Report on the Equivalence and Acceptability Assessments ... · PDF fileENVIRONMENTAL...

November 2017

Report on the Equivalence and Acceptability Assessments for the State Electricity Company of Indonesia (PLN) : Consultation Draft Appendix 2: Environmental Safeguards Acceptability Matrix

DRAFT FOR DISCUSSION ONLY

This assessment is a work in progress, the purpose of which is to encourage an iterative process of feedback and update. When finalized, the Borrower will verify the assessment. The materials are prepared by consultants; hence, ADB does not guarantee the accuracy, reliability, or timeliness of these materials and therefore will not be liable in any capacity for any damages or losses that may result from the use of these materials. ADB, likewise, shall not be responsible for any errors, inadvertent omissions, or unauthorized alterations that may occur in the disclosure of content on this website.

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ABBREVIATIONS

ADB – (Asian Development Bank) AMDAL – (Environmental impact assessment/EIA) ANDAL – (Environmental analysis report) BLH – (District Environmental Management, which later become Dinas Lingkungan) CSR – (Corporate Social Responsibility) CTG – Comprehensive Technical Guidance DEM – (Deputy for Environmental Management) DEP – (Deputy for Environmental Planning) EIA – (Environmental Impact Assessment) EMP – (Environmental Management Plan) ESIA – (Environmental and Social Impacts Assessment) GR – (Government Regulation) GRM – (Grievance Redress Mechanism) HKP – (Law, Communication and Land Acquisition) HSSE – (Health, Safety, Security, and Environment) IEC – (International Engineering Commission) IEE – (Initial Environmental Examination) IPB – (Bogor Agricultural University) ISO – (International Standard Organization) ITS – (Sepuluh November University) IUCN – (International Union for Conservation of Nature) JBB – (Western Java Region) JBT – (Central Java Region) JBTB – (Eastern Java and Bali Region) K2 – (Electrical Safety) K3 – (Occupational Health and Safety) K3L – (Occupational Health, Safety and Environment) KLHK – (Ministry of Environment and Forestry, MOEF) KMP – Knowledge Management Plan KORIGI – (Consortium of Indonesia Geo-polymer Research) LARAP – (Land Acquisition and Resettlement Action Plan) LARAP – (Land Acquisition and Resettlements Action Plan) LIPI – (Indonesian Sciences Institute) MOEF – (Ministry of Environment and Forestry) MOU – (Memorandum of Understanding) NGO – (Non-government organizations) OD – (Organizational Development) PCB – (polychlorinated biphenyl) PIBIB – (map of new permit moratorium) PKK – (family welfare organization) PLN – (State Owned National Electricity Company) PLTA – (hydroelectric power plant) PLTD – (Diesel Power Plant) PLTG – (Gas Power Plant) PLTP – (Geothermal Power Plant) PLTU – (Coal Fired Power Plant) POE – (Pool of Experts) PP – (Government Regulation)

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PROPER – (Environmental Performance Rating Program) PUPR – (Ministry of Public Work and Housing) RKL-RPL – (Environmental Management & Monitoring Plan, complementary of AMDAL

report) ROW – (Right of way) RTRW – (Regional Spatial Plan) SKKLH – (Decree on Environmental Feasibility) SML – (Environment Management System) SNI – (Indonesia National Standard) SOP – (Standard Operating Procedure) SPPL – (Commitment Letter for Environmental Management and Monitoring) SPS – (Safeguard Policy Statement) SPT – (suggestion, opinion, and response) STT – (Engineering University) SUTM – (medium voltage air transmission) TOR – (Terms of Reference) UGM – (Gajah Mada University) UI – (Indonesia University) UIP – (Main Development Unit for Power Generation and Transmission) UPP – (Project Implementation Unit) USD – (US Dollar) WB – (World Bank)

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APPENDIX 2

ENVIRONMENTAL SAFEGUARDS ACCEPTABILITY MATRIX Table 4. Parameters and Rating of Environmental Acceptability Assessment

No. Component/

Subcomponent W/M/S1 Qualitative Parameters

Assessment Results

A. Institutional Capacity A.1 Institutional

structure The institutional structure and human resources of

the implementing institution support its legal mandates and corporate commitment commitment to environmental protection and occupational health and safety at both central and operational unit (UIP)2 levels.

The institutional structure of the PLN (Perusahaan Listrik Negara/State Electricity Corporation) of Indonesia has a number of tiers of responsibility for environmental safeguards. Environment Sub-Division of K3L Division The Health, Safety, Security and Environment (K3L)3 Division at PLN Headquarters (HQ), has one sub-division, the Environment Sub-Division, which is responsible for environmental safeguards at both the planning and implementation stages at corporate level. As one of the corporate functions, the sub-division is divided into two main groups, and managed by a Deputy for Environmental Planning (DEP) and a Deputy for Environmental Management (DEM); The DEP is responsible for assisting UIPs/UPPs and the regional/Wilayah power generating unit in in preparing AMDAL/UKL-UPL during the project planning phase, while the DEM is responsible for supervising and monitoring PLN project operations. The Environment Sub-Division also supports UIP and UPP Environmental Engineers in implementing environmental safeguards. The responsibilities of the Environment Sub-Division that are related to environmental safeguards include: a) Prepare and evaluate policy, strategy, standards

and procedures on environmental management and implement corporate environmental policy;

M Adequate institutional structure or personnel exist to support its legal mandates and corporate.

Neither the institutional structure nor adequate personnel are assigned to support its legal mandates and corporate commitment.

1 Ratings are ‘W’ for weak, ‘M’ for moderate, and ‘S’ for strong. 2 UIPs (Unit Induk Pembangkit/Project Construction Units) are responsible for construction of electric generating projects and have special units responsible for

environmental safeguards. 3 K3 stands for Keselamatan dan Kesehatan Kerja/occupational health and safety.

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No. Component/ Subcomponent

W/M/S1 Qualitative Parameters

Assessment Results

b) Prepare and evaluate environmental assessments for new projects under responsibility of PLN HQ4 and assist regional units in preparing environmental assessments;

c) Prepare and implement and evaluate PLN’s corporate program in environmental management and establish cooperation with stakeholders;

d) Conduct integration and validation of environmental management reports and coordinate permits administration for forest areas.

K3L will improve reporting channel to upper management of PLN. The Senior Manager of the Environment Sub-Division reports to the Head of the K3L Division, who reports to the Director of Human Capital Management, who reports to the PLN President. In order to strengthen the authority of K3L, PLN is conducting internal assessment to promote K3L as more powerful unit. UIP/Project Construction Unit UIPs are responsible for construction of power generation infrastructure, including geothermal, and transmission infrastructure.5 There are 18 UIPs at regional level in the country6. Environmental Engineers/Assistant Environmental Engineers (see sub-component A3) are posted in two units in each UIP: the General Planning Unit of the Planning Sub-division and the Project Control Unit of the Construction Sub-division. In UIPs, the environment staff are Environmental Engineers or Assistant Environmental Engineers. The Environmental Engineer/Assistant EnvironmentalEngineer in the Planning Unit is responsible to ensure environmental planning,

4 AMDAL or EIA for development partners funded projects 5 PLN does not construct all power generation plants in Indonesia. Some are built by independent power producers that sell the electricity to PLN. 6 There are 4 UIPs in Sumatera, 5 UIPs in Java, 3 UIPs in Kalimantan, 2 UIPs in Sulawesi, 1 UIP in Nusa Tenggara, 1 UIP in Maluku, 1 UIP in Papua, and 1 UIP

ISJ.

