Date Attachment Subject
: November 4th, 2012 : Views and Recomendations for FIP document drafts version March and September 2012 : Civil Society Concerns on Indonesian Forest Investment Plan
To: FIP Subcommittee Board of Directors of the World Bank Board of Directors of the Asian Development Bank Board of Directors of International Financial Corporation Dear Sirs/Madams, We are expressing our deep concerns regarding the draft Indonesian Forest Investment Plan which is now under consideration by the FIP Subcommittee. From our point of view, the preparation process of this Forest Investment Plan failed to included meaningful consultation in a participatory manner involving various stakeholders, in particular representatives of potentially affected communities , which are likely to be impacted by the implementation of the Forest Investment Plan. Furthermore, substantively, this forest investment plan does not address the fundamental problems in the forestry sector and does not regard the affected communities, especially women, as primary stakeholders. Our concerns on the Indonesia Forest Investment Plan are as follows (for more detail, please see the enclosed views and recommendations that were sent to FIP Team and Indonesia’s National Forest Council (DKN) on 17 September 2012 and 10 October 2012, attached): 1. The Preparation Process • Meetings that were conducted to discuss the draft FIP document cannot be considered consultations, as they were not based on the principle of meaningful consultation, whether in the aspects of stakeholder representation or process. FIP Discussion processes were conducted in the areas that, for the most part do not represent potentially affected communities in the forestry sector, such as Semarang and Jakarta (pg. 112-115 FIP Document Draft Bahasa Indonesia Version). The participants have represented primarily civil society, academia, government and the private sector more than potentially affected communities. • The “public input” processes carried out by the FIP team, have further marginalized the people of Indonesia who have no access or limited access to the internet, especially potentially affected communities (indigenous and local communities, and especiically, women). This has confirmed that FIP Team has not viewed the potentially afftected communities, men and women, as primary stakeholders in the process of designing the FIP. The Draft Investment Plan mentions the potentially affected communities during the implementation stage, but during the planning design stage, the FIP Team failed to use a clear and well planned approached to ensure that the potentially affected communities, in particular women, could easily be involved or provide input. • The preparatory process for FIP document has not applied the ADB’s own safeguard principle of meaningful consultation and is not inclusive. This preparatory process is funded by the ADB through the technical assistance fund. Hence, there are obligations to follow the ADB’s Policy, including the requirement that all activities must abide by ADB’s Safeguards and other ADB Policies, including the ADB Public Communication Policy1, which includes requirements for "meaningful 1
ADB Safeguard Policy Statement, 2009. Pg 15, para 48. “This safeguard policy statement applies to all ADB-financed and/or ADB-administered sovereign and non-sovereign projects, and their components regardless of the source of financing including
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consulation", and the Gender and Development Policy2, which states that gender considerations must apply to all ADB activities, including technical assistance operations. There are inacuracies and differences in meaning in the FIP document translation from English to Indonesian, leading to a significant potential for misunderstanding or misinterpretation for the people of Indonesia. Poor translation has led to a weakening of meanings.
2. Substance • The Draft FIP refers to the drivers of the deforestation and forest degradation, but does not thoroughly analyze potential risks, impacts and mitigation efforts. The Draft FIP does not apply the ‘do no harm’ principle. There is no comprehensive description of the type and form of tenurial conflicts and gender injustices (and their resolution), which have occured in the various forest areas. Conflict resolution has been directed towards economic resolution focusing on forest benefits. • The Draft FIP fails to be strategic in its approach to the issue of deforestation and forest degradation, including failing to “follow the money” in terms of deforestation and forest degradation.The proposed FIP ignores or mis-maps the primary drivers of deforestation and forest degradation in Indonesia, namely the palm oil sector and pulp/paper industry. The problem of illegal logging and the mismanagement of production forest as well as the natural forests also contribute to the blooming of tax avoidance or fraud and money laundering in the forest products market. According to the INTERPOL3, it is likely that the Indonesian government loses potential tax revenue of between one to two billion USD per year, in the form of unpaid taxes or fees by forest sector conglomerates. Illegal logging not only destroys the forest but is also a global profitmotivated businesses involving tax manipulation and money laundering. Therefore, the FIP should examine the link between poor systems and policies in the forest sector with illegal logging, and support efforts to suppress money laundering and tax manipulation through Indoneisa’s Money Laundering Act No. 8 Year 2010 and Tax Law and policies. • The Draft FIP is not community rights-based. Communities in and around the forest are directed to economic based mechanisms. There is no consideration that the forest has not only an economic function but also social, cultural, even spiritual and ecological functions for the indigenous and local communities. The goals of enhancing capacity for communities appear primarily focussed on increasing the carbon stocks, as well as the burden of rehabilitating the forest areas that were severely damaged due to private sector activities and poor policies. • The Draft FIP does not meet gender justice standards. Women are not seen as primary stakeholders in the designing of FIP. There is no gender-disaggregated information and data baseline. There are no assesments of the drivers of deforestation and forest degradation in a gender perspective. There are no gender impact and risk assessments in and no development of efforts to mitigate and protect women from the impacts and risks of the FIP. There is no affirmative
investment projects funded by a loan; and/or a grant; and/or other means such as equity and/or guarantees (hereafter broadly referred to as projects). 2 ADB’s Gender and Development Policy, Pg. viii-ix, Executive Summary, Gender considerations will be mainstreamed into all ADB activities, including macroeconomic and sector work, and lending and technical assistance (TA) operations. Para 85, GAD will be actively promoted in both TA and loan operations. As with ADB’s economic and sector work, gender considerations will constitute an essential element of project work. ADB will promote the mainstreaming of gender considerations in projects, and gender concerns will be addressed at all appropriate stages of the project cycle from identification through postevaluation. 3
INTERPOL, CHAINSAW PROJECT: An INTERPOL perspective on law enforcement in illegal logging. 2010, published with
World Bank.
