If AMDAL is Abolished, What is the Best Solution for the Environmental Feasibility Study in Indonesia?

What is AMDAL

AMDAL is a study of the significant impacts of a business plan and activities on the environment. The purpose is to guarantee that a business or development activity can run sustainably without damaging the environment. Read more about AMDAL.

Progress on the Government’s Plan on the Abolishment of AMDAL in Indonesia

Discourse on the elimination of Environmental Impact Analysis – Analisis Dampak Lingkungan (AMDAL) and Building Permit – Izin Mendirikan Bangunan (IMB) has sparked controversy among investors, government, and environmentalists. All of them have strong and different opinions. The news about Jokowi’s objection to the complexity of the development permits for investors is one of the reasons why AMDAL and IMB are planned to be removed.

AMDAL and IMB licensing bureaucracy are planned to be simplified included in the Detailed Spatial Plan – Rancangan Detail Tata Ruang (RDTR). The recommendation to use RDTR as a way to evaluate the environmental impacts in Indonesia is done to help make investment easier for business actors in Indonesia.

Based on the Peraturan Menteri – Ministerial Regulation of ATR / BPN No. 16/ 2018 concerning Guidelines for Preparation of Detailed Spatial Plan and Regency / City Zoning Regulations, the definition of Detailed Spatial Plan –  Rencana Detail Tata Ruang (RDTR), is a detailed plan on regency/city’s spatial areas complemented by regency/city zoning regulations. RDTR is valid for 20 years and will be reviewed every five years. The review can be done more than once in five years if there is a strategic environmental change in the form of large-scale natural disasters or changes in regional territorial boundaries.

The illustration of factory waste. Source: Pinterest.com

Pros and Cons of AMDAL Abolishment

According to the Director General of Spatial Planning of the Ministry of Agrarian Affairs and Spatial Planning or the Head of BPN Abdul Kamarzuki, AMDAL is no longer needed because, in the spatial planning, both through the Regional Spatial Planning – Rencana Tata Ruang Wilayah (RTRW) and Detailed Spatial Plan – Rencana Detail Tata Ruang (RDTR), aspects regarding AMDAL have been considered.

Various pros and cons arise from various groups. Deputy Department of Walhi, Edo Rahman said, the discourse on the elimination of RDTR was more urgent than eliminating IMB and AMDAL. Edo stated that the existence of RDTR was often ignored by the government, he also added that in reality, according to ATR/BPN,  from approximately 514 districts and cities, only 53 districts and cities have RDTR. Edo concluded from the data that the regional government did not require the RDTR to be implemented in their region.

Opinion against the abolishment of AMDAL is not only expressed by Edo, but also by the economist Prof. Emil Salim, who stated that AMDAL and IMB often become a source of corruption. According to him, it is not AMDAL and IMB that must be removed, but rather things that complicate the bureaucracy in making AMDAL and IMB that needed to be resolved.

“I asked the officials in the government, why would AMDAL be discarded? He replied that AMDAL is made with good intentions, but the fact is that AMDAL was bribed, overpowered by businessmen. AMDAL became a source of corruption,” Emil said.

On the other hand, an opinion that is in favor of the discourse on the elimination of AMDAL was stated by the Chairperson of the Industrial Estate Association – Himpunan Kawasan Industri (HKI) Sanny.

“Both IMB and AMDAL have been a scourge for our businesses. AMDAL is always identical with long and winding processes, expensive fees, and so on,” he said.

The argument of using RDTR as a simplification of AMDAL and IMB cannot be accepted by environmentalists or groups who are opposed to the discourse of eliminating AMDAL and IMB. The point that makes  AMDAL irreplaceable is that the AMDAL hold specific responsibility for an activity, while the RDTR focuses more on urban/strategic area.   

The comparison above is relevant to the statement made by Bogor Mayor Bima Arya who made a firm rejection to the discourse on the elimination of AMDAL and IMB. He considered that the IMB and AMDAL are still needed because there is not yet a qualified monitoring system. Besides, the abolition of the two permits was deemed to only worsen the regional development arrangements.

Solution for Environmental Feasibility Study  from Waste4Change

From the interviews we did with Muhammad Fariz, Solid Waste Management Specialist of Waste4Change, the bottom line of the AMDAL and IMB controversy is because the process is considered too long and thereby inhibiting investment.

This long process, according to Fariz, was caused by many revision processes that needed to be carried out by the AMDAL drafting team during the AMDAL evaluation commissioning session. The number of revisions is often due to a lack of primary data presented and also the analysis that is not detailed. The competence of the AMDAL drafting team also needs to be improved in terms of the assessment and certification process so the team that compiles the AMDAL has good competence and integrity.

Interviewees Muhammad Fariz, Solid Waste Management Specialist Waste4Change

When AMDAL improvement is carried out, it is hoped that the previous AMDAL process can be more effective so that investment can run effectively but at the same time environment protection and sustainability can also be maintained. If the discourse of  AMDAL abolishment is crystallized, combined with the RDTR document, RDTR can be optimized by accommodating all forms of protection and monitoring of all types of business activities, not only those that promote the general and certain regions. Primary data collection for environmental conditions (baseline) also needs to be done by the RDTR drafting representative asking for a revision of the AMDAL document into the RDTR Document review.

Responding to the statement from the Indonesian Forum for the Environment – Wahana Lingkungan Hidup Indonesia (Walhi), which stated the RDTR was more urgent to be removed, Fariz explained that if we refer to their needs, both of them were still needed, but the RDTR covered more universal regulations and was more regulated in terms of spatial planning, which in it regulates economic aspects, population, physical area, and a more limited area of coverage. So, if we refer from the side of its implementation for evaluating the environmental feasibility of an area, the RDTR document needs to be optimized.

Feasibility of Waste Management Regulated by AMDAL and RDTR

The existence of Law No. 4/1982 concerning Basic Provisions for Environmental Management which was later updated with Law No. 23/1997 on Environmental Management is expected to be able to answer future challenges concerning the use of the environment, including the problem of municipal waste management.

According to Fariz, the current AMDAL is still not enough to become the only reference for managing a company’s waste/activities. The elements related to waste management that is regulated by AMDAL are mostly the activities of collecting, transporting, disposing of garbage and scheduling the transportation of waste or in another word, only governs about waste management in general. Whether or not an AMDAL is going forward for a more specific waste study, Fariz hopes that both AMDAL and RDTR encourage a more comprehensive study related to waste management.

Regardless of the requirements for waste management documents governed by the AMDAL or RDTR for permits of conducting businesses or activities that have an environmental impact in an area, detailed and qualified studies and planning of waste management are important for the sustainability of a business and environmental sustainability. Waste4Change also provides Solid Waste Management Research (Studi Pengelolaan Sampah) service to help in the planning and implementation processes of waste management for a business/non-business activity so that it can participate optimally in efforts to sustainably conserve the environment.

Waste4Change can contribute to help optimizing the study of waste and accommodate the better implementation of planning, by providing accurate planning for the next five or ten years with consideration of the possibilities that will occur such as the addition of employees or the development of the company.








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