Jakarta, October 24, 2025 — The government has just released the draft of the Second Nationally Determined Contribution (SNDC), which is planned for submission 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, officials acknowledged that the delay in submitting the SNDC document was due to difficulties in aligning targets across sectors. Under the Paris Agreement, each country should submit updates to its NDC 9–12 months before the COP agenda.

CELIOS notes that the climate mitigation strategy outlined in the SNDC document is biased toward land-based approaches and does not consider the protection of community tenure rights.

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

He also mentioned the government’s ambitious biofuel program, which targets 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 forests and food-producing areas, which could ultimately trigger massive deforestation. The absence of a clear definition of forests also makes claims of reduced deforestation ambiguous.

Ironically, the mitigation strategy in 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 forests on a large scale. 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 carbon emissions, 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 represents a regression from the spirit of the coal phase-out. Instead of 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 schemes 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 only prolong the lifespan of CFPPs. Gradually reducing coal dependency, rather than retiring plants early, underscores the false solution 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, directly increasing 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 the issuance of mining and smelter permits on small islands and in areas managed by Indigenous communities—and expediting passage of the Indigenous Peoples Bill as urgent legal protection measures. 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 needed to achieve the SNDC’s climate targets. The document estimates total investment requirements at USD 472.6 billion (approximately IDR 7,845 trillion), based on preliminary estimates, making strong international cooperation and support essential.

“We actually have many domestic financing options that can be implemented without burdening the economy—especially vulnerable groups. For example, we could introduce a windfall profits tax or a wealth tax. The data show that more than half of the wealth of Indonesia’s 50 richest individuals is linked to extractive industries. Progressive taxes on 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 Press Release: Second NDC — October 24, 2025 (1) Download