default values in the RFA CO 2 -calculation tool [44], for over land transport of palm oil (mill to port) and overseas transport, have been summarized below:

**Table 2.6 RFA default values for GHG emissions from palm oil transport.**  Type of
transport Distance Fuel use Specific emission Total GHG emiss ion

Mill to port 250 km 1.89 MJ/t km diesel 0.086 kg CO 2 -eq/MJ
fuel 41 kg CO 2 -eq/tonne

Overseas
transport 16,500 km 0.2 MJ/ t km HFO 0.087 kg CO 2 -eq/MJ
fuel 287kg CO 2 -eq/tonne

**Refinery**
The RFA CO 2 -calculation tool [44] specifies conservative defau lt values for refinery of CPO in Asia, which have been summarized below:

**Table 2.7 RFA default values for GHG emissions for palm oil refinement.**  Type of energy input Specific energy use Specific e mission Total GHG emission Electricity 1,093 MJ/tonne 0.137-0.216 kg CO 2 -eq/MJ 150-236 kg CO 2 -eq/tonne Gas 97 MJ/tonne 0.062 kg CO 2 -eq/MJ 6 kg CO 2 -eq/tonne **Total 156-242 kg CO 2**  **-eq/tonne**

Based on the data mentioned in [58], a refinery rel ated GHG emission of 75 kg CO 2 -eq/tonne palm oil can be calculated, which is much lower tha n the conservative RTFO default values.

Conclusion: From the above figures it can be conclu ded that total GHG emissions from transport and refinery together, are in the same or der of magnitude as emissions from fertilizer application.26

2.6 Summary of conclusions The literature review has identified major categori es of GHG emissions from palm oil production, and –based on the variety of data avail able- indicated robust orders of magnitude for each category. Based on the literature data rev iewed, a number of conclusions can be
drawn:

• In plantation and mill operations, GHG emissions fr om POME far exceed other GHG emissions, such as from fertilizer use and diesel u se;

• Various proven technologies exist which can signifi cantly reduce GHG emissions from POME, and consequently overall emissions from opera tions;

• If palm oil production is located on peat, continuo us GHG emissions resulting from oxidation of peat far exceed those from operations;

• Development of new production areas at the expense of high above and/or underground carbon stocks, results in GHG emissions which takes many oil palm cycles to compensate through carbon sequestration in oil p alms. These timeframes by far exceed the lifetime of an average (plantation) comp any;

• If new production areas are developed in areas whic h are not high in carbon stocks, palm oil production may lead to net carbon sequestr ation.27



## 3 Proposals by the GHG Working Group

3.1 Introduction This chapter summarises the proposals from the GHG- WG. The following proposals were discussed, however there was no broad consensus wit hin the GHG-WG on all items discussed,

i.e.:

1. Develop a framework for reducing GHG emissions from RSPO certified palm oil (Section 3.2);

2. Amend a number of RSPO Criteria and/or related Indi cators and/or Guidance, to better include various aspects of GHG emission (reduction) (Section 3.3);

3. Further study a number of other aspects which impac t upon (standards for) GHG emissions from palm oil production, such as indirec t land use change and yield increases (Section 3.4);

4. Extend the mandate of the GHG-WG and establish an E xpert Group (Section 3.5) to
deliberate on the unresolved issues some of which a re outlined above, in order to
reach a consensus.

3.2 Developing a framework to reduce GHG emissions from palm oil production The literature review summarized in the public cons ultation document of 6 July 2009, has categorised GHG emissions from palm oil production as follows:
1. GHG emissions arising from operations during palm o il growing and FFB processing, or more precisely:
1a. Emissions related to the use of fossil fuels fo r plantation internal transport and machinery; 1b. Emissions related to the use of fertilisers; 1c. Emissions related to the use of fuels in the pa lm oil mill, and the use of palm oil mill by-products; 1d. Emissions from Palm Oil Mill Effluent (POME).
2. GHG emissions arising from changes in carbon stock during the development of new plantings;
3. GHG emissions from peat (only when plantings are on peat).

The GHG-WG has noted the literature findings in rel ation to GHG emissions from operations (category 1), but has not unanimously agreed with t he literature study findings in relation to carbon stocks and peat (category 2 and 3). In short , producers’ representatives felt that more data collection is required before (quantitative) s tandards can be set, while non-producers’ representatives felt that sufficient evidence was a vailable for the development of (quantitative) standards.

The literature study findings on carbon stocks and peat, as well as views from the stakeholder groups in the GHG-WG, have been summarised below.28

3.2.1 Literature study findings on carbon stocks (e xcluding peat) The literature review has indicated that the develo pment of new plantings will lead to a change in carbon stocks, depending on the previous land cover. Development of oil palm on grasslands (with mineral soils) will generally lead to an increase of carbon stock (i.e. net CO 2 sequestration) whereas conversion of primary forest s to oil palm will lead to a reduction of carbon stock (i.e. a net CO 2 emission). Whether conversion of secondary or degr aded forests to oil palm will lead to an increase or a decrease in carbon stocks, depends on the exact carbon stocks of those forests, and the assumed carbon sto cks in the oil palm planting.

The scientific literature reported estimated values for aboveground carbon stocks that varied between 25 and 40 tonnes C/ha.
The GHG-WG has not come to a unanimous conclusion a s regards the literature review findings on carbon stocks, and potentially necessar y amendments of the RSPO P&C.

The non-producers’ representatives in the GHG-WG ha ve concluded that the development of new plantings shall not lead to a reduction in carb on stocks. They have suggested that new plantings shall only be developed on land which has a time averaged carbon stock in the order of 35 tonnes/ha (exact figure to be determined acco unting for inclusion of underground biomass, precautionary principle, compensation mech anisms etc.).

The producers’ representatives in the GHG-WG have d oubted the time average carbon stock figure of 35 tonnes/ha, and argued that the time av eraged carbon stock of oil palm plantings is highly variable and may strongly depend on local co nditions. A thesis by Syahrinudin [49] has been submitted to illustrate the variation. The pro ducers’ representatives in the GHG-WG strongly felt that more data need to be collected b efore a threshold for carbon stocks can be
defined.

3.2.2 Literature study findings on peat In relation to peat, the literature review has conc luded the following:

a. In their natural state, tropical peatlands sequeste r carbon by accumulation in peat and biomass. Drainage and degradation of peat forests r esults in carbon losses mainly through increased decomposition of the peat. Conver sion of peatlands to oil palm plantations requires drainage of 60-80 cm below soi l surface which thus enhances peat decomposition. CO 2 -emissions increase with drainage depth;
b. There is a large variety of quantitative data on CO 2 -emissions from drained peatlands, while not all measurement methods applied are relia ble in terms of quantifying emission from peat oxidation. Literature data vary between 18-73 tonnes CO 2 /ha*yr;

c. Carbon sequestration and emission fluxes in natural peat swamps are some orders of magnitude smaller than the carbon losses from oxida tion of drained peat soils.
Methane and N 2 O emissions from both natural peatlands and from oi l palm plantations on peat, are limited;
d. Various authors have indicated the need to further detail data on GHG fluxes in both undisturbed and drained peatlands. However this res earch is not expected to change conclusions a-c above, but rather refine and narrow down the data ranges.

