MPOB comments on the Draft Extended Summary of the HCS+
A new pathway to sustainable oil palm development
General Comments
i.
It is abundantly clear that the primary objective of the HCS carbon-centric
approach and methodology is to render it extremely difficult, or not at all,
for any new expansion of the oil palm industry on both mineral soils and
peatland.
ii.
In order to meet the requirements for an ever burgeoning global human
population in the absence of any significant expansion of the oil palm
industry, the other less productive oil crops will take up many times more
hectarage to make up for the productivity deficit leading to indirect land
use change (ILUC) on an unacceptably vast scale, notably in the EU, USA
and Brazil. It is surprising that this new pathway/strategy to limit oil palm
cultivation appears to overlook this logical and imminent development.
iii.
In the process of defining and safeguarding HCS forests, all other aspects
and elements of sustainability appear to be given less importance so that it
is essentially a forest conservation agenda and strategy with little
consideration given to the proven potential of the oil palm to bring about
rapid development, alleviation of poverty and food security in economically
disadvantaged third world countries in Asia, Africa and South America
despite the claim that this is a new pathway to sustainability. HCS+ is
clearly the methodology to implement the HCS approach which is
obviously
iv.
oriented towards forest conservation.
Judging from the literature to-date, the ‘magic’ figure of 75 t/ha for aboveground biomass and soil carbon individually lacks a scientific basis.
Presumably, it is an arbitrary figure to ensure that mostly grasslands
qualify and peat is completely ruled out. The same can be said of the 15
cm limit for peat (please refer to specific comment on Para 27).
v.
The move to categorise forests having a minimal carbon threshold as HCS
forests must proceed with caution and conscience because of implications
on existing suppliers along the palm oil supply chain. Smallholders, in
particular, are the stakeholders most likely to be adversely affected by this
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move. Similarly, smallholders will find it extremely difficult to comply with
the below ground threshold of 75 tC/ha
vi.
The scientific literature to-date erroneously only refers to generic peat.
Tropical peat differs very much from temperate peat. Also, peat
classification is complex as has been demonstrated in MPOB’s Unified
Peat Classification Scheme (UPCS)1.
vii.
As a basis for incorporation of this pathway into any existing oil palm
certification scheme, HCS+ falls short of a balanced approach and
strategy for the production of sustainable palm oil with its fundamental
criterion for delineation of HCS forests and their conservation as
afforded by the availability of the Lidar technology and high
resolution satellite imagery. In general, the principles and concepts of
overall sustainability, as commonly perceived, are well covered in MSPO,
ISPO and the existing RSPO. In this regard, there is hardly any
significantly revolutionary/innovative concept to be taken up by these
schemes. If at all, only these newer technologies need to be incorporated
if there is an additional objective to limit oil palm expansion in a drastic
manner. It is to be noted that these technologies involve sophisticated
facilities and expertise and are therefore relatively expensive; estimates
through conventional methodology could be adequate and therefore
involve less cost.
viii.
The HCS+ methodology seems to be only to reinforce the original
objective and motive for the establishment of RSPO in 2004, that is, to
check rapid deforestation from logging and subsequent oil palm cultivation.
ix.
The way ahead for Malaysia has been well mapped out – a holistic
commitment to the principles and criteria of sustainability in existing oil
palm areas with a focus on carbon neutrality through incorporation of
best agricultural practices and minimisation GHG emission, as provided
for by the Malaysian Sustainable Palm Oil (MSPO) scheme.
1
Paramananthan S and Wahid O (2014) Soils of the Lower and Middle Baram River Basin, Miri Division,
Sarawak, Malaysia. Published by the Malaysian Palm Oil Board, 2015.
3
x.
In a larger context, apart from considerations of concession level carbon
neutrality, there is an overwhelmingly high element of carbon neutrality at
the state and national levels for the entire Malaysian oil palm industry in
that the loss of carbon inherent in the transformation of forest to
approximately five million hectares of existing planted oil palm is more
than adequately compensated by the governmental conservation/setting
aside of some 18 million hectares which cover about 55 % of the country.
xi.
Biodiversity conservation is based on the guidelines of the National
Conservation Policy for Biodiversity, related state laws and regulations,
and the IUCN List of Endangered Species. Apart from in situ conservation
of plants and animals, a landscape approach is being superimposed on
large oil palm areas, along with forest conservation/restoration, to address
the needs for corridors for animal movement and preservation of
ecological function. Instead of increasing productivity through expansion
on new land, the emphasis has shifted to consolidation of efforts to
increasing yield per unit area through appropriate R & D efforts and
adequate resource mobilisation.
xii.