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action to involve women in all processes of consultation and decision making. There is no gender action plan. Based on those concerns, we urge the Board of Directors of World Bank, Asian Development Bank and International Financial Corporation, and the Sub-Committee of the FIP not to approve this flawed Draft FIP document as well as the implementation of the proposed Indonesian Forest Investment Plan. Any Forest Investment Plan must first ensure: 1) A public Consultation Process in accordance with the principle of meaningful consultation, involving all stakeholders, in particular, potentially affected communities, especially women, by emphasizing and based on the interest of the people of Indonesia, notably communities living in and around the forest area, with assessment of and consideration of forests not only from an economic aspect. 2) Revision of the substance of existing FIP document based on the recommendations from civil society, in particularly ensuring the principle and analysis of gender justice contained in the FIP document, taking note of the “money trail” in the forest sector and focusing to the drivers of the deforestation and forest degradation, namely palm oil and the pulp and paper industriy. Thereby are our concerns and demands. We hope that you will carefully consider our concerns and make the right and fair decision for all the people of Indonesia. Thank you for your attention and cooperation. Sincerely, The Undersigned: Organizations: 1. Solidaritas Perempuan, Indonesia, Signed By Wahidah Rustam 2. AKSI-Action For Gender, Social And Ecological Justice, Indonesia, Signed by Orchida Ramadhania 3. Ulu Foundation, USA, Stephanie Fried 4. Konsorsium pendukung Sitem Hutan Kerakyatan (KpSHK), Indonesia, Signed By Mohammad Djauhari 5. Indonesian Human Rights Committee for Social Justice (IHCS), Jakarta, Indonesia, Signed By Gunawan 6. Konsorsium Pembaruan Agraria, Indonesia, Signed By Idham Arsyad 7. Perhimpunan Rakyat Pekerja, Indonesia, Signed By Anwar Sastro Maruf 8. Kontras, Indonesia, Signed By Sinung Karto 9. Konfederasi Pergerakan Rakyat Indonesia, Indonesia, Signed By Sapei Rusin 10. Perhimpunan Sahabat Hati Damai (PESANDHAI), Indonesia, Signed By Sahat Pandiangan 11. Kelompok Studi Dan Pengembangan Prakarsa Masyarakat (KSPPM), Indonesia, Signed By Suryati Simanjuntak 12. Walhi Sumatera Selatan, Palembang-Sumatera Selatan, Indonesia, Signed By Hadi Jatmiko 13. Solidaritas Perempuan Palembang, Palembang-Sumatera Selatan, Indonesia, Signed By Dra. Ekawati 14. Solidaritas Perempuan Kendari, Kendari-Sulawesi Tenggara, Indonesia, Signed By Sarifain 15. Lembaga Bantuan Hukum (LBH) Padang, Padang-Sumatera Barat, Indonesia, Signed By Syahrul Fitra 16. Huma, Indonesia, Signed By Tandiono Bawor Purbaya, SH 17. Walhi Sumatera Barat, Padang- Sumatera Barat, Indonesia, Signed By Ierichk Coubut 18. Yayasan Trukajaya Salatiga, Salatiga-Jawa Tengah, Indonesia, Signed By Djoewanto 19. GREENPEACE, Indonesia, Signed By Bustar Maitar 20. Front Perjuangan Pemuda Indonesia, Indonesia, Signed By Ferry Widodo 21. Relawan Perjuangan Demokrasi (REPDEM), Indonesia, Signed By Masinton Pasaribu 22. Koalisi Anti Utang (KAU), Indonesia, Signed By Dani Setiawan 3/ 6
23. 24. 25. 26. 27. 28. 29. 30. 31. 32. 33. 34. 35. 36. 37. 38. 39. 40. 41. 42. 43. 44. 45. 46. 47.
