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Ulubelu 3&4 RevisedESIA Report - Volume III

Appendices

February 2011Pertamina Geothermal Energy

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265718 RGE GEV 08 C

F:\PROJECTS\265718 PGE Geothermal ESIAs\(2) Ulubelu\Reports\Submitted Draft\Addressing Comments\Ulubelu 3&4

04 February 2011

Ulubelu 3&4 Revised ESIA Report - Volume III

Appendices

February 2011

Pertamina Geothermal Energy

Mott MacDonald, Victory House, Trafalgar Place, Brighton BN1 4FY, United Kingdom T +44(0) 1273 365 000 F +44(0) 1273 365 100, W www.mottmac.com

Menara Cakawala 15th floor, Jalan MH, Thamrin No. 09 Jakarta - 10340, Indonesia


Mott MacDonald, Victory House, Trafalgar Place, Brighton BN1 4FY, United Kingdom T +44(0) 1273 365 000 F +44(0) 1273 365 100, W www.mottmac.com

Revision Date Originator Checker Approver Description A 27/08//10 V. Hovland B. Cornet D Boyland Draft for comments

B 08/09/10 V. Hovland B. Cornet D Boyland Final Draft

C 27/09/10 B. Cornet M. O’Brien D. Boyland Final Draft for Disclosure

D 07/12/10 B. Cornet M. O’Brien D. Boyland Revised Report for Disclosure

E 09/02/11 M. O’Brien H. White T. Streather

D. Boyland I. Scott Revised Draft ESIA

F 25/02/11 M. O’Brien H. White

D. Boyland D. Boyland Revised ESIA

Issue and revision record

This document is issued for the party which commissioned it and for specific purposes connected with the above-captioned project only. It should not be relied upon by any other party or used for any other purpose.

We accept no responsibility for the consequences of this document being relied upon by any other party, or being used for any other purpose, or containing any error or omission which is due to an error or omission in data supplied to us by other parties

This document contains confidential information and proprietary intellectual property. It should not be shown to other parties without consent from us and from the party which commissioned it.

265718/RGE/GEV/06/F 25 February 2001 F:\PROJECTS\265718 PGE Geothermal ESIAs\(2) Ulubelu\Reports\Submitted Draft\Addressing Comments\Ulubelu 3&4 Revised ESIA Vol III Final Rev A.doc


Chapter Title Page

Appendix A. Standards__________________________________________________________________________ 1A.1. Overview __________________________________________________________________________ 1A.2. Indonesian Standards ________________________________________________________________ 1A.3. World Bank Group Guidelines _________________________________________________________ 10Appendix B. Public Consultation and Disclosure Plan _________________________________________________ 15B.1. Introduction _______________________________________________________________________ 15B.2. Project Location and Description _______________________________________________________ 16B.3. Regulations and Requirements ________________________________________________________ 21B.4. Previous Public Consultation and Disclosure _____________________________________________ 22B.5. Project Stakeholders ________________________________________________________________ 25B.6. Information Disclosure and Community Engagement _______________________________________ 26B.7. Implementation Timescales and Responsibilities __________________________________________ 28B.8. Grievance Mechanism _______________________________________________________________ 29B.9. Confidentiality and Anonymity _________________________________________________________ 30B.10. Grievance Resolution________________________________________________________________ 30B.11. Monitoring and Reporting_____________________________________________________________ 31Appendix C. Land Acquisition and Resettlement Policy Framework ______________________________________ 32C.1. Introduction _______________________________________________________________________ 32C.2. Institutional and Legal Policy Framework ________________________________________________ 35C.3. Land Acquisition and Crop Compensation to Date (as of 1st January 2011)______________________ 53C.4. Summary _________________________________________________________________________ 59C.5. Annex - Requirements of Resettlement Plans_____________________________________________ 61Appendix D. Technical Appendix – Air Quality Assessment ____________________________________________ 62D.1. Introduction _______________________________________________________________________ 62D.2. Methodology_______________________________________________________________________ 62D.3. Modelled Scenarios and Key Input Data _________________________________________________ 70D.4. Receptors_________________________________________________________________________ 73D.5. Dispersion Modelling Results__________________________________________________________ 78D.6. Mitigations ________________________________________________________________________ 93D.7. Potential Residual Impacts Following Mitigation ___________________________________________ 94Appendix E. Noise Assessment Glossary _________________________________________________________ 101E.1. Glossary of Terms _________________________________________________________________ 101Appendix F. Transmission link summary __________________________________________________________ 104F.1. Introduction ______________________________________________________________________ 104F.2. Project Description_________________________________________________________________ 104F.3. Baseline _________________________________________________________________________ 104F.4. Assessment of Impacts _____________________________________________________________ 105F.5. Cumulative impacts and transboundary issues ___________________________________________ 105Appendix G. Revised ESIA Change Register_______________________________________________________ 106Appendix H. PGE and PLN Joint Agreement _______________________________________________________ 108H.1. Overview ________________________________________________________________________ 108Appendix I. Location Permit ___________________________________________________________________ 111I.1. Overview ________________________________________________________________________ 111Appendix J. Ministry of Environment Meeting Minutes _______________________________________________ 117J.1. Overview ________________________________________________________________________ 117Appendix K. Spatial Plan, Lampung Province ______________________________________________________ 121

Content

265718/RGE/GEV/06/F 25 February 2011 1


A.1. Overview

This appendix presents quantitative standards from both national and international standards and guidelines as referenced in Section 4, Volume II relevant to this ESIA.

A.2. Indonesian Standards

A.2.1. Water Quality

Government Regulation (PP) No. 82 of 2001 on Water Quality Management and Water Pollution Control includes the main Indonesian water quality standards as shown in Table A.1 below. The regulation defines Class I for drinking water and Class II as water suitable for recreational, fresh water fish cultivation, livestock and irrigation purposes.

In addition, Ministry of Health Regulation No. 416 of 1990 provides water quality standards for clean water. The Regulation defines clean water as water that is used for everyday purposes with quality that meets health requirements and can be drunk after being boiled. The standards are reported in Table A.2 (as a reference in preparing ESMP).

Appendix A. Standards



Table A.1: Water Quality Standards (Government Regulation No. 82 of 2001) Indonesia Standards

Government Regulation No. 82 of 2001 No. Parameter

1st Class 2nd Class

1 Temperature (0C) +/- 3ºC over ambient +/- 3ºC over ambient

2 TSS (mg/l) 50 50

3 TDS(mg/l) 1000 1000

4 pH 6-9 6-9

5 BOD(mg/l) 2 3

6 COD(mg/l) 10 25

7 DO(mg/l) 6 4

8 Total Phosphate (mg/l) 0.2 0.2

9 NO3 as N (mg/l) 10 10

10 NH3-N(mg/l) 0.5 NA

11 Arsenic (mg/l) 0.05 1

12 Cobalt (mg/l) 0.2 0.2

13 Barium (mg/l) 1 NA

14 Boron (mg/l) 1 1

15 Selenium (mg/l) 0.01 0.05

16 Cadmium (mg/l) 0.01 0.01

17 Chromium (VI) (mg/l) 0.05 0.05

18 Copper (mg/l) 0.02 0.02

19 Iron (mg/l) 0.3 NA

20 Lead (mg/l) 0.03 0.03

21 Manganese (mg/l) 1 NA

22 Mercury(mg/l) 0.001 0.002

23 Zinc (mg/l) 0.05 0.05

24 Chloride (mg/l) 1 NA

25 Cyanide (mg/l) 0.02 0.02

26 Fluoride (mg/l) 0.5 1.5

27 Nitrite (mg/l) 0.06 0.06

28 Sulphate (mg/l) 400 NA

29 Free Cl (mg/l) 0.03 0.03

30 Sulphur as H2S(mg/l) 0.002 0.002

31 Faecal coliform per 100 ml 100 1000

32 Total coliform per 100 ml 1000 5000

Source: Government Regulation No. 82 of 2001



Table A.2: Community Well Water Quality Standards (Ministry of Health Regulation No. 416 of 1990) Clean Water Quality Standard No Parameter

