This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability (2012), as it is expected to have adverse E&S risks and/or impacts that are limited in scale, few, generally site-specific and readily addressed through mitigation measures by adhering to good international industry practice (GIIP). Key E&S aspects include KWS’ E&S management systems and capacity; temporary economic displacement of a small numbers of people; occupational health and safety (OHS); labor and working conditions, including contractors and sub-contractors; emergency preparedness and response; discharge of wastewater and management of sludge; flood hazards; community health and safety; stakeholder engagement; and community grievance redress.

Environmental and Social Management System: As agreed upon between IFC and KWS in the E&S Action Plan (ESAP), KWS will develop an integrated Environment, Social, Health, and Safety Management System (ESMS) consistent with IFC Performance Standards (PS), local regulation and the outcomes of the regulatory environmental impact assessment (“AMDAL”), the IFC PS-aligned E&S Impact Assessment (“ESIA”) and associated E&S Management Plans (“ESMP”).

K-Water has corporate policies related to Code of Ethics, Green Management Policy, Declaration of Human Rights Management, UN Global Compact’s 10 Principles Support, and a Statement of Support for the Sustainable Development Goals.   Similarly, ADHI has a Quality, Health, Safety and Anti-Bribery Policy and a Biodiversity Management Policy. These policies will be utilized by KWS to develop the ESMS. Subsequently, the requirements of these policies and the ESMS itself will be communicated across all KWS staff and the EPC contractor (ESAP No.1)

Identification of Risks and Impacts: The project is in the process of securing the required E&S regulatory approvals, including the AMDAL, for the WTP and a pipeline alignment that, excepting for a 4.4km section is to be subsequently amended based on detailed design. KWS will commence the construction of the downstream pipeline (scheduled for August 2023) only after obtaining all the required regulatory approvals for the relevant sections (e.g. water extraction permits, traffic access, road closure permits, hazardous waste temporary storage, and OHS certification) (ESAP No.2). KWS has also commissioned an ESIA based on IFC PS and World Bank Group (WBG) Environmental Health and Safety (EHS) Guidelines for the Project The ESIA includes an assessment cumulative impacts focused on the downstream pipeline in relation to other existing, planned, or reasonably defined developments and concluded that cumulative impacts on road traffic would be moderate and could be managed through coordination with authorities and the implementation of the project’s ESMPs agreed under ESAP No. 1.

The following Associated Facilities (AF), as defined in PS1, which will be built by the government have been identified (i) an 11.9km upstream section of connecting pipeline specifically serving KWS, (ii) four downstream reservoirs situated in Jakarta (Semanan and Pegadungan), Tangerang City and South Tangerang City that will be the dedicated offtake point with the Project and only receive water from the Project for distribution to the local communities, and (iii) dedicated transmission line, the route and length for which remains subject to finalization.  AF main impacts from these facilities include construction phase impacts to community health and safety, land acquisition and potentially legacy contamination and the client will make efforts to address those risks and impacts in a manner commensurate with its level of control and influence over the relevant government authority as described under PS3 and PS5 below. 

Management Programs and Plans: The proposed approach to E&S management programs and plans to mitigate the identified E&S risks were captured in both the regulatory environmental management and monitoring plans (“RKL-RPL”) and an ESIA SMPs , which  provide a summary of roles and responsibilities, consolidated management and monitoring measures for the construction and operations phase, training and capacity building principles, reporting mechanisms and commits KWS to prepare a range of specific management plans prior to construction commencing. The ESMPs will sit within the ESMS and include, but not limited to, plans for the management of air quality, noise, surface water, waste management, community health and safety, OHS, traffic management, and an emergency preparedness and response plan.

KWS will ensure through the EPC Contract that the EPC Contractor has in place ESMPs plans for the construction phase (separated into WTP and Downstream Pipeline components) and operations phase. (ESAP No.1 & No.4)

Organizational Capacity and Competency: KWS has a E&S Management, and a Land and Permitting, and Human Resources Management Divisions. During the construction phase, a qualified E&S Manager will be appointed, in addition to an E&S specialist and EHS Officer, to supervise the E&S performance of the EPC. In addition to these EHS personnel, KWS will engage a Social/Community Liaison Officer. The ESMS and ESMPs will provide for the establishment of a EHS committee and Contractor Management Plan (CMP) to ensure that robust monitoring and reviews of OHS and E&S performance of both KWS and EPC Contractor. KWS will ensure that the EPC Contractor has sufficient organizational capacity to supplement its own and ensure all obligations as detailed within the various ESMPs are met. (ESAP No.5)

