tangguh lng project e&s external panel ii (2011-2016) · requirements of the amdal as evidence...

Tangguh LNG Project E&S External Panel II

(2011-2016)

4th Operational Compliance Monitoring Report

July 2015

BP Berau - Project Financiers

CONFIDENTIAL

335508 PHR ENS 4 D

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22 July 2015

Tangguh LNG Project E&S External Panel II (2011-2016)


Tangguh LNG Project E&S External Panel II (2011-2016)


July 2015

BP Berau - Project Financiers

CONFIDENTIAL

Mott MacDonald, Graha CIMB Niaga 16th Floor,

Jl. Jenderal Sudirman Kav.58, Jakarta, 12190, Indonesia

T +62 21 252 6588 F +62 21 252 6592 W www.mottmac.com

Tangguh LNG Project E&S External Panel II (2011-2016) 4th Operational Compliance Monitoring Report

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Revision Date Originator Checker Approver Description Standard

A 11.05.14 Tom Streather, Nanang Ananto, Jacqueline Hamadi Laura Jones, Anhar Kramadasistra

Marielle Rowan Simon Lidell 1st draft

B 12.06.15 Tom Streather, Nanang Ananto, Jacqueline Hamadi Laura Jones, Anhar Kramadasistra

Simon Lidell Simon Lidell 2nd

draft addressing client comments

C 10.07.15 Tom Streather Simon Lidell Simon Lidell 3rd draft addressing client

comments

D 22.07.15 Tom Streather Simon Lidell Simon Lidell Final draft

Issue and revision record

This document is issued for the party which commissioned it and for specific purposes connected with the above-captioned project only. It should not be relied upon by any other party or used for any other purpose.

We accept no responsibility for the consequences of this document being relied upon by any other party, or being used for any other purpose, or containing any error or omission which is due to an error or omission in data supplied to us by other parties.

This document contains confidential information and proprietary intellectual property. It should not be shown to other parties without consent from us and from the party which commissioned it.


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Chapter Title Page

Acronyms & Abbreviations i

Executive Summary iii

1 Introduction 1

1.1 Overview _________________________________________________________________________ 1 1.2 Tangguh LNG & Tangguh Expansion Project (TEP) Descriptions ______________________________ 1 1.3 Scope of EPII Monitoring _____________________________________________________________ 3 1.3.1 Overview _________________________________________________________________________ 3 1.3.2 Changes to EPII’s Social Monitoring Scope from the New AMDAL _____________________________ 4 1.3.3 Changes to EPII’s Environmental Monitoring Scope from the New AMDAL _______________________ 6 1.4 Activities & Information Sources for 4

th EPII Monitoring Audit _________________________________ 7

1.5 Overview of Project Performance and Key Developments in 2015 _____________________________ 8 1.6 Limitations of the Fourth EPII Monitoring Audit ___________________________________________ 10

2 Non-Compliance (NC) Review 11

2.1 Overview ________________________________________________________________________ 11 2.2 Approach to Non-Compliance (NC) Assessment __________________________________________ 11 2.3 Non Compliances Identified in EPII 4

th Monitoring Audit ____________________________________ 12

3 Review of Monitoring & Reporting 13

3.1 Overview ________________________________________________________________________ 13 3.2 Environmental Monitoring and Reporting ________________________________________________ 13 3.2.1 Environmental Monitoring Requirements ________________________________________________ 13 3.2.2 Amdal Reporting ___________________________________________________________________ 13 3.2.3 Emissions to Water_________________________________________________________________ 14 3.2.4 Emissions to Air ___________________________________________________________________ 14 3.3 Social Monitoring and Reporting ______________________________________________________ 15 3.3.1 Social Monitoring & Reporting Requirements _____________________________________________ 15 3.3.2 Comment on Social Monitoring and Reporting in 2014 _____________________________________ 15 3.3.3 Grievance Log Review ______________________________________________________________ 20 3.3.4 2014 Social Budget Realization Review _________________________________________________ 20

4 Other Issues and Suggestions 22

4.1 Overview ________________________________________________________________________ 22 4.2 Environmental Management Issues and Challenges _______________________________________ 22 4.2.1 Invasive Species Management ________________________________________________________ 22 4.2.2 Food Waste Composting ____________________________________________________________ 22 4.2.3 Biodiesel Production ________________________________________________________________ 23 4.2.4 Storage of Waste __________________________________________________________________ 23 4.2.5 Erosion Control ____________________________________________________________________ 24 4.2.6 Hazardous Waste Permit ____________________________________________________________ 24

Contents


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4.3 Social Management Issues and Challenges ______________________________________________ 25 4.3.1 Overview ________________________________________________________________________ 25 4.3.2 Ongoing Issues and Challenges _______________________________________________________ 25 4.3.3 Newly Identified Issues and Future Challenges ___________________________________________ 30

5 Concluding Comments 33

Appendices 34

Appendix A. ADB, JBIC Policies & Equator Principles Relevant to the Original AMDAL ______________________ 35 Appendix B. Key Documents Reviewed ___________________________________________________________ 36 Appendix C. Stakeholders Consulted _____________________________________________________________ 39


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Acronyms & Abbreviations

Acronym Description

ADB Asian Development Bank

AGI Acid Gas Incinerator

AIS Alien Invasive Species

BC British Council (BP’s main Education Programme partner)

BOD Biological Oxygen Demand

CA Corrective Action

CAPs Community Action Plans

C&EA Communications & External Affairs

CEMS Continuous Emissions Monitoring System

CFO Community Financial Officer

CFR Case Fatality Rate

Co-op Cooperative

DAFW Days Away From Work

DAV Directly Affected Villages

DF Dimaga Foundation

EMP |Environmental Management Plan

EMS Environmental Management System

EP External Panel

E&S Environmental and Social

FEED Front End Engineering Design

GoI Government of Indonesia

Gvt. Government

H&S Health and Safety

IAV Indirectly Affected Villages

ICBS Integrated Community Based Security

IPIECA International Petroleum Industry Environmental Conservation Association

IPSI Indigenous Peoples and Social Issues

ISO International Standards Organisation

ISP Integrated Social Programme

JBIC Japan Bank for International Cooperation

JNCC Joint Nature Conservation Committee

KK Kepala Kampung (Village Leader)

KPI Key Performance Indicator

LARAP Land Acquisition and Resettlement Plan

LAT Lowest Astronomical Tide

LNG Liquefied Natural Gas

MoE Ministry of Environment

MoU Memorandum of Understanding


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Acronym Description

MCC Mediatama Ciptacitra (BP’s main Health Programme partner)

NC Non Compliance

NOX Nitrogen Oxides

OB Onar Baru

OL Onar Lama

PV Photovoltaic

QPR Quarterly Performance Review

RAV Resettlement Affected Villages

RIF Recordable Incident Frequency

SO2 Sulphur Dioxide

SOP Standard Operating Procedure

STP Sewage treatment Plant

TIAP Tangguh Independent Advisory Panel

TMB Tanah Merah Baru

TSDP Tangguh Sustainable Development Project

UGM Universitas Gajah Mada (BP’s main Governance Programme partner)


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Executive Summary

Introduction

The Tangguh LNG Project (the Project) operated by BP is situated on the south

shore of Bintuni Bay, Teluk Bintuni Regency, Papua Barat Province, Indonesia.

The Project is extracting natural gas from large offshore reservoirs and piping it to

an onshore LNG plant for conversion to LNG.

The External Panel Second Iteration (EPII) has been appointed to undertake

independent monitoring of the project’s compliance environmental and social

(E&S) requirements during the operational period between 2011 and 2016. E&S

requirements are defined in Lenders’ policies, finance agreements and statutory

AMDAL (Indonesian Environmental Impact Assessment) commitments.

This report is EPII’s fourth (E&S) Compliance Monitoring Report covering the

2014 reporting period.

Non Compliance Assessment Findings

EPII identified no level one or level two non complainces (NC1s and NC2s

respectively).

Review of Monitoring and Reporting

The project demonstrates general compliance with Permit requirements and the

requirements of the AMDAL as evidence by outcomes of 2014 PROPER audit

which categorised the Project with a ‘blue’ rating, meaning that the Project is

considered in compliance with its AMDAL and the applicable environmental

requirements.

