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Environmental Monitoring Report – Part 1 # Semiannual Report January-June 2018 June 2018
INO: West Kalimantan Power Grid Strengthening
Project
Prepared by Pusat Manajemen Proyek (Pusmanpro) for the PT PLN and the Asian
Development Bank.
CURRENCY EQUIVALENTS (as of 30 June 2018)
Currency unit – Indonesian rupiah (Rp) Rp1.00 = $0.0000700869
$1.00 = Rp14,268
NOTE
(i) In this report, "$" refers to US dollars. This environmental monitoring report is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature. In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.
PT PLN (PERSERO) UIP KALBAGBAR
Jl. Letjend Suprapto No. 50 G, Pontianak Kalimantan Barat
Strengthening
West Kalimantan Power Grid Project
Environmental Semi Annual Report
January - June 2018
ADB Loan No.3015-INO
AFD Loan No: CID102401B
Submitted by:
PT PLN (Persero)
July 2018
ii
ABBREVIATIONS
ADB - Asian Development Bank
AFD - Agence Française de Développment
EHS - Environmental Health and Safety
EMP - Environmental Management Plan
EMF - Electric and Magnetic Fields
HVTL High Voltage Transmission Line
HIV/AIDS - Human Immunodeficiency Virus/Acquired Immune Deficiency Syndrome
IEE - Initial Environmental Examination
KBB - Kalimantan Bagian Barat (West of Kalimantan Region)
OSH - Occupational Safety and Health (known as Sistem Manajemen
Keselamatan Kerja or SMK3 according to the requirement of Indonesian
Government)
PIC - Project Implementation Consultant
PLN - PT Perusahaan Listrik Negara (Persero) is the state-owned electricity
company
PMU Project Management Unit
ROW - Right of Way
HVTL - High Voltage Transmission Line
EHVTL - Extra High Voltage Transmission Line
HVDC High Voltage Direct Current
UKL -UPL - Upaya Pengelolaan Lingkungan and Upaya Pemantauan Lingkungan
(environmental management and monitoring effort document)
UPP - PT PLN (Persero) Unit Pelaksana Proyek
UIP - PT PLN (Persero) Unit Induk Pembangunan (UIP) X is the previous name
of PLN UIP Kalimantan Bagian Barat
Ha - Hectare
Km - Kilometre
kV - Kilovolt
m - Meter
MVA - Megavolt Ampere
iii
TABLE OF CONTENTS
ABBREVIATIONS ........................................................................................................................... ii
TABLE OF CONTENTS .................................................................................................................. iii
LIST OF TABLE ..............................................................................................................................iv
LIST OF APPENDICES ..................................................................................................................iv
Chapter 1 Introduction ................................................................................................................... 1
Chapter 2 Summary of the Work Progress ..................................................................................... 4
Chapter 3 Environmental Mitigation ................................................................................................ 5
3.1 Package 3: 150 kV Bengkayang – Ngabang – Tayan Power Transmission Lines
(Construction) 6
3.2 Package 5: 150/20 kV Sanggau – Sekadau Substation (Construction) 14
3.3 Package 6 and 7: 150 kV Tayan – Sanggau – Sekadau Transmission Line (Construction
Phase: Foundation work) 25
Chapter 4 Environmental Monitoring ............................................................................................. 40
4.1 Package 3: 150 kV Bengkayang – Ngabang – Tayan Transmission Line 41
4.2 Package 5: 150/20 kV Tayan Extension - Sanggau - Sekadau Substation 45
4.3 Package 6: 150 kV Tayan - Sanggau Transmission Line 49
Chapter 5 Key findings on EMP Implementation and Corrective Action ........................................ 53
Chapter 6 ADB Mission Findings .................................................................................................. 59
Chapter 7 Conclusions .................................................................................................................. 64
iv
LIST OF TABLE
Table 1 Summary of the Work Progress......................................................................................... 3
Table 2 Environmental Mitigation Status of Package 3 .................................................................... 6
Table 3 Environmental Mitigation Status of Package 5 .................................................................. 14
Table 4 Environmental Mitigation Status of Package 6 and 7 ........................................................ 25
Table 5 Environmental Monitoring Status of Package 3 ................................................................ 41
Table 6 Environmental Monitoring Status of Package 5 ................................................................ 45
Table 7 Environmental Monitoring Status of Package 6 ................................................................ 49
Table 8 Key Findings on EMP Implementation and Corrective Actions ......................................... 54
Table 9 Environmental Finding/Status Identified in June, December 2017 and May 2018 ADB/AFD
Missions .......................................................................................................................... 60
LIST OF APPENDICES
Appendix 1 Project Organization Chart
Appendix 2 The Mitigation Implementations of 150 kV Bengkayang – Ngabang - Tayan
Transmission Line
Appendix 3 The Mitigation Implementations of 150 kV Tayan Extension, Sanggau and
Sekadau Substations
Appendix 4 The Mitigation Implementations of 150 kV Tayan – Sanggau – Sekadau
Transmission Line
Appendix 5 The Mitigation Implementations of 150 kV Sanggau – Sekadau Transmission
Line
Appendix 6 EMF and Air Quality Monitoring Result
Appendix 7 Corrective Action and Mitigation Implementation
Semiannual Environmental Report January – June 2018 1
Chapter 1 Introduction
Project Background. The Government of the Republic of Indonesia has signed loan agreements
with the Asian Development Bank (ADB) and the Agence Françoise de Développment (AFD) in the
amount of US$ 49.5 million each to provide funding required by PT Perusahaan Listrik Negara
(PLN Persero). The project includes construction of 82-km long 275 kV power transmission line
from the border of Sarawak in Mambong (East Malaysia) to Bengkayang (West Kalimantan of
Indonesia) and 275/150 kV substation at Bengkayang. In addition, the construction of 145-km long
of 150 kV transmission line from Bengkayang - Ngabang – Tayan as well as installation of 150/20
kV substations at Ngabang and Tayan kV are financed by this loan. The location of the project
within the context of Kalimantan Island is presented in Map 1.
PLN had assigned the joint venture of Tractebel Engineering Ltd. and Power Grid International
Limited (Thailand), Contract No. 0107.PJ/041/DIR/2013 (dated 30 July 2013), to carry out the
monitoring on environmental, health and safety (EHS) implementation related to the construction of
the power transmission line and substations for the period of July - December 2017. This
monitoring report has been prepared to reflect the status of EHS implementation by the project in
accordance to the requirements of the Environmental Management Plans specified in the Initial
Environmental Examination (IEE) documents for the Strengthening West Kalimantan Power Grid
Project. The monitoring report has been prepared in accordance with the requirements of the IEE
document (dated July 2011) - Appendix F: Sample Mitigation Compliance Inspection Monitoring
and Appendix G: Sample Project Environmental Progress and Monitoring Report.
This monitoring report has been prepared in accordance with the requirements of the IEE
document (dated July 2011). Following ADB review of the report in 2017, the monitoring report has
been revised by PT PLN (Persero) Pusat Manajemen Konstruksi which is a unit of PLN responsible
for construction management. PLN Pusmankon takes over the works previously handled by the
contractors mentioned earlier.
Scope and Management of the Project. The EMP implementation described in the environmental
monitoring report of January – June 2018 covers the following construction works:
Package 3: 150 kV power transmission line from Bengkayang to Ngabang (92-km long),
and from Ngabang to Tayan (53-km long);
Package 5: 150/20 kV Tayan Extension, Sanggau and Sekadau Substation;
Package 6: 150/20 kV Tayan – Sanggau Transmission Line; and
Package 7: 150/20 kV Sanggau – Sekadau Transmission Line.
Environmental and OSH implementation of West Kalimantan Strengthening Project is managed by
PLN Head Office, represented by K3L Division as the Project Management Unit (PMU). The PMU
is supported by Project Implementation Unit. PT PLN (Persero) UIP KALBAGTIM, for package 1
and 2, is located in Balikpapan and PT PLN (Persero) UIP KALBAGBAR is located in Pontianak for
package 3 to 7, in which the working areas are divided as such: Environmental and OSH
supervision is controlled by PLN UPP Kalbagbar with 3 located in Singkawang for package 3 and
4, and UPP Kalbagbar 2 located in Sintang for Package 5, 6 and 7. PLN is supported by PLN
Semiannual Environmental Report January – June 2018 2
PUSMANKON as Project Implementation Consultant (PIC) for environmental and OSH monitoring
and reporting of the project. The environmental and OSH implementation and Management
organization chart is detailed in Appendix 1.
Semiannual Environmental Report January – June 2018 3
Map 1 Project Location within Kalimantan Island
Legend:
: International Borders
: 275 kV Transmission line
: 150 kV Transmission line
: 275 kV Substation
: 150 kV Substation
Jagoibabang
275/150 kV Bengkayang SS
150/20 kV Ngabang SS
150/20 kV Tayan SS
150/20 kV Sanggau SS
150/20 kV Sekadau SS
Semiannual Environmental Report January – June 2018 4
Chapter 2 Summary of the Work Progress
The status and progress of the implementation of West Kalimantan Power Grid Strengthening
Project for January – June 2018 period is summarized in Table 1. The project activities conducted
in this period was mainly construction work that included stringing phase for transmission lines on
package 3, vegetation clearing work for substation on package 5, and foundation work for
transmission line on packages 6 and 7.
Table 1 Summary of the Work Progress
Project Packages / Contractor Status and Progress (as of December 2017) Key Party in Charge
Package 3: 150 kV Bengkayang - Ngabang – Tayan Power Transmission Lines
Consortium of KEC International
Ltd and Mitsubishi Corporation
Construction phase - comprising:
Bengkayang – Ngabang transmission line completed; and
Ngabang – Tayang transmission line: String works of the power line is ongoing (project progress is approximately 31%).
Unit Pelaksana Proyek
Kalimantan Bagian Barat 3
(UPP KBB 3)
Package 5: 150/20 kV Sanggau and Sekadau Substations and extension of Tayan substation
PT Siemens Indonesia and
Siemens Malaysia Bhd
construction phase – land clearing
Unit Pelaksana Proyek
Kalimantan Bagian Barat 2
(UPP KBB 2)
Package 6: 150/20 kV Tayan – Sanggau Power Transmission Line
PT Krakatau Engineering and PT
Citramas Heavy Industries
construction phase – land clearing and foundation
work
Unit Pelaksana Proyek
Kalimantan Bagian Barat 2
(UPP KBB 2)
Package 7: 150/20 kV Sanggau – Sekadau Power Transmission Line
PT Krakatau Engineering and PT
Citramas Heavy Industries
construction phase – land clearing and foundation
work
Unit Pelaksana Proyek
Kalimantan Bagian Barat 2
(UPP KBB 2)
Semiannual Environmental Report January – June 2018 5
Chapter 3 Environmental Mitigation
The status and outcomes of the environmental mitigation conducted for Packages 3, 5, 6 and 7 in
the period of January - June 2018 is described in the following sub-chapters of this report.
The environmental mitigation measures defined in Table 9.1 Environmental Management Plan of
the Project’s Initial Environmental Examination or IEE (2011) should be conducted for construction
phase under Package 3 (Bengkayang – Ngabang – Tayan power transmission lines). The
mitigation measures implemented by the Project for Package 3 is reported in Sub-chapter 3.1
The Project’s IEE (2016) applies for Packages 5, 6 and 7. The construction activity currently
underway is the 150 kV Sanggau and Sekadau substations and extension of Tayan substation for
Package 5, 150 kV Tayan – Sanggau power transmission lines for Package 6, and Sanggau –
Sekadau power transmission line for Package 7. Therefore, the environmental mitigation defined in
Construction Phase section of Table 28 Environmental Management Plan of the IEE should be
conducted. The mitigation measures implemented by the Project for Packages 5 to 7 are reported
in Sub-chapters 3.2 to 3.4.
Semiannual Environmental Report January – June 2018 6
3.1 Package 3: 150 kV Bengkayang – Ngabang – Tayan Power Transmission Lines (Construction)
The Bengkayang – Ngabang – Tayan transmission lines were in the construction phase with stringing of the power lines as the primary activity in the
Semester 1/2018 period. The progress of the construction phase is reported 100% as of the end of June 2018. Table 2 describes the mitigation
measures implemented by the Project for this construction activity, including its compliance level against the mitigation requirements defined in the
IEE (2011).
Table 2 Environmental Mitigation Status of Package 3
No Potential Impacts / Mitigation Requirements per IEE
(2011) Mitigation Implemented Compliance Status / Remarks
1. Vegetation Clearing (HVTL alignment)
The RoW is sited so as to avoid high value plantation
trees and mature secondary forest trees as practical
as possible.
The alignment of transmission line routes has
considered avoiding plantation and forestry areas as
indicated in tower schedule. However, several towers
pass through the forest area as this situation cannot
be avoided. For this reason, PLN has secured the
Head of Capital Investment Coordinating Board
Decree No. 6/1/IPPKH/PMDH/2017 (dated on
January 16, 2017) on Forestry Permits (Izin Pinjam
Pakai Kawasan Hutan or IPPKH) to enable
construction and operation of parts of the
transmission line crossing the forest area. The copy of
this permit is included in Appendix 2.a.
Based on this IPPKH permit, PLN will conduct
reclamation and re-vegetation in 2018 – 2021 for
forest areas that have been disturbed by the
construction of the transmission line.
The mitigation implemented with this
regard is compliant with its
requirement.
Vegetation removal will only be allowed within the
designated width of the RoW and the minimum area
required for other infrastructure and activities.
Vegetation cutting within the RoW will be undertaken
to achieve the required clearances.
Vegetation cutting within the RoW was conducted to
achieve the required clearance in accordance with the
requirements of the MEMR Regulation No. 18/2015.
The mitigation implemented with this
regard is compliant with its
requirement.
Tree removal and trimming will only be undertaken by
hand tools, including chain saws.
No tree removal was undertaken during the Semester
1/2018 period.
Not applicable.
The use of herbicides will be strictly prohibited. The prohibition on the use of herbicides has been stated
in the monthly MoM on February 15, 2018, although
vegetation removal is not conducted during the reporting
The mitigation implemented with this
regard is compliant with its
requirement.
Semiannual Environmental Report January – June 2018 7
No Potential Impacts / Mitigation Requirements per IEE
(2011) Mitigation Implemented Compliance Status / Remarks
period, as shown of Appendix 2.a.
Local people will be allowed access to cleared
vegetation for the collection of building materials and
firewood.
No vegetation clearing was conducted during the
reporting period. Therefore, this mitigation requirement
not conducted.
Not applicable.
Burning of cleared vegetation will not be allowed;
instead this material will be used to protect the soil
from erosion, particularly in steeper slope areas, until
more permanent soil protection measures are in
place.
No vegetation clearing conducted during the reporting
period. However, the contractor has provided the
warning sign that the burning of cleared vegetation is
prohibited during this project (as shown in Appendix
2.a)
The mitigation implemented with this
regard is compliant with its
requirement.
2. Soil Erosion (HVTL alignments)
Soil erosion control measures have been
incorporated into the engineering design, including
the use of tower legs with adjustable height which
allow the tower to conform to the slope of the site,
thereby reducing land cutting and erosion.
In addition, mitigations designed in accordance with
relevant guidelines and good construction practices,
adapted to suit the requirements at each site, will
include:
Minimizing the extent and duration of land
disturbance on steep slopes;
Using sandbags, banks or channels to divert
water flows from upslope around the disturbed
area;
Using vegetation cut during the establishment of
the RoW to protect the disturbed ground on a
temporary basis; and
The soil erosion control measures will be
regularly inspected and maintained during
construction and until the area is stabilized and
re-vegetated.
