MPI has implemented a formal environmental and social management system (ESMS) certified to ISO 14001 and OHSAS 18001 standards. MPI’s ESMS incorporates IFC PSs and MPI’s Board has endorsed an environment and social (E&S) Policy that commits to meet IFC PSs in addition to national law. MPI has recently upgraded its ESMS for conformance to ISO-2015 standards and as part of the ESMS upgrade, MPI has incorporated formal screening/selection procedures, covering its new project development, O&M business and asset acquisition business, to ensure that MPI is able to adhere to IFC PSs across its entire operations. RATCH, the second sponsor of the project, has articulated a public commitment to maintaining high standards in management of environment, occupational health and safety (OHS), employee working conditions, and community and broader stakeholder relations in its projects and operations. Ratch has implemented procedures to achieve its commitment and publishes a third party assured Sustainability Report that refers to GRI standards. The plant EPC contractor, Lotte Engineering & Construction (Lotte E&C) of South Korea   and the gas pipeline EPC contractor, PT. Citra Panji Manunggal (CPM) of Indonesia also have EHS management systems certified to ISO 14001 and OHSAS 18001 standards.

MRPR will, as mentioned at ESAP # 1, adopt and implement an Environment, Health, Safety and Social (EHSS) Policy that is aligned and consistent with MPI’s and RATCH’s E&S policies and incorporates IFC PSs. MRPR’s EHSS policy will commit to compliance with national law and the provisions of relevant international standards including IFC PSs on an ongoing basis. The company shall ensure that the EHSS policy is prominently displayed within the project site and communicated to all employees. MRPR will as per its EHSS Policy ensure that the EPC contractor and O&M contractor adhere to its EHSS Policy. Further, to effectively implement this EHSS policy, the company will put in place an environment and social management system (ESMS) for the construction and operation of the project, as indicated under ESAP # 2 and 3.

Identification of Risks and Impacts

The company commissioned a Jacobs Engineering of New Zealand to undertake an ESIA in accordance with national regulatory requirements and international good practice standards including IFC PSs. Baseline surveys were carried out between June and September 2017 (dry season) and January to February 2018 (wet season). The ESIA has also drawn upon publicly available data collected for PLN’s 2 x 110 MW Tenayan CFPP.

The ESIA addresses key environmental and social risks and impacts associated with the project’s construction and operation including those pertaining to: dust, emissions to air, air quality, noise and ambient conditions; greenhouse gas emissions; flooding; water and wastewater; thermal discharge; soil erosion and runoff management; handling, storage and use of hazardous materials; solid waste; ecology and biodiversity; ecosystem services; vehicular emission; traffic and traffic safety; land/RoW/easement acquisition and displacement (physical and economic); legacy claims of Batin Tenayan communities; handling, storage and disposal of hazardous wastes; fire risk in turbine, switchyard and gas facilities; worker living quarters/accommodation during construction and operation; facilities and amenities to be made available to workers; working at height; working in confined spaces; electrical safety; child and forced labor; impacts on indigenous people; impacts on cultural heritage; monitoring, reporting and supervision; and budgetary requirements to comply with national law and international standards including IFC PSs. MRPR will implement additional mitigation/management measures consistent with good international industry practices (GIIP) including those discussed below in construction and operation of the project in accordance with IFC PSs. While a qualitative risk assessment has been undertaken for the gas pipeline, MRPR will, as mentioned at ESAP # 5, undertake a quantitative risk assessment (QRA) for gas pipeline and power plant, and implement mitigation measures based the QRA findings.

Alternatives analysis has been undertaken as part of the ESIA that covers power plant siting options, as pipeline route options, water intake and wastewater discharge pipeline route option, access road alignment, transmission line routing, condenser cooling (once through or closed cooling), stack heights and the no-development option. The alternative analysis included environmental and social considerations also like impact on and proximity to communities, emissions, land acquisition, land titles and source of water. The ESIA report also provides an assessment of key cumulative impacts particularly on ambient air quality and river water quality due to PLN’s 2 x110 MW Tenayan CFPP and the project taken together.

The ESIA assesses the impact of flooding, based on the historical data of water level and meteorology on the project. A project site is situated at an elevation of approximately 17 m above sea level (asl). The elevation of the highest recorded flood is approximately 9.2 m above sea level and, consequently, the project site is not at flooding risk from the Siak River. In order to achieve the project average site elevation of 17 m asl, balanced cut and fill work will be undertaken at site. A surplus of about 45,000 m3 of unsuitable excavated soil from the levelling activity and from excavations for foundations will remain and will have to be disposed. While the site is not at flooding risk based on historical flood flows, also since the site is located 136 km from the coast, sea level rise is not expected to impact the project site. However, to mitigate the risk of flooding from future climate change induced flood event, the company will, as mentioned at ESAP # 3, develop a climate change adaptation policy including monitoring, measurement and corrective actions for: (i) Flood mitigation (safe access /egress during flood events / use of evacuation shelters); and (ii) monitor the banks of the Siak River and address any significant increased erosion of the banks near the water intake structures by stabilization methods.

While an ESMS framework has been provided in the ESIA, MRPR will, prior to start of construction develop the framework into an ESMP for construction stage and prior to start of operations develop and implement an operation stage ESMS. The company will, as part of the process for development and implementation of the ESMS for plant operations, undertake a comprehensive assessment of environmental, occupational health and safety and social (EHSS) risks, aspects and impacts. The ESMS will include a procedure setting forth: (a) operational control procedures and measures to mitigate risks and adverse impacts; (b) monitoring and reporting requirements for ensuring the mitigation measures are implemented effectively and in a timely manner; (c) organizational and financial resources for carrying out the measures; (d) an implementation schedule for these activities; and (e) an appropriate incentive structure to ensure plans are implemented. Prior to commencement of operations, in accordance with ESAP # 12, the Company will obtain applicable clearances, permits, consents, authorization and all regulatory approvals under all the relevant legislation and will submit copies of the same to IFC as and when these are obtained. Further, the Company will comply with all applicable host country labor laws and demonstrate this compliance to IFC.

Management Programs

The ESIA identifies the environmental and social mitigation measures for the project, covering pre-construction, construction, operation and decommissioning phases. Mitigation measures include those related to: emissions to air; ambient noise; water consumption and risk of contamination; wastewater treatment and disposal; thermal discharge into Siak river; land take; hazardous material and waste handling, storage and disposal; socio-economic impacts; avoidance and minimization of impacts on culturally significant features; employee and construction workers working and living conditions; community health, safety and security; traffic and transport management; information disclosure, stakeholder engagement and grievance redress; community development and decommissioning. The aforesaid identified mitigation measures will, prior to start of construction at site, be developed into full management plans and will include: defined action items, responsibilities, monitoring indicators, review/ audit mechanisms and procedures for timely implementation of corrective actions based on monitoring, audit and review findings.