The GHG-WG has not come to a unanimous conclusion a s regards the literature study findings on GHG emissions from peat, and potentially necessa ry amendments to the RSPO P&C. One group, including primarily producers’ representativ es, considered that five years would be needed to organize and execute a further study of p eat emissions, while the other group29

believes that enough information exists to establis h that converted peat forests are the source of significant CO 2 emissions and that steps should be taken immediate ly to reduce those
emissions and to avoid new emissions due to the con version and drainage of peat.

3.2.3 Developing a standard for the carbon intensit y of palm oil Once it appeared that there were strongly divided v iews on both the quality of available quantitative data and on potential decisions on car bon stocks and peat, the GHG-WG has taken a more qualitative approach. It has concentra ted on developing (qualitative) principles for setting carbon standards. Conclusions and recom mendations have been summarized
below.

The GHG-WG recommends that RSPO develops a framewor k for reducing GHG emissions caused by the production of palm oil. This framewor k shall take account of all (potentially) relevant sources of GHG emissions, including in par ticular emissions from land use change, emissions from peat degradation (if applicable), em issions from POME, etc.

The GHG-WG has agreed that a framework to reduce GH G emissions should be organized around a ‘baseline’ that is formulated using the IS O 14064 standards for reducing GHG
emissions. The unit of measurement for the baseline shall be the holding level of the company. Furthermore, the GHG-WG has agreed that this baseli ne should be accompanied by a time bound plan (to be specified by the company), which allows companies flexibility in making GHG emission reductions over time, and also the pos sibility to link emission reductions to trading mechanisms to compensate for lost opportuni ties and costs associated with making
GHG emission reductions.

a. A group of GHG-WG members, led by MPOA and GAPKI re presentatives, have proposed that the baseline should be based on a com pany’s existing land banks, such that GHG emissions from past, present and future la nd use change are used to
estimate what would occur in a business-as-usual sc enario;
b. A group of GHG-WG members, led by Conservation Inte rnational and Wetlands International representatives, have proposed that t he baseline should be based on historical emissions (including those that occurred on high carbon landscapes) so that future emission reductions can be verified objectiv ely;

c. A group of GHG-WG members, led by the Unilever repr esentative, proposed that whatever baseline is selected (either A or B) this should be compared to a standard based on a value that would approximate the emissio ns of other major vegetable oils. The last suggestion assumes companies would incorpo rate within their time bound plan a commitment to reduce emissions from their ba seline level to this (as yet to be determined) industry-wide carbon intensity standard (tonnes CO 2 /tonne CPO).

The GHG-WG recommends that methodological issues in relation to the development of the framework, and issues for which additional data col lection is required, shall be solved as a matter of high priority.

The GHG-WG recommends that RSPO studies the feasibi lity of a mechanism for RSPO internal carbon trading. The Working Group believes that suc h a mechanism will contribute to the cost
effective reduction of overall GHG emissions from R SPO certified producers. In addition, the GHG-WG recommends that mechanisms be developed which provide incentives/compensation for producers to move away from high carbon stock areas.

The Working Group has discussed the possibility to set a moratorium for certification of new developments on peat, until the required additional data collection and detailing of30

methodological issues have been executed. One group supported the moratorium option as a means to put pressure on the development of a carbo n intensity standard but the producers’ representatives opposed the idea as being too restr ictive, moreover they felt that the GHGWG needs to consider the socio-economic implication s of the proposed moratorium on the livelihood of the local people who rely on oil palm

.

3.3 Proposals for amendments of RSPO Principles & C riteria In addition to the proposal by one group in the GHG -WG related to the development of a carbon intensity standard (Refer to Section 2.) the Working Group has discussed a number of recommendations for specific amendments to a number of RSPO Criteria, Indicators and related Guidance. In this Chapter, each of the prop osed amendments is outlined in detail, i.e.:

• Plans to reduce GHG emissions (3.3.1);

• Fossil fuel use (3.3.2);

• Fertiliser use (3.3.3);

• Palm oil mill residues (3.3.4);

• POME (3.3.5);

• Water management on plantations on peat (3.3.6).

3.3.1 Plans to reduce GHG emissions Under Principle 5 **(‘Environmental responsibility and conservation of natural resources and**  **biodiversity’** ) Criterion 5.6 specifies: **‘Plans to reduce pollution and emissions, including greenhouse gases, are developed, implemented and mo**  **nitored’.**

The GHG-WG believes that GHG emission reduction sho uld get a more prominent position under Principle 5, and proposes to add a new Criter ion 5.7 specifically in relation to GHG
emission calculation and reduction.

It is proposed to re-phrase Criterion 5.6 as follow s: **‘Plans to reduce pollution and emissions are developed, implemented and monitored’** 

.

And phrase a new Criterion 5.7 as follows: **‘Specific plans to reduce greenhouse gas emissions are developed, implemented and monitored’** 

.

It is proposed to add under Criterion 5.7 the follo wing Indicator 5.7.1: **‘Significant sources of GHG emissions are identifie d and plans to reduce them implemented’,**  with the following Guidance: **‘Significant sources of GHG emissions may include e missions resulting from carbon stock**  **changes, treatment/re-use of mill residues (POME, E FB), fertilizers and fossil fuels.**  **A system for the assessment, monitoring and reduction of GHG emi**  **ssions should be developed based on ISO**
**14064’**

Furthermore, the GHG-WG recommends to add to this C riterion specific Indicators in relation to the ISO 14064 based framework methodology for re ducing GHG emissions (refer to Chapter 2).31

3.3.2 Fossil fuel use Criterion 5.4 specifies: **‘Efficiency of energy use and use of renewable ener gy is maximised’** 

The National Interpretation for Malaysia specifies the following Indicators under Criterion 5.4: **‘5.4.1 Monitoring of renewable energy per tonne of CPO or palm product in the mill**  **5.4.2 Monitoring of direct fossil fuel use per tonn e of CPO or kW per tonne palm product in the**  **mill (or FFB where the grower has no mill).’**

The National Interpretation for Indonesia specifies the following Indicators under Criterion 5.4: **‘5.4.1. Records of monitoring renewable energy use and its efficiency analysis (energy/ton CPO,**  **or energy/ton palm product). 5.4.2 Records of monitoring of fossil fuels use for**  **operational reason and its efficiency analysis.’**