This mitigation requirement is not applicable for the
reporting period as the stringing works of the power
transmission lines do not cause soil disturbance.
Photo showing the stringing activity is included in
Appendix 2.b.
Not applicable.
3. Drainage (Substation)
The mitigation requirements for drainage are intended for the operation of transmission lines. Therefore, it is not
applicable for the operation of substation reported in this table.
Not applicable
4. Acid Sulphate Soils (HVTL alignments, Substations)
Semiannual Environmental Report January – June 2018 8
No Potential Impacts / Mitigation Requirements per IEE
(2011) Mitigation Implemented Compliance Status / Remarks
No areas of potentially acid forming soil have been
identified in the Project alignment. However, if such
conditions are encountered, the following mitigations
will apply:
If possible, excavation (such as for tower bases)
should be avoided in areas with permanently
saturated soil, peat and swamp (if such are
encountered).
If it is not possible to avoid these areas, then care
should be taken to minimize the exposure to air and
drying of saturated soil. The purpose is to minimize
oxidation, for instance: minimize the time in which the
excavation is left open; If possible, soil that is
saturated at the time of excavation should be
returned to the excavation on completion so that it
remains saturated thus preventing oxidation;
excavated soil which is saturated at the time of
excavation should be mixed with lime to neutralize
acidity, especially in the surface layers; and excess
oil should be mixed with lime and buried.
The construction of tower bases and sub-stations
has been designed to avoid areas with permanently
saturated soil, peat and swamp, and hence
minimizing the potential for encountering acid
sulphate soil conditions.
Nevertheless, the Project reportedly does not have
formal procedures to anticipate acid sulphate soil
conditions or have communicated this precaution to
the Contractors.
The mitigation implemented with this
regard is not compliant with its
requirement.
5. Water Quality Impacts (HVTL alignments, substation)
To protect against impacts on water quality arising
from the spillage of oil, fuel and other hazardous
materials, good international practices will be
adopted, including:
Fuel, oil and hazardous materials will be stored in
designated areas with temporary impermeable
bunds in accordance with international standards
and at distance of at least 100 m from any water
course.
Refueling of machinery, equipment and vehicles
will be undertaken at distance of at least 100 m
from any water course.
Any major work including oil changing and engine
maintenance with the potential for oil to be spilled
will be done in designated areas at distance of at
least 100 m from any water course with
Fuel, oil and hazardous materials and wastes were
stored in the contractor's warehouse without proper
segregation.
Refueling of vehicles was undertaken at the gas
station. However, refueling of the stringing machine
was carried out at the construction site at adequate
distance from water courses.
Any major work including oil changing and engine
maintenance with the potential for oil to be spilled
was conducted at the workshop.
Relevant evident related to the above descriptions is
shown in Appendix 2.c.
The mitigation implemented with this regard is partially compliant with its
requirements.
Semiannual Environmental Report January – June 2018 9
No Potential Impacts / Mitigation Requirements per IEE
(2011) Mitigation Implemented Compliance Status / Remarks
containment to prevent any oil spills
Waste oil shall be collected and taken away for
recycling.
Oil contaminated material shall be disposed of at
designated waste disposal facilities.
Herbicides will not be used in the Project. The prohibition on the use of herbicides has been stated
in the monthly MoM on February 15, 2018, although
vegetation removal is not conducted during the reporting
period, as shown earlier in Appendix 2.a.
The mitigation implemented with this
regard is compliant with its
requirement.
6. Air Quality Impact
Substation construction sites and access roads
should be sprayed with water as necessary to
suppress dust.
Accumulated soil and debris should be cleaned
from the adjacent tarmac roads as required.
Trucks should pass through a water pit when
leaving the site, and excessively muddy trucks
should be washed prior to departure from site.
Truckloads should be covered, with the exception
of on-site or local trips.
Cut and fill should be balanced to the maximum
extent possible at each site in order to minimize
the need for fill and for spoil disposal.
Soil and temporary spoil piles should be covered or
sprayed if generating dust. Piles that are not going to
be used in the short term should be allowed to
develop vegetation cover.
The main activity conducted for Package 3 is stringing of
the transmission line involving the use of stringing
machine, light vehicles, and the cable itself. This activity
does not cause major dust generation, soil and debris,
cut and fill, muddy trucks, and spoil piles. Therefore, the
mitigation requirements as defined herein are not
relevant during the reporting period.
Not applicable.
7. Construction Waste Management (HVTL alignments, Substations)
Solid wastes generated from construction activities
should not be haphazardly left around construction
sites:
Construction waste will be contained in a designated
area on each site (tower site, substation or
substation access road).
Wastes will be routinely collected and disposed of at
The contractor has provided trash bags placed at
designed areas within the construction site. Trash
bags that have been full of construction garbage on a
regular basis have been disposed to Tebedak final
disposal owned by Sanggau District. Supporting
documents related to this mitigation are shown in
Appendix 2.d.
The mitigation implemented with this
regard is compliant with its
requirements.
Semiannual Environmental Report January – June 2018 10
No Potential Impacts / Mitigation Requirements per IEE
(2011) Mitigation Implemented Compliance Status / Remarks
licensed waste disposal facilities.
8. Domestic Waste Management (Worker Camps)
Temporary worker camps will be required to be
provided with appropriate sanitation facilities,
including water supply, washing facilities,
temporary toilets, and waste containers.
Based on ADB mission in December 2017 related to the
workers camp conditions that are still not feasible, on
March 2018 the contractor has increased the number of
worker camp into 2 houses rented from the local people
and improved the sanitation facilities, including water
supply, washing facilities, temporary toilets, and waste
containers.
Supporting documents related to this mitigation are
shown in Appendix 2.e.
The mitigation implemented with this
regard is compliant with its
requirements.
Toilets should either by of a pit type that are at
least 20 m from any water body, or porta-potty
type. If the latter, toilets should be emptied on a
regular or as needed basis, and the effluent
disposed of at an approved waste disposal facility.
As stated earlier the contractor has improved the
sanitation facilities of worker camp as shown in
Appendix 2.e.
Worker camp sanitation facilities should be
developed in consultation with relevant local
authorities and has all required local, province and
national approvals.
The contractor does not develop the sanitation facilities.
Therefore this mitigation requirement is not applicable.
All worker camps should be decommissioned at the
moment it is no longer required and restored to
their natural condition.
Since the temporary worker camp is rented local
people’s houses, so there is no requirement to
conduct the mentioned restoration. Therefore, this
mitigation requirement is not applicable.
9. Roads and Infrastructure (Roads adjacent to HVTL alignments, substations)
A survey will be done at the commencement of the
Project to determine the initial condition of such
assets and infrastructure.
No survey was undertaken as the construction activity
during the reporting period was primarily stringing
works. Therefore, this mitigation requirement is not
applicable.
Not applicable.
Any damaged infrastructure will be repaired to at
least the same standard and condition on
completion of the Project.
Based on observation, at this stringing phase there is
no significant road damage occurred (as shown in
Appendix 2.f)
The mitigation implemented with this
regard is compliant with its
requirements.
10. Encroachment into Protected Forests, Hunting, Wood Collection (HVTL alignments and Gunung Condong)
Hunting and extracting done by workers of forest PLN has conveyed a message in the project’s The mitigations implemented with this
Semiannual Environmental Report January – June 2018 11
No Potential Impacts / Mitigation Requirements per IEE
(2011) Mitigation Implemented Compliance Status / Remarks
products, such as firewood and keeping of firearms
on the Project, will be prohibited.
In addition, Protection Forests and other sensitive
areas will be designated “no go” areas and will be strictly off limit for all workers.
meeting that prohibits all workers about the
mitigation requirements related to accessing forest
and forest products, including maintaining firearms
on the Project areas at MoM on February, 15 2018.
Signpost prohibiting encroachment into protected
forest, hunting and wood collection is posted at
Appendix 2.g.
regard are compliant with its
requirements.
11. Occupational Health and Safety (HVTL alignments, substations)
Prior to the commencement of civil works a
construction phase Occupational Health and Safety
Plan (OHSP) will be developed. The OHSP should:
identify and minimize, so far as reasonably
practicable, the causes of potential hazards to
workers, including communicable diseases such as
HIV/AIDs and vector borne diseases;
provide preventive and protective measures,
including modification, substitution, or elimination
of hazardous conditions, with particular attention to
live power lines, working at height, EMFs, and
exposure to chemicals;
provide measures for the management and
appropriate disposal of hazardous wastes to
ensure protection of the workforce and the
prevention and control of releases and accidents;
provide for the provision of appropriate personal
protective equipment (PPE) to minimize risks;
provide training for workers, and establish
appropriate incentives to use and comply with
health and safety procedures and utilize PPE;
include procedures for documenting and reporting
occupational accidents, diseases, and incidents;
and
Include emergency prevention, preparedness, and
response arrangements in place.
KEC International Limited as the contractor of the
power transmission lines of Package 3 has
developed an environment, health and safety (EHS)
plan. The plan is signed but not scheduled yet, and
therefore its validity is unknown as shown in Appendix 2.h.
The EHS plan provides guidance and procedures
primarily for safety aspects and few for environment
aspects which area considered adequate for
implementation by the Project, including:
EHS Policy
Organization structure
Project safety committee
Organization and responsibility
Personnel protective equipment, including rules
and training for fall protection; belt inspection; and
lanyard inspection.
First aid procedures
Safety rules for store area, maintenance personal,
transmission line construction
Emergency management plan
Accident notification, reporting and investigation
General provisions for environment protection and
waste management.
KEC has implemented the EHS plan by, among
others:
providing safety induction to workers and
providing incentives to workers who obey the OSH
The mitigation implemented with this
regard is partially compliant with its
requirement.
Semiannual Environmental Report January – June 2018 12
No Potential Impacts / Mitigation Requirements per IEE
(2011) Mitigation Implemented Compliance Status / Remarks
rules and use APD properly;
submitting monthly reports including documenting
and reporting occupational accidents, diseases,
and incidents; and
Establishing emergency response procedures
including provision of first-aid kids, fire
extinguishers, and emergency call lists at
construction sites.
Relevant evident of these mitigation measures are
included in Appendix 2.h.
However, the EHS plan does not provide
procedures for risk identification and minimization of
potential hazards to worker including corresponding
preventive and protective measures.
12. Community Health and Safety (HVTL alignments, substations)
Prior to the commencement of civil works, a
construction phase Community Health and Safety
Plan (CHSP) will be developed. The CHSP should
include:
procedures to identify and minimize, so far as
reasonably practicable, the causes of potential
Project related hazards to local communities,
including communicable diseases such as
HIV/AIDs and vector borne diseases;
specific emergency response procedures;
emergency contacts and communication systems/
protocols;
procedures for interaction with local and regional
emergency and health authorities;
emergency equipment and facilities (e.g. first aid
stations, fire extinguishers/hoses, sprinkler
systems);
protocols for fire truck, ambulance and other
emergency vehicle services;
evacuation routes and meeting points; and drills.
KEC International Limited (KEC) does not have a
specific CHSP for the construction of power
transmission lines of Package 3, although some
elements required for it are included in the existing
EHS plan described in the OHS plan described
earlier, as follow:
establishing and providing emergency response
procedures and emergency response equipment
and facilities including provision of first-aid kids,
fire extinguishers, and emergency call lists at
construction sites.
providing emergency contact and communication
system/procedures.
providing the evacuation routes, meeting point
and drills.
providing emergency vehicles services at site
location.
Relevant evident of these mitigation measures are included in Appendix 2.i.
However, the EHS plan does not cover the community
health and safety is procedures for interaction with
The Project is partially compliant
with its mitigation requirement.
Semiannual Environmental Report January – June 2018 13
No Potential Impacts / Mitigation Requirements per IEE
(2011) Mitigation Implemented Compliance Status / Remarks
local and regional emergency and health authorities;
13. Employment Opportunities (HVTL alignments, substations)
The requirements defined to mitigate impacts arising from the employment opportunities are defined and
reported in the social monitoring report submitted separately from this report.
Not applicable.
14. Physical Cultural Resources (HVTL alignments, Substations)
A chance find procedure will be in place:
If physical cultural resources are encountered
during the construction phase, all works at the find
site should be immediately halted.
The find should be assessed by a competent
expert, and procedures to avoid, minimize or
mitigate impacts to the physical cultural resources
should be developed by the expert in cooperation
with the relevant local heritage authority,
proportionate to the value of the resource in
question and the nature and scale of the Project’s potential adverse impacts on it.
Work should not begin until the procedures to
avoid, minimize or mitigate impacts to the physical
cultural resources have been implemented.
When avoidance is not feasible, no alternatives to
removal exist, and the Project benefits outweigh
the anticipated cultural heritage loss from removal,
the physical cultural resource should be removed
and preserved according to the best available
technique.
Any removal should be conducted in accordance
with relevant provisions of national and/or local
laws.
Records should be maintained of all finds,
including chain of custody instructions for movable
finds.
All Project workers and staff should be made
aware of the chance find procedure.
There have been no reports conveyed or reported by
the contractor related to physical cultural resources
within the construction site of the transmission line
within this reporting period. However, the chance find
procedure has not been developed by the Project.
The Project is not compliant with the
mitigation requirement as the chance
find procedure has not been
developed.
Semiannual Environmental Report January – June 2018 14
3.2 Package 5: 150/20 kV Sanggau – Sekadau Substation (Construction)
The Sanggau – Sekadau substations were in the construction phase with clearing vegetation as the primary activity in the Semester
I/2018 period. The progress of the construction phase is reported 0.805% as of the end of June 2018. Table 3 describes the mitigation
measures implemented by the Project for this construction activity, including its compliance level against the mitigation requirements
defined in the IEE (2016).
Table 3 Environmental Mitigation Status of Package 5
No Potential Impacts / Mitigation Requirements per IEE
(2016) Mitigation Implemented Compliance Status / Remarks
1. Vegetation Clearing (HVTL alignments, substations)
Vegetation removal will be allowed with the
designated width of the RoW and the minimum
area required for other infrastructure and activities.
This mitigation requirement is not applicable for the
construction of the substation reported herein as it is
intended for the construction of the transmission line.
Not Applicable.
Vegetation cutting within the RoW will be
undertaken to achieve the required clearances.
This mitigation requirement is not applicable for the
construction of the substation reported herein as it is
intended for the construction of the transmission line.
Not Applicable.
For transmission lines, tree removal and trimming
will only be undertaken by hand tools, including
chain saws.
This mitigation requirement is not applicable for the
construction of the substation reported herein as it is
intended for the construction of the transmission line.
Not Applicable.
For Substation, Clearing vegetation will be
conducted with the combination of cutting trees
with hand and chainsaw, while the stump removal
will be conducted by bulldozer.
Clearing vegetation at the substation site is conducted
with the combination of cutting trees with hand and
chainsaw, while the stump removal will be conducted
by bulldozer as shown in Appendix 3.a
The mitigation implemented with this
regard is compliant with its requirement.
The use of herbicides will be strictly prohibited Project has implemented the visual management
related to the prohibition on the use of herbicide at the
construction site as shown in Appendix 3.a
The mitigation implemented with this
regard is compliant with its requirement.
Local people will be allowed access to cleared
vegetation for the collection of building materials
and firewood.
The land owner and local people participated during
vegetation removal process and took the cut wood or
the vegetation for their domestic purposes as shown
in Appendix 3.a
The mitigation implemented with this
regard is compliant with its requirement.
Burning of cleared vegetation will not be allowed;
instead this material will be used to protect the soil
from erosion, particularly in steeper slope areas,
until more permanent soil protection measures are
There is a visual management as the prohibition on
burning waste at the construction site as shown in
Appendix 3.a
The mitigation implemented with this
regard is compliant with its requirement.
