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Coordination and Supervision (Korsup) KPK and Mineral & Coal Mining Permit Governance

Policy Brief

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Main Findings

1. The general pattern of mining permit (IUP) governance problems consist of (a) Territorial problem: shift/expansion of coordinates, coordinates are not perpendicular, overlap between the same/different commodities, permit is in the area of conservation and protection forest (open pit mining), permit overlaps with an administrative area; (b) Administrative problem: non synchronization of database of local government and the Ministry of Energy and Mineral Resource, the expired IUP has yet to be revoked, invalid address of IUP, IUP which doesn’t go through KP Exploration but rather jump into KP Exploitation, allotment and relinquishment of IUP before the enactment of Law Number 4 Year 2009.

2. Until April 2016, there are 3,982 non-CnC IUP of 10,348 IUP in Indonesia. Only 61.52% or equivalent to 6,366 IUP is eligible to operate. The rest is has yet to meet the standard operation, either in term of administrative or territorial, social, and environmental aspect.

3. Many found permits or contracts which are located in the restricted area for forest area utilization, reaching 1.37 million Hectaress in the conservation forest and 4.39 million Hectaress in the protection forest (open-pit mining). Meaning that 16.2% of IUP area shall be curbed, given total area of IUP/KK/PKP2B is 38.9 million Hectaress which is located in the forest area (26 million Hectares) and land for other uses (12.9 million Hectares).

4. Follow-up of IUP governance through issuance of Ministerial Decree of Energy and Mineral Resources Number 43 Year 2015 is a great momentum to be overseen and synchronized with the process of handover of personnel, funding, facilities and infrastructure as well as document of permit (P3D) as mandated of Law Number 23 Year on Local Government.

Recommendations

1. Immediately curbing the non-CnC IUP and IUP which is operated in the conservation and protection forest. The action taken shall be in accordance with applied regulation also its appointed deadline: Ministerial Decree of Energy and Mineral Resources 43/2015 and the provision of Law 23/2014 regarding process of handover of personnel, funding, facilities and infrastructure as well as document from regency government to provincial government.

2. Immediately issuing Presidential Decree on moratorium of mining permit, thus no more issuance of new permit during the evaluation process until all non-CnC IUPs, which has yet to meet territorial and administrative requirement, has been curbed or resolved.

3. Immediately revitalizing and developing permits database which is also integrated with national One Map policy, by applying a valid mapping and spatial coordinate system also single identity mechanism for company registry.

4. Immediately improving mineral and coal mining permit mechanism both in national and sub-national, which shall be integrated, in line with one map policy, and accommodate applied authority division system.

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Foreword

Along with the strengthening function of KPK on prevention aspect, the role of trigger mechanism is implemented through coordination and supervision (Korsup) function in natural

resources sector by involving related sector-based ministries/agencies (Ministry of Energy and Mineral Resources (MEMR), Ministry of Environment and Forest (MEF), and Ministry of Finance), law enforcer and local government in 12 provinces (plus 19 provinces in 2015) also national and local civil society organizations. The implementation of Korsup is part of National Movement to Save Natural Resources (known as Gerakan Nasional Penyelamatan Sumber Daya Alam-GNPSDA), which is initiated by research and development team of KPK and firstly declared on 6 June 2014 (two years ago). Initially, GNPSDA only covers marine/fisheries, mining as well as forestry and plantation sector. However, considering the complexity of problems and the urgency of a comprehensive governance, the scope of Korsup in mining sector is expanded to oil and gas, electricity and renewable energy sector, which is known as Korsup Energi and officially launched on 15 February 2016.

Mining sector, especially mineral and coal, is one of strategic resources which hugely contributes to national economy. The study conducted by KPK in 2011 revealed critical problems in mineral and coal mining governance, covering development of data and information system on mineral and coal, governance of mining permits (KP and IUP), implementation of regular reporting, practice of reclamation and post-mining and optimization of state revenue. Hence, Korsup in mineral and coal mining or referred to as Korsup Minerba mainly aims to promote an effective mining governance with: (1) Data and information system on mineral and coal which enables an accurate and timely reporting; (2) Reporting system which enables monitoring on production report, thus it can prevent or early detect corruption; (3) Sufficient regulation which enables good mining governance.