The company will, as mentioned at ESAP # 2, develop a construction stage ESMP and contractually require the project’s EPC contractors to comply with the company’s ESMP. The EPC contractors will be required to adhere to applicable social and environmental national requirements and fully implement environmental and occupational health and safety (“EHS”) measures defined in project ESIA and the company’s ESMP. The ESMP will include:  EHSS policy and objectives; roles and responsibilities; plans for project site EHSS management in accordance with GIIP including: construction management plan for excavation/backfilling at site, transportation of construction material, concrete mixing, casting and construction at site; dust management plan, noise management plan, Surface water, Groundwater and contaminated runoff management plan, , wastewater and sewage management plan; traffic management plan; equipment operation and maintenance plan; construction, domestic and non hazardous waste management plan;  hazardous materials and hazardous wastes management plan; labor influx and worker accommodation management plan worker medical checkup, vectors and disease management plan; occupational health and safety management plan; local hiring and training plan; emergency response plan; community development plan; stakeholder engagement plan; security plan; Cultural heritage chance Find Plan; open access plan; monitoring and reporting plan; and contractor compliance management plan. Further, MRPR will also make the ESMP available to owner’s project management consultant/Owners Engineer team (PMC), to enable effective oversight and monitoring of ESMP implementation by the EPC contractors. The EPC contractors (for power plant and gas pipeline) will be contractually required to ensure adherence to the E&S management plan (ESMP) and provide a periodic compliance reports during construction.

As indicated at ESAP # 3, the company will put in place an  ESMS for  the plant operations in accordance with MRPR’s E&S Policy and IFC PSs, which will include procedures for: aspect, impact and risk identification; compliance with regulatory requirements; development and implementation of management programs, including standard operating and operational control procedures for managing EHSS risks and impacts from operation and maintenance (O&M) activities; incident and accident handling, recording, reporting, investigation and analysis; ensuring that O&M contract documents include appropriate E&S provisions; stakeholder engagement and grievance redress; onsite and offsite emergency preparedness and response; maintaining a legal register and a commitment register; compliance and E&S performance monitoring; contractor management and oversight; worker accommodation; security personnel; E&S organization, responsibility and resource allocation; training and awareness; internal and external communication and consultation; monitoring, recording, reporting and documentation of environmental and social performance; bi-annual internal and annual external audit of the ESMS; management review; and EHSS report will be reported by MRPR to lenders. Further, the ESMS will, as indicated at ESAP# 3 also include detailed Operation Control Proceduresfor management and monitoring of: air emissions; noise; ambient noise; ambient air quality; water consumption; operations and domestic wastewater quality, treatment and disposal; thermal discharge into river environment; hazardous material and hazardous waste handling, storage and disposal; occupational health and safety; fire prevention, detection and control; operation and domestic waste management; operation, cleaning and repairs of equipment; emergency and disaster response (including for fire, chemical spills and mishaps, accidental release of hazardous cargo, medical emergencies and exacerbation during cyclones/storms/earthquakes); storm drainage and contaminated runoff management; solid waste; compliance requirements for contractors; local hiring and training; community health, safety, security and grievance redress; and monitoring and reporting. Further, the company will prepare a decommissioning plan in accordance with Good International Industry Practice (GIIP), prior to commencement of any decommissioning related activities.

As committed in ESIA, MRPR will establish a ‘community development fund (CDF)’ to undertake a range of community development initiatives. Corporate social responsibility (CSR) programmes (related to education and skill building) for the local community will be designed and implemented by coordinating with district (Kecamatan) and village (Kelurahan) Offices, including in partnership with local agencies to create business opportunities for the local community.

Organizational Capacity and Competency

MRPR will, as indiacted at ESAP # 4, put in place an appropriate organization for both construction and operation phases comprised of technically qualified, experienced and dedicated EHSS staff. MRPR will employ appropriately qualified senior level environmental and social head and at least one environmental, one safety and two social/community relations staff at the plant site during both construction and operation phases. The company’s [project manager] at site will be overall responsible for EHSS aspects. The project manager will be supported by MRPR’s corporate and site level EHSS staff, and the PMC’s and EPC contractor’s EHSS staff. Each EPC contractor will be required to deploy at least 2 appropriately qualified safety personnel, one medical professional/doctor and one appropriately qualified environmental personnel. The PMC will be required to deploy at least one appropriately qualified and experienced environmental and one safety staff. The MRPR’s corporate and site E&S staff will be supported by MPI’s corporate E&S team. The EPC contractor will be required to implement a training calendar comprised of safety, EHS induction training, daily tool box talks and weekly safety training. MRPR’s EHSS team will be responsible for oversight of implementation of the ESMP during construction stage and implementation of ESMS during operation stage including monitoring and reporting E&S performance related information to MRPR and MPI management, Board, investors and lenders. The EHS site staff deployed by the EPC contractors, will be directly responsible for implementation of the construction stage ESMP. Further, the company will deploy a human resource officer at corporate and Social and External Relation at plant site, supported by appropriate number of staff.

Monitoring and Review

MRPR will implement an EHSS monitoring plan for construction and operation phases that has been outlined in the ESIA, which will be developed into a full monitoring and reporting plan as part of the construction stage ESMP (ESAP # 2) and operation stage ESMS (ESAP # 3) and will include roles and responsibilities, location, parameter and frequency of monitoring.

MRPR, together with the PMC and EPC contractors will as part of the ESMP, implement a safety monitoring program during construction stage comprised of daily/weekly joint safety walks, weekly fire extinguisher checks, tool/machinery checks, safety signage and personal protective equipment (PPE) checking, training and accident/incident monitoring. Procedures to document findings, follow up and close out of the findings from the safety monitoring program will be put in place as part of the ESMP. Feedback from the monitoring program will be provided to the EPC contractors, corrective action plans developed and upon implementation of corrective action, contractors will submit an action taken report with appropriate evidence for tracking and closure. Accident/Incident data will be reported to MRPR and MPI management in monthly project progress reports. Further, as part of the construction stage ESMP, a monitoring program will be put in place that will cover all EHSS aspects of relevance during construction including those related to noise, dust, hazardous and other waste, drinking water quality, surface and groundwater quality, incidents, drills, medical checkup, near miss, hazardous conditions, traffic and construction material transport, contracted worker living and working conditions, worker training, stakeholder engagement, employee and community grievances and redress, and implementation of corrective action based on the monitoring program. MRPR will engage a third party EHSS auditor, as mentioned at ESAP # 4, to undertake semi-annually audits during construction and bi annual audits during the first two years of operation to obtain assurance that the ESMP is being implemented.

A comprehensive monitoring program for the operations phase will be established as part of the ESMS to comply with regulatory monitoring requirements, IFC Performance Standard requirements, applicable WBG EHS Guidelines, taking into account the identified risks and impacts, and information requirements of key stakeholders and affected community including: emissions to air; ambient air quality; ambient noise levels at sensitive receptors; energy and water consumption; drinking water quality; wastewater generation, treatment and reuse; treated domestic and operation waste water quality; surface water quality; ground water quality; hazardous wastes generated and disposed; other solid waste generated and disposed; health and safety data; accidents/incidents onsite and offsite (environmental, health and safety, security, community health and safety, community relations); training and drills; stakeholder engagement; employee and community grievances and redress; community development initiatives; resource efficiency initiatives; media reports; deviations from national and IFC Performance Standard/investor/lenders requirements; corrective actions implemented and periodic reporting of E&S performance to MRPR management, Board and MPI. .

MRPR will, as part of the ESMS, implement procedures for annual third party and bi-annual internal audit. The analysis of information from the monitoring and audit programs will feed into periodic management system review process to assess efficacy of the ESMS and identify measures to further strengthen the ESMS.

 Construction workforces will peak at approximately 1000 workers for the power plant and 300 workers for the gas pipeline.

During construction period, it is anticipated that the bulk of the workforce will be employed from the local communities in the immediate project area. During operation, a total of around 60 individuals will be employed, with only one or two of these anticipated to be sourced from overseas. All others are expected to be from Indonesia, and it is expected that many will be drawn from the current workforce in the Pekanbaru area. During scheduled maintenance in operation phase, there will be additional temporary workers on site which can increase the total staff on site to approximately 200. In addition, the plant will employ contract workers for security, housekeeping, scheduled maintenance and such other works.

