Comment submitted by L. Buana

By 2022 Indonesia will expand more than 100,000 hectares in response the the world increasing demand including biofuel from the USA. However, It seems to me the proportion of Projected Land Cover types impacted oil palm expansion (Tabel II-5) also in the sheet "Indo&Malay LUC area" in the Docket might not be accurate for several reasons: 1. The government has issued Presidential Instruction no 10 2011 (Inpres 10-2011) which posphone the issuance of land use right (for agricultural usage) from primary forest and peat 2. Inline with the Inpress, the government issues indicative map that showing the primary and peat land ("the forbidden land") 3. Minsitry of forestry mentioned that there are about 30 million degraded forest which is possible can be used for agriculture (including plantation usage). With that, i doubt that 43% of the oil palm expansion will be on Forest area (with high carbon stock), also thye 13% on Peat. 4. The plantation expansion has shifted from Sumatera Island to Kalimantan. In Sumatra we mostly do replanting the oild plantation. Because of that I think the Modelling for expansion should be reviced properlly by including existing the policy and regulation of the country.