Coordination and Supervision (Korsup) KPK and Mineral & Coal Mining Permit Governance

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Main Objectives of Korsup Minerba

Main objectives of Korsup Minerba cover:

(1) Mining Permit (IUP) Governance is targeting no more IUP which has yet to meet the requirement of certification of CnC, do not possess tax ID number (NPWP) and Forest Land Borrow and Use Permit (IPPKH), and do not violate regulations on land, spatial, and environment.

(2) Implementation of the company’s financial obligation is targeting all mining companies pay off their financial obligation, including land rent, royalty, tax, reclamation and post-mining fund, guarantee of seriousness and other financial obligations.

Figure 1. Five Main Objectives of Korsup Minerba

Source: KPK, 2014 (processed)

(3) Monitoring on mineral and coal production is targeting all mining companies submit production report on a regular basis, all local government conduct regular reporting on production monitoring in their region, all local government impose sanctions toward companies which do not implement good mining practices and violate applied regulations as well as no more illegal mining (PETI).

(4) Implementation of processing/refinery obligations is targeting no more mining companies which do not conduct processing/refinery obligations and impose sanctions toward those who violate.

(5) Supervision of sales and transportation/mining products shipping is targeting all mining companies submit sales reporting, all local government convey supervision result on sales and transportation/mining products shipping as well as impose sanctions for those who conduct sales and transportation/mining products shipping illegally

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Korsup Minerba and Mining Permit Governance

Mining permit governance in Korsup Minerba is conducted by facilitating coordination across sector to resolve the problems on non-CnC IUP; conduct supervision on freezing or temporary

suspension or revocation of IUP which has yet to meet the requirements; identify factor and actor who hamper effort on mining permit governance; socialization and campaign on system/policy improvement as part of an effort to prevent corruption. These measures are taken by involving all stakeholders, particularly Directorate General of Mineral and Coal Mining, MEMR and local government in the province and regency.

Law and regulations which serve as a legal basis on mining permit governance cover: (1) Article 102 paragraph 2, Government Regulation Number 23 Year 2010 on Implementation of Mineral and Coal Mining Business Activities; (2) Article 2 Paragraph 1 and Article 13 Paragraph 1, Government Regulation Number 55 Year 2010 on Guidance and Supervision of Mineral and Coal Mining; (3) Ministerial Decree of Energy and Mineral Resources Number 2 Year 2013 on Supervision of the Implementation of Mining Management Conducted by Provincial Government and Regency; (4) Ministerial Decree of Energy and Mineral Resources Number 2 Year 2014 on Delegation of Part of Government Affairs on Energy and Mineral Resources to Governor as Government Representative in the Framework of Deconcentration for Fiscal Year 2014; (5) Circular Letter of Director General of Mineral and Coal Number 04-E/30/DJB/2014 dated 14 April regarding Development and Supervision of Mineral and Coal Mining Permit Governance in the Framework of Deconcentration; (6) Ministerial Decree of Energy and Mineral Resources Number 43 Year 2015 on Procedure of Evaluation for the Issuance of Mineral and Coal Mining Permit.

The initial measure in mining permit governance is to conduct data collection and reconcile as well as integrate all mining permit data from government (MEMR) and local government (province and regency). Collected and reconciled data include: IUP and its CnC status (already, on-going process, and non-CnC); number of IUP which don’t possess tax ID number (NPWP) and the cause; number of IUP and its area which operated in the conservation and protection forest; number of IUP which don’t possess Forest Land Borrow and Use Permit (IPPKH); also number of IUP which don’t have or yet to pay reclamation and post-mining fund. Pattern of findings in data collection and reconciliation is summarized in table 1.

The implementation of Korsup is part of National Movement to Save Natural Resources (known as Gerakan Nasional Penyelamatan Sumber Daya Alam-GNPSDA), which is initiated by research and development team of KPK and firstly declared on 6 June 2014.

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Table 1. Pattern of Findings in Monitoring Mining Permits and the Follow-Up

No. Pattern of Findings Follow-Up

1 CnC IUP recorded in the MEMR are not recorded in the local government

Regent/Mayor is urged to submit reference letter to Director General of Mineral and Coal-MEMR, forwarded to KPK

2 IUP issued by local government are not recorded in the MEMR, but is proposed to gain CnC status to the province

Provincial government and Director General of Mineral and Coal are urged to ensure the validity of document of the possibility of back dated IUP, in order to investigate and take legal measures

3 IUP ended, but has yet to be revoked Governor/Regent/Mayor are urged to collect the obligations and immediately write Decree Termination/Revocation of IUP

