Eleven social and environmental civil society groups and networks sent a joint letter to Asia Pulp & Paper (APP) on 24 April 2013, explaining the substantial social and conservation issues APP has failed to address adequately in its Forest Conservation Policy and associated documents. On 5 February 2013, the Sinar Mas Group’s Asia Pulp & Paper (APP) published a new “Forest Conservation Policy” (FCP). Since then, SMG/APP organized several “focus group discussion” meetings with various Indonesian NGOs to socialize their policy and the “Standard Operational Procedures (SOP)” or Protocols it developed to implement it.

Summarizing their responses to these meetings, the NGOs stated “considering how important and fundamental these issues are, we would like to ask APP to pay serious attention to these notes prior to enacting those protocols”. Key issues raised by CSOs mostly based in Sumatra and Borneo included:
* Weaknesses in APP’s definition of FPIC (Free, Prior and Informed Consent) and its guideline to implement it. Weaknesses in APP’s SOP to resolve tenure conflicts, most importantly its reliance on formal legal/litigation approach which has been proven to fail.
* Lack of conservation benefits of the FCP for Sumatra’s ecosystems and unclear benefits for Kalimantan. Lack of a restoration commitment and provisions for remedying the damages to biodiversity, peat ecosystems and tenure rights caused by the millions of hectares of natural forest cleared to supply mixed tropical hardwood (MTH) to APP’s pulp mills.
* Potential to continue sourcing MTH in violation of FCP due to lack of commitment to stop all MTH supply to all mills, combined with incomplete, weak, non-transparent and not independent monitoring.
* Potential expansion of APP’s pulp and paper production worldwide combined with lack of information on the origin of the wood to cover such expansion, and lack of any conservation commitment covering wood sources outside of Indonesia.
* Lack of evaluation of below ground carbon stocks in peat soils in APP suppliers’ existing plantations and of greenhouse gas emissions from their existing plantations on peat and surrounding peat areas impacted by them, and lack of commitment to reduce such emissions.
NGOs concluded that “APP has to acknowledge and redress the vast environmental and social damages that were caused by the company’s practices and to make ecosystem rehabilitation and the resolution of social conflicts the core of its new policy. The company’s performance will be measured against those benchmarks.”

The NGOs made specific recommendations for changes to APP’s policy and its implementation necessary to show at least on paper that APP is committed to supply responsible pulp and paper.

Burung Indonesia, Huma, Jikalahari, JPIK Focal Point Kalimantan Barat, Link-AR Borneo, Sampan, Scale Up, Titian, Wahana Bumi Hijau, Warsi and WWF Indonesia are NGOs signed the letter.