june 2018 - rspo.org

RSPO No deforestation

consultancy: high forest

cover countries

Consultancy report on definitions and recommendations to the RSPO

June 2018

RSPO No deforestation consultancy: High Forest Cover Countries

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About The Proforest Initiative The Proforest Initiative supports governments, companies, civil society

organisations and other stakeholders with responsible production and sourcing of

forest products and agricultural commodities such as timber, palm oil, soy, beef

and sugar.

The Proforest Initiative is part of the not-for-profit Proforest Group, whose

mission is to help people produce and source natural resources sustainably. We

work with others to transform commodity supply chains and sectors through

developing awareness about sustainability, helping to generate commitment to

better practice, supporting implementation of these commitments in practice and

working across sectors and scales to increase the positive impact.

The Proforest Initiative was established to use our expertise and experience to

contribute to this goal more effectively through long-term programmes. We

support multistakeholder initiatives, build local capacity to deliver improved

practices and develop mechanisms to accelerate the practical implementation of

sustainability in agricultural and forest landscapes. We develop tools, guidance

and practices that can be adopted by producers, supply chain organisations,

governments and civil society, and build long-term programmes in partnership

with other organisations.

The Proforest Initiative team is international and multilingual and comes from a

wide variety of backgrounds, including industry, academia and civil society. This

allows us to work comfortably with diverse organisations in a range of cultures.

We have in-house knowledge of more than 15 languages, including English,

Bahasa Indonesia, French, Mandarin, Portuguese and Spanish.

The Proforest Initiative is a registered charity (non-profit organisation) and is

overseen by an independent board of trustees.

For this report, your contact person is:

Mike Senior

[email protected]

The Proforest Initiative

South Suite, Frewin Chambers,

Frewin Court, Oxford OX1 3HZ

United Kingdom

E: [email protected]

T: +44 (0) 1865 243439

W: www.proforest.net

The Proforest Initiative is a registered charity in

England and Wales (Charity no. 1137523) and a

company registered in England and Wales

(Company no. 7293440).

mailto:[email protected]

mailto:[email protected]

http://www.proforest.net/


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Table of contents 1 Introduction & background ------------------------------------------------ 6

1.1 Consultancy objectives --------------------------------------------------------------- 6

2 Methodology ------------------------------------------------------------------- 7

3 Framing RSPO’s vision on deforestation ------------------------------- 10

3.1 RSPO’s vision and goals-------------------------------------------------------------- 10

3.2 No deforestation and palm oil’s image ------------------------------------------ 12

3.3 Implementing ND in practice ------------------------------------------------------ 13

3.4 The high forest cover debate ------------------------------------------------------ 13

3.5 RSPO’s role in tackling deforestation -------------------------------------------- 19

4 Definitions---------------------------------------------------------------------- 20

4.1 Forest ------------------------------------------------------------------------------------ 20

4.2 Carbon and GHGs --------------------------------------------------------------------- 25

4.3 High forest cover ---------------------------------------------------------------------- 27

4.4 Spatial scale ---------------------------------------------------------------------------- 35

4.5 Development status and poverty ------------------------------------------------- 39

4.6 Statistics on potential high forest cover countries --------------------------- 41

5 Approaches and interventions ------------------------------------------- 44

5.1 Lessons from Forest Stewardship Council -------------------------------------- 44

5.2 Defining which areas to protect --------------------------------------------------- 45

5.3 Assessment requirements ---------------------------------------------------------- 47

5.4 Analysis of options discussed by RSPO P&C TF -------------------------------- 47

6 Scenarios/options ------------------------------------------------------------ 48

6.1 Guiding principles --------------------------------------------------------------------- 48

6.2 Defining HFC countries -------------------------------------------------------------- 49

6.3 HFC approaches ----------------------------------------------------------------------- 51

Annex 1: RSPO TF5 HFC approach justification --------------------------- 54

Annex 2. Profiles of selected HFC countries ------------------------------- 61

Annex 3: High Forest Cover case studies synthesis ---------------------- 63


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List of Acronyms BAU Business-As-Usual

CDM CLEAN DEVELOPMENT MECHANISM

CGF Consumer Goods Forum

CPO Crude Palm Oil

CSPO Certified Sustainable Palm Oil

ESIA Environmental & Social Impact Assessment

FMU Forest Management Unit

FPIC Free, prior and informed consent

FSC Forest Stewardship Council

GHG Greenhouse Gas

HCSA High Carbon Stock Approach

HCS High Carbon Stock

HCV High Conservation Value

HCVRN HCV Resource Network

HCVNI HCV National Interpretation

HFC High Forest Cover

HFCC High Forest Cover Country

HFCL High Forest Cover Landscape

HFLD High-Forest, Low-Deforestation

IFL Intact Forest Landscape

LCA Life Cycle Analysis

LDF Low Density Forest

LULUCF Land Use, Land Use Change and Forestry

MDF Medium Density Forest

ND No Deforestation

NGO Non-governmental organisation

NDPE No deforestation, no Peat, no Exploitation

NPP RSPO’s New Planting Procedure

P&C RSPO’s Principles & Criteria for the production of sustainable

palm oil


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PNG Papua New Guinea

REDD+ Reducing Emissions from Deforestation and forest Degradation

RSPO Roundtable on Sustainable Palm Oil

RSPO ND RSPO P&C Review Task Force’s “No deforestation” sub-group

SiHA Simple Historical Approach

SpHA Spatial Historical Approach

TF RSPO’s P&C Review Task Force

UNFCCC United Nations Framework Convention on Climate Change

VCS Voluntary Carbon Standard

WIA Welfare Impact Assessment

WRI World Resources Institute

YRF Young Regenerating Forest

ZND Zero Net Deforestation


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1 Introduction & background The Roundtable on Sustainable Palm Oil (RSPO) Principles and Criteria Review

Task Force is currently reviewing the P&C with the aim of finalising the new P&C

by November 2018. A critical issue for RSPO and its stakeholders in the P&C

review is the issue of “No deforestation”, and the P&C Review Task Force has

agreed to include requirements for “No deforestation” under Criterion 7.3.

In the draft of the revised P&C for the first public consultation in August 2017, it

was stated that “there is clear intent from the RSPO P&C Review Task Force to

include in addition, requirements for “no deforestation” potentially using the HCSA

[High Carbon Stock Approach] toolkit and methodology as a reference point.”

At present the P&C Review Task Force has not reached consensus on the

methodology or wording that will be included in the new standard to implement

“No deforestation”. In particular, the Task Force recognises the following:

- The current HCSA methodology and toolkit applies to fragmented tropical

moist forest landscapes, and could be adopted for these contexts in the

RSPO P&C,

- The need to look at how inclusion of a “no deforestation” requirement

would be applied in “High Forest Cover Landscapes or Nations, that are at

high risk of deforestation”, and

- “Preventing responsible oil palm development in such areas may result in

the development of other crops instead, defeating the purpose of RSPO.”

To try and address the above challenges the RSPO released a call for tender for

two consultancy projects on “Input to development of No Deforestation element

of RSPO P&C Criterion 7.3”. The proposed objective of these consultancy projects

was to provide technical support to the RSPO Principles and Criteria Review Task

Force on the No Deforestation (ND) element of Criterion 7.3. The call for tender

was divided into two parts: A) High Forest Cover Countries, and B) Application to

small and medium growers.

This report is the output for Part A: High Forest Cover Countries.

1.1 Consultancy objectives

The Terms of Reference for the consultancy specified that the work will include

the following:

• Desk study, to include review of relevant peer-reviewed scientific

literature around High Forest Cover (HFC) countries and landscapes;

• Collate information, case studies and experience relevant to HFC

countries incorporating information from HCSA studies, (e.g. Olam, New

Britain Palm Oil, and other companies that have conducted HCSA studies);

• Propose definitions of High Forest Cover and identify the countries where

HFC process might be applied based on different methodology

approaches (carbon thresholds, % forest cover, % forest cover vs arable

land, poverty index);

• Map out a possible country level process; and

• Suggest how this links to support the development of NI processes.


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2 Methodology This work was conducted in the following four phases. The methodology was

developed based on the ToR prepared by RSPO and the consultants’ experiences

from other similar processes. Throughout the work the consultants had regular

contact with the RSPO P&C Review Task Force’s (TF) “No deforestation” Interim

Group (NODIG) through calls and via email to support the process and ensure the

work remained focused on the required deliverables.

2.1.1 Phase 1: Document review and targeted consultation

The first phase collated an overview of the current status of knowledge on HFCL

definitions, social dimensions, case studies, implementation challenges and

policies, based on:

- A desk-based literature review of relevant peer-reviewed literature,

- Targeted consultation with a limited number of selected experts, e.g.

HCSA members, companies operating in HFCLs, scientists, social and

environmental NGOs and policy makers,

- Collation of relevant case studies of proposed palm developments and

HCS assessments in HFCLs, e.g. Olam, New Britain Palm Oil, Sime Darby,

Golden Veroleum, Sipef, and

- Existing policies or approaches for avoiding or limiting deforestation in

HFCLs, e.g. HCS+, FSC experience on IFLs (motions 12 and 65)

The following stakeholders were directly consulted during this phase:

Name Organisation Sector

Reuben Blackie IDH NGO

Alwi Hafiz GVL Grower

Sander van den Ende NBPOL Grower

Philippa Atkinson Independent Social and economic

researcher and

consultant

Jan Pierre Jarrin Peters Oleana Miller and refiner

Anders Lindhe HCVRN NGO/technical

organisation

Mike Zrust Daemeter Consulting Technical

organisation/consultancy

Grant Rosoman was also contacted, as a Greenpeace representative, to request a

consultation call, but the call did not proceed due to scheduling issues.


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In addition, the HCSA High Forest Cover Landscape WG co-chairs were contacted

to request relevant information for the literature review. The HCSA co-chairs and

Executive Director (Grant Rosoman, Perpetua George and Judy Rodrigues) were

also contacted at the start of the consultancy to notify them about the work.

As well as direct consultations, the consultants were able to draw on previous

conversations with a range of private sector, NGO and government stakeholders

through initiatives such as the HCSA, Africa Palm Oil Initiative, The Forest

Dialogue’s “Understanding Deforestation Free” Gabon chapter amongst others.

2.1.2 Phase 2: Development of scenarios

Based on the results of Phase 1, a series of potential scenarios were developed,

with a strength-weakness analysis. These scenarios cover the following:

- Definitions for High Forest Cover based on various parameters, including

carbon threshold, % forest cover, forest quality, forest area/patch size,

- Definitions of landscape and/or scale,

- Definitions and thresholds for HFC countries/jurisdictions based on

income or development status,

- Identification of potential HFC countries, jurisdictions or landscapes,

- Possible options for an RSPO HFC approach, to include:

o Pre-conditions for development (including social requirements),

o Scale of implementation (e.g. concession/management unit,

landscape or jurisdiction),

o Roles of/links to RSPO National Interpretation processes,

o Minimum outputs/requirements, e.g. area or % to be protected,

social outcomes,

o Due diligence and assessment process, e.g. use of HCV and HCS

assessments

- Gaps and outstanding questions

- Proposed preliminary timeline and process for finalising RSPO’s HFC

approach

2.1.3 Phase 3: Presentation & consultation on scenarios and definitions

Scenarios developed in Phase 2 were presented to the RSPO P&C Review TF and

RSPO NODIG during the TF5 meetings in Kuala Lumpur on 14-16th May 2018 (as

well as during pre-meetings with the NODIG). Draft findings and

recommendations were shared with the NODIG twice prior to the TF5 meetings

during update calls.

The objective of Phase 3 was to receive TF and specifically ND sub-group member

feedback on potential definitions and scenarios to feed into Phase 4.

A summary of calls and meetings held with the RSPO during this consultancy is

provided here:

Date (2018) Meeting

29th March Kick-off call with NODIG

19th April Update call with NODIG


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4th May Update call with NODIG to present initial findings &

recommendations prior to meeting with HCSA on 11th May

13th May Preparatory meeting with NODIG to present results of Phase

2

14-16th May Presentation of Phase 2 results to RSPO P&C TF & technical

support to NODIG

2.1.4 Phase 4: Finalisation of scenarios and proposed process for formalizing an RSPO HFC approach

The final phase incorporated feedback received from the TF and ND sub-group, to

revise proposed definitions and scenarios. The objective of this was to refine

definitions and scenarios into a smaller set that can practically be taken forward

by the RSPO P&C TF for wider consultation and finalisation.

The key outputs of this phase were the refined definitions and scenarios, as well

as a proposed process to be followed by the RSPO after May for formalising and

finalising a RSPO HFC approach.

Note: the above methodology was developed at the start of the project as a

proposed approach. In practice, the work required a more iterative discussion with

the NODIG throughout, rather than a strict 4 phase process. As a result, the final

outputs produced included separate outputs not covered in the original scope and

omitted some areas deemed less relevant by the NODIG.


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3 Framing RSPO’s vision on deforestation Before diving into the technical details of definitions or discussing potential

approaches to tackling deforestation, it is important to take stock of RSPO’s wider

vision and goals and how these may inform the RSPO’s vision on tackling

deforestation. In turn this vision must be informed by market signals, wider

commitments and initiatives in the global palm sector.

3.1 RSPO’s vision and goals

As a voluntary private sector initiative, the RSPO was established in response to

consumer and market demands for sustainability in the sector, to be a tool that

allowed consumers to reliably source sustainable palm oil. Although RSPO is a

multi-stakeholder, membership organisation, ultimately as a voluntary initiative it

must respond to consumer demands on sustainability, including on deforestation.

However, through its vision and mission the RSPO seeks to do more than simply

respond to consumer demands, with the vision to:

“transform markets to make sustainable palm oil the norm”.

This bold vision is also supported by the RSPO’s new Theory of Change (ToC)

which specifies as goals broadly focused around People, Planet and Prosperity of

“Resilient & Healthy Landscapes & Communities”, and “Green & Inclusive

Growth”. The ToC also specifies desired impacts as shown in Figure 1, as well as

more tangible desired long-term outcomes. The outcomes of greatest relevance

to the concept of “No deforestation” are as follows:

- Biodiversity protected, - Ecosystem services enhanced, - Land degradation neutrality, and - Sustainable land use planning.


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Figure 1. RSPO’s Theory of Change, vision, goals and the intended impacts.

