Jakarta, October 24, 2025 — The government has just released the draft of the Second Nationally Determined Contribution (SNDC), which is planned to be submitted to the United Nations Framework Convention on Climate Change (UNFCCC) ahead of COP 30 this November in Brazil.
During a public consultation session held by the Ministry of Environment and Forestry, it was acknowledged that the delay in submitting the SNDC document was due to difficulties in aligning targets across sectors. In fact, under the Paris Agreement, NDC updates should be submitted by each country 9–12 months prior to the COP agenda.
CELIOS notes that the climate mitigation strategy outlined in the SNDC document shows a bias toward land-based approaches without considering the protection of community tenure rights.
Responding to this, CELIOS researcher Viky Arthiando explained, “The document includes a mitigation point through rehabilitation of degraded land via the development of energy plantations. The large-scale development of biomass plantations—legally referred to as Energy Plantation Forests—could potentially trigger new tenure conflicts in areas where indigenous and local community management rights have yet to be legally recognized.”
He also mentioned the government’s ambitious biofuel program targeting B40 by 2025. However, this policy lacks a robust monitoring mechanism to prevent the expansion (moratorium) of palm oil and other bioenergy feedstock plantations into forest and food-producing areas, which could ultimately trigger massive deforestation. The absence of a clear forest definition also makes claims of reduced deforestation ambiguous.
Ironically, the mitigation strategy in the agricultural sector places the burden of emission reduction on small farmers rather than large corporations or projects such as food estates that clear forests extensively. 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 additional carbon emissions of 782.45 million tons of CO₂, equivalent to a carbon loss of IDR 47.73 trillion, effectively offsetting mitigation benefits in other sectors.
In the power generation sector, the government’s mitigation strategy shows a regression from the spirit of coal phase-out. Instead of accelerating 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 schemes and CCS/CCUS—fails to address the root problem, which is 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 only prolong the lifespan of CFPPs, while gradual reduction (rather than early retirement) of coal dependency highlights a false solution to 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 “hard-to-abate” emission sources. In fact, the massive expansion of these industries relies heavily on captive coal-fired power plants in industrial zones, which directly increase national aggregate carbon emissions. By neglecting this sector, she argued, the decarbonization roadmap becomes virtually impossible to achieve.
CELIOS also recommends implementing no-go zones (prohibitions on granting mining and smelter permits on small islands and in indigenous community-managed areas) and expediting the passage of the Indigenous Peoples Bill as urgent legal protection measures. Without these, 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 financial needs to achieve the SNDC’s climate targets. The document states that total investment requirements amount to USD 472.6 billion (approximately IDR 7,845 trillion) based on preliminary estimates, requiring strong international cooperation and support.
“We actually have many domestic financing options that can be implemented without burdening the economy—especially vulnerable groups. For example, through a windfall profit tax or wealth tax. Looking at the data, more than half of the wealth of Indonesia’s 50 richest individuals is linked to extractive industries. Implementing progressive taxes on extractive corporations or wealthy individuals whose income sources come from environmentally destructive sectors could be a fair way to curb ecological degradation and finance the climate transition,” concluded Bhima.