Semiannual Environmental Report January – June 2018 15
No Potential Impacts / Mitigation Requirements per IEE
(2016) Mitigation Implemented Compliance Status / Remarks
in place.
2. Soil Erosion (HVTL alignments, substations)
Soil erosion control measures have been
incorporated into the engineering design, including
the use of adjustable height tower which allow the
tower to conform to the slope of the site, thereby
reducing land cutting and erosion.
This mitigation requirement is not applicable for the
construction of the substation reported herein as it is
intended for the construction of the transmission line.
Not Applicable
In addition, mitigations is designed in accordance
with relevant guidelines and good construction
practices adapted to suit the requirements at each
site e.g:
The mitigations is designed in accordance with
relevant guidelines and good construction practices
adapted to suit the requirements that have been
implemented at each site as described below:
Not Applicable
a) Transmission line:
On steep slope:
- Minimizing the extent and duration of land
disturbance
- Using sandbags, banks or channels to divert
water flows from upslope around the disturbed
area;
- Using vegetation cut or foliage to protect
disturbed ground on a temporary basis
On dry flat area, using vegetation cut or foliage to
protect disturbed ground from rain water gives
impact on a temporary basis
Rice field and wet area no significant erosion is
anticipated
a) Transmission line:
This mitigation requirement is not applicable for the
construction of the substation reported herein as it is
intended for the construction of the transmission line.
Not Applicable
b) Substation area:
Compaction the soil will be conducted in the
embankment areas, and embankments should be
re-vegetated with local grasses, and covered with
protecting layers of rice straw or similar material to
guard against rapid gully and rill erosion.
b) Substation area:
The current activities on substation are site clearing and
a temporary fence construction. In order to prevent
erosion, in the early construction phase, compaction
has been carried out in the embankment area at the
location of the Sanggau substation as shown in
Appendix 3.b
The mitigation implemented with this
regard is compliant with its requirement.
Construction of slope protection (e.g. retaining wall,
gabions etc). And planting of vegetation strips
shrubs and grasses across contours of exposed
slopes.
As stated earlier, there is no construction of slope
protection yet; therefore this mitigation is not applicable
during S1/2018.
Not Applicable
Semiannual Environmental Report January – June 2018 16
No Potential Impacts / Mitigation Requirements per IEE
(2016) Mitigation Implemented Compliance Status / Remarks
Under the outdoor equipment there will be
deployed gravel over the land; the unused open
area will be covered with grass and small plants.
There will be very limited erosion problem.
As stated earlier, therefore this mitigation is not
applicable during S1/2018.
Not Applicable
The soil erosion control measures will be regularly
inspected and maintained during construction and
until the area is stabilized or re-vegetated.
Soil erosion control have been carried out and
monitored regularly during this construction until
completion period.
The implementation of soil erosion control measure has
been reported in the HSE monthly report by the
contractor.
The documentation related to this mitigation is shown in Appendix 3.b
The mitigation implemented with this
regard is compliant with its requirement.
3. Drainage (substations)
Site drainage plans will be developed in accordance
with good drainage practices management for each
substation, including constructing above flood levels
and ensuring drainage around the site is provided for
high storm flows.
The final drainage design drawing have not been
submitted by the contractor, therefore the mitigation
steps by constructed drainage above the flood level and
ensured drainage around the site provided for high
storm flow have not been implemented yet.
The mitigation measures implemented by the Project are not compliant with
its mitigation requirement.
4. Water Quality Impacts (HVTL alignments, substations)
Mitigation measures to protect water quality from
erosion are the same as “Vegetation Clearing” and “Soil Erosion, above. To protect against impacts on water quality arising
from spillage of oil, fuel and other hazardous
materials, good international practices will be
adopted, including:
Fuel, oil and hazardous materials will be stored in
designated areas with temporary impermeable
bunds in accordance with international standards
and at distance of at least 100 m from any water
course.
Refueling of machinery, equipment and vehicles
will be undertaken at distance of at least 100 m
from any water course.
Any major work including oil changing and engine
Fuel, oil and hazardous materials and wastes were
stored in the contractor's warehouse without proper
segregation.
According to PLN DIVK3L letter
No.0199/KLH.01.02/KDIVK3L/2017 (dated 15 May
2017) on Repairing and Organizing Material
Storage Containing Hazardous Material stipulates
the technical and administrative requirements
related to management of hazardous materials and
wastes.
Refueling of vehicles was undertaken at the gas
station. However, refueling of the stringing
machine was carried out at the construction site at
adequate distance from water courses.
Any major work including oil changing and engine
maintenance with the potential for oil to be spilled
The mitigation implemented with this regard is partially compliant with its
requirements.
Semiannual Environmental Report January – June 2018 17
No Potential Impacts / Mitigation Requirements per IEE
(2016) Mitigation Implemented Compliance Status / Remarks
maintenance with the potential for oil to be spilled
will be done in designated areas at distance of at
least 100 m from any water course with
containment to prevent any oil spills washing away.
Waste oil shall be collected and taken away for
recycling.
Oil contaminated material shall be disposed of at
designated waste disposal facilities.
was conducted at the workshop.
Relevant evident related to the above descriptions
were shown in Appendix 3.c.
Herbicides will not be used in the Project There is a visual management related to the prohibition
on the use of herbicides at the construction site as
shown in Appendix 3.c
The mitigation implemented with this
regard is compliant with its requirement.
5. Air Quality Impacts (HVTL alignments, substations)
Spray the dusty soil within substation construction
area with water
The main activities during this period is land clearing,
therefore this mitigation are not applicable.
Not Applicable
Accumulated soil and debris should be cleaned
from adjacent asphalt roads in the entrance of
substation.
Accumulated soil and debris has been cleaned from
adjacent asphalt roads in the entrance of substation as
shown in Appendix 3.d
The mitigation implemented with this
regard is compliant with its requirement.
Truckloads with dusty soil should be
covered, with the exception of on-site or local trips.
Trucks operating in this period transported vegetation
cleared waste to the final disposal which located near
the substation's location (local trips). Therefore this
mitigation measures are not applicable in this period.
Not Applicable
Cut and fill should be balanced to the maximum
extent possible at each site in order to minimize the
need for fill and spoil disposal.
The cut and fill volume corresponds to Bill of Quantity
(BoQ) contract and drawing design. The current
activities on substation are only site clearing work and
a temporary fence construction. There is no cut and fill
activities yet. Therefore this mitigation measure is not
applicable during this reporting period.
Not Applicable
Construction waste and garbage burning are
prohibited.
PLN has already conveyed a prohibition on burning of
construction waste and garbage during construction in
monthly meetings with contractors.
There is a visual management related to the prohibition
on waste burning at the construction site as shown in
Appendix 3.d
The mitigation implemented with this
regard is compliant with its requirement.
Semiannual Environmental Report January – June 2018 18
No Potential Impacts / Mitigation Requirements per IEE
(2016) Mitigation Implemented Compliance Status / Remarks
6. Construction Waste Management (HVTL alignments, substations)
Solid wastes generated from construction activities
should not be haphazardly left around construction
sites.
Construction waste will be contained in a
designated area on each site (tower site,
substation).
Wastes will be routinely collected and disposed of
at safe waste disposal facilities indicated by the
District Environmental agencies
The remaining clearing materials in the form of wood
and tree roots are collected at the temporary disposal in
the construction site. Then it’s stored into the empty
land owned by residents who are willing to be used as
the location of waste disposal of site clearing materials
as shown in Appendix 3.e
The mitigation implemented with this
regard is compliant with its requirement.
Construction waste burning is prohibited PLN has already conveyed a prohibition on burning of
construction waste and garbage during construction in
monthly meetings with contractors.
In the implementation, there is a visual management
related to the prohibition on waste burning at the
construction site as shown in Appendix 3.e.
The mitigation implemented with this
regard is compliant with its requirement.
7. Domestic Waste Management (HVTL alignments, substations)
Temporary worker camps will be required to be
provided with appropriate sanitation facilities,
including water supply, and washing facilities,
temporary toilets, and waste containers.
The temporary worker of the contractor’s camp is a
rented house from the local people, which has been
equipped with good sanitation facilities including
adequate water supply obtained from groundwater,
washing and toilet facilities, and a trash bag to collect
domestic waste as shown in Appendix 3.f.
The mitigation implemented with this
regard is compliant with its requirement.
Domestic waste will be routinely collected and
disposed of at safe waste disposal facilities
Domestic garbage of workers collected in trash bag has
been discharged to the nearest final disposal from the
worker camp ie; Sei Kosak and Sanggau final disposal
as shown in Appendix 3.f
Toilets should either by of a pit type that are at
least 20 m from any water body, or porta-potty
type. If the latter, toilets should be emptied on a
regular or as needed basis, and the effluent
disposed of at an approved waste disposal facility.
The Contractor does not develop the sanitation
facilities, and therefore this mitigation requirement is not
applicable.
Worker camp sanitation facilities should developed
in consultation with relevant local authorities and
has all required local, province and national
The rented house has sanitation facilities; therefore the
requirement of this mitigation is not applicable.
Semiannual Environmental Report January – June 2018 19
No Potential Impacts / Mitigation Requirements per IEE
(2016) Mitigation Implemented Compliance Status / Remarks
approvals
All worker camps should be decommissioned when
it is no longer required and restored to their natural
condition.
Since the temporary worker camp is renting local
people house, so, there is no requirement to conduct
the mentioned restoration. Therefore, this mitigation
requirement is not applicable.
Garbage burning is prohibited. PLN has already conveyed a prohibition on burning of
construction waste and garbage during construction in
monthly meetings with contractors.
In the implementation there is a visual management
related to the prohibition on waste burning in the project
as shown in Appendix 3.f
8. Roads and Infrastructure Impacts (HVTL alignments, substations)
A mapping of the locations of expected heavy
equipment mobilization is needed versus
settlement area locations. This needs inventory and
monitors the potential damage to existing roads.
The using of heavy equipment only applied to the
open storage area. Its location is far away from
settlement area.
The mitigation implemented with this
regard is compliant with its requirement.
Any damaged infrastructure, after heavy equipment
mobilization, will be repaired to at least the same
standard and condition on completion of the
Project, especially caused by the transportation of
heavy equipment e.g. 150 kV power transformer.
In the site clearing phase there is no heavy
equipment mobilization, therefore there is no road damage during this period as shown in Appendix 3.g
The mitigation implemented with this
regard is compliant with its requirement.
9. Encroachment into Protected Forests, Hunting, Wood Collection (HVTL alignments, substations)
Hunting extraction by workers of forest products such
as firewood, and keeping of firearms on the Project,
will be prohibited. To avoid impact on ecological
valuable sites, habitats, natural forest, flora and fauna,
this risk should be particularly be monitored along the
ecologically sensitive alignments of the Transmission
line: along the 35 km between Tayan and Sosok where
the alignment passes close by secondary forest within
production forest reserves; along the alignment which
runs close (3.5. and 11 km) to the primary forest within
Gunung Tiong Kandang and Gunung Sanggau; and
along the alignment which passes close (1.5 km
In accordance with letter from the Ministry of Forestry
No.S386 / BPKH.III-2/2015 dated May 13, 2015
regarding the Result of Technical Review of the
Function of Forest Areas Against the location of SUTT,
West Kalimantan Province stated that the location of
the Tayan – Sanggau – Sekadau – Sintang HVTL plan
is entirely Other Use Areas.
The Tayan, Sanggau and Sekadau substations is
located on the land owned by local residents.
In the implementation there is a visual management
related to the prohibition on encroachment into
protected forest, hunting and wood collection in the
The mitigation implemented with this
regard is compliant with its requirement.
Semiannual Environmental Report January – June 2018 20
No Potential Impacts / Mitigation Requirements per IEE
(2016) Mitigation Implemented Compliance Status / Remarks
distant) to the primary forests of the Pancur Aji Forest
Recreation Reserve.
project site as shown in Appendix 3.h
10. Impacts on Cultural Heritage Sites(HVTL alignments, substations)
The Project area falls closely adjacent several notable
heritage sites:
Although, it is unlikely to suffer impact from Project
due to separation distance (as a mitigation
measure for these sites), Project workers should be
made aware that these sites should not be
disturbed or material extracted if visited. Project
construction traffic and heavy equipment should
also not be routed anywhere near these sites to
avoid vibration damage.
During site clearing, there is no heavy equipment
transportation activity such as transformers that have
the potential to cause vibration that can damage the
nearest cultural heritage site. Therefore mitigation
measures in this period are not applicable.
Not Applicable
The Project Transmission Line construction
should also take care not to make impact on the
potential un- mapped locally important cultural
sites, such as community sacred forest groves
(Hutan Adat) and sacred grave sites (tempat
keramat). Consultation should be conducted with
local Traditional Leaders (Temengung) for each
indigenous ethnic group to identify and avoid any
such sites prior to construction of all project works.
To anticipate the existence of the potential un- mapped
locally important cultural sites, prior to the start of
construction; the contractor has coordinated with the
customary head in the Ngudas event and ascertained
no construction site that passes through this location
as shown in Appendix 3.i
The mitigation implemented with this
regard is compliant with its requirement.
11. Occupational Health and Safety (HVTL alignments, substations)
Prior to the commencement of civil works a
construction phase Occupational Health and Safety
Plan (OHSP) will be developed. The OHSP should:
identify and minimize, so far as
reasonably practicable, the causes of potential
hazards to workers, including communicable
diseases and vector borne diseases;
provide preventive and protective
measures, including modification, substitution, or
elimination of hazardous conditions, with
particular attention to live power lines, working at
height, working during thunderstorms (lightning
strikes), EMFs, and exposure to chemicals;
Provide measures for the management and
PT Siemens as the contractor of package 5 has
developed an occupational health & safety plan
that has been reviewed and signed dated on
February, 12 2018 as shown in Appendix 3.j
The EHS plan provides guidance and
procedures primarily for safety aspects and few
for environment aspects which area considered
adequate for implementation by the Project,
including:
- Hazard Communication Program
- Carcinogen Policy
- General Hazard
The mitigation implemented with this regard is partially compliant with its
requirement.
Semiannual Environmental Report January – June 2018 21
No Potential Impacts / Mitigation Requirements per IEE
(2016) Mitigation Implemented Compliance Status / Remarks
appropriate disposal of hazardous wastes to
ensure protection of the workforce and the
prevention, and to control of releases and
accidents;
Provide the provision of appropriate personal
protective equipment (PPE) to minimize risks;
Provide training for workers, and establish
appropriate incentives to use and comply with
health and safety procedures and utilize PPE;
Include procedures for documenting and reporting
occupational accidents, diseases, and incidents;
and
Include emergency prevention, preparedness, and
response arrangements in place.
- Personal Protective Equipment
- Exposure to Element
- Flammable Materials
- Safety, Health and Environmental Training
- General Safe work Practices
- Detailed Descriptions
- Buried Services
- Compressed Gas cylinders
- Electricity
- Fire Prevention
- Hand tools
- Heavy Lifting Equipment
- Scaffolding and Ladder
- Illumination
- Housekeeping
- Work Planning and Job Safety Analysis
(JSA)
- Medical Surveillance
- OHSE Inspection/Audits
- Emergency Response and Procedure
- Recordkeeping and Reports
- Emergency Preparedness
- Accident Reporting Procedure
- Evacuation Procedure
PT Siemens has implemented the EHS plan by,
among others:
providing safety induction to workers OSH rules
and use PPE properly;
providing appropriate personal protective devices
(PPE) to minimize the risk;
submitting monthly reports including documenting
and reporting occupational accidents, diseases,
and incidents; and
Semiannual Environmental Report January – June 2018 22
No Potential Impacts / Mitigation Requirements per IEE
(2016) Mitigation Implemented Compliance Status / Remarks
Establishing emergency response procedures
including provision of first-aid kids, fire
extinguishers, and emergency call lists at
construction sites.