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Assessment Results

specifically prepare, implement and evaluate activities of environmental impact assessment and environmental management during planning phase. The Environmental Engineers/Assistant Environmental Engineering the Construction Unit is responsible for supervising and monitoring environmental program during construction phase. Environmental Engineers/Assistant Environmental Engineers in the UIP Planning and Construction Sub-divisions report to the Deputy Managers of their respective units. The Environmental Engineers/Assistant Environmental Engineers formally coordinate their work. The Environmental Engineers/Assistant Environmental Engineer in the General Planning Unit hands over responsibility for implementing the RKL-RPL to the Environmental Engineers/Assistant Environmental Engineer in the Project Control Unit. The procedure is the same for activities that require UKL-UPL All documents related to environmental safeguards must be submitted through the Deputy Managers of the respective units to the respective Sub-Division Managers who report to the UIP General Manager. UIP General Managers have primary authority for environmental safeguards at the regional level. They report to their respective Regional Directors and, in parallel, coordinate with the Director of the K3L Division on all issues related to environmental safeguards. UPP/Project Implementing Unit Under each UIP, there are 2–3 UPPs; it varies regionally. In UPPs, there is one Assistant Environmental Engineer or Junior EnvironmentalEngineer posted in the Engineering Sub-section. The Assistant Environmental Engineer or Junior Environmental Engineer is responsible for supporting and implementing survey activities for project planning related to the implementation of environmental impact assessment and environmental management. In

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Assessment Results

addition, the environmental staff is responsible for supervisign and monitoring environment parameters during project implementation. UPP Assistant Environmental Engineers/Junior EnvironmentalEngineers report to the Assistant Manager for Engineering (ASMAN Teknik) who reports to the UPP Manager, who reports to the UIP General Manager. Environmental Engineers in UIPs and UPPs do not report directly to UIP General Managers and their counterparts in Wilayahs do not report directly to the Distribution Managers. PLN Wilayahs/Regional offices There are 15 Wilayahs in the country.7 There is Supervisor for Safety, Occupational Health and Environment in each Wilayah, reporting to the Deputy Manager for Operational Control of the Distribution System. Due to PLN’s decentralized structure, the Environment Sub-division of K3L has only indirect authority to manage/control the use of environmental safeguards in UIPs, UPPs and Wilayahs

A.2 Budget Adequate budget allocated specifically to support mandates of the institution and SML commitment

PLN has allocated funds for environmental management and monitoring activities for K3L, UIPs and UPPs and Wilayahs. PLN Headquarters maintains the corporate master budget, which includes the budgets for all UIPs/UPPs and Wilayahs. PLN’s overall budget for the 2016/2017 fiscal year is IDR120 trillion or approximately USD9,094,353,922. For the 2016/2017 fiscal year, the total budget8 for all

M Budget has been allocated but is insufficient or shared with other competing subsectors

No budget allocated to support its mandates and SML commitment, directly or indirectly

7 There are six PLN Wilayahs in Sumatera, three in Kalimantan, two in Sulawesi, two on Nusa Tenggara, one in Maluku, and one in Papua. In addition, for customer

services, there are seven PLN Distribusi located in West Java, Jakarta Raya and Tangerang, Banten, Central Java and DI Yogyakarta, East Java, Bali, and Lampung. While for generators (pembangkit), there are 3 PLN Pembangkit in Sumatera and Tanjung Jati. There are also 2 PLN P3B Sumatera and P2B Jawa Bali responsible for operating the substation and for transmission, and 3 PLN Transmission units (Western Java, Central Java, and Eastern Java and Bali).

8 PLN’s Sustainability Report (2016).

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Assessment Results

environment-related work in PLN – which encompasses preparation of AMDAL and UKL-UPL, management and environmental monitoring, research in the field of the environment, and reforestation activities for the surrounding area of power generation plants and other supporting areas – is USD 10,244,0319, or 0.1% of the total budget Depending on the scope of study and remoteness of each proposed project, typically the cost estimate for AMDAL is in the range of IDR 500 million to IDR 1,000 million. The cost estimate for UKL-UPL is in the range of IDR 300–600 million. The cost for monitoring RKL-RPL/UKL-UPL is budgeted for the 2016/2017 fiscal year at IDR 700 million.10 Budget for K3L Environment Sub-Division PLN annually allocates the budget for K3L, excluding staff salaries and the cost of preparing AMDAL and UKL-UPL. For fiscal year 2017, the K3L budget is USD 5,060,738, allocated as follows11:

• Safety and occupational health (USD 1,370,246) or ± 27%

• Security (USD 2,860,932) or ± 57%

• Environment (USD 369,079) or ± 16%. This budget covers supervision, monitoring and capacity building of the staff as well.

The environment budget is allocated as follows:

• Capacity Building in Environmental Management and Implementation of Regulations (Workshop and Socialization); USD 56,840

• Review of environmental management with competent agencies /consultants; USD 90,943

• Develop networking with external parties in environmental management; USD 22,736

9 Exchange rate at September 12, 2017 (1 USD = 13,195) 10 Appendix of Investment Budget (SKAI) 2017; No. 01/UJT2/2017 11 Budget Recapitulation of K3L Division (2017).

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Assessment Results

• Expose on environmental management program; USD 37,893

• Preparation of visual document on environment; USD 11,368

• Development of application for environmental management; USD 56,840

• Improvement of competence for planning’s human resource with MOEF/KLHK-accredited training centers; USD 9,094

• Review on Board of Directors’ decrees on environmental management with competent parties/consultants; USD 7,579

• Fulfillment of donor’s environmental and social safeguard policy requirements; USD 11,368

Budget for UIPs/UPPs Each UIP/UPP prepares a detailed annual work plan with project-specific budgets that include the cost of environmental impact assessment (AMDAL/UKL-UPL) and implementation of the RKL-RPL. During interviews, project staff at the UIP/UPP level indicated that project budgets for environmental safeguards are sufficient but breakdowns of project budgets were not available for review. Budget for Wilayahs: Each Wilayah prepares an annual budget. Information on Wilayah budgets was not available.