Sarekat Hijau Indonesia, Garut-Jawa Barat, Indonesia, Signed By April Perlindungan Koalisi Rakyat Untuk Hak Atas Air (Kruha), Indonesia, Signed By Muhammad Reza Comunity Center Imbas Bersinar, Mataram-NTB, Indonesia, Signed By Tanwir, S.P Aliasi Masyarakat Adat Nusantara (AMAN) Lombok Barat, NTB, Indonesia, Signed By Raden Moh. Rais Solidaritas Perempuan Mataram, Mataram-NTB, Indonesia, Signed By B.Zulhiatina Suara Perempuan Desa, Malang-Jawa Timur, Indonesia, Signed By Salma Safitri Solidaritas Perempuan Sintuwu Raya, Poso-Sulawesi Tengah, Indonesia, Signed By Paulina Rusu Violet Gray, Aceh, Indonesia, Signed By Edi Saputra Atapku, Aceh, Indonesia, Signed By Rasulika Septila Serikat Inong Aceh (SEIA), Aceh, Indonesia, Signed By Agustina KPI Aceh, Aceh, Indonesia, Signed By Parmawati Aceh Women's For Peace Foundation, Aceh, Indonesia, Signed By Irmasari Balai Syura Uroeng Inoeng Aceh, Aceh, Indonesia, Signed By Nursiti PKBI Aceh, Aceh, Indonesia, Signed By Eva Khofifah Masyarakat Transparansi Aceh (MATA), Aceh, Indonesia, Signed By Abdullah Abdul Muthaleb Solidaritas Perempuan Bungoeng Jeumpa, Aceh, Indonesia, Signed By Cut Risma Aini Solidaritas Perempuan Sumbawa, Sumbawa-NTB, Indonesia, Signed By Ardani Hatta Koalisi Perempuan Indonesia Untuk Keadilan Dan Demokrasi, Indonesia, Signed By Dian Kartika Sari Solidaritas Perempuan Palu, Palu-Sulawesi Tengah, Indonesia, Signed By Ruwaida Arus Pelangi, Indonesia, Signed By King Oey Solidaritas Perempuan Jabotabek, Jakarta-Indonesia, Signed By Nurhidayah The Asian Muslim Action Network (AMAN) Indonesia, Signed By Indonesia, Signed By Ruby Solidaritas Perempuan Kinasih, Yogyakarta, Indonesia, Signed by Novita Dwi Arini Solidaritas Perempuan Kahyangan Api, Bojonegoro-Jawa Timur Indonesia, Signed By Murtiningsih Solidaritas Perempuan Anging Mammiri, Makssar-Sulawesi Selatan, Indonesia, Signed by Hajar
International: 48. AMIHAN-National Federation Of Peasant Women, Philippines, Signed By Tess Vistro 49. Cambodian League For The Promotion And Defense Of Human Rights, Cambodia, Signed By Naly Pilorge 50. Asia Pacific Forum On Women, Law And Development (APWLD), Asia Pacific, Signed By Kate Lappin 51. Womanhealth Philippines, Philippines, Signed By Ana Maria R. Nemenzo 52. EquityBD, Bangladesh, Signed By M. Rezaul Karim Chowdhury 53. All Nepal Peasants Federation, Nepal, Signed By Keshab Khadka 54. Pakistan Fisherfolk Forum, Pakistan, Signed By Saeed Baloch 55. Bangladesh Krishok Federation, Bangladeh, Signed By Badrul Alam 56. Nadi Ghati Morcha, India, Signed By Gautam Bandyopadhyay 57. SANLAKAS, Philippines, Signed By Marie Marguerite M. Lopez 58. VOICE, Bangladesh, Signed by Farjana Akter Individuals: 59. Risma Umar, Jakarta, Indonesia 60. Aliza Yuliana, Jakarta, Indonesia 61. Ade Herlina, Padang, Indonesia 62. Nisa Anisa, Bogor-Jawa Barat, Indonesia 63. DD Shineba, Jakarta, Indonesia 64. Iwan Nurdin, Jakarta, Indonesia 65. Ridwan Darmawan, Jakarta, Indonesia 66. Estu Fanani, Bantul-Yogyakarta, Indonesia 67. Aftrinal Sya’af Lubis SP., Bogor-Jawa Barat, Indonesia 68. Nurul Utami, Indonesia 69. Oding Affandi, Medan, Indonesia 4/ 6
