Voluntary Sustainability Certification and State Regulations: Paths to Promote the Conservation of Ecosystem Services? Experiences in Indonesia

Round 1

Reviewer 1 Report

1. A huge amount of complexity, with insufficient analytical structure to guide the reader. Key items of the conceptual framework are the Lambin et al interactions between policies (complementarity, substitution and antagonism); the three stages in the regulatory process (agenda setting and negotiation, implementation, and monitoring and enforcement); and transition theory.  Very little explanation is provided of any these concepts.  Figure 3, presented relatively late in the paper, actually presents some very useful ideas that could help to guide the narrative presentation.  I suggest that the authors also refer to the literature for a framework on the essential components of compensation or market for ecosystem services.  Distinguishing between compensation, rewards and payments would also help.   
2. The paper is very long (10,000 words of text) and dense. I would recommend simplification and removal of perhaps 2,000 words.  Perhaps some material could be removed or moved into another manuscript, such as the material regarding responsible sourcing of agricultural value chain commodities.  Is that experience directly relevant to FSC certification for ES?  Sub-section 4.1 is very long and tedious to read.
3. Another thing that might help is to break up long sections with some simple sub-headings, eg section 3.2 contains a number of distinct arguments that don’t necessarily flow from one to the next.
4. The reader is assumed to hold a lot of context specific information. For example lines 373-391 assume that readers are very familiar with REDD+ (eg. High Carbon Stock Approach). 
5. There are tonnes of grammatical mistakes throughout the whole paper, some of which are just annoying, but many of which make it very difficult to comprehend the full meaning. Just in the first few sentences, I found the following examples.  The whole paper needs very careful copy-editing.

Lines 21-22. “…. Were found to be both complementary, supporting and antagonistic.”  Both is not the correct word.

Lines 22-23. “Antagonism occurred ….and due to different contradictory state regulations.” The word different is redundant and this lacks a verb. 

Lines 24-25. “The voluntary instruments were developed …. Without any substitution with regulatory standards.”  Meaning of this is unclear.

Lines 25-30.  A run-on sentence, too many verbs in the same sentence.

Line 49-51 Five verbs and prepositions in the same sentence “To contribute to tackle… to improve, to promote, to address.

6. There seems to be little relationship between the material in Table 1 and narrative description of the content of the table.

Table 1.  The four types of ecosystem services are not discussed.  Distinctions between blanks, small x and large X are not provided. I have trouble believing that none of these laws actually have a primary focus on provisioning services of trees – timber, resin etc.  The table is also inconsistent with the narrative description of the content of the table.  The order in which the laws are listed has no clear logic.

Section 3.2 Lines 359-361. “The existence of both mandatory, such as 360 the mandatory government ISPO alongside and voluntary standards such as RSPO was also stated 361 to create confusion among public, consumers and private sector.”  I really don’t follow the argument here.

Lines 373-374.  “Zero-deforestation commitments advocating responsible sourcing of agricultural value chain 374 commodities such as palm oil, timber, soya and cacao.”  This is not a sentence.

7. I don’t understand the left column of Table 3. How did the authors identify these particular issues?

Author Response

Please see attachment.

Author Response File: Author Response.docx

Reviewer 2 Report

The article deals with an important challenge for sustainability programs – the relationship between voluntary schemes, market-based schemes and state regulation of the environment – or forests specifically. The research topic is therefore of broad interest to readers. However, I have a number of concerns regarding the paper in its current form that I believe need to be addressed.

My core concern is the conceptualisation of “ecosystem services” throughout the article. Page 8 (Line 286) defines ES based on the FSC principles. This is fine and, I imagine, a broadly accepted definition. Indeed, the definition seems to be drawn directly from the Millennium Ecosystem Assessment definition, even though the MEA is not discussed or acknowledged in the paper. The acronym “ES”, however, is also used throughout the paper, starting (I think) on page 2 (line 63) and then on line 72, where it is appended to “FSC”, but “ES” is never explained or defined. This is important, as the way “ES” is subsequently used through the article suggests a much more specific usage than “ecosystem services” as defined on page 8. I think “ES” is linked directly to the FSC ES. For example, the table on page 12 states: “No examples for ES certification, but apparent in REDD+ and PES projects”. This seems to make it clear that ES certification is considered distinct from PES. If so, I find this confusing, since many PES projects, including REDD+, do involve a certification process – such as the Verified Carbon Standard (VCS) mentioned on page 9 (line322), whose systems appear to have been a model for the FSC ES. As such, the FSC ES seems to be an attempt by the FSC to get into the broader business of certifying ecosystem services for PES schemes and it is not clear if the FSC ES is sufficiently unique and of broad enough interest and relevance to justify the conceptual distinctions apparently being made in the paper. Conversely, it seems that engaging with the broader attempts in the literature to analyse the interrelationships between PES and state regulation could strengthen the paper.

