JAMBI, LENSAJABAR.COM — PT. Marga Bara Jaya (MBJ) proposed to the Ministry of Environment and Forestry (KLHK) of the Republic of Indonesia to build a Coal Road Special Road from Beringin Makmur Village, Rawas Ilir District, North Musi Rawas Regency to Mendis Village, Bayung Lencir District, Musi Banyuasin District, South Sumatra Province. However, the planned construction of special coal transportation road will pass or divide the remaining lowland forest areas of Sumatra in Limited Production Forests (HPT) of the Meranti Forest and Lalan Forests which have been burdened with 34 rights or IUPHHK-Ecosystem Restoration to PT Indonesia Ecosystem Restoration (REKI). , 5 Km (22.5 Km in South Sumatra Province and 12 Km in Jambi Province.
By considering aspects of policy and regulation, ecological aspects and socio-cultural aspects, namely:
1. That the construction of special coal transportation roads is contrary to the policy and commitment of the Government of Indonesia to reduce greenhouse gas emissions by 29 percent in business as usual as stated in the INDC (Indonesia ‘s Intended Nationally Determined Contribution), because it triggers deforestation and forest degradation.
2. That the construction of special coal transportation roads contradicts the Convention on Biological Diversity, Article 14, which has been signed and ratified by Indonesia through Law Number 5 of 1994 concerning Ratification of the United Nations Convention on Biological Diversity, stating that the parties must: “Implement appropriate procedures for using environmental impact analysis of proposed projects, which may have a significant impact on biodiversity, with the aim of avoiding or minimizing impacts, and enabling community participation in the procedure. “So, analyzing environmental impacts and social impacts in making coal haul roads must be carried out independently and deeply.
3. That the construction of special coal transportation roads is contrary to Government Regulation (PP) Number 6 of 2007 in conjunction with Government Regulation Number 3 of 2008 concerning Forest Arrangement and Preparation of Forest Management and Forest Utilization Plans, where ecosystem restoration is defined as an effort to restore biological elements (flora and fauna) and non-biological elements (soil, climate and topography) in an area to the original species, so that biological balance and its ecosystem are achieved. Ecosystem restoration areas are managed through maintenance, protection and restoration of forest ecosystems including planting, enrichment, thinning, captive breeding, and the release of flora and fauna. Therefore, the plan to build a coal haul road that divides ecosystem restoration areas will disrupt the efforts to restore the forest ecosystem.
4. That the construction of a special coal transportation road is contrary to the Regulation of the Minister of Environment and Forestry of the Republic of Indonesia Number: P.27 / Menlhk / Setjen / Kum.1/7/2018 concerning Borrowing Using Forest Zone Guidelines, where Article 12 Paragraph (1) regulate that the Loan to Use Forest Zone (IPPKH) for mineral and coal mining activities is not given to production forest areas which are burdened with Business Permit for Utilization of Timber Forest Products Ecosystem Restoration in Natural Forests or reserves of Community Plantation Forests, Community Forests and Village Forests.
5. That the construction of special coal transportation roads contradicts the Regulation of the Minister of Environment and Forestry of the Republic of Indonesia Number: P.28 / Menlhk / Setjen / Kum.1/ 7/2018 concerning Procedures for Granting, Expansion of Work Areas and Extension of Business Permits for Utilization of Results Timber Forest in Natural Forests, Business Permit for Utilization of Timber Forest Products in Ecosystem Restoration, or Business Permit for Utilization of Timber Forest Products from Industrial Plantation Forests in Production Forests, which are referred to as IUPHHK-RE. given to build areas in natural forests in production forests that have important ecosystems so that functions and representations can be maintained through maintenance, protection and restoration of forest ecosystems including planting, enrichment, thinning, captivity of animals, release of flora and fauna to restore biological elements (flora and fauna) and non-biological elements (soil, oil) m and topography) in an area to the original species, so that biological balance and its ecosystem are achieved. Therefore the special coal-fired road will disrupt the maintenance, protection and restoration of forest ecosystems carried out by PT REKI in an effort to achieve biological balance and its ecosystem.
6. That the construction of special roads for coal transportation is contrary to the Regional Regulation of South Sumatra Province No. 11/2016 concerning the RTRW of South Sumatra Province 2016 – 2036, in article 54 paragraph (2) Prohibition against spatial utilization activities that can disrupt the sustainability of water resources, balance protection functions, flora and fauna conservation, and utilization of stands.
7. That the construction of special roads for coal transportation is contrary to the Regional Regulation of Musi Banyuasin No. 8/2016 concerning RTRW of Musi Banyuasin Regency in 2016 – 2036; where the special road for coal transportation crosses the Production Forest and Limited Production Forest areas and is not a convertible production forest area that can be converted to other activities outside forestry, and not reserved for infrastructure, agriculture and plantations.
8. That the construction of special roads for coal transportation is contrary to the Regional Regulation of Batanghari District No. 1/2013 concerning Batanghari Regency RTRW for 2011-2031 in article 102 paragraph (2), namely the existence of general provisions on zoning regulations in production forest areas because the prohibited activities include: activities that exist in production forests that do not guarantee the survival of life in the lower area or damaging protected ecosystems, anyone is prohibited from cutting down trees within a certain radius / distance from springs, edge of cliffs, rivers and creeks located in forest areas, and restrictions on the construction of facilities and infrastructure in production forest areas.
9. That the special road construction of coal transportation will damage the ecosystem that is being restored, increase the potential for deforestation and fragmentation of forest areas, threaten the preservation of high biodiversity in lowland forests of Sumatra, and disturb wildlife life for 26 rare, critical and protected species .
10. That the construction of special coal transportation roads will open access and increase human-wildlife conflict, poaching and illegal logging.
11. That the construction of special coal transportation roads will cause soil erosion due to the absence of forest cover, increase river sedimentation, especially the Meranti, Kapas, and Lalan sub-watersheds (sub-watersheds), and increase the risk of flooding.
12. That the construction of special roads for coal transportation will cause pollution and reduce water quality, so that it has a negative impact on public health and wildlife.
13. That the construction of a special road for coal transportation will disrupt and eliminate the source of family life for the indigenous people of the Suku Anak Dalam (SAD) Nine who still depend their lives on forest and water resources in the ecosystem restoration area.
14. That the construction of special coal transportation roads will open access and increase pressure due to forest clearing and potentially lead to horizontal conflicts with the Batin Sembilan community.
Based on these considerations, the Jambi Civil Society Coalition expressed an attitude:
1. REFUSED the plan to construct a special coal transportation road proposed by PT Marga Bara Jaya which passes or divides Sumatra’s lowland natural forest in Limited Production Forests (HPT) Meranti Forest and Lalan Forests which are being managed through IUPPHK-Ecosystem Restoration by PT REKI.
2. RECOMMEND so that PT Marga Bara Jaya builds an operational partnership to use existing roads, namely through PT Conoco Phillip and PT Bumi Persada Permai roads.
3. RECOMMEND so that the Ministry of Environment and Forestry (KLHK) facilitates the cooperation of existing road use operations in the area of PT Sentosa Bahagia Bersama, which has never been involved as a key stakeholder of the planned construction of special coal transportation roads by PT Marga Bara Jaya. (MRS / Red)