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PT Perusahaan Listrik Negara (Persero)

$617.5 million
Renewable Energy
Environmental and Social Review Summary

Environmental and Social Review Summary

This Environmental and Social Review Summary (ESRS) is prepared by MIGA staff and disclosed prior to the date on which MIGA’s Board of Directors considers the proposed issuance of a Contract of Guarantee. Its purpose is to enhance the transparency of MIGA’s activities. This document should not be construed as presuming the outcome of the decision by MIGA’s Board of Directors. Board dates are estimates only.

Any documentation that is attached to this ESRS has been prepared by the project sponsor, and authorization has been given for public release. MIGA has reviewed the attached documentation as provided by the applicant and considers it of adequate quality to be released to the public, but does not endorse the content.

MIGA has been approached by potential lenders to provide a Non-Honoring of Financial Obligations by a State-Owned Enterprise (NH-SOE) guarantee for a proposed facility (the Facility) to Perusahaan Listrik Negara (PLN), the power sector state-owned enterprise (SOE) in Indonesia. Under MIGA’s COVID-19 Response facility, the proceeds of the Facility will be used by PLN to make payments under existing Power Purchase Agreements (PPA) to eligible Independent Power Producer (IPPs) (hereafter referred to as ‘the Project’). Eligible IPPs include IPPs that are currently operational, were supported by Development Finance Institutions (DFI) and were subject to public disclosure. Consistent with World Bank operational guidance and MIGA’s Exclusion List, eligible IPPs do not include coal-fired or nuclear power stations. IPPs that have been identified as eligible to receive proceeds of the Facility are summarized in the table below, followed by a brief description of PLN and each IPP.




Installed Capacity

Type of Project

Rajamandala Electrik Power


47 MW


PT Bajradaya Sentranusa (Asahan 1)


180 MW


Ulubelu Unit 3


55 MW


Ulubelu Unit 4


55 MW


Lahendong Unit 5


20 MW


Lahendong Unit 6


20 MW


Sarulla PLTP


110 MW



PLN is the integrated utility in Indonesia, responsible for electricity generation, transmission and distribution. As of the end of March 2020, PLN owned more than 72.5% of power generation capacity in Indonesia (approximately 45.8 Gigawatt (GW) of installed capacity), 100% of transmission lines (approximately 59,218 km) and 100% of the distribution network (approximately 988,600 km) serving approximately 76.5 million customers. PLN’s business lines include: (i) planning and development activities of electric power facilities; (ii) construction of electricity infrastructure; (iii) utilization and commercialization activities of power plants, including operation of its own plants, purchase of power from IPPs and electricity transmission and distribution to customers; and (iv) research and development. As of March 31. 2020 PLN employs approximately 53,737 staff throughout its regional operating segments (Sumatra; Western Java; Central Java; Eastern Java Madura and Bali, Kalimantan; Sulawesi; and Maluku Papua and Nusa Tenggara). PLN is comprised of 15 regional units, 7 distribution units, 3 generation units, 3 transmission units, 2 generation and transmission units, 18 construction units, 2 dispatching center units and 6 service/supporting units. Two divisions in headquarters are responsible for planning IPP projects (IPP Division and New and Renewable Energy Division) and regional operation divisions are responsible for the monitoring IPP projects during the operations phase.

The Rajamandala Hydropower Project is a 47 megawatt (MW) run-of-river hydropower plant developed on a build-operate-transfer basis. The project is located within a cascade of existing hydropower plants, between the 700 MW Saguling and 1,008 MW Cirata power stations, along the Citarum River in West Bandung Regency and Cianjur Regency, West Java Province, Indonesia (approximately 200 km south-east from Jakarta). MIGA provided a guarantee in August 2014, which is still active (see link to ESRS). Rajamandala was completed in 2019.

Asahan 1 is an operational (completed in 2010) 180 MW run-of-river hydropower plant, which is part of a three-dam cascade. The plant is located 25 km downstream of Lake Toba on the Asahan River in North Sumatra, and 230 km southeast of the city of Medan. IFC made an initial investment in 2014, and consideration of a second investment was disclosed in 2018, and the loan agreement was signed in March 2020 (see link to ESRS ).