An appropriate level of environmental and social monitoring is carried out by BP

and third parties and BP is considered to be generally in compliance with its

monitoring and reporting requirements.


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Other Comments & Suggestions

We have also made some suggestions as to areas where the Project may wish to

focus continuous improvement efforts in recognition of the future development of

Train 3. These relate to common activities and identify where there may be

opportunities to bring those activities in line with current international Lender

standards and guidelines. Areas of focus include invasive species management,

food and waste composting, storage of waste and erosion control.

The Social Programme continues to be well resourced and implemented. It is

resulting in sustainable development outcomes and community benefit sharing.

Key achievements for 2014 include the health programme embedding services

within the local government health department; and BP providing 4MW of

electricity for the rural electrification of local villages. BP is aware of, and is

continuing to tackle ongoing challenges related to balancing demand for

community produce with supply, livelihood market dependency, revenue sharing,

industrial development within the area and the effect that all of this has on

community relations.

Concluding Comments

In conclusion, EPII finds the Project to be compliant with Project requirements. No

critical or significant environmental and social risks have been identified in relation

to compliance with Project requirements. EPII would like to acknowledge the

openness and assistance of BP’s team leaders and the Lenders’ Consultants in

providing information and explanation and facilitating the monitoring visit.

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1.1 Overview

This report is the External Panel Second Iteration’s (EPII) annual operational monitoring report of the

Tangguh Liquified Natural Gas facility (Tangguh LNG or the Project). EPII has been appointed to

undertake independent environmental and social (E&S) monitoring of the Project’s compliance with project

requirements during the operational period between 2011 and 2016. This is the fourth annual monitoring

report of EPII, and the eleventh EP compliance monitoring report overall, following the seven reports

produced by EPI between 2005 and 2010. This report covers Project performance from April 2014 to April

2015.

1.2 Tangguh LNG & Tangguh Expansion Project (TEP) Descriptions

Tangguh LNG is situated on the south shore of Bintuni Bay, Kabupaten Teluk Bintuni, Papua Barat

Province (formerly part of the Papua Province), Indonesia (see Figure 1.1). Tangguh LNG is extracting

natural gas from large offshore reservoirs and piping it to an onshore LNG plant for conversion to LNG,

after which it is exported by shipping tanker to markets in the Asia-Pacific region and beyond. Construction

commenced in 2005 and the first cargo of LNG was shipped in the second quarter 2009. Tangguh LNG is

anticipated to have an operational lifespan of more than 20 years with the potential for expansion

depending on reservoir performance and proofing of additional reserves.

Figure 1.1: Tangguh LNG Project Locations and Affected Communities (according to original 2003 Amdal)

Indirectly Affected Villages far from the project =

Indirectly Affected Villages near the project =

Directly Affected Villages (DAV) =

1 Introduction

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The Tangguh LNG Environmental and Social (E&S) Project follows on from the AMDAL (Indonesian

statutory Environmental Impact Assessment) commitments and the international project finance

agreements between the Lenders and BP made in 2003. In accordance with these requirements, prior to

and throughout construction, BP has developed and implemented a number of environmental and social

management and monitoring plans, most notably: Environmental Management System (EMS); Land

Acquisition and Resettlement Plan (LARAP); Indigenous Peoples Development Framework (IPDF); and

Integrated Social Programme 1 (ISP1) 2005 -2010, which incorporated an Indigenous Peoples

Development Plan (IPDP) in accordance with the requirements of the IPDF.

Following completion of construction and the commencement of the operational phase of the Tangguh

LNG facility, ISP1 was revised to become the Community Investment Programme (CIP) 2011-2015 which

was published at the end of 2011 in advance of the first EPII monitoring audit in 2011.

All of the aforementioned documents were reviewed in detail by EPII in advance of the first audit in

November 2011 and are key reference documents for this and all future EPII audits. The additional

documents and data reviewed for this audit are listed in Appendix A.

Figure 1.2: LNG tanker moored at the site.

Source: Mott MacDonald

In 2015 the Engineering, Procurement and Construction (EPC) Contract will be awarded for the

construction of third train (Train 3), two more offshore platforms, a new receiving facility, a second LNG

jetty and other associated infrastructure: this is known as the Tangguh Expansion project (TEP). The TEP

is expected to be commissioned in 2020. The TEP will result in additional and new environmental and

social impacts and therefore it has required a new AMDAL process which was completed, approved and

came into effect in July 2014. The effect of this new AMDAL on the scope of EPII’s monitoring is discussed

in the next section.

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1.3 Scope of EPII Monitoring

1.3.1 Overview

The detailed scope of EPII Operational Monitoring was outlined in the first annual monitoring report issued

in February 2012. In summary, the overall objectives and functions of EPII are to assess the compliance of

operational activities of the Project with the Project’s requirements:

Applicable Asian Development Bank (ADB) and Japan Bank for International Cooperation (JBIC)

policies and the Equator Principles (see Appendix A)

Production Sharing Contract (PSC) Parties and Loan Agreements

AMDAL documentation and requirements of the:

– 2002 AMDAL for Trains 1 & 2 (hereafter refered to as the old AMDAL)

– 2014 AMDAL for Trains 3 & 4 (hereafter refered to as the new AMDAL), approved July 2014

Specific statutory requirements laid out in permits

Environmental and social management plans developed by BP

EPII’s primary role is the identification of areas of non-compliance (NC) with the Project requirements.

Where NCs are identified, EPII provides practical recommendations as to how NCs can be addressed by

BP. EPII also identifies other risks and important issues that are not specifically NCs, but that EPII

suggests are addressed by BP in accordance with good international industry practice (GIIP).

In relation to topics where NC or risk findings are not presented in this report, the Project can be

considered to be fully compliant in these areas. Although this approach and this report do not aim to

identify all of the examples of GIIP and effective project performance, some such examples are highlighted

in various sections of the report. It should be noted that whilst the report focuses on areas of poor

performance, the overall conclusions of EPII after this third audit are that the Project continues to be well

resourced, appropriately managed, and is resulting in beneficial sustainable development outcomes.

Although BP is required to address NCs identified by EPII according to the project finance agreements, it is

not a project requirement for BP to follow the specific recommendations of EPII. BP formulates detailed

action plans and measures to address NC and other important issues using its own experience and

expertise. Actions recommended by EPII are suggestions aimed to assist BP in improving performance.

The EPII team hopes to add value to the environmental and social sustainability management of the

Tangguh LNG Project.

The new AMDAL resulted in some new compliance requirements coming in to effect. The ways in which

these new requirements have changed to social and environmental monitoring scope of EPII are

summarised in the following sub-sections.

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1.3.2 Changes to EPII’s Social Monitoring Scope from the New AMDAL

Most of the changes in Project’s social requirements and comitments as a result of the TEP and the new

AMDAL comitments will result from change villages being supported by BPs social programmes resulting

from:

An increase in the size of the area and the number of communities affected by project activities, largely

as a result of the drilling new wells for train 4 in the Kokas area to the west of the Project site; and

The sub-divison of many of the villages targeted in the original AMDAL into smaller villages (due to

population growth and for political reasons1).

Now 62 ‘villages surrounding the Tangguh LNG project’ will be supported by BP programmes to varying

degrees, but the previous programmes will not be replicated in all of these villages to the same extent as

the was the case for the original 14 Directly Affected Villages (DAVs) and Indirectly Affected Villages

(IDAVs) (hereafter refered to as ‘old AMDAL’ villages).

EPII’s scope will not be affected by this change and we continue to only monitor activities in the 14 old

AMDAL villages as located in Figure 1.1.

In addition to changes to the coverage area, there has also been changes to the content, objectives and

focus of BP’s social AMDAL comitments and programmes which affect EPII’s scope. The operational

phase social requirements for the old AMDAL were translated into the Community Investment Programme

(CIP, originally referred to as the Integrated Social Programme 2: 2011-2015). EPII has been monitoring

against the CIP over the previous three audits and we undertook a mid-term evaluation of its progress in

2014.

Many of the old AMDAL requirements have been carried over into the new AMDAL, whereas some

requirements are completely new. Reporting requirements aginst the new AMDAL requirements came into

effect in January 2015. These requirements have been translated into the draft Tangguh Sustainable

Development Programme (TSDP), which is expected to be finalised and approved in June 2015. As such,

complaince against the TSDP will be considered in the fifth audit in 2016.