Maximum Concentration

Remarks

A. Physical

1 Odour - No odour

2 TDS (mg/L) 1,500

3 Turbidity (NTU scale) 25

4 Taste - No taste

5 Temperature (°C) +/- 3 Deviation from air temperature

6 Colour (TCU Scale) 50

B. Chemical

B.1 Inorganic Chemicals

1 Mercury (mg/L) 0.001

2 Arsenic (mg/L) 0.05

3 Iron (mg/l) 1.0

4 Fluoride (mg/l) 1.5

5 Cadmium (mg/l) 0.005

6 CaCO3 (mg/l) 500

7 Chloride (mg/l) 600

8 Chromium (VI) (mg/l) 0.05

9 Manganese (mg/l) 0.5

10 Sodium (mg/l) NA

11 Nitrate (mg/l) 10

12 Nitrite (mg/l) 1.0

13 pH 6.5 - 9.0 Minimum and maximum limit. pH for rain water is 5.5

14 Selenium (mg/l) 0.01

15 Zinc (mg/l) 15

16 Cyanide (mg/l) 0.1 17 Sulphate (mg/l) 400 18 Sulfide (as H2S) (mg/l)) NA 19 Lead (mg/l) 0.05 20 Copper (mg/l)) NA

B.2 Organic Chemicals

1 Aldrin and Dieldrin (mg/l) 0.0007

2 Benzene (mg/l) 0.1

3 Benzo [a] pyrene (mg/l) 0.00001

4 Chloroform-Total Isomers (mg/l) 0.007

5 Chloroform (mg/l) 0.03

6 2.4-D (mg/l) 0.1

7 DDT (mg/l) 0.03

8 Detergent (mg/l) 0.5

9 1,2 Dichloroethene (mg/l) 0.01

10 1.1 Dichloroethene (mg/l) 0.0003



Clean Water Quality Standard No Parameter

Maximum Concentration

Remarks

11 Heptachlor and Heptachlor Epoxide (mg/l)

0.003

12 Hexachlorobenzene (mg/l) 0.00001

13 Gamma-HCH (mg/L) 0.004

14 Methoxychlor (mg/l) 0.1

15 Pentachlorophenol (mg/l) 0.01

16 Total Pesticide (mg/l) 0.1 17 2.4.6-trichlorophenol (mg/l) 0.01 18 Organic substances (KMn04) (mg/l) 10

B.3 Microbiology

1 Total coliform per 100 ml 50 Not for piped water

2 Faecal coliform per 100 ml 10 For piped water

B.4 Radioactivity

1 Gross Alpha Activity (Bg/l) 0.1

2 Gross Beta Activity (Bg/l) 1.0 Source: Ministry of Health Regulation No. 416 of 1990



A.2.2. Wastewater Quality

The National Standard for wastewater quality from oil and gas and geothermal exploration and production activities is the Minister of Environment Regulation No. 04 of 2007.

Table A.3: Wastewater Quality Standard for (Onshore) Geothermal Exploration and Production Activities No Type of Wastewater Parameter Maximum

Concentration Measurement Methodology

Dissolved Sulphide (as H2S)

1 mg/L SNI 06-2470-1991 or APHA 4500-S2

Ammonia (as NH3-N) 10 mg/L SNI 06-6989.30-2005 or APHA 4500-NH3

Total Mercury (Hg) 0.005 mg/L SNI 19-1429-1989 or SNI 06-2462-1661 or SNI 06-2912-1992 or

APHA 3500-Hg

Total Arsenic (As) 0.5 mg/L APHA 3500-As

Temperature 45 oC SNI 06-6989.23-2005

1 Production Water

pH 6-9 SNI 06-6989.11-2004

Oil and Fat 15 mg/L SNI 06-6989.10-1004 2 Wastewater and Drainage Total Organic Carbon 110 mg/L SNI 06-6989.28-2005 or

APHA 5310 Source: Minister of Environment Regulation No. 04 of 2007



In addition, effluent form thermal power plants are regulated by the Minister of Environment Regulation No. 08 of 2009, as reported in Table A.4.

Table A.4: Wastewater Quality Standard MOE Regulation No. 08 of 2009 No Type of Wastewater Parameter Maximum

Concentration

pH 6-9

TSS 100 mg/L

Oil and Grease 10 mg/L

Free Cl2 0.5 mg/L

Chromium (Cr) 0.5 mg/L

Copper (Cu) 1 mg/L

Iron (Fe) 3 mg/L

Zinc (Zn) 1 mg/L

1 Sourced from Main Processes

Phosphate (PO4-) 10 mg/L

pH 6-9

Free Cl2 1 mg/L

Zinc (Zn) 1 mg/L 2 Sourced from Blow down Cooling Water

Phosphate (PO4-) 10 mg/L

COD* 300 mg/L

TOC** 110 mg/L 3 Containing Oil***

Oil and Grease 15 mg/L Source: Minister of Environment Regulation No. 08 of 2009 Note : * COD parameter is only valid until 31 December 2009 ** Parameters TOC into force on 1 January 2010 *** if the source of waste water containing oil is not flow to the WWTP



A.2.3. Air Quality and Atmospheric Emissions

The construction phase of the project could potentially lead to emissions of a range of combustion related pollutants including nitrogen oxides (NOx), particles and carbon monoxide. In the operational phase, the only pollutant of concern is hydrogen sulphide (H2S) which is released from the cooling towers, rock mufflers and during the initial well testing phase.

The primary Indonesian ambient air quality standards are set out in Government Regulation No. 41 of 1999 regarding Air Pollution Control. These are presented in Table A.5, below.

The 1999 Regulations do not include ambient standards for hydrogen sulphide or ammonia (NH3); concentrations of these pollutants are instead regulated under Ministry of Environment Decree No. 50 of 1996 regarding odour standard. These are also presented in Table A.5 below.

During the production of the ESIA, MML requested a meeting with the Indonesian Ministry of Environment to clarify the applicability of the odour standard for geothermal power plant developments, specifically in relation to H2S. This meeting was held in Jakarta on 14th January 2011 and the signed minutes are presented in Appendix J. As the meeting minutes record, the H2S standard in the odour standard is designed to protect against community nuisance and protect community health. The Ministry of Environment acknowledged that the H2S standard is more stringent than international standards (see Section A.3.2 below which presents the World Health Organisation (WHO) Guidelines for ambient H2S). In addition, the meeting minutes record that:

“According to KLH [Ministry of Environment], the odour standard for H2S was specifically aimed at manufacturing industry. Not operations in naturally occurring H2S areas.”

Such ‘naturally occurring H2S areas’ includes Ulubelu where the Project is proposed. Although not referenced in the odour standard, the MOE confirmed the H2S standard is a 2 hour average as determined from the measurement method (see Appendix J). The Ministry of Environment noted that it was not in a position to comment on the applicability of the odour standard to geothermal areas until the geothermal industry, as a forum, presents evidence regarding the difficulty of the application of the standard. In addition, the meeting minutes record that:

“KLH [Ministry of Environment] will review any evidence base presented against best practice with a view to exempting the standard from geothermal areas.”

The ESMP (Volume IV) identifies the need for an Indonesian Geothermal Environment Forum in recognition of the need for various government monitoring agencies to be more familiar with key issues that represent potential barriers to geothermal development. PGE is committed to the formation of an industry-wide geothermal environment forum whereby issues such as the difficulty with the application of the H2S standard within MOE Decree No. 50 of 1996 can be presented as a collective for discussion with government stakeholders.

On the basis of the meeting with the Ministry of Environment and PGE’s commitment to the formation of an industry-wide geothermal environment forum, the 1996 Decree standard for H2S has been presented below, but it has not been used within the EIS to assess the ambient air quality impacts of H2S emissions from the Project. Instead, the WHO guideline standard for the protection of human health has been used (see Section A.3.2, below).



Table A.5: Indonesian Ambient Air Quality Standards for the Protection of Public Health Parameters and values

CO NH3 H2S NO2 SO2 PM10 TSP( a) Source Averaging

Period µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3

1 Hour 30,000 - - 400 900 - -

24 Hour 10,000 - - 150 365 150 230 Government Regulation No. 41 of 1999 Annual - - - 100 60 - 90

MOE Decree No. 50 of 1996 (c) 2 Hour (b) - 1,360 28 - - - -

Note: (a) Total suspended particulates (b) Although not referenced in the MOE decree, the MOE advised that it is a 2 hour averaging period based on the measurement method as recorded in the MOM with Ministry of Envyronment (see Appendix J) (c) Decree regarding odour standard, not for protection of public health

In addition to the ambient air quality standard described above for the protection of the public, Ministry of Manpower Letter No. SE-01/MEN/1997 regarding Ambient Threshold Limits of Chemical Factors in Working Environments; provides occupational H2S exposure limits. This is presented in Table A.6 below.

Table A.6: Indonesian Ambient Air Quality Standard for the Protection of Occupational Health, H2S

Name Averaging Period H2S

Ministry of Manpower Letter No. SE-01/MEN/1997 8 Hour 10ppm / 14,000 µg/m

3

Emissions to air from geothermal power plant are regulated by Ministry of Environment Regulation No. 21 of 2008 on air emissions from stationary sources and power plants. This limit is presented in Table A.7.