Ulubelu Units 3 and 4 are operational geothermal power plants in Ulubelu, Lampung Region, South Sumatra, which is owned and operated by Pertamina Geothermal Energy (PGE), a subsidiary company of Pertamina, a state-owned oil and gas company. Unit 3 (55 MW installed capacity) started operations in July 2016 and Unit 4 (55 MW installed capacity) in March 2017. Lahendong Units 5 and 6 are also operational geothermal power plants that are owned and operated by PGE in the Minahasa district, North Sulawesi Province. Unit 5 (20 MW) started operations in September 2016 and Unit 6 (20 MW) started in December 2016. PGE received a $300m loan from the World Bank for developing the 110MW Ulubelu geothermal energy facility and the 40MW Lahendong geothermal project as part of the Geothermal Clean Energy Investment Project (P113078).

The Sarulla Geothermal Power Plant is a 330MW geothermal power plant comprised of three 110 MW units, which became operational in March 2017, October 2017 and April 2018 (respectively). The plant is located in Pahae Julu and Pahae Jae Districts, North Tapanuli Regency, North Sumatra Province and is owned and operated by Sarulla Operations Limited (SOL), a consortium of Medco, Itochu, Kyushu, INPEX and Ormat. The Asian Development Bank (ADB), Japan Bank for International Cooperation (JBIC) and six other commercial banks provided $1.17 billion in financing in March 2014 (refer to ADB public disclosure on the project).

As these IPPs all benefited from DFI financing, it is understood that international standards consistent with the objectives of MIGA’s Performance Standards (PS) were applied to the design, construction and operation of the projects; however, for this Project, PLN will have no control and only limited leverage to enforce MIGA’s environmental and social (E&S) requirements on the IPPs. Therefore, this ESRS will describe PLN’s corporate level E&S Management System (ESMS), and their mechanisms and capacity for monitoring and enforcing the E&S requirements in the PPAs.


The Project is categorized as Category B according to MIGA’s Policy on Environmental and Social Sustainability (2013) because E&S risks and impacts of the use of proceeds are limited, site-specific and can be minimized, avoided or mitigated by adhering to generally recognized performance standards, E&S Management plans and procedures, Environmental Health and Safety (EHS) guidelines and / or design criteria.

The most significant potential E&S risks are related to PLN’s institutional E&S capacity to monitor and enforce E&S requirements in PPAs on Sub-Projects and management of labor risks, including those associated with COVID-19. Other indirect E&S risks include those associated with the operation of Sub-Projects, including environmental, health and safety performance of the current operations and compliance with permitting requirements.

While all Performance Standards are applicable to this investment, based on our current information, the investment will have impacts which must be managed in a manner consistent with the following Performance Standards:

  • PS1:  Assessment and Management of Environmental and Social Risks and Impacts
  • PS2:  Labor and Working Conditions
  • PS3:  Resource Efficiency and Pollution Prevention
  • PS4:  Community Health, Safety and Security

As the MIGA-guaranteed financing will be used for PLN’s payment obligations under existing PPAs and will not result in any capital expenditure or expansion of sub-projects, PS 5 Land Acquisition and Involuntary Resettlement, PS 6 Biodiversity Conservation and Sustainable Management of Living Natural Resources, PS 7 Indigenous Peoples and PS 8 Cultural Heritage do not apply. While some of these PSs apply to the underlying sub-projects, PLN’s ability to monitor and enforce potential impacts related to these PSs are covered under PS 1.

In addition, the following World Bank Group Environmental, Health, and Safety (WBG EHS) Guidelines are applicable to the Project:

  • General EHS Guidelines (2007)
  • EHS Guidelines for Geothermal Power Generation (2007)
  • EHS Guidelines for Electric Power Transmission and Distribution (2007)

The following documents were reviewed by MIGA:

  • PLN Annual Report 2019
  • PLN Sustainability Report 2019
  • Proposed PLN Guidelines on Environmental Safeguards for Development of Electricity Infrastructure (Unpublished draft, November 2019)
  • Indonesia: PLN Agency-Level Use of Country Safeguard Systems Equivalence Assessment of Environmental Safeguards (October 2019)
  • Indonesia: PLN Agency-Level Use of Country Safeguard Systems Equivalence Assessment of Social Safeguards (October 2019)
  • Indonesia: PLN Agency-Level Use of Country Safeguard Systems Acceptability Assessment of Environmental Safeguards (October 2019)
  • Indonesia: PLN Agency-Level Use of Country Safeguard Systems Acceptability Assessment of Social Safeguards (October 2019)
  • Publicly available E&S information on sub-projects (refer to links in Section A)

In addition to reviewing the above documents, MIGA also reviewed available documents (including the E&S provisions in the PPAs) related to the sub-projects (see links to relevant publicly available documents in the Project Description section). MIGA also carried out virtual E&S due diligence with relevant staff from PLN in June 2020, including meetings with key E&S staff and management. Prior to the virtual due diligence, MIGA sent an E&S due diligence questionnaire to PLN, which provided the basis for discussion. To get an understanding of potential legacy risks and the current E&S performance and compliance status of sub-projects, MIGA held meetings with WB and IFC E&S specialists and ADB E&S Specialists.

MIGA’s due diligence review considered the E&S management and documentation for the Project and identified gaps (if any) between these and MIGA’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable time period, are summarized in the paragraphs that follow and, in the E&S Action Plan (ESAP) attached to this ESRS.  Through the application of these measures, the Project is expected to be implemented in accordance with the MIGA Performance Standards and applicable WBG EHS guidelines.

Key E&S issues associated with the Project business activities are summarized in the paragraphs that follow.

PS1:  Assessment and Management of Environmental and Social Risks and Impacts

Environmental and Social Assessment and Management System:

PLN has a corporate overarching E&S policy and guidelines, which provide a framework under which individual units develop their own Environmental and Social Management Systems (ESMS). PLN units are individually International Standard Organization (ISO) certified: at the end of 2019, 31 units were ISO 14001:2015 (Environmental Management System) certified; ii) 2 units were certified in ISO 50001:2012 (Energy Management System) and, iii) 55 units were certified in ISO 9001: 2008 (Quality Management System) certified.

The units responsible for the planning, preparation, monitoring and enforcement of PPAs (IPP Division, New and Renewable Energy Division and Regional Operation Divisions) have systems in place for monitoring operational performance of IPPs, but this monitoring does not currently include E&S compliance. All PPAs have E&S requirements, which require IPPs to have the required environmental permits and follow the prevailing national regulation. Monitoring and enforcement of those requirements is conducted by the corresponding regional environmental authority. As a condition of the Contract of Guarantee, PLN will develop a procedure to undertake an at least annual review of the E&S compliance status of IPPs (ESAP item).    


PLN’s commitment to environment, health and safety is stated in its policy on Occupational Health, Safety and Security and Environmental Protection (OHSSE) (2015). This policy provides a framework for overall OHSSE management for all PLN’s activities, including activities of its subsidiaries and contractors. The policy includes principles related to prioritization of OHS and environmental protection, compliance with relevant laws and regulation, identification of risks, capacity management, and stakeholder engagement.

The OHSSE Policy is communicated directly to employees when they are appointed, and through induction and regular training and awareness events.

Identification of Risks and Impacts:

For all new projects, PLN undertakes environmental screening in line with Indonesian environmental Law no. 32/2009 1997 (“Environmental Law”) for management and protection of environment. The Environmental Law identifies three types of environmental documents based on type and scale of proposed activity and environmental sensitivity of the project site and surrounding areas. A full E&S Impact Assessment (ESIA, referred to as Analisis Mengenai Dampak Lingkungan (AMDAL)) and Environmental Management and Monitoring Plan (EMP-EMoP, referred to as RKL-RPL) is required for projects expected to cause significant environmental and / or social impacts. Environmental management and monitoring measures (referred to as UKL-UPL) are required for projects that are not expected to cause significant environmental and / or social impacts, but still require an environmental permit; and an environmental management commitment letter is  required for projects that are not required to prepare an AMDAL or UKL-UPL or obtain environmental permits. Permits, which are issued once the government approves the AMDAL or UKL-UPL, contain limits or conditions that a project must follow during the construction, operations and maintenance phases.