If the paper is in fact dealing with a much more specific type of PES, this needs to be made clear. It would certainly be helpful to explain the intended, and specific, market uses of the FSC ES Certification program. It is clearly intended to be used in some kind of PES market, but the details are missing. Related to this, it might be helpful to include further detail regarding the case studies in Indonesia - or perhaps one or two of them depending on the depth of insights gained through the 13 semi-structured interviews. Were any of the sites visited by the authors? If so, some of that field detail might be helpful.

I recommend the following 2010 Gomez-Baggenthun article below to help think through the origins, conceptualisation and mainstreaming of ecosystem services:

Gómez-Baggethun, E., De Groot, R., Lomas, P. L., & Montes, C. (2010). The history of ecosystem services in economic theory and practice: from early notions to markets and payment schemes. Ecological economics, 69(6), 1209-1218.

It may help address some of the ambiguity of what is meant by ES / ecosystem services in the paper, which poses further problems when presented in the 4 research questions on Page 3. 143-147. For example, “How are ecosystem services translated into state regulations in Indonesia?” Remembering that “ecosystem services” are ultimately a way of framing environmental challenges by drawing on utilitarian language, and that it is increasingly being used to address all manner of environmental phenomena, any aspect of environmental law could conceivably fall under the purview of this analysis. “Content Analysis” was identified as a key method and this appears to be applied in Section 3.1 and Table 1. Given the ambiguity over what is actually meant by “ecosystem services”, it might be helpful to explain what justifies an “X” or an “x” in Table 1. Does it indicate a specific mention of these terms (ie. “provisioning ecosystem service”) in the regulation or is this the authors’ interpretation of these regulations as referring to these different services. If I’m honest, I’m not really sure what the main take-home message is from this table and what it tells us about these regulations. In addition, the scope of the laws included here, and the general analysis, seems to refer only to forest-related ecosystem services. This should me made clear and consistently applied.

Would a more helpful question be: “How are PES translated into state regulations in Indonesia? In which case, Government Regulation No. 46/2017 Environmental Economic Instrument seems critical.

Given the attempt in the article to analyse Indonesian environmental / forest law, I’d recommend that the authors attempt to engage with, or at least be familiar with, some of the legal research that has been published on environmental management and ecosystem services in Indonesia. For example, the following publication may be helpful (I’m sure there are others) as it deals quite specifically with REDD+, which is a type of PES: Butt, S., Lyster, R., & Stephens, T. (2015). Climate change and forest governance: lessons from Indonesia. Routledge.

I believe that providing greater analytical clarity at the outset regarding the terms being used would result in much more useful discussion and conclusion sections. In the current form of the paper, the nature of the interrelationships (the core conceptual claim being made) currently lack specificity and this detracts from the strength of the argument in these sections.

Other minor comments:

The paper requires a solid edit for language. For example, on page 13 (lines 430-432), there are four spelling mistakes in a single sentence: “multiple laws and regulations in conjunciton with sustainability tools and private initaitves can create difficulties in determing which were effective and contributed to meet sustaianblity goals”. Unfortunately, this gives the impression of a rushed submission.

Page 2. 49: “To contribute to tackle the threats to maintaining ecosystem services….”

Page 2.76: “alternate” – alternative? Page 2.Line 89 uses “alternative”.

Page 4.191: “both which form the basis….”

Page 6. 205. Are environmental services and ecosystem services used interchangeably in the paper?

Page 6. 225: “Twelve years after being mandated in Articles 42 and 43 of Law No. 32/2009, the Government Regulation No. 46/2017 on Economic Instruments on the Environment was adopted.” Should this be eight years? Perhaps clarify.

Is figure 1 the authors own work?

Page 10. 352: “Interviewees mentioned concerns about the legitimacy of voluntary standards such as the Round Table for Sustainable Palm Oil (RSPO) certification and a number of cases where FSC has disassociated itself from timber companies, refusing the certification of any wood produced by  companies, even if it was harvested in FSC-certified forests”. A better explanation is required here. Clarify what kind of stakeholder the interviewee is.