Table A.7: Indonesian Air Emission Standards for H2S Parameters and Values(a)

Name NH3 (mg/Nm3)

H2S (mg/Nm3)

MOE Regulation No.21 of 2008 0.5 35

Note: (a) At reference conditions 25oC, 1 ATM



A.2.4. Noise

Indonesian standard for environmental noise is set in Ministry of Environment Decree No. 48 of 1996 as shown in Table A.8. A noise health and safety limit is set in Ministry of Manpower Decree No. 51 of 1999.

Table A.8: Indonesian Noise Standards (dBA) Measured Sites National standard Kep.

MenLH 48/1996 National standard Kep.

Menaker 51/1999

Residential area 55

Green open space 50

Industrial area 70

Occupational safety and health 85 (8 hours)* 88 (4 hours)* 91 (2 hours)* 94 (1 hour)*

97 (30 minutes)* Source: Ministry of Environment Decree No. 48 of 1996 Ministry of Manpower Decree No. 51 of 1999

* Exposure limit per day



A.3. World Bank Group Guidelines

A.3.1. Overview

IFC Performance Standard 3 and World Bank OP 4.01 specify the use of the World Bank Group Environmental, Health, and Safety Guidelines (known as the "EHS Guidelines"). These guidelines were developed as part of a two and a half year review process that ended in 2007.

The revised World Bank Group EHS Guidelines are a set of general and industry specific examples of international good practice. The General EHS Guidelines contain information on crosscutting issues applicable to projects in all industry sectors. They provide guidance on performance levels and measurements considered to be achievable at reasonable cost by new or existing projects with the use of existing technologies and practices. The Project will be designed to comply with the levels and measures identified in the EHS Guidelines where Indonesian host country requirements are less stringent or do not exist.

The General EHS Guidelines provide both environmental and occupational health & safety (OHS) standards. No measurement method references are quoted within the World Bank Group guidelines and it is assumed that internationally recognised measurement methods such as various ISO standards will apply.

A.3.2. Waste water effluents

No specific liquid effluent discharge guidelines are provided within either the World Bank Group General EHS Guidelines or EHS Guidelines for Geothermal Power Generation. However, liquid effluent discharge guidelines are provided within the World Bank Group EHS Guidelines for Thermal Power Plants which are presented for reference purposes. In comparison with Indonesian national standards, certain parameter requirements in the World Bank Group EHS Guidelines are more stringent (total suspended solids, residual chlorine, copper, iron and cadmium). The Project will comply with these more stringent standards.

Table A.9: World Bank Group Standards for Liquid Effluent Discharge Pollutant Unit Limit Comment

pH pH 6 - 9 -

TSS mg/l 50 -

Oil and Grease mg/l 10 -

Total Residual Chlorine mg/l 0.2 Chlorine “shocking” may be preferable in certain circumstances.

Chromium (total) mg/l 0.5 -

Copper mg/l 0.5 -

Iron mg/l 1 -

Zinc mg/l 1 -

Cadmium mg/l 0.1 -

Mercury mg/l 0.005 -

Arsenic mg/l 0.5 -

Temperature Increase mg/l +5ºC Site specific requirement; elevated temperature areas due to discharge of once-through cooling water should be minimized by adjusting intake and outfall design through the project specific EA depending on the sensitive

aquatic ecosystems around the discharge point.



To limit impacts on water quality in case of limited or no sewerage network, the following World Bank Group General EHS Guidelines will apply to any sanitary waste water after being treated in waste water treatment plant.

Table A.10: Indicative Values for Treated Sanitary Sewerage Discharges Pollutants Units Guideline Value

pH pH 6-9

BOD mg/l 30

COD mg/l 125

Total nitrogen mg/l 10

Total phosphorus mg/l 2

Oil and grease mg/l 10

Total suspended solids mg/l 50

Total coliform bacteria MPN(b) / 100ml 400 (a) Notes a) not applicable to centralised, municipal, wastewater treatment systems which are included in EHS guidelines for water

and sanitation b) MPN = Most probable number

A.3.3. Ambient Air Quality

As noted above, the construction phase of the project could potentially lead to emissions of a range of combustion related pollutants including nitrogen oxides (NOx), particles and carbon monoxide. In the operational phase, the only pollutant of concern is hydrogen sulphide which is released from the cooling towers, rock mufflers and during the initial well testing phase.

The Project shall be designed to comply with the relevant national standards or, in their absence, the current WHO air quality guidelines, as required by the World Bank Group General EHS Guidelines. As other pollutants such as NO2, SO2 and PM10 are adequately covered under Indonesian legislation (Government Regulation No. 41 of 1999) only WHO guidelines for H2S are referenced given that the MOE Decree No. 50 of 1996 regarding odour standard has not been used within this assessment for the justification provided previously in Section A.2.3. The current WHO guidelines for H2S are presented in Table A.11.

Table A.11: WHO Ambient Air Quality Guidelines Pollutant Averaging Period Value (µg/m3)

Hydrogen Sulphide 24 Hour 150 (guideline)

The latest version of the WHO Guidelines (Global Update, 2005), focus on the key criteria pollutants of particulate matter, ozone, nitrogen dioxide and sulphur dioxide and do not contain specific guideline values for H2S.

The WHO Air Quality Guidelines for Europe, 2nd Edition 2000 (henceforth the WHO guidelines) was a landmark publication that provided information on a much wider range of pollutants than previous guidance. Although the publication was made in Europe, the preface and foreword notes that WHO guidelines were and have been applied world-wide as best practice, and consequently led to the 2005 Guidelines adopting a ‘Global’ moniker. The 2000 Guidance, from which the guideline for H2S is sourced and draws heavily on international data, acknowledges that when States use the guidelines for setting legally binding standards,



considerations such as prevailing exposure levels, technical feasibility, source control measures, abatement strategies, and social, economic and cultural conditions should be taken into account.

In many jurisdictions, such as the United States and Europe, such considerations have led to the introduction of a threshold of tolerance to account for exceptional, worst case episodes. In practice this means defining a number of allowable occurrences greater than the prescribed value to account for potential abnormal or infrequent pollutions episodes - these are often referred to the guideline values being applied as percentiles. This principal has been applied within the assessment by comparing the second highest modelled 24 hour H2S concentrations against the WHO guideline value. Not only is this in accordance with the spirit of the guidelines, but it also ensures that conclusions are not based on potential outlier results produced by the modelling.

The WHO defines a guideline as “…any kind of recommendation or guidance on the protection of human beings or receptors in the environment from adverse effects of air pollutants”. This assessment has interpreted the application of the WHO standard as being relevant to those locations only where receptors can reasonably be expected to be exposed for the specified averaging period. . This is in accordance with the application of, for example, the EU Air Quality Directive (2008/50/EC) where application of ambient air quality objectives excludes areas of non fixed habitation (i.e. residential areas), work and industrial locations and within roads. In the case of H2S, the averaging period is 24 hours and therefore this guideline has only been applied to locations where receptors can reasonably be expected to be located for this duration, i.e. residential locations, as well as health care facilities, schools and similarly sensitive sites. This approach is consistent with international interpretation of air quality standards such as those in Europe.

Some studies of the potential impacts of H2S on vegetation have been undertaken in the US and Canada which has included studies on plants in the biosphere as well as in laboratory experiments. In general, studies have found that negative effects on vegetation occur only with prolonged exposure to H2S, and that lower levels can stimulate growth in certain types of plants. No formal guidelines have been set for the impacts of H2S on vegetation, but a report published by Alberta Environment (Assessment Report On Reduced Sulphur Compounds, 2004) recommended a limit of 140µg/m3 as a no observable effect concentration, for long-term exposure (long-term exposure usually being interpreted, for example within the EU, as annual average periods). Therefore in the present assessment, this limit has been adopted as an annual mean to assess the potential effects of H2S on vegetated areas. Modelled concentrations of ground level H2S have therefore been compared against this standard for areas designated as Hutan Lindung (Watershed Protection Forest) and surrounding agricultural areas. As the existing vegetation is already exposed to some levels of ambient H2S they are likely to already be desensitized to exposure and therefore this limit is likely to be conservative.



A.3.4. Noise

The World Bank Groups General EHS Guidelines set out recommended environmental noise limits for new developments, as presented in Table A.12.

Table A.12: IFC / World Bank Noise Limits One hour LAeq(dBA) Receptor

Daytime 07:00 – 22:00

Night-time 22:00 - 07:00

Residential; institutional; educational receptors: 55 45

Industrial; commercial 70 70

A.3.5. Occupational health and safety standards

Guidelines values for occupational health and safety (OHS) limits, as described in World Bank Group guidelines that will be used for this project in addition to general good practice measures are provided in further detail below. The Project shall be designed to comply with the relevant Indonesian and World Bank Group guidelines on OHS. Where the Indonesian and international standards differ, the more stringent of the two will be applied.