A.3 Staffing Both qualitatively and quantitatively a technically competent management staff is in place to support the SML workload requirements

At PLN headquarters, the Environment Sub-Division of the K3L Division employs a total of 8 staff, three (37.5%) of whom are Environmental Engineers – one in the Environmental Planning Unit and two in the Environmental Management Unit. Two of the Environmental Engineers have graduate degrees in environmental engineering; the other Environmental Engineer has a graduate degree in another field. In 2017, all three of these positions are filed with full-time staff. The administrative staff hold graduate degrees in different fields. K3L indicated during interviews that it has

M The number of technically competent management staff is insufficient to support the SML workload

No/few technically competent management staff are in place to implement the SML responsibilities

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Assessment Results

plans, for the near future, to hire additional graduate and post-graduate personnel with qualifications in environmental fields. Each UIP has one Environmental Engineer/Assistant Environmental Engineer in the General Planning Unit of the Planning Sub-division and one in the Project Control Unit of the Construction Sub-division. Each UPP employs one Assistant Environmental Engineer/Junior EnvironmentalEngineer. Each Wilayah employs one Supervisor who is responsible for safety and occupational health, as well as environmental issues. All of these environmental-related positions are filled by full-time staff.. The UIPs for each of the projects visited had full-time staff in both Environmental Engineer/Assistant Environmental Engineer positions and the UPPs had full-time staff in the Assistant Environmental Engineer/Junior Environmental Engineer positions. This assessment did not visit and verify staffing in all UIPs/UPP. The UIP for East Java and Bali I has three UPPs. The UIP has 108 full-time staff. One UPP has 30 staff, another has 21, and the third has 18. All UIP and UPP staff are full time. The two Environmental Engineers/Assistant Environmental Engineers in the UIP constitute 2% of the UIP’s total staff. Each UPP has one Assistant Environmental Engineer/Junior Environmental Engineer, which means that an Environmental Engineer accounts for 3%, 5%, and 5.5%, respectively, of UPP staff. A similar breakdown for all UIPs/UPPs in the PLN system was not available.

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Assessment Results

Level Number Role Qualification

HQ (K3L)

3 (of 1 K3L) Environmental Engineer positions

S1 (graduate)12

UIP 36 (of 18 UIPs)

Environmental Engineer /Assistant Environmental Engineer positions

S1 (graduate)

UPP 65 (of 18 UPPs)

Assistant Environmental Engineer/ Junior Environmental Engineer positions

S1 (graduate)

PLN Wilayah/ Region

182 (of 15 PLN Wilayahs)13

Safety, Occupational Health and Environment Supervisor positions

S1 (graduate)

Total 286

All environmental staff in K3L and in UIPs/UPPs and Wilayahs are required to meet qualifications, including for environmental safeguards, as specified in the “Competence Directory”14 issued by PLN Headquarters. PLN’s Competence Directory specifies that all grades of Environmental Engineers/Assistant Environmental Engineer/Junior Environmental Engineer are responsible for environmental safeguards. The Competence Directory also specifies that all grades of Environmental Engineers/ Assistant Environmental Engineers/Junior

12 S1 (Graduate) is a university degree awarded after at least four years of study. 13 Combined number of K3 (occupational health and safety), K2 (electrical safety) and Environment 14 A guidance book describing all staff positions and the generic and technical skills and knowledge required for each post.

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Assessment Results

Environmental Engineers must have at least the following qualifications:

• Environmental management and monitoring (meaning environmental safeguards); and

• Environmental audit.

The Competence Directory does not specify the qualifications required for Safety, Occupational Health and Environment Supervisors at Wilayah level. In 2017, with the exception of two Environmental Engineers in K3L, all Environmental Engineers in PLN are either civil engineers or chemical engineers. For basic training on AMDAL (AMDAL A) and review of AMDAL documents (AMDAL C), PLN sends Environmental Engineers to private or public universities. PLN’s Corporate University trains them on preparation of AMDAL documents (AMDAL B) and on preparing UKL-UPL.

PLN staff who are responsible for environmental safeguards have educational backgrounds in a range of different fields rather than specialized education. According to interviews with staff at the UIP/UPP level, the number of Environmental Engineers on staff is not sufficient to handle the project workload, particularly under the recent 35000 MW electrification acceleration program.

During interviews, UIP staff indicated that UIP/UPP staff have sufficient technical expertise for conducting AMDAL, but at current staffing levels UIP/UPP staff do not have sufficient capacity to also evaluate consultants’ reports. When UIP/UPP staff do not have the human or financial resources to review consultants’ reports, K3L staff may support them, if the UIP/UPP requests assistance.

A.4 Institutional knowledge

Significant efforts are made for KM for and maintaining continuity of qualified/trained staff

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Assessment Results

management (KM)

M Limited efforts for KM and maintaining continuity of qualified/trained staff

There is significant effort for knowledge management in PLN, but no specific knowledge management plan or system for environmental safeguards. A dedicated unit for knowledge management structurally established under Director of Human Capital, the Knowledge Management Unit is responsible for ensuring strategic policy, knowledge management program, and competence development with main duties:

a. Prepare, implement and evaluate strategic policy and regulation on knowledge management, knowledge transfer, and knowledge management audit

b. Prepare, implement and evaluate assessment and testing for new innovation at unit and recommend as best practices for other units

c. Control, implement and evaluate dissemination process of knowledge management and application of new innovations in the operational works at units

d. Prepare, implement and evaluate knowledge management program as effort to improve staff competence, quality and company performance

e. Prepare, implement and evaluate the requirement for personnel’s learning and competence development

For the purposes, PLN has established a Portal Knowledge Management System (KMS) at http://kmpln.pln.co.id represents a media to facilitate and accelerate sharing process of knowledge, expertise, experience and collaboration among staff (knowledge workers). As this is internal use, a username and password required to access the portal. The KMS portal is used to:

• Facilitate Knowledge Sharing by uploading contents at Knowledge Repository.

There is high turnover of staff and no effort to retain institutional KM.

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Assessment Results

• Facilitate staff in acquiring knowledge by downloading from Knowledge Repository or from Wiki, which might be enriched by all staff, so it can be a kind of dictionary for existing knowledge in the KMS portal.

• Facilitate for searching of staff can be asked for experience sharing, asked for discussion on a knowledge or collaboration. Staff can publish information on their interest, knowledge, experience and responsibility in the company in page of Mysite.

• Facilitate delivery of opinion and thinking through Mysite Blog

• Establish network and discuss on a topic through Online Community of Practice (CoP)

Knowledge management (KM) is a corporate policy, applied nation-wide to all PLN units, but focuses primarily on engineering and technical matters. 15 For example, at the UIP/UPP level, every month, staff from UPPs are invited to UIP to discuss specific topics related to on-going projects. This knowledge sharing is also provided through teleconference and web-based media, where UPP staff can interact with central level mentors.

A.5 Access to independent technical expertise

Full access to independent technical expertise as necessary to supplement its own technical expertise

PLN has a limited professional staff capacity with technical expertise in environmental safeguards. Therefore, in practice, almost all projects use external experts or consultants to assist them with environmental safeguards.

