HCS Science Study:
Draft Synthesis Report
General Comments
The report
Although the report is well intentioned and thought out, it is not entirely reader-friendly.
It took a number of readings before one could appreciate the information given in the
report. The feeling is that the report was condensed from a more comprehensive writeup but in the process of summarising it is probable that some information were lost,
leaving gaps in the report.
The main objectives of the High Carbon Stock Science Study are to come up with a
Synthesis Report to provide the following:

A definition of HCS forests that is based on the level of net GHG emissions from
biomass and soils that would result from their conversion to oil palm plantations;

Threshold values for GHG emissions to enable the identification of forests where
conversion to oil palm is acceptable. The thresholds will vary geographically to
take account of the regional socio-economic context (and thus the variable social
welfare benefit resulting from new plantation development) in Southeast Asian
and African countries where expansion of the oil palm industry is planned;

A practical method for identifying and delineating (mapping) these HCS forests
on the ground; and

Guidance on how to accommodate the rights and livelihoods of local
communities and indigenous peoples when implementing a future HCS approach
to land use planning.
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The commendable feature of the study is that it also addresses the need for a
developing country to alleviate poverty among economically deprived indigenous and
local communities, thereby elevating overall national prosperity.
Definition of a forest
The fact that to-date that there is no consensus on the definition for a forest indicates
the lack of knowledge in forest science coupled with the complexity of the situation. It is
also because of this lack of clear definition for forest that the term “deforestation” is
meaningless and it follows that the talk about “zero deforestation” does not also make
sense. The current situation therefore creates opportunities for parties with their own
private agenda to gain their objectives by coming up with thresholds for defining high
carbon stock to classify land into different forest types.
Traffic light system
The use of a traffic light system to define the thresholds at which conversions are
allowed, allowed under certain conditions or not allowed is too inflexible a system for the
aim of addressing/accommodating the developing needs of countries where there are
many opportunities (land) for socio-economic development.
Conservation of forest
It is agreed that development of land for agriculture including oil palm must be carried
out with proper planning. At the Rio Earth Summit 1992, Malaysia has pledged to
maintain at least 50% of the country’s land under forest cover. We
“We are fully committed to our pledge of retaining a minimum 50 percent level of forest
and tree cover in perpetuity”
Tun Dr. Mahathir Mohamad
Former Prime Minister of Malaysia
13 September 1993
Official Opening of the
14th Commonwealth Forestry Conference
Since then, twenty three years later, Malaysia continues to honour this pledge. Its 100year legacy in forest management notwithstanding, Malaysia continues to raise the bar
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on
Sustainable
Forests Management
(SFM) standards,
notably through
the
implementation of the Malaysian Criteria and Indicators (MC&I) but also through its
enforcement and international benchmarking activities.
Land use policy
According to the World Development Indicators1 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. In order to reflect the socio-economic consideration of development, the
percentage of forest land in a 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. 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.
Therefore, in the development of the oil palm industry in Malaysia, a country aiming to
transform into a high-income nation by the year 2020, besides the attention on
conservation of forests, we should also take note of 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”
1
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.
3
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 portion of land which has already been
set aside by Malaysia for agriculture falling into the red or amber zone. 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?
LIDAR
It is also important to revisit the use of LIDAR for determination of threshold values
bearing in mind the cost implications, especially for small and medium estates as well
as, very importantly, smallholders. It must be borne in mind that there are other costs
involved with respect to stakeholder surveys, HCV assessments and soil surveys which
involve a relatively high financial outlay. While cost estimates have been provided in
the Report, in actual fact it can be expected that there will be much higher expenditure
involved for the expertise to interpret the image analyses and derive the required data.
Comments by paragraph
Paragraph No. 14
The HCS study is supposed to relate to the focus on GHG emissions. However, there
is no indication of the relationship between C and GHG emissions. For example, one
needs to know how much GHG will be emitted from an area containing biomass of 75 t
C/ha or a soil carbon of 75 t per ha. C emissions were mentioned in various parts of the
report and although this can be converted to GHG emissions in terms of CO 2, it is rather
confusing C emissions, C and GHG emissions are not clearly stated.
Paragraph No. 16
In the green zone the carbon stock of an oil palm plantation averaged over its entire
cycle must be larger than that of the unconverted land over the same period. Also in
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Para 90 it was stated that Loss of carbon stock (resulting in GHG emissions) will be
only one factor considered when determining whether a forest should be converted to
oil palm.
It is noted that the report does not give a value for oil palm carbon stock and value is