Noise

Table A.13 summarises relevant World Bank Group Guidelines for occupational noise exposure, which should be complied with at the relevant locations on site.

Table A.13: Noise Limits for Various Working Environments Location / Activity Equivalent Level

LAeq,8h Maximum

LAmax,fast

Heavy industry (no demand for oral communication) 85 dB(A) 110 dB(A)

Open offices, control rooms, service counters or similar 45 – 50 dB(A) –

Individual offices (no disturbing noise) 40 – 45 dB(A) –

Hydrogen Sulphide H2S

The World Bank Group EHS Guidelines for Geothermal Power Generation provide examples for sources of occupational health and safety guidelines. These include those established by the Occupational Safety and Health Administration of the United States (OSHA). Other international standards include Icelandic workplace exposure limits for hydrogen sulphide (Icelandic Regulation No. 320 on Pollution and the working environment, 2009). These are presented in Table A.14. Both US and Icelandic standards are comparable to the Indonesian occupational health exposure limit presented in Table A.6.

In accordance with requirements of the World Bank Group General EHS guidelines, as the Indonesian occupational limit exists and is comparable with Icelandic standards and more stringent than relevant US standards referenced, it has been applied to assess the air quality impacts of the project at occupational receptors.



Table A.14: International Occupational Exposure Standards for H2S Organisation Averaging Period Value

Icelandic permitted concentration for occupational exposure 8 hours 14,000 µg/m

3

- 20ppm / 28,000 µg/m3 (Acceptable

Ceiling concentration) Occupational Safety and Health Administration of the United States Acceptable maximum peak above the

acceptable ceiling concentration for an 8 hour shift

50 ppm / 70,000 µg/m3



B.1. Introduction

B.1.1. Public Consultation and Disclosure Plan (PCDP) Objectives

Pertamina Geothermal Energy (PGE) applied for a grant from the Government of the Netherlands that has been provided through the World Bank. The purpose of the grant was to contribute to the cost of initial development of three of PGE’s geothermal power projects including the preparation of international Environmental and Social Impact Assessments for each of the three projects.

The scheme considered in this report is the Ulubelu Units 3&4 Geothermal Power Project (“the Project”) located in South Sumatra, Indonesia which is being considered for financing by the World Bank. The Project is comprised of two units with an output capacity of 55MW each (110MW in total). In addition, the Project will also encompass the development of a steam field for provision of geothermal energy to the power plant including four clusters of production wells and two clusters of reinjection wells. The Project is, at the time of writing, at drilling stage.

Environmental assessment for the purpose of permitting and compliance with Indonesian legislation is undertaken on behalf of PGE by a local university consultancy, Universitas Lampung (the Local Consultants). The AMDAL process (ESIA process) for the Project has been completed and approval from the Head of the Environment Agency of Lampung Province was issued on October 20, 2010.

PGE has appointed Mott MacDonald Limited (MML) to assist them in completing a full Environmental and Social Impact Assessment (ESIA) to international standards, in compliance with World Bank (project financier) procedures and guidelines. One requirement of international standards is the production of a Public Consultation and Disclosure Plan (PCDP) or Stakeholder Engagement Plan (SEP) to ensure that the appropriate consultation and engagement with the public and relevant stakeholders is undertaken.

In Indonesia, project related public consultation and disclosure is required under the AMDAL (national environmental permitting) process. Appropriate and meaningful consultation is also a key international finance requirement because it is integral to project planning and development.

This PCDP is a strategic document for planning a comprehensive and culturally appropriate approach to consultation and disclosure for the lifecycle of the Project. The purpose of this PCDP is to provide a consultation and participation strategy for the Project which: Identifies people or communities that are or could be affected by the project, as well as other interested

parties; Ensures that such stakeholders are appropriately engaged on environmental and social issues that

could potentially affect them through a process of information disclosure and meaningful consultation; Maintains a constructive relationship with stakeholders on an ongoing basis through meaningful

engagement during project implementation; and Meets legal requirements related to consultation.

The PCDP is underpinned by the principles that community engagement should be free of external manipulation, interference, coercion and intimidation, and conducted on the basis of timely, relevant, understandable and accessible information, in a culturally appropriate manner. Consultation activities should always be well planned and based on principles of respectful and meaningful dialogue.

Appendix B. Public Consultation and Disclosure Plan



B.2. Project Location and Description

The Project is located 80km west of Bandar Lampung, South Sumatra, Indonesia. The Project is located in proximity to the villages of Datarajan, Gunung Tiga, Karang Rejo, Pagar Alam, and Muara Dua. The Project area is located in the Tanggamus district which was separated by law in 1997 from the territory of the South Lampung District. The area is a cultivated (rice and plantations) undulating basin surrounded in the Western, Northern and Eastern sides by mountainous areas. The Project site is bordered by an area of watershed protection forest (Hutan Lindung) in the North (Gunung Rindingan) and South, especially on the elevated areas with steep slopes. A sand quarry is located in Datarajan.

The Project location is presented in Figure B.1, Project components in Figure B.2 and Project Area Features in Figure B.3.

Figure B.1: Project Location

Source: National Coordinating Agency for Surveys and Mapping

Project Location



Figure B.2: Project Component Scope

Legend:

Source: Mott MacDonald



Figure B.3: Project Area Features

Legend:

Source: Mott MacDonald



To utilise geothermal energy, production wells are drilled down into the heated water contained within the Earth's crust - the geothermal reservoir. Once these geothermal reservoirs are tapped into, the heated water and steam rise to the surface where the steam is separated and used to power steam turbines, which then generate energy that can be harnessed as electricity. Brine and condensate are returned via reinjection wells back to the geothermal reservoir.

During operation, the main process activities include: Steam production where steam is extracted, processed and also subsequently reinjected; Power plant, where the extracted steam is used to generate electricity; and evacuation of electricity via

transmission lines.

The Project consists of six clusters (groups of wells) and one power plant of two units (Units 3&4, 110MWe net). Each cluster will comprise one to six wells specific to the Project. Table B.1 summarises the currently identified Project components that form the focus of this ESIA for Ulubelu Units 3&4. The Feasibility Study concluded that for the Unit 3&4 power plant (a total of 16 production wells will be required. In addition, the total number of reinjection wells would be 4 large diameter wells for brine reinjection and a separate additional well would be needed for condensate reinjection. The three production wellpads (Clusters E, G and H) shown in Table B.1 below will eventually accommodate up to six production wells each. A further reinjection well will also be required beyond those currently identified in Table B.1. Land already acquired and estimates of land required for future acquisition are provided together with approximate location co-ordinates.

B.2.1. PCDP Structure

This PCDP is organised by sections to cover: Regulations and requirements; Review of consultation and disclosure previously carried out on the project; Identification of stakeholders; The disclosure and consultation implementation programme; Details of a timetable for consultation and disclosure; The grievance mechanism; and Monitoring and reporting requirements.



Table B.1: Main Project Components Easting Northing

Component WSG 84 Projection

Area (m2)

Land Acquired

Drilled/ Built

Power Plant Units 3&4 452945 9413488 81,982.04 Yes No

Well A3 (UBL-18) 453184 9411106 Yes Wellpad Cluster A (a) (Reinjection) Well A4 (UBL-22) 453188 9411100

22,236.00 Yes Yes

Wellpad Cluster B (a) (Production) Well B4 (UBL-15) 451995 9413499 52,144.00

(b) Yes Yes

Well E1 (UBL-10) 454291 9412758 Yes Wellpad Cluster E (Production) Well E2 (UBL-20) 454295 9412762

47,046.55 (b) Yes Yes

Well F2 (UBL-19) 454996 9412413 Yes Wellpad Cluster F (a) (Reinjection) Well F3 (UBL-21) 454998 9412406

31,115.68 (b) Yes Yes

Well G1 (UBL-23) 452477 9414224 Yes

Well G2 (UBL-24) 452477 9414217 No

Well G3 (UBL-25) 452481 9414210 No

Well G4 (UBL-26) 452482 9414204 No

Wellpad Cluster G (Production)

Well G5 (UBL-27) 452481 9414197

38,933.31 (b) Yes

No

Well H1 (UBL-28) 453128 9412412 No

Well H2 (UBL-29) 453130 9412405 No

Well H3 (UBL-30) 453133 9412399 No Wellpad Cluster H (Production)

Well H4 (UBL-31) 453135 9412392

56,442.38 (b) (f) Yes

No

Water Pumping Station 1 455207 9409056 260.00 Yes Yes

Water Pumping Station 2 452690 9413615 2,224.13 Yes Yes

Water Pumping Station 3 454322 9411387 9,345.33 (c) Yes Yes

500m Plant Connection to PLN Grid (Switchyard Unit 1&2) (d) (d) 2,150 No No

Production Pipeline Corridors (e) (e) 5,253.63 Yes No Notes: (a) Area information is for entire wellpad although only specific wells identified are dedicated to Units 3&4. (b) Includes area of road access. (c) Includes land acquired for the water supply pipeline corridor. (d) Exact routing not currently known. The transmission line will include at least three transmission towers each with a 20m

x 20m footprint and a line corridor width of 40m. The small area required for the tower bases and any area required to ensure the safe operation of the transmission line will be acquired by PGE through a fair negotiated settlement. In addition, compensation will be provided by PGE to secure the transmission line Right of Way.

