Transboundary Haze Pollution in Island Southeast Asia: A Crisis of Collective Action

Transboundary Haze Pollution in Island Southeast Asia: A Crisis of Collective Action

Monday, December 27, 2021 - 3:57pm
Author: 
Megan McQueen

Abstract

Transboundary haze pollution from forest and peat fires in Indonesia continues to affect Indonesia, Malaysia, and Singapore on an almost yearly basis. Episodes of transboundary haze are linked to negative health and economic outcomes. Peat fires produce the thick and sooty smoke that travels long distances to blanket nearby countries in haze. Unsustainable farming practices on protected Indonesian peatlands by domestic, Malaysian, and Singaporean palm oil companies create the conditions for these fires. The global demand for cheap palm oil from developing countries like Indonesia provides an incentive for actors including companies, the Indonesian state, and local officials to participate in the production of this profitable commodity. Furthermore, a system of patronage politics between companies and government actors allows palm oil companies to skirt regulations and obtain licenses to farm on protected peatlands. Attempts at regional cooperation also failed to mitigate the haze pollution due to a lack of enforcement mechanisms and the complex nature of regulating a transboundary issue. This paper examines the effects of transboundary haze in Southeast Asia and the reasons it continues to affect the region. It argues that transboundary haze pollution is a collective action problem, where stakeholders are incentivized (politically or monetarily) to engage in activities that harm the environment and damage their home countries.

Keywords: Transboundary haze pollution, sustainable agriculture, ASEAN, oil palm farming, environmental agreements, air pollution

Introduction

Transboundary haze pollution has affected Indonesia and neighboring countries on a near-annual basis for decades. Stemming from forest and peat fires on Indonesian islands Sumatra and Borneo, transboundary haze is responsible for a host of economic, health and geopolitical issues. The primary cause of the haze-producing fires is palm oil farming practices on Indonesian peatland. Draining in preparation for plantation agriculture, which leaves peatland dry and fire-prone, as well as intentional burns to clear the land, are the main contributors. Formal policy efforts directed at mitigating or preventing the haze have all failed to stop episodes of haze from recurring during dry seasons. The Indonesian government has put in place policies to promote sustainable farming on peatland and prohibits land-clearing by fire, but a lack of enforcement and complex patronage ties between palm oil investors and state officials allow harmful practices to continue.

In this paper, I will examine the negative consequences of the transboundary haze pollution, the land use and business practices that produce it, and the reasons why attempts to prevent it have failed thus far. This paper will argue that transboundary haze continues to affect island Southeast Asia because stakeholders lack the economic and political incentives to end unsustainable land use practices in Indonesia. Transboundary haze represents a complex collective action problem: while individual actors in affected countries suffer from the health and economic impacts of yearly haze pollution, corporations and local officials choose to engage in practices that bring these harms to their home countries. These actors are motivated by financial and political gain that current governing elites in Indonesia and the global demand for palm oil both perpetuate. Furthermore, the Indonesian state favors the interests of palm oil companies because the industry fuels a narrative of economic growth and poverty reduction. Although the responsibility for haze prevention falls ultimately to the Indonesian government, it is valuable to keep in mind the roles of globalization, export capitalism, and economic inequality in driving these negative outcomes. 

Background: Transboundary Haze and its Consequences

Transboundary haze is a form of seasonal air pollution that crosses national borders, affecting up to six Southeast Asian countries on a near-annual basis.[1] The particulates that make up the haze arise from forest and peat fires during the dry season, mostly in Indonesia on the islands of Borneo and Sumatra. When this particulate matter travels across national borders, it is called transboundary haze.[2]

Transboundary haze pollution has adversely impacted air quality in Indonesia, Malaysia, and Singapore for decades.[3] Although there are reports of haze beginning in the 1980s, the first major episode occurred in 1997 when Singapore, Kuala Lumpur and to a lesser extent Jakarta (along with other Southeast Asian cities) experienced weeks of air pollution with widespread concerns about its economic and health consequences.[4] The most recent serious episodes of haze took place in 2015, 2016 and 2019.  

