“Steve Zwick should withdraw his analysis and apologize,” Greenomics Indonesia responds to Ecosystem Marketplace’s Rimba Raya article

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A couple of weeks ago, REDD-Monitor wrote about about a Greenomics Indonesia report that questioned whether the Rimba Raya REDD project in Indonesia has the necessary approvals from the government of Indonesia. Infinite Earth, the project developer responded. Greenomics Indonesia replied to the response. Last week, Ecosystem Marketplace joined the debate.

Yesterday, Greenomics Indonesia sent REDD-Monitor a response to the Ecosystem Marketplace article.

In his article, Steve Zwick, the Managing Editor at Ecosystem Marketplace states that the Greenomics report, “selectively references government decrees and letters that support its claims while inexplicably ignoring those that prove it wrong.” Zwick writes that,

Indeed, every “smoking gun” the Greenomics authors claim to have discovered is also referenced in the May 2013 Verification Report, which is the document that auditors from SGS Global Services were required to compile in the process of certifying the project under the Verified Carbon Standard (VCS).

Greenomics Indonesia is sticking to its guns and in its response (below) asks Zwick to withdraw his analysis and apologise. The Greenomics Indonesia response can be downloaded here (pdf file, 679 kB).

For those who want to look further into the details of this debate, here are some relevant links:


  • Steve Zwick’s analysis was based on an incorrect translation from Indonesian to English of a letter issued by a Director General at the Ministry of Forestry.
  • As a consequence, his analysis is fatally flawed from the legal perspective. Accordingly, Steve Zwick should withdraw his analysis and apologize to the public, the carbon market and Greenomics Indonesia.
  1. An analysis by Steve Zwick claims that a recent report by Greenomics Indonesia on the Rimba Raya Conservation Project (published on 4 July 2013) is misleading. This analysis (which was posted at www.ecosystemmarketplace.com on 23 July 2013) clearly demands a response from Greenomics Indonesia. Why is a response necessary? Because we need to explain to Steve Zwick, the public and the carbon market that the analysis by Steve Zwick that was based on the letter issued by the Director General of Forestry Planology on 6 May 2013 was incorrectly translated from Indonesian into English. In addition, Steve Zwick’s analysis also failed to take into account the most recent and up-to-date letters issued by two Directors General of the Ministry of Forestry clarifying the latest legal status of the Rimba Raya Conservation project. The two letters, dated 13 and 18 June 2013, were addressed to PT Rimba Raya Conservation.
  2. As Steve Zwick’s analysis failed to use a correct translation of the letter of 6 May 2013 from the Director General of Forestry Planology and also failed to discuss the content of the two subsequent letters, its conclusions are misleading to the public and the carbon market, and clearly demonstrate that Steve Zwick fails to comprehend the latest legal status of the Rimba Raya Conservation Project.
  3. The authorized director at the Directorate General of Forestry Planology has confirmed to Greenomics Indonesia that the letter issued by the Director General of Forestry Planology on 6 May 2013 was never translated into English by the Directorate General of Forestry Planology. This means that the translation used by Steve Zwick in support of his analysis was an unofficial translation. Even more worrying is the fact that the said letter was incorrectly translated. In the translation referred to by Steve Zwick, the phrase “the endorsed areas” should have read “the areas that could be considered”. This mistake, according to the authorized director, has resulted in a fatal error in the legal purport of the letter of 6 May 2013 from the Director General.
  4. Greenomics Indonesia would therefore ask Steve Zwick to study the letter of 6 May 2013 from the Director General of Forestry Planology based on a legally correct translation, and simultaneously considering the two Directors General’s letters (issued respectively on 13 and 18 June 2013) so as to make himself aware that his analysis is misleading. Steve Zwick needs to encourage Infinite-Earth to translate the letter of 6 May and to request copies of the two letters from the Directors General on the Rimba Raya Conservation Project. As both letters are written in the Indonesian language, of course they will need to be correctly and accurately translated into English so that there is no repeat of the incorrect rendering from Indonesian to English of the letter from the Director General dated 6 May 2013.
  5. Through this response, Greenomics Indonesia would like to explain the substance of the letter of 6 May 2013 from the Director General of Forestry Planology, and the two Directors General’s letters dated 13 and 18 June 2013 in the public interest and so that the carbon market is not misled by Steve Zwick’s analysis.