The essence of RSPO’s vision was also captured in the revised P&C draft for public

consultation in 2017 in wording on No deforestation for Criterion 7.3, which

stated that RSPO wants to “transform all markets worldwide” by adopting a

“highly inclusive approach that is accessible to less developed high forest cover

areas; and … the free, prior, informed decisions of customary land rights holders”.

The draft text for 7.3 stated that RSPO’s aim was “to achieve forest landscape

conservation and manage conservation areas according to RSPO requirements”.

In summary and most critically, RSPO needs to ensure that it not only avoids

deforestation caused by oil palm, but needs to actively contribute to reducing

and ultimately stopping deforestation for oil palm production. In practice, to

transform global markets means taking into account:

1. Future, global CPO consumption trends as well as trends in consumption

of RSPO-certified CPO (CSPO). By continent, the main CPO consumers are

Asia (53%, of which 17% in India and 9% in China), Europe (24%), Africa

(16%) and North America (5%).1 However, by far the main markets for

CSPO are Europe and North America (30% of global production). Future

growth in CPO demand is set to continue increasingly dramatically with

1 Imports by value, taken from https://atlas.media.mit.edu/en/profile/hs92/1511/

https://atlas.media.mit.edu/en/profile/hs92/1511/


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global trade in palm oil to increase by 24% by 2026,2 and demand is

expected to be highest in Africa and Asia3, and

2. Future, global CPO production trends. Numerous palm producer and high

forest countries have ambitious growth plans for the sector, e.g. the PNG

government plans to increase production from 0.5 to 1.5 million tonnes of

CPO by 2030 and Gabon to develop a further 300,000 ha of palm (under

the “Gabon Emergent” agenda). Whether these projections are met is

another question, but what is undeniable is that large areas have been

identified or allocated for palm development (540,000 ha in Liberia4, at

least 500,000 ha across the Congo Basin5).

If RSPO is to have global influence and transform global markets it needs to find a

balance that:

- Satisfies sustainability demands in key current markets, such as Europe

and North America,

- Ensures greater uptake in Asian and African markets, and

- Supports sustainable growth in new production areas.

3.2 No deforestation and palm oil’s image

“Brand” palm oil continues to struggle in European and North American markets

as a result of NGO campaigns as well as lobbying by European food and agri-

business groups. Whatever the motives for the campaigns, criticism has focused

on claims of deforestation, land-grabbing and worker exploitation in the industry.

This is wrapped up in criticism, by international social and environmental NGOs, of

palm’s ‘large-scale plantation model’ as one that contributes little to improving

the livelihoods of rural populations.

This has led to a large number of companies in the palm supply chain making

commitments to No Deforestation, Peat or Exploitation (NDPE) over the past 5

years. In practice these mean committing to avoiding conversion of, and in some

cases protecting, High Conservation Value (HCV) and High Carbon Stock (HCS)

areas. Furthermore, the EU Parliament has voted to ban palm oil in biofuels by

2020.

Whilst the demand for ‘no deforestation’ may have originated from markets and

consumers in Europe and North America, the scope of the commitments made is

now much wider. For example, the Consumer Goods Forum (CGF) has also been

an important initiative for change and represents 400 companies across 70

countries and CGF has committed to ‘zero net deforestation’ by 2020, and in its

2 USDA Agricultural Projections to 2026

3 Pacheco P, Gnych S, Dermawan A, Komarudin H and Okarda B. 2017. The palm oil global value

chain: Implications for economic growth and social and environmental sustainability. Working Paper

220. Bogor, Indonesia: CIFOR.

4 HCS+ Consulting Study 17: Palm oil in Liberia

5 Earthsight. 2018. The Coming Storm


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Sustainable Palm Oil Sourcing Guidelines it expects members to protect HCV areas

and encourages them to protect HCS areas.

In the palm sector in Indonesia and Malaysia, company groups with NDPE policies

cover 74 percent of the total refinery capacity in these countries and 85% of

global refining capacity.6 The upshot of this is that these companies should be

aiming for all of this production to be deforestation-free by 2020.

3.3 Implementing ND in practice

To date many companies have struggled to fully implement their ND

commitments. The High Carbon Stock Approach (HCSA) was developed as a tool

for supporting companies to implement ND in practice and has been used in

allowing large companies to identify HCS forest to avoid (and in theory protect) in

fragmented moist tropical forest landscapes. HCSA decided not to adapt its toolkit

for High Forest Cover Landscapes (HFCLs) – recognising that it is a toolkit for ‘no

deforestation’, and so could not sanction deforestation. HCSA will only allow

some limited development for ‘legacy cases’ and will focus on alternative

development options in HFCLs.

Therefore, HCSA still faces several key implementation gaps:

1. How do you implement ND in smallholder and high forest cover contexts?

2. How do you avoid ‘leakage’ and ensure that forests are not only avoided

by companies, but are actually protected from deforestation by other

actors?

It is important to note that most NDPE commitments also include commitments

to improving rural livelihoods and ensuring smallholder inclusion – two factors

often in conflict with ND, especially in high forest cover contexts. This conflict has

not been well communicated in consumer markets, with deforestation messaging

dominant over social messaging, and there are as yet no widely accepted tools for

how to implement these different commitments on the ground. Although some

pilot projects are now underway to grapple with this at a landscape-level, few

consumers are aware of the challenges, resources and time involved in

simultaneously and quickly implementing ND, smallholder inclusion and rural

livelihood development on the ground.

3.4 The high forest cover debate

Advocates for sustainable palm oil are broadly in agreement about the need for

ND in fragmented landscapes, but there remains significant debate about high

forest cover (HFC) contexts. The debate has raged for a number of years through

the HCS convergence process and more recently in the HCSA’s HFC Landscapes

Working Group.

On the surface, the argument is polarised between:

6 http://www.aidenvironment.org/publication/4927/

http://www.aidenvironment.org/publication/4927/


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- On one hand the urgent need to stop deforestation globally and protect

the world’s last remaining large blocks of forest along with their

biodiversity and the livelihoods of peoples dependent on them, and

- On the other, the view that some deforestation is required to support

economic and rural development in what are typically some of the world’s

poorest countries or areas.

In reality, there are some more nuanced concerns on both sides of the debate

that have arguably not been objectively or impartially considered – and as a result

have not allowed the debate to advance. These include:

- A slippery slope: Many NGOs fear that allowing some limited

deforestation in HFCLs will set a precedent or open a backdoor to allow

further deforestation, e.g. once mills are established then opportunistic

clearance will follow,

- Business as usual & unintended consequences: Many feel that a strict

‘gross zero deforestation’ requirement for palm oil in HFCLs will have

unintended consequences of even higher deforestation resulting from

leakage to other crops or actors. It is felt that such a hard-line approach

ignores the business-as-usual trajectory in most HFC countries.

Unintended consequences may result from:

o Pushing responsible companies away from these high-risk areas,

leading to concessions being given to less reputable companies

o Ignoring other primary deforestation drivers in HFCLs. For

example, annual crops cause 66% of deforestation in Central

Africa7 and in PNG 48% of deforestation is caused by commercial

logging and 46% by subsistence agriculture (compared to 1.6% for

agriculture and mining). In most cases, these threats are only

increasing with logging ongoing and subsistence agriculture

increasing its impact as rural populations grow.

- Community expectations: There has been a tendency to oversimplify the

social aspects of deforestation in HFCLs. For example, on one side

portrayals of all local communities objecting to oil palm development,

versus claims that communities are desperate for jobs. The reality is often

highly variable both within individual communities and across

geographies:

o In instances where growers already have some footprint in the

area, it is not uncommon for communities (or at least some

community members) to expect some level of palm development

due to desires for jobs and the absence of other immediate

alternatives. In the context of PNG in particular, where 97% of

land is customarily owned, many clans actively want companies to

develop oil palm on their land because they receive a land rent

and share of the profits from the company.

7 Mosnier, et al. 2017. CoForTips Congo basin forests: tipping points for biodiversity conservation

and resilience. Final Report (La modélisation des changements d’utilisation des terres dans les pays

d’frique Centrale 2000-2030).


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o Ideas that all communities want to or even are able to live

exclusively off traditional forest livelihoods and/or subsistence

agriculture does not reflect the reality of all situations. In fact, in

some cases such ideas may even be a threat to communities’

health or food security given that palm growers are often only

allocated land by government after forest has been logged and

degraded, and with growing local populations putting increasing

pressure on forest resources, “traditional” livelihoods may no

longer be able to provide reliably healthy or diverse diets. It could

be argued that the presence of a responsible company in such

situations could help to support a) a transition to a cash income,

b) help communities to secure their land tenure of forests and

gardens, and c) improve productivity of food crop areas or protect

forest from illegal encroachment.

- Rural livelihoods: Oil palm is often touted by companies as one of the

best options for rural development where rural populations are unskilled

as it provides jobs and other social infrastructure. Conversely,

international NGOs often argue that the ‘large-scale plantation model’

does not delivery adequate social benefits to rural populations, with

evidence of declining food security and low or inadequate wages.

- Messaging: A huge amount of attention has been given to ND

commitments in international media and by NGO campaigns, and many

companies are bought into this. As a result, there is an apparent

reluctance to adjust or nuance this message to communicate the

challenge of HFCLs because of fears it may undermine credibility.

The above concerns & unknowns can be partially answered by an analysis of

existing evidence (where available). This is synthesised in the table below:

Concern Evidence available or justification

“Slippery slope” • Studies have shown that development in the form of roads or palm oil mill

construction frequently trigger further deforestation8 – suggesting that

establishment of palm operations in HFCLs (with accompanying mills and

roads) may lead to some associated deforestation. However, much of this

seems highly likely, if not more likely, to happen whether or not RSPO-

certified operations are present. RSPO can be a tool to reduce

deforestation compared to business-as-usual (BAU), as shown by a recent

study9.

• Other initiatives to limit deforestation are far more advanced than when

palm development first started in Kalimantan and Sumatra 40+ years ago,

8 e.g. Laurance, W. F., Albernaz, A. K., Schroth, G. , Fearnside, P. M., Bergen, S. , Venticinque, E. M.

and Da Costa, C. 2002. Predictors of deforestation in the Brazilian Amazon. Journal of Biogeography,

29: 737-748. doi:10.1046/j.1365-2699.2002.00721.x ; Tomita, Atsushi.2017. "Land Change History of

Oil Palm Plantations in Northern Bengkulu Province, Sumatra Island, Reconstructed from Landsat

Satellite Archives" . CUNY Academic Works. http://academicworks.cuny.edu/gc_etds/1857

9 Carlson et al. 2017. PNAS. Effect of oil palm sustainability certification on deforestation and fire in

Indonesia

http://academicworks.cuny.edu/gc_etds/1857


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for example, with improved government regulation and also

government/jurisdictional recognition of RSPO.

• Tropical countries that have managed to somewhat stabilise deforestation

have a balance of approximately 50% forest in their territories, and have

developed diversified economies. For example, oft-sighted best in class

example Costa Rica in fact only has 50% forest cover. Malaysia’s efforts to

stabilise forest cover at 50% of the territory have been supported by fast

economic growth driven by oil & gas, oil palm and technology leading to a

more educated and urbanised population.

Unintended

consequences &

leakage

• Major development is planned in many HFCC/Ls for forestry or agriculture,

e.g. 3 million ha of land allocated to concessions in West Papua/Papua10,

approximately 25% of Congo Basin is under logging concessions11 –much of

which is subject to destructive, poorly regulated logging.12 Non-RSPO

members/non-NDPE committed companies already clearing in Papua

(especially in Merauke Regency, Papua where a huge chunk has been

allocated for logging, pulp plantations or oil palm; Neville Kemp pers.

comm.).

• Although NDPE-committed companies may touch up to 80% of global palm

production13, the major current and projected future demand14 for palm

oil (including biofuels) from Indonesia), Malaysia, India, China and also

sub-Saharan Africa means that market drivers will likely see new actors

emerging or efforts to vertically integrate in order to avoid trading through

NDPE companies – potentially leading to a split market.15 Failing this, it’s

likely that growth in production of other oil crops such as soya oil will meet

the demand (demand for which continues to increase)14 – leading to even

more pressure on land.

• Other commodities or drivers of deforestation and degradation are likely

to fill the void at a production level as companies or communities look for

income sources, e.g. pulp plantations, subsistence agriculture (with

growing populations), etc. Indeed other deforestation drivers like

10 https://chainreactionresearch.com/wp-content/uploads/2017/04/palm-oil-stranded-land-size-

equals-ten-million-football-fields-crr-170407.pdf

11 WRI Congo Basin Forest Atlas; and https://globalforestatlas.yale.edu/congo/forests-and-

logging/logging

12 For example: https://www.reuters.com/article/us-congodemocratic-environment-

idUSKBN0OJ00E20150603

13 https://chainreactionresearch.com/report/unsustainable-palm-oil-faces-increasing-market-

access-risks-ndpe-sourcing-policies-cover-74-percent-of-southeast-asias-refining-capacity/

14 USDA 2017. USDA Agricultural Projections to 2026

15 Earth Innovation Institute. 2016. Making Corporate Deforestation Pledges Work.

earthinnovation.org

https://chainreactionresearch.com/wp-content/uploads/2017/04/palm-oil-stranded-land-size-equals-ten-million-football-fields-crr-170407.pdf

https://chainreactionresearch.com/wp-content/uploads/2017/04/palm-oil-stranded-land-size-equals-ten-million-football-fields-crr-170407.pdf

https://globalforestatlas.yale.edu/congo/forests-and-logging/logging

https://globalforestatlas.yale.edu/congo/forests-and-logging/logging

https://www.reuters.com/article/us-congodemocratic-environment-idUSKBN0OJ00E20150603

https://www.reuters.com/article/us-congodemocratic-environment-idUSKBN0OJ00E20150603

https://chainreactionresearch.com/report/unsustainable-palm-oil-faces-increasing-market-access-risks-ndpe-sourcing-policies-cover-74-percent-of-southeast-asias-refining-capacity/

https://chainreactionresearch.com/report/unsustainable-palm-oil-faces-increasing-market-access-risks-ndpe-sourcing-policies-cover-74-percent-of-southeast-asias-refining-capacity/


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subsistence agriculture are currently primary drivers in Africa and Papua

New Guinea.16

Community

expectations

• Community support for or resistance to oil palm is highly context

dependent. 17 Much coverage is polarised on the issue suggesting either

that palm has universally negative social impacts or that it is a silver bullet

for rural development. The reality is that 40% of palm is produced by

smallholders, many of whom have significantly improved their quality of

life as a result, however, in many cases establishment of large plantations

without FPIC has led to negative impacts on community rights holders.