People and countries in reach of the smoke suffer environmental, economic, and health damages that are often serious. A scholarly review by Kang Hao Cheong et al (2019) found that the haze has acute health consequences including respiratory issues, cerebrovascular disease, cardiovascular disease, and increases in rates of non-accidental and cardiovascular deaths in affected countries.[5] In Malaysia, researchers found that haze occurrences were associated with increased inpatient hospital cases and a corresponding loss in economic productivity.[6] The 2015 haze episode in Singapore, which lasted two months, cost the country an estimated S$1.83 billion in lost tourism, reduced productivity, lost business, healthcare costs, and cost of mitigation actions by the Singaporean government.[7] Another study found that Singaporean households increased energy and other utilities consumption during haze episodes.[8] More generally, sick days and school closures due to the haze place additional burdens on children and caretakers. Farms are affected by a lack of sunlight during haze episodes, because plants are unable to photosynthesize. [9] And then there is the damage to the environment—the 2015 fires alone burned a swath of forest, peat, and other land in Indonesia more than four times the size of Bali.[10]

Peat Fires and Transboundary Haze

Tropical lowland peatland swamps are a type of forestland commonly found in Southeast Asia, with Southeast Asia accounting for 6% of the total peatland of the world. Indonesia is the fourth largest in the world in terms of peatland area. Over 12% of Indonesia’s land area is peatland, with most of this located on the islands Borneo, Sumatra, and Irian Jaya.[11]  While most crops are not suitable for cultivation on peatland, oil palm can thrive when the peatland has been deeply drained.  While indigenous farmers have practiced swidden agriculture in the region for over 200 years, large commercial operations are primarily to blame for recent severe haze episodes. Researchers have traced the fires and smoke over the last several decades to commercial land clearing for palm oil and timber plantations developed under government license.[12]

Peat fires are the greatest contributor to the transboundary haze crisis. Helena Varkkey,[13] who specializes in transboundary haze studies at the University of Malaya, concluded as much after over 100 in-depth interviews with government officials, NGO actors, corporate representatives, academics, and other stakeholders. Forest fires, Varkkey points out, are more common but burn only tree canopies and produce little smoke for short periods of time. Peat fires spread below the surface to reach carbon-rich soil, producing thick and sooty smoke that travels long distances. These peat fires are also harder to put out. Thus, relatively infrequent peat fires can have dire environmental consequences, burning for longer and producing the noxious haze that envelops affected countries.[14]

Peatlands are not ordinarily fire-prone: they are flooded year-round in their natural state. They become flammable only when drained in preparation for planting. Once peatlands are drained, the dry biomass can catch fire accidentally. El Niño-related droughts increase the risk of such blazes.

Additionally, some companies use fire as a cheap and effective method of clearing peatland in preparation for planting lucrative crops like oil palm.[15] By burning away unwanted grass and weeds, companies reduce the risk of pests and lower their operating costs. Because palm oil is a commodity good used in a wide range of products, companies face pressure to keep costs low to maintain their profitability. It is already costly to drain peatlands in preparation for planting, thus fire as a cost-cutting method holds appeal. While not all companies use fire to clear land, satellite images and field research suggest larger plantations use open burning on peatlands.[16] The next section of this paper will address palm oil farming as a key contributor to the peat fires that cause transboundary haze pollution.

Palm Oil and Patronage Politics

The acute cause of transboundary haze is the burning of carbon-rich Indonesian peatland as a byproduct of agricultural activity. Oil palm farming, specifically the acts of draining and/or clearing of peatland in preparation for planting, is linked to these fires. If oil palm plantations were operated sustainably, the risk of fire would reduce substantially. So why does the issue endure? Three factors combine to form an environment where unsustainable farming practices continue to wreak ecological havoc: demand for palm oil sourced from developing countries, Indonesia’s status as a post-colonial developing economy, and complex patronage networks that protect the operations of oil palm companies in Indonesia. Investors and companies from neighboring Singapore and Malaysia participate in this system, contributing to the haze pollution that affects their home countries.