The CIP programmes are compared with those of the new draft TSDP in Table 1.1, overleaf, which also

provides an overview of how this effects EPII’s scope for this and future audits.

1 Fourteen viallges are required to establish a District. Districts receive more finance from the Government. Thereore, this approach of

sub-dividing villages is known in Indonesia to obtain more government finances.

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Table 1.1: Overivew of CIP and new draft TSDP programmes and the effect on EPII’s monitoring scope

CIP/ISP2 Programmes

New draft TSDP Programmes Overview of changes to EPII monitoring scope

(from July 2014 onwards)

1. Governance No substantive change of objectives or EPII's scope

2. Communications and external affairs

3. Community health

4. Education and training 5 flagships schools required but locations still to be determined; if in 14 old AMDAL villages will affect EPII’s scope for future audits – for this audit, scope remains the same

5. Livelihoods 5. Local Economic Development Program (LED)

CIP agriculture and fisheries livelihood support programmes continuing, but new emphasis on Papuan business development. Longer time requirement to place non-hydrocarbon businesses outside of site fence into some of the 14 old AMDAL villages, but not applicable for this audit.

6. Workforce & Papuan Development

This supersedes the requirements of the original Indigenous Peoples’ Development Framework and is a now stand-alone programme2. The previous target of 85% of Papuan workforce by 2029, but this is now subdivided further into three groups which will means a slight variation to EPs scope.

7. Integrated Community based Security (ICBS)

Now stand alone programme3. No substantive change in objectives or EPII’s scope.

8. Environmental Protection Awareness

New programme with the objective of increasing local awareness, capacities, and participation related to environmental issues & applicable management practices. Applicable to 14 old AMDAL villages and therefore is included in EPII scope.

This program is not an AMDAL commitment or Lenders requirements but is an additional program in TSDP. Thus, the review on this is not of Compliance Review, but to see the output and outcome of this program on the 14 old AMDAL villages.

9. Tangguh Sustainable Project (TSP – North Shore Housing and 4+4 Mw Electricity Project

New programme with the objective of supporting and increasing communities’ standard of living in Teluk Bintuni by providing reliable energy sources and improving housing. North shore housing affects 2 of the 14 old AMDAL villages of the Weriagar and Tomu Districts, and therefore is within EPII’s scope. EPII will focus on the impact and any social risks of this project implementation on the 14 old AMDAL villages. The TSP project management itself is outside EPII scope as the project is funded by Tangguh Expansion Project and not by Lenders.

In conclusion, the most substantive changes to EPII’s social monitoring scope relate to different definitions

of indigenous peoples (IP) groups and their respective workforce targets; and,three new programmes

related to environmental protection awareness , TSP and the IEDP. Comment on BP’s progress in meeting

the old and the new requirements, and the quality of BPs internal monitoring against these requirements, is

provided in section Review of Monitoring & Reporting.

2 Under the original 2004 Amdal, this was a requirement of HR rather than ISP/CIP.

3 Previously within the CIP this was contained within the Governance programme.

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1.3.3 Changes to EPII’s Environmental Monitoring Scope from the New AMDAL

The new AMDAL has resulted in a number of changes to environmental management at Tangguh,

principally for environmental monitoring. The new AMDAL requirements have been translated into the

Environmental Management Plan (RKL) and the Environmental Monitoring Plan (RPL) for the integrated

activities of the Tangguh Expansion Project. A summary of the key changes is set out below in Table 1.2.

Table 1.2: Old AMDAL 2002 and new AMDAL TEP 2014 and the effect on EPII’s monitoring scope

AMDAL 2002 AMDAL TEP 2014 Relevance EPII 2014 Audit

RKL-RPL refers to relevant Indonesian regulation and international requirement at that period.

Updated reference regulation, both Indonesian regulation and international requirement (IFC 2012, Equator Principles 3, ADB).

The RKL/RPL produced for the AMDAL TEP sets out the requirements for Tangguh LNG, applicable Indonesian and IFC standards and the standard for the TEP (the most stringent of the aforementioned).

The requirements and limits are set out in the Environmental Permit issued following approval of the AMDAL.

Audit has referred to the emission limits included in the new AMDAl which are in compliance with MoE Regulation no. 19/2009 on Stationary Emission Standards for Oil and Gas Business/Activity & IFC 2012

Parameter and location of management and monitoring activity as agreed in RKL-RPL 2002.

A number of the sampling locations and parameters relating to the existing Tangguh plant have changed following the updated AMDAL and water quality discharge permits.

Changes relate/ will relate to:

Surface water

Groundwater

Ambient seawater

Seabed Sediment

Ambient air

Air Emission

Changes came into effect following the approval of the AMDAL in July 2014. As such the reporting for April – Dec 2014 includes a combination of reporting against the old and new AMDALs.

Water supply only from desalination.

Included the addition of a groundwater option to replace or supple for desalination, and to reduce volumes of brine water reject.

If groundwater is used, management and monitoring plans for trains 1 and 2 will also be updated.

No effect on EPII scope for this audit.

Wastewater discharge point at -13 m LAT.

Wastewater discharge point at -6 m LAT.

During the reporting period, water quality continued to be monitored from wastewater discharge point at -13 m LAT.

The discharge point -13 m LAT in LNG jetty 1 will still be used until operation of Train 3 commences.

CEMS only installed on CEMS will be installed for all stacks in process CEMS is currently installed on two AGIs

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AMDAL 2002 AMDAL TEP 2014 Relevance EPII 2014 Audit

stacks with significant impact, i.e. AGI and gas turbine.

area (i.e. AGI, boiler, gas turbine) with capacity >25 MW.

and two gas turbines. The results of monitoring data from the Lenders Report dated April 2014 – March 2015 have been reviewed as part of this audit.

CEMs will be installed on the new AGI, boilers and gas turbines as part of the TEP.

No effect on EPII scope for this audit.

No hazardous waste incinerator during operation stage.

Hazardous waste incinerator will be installed for operation.

Not currently applicable. It will be applicable upon commencement of TEP.

Activities at Babo not included.

Activities at Babo included within the new AMDAL.

Activities at Babo are not internationally financed and as such are not included within the EPII scope.

Comments on BP’s compliance with both the old and new requirements, and the quality of BP’s internal

monitoring against these requirements, is provided in Chapter 3.

1.4 Activities & Information Sources for 4th

EPII Monitoring Audit

The EPII team undertook its fourth annual monitoring audit between the 30th March and 13

th April 2015.

The first few days of the audit was spent in Jakarta in BP’s central offices to review the project

documentation and to participate in presentations by BP project personnel. The following week was spent

at the Tangguh LNG Facility to review the site and surrounding community conditions. Interviews were

undertaken with project and external stakeholders and focus group discussions were held in some villages

(see Figure 1.3).

Figure 1.3: Focus group discussion in Onar Baru Village

Source: Mott MacDonald Source: Mott MacDonald

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The locations visited within and outside of the project site are presented in Table 1.3 beow. The audit

concluded with a close out meeting in Jakarta on 13th April 2015 to present the findings outlined in this

report.

Table 1.3: Locations visited

Locations visited within the Project site Locations visited outside the Project site

LNG Plant Area Arguni and Taver Villages

Combo Jetty Onar Lamu and Onar Baru Villages

Wastewater Treatment Plant Bintuni Town

Permanent Sewage Treatment Plant (STP) facility Weriagar

Plant construction phase lay-down area Tanah Merah Baru (TMB) & Saengga Villages

Central Waste Accumulation Area Babo Town

Hazardous waste storage area Manggosa Pathway

Sewage treatment plants (A, C1, C2) New Genting Oil Road linking TMB and Tofoi

Reverse Osmosis Plant

New Sanitary landfill

Existing inert landfill site

Existing organic waste landfill site and associated leachate pond

Production laboratory

Log pond and perimeter fence

Perimeter fence (including managed access point)

PLN Substation

The key types of project and external stakeholders interviewed were:

BP Jakarta-based and site personnel

Government officials at the regency and village level

Project affected people and community and Adat leaders in the Directly Affected Villages (DAVs)

BP’s Implementing partners

The full list of documents reviewed is presented in Appendix B and the full list of stakeholders that EPII met

is presented in Appendix C.