• It is often stated that local communities are the best forest protectors,18

and this is undoubtedly the case for certain indigenous groups where land

rights are clear and livelihoods are still derived from the forest. However,

in many cases communities (sometimes local, sometimes migrants) are

driving deforestation either for subsistence agriculture or smallholder

commodity agriculture.19

• HCV-HCS assessments often show ‘traditional livelihoods’ less reliable due

to logging and population growth

Rural livelihoods • It is often argued that palm oil production does not support rural poverty

alleviation20, rather leading to food insecurity, loss of land rights etc.

However, there are social benefits from palm development if carefully

managed, e.g. with adequate wages and social infrastructure for workers,

provisions to ensure food security, through smallholder programmes,

etc.21 Once again results are context specific and overgeneralising is

unhelpful.

16 Kissinger, G., M. Herold, V. De Sy. 2012. Drivers of Deforestation and Forest Degradation: A

Synthesis Report for REDD+ Policymakers. Lexeme Consulting, Vancouver Canada, August 2012.

17 E.g. Li TM. 2015. Social impacts of oil palm in Indonesia: A gendered perspective from West

Kalimantan. Occasional Paper 124. Bogor, Indonesia: CIFOR; Obidzinski, et al. 2012. Environmental

and social impacts of oil palm plantations and their implications for biofuel production in Indonesia.

Ecology and Society 17(1): 25.

18 RRI and WRI 2014. Securing Rights, Combatting Climate Change. How Strengthening Community

Forest Rights Mitigates Climate Change

19 Ravikumar et al. (CIFOR). 2017. Is small-scale agriculture really the main driver of deforestation in

the Peruvian Amazon? Moving beyond the prevailing narrative. Conservation Letters 10(2): 170-177;

Forest Trends. 2014. Consumer Goods and Deforestation: An Analysis of the Extent and Nature of

Illegality in Forest Conversion for Agriculture and Timber Plantations.

20 Rhein (RRI). 2015. Industrial Oil Palm Development. Liberia’s Path to Sustained Economic

Development and Shared Prosperity? Lessons from the East.

21 E.g. Atkinson. 2015. Palm oil in Liberia: Missed opportunities and second chances. HCS+ Consulting

Study 17; Zen et al. 2015. High Carbon Stock (HCS) and the socioeconomics of palm oil: Towards

improving the sustainability of the palm oil sector in Indonesia. HCS+ Consulting Study 14.


18

• Smallholders have benefitted significantly from palm in Indonesia,

although there are negative impacts from lack of FPIC, unequal benefit

sharing & poor land rights22.

• Some communities in Liberia are also now supportive of palm

development as a job provider, as companies have improved community

engagement following initial mistakes.21 Similarly, in Papua New Guinea

palm oil production either by smallholder or large estates where land is

leased from customary land owners have led to micro-level economic and

social development.23

Messaging: “no

means no”

• Many campaign groups often cite the rapid rate of climate change and

major contribution of deforestation24, and the loss of biodiversity resulting

from tropical deforestation25, as reasons for urgent action to stop

deforestation for oil palm and other commodities.

• However, recent research has indicated that unsustainable hunting poses

the greatest imminent threat to the survival of endangered vertebrates in

Southeast Asia,26 which is likely to have knock-on impacts on forest

conservation and livelihoods. Evidence suggests that the presence of FSC-

certified companies can help to protect biodiversity through community

engagement and efforts to reduce hunting pressure on threatened

species.27 Can RSPO companies play a similar role through effective

management of adequately sized HCV or HCS conservation areas?

• Given the evidence above, perhaps the most relevant questions are:

• What are the most effective ways of stopping deforestation as

quickly as possible and protecting tropical biodiversity (given the

risks of leakage etc outlined above)?

• How can positive momentum from corporate commitments be

leveraged to actively contribute to stopping deforestation and

protecting biodiversity, rather than simply displacing risk by

avoiding sourcing from high risk or high forest areas?

22 Rist et al. 2010. The Livelihood Impacts of Oil Palm: Smallholders in Indonesia. Biodiversity and

Conservation

23 ITS Global. 2011. The Economic Benefits of Palm Oil in Papua New Guinea

24 http://www.unredd.net/about/what-is-redd-plus.html

25 Alroy, J.2017. Effects of habitat disturbance on tropical forest biodiversity. Proc. Natl. Acad. Sci.

USA 114:6056–6061

26 Harrison et al. 2016. Impacts of hunting on tropical forests in Southeast Asia. Conserv. Biol. 30(5):

972-81

27 Christophersen et al. 2010. 6.2 Addressing the bushmeat crisis through certification. ETFRN News

51: September 2010

http://www.unredd.net/about/what-is-redd-plus.html


19

3.5 RSPO’s role in tackling deforestation

Considering the wider context of corporate “NDPE” commitments, the position of

HCSA, and RSPO’s vision and Theory of Change, RSPO needs to decide what it role

is and vision on tackling deforestation.

Due to its growing market share and its strong role in convening multiple

stakeholder, RSPO is well placed to contribute to halting deforestation, although it

is important to recognise limitations of RSPO: primarily that it is a voluntary

standard for the site-level. This means allowing members to have viable projects

at a site-level, where some deforestation may be needed in order to reduce

deforestation against the BAU scenario in HFCLs.

Efforts are ongoing to explore jurisdictional RSPO certification where impact could

be increased even further, but this report focuses on the potential role RSPO

could play through site-level certification.

In this context RSPO could potentially play a pivotal role in stopping deforestation

High Forest Cover contexts, but only if it stays engaged and relevant and does not

shut the door on viable, sustainable projects in HFCLs. This means building a

positive vision for stopping deforestation, protecting forest and supporting

livelihoods in HFCLs.

Such a vision could support supply chain companies to meet commitments on:

stopping deforestation, smallholder inclusion and improving rural livelihoods

through addressing stakeholder concerns (Table 1).

Table 1. Summary of a positive vision and message for RSPO on allowing deforestation in HFC contexts

Concerns Possible messages

Slippery slope & messaging • Time bound & maximum cut-off. Option to use 2020 cut-off and 2030, or sooner

• Name in P&C: is “No deforestation” appropriate? Or is it more accurate to refer to stopping deforestation and improving rural livelihoods?

Community expectations & rural livelihoods

• FPIC assured

• Social benefits assured through a new plantation model or smallholder model

Climate change • Carbon neutrality

Biodiversity conservation • All HCVs identified and maintained,

• Requirements for corridors or enhanced connectivity,

• Reduced hunting pressure,

• Require ratios of conserve: develop area or percentages of Management units to be protected?


20

4 Definitions

4.1 Forest

Before going through the different criteria that could be considered to define High

Forest Cover, it is worth recalling that there are as many definitions of forest as

purposes of defining forest. This is because forest definitions provide the

conceptual, institutional, legal, and operational basis for the policies and

monitoring systems that drive or enable deforestation, forest degradation,

reforestation, and forest restoration.28

Figure 2. Forest definitions adopted by major international environmental and forestry

organizations28

International environmental and forestry organizations have adopted various

official definitions of forest, even though these are not intended to encompass

the totality of forests’ values and uses.28

In more specific contexts, forest definitions vary depending on their purpose: be it

value for timber; carbon storage; improving livelihoods of forest dependent

people; whether forests are natural or planted; whether forests are pre-existing

or newly established; whether forest are continuous or fragmented; whether

forests are composed of native or non-native species.

4.1.1 RSPO’s forest definitions

The RSPO does not have its own definition of forest in the P&C,29 although a

definition of primary forest is given:

- “A primary forest is a forest that has never been logged and has developed

following natural disturbances and under natural processes, regardless of

its age. Also included as primary, are forests that are used

28 Chazdon et al. 2016. When is a forest a forest? Forest concepts and definitions in the era of forest

and landscape restoration. Ambio.

29 RSPO 2013. Principles and Criteria for the Production of Sustainable Palm Oil


21

inconsequentially by indigenous and local communities living traditional

lifestyles relevant for the conservation and sustainable use of biological

diversity. The present cover is normally relatively close to the natural

composition and has arisen (predominantly) through natural

regeneration”

RSPO also provides for protection of any forests of High Conservation Value, with

Criterion 7.3 requiring that no new plantings have replaced primary forest, or any

area required to maintain or enhance one or more HCVs30.

4.1.2 Forest definitions under the HCV approach

Forests were the original context for the development of the HCV concept: “All

forests are valuable, but some are more valuable than others.” To make this

concept operational, there was a need to define “exceptional” or “significant”

forest values31. The HCV methodology includes 6 conservation values (HCVs)

applicable to forests and any other ecosystem, although it does not provide

specific global definitions of what is a forest. Any forests with significant values

are considered HCVs and are defined with reference to global Common Guidance

for the Identification of HCVs by the HCVRN and its interpretation in different

local or national contexts.

Any forest considered to be of global, regional or national significance is

considered an HCV. The only definitive global forest definition used in the HCV

approach is for HCV 2, which explicitly includes Intact Forest Landscapes (IFLs).

However, forests are also frequently considered HCV under the other 5 categories

– recognising their importance:

- For supporting threatened species (HCV 1),

- As rare or threatened ecosystems (HCV 3),

- For provision of ecosystem services (HCV 4),

- As sources of communities’ basic needs (HCV 5), and

- For cultural sites and values (HCV 6).

The global HCV Common Guidance requires interpreting in each national context,

and is often done through HCV National Interpretations (HCVNIs). Many national

interpretations currently focus on “HCV Forests” – a hangover from before the

HCV approach was expanded to all ecosystems. HCVNIs are important for two

reasons: Firstly, because the generic values include terms like significant, critical

and concentration, which need to be qualified according to the local context to

determine what really are the “High” Conservation values in that context (e.g.

which forest types or species populations). Secondly because appropriate

management of an HCV depends on the level of threat to the value, which can

vary dramatically between countries.

30 Criteria 7.3.1: There shall be evidence that no new plantings have replaced primary forest, or any

area required to maintain or enhance one or more High Conservation Values (HCVs), since

November 2005. New plantings shall be planned and managed to best ensure the HCVs identified

are maintained and/or enhanced (RSPO 2013)

31 HCVRN 2013. Common guidance for the identification of High Conservation Values


22

➔ Both the HCV approach, and the RSPO, use national interpretations to

recognise national priorities and differences, whilst still being framed by

global guidance. In the context of forest definitions, this means that the

HCV approach recognises that what may be considered important forest in

a forest-poor country like Nigeria is unlikely to be considered important in

a highly forested country like Gabon. Consequently, the HCV approach

provides a tool for sustainable land development that aims to protect the

most important values whilst permitting some socially and

environmentally responsible agricultural development.

4.1.3 Forest as ‘defined’ under the HCSA

The High Carbon Stock Approach (HCSA) methodology aims to identify and

protect viable tropical forest. It was developed as a tool for implementing “No

deforestation” in practice in tree plantation and agricultural developments – in

reality it is currently primarily a toolkit for identifying potentially viable forest. The

toolkit was developed for use in low and medium forest cover tropical moist

forest landscapes, where viable agricultural developments can generally be

established at the same time as protecting HCS forest and HCV areas.

HCSA uses field data on levels of biomass, vegetation structure and composition,

together with a view from above (satellite or Light Detection and Ranging –

LiDAR), to create an HCS classification ranging from high-density forest to

degraded former forest areas of scrub and open land32. The HCS vegetation

classes are as follows:

• High, Medium and Low Density Forest: Closed to open canopy natural

forest ranging from high density to low density forest. Inventory data

indicates presence of trees with diameter >30 cm and dominance of

climax species. More detailed parameters for these 3 classes are available

in the HCSA toolkit.

• Young Regenerating Forest: Highly disturbed forest or forest areas

regenerating to their original structure. Diameter distribution dominated

by trees 10-30 cm and with higher frequency of pioneer species compared

to LDF. This land cover class may contain small areas of smallholder

agriculture.

• Scrub: Land areas that were once forest but have been cleared in the

recent past. Dominated by low scrub with limited canopy closure. Includes

areas of tall grass and fern with scattered pioneer tree species. Occasional

patches of older forest may be found within this category.

• Open Land: Recently cleared land with mostly grass or crops. Few woody

plants.

The methodology identifies High Carbon Stock forest (‘viable forest’) to be

excluded from development, and non-HCS areas that can be developed. The line

32 High Carbon Stock Approach Steering Group Toolkit v2. 2017.


23

is drawn based on a combination of forest type and patch size, but can be

generalised as Young Regenerating Forest with core patch size of >10ha33.

Figure 3. HCSA threshold and "definition" of forest

It is important to note that the HCSA forest methodology essentially provides for a

top-down, global definition of forest. The approach does allow

parameters/characteristics of the vegetation classes to be refined for different

countries (with different forest types) – but the threshold is always YRF. This is a

distinct difference from the HCV approach which allows for more national

interpretation.

4.1.4 Why forest definitions matter

The choice of forest definition impacts on assessment of forest cover and forest

cover change. For example, in many cases, forest assessments (such as for the UN

FAO or using Hansen et al. data) do not distinguish between land covered by

natural and planted forests28. Thus, if natural forests are cleared and replaced

with plantations, no net loss of forest cover occurs28. Furthermore, tree harvesting

from managed plantations is not distinguished from clearance of natural forest.28

Using widely adopted structural forest definitions based solely on tree height,

minimum area, and crown cover without considering other parameters or forest

use, countries can show zero net deforestation or even a gain in forest extent,

even while having converted considerable areas of natural forest within the same

time interval.28 In mapping global tree cover, Hansen et al. (2014) included

plantations of oil palm, rubber, and tree monocultures in their definition of forest

cover.

Another major policy consequence of using forest definitions based solely on

indices of forest structure is the inability to differentiate forests disturbed by

logging operations from ‘secondary’ forest regrowth on former agricultural land.28

The ramifications of the choice of forest definition are discussed in Box 1.