Human Resources Policies and Procedures

MPI has human resource (HR) policies and procedures that meet national requirements and PS2 provisions. MRPR will, as mentioned at ESAP # 6, develop and implement HR policies and procedures drawing upon MPI’s HR manual and IFC PS2 provisions. Accordingly, MRPR’s HR manual will include policies and procedures relating to: compliance with applicable labor laws; employment and types of employment; attendance, working hours and overtime; working age, forced labor, leaves; conduct and discipline; employee complaints/grievance redress; wage and compensation; bonuses and other benefits; personal particulars; travel related reimbursement; performance appraisal; training and development; equal opportunity and nondiscrimination; separation, retrenchment, collective bargaining, management of contractor/service provider, contractor/service provider compliance with statutory labor requirements and IFC PS2 provisions, and ensuring service provider/contractors’ employees access to a grievance mechanism.The company will, as indicated at ESAP # 6 develop and implement the HR manual for the plant and make a copy of the HR manual/handbook available to each employee and communicate it to employees through training including at new employee induction. Further, as part of its HR Policies, MRPR will require the EPC and O&M contractors to implement HR policies and procedures that comply with the national laws and IFC PS2.  MRPR will as part of the EPC contract specify the standards for worker accommodation in accordance with PS2.

Working Conditions and Terms of Employment

In addition to the HR manual/handbook being made available to each employee, the terms and conditions in accordance with national law and the HR manual will be specified in the employment contract. The company will implement appropriate third-party audit procedures during both construction and operation to obtain assurance on statutory compliance by contractors/service providers with applicable labor laws and IFC PS2 provisions. MRPR’s HR Manual to be developed (refer to ESAP # 6) will require that all employees working on the project shall have a mutually agreed contract of employment with their employer. This contract will include: type of employment; period of employment - working hours, working days and length of employment; holidays; annual leave and public holidays; duties and job title; payment including overtime; insurance; procedures to deal with personal grievances; and termination of employment. In addition, the following will be a requirement of the EPC Contractors or MRPR in regards to labour and working conditions: provision of information throughout the recruitment process on the employer’s labour health and safety policies; assignment of tasks to employees that are consistent with their physical capacities and job skills; operation of programmes for employees' health management, including regular health checks; and ongoing safety education and training as required to perform, supervise, and manage assigned tasks without mishap.

MRPR will, under its proposed HR Policy and Procedures, require the EPC contractors to: identify all compliance requirements under the national labor and employment laws and PS2 covering its employees and sub contractors’ workers including on terms of employment, minimum age, non-discrimination and equal opportunity, freedom of association, worker accommodation and occupational health and safety; put in place a grievance mechanism for its employees and sub contractors’ workers; and implement procedures to demonstrate its and its sub contractors’ compliance with the national laws and MRPR’s labor standards.

Labour Accommodation: 

While at this stage no accommodation facility is expected to be provided for the construction workers by the company or their EPC contractors. However, should the accommodation be provided to the workers, onsite or offsite, the company shall ensure that the EPC contractor develops and implements construction labor camp guidelines in accordance with PS2 provisions on workers’ accommodation covering both their own and their sub contractors workers. MRPR will require the EPC contractors  to provide the worker accommodation in line with the requirements of IFC Performance Standard 2 including related to: appropriate construction material for the accommodation and protection from extreme weather; adequate space and facilities, ventilation, amenities and utilities provided, access to electricity; access to water supply and sanitation safe cooking place, protection against vector- borne diseases; facilities to meet the needs of women workers/women family members of workers; handling, treatment and disposal of waste, wastewater and sewage from the accommodation; fire safety and emergency response; hygiene, disease prevention and vector control; access to medical facilities; avoidance of conflict with host communities; and safety and security. 

Workers’ Organization

MRPR will as part of the HR manual commit to complying with relevant laws related to employees/workers union/organization.

Non-discrimination and Equal Opportunity

MRPR shall ensure that the principles of non-discrimination and equal opportunity are included in its HR Policy and Procedures that the EPC Contractor abides by the same while engaging local subcontractor or contract workers. MRPR will also implement appropriate procedures pertaining to prevention of sexual harassment in accordance with statutory/national legal requirements.

Retrenchment

There are no plans to undertake retrenchment though the company will, as part of the HR policies articulate a retrenchment policy that meets PS2 provision and is applicable for any collective dismissals, in the event of any significant future retrenchment.

Grievance Mechanism

MRPR will, as part of its HR Policy and Procedures Manual (ESAP # 6), develop, communicate and establish a formal employee grievance mechanisms in line with PS2 provisions with detailed time bound steps to be taken upon receipt of a complaint; include an appeals procedure; and procedures for documentation, analysis and reporting of grievances received and resolved to senior management. The grievance procedure will enable employees to raise anonymous complaints, and will have provisions for protection of confidentiality and non- retribution. Further, the company will as part of the ESMS maintain grievance records and will monitor redress of grievances. With respect to their contractors’ including EPC and sub-contractors and O&M stage contractors, MRPR will ensure that a formal grievance mechanism is accessible to all contract workers and will require regular reporting from its contractors on the implementation of the mechanism.

Protecting the Work Force

The company will, as part of its HR Policy and Procedures Manual (ESAP # 6), put in place policies and procedures relating to child labour and forced labour, consistent with the national requirements as well as IFC PS. These policies will be applicable to the EPC contractors and their sub- contractors hired for the project.

Occupational Health and Safety

MRPR will require the EPC contractors to develop and implement a comprehensive occupational health and safety management plan as part of their ESMP (ESAP # 2).

Further MRPR will, as part of the operation stage ESMS (ESAP # 3) for the plant develop, detailed occupational health and safety (OHS) management procedures. The OHS procedures in both the ESMP and ESMS will include, among other relevant aspects, procedures including for: health and safety (H&S) Policy; H&S objectives; hazard and risk assessment for each key activity; roles and responsibility allocation; safety signage; provision and use of personal protective equipment; safety induction; safety awareness and training to employees including contract workers; worker competency assessment for key high risk activities; work permit system; safe work procedures for various activities that exposes workers and employees to hazardous conditions (working at height, confined spaces, temperature, poor weather); safe design, provision of adequate amenities and maintenance of hygienic conditions in the  of workplace and accommodation; medical surveillance; disaster management; emergency response; mock drills; joint disaster and emergency response exercises with relevant external authorities/agencies; medical checkup; fire fighting and other emergency response infrastructure and equipment; composition, terms of reference of joint worker management EHSS  committee meeting, procedures and follow up; lead and lag OHS indicator monitoring; near miss, accident, incident investigation, reporting and corrective action; training on safe procedures for drivers; internal vehicle traffic movement; contractor/service provider safety evaluation and control; asset safety investigations; procedures for periodic internal and third party audits; check lists for onsite physical situation checks; adoption and implementation of safety risk mitigation hierarchy in risk evaluation and accident prevention;  and ensuring availability of doctors or para-medical staff and access to emergency medical facilities and ambulance together with facilities for administering first aid. The company will monitor implementation by the contractor.

Workers Engaged by Third Parties

There will be about 1,300 contract workers engaged at the plant and pipeline construction site.