4 IUP operate in the conservation and protection forest

Governor/Regent/Mayor are urged to send letter of notification on relinquishment/ temporary suspension and ask the company to manage licensing in Ministry of Environment and Forest

5 Not valid/clear address of IUP Governor/Regent/Mayor are urged to ensure the address of IUP in their region

6 IUP revoked, but included in the unregistered permit in MEMR

Governor/Regent/Mayor are urged to immediately coordinate with Director General of Mineral and Coal in order to be excluded from IUP database in MEMR

Source: Presentation of KPK in Monev of Korsup Minerba in Bali, 3-4 December 2014

Following data collection and reconciliation, the next measures are evaluating and curbing IUP, which are conducted through administrative arrangement as well as sanctions and law enforcement. Administrative arrangement is pursued through coordination and submission/reconciliation of data between local government and MEMR in order to complete IUP database, review IUP validity (validity of IUP address and investigate the possibility of back date), as well as recommend licensing management which involves MEF. While sanctions and law enforcement will be executed through relinquishment/temporary suspension of IUP which operate in the conservation and protection forest till the completion of its time period, as well as revocation of IUP which has expired and yet to meet standards of CnC. The result of evaluation then reported on a periodic basis to KPK and MEMR directly or through forum monitoring and evaluation which is held periodically by Team of Korsup Minerba. Progress of mining permit evaluation is presented in Figure 2.

the next measures are evaluating

and curbing IUP, which are

conducted through administrative

arrangement as well as sanctions and law

enforcement.

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Figure 2. Progress of Mining Permit Evaluation in Korsup Minerba

Till April 2016, there are 3,982 non-CnC IUP of 10,348 IUP in Indonesia. Only 61.52% or equivalent to 6,366 IUP is eligible to operate. The rest is shall be curbed and, if needed, immediately revoked, if has passed the deadline and not take improvement measures. Evaluation and CnC certification in mineral and coal mining has been going since 2011 and has entered 17th phase today. Main criteria of CnC assessment cover administrative, territorial, technical, financial and environmental aspect. Those criteria are translated into the absence of overlapping (the same/different commodities, such as plantation and forest); comply with spatial and environmental provisions (not operate in the conservation and protection forest by conducting open pit mining); meet financial obligations (royalty, land rent, tax, guarantee fund and others); and other aspects.

In general, the problems of non-CnC IUP can be categorized to two, which are territorial and administrative problems also mix of those two problems. Classification of problems in detail are presented in figure 3.

Main criteria of CnC assessment cover administrative, territorial, technical, financial and environmental aspect.

2011

IUP Reconciliation

1 May 20111st Phase Reconciliation

Oct-Nov 20122nd Phase Reconciliation

Korsup KPK Mineral & Coal

Status per Feb 2016

Status per April 2016

15 April 2014 Delegation of non-CnC IUP from regency to province

Information:

12 Provinces: Central Sulawesi, Riau Island, East Kalimantan, South Kalimantan, Central Kalimantan, West Kalimantan, South Sumatera, Jambi, Bangka Belitung, North Maluku, Southeast Sulawesi and South Selatan

19 Provinces: Aceh, North Sumatera, Riau, West Sumatera, Bengkulu, Lampung, Banten, Maluku, Papua, West Papua, West Java, East Java, Central Java, DIY, East Nusa Tenggara, West Nusa Tenggara, North Sulawesi, West Sulawesi and Gorontalo

Korsup KPK Current conditionIUP Evaluation by Gov Delegation to Province

May Jun Apr Jun - Dec Mar - Oct Feb Apr

2012-2013 2014 2015 2016

Total : 9,662 Total : 10,971 Total : 10,922 Total : 10,332 Total : 10,331 Total : 10,348

C&C: 3,778 C&C: 6,004 C&C: 6,042 C&C: 6,374 C&C:6,365 C&C: 6,366

Non C&C: 5,884

Non C&C: 4,913

Non C&C: 4,880

Non C&C: 3,948

Non C&C: 3,966

Non C&C: 3,928

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Figure 3. Classification of the Problems of non-CnC IUP

Source: Directorate General of Mineral and Coal, MEMR, 2016 (processed)

Group-6 Group 3 + 4Group-7 Group 2 + 4Group-8 Group 1 + 5

The Problems of Non-CNC IUP

(Non Rock)