Insofar as Malaysia is concerned, there will not be any more sizeable
expansion of the oil palm industry in the future even after allowing for oil
palm planting as part of programmes to ensure the economic well-being,
social equity and inclusivity of indigenous and other local communities. It
is the official policy to maintain a national forest cover of at least 50
percent, given the effective implementation of national policy guidelines for
forest conservation and management together with the execution of an
effective forest certification scheme by the Malaysian Forest Conservation
Council (MTCC). The concern with respect to the cultivation of oil palm on
peatland is no longer valid in the light of the recent official announcement
by the Sarawak state government that there will be no more logging
concessions nor issue of new licenses for oil palm cultivation on peatland.
Accordingly, this HCS+ pathway can be considered as being largely
irrelevant and inapplicable to the Malaysian situation.
4
Comments Directed to Specific Paragraphs in the Extended
Summary
From a climate perspective there is no threshold above which emissions are
relevant and below which they are not. The determination of a threshold can
therefore not be based only on climate considerations, but must build on a general
and widely accepted concept of what constitutes a significant forest. This includes
consideration of its carbon stock, but also other important aspects including its
ecosystem services and biodiversity. In our expert judgement, guided by a global
overview, HCS forests can be defined as those having at least 75 tonnes of carbon
per hectare (tC/ha) in above-ground carbon (AGC). Such forests should not be
converted to oil palm.
27.
In determining the changes in carbon stocks between 1990 and 2002, the National
Forest Inventories were used to account for changes in carbon stocks in the forest.
Significant reduction in carbon stock was noted in Good Forest between NF1 (1972)
and NF2 (1982), from 175t/ha to 133t/ha (Figure 1). However, the carbon stocks
were almost similar between 1982 and 2002. The carbon density of moderate forest
was about 137 t/ha between 1982 and 2002. The logged forests, 11-20 years and
21-30 years and more than 30 years, showed an increase in the carbon density
(Figure 1). At 1-10 and 11-20 years after logging the carbon stocks were less than
100 t/ha. Therefore, the threshold of 75 t C/ha is not an acceptable value for defining
HCS forests.
It is imperative to provide the full list of carbon stock values/ literatures used for the
estimation of AGC. Details including geographical location, soil type, forest
classification, degree of logged forest, and national/ regional forest inventory are
some of the important criteria for assessment and considerations. In addition,
clarification needed for the other important aspects of ecosystem services and
biodiversity.
5
Figure 1. Carbon density according to forest management
Legend: SL = State Land forest; PSSL= Peat swamp in State Land forest; PS= Peat
swamp forest; Logged x-x refers to years after the logging.
32.
We see no need to vary the thresholds for different countries/regions. This is
because heavily forested regions and landscapes contain more opportunities to set
aside forests and thus to compensate for higher site-specific losses of carbon as a
result of conversion. In regions where all land is HCS, regional planning by
governments should determine how best to achieve conservation and development
goals while maintaining carbon neutrality.
It is laudable that regional planning by governments should determine how best to
achieve conservation and development goals in maintaining carbon neutrality in
regions where all land is HCS. It must also be noted that such regions are rare.
According to the World Development Indicators2 for Rural Development and land
use, the percentage of forest area in Malaysia in 2012 is 61.7%, Liberia 44.3%,
Indonesia 51.4%, Colombia 54.3%, Papua New Guinea 62.8% and Brazil 61.8%.
Contrast these figures with developed nations such as Australia, United Kingdom,
Netherlands, Denmark and France with figures of 19.2%, 12.0%, 10.8%, 12.9% and
29.3% respectively. MPOB strongly feels that in order to reflect the socioeconomic consideration of development, the percentage of forest land in a
2
The primary World Bank collection of development indicators, compiled from officially-recognized
international sources. It presents the most current and accurate global development data available,
and includes national, regional and global estimates.