MRPR will, as part of the ESMP (ESAP # 2) for construction and ESMS (ESAP # 3) for operation stage, implement contractor management procedures including: (i) a compliance checklist against the applicable legal requirements and IFC Performance Standards; (ii) OHS performance criteria as part of contractor qualification and selection; (iii) a workers  code of conduct and (iv) EHS monitoring and audit procedures to obtain assurance on contractor compliance with relevant requirements. The required set of procedures will ensure, among other aspects, the following: compliance of the contractor and its subcontractors with applicable statutory requirements and IFC Performance Standards on labor; consistency of worker accommodation with IFC guidance; implementation of grievance mechanism; protection of the work force, including engagement of migrant workers, if any, on substantially equivalent terms as non-migrant workers performing same work.

 Resource Efficiency and GHG Emission:

MRPR will, as part of its operation stage ESMS, implement procedures for: reuse of water and treated wastewater where possible; implementing measures to monitor energy consumption; and implement programs to reduce specific energy consumption. Further, a cycle of concentration (COC) of [6 ] has been envisaged for cooling water, which will reduce the cooling tower make-up requirement.

Construction phase GHG emissions are not considered significant and can be managed through routine preventive maintenance of machines and engines to ensure combustion efficiency. The project design consists of combined cycle gas turbine (CCGT) technology which is considered the most efficient option in terms of fossil fuel energy conversion efficiency due to the lower carbon intensity of natural gas (when compared with other fossil fuels) as well as the use of waste heat to generate additional power in the combined cycle mode. The overall approximate efficiency rating is expected to be about [55%] net of the fuel’s Lower Heating Value (LHV). The greenhouse gas (“GHG”) emissions are expected to be approximately [375 g CO2-eq /kWh] with a total direct annual GHG emission of approximately [0.919] tons CO2-eq.

The company will implement a program to minimize and monitor SF6 leaks from gas insulated systems. The Company will ensure that all air conditioning equipment and fire safety equipment comply with the Ozone Depleting Substances phase-out plan of Government of Indonesia and Montreal Protocol. Based on the high efficiency of the selected technology, no additional GHG reduction measures are required for the plant during the operational phase.

Pollution Prevention and Control during Construction

The environmental impacts from construction activities for the plant and the related facilities (gas pipeline, water pipeline, access road and transmission line) (i.e., source and transport of construction material, land clearing and filling, cement concrete batching plant, internal roads, drainage, access roads, 1440 m3 dredging in Siak River for temporary jetty etc.) are those typical of most construction sites and include: dust generation; soil erosion and sediment loading increases; noise; waste management; potential spills of hazardous and other material; construction debris disposal; domestic solid waste and wastewater from construction camps; increased water usage; and construction vehicle traffic. MRPR will contractually require their EPC and construction contractors to control these to acceptable levels through application of standard construction environmental controls and mitigation measures recommended in the ESIA. As indicated under Performance Standard 1, the company will require the EPC contractors to develop and implement a construction stage ESMPs, that meets applicable aspects of IFC PSs and applicable aspects of WBG EHS Guidelines. Some of the specific mitigation measures to be applied include: installation of sediment traps to reduce sediment in runoff generated during land clearing/filling; collection, storage and disposal of liquid and solid wastes generated during construction through authorized treatment and disposal facilities; implement measures to minimize risk of spill and overflow during transportation; constructing paved roads early where feasible and cleaning of paved roads; provision of water sprays to control dust on roads and stockpiles; and covered transport of construction materials in trucks.

Temporary impacts to air quality may occur during the construction phase. The EPC contractors will be required to undertake: water spraying in vehicle movement areas for dust suppression; covered transport of material; management of fill/excavated earth and construction material, including staggered excavations at neighboring locations and wetting stockpiles; restricting excavations and construction material handling during high wind conditions; vehicular movement planning to minimize trips; wheel washing; minimizing drop heights for friable material; minimizing time for which excavated/fill earth is left loose at site; management of pollution from vehicular and equipment emissions; and other measures for minimization of fugitive dust emissions (e.g., covering stockpiles). Increase in ambient noise levels is expected during construction due to increased traffic, use of earthmoving and other construction equipment. The company will: not undertake high noise generation activity at night; and undertake transportation planning to minimize traffic through communities at night.

Groundwater will not be used for construction or domestic use. Generation of wastewater will mainly be limited to sanitary wastewater/sewage from labor accommodation and project office areas during construction. MRPR will, as part of the ESMP implementation, ensure that construction waste water (from equipment cleaning, transit mixer washing and other equipment washing/maintenance work) will be disposed through an oil water separator and settling tank. The treated wastewater will be used in dust suppression. The sewage will be treated through septic tank and soak pit. The company will ensure that non-hazardous construction waste will be used for site filling and other wastes (packing material, metal, debris, cement bags, drums/carbuoys etc.), garbage from worker accommodation are collected, segregated, stored and disposed of to re-users or in government authorized debris treatment and disposal areas.

Hazardous materials that will be stored at site during construction include: gas cylinders, diesel, lubricating oils, transformer oil, paints, batteries and other chemicals, and hazardous wastes (used oils, waste/residual paint, oil/paint soaked rags/material, filters, empty oil/paint/chemical drum/barrels, spent batteries etc.) are expected to be generated during construction. These hazardous material and hazardous wastes handled/generated at site during construction will be: stored under segregation and containment; handled/used with appropriate care and personal protective equipment; and hazardous waste will be disposed through entities authorized to handle, recycle and dispose hazardous wastes.

About 45,000 m3 of surplus excavated earth will be disposed of on one of the two parcels of neighboring land that are being considered for disposal. At the end of construction, a post-construction survey of the construction area will be conducted to confirm that all debris and wastes have been removed and appropriately disposed at the end of the construction phase. 1440 m3 of dredged material from the temporary jetty will be stacked for backup area filling.

The company will, as part of the construction phase ESMP and contractually, require and ensure that the construction contractors adopt good EHS practices during construction including: training equipment operators and drivers in safe and defensive driving techniques; developing a materials movement plan to ensure that vehicle movement during construction has minimal impact on daily life patterns of nearby communities; speed controls; backup alarms; undertake appropriate measures to reduce fugitive emissions from storage and transport of construction and waste material; periodic noise monitoring in nearby resident communities on the transport route; and undertaking community safety awareness program.

Air Emissions and Ambient Air Quality

The Project is a gas based power project. Hence, oxides of nitrogen (NOx) are the key emission to air. The company is designing the project to meet the WBG EHS Guideline NOx limits through use of dry low NOx combustors and its stack emissions will meet the WBG EHS Guideline limits for NOx of 51 mg/NM3 for non-degraded airshed. Ambient air quality baseline data indicates that the baseline concentrations of PM2.5, PM10, Total Suspended Particulate Matter, NO2, SO2 and CO are all within the Indonesia National Ambient Air Quality Standards both at project site and along the gas pipeline route. Nitrogen dioxide (NO2) baseline data collection involved active sampling (1-hour sampling period) in accordance with Indonesian Standard Method SNI 19-7119.2-2005, and passive sampling (14-day sampling period per monitoring event) in accordance with NIOSH Standard 6700 (1998). NO2 baseline data monitoring was undertaken in two seasons, July 2017 (dry season) and January/February 2018 (wet season). 10 samples of dry season data  was collected at 10 locations and in the wet season, 3 active and 4 passive samples were collected for baseline data collection. The 1 – hr average NO2 national standard is 400 ug/m3 and 24-hr average national standard is 150 ug/m3. Five year continuous ambient air quality data from Pekanbaru city was also evaluated to assess NO2 concentration in ambient air.  The monitored baseline NO2 levels near the project site is less than 17 ug/m3 for 1-hr average, the 14  day average NO2 level is less than 0.01 ug/m3. The 95 percentile of the NO2 baseline level from 5 year continuous monitoring data in Pekan Baru is 30 ug/m3 for 1-hr average and 24 ug/m3 for 24-hr average.