All of the six projects assessed used external accredited consultants, either from private firms or local universities. PLN recruits consultants through its Engineering Procurement Planning Unit. Most consultants hired are Indonesian nationals: individuals, university-based

M Limited access to independent technical expertise as necessary to supplement its own technical expertise

No access to independent technical expertise as necessary to supplement its own technical expertise

15 AMDAL of High Voltage Air Transmission 70 kV Nonohonis – Kefamenanu

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Assessment Results

consultants, private consulting firms, and State-owned consulting firms. International consultants are rarely recruited, primarily because of the constraints of Indonesia’s AMDAL certification requirements. International consultants are recruited to prepare EIA and ESIA for loan projects. PLN does not maintain a pool of experts and recruits consultants on an ad hoc basis, as necessary.

K3L’s Environmental Engineers are responsible for preparing all Terms of Reference (ToR) for national and international consultants for all projects, donor-funded and PLN-funded, and for reviewing AMDAL for loan projects. UIP’s Environmental Engineer/Assistant Environmental Engineers are responsible for reviewing AMDAL for PLN-funded projects.

PLN establishes Memoranda of Understanding (MOU) with public and private universities and independent research centers to provide external expertise in many areas related to the technical aspects of environmental safeguards. PLN has entered into MOUs for external technical expertise on issues including waste management, EIA, environmental monitoring, and permit management. Detailed information on individual MOUs was not available.

A.6 Legal counsel

Full access to internal and external legal counsel regarding its critical mandates

Within PLN HQ, there is a Division of Corporate Law with the responsibility of assuring compliance with internal and government regulations. This unit also supports compliance with regulations and corporate business codes related to environmental safeguards and and compliance with good corporate governance principles. The unit has been involved in settling disputes related to pollution issues. None of the six projects assessed in the field had had any direct involvement with the Division of Corporate Law on issues related to environmental safeguards and subsequent permitting processes. The Law,

M Limited access to legal counsel regarding its critical mandates

No access to legal counsel regarding its critical mandates

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Assessment Results

Communication and Land unit in the UIP was involved in settling disputes involving pollution issues in one of the projects assessed.

A.7 Supporting equipment and facility

Adequate equipment and/or facilities to support its mandates and SML commitment

PLN lacks environmental laboratory or other environmental monitoring equipment or facilities particularly on emission and noise. Instead, PLN cooperates with local universities and government-accredited laboratories to implement the duties for testing and measurement of air, water and noise whenever it requires. However, especially for power plants some instruments such as noise and emission measurement and monitoring devices installed to control the process. For example, PJB (Java-Bali Power Generation) run continuous air quality and noise monitoring in the power house. Similarly, as indicated in the case/desk study, measurement for electromagnetic force (emf) also carried out by PLN Based on six case studies, preparation of AMDAL or UKL-UPL for PLN projects uses external resources, i.e., national laboratories accredited under the Indonesian National Standard (SNI) (SNI/ISO/IEC 17025:2008; ISO/IEC 17025:2005) on General Requirements for the Competence of Testing and Calibration Laboratories. The services cover sampling of baseline information for physical, chemical and biological parameters during preparation of AMDAL or UKL-UPL and periodical laboratory measurement of physical, chemical and biological parameters for environmental management and monitoring report. Frequency of monitoring depends on the specific parameters to be measured, as set forth in the RKL-RPL or UKL-UPL. Especially for coal power plants, which use coal wtiht sulphure contents more than 20%, it is required by regulation to install CEMS (Continous Emission Monitoring System) to ensure that air quality standard met and maintained. Similarly, power plants have laboratory for water quality monitoring.

M Limited or partial equipment and/or facilities to support its mandates and SML commitment

No adequate equipment or facilities to support its mandates and SML commitment

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Assessment Results

A.8 Capacity building program and in-house training/ training center

Effective capacity building program to improve/upgrade their human resources both at in-house training center and outsourcing training

PLN prepares a biannual master plan for capacity building, including for environmental safeguards, at basic, intermediate and advanced levels. Capacity building is conducted both using external training providers and PLN’s in-house training center PLN Corporate University.

PLN’s Corporate University comprises 10 separate Academies at technical and regional levels that provide in-house capacity-building for PLN.16 In addition to technical engineering and administrative matters17, the Health and Safety, Security and Environment (HSSE) Academy, based in Semarang, also covers environmental subjects, among others, including:

• Mentoring on Environmental Protection and Management

• Environmental audit

• Corporate Performance Rating Program in Environmental Management/PROPER

• K2, K3 and Environment

• Environmental Management and Monitoring toward PROPER Based Green Company

• Preparation of Environmental Feasibility of Electricity Projects Environmental Management System ISO 14001: 2015

M Ineffectively implemented capacity building program to improve/upgrade human resources

No/limited capacity building program to improve/ upgrade t human resources

16 PLN UDIKLAT BOGOR) (Project Academy)

PLN UDIKLAT JAKARTA (Leadership Academy & Corporate Culture Academy) PLN UDIKLAT SURALAYA (Primary Energy & Power Generation Academy) PLN UDIKLAT SEMARANG (Transmission & Live Line Maintenance Academy) PLN UDIKLAT PANDAAN (Distribution & Commerce Academy) PLN UDIKLAT TUNTUNGAN PLN UDIKLAT PADANG PLN UDIKLAT PALEMBANG PLN UDIKLAT MAKASSAR PLN UDIKLAT BANJARBARU PLN Unit Assessment Center (Jakarta) PLN Certification Unit (Jakarta)

17The entire 2017 curriculum of all PLN Academies for 2017 can be found, in Bahasa Indonesia, at this link: http://simdiklat.pln-pusdiklat.co.id/tab_es_diklat_tdk_laris.php.

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Assessment Results

• Basic Electricity Safety and Environment

• Advanced Electricity Safety and Environment Capacity building specifically related to environmental safeguards is limited within the PLN system. For external training providers, PLN has established cooperation with several prominent universities to provide training on AMDAL and other environmental management issues, among them Bogor Agricultural University (IPB), Gajah Mada University (UGM), University of Indonesia (UI) and environmental study centers of regional universities. Details of the contents of these cooperation agreements was not available. PLN send their staff regularly to attend three levels of courses on AMDAL/EIA:

• AMDAL A (Basic AMDAL Preparation Course)

• AMDAL B (Advanced AMDAL Preparation Course)

• AMDAL C (AMDAL Review Course) The training is not only intended for Environmental Engineers, but also for general staff, including managers and higher-level executives. In addition, PLN has established cooperation with Indonesia University to provide specific environmental training on:

• Hazardous Substances and Hazardous Waste Management

• Environmental Conflict Management

• RKL-RPL Monitoring, Implementation and Evaluation

Detailed information on the contents of this cooperation agreement was not available. As part of its mandate, the Environment Sub-Division of K3L Division provides capacity building through workshops and socialization on environmental

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Assessment Results

management for staff working at UIP/UPP and Wilayah levels. There are on-going activities with the assistance of WB, ADB and other interested parties to establish a network of safeguards learning centers for Indonesia; PLN Corporate University is included in the first target group.