Relevant evident of these mitigation measures are included in Appendix 3.j
However, the EHS plan does not provide
identification and minimization of potential
hazards to worker including corresponding
preventive and protective measures.
12. Community Health and Safety (HVTL alignments, substations)
Prior to the commencement of civil works a
construction phase Community Health and Safety Plan
(CHSP) will be developed. The CHSP should include:
procedures to identify and minimize, so far as
reasonably practicable, the causes of
potential Project related hazards to local
communities, including communicable
diseases such as HIV/AIDs and vector borne
diseases;
The houses and settlements in close
Location from the Transmission line should be
clearly spatially mapped in order to better
inventory and address the EMF (electro-
magnetic fields) health and safety impact risk.
An effective socialization program should
follow in this at the mapped locations to
address community concerns in regard to the
EMF effects of Transmission line operation.
specific emergency response procedures;
Relevant emergency equipment.
Protocols for emergency vehicle services;
Put safety sign.
PT Siemens does not have a separate health
and safety plan for managing health and safety
risks to the community. Some health and safety
provisions as described in the OHSP (above)
are applicable for managing these risks
including of :
- Providing specific emergency response
procedures, emergency equipment. and
vehicles;
- Providing the safety sign
Relevant evident of these mitigation measures are
included in Appendix 3.j
However, the EHS plan does not cover the
procedures to identify and minimize, so far as
reasonably practicable, the causes of potential Project
related hazards to local communities, including
communicable diseases such as HIV/AIDs and vector
borne diseases.
The mitigation implemented with this regard is partially compliant with the
mitigation requirements.
13. Employment Opportunities (HVTL alignments, substations)
to Communicate about employment opportunities on a regular basis and to demonstrate the efforts are made Not Applicable.
Semiannual Environmental Report January – June 2018 23
No Potential Impacts / Mitigation Requirements per IEE
(2016) Mitigation Implemented Compliance Status / Remarks
to accommodate as many people as possible.
Be clear about the limited possibility and communicate this limitation during the meetings
Give priority to impact affected people to participate with the project works e.g. in transmission work the
material transportation from roadside to tower site, and other unskilled and semi-skilled available labor –either transmission line works and substation works
14. Physical Cultural Resources (HVTL alignments, substations)
. Awareness to all workers concerning chance find
physical cultural resources during construction
implementation:
If physical cultural resources are encountered
during the construction phase, all works at the find
site should be immediately halted.
The find should be assessed by a competent
expert, and procedures to avoid, minimize or
mitigate impacts to the physical cultural resources
should be developed by the expert in cooperation
with the relevant local heritage authority,
proportionate to the value of the resource in
question and the nature and scale of the Project’s potential adverse impacts on it.
The find should be assessed in
consultation with local Traditional Leaders
(Temenggung) for each indigenous ethnic group
to identify the local cultural significance and
obtain guidance on what follow-up actions to
conduct under supervision of local communities.
Work should not begin until the
procedures to avoid, minimize or mitigate impacts
to the physical cultural resources have been
implemented.
In case avoidance is not feasible, no alternatives
to removal exist, and the Project benefits outweigh
the anticipated cultural heritage loss from removal;
the physical cultural resource should be
removed and preserved according to the best
available technique.
A chance find procedure from PT Siemens has been
developed on EHSP document page 50 chapter 5.32
about Unexpected discovery. But the contractor has
not conducted the awareness to the employee yet
regarding this procedure.
Relevant documents related to this mitigation are
shown on Appendix 3.k
The mitigation implemented with this
regard is partially compliant with its
requirement.
Semiannual Environmental Report January – June 2018 24
No Potential Impacts / Mitigation Requirements per IEE
(2016) Mitigation Implemented Compliance Status / Remarks
Any removal should be conducted in accordance
with relevant provisions of national and/or local
laws.
Records should be maintained of all finds, including
chain of custody instructions for movable finds.
All Project workers and staff should be made
aware of the chance-find procedure.
Semiannual Environmental Report January – June 2018 25
3.3 Package 6 and 7: 150 kV Tayan – Sanggau – Sekadau Transmission Line (Construction Phase: Foundation work)
The Tayan – Sanggau – Sekadau transmission lines were in the construction phase with clearing vegetation as the primary activity in
the Semester I/2018 period. The progress of the construction phase is reported 10.6% for package 6 Tayan – Sanggau and 10.40 % for
package 7 Sanggau - Sekadau as of the end of June 2018. Table 4 describes the mitigation measures implemented by the Project for
this construction activity, including its compliance level against the mitigation requirements defined in the IEE (2016).
Table 4 Environmental Mitigation Status of Package 6 and 7
No Potential Impacts / Mitigation Requirements per IEE
(2016) Mitigation Implemented Compliance Status / Remarks
1. Vegetation Clearing (HVTL alignments, substations)
Vegetation removal will be allowed with the
designated width of the RoW and the minimum
area required for other infrastructure and activities.
Vegetation cutting within the RoW will be
undertaken to achieve the required clearances.
Vegetation cutting within the RoW was conducted to
achieve the required clearance in accordance with
the requirements of the MEMR Regulation No.
18/2015.
The mitigation implemented with this
regard is compliant with its requirement.
For transmission lines, tree removal and trimming
will only be undertaken by hand tools, including
chain saws.
In the PT KE’s HSE plan document on page 27 of
chapter 7.22 concerning Environmental Management
sub clause vegetation clearing. It is mentioned that
vegetation clearing such as cutting trees can only be
done manually (using a chainsaw).
During this foundation work phase, tree removal and
trimming process only be undertaken by hands tools,
including chain saw, as shown in Appendix 4.a
The mitigation implemented with this
regard is compliant with its requirement.
For Substation, Clearing vegetation will be
conducted with the combination of cutting trees
with hand and chainsaw, while the stump removal
will be conducted by bulldozer.
This mitigation requirement is not applicable for the
construction of the substation reported herein as it is
intended for the construction of the transmission line.
Not Applicable
The use of herbicides will be strictly prohibited In the PT KE’s HSE plan document on page 28 of
chapter 7.22 concerning Environmental Management
sub clause vegetation clearing it is mentioned that
herbicides is prohibited in vegetation clearing
process.
PLN has already conveyed a prohibition on the use of
pesticides during construction in in Minute of Meeting
monthly HSE on May, 4 2018.
The mitigation implemented with this
regard is compliant with its requirement.
Semiannual Environmental Report January – June 2018 26
No Potential Impacts / Mitigation Requirements per IEE
(2016) Mitigation Implemented Compliance Status / Remarks
The visual management related to the prohibition on the
use of herbicides at the construction site as shown in
Appendix 4.a
Local people will be allowed to access to cleared
vegetation for the collection of building materials
and firewood.
In the PT KE’s HSE plan document on page 28 of
chapter 7.22 concerning Environmental Management
sub clause vegetation clearing. It’s mentioned that the
use of vegetation cleared for buildings or firewood
was only allowed to be used by the surrounding
people.
The land owner and local people participated during
vegetation removal process and took the cut wood or
the vegetation for their domestic purposes as shown
in Appendix 4.a
The mitigation implemented with this
regard is compliant with its requirement.
Burning of cleared vegetation will not be allowed;
instead this material will be used to protect the soil
from erosion, particularly in steeper slope areas,
until more permanent soil protection measures are
in place.
In the contractor's HSE plan document on page 28 of
chapter 7.22 concerning Environmental Management
sub clause vegetation clearing it is mentioned that
burning cleared vegetation were prohibited.
PLN has already conveyed a prohibition on burning of
cleared vegetation during construction in in Minute of
Meeting monthly HSE on May, 4 2018
The visual management related to the prohibition on
burning at the construction site as shown in Appendix
4.a
The mitigation implemented with this
regard is compliant with its requirement.
2. Soil Erosion (HVTL alignments, substations)
Soil erosion control measures have been
incorporated into the engineering design, including
the use of adjustable height tower which allow the
tower to conform to the slope of the site, thereby
reducing land cutting and erosion.
Based on engineering the adjusting of height of tower
is not applicable due to the RoW clearance. Hence, the
design of retaining wall is applied. Therefore this
mitigation measures is not applicable.
Not Applicable
In addition, mitigations, designed in accordance
with relevant guidelines and good construction
practices adapted to suit the requirements at each
site e.g:
The mitigations, designed in accordance with relevant
guidelines and good construction practices adapted to
suit the requirements have been implemented at each
site as described below:
Not Applicable
a) Transmission line:
On steep slope:
- Minimizing the extent and duration of land
a) Transmission line:
In the contractor's HSE plan document on page 28 of
chapter 7.22 concerning Environmental Management
The mitigation implemented with this
regard is compliant with its requirement.
Semiannual Environmental Report January – June 2018 27
No Potential Impacts / Mitigation Requirements per IEE
(2016) Mitigation Implemented Compliance Status / Remarks
disturbance
- Using sandbags, banks or channels to divert
water flows from upslope around the disturbed
area;
- Using vegetation cut or foliage to protect
disturbed ground on a temporary basis
On dry flat area, using vegetation cut or foliage to
protect disturbed ground from rain water impact on
a temporary basis
Rice field and wet area no significant erosion is
anticipated
sub clause soil erosion have been mentioned that the
soil erosion management would be implemented
during construction.
In the implementation.
Transmission line:
On steep slope
The management of erosion conducted at the
current sloping / steep location are:
- Install the embankment, before
construction begins to prevent erosion.
- Using vegetation cut or foliage to
protect disturbed ground on a temporary
basis.
- On dry flat area, using vegetation cut or
foliage to protect disturbed ground from
rain water impact on a temporary basis.
Relevant documentation related to this mitigation is
shown in Appendix 4.b
b) Substation area:
Compaction the soil will be conducted in the
embankment areas, and embankments should be
re-vegetated with local grasses, and covered with
protecting layers of rice straw or similar material to
guard against rapid gully and rill erosion.
Construction of slope protection (e.g. retaining wall,
gabions etc). And planting of vegetation strips
shrubs and grasses across contours of exposed
slopes.
Under the outdoor equipment there will be
deployed gravel over the land; the unused open
area will be covered with grass and small plants.
There will be very limited erosion problem.
b) Substation area:
This mitigation requirement is not applicable for the
construction of the substation reported herein as it is
intended for the construction of the transmission line.
Not Applicable
The soil erosion control measures will be regularly
inspected and maintained during construction and
until the area is stabilized or re-vegetated.
In the contractor's HSE plan document on page 28 of
chapter 7.22 concerning Environmental Management
sub clause soil erosion have been mentioned that the
control of soil erosion will be monitored regularly
during the construction stage until the area is
The mitigation implemented with this
regard is compliant with its requirement.
Semiannual Environmental Report January – June 2018 28
No Potential Impacts / Mitigation Requirements per IEE
(2016) Mitigation Implemented Compliance Status / Remarks
stabilized and re-vegetated
The soil erosion control measure has been reported in
the HSE monthly report by the contractor as shown in
Appendix 4.b
3. Drainage (substations)
The mitigation requirements for drainage are intended for the operation of transmission lines, and therefore not
applicable for the operation of substation reported in this table.
Not Applicable.
4. Water Quality Impacts (HVTL alignments, substations)
Mitigation measures to protect water quality from
erosion are the same as “Vegetation Clearing” and “Soil Clearing”, above
The prevention to protect water quality from erosion
during vegetation clearing as described before in
Chapter 3.3 Number 1 and 2
The mitigation implemented with this
regard is compliant with its requirement.
To protect from impacts on water quality arising
from spillage of oil, fuel and other hazardous
materials to be taken away by licensed third party.
In the contractor's HSE plan document on page 29 of
chapter 7.22 concerning Environmental Management
sub clause Water Quality Impact it is mentioned that
Fuel, oil and hazardous materials must be stored in
designated areas with a minimum distance of 100 m
from the waterway.
PT KE has created oil, fuel and other hazardous
materials warehouses, to prevent its spills and spread
to the environment as shown in Appendix 4.c
The mitigation implemented with this
regard is compliant with its requirement.
Fuel, oil and hazardous materials will be stored in
designated areas with temporary impermeable
bunds in accordance with National standards and
at distance of at least 100 m from any water
course.
In the contractor's HSE plan document on page 29 of
chapter 7.22 concerning Environmental Management
sub clause Water Quality Impact it is mentioned that
Fuel, oil and hazardous materials must be stored in
designated areas with a minimum distance of 100 m
Fuel, oil and hazardous materials have already stored
in designated areas with temporary impermeable
bunds in contractor warehouse accordance with
National standards and at distance of at least 100 m
from any water course as shown in Appendix 4.c
The mitigation implemented with this
regard is compliant with its requirement.
Refueling of machinery, equipment and vehicles
will be undertaken at distance of at least 100 m
from any water course.
In the contractor's HSE plan document on page 29 of
chapter 7.22 concerning Environmental Management
sub clause Water Quality Impact it is mentioned that
refueling of engine fuel, equipment and vehicles must
be carried out at a minimum distance of 100 m from
The mitigation implemented with this
regard is compliant with its requirement.
Semiannual Environmental Report January – June 2018 29
No Potential Impacts / Mitigation Requirements per IEE
(2016) Mitigation Implemented Compliance Status / Remarks
the waterway.
Refueling of machinery, equipment and vehicles will
be undertaken at gas station. However refueling the
concrete mixer machine is carried out at site, at the
time of fuel refueling used external drum to
accommodate in case of oil spill, as shown in
Appendix 4.c
Any major work including oil changing and engine
maintenance with the potential for oil to be spilled
will be done in designated areas at distance of at
least 100 m from any water course with
containment to prevent any oil spills washing away.
Any major work including oil changing and engine
maintenance with the potential for oil to be spilled will
be done in local workshop.
Not Applicable
During construction of tower site in rice field
and wet areas, extra measures shall be applied to
prevent water contamination by the oil drip or
spilled waste water from cement mixers and
concrete.
In the contractor's HSE plan document on page 29 of
chapter 7.22 concerning Environmental Management
sub clause Water Quality Impact it is mentioned that
during construction of tower site in rice field and
wet areas, extra measures should be applied to
prevent water contamination by the oil drip or spilled
waste water from cement mixers and concrete.
Since there is no construction work located at rice field
and wet areas during this period, therefore this
mitigation measures is not applicable.
Not Applicable
Waste oil and oil contaminated material shall be
collected to be taken away by licensed third party.
Waste oil and oil contaminated materials is still only
collected in contractors’ warehouse, because of its
very small / insignificant amount. If the amount of oil
waste has met the requirements for disposal, it will be
submitted to the waste manager to be managed
according to Government Regulation no. 101/2014
concerning Management of Hazardous and Toxic
Wastes.
The mitigation implemented with this
regard is compliant with its requirement.
Oil contaminated material to be taken away by
licensed third party.
As stated earlier The mitigation implemented with this
regard is compliant with its requirement.
Herbicides will not be used in the Project In the contractor's HSE plan document on page 28 of
chapter 7.22 concerning Environmental Management
sub clause vegetation clearing it is mentioned that
herbicides was prohibited in vegetation clearing
The mitigation implemented with this
regard is compliant with its requirement.
Semiannual Environmental Report January – June 2018 30
No Potential Impacts / Mitigation Requirements per IEE
(2016) Mitigation Implemented Compliance Status / Remarks
process.