Dispersion modeling for PM10, NOx, SO2 and CO has been undertaken taking into account cumulative air quality impacts from PLN’s Tenayan CFPP thermal power plant.  The cumulative air quality impact includes dispersion modeling taking into account emissions from Teanayan CFPP. A two stage modelling approach was taken, first using the TAPM prognostic meteorological model to provide meteorological data for the modelling period. The AERMOD dispersion model (Version 14134) was then used to predict the ground level concentrations of the pollutants discharged from the proposed site. The modeling also considered potential downwash effects for the desing stack height.  The modeling indicates that the project related and cumulative maximum incremental ground level concentration of NOx, CO, SO2 and PM10 will not be significant. The project’s predicted contribution to incremental ground level concentration (GLC) of PM10 (annual average) is negligibly small at 0.6 µg/m3 and 2 µg/m3 (24 hr-avg). The maximum predicted incremental ground level concentrations of NO2 (1 hr-avg) and NO2 (24 hr-avg) at 41.4 and 12.8 µg/m3 respectively are within WBG EHS Guideline limits and less than 25% of the corresponding national ambient air quality standard. SO2 maximum incremental ground level concentrations from the project for 1 hr-avg, 24 hr-avg and annual-avg are [2.5 µg/m3, 0.6µg/m3 and [0.2] µg/m3, respectively and meet WBG EHS Guideline requirements. Maximum incremental ground level concentration CO contribution from the project at 10.2 and 2.5 µg/m3 for 1 hr-avg and 24 hr-avg respectively is also within WBG EHS Guideline limits. The modelling results further indicate that the cumulative incremental maximum GLCs of PM10, NO2, SO2 and CO due to the project and the Tenayan CFPPwill be: NO2 [53.4] and [15.7] for 1 hr-avg and 24 hr-avg respectively, PM10 [2.7] and [0.8] µg/m3 for 24 hr-avg and annual-avg respectively; SO2 141.9, 29.1 and 6.4 µg/m3 for 1 hr-avg, 24 hr-avg and annual-avg respectively; and CO 10.4 and 2.6 µg/m3 for 1 hr-avg and 24 hr-avg respectively. The ambient PM25, PM10,  NOx, SO2 and CO levels will remain within national standards.

Noise

Main sources of noise from the power plant are the gas turbine-generators, the steam turbine-generators, HRSG, stack outlet, vent fans and the cooling tower. The noise levels generated by the plant equipment range between 80 to 110 decibels. The nearest sensitive receptor, a resident community is 3 km from the plant site.

For the gas pipeline route, noise impacts may be associated with daytime construction work only, so only 2 hour day time noise monitoring was undertaken while for the power plant 48 hour monitoring undertaken and results are presented for each time interval of the 24-hour monitoring period. Baseline noise levels during the day and night at sensitive receptors is at 56 dB(A) near the project site, while along the pipeline route ambient noise levels were monitored in the day time only and is in the 37 to 72 dB(A) range. Higher baseline noise levels are at locations close to the road. The baseline levels are above the national norms for residential areas.

Noise modelling for the project was undertaken by SoundPLAN modelling software implementing the CONCAWE method of calculation. Noise modeling for the plant as designed predicts that noise increment due to the project at sensitive receptors will be below 3 dB(A). Further, cumulative noise impact modeling also indicates that the incremental noise levels due to the two plants together is predicted to be below 3dB(A) and is expected to meet the WBG EHS Guideline norms.

Water Usage and Wastewater Treatment

A closed cooling system with cooling towers is envisaged. Boiler and cooling tower blowdown will be discharged into Siak river at a temperature upto 5 degree Celsius (degree C) above the ambient river water temperature. The water intake and wastewater discharge points will be located 30 m into the river stream from the river bank.

The plant is expected to consume 10 m3/h of Siak river water for boiler feed, 340 m3/hr condenser cooling, and  20 m3/h for domestic use the total being 370 m3/hr (0.103 m3/s), which is approximately less than 1.5 % of the lowest recorded flow of [7.03] m3/s in Siak River since [1980]. The cumulative water requirement taking into account the Tenayan CFPP has been assessed at about 720 m3/h, which is not expected to exceed [3] % of the lowest recorded flow of Siak river. The raw water will be treated in a filtration plant (flocculation, sedimentation, grit and sand gravity filter). This treated water will be demineralized for boiler feed. The treated water will be further treated through activated carbon filter and sodium hypochlorite for domestic use and the condenser cooling water will be treated with addition of biocides or chlorine.

Effluents from project include thermal discharges due to cooling tower and boiler blow down, filtration system backwash, and DM plant back wash water, and sanitary wastewater. Where possible,  treated wastewater will be utilized within the project premise for green area, whereas remaining 80 m3/day  will be discharged back to the Siak River.

The wastewater to be disposed by the project will be 80-m3/hr at a temperature of up to 5  degree C above ambient river water temperature. An assessment of the mixing zone has been undertaken using two empirical approaches. This includes a thermal mass balance and a river heat exchange at the mixing zone under steady state conditions. The thermal discharge dispersion plume assessment for two scenarios i.e. one for the thermal discharge only from the project and second taking into account the cumulative thermal discharge from the project and Tenayan CFPP. The modeling for the first scenario indicates immediate mixing and the elevated temperature is confined within a plume of about [20] m width and [20] m length (in downstream direction). In light of the fact that Tenayan CFPP’s wastewater discharge point is located [xxxx] m downstream of the project wastewater discharge point, cumulative impact is not expected, as the wastewater from Riau IPP will have attained ambient conditions by the time it reaches Tenayan CFPP discharge point.

The DM backwash of 2 m3/hr after neutralization will be mixed with the cooling tower blowdown for disposal in Siak River. Sanitary waste water 12 m3/day from the plant will also be mixed with cooling tower blowdown for disposal into the river. The neutralization sump/ tank will be provided with appropriate corrosion resistant lining. Compressor cleaning water will be generated periodically and will be tankered off to a hazardous waste treatment and disposal site. The Company will put in place a sewage treatment plant. Treated sewage will meet national standards and may be used on premises in accordance with the national permitting conditions or discharged through the wastewater pipeline. The company will also ensure that the residual chlorine in the condenser cooling water remains below 0.2 mg/l. Oil contaminated waste water will be generated periodically and will be tankered off to a hazardous waste treatment and disposal site.

The storm water drainage system will comprise sediment trap/oil/water separators and all drainage in the vicinity of designated hazardous materials storage areas will discharge to the effluent treatment system. Storm water/ surface runoff water, from areas not likely to be contaminated, will be collected through the gulleys and surface drains into underground drainage, including any rain water collected from building roofs that does not risk being contaminated. This underground drainage will be collected in a sump for feeding to cooling tower or discharged into the Siak river. Surface runoff from areas that have potential for contamination including from the area within the transformer secondary containment will be treated through an oil-water separator and discharged to Siak river. Storm water or wastewater with potential chemical contamination will be treated in the wastewater treatment plant. (The company will ensure that the wastewater being disposed of to Siak river is treated to meet WBG EHS Guidelines.)