Territorial Administrative Territorial & Administrative

Group-1 1. Shift/ Expansion

of the Coordinate2. Overlap with the

same commod-ities

3. More than 50% of IUP are is in the conservation forest

4. Overlap with the same com-modities and an administrative area

Group-2 1. Coordinate is

not perpen-dicular

2. Less than 50% of IUP area is in the conservation forest

Group-3 1. Overlap with

different commodities

2. Overlap (wholly or partly) with an adminis-trative area of other regency

Group-4General Ad-ministration

Group-5 1. Doesn’t go

through KP Exploration but rather jump into KP Exploitation for mineral & coal

2. Allotment & relinquishment of IUP proposed before Law 4/2009 in an effective KK/PK-P2B/KP/IUP, area of KK/PKP2B/KP just relinguished after Law 4/2009. IUP is issued be-fore/after WIUP relinguishment

3. KP issued after Law 4/2009 (12 January 2009)

Mining Permit Governance in the Forest Area

Ecologically, forest plays an important role in maintaining the balance of nature; water supply for human life and all life on earth through natural cycles; the lungs of the world; as well as a habitat for a wide

range of biodiversity. According to the law, mining activity that’s located in the forest area is categorized as Use of Forest Area (PKH). PKH is defined as the use of a portion of forest for development other than forestry activities without changing the function and designation of forest. PKH is conducted by Borrow and Use of Forest Area Permit (IPPKH) through the submission

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to the Minister of Environment and Forests. IPPKH is closely related to the compensation for land or compensation payment of non-tax revenues (non-tax revenues, IUPPKH).

Based on the explanation of Korsup Minerba team, the overlay of the map of all IUP and Contract of Work (COW) & Working Agreement on Coal Mining Business (PKP2B) with forest area map and IPPKH in Indonesia resulted total area of mining permit and contract in the forest area and IPPKH amounted 38,894,231 Hectaress, consisting IUP area of 34,727,334 Hectaress; COW area of 2,210,698 Hectaress; PKP2B area of 1,956,194 Hectaress (Directorate General of Planning, Ministry of Forestry, 2014). Table 2 illustrates the data overlay conducted by the Directorate General of Planning, Ministry of Forestry.

Table 2. Overlay of IUP, COW and PKP2B with Forest Area Map and IPPKH – National

Type of Permits

Conserva-tion Protection Production Forest Land for Other

Uses Grand

Forest (A) Forest (B) Forest ( C) Area (D=A+B+C) (E) Total (D+E)

             

IUP 1,160,181 3,922,584 17,909,481 22,992,246 11,735,091 34,727,338

Operation Production 18,819 173,196 2,022,352 2,214,367 2,232,884 4,447,250

CnC 10,852 75,068 1,612,090 1,698,010 1,730,613 3,428,623

NonCnC 7,967 98,128 410,262 516,357 502,271 1,018,627

Survey/Exploration 1,141,363 3,749,388 15,887,130 20,777,880 9,498,814 30,276,694

CnC 119,499 1,380,574 8,057,850 9,557,924 5,125,754 14,683,678

NonCnC 1,021,863 2,368,814 7,829,279 11,219,956 4,373,060 15,593,016

             

COW 110,219 890,541 837,558 1,838,318 372,380 2,210,698

Operation Production 10,166 236,046 285,484 531,696 151,654 683,350

Survey/Exploration 100,053 654,496 552,075 1,306,624 220,725 1,527,348

             

PKP2B 101,998 123,752 927,171 1,152,921 803,274 1,956,194

Operation Production 10,074 16,695 539,780 566,549 698,355 1,264,904

Survey/Exploration 91,924 107,056 387,390 586,370 104,919 691,290

Grand Total 1,372,398 4,936,878 19,674,211 25,983,486 12,910,744 38,894,231

Source: Directorate General Planning, Ministry of Forestry, 2014 (processed)

According to the law, mining activity that’s located in the forest area is categorized as Use of Forest Area (PKH).

In particular, the overlay result also shown 1.37 million Hectaress area of IUP/KK/PKP2B located in conservation forest and 4.93 million Hectaress also located in protection forest. In fact, referring to Law 41/1999 on Forestry, the use of forest areas for development other than forestry activities can only be carried out for activities that have a strategic goal that cannot be circumvented, and are only allowed in the production forest area and/or protected forest area with special provisions. While in the conservation forest (especially in the nature reserve, wilderness zone, and a core zone of the national park) is completely

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prohibited for mining activities.