(e) Routes between wellpads and power plant as indicated on Figure B.2. (f) Area acquired for Cluster H includes brine and condensate pipeline corridors to reinjection Clusters A and F.



B.3. Regulations and Requirements

B.3.1. Overview

This PCDP is undertaken to meet the legislation and policy regulations of the Government of Indonesia and to meet the information disclosure, consultation and stakeholder participation requirements of the World Bank. These requirements are summarised below.

B.3.2. National Consultation Requirements under the AMDAL Process

Public involvement was formally introduced into the AMDAL process through a decree by of the Head of the Environmental Impact Management Agency (EIMA or Bapedal) in 2000. This decree—No. KepDal 08/2000 covers transparency of information and allows for governors to be flexible in arranging further implementations at the provincial level according to context specificity. Four key objectives are addressed in the guidelines including: the protection of the community’s interests; community empowerment; transparency of the AMDAL process; and stakeholder partnership building. The guidelines also embody four overarching principles: (1) the equal position of AMDAL stakeholders; (2) transparency in decision-making; (3) equality in problem resolution; and (4) coordination, communication and cooperation among AMDAL stakeholders. The term ‘public involvement’ in the AMDAL process is interpreted as public participation in the decision making process.

Under Indonesian guidelines, consultation with the public is conducted during all stages of the project. Firstly, during the prearrangement stage of the project (before AMDAL documents are prepared); secondly during the Terms of Reference preparation; and thirdly through the public’s representative who sits on the AMDAL commission or makes written submissions to the commission. Once all the AMDAL documents have been prepared, the proponent presents those documents to the AMDAL commission for further review. Ahead of the review process, members of the public have one further opportunity to express their views and offer comments and suggestions.

B.3.3. International Consultation Requirements of the World Bank

Public consultation, disclosure and stakeholder engagement are key requirements of World Bank Environmental and Social Safeguard Policies. World Bank Operational Policy (OP) 4.01 Environmental Assessment states that for all Category A and B projects proposed for WB financing, during the ESIA process the borrower must consult project-affected persons (PAPs) and groups and local nongovernmental organizations (NGOs) about the project's environmental aspects and takes their views into account. The borrower must initiate such consultations as early as possible. For Category A projects - such as this project - the borrower must consult these groups at least twice: shortly after environmental scoping and before the terms of reference for the ESIA are finalized; and once a draft ESIA report is prepared.

In addition, the borrower consults and engages with such groups throughout construction and operation phases as appropriate about environmental and social considerations.

WB OP 4.01 also specifies information disclosure requirements. For meaningful consultations between the borrower and project-affected groups and local NGOs on all Category A and B projects, the borrower must provide relevant material in a timely manner prior to consultation and in a form and language that are understandable and accessible to the groups being consulted.



For a Category A projects, the borrower must provide for: The initial consultation a summary of the proposed project's objectives, description, and potential

impacts. For consultation after the draft ESIA report is prepared, the borrower must provide a summary of the

ESIA's conclusions.

For Category A projects, the borrower makes the draft ESIA report available at a public place accessible to project-affected groups and local NGOs.

Public availability in the borrowing country and official receipt by the WB of Category A reports for projects proposed for WB financing are prerequisites to WB appraisal. Once the borrower officially transmits the Category A ESIA report to the WB, the WB distributes the summary (in English) to the executive directors and makes the report available through its InfoShop (http://publications.worldbank.org) for a period of 120 days for interested parties to submit comments prior to the meeting at which the Bank's Executive Directors will decide whether to approve the project. The borrower can also make the report available through its own website.

B.4. Previous Public Consultation and Disclosure

B.4.1. Overview

PGE has actively undertaken various community engagement activities including information disclosure and public consultation. The sections below describe consultation activities carried out by PGE prior to and during the AMDAL and land Acquisition Processes. An overview is also provided of stakeholder responses to date and corporate responsibility activities of PGE. A chronology of subsequent activities carried out by the International Environmental and Social Consultants during the ESIA process is presented below and further discussed in Volume II.

B.4.2. Indonesian AMDAL Consultation

The Steamfield Development ANDAL report (2003) summarises the initial Socialisation (consultation) on the steamfield development carried out by PT PERTAMINA (PERSERO) on 13 September 2003. PLN (power plant) Units 1&2 ANDAL report (2004) discussed the socialisation carried out for the PLN Units 1&2 for which the socialisation events were held on 8th July, 31st July and 17th September 2004. Socialisation was carried out in accordance with the Indonesian Government’s regulations (discussed in Section B.3.2 above). These events revealed general local support and no opposition to the Project.

In 2010, PGE carried out socialisation for the ANDAL on the PGE Units 3&4 (and additional clusters beyond those addressed within the original Steamfield ANDAL) which included a public meeting on 11th January 2010. Adverts for this meeting were placed in newspapers, the ‘Lampung Post’ and ‘Media Indonesia’ on 21st and 31st December 2009 to inform people of the consultations and to encourage people’s participation. The process was aimed at gaining inputs from members of the community on the likely costs and benefits for local people. Stakeholders involved in the consultations included social/community leaders, district staff and village (Pekon) heads from villages in the Project area. At the village level, further consultation was carried out with members and leaders from the local community being involved.



B.4.3. Land Acquisition Consultation

One of PGE’s core land acquisition principles is:

“Land acquisition for development shall involve public participation commencing from the planning stage of development through to execution and the post-acquisition of land stage – all negotiations with the land owners are carried out collectively in a public location, and in the presence of village heads and community leaders, in an open and consultative manner without any coercion and with sufficient time for consideration of offers.”

In practice this means (in accordance with Indonesian Law) disclosing information about the project from the outset, and undertaking consultation with local community leaders and the land holders over local prevalent market prices and entitlements to compensation.

As summarised in Table B.1 above, all of the land required for the project has been acquired except for the 500m transmission line connection to the PLN substation. Land for Clusters A to H, the road network used for transport, the power plants and the interconnection pipes have been acquired in twelve acquisition efforts. The first acquisitions, Clusters A and B, were completed when PGE was a division of Pertamina; the remaining purchases were carried out by PGE as a separate entity, the last of which was concluded in October, 2010. The recorded land acquisition consultation activities undertaken by PGE are summarised in Table B.2 below.

Table B.2: Disclosure and Consultation Activities Undertaken as Part of the Land Acquisition Process Village Date Details of deliberations and land acquisition

Muara Dua (Unknown dater) 2008

Cluster C socialization on land acquisition plan

Muara Dua March 4, 2008

Cluster C land and crop negotiations; Negotiate the price of land, the community agreed to paddy fields Rp. 20,000, - and crops Rp.12.500

Muara Dua & Pagar Alam

(Unknown date) 2008

Cluster D and Roads socialization on land acquisition plan

Pagar Alam (Unknown date) 2008

Cluster E and Roads socialization on land acquisition plan

Pagar Alam & Air Abang

May 11, 2009 Cluster F socialization on land acquisition plan

Muara Dua May 11, 2009 Cluster G socialization on land acquisition plan

Muara Dua February 24, 2010

Cluster H socialization on land acquisition plan; Inform the community that the location of H will be located in Paddy fields; Communities agreed if their land would be released to the location of H and the entrance of location H.

Muara Dua March 12, 2010

Cluster H: Negotiate the price of land, the community agreed to paddy fields Rp. 20,000, - and crops Rp.12.500

Muara Dua May 7, 2010 Cluster H socialization on land acquisition plan (injection route from Cluster H to Cluster A). Communities agreed if their land would be released to the location of Injection pipeline

Muara Dua May 20, 2010 Cluster H and Injection Route : Negotiate the price of land (injection route from Cluster H to Cluster A)., the community agreed to paddy fields Rp. 20,000, - and crops Rp.12.500.

Source: PGE Land Acquisition Team



Although no details have been provided of previous consultation activities, the agreement and payments made for land and crops provide clear evidence that this was negotiated on a willing buyer – willing seller basis.