The oil palm tree produces high-quality oil used in cooking products in developing countries, and food products, cosmetics, soaps, and detergents around the world. Palm oil is favored for its versatility and low production cost.[17] For these reasons, it has worked its way into many of the products that consumers in rich nations use every day. Demand for and global production of palm oil are increasing rapidly.[18] Oil palm grows only in the tropics, and the number oil palm plantations in tropical regions is rising to meet growing global demand.[19] Today, oil palm plantations account for 10% of global cropland. Globally, the average individual consumes 8 kg of palm oil a year. And of this, Malaysia and Indonesia product 85% of the world’s total palm oil—with Indonesia as the world’s leading producer.[20] [21]

The legacy of Dutch colonialism has shaped the Indonesian government’s outlook on industrial agriculture as a poverty-reduction strategy. Christopher Atkinson argues in a 2014 paper that the political instability facing the ruling class of a newly independent Indonesia led to a focus on consensus-building and social harmony. Exercising control over economic activity was the means through which the elite governing class could build consensus and stability. By this model, the Indonesian government and elites draws legitimacy from the “maintenance of acceptable levels of economic growth.”[22] By framing the narrative of industrial oil palm production as one of economic empowerment, the Indonesian state can justify its support for an industry that does damage to local ecosystems and regional air quality. Competition with neighboring Malaysia to be the largest palm oil producer in the world further fuels state interest in its ever-growing oil palm sector.

For Indonesia, palm oil represents an opportunity for economic growth and poverty reduction. Tyson et al argue that the Indonesian state favors—through regulation, subsidies, and land licensing practices—palm oil companies and “seeks legitimization through claims about national economic benefits.” These economic benefits include “absolute poverty reduction, employment and tax revenue.”[23] This narrative of palm oil as an economic growth engine persists both within and outside of Indonesia. The International Monetary Fund recently pushed Malaysia and Indonesia to produce even more palm oil, viewing the industry as a growth mechanism for developing economies.[24] While palm oil production remains a lucrative investment for companies and supplies substantial tax revenue to the Indonesian state, its environmental harms and the persistent underinvestment in affected rural areas undermine the legitimacy of these claims.

Patronage relationships between palm oil corporations from neighboring countries and Indonesian government officials further complicate efforts to enforce sustainable farming practices. Varkkey defines patronage politics as “a special case of dyadic (two-person) ties…in which an individual of higher socio-economic position (patron) uses his/her own influence and resources to provide protection or benefits…for a person of lower status (client) who…reciprocates by offering general support and assistance…to the patron.”[25] In the Indonesian context, individuals with government positions protect companies who engage in (often damaging) farming practices in the hopes of securing high-paying board positions with the company after retiring from government office. Firms often cultivate long-term relationships with patrons and receive help getting licenses to develop peatland, accessing local markets and distribution systems, and navigating local bureaucracy.[26] Using this model of patron-client cooperation, investors from Singapore and Malaysia integrate themselves into local Indonesian systems to profit from Indonesia’s domestic palm oil sector.

Regulating Away the Haze

Since the first major haze episodes in 1997 and 1998, local media coverage in Indonesia, Malaysia, and Singapore has reflected the public’s desire for solutions to the problem. Despite the limited ability of the press in some affected nations to criticize their governments or government-affiliated entities, calls for government action on the issue reflect the understanding that policy should play a role in ending the haze crisis.[27] So far, though, domestic regulations and international agreements have brought about little improvement.