In addition to national requirements, in cases where projects are financed by an international lender, PLN requires the project to use international standards for environmental assessment, design and technology, and emission, effluent and waste management in line with the requirements of the relevant lender(s).

All of PLN’s existing and operating subprojects, as well as the IPPs that will benefit from the proceeds of the MIGA-guaranteed facility completed project-level ESIAs prior to development in line with Indonesian environmental laws and regulations and have the appropriate environmental permits in place. As indicated in the Project Description above, all of the IPPs were supported by DFIs, and therefore applied international standards (e.g. World Bank or Asian Development Bank safeguards or IFC or MIGA Performance Standards) to their project-level ESIA, design and implementation. Except for the two units at the Sengkang Combined Cycle Power Plant, ESIAs for the sub-projects have been publicly disclosed by the relevant DFI. 

Management Programs:

To facilitate implementation of the ESMS, PLN has developed associated policies, procedures and programs, which ensure appropriate identification and management of E&S risks and impacts for new projects being developed and at existing projects that are under operations. In October 2018, PLN developed Environmental Protection and Management Guidelines (PPLH), which describes the internal and external stakeholders’ involvement in environmental management and explains the requirements for environmental permits. PLN also recently developed and updated proposed Environmental Safeguard Guidelines (ESG) (Draft Version November 2019) with support from the ADB to guide assessment and management of PLN projects. The ESG describes PLN’s current approach to E&S safeguards and provides processes and methods to enhance the current approach to meet ADB’s safeguard policy requirements. The ESG is primarily intended to be used for projects with ADB financing and has not yet been implemented. 

Individual projects, requiring an AMDAL are also required to prepare an RKL-RPL describing mitigation measures, standards to be used as reference, frequency and timing of mitigation measures (implementation schedule), who is responsible to implement the mitigation measures, as well as reporting and monitoring obligations. Once environmental permits are issued, the implementation of the UKL-UPL or RKL-RPL is the full responsibility of PLN (for PLN owned and operated projects) or the IPP. ADB’s recent review of PLN’s E&S capacity and implementation of its ESMS indicated that PLN has extensive experience in operating and managing power plants; however, the E&S performance of PLN’s plants vary. Some of its powerplants have participated in the Program for Rating the Performance of Companies in Environmental Management (PROPER), which is a government program that rates industrial operations based on their environmental performance. PLN plants have received ratings of blue (compliant), green (beyond compliance) and even gold (highest rating). Some of PLN’s powerplants have ISO 14001 certifications on environmental management; however, not all PLN facilities utilize such environmental management systems, and some facilities lag behind in their E&S performance. PLN has indicated that they are committed to increasing the number of facilities that apply comprehensive ESMSs.

As per government requirements, the sub-projects developed RKL-RPLs as part of the ESIA (AMDAL). Available information on DFI websites indicates that the management plans in place include specific plans related to; air quality, noise, waste management (non-hazardous and hazardous materials); emergency preparedness and response, water management, wastewater management, OHS, biodiversity; stakeholder engagement and established community grievance procedure through which all complaints shall be reported, recorded, and investigated. Discussions with PLN and available monitoring reports indicate that the sub-projects are in compliance with national laws, regulations and environmental permit requirements. 

Organizational Capacity and Competency:

PLN is a large institution with headquarters in Jakarta and regional offices spread throughout the country. The headquarter office holds various corporate responsibilities, including Division of Health, Safety, Security and Environment (DIVHSSE) under the Directorate of Human Capital Management. The Occupational Health and Safety and Environment (OHSE) team within DIVHSSE has a total of 25 staff and is subdivided into 5 sub-units: (i) environmental operational management, (ii) environmental planning management and (iii) E&S safeguards and climate change management (iv) Occupational Health and Safety and (v) Security. At the regional level, the total number of OHSE staff is 1,768. Development of powerplants starts with the initial design process by the Engineering team, currently within the corporate division for project development. Assessment of new projects, including site selection is undertaken by OHSE teams within development units (UIPs) in the regions with technical support from DIVHSSE, as required. Once new facilities are fully constructed, E&S responsibilities are transferred to operating units within the regions. With respect to IPPs, the regional operation divisions that manage PPAs upon the commercial operation of the facilities do not have any OHSE staff; however, the environmental operational management unit in HSSE division provides support for the monitoring of E&S requirements, as needed.