The use of forest area for mining activities are carried out by the following provisions: (1) If located in production forest area, it shall be conducted through open-pit mining mechanism and/or underground mining; (2) If located in protection forest area, it can only be conducted through underground mining mechanism, with several provisions, including prohibition on causing the decline of ground level, changing the core functions of the forest area permanently and damaging groundwater aquifers (underground layers containing water and can drain the water). The use of forest and forest area basically shall be adjusted with the principal function of forests, namely conservation, protection and production functions. Therefore, the provision for the issuance of permits of forest use shall be followed by the implementation of all obligations and good governance, which is accompanied by plans for rehabilitation and reclamation of forests and land use in order to maintain the balance of the ecosystem (Abdullah, 2015).

Mining Permit Governance by Local Government

Local government is a crucial stakeholder in the implementation of the Korsup Minerba, particularly related to permit governance, since most of the permits in sub-national are issued by the Regent/Mayor

and Governor. The division of local government role in the initial design of the implementation of the Korsup Minerba is specifically shown in figure 4.

• Preparing Data & Information of IUP issued by regency/city

• Implementing the action plan in the region (monitoring-evaluation and reporting)

• Preparing Data & Information of IUP issued by regency/city

• Implementing the action plan in the region (monitoring-evaluation and reporting)

• Coordinating data collection of the regency/city & Facilitating coordination meeting of cross-agency and cross-district/municipality.

• Coordinating the implementation of the action plan (monitoring-evaluation and reporting) at the regency/city level.

Regency

Provincial Government

The use of forest and forest area basically

shall be adjusted with the principal

function of forests, namely conservation,

protection and production functions.

Figure 4. The Role of Local Government in Korsup

Minerba

Source: Korsup Minerba KPK, 2014 (processed)

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The role of local government in the permit governance is mainly carried out through coordinating data and information related to IUP and its status, rechecking administrative and territorial requirement, checking the obligations of license holders such as payment of tax and financial obligation, reclamation and post-mining rehabilitation fund, as well as other obligations such as the construction of the

Table 3. Total of IUP and CnC Status

Province Total of IUP

(2014)

Total of IUP

(Per April 2016)IUP CnC IUP Non-CnC IUP CnC IUP Non-CnC

NAD 48 102 48 89North Sumatera 67 44 67 44Riau 45 47 52 40Riau Island 114 47 89 31West Sumatera 136 145 142 149Jambi 200 198 185 68South Sumatera 276 83 234 51Bengkulu 91 66 91 61Lampung 148 93 119 78Bangka Belitung 484 601 790 353Banten 27 60 35 53West Java 329 290 329 291Central Java 143 132 142 114Yogyakarta 1 15 1 2East Java 187 150 195 152Bali N/A N/A 0 10West Nusa Tenggara 34 116 38 117East Nuasa Tenggara 134 172 145 163Maluku 90 12 93 11West Papua 34 81 38 77Papua 40 85 40 93West Kalimantan 370 312 389 260Central Kalimantan 555 311 580 312South Kalimantan 404 441 429 408East Kalimantan 993 450 856 309North Kalimantan 186 65 127 31Central Sulawesi 244 199 211 114South Sulawesi 172 242 212 218Southeast Sulawesi 314 184 361 101North Sulawesi 70 55 71 54West Sulawesi 45 28 14 17North Maluku 227 108 207 97Gorontalo 23 23 31 14Central N/A N/A 5 0

6,231 4,957 6,366 3,982

Source: MEMR, 2016 (processed)

smelter and the obligation to manage related permits such as IPPKH and production permit (after exploration). Then the next measures taken by local government includes relinquishment of IUP area and revocation of IUP which are operated in the conservation/protection forest, has been expired, also non-CnC IUP. The number of non-CnC IUP status in every province of Korsup presented in table 3.

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Follow up of Korsup Minerba

Along with the enactment of Law No. 23/2014 on Local Government

in October 2014, the regency/city no longer has the authority to

issue IUP. Through this policy, the implementation of government

affairs, particularly in term of the issuance of mining permits only carried

out by the central government and the provincial government. The

previous authority possessed by regency/city are completely drawn into

the province. This delegation of the authority mandates that the handover

of personnel, funding, infrastructure, and documents (P3D) must be

completed within a period of two years after the law is enacted, which is

October 2, 2016.

Thus, the action plan of mining permit (IUP) governance which is part

of Korsup Minerba action plan is in line with the ongoing process of P3D.