33 This is a generalisation and ignores specific permutations of the HCSA Decision Tree. Actual areas

defined as HCS forest depend also on a risk assessment and biodiversity value


24

Box 1: Comparing forest cover statistics for Liberia

Liberia provides an interesting example of the ramifications of choosing different forest definitions. We compared

five different forest cover statistics for Liberia, as presented below:

Forest cover statistics (% of land area)

FAO USGS

EROS34

REDD+ Forest Reference Level35 (>30%

canopy density = national definition)

REDD+ Forest Reference Level

(>10% canopy density)

IFL

43% 68% 68% 83% 3%

This comparison indicates the huge differences that can be seen when using different definitions of forest cover,

and we highlight the following key points of particular relevance to this paper:

Accuracy of GIS methods. Two recent studies (USGS and REDD+) provide very similar estimates, lending support to

current methods based on classification of satellite imagery,

Unreliability of FAO statistics (self-reported) and estimates based on satellite imagery classification,

Is YRF forest? Liberia has 15% of land of scrub/forest with 10-30% canopy density. This class aligns quite well with

HCSA’s YRF forest class (see maps below), but is not included in Liberia’s national forest definition (>30%),

indicating that HCSA’s definition of forest is more strict than the national definition – the same is true for other

countries. This is supported by HCSA field trials in Liberia which identified minimal areas of non-HCS.

The following maps indicate overlap

between HCSA’s definition of YRF and

above (non-white areas in top map) and

the Liberian 10% forest class (light green

in bottom map).

34 Tappan, G.G., Cushing, W.M., Cotillon, S.E., Mathis, M.L., Hutchinson, J.A., and Dalsted, K.J. 2016.

West Africa Land Use Land Cover Time Series: U.S. Geological Survey data release,

http://dx.doi.org/10.5066/F73N21JF

35 Metria & GeoVille 2016. Final Report LIBERIA LAND COVER AND FOREST MAPPING FOR THE

READINESS PREPARATION ACTIVITIES OF THE FORESTRY DEVELOPMENT AUTHORITY; Goslee et al

2016. Development of Liberia’s REDD+ Reference Level Draft Final Report for Republic of Liberia

Forest Development Authority. Winrock Int.

http://dx.doi.org/10.5066/F73N21JF


25

4.2 Carbon and GHGs

Carbon storage is one of the many ecosystem services provided by forests, and

concerns about the contribution of deforestation to GHG emissions have resulted

in various policy measures to reduce deforestation and to protect forests for their

existing carbon stores and roles as carbon sinks. These include:

- Governmental measures related to reducing emissions from Land Use,

Land Use Change and Forestry (LULUCF), such as REDD+ under the

UNFCCC,

- Measures to limit private sector emissions such as:

o Corporate commitments to conduct Life Cycle Analyses (LCA) of

GHG emissions and reduce GHG emissions (including Scope 3

“indirect” emissions such as those caused by deforestation or

land use change), and

o Requirements of voluntary certification schemes. These may

include requirements within sector specific schemes such as the

RSPO, or dedicated carbon accounting or emission reductions

schemes, such as the Voluntary Carbon Standard (VCS).

The broad goal of these initiatives is to reduce GHG emissions, although specific

objectives or targets vary from “reducing deforestation” to achieving “net zero

GHG emissions”. The specific objective in turn affects what commercial activities

or mitigation measures are required, and we again return to the “value” of forest,

because a focus purely on carbon emissions may allow a company to deforest if

this is offset through efficiencies elsewhere in the product lifecycle.

Considering these approaches can help the RSPO TF to reflect on 1) the

importance to RSPO of the “carbon” value of forest, and 2) the value of carbon as

a quantifiable metric or proxy to define and measure forest.

4.2.1 RSPO and carbon stock

RSPO encourages development on low carbon stock areas. Low carbon stock

areas according to RSPO are areas meeting zero emission standards over one crop

rotation.

RSPO does not require reductions or caps in GHG emissions, merely encouraging

efforts to reduce emissions. RSPO also does not require specific methodologies

for carbon monitoring, although it does provide the PalmGHG tool for use by

companies.

4.2.2 Carbon stock to define forest: history

In the 1980s, concerns about climate change led to the establishment of the

Intergovernmental Panel on Climate Change (1988) and the creation of the UN

Framework Convention on Climate Change (1992), initiating a new forest

management objective: forests as carbon stocks. The Kyoto Protocol contains the

terms reforestation and afforestation which subsequently had to be defined and


26

operationalized in this context. The adoption of the Bali Action Plan in 2007 gave

rise to the Forest Carbon Partnership Facility and the UN-REDD Programme.

Biomass and carbon density became the metrics of forest monitoring and

assessment.28,36 Attempts to quantify and monetize carbon sequestration and

other ecosystem services were expanded to incentivize forest protection and

reforestation through payments for ecosystem services.37

4.2.3 Pros and cons of carbon thresholds

Pros

The major advantage of using carbon as a proxy for forest value is that it can

easily be quantified and measured, simplifying assessment and monitoring over

time.

Cons

Carbon greatly oversimplifies “forest value”, for example by undervaluing local

people’s use of low- and medium-carbon forests, which are typically those areas

closest to villages where carbon stocks are lower but where most farming,

collecting and hunting activities take place. This means that if a very strict carbon

threshold is used it may technically mean that local people can’t clear young

secondary forest, rendering even typical smallholder palm plantations

‘unsustainable’. Furthermore, if companies seek out low-carbon stock areas for

development this is likely to increase the risk of conflict with communities given

that such areas are more likely to be under community use.

Furthermore, many ecologically unique or important forests or ecosystems are

characterized by low carbon stock,38 e.g. Kerangas (heath) forest or savannah

woodlands.

These risks are amplified in highly forested countries and where globally defined

thresholds (such as that of the HCSA) are applied. For example, Gabon has 88%

forest cover, and the average carbon stock in its forests is 180 tC/ha.39,40

Application of a threshold like 35 tC/ha (as previously, but no longer solely, used

by HCSA) leaves only some marginal areas of savannah in the country or tiny

patches of young regrowth in forest areas. As such it has been argued that such

strict ‘High Carbon Stock’ definitions make sense for protecting the little

remaining forest in highly fragmented landscapes, but are incompatible with

36 Saatchi et al. 2011. Benchmark map of forest carbon stocks in tropical regions across three

continents. Proceedings of the National Academy of Sciences 108: 9899.

37 Wunder, S. 2007. The efficiency of payments for environmental services in tropical conservation.

Conservation Biology 21: 48–58.

38 Putz & Redford. 2009. Dangers of carbon-based conservation, editorial. Global Environmental

Change 19 (2009) 400–401.

39 https://www.linkedin.com/pulse/high-carbon-stock-forests-carbon-neutral-palm-roadmap-

stewart

40 Burton et al. 2016. Reducing Carbon emissions from forest conversion for oil palm agriculture in

Gabon. Conservation Letters

https://www.linkedin.com/pulse/high-carbon-stock-forests-carbon-neutral-palm-roadmap-stewart

https://www.linkedin.com/pulse/high-carbon-stock-forests-carbon-neutral-palm-roadmap-stewart


27

development agendas of highly forested nations like Gabon.39 Studies in Gabon

have encouraged the application of national thresholds to greatly restrict forest

conversion through national-level zoning/identification of productive, low carbon

agricultural land, coupled with requirements for finer-scale carbon, biodiversity

and community use assessment at the concession-level.40

Other risks identified of using strict carbon thresholds include a blind focus on

increasing carbon stocks of forests to the detriment of forest structure and

composition. As such, many have argued for the importance of forest definitions

that consider multiple aspects including biodiversity and social use.38

According to some scientists, forest definitions focusing on attributes of living

trees, combined with regenerating processes such as recruitment and succession,

whilst useful, are ecologically incomplete. Definition of forest should incorporate

both attributes of the living trees and turnover in the dead-wood component to

more effectively characterize an ecosystem that is dynamic. This would allow to

infer whether a tree-covered land unit is likely to be in a static, degrading, or

unstable state, and potentially vulnerable to tipping into a ‘non-forest’.41

4.3 High forest cover

The concept of high forest cover countries and landscapes has been around for

some time, originating from discussions within the United Nations Framework

Convention on Climate Change (UNFCCC) around the policy of Reducing Emissions

from deforestation and forest degradation (REDD+). More recently the concept

has been further discussed within the HCSA. These discussions and lessons are

synthesised here.

4.3.1 REDD+ High-Forest, Low-Deforestation countries

The concept of REDD+ was agreed in negotiations of the UNFCCC, based on

recognition of the significant contribution of forest degradation and deforestation

to global climate change. It is a policy designed to reduce these emissions through

improved forest conservation, sustainable forest management and enhancement

of forest carbon stocks in developing countries.42 A core component of REDD+ was

for developed countries to transfer results-based payments to forested

developing countries to support their implementation of REDD+ programmes and

activities.

A critical issue emerging from the REDD+ discussions surrounded the topic of

“High-Forest, Low-Deforestation” (HFLD) countries. These are countries that

remain mostly forested and where historic deforestation rates were low, and in

many cases were relatively undeveloped often with high poverty levels. These

HFLD countries’ forests were critically important to protect, but they also have

41 Buettel et al. 2017. Missing the wood for the tree? New ideas on defining forests and forest

degradation. Rethinking Ecology

42 http://redd.unfccc.int/fact-sheets/unfccc-negotiations.html

http://redd.unfccc.int/fact-sheets/unfccc-negotiations.html


28

development needs that would typically use logging or agriculture as means of

growing their economies and improving livelihoods.

This became particularly important when defining national forest reference levels

or baselines of GHG emissions for REDD+, which are the basis for determining

results-based payments. Countries would receive payments only if they could

demonstrate that they were reducing deforestation from the historic or reference

level. But for HFLD countries (including the Coalition for Rainforest Nations) that

have kept most of their forest standing, was it fair to expect them to keep all of

their forests standing and potentially forego development without any

compensation? This meant ensuring that:

1. Reference levels took this into account, and

2. Safeguards were in place to ensure local livelihoods could be met and

improved in HFLD countries.

Ultimately under REDD+, it was agreed that countries could define their own

reference levels based on some flexible guiding rules. There has been extensive

research into different methodologies for defining reference levels based on a

combination of forest cover, deforestation rate and other variables.

4.3.1.1 Defining HFLD Da Fonseco et al. (2007)43 classified developing countries based on remaining forest cover and deforestation rate (see Figure 4):

1. Low forest, high deforestation 2. Low forest, low deforestation 3. High forest, high deforestation 4. High forest, low deforestation

Values for forest cover, forest area and deforestation rate taken from the UN Food and Agriculture Organization (2005).44 To define the four categories, the authors use cut-offs of 50% remaining forest and 0.22% forest loss per year. Remaining forest of 50% was selected as the “simplest arbitrary cut-off.” A cut-off of 0.22% per year was selected because it represented the global average rate of deforestation for the reference period of 1990-2000.45 Therefore, HFLD countries have forest cover >50% and deforestation rates <0.22% (Figure 4).

43 Da Fonseca, et al. (2007) No forest left behind. PLoS Biol 5(8): e216.

doi:10.1371/journal.pbio.0050216

44 Food and Agriculture Organization of the United Nations (2005) Global forest resources

assessment 2005: Progress towards sustainable forest management.

45 Griscom et al. 2009. Sensitivity of amounts and distribution of tropical forest carbon credits

depending on baseline rules. Environmental Science and Policy


29

Figure 4. Summary of countries categorised by the da Fonseca methodology

Another idea has been to adopt reference levels indexed to the global

deforestation rate for countries with little or no historic deforestation, allowing

HFLD countries to receive “preventive credits” that would be lost if the

deforestation rate were to increase.45

Griscom et al. have suggested that the da Fonseca method may be overly

simplified, and so conducted a quantitative analysis of ‘‘natural’’ groupings of

countries according to the same variables. Using a multivariate cluster analysis

they calculated the two variables as (1) proportion of original forest cover

remaining based on data from the FAO 2005 National Forest Resource

Assessment (FRA), and (2) rate of forest change combining FAO 2005 data on

forest loss and WRI data on original forest cover (Bryant et al., 1997). The analysis

came up with five natural categories.


30

Figure 5. Clusters of countries identified by Griscom et al. See caption included in graphic for more

details.

4.3.2 Forest transition models

Another methodology proposed is based on the forest transition model, as widely

discussed in development and environmental literature. Griscom et al. considered

the da Fonseca categories as part of a time sequence:

- HFLD countries (Fonseca Type 4) typically shift to…

- Increased rates of deforestation as they develop (Fonseca Type 3), but…

- Then reach a change point where forest loss starts to decline (Fonseca

Type 2) and..

- Finally reverses due to forest regeneration, restoration or reforestation

(Fig. 1).

Figure 6. Generalised forest transition model, taken from Griscom et al.


31

4.3.3 Deforestation baseline approaches

Two other approaches proposed for defining REDD baselines are retrospective

and prospective baselines.46

Retrospective baseline methods are based on the trend of historic deforestation

rates being extrapolated into future commitment periods. This ideally uses

multiple-year periods for estimates to avoid biases from high interannual

variation. A weakness of retrospective methods is that they assume linear rates of

deforestation, so not considering changes linked to forest developmental

transitions.

Examples of a retrospective baseline approach (or Joint Research Centre

approach) is Mollicone et al.47, who calculate a baseline from satellite imagery

from the period 1990 to 2005, including a method to separate intact forest, non-

intact forest and non-forest land. The method considers a global baseline rate

requiring emissions reductions for those above the global average and allowing

those below it to benefit from ‘avoided deforestation’ payments.

Huettner et al. also discuss other retrospective methods they refer to as a Simple

Historical Approach (SiHA) and Spatial Historical Approach (SpHA), which use

global satellite imagery combined with either global biomass and carbon

conversion factors (for SiHA) or local factors (for SpHA).

Prospective approaches use predictive and dynamic spatial land-use modelling to

estimate future land use changes. They attempt to incorporate the dynamics of

deforestation drivers and various different models to most effectively estimate

deforestation and future land use scenarios. They can readily be tailored to

different national contexts or drivers. Examples include CLUE-S. Interestingly,

these approaches have been less popular amongst policy makers, seemingly due

to their complex methods (hence perceived opaqueness) and impractical

requirements for detailed data – such models have been seen as more viable at a

project level, e.g. within voluntary carbon schemes.