A.9 Supervision and monitoring

Regular and effective supervision and monitoring for compliance with environmental safeguard requirements and practices

Environmental supervision is carried out based on the RKL-RPL document once a construction project construction has commenced and monitoring is carried and reported on every six months. UIPs are the PLN entities that are responsible for monitoring. A UPP’s Assistant Environmental Engineer/Junior Environmental Engineer supervises each project, which includes ensuring that contractors comply with the RKL-RPL or UKL-UPL as attached to the construction contract. Conditions related to environmental safeguards are stipulated when a tender is issued and obligations related to environmental safeguards are included in all contracts with contractors. Monitoring of the implementation of the RKL-RPL or UKL-UPL involves checking specified inspection parameters, threshold values or quality standards, and any critical issues observed. Sampling and measurement must use calibrated instruments to ensure validity of the measurements. As reflected in sample monitoring reports from six projects assessed in the field, monitoring reports also evaluate (i) trends, (ii) critical parameters, and (iii) compliance. When monitoring results indicate non-compliance, the monitoring report must specify corrective actions, and contractors must implement the corrective measures under the supervision of the UPP Junior Environmental Engineer. Of all projects assessed, six case studies found delays in submission of monitoring reports and minimal quality of monitoring reports.

M Either irregular or ineffective supervision and monitoring for compliance with environmental safeguard requirements and practices

No/limited supervision and monitoring carried out for compliance with environmental safeguard requirements and practices.

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Assessment Results

The UIP must review all monitoring reports prior to submitting them to the respective environmental agency and other related agencies to ensure compliance with laws and regulations and other requirements. There is no obligation for PLN to disclose monitoring reports to the public. Public exposure of the environmental performance rating of companies is done through the PROPER18 program. PLN has established a PROPER Assessment Team, which is responsible for ensuring compliance with national environmental quality standards.. The team coordinates with the Environment Sub-division of K3L, but reports directly to the Director of Human Capital Management. The duties of team are as follows:

• Conduct pre-assessment for preparation and consistency of PROPER compliance for power plants within PLN

• Conduct evaluation to the assessment results carried out within PLN

• Prepare recommendation to the assessment results carried out within PLN

• Prepare report on PROPER assessment and submit the report to Head of the K3L Division

• Monitor progress of corrective actions for power generation plants as the recommendation of assessment carried out within PLN.

Based on PLN’s 2016 Sustainability Report, a total of 81 PLN units participated in PROPER during 2016 (in 2015, 72 units participated) with three units in the Green (second-highest category), 70 units in the Blue category (third-highest category) and eight units in the Red category (next to the lowest category). In 2015, some PLN units had been in the Black (worst) category. In 2016, PLN had no units in the Black category.

18 Performance Rating Program (PROPER) initiated by MOEF/KLHK.

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W/M/S Qualitative Parameters

Assessment Results

B. Process and Procedure B.1 Procedures to

ensure compliance with national and international requirements

Adherence to all national and local regulations, PLN’s standard, other sectors standards, and international best practices

In order to ensure compliance with national and internal legal requirements, PLN internally evaluates AMDAL and UKL-UPL documents , firstly by UIP and then by K3L prior to submitting them to the Ministry of Environment (MOEF/KLHK). Only AMDAL/UKL-UPL that comply with all national and internal PLN regulations are submitted. The flowchart showing the stages of the process is Figure 1, above. Table 1 gives indicative times for delivery. Available documentation for the six projects assessed in the field indicated that all required procedures were followed to ensure compliance with national and sub-national laws and regulations. Documentation for three of the projects assessed in the field and all 12 projects for which a desk assessment was done also described the measures taken to comply with PLN’s internal regulations.

M Adherence to all national and local regulations, including PLN’s standard.

Adherence to limited to minimal requirements of national legislation and procedures only

B.2 Establishment of targets and achievement for K3L’s performance

Targets are designed to exceed K3L requirements to include emerging best practices

The Environment Sub-Division of the K3L Division has eight categories of targets for corporate performance in 2017, six of which include activities related to environmental safeguards. The targets that are directly related to the issues raised in this assessment are: improving PLN’s performance as measured by the PROPER rating system; expanding monitoring activities; revising the Competence Directory; and training.

M Targets are designed to meet all objectives and requirements of SML

No particular targets are set relative beyond compliance with legal requirements

B.3 Coordination with other bodies responsible for approval

S Clear procedures are in place for ensuring that coordination with other bodies responsible for approval

Preparation of AMDAL and UKL-UPL and securing environmental permits also involves government agencies in addition to MOEF/KLHK. Project compliance with spatial planning is assessed from the initial stage of screening in coordination with the national and sub-national agencies responsible for spatial planning. On spatial planning, PLN coordinates with the Local Development Planning Agency (Bappeda), Public Works and Spatial Planning, Kimrum (Settlements and Housing), or Local Coordination Agency for Spatial Plan (BKPRD), or National Coordination Agency for Spatial Plan(BKPRN) to ensure compliance of project locations with spatial planning. Agencies responsible for spatial

Environmental approval documents are a pre-condition for the projects

Links between assessment document and development/ permitting are unclear

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Assessment Results

planning issue recommendations on what PLN projects must do to comply with spatial planning requirements. Depending on the requirements of a PLN project, additional environmental related permits may also be required from other agencies, including: - Groundwater abstraction (Ministry of Energy and

Mineral Resources or its regional offices) - Hazardous waste storage, transport and use

(MOEF/KLHK or its regional offices) - Forest use (MOEF/KLHK or its regional offices) K3L is responsible for managing the processes of securing permits from other agencies. PLN uses an integrated management system based on International Organization for Standardization (ISO) standards. Document management and control is one of the most essential components of this system. In all projects assessed, preparation of AMDAL and UKL-UPL and the environmental permitting process always involves environmental agencies (MOEF/KLHK and its provincial and district offices). All projects assessed also involved coordination with other agencies/bodies responsible for approvals and permitting. In addition to MOEF/KLHK and spatial planning agencies, in one of the projects assessed PLN also coordinated with the General Directorate of Marine Transport. All of the projects assessed complied with all requirements. The evidence, as attached in AMDAL or UKL-UPL documents, was available for 10 of the 18 projects assessed. For the other eight projects, attachment of evidence of compliance with the spatial plan was not mandatory because the status of the location was clear.