important in determining the change in carbon as a result of conversion to oil palm and
also a fair threshold value for classifying into the red, amber and green zones.
It has been reported that when oil palms reach maturity, oil palm carbon stock is about
90 tonnes of carbon per hectare (Tomich2 et al. 2002; Casson3 et al. 2007; Yusoff and
Hansen4 2007). Based on MPOB’s latest research (pending publication), the carbon
stock value of oil palm oil of 28 year is in 72 t C/ha and 21 year palm is around 45 t
C/ha.
Paragraph No. 20
It was propose that an upper threshold for loss of soil carbon over a 25 year crop
rotation that is equivalent to the biomass threshold (75 t C/ha) be used as the guide for
the traffic light system. A detailed justification on why and how this figure was arrived at
is lacking.
Paragraph No. 22
It was mentioned that the upper threshold i.e. the boundary between the amber and red
zone would be the same for different countries and regions.
This would not be in-line with the second objective of the study which states that:
The thresholds will vary geographically to take account of the regional socio-economic
context (and thus the variable social welfare benefit resulting from new plantation
2
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
3
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.
4
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
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development) in Southeast Asian and African countries where expansion of the oil palm
industry is planned.
Paragraph No. 65 and 66
It was recommended that a threshold of 100 t/ha be used as guide for conversion as it
corresponded to secondary forests of about 20 years of age in tropical areas where oil
palm is established. These secondary forests are considered native advanced growth
secondary forests. However, it is not clear how this 100 t /ha (equivalent to 50 t C/ha)
was determined.
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.
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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.
Therefore, an estimated value of 100 t C/ha based on carbon stocks from
disturbed/secondary forests (Henson5, 2009; Morel6, 2009) is the more practical
threshold.
Paragraph No. 68 and 117
The report proposed a soil carbon threshold expressed in terms of net emissions that is
equivalent to the biomass threshold (75 t C/ha). The soil threshold thus allows a net loss
of soil carbon of a maximum of 75 t/ha over the crop rotation.
If the justification for the biomass threshold is not sufficient or clear, the threshold for
soil will similarly be questionable.
Setting the threshold of a 75 t/ha for soil carbon means that no expansion on peat is
allowed. This will affect the smallholders whose available land for agriculture is peat
land. This would mean that the socio-economic aspect is not addressed.
The report also stated that there is no globally accepted definition of peatland.
However, recently Malaysia has recently come up with the Unified Peat Classification
System (UPCS) 7for tropical peat8. This system characterises peat based on its
maturity i.e. sapric, hemic or fibric.
It should also be taken into account that nearly all the studies to-date have been carried
out on generic peat in the absence of a suitable classification system which
differentiates peat into sapric, hemic and fibric types and further into classes,
subclasses etc.
Available classification systems have been influenced by/adapted
5
Henson, I. E. (2009). Comparative ecophysiology of oil palm and tropical rain forest. Chapter 1: Sustainable
production of oil palm: A Malaysian Perspective (Eds Gurmit Singh, Lim KH, Teo, L; Chan, KW). Published by the
Malaysian Palm Oil Association, Kuala Lumpur, 1-52.
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Morel, A. (2009). Estimates of Aboveground Biomass Forest and Oil Palm Values for Sabah, Malaysia. University
of Oxford, Environmental Exchange Institute, September 2009.
7
Veloo, R., et al., Classification of tropical lowland peats revisited: The case of Sarawak, Catena (2014),
http://dx.doi.org/10.1016/j.catena.2014.01.004
8
Paramananthan and Wahid (2014). Soils of the lower and middle Baram river basin. Published by the Malaysian
Palm oil Board
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from those which have been developed for temperate peat and therefore are not
applicable for tropical soils. Now, the UPCS is applicable – perhaps with some
adaptation - to any tropical peat situation in the world. This means that data from
generic peat is highly questionable
Conclusion
The report has not achieved the objectives originally set out in the study. The guidance
on how to accommodate the rights and livelihoods of local communities and indigenous
peoples has not been achieved because the threshold value of 75 t C/ha will lead to a
lot of smallholders being unable to develop their land for oil palm.
Since the lower threshold is set at a point where C stock in plantation is equal to that in
land without conversion (both averaged over 25 years) it is important that the C stock in
oil palm plantation is determined. This value has not been identified in the report. If is
important in view of publications which reported that the carbon stock of oil palm of 25
years can be 75 t C/ha or higher. This would make the upper threshold of 75 t C/ha
biomass rather odd because the upper threshold is also the lower threshold.
The report talks about threshold values of GHG emissions but these have not been
identified although the threshold value for biomass carbon loss and soil loss have been
set at 75 t C/ha.
The proposal to use LIDAR needs to be re-calculated to obtain more accurate estimates
because of cost implications for small and medium estates and smallholders.
With the current development to classify peat based on UPCS, it is timely to revisit past
reports on peat emissions and carbon stock which were derived from work on generic
peat.
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