Other baseline models are shown in Figure 7.

46 Huettner et al. 2009. A comparison of baseline methodologies for 'Reducing Emissions from

Deforestation and Degradation'. Carbon Balance and Management.

47 Mollicone et al. 2007. An incentive mechanism for reducing emissions from conversion of intact

and non-intact forests. Climatic Change, 83:477-493


32

Figure 7. Comparison of different baseline methodologies taken from Griscom et al.

4.3.4 HCS High Forest Cover Landscape (HFCL)

The High Carbon Stock Approach (HCSA) methodology considers High Forest Cover Landscapes (HFCL) as landscape with more than 80% of forest cover (HCS Approach Steering Group 2017). Note that unlike discussions in the REDD+ context, where HFLD were defined at national (or sometimes sub-national jurisdictional scales), HCSA defines HFCLs at a much smaller landscape scale.

The HCSA steering group set up this figure based on research on landscape-level

impacts of deforestation in the Amazon48. The study reveals that forest structure

is weaken when approximately 20% of the forest cover has been removed. A

second study about effects of habitat fragmentation on birds and mammals49

highlights the fact that habitat loss increases once total habitat drops below 30%

because of increasing habitat fragmentation consequences. These figures served

as a basis for setting up HCSA’s forest cover thresholds.

Whilst the use of ecological evidence is clearly important, it is worth noting that these definitions and studies are based on patterns of clearance and fragmentation in the Amazon, which may not necessarily be reflective of patterns elsewhere (e.g. in palm growing regions). In addition, these variables arguably have greater bearing on how the size and connectivity of conservation areas should be designed than they do on how to define highly forested areas. What is more, these studies do not consider the socio-economic dimension or trajectory in HFC landscapes or countries that are considered critical in discussions about equity of ‘no deforestation’ policies.

48 Francisco José Barbosa Oliveira de Filho, Jean Paul Metzger. 2006. Thresholds in landscape

structure for three common deforestation patterns in the Brazilian Amazon, Landscape ecology

49 Henrik Andrén. 1994. Effects on habitat fragmentation on birds and mammals in landscapes with

different proportions of suitable habitat: a review, Oikos 71: 355-36


33

Forest cover landscape categories in the HCS Approach toolkit

Low <30%

Medium 30-80%

High >80%

Table 2: Forest cover categories in the HCS Approach toolkit

Box 2. Lessons from the HCSA High Forest Cover Landscape Working Group

Diverse recent case studies presented during HCSA working groups raised the importance of

developing an adapted methodology to be applied to HFCL. It was argued that in HFCLs, the HCSA

toolkit often results in economically non-viable projects for industrial exploitation. Moreover, it

creates “stranded assets” from the perspective of the companies involved. Some of the implications

highlighted were as follows:

• Producer abandons HCS or NDPE commitment,

• Producer or owner divests (sells plantation or production company),

• Companies bought up by companies with no NDPE commitment,

• Producer allows lease to lapse, and return to Government for reallocation,

• Trader /supply chain might drop suppliers with no NDPE commitments

All of these scenarios suggest a high probability of deforestation unless NDPE companies aspire to

actively protect these concessions under forest cover for perpetuity – but which of course comes

with huge cost and management implications.

The issue of ongoing “leakage” or scope for the oil palm industry to continue with deforestation

beyond the control of the current HCS approach was also highlighted, with some working group

members fearing that demand from markets that accept “unsustainable” products, such as China

and India, would continue to drive BAU or worse deforestation in HFCLs in the absence of a market

demand from NDPE companies to reduce deforestation. It was mentioned that many palm oil

growers are still not committed to deforestation and that some companies are exploring

development of vertically integrated supply chains to avoid having to trade through NDPE

companies.

Another critical point of discussion was around the importance of development in many poor HFCLs

where palm production could help to create jobs, build social infrastructure such as schools, health

clinics and roads (which are often sorely lacking). It was argued that palm does not always provide

these benefits locally and that alternative development or economic activities should be prioritised

that don’t require deforestation. Growers in turn argued that no other actors or companies are

currently providing realistic alternatives to palm or other land-based development options.

4.3.5 IFLs in HCV 2 and FSC

The methods discussed above focus more on definitions related to % coverage of

jurisdictions or landscape of forest. An alternative approach is simply to map the

most important landscape-level forests directly, irrespective of jurisdictional

boundaries. This is the approach taken for IFLs.


34

The HCV common guidance refers to a definition of large undisturbed landscape-

level forests, known as Intact Forest Landscapes (IFL). The concept was coined by

Greenpeace, working with other organisations50 to map Frontier Forests and

Intact Forest Landscapes at a global and regional level since the 1990’s. The

definition of an IFL is:

“a territory within today’s global extent of forest cover which contains forest and

non-forest ecosystems minimally influenced by human economic activity, with an

area of at least 500 km2 (50,000 ha) and a minimal width of 10km (measured as

the diameter of a circle that is entirely inscribed within the boundaries of the

territory)”

IFL are considered as HCV 2 that are landscape-level ecosystems and ecosystem

mosaics51.

HCVNIs (see 4.1.2) are interesting regarding HCV 2 because the way it is

understood and applied for forests will be different in Canada (where the country

retains large tracts of undisturbed forest) from the way it will be treated in Ghana

(where there are only a few remaining forest blocks, none of which are

undisturbed). This means that different countries use different thresholds for how

large a forest block should be to be considered HCV 2, ranging from a global

standard of 50,000 ha down to 10,000 ha in countries with lower forest cover or 1

million ha in high forest countries like PNG.

Figure 8. Countries that have HCV National Interpretations. Note several HFC countries, such as

Papua New Guinea, Canada, Liberia and others.

50 The IFL mapping team is an alliance of research and non-governmental ecological organizations

and is constantly improving and updating the Intact Forest Landscapes dataset. The following

organizations contributed to the year 2000 IFL mapping and 2000-2013 map update: Greenpeace;

Global Forest Watch; Transparent World; The Global Land Analysis and Discovery (GLAD) laboratory,

Department of Geographical Sciences at the University of Maryland, WWF Russia, Luonto Liitto

(Finnish Nature League), Forest Watch Indonesia, and other regional NGO.

51 Large landscape-level ecosystems and ecosystem mosaics that are significant at global, regional or

national levels, and that contain viable populations of the great majority of the naturally occurring

species in natural patterns of distribution and abundance; https://www.hcvnetwork.org/about-hcvf

https://www.hcvnetwork.org/about-hcvf


35

4.3.6 Analysis of High Forest Cover definitions

Each of the definitions and methodologies discussed above was developed for a

different purpose (Table 3), ranging from mapping important contiguous blocks of

forest to identifying countries at an early stage of the forest transition to inform

policy development. It is important that RSPO considers its objectives when

defining a HFC threshold, to ensure appropriate variables are considered. Indeed,

RSPO has said that a key motive is to recognise the development status of

countries whilst contributing to forest conservation. As such, other variables

beyond the biophysical may need consideration. These are discussed further

under sections 7 and 8.

One method emerging from REDD+ discussions of potential interest to RSPO’s

site-level focus are the prospective baseline models. These have been increasingly

used at a site/project-level for carbon projects to extrapolate potential

development scenarios. Given concerns about palm developments resulting in a

slippery slope of deforestation, perhaps RSPO could consider requiring growers to

use these prospective models to better understand and mitigate future

deforestation (including land requirements of communities).

Table 3. Comparison of relevant high forests cover thresholds or definitions

Source Forest

cover

Deforestation

rate

Rationale

HCSA 80% at

landscape

Not included Amazon study (Oliveira de Filho and Metzger 2006).

Threshold after which patch size & isolation

reduces rapidly

REDD+ 50%

national

0.22% p.a. Griscom et al. 2009. “Arbitrary” forest cover. Mean

deforestation rate (2005)

FCPF

Carbon

Fund

Not

specified

Not specified “achieve net emission reductions … and to pilot

REDD+ across a diverse set of countries, including

those … with high forest cover and low

deforestation”

IFLs NA NA Different approach focused on mapping important,

intact forest of at least 50,000 ha, 10 km wide

4.4 Spatial scale

The RSPO P&C is applied at a site-level, however, the spatial scale being discussed

in this paper is about how you define HFC contexts which necessarily require

looking at a broader scale.


36

RSPO has decided a priori to focus on HFC Countries, and so we will not discuss

scale at length, only to provide a brief analysis of some of the pros and cons of a

national Vs a sub-national spatial scale.

Landscape

It is now widely acknowledged that issues of deforestation and development

happen beyond the scale of individual concessions, properties or management

units. They occur in interconnected landscapes with interacting drivers, indirect

impacts and ecological dynamics. Furthermore, the mix of these drivers and

dynamics are typically unique to each landscape. This is a major motivation for

why the HCV and HCS approaches require particular attention to be given to the

wider landscape around individual developments.

In recognition of this, the HCSA defines HFC at a landscape-level but the HCSA

methodology allows only very minimal flexibility for ‘more conversion’ in high

versus medium or low forest cover landscapes.

The advantage of looking at a landscape scale is that it considers the real

dynamics mentioned above and can allow for a greater scale of implementation

beyond simply site-level without requiring the huge level of coordination needed

for national or jurisdictional scale.

A major risk of RSPO defining landscapes at a landscape (or jurisdictional) scale

and then allowing exceptions for deforestation is that it would allow many areas

on the frontier of deforestation in otherwise heavily deforested countries to

justify further clearance. For example, the Heart of Borneo or Leuser ecosystems

at a local landscape level are still highly forested, but most would argue that they

should be largely protected and that any (if at all) further palm development

should focus on nearby areas that are already degraded or under agricultural use.

Of course, whether having a strict stance for “no deforestation” for palm in these

sub-national landscapes actually provides a strong enough incentive to stop

deforestation is another question.

Biogeographic region

A less widely considered approach would be to consider biogeography in defining

scale. Forested landscapes stretch over national boundaries which don’t usually

follow natural features and so a biogeographic scale would better capture this.

For examples, the WWF Ecoregion 200 approach uses biogeography as its basis in

analysing global patterns of biodiversity, resulting in 238 ecoregions comprising

142 terrestrial, 53 freshwater, and 43 marine priority ecoregions (Figure 9). As an

example, the island of New Guinea contains 2 priority forest ecoregions: New

Guinea Montane Forests and New Guinea Mangroves. These ecoregions are

spread across PNG, and West Papua and Papua in Indonesia.


37

Figure 9. WWF Ecoregion 200 map

In Southeast Asia, different biogeographic zones have been defined based on the

distribution of fauna, divided into 3 distinct regions:

• Sundaland: Peninsular Malaysia, Borneo, Sumatera, Java, Palawan

• Wallacea: Central Indonesian islands, (Philippines), (Eastern Indonesian

Islands)

• New Guinea, (Eastern Indonesian Islands).

Figure 10. Biogeographic boundaries in Southeast Asia as defined by different biologists.


38

A biogeographic approach could potentially justify including the Indonesian part

of New Guinea (i.e. West Papua and Papua provinces) as an exception to country-

specific HFCL rule:

• The island of New Guinea is a distinct biogeographic region on its own –

the division of the island into two different countries is completely

arbitrary

• The ecoregions within New Guinea are contiguous areas extending across

the Indonesia-PNG border

• The ecoregions in the Indonesian side of New Guinea are distinct from

those in other parts of Indonesia

• The island as a whole has a high forest cover including the Indonesian

portion which may have an even a higher forest cover than PNG

A similar approach could also justify including the Amazon biome as a HFC

landscape.

Country

Defining HFC Countries would follow logic applied in REDD+ discussions. It

recognises that in most countries the major macro-level economic, social and

environmental policies and legislation are made at a national level, and that any

large-scale zoning to identify protected areas or define important forests also

happen at this scale. Importantly, efforts to alleviate poverty and improve rural

livelihoods are typically stimulated by national policy measures or initiatives, e.g.

to subsidise certain crops or invest in social infrastructure. Therefore, recognising

this allows HFCCs more flexibility and sovereignty to develop such national

strategies – whilst allowing responsible RSPO growers to operate in and support

these national initiatives.

The main risk of a national definition relates to the fact that many countries,

although in theory governed centrally, are in fact highly heterogenous

geographically, socially, economically and environmentally. For large countries

and those with inequal forest distribution this is particularly true, for example,

Indonesia, Brazil and the other Amazonian countries.

Within Indonesia there are huge differences between Sumatra and Kalimantan

where huge deforestation which occurred over the past 50 years has allowed

major development of palm and other commodities and also supporting economic

growth and, in places, rural development. Conversely, Papua and West Papua

provinces remain mostly forested, have lower life expectancy than other

provinces and less access to infrastructure (physical and social).52 Furthermore,

national definitions often overlook cultural and historical factors, for example,

that former Irian Jaya (Papua and West Papua) is culturally and ethnically distinct

from western Indonesia.

52 E.g. http://www.ifa-fiv.org/wp-content/2014/09/Indonesian_Ageing_Monograph-print-version1.pdf


39

If countries such as Brazil, Indonesia, Ecuador, Peru and Colombia are all defined

as low forest cover countries and not allowed to deforest because national forest

cover is approximately 50%, risks may be as follows:

- Is it equitable for jurisdictions that are still highly forested and perhaps

poorer for a top-down imposition of strict local requirements based on

global values?

- If these jurisdictions already have development strategies and have

allocated land to companies, what is the BAU trajectory for these areas in

terms of deforestation?

- Will RSPO have greater impact and influence on changing this trajectory if

it a) does not allow growers in these areas to be certified, or b) if it allows

growers to do some limited conversion that is less than may happen under

BAU?

4.4.1 Analysis of different spatial scales

A table comparing the pros and cons of different scales is provided below.

Scale Advantages Disadvantages

Country • Quicker to agree amongst RSPO stakeholders

• Link to national initiatives and policy making

• Avoids perceived risk of “opening up” Papua and West Papua

• Unequal development in country • RSPO risks losing influence over known

new frontiers e.g. Papua. Most certified areas are long established – how to stay relevant for new development?