PLN has already conveyed a prohibition on the use of
pesticides during construction in t Minute of Meeting
monthly HSE on May, 4 2018 and there is a visual
management related to the prohibition on the use of
herbicides at the construction site shown earlier in
Appendix 4.a
5. Air Quality Impacts (HVTL alignments, substations)
Spray the dusty soil within substation construction
area with water
This mitigation requirement is not applicable for the
construction of the substation reported herein as it is
intended for the construction of the transmission line.
Not Applicable
Accumulated soil and debris should be cleaned
from adjacent asphalt roads in the entrance of
substation.
This mitigation requirement is not applicable for the
construction of the substation reported herein as it is
intended for the construction of the transmission line.
Not Applicable
Truckloads with dusty soil should be
covered, with the exception of on-site or local trips.
In the contractor's HSE plan document on page 29 of
chapter 7.22 concerning Environmental Management
sub clause Air Quality Impact has been mentioned
that truckloads with dusty soil should be
covered, with the exception of on-site or local trips.
During this work, excavated soil is not discharged out
of this construction site and will be used as a tower
cover when construction is completed. Therefore this
mitigation requirement is not applicable during this
period.
Not Applicable
Cut and fill should be balanced to the maximum
extent possible at each site in order to minimize the
need for fill and for spoil disposal.
In the contractor's HSE plan document on page 29 of
chapter 7.22 concerning Environmental Management
sub clause Air Quality Impact has been mentioned
that Cut and fill should be balanced to the maximum
extent possible at each site in order to minimize the
need for fill and for spoil disposal.
Since to there is no cut and fills activities yet, therefore
this mitigation measure is not applicable during this
reporting period.
Not Applicable
Construction waste and garbage burning are
prohibited.
In the contractor's HSE plan document on page 17 of
chapter 7.8 concerning Housekeeping, at point 7 it is
mentioned that waste or the rest of materials should
The mitigation implemented with this
regard is compliant with its requirement.
Semiannual Environmental Report January – June 2018 31
No Potential Impacts / Mitigation Requirements per IEE
(2016) Mitigation Implemented Compliance Status / Remarks
not be burned.
PLN has already conveyed a prohibition on burning of
cleared vegetation during construction in Minute of
Meeting monthly HSE on May, 4 2018 and there is a
visual management related to the prohibition on burning
waste at the construction site as shown earlier in
Appendix 4.a
6. Construction Waste Management (HVTL alignments, substations)
Solid wastes generated from construction activities
should not be haphazardly left around construction
sites.
Construction waste will be contained in a
designated area on each site (tower site,
substation).
Wastes will be routinely collected and disposed of
at safe waste disposal facilities indicated by the
District Environmental agencies
The contractor has provided a trash bag to collect the
garbage contained at each tower construction site and
routinely dispose of the waste routinely to Sei Kosak
final disposal owned by Sanggau district and Sekadau
final disposal owned by Sekadau district, as shown in
Appendix 4.d
The mitigation implemented with this
regard is compliant with its requirement.
Construction waste burning is prohibited In the contractor's HSE plan document on page 17 of
chapter 7.8 concerning Housekeeping, at point 7 it is
mentioned that waste or the rest of materials should
not be burned.
PLN has already conveyed a prohibition on waste
burning during construction in monthly meetings with
contractors. The prohibition is written in MoM's monthly
HSE meeting of May 2018 and there is a visual
management related to the prohibition on burning the
construction site as shown earlier in Appendix 4.a.
The mitigation implemented with this
regard is compliant with its requirement.
7. Domestic Waste Management (HVTL alignments, substations)
Temporary worker camps will be required to be
provided with appropriate sanitation facilities,
including water supply, and washing facilities,
temporary toilets, and waste containers.
The contractor's temporary worker camp is a rented
house from the local people, which has been equipped
with good sanitation facilities including adequate water
supply obtained from groundwater, washing and toilet
facilities, and a trash bag to collect domestic waste as
shown in Appendix 4.e
Overall, the mitigation implemented with
this regard is compliant with its
requirements.
Domestic waste will be routinely collected and
disposed of at safe waste disposal facilities
Domestic garbage of workers collected in trash bag will
be discharged to the nearest final disposal stated
Semiannual Environmental Report January – June 2018 32
No Potential Impacts / Mitigation Requirements per IEE
(2016) Mitigation Implemented Compliance Status / Remarks
earlier in Appendix 4.d
Toilets should either by of a pit type that are at
least 20 m from any water body, or porta-potty
type. If the latter, toilets should be emptied on a
regular or as needed basis, and the effluent
disposed of at an approved waste disposal facility.
The Contractor does not develop the sanitation
facilities, and therefore this mitigation requirement is not
applicable.
Worker camp sanitation facilities should developed
in consultation with relevant local authorities and
has all required local, province and national
approvals
As stated earlier
All worker camps should be decommissioned when
no longer required and restored to their natural
condition.
Since the temporary worker camp is renting local
people house, so there is no requirement to conduct
the mentioned restoration. Therefore, this mitigation
requirement is not applicable.
Garbage burning is prohibited. In the contractor's HSE plan document on page 17 of
chapter 7.8 concerning Housekeeping, at point 7 it is
mentioned that waste or the rest of materials should
not be burned.
PLN has already conveyed a prohibition on garbage
burning during construction in monthly meetings with
contractors. The prohibition is written in MoM's monthly
HSE meeting of May 2018 and there is a visual
management related to the prohibition on burning
waste at the construction site, as shown earlier in
Appendix 4.a
8. Roads and Infrastructure Impacts (HVTL alignments, substations)
A mapping of the locations of expected heavy
equipment mobilization is needed versus
settlement area locations. This needs inventory and
monitors the potential damage to existing roads.
No mapping of the locations of expected heavy
equipment mobilization is needed versus settlement
area locations were undertaken during the foundation
works.
The mitigation implemented with this
regard is not compliant with its
requirement.
Any damaged infrastructure after heavy equipment
mobilization will be repaired to at least the same
standard and condition on completion of the
Project, especially caused by the transportation of
heavy equipment e.g. 150 kV power transformer.
In the contractor's HSE plan document on chapter
7.22 page 31 of Environmental Management have
been mentioned that the construction activities and
transportation of building materials (rock, sand and
cement) from supplies and heavy equipment could
cause damage to roads and other local infrastructure.
The mitigation implemented with this
regard is compliant with its requirement.
Semiannual Environmental Report January – June 2018 33
No Potential Impacts / Mitigation Requirements per IEE
(2016) Mitigation Implemented Compliance Status / Remarks
To reduce its impact, the contractor must repair the
damage at least with the same standards and
conditions as before. Mapping the location of heavy
equipment mobilization needs to consider the
location of settlements.
Based on observation, there is no significant road
damage occurred and the contractor has repaired the
damage road immediately, as shown in Appendix 4.f
9. Encroachment into Protected Forests, Hunting, Wood Collection (HVTL alignments, substations)
Hunting extraction by workers of forest products such
as firewood, and keeping of firearms on the Project,
will be prohibited. To avoid impact on ecological
valuable sites, habitats, natural forest, flora and fauna,
this risk should be particularly be monitored along the
ecologically sensitive alignments of the Transmission
line: along the 35 km between Tayan and Sosok where
the alignment passes close by secondary forest within
production forest reserves; along the alignment which
runs close (3.5. and 11 km) to the primary forest within
Gunung Tiong Kandang and Gunung Sanggau; and
along the alignment which passes close (1.5 km
distant) to the primary forests of the Pancur Aji Forest
Recreation Reserve.
In the contractor's HSE plan document on page 31 of
chapter 7.22 Environmental Management have been
mentioned that the contractor must ensure that
project work does not interfere with or pass through
areas that have status as protected forests, wildlife
reserves, national parks or other areas that have
special ecological benefits. The impact of working on
small scale projects such as hunting, lighting fires &
collecting wood must be monitored and minimized.
PLN has already conveyed a prohibition on accessing
forest and forest products, including maintaining
firearms on the Project during construction at Minute of
Meeting monthly HSE on May 2018. The visual
management related its prohibition on project site as
shown in Appendix 4.g
The Project is considered compliant
with this mitigation.
10. Impacts on Cultural Heritage Sites (HVTL alignments, substations)
The Project area falls closely adjacent several notable
heritage sites:
Although unlikely to suffer impact from Project due
to separation distance, as a mitigation measure for
these sites, Project workers should be made aware
that these sites should not be disturbed or material
extracted if visited. Project construction traffic and
heavy equipment should also not be routed
anywhere near these sites to avoid vibration
damage.
In May 2018, capacity building of the IEE 2016
document and implementation was followed by all
implementing contractors and supervisors in the field.
Contractors have been instructed to transport heavy
equipment related to the project not to pass through
cultural heritages sites, as shown in MoM in
Appendix 4.h
The mitigation implemented with this
regard is compliant with its requirement.
The Project Transmission Line construction To anticipate the existence of the potential un- The mitigation implemented with this
Semiannual Environmental Report January – June 2018 34
No Potential Impacts / Mitigation Requirements per IEE
(2016) Mitigation Implemented Compliance Status / Remarks
should also take care not to make impact on the
potential un- mapped locally important cultural
sites, such as community sacred forest groves
(Hutan Adat) and sacred grave sites (tempat
keramat). Consultation should be conducted with
local Traditional Leaders (Temengung) for each
indigenous ethnic group to identify and avoid any
such sites prior to construction of all project works.
mapped locally important cultural sites, prior to the
start of construction; the contractor has coordinated
with the customary head in the Ngudas event and
ascertained no construction site that passes through
this location as shown on Appendix 4.h
regard is compliant with its requirement.
11. Occupational Health and Safety (HVTL alignments, substations)
Prior to the commencement of civil works a
construction phase Occupational Health and Safety
Plan (OHSP) will be developed. The OHSP should:
PT Krakatau Engineering as the contractor of
Package 6 has developed an occupational health &
safety plan since January, 09, 2017.
The EHS plan provides guidance and procedures
primarily for safety aspects and few for
environment aspects which area considered
adequate for implementation by the Project,
including:
- Leadership and Commitment
- HSE Organization and Responsibilities
- Planning and Working Procedures
- Working Control
- Emergency Preparedness
- Reporting
- Audit
- Subcontractor
Relevant supporting documents are presented in
Appendix 4.i
The mitigation implemented with this
regard is compliant with its requirement.
identify and minimize, so far as
reasonably practicable, the causes of potential
hazards to workers, including communicable
diseases and vector borne diseases;
The Environmental Health and Safety Plan (EHSP)
document from KE chapter 7.23 pages 33 concerning
Community Health and Safety has been mention that
contractor will arrange the procedure concerning the
potential hazards that may occur during the
construction and control process including
communicable disease and vector borne disease.
On April 2018 contractor has conducted HIV AIDS
The mitigation implemented with this
regard is compliant with its requirement.
Semiannual Environmental Report January – June 2018 35
No Potential Impacts / Mitigation Requirements per IEE
(2016) Mitigation Implemented Compliance Status / Remarks
training for workers and surrounding people as reported
in Appendix 4.i
provide preventive and protective
measures, including modification, substitution, or
elimination of hazardous conditions, with
particular attention to live power lines, working at
height, working during thunderstorms (lightning
strikes), EMFs, and exposure to chemicals;
The Environmental Health and Safety Plan (EHSP)
document from KE has provide preventive and
protective measures; including modification,
substitution, or elimination of hazardous conditions,
with particular attention to working at height on page
13 chapters 7.
The mitigation implemented with this
regard is compliant with its requirement
Provide measures for the management and
appropriate disposal of hazardous wastes to
ensure protection of the workforce and the
prevention and control of releases and accidents;
In the contractor's HSE document on page 28 chapter
7.20 concerning Hazardous waste management, the
Contractor has established procedures for the
management and appropriate disposal of hazardous
wastes to ensure protection of the workforce and the
prevention and control of releases and accidents;
The contractor has made hazardous waste warehouse
and provides labeling (MSDS) according to the type
and characteristic, as the documentation shown in
Appendix 4.i
The mitigation implemented with this
regard is compliant with its requirement.
Provide for the provision of appropriate personal
protective equipment (PPE) to minimize risks;
In the contractor's HSE document on page 16 chapter
7.7 concerning Personal Protective Equipment (PPE), It
is mentioned that the needs of PPE during the project
were derived from the identification and control of
occupational risks contained in the Job Health Safety
and Environment (JSEA) documents. Types of PPE
adjusted for potential hazards in the work to be
performed.
In implementation workers have used PPE in
accordance with the type of work, as the documentation
is shown in Appendix 4.i
The mitigation implemented with this
regard is compliant with its requirement.
Provide training for workers, and establish
appropriate incentives to use and comply with
health and safety procedures and utilize PPE;
In the contractor's HSE document on page 13 chapter
7.5 concerning Trainings, it is mentioned that PT. KE
conducts regular training related to HSE, both in house
and external training in order to increase competence
regarding HSE.
During this period the contractor has held some training
such as emergency response and HIV AIDS
prevention, as the documentation shown in Appendix
The mitigation implemented with this
regard is compliant with its requirement.
Semiannual Environmental Report January – June 2018 36
No Potential Impacts / Mitigation Requirements per IEE
(2016) Mitigation Implemented Compliance Status / Remarks
4.i
Include procedures for documenting and reporting
occupational accidents, diseases, and incidents;
and
In the contractor's HSE document on page 36 chapter 9
concerning Incident Reporting and Investigation,
contractor has provided procedure for documenting and
reporting occupational accidents, diseases, and
incidents.
The contractor makes a report related to accidents,
disease and incidents and reports it to the HSE
supervisor monthly, as the documentation shown in Appendix 4.i
The mitigation implemented with this
regard is compliant with its requirement.
Include emergency prevention, preparedness, and
response arrangements in place.
In the contractor's HSE document on page 34 chapter 8
concerning Emergency Condition, contractor has
provided procedure for emergency prevention,
preparedness and response arrangements in place.
The contractor has set up the emergency team which
equipped with emergency training procedure and
emergency equipment (first aid kid box, fire
extinguisher, evacuation route, safety sign, etc.) that
can be used in emergency conditions, as shown in
Appendix 4.i
The mitigation implemented with this
regard is compliant with its requirement.
12. Community Health and Safety (HVTL alignments, substations)
Prior to the commencement of civil works a
construction phase Community Health and Safety Plan
(CHSP) will be developed. The CHSP should include:
PT KE's OHSP plan has included procedures related
to community health and safety as stated in the HSE
plan page 34.
All health and safety provisions as described in the
(above) are applicable for managing these risks and
all requirements contained in the IEE 2016 document.
which are specifically addressed in the plan, describe
as below:
The mitigation implemented with this
regard is compliant with its
requirement.
procedures to identify and minimize, so far as
reasonably practicable, the causes of potential
Project related hazards to local communities,
including communicable diseases such as
HIV/AIDs and vector borne diseases;
The Environmental Health and Safety Plan (EHSP)
document from KE chapter 7.23 pages 33 concerning
Community Health and Safety have been mentioned
that contractor would arrange the procedure
concerning the potential hazards that may occur during
the construction and control process including
communicable disease and vector borne disease.
The mitigation implemented with this
regard is compliant with its requirement.
Semiannual Environmental Report January – June 2018 37
No Potential Impacts / Mitigation Requirements per IEE
(2016) Mitigation Implemented Compliance Status / Remarks
On April 2018 contractor has conducted HIV AIDS
training for workers and surrounding people, as the
related evident shown earlier in Appendix 4.i
The houses and settlements in close
Location from the Transmission line should be
clearly spatially mapped in order to better inventory
and address the EMF (electro-magnetic fields)
health and safety impact risk. An effective
socialization program should follow in this at the
mapped locations to address community concerns
in regard to the EMF effects of Transmission line
operation.
Implementation of these mitigation requirements is
described in a social monitoring report submitted
separate from this environmental monitoring report.