    • In his analysis, Steve Zwick refers to the letter of 6 May 2013 from the Director General of Forestry Planology, Bambang Soepijanto. In detailing the proposed areas to be covered by the Rimba Raya ecosystem restoration plan, Steve Zwick should not omit to write that the said areas are in fact “areas to be considered” for inclusion in the ecosystem restoration plan of PT Rimba Raya Conservation. These areas extend to approximately 64,136 hectares. So, why is Steve Zwick’s analysis misleading? Because Steve Zwick used an incorrect translation of the letter of the Director General of Forestry Planology. After using their incorrect translation, Steve Zwick also fails to have regard to the subsequent letter issued by Director General Bambang Soepijanto on 18 June 2013, which clarified the previous letter dated 6 May 2013, that is, the letter referred to by Steve Zwick.
    • In the letter of 18 June 2013, Director General Bambang Soepijanto stated that outside the area of approximately 36,331 hectares that had been approved by the Minister of Forestry, the other areas could be considered for ecosystem restoration under the Rimba Raya Conservation Project, but would first need to be processed in accordance with the applicable legislation. That is, other than the approximately 36,331 hectares for which a license has already been granted, the remaining areas will still need to be officially processed. This is what Steve Zwick has failed to understand.
    • Steve Zwick’s analysis also failed to take account of the letter issued by the Ministry of Forestry’s acting Director General of Forest Protection and Nature Conservation on 13 June 2013. This letter, which is addressed to the PT Rimba Raya Conservation, was issued in response to the press release titled “World’s Largest REDD Project, Rimba Raya, earns VCS Verification from SCS Global Services”, which was published on 30 May 2013. The letter clearly states that the proposed collaboration between the Tanjung Puting National Park Authority and PT Rimba Raya Conservation (PT RRC) cannot include exploitation activities in the form of carbon storage and/or absorption over an area of 18,642 hectares in the Tanjung Puting National Park. The letter explained that the Rimba Raya Conservation Project can only accommodate exploitation activities in the form of carbon storage and/or absorption that have been granted a license by Minister of Forestry or an authorized official. To this day, PT. RRC has not received any such license for exploitation activities in the form of carbon storage and/or absorption in the Tanjung Puting National Park.

  6. Steve Zwick should note that the Greenomics Indonesia report published on 4 July 2013 was based on the most recent legal status of the Rimba Raya Conservation project, as described in the two Directors General’s letters. It is certainly strange that the analysis by Steve Zwick, which fails to refer to these two letters, claims that the report by Greenomics Indonesia is misleading, while in reality it is the analysis by Steve Zwick that is misleadin g as it fails to refer to the two letters, which taken together contain the most up-to-date description of the legal status of the Rimba Raya Conservation Project.
  7. And, most importantly, Steve Zwick needs to acknowledge to the public and carbon market that he used an incorrect English translation of the letter issued on 6 May 2013 by the Director General of Forestry Planology. His analysis is unworthy of a professional and, accordingly, he needs to withdraw it as soon as possible and apologies to the public and carbon market. In addition, Steve Zwick needs to publicly apologize to Greenomics Indonesia.
  8. In conclusion, Greenomics Indonesia would suggest that Steve Zwick should obtain a correctly translated copy of the letter of 6 May 2013 from the Director General of Forestry Planology. In addition, he should also obtain copies of the two letters issued by the Directors General on 13 and 18 June 2013, and ensure that both are translated correctly into English, both substantively and legally.
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6 Comments

  1. Clear as mud.

  2. I’ve spent a lot of time to follow this debate, but at the end I was surpised. There are at least two information that can be accused as mistake by design. The first is wrong translation that caused the second one, wrong information about total area. Therefore I have a critical question for this case. How can this company can get VCS verification, if in the fact they have supplied wrong material correlating with the legal issues? Mybe I am the one of Central Kalimantan that follow this case, where this project taking place. That why I am very doubt about REDD+, RE and Carbon Market. How can RE activities be granted for carbon market? Can we sell something that this world created as our own? If so, I just found the new easy way to make money. Thank you God, your creation incrrease the carbon balance by themself. I just need to keep watching! I am sorry if I am wrong. I hope all of you do the real thing for REDD+ before thingking to sell carbon.

  3. Thanks for responding to my piece, but my analysis was not based solely on the translated document you reference. It was mostly based on a comparison of your “report” to the readily-available, audited, and notarized documents that Chris has kindly posted above. These showed your “report” was wrong on several fronts.

    You pointed out, for example, that part of the Rimba Raya project was developed in the Tanjung Putting National Park, but you ignored the fact that the state moved the boundary of the park into the project area after the carbon project had already saved that portion of forest. Without the Rimba Raya project, that forestland would have been converted to palm oil production. You also kept focusing on the 64,000-hectare management zone and not on the 47,000-hectare accounting area, which is where the carbon credits are being generated.

    Now, rather than address the areas where you were so clearly and verifiably wrong, you insist that you have found some phrasing in the letters that you believe could be used to challenge a small part of the project. You alluded to this in your report, but the accusation is quite vague, and it’s hardly the thundering indictment of the project you trumpeted. This sounds more like a game of “gotcha”, where you’re digging and digging to find something — anything — that you can use to bring the project into disrepute. I’d need to speak with Indonesian legal scholars to find out how valid that claim is, but given that you were so obviously wrong on so many other points, I’m skeptical of this one and confused by your motives.