• Highly likely leakage to other commodities and non-RSPO palm in high forest areas within low/medium forest cover countries

Jurisdiction • Aligned with implementable jurisdictional approaches

• RSPO able to influence trajectory in key areas like Papua

• Option to make case for reduced deforestation Vs BAU

• Criticism over Papua, Amazon & ‘greenwash’

• Risk of actors justifying Leuser, HoB as “HFCLs”

Biogeographic • RSPO able to influence trajectory in key areas like Papua

• Ecological perspective on forests to protect

• Criticism over Papua, Amazon & ‘greenwash’

4.5 Development status and poverty

Social equity is a key factor in the HFC debate. To crudely summarise, many highly

forested countries and landscapes are also those with higher levels of poverty.

Various approaches have been explored to try and quantify development status

or poverty as a way of identifying areas or countries where some deforestation


40

may be acceptable on the grounds of poverty alleviation and improving

livelihoods.

One approach is simply to consider forest cover and/or deforestation rate itself as

a proxy for development status or status in the “forest transition”, e.g. if a country

has a high remaining forest cover it could be assumed to be relatively

undeveloped. In affect this is the approach that was taken in REDD+, where

reference levels are typically defined based on deforestation rate and forest

cover.

The Sustainable Palm Oil Manifesto (SPOM) group explored using specific social

indicators as a way of quantifying development status. These findings were

captured in the resulting HCS+ Study. Not all of these learnings were captured in

the “converged” HCS Approach that is now used, and so are captured here.

Ultimately HCS+ did not include an explicit social threshold. In short, they decided

that it was not possible or advisable to quantify a social threshold because:

• Virtually all social indices, such as the Human Development Index and

Multi-Dimensional Poverty Index, are calculated at a national level. This

means they do not capture often significant differences in development

status or poverty levels between rural and urban areas. In fact, they may

be skewed by urban areas because that is where most people live. An

example is Gabon, which scores fairly highly on HDI and other indices

because the majority of the population is urban and relatively well-off,

but the minority of the population living in rural areas remains

significantly poorer than their urban compatriots,

• The use of a single hard cut-off or threshold risks creating severe

‘boundary effects’ whereby two countries with only a 1 or 2% difference

in the value face wildly different requirements,

• In practice, virtually all tropical countries and especially all potential

HFCCs have enough rural poverty to “justify” some development. Life

expectancy, health and income levels are invariably relatively low in rural

tropical areas compared to either national or global expectations.

The main conclusion from the HCS+ Study was the importance of ensuring two

fundamental processes or outputs:

1. Minimise social harm during new developments. Primarily this can be

achieved through an effective FPIC process, for example, referring to the

HCSA’s social requirements, and

2. Maximise social benefits of developments. Once a development is

established it is vital that benefits are adequately shared amongst

customary rights holders, local community and workers. This requires

effective benefit-sharing models as well as indicators to effectively

monitor social benefits. As a monitoring indicator the HCS+ study

developed the Palm Oil Welfare Index, which has since been adapted into

the Welfare Impact Assessment (WIA).


41

4.6 Statistics on potential high forest cover countries

Based on the variables discussed above, statistics for a number of key variables have been collated here for known current or major potential future palm

producer countries. Clearly low forest cover countries such as Ghana, Ivory Coast, Nigeria and Sierra Leone are omitted for brevity.

Country % forest (FAO)

% IFL % forest (national/ regional)

Source for national/regional forest cover***

Oil palm (% total land area) (FAO)

Deforestation rate (%/yr; FAO)

Deforestation rate trend (FAO)

Deforestation rate (%/yr; national/ regional source)

Deforestation rate trend (national/ regional)

Source of deforestation rate (if different from national/ regional forest cover)

Gabon 89.3 26.3 88.3 OFAC 0.0 -0.9 Decreasing 0.1 Decreasing

Solomon Islands

78.1 10.6 76.6 MinFR 2010 0.6 0.3 Increasing 0.3 Constant

PNG 72.5 23.8 71.0 PNGFA 2012 0.4 0.0 Constant 0.1 Constant CCDA 2017

DRC 67.3 22.0 68.8 OFAC 2010 0.1 0.2 Constant 0.2 Constant

Liberia 43.4 2.7 68.0 Metria & GeoVille; Winrock 2016

0.2 0.7 Constant 0.9 Constant

R of Congo 65.4 27.0 67.1 OFAC 0.0 0.1 Constant 0.5 Increasing

Myanmar 42.9 4.0 63.0 Bhagwat et al 2017 0.2** 1.8 Increasing 0.3 Constant

Malaysia 67.6 3.9 55.2 NRE 2014 15.2 -0.1 Decreasing 0.4 Decreasing REDD Desk

Indonesia 53.0 15.0 54.2 MinEF 2015 5.4 0.7 Increasing 0.9 Constant

Brazil 58.0 21.8 54.0 2013. Brazilian Forest Service (SFB)

0.0 0.2 Decreasing 0.5 Decreasing


42

Peru 57.8 33.5 53.0 MINAM 2015 0.0 0.2 Constant 0.1 Constant

Costa Rica 53.9 4.9 52.4 REDD Desk 1.4 1.1 Increasing -0.9 Decreasing

Colombia 51.0 24.2 51.7

Sistema de Monitoreo de Bosques y Carbono (2016)

0.3 0.0 Decreasing 0.3 Increasing

Ecuador 50.5 16.3 51.6 MAE 2014 1.1 0.6 Constant 0.7 Decreasing

Cameroon 39.8 6.8 51.4 2013. OFAC (de Wasseige et al)

0.3 1.1 Increasing 0.9 Constant REDD Desk

Honduras 40.8 3.5 48.0 UN REDD 1.4 2.4 Increasing 0.9 Constant

Guatemala 32.5 3.6 34.2 INAB 2012 1.3 1.0 Decreasing 1.5 Constant REDD Desk

Thailand 32.0 2.7 32.0 RFDT 2016 1.3 -0.2 Decreasing 0.1 Constant

CAR 35.6 0.7 15.1 OFAC 0.0 0.1 Constant 1.8 Decreasing

**Myanmar oil palm stats not available from FAO, taken from Baskett 2015

***Full list of references provided here:

Myanmar palm area

Baskett, J.P.C. 2015. Myanmar oil palm plantations: A productivity and sustainability review Report no. 28 of the Tanintharyi Conservation Programme, a joint initiative of Fauna & Flora International and the Myanmar Forest Department.

Forest cover

Brazil Min of Env, Brazilian Forest Service. 2013. BRAZILIAN FORESTS at a glance. Available at: http://www.florestal.gov.br/publicacoes/571-brazilian-forests-at-a-glance-2013

http://www.florestal.gov.br/publicacoes/571-brazilian-forests-at-a-glance-2013


43

CAR, Gabon, RoC, Cameroon

Les forêts du bassin du Congo – État des Forêts 2013. Éds: de Wasseige C., Flynn J., Louppe D., Hiol Hiol F., Mayaux Ph. – 2014. Weyrich. Belgique. 328 p. Dépôt légal : D/2014/8631/30 ISBN : 978-2-87489-298-1

Costa Rica https://theredddesk.org/countries/costa-rica/statistics

Ecuador Ministerio del Ambiente. 2014. Ecuador’s Forest Reference Emission Level for Deforestation

Guatemala https://theredddesk.org/countries/guatemala/statistics

Honduras http://www.unredd.net/index.php?option=com_docman&task=doc_download&gid=13374&Itemid=53

Indonesia MinEF, Republic of Indonesia 2015. NATIONAL FOREST REFERENCE EMISSIONS LEVEL FOR REDD+ In the Context of Decision 1/CP.16 Paragraph 70 UNFCCC

Liberia

Metria & GeoVille 2016. Final Report LIBERIA LAND COVER AND FOREST MAPPING FOR THE READINESS PREPARATION ACTIVITIES OF THE FORESTRY DEVELOPMENT AUTHORITY; Goslee et al 2016. Development of Liberia’s REDD+ Reference Level Draft Final Report for Republic of Liberia Forest Development Authority. Winrock Int.

Malaysia http://www.nre.gov.my/en-my/Forestry/Pages/Statistics-Forest.aspx ; https://theredddesk.org/countries/malaysia/statistics

Myanmar Bhagwat T, Hess A, Horning N, Khaing T, Thein ZM, Aung KM, et al. (2017) Losing a jewel—Rapid declines in Myanmar’s intact forests from 2002-2014. PLoS ONE 12(5): e0176364. https://doi.org/10.1371/journal.pone.0176364

Peru MINAM 2015 http://sinia.minam.gob.pe/documentos/cobertura-perdida-bosques-nivel-nacional

PNG PNGFA 2012 Forest Base Map; Climate Change and Development Authority 2017. Papua New Guinea’s National REDD+ Forest Reference Level Submission for UNFCCC Technical Assessment in 2017.

Solomon Islands Ministry of Forestry and Research 2010. http://mofr.gov.sb/foris/forestArea.do#marker

Thailand Royal Forest Department of Thailand 2016. http://forestinfo.forest.go.th/Content.aspx?id=72

https://theredddesk.org/countries/costa-rica/statistics

https://theredddesk.org/countries/guatemala/statistics

http://www.unredd.net/index.php?option=com_docman&task=doc_download&gid=13374&Itemid=53

http://www.nre.gov.my/en-my/Forestry/Pages/Statistics-Forest.aspx

https://theredddesk.org/countries/malaysia/statistics

https://doi.org/10.1371/journal.pone.0176364

http://mofr.gov.sb/foris/forestArea.do#marker

http://forestinfo.forest.go.th/Content.aspx?id=72


44

5 Approaches and interventions The second key part of any HFC approach that RSPO develops, following on from

defining where the approach applies, is what the approach itself looks like and

requires. For example, what is the assessment process for determining what areas

should be developed or protected and what are the desired outcomes?

To inform the development of a robust approach we review a selection of

approaches and strategies used elsewhere and try to draw relevant lessons from

them.

5.1 Lessons from Forest Stewardship Council

No conversion

The Forest Stewardship Council (FSC) standard includes a strict requirement for

no conversion of natural forest since 1994. In recent years this requirement has

come under scrutiny, as stakeholders question its impact in actually preventing

deforestation and on the viability of forestry operations.53 It has been strongly

argued that having this rule has prevented FSC from having any impact or control

over limiting deforestation in developing countries and in the tropics - where huge

deforestation has happened since 1994 and there is very little FSC certified

production. It is felt by many in the global South that FSC is essentially irrelevant

or discriminatory to these contexts and countries, and that such a rule prohibits

developing countries from creating sustainable livelihoods from their natural

resources.

As a result of these discussions FSC is now considering changing requirements to

have a greater focus on net positive conservation outcomes that potentially allow

limited conversion in exchange for protection or restoration of equivalently-sized

areas.

Is there a risk that RSPO follows a similar path to FSC if it takes a very strict stance

on no conversion?

IFLs

The FSC protects HCV forests, and consequently IFLs, under FSC principle 954.

However, in recent years there have been renewed debates about how to protect

IFLs within the FSC system with environmental chamber representatives, most

notably Greenpeace, demanding the FSC provide additional protections to IFLs

beyond those provided to HCVs. FSC decided to reinforce IFLs conservation

through motion 65 in 2014.

The motion called for national standard development groups and certification

bodies (CBs) to put in place measures to protect the vast majority of IFLs.55 At the

same general assembly in 2014, motion 07 was also passed.

53 https://ga2017.fsc.org/changing-the-1994-conversion-rule/

54 FSC Principle 9: The Organization shall maintain and/or enhance the HCVs in the forest

management unit (FMU) through applying the precautionary approach (FSC 2018)

55 https://ga2017.fsc.org/history-of-a-motion-intact-forest-landscapes-ifls/

https://ga2017.fsc.org/changing-the-1994-conversion-rule/

https://ga2017.fsc.org/history-of-a-motion-intact-forest-landscapes-ifls/


45

To work out how to do this FSC established a multistakeholder advisory group

including representatives from key IFL areas (Canada, Russia, Amazon, Congo

Basin, Indonesia). Initially, the advisory group proposed that the development of

IFL indicators work in parallel with the development of national standards (FSC

General Assembly 2017 2018).

FSC developed default indicators requiring the full protection of a core area of

each IFL within the Forest Management Unit (FMU), where core areas comprising

at least 80 per cent of the IFL fall within the FMU. This was later revised to state

that forest management operations within IFLs, including harvesting and road

building, could proceed as long as they did not impact more than 20 per cent of

IFLs within the FMU and did not reduce any IFLs below the 50,000 ha threshold in

the landscape. These measures are in place until new national standards, with

nationally agreed requirements are in place.

This debate is another example of where national and local rights have been in

conflict with global values and rights. Many local and national stakeholders,

including social rights groups, have been strongly opposed to environmental

restrictions in IFLs that they see as unfairly penalising poor communities and

countries and potentially pushing sustainable forestry operators out to be

replaced by more unscrupulous actors.

5.2 Defining which areas to protect

Different mechanisms and standards have tried different approaches for

determining which important forests or ecosystems should be protected. Two

approaches that have been used are, firstly, those that require a proportion of the

land area or management unit to protected (henceforth ‘proportional

protection’) and secondly, value-based approaches that require specific areas or

values to be protected.

Proportional protection requirements

The Sustainable Agriculture Network (SAN) standard requires producers to set-

aside 10% of their management units under natural vegetation, and FSC requires

producers to maintain a representative sample of natural vegetation.

Similar approaches have also been adopted in some countries’ legislation, for

example, in Brazil’s Forest Code. The Forest Code requires land owners to protect

a certain percentage of their property depending on which biome they are in

(Figure 11), as well as to protect key areas for ecosystem services such as riparian

buffers and steep slopes.56

If not coupled with other safeguards, these approaches are applied across the

board meaning that all users must comply even if in practice their area consists or

all primary forest or all degraded scrubland.

56 Proforest. 2017. Assessing compliance with the Forest Code: a practical guide


46

Figure 11. Requirements for the percentage of the property that must be set-aside as a legally

protected reserve in different Brazilian biomes

Value-based protection

Value-based approaches such as the HCV and HCS approaches take a different

approach, and are context specific. They place more emphasis on an assessment

at the start to identify what is there and then require those values to be either

avoided or protected. If you don’t have any HCVs or HCS forest on your land you

don’t have to set-aside any area, but if 100% of the area is made up of HCV and

HCS areas then you will struggle to have a viable production operation.