Therefore, the MEMR issued Ministerial Decree of Energy and Mineral Resources 43/2015 in order to accelerate the evaluation process of

CnC conducted by the governor, which is no later than 90 working days

since its issuance date. The implementation of the decree is supported

by follow-up to accelerate the process, including the issuance of Circular

Letter of the Directorate General of Mineral and Coal No.01.E/30/DJB/2016

dated January 5, 2016 which describes the decree, the Director General of

Mineral and Coal held coordination meeting with the Head of the Energy

and Mineral Resources Provincial Agencies (February 2, 2016), as well as

undertook an inventory of non-CnC IUP recorded in the Directorate General

of Mineral and Coal and need to be resolved by the governor. Scope of

Ministerial Decree 43/2015 is illustrated in figure 5.

Along with the enactment of Law

No. 23/2014 on Local Government in October

2014, the regency/city no longer has the

authority to issue IUP.

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Figure 5. Category of Evaluation for the Issuance of IUP

Source: Ministerial Decree of Energy and Mineral Resources 43/2015

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Recommendations

1. Immediately curbing the non-CnC IUP and IUP which is operated in the conservation and protection forest. The action taken shall

be in accordance with applied regulation also its appointed deadline:

Ministerial Decree of Energy and Mineral Resources 43/2015 and the

provision of Law 23/2014 regarding process of handover of personnel,

funding, facilities and infrastructure as well as document from regency

government to provincial government. If the appointed deadline

has been passed, but still there is no significant progress, Minister of

Energy and Mineral Resources may take an action to curb the non-

CnC IUP by issuing temporary suspension. This is in line with Article

152 of Law 4/2009.

2. Immediately issuing Presidential Decree on moratorium of mining permit, thus no more issuance of new permit during the evaluation

process until all non-CnC IUPs, which has yet to meet territorial and

administrative requirement, has been curbed or resolved. Moratorium

on mining permit is President Joko Widodo statement in the

declaration of a national movement to rescue wild animals and plants

in Karya Island, Seribu Archipelago, Jakarta.

3. Immediately revitalizing and developing permits database which is also integrated with national One Map policy, by applying a

valid mapping and spatial coordinate system also single identity

mechanism for company registry. Development of integrated data is

crucial to prevent any problematic IUP, prevent in-eligible company

to get mining permit, and prevent any violation of technical and

environmental provisions. Integrated database system also facilitates

monitoring process of compliance on state revenue payments,

environmental and social obligations, as well as coordination and

evaluation across-government agencies.

4. Immediately improving mineral and coal mining permit mechanism both in national and sub-national, which shall be

integrated, in line with one map policy, and accommodate applied

authority division system. The improvement mechanism refers

to improvement of transparency and accountability to prevent

corruption, verification process that considers local community rights

and environmental rights, also a mechanism that enables to mitigate

environment, economic and social risks and impacts.

Development of integrated data is crucial to prevent

any problematic IUP, prevent in-

eligible company to get mining permit,

and prevent any violation of technical

and environmental provisions.

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References

1. Abdullah, Maryati and Jensi Sartin. 2015. Tata Kelola, Penerimaan Negara, dan Dana Bagi Hasil Sektor Kehutanan. (Publish What You Pay Indonesia: Jakarta).

2. Tim Litbang KPK. 2014. Gerakan Nasional Penyelamatan Sumber Daya Alam. Komisi Pemberantasan Korupsi.

3. ____________, Undang-Undang Nomor 4 Tahun 2009 tentang Pertambangan Mineral dan Batubara berikut penjelasannya, Lembaran Negara RI.

4. ____________, Undang-Undang Nomor 19 Tahun 2004 tentang Kehutanan berikut penjelasannya, Lembaran Negara RI.

5. ____________, Peraturan Menteri Energi dan Sumber Daya Mineral Nomor 43 Tahun 2015 tentang Tata Cara Evaluasi Penerbitan Izin Usaha Pertambangan Mineral dan Batubara, Lembaran Negara RI.

WritersMaryati AbdullahNational Coordinator, Publish What You Pay Indonesia

Meliana LumbantoruanResearch and Knowledge Manager, Publish What You Pay Indonesia

Translated to English Rizky Ananda Wulan Sapta RiniProgram Manager, Publish What You Pay Indonesia

Meliana LumbantoruanResearch and Knowledge Manager, Publish What You Pay Indonesia

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