Monitoring and Review: The ESMP defines a framework E&S monitoring program based on the outcomes of the ESIA, covering both the construction and operations phase. It defines components, parameters to be monitored, location, frequency, and recommended responsibility. As part of ESMS (ESAP No 1), KWS will be required to develop detailed monitoring, inspection, reporting and review programs and procedures, including defining the roles and responsibilities of the EPC Contractor. This will form the basis of KWS’s reporting to IFC and supplement is regulatory monitoring and reporting obligations. KWS will submit periodic reports to the Indonesian Ministry of Environment and Forestry as required by the approved RKL-RPL.

Human Resource Policy and Management: The KWS staff for the oversight and management of the construction phase is anticipated to be approximately 20 people, with 15 of these anticipated to be Indonesian nationals. Upon the shift into the operations phase, it is anticipated that up to 40 employees will be required. KWS has developed a comprehensive Human Resources (HR) Manual to meet the requires of the Indonesian Department of Manpower. The EPC construction force is estimated to be 400 total workers across the WTP and pipeline and is required to be recruited and managed in accordance with local labor laws.

As part of the ESAP, KWS will update its HR Manual to ensure compliance with the requirements of PS2, capturing (i) policy statements and accompanying procedures relating to retrenchment planning, freedom of association/collective bargaining, prohibition of child and forced labor, (ii) updates to grievance mechanism to capture aspects such as ability to lodge grievances anonymously and address gender-based violence grievances,(iii) use of recruitment intermediaries, and (iv) contractual obligations for EPC contractor, outsource labor and workers engaged by 3rd parties to follow PS2 requirements. (ESAP No.6).  As part of ESAP No. 1, KWS will develop and implement a CMP to ensure that the EPC Contractor and all other contractors and sub-contractors engaged in the construction and operations of the Project are fully aligned with PS2 requirements.

Workers Accommodation: KWS will not establish a workers’ accommodation facility for neither the construction nor operations phase on the site. With the commitment to hire at least 30% of the entire construction workforce (ie 121 people) from the communities surrounding the project and the highly urbanized nature of the Project area affording a multitude of accommodation options, the EPC Contractor will likewise not be establishing any temporary workers facility.

Occupational Health and Safety: KWS is developing an OHS policy and OHS Management Manual outlining how the health and safety of its staff will be managed and oversight of the performance of all contractors, sub-contractors and third parties. This will be addressed through the development of the ESMS prior to construction commencing. At the EPC Contractor level, the OHS policy and management plans and procedures will also be established. KWS will be responsible for the identification and management of all OHS risks during the operations phase of the Project and therefore needs to ensure that the WTP is provided with necessary physical safety features such as walkways, handrails, lighting, and hazardous materials storage facilities, and (ii) develop an OHS management system and relevant procedures, with particular focus on sludge management and handling, and the storage, use and handling of chemicals utilized in the water treatment process. (ESAP No.1)

Resource Efficiency and Greenhouse Gas Emissions: The project will be powered by a dedicated transmission line from the national grid and will not generate more than the 25,000tonCO2eqper year.  In the event of a power outage, the project will employ diesel generators, which will not be a common occurrence. Diesel storage tanks will be designed and constructed in accordance with GIIP.

Pollution Prevention: Construction emissions will be managed in accordance with the WBG EHS Guidelines and Indonesian regulatory requirements.  Horizontal drilling will produce a slurry requiring specific management and disposal. As part of detailed planning for the construction phase KWS will undertake further detailed assessment and management planning regarding capturing all discharges (ESAP 6).  During operations, the WTP will generate water treatment sludge (WTS) that is not anticipated to be hazardous based on treatment methods and the anticipated quality of input waters. WTS in Indonesia is generally approved for disposal to land, for which the project will secure an appropriate permit. Design of the Project includes provision for an emergency sludge disposal pond, only activated in the event of an abnormally high excursion of turbidity of the feed water.  The emergency sludge disposal pond is located at ground level and discharges to the drainage culvert that runs under the plant and eventually into the surrounding environment and water courses. KWS is in the process of securing the relevant permits to activate those discharges should they ever become necessary. Being at ground level, the pond may also be subject to inundation during flood events should they be improperly situated. As part of the final detailed design for the WTP, KWS will undertake additional evaluation and planning regarding flood risks to ensure that the final pond siting is above the adopted flood levels. (ESAP No.7). The WTP and pipeline are not in areas likely subject to legacy contamination risks. One of the proposed reservoirs (being an AF) is situated on a site with potential contamination sources for which KWS will consult with government authority responsible to ensure contamination risks are fully identified and managed.