1.5 Overview of Project Performance and Key Developments in 2015

The project performed extremely well in technical terms in 2014 with a record 117 cargoes delivered. The

same can be said of environmental, health and safety performance with key achievements including:

In December 2014, the Project retained its ‘blue’ rating in its Ministry of Environment (MOE) PROPER

audit for the third year in a row, meaning that the Project is considered in compliance with its AMDAL

and the applicable environmental requirements. BP have an official objective to maintain its blue rating

in 2015, whilst striving to obtain a green rating.

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Ongoing improvements around flaring resulted in a 25% reduction in 2014 from 2013 .

GHG emissions for 2014 were 4.73 million tonnes (mt), demonstrating a decrease in GHG emissions of

4.77mt in 2013 despite increased LNG production. The reduction in GHG emissions produced was a

result of reduced flaring and completion of a program to replace diesel power generation with electricity

from a plant at the camp area. This reduced 1000 tonnes/quarter of CO2 emission.

Strong performance in health and safety with only one recordable injury representing a 0.03%

recordable incident frequency (RIF)4. One medical treatment was reported, for which BP undertook a

detailed investigation and a review of corrective actions. No ‘day away from work’ (DAFW) cases were

reported.

In 2014 the Project implemented a four point safety intervention case to improve the occupational

health and safety statistics. The STOP Card system (CARE) (see Figure 1.4) was introduced which

encourages employees to speak up if they observe unsafe acts.

Figure 1.4: BP's STOP Card System (CARE)

Source: BP

Key social development contributions in 2014 included:

The health programme embedding services within the local government health department

representing a state of ‘development with the community’ as opposed to ‘development for the

community’.

The education programme achieving a student passing rate of 100% for elementary and junior high

and 99% in senior high.

BP providing 4MW of electricity to a substation at the site perimeter which is sold to the state electricity

utility PLN. In 2014, PLN constructed infrastructure to connect Tanah Merah Baru, Saenga and other

villages that are receiving electricity around the clock.

BP achieving the very challenging workforce targets for indigenous peoples and Papuans.

4 Recordable Injury frequency is defined as number of incidents per 200,000 man-hours.

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These and other achievements are discussed in further detail in Chapter 3.

1.6 Limitations of the Fourth EPII Monitoring Audit

Consultation fatigue was identified as an issue by EPII during the 2013 audit and this has continued in

2014 as a result of the Amdal process. There has also been some tension with communities who have

expressed their dissatisfaction with unresolved issues related to Adat revenue sharing claims to the

government. As a result of this, it was agreed with BP that EPII would hold fewer community meetings, and

instead would focus on key informant interviews involving a smaller range of stakeholders. Despite the

above approach, one security incident occurred during consultations resulting in a security stand down, as

discussed further in section 4.3.2.5. Hence, a day of EPII community consultation activities for the audit

was lost.

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2.1 Overview

This section presents findings of the non-compliance assessment. Its key objective is the identification of

areas where the Project is not in compliance with the Project/Lenders’ requirements. The approach to the

assessment and the categorisations used by EPII as well as the results and recommendations are

presented in the sub-sections below.

2.2 Approach to Non-Compliance (NC) Assessment

All of the information and evidence gathered from the site visit activities and information sources has been

used by EPII to identify areas of non-compliance (NC) with Project requirements. The following two levels

of NC are defined in the Project finance agreements:

a. “Level 1 [hereafter referred to as NC1] means any failure to comply with, or any action or

omission which is inconsistent with, any Environmental and Social Requirement, but which

failure, action, or omission does not constitute a Level 2 E&S Non Compliance”;

b. “Level 2 [hereafter referred to as NC2] means any failure to comply with, or any action or

omission which is inconsistent with, any Environmental and Social Requirement, but which

failure, action, or omission (considered either on its own or in conjunction with any other one or

more such failure(s), action(s) or omission(s)):

i. Has resulted in or is reasonably likely to result in material damage or harm to, or a

material and adverse impact on, the environment;

ii. Constitutes or is reasonably likely to constitute a “significant impact” for the purposes of

and as defined in the Indonesian Decree Concerning Guidelines for the Determination of

Significant Impacts (BAPEDAL Decree No. KEP-056/1994);

iii. Has resulted in or is reasonably likely to result in material damage or harm to, or a

material and adverse impact on, the lives, livelihood, quality of life, health, safety, security,

property or cultural heritage of affected people; or

iv. Has resulted in or is reasonably likely to result in the revocation of, or the refusal to grant,

any approval, consent, permit or other authorisation required for the implementation of the

Tangguh E&S Project (but only to the extent that such approval, consent, permit or other

authorisation is required for implementation of the Tangguh E&S Project at that time).”

EPII has endeavoured to apply these definitions as literally as possible, presenting conclusions supported

with evidence. Where evidence is not clear-cut and professional judgement has been used, this has been

clearly explained and justified with reasoned arguments.

Where NCs have been identified, corrective actions have been recommended to address them. EPII has

aimed to be practical with consideration of costs and constraints faced by BP, actual or predicted change

in circumstances, likelihood of effectiveness of corrective actions and where appropriate, key performance

indicators (KPIs) that can be used to measure success.

2 Non-Compliance (NC) Review

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2.3 Non Compliances Identified in EPII 4th

Monitoring Audit

In the third annual audit EPII identified no non compliances (NC1 or NC2).

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3.1 Overview

This section presents the findings of EPII’s review of BP’s internal and external monitoring, continuous

improvement planning, and reporting to lenders, communities and other external stakeholders in

accordance with Project requirements.

3.2 Environmental Monitoring and Reporting

3.2.1 Environmental Monitoring Requirements

BP is required to carry out regular monitoring and reporting as well as occasional studies and surveys. The

commitments arise from:

The 2002 AMDAL

The 2014 AMDAL (and associated Environmental Permit (Izin Lingkungan) No. 02.37.07 Year 2014

Dated 24 July 2014)

The PSC Parties Agreements signed in 2003

The International Standards Organisation (ISO) 14001 certified EMS: although it is not legally binding,

failure to comply could result in the loss of certification

Environmental permits issued by government authorities

Permits from the environmental authorities, in particular the Ministry of Environment including an

environmental management plan (RKL) and monitoring plan (RPL) which become statutory

requirements following their approval by the authorities.

It should be noted that additional Project activities not covered in the original AMDAL (such as dredging

work or helipad construction) have only required Environmental Management Effort and Environmental

Monitoring Effort (UKL/UPL) studies.

Where applicable to the existing Project, the environmental monitoring requirements of the new

Environmental Permit came into effect in July 2014 following approval of the new AMDAL. This relates to a

change of sampling points for surface water monitoring.

Compliance with these requirements and the results of environmental monitoring are discussed in the

following sub-sections.

3.2.2 Amdal Reporting

The AMDAL report for April to December 2014 did not contain the quarterly surface water monitoring

results obtained in June 2014 in accordance with the requirements of the 2002 AMDAL. It was noted that

there was no exceedances in the monitoring data. EPII raised this issue with BP, who confirmed that there

had been verbal agreement with the MOE that the reporting period,and the monitoring and reporting

requirements would change to follow the new AMDAL. However, there was no documented evidence of

this discussion to confirm the revised approach for reporting has been agreed. We have since been

provided with confirmation from the MOE contact. EPII recommends that written records of all verbal

3 Review of Monitoring & Reporting

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discussions relating to permitting matters be maintained. Furthermore, monitoring and reporting

procedures should be updated to show a change in process.

To effectively manage future communications with government departments, BP has established a

governmental liaison role. EPII consider that this is a suitable approach which will formalise discussions

held and recommends that records need to be maintained of communications relating to permitting

matters.

3.2.3 Emissions to Water

In July and September 2014, the ammonia concentration of produced water reached 8.46mg/l and

8.03mg/l exceeding the 5 mg/l concentration standard in the wastewater effluent permit 125/2013. This is

an exceedance rather than a non-compliance. Permit 125/2013 includes limits on monthly loading (kg) as

well as concentrations (mg/l) and based on the wording of the permit, the non-compliance only applies

when both parameters are exceeded.

It is understood that on a number of occasions in 2014 when exceedances were identified, the water was

recirculated in the system and not discharged via the -13m LAT common outfall. Discharges to the outfall

only occurred on occasions where the water treatment system was at capacity.