PLN has training programs in place, including a Capacity Development Master Plan, to ensure that staff are familiar with the ESMS and associated plans, procedures and manuals. PLN also ensures that all E&S personnel are qualified and competent to carry out their duties through a rigorous hiring and selection process, or, where necessary, arrange for suitable training to be undertaken to achieve the required competency level. Staff in DIVHSSE and regional level have demonstrated capacity to adequately implement the ESMS; however, the capacity at the regional level on planning and implementing additional requirements as per DFIs’ E&S standards can be improved. With the support of the World Bank and ADB, PLN is currently working to improve regional capacity. PLN has a Center of Training and Education (“corporate university”), which provides training to all staff based on regular analysis of learning needs. The Center of Training and Education provides E&S safeguard training at basic, intermediate and advanced levels, including training on environmental protection and management, environmental audit, environmental pollution performance rating, and safety. UIP environmental staff are required to complete introductory courses on AMDAL and UKL-UPL preparation. DIVHSSE provides additional capacity building through special workshops and information dissemination on environmental management for staff working at the regional levels. Also, both the ADB and the World Bank have implemented technical assistance and capacity building programs specifically targeted to improve the E&S capacity in PLN at both headquarters and regional level.

Emergency Preparedness and Response:

As part of the ESMS and in line with the requirements of local legislation, PLN requires individual units to develop Emergency Preparedness and Response Plans (EPRP) to address potential natural hazards, fire and other external emergencies (such as security incidents). PLN units also coordinate closely with local law enforcement, health and emergency services providers to responds to natural disasters and other emergency situations.

The sub-projects that will receive payments under the MIGA-guaranteed facility have developed projects-specific EPRPs to address projects risks including fire and other external emergencies during the project operations in line with both Government of Indonesia and applicable lender requirements.

Monitoring and Review:

PLN’s system of reporting of environmental mitigation and monitoring consists of internal and external reports. At the project-level, external reports to the government are described in the RKL-RPL or UKL-UPL, which specify the contents and frequency of reports, as well as recipients (government agencies). The objective of monitoring during the operations and maintenance phase includes monitoring the effectiveness of impact mitigation efforts; to identify emerging issues and unexpected impacts; and to design corrective actions and improvements (as necessary). For projects with significant E&S risks, including significant biodiversity impacts or social impacts, PLN may engage a third-party consultant to undertake independent monitoring of the implementation of management plans to address these specific issues.

Periodic environmental audits are also required by the government for most projects in the energy sector as an instrument to prevent environmental damage and pollution. Qualification for environmental auditors and procedures for the environmental audit are described in a regulation issued by the Ministry of Environment and Forestry (MOEF). PLN has developed an internal environmental audit program for all major facilities to determine environmental conformance on an annual basis, which uses the PROPER program’s self-assessment tool. The annual PROPER assessments are disclosed on the MOEF website.

PLN prepares both an Annual Report and an Annual Sustainability Report, which are publicly disclosed on its website in both Bahasa and English. The Annual Sustainability Report is prepared in accordance with the requirements of the Global Report Initiative. As a condition of MIGA’s contract of guarantee, PLN will be required to provide MIGA with an annual E&S performance report.

Six (6) of the 97 sub-projects that will benefit from the MIGA-guaranteed facility participate in the PROPER program. Of these, 4 have PROPER green ratings (beyond compliance) and 2 have blue ratings (in compliance).  In addition to national requirements, the sub-projects are all required to submit monitoring reports to the DFIs that have supported the project.

Stakeholder Engagement:

At a corporate level, PLN has identified stakeholders and has developed and implemented a plan, which includes different methods of engagement for different stakeholders. A summary of the approach to stakeholder engagement is provided in the Annual Sustainability Report. At a project level, public participation is required as part of the ESIA process in Indonesia, which includes discussions with local government representatives, surrounding communities and affected people. Feedback from the consultation sessions is incorporated into the AMDAL and RKL-RPL. PLN’s updated 2019 Environmental Safeguard Guidelines includes measures to ensure that stakeholder engagement is inclusive and meaningful.