By comparison a ratio-based approach can allow companies to have a viable

operation whilst contributing to conservation, but without the risk of being

overburdened with sometimes costly conservation requirements.

Combining approaches

It is worth noting that some standards and policies combine both proportional

and value-based approaches to ensure adequate safeguards, and approaches to

share the costs to conservation (e.g. net approaches or offsetting). For example,

FSC has many elements:

- No conversion of natural forest,

- Maintain or enhance HCVs, and

- Maintain a representative sample of natural ecosystems.

The HCS+ Study also used a combined approach by having different carbon

thresholds designed to protect the more valuable forest (>75tC/ha) and allowing

some forests with less carbon to be developed only if the entire operation was

carbon neutral in terms of land-use emissions.

This had the effect of requiring companies to be responsible for managing and

protecting set-asides – a powerful idea that has been lacking from many policy

approaches that have led to leakage because of inadequate efforts to go beyond

avoidance of deforestation to protection of avoided areas.

Produce-Protect-Include approaches

The main challenge of the HCS approach in HFCLs has been that it simply does not

allow companies or producers sufficiently large or viable areas to develop. In large

part this is the result of the approach setting a strict, top-down bar for what is

considered forest and so allows no flexibility to plan a viable operation that

balances conservation, production and community needs.

As a result, some companies and organisations working in HFCLs have been

exploring alternative approaches that are more bottom-up and participatory, for


47

example, IDH, Sime Darby and Golden Veroleum in Liberia. The trials have focused

on ‘produce-protect-include’ (PPI) approaches that integrate these three pieces

through participatory land-use planning processes.

The main motivation for these trials was the need for something more flexible in

these contexts, given that the HCSA was found to be too limiting. These

organisations recognise the need to protect important forest and other values in

these landscapes but felt that a more bottom-up approach would be more

effective by getting community buy-in and that necessarily allowed some

production to ensure income and livelihoods were met and improving. There is

growing interest in PPI approaches in HFC contexts as a means of:

1. Allowing companies or investors to stay engaged by supporting some

development, and

2. Ensuring careful planning that prevents creeping deforestation and

ensures biodiversity is protected.

5.3 Assessment requirements

A HFC approach will require some kind of due diligence or assessment process

prior to any new developments to identify which areas to protect. The RSPO

system already requires various assessments as part of its New Planting

Procedure, namely HCV, Land Use Change, GHG (including carbon stock), soil

suitability and ESIA assessments.

The HCSA now represents a similar methodology for conducting a pre-

development baseline assessment, specifically aimed at identifying forest areas

that should be set-aside from development.

Realistically, the RSPO has two options that could be used in a new HFC approach:

1. Use a modified version of the existing NPP assessments to better

integrate and strengthen the land cover assessment requirements with

HCV requirements. This could enable requirements that protect HCVs and

certain forests, or

2. Use the integrated HCV-HCSA assessment methodology.

These would be reliable options that would avoid creating new methodologies,

although RSPO would still need to agree on what thresholds would be applied for

areas or forests to be protected.

5.4 Analysis of options discussed by RSPO P&C TF

The RSPO P&C TF has come up with various ideas during TF meetings for what a

HFC approach could look like. Some of the more prominent ideas are listed below

with a short analysis of their pros and cons.

Proposed idea Pros Cons


48

Shift HCS boundary up to LDF • No need for new methodology

• Aligns with initial HCSA legacy ideas

Limited developable area in some contexts, e.g. Gabon

Use a higher carbon threshold Option to define with a new RSPO specific approach (e.g. with more flexibility than HCSA)

HCSA moved away from fixed thresholds and not using only carbon because carbon is a poor approximation of forest’s full value

Define relative, national level

vegetation thresholds through

national level mapping (e.g.

YRF in Gabon = LDF in

Indonesia)

Fits with RSPO model of inclusivity & NI approach

Impractical, costly to do full mapping at national level. Alternative could be to validate/adjust thresholds through pilots

Offsetting mechanism Allows positive messaging & aligns with net commitments, e.g. CGF

• Baggage of HCS+ • ZND not supported by

campaign NGOs

Allow NIs to set their own

threshold

Fits with RSPO model of

inclusivity & NI approach,

allowing local ownership

Risk of ‘sanctioning’

deforestation if global RSPO

guidance does not ensure some

safeguards or max limits

6 Scenarios/options Based on the literature review, interviews and discussions with the RSPO NODIG,

this section puts forward proposals to the RSPO NODIG for how to develop a HFC

approach. Recommendations are made for guiding principles, potential HFC

thresholds/definitions and for requirements of the HFC approach itself.

Supporting justification is provided in Annex 1 for the final text agreed by the

NODIG and RSPO taskforce on HFC countries for public consultation.

6.1 Guiding principles

Based on lessons learnt from other discussions, standards and stakeholder

concerns the following guiding principles for a robust HFC approach were

identified:

• Applies only in HFC areas (as defined by RSPO)

• Time-limited

• Net positive carbon impact

• Net positive or neutral biodiversity e.g. through HCVs secured, reduced

hunting, compensation and/or a minimum ratio of conserve : develop


49

• Forest conservation e.g. assured protection of HCV and HCS areas in

concessions & wider landscape

• Socially positive both before, during and after the development process:

• Pre-development: FPIC & social requirements

• Once established: new models for benefit sharing, e.g.

smallholder model

• Requirement to support57 wider landscape initiatives to reduce leakage

risk

Several additional ideas raised or identified during consultations included:

- Avoid absolute thresholds. Lessons from FSC and the HCS+ Study suggest

that using single fixed thresholds can be problematic because of major

boundary effects. It was recommended using either bounded categories

or continuous variables with a bottom cut-off. For example, RSPO could

determine eligibility for a HFC approach by considering remaining forest

where the HCSA class available for development gradually gets stricter as

forest cover declines: e.g. 90-100% forest cover allows up to MDF to be

cleared, 70-90% allows up to LDF, 50-70% allows up to YRF and <50%

requires full HCSA implementation

- Require “no conversion” of all natural ecosystems, but with a slightly less

strict bar e.g. protect 50% of all natural ecosystems in the management

unit

- Mandatory compensation required for all conversion of HCS or other

ecosystems

- How to include smallholders? Have the same rules for all but give

everyone a 10ha discount for conversion. This would act to support

smallholders by allowing them enough clearance to have a viable

livelihood. The threshold could of course be adjusted to reflect the farm

size needed for a viable livelihood in different contexts.

6.2 Defining HFC countries

The following options were proposed for how to define HFC countries:

Option 1

Combine % forest cover (FAO) with % IFLs – measure of forest cover and

development status. Countries must be above XX % for both variables to qualify:

e.g. 70% forest, 20% IFL.

• Pro: Uses both national and global datasets and spreads ‘risk’

• Con: Reliability of FAO data, controversy of IFLs

Option 2

57 “Support” to be defined by RSPO


50

Combine % forest cover (FAO) with % IFLs, % oil palm area AND deforestation

rate, to give a more comprehensive measure of forest cover and development

status.

One scenario for this would be to use the following thresholds, resulting in only

Gabon and PNG qualifying:

• >70% forest cover AND;

• IFL>20% AND;

• oil palm <0.5% AND;

• Deforestation rate>0.1%

Country

% forest

(FAO)

IFL (% land

area)

Oil palm (%

land area)

Annual

deforestation

(%; FAO)

Gabon 89.3 26.3 0.02 1.1

PNG 72.5 23.8 0.37 0.1

Option 3

Use a continuous or banded approach based on forest cover, e.g. >70% use one

HCS threshold, 50-70% use another, <50% use HCSA. If the principle is supported

it may be possible to explore including other variables as considered above.

Option 4

No threshold used. Countries specified a priori or based on qualitative factors, e.g.

known palm frontiers, deforestation threat, higher forest cover.

Option 5

A combined semi-quantitative approach is used, combining quantitative variables

of forest cover and % oil palm cover, with qualitative variables to assess whether

the country is a palm frontier. Countries would have to meet all of these criteria

to qualify.

This approach was supported by the NODIG as follows:

Parameter Threshold


51

Forest cover (REDD+ national (recent,

trusted))

>60%

Oil palm cover <1%

Deforestation trajectory Historically low, but increasing or constant

‘Threat’ from palm expansion Known frontier area or major areas allocated

for development

HCSA trials indicate HFCL Trials of the HCSA toolkit indicate non-viable

for development

6.3 HFC approaches

6.3.1 Site-level approach

Various options for an RSPO HFC approach were presented to the NODIG and

discussed within the group. A refined list of options presented prior to the TF5

meetings is presented here. Note that these options each include slightly different

combinations of elements and principles. In practice RSPO could pick different

combinations from each of these options:

Option Description

1 HCSA applies across the board:

• Toolkit for low/medium FCLs

• Legacy case procedure for HFCLs

• No new development in HFCLs

• What about smallholders?

2 HCSA with threshold shifted, with or without cut-off date?

• Ensures social benefit through HCSA social requirements, WIA

• Carbon neutral, HCVs secured etc.

• Where is HCS threshold? LDF or MDF?

3 HCV only until 2020, with safeguards – HCSA applies everywhere from

2020?

• Conserve: Develop = 1:1

• Apply HCSA social requirements and WIA to demonstrate social

benefits

• Carbon neutral


52

• Compensation payments US$2,500 x ha developed

4 Smallholder only model – applies now to 2025?

• Conserve: Develop: Food Security = 1:1:1

• Carbon neutral

• HCVs secured. Hunting pressure reduced. Min. 1km wide corridors

connect intact areas

5 Zero net deforestation – applies now to 2025/30?

• Restore/conserve 1 ha for 1 ha developed. In same biome (ideally

country)

• Carbon neutral, HCV approach, smallholder only model, HCSA

social requirements & WIA

6.3.2 Wider landscape or jurisdictional requirements

One concern about site-level approaches is that they may not adequately address

deforestation drivers in the wider landscape and that conservation efforts in

isolation are unlikely to be effective. Therefore, it was proposed to include some

requirements as part of a HFC approach that require companies to act at these

wider scales. Examples of requirements proposed were:

• At a landscape level:

• Maintain HCV and HCS areas in the wider landscape (at least 5km

from the concession boundary)

• Stabilise deforestation in wider landscape in 3 years

• Implement community livelihood and conservation programmes

to demonstrate reduced deforestation in landscape

• Collaborate with other actors to ensure effective connectivity (at

a minimum through physical corridors)

• At a jurisdictional level:

• Engage actively with governments to agree policies for capping

deforestation at 5% (TBC) from current level, and ensure no more

concessions are allocated

• Actively participate in jurisdictional approaches to implement No

Deforestation across all sectors by latest 2030

• Jurisdictional programme funded & implemented

• Financial contribution from grower


53

• Deforestation reduced in 3 years, halted by 2030…

6.3.3 Outstanding questions for the RSPO NODIG

To finalise proposed RSPO P&C text for public consultation the above approaches

and options will need to be reviewed by the NODIG and it will be necessary for

the group to agree on the following elements:

• No HCSA smallholder approach yet. RSPO needs to agree what approach

can be used to “limit deforestation” by smallholders in HFC contexts

Minimum outcomes or Qs for sub-group

• For an approach applied to smallholders or community land. What

definitions of smallholder and community land?

• Scale of implementation/assessment: If only smallholder or community

development is allowed, will assessments need to be conducted at a

larger site/landscape scale?

• HCVs identified and maintained

• Carbon/forest: requirements on HCS threshold (MDF?) or carbon

neutrality?

• Ratio of Conserve: Develop: Food Security areas? E.g. 1:1:1

• Social requirements: FPIC assured and participatory land use planning.

Use HCSA social requirements – but need to adapt for more landscape

level?

• Time-limited?

Assessment process

• HCV-HCS-FPIC assessment for the site/landscape or HCV for smallholders

tool (not designed for landscape participatory planning)?

• Quality assurance? Can it use the existing HCVRN ALS system?


54

Annex 1: RSPO TF5 HFC approach justification Thresholds for defining High Forest Cover Countries in the context of the RSPO

P&C’s proposed criterion 7.13

1. Why use a 60% threshold for High Forest Cover?

The percentage forest cover of a country, i.e. the land area under forest cover as a

percentage of the total land area of a particular country, is the most widely used

approach in describing forest cover. Our analysis of the best available forest cover

data for potential HFC countries indicate that a 50% threshold maybe too low as it

would include countries with high historic deforestation and a now fragmented

forest cover, while a 70% threshold would exclude some countries that have

minimal areas of developable land based on field trials of the HCSA approach,

such as Liberia.

2. Why use national or regional datasets as a first priority for determining

country-level forest cover and FAO data as a second priority?

For the FAO data, it is largely left to the national governments to provide their

forest cover data and there is no clearly defined process for ensuring data

accuracy. As such, there is much variability in how national governments compile

their statistics with some countries potentially under-reporting their forest cover

(e.g. Liberia) or over-estimating their forest cover (e.g. Malaysia).

We opted to use national or regional datasets as it allowed use of more up-to-

date statistics and to look for more reliable estimates, for example, developed for

national REDD+ programmes using highly accurate land cover classification

techniques. For example, REDD+ requirements there are protocols for national

governments to provide their statistics for forest cover with a tiered approach for

methodologies. There is a push for national governments to advance from Tier 1

to Tier 2 and Tier 3 with a corresponding increase in accuracy.

3. Why use a threshold of less than 1% oil palm cover?

In addition to using forest cover data as a criterion for HFC countries, there is also

a need to have a criterion that serves as a proxy for the development status of a

country, its current dependence on oil palm for economic development and the

potential for oil palm expansion. The oil palm cover of a particular country,

expressed as a percentage of the total land area of a country, serves this purpose

and the data for a wide range of countries is readily available from the FAO Stats

web portal. This threshold of 1% oil palm cover would allow for the inclusion of

many countries that are widely perceived to be new oil palm expansion fronts and

may benefit from adopting RSPO standards in avoiding the clearance of HCV areas

and HCS forests. Countries that have a higher percentage of oil palm cover are

assumed to be already deriving economic benefits from oil palm development and

therefore may be less dependent on further forest conversion to oil palm in order


55

to drive further economic growth. Other proxies for a country’s development

status (e.g. Human Development Index, poverty levels) were also explored but

based on lessons learnt from the Sustainable Palm Oil Manifesto (SPOM)’s HCS

Study, these proxies were not very useful at a national level due to spatial income

disparities and unequal development within a particular country.