Additional consultation will be required for the 500m transmission line connection to the PLN substation at Units 1&2. This activity will be guided by the PGE Land Acquisition and Resettlement Policy Framework that has been produced. It outlines the methods PGE uses for disclosing information to and consulting with PAPs affected by land acquisition impacts.

B.4.4. ESIA Consultation and Disclosure Activities

The international ESIA team undertook two site visits during the ESIA process in order to inform the inception (scoping) processes, to assist PGE in disclosing the inception (scoping) findings to local communities and NGOs and to support PGE in gathering comments used to inform the preparation of the full ESIA: International ESIA Inception (Scoping) Site Visit Stakeholder Interviews between 22nd – 23rd March,

2010; International ESIA Main Site Visit Stakeholder Interviews between 13th – 15th June, 2010; International ESIA Main Site Visit Public Consultation and Disclosure Meeting on 14th June, 2010; Disclosure of the Draft ESIA for 120-days period commencing in September 2010; and Draft ESIA Consultation and Disclosure Event on 26th October 2010.

B.4.5. Community Investment Activities

PGE provides community investment to catalyse development benefits within the communities in which it operates. During the ESIA Scoping Site Visit community leaders expressed satisfaction at the level of investment PGE had undertaken in the area. The main benefit was seen as being the road, which had opened up the area to development. PGE have also had significant inputs into education, including investment in school buildings and teachers’ salaries, provision of scholarships, and school uniforms and bags. Water supplies have been installed into the villages and education programmes on road safety, disease and good sanitation have been implemented.

PGE has a Corporate Social Responsibility program targeted at five areas as shown below: Income Generation: 5% of the investments; Education: 33%; Infrastructure: 24%; Health: 19%; Environment: 19%.

In 2009 in Ulubelu, the following amounts were invested: Education: Rp. 1,187,991,000; Infrastructure: Rp. 101,773,000; Income generation: Rp. 46,000,000; Sponsorship: Rp.38,000,000.

For the remainder of 2010 and 2011, PGE’s community investment budget includes the following activities: Education: investment in school renovation totalling 250,000,000 Rp. and in scholarships, school

supplies and teacher education totalling 300,000,000 Rp; Agricultural assistance: investment in provision of fertilizer totalling 100,000,000 Rp; and



Community infrastructure: investment of 3,500,000,000 Rp. in road maintenance and upgrades; 600,000,000 Rp. in renovation of four Mosques (Karang Rejo, Gunung Tiga, Nurul Huda and Nur Falah); and, 30,000,000 Rp. to be invested in installation of clean-water distribution points.

B.5. Project Stakeholders

B.5.1. Overview

Stakeholder consultation is undertaken to determine the views of persons and organisations that may be affected directly or indirectly, positively or negatively, by the Project or that can affect the outcome of the Project.

A key step in successful stakeholder engagement is the identification of the various individuals or groups who (i) are affected or likely to be affected directly or indirectly by the project (“affected parties”), or (ii) may have an interest in the project (“other interested parties”). The process of identifying affected parties and other interested parties is summarised below.

B.5.2. Stakeholder Identification

To date PGE and Universitas Lampung (Local Consultants) have been involved in identifying and reaching out to stakeholders. Stakeholders identified to date during the development of the Project are summarised below in Table B.3. Additional stakeholders will be incorporated into the disclosure and consultation process. The Public Relations Officer (PRO) will keep a file with names and organisations and their contacts. As new stakeholders are identified they will be added to the list.

Table B.3: Stakeholders Identified for the Project Stakeholder Group Identified Stakeholders

National Government Ministries/Bodies

Kementerian Negara Lingkungan Hidup (Ministry of Environment); Directorate Energy, Ministry of Mines and Energy; Direktorat Jenderal (Ditjen) Energi Baru Terbarukan dan Konservasi Energi (EBTKE) (Directorate-General of New Energy, Renewable and Energy Conservation)

PLN/PGE Internal Stakeholders PLN Head office, Jakarta

Provincial/Regional Government Badan Lingkungan Hidup/BLH (Env Agency at Provincial and Regency Levels); Dinas Pertambangan dan Energy (Mines and Energy agency at Provincial and Regency levels); Dinas Pekerjaan Umum (Public Works Agency at Provicial and Regency Levels); Dinas Kehutanan (Forestry agency at Provincial and Regency levels); Dinas Sosial (Social agency at Provincial and Regency levels)

Local Government District Governor or Head of Kecamatan Ulubelu (sub-district); Head of Kepala Desa (villages leaders) in all locations

Local NGOs / Civil Society Laskar Merah Putih (Province), WALHI (NGOs) / Campaigners against power development in area at National and Provincial levels / PKK (Housewives association)

Local communities Community leaders and community members in the villages of Datarajan, Gunung Tiga, Karang Rejo, Pagar Alam, and Muara Dua.

Industry and Businesses Agriculture, livestock

Farmers Local Gapotkan representatives

Education Village school Heads

Local Universities/ academics Lampung University

Media Local News Paper (Lampung Post), Tribun Lampung,



B.6. Information Disclosure and Community Engagement

B.6.1. Overview

To date there has been a range of activities to disclose information and to exchange opinions. The Project is committed to information disclosure and community engagement throughout the project lifecycle. The sections below look at activities to be implemented during the rest of the drilling phase, and for the operation phase.

B.6.2. Information Disclosure

During the AMDAL process, statutory consultation requirements were met and efforts were made to facilitate local community participation in that process. However, insufficient data is available to document the information disclosure process. In addition, further activities were undertaken and efforts made to meet with parties indicating opposition to the Project. The key Project issues that local community members and local authority representatives need to fully understand relate to: What the technology is, in particular for operation phase, and how it differs from combustion power

plants; What the project components look like; What the effects on maize, ground nuts and crops production will be; and, What the effects on human health will be.

Disclosure of relevant Project information helps stakeholders understand the risks, impacts and opportunities of the Project. Sometimes information needs to be reiterated several times or described in various manners to help people understand projects better.

For the Ulubelu Units 3&4 Project consultation is carried out during the ESIA process. These are all described in more detail below.

B.6.3. Environmental and Social Impact Assessment (ESIA)

The ESIA, undertaken by MML, identifies the likely environmental and social effects associated with the proposed Project. The ESIA process requires the following activities relevant to public disclosure and consultation are undertaken: Public consultation event at the scoping stage of the ESIA to provide information about the project, the

ESIA approach and discuss key environmental and social issues; Public consultation on the draft ESIA report, providing an opportunity for comments on the report; and Production of a Non-Technical Summary of the ESIA.

ESIA Consultation activities and outcomes are fed back to the ESIA technical specialists and reported in the ESIA. MML produce these documents in English. The ESIA is translated into Bahasa Indonesia for distribution to stakeholders. The documents are made available for consultation and comments by PGE at their head office, site office and at the village head’s offices in the project affected area, for a period of 120 days. Additional consultation with individual stakeholders is undertaken by PGE where this is necessary to inform individual issues identified in the ESIA.



B.6.4. Media Communications

PGE has a Corporate Secretary responsible for media communication. All project team members should be made aware of this and all media requests or contacts should be directed to the Corporate Secretary who will manage media relations. This role will involve other team members as appropriate and will inform them of the key project messages that have already been identified. The Corporate Secretary has press release contacts and content templates which will be used as required. The Corporate Secretary will work closely with the Public Relations Officer who is responsible for the site.

B.6.5. Community liaison during Drilling, Construction and Operation

The PGE Public Relations Officer who is based on site has overall responsibility for managing consultation and disclosure for the Project. This includes the drilling, construction and operation phases. In addition, the contractors will be required (through contract clauses) to identify a Community Liaison Officer (CLO). The PRO should organise meetings with stakeholders (except for media), especially the local group leaders (for instance there are women’s groups, youth groups, village elders, religious leaders) and the elected and appointed local authorities to provide a regular opportunity to discuss any issues or concerns stakeholders may have. The PRO is the main point of contact for stakeholders.

The PRO, with assistance from the CLO, is responsible for logging grievances according to the grievance mechanism detailed below. The definition of a complaint or grievance in the context of this PCDP and additional requirements over and above the provisions of the existing procedure are discussed in more detail in Section B.8 below. The PRO works to close out grievances in a timely and satisfactory manner.

The PRO is responsible for producing annual summaries that provide details related to community investment activities and the use of the grievance mechanism. These are submitted to the Corporate Secretary for inclusion in the Project’s Annual Reports.

For the first four years of operation, an annual open day will be organised to allow local villagers to see the facilities functioning up close to improve local understanding of the technology.