On both occasions that there were exceedances in 2014, BP notified the MoE of the exceedance and

noting measures being taken to reduce ammonia concentrations from produced water. Further, BP should

be commended for going beyond the legal notification requirements and reporting to the MoE in November

2014 that there could be an exceedance based on the trends that were observed through internal water

quality monitoring5.

These exceedances represent ongoing difficulties BP has experienced in achieving the ammonia

concentration standard for produced water. BP has established a strategic action plan with the objective of

identifying methods to improve the performance of waste water treatment. Options for pre-treatment of

water are being considered and a university and research center has been appointed to lead the ongoing

investigation. EPII look forward to a resolution being reached on this point by the next annual visit in 2016.

3.2.4 Emissions to Air

There were no exceedances of external emissions to air limits within the reporting period.

5 External produced water quality monitoring results in November 2014 showed no exceedance of ammonia.

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3.3 Social Monitoring and Reporting

3.3.1 Social Monitoring & Reporting Requirements

The CIP translates the monitoring and reporting requirements stipulated by the old AMDAL6 and the PSC

Parties Agreements into a CIP monitoring, evaluation and reporting framework. Namely:

Internal monthly programme tracking and reporting - to collect data and information to develop

preliminary findings on the progress of activities;

Internal Quarterly Performance Review (QPR) – to review the targets of activities to identify the

problems and challenges;

External bi-annual AMDAL and lenders reports7 – to monitor the progress of stated results and

commitments and to formulate recommendation; and

Annual Performance Review – to review the progress and achievement of activities, formulate

refinement and adaptation to actual context.

As well as social programme performance, one of the key parameters required to be monitored and

reported by BP is community grievances.

The old Amdal requirements for BP’s internal monitoring and reporting activities were defined in the CIP

which was applicable until January 2015, after which the new AMDAL and TSDP monitoring requirements

came into effect. Precise key performance indicators (KPIs) were still being defined by BP at the time of

the audit.

Compliance with these requirements and EPII’s opinions on the quality and outcomes of the monitoring is

discussed in the following sub-sections.

3.3.2 Comment on Social Monitoring and Reporting in 2014

Overall, EPII is of the opinion that the internal monitoring and reporting approach and systems continue to

be adequate and effective, and that BP is meeting its internal and external reporting commitments in line

with Project requirements.

The monitoring findings identified by BP in relation to each of their social programmes during the reporting

period – including the new TSDP programmes relevant since January 2015 - are summarised in Table 3.1

overleaf, along with EPII’s comments on the monitoring approach.

6 The AMDAL contains 222 social commitments for the operational phase of the project and approximately 22 of these include

specific monitoring requirements. BP informed EPII during the site visit that not all of the AMDAL social commitments were included in the scope of EPII, however it was not clarified which items were included and which weren’t. This issue will require clarification prior to the next EPII monitoring visit.

7 These reports are requirements of the PSC parties agreements lender monitoring and reporting requirements.

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Table 3.1: Overview of BP social programme monitoring findings and EPII comment

CIP/TSDP programme

Overarching objectives Selected BP monitoring findings and plans EPII comment

1. Governance Contribution to the improvement of governance of government and civil society in accordance with transparency, accountability, and participation principles.

The Programme was largely on hold during 2014 as partnership agreements came to an end and its scope was revisited. Achievements in 2014 included:

Use of radio in Bintuni for public monitoring and

citizen oversight of budgetary spending

Development of networks between local and

central government to address specific issues

such as revenue sharing and remote community

transportation

A gap analysis of the governance programme is expected to be complete by June 2015. This will be followed by a workshop with UNDP and government, SKKMigas, to redefine the programme. Genting and Eni will be invited so that governance can be looked at holistically among the various oil projects.

The achievements reported in the April to December 2014 monitoring report provide some information on increasing civil society organisation participation levels and participatory planning.

This is understandable in light of the scale back of the programme.

However, the local election for Bupati Bintuni will happen in December 2015 where during the period before and after, the local government will be focusing on politics/election. The program will start when new Bupati is in office early 2016.

2. External Relations Promotion of mutual respect and constructive relationship between Tangguh LNG and its local stakeholders in West Papua.

In addition to ongoing grievance management,

Community Action Planning and reporting to

communities via the ‘Kadate’ newsletter, in 2014 BP

provided:

Visits for Onar and Tanah Merah Baru residents to

restricted access cemeteries

Support for several social and religious events in

the villages such as Independence Day

commemoration, Ramadan Eid and Chistmas

celebrations.

BP recognises the issue of consultation fatigue and is actively trying to manage it by not visiting the same village in the same month. In previous audits EPII flagged up that consultation fatigue may be exacerbated because the M&E and study results are not routinely fed back to the communities and stakeholders who provide the data and opinions, other than through the Kadate community newsletter, which does not go into much depth.

We previously recommended that BP finds ways to communicate these results, for instance through non-technical summaries. These recommendations still stand. However it is noted that BP did share the education results from the survey during program discussions with Fakfak and Bintuni local governments and education stakeholders.

3 Community health Supporting local government and local community to improve health quality / accessibility of services.

BP states that in 2014 local health providers achieved

a new level of empowerment as the implementing

partner YSA was fully embedded in local government

and all programmes have budget sharing. The BP’s

health staff is now monitoring from Jakarta. Key

achievements include:

Completed emergency maternity services in the

Babo Puskesmas (health clinic) and a referral

The health programme continues to be a success story for BP and BP is commended for reaching a state of integration of services with the local government.

EPII identified that there were 110 births in Babo Puskesmas in 2014 compared with 37 in 2013 which shows a local culture shift from use of traditional birth attendants, as explained at the Posyandu (see Figure 3.1).

BP reported zero cases of malaria in 2014 but EPII consultation with

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CIP/TSDP programme


service for high risk mothers established

The head of the local health department of Bintuni

regency and BP programme manager were invited

to present the malaria programme to the national

Civil Servant Empowerment ministry as a capacity

building activity.

the Puskesmas as a result of local transmission. However, 14 cases found among Genting oil workers, who had apparently been infected as a result of malaria being introduced into the area by migrant construction workers.

Lack of transport from remote villages to maternal health facilities such as that in Babo and for serious cases, to Bintuni hospital, continues to be the key challenge.

A key achievement identified by EPII is that in TMB there were zero cases of mother and child malnutrition in in 2014.

4. Education and training

Supporting local government and local community efforts to achieve an educated and skilled local population.

In 2014 the contract with the education partner British Council was completed and the partnership arrangement was re-tendered. The prequalification process failed because only one applicant passed the BP’s HSE requirements, so the process is being repeated. If the process fails for a second time, a direct appointment can be undertaken according to SKKMigas rules. Despite this, key achievements and findings in 2014 include:

Student passing rate of 100% for elementary and

junior high, and 99% in senior high.

Recruitment of 35 full time teachers paid by BP to

support elementary and high school programmes

in villages

Provisions of scholarships

Upon returning to the high school in Babo EPII were pleased to hear that in 2014 visits were facilitated to the LNG facility for school children (this was requested to EPII via the previous audit) which was well received by students and teachers alike, who found it inspiring.

The Indigenous Enterprise Development Programme (IEDP) team (see the next row) took a coordinated approach with the education teams to ensure that the education programmes are aligned with the long term objective of increasing the IP workforce on the Project and promoting Papuan businesses.

The education team has developed shcolarship database that define the beneficiaries as well as their origin and type of scholarship received.

Adult literacy and commitment to children’s education is still a key constraint to realising education objectives, and efforts in these programmes should be stepped up. However, the Education program has developed an initial literacy program in the village through PPL (field program provided by UNCEN) in 2014. This is an effort to improve community capacity in literacy as well as among the students. The literacy issues still become a challenge due to cultural constraint.

5. Livelihoods / Local Economic Development

Improving capacity of households in local community to create diversified and sustainable income sources, and empowerment of indigenous Papuan contractors to be competitive.

Under the TSDP, there is new emphasis on Papuan business development; also, there is a

2014 saw a decline in the total amount of agriculture produce supplied to Tangguh catering (provided by Indocater) as a result of a reduction in demand due to the reduction in the number of workers on site. Efforts continue to open up alternative markets. Key achievements identified by BP monitoring include:

New outlet opened in Fak Fak in Nov 2014

282 tonnes of agricultural and fisheries products

supplied to Tangguh catering from 7 stocking

points in 14 old Amdal villages - $694,000.