B.4 Incorporation of pollution control into standard environmental

Pollution control requirements are clearly reflected in the RKL-RPL

Pollution from transmission and distribution projects only occurs during construction and maintenance, while pollution from power plants occurs continuously. Mitigation measures formulated in environmental management plans (RKL-RPL or UKL-UPL) are

M Pollution control requirements are reflected in the RKL-RPL but somewhat confusing, ineffective and/or overlapping

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Assessment Results

management measures and hazardous waste management

Links between pollution control and other environmental management procedures are unclear.

commensurate with the type of project and type of impact and vary from project to project. For some projects, mitigation measures are carried out periodically and for others they are continuous. All projects assessed incorporated standard environmental management measures for pollution control into the RKL-RPL or UKL-UPL. One of the six projects assessed in the field included an appendix describing permits for collection and transport of hazardous wastes, hazardous waste manifests, hazardous waste management balance, and hazardous waste reporting sheets. The RKL-RPL for a coal-fired power plant in Muara Karang (Jakarta), which was one of the desk assessment case studies, requires using a particular technological approach for pollution prevention, including use of low nitrogen oxide (NOx) burners to control and reduce NOx emissions during operation; and an enclosure system for noise control. In addition, the RKL-RPL also requires quarterly emission monitoring and reporting on emissions loads, through a continuous emission monitoring system. Similar monitoring and reporting is also required out for emissions from mobile sources, and for wastewater pollution loads. The RKL-RPL of another of the 12 desk study projects assessed also specifies a technological approach to reduce air emissions from the power plant, requiring use of de-NOx for nitrogen oxide emissions and an electrostatic precipator for fly ash. PLN has prepared a standard operating procedure for managing waste, including hazardous wastes such as Sulfur hexafluoride/ SF6/, polychlorinated biphenyls/ PCBs, and transformer oil. The procedure covers identification, collection, containment/storage, and transport of the hazardous and non-hazardous wastes.

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Assessment Results

One of the projects assessed in the field and three projects for which desk assessments were done, reflected the use of PLN’s standard operating procedure. In addition to waste management, PLN also uses non-polluting technology, including gradual phase-out of PCBs use for new installations since 1998.

B.5 Consistent use of expertise for conducting environmental assessments

Suitable expertise is always deployed to meet the requirements of individual project assessments

In Indonesia, project proponents must prepare AMDAL or UKL-UPL. A project proponent may do this on its own or may hire expert accredited consulting firms with certified consultants. Due to limited in-house staff capacity, PLN usually hires certified consultants as well as accredited firms to carry out AMDAL and UKL-UPLfor its projects. K3L’s involvement in hiring environmental consultants is just to develop TOR; the rest of the process is carried out by the Procurement Division. PLN, with support from a pool of certified experts, led AMDAL/UKL-UPL preparation for only one of the 6 field case study projects assessed.19 For all other projects assessed, AMDAL/UKL-UPL was prepared by certified private/state-owned consulting firms or universities. External expertise is not consistently available with respect to PLN’s own safeguards requirements or those set by the government. Some of the consultants and consulting firms are qualified, while others lack competence. Due to the high variability in consultants’ competence, the quality of AMDAL/UKL-UPL also varies, depending on the qualification and experience of the consultants employed to prepare them. As of December 2014, there were 936 certified individual AMDAL consultants in Indonesia; approximately 40 percent of them are based in Jakarta and West Java. Because the number of certified consultants and accredited firms operating in the regions, especially off-

M Inconsistent use of expertise from project to project resulting in variable quality in the conduct and review of impact assessments

Expertise for conducting or reviewing impact assessments often unavailable or not deployed

19 Development of SUTT (HVTL) 150 kV Kadipaten Incomer and GI (Substation) 150 kV Kadipaten, Majalengka, West Java

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Assessment Results

Java locations20, is limited, some PLN projects in the regions use university-based experts to prepare AMDAL/UKL-UPL. All six of the projects assessed in the field employed both private AMDAL consulting firms and university-based AMDAL teams. PLN staff did not prepare the AMDAL for any of these projects.

B.6 Risk assessment

Assessments are conducted routinely for all projects and conducted commensurate with level of potential risks

As a part of its internal supervision and control system, PLN has established a risk management policy21 in order to minimize potential losses. PLN also created a Risk Management Division which is responsible for ensuring that risks are managed in a correct, continuous, and comprehensive manner, and to mitigate all identified risks, including environmental ones. No information was available on the relationship of PLN’s risk management policy to environmental safeguards. The AMDAL/UKL-UPL of all but one of the six projects assessed in the field addressed management of the specific risks associated with electromagnetic fields and the corona effect. Meanwhile, for power plant projects, analysis of such transmission risk was not included, with the exception of one desk study of a power generation plant combined with a transmission line.

M Assessments are conducted routinely for all projects

Environmental and social assessments are undertaken only for projects that present certain significant adverse impacts

B.7 Mitigation hierarchy

Avoidance (e.g., of environmentally sensitive and tribal areas, resettlement) is practiced wherever feasible, with all other impacts proactively mitigated

From the screening phase, actions are identified to avoid or mitigate impacts, particularly on environmentally sensitive and tribal areas and with projects involving resettlement, wherever feasible. PLN frequently shifts the alignment of transmission lines to avoid impacts. Similarly, at the feasibility study stage, siting of power plants is planned to avoid sensitive areas as much as possible. One transmission line project, of the 12 projects for which a desk assessment was done, shifted the route of the transmission line to avoid adverse impacts. Another transmission line project for which a desk assessment was done avoided resettlement, tourism, natural

M Mitigation is conducted proactively

Impacts are mitigated as encountered during construction

20 TA-7566 REG: Strengthening and Use of Country Safeguard Systems (March, 2015) 21 PLN’s Sustainability Report (2016).

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Assessment Results

sanctuary, cultural heritage, historical buildings, and gas station to reduce its impacts.22 One power generation project built a separate access road to avoid traffic congestion. 23

B.8 Conduct of meaningful public consultation

Public consultation meets all requirements, including engagement of all categories of stakeholders, including vulnerable populations (e.g., women, indigenous/tribal people, the poor, etc.)

In the initial announcement and public consultation stage of the AMDAL process, PLN makes public announcements through local newspapers, radio/TV broadcasting, and by posting announcements at government offices, inviting the public to respond and submit suggestions, opinions, responses, or (objections to a project. However, there is no evidence that people respond and send their comments. Such public announcements are not an effective means to gather comments and inputs from communities. Written comments are rarely received, especially from rural and periurban communities where people are not so familiar with written communication and prefer verbal and face-to-face interactions. Other forms of public consultations are welll documented, and attached as part of AMDAL/UKL-UPL documentation. Community leaders, family welfare organizations (Pembinaan Kesejahteraan Keluarga/PKK), and local NGOs participate in consultations at the scoping (KA-ANDAL) phase and consultations on the assessment results (ANDAL plus RKL-RPL). Such consultations are supported with questionnaires that allow people to respond both orally and in writing during the consultation and are well documented All suggestions, opinions, and responses are recorded and PLN checks and verifies them. Depending on the significance and validity of the issues raised, public participation may lead to revisions to AMDAL and UKL-UPL documents. All 18 projects assessed conducted formal public consultations with varying degrees of involvement of vulnerable groups. For all of the projects assessed,

Public consultation partially meets the requirements

W Public consultation is pro forma only.