B.6.6. Updating the PCDP

This PCDP should be reviewed annually by the Project Manager and Corporate Secretary to see if further activities need to be included and to address any changes to the Project or local context that may occur.



B.7. Implementation Timescales and Responsibilities

B.7.1. Overview

It is important that consultation and disclosure undertaken as part of the Project occurs at appropriate timescales to allow stakeholders to be informed and contribute to the appropriate management of environment and the development of the Project. This section assigns timescales and responsibilities to the activities identified in the previous section.

B.7.2. Implementation

The activities described above are presented in Table B.4 below with suggestions regarding when they were or should be implemented and the various people who have responsibility.

Table B.4: Information Disclosure Consultation and Community Engagement Schedule Activity Timing Responsibility

ESIA Pre-consultation March 2010 MML accompanied by PGE

ESIA –consultation event on scoping

June 2010 Material in English by MML Event arranged and advertised by PGE

ESIA – distribution of the draft report

October 2010 Final English version by Mott MacDonald NTS to be translated to Bahasa and distributed in project affected communities by PGE.

ESIA – consultation event on draft report

October 2010 Event arranged and advertised by PGE. PGE to inform the community of ESIA’s availability and location prior to the meeting.

Revised ESIA – distribution of report

March 2011 Final English version by Mott MacDonald To be translated to Bahasa and distributed in project affected communities by PGE. The ESIA should be made available at PGE’s headquarters, site office and Kepala Desa’s offices at each affected village.

Media communications As requested or when press releases deemed relevant

Corporate Secretary, Public Relations Officer

Stakeholder meetings during drilling and operation

Within the first three months and proactively as needed thereafter

Public Relations Officer

Community investment activities Annually Public Relations Officer, Corporate Secretary

Annual reports Annually Public Relations Officer, Project Manager, Corporate Secretary

Open days during operation Annually for at least the first four years Public Relations Officer, Project Manager, Corporate Secretary

B.7.3. Responsibilities

Specific documents related to the Environmental and Social Assessment are provided by MML and implementation support from the Local Consultants. PGE will be responsible for organising translation of documents other than the NTS into the local language and ensuring they are distributed to the appropriate stakeholders.



During drilling and operation, the PRO will be responsible for meeting with stakeholders and implementing the grievance mechanism. The PRO will pass media requests to and interact regularly with PGE’s Corporate Secretary. The PRO will document interactions with all stakeholders. The PRO will be responsible for logging grievances and working with PGE’s Project Manager and the contractor’s CLO to resolve them. The funding for the corporate investment activities will be approved by PGE’s Board and be managed by the Corporate Secretary.

B.8. Grievance Mechanism

B.8.1. Overview

A grievance can be defined as an actual or perceived problem that might give grounds for complaint. The sections below consider types of grievances, confidentiality and anonymity, and the Project’s grievance resolution process.

B.8.2. Current PGE Practice

At present PGE does not have a formally documented community grievance mechanism and resolution process. Grievances raised by community members, representatives or groups are not currently recorded by PGE, therefore no list of grievances and their associated resolutions has been provided for the purposes of this ESIA. PGE has stated however, that through the AMDAL consultation processes, it has been explained to the local communities that grievances can be submitted to the site manager. If grievances are not resolved to the complainant’s satisfaction they can then contact PGE’s Headquarters. It is not clear if contact details have been provided to the local communities.

Although there is currently no formal grievance process, evidence of grievance resolution can be found in PGE’s Corporate Social Responsibility activities (discussed in detail in Volume II) whereby PGE have invested in road infrastructure in response to community complaints regarding road surfaces being broken up by Project traffic (whether substantiated or not).

PGE has agreed to develop a community grievance mechanism for the project (all phases) and disclose this to the local community, as specified in the PCDP presented in ESIA Volume III and in the subsections below. PGE’s Project Manager with support from the Public Relations Officer has overall responsibility to manage grievance issues related to the Project.

B.8.3. Type of Grievances

Potential impacts and effects that are most likely to give rise to grievances for this Project are related to: Construction, drilling and steam venting noise; Presence of a construction labour force and the effects on neighbouring villages, local services and

infrastructure; Water resources and water pollution; Community health and safety, for instance in relation to impacts of increased traffic on nearby residents;

and, Damage to surrounding natural environment, including crops.

Anyone will be able to submit a grievance to the Project if they believe a practice is having a detrimental impact on the community, the environment, or on their quality of life. They may also submit comments and suggestions.



Grievances could include: Negative impacts on a person or a community (e.g. financial loss, physical harm, nuisance); Dangers to health and safety or the environment; Failure of PGE its sub-contractors and their workers or drivers to comply with standards or legal

obligations; Harassment of any nature; Criminal activity; Improper conduct or unethical behaviour; Financial malpractice or impropriety or fraud; and Attempts to conceal any of the above.

Grievances during construction will be investigated by PGE to review the validity and responsibility. The PRO or Corporate Secretary will explain in writing (or orally, where literacy is an issue) the manner in which the review was carried out, the results of the review, any changes to activities that will be undertaken to address the grievance or how the issue is being managed to meet appropriate environmental and social management systems and requirements.

B.9. Confidentiality and Anonymity

The Project will aim to protect a person’s confidentiality when requested and will guarantee anonymity in annual reporting. Individuals will be asked permission to disclose their identity. Investigations will be undertaken in a manner that is respectful of the aggrieved party and the principle of confidentiality. The aggrieved party will need to recognise that there may be situations when disclosure of identity is required and the Project will identify these situations to see whether the aggrieved party wishes to continue with the investigation and resolution activities.

B.10. Grievance Resolution

With implementation of the formal grievance mechanism, PGE logs grievances and the logging system will be formalised. A comments sheet will be produced by PGE’s Corporate Secretary for those wanting to make a complaint or comment, in addition to the route of writing to PGE, directly or through the village leader. Should any member of PGE’s staff receive an informal or formal verbal complaint, it must be written down and passed to the PLO for recording and follow up. PGE’s corporate procedure for grievances will be included in appropriate project communication materials such as the non-technical summary. In the first instance, grievances will be directed to the PRO (in some cases this may be via the contractor’s CLO) who will classify grievance according to Table B.5.

Table B.5: Grievance Classification Criteria Grievance Classification

Risk Level Validity Response

Low No or low Unsubstantiated PRO will conduct investigation, document findings and provide a response

Medium Possible risk and likely a one off event

Possible substantiation PRO and an appropriate investigation team (including contractors CLO) will conduct investigation. The Project/Site Manager may decide to stop work during the investigation to allow the corrective preventive actions to be determined. The PRO will provide a response.

High Probable risk and could reoccur

Probable substantiation

PRO will organise a Major Investigation Team including PGE for prompt investigation and resolution. Work will be stopped in the affected area. The PRO will provide a response.



The PRO will log the receipt of a comment, formally acknowledge it, track progress on its investigation and resolution, and respond in writing with feedback to the aggrieved party. The contractor’s CLO will initiate the investigation and ensure its speedy conclusion aiming to provide a response with 10 working days, unless there are exceptional circumstances. If the Project receives a large number of unsubstantiated grievances, the process will be reviewed to define instances when no response is needed.

PGE may hire an independent national consultant to investigate grievances if required, or to monitor environmental and social indicators during the operational phase; this independent company/consultant would play an important role in investigating the validity and responsibility for the grievance effect. Project staff, and outside authorities as appropriate, will also contribute to the investigation. The PRO and contractor’s CLO will collaborate to identify an appropriate investigation team with the correct skills to review the issue raised and to decide whether it is Project related or whether it is more appropriately addressed by a relevant authority outside the Project. The investigation will also aim to identify whether the incident leading to the grievance is a singular occurrence or likely to reoccur. Identifying and implementing activities, procedures, equipment and training to address and prevent reoccurrence will be part of the investigation activities. In some cases it will be appropriate for the PRO and contractors CLO to follow up at a later date to see if the person or organisation is satisfied with the resolution or remedial actions.

The PRO will summarise grievances to report on project performance bi-annually during construction (including drilling, SAGS and power plant) and annually during operation removing identification information to protect the confidentiality of the complainant and guaranteeing anonymity.

PGE Project Public Relations Representative: Mr, Anshoruddin

Address : Pekon Karang Rejo, Ulubelu District Tanggamus, Lampung Province - Indonesia

Tel : +62 21 39833316

Email: [email protected] / [email protected]

B.11. Monitoring and Reporting

This PCDP identifies various activities that require monitoring and reporting including the following: The progress / updating of the ESIA. PRO and contractor’s CLO activities: minutes of consultation meetings will be produced and all original

written consultation correspondence will be retained as evidence of the process and outcomes. Grievance logging and tracking: each grievance will be given an identification number and followed

through by recording details and timing for their resolution and closing out. Annual reporting: a Project specific annual report summarising project performance, PRO activities

including grievances, will be produced.