The National Interpretation for PNG specifies the f ollowing indicators under Criterion 5.4: **‘5.4.1 Monitoring Kilowatt hour per tonne of palm p roduct in the mill from renewable energy**  **sources. Kilogram steam per tonne of FFB. Monitorin g trend for the preceding 5 years.**  **5.4.2 Monitoring Kilowatt hour per tonne of palm pr oduct from non renewable energy**  **resources. Monitoring trend for the preceding 5 yea rs.’** 

The GHG-WG concludes that reporting on fossil fuel use is sufficiently covered by the Indicators in the respective national interpretatio ns. The GHG-WG recommends to add to the guidance under Criterion 5.4 that ‘ **Use of sustainable biofuel on plantations should be considered as an alternative to the use of fossil f**  **uel’**

3.3.3 Fertiliser use Criterion 4.2 specifies: **‘Practices maintain soil fertility at, or where pos sible improve soil**  **fertility to, a level that ensures optimal and sust ained yield'.** 

The National Interpretation for Malaysia specifies the following Indicator 4.2.1: **‘Monitoring of fertilizer inputs through annual fertilizer recomme**  **ndations’**

.

The National Interpretation for Indonesia specifies the following Indicator 4.2.2: **‘Records of efforts to maintain and increase soil fertility (e.**  **g. the use of fertilizer, legume cover crops , compost, and land applications of POME or EFB) base**  **d on the results of analysis carried out as in Point 1 above)’** 

.

The National Interpretation for PNG specifies the fo llowing Indicator 4.2.1: **‘Records of fertilizer inputs are maintained’** 

.

All three National Interpretations refer specifical ly to the monitoring of fertilizer inputs. For the purpose of quantifying GHG emissions, it will b e necessary to monitor specifically the type of fertilizers used, and the annual quantities used per tonne of CPO or per tonne of FFB. The GHG-WG recommends to add the following to the exist ing Indicators:

**‘Types of artificial fertilizers applied shall be m onitored. Quantities of fertilizers per tonne CPO**  **or per tonne of FFB shall be calculated’.**32

3.3.4 Palm oil mill residues

Relevant references in current set of P&Cs Criterion 5.3 specifies: ‘ **Waste is reduced, recycled, re-used and disposed of in an**  **environmentally and socially responsible manner** ’.

The National Interpretation for Malaysia specifies the following Indicator 5.3.3 ‘ **Evidence that crop residues/biomass are recycled (Cross reference**  **Criterion 4.2)** ’, with Specific Guidance referring to the discharge of POME only (i.e. no re ference of EFB).

The National Interpretations for Indonesia and PNG do not provide a specific Indicator in relation to the recycling of palm oil mill residues (under Criterion 5.3). The PNG Guidance under Criterion 5.3 specifies that **‘Improving the efficiency of resource utilization a nd recycling**  **potential wastes as nutrients or converting them in to value added products (e.g. through**  **animal feeding programmes)’.**

Criterion 4.2 specifies: **‘Practices maintain soil fertility at, or where pos sible improve soil**  **fertility to, a level that ensures optimal and sust ained yield’** 

.

The National Interpretation for Malaysia specifies the following Indicator 4.2.3 ‘ **Monitor the area on which EFB, POME and zero-burning planting i**  **s applied** ’.

The National Interpretation for Indonesia specifies the following Indicator 4.2.2: **‘Records of efforts to maintain and increase soil fertility (e.**  **g. the use of fertilizer, legume cover crops, compost, and land applications of POME or EFB) base**  **d on the results of analysis carried out as**
**in Point 1 above’.**

The National Interpretation for PNG specifies Indic ator 4.2.3: **‘A nutrient recycling strategy should be in place’**  , with the Guidance including the following: **‘The nutrient recycling strategy should include EFB, POME, other mill-by products, p**  **alm residues after replanting and any use of biomass for by-products or energy production’.** 

Rationale behind proposed amendments Literature data provide little quantitative data on the GHG effects from potential disposal/recycling routes for palm oil mill by-prod ucts, in particular EFB (for POME refer to Section 3.2.4). However, it appears that landfillin g of EFB has a worse GHG score that other options, due to the generation of methane emissions

.

Current Principles & Criteria stimulate EFB recycli ng as part of a nutrient management/soil improvement plan. However, landfilling of EFB is no t explicitly discouraged. The GHG-WG
believes that this shall be done.

Proposal for amendments It is proposed that under Criterion 5.3, the follow ing indicator is added under the respective National Interpretations: **‘Landfilling of EFB and other palm oil mill residue s shall be avoided’.** 33

3.3.5 POME
The GHG-WG has concluded that the conventional meth od of POME treatment, i.e. including anaerobic open lagoons, is a significant source of GHG emissions, in particular methane. Several technologies are available for effective me thane emission reduction from POME, including biogas capture, decanters, co-composting with EFB, and denitrification technologies. Biogas capture technologies have been well document ed in literature, including data on efficiencies, also in the framework of CDM reportin g requirements of those projects. For the other technologies, no quantitative data have been found on methane reduction efficiencies.

The GHG-WG have identified and discussed three main options for setting a standard to
reduce methane emissions from POME:

a. Mandatory biogas capture for mills above a certain treatment capacity (threshold capacity to be specified).
b. Not prescribing a single technology, but instead de fining a methane reduction target (% from a certain baseline) or setting a maximum em ission (m 3 CH 4 /tonne POME).

c. Neither prescribing a single technology nor setting a quantitative methane reduction target, but instead requesting that ‘the feasibilit y is studied of reducing methane emissions through the application of certain measur es or technologies’. This requirement resembles the current Indicator under C riterion 5.4.

The GHG-WG has not come to a conclusion as regards the preferred option. Instead, the GHGWG has concluded that emission reduction from POME shall be dealt with under the umbrella of the ISO 14064 based framework methodology for re ducing GHG emissions. Specific indicators on POME might then be included under pro posed new Criterion 5.7 (‘Plans to reduce GHG emissions’).

3.3.6 Water management on plantations on peat The current National Interpretations have some spec ific requirements set in relation to existing plantations on peat (in particular under C riterion 4.3).

Criterion 4.3 specifies **: ‘Practices minimize and control erosion and degra dation of soils’** 

The National Interpretations specify the following Indicator 4.3.4: ‘ **Subsidence of peat soils should be minimized through an effective and docume**  **nted water management programme** ’,
and Guidance: ‘ **For existing plantings on peat, water table should be maintained at a mean of**  **60 cm (within a range of 50-75cm) below ground surf ace through a network of appropriate**  **water control structures e.g. weirs, sandbags, etc. in fields, and water gates at the discharge**  **points of main drains** ’

In the National Interpretations for Malaysia and In donesia, this indicator has the status of ‘minor compliance issue’, where as in the National Interpretation for PNG it has the status of ‘major compliance issue’.