Solid Waste Management

During operation stage garbage and domestic waste will be generated in the plant. Bio-degradable waste will be composted and used for greenbelt development/horticultural purposes. Domestic waste/garbage generated in the plant during operation stage will be collected by authorized municipal contractors and disposed of at municipal approved government-operated waste facilities. The company will as part of the ESMS implementation segregate, label and store solid waste in a designated area during operation. MRPR will ensure that other wastes (packing material, metal, debris, cement bags, drums/carbuoys etc.) are collected, stored and disposed off to re-users or in government authorized debris treatment and disposal areas. This will be disposed to local government authorized disposal areas. Waste paper and other office garbage will be recycled through a qualified agency. Further, the company will enter into a take back arrangement with suppliers for waste toner cartridges, ink cartridges, fluorescent tubes to facilitate their recycling/reuse. Solids from the water filtration plant at 21 kg/hr will be collected and disposed at an authorized disposal site.

Hazardous Materials and Waste

The primary hazardous waste during operations include: the oil collected from oil water separators; sludge and residual solids from oil and grit separator tank; waste water treatment plant sludge; compressor cleaning waste; oil filters; batteries; oil and grease contaminated maintenance waste; used oil/paint/chemical drums and carbuoys; oil contaminated water or spills from oil storage areas; used oil generated in maintenance; oily rags/oil contaminated scrap from maintenance activity; switchgear, dielectric containing material; and transformer oil from oil water separator.  MRPR will, as part of ESMS implementation (refer ESAP # 3), ensure that other hazardous material (fuel, lubricant oils, transformer oil, batteries, hydrochloric acid, sulfuric acid, caustic soda, sodium hypochlorite, solvents, etc.) and hazardous wastes handled/generated at site during operation are: stored under segregation and containment; handled/used with appropriate care and personal protective equipment; and hazardous waste is disposed through entities authorized to handle, recycle and dispose hazardous wastes.

Some of the reusable waste/scrap may be sold/ handed over by the Company to scrap dealers. Further, the Company will implement procedures to assure itself that the hazardous waste treatment and disposal facilities remain compliant with the national laws and good international industry practices. Further, the company will ensure that: transformers do not use PCB containing oils; and ozone depleting substances banned/phased out under Montreal Protocol are not used.

 Infrastructure and Equipment Design and Safety

The nearest resident community to plant is 3 km from the site. Due to the proximity of Siak River, the bulk of the construction material, heavy machinery and equipment required for the project will be transported via the waterways to a temporary jetty near the Tenayan CFPP. From the jetty the material will be moved by existing roads to the project site. There is [no resident community] on the route from the temporary jetty location to the project site. An increase in road traffic is expected due to movement of labor and transportation of some construction material during construction phase. While several warungs operate in the area from time to time, there is no residential  communities in the vicinity of the proposed water intake structure and proposed wastewater discharge location. Hoever, there are residential and commercial structures in the immediate vicinity of the gas pipeline at several locations. The ESMP will include, a detailed transport, traffic and access control management plan with procedures including: training of equipment operators and drivers in safe driving techniques; implementation of a personnel and materials movement plan to ensure that vehicle movement during construction takes into account the daily life and traffic patterns; speed controls; alarms; posting traffic marshals at high risk locations; undertaking appropriate measures to reduce fugitive emissions from storage and transport of construction and waste material; access control when working in areas open to public access; barricading of excavated areas;  safety signage; illumination; restriction of night time activities to low noise generating work; periodically monitor noise levels in potentially affected communities/villages; and undertaking community awareness programs.  In transmission line route planning, MRPR will take into account risks and impacts including electrocution, as applicable. Further, for communities’ resident in the vicinity of the transmission line, MRPR will implement a general awareness program detailing dos and don’ts to minimize electrocution risk.

While MRPR Has carried out a qualitative risk assessment for the gas pipeline, the company will, as mentioned in ESAP # 4, undertake a quantitative risk assessment and follow the requirements of KEPMEN 300 (an Indonesian approach which specifies measures which exceed the normal design requirement of ASME B31.8/SNI3474 to provide adeaquate separation between the pipeline and any structures or properties nearby and  ensure that societal risk exposure of communities along the gas pipeline route is within ALARP levels.

The projects and related facilities have been designed to Indonesian national  engineering standards . The project site is located in seismic zone III and the design of the facilities will take account of the specific seismic risk for the area, in accordance with the Indonesian Standard SNI 1726. Flood risk assessment has been undertaken.

Ecosystem Services

Siak River is used for navigation/transportation and fishing. The project will use water from Siak river for construction and operation purposes. The total water consumption by the project is estimated at less than 1% of the lean season flow during construction and 1.5% of the lean season flow during operation. The cumulative consumption of water by the project and Tenayan CFPP during operation phase is 3% of the lean season flow.

Groundwater levels in the areas near the project site are very close to the ground level. Dewatering for pipeline or foundation or underground facilities construction could result in drop in groundwater levels in 500 m radius of dewatering locations for the duration of dewatering. The assessment has identified 8 wells within the 500 m radius that will experience a drawdown of up to 0.5 to 0.8 m for temporary periods during dewatering. These wells are used for irrigation purposes and the company will closely monitor the water levels in these wells and coordinate with the well users to avoid adverse impact. Communities typically use groundwater for consumption and their source will not be affected by the project construction and operation. The ground water being so close to ground surface level means the risk of groundwater contamination is high. MRPR will implement measures described above to mitigate risk of ground water contamination. Baseline ground water quality assessment has been undertaken as part of the ESIA. The company will as part of the ESMS implement procedures to monitor ground water quality and depth. Thermal dispersion assessmentshave that in the lean season flow also, immidiate mixing should occur within approximately 20 m of the discharge point. This is not expected to have a material impact on fishing related activities and fish catch.

Community Exposure to Disease

An influx of 1250 workers is expected during the peak construction phase. The company will as part of the ESMP require the EPC contractors to: provide adequate provisions within the site and worker accommodation including basic amenities toilets, bathing facilities, potable water and for wastewater and garbage collection, treatment and disposal in order to minimize the workers and community exposure to water-borne, water-based and vector-borne diseases; and undertake health check-up of workers including provision of adequate medical assistance or on-site medical facility or access to appropriate medical facility. Further, appropriate drainage will be provided to avoid disruption in surface/storm water drainage and to prevent flooding in adjoining areas and fields in the rainy season. MRPR will assess and manage potential host community impacts on account of influx of labor as part of its construction stage ESMP (ESAP # 2).

Emergency Preparedness and Response

Outline of an emergency response plan has been delineated in the ESIA. The company will, as part of the ESMPs to be prepared as per ESAP # 2, require the EPC contractors to , undertake a construction phase hazard and risk assessment and develop an emergency preparedness and response plan EPRP). The EPRP will among other aspects cover emergencies such as fire, electrical shock, personal injury, food poisoning, large mechanical accident, drowning accident, radiation accident, and other environmental pollution accident. Further, as part of the operation stage ESMS (ESAP # 3), the company will undertake an operation phase hazard analysis and risk assessment. Based on the hazard analysis and risk assessment, MRPR will: develop and implement an onsite and offsite Emergency Preparedness and Response plan for operation phase. The operation phase EPRP will have in place procedures, trained personnel, and equipment for responding to emergencies, including fire, chemical spills and mishaps, accidental release of hazardous material and medical emergencies; include procedures to assess and manage risk of emergency exacerbation due to natural hazards like earthquake, flood, cyclones/storms appoint a suitably qualified emergency coordinator; communicate the emergency response plan to key stakeholders including local/district emergency response authorities and neighboring communities; undertake awareness training including drills for building awareness on emergency response;  participates in any drills conducted by district/local government emergency authorities; and continually improves the emergency plan based on outcome of the drills.

