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null APP’s Response to Greenpeace, Burning Issues: Five Years of Fire dated 22 October 2020

APP’s Response to Greenpeace, Burning Issues: Five Years of Fire dated 22 October 2020

Greenpeace had offered APP an opportunity to share its point of view prior to the publication of the above article.  APP provided factual corrections as well as its opinion to Greenpeace on 5th October 2020.  APP also offered to engage in dialogue with Greenpeace to provide further clarifications and context around the issues raised in the report, which was not taken up.  

Upon reviewing the published report in detail, we note that Greenpeace had reflected very little of the feedback it was provided.  We therefore release the following information note to share the material that was previously made available to Greenpeace, and to provide greater clarity on the issue, especially with regard to areas that pertain to APP’s performance in forest protection and fire prevention.

APP Suppliers

In the pre-report clarification sent to APP by Greenpeace, several errors were noted. APP clarified that the following companies were not part of APP’s supply chain and has no commercial agreements with them.  These are:

  •  PT Kirana Chatulistiwa
  •  PT Hutan Rindang Banua
  •  PT Bangun Rimba Sejahtera

PT Artelindo Wiratama was also incorrectly listed as an APP supplier. While they are currently undergoing the Supplier Evaluation and Risk Assessment (SERA) process, which is a requirement before new suppliers can be part of APP’s supply chain, they were not a supplier in the time period examined by this report.

Details of all APP's pulpwood supplier concessions are publicly available on APP’s sustainability dashboard (, including names, locations, sizes and status of High Conservation Value (HCV) and High Carbon Stock (HCS) assessments. You may also refer to APP’s 2019 report on commercial links to all Indonesian industrial forest companies ( 

Sanctions Against APP Suppliers

Greenpeace also used sanctions as an indicator in their report. This can be misleading. There are different levels of sanctions that the Government of Indonesia can impose on companies as a result of forest fire cases.  These are: 

  1.  Administrative Sanctions: Mandating a company to assist with investigations and provide comprehensive reporting to ensure the company is in compliance
  2.  Operational Sanctions: Mandating a company to implement detailed corrective actions
  3.  Freeze of License which results in the temporary suspension of operations until corrective actions have been fulfilled
  4.  Termination of License should the company be unable or unwilling to fulfill corrective actions 

Over the period of 2015 - 2018, 23 companies in APP’s supply chain received administrative sanctions while 2 received operational sanctions. There were no sanctions handed out to APP or its suppliers in 2019. Sanctions were all lifted following the fulfilment of obligations set for the respective companies. As of Dec 2019, there were no pending investigations or outstanding penalties on APP or APP supplier companies.  This information was provided to Greenpeace during clarification.

However, the published report continued to identify a total of 33 sanctions, including 3 in 2019. It is unclear how Greenpeace arrived at this number, as the report does not list the source of this information, nor the list of suppliers they used for comparison.

Forest Fires in Indonesia

Fire is an issue that greatly concerns all parties.  APP and its suppliers are also victims of this phenomena as portions of its standing stock have been, and continue to be at risk of being, destroyed by fires.  

The causes of forest fires are complex, as are the solutions required to prevent, contain and reduce the threat. Those who study these fires need to have a deeper understanding of the issues that goes beyond just viewing satellite photographs and burn scars.  

Greenpeace appears to extrapolate that fires on concession land presents evidence that plantation operators are continuing to use fire to clear land for commercial crops.  APP and its suppliers have had a zero-burn policy for many years and will never use fire to clear land. To simply assume the presence of fires means land clearance by concession holders greatly oversimplifies the situation, mistaking correlation with causality. No conclusion can be drawn without also understanding the origins and specific location of these fires and without overlaying this with the social dynamics that exist in those areas.  If indeed the issue is as Greenpeace suggests, it would be difficult to understand why areas that were burnt in previous seasons - allegedly for planting - would be subject to fires in subsequent seasons. Plantation crops can take as long as five years to mature, and there is no reason for any company to burn its own crop.  

This assertion also fails to explain the large amount of fire alerts and burnt areas outside concession boundaries.  Why do these fires occur?  The open platform Global Forest Fire Watch by WRI, showed that 80% of total fire alerts were recorded as being outside concession boundaries in 2019 which was a dry year.  What would also be telling is an analysis of the land post fire, and the crops grown if any.  This would offer more convincing evidence if their initial assertion were true.

The aggregated number used in the Greenpeace report also masks the significant progress that has been made since the devastating fires in the base year of 2015.  The report aggregates the data from 2015 onwards. The base year of 2015 skews the data. But since then, companies like APP have invested significantly in fire prevention, early warning, preparedness and suppression to prevent a reoccurrence of the disaster of 2015.  APP invested more than US$150 million in Integrated Fire Management to build up its surveillance, preparation and firefighting capabilities. This includes investment in equipment - including helicopters, fire engines and support vehicles - so that forces can respond quickly and effectively to outbreaks of fire. Today, APP has one of Indonesia's largest private fire protection forces with over 3,000 trained firefighters.  

This investment is a big part of the reason why the subsequent four years has seen a general reduction in fire incidents, and considerable progress in combating the threat of fires.  With the end of the dry season in a few weeks, 2020 will see APP record one of its best years in combating fire, where fire affected areas will be very small, and where the firefighting team contained fires to less than two hectares within four hours more than 90% of the time.  

Lastly, the report also does not refer to the involvement of other stakeholders in solving the problem.  It also does not give credit to the community programs which companies like APP put in place to prevent the use of fire in community agriculture, which is one of the major causes of forest fires. The APP initiated DMPA Program, based on the Integrated Forestry & Farming System concept, delivers education on fire risks and discourages the use of slash and burn in community farms. It also addresses the main root cause of these fires, which is poverty. 

By improving the community's access to better, more sustainable, livelihoods, APP is not only able to improve lives, but to also reduce fire risk and deforestation in areas in and around its supplier concessions. To date, more than 31,000 households from 390 villages have benefitted from the program.  As the program is relatively still in its early stages, the long-term success remains to be seen, but anecdotal evidence suggests that it has already contributed significantly to a change towards more sustainable agriculture. 

The point is worth reinforcing: the issue of fire is a complex one.  Understanding the topic requires us to go beyond aggregating data and reading conclusions in a superficial way.  If Greenpeace’s concern is to understand these issues in greater depth, and address the threat of fires, APP remains open to engage in a dialogue. 

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