22 AMDAL of High Voltage Air Transmission 70 kV Nonohonis – Kefamenanu 23 AMDAL of PLTMG Minahasa Peaker (150 MW)

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Assessment Results

public consultations were well documented and the minutes were attached to each AMDAL or UKL-UPL document. Evidence from the projects assessed indicates that when PLN holds public consultations participation is less than acceptable but the consultations are well-documented. Seven of the 18 projects assessed required AMDAL and public consultations were carried out. Minutes of meetings and lists of attendants from these projectsshowed that women were represented when they were the heads of households. For two of the projects, few women were involved as active representatives in the public consultation and there was no evidence of adequate involvement of women and/or vulnerable groups in the others. Participants in the consultations for these projects were mostly officers from district or provincial environmental agencies, Army, Police and technical agencies, local leaders, and sometimes NGOs. Affected people were not always directly involved but were often represented by local leaders. In the consultations for these seven AMDAL projects, there was no special attention to ensure that women and vulnerable groups were represented in public consultations. Eleven of the projects assessed required UKL-UPL, where information was disseminated in conjunction with the land acquisition process for the project. This information sharing was not equivalent to public consultation.

B.9 Grievance redress mechanism

Establish a systematic process for receiving, evaluating and addressing affected people’s project-related concerns, complaints, and grievances.

No grievance redress mechanism (GRM) for environmental safeguards was established for any of the 18 projects assessed. Grievances related to any aspect of a project are handled through negotiation. All of PLN’s administrative levels may be involved in efforts to resolve any complaint. PLN bears all costs of grievance redress – affected persons bear none of these costs. Grievances raised by customary communities follow the communities’

Establish a Grievance Redress Mechanism with moderate function for receiving, evaluating and addressing affected people’s project-related concerns, complaints, and grievances

W No grievance redress mechanism established

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Assessment Results

customary internal mechanisms, if any, or any mechanism provided by local government based on community request. Affected persons may bring their complaints to village leaders and/or customary leaders who bring the complaint to a PLN office. PLN follows this practice for all of its projects, but does not maintain systematic records of grievances and how they are resolved at any level of the corporation. PLN has a complaint management system accessible (i) through the call center 123, which can be accessed by anyone anywhere in Indonesia through the company website, email, telephone, or social media; (ii) online by using an integrated complaint-solving application; and (iii) through customer services. These facilities are available for affected persons to report any incident or complaint about PLN operations, but are not project-specific and have not been used effectively for grievances involving environmental issues. Addressing environmental issues and complaints is regulated by Indonesian law. Affected persons can use the existing grievance redress mechanism provided by MOEF/KLHK and its regional offices, which have primary responsibility for environmental compliance and law enforcement in any type of project. When MOEF/KLHK or one of its regional offices receives an environmental complaint, the receiving office verifies it and either resolves it or forwards it to the appropriate agency for action. When a PLN office receives a notification or warning from MOEF/KLHK or one of its regional offices, the corresponding regional office is supposed to act immediately. The MOEF/KLHK GRM has a procedure requiring local authorities to document that the complaint was identified, noted, managed and solved.

B.10 Protected areas and biodiversity conservation

Strictly comply with national and international practices (among others ADB SPS requirements) in environmental assessment

Preventing or avoiding impacts on critical habitats is anticipated from the screening stage of the AMDAL/UKL-UPL process, when the environment authority must evaluate compliance of the location of an activity with the

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Assessment Results

Comply with national and local regulations in environmental assessment

corresponding spatial plan. Project locations must also comply with the indicative map of new permit moratorium (Peta Indikatif Penundaan Izin Baru/ PIPIB).24 No business and/or activity is allowed in moratorium areas, except for special cases, and with very strict requirements. Three of the 18 projects assessed involved impacts on biodiversity. One of the transmission line projects crossed a marine area and raised biodiversity issues. The baseline information in the UKL-UPL on biological components, species richness, abundance, biodiversity and value index, and dominance value especially for aquatic/marine biology, is quite extensive and complete and the assessment of impacts on biodiversity in this UKL-UPL. Another transmission line project assessed crossed a forest area, and a biodiversity assessment was carried out. The AMDAL report for this project addressed the biodiversity index using the IUCN Red List to identify endangered species of flora and fauna. The AMDAL report of a hydroelectric power generation project also assessed impacts on biodiversity, identifying endangered species and their vulnerability by reference to theConvention on International Trade in Endangered Species of Wild Fauna and Flora (CITES). Electricity projects raise specific challenges affecting biodiversity. PLN urgently needs specific technical guidelines on siting projects, particularly in protected forests, including mangrove forests.

W No or little consideration of biodiversity in environmental assessment

B.11 Screening Comprehensive environmental screening process involving multiple factors, field visits, consultation and peer review

Screening takes place for every project. PLN as project proponent discusses the type of environmental assessment required with the environmental agency which determines the type of study to be carried out. All 18 projects assessed were screened using legally-established criteria. Several projects whose scale

M Consults with Environmental Management Agency on screening decision

Screening decision is a formality based on limited local information or consultation

24 As stipulated in Presidential Instruction No. 10/ 2011 on Moratorium of New Permit Issuance and Refining of Primary Forest and Peat Land Management or its

revision as well as issuance of new regulation.”

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Assessment Results

equaled or exceeded the screening criteria were subject to AMDAL, while the 11 others were subject to UKL-UPL. Compliance with the respective spatial plan is the most important determining factor. It was the first step in the screening process for each project and confirmation of compliance was attached as an appendix to the AMDAL or UKL-UPL.

B.12 Scoping Scoping and development of study KA-ANDAL based on preliminary analysis, public consultation and peer review.

All 18 projects assessed complied with regulatory requirements for scoping. The seven projects which required AMDAL were subject to scoping and the 11 projects that required UKL-UPL were not because there is no obligation to for scoping for projects in the UKL-UPL category. PLN conducted internal peer review of scoping document (KA-ANDAL) to ensure their quality and compliance with requirements.

M Scoping and development of study KA-ANDAL adhere to national legislation and procedures only

Scoping and development of study KA-ANDAL rely on administrative correctness only.

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C. Output/Outcome C.1 Content of the

study report Comprehensive structure provided based on

international best practice, adapted as necessary to local conditions and highly sensitive to scoping

Review of the environmental assessment reports among 18 projects assessed revealed that the contents of seven AMDAL reports and five of the UKL-UPL documents were compliant with regulatory requirements; six of the UKL-UPL reports were not.

M Content of study report varied based on the results of scoping

Strict adherence to structure set out in national guidelines

C.2 Quality of analysis25

Magnitude and significance of key impacts assessed using both quantitative and qualitative methods

Of the 18 projects assessed, four AMDAL and three UKL-UPL reports adequately assessed and analyzed the magnitude and significance of key impacts, using both quantitative and qualitative methods. The depth of analysis for three AMDAL and eight UKL-UPL documents was not commensurate with the potential project impacts. In addition to standard methods required by national regulations, of the AMDAL report for one of the projects assessed used additional quantitative approaches, including mathematical or statistical modelling. Impact analysis for 10 of the 18 projects assessed was generally comprehensive and covered most potential impacts.