  4. Steve, your analysis was based on an inaccurate translation from Indonesian to English of one of key letters issued by a Director General at the Ministry of Forestry. This means that your analysis is fatally flawed from the legal perspective.

    Your analysis also failed to take into account the most recent and up-to-date letters issued by two Directors General of the Ministry of Forestry clarifying the latest legal status of the Rimba Raya Conservation project. The two letters, dated 13 June 2013 and 18 June 2013, were addressed to PT Rimba Raya Conservation.

    I encourage you to obtain a correctly translated copy of the letter of 6 May 2013. In addition, you should also obtain copies of the two letters issued by the Directors General on 13 June 2013 and 18 June 2013, and ensure that both are translated correctly into English, both substantively and legally.

    After securing and studying translated copies of the three letters, I would ask you to reconsider your analysis, particularly as regards the legal aspects. Thanks and regards, Elfian (Greenomics Indonesia)

  5. Aside from this debate between Steve Zwick and Greenomics, I’m not entirely convinced of the logic in Steve’s article and the extent to which it is predicated on how REDD+ works. Here are some observations or questions for Steve, Infinite Earth, Elfian, or anyone else who wants to chip in. The sections in parenthesis are from the article in Ecosystem Marketplace:

    “The document rightly points out that 18,642 hectares of the project area are in the Tanjung Putting National Park, and it implies this territory was already protected before the project began. But it ignores readily-available documents that tell the full story. Specifically, it ignores the fact that the state moved the boundary of the park into the project area after the carbon project had already saved that portion of forest.”

    These comments make some assumptions about when we can say the project “began”. Does it begin after the project developer has secured tenure over the project area? That date came after the boundaries of the park had been moved (by classifying it as “Protected Forest” – see below). So might it be more accurate to say that the Government had rightfully decided to protect an area of deep peat (in accordance with Indonesian law) by enveloping it into a national park to which it was contiguous?

    The statement that the project had “saved” the portion of forest is equally subjective. It’s unclear how the project “saved” the forest before the developers had legal tenure over it. If the area is now protected, as Steve observes, should polluters be allowed to offset their emissions somewhere else on the basis of credits issued by Infinite Earth/VCS? It’s protected, right, so where’s the additionality now?

    “…they were credited with preventing 2,462,212 tons of carbon dioxide from being emitted from July 2009 through June 2010.”

    Infinite Earth didn’t have tenure over this area during this period, so why are they being credited with that prevention? Surely the credit for preventing thos emissions during that period should go to the Indonesian Government, which by that point was still prevaricating over whether it should allocate the land for palm oil or ecosystem restoration? The only body that is “crediting” it for this period is VCS, which has a commercial interest in doing so to show that REDD+ is a viable business. I would be interested to know if the Indonesian government can legally credit these emission reductions to Infinite Earth during a period in which it had no secure tenure over the area. Why not issue them to local villagers – who arguably did and do have tenurial claims?

    I guess it’s in no one’s interests to say that, actually, no one should be issued credits for reducing emissions during this period, because everyone has a financial interest in suggesting that they did. Infinite Earth, Gazprom, the Government, VCS, polluters somewhere, all stand to gain by pretending Infinite Earth’s actions prevented emissions during this period. But that suggestion is entirely subjective, and not legally robust.

    “It wasn’t until March 2013 – long after the project developers had saved the forest – that the state expanded the park into the project area.”

    In fact the area in question was reclassified as Protected Forest by the Ministry of Forestry as far back as 2011.

    “At that point, the project developers entered into a Cooperation Agreement […] spelling out their new obligations as custodians of a piece of national park, but they had already been protecting the forest for years.”

    In what sense had they been “protecting the forest for years” by 2013? Let’s be clear – they weren’t phsyically there, right? What Steve means I think is that the idea of there project was preventing the government from approving palm oil permits. That’s a very different thing, and should we allow polluters to offset on the basis of an idea?

    Steve ends with the following point:

    “With so many pieces of the puzzle so readily available, one has to wonder why Greenomics chose to focus on just a few.”

    The problem is just that – it is a puzzle. Sure there are pieces available, but shouldn’t we be looking at a finished picture? At its heart the problem is that there is no independent, formal scrutiny by any body that does not have a vested interest in seeing the project generate “credits” – and as many as possible. Elfian and Steve are both relatively independent, but can’t come to a consensus.

    Is this a sensible way to MRV?

    To conclude my rambling comments… I don’t think Steve or Elfian are trying to mislead the carbon market. I think the way that the voluntary REDD+ process is structured provides no grounds for clarity, in what is a very murky, subjective and abstract concept that requires as much clarity as possible.

  6. Hi Twitcher, I totally agree and support your comments and/or verious questions above. I reckon Steve needs to elaborate more about his analysis and justification in his report so as to make everything away from just subjective conclusion.

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