Security Personnel

Security personnel will be deployed at the plant during construction site and 8 security personnel will be deployed upon commencement of plant  operations. They will not be armed and no armed security will be deployed during the plant operation stage as well. The company will as part of the ESMP for the construction phase and as part of the ESMS for operation phase implement formal procedures for ensuring that: past records of security personnel employed are screened; security personnel have clear objectives and permissible actions laid out;  personnel are trained in handling various situations with clear procedures; security incidents are recorded, investigated and corrective action implemented; security personnel are trained in avoidance of human rights violations; bona fide complaints against security personnel are investigated/disciplinary actions implemented; and there is a grievance mechanism for aggrieved members of community or employees in the event of a violation of the code for security personnel.

 Protection and Conservation of Biodiversity

The project is located in central Sumatra, Indonesia. The project overlaps the Sumatran lowland rain forests ecoregion, which forms part of the Sundaland biodiversity hotspot. IFC conducted its own biodiversity screening using IBAT, and a third party biodiversity assessment including Critical Habitat (CH) screening was undertaken as part of the ESIA.

The project area (including a 1km buffer around all associated infrastructure) based on indirect evidences is a Modified Critical Habitat. Most of the project area is Modified (e.g. existing palm oil plantations, rubber stands, scrub, settlements and roads) with patches (1% of project area) of less modified fallow plantation (e.g. plantation with regenerating native mix, possibly over 10 yrs old) and low quality Natural Habitats (e.g. young regenerating/disturbed forest, mangrove stands). These less modified/low quality Natural Habitat patches are located in a series of 4 discrete patches adjacent to the transmission line and gas pipeline routes (primarily along areas of existing paved roads). It should be noted that the landscape is under ongoing modification (e.g. oil palm replanting rotations every 15yrs). The patches of less modified/low quality Natural Habitats are under independent ownership (i.e. not by the project) and while future land use is unknown, further modifications are considered possible. The project area based on indirect evidences is potentially Critical Habitat for threatened species (IUCN Critically Endangered Sunda pangolin). This species is widespread in the region, including within highly modified and degraded natural habitats and is primarily threatened due to unsustainable illegal hunting and trade. Impacts to the species by the project include disturbance during construction (e.g. noise) and potential for collection by contractors. Induced access is considered limited as all infrastructure is adjacent to existing settlements and roads. The gas pipeline will be buried and the habitat impact from gas pipeline will be temporary during construction period only. Based on the ESIA and CH Screening findings, a management plan has been developed which includes measures such as: full avoidance of Natural Habitats, siting construction camps away from sensitive areas, pre-construction screening and rerouting of associated infrastructure around sensitive sites, burial of pipelines and maximum rehabilitation of the ROW, awareness raising of construction staff. The Company shall develop a Biodiversity Action Plan (BAP), including a zero tolerance policy, and associated procedures, with regards collection, possession or transport of pangolin and any other species that are IUCN Red List threatened, CITES listed, and legally protected (ESAP # 8). The above no tolerance policy will be included in the ESMP for construction stage and ESMS for operation stage (refer ESAP # 1) and communicated to all workers as part of their periodic EHS training program. Post-mitigation impacts are considered negligible and commensurate net gains will be delivered via additional actions (e.g. support to existing NGO and government agency conservation efforts for target species such as pangolin) which are currently being scoped. Note that areas of cleared oil palm plantation will be rehabilitated with indigenous species. Agile Gibbon (IUCN Endangered) were found in one patch along the transmission line but the small numbers are not considered significant by independent species experts. These gibbons and additional biodiversity values (e.g. Black Partridge, are present which will require special consideration within management plans (e.g. IUCN Endangered Agile Gibbon) due to their IUCN threat status or national priority. As with pangolins, these are concentrated into discrete patches along the transmission lines and pipelines, and are adequately addressed within the management plan. No significant residual impacts to these values are thus expected. he project footprint does not overlap with any known protected areas or internationally recognized areas.

Ecosystem Services

Priority ecosystem services with potential to be impacted include access to and contamination of groundwater, and disrupted use of the Siak river for fishing or navigation. Measures to manage groundwater impacts are described under PS3. Measures to reduce impacts to fisheries include design of intake structures to reduce fish mortality (e.g. screens, low intake velocity), location of jetties and other infrastructure away from known fishing and spawning sites. According to the ESIA, these structures if possible will not materially limit access to fishing grounds or fishing areas for any fishing communities. Further, the company will during construction and dredging stage, impacts from which are temporary, implement procedures to minimize area and duration of turbidity increase. Fishing activity is not expected to be affected due to thermal discharge as ambient conditions will be achieved within an approximately 20 m of the discharge point.

Invasive Alien Species

The Company shall establish measures, as part of its ESMP, to prevent introduction of invasive alien species, and introduce measures to control their occurrence in areas under its control (ESAP #1). This will include preferential use of indigenous species within any rehabilitation or landscaping by the Company.

 Protection of Cultural Heritage in Project Design and Execution:

The ESIA mentioned that the power plant site does not contain any historical and cultural heritage sites which will be impacted by the power plant and its associated facilities. However, the social survey component of the ESIA identified that Okura village contains a sacred cemetery of village elders located close to the village settlement in a place called Tebing Tinggi, located opposite to the project site i.e. on the other side of the Siak River. Given its location no direct impacts are anticipated to this cultural heritage feature. The social survey identified two other structures along the gas pipeline route:  the burial site of Princess Kacamayang, daughter of a king during the Gasib kingdom, in Kuala Gasib Village, approximately 3 km from the proposed gas pipeline, and The Putri Puan Elok’s tomb, one of the daughters of a noblemen during Gasib Kingdom era is located approximately 2 km from the proposed gas pipeline route. According to villagers, some notable tombs belong to Raja Panjang and a nobleman are also located nearby. Some of the villagers consider these tombs sacred and often visit them as a form of respect. The exact locations are not included in the ESIA to protect the integrity and privacy of these resources for cultural preservation purposes; however, the company will consider these sites through ensuring proper consultation with the community by early disclosure of the gas pipeline route and water pipeline routes to the community. The project, based on the current understanding of the identified sites, avoided these structures while considering alternate options for the gas pipeline route. The proposed project therefore does not impact any critical cultural heritage site.

Chance Find Procedures:

A chance find procedure framework has been prepared as part of ESIA to provide for dealing with potential archaeological and/or culturally significant finds during the construction phase of the project. MRPR will develop and implement a chance find procedure for all project components.  This procedure will be applied by the EPC contractor and all subcontractors during all project construction works.

The company will, develop and implement a chance find framework as indicated at ESAP # 10. MRPR will use this chance find procedure framework to make specific chance find procedure for the various components of the project, especially for the two EPC contractors to strictly implement the same during construction activities and associated excavation. The requirements of the chance find procedure will be captured in the Worker's Code of Conduct (as part of the construction stage ESMP as indicated in ESAP # 2) that will include a section on cultural heritage and respect of local beliefs and traditions in the local communities and will be included in the construction phase ESMP. All workers will be made aware of the Code of Conduct and awareness sessions will be organized for all new staff. If any element of cultural heritage is discovered during the construction of the Project, mitigation measures to protect the cultural heritage and to ensure that the local population can access them will be defined and implemented. These measures will be defined in a participatory manner with the affected persons or communities. These sacred sites will be mapped and analyzed in corporation with Riau Museum and Education and Culture division of district and province.

Consultation

Consultations were undertaken with the community to identify areas of cultural importance. Opportunity was also provided to the stakeholders in the public meetings as well as in the community surveys undertaken across the proposed plant and associated facilities.