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country should be taken into account in HCS+. This coupled with the fact that
population growth is a certainty and land will be needed not just for agriculture but
also for housing. As much urbanisation will occur in Africa and Asia and this will
encroach on land for agriculture, it is expected that expansion onto forest land will be
inevitable. The fact is that in the past three decades in Malaysia, sizeable areas
under oil palm plantations have been replaced by housing schemes and roads
because of urbanisation. In this regard, it would be more objective if the area
allowed for expansion for oil palm is based on the area of land still available
for expansion, subject to a committed limit for the percentage of forest land
that the country should retain e.g. 50% in Malaysia. This will demonstrate the
understanding and consideration of governmental targets and realities of each palm
oil producing country
In Malaysia, large tracts of forests are being preserved permanently. For every
hectare of oil palm, the country preserves four hectares of permanent forest, which is
a very healthy balance in terms of land use policy. Palm oil plantations are restricted
to the 23.95 % of land set aside for agricultural development in Malaysia. With the
threshold of 75 t C/ha for any development, it will lead to a significant portion of land
which has already been set aside by Malaysia for agriculture falling into the definition
of HCS forests where conversion to oil palm is not allowed. It also means quite a
significant area of NCR (native customary right) land may not be allowed to be used
for oil palm cultivation. How then can this be addressed in the context of socioeconomic development? Would not a governmental legislation override a private
sector driven initiative?
Here, MPOB would like to highlight Article 1 of the 1993 Vienna World Conference on
Human Rights which states that:
“The human right to development also implies the full realisation of the right of people to
self-determination which includes, subject to the relevant provisions of both International
Covenants on Human Rights, the exercise of their inalienable right to full sovereignty over
all their natural wealth and resources”
Therefore, MPOB strongly feels that the Malaysian government should
determine how best to achieve conservation and development goals while
maintaining carbon neutrality.
7
36
Figure 3. Schematic diagram illustrating carbon neutral development of oil
palm at the concession level. Protected forests include HCV, HCS, and other nonHCS forests set aside to help achieve carbon neutrality. Small patches of HCS forest
and peat may also occur within the amber zone.
Since this extended summary stated that HCS forests include forests that have, on
average, a minimum of 75 tC/ha in above-ground carbon (AGC), the amber zone in
Figure 3 should not be categorised as “Carbon deficit from conversion”. This is
because the zone is a non-HCS forests area i.e. less than 75 tC/ ha. It has been
reported that when oil palms reach maturity, oil palm carbon stock is about 90 tonnes
of carbon per hectare (Tomich3 et al. 2002; Casson4 et al. 2007; Yusoff and Hansen5
2007). Consequently, the amber zone should be at least listed as “Carbon neutral
from conversion”. Using the same logic, it would imply that this HCS+ has defined
thresholds and guidelines to ensure that oil palm cultivation will not only be carbon
neutral but also carbon offsetting. These strict guidelines laid down for oil palm
cultivation are rather discriminatory especially when compared with cultivation of
crops with much lower carbon sequestration.
76.
For large companies and associated small-holders, the following elements of
HCS+ should be implemented immediately for new oil palm plantation developments:
Protect high carbon stock forests, and high carbon stock organic soils
Protect HCV forests and other riparian set-asides
Achieve carbon neutral development
Make stronger efforts to promote positive socio-economic outcomes and to measure
and report effectiveness.
Within 5 years the full HCS+ methodology should be refined and fully implemented,
facilitated by learnings from comprehensive field studies evaluating the HCS+
methodology in differing countries. These field studies should include several in
Indonesia, one in Malaysia, and at least one in west/central Africa. These trials
should explore mechanisms to bring independent smallholders within the HCS+
sustainable development framework.
3
Tomich, T., de Foresta, H., Dennis, R., Ketterings, Q., Murdiyarso, D., Palm, C., Stolle, F., Suyant and Van
Noordwijk, M. (2002). Carbon offsets for conservation and development in Indonesia. American Journal of
Alternative Agriculture 17(3): 125–127
4
Casson, A. Tacconi, L. and Deddy, K. (2007). Strategies to reduce carbon emissions from the oil palm sector in
Indonesia. Paper prepared for the Indonesian Forest Climate Alliance, Jakarta.
5
Yusoff, S. and Hansen, S.B. (2007). Feasibility study of performing a life cycle assessment on crude palm oil
production in Malaysia. International Journal of Life Cycle Assessment 12: 50–58
8
It is rather impractical to expect independent smallholders to achieve carbon neutral
development through forest set-asides in view of the small land area that they have
for cultivation of oil palm. For successful implementation of forest set-asides, benefits
and incentives will need to be addressed through appropriate financial mechanisms
and resource mobilization.
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