M Some quantitative analysis of impacts provided in the study linked to baseline conditions

Baseline information lacks focus containing much irrelevant information and very limited analysis

C.3 Consideration of alternatives

Assessment of alternatives including the ‘no project’ alternative.

PLN assesses alternatives on the basis of which one provides the highest profit, financially and non-financially, and at the same time ensures the lowest risks. One of the non-financial criteria is environmental feasibility. When PLN projects will have environmental impacts, the alternatives assessed may include location, use of production machinery, production capacity, technical specifications, facilities, building layout, timing and duration of operation, among others. Alternative locations are considered particularly in the cases of siting of power generation plants and alignment of transmission lines. Transmission lines are not always in straight line,

M Project alternatives emerged and considered in the assessment.

AMDAL study considers one alternative only

25 Depth of analysis is one of four criteria on which the quality of all documentation associated with the environmental impact assessment process is to be evaluated.

The other criteria are: 1) consistency; 2) compliance (mandatory); and 3) relevance (Regulation of Minster of Environment and Forestry No. 08/2013 on Procedure for Review and Examination of Environmental Documents and Issuance of Environmental Permit).

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Assessment Results

but made crooked, to avoid impacts on environmentally and/or socially sensitive areas. The AMDAL report for one of the projects assessed considered the no-project alternative and compared it with what the situation was anticipated to be if the project were implemented. Of the 18 projects assessed, one transmission line/sub-station project considered two alternatives:

• Option or Alternative 1: Expansion of the medium voltage networkby sourcing from an existing sub-station. This was theno-project alternative.

• Development of a new sub-station with similar capacity. This was the new development alternative.

C.4 Operational environmental management plan

RKL-RPL includes specific mitigation and monitoring plans based on key impact areas identified in the AMDAL study

Of the 18 projects assessed, the RKL-RPL for seven of them appropriately included specific mitigation and monitoring plans based on key impact areas identified in the AMDAL study. The RKL-RPL matrices for six of those seven projects followed the required formatand covered all required content. The RKL-RPL for the seventh project was prepared under the regulation in effect prior to 2012, and therefore did not contain the matrix and some of the content that has been required since 2012. Eleven of the projects assessed required UKL-UPL, which included the environmental and monitoring plan in the same document.

M Moderate RKL-RPL in terms of operational value and effectiveness

RKL-RPL formulaic, lacking in substance and of limited operational value to decision makers

C.5 Method for review of content and substance of reports submitted

Detail reviews of project impact assessments undertaken, includes peer review and may include field visits by environmental specialists

PLN has Environmental Engineers assigned to the Environment Sub-Division of K3L at HQ and to UIPs at regional/project level. UIP staff review AMDAL/UKL-UPL documents first and then K3L staff review them. PLN internal review of AMDAL and UKL-UPL reports focuses on technical issues; environmental safeguards staff may recommend changes to the siting and/or design of a project. MOEF/KLHK has developed a checklist for reviewing AMDAL and UKL-UPL reports but PLN staff do not make maximum use of it for their internal review. During interviews, K3L staff indicated that internal review is done

Reviewers engage in significant discussion on technical matters and may recommend changes to the siting and/or design of the project.

W Reviewers look for administrative correctness rather than discussing substantive environmental and social issues

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Assessment Results

without specific guidance, and that PLN mostly relies on internal knowledge and the skill of the individual reviewer. No information was available on how PLN conducted review of the 18 projects assessed, except for one power generation project. The scoping report (TOR/KA-ANDAL) for that project showed that K3L’s review focused primarily on compliance with regulations and administrative requirements.

C.6 Arrangements for access to environmental documents and monitoring reports

Total transparency through provision of accessible information in local language is undertaken prior to finalization of the Final Environmental Assessment Reports and monitoring reports disclosed

MOEF/KLHK and its regional offices are responsible for disclosure of approved AMDAL and UKL-UPL reports. Some AMDAL or UKL-UPL documents for PLN projects can be found at the MOEF/KLHK website and documents can also be accessed on request. There is no legal requirement for PLN to disclose AMDAL and UKL-UPL documents and monitoring reports. In practice, PLN voluntarily discloses the AMDAL and UKL-UPL reports of some projects on the company website. However, there is no evident that monitoring reports are disclosed to public. By regulation, as a project proponent PLN must report to the environmental authority every six months on implementation of environmental management and monitoring plans (RKL-RPL). However, there is no legal requirement for individual proponents to disclose such reports to the public. Instead, MOEF/KLHK and its regional offices are required to disclose the reports26. PLN had not made systematic arrangements to disclose the AMDAL/UKL-UPL and monitoring reports of any of the 18 projects assessed. However, documentation for at least two of the projects is readily online and can be downloaded by the public.

M Reports placed in a public place and publicized in a local newspaper (or other media)

No specific arrangements made for access to information

C.7 Formal procedures based on regular reporting applied

26 PermenLH No. 06/2011 on Public Information Service.

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Implementation of requirements for monitoring project impacts

M RKL-RPL is an operational document, and may be subject to ‘revisions’ during lifetime of project

As a project proponent, PLN is responsible for monitoring RKL-RPL implementation every six months. MOEF/KLHK and its regional offices are responsible for supervising this monitoring. Monitoring parameters include: time series data from previous laboratory measurements for air quality, water quality, and noise levels: social, economic and cultural data trend evaluation; critical level evaluation; and compliance evaluation. Monitoring reports are required to specify corrective actions and/or new requirements. Environmental documents may be amended or updated in case of major changes. Four of the projects assessed – three transmission line projects and one power generation project – have conducted monitoring of project impacts. Of the other 14 projects assessed, 13 had only recently completed AMDAL/UKL-UPL assessment and have not been implemented while the others have no monitoring data. In addition to the standard monitoring parameters, three of the transmission line projects assessed also carried out monitoring electric magnetic fields and fire risk. The monitoring results of four of the 18 projects assessed were evaluated to determine their critical evaluation level and compliance with all regulatory requirements, especially those related to environmental quality standards. Monitoring reports included laboratory analyses carried out by an Indonesia National Accreditation Committee (KAN) accredited laboratory.

RKL-RPL not used or referred to after review and approval completed

C.8 Environmental audit

Environmental audit carried out regularly High-risk projects and activities and those that are suspected of violations may be subjected to environmental audit. None of the 18 projects assessed were subject to environmental audit. PLN’s integrated management system (see sub-component B.3), which includes ISO 14001 on environmental management, requires Wilayahs to conduct regular audits of power generation

M Environmental audit carried as required by law

No environmental audit carried out

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plant operations. PLN power generation plants also participate in PROPER (see sub-component A.9), which requires self-assessment and reporting on the basis of internal and external audits.

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