The sub-projects were all subject to both AMDAL consultation requirements, as well as DFI requirements for stakeholder engagement, which are consistent with the objectives of MIGA’s PS1. 

External Communication and Grievance Mechanisms:

PLN has a corporate-level grievance redress mechanism (C-GRM), which also applies to projects under development. The mechanism includes a Customer Care call center, which functions as the entry-point for complaints and grievances related to PLN’s activities and projects. Complaints are automatically recorded in the system, and grievances are forwarded to relevant units/departments for proper handling. The grievance system, however, is not fully developed and does not yet have specific guidelines or procedures for handling, documentation and reporting of grievances. Some complaints are received by contractors or by on-site PLN staff, and as there is no structure for resolution of grievances and reporting these tend to be handled in an ad hoc manner. The proposed Environmental Safeguard Guidelines (draft version, November 2019) provide measures to improve PLN’s GRM, many of which have been incorporated into PLN’s external communication procedure (see below).

PLN recently developed a procedure for external communication and disclosure of environmental documents. This procedure includes guidance for receiving, registering and responding to external communications from the public. The procedure applies to comments regarding both PLN owned and operated projects and IPPs where PLN is the off-taker, and provides specific guidance for how complaints regarding IPPs will handled. Projects that are funded by international lenders follow lenders requirements for disclosure (involving posting on website); while projects financed by other sources follow common practice in Indonesia, which require the draft ESIA report to be disseminated to members of the ‘AMDAL Review Commission’, which includes representatives of the affected communities and any interested civil society organizations or non-governmental organizations. The final, approved ESIA is considered a public document, which can be shared with the public upon request.

PS2:  Labor and Working Conditions

As of the end of December 2019, the total number of PLN employees was 54,129, consisting of 45,061 employees directly employed by PLN and 9,068 staff employed in subsidiary companies. Approximately 80% of the staff are male and 20% female. Almost all employees are permanent PLN staff, and PLN does not engage seasonal staff or daily workers. Supporting workers, such as meter reading officers, contract center officers, security guards, cleaning services and others, are engaged through contractual agreements with partner companies.

Working Conditions and Management of Worker Relationship:

Over the past 5 years, PLN has implemented a 5-year Human Resource (HR) Road Map (2015 – 2019) to improve its HR management. PLN’s HR Management Systems includes policies and procedures for recruitment, working conditions, career development and performance management that are in line with the requirements of PS2. As part of the HR Road Map, PLN undertakes an audit of its HR systems every 2 years. All PLN employees have contracts with labor rights in accordance with applicable regulations. PLN is committed to applying the principle of non-discrimination policy. Working conditions, which are outlined in employee contracts, include terms of reference for the relevant position, remuneration, working hours, overtime rates, sick pay, freedom of association and termination notices. These terms are further explained to all employees during pre-service learning.

All PLN employees have the right to join a labor union. In 2019, approximately 31,000 staff were members of 4 different unions (SP-PLN Union; Employee Union of PLN; LASKAR PLN Union and Labor Union of PT-PLN). SP-PLN is the oldest union (formed in 2001) with the largest membership (approximately 24,000 members) and Labor Union of PT-PLN is a new union that was formed in 2019 and has approximately 500 members. There is a collective bargaining agreement in place, which is in the process of being renewed.

PLN has a clearly defined formal and robust grievance mechanism for all workers, and also undertakes an annual employee engagement survey to get an understanding of employee satisfaction and areas for improvement. PLN’s workers grievances mechanism and process are communicated to all staff and each PLN unit provides the staff with flyers and materials that details how staff can raise grievances/complaints with their respective units and managers. PLN also provides a forum for management and representatives of employees or labor unions to express their opinions on management policies, find solutions to employment problems that may have occurred, and provide/get input to minimize the potential for employment problems. This is in the form of a communication and consultation forum called the Bipartite Cooperation Institution (CI Bipartite), which is spread across all PLN units and subsidiaries. In addition, there is an anonymous whistle blowing system.