New cooperatives with local women to sew

During this audit many of the challenges and issues unidentified by EPII related to the agricultural programmes and these are discussed in more detail in section 4.

A suggestion for BP to improve its monitoring and reporting is to measures consumption of fisheries and agricultural produce by Tangguh LNG not according to volume, but percentage of total purchase, in order to demonstrate the trends, aiming for increased percentages of the total coming from the local communities and IPs.

There is high demand for new livelihood streams and the cooperatives in Babo expressed excitement at the opportunity offered to them for assistance with developing a fisheries and crab

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CIP/TSDP programme


requirement to place non-hydrocarbon businesses outside of the site fence.

uniforms – first uniforms in August (in wider

villages beyond DAVs)

New livelihood programmes: mangrove syrup,

fresh water fisheries.

fattening business. They have prepared the land in readiness.

New programmes under the TSDP – came into effect since January 2015 (monitoring approach still being defined)

6. Workforce & Papuan Development

Empowerment and skills development of Papuan peoples. The previous target of 85% of workforce being Papuan by 2029 still stands.

BP has developed a MoU with the local government to

improve the local Polytechnic in Fak Fak and SMK

Bintuni. 2014 achievement include

Target for 2015 was 51.5% of the workforce being

Papuan and the actual achievement was 52.1%,

so BP is on track.

Key challenge is to identify indigenous enterprise

outside the fence, to support low tech activities

9 batches of site apprenticeship programme were

completed and 40% are now working in the

Tangguh facilities

Meeting the extremely challenging workforce targets every year continues to be a commendable achievement by BP. This will get increasingly challenging as the requirement to have higher percentages of indigenous and Papuan peoples in technical and managerial roles begins.

Going forward it will be critical that the Indigenous Enterprise Development, Workforce and Education teams take a coordinated approach to achieve these objectives.

7. Integrated Community based Security (ICBS)

This is now a standalone programme8. .

Key achievements include:

Joint exercise involving police and BP

ICBS evaluation was undertaken in late 2014 (still

awaiting findings)

BP is aware of and monitoring the impact of other operators in the area, for example, Genting oil was previously using the military for security creating local tensions.

8. Environmental Protection Awareness

Increasing local awareness, capacities, and participation related to environmental issues & applicable management practices.

At the time of the audit this programme was yet to start and as such no monitoring data was available.

To be reviewed in the fifth audit in 2015.

9. Tangguh Sustainable Project (TSP – North Shore Housing and 4+4 Mw Electricity Project)

Supporting and increasing communities’ standard of living in Teluk Bintuni by:

Providing reliable energy

source through rural

electrification Supporting the

government’s north shore

housing project to protect

villages from erosion

BP provides 4MW of electricity which is distributed

to TMB, Saenga and other villages. BP states that

affordability is not a problem but willingness to pay

is. In Taroy people refused to pay because they

feel they have an entitlement as they own the gas

being used to generate the electicity. This is

another manifestation of the unresolved revenue

sharing issue.

North shore housing project major achievements

Previously electricity was only available for six hours per day via

use of gensets in the villages closest to the site, now the

villages are permanently connected. This is a great

achievement and should be commended as lack of electricity is

repeatedly identified as key constraints to health, education and

livelihoods within the affected villages. The Onar villages are

expected to be connected next, and distribution poles have

already been erected.

Some stakeholders consulted by EPII stated that they knew that

8 Previously within the CIP this was contained within the Governance programme.

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CIP/TSDP programme


. in 2014 include appointment of a feasibility

consultant, a site survey and pre-feasibility study

the North Shore Housing project is an AMDAL commitment, but

had not heard anything about it. Requests were raised for a

socialisation on the topic, which BP has agreed to do alongside

the local government once the revenue sharing issue is further

resolved.

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Figure 3.1: Babo Posyandu (maternal health clinic)

Source: <ott MacDonald site visit 2015

3.3.3 Grievance Log Review

EPII’s review of the grievance log showed that although there were 38 entries in 2014 from seven different

villages, none were actual grievances about project performance or impacts. Rather, all communications

recorded were comments about the social programmes and requests for information, jobs or investment.

This is a satisfying achievement, and reflects the duty of care that BP is talking in relation to community

operations.

One of the people who had lodged some comments was the same individual who was responsible for the

security incident discussed further in Section 4.3.2.5. Discussions with BP’s community relations teams

revealed that this individual, and others, were known dissenters. It was recommended that in the future

when comments or communications are raised from these ‘high risk’ individuals, this is flagged to ensure

that extra care is taken when responding to not exacerbate any bad feelings or catalyse any incidents or

attacks.

3.3.4 2014 Social Budget Realization Review

Upon reviewing the 2014 budget and expenditure EPII finds that the ISP2 programme continues to be well

resourced and that the budget is largely appropriate in terms of continuing to meet Project requirements.

2014 saw the introductions of a new budget line focussing on Papuan development in accordance with

EPII’s previous recommendations and the requirements of the new Amdal.

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The 2014 budget absorption was 73.1% with underspends in all budget lines except in education and

vocational training. This was as a result of the primary focus being on the Amdal for the TEP, and the

context of wider economic constraints resulting from the reduction in oil prices.

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4.1 Overview

This chapter identifies other environmental and social issues identified as part of the audit and offers

suggestions for continual improvement.

4.2 Environmental Management Issues and Challenges

4.2.1 Invasive Species Management

Since the last EPII audit visit, an increased prevalence of Mimosa, an invasive species (but not considered

by BP to be an Alien Invasive Species (AIS) was noted on site, leading to concerns that the increased

abundance of this species is adversely affecting the natural habitat. It is understood that the flora and

fauna survey, which is currently out for tender and will be undertaken in late 2015/early 2016, will include a

review of invasive species on site. It is recommended that following the survey, a weed and pest

management programme is developed and implemented for the control of invasive species.

Figure 4.1: Evidence of Mimosa at the onsite log pile


4.2.2 Food Waste Composting

The onsite food waste composter operated for one month in 2014 before being shut down due to a

breakdown of an electrical component of the plant. Previously, the composter had been shut down for

more than two years while agreement for sourcing a replacement part was agreed with the authorities.

These shutdown periods resulted in unprocessed food waste going directly to the organic waste landfill,

which is against the GIIP ‘4Rs’ (reduce, reuse, recycle and recovery of waste). The use of the composter

4 Other Issues and Suggestions

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to reduce the amount of waste going to landfill would assist BP to achieve a green ranking in the PROPER

audit, where efforts for waste minimisation are a ranking consideration.

EPII consider that in future BP should adopt a more proactive approach to avoid similar delays. It is

recommended that the preventative management programme for the composter is reviewed to increase

the frequency of maintenance periods, to identify spare parts which should be procured, and to lessen the

duration of any future outage periods. Once the composter returns to operation, it is recommended that BP

identify local villages that would benefit from receiving a proportion of the compost produced.

4.2.3 Biodiesel Production

Previously EPII reported on the success of the laboratory trials held at Tangguh to convert used cooking

oils to biodiesel for use in onsite vehicles (see Figure 4.2). Whilst there have been some delays in

establishing the full biodiesel production programme on site, tenders for a biodiesel mini pilot plant with a

capacity of 100 litres/batch will be commissioned by the end of 2015. This will not only reduce the use of

conventional fuel used by on-site vehicles, it will also reduce transportation and disposal costs of waste

cooking oils which currently are sent to West Java for disposal.

Figure 4.2: Laboratory trials of biodiesel


4.2.4 Storage of Waste

During the visit to the reverse osmosis (RO) plant, it was noted that several drums of waste, including

waste oil (hazardous), were labelled and stored incorrectly on the edge of the bund wall. In the event of a

spillage there is a risk that it would not be contained. It is understood that the contractor responsible for the

RO plant was waiting for the waste to be removed. Regardless, waste should have been stored correctly. It

is important that BP ensure that all contractors are made fully aware of the procedures for waste handling,

storage and disposal. The EPII does not consider this to represent a significant issue, but does highlight

the need for regular site inspections and training of contractors. This is particularly pertinent given the

future works planned.