Indonesian regulations surrounding peatland use and land-clearing practices should, in theory, lead to “sustainable management of peatlands and low risk of fires.”[28] For example, Indonesian law prohibits the conversion of peatland into plantations. Yet, more than a quarter of all Indonesian oil palm plantations are on reclaimed peatland—land that has been drained and stripped of weeds before planting. [29] This is because companies use patronage relationships with Indonesian officials to continue to develop and farm on protected peatlands. Patrons aid their corporate clients in obtaining licenses to operate plantations on peatland. Decentralization of the Indonesian bureaucracy also leaves regional officials willing to help companies skirt regulations to benefit from investments on a local level.[30] Indonesian law also bans land-clearing by fire.[31] Still, satellite imagery and field research support the conclusion that this practice continues to take among large plantation groups. A lack of enforcement and the low cost of potential fines relative to the savings from this land-clearing method both contribute to its persistence.

International agreements have been similarly ineffective at mitigating the transboundary haze problem. The ASEAN Agreement on Transboundary Haze Pollution (2002)[32] was a major attempt at cooperatively addressing the issue. However, the regular recurrence of haze episodes since its signing show it has not had the intended effect. This is due in part to ASEAN’s non-interference principle and the non-cooperation of the Indonesian government, which did not ratify the agreement until 2014—a full 12 years after its introduction. Under the non-interference principle, ASEAN nations should not meddle in the domestic affairs of other nations. As such, the framing of the ASEAN agreement lacks a mechanism of enforcement to ensure countries including Indonesia uphold its terms.[33] Without an enforcement mechanism, it is difficult to imagine the agreement driving Indonesia to reduce the profitability of its palm oil sector.  

In 2014, Singapore passed the Transboundary Haze Pollution Act (THCP) which penalizes companies who contributes to the haze in Singapore, even if their activities take place outside Singaporean territory.[34] While the THCP expressly allows for the prosecution of extra-territorial activities (including those of non-Singaporean companies), investigating and prosecuting actions beyond Singapore’s borders remains complicated.[35] More than seven years later, the Act has still not been used to prosecute any actors for contributing to the haze. The THCP’s example illustrates the challenges of regulating this kind of transboundary issue.

Conclusion

Transboundary haze pollution from forest and peat fires in Indonesia continues to affect Indonesia, Malaysia, and Singapore on an almost yearly basis. Episodes of transboundary haze are linked to negative health and economic outcomes, including respiratory issues and lost productivity. Peat fires in particular produce the thick and sooty smoke that travels long distances to blanket the region in haze. Unsustainable farming practices on protected Indonesian peatlands by domestic, Malaysian, and Singaporean palm oil companies create the conditions for these fires. The global demand for cheap palm oil from developing countries like Indonesia provides an incentive for actors including companies, the Indonesian state, and local officials to participate in the production of this profitable commodity. Furthermore, a system of patronage politics between companies and government actors allows palm oil companies to skirt regulations and obtain licenses to farm on protected peatlands. Attempts at regional cooperation also failed to mitigate the haze pollution due to a lack of enforcement mechanisms and the complex nature of regulating a transboundary issue.

Ultimately, the transboundary haze crisis is one of collective action: individual stakeholders are incentivized by politics or material gain to participate in the system of land use leads to fires and thus to haze episodes, despite the negative consequences for their home countries. Any solution with a chance of success must address the incentives that drive these behaviors by either increasing the expected cost of violating regulations or reducing the cost of choosing more sustainable farming practices. Until then, it remains doubtful whether media attention and environmental agreements will help to clear the skies over island Southeast Asia.


Works Cited

Agarwal, S., Foo Sing, T., & Yang, Y. (2020). The impact of transboundary haze pollution on household utilities consumption. Energy Economics, 85, 104591. https://doi.org/https://doi.org/10.1016/j.eneco.2019.104591

ASEAN Agreement on Transboundary Haze Pollution. (2002). In.