Community Access

The ESIA and the findings of the social survey do not indicate loss of community access to existing sites of cultural importance because of the proposed power project and its associated facilities. However, in case there is a temporary or permanent loss of access (considering that some of the alignments have not yet been finalized, the company will as part of the construction stage ESMP as indicated in ESAP # 2) identify open access through community consultations. Should the open access be limited/curtailed for the community members because of health, safety, or security consideration, alternatives specifying dates and times when access will be provided, providing health and safety equipment and training for specified users of the site, or other measures that balance access with health, safety or security measures as part of the open access management plan to be developed as part of the construction stage ESMP. The agreements with affected communities on access shall be documented.

 Stakeholder mapping/ analysis:

The SIA report includes a preliminary mapping of stakeholders. The key stakeholders identified are the district government agencies, project affected people, utilities implementing the associated facilities and local community leaders and influential people. The company is in the process of updating the Stakeholder Engagement Plan (SEP) with revised stakeholder analysis, key concerns, expectations, impact and influence, and risk rating of various stakeholder groups. This will include the stakeholders who are likely to suffer livelihood loss because of the project including the Okura villagers (fishing in Siak river) and the various kiosk owners across the gas pipeline and the water pipeline route.

Stakeholder Engagement Plan:

The company has proposed a draft SEP as part of its SIA but the same is being developed further to ensure ongoing community engagement during construction and operation phases of the project. The detailed SEP, as described above, will include detailed stakeholder analysis, key concerns, expectations, impact and influence, and risk rating of various stakeholder groups. The SEP will be a live document and will be updated based on the feedback from the various stakeholders. It will include details on engagement strategy, information disclosure, monitoring (including participatory monitoring where appropriate), stakeholder feedback mechanism, reporting, etc. and guidance on maintaining records of stakeholder consultations. 

Information Disclosure:

The AMDAL (Environment Impact Assessment) is the key Government of Indonesia regulatory approval process required for the project to proceed (it includes detailed impact assessment studies and finalization of the Terms of Reference for the impact assessment). Prior to commencing the environmental studies required by the AMDAL, MRPR was expected to conduct project consultation including a public meeting to inform the potentially affected communities about the proposed activities. A 30-day period was provided by MRPR during 3rd quarter of 2017, in which the stakeholders were expected to provide their concerns and the company took the community inputs into consideration while preparing the AMDAL report. Before consulting on the scope of the ESIA, information about the project was prepared by MRPR for disclosure to affected communities, and included: a description of the project and its objectives; an explanation of the SEP, including the timing of consultations, the process and deadlines for public comment, estimated dates for final decision-making, and the grievance mechanism; an outline of the impacts to be assessed in the ESIA; and any existing proposals for mitigation measures. All information was presented in Bahasa-Indonesian and, where possible, in the local dialect. Visual information (for example, diagrams and maps) was presented to communicate to people who have poor literacy levels. Written information was disseminated to all parties prior to engaging in consultation. Information was distributed through stakeholder representatives and information was made available in public areas.

The company will undertake draft ESIA disclosure, as a part of which non-technical summary and ESMP (Environmental and Social Management Plan), discussion on mitigation measures in response to issues raised in consultation to date with affected communities will be disclosed. During the ESIA disclosure, it is expected that list of people affected by land take and easement rights will be identified and disclosed. As agreed in ESAP # 7, the company will disclose the Livelihood Restoration Plan and as summary of the ESIA and the community development plan (CDP) in local language and these should be widely disseminated to the PAHs.   The company will ensure the information is available in publicly accessible locations (such as local authority officers, public libraries, village centers, and through NGOs). Information will also be available on the project’s website. Culturally appropriate advertisements will be placed in local and national newspapers explaining where and when the information may be reviewed, and the avenue and timeframe for making comments. Advertisements will also notify the public of public disclosure meetings. Further, as part of the SEP, the company shall develop a plan for ongoing and timely disclosure of information to the affected communities and key stakeholder groups.

Consultation:

The first public consultation for the project was conducted in Kelurahan Bencah Lesung Office on 11th October 2016 and was attended by 78 participants including 11 women, 2 non-governmental organizations (NGOs) and a University of Riau lecturer in Kelurahan Bencah Lesung Office. The information on the project and the response to the community suggestions and concerns were handled by the MRPR representatives. Suggestions from the communities present in the public meeting include: MRPR to improve the bridge at Tenayan Jaya road; proper signs to indicate proposed gas pipeline route location; employment of local community members in different employment options, rather than employing just the security officers; MRPR community liaison officer (CLO) should discuss CSR proposals with sub-district and district Government Officers; MRPR project office should be accessible to local communities; understand the impact of the power plant on the palm oil plantations surrounding the site; improvement of the roads used to transport heavy equipment to the power plant site; training to improve the capacity building of local human resources; and better opportunity for women employment.

MRPRs CLO has visited most of the villages around the power plant and along the gas pipeline in order to maintain communications and provide ongoing information related to the project. During 11th & 15th of December 2017, two community meetings were conducted at different locations along the gas pipeline route and another meeting was conducted in the office of Kelurahan Tenayan Raya. A social survey of Tuah Negeri, Bencah Lesing and Industri Tenayan Villages adjacent to the power plant and the five villages along the gas pipeline route Kuala Gasib, Pinang Sebatang, Meredan, Tualang Timur and Melebung was conducted by NBC. During the social surveys community concerns in relation to the project were recorded and generally consisted concerns regarding safety of the nearby settlement, appropriate compensation towards loss of structures and crops, proper communication, awareness and information sharing on project and its impacts in a timely manner, employment opportunities for the people of affected villages, fair compensation and secrecy of personal data, regular monitoring of the gas pipeline. The company updated the community against the current status of the various assessment undertaken by the project and the manner in which the various concerns will be incorporated in the ESIA and the ESMP for the construction and operations stage of the project. The company also confirmed that following completion of the ESIA, a meeting will be conducted with the local communities to communicate the findings of the ESIA.

MRPR has also undertaken parallel consultations with the land owners for the land plot proposed for the power plant. As the land acquisition process for the gas pipeline is ongoing the final land owners are still to be confirmed along with the proposed compensation measures (including those land owners associated with the power plant). MRPR will properly document the various consultations being undertaken as part of the land negotiations, community expectations and concerns associated with the negotiations and will update the SEP records. The SEP will also be updated based on the feedback from these consultations.

External Communications and Grievance Mechanisms:

The company has developed a communications protocol as part of ESIA which will need to be further updated and followed by the CLO for sharing information with the community and other stakeholders. The purpose of the communications protocol is to provide a documented record of the communications that are involved in community consultation for the Project. As indicated in ESAP # 11, periodic reports will be provided by MRPR to the local communities on the environmental and social performance of the development, progress on livelihood initiatives and on concerns raised by the communities. During construction the periodic reports will be shared with the communities on a six monthly basis and annually during operation. The ESIA includes a grievance mechanism which will be further updated by the company with a detailed grievance receiving and handling process. In recent consultations, the company has started explaining the grievance mechanism to the affected communities.

Ongoing Reporting to Affected Communities:

Ongoing consultation during the construction and operation period will be carried out by the CLOs. For ongoing information disclosure, the company will, during further disclosures share information through printed information brochures, press releases, fliers, etc. The SEP, under finalization, will include a stakeholder feedback mechanism to provide formal responses to community enquiries and concerns.

  MRPR will disclose the ESIA and ESAP at the following address:

The Energy Building 29th Floor SCBD Lot 11A

Jl. Jend. Sudirman Kav. 52-53

South Jakarta 12190  

Indonesia