70. Sulhani M Pratiwi, Kendari-Sulawesi Tenggara, Indonesia 71. ST. Aisyah, SE, Kendari-Sulawesi Tenggara, Indonesia 72. Rahma R. Talui, Kendari-Sulawesi Tenggara, Indonesia 73. Husnawati , Kendari-Sulawesi Tenggara, Indonesia 74. Nurhamida , Kendari-Sulawesi Tenggara, Indonesia 75. Ismad Jaya, Kendari-Sulawesi Tenggara, Indonesia 76. Sufri, Kendari-Sulawesi Tenggara, Indonesia 77. Hasma, Kendari-Sulawesi Tenggara, Indonesia 78. Husman Budiman, Kendari-Sulawesi Tenggara, Indonesia 79. WD. Imami, Bau-Bau-Sulawesi Tenggara, Indonesia 80. Nihrawati, Kendari-Sulawesi Tenggara, Indonesia 81. Patmawati, Kendari-Sulawesi Tenggara, Indonesia 82. Norma Azazi, Kendari-Sulawesi Tenggara, Indonesia 83. Munirmawati, Kendari-Sulawesi Tenggara, Indonesia 84. Ramla, Kendari-Sulawesi Tenggara, Indonesia 85. Arieska Kurniawati, Jakarta, Indonesia 86. Rendro Prayogo, Indonesia 87. Dewi Kartika, Jakarta, Indonesia 88. Tina Napitupulu, Jakarta, Indonesia 89. Dimpos Manalu, Yogyakarta, Indonesia 90. L. Wilsan Ibnu Hanif., Mataram-NTB, Indonesia 91. Lalu Tahta Dzhilal Aqli, Mataram-NTB, Indonesia 92. Sitra, Mataram-NTB, Indonesia 93. Dinda Nuuranisaa Yura, Jakarta, Indonesia 94. Ahmad Marthin Hadiwinata, Jakarta, Indonesia 95. Mickael B. Hoelman, Jakarta, Indonesia 96. Yuni Riawati, Mataram-NTB, Indonesia 97. Frida Kantjai, Poso-Sulawesi Tengah, Indonesia 98. Ester Parinding, Poso-Sulawesi Tengah, Indonesia 99. Risma Moguntu , Poso-Sulawesi Tengah, Indonesia 100. Jasmine Kamba, Poso-Sulawesi Tengah, Indonesia 101. Sury Kayupa, Poso-Sulawesi Tengah, Indonesia 102. Ani Ta'ere, Poso-Sulawesi Tengah, Indonesia 103. Hernia Sangira, Poso-Sulawesi Tengah, Indonesia 104. Ika Tendea, Poso-Sulawesi Tengah, Indonesia 105. Soeherry, Banda Aceh-Aceh, Indonesia 106. Melisa Silviana, Banda Aceh-Aceh, Indonesia 107. Abdul Muiz, Banda Aceh-Aceh, Indonesia 108. Henny Ulfa, Banda Aceh-Aceh, Indonesia 109. Arabiayani, Banda Aceh-Aceh, Indonesia 110. Dina Kosadiana, Banda Aceh-Aceh, Indonesia 111. Faisal, Banda Aceh-Aceh, Indonesia 112. Junaidi Abdillah, Banda Aceh-Aceh, Indonesia 113. Ruwaida, Banda Aceh-Aceh, Indonesia 114. Kamal Apriansyah, Banda Aceh-Aceh, Indonesia 115. Rosmidar, Banda Aceh-Aceh, Indonesia 116. Mariani MS, Sumbawa-NTB, Indonesia 117. Amir Manuk Allo, Sumbawa-NTB, Indonesia 118. Novianti Kartini, Sumbawa-NTB, Indonesia 119. HUSNULYATI, Sumbawa-NTB, Indonesia 120. Wardarina, Chiangmai, Thailand 121. Wiwin Matindas, Palu-Sulawesi Tengah, Indonesia 122. Suhartati, Palu-Sulawesi Tengah, Indonesia 5/ 6
123. 124. 125. 126. 127. 128. 129. 130. 131. 132. 133. 134. 135. 136.
Sri Mustika, Palu-Sulawesi Tengah, Indonesia Indriyani, Palu-Sulawesi Tengah, Indonesia Maya Safira, Palu-Sulawesi Tengah, Indonesia Supryanti, Bogor-Jawa Barat, Indonesia Syarifa, Bogor-Jawa Barat, Indonesia Vonny Iriani, Bogor-Jawa Barat, Indonesia Rohayana, Bogor-Jawa Barat, Indonesia Djabaedah, Jakarta, Indonesia Halima, Jakarta, Indonesia Elasar, Jakarta, Indonesia Nurhaya, Jakarta, Indonesia Thaufiek Zulbahary, Bogor-Jawa Barat, Indonesia Donna Swita Hardiani, Banda Aceh-Aceh, Indonesia Marhaini Nasution, Jakarta, Indonesia
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