Jakarta, October 24, 2025 — The government has just released the draft of the Second Nationally Determined Contribution (SNDC), which is expected to be submitted to the United Nations Framework Convention on Climate Change (UNFCCC) ahead of COP 30 in Brazil this November.

During a public consultation session held by the Ministry of Environment and Forestry, officials acknowledged that delays in submitting the SNDC document were due to difficulties in aligning targets across sectors. Under the Paris Agreement, however, each country should submit its updated NDC 9–12 months before the COP.

CELIOS notes that the climate mitigation strategy outlined in the SNDC document favors land-based approaches without adequately considering the protection of community tenure rights.

In response, CELIOS researcher Viky Arthiando explained, “The document includes a mitigation measure to rehabilitate degraded land through the development of energy plantations. Large-scale biomass plantation development—legally referred to as Energy Plantation Forests—could potentially trigger new tenure conflicts in areas where the management rights of Indigenous and local communities have yet to be legally recognized.”

He also pointed to the government’s ambitious biofuel program, which targets B40 by 2025. However, this policy lacks a robust monitoring mechanism to prevent palm oil and other bioenergy feedstock plantations from expanding into forested and food-producing areas, potentially triggering massive deforestation. The absence of a clear definition of forest also makes claims of reduced deforestation ambiguous.

Ironically, the mitigation strategy for the agricultural sector places the burden of reducing emissions on small farmers rather than on large corporations or projects such as food estates, which clear extensive areas of forest. CELIOS links this to the conversion of two million hectares of forest in Merauke for food estate programs. CELIOS’ analysis estimates that the project could instead generate an additional 782.45 million tons of CO₂ in emissions, equivalent to a carbon loss valued at IDR 47.73 trillion, effectively offsetting mitigation benefits in other sectors.

In the power generation sector, the government’s mitigation strategy marks a retreat from the spirit of the coal phase-out. Rather than accelerating the early retirement of coal-fired power plants (CFPPs), the SNDC document emphasizes the use of Clean Coal Technology (CCT), such as supercritical and ultra-supercritical systems, as a transition solution.

“This approach delays genuine decarbonization. Adopting technologies that merely extend the life of CFPPs—including biomass co-firing and CCS/CCUS—fails to address the root problem: dependence on coal,” said Fiorentina Refani, Director of Socio-Bioeconomic Studies at CELIOS.

The use of biomass as a bioenergy source and the application of CCT ultimately serve only to prolong the lives of CFPPs. A gradual reduction in coal dependence, rather than early retirement, underscores the false solutions being presented as an energy transition in the power sector.

Furthermore, Fio pointed out that the SNDC also fails to recognize the nickel and steel downstream industries as major sources of “hard-to-abate” emissions. In fact, the massive expansion of these industries relies heavily on captive coal-fired power plants in industrial zones, which directly increase Indonesia’s total carbon emissions. By neglecting this sector, she argued, the decarbonization roadmap becomes virtually impossible to achieve.

CELIOS also recommends establishing no-go zones—prohibiting mining and smelter permits on small islands and in areas managed by Indigenous communities—and expediting the passage of the Indigenous Peoples Bill as urgent legal safeguards. Without these measures, Indonesia’s energy transition risks becoming a pseudo-green project that merely replaces one form of exploitation with another.

CELIOS Executive Director Bhima Yudhistira also highlighted the financing required to achieve the SNDC’s climate targets. The document estimates total investment needs at USD 472.6 billion (approximately IDR 7,845 trillion), based on preliminary calculations, underscoring the need for strong international cooperation and support.

“We actually have many domestic financing options that could be implemented without burdening the economy—especially vulnerable groups. These include a windfall profit tax or a wealth tax. The data show that more than half the wealth of Indonesia’s 50 richest individuals is linked to extractive industries. Applying progressive taxes to extractive corporations or wealthy individuals whose income comes from environmentally destructive sectors could be a fair way to curb ecological degradation and finance the climate transition,” Bhima concluded.

CELIOS Second NDC Press Release - October 24, 2025 (1) Download