Atkinson, C. L. (2014). Deforestation and Transboundary Haze in Indonesia. Environment and urbanization Asia, 5(2), 253-267. https://doi.org/10.1177/0975425315577905

Cheong, K. H., Ngiam, N. J., Morgan, G. G., Pek, P. P., Tan, B. Y.-Q., Lai, J. W., Koh, J. M., Ong, M. E. H., & Ho, A. F. W. (2019). Acute Health Impacts of the Southeast Asian Transboundary Haze Problem-A Review. International journal of environmental research and public health, 16(18), 3286. https://doi.org/10.3390/ijerph16183286

Forsyth, T. (2014). Public concerns about transboundary haze: A comparison of Indonesia, Singapore, and Malaysia. Global environmental change, 25(1), 76-86. https://doi.org/10.1016/j.gloenvcha.2014.01.013

Lee, J. S. H., Jaafar, Z., Tan, A. K. J., & Carrasco, L. R. (2016). Toward clearer skies: Challenges in regulating transboundary haze in Southeast Asia. Environmental science & policy, 55, 87-95. https://doi.org/10.1016/j.envsci.2015.09.008

Mohan, M. (2017). A Domestic Solution for Transboundary Harm: Singapore’s Haze Pollution Law. Business and Human Rights Journal, 2(2), 325-333. https://doi.org/10.1017/bhj.2017.10

Muhammad, F. (2021). Environmental agreement under the non-interference principle: the case of ASEAN agreement on transboundary haze pollution. International environmental agreements : politics, law and economics. https://doi.org/10.1007/s10784-021-09545-4

Othman, J., Sahani, M., Mahmud, M., & Sheikh Ahmad, M. K. (2014). Transboundary smoke haze pollution in Malaysia: Inpatient health impacts and economic valuation. Environmental Pollution, 189, 194-201. https://doi.org/https://doi.org/10.1016/j.envpol.2014.03.010

Palm Oil. (2021).  World Wildlife Foundation. Retrieved 12 December from https://www.worldwildlife.org/industries/palm-oil

Quah, E., Chia, W.-M., & Tan, T.-S. (2021). Economic impact of 2015 transboundary haze on Singapore. Journal of Asian Economics, 75, 101329. https://doi.org/https://doi.org/10.1016/j.asieco.2021.101329

Tan, S. T., Hashim, H., Abdul Rashid, A. H., Lim, J. S., Ho, W. S., & Jaafar, A. B. (2018). Economic and spatial planning for sustainable oil palm biomass resources to mitigate transboundary haze issue. Energy, 146, 169-178. https://doi.org/https://doi.org/10.1016/j.energy.2017.07.080

Transboundary Haze Pollution Act, (2014). https://sso.agc.gov.sg/Act/THPA2014#al-

Tullis, P. (2019, 19 February). How the World Got Hooked on Palm Oil. The Guardian. https://www.theguardian.com/news/2019/feb/19/palm-oil-ingredient-biscuits-shampoo-environmental

Tyson, A., Varkkey, H., Banna Choiruzzad, S. A., Associate Professor of Southeast Asian Politics in the School of, P., & International Studies, U. o. L. (2018). Deconstructing the Palm Oil Industry Narrative in Indonesia: Evidence from Riau Province. Contemporary Southeast Asia, 40(3), 422-448. https://doi.org/10.1355/cs40-3d

Varkkey, H. (2012). Patronage politics as a driver of economic regionalisation: The Indonesian oil palm sector and transboundary haze. Asia Pacific Viewpoint, 53, 314-329. https://doi.org/10.1111/j.1467-8373.2012.01493.x/abstract

Varkkey, H. (2013). Oil Palm Plantations and Transboundary Haze: Patronage Networks and Land Licensing in Indonesia’s Peatlands. Wetlands, 33(4), 679-690. https://doi.org/10.1007/s13157-013-0423-z

Varkkey, H. (2016). Recent Asean Developments On Peat Fires And Haze: National Responses. Malaysian Journal of International Relations, 4(1), 163-173. https://doi.org/10.22452/mjir.vol4no1.8

Varkkey, H. (2018, 8 November). ‘Transboundary Haze’: The Seasonal Pollution Plaguing Southeast Asia. The New Lens. https://international.thenewslens.com/article/107781