Not Applicable
specific emergency response procedures; The Environmental Health and Safety Plan (EHSP)
document from KE chapter 7.23 pages 33 concerning
Community Health and Safety has been mention that
contractor has made the specific emergency response
procedures to the affected people near the project site.
Each construction site has been equipped with
emergency equipment that can be used in emergency
conditions as shown earlier in Appendix 4.i
The mitigation implemented with this
regard is compliant with its requirement.
Relevant emergency equipment. The Environmental Health and Safety Plan (EHSP)
document from KE chapter 7.23 pages 33 concerning
Community Health and Safety has been mentioned that
the contractor would made the relevant emergency
equipment to the affected people near the project site.
The relevant emergency equipment that already in
place is first aid kit and fire extinguisher as shown
earlier in Appendix 4.i
The mitigation implemented with this
regard is compliant with its requirement.
Protocols for emergency vehicle services; The Environmental Health and Safety Plan (EHSP)
document from KE chapter 7.23 pages 33 concerning
Community Health and Safety, has been mentioned
that the contractor would provide emergency contacts
and communication systems for the community, such
as emergency vehicle services to the affected people
near the project site.
The contractor has provided the suggestion car as of
The mitigation implemented with this
regard is compliant with its requirement.
Semiannual Environmental Report January – June 2018 38
No Potential Impacts / Mitigation Requirements per IEE
(2016) Mitigation Implemented Compliance Status / Remarks
transportation in case of emergency as shown in
Appendix 4.j
Put safety sign. The Environmental Health and Safety Plan (EHSP)
document from KE chapter 7.23 pages 34 concerning
Community Health and Safety has been mention that
the contractor will provide the safety sign at the project
location.
Safety sign has been installed in all construction sites,
as the basis of security for the community around the construction site as shown in Appendix 4.j
The mitigation implemented with this
regard is compliant with its requirement.
13. Employment Opportunities (HVTL alignments, substations)
Communicate about employment opportunities on a regular basis and demonstrate the efforts being made to
accommodate as many people as possible.
Be clear about the limited possibility and communicate this limitation during the meetings
Give priority to impact affected people to participate with the project works e.g. in transmission work the
material transportation from roadside to tower site, and other unskilled and semi-skilled available labour
either transmission line works and substation works
Not Applicable
14. Physical Cultural Resources (HVTL alignments, substations)
Awareness to all workers concerning chance find
physical cultural resources during construction
implementation:
If physical cultural resources are encountered
during the construction phase, all works at the find
site should be immediately halted.
The find should be assessed by a competent
expert, and procedures to avoid, minimize or
mitigate impacts to the physical cultural resources
should be developed by the expert in cooperation
with the relevant local heritage authority,
proportionate to the value of the resource in
question and the nature and scale of the Project’s potential adverse impacts on it.
The find should be assessed in
consultation with local Traditional Leaders
(Temenggung) for each indigenous ethnic group
to identify the local cultural significance and
In the contractor's HSE document on page 31 chapter
7.22 concerning Environmental Management section
find chance procedure, there are already procedures for
finding chance concerning physical cultural resources.
But the contractor has not conducted the awareness to
the employee yet regarding this procedure.
The mitigation implemented with this
regard is partially compliant with its
requirement.
Semiannual Environmental Report January – June 2018 39
No Potential Impacts / Mitigation Requirements per IEE
(2016) Mitigation Implemented Compliance Status / Remarks
obtain guidance on what follow-up actions to
conduct under supervision of local communities.
Work should not begin until the
procedures to avoid, minimize or mitigate impacts
to the physical cultural resources have been
implemented.
Where avoidance is not feasible, no alternatives
to removal exist, and the Project benefits outweigh
the anticipated cultural heritage loss from removal;
the physical cultural resource should be
removed and preserved according to the best
available technique.
Any removal should be conducted in accordance
with relevant provisions of national and/or local
laws.
Records should be maintained of all finds, including
chain of custody instructions for movable finds.
All Project workers and staff should be made
aware of the chance-find procedure.
Semiannual Environmental Report January – June 2018 40
Chapter 4 Environmental Monitoring
The outcomes of the environmental mitigation conducted for the Work Packages 3 and 5 to 7 in the
period of January – June 2018 were monitored to ensure its effectiveness and compliance with the
requirements of the environmental monitoring plan defined in the Project’s IEE. The work packages that are in the pre-construction, construction, and operation phases are required to implement
environmental monitoring as defined in the IEE.
The environmental monitoring requirements of Package 3 (i.e. power transmission lines from
Bengkayang to Tayan including associated substations) are defined in Table 9.2 on EMP of the
2011 IEE and its implementation including compliance status is described in sub-chapters 4.1 to
4.3.
The environmental monitoring requirements of Packages 5 to 7 (i.e. power transmission lines from
Tayan to Sekadau including associated substations) are defined in Table 29 on the EMP of the
2016 IEE and its implementation including compliance status is described in sub-chapters 4.2 to
4.3.
Semiannual Environmental Report January – June 2018 41
4.1 Package 3: 150 kV Bengkayang – Ngabang – Tayan Transmission Line
The Bengakayang – Ngabang – Tayan transmission line were in the construction phase with stringing of the power line as the primary
activity in the Semester 1/2018 period. Table 5 describes the environmental monitoring conducted by the Project for this construction
activity, including its compliance level against the mitigation requirements defined in the IEE (2011).
Table 5 Environmental Monitoring Status of Package 3
No Aspects and Means of Monitoring Monitoring Implemented Compliance Status
1. Vegetation Clearing (RoW)
Ensure that vegetation removal mitigations are
implemented within the RoW (monthly during
vegetation clearing).
No vegetation clearing was conducted during the stringing
works of the transmission wires. Therefore, monitoring was
not required during the reporting period.
Not applicable
2. Drainage (Substations)
The monitoring requirement defined under this subject is intended for the construction of substation, and therefore not
applicable for that of transmission lines reported herein.
Not applicable
3. Soil Erosion (Tower and Substation Sites)
Ensure soil erosion control measures applied.
Monitor effectiveness of soil erosion control
measures (monthly during construction).
The construction activity conducted for the reporting period
was primarily stringing of the transmission wires which did
not cause disturbance to the soil layer. Therefore, no
monitoring of soil erosion was implemented.
Not applicable
4. Acid Sulphate Soils (Tower and Substation Sites)
Check for presence of potentially acid forming soils
at construction sites
If encountered, ensure mitigations are implemented
(monthly during construction)
The construction activity conducted for the reporting period
was primarily stringing of the transmission wires which did
not cause disturbance to the soil layer or exposure of acid
sulphate soils. Therefore, no monitoring of acid sulphate soil
was implemented.
Not applicable
5. Water Quality (Construction Sites and Storage Areas)
Ensure mitigation measures are in place with respect to
oil, fuel and other hazardous materials storage,
handling, disposal; and fuelling and maintenance of
equipment (monthly during construction)
Storage and handling of fuel, oil, and hazardous materials
including hazardous/toxic wastes (known as ‘B3’ waste) are implemented by PLN based on the requirements set
out in the Head of Occupational Health & Safety and
Environment Letter No. 0199/KLH.01.02/KDIVK3L/2017
(dated 15 May 2017) on Warehouse Improvement and
Management for B3 and Non-B3 Wastes Generated by
Electricity Distribution.
The implementation of this
monitoring is partially compliant
with the mean of monitoring
defined herein.
Semiannual Environmental Report January – June 2018 42
No Aspects and Means of Monitoring Monitoring Implemented Compliance Status
However, monitoring indicates, the mitigation measures
for water quality with respect to oil, fuel and other
hazardous materials storage, handling, disposal; and
fueling and maintenance of equipment have not been
implemented well.
6. Air Quality (Construction Sites and Storage Areas)
Ensure mitigation measures with respect to dust
control, truck cleaning, load covering, and soil and spoil
pile management are in place (at construction sites and
storages areas)
According to the air quality quarterly monitoring conducted by
Tanjungpura University on Mei 2018 at Tebang Benua village
Balai District and at Tae village, Batang Tarang district, the
concentrations measured are respectively:
For Bengkayang – Ngabang
No Parameter Unit Result
Threshold
Standard
*)
1. Dust µg/Nm3 2.46 230
2. NO2 µg/Nm3 0.34 400
3. Sulfur Dioxide
(SO2)
µg/Nm3 260.27 900
4. Oxidant (O3) µg/Nm3 50.33 235
5. Carbon
Monoxide (CO)
ppm 8 30000
For Ngabang – Tayan
No Parameter Unit Result
Threshold
Standard
*)
1. Dust µg/Nm3 5 230
2. NO2 µg/Nm3 0.58 400
3. Sulfur Dioxide
(SO2)
µg/Nm3 326.19 900
4. Oxidant (O3) µg/Nm3 28.29 235
5. Carbon
Monoxide (CO)
ppm 2 30000
The implementation of this
monitoring is compliant with its
requirements.
Semiannual Environmental Report January – June 2018 43
No Aspects and Means of Monitoring Monitoring Implemented Compliance Status
*) Ambient air quality Government Regulation No. 41/1999.
Relevant air quality measurement result is shown in
Appendix 5.a of this report.
7. Waste Management (Construction Sites and Worker Camps)
Ensure construction and domestic waste management
collection, storage and disposal mitigations are in place
(monthly during construction).
Monitoring result indicates that construction and domestic
waste management was good. Each construction site has
been provided with trash bags and these are disposed of
regularly to the final disposal.
Worker camp improvements have been made by contractors
by adding the rented house and improving sanitation
facilities, including toilets and washing facilities as well as
providing trash bags to be disposed of to the final disposal on
a regular basis as shown earlier in the Appendix 2.d.
The implementation of this
monitoring is in compliant with the
mean of monitoring defined herein.
8. Roads Infrastructure (Construction Sites, access Roads, Relevant District Roads)
Ensure any damage is documented and repaired
(monthly during construction).
The monitoring indicates that there is no road damage during
this construction period (stringing phase), as shown in
Appendix 2.f.
The implementation of this
monitoring is in compliant with the
mean of monitoring defined herein.
9. Encroachment (Gunung Condong in West Kalimantan, Areas adjacent to RoW)
Ensure no hunting or firewood collection is undertaken
by workers, and that Protection Forests and other
sensitive areas are “no go” for workers (i.e. Gunung Condong and areas adjancent to RoW) – monthly
during construction
The visual monitoring conducted by the Project
Implementation Consultant indicates that there is no
hunting or firewood collection undertaken by workers
during this construction period (stringing work).
Warning sign on the prohibition for hunting or firewood
collection has been installed at the construction site as
reminder construction sites as shown in Appendix 2.g.
Conducting this monitoring is
compliant with the requirement
defined herein.
10. Occupational and Community Health and Safety (Construction Sites and Worker Caps)
Ensure construction phase OHS and CHS have been
developed and are being implemented (monthly during
construction)
The monitoring from HSE Supervisor (PIC) indicated that
the OHS plans have been developed and implemented in
the project through, among others: working at height and
provision of PPE and the use of safety harness related to
working at height. Relevant photos indicate this
implementation is shown in Appendix 2.h.
However, there is no evident that CHS (community safety
plan) has been developed and implemented according to
this requirement.
The implementation of this monitoring is partially compliant
with the mean of monitoring
defined herein.
Semiannual Environmental Report January – June 2018 44
No Aspects and Means of Monitoring Monitoring Implemented Compliance Status
11. Employment Status (Construction Sites)
Ensure good communication and transparent process
with local people regarding employment opportunities
Implementation of these monitoring is described in a social
report submitted separate from this environmental
monitoring report.
Not applicable.
12. Physical Culture Resources (Construction Sites)
Ensure chance find procedure is in place and applied if
required
The Chance Find Procedure is not in place for the Work
Package 3, and no formal monitoring has been conducted in
this regard.
The Project is not compliant with
this monitoring requirement.
Semiannual Environmental Report January – June 2018 45
4.2 Package 5: 150/20 kV Tayan Extension - Sanggau - Sekadau Substation
The Tayan Extension – Sanggau – Sekadau substations were in the construction phase with vegetation clearing as the primary activity in the
Semester 1/2018 period. Table 6 describes the environmental monitoring conducted by the Project for this construction activity, including its
compliance level against the mitigation requirements defined in the IEE (2016).
Table 6 Environmental Monitoring Status of Package 5
No Aspects and Means of Monitoring Monitoring Implemented Compliance Status
1. Vegetation Clearing (RoW)
Ensure that vegetation removal mitigations are
implemented
Monitoring indicates that the vegetation removal mitigations
are implemented, as shown earlier in Appendix 3.a.
The implementation of this
monitoring is in compliant with the
mean of monitoring defined herein. Monitor effectiveness of vegetation removal control
measures
Implementation of mitigation measures related to vegetation
removal control has been well-implemented and effective
2. Drainage (Substations)
Ensure drainage plans are implemented Monitoring indicates that the drainage plan is already in the
design engineering document, but until recently it has not
been finalized by the contractor.
The implementation of this
monitoring is not compliant with
the mean of monitoring defined
herein.
Monitor effectiveness of drainage system The construction phase is still in on-site clearing and
therefore the effectiveness of making this drainage system
cannot be measured. Thus, no monitoring of effectiveness of
drainage system was required at this phase.
Not Applicable
3. Soil Erosion (Tower and Substation Sites)
Ensure soil erosion control measures are applied Based on the results of monitoring by the environmental
supervisor from PIC at the location of the Sanggau
substation, erosion prevention has been carried out due to its
location, which is directly adjacent to the river, namely by
creating an embankment that functions as a sediment trap.
The monitoring described is shown in Appendix 3.b.
The implementation of this
monitoring is compliant with the
mean of monitoring defined herein.
Monitor effectiveness of soil erosion control
measures
Erosion handling by making sediment traps at the Sanggau
substation has been effective in preventing erosion.
The implementation of this
monitoring is compliant with the
mean of monitoring defined herein.
4. Water Quality (Construction Sites and Storage Areas)
Ensure mitigation measures are in place with
respect to oil, fuel and other hazardous materials
Monitoring indicates that the site clearing work does not use
oil, fuel or other hazardous materials in significant amount
The implementation of this
monitoring is in compliant with the
Semiannual Environmental Report January – June 2018 46
No Aspects and Means of Monitoring Monitoring Implemented Compliance Status
storage, handling, disposal; and fuelling and
maintenance of equipment
that may impact the water quality around the construction
site. Therefore, mitigation measures for water quality control
in this phase does not need to be implemented.
In addition, based on the results of measurements of water
quality at the Sanggau substation conducted on May 11,
2018 in collaboration with the University of Tanjung Pura, it
was stated that all parameters were still under the threshold
for water quality grade 1, according to Government
Regulation 82 / 2001. The water quality measurement result
is shown in Appendix 5.b.
mean of monitoring defined herein.
Monitor effectiveness of mitigation on water quality As above
5. Air Quality (Construction Sites and Storage Areas)
Ensure mitigation measures with respect to dust
control, truck cleaning, load covering, and soil and
spoil pile management are in place
According to the air quality quarterly monitoring conducted by
Tanjungpura University on March 2018 at Kawat village,
Tayan District, the concentrations measured as shown
below:
No Parameter Unit Result
Threshold
Standard
*)
1. Dust µg/Nm3 4.29 230
2. NO2 µg/Nm3 6.86 400
3. Sulfur Dioxide
(SO2)
µg/Nm3 655.0 900
4. Oxidant (O3) µg/Nm3 437.34 235
5. Carbon
Monoxide (CO)
ppm 34.9 30000
*) Ambient air quality Government Regulation No. 41/1999.
Relevant air quality measurement result is shown in
Appendix 5.c.
