Jakarta, 16 March 2012 To: Hadi S. Pasaribu Focal Point FIP Indonesia Ministry of Forestry David McCauley CC Program Coordination Unit Regional and Sustainable Development Department Asian Development Bank Ancha Srinivasan Senior Climate Change Specialist Southeast Asia Regional Department Asian Development Bank Michael Brady Forest Program Manager IFC Werner Kornexl Senior Climate Change Specialist The World Bank Gerhard Dieterle Adviser Dear Sirs, We, from the civil society, would like to thank you for inviting us to comment on the draft Forest Investment Programme (FIP) issued by the Multilateral Development Banks (Asian Development Bank, World Bank, and IFC) together with the Government of Indonesia (Ministry of Forestry). However, we consider the draft is far from an attempt to apply the principles of good governance, democracy and human rights in Indonesia. Our disappointments, among others, are concerning the following: 1. FIP draft document that is posted on the Ministry of Forestry website (http://www.dephut.go.id/index.php?q=id/node/8365) is only available in English, not in the Indonesian language, although the document explicitly claims as a document of the Republic of Indonesia. Furthermore, the document is only available on the website. This is not acceptable, because the main target of this document is effective participation of the Indonesian people, especially indigenous and local communities living in and around the forests. In addition, the World Bank and ADB policy itself clearly state that public consultation documents should be available in the national and local languages. Therefore, we question the accountability of these documents to all Indonesian people, especially more than 60 million indigenous peoples and local communities in and around the forest areas. 2. Time given to the public to provide their views and opinions is just two weeks. This duration is too short for the public to read a document over 100 pages thick, and provide substantial views. This indicated FIP is not serious in involving active participation of indigenous peoples and local communities in and around forest areas, where this program will be executed. 3. We do not see public participation has been taken into consideration substantially during the drafting of this document. There is no reference in this draft that reflects the public view taken from consultations, written inputs, or even input provided by the Community Chamber and NGO Chamber of National Forestry Council. 4. This document and its creation process have not clearly described concrete contribution that will be supported to make a national strategy materialise in policy and in practice. Without a clear relationship as such, this document will potentially disrupt the coordination between state agencies and sour the orientation of national policies relating to reducing emissions in the forestry sector. These facts show that the Asian Development Bank, World Bank, IFC as part of the FIP joint team together with the Government of Indonesia did not seriously consider the inputs that had been submitted by Indonesian Civil Society. Due to above reasons, we urge that: 1. There should be documents in Indonesian and local languages (to be swiftly produced based on the location of the planned project site) provided. 2. There should be an extension of the deadline for the public to give their views, as soon as the draft in Indonesian and local languages are made available for public distribution. The duration of this extension should take into consideration the involvement of indigenous and local communities. 3. There should be space for local communities and indigenous peoples to participate fully, taking into account the special needs of vulnerable groups (such as women, children, and elderly). Where the process should provide space and opportunities for local communities and indigenous peoples to participate in providing opinions and views to engage in discussion of this draft. There should be freedom without intimidation or coercion, and for them to accept or not to accept. 4. Availability of documents should not be only via website, but should also actively embrace local community participation through various participation procedures. These procedures should be widely known to the local community, especially taking into account the special needs of vulnerable groups, such as women, children and the elderly. 5. Results of consultation and public participation that are carried out widely and genuinely should be a main reference in the entire process of FIP, including the document creation. 6. Considering that FIP claims to be a national document, the FIP draft document should clarify its relation and position with the National Strategy that is being built by SATGAS REDD+. In relation to the matters above, then we demand the whole process related to FIP be postponed until the occurrence of synchronization with the process of establishing a clear National Strategy that can actually guarantee to save the remaining forests of Indonesia and improve governance in the forestry sector. Signatories; 1. HuMa 2. debtWATCH Indonesia 3. BIC 4. WALHI 5. Greenpeace Indonesia 6. ICEL 7. KPSHK 8. Sawit Watch 9. AMAN 10. ELAW Indonesia Copies: Chairman SATGAS REDD+ Consultant Team