Protecting the Work Force:

PLN does not make use of child labor and/or forced labor in its operations. All employees must be at least 18 years of age to quality for a job as stipulated in Indonesia labor laws. The company uses identity documents to verify age at the time of engagement. As part of its review of contractors, PLN also confirms that contractors do not use child labor and/or forced labor in their operations.

Occupational Health and Safety:

As indicated above, PLN’s policy on occupational health and safety (OHS) is integrated with its Environmental Protection Policy and at the corporate level has a certified OHS management system. In 2019, 304 PLN units held OHS Management System certification. PLN’s OHS Management System is applied to both PLN’s activities and work locations and to their contractors. PLN undertakes an annual self-assessment of the ‘maturity level’ of its OHS Management System, which is a measurement tool to assess the consistency of implementation. In 2019, PLN’s OHS Management System maturing level was 4.73 on a scale of 1 (least mature) to 5 (most mature), which indicates a high level of maturity and the ability of the system to drive continuous improvement.

At the corporate level, work safety practices are specifically managed by DIVHSSE. In addition, PLN has an OHS Advisory Committee (P2K3), which is a special body created to coordinate the activities and programs related to OHS across PLN’s operations throughout Indonesia. The P2K3 is comprised of the Director of Human Capital Management, Head of HSE Division, Head of General Division, OHS Senior Manager and Corporate Security, Deputy Manager of OHS and Corporate Security and 24 OHS Trustees executing members led by the Head of HSE Division. P2K3 aims to create a safe, reliable and environmentally friendly working environment with a goal of zero accidents. The duties and responsibilities of the P2K3 are to: (i) carry out investigations in the event accidents; (ii) to provide recommendations for improvement from the results of investigations; (iii) evaluate regulation implementation concerning electricity safety in all PLN units; (iv) foster the implementation of all electricity safety policies and procedures in all PLN units; and (v) prepare reports on the execution of electricity safety investigations.

PLN regularly tracks health and safety indicators and uses an application (Inspekta) to record and map all unsafe actions, unsafe conditions, near misses and accidents (work accidents and installation accidents) at work. This application was launched in 2019 and is planned to be distributed to all PLN Units and subsidiaries in 2020. In 2019, PLN had 61 work accidents, 27 fatalities and an injury frequency rate of 0.08 times accidents per 1 million hours of people per year.

The Coronavirus Disease 2019 (COVID-19) has potential risks and impacts on PLN and its activities. To reduce the potential impact of COVID-19 on workers, customers and communities, PLN have developed policies and procedures to ensure that the risks associated with COVID-19 are adequately addressed.

Workers Engaged by Third Parties and Supply Chain

PLN monitors contractor performance, and only engages contractors that meet required national laws and regulations. PLN also implements a Contractor Safety Management System CSMS), which is an OHS Management System required for contractors to assess and monitor the OHS performance of contractors during projects constructions and operations. OHS and environmental considerations are also incorporated into procurement decision-making and contracts.

PS3:  Resource Efficiency and Pollution Prevention

As described in the Project description, PLN’s activities include energy generation (45.8 GW of installed capacity, 72.5% of the generation capacity of Indonesia), transmission and distribution, all of which have associated resource use and potential pollution (e.g. air and noise emissions, waste and effluent generation).

Resource Efficiency:

PLN strives for energy efficiency through the implementation of various programs or policies. Programs or policies related to energy efficiency include, among others, carrying out regular repairs

and maintenance, rehabilitation/refurbishment to maintain capacity, maintaining engine reliability and improving plant efficiency, and applying the latest electricity generation technology in stages. In the 2019 Sustainability Report, PLN reported that they had successfully reduced greenhouse gas (GHG) emissions level through this energy efficiency program.

PLN implements several innovative programs, such as modifications of boiler water injection patterns and overflow at cooling towers, to improve water efficiency across its activities and operations. The 2019 Annual Report indicated an improvement in water efficiency across 10 of its most water resource use intense operations.