In relation to existing plantings on peat, the GHG- WG recommends that in the National Interpretations for Malaysia and Indonesia, the sta tus of this Indicator is amended from ‘minor compliance issue’ to ‘major compliance issue’, such as to strengthen the importance of this requirement.34

3.4 Other conclusions recommendations Further to the (specific) recommendations outlined in Chapter 2 and 3, the GHG-WG has formulated a number of more generic conclusions and recommendations in relation to indirect land use change, yield increases, reduction of fire s, development of a CSPO market, and
biofuel standards in the EU. These recommendations have been summarised in this Chapter.

GHG emissions from indirect land use change
The members of the GHG-WG have discussed the issue of indirect land use change, but have been unable to come to agreement on its significanc e regarding the palm oil industry. However, they did agree that it would be difficult to address within the current framework of the RSPO P&C, because the system is based on measur es taken by individual companies within the context of their operations, whereas indirect l and use change, by definition, occurs outside of those operations and are beyond their control. N onetheless, because this issue has been highlighted by several academic studies and is rele vant in current policy discussion in international forums, the members of the GHG-WG hav e flagged this as an issue in need of further study.

Yield increases The GHG-WG has concluded that increasing yields has the potential to significantly reduce the overall carbon footprint of palm oil production, as it reduces the need for expansion and carbon stock conversion, and lowers the average GHG emissions per tonne CPO/FFB produced. This relates in particular to smallholders, who on average have a much lower yield than large scale producers. The GHG-WG recommends that RSPO studies and impleme nts mechanisms which facilitate significant yield increases, in particular from sma llholders.

Fires
Intended and accidental fires related to the cleara nce of land for palm oil, are a significant source of GHG emissions, in particular when occurri ng on drained peatlands. The GHG-WG
recommends that RSPO studies which further measures are required, within or outside the framework of RSPO, to reduce occurrence of fires.

Development of CSPO market The GHG-WG has concluded that the development of a significant and fair CSPO market is a financial incentive for further steps towards decre asing the carbon intensity of palm oil production. The GHG-WG calls upon RSPO members buyi ng palm oil to contribute to the development of this market.

Qualification of CSPO on EU biofuel market The GHG-WG has concluded that its agreed recommenda tions are insufficient to allow CSPO to meet the sustainability requirements of the EU Rene wable Energy Directive, as summarised in
Box 2 below.

Note: Producers’ representatives in the GHG-WG feel that the EU sustainability requirements
as outlined in Box 2 have not been discussed in det ail, and should therefore not have been included in this report with the intention to infor m the Executive Board and others of relevant issues pertaining to biofuels.35

Box 2 Summary of relevant sustainability requiremen ts in EU Renewable Energy Directive

Art. 17.2 The greenhouse gas emission saving from t he use of biofuels and bioliquids taken into accoun t for the purposes shall be at least 35% (and target increases step-wise)

Art. 17.4 Biofuels and bioliquids shall not be made from raw material obtained from land with high carbon stock, namely land that had one of the follo wing statuses in January 2008 and no longer has tha t

status (a) wetlands, namely land that is covered with or s aturated by water permanently or for a significant part of the year (b) continuously forested areas, namely land spanni ng more than one hectare with trees higher than five metres and a canopy cover of more than 30%, or trees able to reach those thresholds in situ © land spanning more than one hectare with trees hi gher than five metres and a canopy cover of between 10% and 30%, or trees able to reach those t hresholds in situ, unless evidence is provided that the carbon stock of the area is such that, when the methodology laid down in part C of Annex V is applied, the emission saving reductions are fulfill ed

Art. 17.5 Biofuels and bioliquids shall not be made from raw material obtained from land that was peatland in January 2008, unless evidence is provid ed that the cultivation and harvesting of that raw material does not involve drainage of previously un drained soil

Art. 19.6 The European Commission shall, by 31 dece mber 2010, submit a report reviewing the impact of indirect land-use change on greenhouse gas emiss ions and addressing ways to minimise that impact

3.5 Procedural aspects To allow an effective follow-up of the recommendati ons outlined in the previous sections, the GHG-WG proposes the following:

1. That the mandate of this Working Group will be exte nded until 31 December 2009. This will allow the Working Group to review the input from th e extended public consultation period and –
on the basis of Executive Board and/or General Asse mbly decisions – to detail the Terms of Reference to develop the framework for a voluntary incentive system to reduce GHG emissions
within the RSPO. 2. Establish an expert group to develop the informatio n resources that are sufficiently accurate to inform the implementation of a voluntary framework to reduce GHG emissions, particularly the definition of what type of baseline will be adopted within that voluntary system and the designation of default (average) values regarding c arbon stocks on oil palm plantations and the different types of landscapes that are being conver ted to oil palm plantations, as well as the GHG emissions from intact peat forest, drained peatland s currently planted with oil palm, and peatlands that were previously planted to oil palm, but which are now undergoing restoration to a natural forest ecosystem.36



## 4 References

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[12] Directive 2009/28 of the European Parliament a nd of the Council on the promotion of the use of energy from renewable sources and amending a nd subsequently repealing Directives 2001/77/EC and 2003/30/EC. Brussels (Belgium), 23 A pril 2009.

[13] Fargioni J, Hill J, Tilman D, Polasky S, Hawth orne P (2008). Land clearing and the biofuel carbon debt. Science, doi: 10.1126/science.1152747.37

[14] Field, R.D., G.R. van der Werf and S.S.P. Shen (2009). Human amplification of droughtinduced biomass burning in Indonesia since 1960. Na ture Geoscience, Vol 2, March 2009.

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2007.42 

## Appendix 1



# Terms of Reference for the RSPO Working Group on

Greenhouse Gases43



## Terms of Reference RSPO Greenhouse Gas Working Group (GHGWG)

These Terms of Reference outline the scope of work, expected outputs and timeframe of the RSPO GHG Working Group.

 Background

There is rising worldwide concern about global clim ate change driven by increasing greenhouse gas (GHG) emissions. Climate change is n ow accepted as one of the top issues of the environment and sustainable developme nt agenda with all sectors of society needing to identify ways to reduce GHG emis sions. Biofuels offer the potential for reducing GHG emissions and palm oil provides on e pathway to producing biofuels because of its high productivity and the high energ y use ratio in its production and processing. 1 At the same time, the reduction of deforestation is considered to be one of the cost-effective GHG abatement measures availa ble over the short term, 2 because it represents more than 20% of all GHG emission, 3 of which 80% of the global total are estimated to come from the Amazon and Southeast Asi a, 4 two regions with the largest potential for expansion of oil palm cultivation. I f the perceived conflicts between oil palm cultivation, deforestation, and GHG emissions are resolved, the future potential for palm oil as a biofuel feedstock will be signifi cantly enhanced.