The implementation of this
monitoring is in compliant with the
mean of monitoring defined herein.
Monitor effectiveness of mitigation on air quality The mitigation measures are effective, based on air quality
monitoring result.
6. Waste Management (Construction Sites and Worker Camps)
Ensure construction and domestic waste
management collection, storage and disposal
Monitoring result indicates that construction and domestic
waste management was good. Each construction site has
The implementation of this
monitoring is in compliant with the
Semiannual Environmental Report January – June 2018 47
No Aspects and Means of Monitoring Monitoring Implemented Compliance Status
mitigations are in place. been provided trash bags and these are disposed of
regularly to the final disposal.
Worker camp improvements have been made by contractors
by improving sanitation facilities including toilets, washing
facilities and providing trash bags to be disposed of to the
final disposal on a regular basis.
Relevant evidence of the monitoring described is shown in
Appendix 3.e and 3.f.
mean of monitoring defined herein.
Monitor effectiveness of mitigation on waste
management
Implementation of mitigation measures related to waste
management has been well-implemented and effective.
7. Roads and Infrastructure (Construction Sites, Access Roads, Relevant District Roads)
Ensure mitigation measures are in place with
respect to road and infrastructure damage by heavy
equipment transport (monthly during construction).
In the phase of clearing works there is no activity of heavy
equipment. Therefore, the mitigation measures with respect
to road and infrastructure damage by heavy equipment
transport has not been implemented at this monitoring
period.
Not Applicable
Ensure any damage does is documented and
repaired
The monitoring indicates that there is no road damage during
this construction period (foundation excavation). Relevant
evidence of the monitoring described as shown in Appendix
3.g.
The implementation of this
monitoring is in compliance with
the mean of monitoring defined
herein.
Monitor effectiveness of mitigation on Road and
infrastructure
Implementation of mitigation measures related to mitigation
on road and infrastructure has been well-implemented and
effective.
The implementation of this
monitoring is in compliance with
the mean of monitoring defined
herein.
8. Encroachment (Gunung Condong in West Kalimantam, Areas adjancent to RoW)
Ensure mitigation measures are in place with
respect to no hunting or wildlife collection, plant or
timber collection, or lighting of fires, or possession
of firearms, traps or snares, by workers.
Monitoring indicates that, the location of the substation on
package 5 is entirely in the plantation land owned by the
local resident who have been bought and surrounded by
settlements and plantation land.
Monitoring indicates that there is already a management
visual in the form of a prohibition on hunting at construction
sites during this construction period (site clearing).
Relevant evidence of this monitoring describe earlier in
Appendix 3.h.
The implementation of this
monitoring is in compliance with
the mean of monitoring defined
herein.
Monitor effectiveness of mitigation on As above.
Semiannual Environmental Report January – June 2018 48
No Aspects and Means of Monitoring Monitoring Implemented Compliance Status
Encroachment impact
9. Occupational and Community Health and Safety (Construction Sites and Worker Camps)
Ensure mitigation measures are in place with
respect to construction phase and OHS and CHS
have been developed and are being implemented
The monitoring results show that the OHS and CHS plans
have been developed, but some of requirement has not fully
implemented in the construction phase, such as the absence
of HIRACH documents and the absence of worker trainings.
The implementation of this
monitoring is partially compliant
with the mean of monitoring
defined herein.
Monitor effectiveness of mitigation on Occupational
and Community Health and Safety
Implementation of mitigation measures related to
Occupational and Community Health and Safety has been
well-implemented and effective.
10. Physical Cultural Resources (Construction Sites)
Ensure mitigation measures are in place with
respect to implementation of chance-finding
physical cultural resources awareness and applied if
required
Monitoring indicates that mitigation measures on the chance-
find of physical cultural resources are in place and applied if
it’s required.
The implementation of this
monitoring is compliant with the
mean of monitoring defined herein.
Monitor effectiveness of mitigation on physical
cultural resources
Implementation of mitigation measures related to Physical
Cultural Resources has been well-implemented and
effective.
Semiannual Environmental Report January – June 2018 49
4.3 Package 6: 150 kV Tayan - Sanggau Transmission Line
The Tayan Extension – Sanggau – Sekadau substations were in the construction phase with vegetation clearing as the primary activity
in the Semester 1/2018 period. Table 7 describes the environmental monitoring conducted by the Project for this construction activity,
including its compliance level against the mitigation requirements defined in the IEE (2016).
Table 7 Environmental Monitoring Status of Package 6 and 7
No Aspects and Means of Monitoring Monitoring Implemented Compliance Status
1. Vegetation Clearing (RoW)
Ensure that vegetation removal mitigations are
implemented
Monitoring indicates that the vegetation removal mitigations
are implemented, as shown earlier in Appendix 4.a.
The implementation of this
monitoring is in compliance with
the mean of monitoring defined
herein. Monitor effectiveness of vegetation removal control
measures
Implementation of mitigation measures related to vegetation
removal control has been well-implemented and effective.
2. Drainage (Substations)
The monitoring requirement defined under this subject is intended for the construction of substation, and therefore not
applicable for that of transmission lines reported herein.
Not Applicable
3. Soil Erosion (Tower and Substation Sites)
Ensure soil erosion control measures are applied Monitoring indicates that the soil erosion control mitigation
measures are implemented , as shown earlier in Appendix
4.b.
The implementation of this
monitoring is in compliance with
the mean of monitoring defined
herein. Monitor effectiveness of soil erosion control
measures
Implementation of mitigation measures related vegetation
removal control has been well-implemented and effective
4. Water Quality (Construction Sites and Storage Areas)
Ensure mitigation measures are in place with
respect to oil, fuel and other hazardous materials
storage, handling, disposal; and fuelling and
maintenance of equipment
Monitoring indicates that the mitigation measures are in
place with respect to oil, fuel and other hazardous materials
storage, handling, disposal; and fuelling and maintenance of
equipment, as shown earlier in Appendix 4.c.
The implementation of this
monitoring is in compliance with
the mean of monitoring defined
herein.
Monitor effectiveness of mitigation on water quality Implementation of mitigation measures related vegetation
removal control has been well-implemented and effective
5. Air Quality (Construction Sites and Storage Areas)
Ensure mitigation measures with respect to dust
control, truck cleaning, load covering, and soil and
spoil pile management are in place
According to the air quality quarterly monitoring conducted by
Tanjungpura University on May 2018 at Cempedak village
Tayan Hilir District for package 6, the concentrations
The implementation of this
monitoring is in compliance with
the mean of monitoring defined
Semiannual Environmental Report January – June 2018 50
No Aspects and Means of Monitoring Monitoring Implemented Compliance Status
measured are shown below:
No Parameter Unit Result
Threshold
Standard
*)
1. Debu µg/Nm3 3.41 230
2. NO2 µg/Nm3 0.70 400
3. Sulfur Dioxide
(SO2)
µg/Nm3 186.59 900
4. Oxidant (O3) µg/Nm3 16.87 235
5. Carbon
Monoxide (CO)
ppm 2 30000
According to the air quality quarterly monitoring conducted by
tanjungpura University on May 2018 at Peniti village
Sekadau Hilir district for package 7, the concentrations
measured are shown below:
No Parameter Unit Result
Threshold
Standard
*)
1. Debu µg/Nm3 3.45 230
2. NO2 µg/Nm3 1.66 400
3. Sulfur Dioxide
(SO2)
µg/Nm3 206.82 900
4. Oxidant (O3) µg/Nm3 79.69 235
5. Carbon
Monoxide (CO)
ppm 1 30000
*) Ambient air quality Government Reulation No. 41/1999.
Relevant air quality measurement result is shown in
Appendix 5.d.
herein.
Monitor effectiveness of mitigation on air quality The mitigation measures are effective, based on air quality
monitoring result.
6. Waste Management (Construction Sites and Worker Camps)
Semiannual Environmental Report January – June 2018 51
No Aspects and Means of Monitoring Monitoring Implemented Compliance Status
Ensure construction and domestic waste
management collection, storage and disposal
mitigations are in place.
Storage and handling of fuel, oil, and hazardous materials
including hazardous/toxic wastes (known as ‘B3’ waste) are implemented by PLN based on the requirements set
out in the Head of Occupational Health & Safety and
Environment Letter No. 0199/KLH.01.02/KDIVK3L/2017
(dated 15 May 2017) on Warehouse Improvement and
Management for B3 and Non-B3 Wastes Generated by
Electricity Distribution.
Worker camp improvements have been made by
contractors by improving sanitation facilities including
toilets and washing facilities as well as providing trash
bags to be disposed of to the final disposal on a regular
basis, as shown earlier in Appendix 4.e.
The implementation of this
monitoring is in compliance with
the mean of monitoring defined
herein.
Monitor effectiveness of mitigation on waste
management
Implementation of mitigation measures related to waste
management has been well-implemented and effective.
7. Roads and Infrastructure (Construction Sites, Access Roads, Relevant District Roads)
Ensure mitigation measures are in place with
respect to road and infrastructure damage by heavy
equipment transport.
No mapping of the locations of expected heavy equipment
mobilization is needed versus settlement area locations
were undertaken during the foundation works.
The mitigation implemented with this regard is not compliant with
its requirement.
Ensure any damage is documented and repaired The monitoring indicates that there is no road damage during
this construction period (foundation excavation), as shown
earlier in Appendix 4.f.
The implementation of this
monitoring is in compliance with
the mean of monitoring defined
herein.
Monitor effectiveness of mitigation on Road and
infrastructure
Implementation of mitigation measures related to mitigation
on road and infrastructure has been well-implemented and
effective.
The implementation of this
monitoring is in compliance with
the mean of monitoring defined
herein.
8. Encroachment (Gunung Condong in West Kalimantan, Areas adjancent to RoW)
Ensure mitigation measures are in place with
respect to no hunting or wildlife collection, plant or
timber collection, or lighting of fires, or possession
of firearms, traps or snares, by workers.
Monitoring indicates that there is already visual management
with respect to no hunting or firewood collection undertaken
by workers during this construction period, as shown earlier
in Appendix 4.g.
The implementation of this
monitoring is compliant with the
mean of monitoring defined herein.
Monitor effectiveness of mitigation on
Encroachment impact
Implementation of mitigation measures related to mitigation
on encroachment has been well-implemented and effective.
9. Occupational and Community Health and Safety (Construction Sites and Worker Camps)
Semiannual Environmental Report January – June 2018 52
No Aspects and Means of Monitoring Monitoring Implemented Compliance Status
Ensure mitigation measures are in place with
respect to construction phase and OHS and CHS
have been developed and are being implemented
The monitoring results show that the OHS and CHS plans
have been developed and implemented well in the construction phase, as shown earlier in Appendix 4.i.
The implementation of this
monitoring is compliant with the
mean of monitoring defined herein.
Monitor effectiveness of mitigation on Occupational
and Community Health and Safety
Implementation of mitigation measures related to
Occupational and Community Health and Safety has been
well-implemented and effective.
10. Physical Cultural Resources (Construction Sites)
Ensure mitigation measures are in place with
respect to implementation of chance find physical
cultural resources awareness and applied if required
Monitoring indicates that chance find procedure are in place
and applied during this construction period . But the
awareness is has not yet conducted.
The implementation of this monitoring is in partially
compliance with the mean of
monitoring defined herein. Monitor effectiveness of mitigation on physical
cultural resources
Implementation of mitigation measures related to physical
cultural resources has been well-implemented and effective.
Semiannual Environmental Report January – June 2018 53
Chapter 5 Key findings on EMP Implementation and Corrective Action
As detailed in Chapters 3 and 4, the Project including PLN units and contractors involved has
conducted, to varying degrees, environmental management plan (EMP) including monitoring
requirements defined in the 2011 and 2016 IEE. Some mitigation and monitoring implemented are
in compliant with the requirements of IEE. However, some of the mitigation and monitoring
conducted are partially compliant and, in few important cases, have not been conducted and
therefore not compliant with the IEE requirements.
The following table summarizes the environmental mitigation and monitoring that are not compliant
or partially compliant as described in Chapters 3 and 4, as well as the recommended corrective
actions that should be implemented by PLN including its associated units and contractors.
Semiannual Environmental Report January – June 2018 54
Table 8 Key Findings on EMP Implementation and Corrective Actions
No Aspects / Findings Corrective Actions Responsible Parties
(and Due Date)
Remarks
Package 3: Bengkayang – Ngabang – Tayan Transmission Lines (Construction: Stringing Works)
1 Vegetation Removal (HVTL alignment)
There is no formal documentation indicating that the
Project does not use herbicides for pest management.
Develop a related document e.g. instruction
prohibiting the Project to use herbicides; and report
the monitoring of this in the site inspection record,
minutes of meeting or other documents as
appropriate.
KEC International Ltd
(Q2/2018)
Until the
construction has
been finished, the
contractor has not
closed this issue.
There is no formal documentation indicating that the
burning of cleared vegetation will not be allowed at
the project
The contractor has posted a warning sign on
prohibition of burning of cleared vegetation during
construction in project location.
KEC International Ltd
(Q4/2017)
Closed
2. Acid sulphate soils (HVTL alignment)
There is no formal documentation, procedures or
awareness on mitigation requirements related to the
potential acid sulphate soils in the project areas.
Conduct awareness to workers regarding the
potential presence of acid sulphate soil at the
construction site and provide management
directions if this type of soil is encountered.
Evidence can be delivered in the form of MoM
meetings, attendance list and handout of capacity
building.
PLN UIP
KALBAGBAR,
Contractor KEC
International Ltd
(Q1/2018)
Until the
construction has
been finished, the
contractor has not
closed this issue.
3. Domestic Waste Management (HVTL alignment)
The temporary workers camp is still lacking adequate
sanitation facilities and waste container.
On March 2018 the contractor has increased the
number of worker camp into 2 houses rented from
the local people and improved the sanitation
facilities, including water supply, washing facilities,
temporary toilets, and waste containers, as describe
earlier in table 3.1.
KEC International Ltd
(Q2/2018)
Closed
4. Encroachment into Protected Forest, Hunting and Wood Collection
There is no sign or procedure to all workers about
the prohibition to accessing forest and forest
products, including maintaining firearms on the
Project areas
Develop the required instruction and communicate it
through safety or minutes of meeting as appropriate
PLN UIP
KALBAGBAR, KEC
International Ltd
(Q2/2018)
Until the
construction has
been finished, the
contractor has not
closed this issue.
5. Occupational Health and Safety
Semiannual Environmental Report January – June 2018 55
No Aspects / Findings Corrective Actions Responsible Parties
(and Due Date)
Remarks
EHS plan does not provide identification and
minimization of potential hazards to worker,
including corresponding preventive and protective
measures.
Develop a related procedure or other documents as
appropriate and consistently enforce the
implementation of the procedures and increase its
supervision.
KEC International Ltd
(Q2/2018)
Until the
construction has
been finished, the
contractor has not
closed this issue.
6. Community Health and Safety
There is no procedure for interaction with local and
regional emergency and health authorities in EHSP
document.
Contractor submitted procedure for interaction with
local and regional emergency and health
authorities in EHSP document.
KEC International Ltd
(Q2/2018)
Until the
construction has
been finished, the
contractor has not
closed this issue.
7. Physical Cultural Resources
The chance find procedure to identify and manage
physical cultural resources in the project area has not
been developed.
Develop a chance find procedure considering the
requirements of the Project’s IEE (2011). PLN UIP
KALBAGBAR, KEC
International Ltd
(Q2/2018)
Until the
construction has
been finished, the
contractor has not
closed this issue.
Package 5 150/20 kV Sanggau and Sekadau Substations (Construction Phase)
1. Drainage
There is no approved drainage engineering design
yet.