Page 11.396. “after seven years ES certification is still in its infancy.” Does this refer to the FSC certification program only? More could be learnt from other PES schemes in Indonesia.

Page 13.424: “whilst the Economic Instruments Law talks specifies ecolabels”

Use of “Complimentary”, “complementary” and “complementarity” throughout the paper.

Author Response

Please see the attachment.

Author Response File: Author Response.docx

Round 2

Reviewer 1 Report

The manuscript has greatly improved and is now much more readable.  I now get a sense of two very different writing styles.  I would suggest one more round of edits to make the writing style more consistent.   

I have a few minor suggestions:

lines 246. Should be "command-and-control mechanisms".

Line 265.  I don't think that "vice versa" makes sense in this case.  Take out or explain.

lines 303-304.  These two sentences seem to be directly contradictory.  Does radical mean sudden or not?

line 310 and elsewhere in the manuscript.  Should be "may be" rather than maybe.

line 317. Should be incubators rather than incubations.

Figures 1 and 4.  Two versions of the same graph are included in the paper.  Is this intentional?  

lines 355-360.  A more accepted term is 'referral sampling' rather than snowball. 

line 379 Should be policies, strategies and rules.

line 710 Should be "were included in the"

line 760.  The authors assume advanced knowledge of REDD+ by referring casually to payments that are output versus input based.  I don't think that this distinction is essential to their argument and can be removed.  If essential, then the distinction needs to be explained. 

line 1064 Should be "to demonstrate that restoration:"

lines 1238 and following section.  The fact that there are other competing certification mechanisms is brought up in a very casual manner, without explanation until lines 1299-1302.  I suggest that the authors find a way to note this earlier in the paper, possibly in the methods section.  In these sections, some of the explanation now provided in 1299-1302 could be brought forward to line 1238.   

lines 1567-1568.  This sentence seems to come out of the blue (I don't recall seeing this earlier in the paper) and is confusing.  What in the world do you mean by "which are not be separate"? 

Author Response

Thank you for the detailed feedback, We haver tried to address all but one comment which was not clear.

The manuscript has greatly improved and is now much more readable.  I now get a sense of two very different writing styles.  I would suggest one more round of edits to make the writing style more consistent.   We have edited again and hope its now better.

I have a few minor suggestions:

LINE 104 lines 246. Should be "command-and-control mechanisms". Revised

LINE 123 Line 265.  I don't think that "vice versa" makes sense in this case.  Take out or explain.  Deleted, it was redundant

lines 303-304.  These two sentences seem to be directly contradictory.  Does radical mean sudden or not? 

the meaning of radical was defined in line 160: The term ‘radical’ addresses the speed of changes, rather than the size of changes. Its not contradictory, ie speed is the term that covers both slow AND fast

line 310 and elsewhere in the manuscript.  Should be "may be" rather than maybe. Revised

line 317. Should be incubators rather than incubations. Revised

Figures 1 and 4.  Two versions of the same graph are included in the paper.  Is this intentional? They are not the same! Ill Figure 1 is drawn from Delmas and Young and figure 4 is the FORCES system in Indonesia

lines 355-360.  A more accepted term is 'referral sampling' rather than snowball.Revised

line 379 Should be policies, strategies and rules. Revised

line 710 Should be "were included in the" Revised

line 760.  The authors assume advanced knowledge of REDD+ by referring casually to payments that are output versus input based.  I don't think that this distinction is essential to their argument and can be removed.  If essential, then the distinction needs to be explained. Revised and deleted

line 1064 Should be "to demonstrate that restoration:" Revised

lines 1238 and following section.  The fact that there are other competing certification mechanisms is brought up in a very casual manner, without explanation until lines 1299-1302.  I suggest that the authors find a way to note this earlier in the paper, possibly in the methods section.  In these sections, some of the explanation now provided in 1299-1302 could be brought forward to line 1238.   It is not clear to us what the reviewer means - there are no competing certification schemes for multiple ES. Also because the line number doesn’t match the pdf or word version submitted.

lines 1567-1568.  This sentence seems to come out of the blue (I don't recall seeing this earlier in the paper) and is confusing.  What in the world do you mean by "which are not be separate"?  Revised