Although there are different views by diverse stake holders as to the scale of emissions from palm oil production – it is generally agreed t hat emission sources from the palm oil sector include those from the clearance of forests and peatlands for plantation development, use of fossil fuels for operating, pro cessing and transport, fertiliser use, and methane emissions from wastewater treatment pon ds. Accepted mitigation measures include establishing new plantations on lo w biomass landscapes, increased energy efficiency, reforestation of degraded landsc apes, maintenance of optimal water levels in peatlands, and methane capture and bio-en ergy production. A number of palm oil companies have addressed these issues are alrea dy generating revenues by certifying reductions in GHG emissions via the Clea n Development Mechanism (CDM), but other companies have yet to access such resourc es.

The reduction of GHG emissions and the avoidance of deforestation in the establishment of new plantations are increasingly b eing recognized in the RSPO as an emerging and critical issue that requires further i nvestigation and adjustments to the existing RSPO Principles and Criteria (P&C), which were adopted in November 2005. The issue was raised by a number of stakeholders in the review process, but the RSPO Criteria Working Group (CWG) was not able to f inalize revised wording to incorporate GHG issues into the revised P&C present ed to the GA4 in November 2007. In October 2007, the CWG therefore made an urgent r ecommendation to the RSPO Executive Board for the establishment of GHG Workin g Group. The Executive Board in

1 Fargione J, Hill J, Tilman D, Polasky S and Haw thorne P (2008) Land clearing and the biofuel carbo n debt. Science 319:1235-1238. 2 McKinsey & Company (2007) Reducing U.S. Greenhous e Gas Emissions: How Much at What Cost? http://www.mckinsey.com/clientservice/ccsi/greenhou segas.asp (accessed 11/20/2008). 3 Intergovernmental Panel on Climate Change (2007) Climate Change 2007 – The Physical Science Basis:
Contribution of Working Group I to the Fourth Asses sment Report of the IPCC , Cambridge University Press, Cambridge, UK. 4 Hansen MC, Stehman SV, Potapov PV, Loveland TR, T ownshend JRG,. DeFries RS. Pittman1 KW, Stolle F, Steininger MK, Carroll, M, DiMiceli C (2008) Humid tropical forest clearing from 2000 to 2005 quantified by using multitemporal and multiresolution remotely sensed d ata Proc. Nat. Acad. Science 105:9439–9444.44

its meeting in November 2008 recognized the concern and called for the development of a draft Terms of Reference (ToR) to guide a deci sion on the establishment of the
group.

The GHG Working Group is envisaged to be a short-te rm, multi-stakeholder expert panel established to review the current P&C in rela tion to GHG emissions in the production of palm oil and to advise the Executive Board on options for adjustment of the RSPO P&C. The GHG Working Group is not envisage d to develop a separate certification or auditing scheme, nor should it dev elop a comprehensive methodology for assessment and monitoring of biomass and GHG em issions from palm oil operations. Rather, the GHG Working Group will inc orporate key features into the existing P&C framework to provide credible proxy me asures for GHG emissions, 5 including those originating from above and below-gr ound carbon pools from natural and anthropogenic land cover types that are convert ed to oil palm plantations. 6 The proposed changes to the RSPO P&C will enable manage rs and certifiers to assess GHG emissions associated with the establishment of new plantations, ongoing operations in plantations and processing facilities , as well as identify lands where new oil palm plantations are inappropriate. While doin g so, it will strive to align and coordinate the RSPO P&C for palm oil production wit h complimentary standards to promote the use of biomass for fuel applications an d sustainable forest management.

2. Objectives

The proposed objectives of the GHG Working Group ar e to:

2.1 Review and synthesize relevant information on p alm oil production and GHG emissions, particularly related to the development of plantations, but also including plantation operations, industrial process ing and the transport of palm oil,

2.2 Identify options for avoiding or mitigating GHG emissions at all stages of the production chain.

2.3 Provide technical guidance and recommendations on how to address GHG emissions from palm oil production and processing w ithin the RSPO P&C.

2.4 Provide specific recommendations for modifying of the existing RSPO P&C terminology, in order to establish auditable and ac hievable indicators for units of certification

2.5 Coordination with similar certification schemes under development in forestry, agro forestry and biofuels industries.

2.6 Provide objective information from peer-reviewe d sources to guide communication related to the sustainability of palm oil in the context of biofuels and bioenergy.

3. Proposed Activities

5 Note: Proxy measures for biomass estimates of la nd-cover types are typically based on changes in ve getation cover derived from remote sensing technologies. 6 Note: Oil palm plantations established in pasture or other low biomass vegetation types are very eff ective carbon sinks and can be used to offset GHG emissions from other components of an enterprises’ activities or p otentially be eligible for carbon-based subsidies in future volun tary or compliance markets.45

The initial timeframe of the GHG Working Group’s ti meframe is proposed to be 9 months starting in January 2009. Within this period the following activities are proposed:

3.1 Conduct a literature review of key issues regar ding GHG emissions and the oil palm industry in order to inform future discuss ions pertaining to the evolution of the RSPO P&C framework:

3.1.1 Life Cycle Analyses for Oil Palm and other re levant information to identify the main sources of GHG emissions from pal m oil production (including land development, drainage, fertilizatio n, plantation operation, processing, and the transport of palm oi l).

3.1.2 The social dimensions of carbon accounting in cluding “leakage” (i.e. displacement of land use) and “permanence” (i.e. lo ng term vs. short term land use impacts), market-driven crop displace ment, impact on food prices and other social implications, as well as the potential role of smallholders in oil palm production.

3.1.3 The availability, accuracy, and cost of exist ing and new technologies that can be used to estimate carbon stocks on lands capes prior to and following the establishment of oil palm plantations (i.e., satellite and airborne platforms using L-band RADAR and LIDAR tec hnologies). 7

3.1.4 Existing methodologies and approaches for cal culation of GHG emission from oil palm plantations and processing a nd options of use of proxy indicators (eg. energy, fertilizer use, pr evious land use). With a view to develop a “Carbon Score Card” that can ai d reporting on the dimensions of total GHG emissions related to palm o il production.

3.2 Identify measures that will allow producers to avoid GHG emissions originating from the establishment of new plantatio ns:

3.2.1 Site selection criteria that will avoid GHG e missions by ensuring that all new plantations are established on low biomass landscapes.

3.2.2 Special recommendations and measures that can assist smallholders to reduce GHG emissions (i.e., raising yields and r educing the use of pesticides), either individually, via producer coop eratives, or in partnership with processors.

3.3 Review the current RSPO P&C and recommend adjus tments to incorporate GHG issues, if possible focussing on indicators and systems that are auditable and achievable in order to facilitate the certification process and which produce real and meaningful reduction in GHG emissions.

• Recommend further work required to refine guidance or assist in its implementation.