Varkkey, H., Tyson, A., & Choiruzzad, S. A. B. Palm oil intensification and expansion in Indonesia and Malaysia: Environmental and socio-political factors influencing policy. Forest policy and economics, 92, 148-159. https://doi.org/10.1016/j.forpol.2018.05.002


[1] Varkkey, H. (2018, 8 November). ‘Transboundary Haze’: The Seasonal Pollution Plaguing Southeast Asia. The New Lens. https://international.thenewslens.com/article/107781

[2] Varkkey, H. (2016). Recent Asean Developments On Peat Fires And Haze: National Responses. Malaysian Journal of International Relations, 4(1), 163-173. https://doi.org/10.22452/mjir.vol4no1.8

[3] While other Southeast Asian countries have been affected by transboundary haze, the most affected nations are Indonesia, Malaysia and Singapore.

[4] Forsyth, T. (2014). Public concerns about transboundary haze: A comparison of Indonesia, Singapore, and Malaysia. Global environmental change, 25(1), 76-86. https://doi.org/10.1016/j.gloenvcha.2014.01.013

[5] Cheong, K. H., Ngiam, N. J., Morgan, G. G., Pek, P. P., Tan, B. Y.-Q., Lai, J. W., Koh, J. M., Ong, M. E. H., & Ho, A. F. W. (2019). Acute Health Impacts of the Southeast Asian Transboundary Haze Problem-A Review. International journal of environmental research and public health, 16(18), 3286. https://doi.org/10.3390/ijerph16183286

[6] Othman, J., Sahani, M., Mahmud, M., & Sheikh Ahmad, M. K. (2014). Transboundary smoke haze pollution in Malaysia: Inpatient health impacts and economic valuation. Environmental Pollution, 189, 194-201. https://doi.org/https://doi.org/10.1016/j.envpol.2014.03.010

[7] Quah, E., Chia, W.-M., & Tan, T.-S. (2021). Economic impact of 2015 transboundary haze on Singapore. Journal of Asian Economics, 75, 101329. https://doi.org/https://doi.org/10.1016/j.asieco.2021.101329

[8] Agarwal, S., Foo Sing, T., & Yang, Y. (2020). The impact of transboundary haze pollution on household utilities consumption. Energy Economics, 85, 104591. https://doi.org/https://doi.org/10.1016/j.eneco.2019.104591

[9] Varkkey, H. (2018, 8 November). ‘Transboundary Haze’: The Seasonal Pollution Plaguing Southeast Asia. The New Lens. https://international.thenewslens.com/article/107781

[10] Quah, E., Chia, W.-M., & Tan, T.-S. (2021). Economic impact of 2015 transboundary haze on Singapore. Journal of Asian Economics, 75, 101329. https://doi.org/https://doi.org/10.1016/j.asieco.2021.101329

[11] Varkkey, H. (2013). Oil Palm Plantations and Transboundary Haze: Patronage Networks and Land Licensing in Indonesia’s Peatlands. Wetlands, 33(4), 679-690. https://doi.org/10.1007/s13157-013-0423-z

[12] Atkinson, C. L. (2014). Deforestation and Transboundary Haze in Indonesia. Environment and urbanization Asia, 5(2), 253-267. https://doi.org/10.1177/0975425315577905

[14] Varkkey, H. (2018, 8 November). ‘Transboundary Haze’: The Seasonal Pollution Plaguing Southeast Asia. The New Lens. https://international.thenewslens.com/article/107781

[15] Ibid.