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4.2.5 Erosion Control

During the visit to the new inert and organic waste landfill site, evidence of soil erosion was observed. A

number of gullies have formed on land adjacent to the landfill area (as shown in Figure 4.3), with soil runoff

going into a drainage channel and in the direction of the natural waterway at the site boundary.

Furthermore, it was noted that the drainage channel does not extend as far as the site boundary resulting

in further erosion channels developing at the outfall of the drainage channel (refer to Figure 4.4). As a first

step, it is recommended that the erosion control berms are installed in areas where rill erosion is occurring

and the area of bare earth is re-vegetated. The drainage channel termination should also be reviewed with

a suitable collection sump or tie into any existing drainage network.

Figure 4.3: Evidence of erosion on land adjacent to the

new landfill site

Figure 4.4: Erosion channels from the drainage channel

outfall in the direction of the natural water way

Source: Mott MacDonald Source: Mott MacDonald

4.2.6 Hazardous Waste Permit

The EPII report 2014 reported that BP had not obtained a hazardous waste permit, as a result

longstanding issue that is related to third party administrative function outside the control of BP. A

hazardous waste permit (188.4.5/A-39) has now been obtained from the Bintuni Regency for the temporary

storage of hazardous waste at site, which allows hazardous waste to be stored for a maximum of 90 days

on site.

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4.3 Social Management Issues and Challenges

4.3.1 Overview

4.3.1.1 Overview

The sub-section below discusses a number of ongoing issues identified in previous EP audits and already

recognised by BP, namely challenges faced by the livelihood programmes, and issues of community

dependency, revenue sharing, transport and community relations challenges. A number of new issues are

identified relating to the potential resettlement of the Onar villages, risks resulting from the area opening

up, oil price fluctuations and the change in government in 2015.

4.3.2 Ongoing Issues and Challenges

4.3.2.1 Balancing Livelihood Programme Supply with Project Demand for Produce

The ongoing challenge of balancing the Project’s need for agriculture and fisheries products (see Figure

4.5) with the supply from the communities persists. This issue has been identified previously by EPII and is

considered very important because Indocater, the site produce supplier, is the main and in many cases the

only market outlet for local communities who are largely dependent on the company for their agriculture

production income.

Figure 4.5: Fisheries Livelihood programme Produce


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4.3.2.2 Communities’ Market Dependence on BP

Addressing this issue is critical to the success of BP’s livelihood programmes. This can be seen though

examples of failed initiatives such as the agricultural cooperative in Onar Baru that disbanded a few years

ago due to demand not matching supply and loss of motivation in the village. There are now only three

active farmers in Onar Baru which would make the reestablishment of a cooperative challenging.

The importance of ’local content’ (in this case, procurement of local produce) to the sustainability of the

Tangguh Project is recognised in the new Amdal which includes the target of 65% of agriculture and

fisheries produce being consumed by the Project as coming from the local communities after train 3 is

operational in 2020. EPII noted to BP that only the total tonnage of produce that is consumed from the

local communities is being reported, rather than the percentage of the total consumption by Indocater

coming from the communities. Therefore, it is difficult to monitor progress in reaching this target. It was

suggested to BP that the monitoring and reporting approach is revised to address this As of December

2014 they were at 25% of fisheries produce and 17% of agricultural produce coming from the local

communities.

EPII village consultation identified a number of cases of over-production in the communities. Some

frustration was expressed by cooperatives that both fisheries and agricultural produce was not being

purchased and as such was being wasted. Farmers and fishers indicated this was adversely affecting

livelihoods in cases where producers did not receive economic return for their labour. There appears to be

four main challenges causing this, as outlined below, along with EPII suggestions to consider overcoming

them:

1. Minimum consumption contracts: it became apparent through community consultation that BP has

agreed contracts with a number of cooperatives guaranteeing a minimum purchase (tonnage) per

week.9. EPII suggests that in light of demand varying from month to month, it does not make sense to

have minimum purchase agreements and these should be revised. Furthermore, there needs to be

more regular and timely communication to communities about changing demand levels as was

specifically requested by some communities consulted by EPII.

2. Meeting minimum produce quality requirements: producers must meet the strict regulatory and

Project produce quality requirements relating to sanitation, hygiene, produce type and size. Produce is

inspected at the stocking points and if requirements are not met, it cannot be purchased. Overcoming

this is challenging and BP’s agriculture team is diligently working to raise production standards on an

ongoing basis.

3. Adverse weather and produce transport challenges: sometimes the produce collection boat cannot

travel to the stocking points to collect the produce before it has perished and cannot meet the quality

criteria. EPII, BP and the local government recognise that this issue of transport is a cross-cutting

challenge which affects many aspects of daily life.

9 EPII has reviewed a sample of one of these contracts and can verify the claims made by communtiies of a guaranteed minimum

purchase.

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One solution proposed by cooperatives in Tanah Merah Baru who have requested that BP to allow

delivery of produce by land through the site fence. BP is looking in to this, but it may not be possible for

security reasons. BP is also investigating the opportunity to upgrade the boats so they have higher

capacity for produce storage.

4. Communities’ market dependency on BP: BP is fully aware that the overarching and longer term

issue is the communities’ market dependency on BP, as discussed in more detail in the following

section.

BP has stated that its livelihoods team will work on a strategy with the Project logistics team to overcome

the challenges that the EP has identified in order to increase local production and purchases.

BP are considering a number of options to open up alternative markets for agriculture and fisheries

produce in the Bintuni and Fak Fak regencies and beyond, including:

Discussing opportunities to supply a shipping company in Babo with crab and agricultural produce.

There has also been interest and demand expressed from traders from Kokas and Bintuni, however

the cost of transport is making this prohibitive at present.

The Mayri Cooperative has plans to develop a village outlet in TMB to sell excess supplies.

Discussions with local government about a joint strategy to penetrate markets further afield in Java and

beyond.

EPII feels that, when considering new livelihood initiatives such as the crab cultivation scheme being

conceived in 2015, greater consideration should be given to market penetration strategies early in the

planning process. If schemes are to be sustainable, efforts should be made to ensure that schemes are

designed not only to provide services to the Project in the short term, but also to gain access external

markets and demand for produce and services.

One example where this was not done was the bicycle repair business established in Babo in 2012. The

business progress was noted in previous EP audit reports. The livelihood team provided training, business

support and inputs to a team of local people to set up a workshop to provide bicycle repair services to

Project workers and community members. However, in Q2 2014 when BP stopped sending bicycles to

Babo for repair, the business quickly ceased to operate. This demonstrates the market dependence of the

initiative on the Project.

BP states that the failure of the bicycle repair business is also due to the greater availability and use of

motorcycles in recent years, a trend which EPII feels could have been identified at inception of the

livelihood scheme.

EPII suggests that lessons could possibly be learnt from Onar Tengah (‘Centre Onar’), the recent village

that has come into existence through economic migrants who have travelled to the area to pursue shrimp

and fisheries opportunities. They appear to be independently running successful enterprises and have

access to other markets. Whilst it is recognised that they are more experienced and established fishermen

with additional skills and resources for transporting produce to market and providing credit, opportunities

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could be considered to learn from them in relation to market diversification and business

professionalisation.

4.3.2.3 Effective Functioning of Cooperatives and Jealousy over Stocking Point Locations

Some Onar Baru farmers stated that payment from the Mayri Cooperative10

in Tanah Merah Baru often

takes one or two months after produce is delivered. Some Onar Lama farmers claim that the cooperative is

two years behind with payments and it owes six million rupiah to farmers in the village. The Mayri

cooperative acknowledged to EPII that there are often delays in payment. The cited reasons related to

weather and tidal conditions, transport challenges, and also their inexperience with accounting. Whilst last

year farmers received support from Bina Swadaya in improving production, they stated that they did not

receive any business mentoring and that they need this to function more effectively.

Both Onar villages have requested assistance from BP with establishing their own cooperative, rather than

having to transport their produce to Tanah Merah Baru stocking point. This would save them the expense

of transport and could prevent the long waits for payment. They want to be able to sell produce directly to

Indocator and have a stocking point established in the Onar villages. In Weriagar too, there were

complaints to EPII that stocking point management needs improvement with better communications about

collections.