4. Why use a combination of 60% threshold for HFC and 1% threshold for oil

palm cover?

Using forest cover alone as a criterion for HFC countries is not advisable due to

issues with data inaccuracy and its inability to provide a good indication of a

country’s development status or potential for oil palm development. Combining it

with a criterion for oil palm cover allows for a more accurate selection of

countries that still have a relatively high forest cover but are likely to see active

conversion of forest to oil palm for the purpose of economic development.

A full list of countries considered and statistics used are provided at the end of

this document.

5. Why use a threshold of Medium Density Forest (rather than LDF) for

legacy cases and community development?

During discussions within the HCSA’s HFC Landscapes WG it was indicated by

several representatives from Technical Support Organisations that the application

of an LDF threshold would likely be very restrictive on the potential areas

available for development – given that many of the case studies in HFCLs had

minimal land cover of the YRF class and below.58

This approach is supported by evidence collected during this consultancy project

indicating:

• Based on five HFCL case studies from the HCSA and SPOM, on

average only 14% of AoIs was in the YRF land cover class (Range: 4

to 24%; case studies in Papua, PNG and Gabon), and

• Negligible areas of forest with carbon stock <35 tC/ha59 (a proxy

for the lower threshold of YRF) at a national level for a sample of

potential HFC countries:

58 Although it was also noted that there would need to be further analysis to verify this conclusion

59 It is noted that the HCSA methodology does not use 35 tC/ha as a fixed threshold for HCS forest,

but in the absence of national level HCS maps this was used as a proxy for the lower threshold of the

YRF class.


56

Figure 12. Aboveground live woody biomass on the island of New Guinea. White areas are

those with carbon stock less than 35 tC/ha. Based on data from Baccini et al. 2000

Figure 13. Aboveground live woody biomass in Gabon. White areas are those with carbon

stock less than 35 tC/ha. Based on data from Baccini et al. 2000


57

National statistics on forest cover, deforestation rates and oil palm area

Country

%

forest

(FAO)

%

IFL

% forest

(national/

regional)

Source for nat/reg

forest cover***

Oil palm

(% total

land area)

Deforestation

rate (%/yr;

FAO)

Deforestation

rate trend

(FAO)

Deforestation

rate (%/yr;

nat/reg

source)

Deforestation

rate trend

(nat/reg)

Source of

deforestation

rate (if different

from nat/reg

forest cover)

Gabon 89.3 26.3 88.3 OFAC 0.0 -0.9 Decreasing 0.1 Decreasing

Solomon

Islands 78.1 10.6 76.6 MinFR 2010 0.6 0.3 Increasing 0.3 Constant

PNG 72.5 23.8 71.0 PNGFA 2012 0.4 0.0 Constant 0.1 Constant CCDA 2017

DRC 67.3 22.0 68.8 OFAC 2010 0.1 0.2 Constant 0.2 Constant

Liberia 43.4 2.7 68.0 Metria & GeoVille;

Winrock 2016 0.2 0.7 Constant 0.9 Constant

R of Congo 65.4 27.0 67.1 OFAC 0.0 0.1 Constant 0.5 Increasing

Myanmar 42.9 4.0 63.0 Bhagwat et al 2017 0.2** 1.8 Increasing 0.3 Constant

Malaysia 67.6 3.9 55.2 NRE 2014 15.2 -0.1 Decreasing 0.4 Decreasing REDD Desk

Indonesia 53.0 15.0 54.2 MinEF 2015 5.4 0.7 Increasing 0.9 Constant


58

Brazil 58.0 21.8 54.0 2013. Brazilian

Forest Service (SFB) 0.0 0.2 Decreasing 0.5 Decreasing

Peru 57.8 33.5 53.0 MINAM 2015 0.0 0.2 Constant 0.1 Constant

Costa Rica 53.9 4.9 52.4 REDD Desk 1.4 1.1 Increasing -0.9 Decreasing

Colombia 51.0 24.2 51.7

Sistema de

Monitoreo de

Bosques y Carbono

(2016)

0.3 0.0 Decreasing 0.3 Increasing

Ecuador 50.5 16.3 51.6 MAE 2014 1.1 0.6 Constant 0.7 Decreasing

Cameroon 39.8 6.8 51.4 2013. OFAC (de

Wasseige et al) 0.3 1.1 Increasing 0.9 Constant REDD Desk

Honduras 40.8 3.5 48.0 UN REDD 1.4 2.4 Increasing 0.9 Constant

Guatemala 32.5 3.6 34.2 INAB 2012 1.3 1.0 Decreasing 1.5 Constant REDD Desk

Thailand 32.0 2.7 32.0 RFDT 2016 1.3 -0.2 Decreasing 0.1 Constant

CAR 35.6 0.7 15.1 OFAC 0.0 0.1 Constant 1.8 Decreasing


59

*Countries chosen are known current or major potential future palm producer countries. Clearly low forest cover countries such as Ghana, Ivory Coast, Nigeria

and Sierra Leone are omitted for brevity. Yellow highlighted countries are those that were reclassified compared to the provisional list in the TF5 text for public

consultation, based on use of more accurate forest cover statistics: Peru no longer qualifies as a HFCC due to its forest cover being less than 60% and Myanmar

is added as a HFCC due to its high forest cover and potential as an oil palm frontier.

**Myanmar oil palm stats not available from FAO, taken from Baskett 2015

***Full list of references provided here:

Myanmar palm

area

Baskett, J.P.C. 2015. Myanmar oil palm plantations: A productivity and sustainability review Report no. 28 of

the Tanintharyi Conservation Programme, a joint initiative of Fauna & Flora International and the Myanmar

Forest Department.

Forest cover

Brazil Min of Env, Brazilian Forest Service. 2013. BRAZILIAN FORESTS at a glance. Available at:


CAR, Gabon,

RoC, Cameroon

Les forêts du bassin du Congo – État des Forêts 2013. Éds: de Wasseige C., Flynn J., Louppe D., Hiol Hiol F.,

Mayaux Ph. – 2014. Weyrich. Belgique. 328 p. Dépôt légal : D/2014/8631/30 ISBN : 978-2-87489-298-1

Costa Rica https://theredddesk.org/countries/costa-rica/statistics

Ecuador Ministerio del Ambiente. 2014. Ecuador’s Forest Reference Emission Level for Deforestation

Guatemala https://theredddesk.org/countries/guatemala/statistics

Honduras http://www.unredd.net/index.php?option=com_docman&task=doc_download&gid=13374&Itemid=53


https://theredddesk.org/countries/costa-rica/statistics

https://theredddesk.org/countries/guatemala/statistics

http://www.unredd.net/index.php?option=com_docman&task=doc_download&gid=13374&Itemid=53


60

Indonesia MinEF, Republic of Indonesia 2015. NATIONAL FOREST REFERENCE EMISSIONS LEVEL FOR REDD+ In the

Context of Decision 1/CP.16 Paragraph 70 UNFCCC

Liberia

Metria & GeoVille 2016. Final Report LIBERIA LAND COVER AND FOREST MAPPING FOR THE READINESS

PREPARATION ACTIVITIES OF THE FORESTRY DEVELOPMENT AUTHORITY; Goslee et al 2016. Development of

Liberia’s REDD+

Reference Level Draft Final Report for Republic of Liberia Forest Development Authority. Winrock Int.

Malaysia http://www.nre.gov.my/en-my/Forestry/Pages/Statistics-Forest.aspx ;


Myanmar

Bhagwat T, Hess A, Horning N, Khaing T, Thein ZM, Aung KM, et al. (2017) Losing a jewel—Rapid declines in

Myanmar’s intact forests from 2002-2014. PLoS ONE 12(5): e0176364.


Peru MINAM 2015 http://sinia.minam.gob.pe/documentos/cobertura-perdida-bosques-nivel-nacional

PNG PNGFA 2012 Forest Base Map; Climate Change and Development Authority 2017. Papua New Guinea’s

National REDD+ Forest Reference Level Submission for UNFCCC Technical Assessment in 2017.

Solomon Islands Ministry of Forestry and Research 2010. http://mofr.gov.sb/foris/forestArea.do#marker

Thailand Royal Forest Department of Thailand 2016. http://forestinfo.forest.go.th/Content.aspx?id=72

http://www.nre.gov.my/en-my/Forestry/Pages/Statistics-Forest.aspx




61

Annex 2. Profiles of selected HFC countries Gabon

% forest cover 88%

Deforestation rate 0.1%

Deforestation

drivers

Palm, rubber, subsistence agriculture

Degradation: logging

Socio-economic

status

For the region a wealthy country but very inequal with

~30% of the population living in poverty, most of whom

rely on subsistence or small-scale agriculture.60

Types of producers Large-scale palm and rubber; small numbers of

subsistence smallholders

Policies in place Ambitions of becoming a leading palm oil exporter by

increasing production from 13,000 to 280,000 tons

year−1 by 2025 (Republique Gabonaise 2011, 2012, in

Burton, et al. 2016).

National palm oil strategy in development, to identify

nationally defined HCVs and high carbon stock forest to

protect

BAU? Allocated

land/concessions

There are currently 130,680 ha of oil palm concessions in

the country of which 58,980 ha is plantable, based on

environmental, social, and agronomic suitability

Large parts of the country allocated for forestry

concessions

Papua New Guinea

% forest cover 73%

Deforestation rate 0.1%

Deforestation

drivers

Subsistence agriculture & industrial forestry

Degradation: industrial forestry

Socio-economic

status

38% of Papua New Guineans live in poverty, 41.3% in

rural areas.61

60 https://borgenproject.org/poverty-in-gabon/

61 https://devpolicy.anu.edu.au/pdf/2011/Rural_Poverty_Remote_PNG_Report.pdf

https://borgenproject.org/poverty-in-gabon/

https://devpolicy.anu.edu.au/pdf/2011/Rural_Poverty_Remote_PNG_Report.pdf


62

Types of producers A handful of large palm companies, with the two main

companies RSPO members or certified. 100% of exported

CPO is RSPO certified.

Several new, uncertified members have recently begun

developing.

Majority of development on community land leased from

communities – communities receive land rent and profit

shares.

Policies in place Government Development Strategic Plan 2010-2030,

Vision 2050, including a goal to increase palm production

from 556,000 tonnes in 2007 to 1.5 million tonnes in

2030.

REDD+ country with a national REDD+ programme in

development to reduce deforestation

BAU? Allocated

land for

development

97% of land is customarily owned in PNG so in theory

communities decide on how to use their land. However,

corruption has exploited this through Special Agricultural

Business Leases. Although these are being clamped down

on now, there are also problems with unscrupulous

actors making agreements with clan leaders to develop

palm or forestry operations without true FPIC of wider

community members

Increasingly new palm companies are establishing in PNG

that are not RSPO members, including logging companies

that are developing palm having exploited all timber


63

Annex 3: High Forest Cover case studies synthesis The following case studies were shared with the consultants for this study. The

full results are considered confidential, and so only a synthesised analysis of the

studies is provided in the table below:

1. Hargy/Sipef, New Britain, PNG

2. HCS+ Study, Gabon, Mouila 1&2, Olam

3. Golden Veroleum, Liberia

4. NBPOL, PNG

5. Sime Darby, Liberia

6. Goodhope, Papua Province, Indonesia

For non-confidential topics, the numbers above are used to reference sources of

the following information.

Issue Summary analysis of case studies

SOCIAL

No deforestation

vs. oil palm for

community

income

Local communities (most of the time they are land owners)

pressure companies for oil palm development because it is

(1,2,3,4):

• A source of income

• A source of employment

• Development in a wider sense

In some cases pressures from local communities for

development can be very severe, e.g. there was one case of

violent attacks on a plantation by local communities asking for

jobs.

Government Governments are also pushing companies for development

and expansion (3, 4)

What were the

main threats to

forest? Was oil

palm always the

biggest one?

What else?

In most case studies, “sustainable” oil palm is not the main or

only threat to forests. The main identified threats are:

• Logging (1)

• Village oil palm (1)

• Non-certified oil palm producers (1)

• Subsistence agriculture is the primary driver of

deforestation (4)

• Industrial forestry (forest degradation) (4)

Were there other

oil palm

companies in

area?

In certain contexts, e.g. PNG, it is often mentioned that if the

current company does not develop land offered by

companies, that communities are likely to offer the land to

other companies to develop. In East New Britain there are

several other non-RSPO companies now


64

What were the

opportunities or

potential

solutions

proposed

Opportunities

• Development may reduce pressure in communities to

open up areas to community logging and farming,

allowing support for efforts to promote forest

conservation in high priority national parks and targeted

protection zones

• Potential for poverty reduction

• Source of employment

• Basic infrastructures

Potential solutions proposed in case studies

• Adapted carbon threshold to national context

• Thresholds to permit agriculture in previously degraded

forests while avoiding deforestation of older secondary

and primary forests

• A combined national level prioritization exercise to zone

out critical carbon and biodiversity areas and then more

degraded forests open for development but only if

companies follow strict site-level due diligence, e.g. HCV

• Set-asides ratio at the concession ensuring no-net carbon

emissions from plantation development

• If the context requires forest conversion for development,

emissions could be offset through set-asides at the

concession level to prevent immediate emissions and

sequester carbon under proper management. Example

from Gabon: a rule-of-thumb ratio of 2.4-2.6 conserved

hectare to each converted hectare of forest should be set-

aside if the 118 Mg C ha−1 threshold is applied, to ensure

carbon neutrality (2)

• Conduct a landscape study consisting of 3 steps to

determine possible development (4):

➔ Due-Diligence: desktop research and initial

stakeholder discussion

➔ Draft Land Use plan: HCS, HCV, ESIA and other

relevant assessments, a report with various

development options is proposed

➔ Draft Management Plan and Agreement: full

management Plan including monitoring is

proposed and agreed by key stakeholders

Risks of not

allowing some

development in

HFCLs

• Externalise deforestation to less sustainable actors

• Social conflicts:

o Communities with more forest may receive less

income from oil palm than those with less forest


65

o Companies prioritising low carbon areas may be

more likely to then conflict with community use

areas


66

june 2018 - rspo.org

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