7 Note: The most common remote sensing technologie s are based on optical sensors (LANDSAT, SPOT, CBRS ), which can be of limited use in high rainfall areas due to frequent cloud cover and infrequent data acq uisition protocols; new RADAR satellites and LIDAR sensors ( an infrared laser instrument) provide cost effectiv e alternatives that not only document forest cover but provide dir ect measurements that can be used as proxies for ab ove ground biomass..46

4. Proposed Outputs

The GHG Working Group will develop:

4.1 A document that summarizes the scientific liter ature on GHG emissions and palm oil.

4.2 Clear standards on site selection to avoid GHG emissions on new oil palm plantations.

4.3 Auditable and achievable amendments to the curr ent RSPO P&C guidance and indicators based on this review process.

4.4 Recommendations for coordinating mechanisms and communication strategies.

5. Proposed Operational Arrangements

GHG Working Group Participants

To ensure a representative mix of stakeholders and expertise, it is envisaged that the Working Group would comprise 12 members

Members:

It is proposed that members of the group come from the following sub-groups:

i. Representatives from the Criteria Working Group or Executive Board (to ensure a strong understanding of RSPO processes and the cu rrent P&C) - 4 members with a range of different backgrounds including pal m oil/biofuel industry, environmental NGO, social NGO)

ii. Experts on Greenhouse Gases and climate change – 4 members with a range of different experiences including carbon stocks in fo rest and peatlands, palm oil life cycle analysis and GHG emission/mitigation opt ions.

iii. Other members – 4 members from industry, NGOs, government or research institutes with practical experience in implementin g measures to assess or mitigate GHG emissions from palm oil production and processing.

Chair:

The working group should be chaired by an independe nt expert in GHG emission, who will also be contracted to facilitate the work of t he Working Group.

He/she will be responsible for leading the working group, organising and coordinating the contributions of the different members of the w orking group to ensure that the mandate is fulfilled, all the outputs are adequatel y addressed, and that the outcome is of high quality and correctly reflects the collecti ve and individual positions of the working group members.

Consultant/Facilitator:47

The working group should be supported by an indepen dent consultant/facilitator with appropriate experience on GHG life cycle assessment from palm oil/ land use change and understanding of appropriate certification sche mes. The consultant will prepare the meetings (agenda, invitations, distribution of docu ments, minutes) and Chair them, act as a moderator at stakeholder meetings, collate pub lic comments and draft the inception, interim and final reports, coordinating and synthesising the inputs of the members of the group. The consultant will also carr y out some appropriate desk research/analysis as may be required by the working group.

Proposed Timetable

The working group will meet two times during 2009 ( two days per meeting), although the number of meetings can be adapted as necessary. One public consultation meeting should be organized before submitting the text for adoption by the Executive Board of the RSOP. Participants will need to assume respons ibilities and commit time between meetings to deliver the objectives. Meetings are te ntatively proposed in April/June 2009 with public consultation in May/June to enable a re commendation to be considered by the Executive Board in September 2009.48 

## Appendix 2



# Composition of RSPO Working Group on GHGComposition of RSPO Working Group on GHG

RSPO Category Name of expert Organisation Oil palm growers Purboyo Guritno PT Makin Group Ong Kim Pin Kulim Berhad

Mamat Salleh MPOA / RSPO EB Chew Jit Seng MPOA (alternate) /RSPO EB Jean-Charles Jacquemard PT Socfindo

Palm oil processors/traders Dr Klimes ADM

UR Unnithan Carotina Sdn Bhd

Kaisa Hietala Neste Oil Riitta Lempiainen Neste Oil (alternate) Adrian Suharto Neste Oil (alternate)

NGOs Faizal Parish Global Environment Center Suzana Mokheri Global Environment Center (alternat e)

Sander van Bennekom OxfamNovib Johan Verburg OxfamNovib (alternate) Norman Jiwan Sawit Watch/RSPO EB Bambang H. Saharjo Sawit Watch (alternate)

Marcel Silvius Wetlands International Tim Killeen Conservation International/ RSPO EB

Consumer goods/retailers Jonathan Fursland Royal Du tch Shell Amir Abdul Manan Royal Dutch Shell (alternate)

Sarah Sim Unilever Llorenc Mila-i-Canals Unilever (alternate)

Banks & Investors Ken MacDicken IFC

Technical experts Niels Wielaard Sarvision Simon Lord Global Sustainability Associates Petra Meekers Global Sustainability Associates (al ternate)

Dr Puah Chew Wei MPOB

Dr Chen Sau Soon SIRIM B.G. Yeoh Eco Securities Malaysia Sdn Bhd Robert Cheong TUV Nord
Yohannes Samosir Indonesian Palm Oil Research Inst itute Ian Henson Independent consultant

Observers at Working Group meetings Name Organisation/Affilliation Dr. Vengeta Rao RSPO Secretary General Ms. Jutta Poetz RSPO Secretariat Biodiversity Coor dinator/New Plantings Working Group Darrel Webber WWF Malaysia

GHG Working Group facilitator : Arjen Brinkmann (Brinkmann Consultancy)

## Appendix 3



# GlossaryAbove-ground biomass: All living biomass above the soil including stem, stump, branches,

bark, seeds, and foliage.

Afforestation: planting of new forests on lands that historically have not contained forests.

Below-ground biomass: All living biomass of live roots. Fine roots of le ss than (suggested)
2mm diameter are sometimes excluded because these o ften cannot be distinguished empirically from soil organic matter or litter.

Biomass: the biodegradable fraction of products, waste and residues from biological origin from agriculture, forestry and related industries i ncluding fisheries and aquaculture, as well as the biodegradable fraction of industrial and munici pal waste.

Canopy cover: The percentage of the ground covered by a vertical projection of the outermost perimeter of the natural spread of the foliage of p lants. Cannot exceed 100%. (Also called crown closure).

Carbon compensation project: a project dedicated to ‘offset’ greenhouse gases e missions
from another organisation’s project, which overall results in less carbon dioxide or other
greenhouse gases in the atmosphere than would other wise occur.

Carbon sequestration: The process of removing carbon from the atmosphere and depositing it

in a reservoir.

Carbon stock: The quantity of carbon in a “pool”, meaning a rese rvoir or system which has the capacity to accumulate or release carbon. Examp les of carbon pools are living biomass (including above and below-ground biomass), dead or ganic matter (including dead wood and litter) and peat soils.

Carbon dioxide equivalent: a measure used to compare different greenhouse gase s based on their global warming potentials (GWPs). The GWPs ar e calculated as the ratio of the radiative forcing of one kilogram greenhouse gas emitted to t he atmosphere to that from one kilogramme CO 2 over a period of time (usually 100 years).

Clean Development Mechanism (CDM) : A mechanism under the Kyoto Protocol through which developed countries may finance greenhouse-ga s emission reduction or removal projects in developing countries, and receive credi ts for doing so which they may apply towards meeting mandatory limits on their own emiss ions.