Public domain documents are to be distributed widely to stakeholders including regulatory agencies, project financiers local authorities and local communities.



C.1. Introduction

C.1.1. Background

Pertamina Geothermal Energy (PGE), a subsidiary of PT Pertamina (Persero), was established in 2006 as mandated by the Government of Indonesia (GoI) to develop 15 Geothermal Business Working Areas in Indonesia.

Geothermal power is a clean and efficient alternative for diversifying Indonesia’s electricity generation mix. Indonesia has the world’s largest geothermal potential that could fuel about 27,000 MW of generation capacity. However, the resource makes up only 3.2 percent of the present generation capacity.

The GoI has requested a loan from the World Bank (WB) to support the development of up to 370 MW of capacity. The designated implementing agency is PGE who has requested the WB to assist with finance investment in two sites at an advanced stage of preparation: Ulubelu Units 3&4 in Lampung Province, Sumatra, and Lahendong Units 5&6 in North Sulawesi

The development objective of the proposed WB investment is to increase the utilisation of clean geothermal based electricity in order to reduce pollution and improve the environment. This will be achieved through: a) development of geothermal power generation capacity in fields under the control of PGE, and b) strengthening the institutional capabilities of the company through technical assistance and capacity building so that PGE can contribute to sector development on a sustained basis.

The bulk of project investment will be devoted to establishing up to 150 MW of power generation capacity (Ulubelu Units 3&4 and Lahendong Units 5&6) which will include the confirmation of resources, production drilling, development of the steam gathering systems, and the construction of the power plants. Upon completion, PGE will be in a position to sell geothermal power into the national electricity grid in order to meet growing electricity demand in an environmentally friendly manner.

Pertamina has been working in Ulubelu since the mid 1990s undertaking preliminary exploration surveys. Since the establishment of PGE in 2006 as a subsidiary of Pertamina, PGE progressed with developing a number of clusters, drilling wells and preparing the roads and other infrastructure needed to start production. Lahendong Units 5&6 is actually located on the Tompaso field which is located near PGE’s existing Lahendong field in operation since 2000. Work in the Tompaso field (registered as Lahendong Units 5&6) started in 2007, resulting in two production clusters and one reinjection cluster.

C.1.2. World Bank Operational Policy 4.12 (Involuntary Resettlement)

Land for all facilities will be, or has been acquired by PGE. Since PGE is legally registered as a private company, it acquires land through direct negotiations, based on the principle of willing buyer-willing seller. However, PGE can request expropriation if negotiations fail and if no viable alternative siting exists. Therefore, the World Bank Operational Policy (OP) 4.12 (Involuntary Resettlement) would be triggered, for which PGE has prepared this Land Acquisition and Resettlement Policy Framework, which describes in detail PGE’s land acquisition procedures as well as steps that will be taken under expropriation. OP 4.12 includes safeguards to address and mitigate against impoverishment risks associated with any land acquisition or involuntary resettlement under development projects.

Appendix C. Land Acquisition and Resettlement Policy Framework



The primary objective of this Land Acquisition and Resettlement Policy Framework and Note is to provide details of the land acquisition procedures employed by PGE on both project sites to date, as well as an indication as to the expected land acquisition required for the remainder of the Project. This demonstrates that PGE practices follow the principle of willing buyer-willing seller. A secondary objective is to provide detailed procedures that will be applied if PGE requests the expropriation of any land, as well as requirements for reporting to the World Bank to ensure and demonstrate compliance with OP 4.12.

Although this policy framework is intended to provide a framework for land acquisition and resettlement impacts associated with these specific projects, it is also intended to provide an overarching framework for land acquisition relevant to any future project that PGE pursues.

Resettlement in this document refers to the direct economic and social impacts that are caused by the involuntary taking of land which results in relocation or loss of shelter, loss of assets or access to assets, or loss of income sources or means of livelihood whether or not the affected persons must move to another location. The Bank policy also refers to the involuntary restriction of access to legally designated parks and protected areas resulting in adverse impact on the livelihoods of the displaced persons.

C.1.3. Report Structure

PGE has prepared this Land Acquisition and Resettlement Policy Framework (LARPF) as a means to demonstrate compliance with both national laws and regulations and international best practice as exemplified by WB OP 4.12. The document consists of two main sections: 1. Firstly, an outline of PGE’s Land Acquisition and Resettlement Policy Framework which includes

acquisition principles and corporate and field-level institutional and management arrangements by PGE Land Acquisition Teams. A detailed description of PGE’s actual approach to land acquisition through negotiated settlement is provided. In addition, by law PGE may request the Government to expropriate land through eminent domain1 (under the Presidential Regulation, Perpres 65/2006) as a last resort. The LARPF also includes procedures in order to ensure compliance with WB OP 4.12.

2. Secondly, a description of land acquisition and asset compensation undertaken to date as well as the land acquisition anticipated to complete Ulubelu Units 3&4 and Lahendong Units 5&6 sites. Additionally, a comparison of the variation in prices paid for land and trees/crops across time and between locations is provided.

The document is based upon known information at the time of writing and is intended to be a live document that can be updated and modified to reflect changes in law and/or acquisition status.

_________________________ 1 Eminent domain is the right of the state to acquire land, using its sovereign power, for public purposes. National law establishes

which public agencies have the prerogative to exercise eminent domain.



C.1.4. Resettlement Policy Framework – WB OP 4.12

This Land Acquisition and Resettlement Policy Framework corresponds with the requirements of a Resettlement Policy Framework, the components of which are described in WB OP 4.12 Annex A (paragraphs 23 – 25) and are shown below:

(a) a brief description of the project and components for which land acquisition and resettlement are required, and an explanation of why a resettlement plan as described in paras. 2-21 or an abbreviated plan as described in para. 22 cannot be prepared by project appraisal;

A project description is provided as part of the projects specific information in Section 2 of the ESIA Volume 2. No resettlement has occurred to date and none is envisaged at this stage. Should expropriation or resettlement be required at a later stage, an outline of the requirements of an ARAP and a RAP is provided in C.5 and a framework for resettlement is provided in this document.

(b) principles and objectives governing resettlement preparation and implementation;

PGE’s principles for land acquisition are outlined in Section C.2.2.

(c) a description of the process for preparing and approving resettlement plans;

Section C.2.5 provides details on the necessary pre-requisites and procedures for resettlement planning should it be required.

(d) estimated population displacement and likely categories of displaced persons, to the extent feasible;

Section C.3.3 gives information regarding the land acquisition needed for the remainder of the Ulubelu 3&4 and Lahendong 5&6 projects. Details on the number of affected persons are yet to be established; no persons are expected to be displaced.

(e) eligibility criteria for defining various categories of displaced persons;

Eligibility for entitlements is discussed in Section C.2.5.10.

(f) a legal framework reviewing the fit between borrower laws and regulations and Bank policy requirements and measures proposed to bridge any gaps between them;

The legal framework is reviewed in Section C.2.1.

(g) methods of valuing affected assets;

Section C.2.5.7 describes the establishment of an independent assessment to value affected assets if there is expropriation.

(h) organizational procedures for delivery of entitlements, including, for projects involving private sector intermediaries, the responsibilities of the financial intermediary, the government, and the private developer;

Organisational procedures, roles and responsibilities are detailed in Section C.2.3.



(i) a description of the implementation process, linking resettlement implementation to civil works;

The implementation process is presented in Section C.2.5.19.

(j) a description of grievance redress mechanisms;

This is described in Section C.2.5.16 and draws on the grievance mechanism presented in the Public Consultation and Disclosure Plan for the ESIA for the project (Appendix B, Volume III), which will be disclosed when completed.

(k) a description of the arrangements for funding resettlement, including the preparation and review of cost estimates, the flow of funds, and contingency arrangements;

Issues of funding are addressed by Section C.2.3 and Section C.2.5.18 discusses cost estimation in the event of expropriation or involuntary resettlement. Examples of prices paid for land and assets for the two sub-projects (Ulubelu 3 &4 and Lahendong 5&6) are shown in Sections C.3.1 and C.3.2.

(l) a description of mechanisms for consultations with, and participation of, displaced persons in planning, implementation, and monitoring; and

Consultation with project affected persons (PAPs) is a key element of this Land Acquisition and Resettlement Policy Framework and is an inherent part of PGE’s existing practices. This document discusses consultation in Section C.2.4.2, which describes PGE’s current procedures of negotiated settlement, and in Section C.2.5.6 which describes the processes required for consultation when expropriation of land becomes necessary.

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