Develop related drainage engineering design to be
approved
Contractor PT
Siemens Indonesia
Q.4/2018
-
2. Air Quality
There is no air quality management by spraying dusty
areas because there is no water supply to the
constructions location yet.
In accordance with the contractor's plan, water
supply will be implemented after the development of
site office is completed.
Contractor PT
Siemens Indonesia
Q.4/2018
-
3. OSH Implementation
There are no workers training related to HSE
implementation yet
Prepare the trainings related to the HSE
implementation in site.
Contractor PT
Siemens Indonesia
Q.4/2018
Since the
construction
started in May
2018 and is still in
the early phase
with a non-
significant number
Semiannual Environmental Report January – June 2018 56
No Aspects / Findings Corrective Actions Responsible Parties
(and Due Date)
Remarks
of workers,
workers’ training is planned to be
conducted at Q4
2018.
4 EMP Incorporation into Detailed Project Design
There is no evident suggesting that monitoring has
been conducted to ensure that EMP is incorporated
into detailed design of the substation.
Provide evidence to justify whether EMP has been
incorporated into the siting/selection of the location
of the substations.
PLN UIP
KALBAGBAR, PLN
DIVK3L
(Q4/2018)
This is pending
issues from
previous semester
5 Overall Project Siting
The location of the substation has reportedly been
selected to avoid sensitive locations. However, there
is no evident available to support the earlier
statement.
Provide evidence to justify whether EMP has been
incorporated into the siting/selection of the location
of the substations.
PLN UIP
KALBAGBAR, PLN
DIVK3L
(Q4/2018)
This is pending
issues from
previous semester
Package 6 & 7 150 kV Tayan – Sanggau - Sekadau Transmission Line (Construction Phase)
1. Permanent alienation of Land and Vegetation for Transmission Line
Regarding to the letter from the Ministry of Forestry
No.S386 / BPKH.III-2/2015 dated May 13, 2015
regarding the Result of Technical Review of the
Function of Forest Areas Against the location of
SUTT, West Kalimantan Province stated that in the
location of the Tayan – Sanggau – Sekadau – Sintang
HVTL, there is 14 towers that located in swamp area
including of T.8, T.9,T.10,T.11,T12,T.91,T.92,T.93,
T.94, T.95, T.96, T.97, T.98, T99, T.100.
Conducting re-check on Indicative Map of
Suspension for New License (PIPIB) for
transmission lines that are indicated passing the
other uses area (swamp location).
If after checking and overlaying, it was indicated that
there are towers that crosses swamp location, then:
- Conducting reroute to avoid and to minimalize
the construction located in swamp area;
- If re-route is impossible, then construction
activities will be done during dry conditions;
- Coordinating with relevant agencies in
connection with activities at the swamp location.
PLN UIP
KALBAGBAR,
Contractor PT
Krakatau Engineering.
Q.4/2018
Based on
Presidential
Instruction No.
6/2013 concerning
Suspension New
Licenses and
Improving Forest
Governance of
Primary Forest and
Peat Land (PIPIB),
it is stated that
there was an
exception to the
obligation to
administer a PIPIB
permit, one of which
was given to the
national
development of the
Semiannual Environmental Report January – June 2018 57
No Aspects / Findings Corrective Actions Responsible Parties
(and Due Date)
Remarks
Electricity sector.
The document are
shown in Appendix
6.a.
2 Disturbance of Houses Infrastructure and Sensitive Ecosystem, including Impacts from EMF
Careful routing of the transmission lines to ensure
that final alignment avoids possible sensitive
ecosystems such as forests; sensitive buildings.
As above PLN UIP
KALBAGBAR,
PT Krakatau
Engineering
(Q4/2018)
Pending issues
from previous
semester.
3. Impacts on Rivers at Crossings
The placement of the tower base that cross the river
has not paid attention to the flood plan area.
Conduct a survey of potential flood areas in T.60 – T
62 located in Penyeladi Village and T 72 - T 73 in
Semuntai Village which crosses the Kapuas River.
If the area is identified as a flood-prone area, it must
be re-routed for construction good practices to avoid
hydrological disturbances, garbage accumulation,
and structural damage.
PLN UIP
KALBAGBAR,
Contractor PT
Krakatau Engineering.
Q.4/2018
Pending issues
from previous
semester.
4. EMP Incorporation into Detailed Project Design
There is no evident suggesting that monitoring has
been conducted to ensure that EMP is incorporated
into detailed design of the location of tower
base/siting.
Provide evidence to justify whether EMP has been
incorporated into the siting/selection of the location
of the substations.
PLN UIP
KALBAGBAR,
Contractor PT
Krakatau Engineering
(Q4/2018)
Pending issues
from previous
semester.
5. Overall Project Siting
There is no evident to show that these monitoring
requirements during have been incorporated at the
time of the design of tower siting.
Provide evidence to justify whether EMP has been
incorporated into the siting/selection of the location
of the substations.
PLN UIP
KALBAGBAR,
Contractor PT
Krakatau Engineering
(Q4/2018)
Pending issues
from previous
semester.
6. Roads and Infrastructure Impacts (HVTL alignments, substations)
There is no mapping of the locations of expected
heavy equipment mobilization is needed versus
settlement area locations were undertaken during
Develop related map and conduct awareness to the
subcontractor.
PLN UIP
KALBAGBAR,
Contractor PT
-
Semiannual Environmental Report January – June 2018 58
No Aspects / Findings Corrective Actions Responsible Parties
(and Due Date)
Remarks
the foundation works. Krakatau Engineering
(Q4/2018)
7. Physical Cultural Resources (HVTL alignments, substations)
Awareness related to the chance finding procedure
has not been done yet for all workers.
Conduct the awareness to the workers related to
this procedure and provides the evident as
documentation or attending list.
PLN UIP
KALBAGBAR,
Contractor PT
Krakatau Engineering
(Q4/2018)
-
Semiannual Environmental Report January – June 2018 59
Chapter 6 ADB Mission Findings
In June 2017, December 2017 and May 2018, a joint review mission from ADB's environmental
specialists and PLN has been conducted to see the environmental and OSH management that has
been carried out during this construction period. Key non-compliance with IEE that was identified in
the mission and field inspections, including related corrective actions and status of application (as
of June 2018), are presented in Table 9.
Semiannual Environmental Report January – June 2018 60
Table 9 Environmental Finding/Status Identified in June, December 2017 and May 2018 ADB/AFD Missions
No Findings
Finding/Status in
June 2017 Mission
Finding/Status in
December 2017 Mission
Finding/Status in
May 2018 Mission
PIC Corrective Action
Status
1 Construction and domestic wastes were improperly managed
To be implemented by August 2017
Not fully compliant; requires improvement
Ongoing process PT. KEC International Ltd, PLN UIP KALBAGBAR, PIC
Closed.
Improvements to construction and domestic waste management have been carried out by collecting waste on the trash bag and regularly discharging the waste into the the Tebedak final disposal owned by local district, as reported in Appendix 7.a
2 Revise semi-annual environmental internal monitoring report required [by PLN (K3L); due date: by August 2017]
The finding was identified.
Ongoing process Ongoing process PLN UIP KALBAGBAR, PIC, DIVK3L
Closed.
Revised semi-annual environmental internal monitoring report for S1/2017 and S2/2017 have been submitted on September and October 2018 as shown in Appendix 7.b
3 Separate environmental monitoring consultants independent from the PIC to be recruited by PLN and responsible for implementing the EMP and assisting in environmental reporting [PLN (K3L); due date: by August 2017]
The finding was identified.
- DIVK3L Pending item to be discussed between PLN and ADB
4 Contractor to deploy full-time environmental and OSH officers to enforce and provide awareness on the EMP and OSH requirements as well as impact mitigation measures in the IEE and disseminate proper
The finding was identified.
Ongoing process Ongoing process PT. KEC International Ltd, PLN UIP KALBAGBAR, PIC
Closed.
The contractor has submitted data on environmental inspectors and K3 supervisors with letter No.54 / KE-CHI / Package 6 & 7/1/2018 dated
Semiannual Environmental Report January – June 2018 61
No Findings
Finding/Status in
June 2017 Mission
Finding/Status in
December 2017 Mission
Finding/Status in
May 2018 Mission
PIC Corrective Action
Status
OSH procedures among project personnel, sub-contractors, and laborers (due date: by Sept 2017 for Packages 6 and 7; and by December for Package 5)
January 25, 2018 regarding the assignment of West Kalimantan strengthening safety project personnel as attached in Appendix 7.c
5 Contractor did not provide HIV/AIDS prevention and other living environment training [by PLN (UIP, K3L) and PIC; due date: Q1/2018]
- The finding was identified.
Ongoing process PT. KEC International Ltd, PLN UIP KALBAGBAR, PIC
Closed.
Contractors for package 3 have conducted HIV / AIDS prevention training in March 2018, while in package 6 and 7 work HIV / AIDS training has been conducted in April 2018.
The relevant evidence shown in Appendix 7.d
6 Making ready a proper living environment for workers in their camp [by PLN (UIP, UPP, K3L) and PIC; due date: Q1/2018)
- The finding was identified.
Ongoing process PT. KEC International Ltd, PLN UIP KALBAGBAR, PIC
Closed.
The contractor has rented 1 additional house for workers with more decent conditions as per March 2018.
The relevant evidence shown in Appendix 7.e
7 Training and capacity building plan and its implementation for workers, contractors, and others [by PLN (UIP) and PIC; due date: Plan by January 2018, implementation by 2018]
- PIC has carried out capacity building to improve understanding of IEE and RCCP documents by inviting all parties. Including the PLN UPP construction implementing unit, PLN UIP, PLN DIVK3L and representatives of all contractors in
Ongoing process PLN UIP KALBAGBAR, PIC, DIVK3L
Closed.
Training and capacity building plan have been developed. 1st Implementation was conducted at April 5th 2018.
The relevant evidence shown in Appendix 7.f
Semiannual Environmental Report January – June 2018 62
No Findings
Finding/Status in
June 2017 Mission
Finding/Status in
December 2017 Mission
Finding/Status in
May 2018 Mission
PIC Corrective Action
Status
November 2017. The relevant evidence shown in Appendix 10.d
PIC will conduct next capacity building at S1/2018.
8 Briefing/meeting with new PIC on environmental requirements of the project and BAEMR [by PLN (Monitoring Supervisor of UIP, K3L officer from UPP, PIC; due date: Jan – Feb 2018]
- The finding was identified.
Ongoing process PLN UIP KALBAGBAR, PIC, DIVK3L
Closed.
Briefing/meeting with new PIC on environmental requirements of the project and BAEMR has been conducted on August 2018, as shown in Appendix 7.g.
9 Clear version of HIRARC (Hazard Identification, Risk Assessment and Risk Control) of package 3
- - Ongoing process PLN UIP KALBAGBAR, PIC, DIVK3L
Closed.
PLN informally has instructed the contractor of package 3 to submit the clear version of HIRACH, but until this construction work is completed and HSE supervisor from KEC has been mobilized, there is no clear of HIRACH document that has been submitted.
10 Mobilization of field environmental safeguard officer from contractors for P5 (Sanggau and Sekadau substations).
- - The finding was identified
PLN UIP KALBAGBAR, PIC, DIVK3L
PLN informally has instructed the contractor for package 5 to mobilize the environmental safeguard officer to the field. The contractor confirmed that they will mobilize the environmental safeguard on August 2018.
11 Sanggau substation - - - The finding was PLN UIP Closed.
Semiannual Environmental Report January – June 2018 63
No Findings
Finding/Status in
June 2017 Mission
Finding/Status in
December 2017 Mission
Finding/Status in
May 2018 Mission
PIC Corrective Action
Status
Engineering plan for diverting small stream using culvert along the border to avoid sedimentation of the stream, and installing sediment trap along the border to avoid sedimentation of river.
identified KALBAGBAR,
PIC, DIVK3L
PLN informally has instructed
to build the sediment trap at
Sanggau substation. In June
2018, a sediment trap has
been constructed along the
boundary of the substation to
prevent sedimentation of soil
into the river around the
substation as the evident
shown at Appendix 7.h
12 Sekadau substation - Ensure timely issuance of permit for disposal of vegetation waste
- - The finding was identified
PT Siemens, PLN
UIP
KALBAGBAR,
PIC, DIVK3L
Closed.
In May 2018, there was
already a letter of agreement
with residents who are willing
to hand over their land as the
final disposal of waste
vegetation.
Relevant evidence of this activities are shown at Appendix 7.i
13 Package 6: Provision of water
supply and toilet facilities for
worker camp
Package 7: Completion of new toilets and bathroom facilities for worker camp
- - The finding was identified
PT KE, PLN UIP
KALBAGBAR,
PIC, DIVK3L
Closed.
PLN has instructed the
contractor to immediately
improve the sanitation
facilities at the worker camp
immediately. In May 2018, the
contractor has provided water
supply and toilet facilities at
the worker camp.
Relevant evidence of this activities are shown at Appendix 7.j
Source: ADB and AFD MOUs of June 2017 Mission (dated 24 July 2017), December 2017 Mission (dated 18 December 2017) and May 2018 Mission (dated 09 May 2018)
Semiannual Environmental Report January – June 2018 64
Chapter 7 Conclusions
Lack of understanding on the HSE requirements as stated in IEE 2011 and IEE 2016 documents
leads to inconsistent implementation and non-compliant with these regards at the West Kalimantan
Power Grid Strengthening Project in the period of Semester 1/2018. Further, mitigation and
monitoring conducted are not supported with the required, written evidence is identified as key
issue in this environmental monitoring report. The followings are recommended as corrective
actions to improve the HSE implementation and next monitoring report:
PLN and its contractors have made efforts to implement the required environmental mitigation
and monitoring requirements defined in the Project’s IEE (2011) and IEE (2016); and some of these efforts comply, but some others do not comply or partially comply with the mentioned IEE.
Those do not comply with the IEE (2011) are mitigation and/or monitoring related to the
following aspects: acid sulphate soils; and physical cultural resources.
Those partially comply with the IEE (2011) is mitigation and/or monitoring related to the
following aspects: water quality impacts; occupational health and safety; and community health
and safety.
Those do not comply with the IEE (2016) are mitigation and/or monitoring related to the
following aspects: drainage; and roads and infrastructure impacts.
Those partially comply with the IEE (2016) is mitigation and/or monitoring related to the
following aspects: water quality impacts; occupational health and safety; and community health
and safety; and physical cultural resources.
The key issues associated with the above shortfalls are: lacking or incomplete evidence
indicating whether the mitigation and monitoring have been effectively implemented by the
Contractors, shortage of PLN supervision and personnel and also incomplete study documents
needed in the construction of transmission lines such as: development studies in river area and
management impact of constructions in protected area such as areas, primary forest, wetland,
peat lands, swamp forest, mangroves, estuarine areas.
Corrective action plans for each of the issues mentioned earlier have been defined in this
monitoring report.
To improve environmental, health and safety performance, the Project recommends the followings:
PLN shall hold regular capacity building with speakers from ADB, other competent parties and
internal PLN personnel that can share its experiences from elsewhere.
PLN shall improve supervision to the contractors to strictly implement the mitigation measures.
PLN shall carry out regular and documented inspections during monitoring.
Prepare and develop a formal procedure, upgrade existing procedure/document or a
supplementary document as identified in the corrective action plan.
Contractor shall improve their performance in presenting monthly reports submitted to PLN,
including: complete and accurate data of the mitigation items in accordance with the
requirements mentioned in the IEE 2011 and IEE 2016 documents completely; and complete
Semiannual Environmental Report January – June 2018 65
evidence of the implementation of mitigation measures in the form of photos, supporting
documents as well as relevant drawing.