Dear Mr. President of the Republic of Indonesia,

We, the undersigned, welcome the steps taken by Your leadership in addressing the impacts of climate change. The commitment that You have shown through the Presidential Instruction regarding the Suspension of New Permit Issuance and Improvement of Primary Natural Forest and Peatland Governance and the National Action Plan for Greenhouse Gas Emission Reduction is a significant advancement.

We acknowledge that climate change is mainly caused by human activities that do not wisely manage natural resources, which consequently contribute to environmental destruction. The above policies could be a good initial step in ensuring the protection of the remaining natural forests and peatland ecosystems. This is urgent because deforestation, peatland conversion, and forest fires remain the largest sources of greenhouse gas emissions in Indonesia, resulting in environmental damage and disasters.

In addition to being carbon-rich areas, peatland ecosystems are also the habitat of indigenous/local communities and home to biodiversity, especially for endemic species (iconic species) in Indonesia such as the Sumatran tiger, proboscis monkey, orangutan, Sumatran elephant, and others.

Currently, what troubles us and raises our concerns is the Draft Government Regulation on the Protection and Management of Peatland Ecosystems (RPP Peatland). The draft regulation is deemed not strong enough to protect peatland ecosystems, even appearing weak compared to Presidential Instruction No. 6 of 2013. Based on official government map analysis and data, almost 40% of peatland ecosystems have been granted permits for exploitation, leaving around 60% protected, mostly located in conservation, protected, and moratorium areas. Monitoring and analysis of fire point distribution in February 2014 found that 75% of fires occurred in peatlands.

Regulations regarding the Protection of Peatland Ecosystems should ideally be a comprehensive effort to protect peatland ecosystems due to their irreversible nature. However, it is regrettable that the content of this draft regulation provides a high tolerance for peatland ecosystem damage by dividing peatland ecosystems into protective and cultivation functions that determine the standard criteria for damage.

Specifically, the reasons we urge for the postponement of the approval and reconsideration of this draft regulation are as follows:

1. The content of this draft regulation is legally flawed because:
   1. Article 35 provisions in this draft regulation contradict Articles 98 and 99 of Law No. 32 of 2009 as violations of standard damage criteria are criminal offenses, subject to criminal sanctions, not administrative sanctions as stipulated in this draft regulation.
   2. The determination of regulations on standard criteria for peatland ecosystem damage with a depth of less than one meter into environmental permits as stipulated in Article 23 Paragraph (2) of this draft regulation violates the spirit of law enforcement in Law No. 32 of 2009, as violations of standard damage criteria are criminal acts while violations of environmental permits are administrative offenses.
2. Technical considerations

The differentiation of standard criteria for ecosystem damage based on functions as stipulated in Article 22 of this draft regulation is irrational as peatlands are an integrated ecosystem.

Respected Mr. President, as part of the Indonesian people who are fighting alongside You to assist in the conservation of forests and peatland ecosystems in Indonesia, we hope that You first ensure several things:

1. Formulate a Government Regulation on standard criteria for peatland ecosystem damage in accordance with the mandate of Article 21 paragraph (3) letter f of Law No. 32 of 2009 on Environmental Protection and Management.
2. Conduct a review and environmental audit for companies operating in peatland areas.
3. Before arranging the protection and management of peatlands, the government should prioritize the drafting of Environmental Inventory Regulation, Eco-Region Determination Regulation, and Environmental Protection and Management Regulation. With the enactment of these regulations, the Government and Regional Governments can develop a comprehensive and integrated environmental planning grand design, where the Peatland Ecosystem Protection and Management Plan (RPPE Peatland) refers to the Environmental Protection and Management Regulation.
4. Conduct environmental inventory in accordance with the mandate of Law No. 32 of 2009 on Environmental Protection and Management, and ensure that the policy is continued with the designation of eco-region areas and the preparation of national and regional Environmental Protection and Management