Degraded forest: forest that has lost biomass after logging, fire, or some combination of the

two.

Greenhouse gases (GHGs): The atmospheric gases responsible for causing glob al warming and climate change. The major GHGs are carbon dioxid e (CO2), methane (CH4) and nitrousoxide (N20). Less prevalent --but very powerful -- greenhouse gases are hydrofluorocarbons

(HFCs), perfluorocarbons (PFCs) and sulphur hexaflu oride (SF6).

Peat soils: soils that have 50 cm or more organic soil matter within 100.

Reforestation: Replanting of forests on lands that have previousl y contained forests but that
have been converted to some other use.

Remote sensing: practice of acquiring and using data from satellite s and aerial photography to infer or measure land cover/use. May be used in com bination with ground surveys to check the accuracy of interpretation.

Secondary forest: Forest regenerated largely through natural process es after significant human (‘slash and burn’) or natural disturbance of the original forest vegetation.

Sequestration: a process, activity or mechanism which removes a g reenhouse gas from the atmosphere.

## Appendix 4



# Measuring carbon stocksBackground carbon stock and canopy cover measuremen ts GHG emission WG

Draft version 18-06-2009. Niels Wielaard, SarVision

Applicable measurement approaches As noted in the paper of Goetz et al that I contrib uted “attempts to map above ground biomass without satellite imagery are insufficient”. In my opinion, solely relying on ground assessments should not be recommended for assessing compliance with sustainab le oil palm production:

1. The number of locations that can be assessed wit hin in the framework of a social and environmental impact assessment will likely be insufficient and i ts spatial coverage limited. For relevant and accur ate biomass indications, vegetation stratification is r equired first to do field measurements in represent ative areas. Such stratification is commonly based on... sa tellite data. 2. Stocks which are easiest to measure, i.e. forest carbon stocks using tree measurements of diameter at breast height (DBH) are NOT the primary focus of me asurements. The focus of measurements should be
lands with carbon stocks below 35 to 70 tonnes carb on/ha. Such areas will mostly be shrublands with an excessive number of stems with (very) small DBH or grassland that can not be surveyed using DBH

measurements. 3. It is not possible to do field measurements in t he past, would it be required. It is not possible t o perform measurements in all places that will be converted t o plantations just before or after the cut-off date s such as January 2008, 2010 or any other proposed by coun try systems (e.g. UK, Netherlands), EU RED, or the
revised RSPO P&C.

Leading scientists have developed recommendations f or credible carbon measurements using a
combination of field measurements and satellite/air borne sensor data. Guidance is documented in the GOFC GOLD source book ( http://www.gofc-gold.uni-jena.de/redd/index.php ), developed to complement the IPCC Good Practice Guidance (IPCC, 2003) and I PCC Guidelines (IPCC, 2006) by providing additional explanation, clarification and enhanced methodologies for obtaining and analyzing key data. GOFC GOLD is a platform of leading forest monitorin g experts (space agencies, institutes, industry). Australia has already developed an operational Nati onal Carbon Accounting System, in which satellitebased land cover maps are playing a key role (AGO, 2009). This approach is currently adapted and transferred to tropical regions, including Indonesi a. This work is coordinated within the framework of a new initiative of the Group on Earth Observation (G EO). GEO is an international collaborative effort o f over 78 countries, institutes and space agencies, i nitiated by the G8. GEO has defined a ‘Forest Carbo n Tracking task’ ( http://geo-fct.org/ ), aiming to establish an operational independent g lobal carbon information system, integrating national level syst ems. Its objectives are: (i) to demonstrate that coordinated Earth observati ons can provide reliable information of suitable consistency, accuracy and continuity to support for est carbon monitoring, reporting and verification; (ii) to define a set of standards and requirements that any methodology should adopt to provide the mo st accurate results relying on the full potential of e xisting observational and processing capabilities.

Obviously, the oil palm sector could benefit much f rom carbon stock information resulting from the GEO Forest Carbon Tracking task, and technical guidance by GOFC GOLD.

Mapping carbon stocks Of the credible, internationally accepted wide area carbon stock assessment approaches that exist, the following are most applicable (GOFC GOLD, 2008, CIF OR, 2008):
1. indirect measurement: using field measurement data in combination with land cover/vegetation type data derived from satellite imagery;
2. indirect measurement: using field measurement data in combination with land cover/vegetation type data derived from satellite imagery and other spati al data for spatially explicit modeling of carbon stocks;
3. direct measurement: using biomass information detec ted more directly from the (radar) satellite signal (i.e. without the requirement to use land co ver/vegetation type maps as a proxy by assigning biomass values to each thematic type class).Indirect measurement

The lack of clear and agreed definitions of land co ver vegetation types currently leads to much confus ion. For example, there is a lot of debate and dispute a s to whether forest earmarked for conversion to plantation is ‘degraded’ or not.

This problem might be addressed by adhering to the classes proposed by IPCC. IPCC has identified six broad ‘high-level’ categories of land use consisten t with the IPCC Guidelines, to be reported at the national level. These include forest land, cropland , grassland, wetlands, settlements, and other land. According to IPCC it is good practice to specify na tional definitions for all categories used in the inventory and report any threshold or parameter val ues used in the definitions. Furthermore, it is goo d practice to make locally relevant additional classe s subcategories of the suggested high-level categor ies. This could include well described and therefore obj ectively measurable shrubland or ‘degraded’ forest classes. The 30% canopy cover threshold as defined by the EU RED is also useful to distinguish forest from ‘degraded’ forest. The oil palm sector could use such IPCC maps when m ade available by national governments in compliance with UN climate convention requirements.

To further address the definition problem, the FAO has developed a classification ‘language’ to operationalize the definition of thematic map class descriptions in terms of objectively measurable parameters; e.g. canopy cover, number of months flo oded, etc. This so-called FAO Land Cover Classification System (LCCS - http://www.glcn-lccs. org/) is applicable to all climatic zones and environmental conditions and compatible with existi ng classification systems developed by countries.
LCCS has been submitted to become an international standard through the TC 211 technical committee of the International Organization for Standardization (ISO).

Direct measurement Traditionally used satellite sensors (e.g. landsat) can not be used for accurate direct measurement of biomass. The direct relationship between radar sens ors and biomass has been investigated since the ear ly 90’s (LeToan et al, 1992; Beaudoin et al 1994; Imho ff, 1995; LeToan et al 2004). Studies from Malaysia
also indicate that radar data can be used as an ind icator for biomass (Hazim and Kadir, 1999). Current ly operational satellite radar can be used to measure biomass up to 50-100 ton/ha. Forest biomass can not be reliably measured directly as the satellite signal saturates beyond 100 ton/ha. The proposed time aver aged carbon stock of oil palm, as well as bare areas, gr assland and shrublands however, is within the range that can be measured. Measurement error is typically in the order of 20 tons/ha (e.g. Pierce et al. 2002), which is relatively large. Nevertheless, if only a simple scheme is used identifying bare areas, grassland, shrubland, mature plantations and forest it should be acceptable as a proxy.