Air Emissions, Ambient Noise, and Odor: The construction phase of the project will generate both point source and fugitive air emissions, however these are readily mitigated. Handling of chemicals utilized in water treatment could result in noxious vapors in the event of improper handling. Handling procedures and an emergency preparedness and response plan (EPRP) will be in place to limit the potential for such an occurrence. As it relates to noise, percussive piledriving in the preparation of foundations of the WTP will be taking place approximately 100 m from a nearby school for which a noise and vibration management plan will need to be developed and implemented (ESAP No.1). Additionally, the pipeline construction will take place at night between the hours of 10 PM and 4 AM to minimize traffic impacts. There are residential receptors within 5 to 10 m from the boundary of the toll road corridor that may be subject to noise and vibration impacts. Detailed planning will capture noise and vibration management methods, and engagement with local authorities and households. Noise and vibration impacts from the operations phase are not anticipated to be significant, however, quantitative assessment and confirmatory monitoring will be necessary based on the final detailed design. (ESAP No.1)

Chemicals and Waste Management: As part of ESAP No. 1, the project will develop a waste management plan as part of its suite of ESMPs to manage construction phase waste. This will also include measures to prevent and respond to spills of fuels and fluids, plus the abovementioned drilling slurry. During operation, chemicals used in water treatment and cleaning will be stored and used on site. Plans will be developed, and regulatory permits secured to facilitate storage and handling of these chemicals.

Community Health and Safety: The WTP location and access arrangements during the construction phase   mean that community health and safety impacts will be minimal. The pipeline corridor will be developed in areas of local road networks where there is a higher likelihood of interaction with the local community.  The development and implementation of community encroachment procedures, traffic management plans and workplace OHS plans (ESAP 1), coupled with stakeholder engagement will minimize these impacts. Impacts may also arise with toll road users at the access point to the WTP construction site and pipeline installation activities taking place in the toll road shoulder. The design of the intersection of the toll road and WTP site will be in accordance with requirements of the Government of Indonesia and GIIP. KWS will follow any necessary directives from the Toll Road operator and requirements of the regulatory traffic impact assessment (“Andalalin”) that has been approved for the Project.

Infrastructure and Equipment Design and Safety Flooding hazard: The WTP site and adjoining areas are prone to flooding. KWS will utilize the existing flood model to inform the need for any flood mitigation measures to minimize impacts both the project and the surrounding communities (ESAP No. 7).

Hazardous Materials Management and Safety: There will be some hazardous materials used in the construction (eg oils) and operation of the plant (primarily flocculating agents).; These will be managed, stored and handled in accordance with WBG EHS Guidelines and Indonesian regulations.  It is not anticipated they will present any particular hazard to the surrounding communities.

Security Force Management: As per ESAP No. 1, a construction phase Security Management Plan (SMP) in line with PS4 will be developed prior to construction commencing. With the pipeline being constructed in public rights of way, the potential for trespassers (whether intentional or inadvertent) to enter active construction zones is high. The community grievance mechanism will include provisions for affected communities to express concerns about security arrangements and acts of security personnel. (ESAP No.8)

KWS has undertaken stakeholder engagement with various communities, landowners, government authorities and representatives of community organizations throughout 2021 and 2022. This included consultation in the shape of community forums for the AMDAL, including neighbours of the WTP site, engagement in collecting baseline data for the AMDAL and ESIA and in conducting the due diligence process. KWS will develop a Stakeholder Engagement Plan (SEP) that builds upon the stakeholder identification, analysis and engagement strategy presented within the ESIA. As part of SEP implementation, KWS will be required to disclose the ESIA and associated management, mitigation and monitoring measures prior to construction commencing. (ESAP No.9)

 Contact Person: Chi Ho Song

Company Name: PT Karian Water Services

Address: Equity Tower, 42nd Floor Unit E, Jl Jendral Sudirman Kav 52-53, Jakarta Selatan 12190, Indonesia

Email: karian.cfo@gmail.com

Phone:+62-81389285745