[16] Varkkey, H. (2013). Oil Palm Plantations and Transboundary Haze: Patronage Networks and Land Licensing in Indonesia’s Peatlands. Wetlands, 33(4), 679-690. https://doi.org/10.1007/s13157-013-0423-z

[17] Tullis, P. (2019, 19 February). How the World Got Hooked on Palm Oil. The Guardian. https://www.theguardian.com/news/2019/feb/19/palm-oil-ingredient-biscuit…

[18] Palm Oil. (2021).  World Wildlife Foundation. Retrieved 12 December from https://www.worldwildlife.org/industries/palm-oil

[19] Tan, S. T., Hashim, H., Abdul Rashid, A. H., Lim, J. S., Ho, W. S., & Jaafar, A. B. (2018). Economic and spatial planning for sustainable oil palm biomass resources to mitigate transboundary haze issue. Energy, 146, 169-178. https://doi.org/https://doi.org/10.1016/j.energy.2017.07.080

[20] Tullis, P. (2019, 19 February). How the World Got Hooked on Palm Oil. The Guardian. https://www.theguardian.com/news/2019/feb/19/palm-oil-ingredient-biscuit…

[21] Tyson, A., Varkkey, H., Banna Choiruzzad, S. A., Associate Professor of Southeast Asian Politics in the School of, P., & International Studies, U. o. L. (2018). Deconstructing the Palm Oil Industry Narrative in Indonesia: Evidence from Riau Province. Contemporary Southeast Asia, 40(3), 422-448. https://doi.org/10.1355/cs40-3d

[22] Atkinson, C. L. (2014). Deforestation and Transboundary Haze in Indonesia. Environment and urbanization Asia, 5(2), 253-267. https://doi.org/10.1177/0975425315577905

[23] Tyson, A., Varkkey, H., Banna Choiruzzad, S. A., Associate Professor of Southeast Asian Politics in the School of, P., & International Studies, U. o. L. (2018). Deconstructing the Palm Oil Industry Narrative in Indonesia: Evidence from Riau Province. Contemporary Southeast Asia, 40(3), 422-448. https://doi.org/10.1355/cs40-3d   

[24] Tullis, P. (2019, 19 February). How the World Got Hooked on Palm Oil. The Guardian. https://www.theguardian.com/news/2019/feb/19/palm-oil-ingredient-biscuit…

[25] Varkkey, H. (2012). Patronage politics as a driver of economic regionalisation: The Indonesian oil palm sector and transboundary haze. Asia Pacific Viewpoint, 53, 314-329. https://doi.org/10.1111/j.1467-8373.2012.01493.x/abstract

[26] Ibid.

[27] Forsyth, T. (2014). Public concerns about transboundary haze: A comparison of Indonesia, Singapore, and Malaysia. Global environmental change, 25(1), 76-86. https://doi.org/10.1016/j.gloenvcha.2014.01.013

[28] Varkkey, H. (2013). Oil Palm Plantations and Transboundary Haze: Patronage Networks and Land Licensing in Indonesia’s Peatlands. Wetlands, 33(4), 679-690. https://doi.org/10.1007/s13157-013-0423-z

[29] Ibid.

[30] Varkkey, H., Tyson, A., & Choiruzzad, S. A. B. Palm oil intensification and expansion in Indonesia and Malaysia: Environmental and socio-political factors influencing policy. Forest policy and economics, 92, 148-159. https://doi.org/10.1016/j.forpol.2018.05.002

[31] Lee, J. S. H., Jaafar, Z., Tan, A. K. J., & Carrasco, L. R. (2016). Toward clearer skies: Challenges in regulating transboundary haze in Southeast Asia. Environmental science & policy, 55, 87-95. https://doi.org/10.1016/j.envsci.2015.09.008

[32] ASEAN Agreement on Transboundary Haze Pollution. (2002). In.

[33] Muhammad, F. (2021). Environmental agreement under the non-interference principle: the case of ASEAN agreement on transboundary haze pollution. International environmental agreements : politics, law and economics. https://doi.org/10.1007/s10784-021-09545-4

[34] Transboundary Haze Pollution Act, (2014). https://sso.agc.gov.sg/Act/THPA2014#al-

[35] Mohan, M. (2017). A Domestic Solution for Transboundary Harm: Singapore’s Haze Pollution Law. Business and Human Rights Journal, 2(2), 325-333. https://doi.org/10.1017/bhj.2017.10

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