Satellite lidar (laser) is very promising, but will not be operationally available in the next few yea rs. Airborne radar (Hoekman and Quiñones, 2002; Santos et al, 2003) and airborne lidar (Lucas et a l, 2006; Boudreau et al, 2008) are readily available and wil l provide much more accurate results, but at high c ost.

Mapping canopy cover The mapping of canopy cover (required to demonstrat e compliance with the EU RED 30% threshold for continuously forested areas) is relatively straight forward. Very high resolution satellite data or aer ial photography (at 0.10 – 2.5m spatial resolution) can be used to identify individual trees. Using visual analysis or computer classification, tree crown cov er can be classified at full resolution and results aggregated to canopy cover percentages over larger spatial units required (e.g. per hectare). This is common practice in Australia (AGO. 2009) and Malays ia (e.g. Ming, 2003). Other studies have demonstrated it is also well possible to extrapolat e local very high resolution canopy cover mapping results to regional and even global scale with acce ptable accuracy (Hansen et al, 2002). In addition, techniques have been developed to clas sify canopy cover using widely used satellite senso rs such as 30m spatial resolution Landsat-type data (J oshi et al, 2005). The development of one of such freely available techniques, Forest Canopy Density mapping (Rikimaru et al, 2002), has been funded by ITTO and applied by government agencies in Sabah an d Indonesia. A consistent, yet approximate, application should suffice.Accuracy of measurements

Carbon stock measurement can and does not have to b e perfect from the start, as long as commitment to continuous improvement is assured. Despite known un certainties, experts agree that well documented techniques and satellite data are available for rel iable mapping of carbon stocks over large areas. Applicable techniques and data have been published in refereed scientific literature and are progressi ng rapidly (Goetz et al, 2008).

The Voluntary Carbon Standard for credible carbon o ffset trading recommends that “When highly uncertain data and information are relied upon, the project proponent shall select assumptions and values that ensure that the quantification does not lead to an overestimation of GHG emission reductio ns or removal enhancements.” The IPCC good practice guidance supports the devel opment of inventories that are “transparent, documented, consistent over time, complete, comparable, assessed for uncertaint ies, subject to quality control and assurance, efficient in the use of resources available to inventory age ncies,” and last but not least, “ in which uncertainties are reduced as better inform ation becomes available”

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The situation with respect to accuracy will improve further as new satellite missions and approaches c ome online in the next few years, several of which are designed specifically with the intent of improving estimates of the standing stock of carbon in biomas s, and changes in those stocks through time (Hought on and Goetz, 2008).

References AGO, 2009. URL: http://www.climatechange.gov.au/ncas/activities/lan dcover.html

Beaudoin, A., Le Toan, T., Goze, S., Nezry, E., Lop es, A., Mougin, E., Hsu, C.C., Han, H.C., Kong, J.A

., Shin, R.T., Retrieval of forest biomass from SAR da ta. International Journal of Remote Sensing , (14), 2777 – 2796, 1994.

Goetz, S., A. Baccini, N. Laporte, T. Johns, W. Wal ker, J. Kellndorfer, R. A. Houghton, 2008. Mapping and Monitoring Carbon Stocks with Satellite Observa tions: An Update

Good Practice Guidance for Land Use, Land-Use Chang e and Forestry (LULUCF), to support the
Revised 1996 IPCC Guidelines for National Greenhous e Gas Inventories (IPCC Guidelines) URL: http://www.ipcc-nggip.iges.or.jp/public/gpglulucf/g pglulucf_contents.html

Hazim and Kadir, 1999. Comparison of JERS-1 and Rad arsat Synthetic Aperture Radar Data for Mapping Mangrove and Its Biomass. URL http://www.gisdevelop ment.net/aars/acrs/1999/ps3/ps300e.asp

Hoekman, D.H., Quiñones, M.J., Land Cover Type and Biomass Classification Using AirSAR Data for Evaluation of Monitoring Scenarios in the Colombian Amazon. IEEE Transactions on Geoscience and Remote Sensing 38 (2), 685 – 696, 2002.

Houghton, R.A. and S.J. Goetz, 2008. New satellites offer a better approach for determining sources an d
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Imhoff, M.L., Radar backscatter and biomass saturat ion: ramifications for global biomass inventory. IEEE Transactions on Geoscience and Remote Sensing, 33(2), 511-518, 1995.

IPCC. 2003. Good Practice Guidance for Land Use, La nd-Use Change and Forestry (LULUCF). Available at http://www.ipcc-nggip.iges.or.jp /

IPCC. 2006. Guidelines for National Greenhouse Gas Inventories – Volume 4: Agriculture, Land Use and Forestry (AFOLU). Available at http://www.ipcc-nggi p.iges.or.jp/

Le Toan, T., Beaudoin, A., Riom, J., & Guyon, D., R elating forest biomass to SAR data. IEEE Transactions on Geoscience and Remote Sensing, 30(2 ), 403-411, 1992.Le Toan T, Quegan S, Woodward I, Lomas M, Delbart N and Picard C 2004 Relating radar remote

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Lucas, R.M., Cronin, N., Lee, A., Moghaddam, M., Wi tte, C. & Tickle, P. 2006. Empirical relationships
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Lucas, R.M., Cronin, N., Moghaddam, M., Lee, A., Ar mston, J., Bunting, P. and Witte, C., Integration o f Radar and Landsat-derived Foliage Projected Cover f or Woody Regrowth Mapping, Queensland, Australia, Remote Sensing of Environment, 100, 407- 425, 2006.

Lucas, R.M., Mitchell, A.L., Rosenqvist, A., Proisy , C., Melius, A. and Ticehurst, C., 2007. The poten tial of L-band SAR for quantifying mangrove characterist ics and change. Case studies from the tropics and subtropics. Aquatic conservation: marine and freshw ater ecosystems - Special Issue: Radar Applications for Wetlands Management. 17, 245-264, 2007.

Pierce, L.; Pan Liang; Dobson, M.C., 2002. Regrowth biomass estimation in the amazon using JERS1/RADARSAT SAR composites. Geoscience and Remote Se nsing Symposium, 2002. IGARSS apos;02. 2002 IEEE International Volume 4, Issue , 24-28 Jun e 2002 Page(s): 2075 - 2077 vol.4

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, S.J.S., Airborne P-band SAR applied to aboveground biomass studies in the Brazilian tropical rainfores t. Remote Sensing of Environment, 87, 482-493, 2003.