Pollution Prevention:

To minimize pollution from their facilities, PLN applies the Government of Indonesia’s PROPER, a voluntary program where companies self-monitor environmental performance and submit reports to the MOEF. Indicators of performance in the report include marine pollution; hazardous and general solid waste; air emissions (including GHGs); biodiversity; water efficiency and water pollution; and corporate social responsibility. MOEF reviews the reports and provides a compliance rating for each company: gold/green (beyond compliance); blue (compliant); red (partial compliance) and black (non-compliant). In 2019, PLN obtained 5 gold ratings; 16 green ratings and 98 blue ratings.

Waste generated by PLN from electricity operational activities consists of 2 types of waste, namely hazardous waste and general solid waste. All waste is managed in line with applicable laws and regulations. Hazardous waste generated by PLN activities includes fly ash and bottom ash (FABA), used lubricants and expired chemicals. All units have permits for temporary storage of hazardous waste, while some units have landfill permits and / or self-utilization permits. PLN generated approximately 3 million tons of FABA in 2019, and of that, self-utilized approximately 6,000 tons as a raw material for making bricks, paving blocks, fence panels, concrete and road bases. Of the remaining FABA, approximately 1.6 million tons was disposed to licensed third-parties to be reused.  PLN implements a number of programs to reduce, reuse, or recycle general solid waste. These programs resulted in a 5% decrease in overall solid waste in 2019.

All PLN plants are equipped with water treatment plants to process cooling water from generators so that output water meets environmental standards before being returned to the receiving water body. Treated water is also reused as much as possible, including as generator cooler in a closed circuit, for watering plants or for watering coal dust in coal yards.

PLN plants comply with Government of Indonesia air emission standards, and PLN is implementing programs to reduce air pollution in line with government objectives. Reduction of air emissions is achieved through preventative maintenance, use of best available technology, optimization of design and efficiency measures.

PS4:  Community Health, Safety and Security

Community Health and Safety  

To manage community health and safety risks, PLN has an internal regulation on Public Safety, which provides a framework to ensure that PLN activities do not affect the health and safety of surrounding communities. The Emergency Response Plans, which are mentioned under PS 1, also consider potential impacts on the community and PLN coordinates with local law enforcement, ambulance and fire services. For its own staff, PLN enforces employee disciplinary rules, which require employees to maintain high standards of behavior when interacting with the public.

Security Personnel:

PLN’s own facilities and the IPP sub-projects are considered as National Vital Objects (NVO), and therefore, security is provided by the police and the military. PLN has Memorandums of Understanding (MOU) with police and the military for the protection of their facilities. All sites and assets are also secured by fencing, controlled access and guarded 24 hours per day by private security guards.

PLN has developed an overarching security policy and security frameworks that guides individual project specific security policy and frameworks. In addition, PLN’s 47 installations are certified with security management system per the Ministry of Energy and Mineral Resources directive which classified these facilities as NVO.

Broad Community Support is not applicable for this Project. 

The documentation listed below is available electronically as PDF attachments to this ESRS at

The above documentation is also available for viewing at the following locations or by contacting the person below:


  Contact: Adi Setiawan

  Position: Corporate Secretary


MIGA supports its clients (as defined in MIGA Policy on Environmental and Social Sustainability) in addressing environmental and social issues arising from their business activities by requiring them to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities.

In addition, Affected Communities have unrestricted access to the Compliance Advisor/Ombudsman (CAO), the independent accountability mechanism for MIGA. The CAO is mandated to address complaints from people affected by MIGA-guaranteed business activities in a manner that is fair, objective, and constructive, with the goal of improving environmental and social project outcomes and fostering greater public accountability of MIGA.

Independent of MIGA management and reporting directly to the World Bank Group President, the CAO works to resolve complaints using a flexible, problem-solving approach through its dispute resolution arm and oversees project-level audits of MIGA’s environmental and social performance through its compliance arm.

Complaints may relate to any aspect of MIGA-guaranteed business activities that is within the mandate of the CAO. They can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of a MIGA-guaranteed business activity. Complaints can be submitted to the CAO in writing to the address below:

Compliance Advisor/Ombudsman
International Finance Corporation
2121 Pennsylvania Avenue NW
Room F11K-232
Washington, DC 20433 USA
Tel: 1 202 458 1973
Fax: 1 202 522 7400