Commenter(s) :
Tom Johnson (EarthSight)
Date of Comment :
29 June 2016
Nature of Comment :
Substandard NPP assessment
Comment Summary :
- The assessments were carried out by a lead assessor who has carried out several critically flawed – and one demonstrably fraudulent –NPP assessments in the past, that have led to a number of RSPO complaints.
- The assessment exhibits the same flawed methods and findings that characterised previous substandard assessments. In particular, the use of “purposive” sampling methods, and identifying only rivers and other areas proscribed by Indonesian law, as HCVs. The CB that verified one of the above assessments has been struck off, but the lead assessor remains able to carry out these weak assessments. Some of the language in the summary reports is meaningless and/or indecipherable. The documents include information indicating that the company was operating illegally for at least two years. Further, that the lead assessor knew this to be the case. Yet this is not raised as a concern. The RSPO NPP assessment appears to be a rehash of the Indonesian AMDAL process, which took place in 2009, before the company was an RSPO member and falls far short of RSPO requirements. The assessments therefore took place six years ago, against a weaker standard. Yet have been deemed suitable for the RSPO. There are ambiguous references to social issues that indicate tenurial conflicts may emerge, or have already emerged. The management plan indicates that land tenure conflicts will be mitigated through a land inventory, by 2010. It is now 2016. An analysis suggests that the company cleared areas identified as HCVs prior to the submission of the NPP notification. In sum the company’s membership of the RSPO and this assessment provides nothing additional to Indonesian law, and the company has not even complied with that. Yet the assessor and CB found no reason to raise concerns over this.
Response from Grower :
- Tlt is noted that the appointment of Mr. Nyoto as the assessor is based on the fact that he is one RSPO Approved Assessor at the time when the assessment was conducted, so he and his team are qualified as an assessor for HCV under the auspices of RSPO.
- The potential conservation and social liability regarding the loss of potential HCV area due to land clearance without prior HCV assessment, we had already identified through a Land Use Change Analysis of RSPO Remediation and Compensation Procedure, and the report is still under review by the RSPO Compensation Panel. Furthermore, we have planned to conduct a HCV verification review using an independent third party consultant, to review recent conditions and future recommendations for managing and monitoring PT AIEK’s HCV areas.
NPP Public Notification/Comment Status :
Closed
Comment referred to Complaints :
No
Commenter(s) :
Audrey Versteegen (Environmental Investigation Agency)
Date of Comment :
16 July 2016
Nature of Comment :
Non- compliance of SEIA and HCV assessments
Comment Summary :
- TSEIA – non-compliant with RSPO NPP 2015 as it is out of date.
- HCV assessment – non-compliant with the RSPO NPP 2015 as it is out of date.
- HCV assessment – non-compliant with HCV Resource Network (HCVRN) best practice.
- HCV assessment – non-compliant with HCVRN ALS requirements
Response from Grower :
NPP Public Notification/Comment Status :
Closed
Comment referred to Complaints :
No