As noted previously, earlier efforts at establishing cooperatives in the Onar villages failed partly due to

supply and demand issues. However, in both Onar villages it was widely acknowledged that the UBSP

women’s savings and loans schemes were the most successful operational institutions. One option to

reduce dependence on the Mayri Cooperative could be to use UBSP’s capital to establish a new Onar

cooperative.

4.3.2.4 Revenue Sharing and its Effect on Community Relations

The socialisation activities to present the new Amdal to the communities have been delayed due to the

lack of resolution regarding revenue sharing and the north shore Adat communities’ claims for 54 billion

rupiah from the local government. This has resulted in some tensions with the local communities who hold

BP partly responsible, despite the fact that this issue is the responsibility of the government.

EPII commends BP for its efforts to facilitate the resolution of this issue through, for example, continuing

advocacy for a ‘Perdasus’ (special bylaw) mechanism so that revenue is not just shared at regency level,

but flows down to local Adat community leaders. Efforts are ongoing to get the draft regulation enacted. BP

also facilitated a workshop in February 2015 to introduce oil and gas industry revenue sharing to house

representatives of Teluk Bintuni regency, NGOs and university representatives.

In addition, EPII suggests that BP repeats the community socialisations held previously in 2014 on revenue

sharing, to explain that it is not BP’s responsibility to enact Perdasus, but that BP is doing what it can to

push the government towards resolving the issue. This would go some way to addressing misinformation

10

The Mayri cooperative in TMB has 80 farmers (up from 70 in 2014) from TMB, Tofoi, Saenga and Onar Lama and onar Baru.

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in the communities. For example one of the Kepala Kampungs of consulted in the North Shore villages

stated a common north shore perception that the benefits of the oil and gas revenue to the provincial and

regional government were in the region of twelve trillion per year, and there is little evidence of it trickling

down to small communities.11

4.3.2.5 Community Relations

Community frustration continues threaten community relations manifested in security incidents that lead to

‘safety stand downs’ (temporary withdrawal of staff from villages). There were two security stand downs in

2014. Both were the result of boat detentions (obstruction). Such incidents disrupt the Project’s social

programmes.

During the audit on Sunday 5th April the EP and the Lenders Consultant’s team experienced one such

incident when its boat was attacked and a window was smashed (see figure. Upon investigation this was

caused by one agitator acting alone rather than an organised action. It was concluded that he did not have

a valid grievance, but it meant that there was a security stand down in the village which was to the

detriment of the community.

EPII recognises that such incidents can never be completely avoided and believes that overall BP has

fostered good community relations to date, in light of high expectations and dissatisfaction with the

government. Continuing to monitor and analyse grievances closely, especially from known agitators as

discussed earlier, is important to maintain the harmonious relations and manage any dissent. This is

especially relevant as BP informed EPII that recently a community threatened to undertake a sit-down

protest on an LNG jetty unless BP resolves the revenue sharing issue and pays the 54 billion rupiahs. BP

states that if this happens, the military will have to be called in as a last resort to prevent Project operations

being disrupted.

4.3.2.6 Coordination with Local Government

Whilst in some areas BP has achieved great success in coordinating its programmes with local

government (Pemda) in 2014, for example in health, Pemda repeated comments made to EPII in previous

audits that there could be more regular communication to better align some programmes. BP responded

that its implementing partners regularly communicate with Pemda, although it was acknowledged that the

new Amdal process has delayed meetings with local government in 2014 and that this will be stepped up in

2015. A significant coordination and collaboration also happened in agriculture program. Tangguh

Livelihood team fully supported the local government program on its rice plantation project in Bintuni

during end of 2014. Tangguh provided technical assistance and expertese while the project was lead by

the local government.

The last meeting between BP and Pemda was held in January 2015 to synchronise the timing of planning

and budget expenditure. The next one is planned in August to support the development of Bintuni RPJMD

(5 year plan 2016-2020). Also, there were smaller meetings between TSDP program staff with the relevant

11

He stated that his information source was the local newspaper.

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departments in the regency governments based on programs needs. There is also Bintuni 12th

anniversary event on 9th June, 2015 where BP management will meet with Bupati Bintuni as well as

exhibition booth at the government’s event in Bintuni town.

EPII suggests that consideration is given to holding quarterly meetings to share results and scheduling.

EPII feels that a key objective should be for the government to be seen to have an equal presence in the

villages as BP and its partners12

, to counter the culture of villages being dependent on BP for social

services.

4.3.3 Newly Identified Issues and Future Challenges

4.3.3.1 Potential Resettlement of the Onar Villages

The location of the Onar villages has tentatively been identified by the government as an industrial

development area where a downstream petrochemical production is to be located. This is likely to result in

the resettlement of the villages.

Many of the villagers in Onar Baru have not yet received their land ownership certificates from the

government following their resettlement from Onar Lama. The certificates cannot be issued by BP until the

land status is converted by the government from ‘Productive Forest’ to ‘Land for ‘Specific Use’. Without

these land certificates, residents do not have legal entitlements to compensation for loss of land as a result

of future resettlement to facilitate this planned industrial development.

The new petrochemical plans pose potential impoverishment risks to the Onar communities and

reputational risk to the Project and BP resulting from resettlement of the Onar communities for a second

time. BP recognises this, and although it is not BP’s formal responsibility to convert the status of the land,

BP continues to make considerable efforts to resolve the land registration issue, and to obtain more

information about potential displacement.

4.3.3.2 Economic Development of the Area

The aforementioned petrochemical economic development plans are indicative of the area opening up to

industrial and commercial development. As normal, the development poses risks and opportunities and will

require coordinated management. In 2014 Genting oil completed construction of a highway linking Tanah

Merah Baru and Tofoi villages just a few metres from the Mangossa pathway and the Project’s perimeter

fence (see Figure 4.6). Apparently there are plans to extend the highway to Saenga.

12

Some villagers stated to EPII that they only saw BP in the villages, not government officers.

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Figure 4.6: New Genting Oil Highway adjacent to the Project site perimeter


Risks may occur from the influx of other oil and gas companies. There are likely to be economic migrants

with related influx problems, some of which are already being seen. For instance, malaria was reintroduced

into Tanah Merah Baru from Genting Oil construction labour forces. Other cumulative impacts include

environmental degradation, dilution of traditional culture, and disruption of community relations as a result

of the differing approaches of companies operating in the area.

4.3.3.3 Oil Price Fluctuations and Budget Reductions in 2015

Due to the recent reduction in oil prices there are expected to be budgetary cuts to BP’s social

programmes over the next monitoring period. This may pose constraints on meeting programme objectives

and achieving outcomes and process efficiency improvements could be explored.

4.3.3.4 The Change in Government in 2015

The 2014 presidential elections mean new political bodies and a new house of representatives at the

provincial and regency levels. BP has had to divert resources to efforts to form new relationships with

government, and this will continue following the local elections in 2015. In addition, some programs,

especially the governance program, will slow down in 2015 due to the election activities by the local

government, until the new Bupati is in office.

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Figure 4.7: EPII, Lenders’ Consultant and BP team with Onar Baru villagers


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Tangguh LNG continues to demonstrate a high level of project compliance with environmental and social

requirements. No environmental or social non-compliances have been identified.

EPII finds that the Project continues to operate a well-defined Environmental Management System and

that key issues are identified and dealt with adequately. Going forward, a key action will be disseminating

the new requirements of the AMDAL to all employees, particularly to contractors.

The Social Programme continues to be well resourced and implemented. It is resulting in sustainable

development outcomes and community benefit sharing. Key achievements for 2014 include the health

programme embedding services within the local government health department; and, BP providing 4MW of

electricity for the rural electrification of local villages. BP is aware of, and is doing a good job of tackling

ongoing challenges related to livelihood dependency, revenue sharing and industrial development within

the area.

In conclusion, EPII finds the Project to be compliant with Project requirements. No critical or significant

environmental and social risks have been identified in relation to compliance with Project requirements.

EPII would like to acknowledge the openness and assistance of BP’s team leaders and the Lenders’

Consultants in providing information and explanation and facilitating the monitoring visit.

5 Concluding Comments

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Appendices

Appendix A. ADB, JBIC Policies & Equator Principles Relevant to the Original AMDAL ______________________ 35 Appendix B. Key Documents Reviewed ___________________________________________________________ 36 Appendix C. Stakeholders Consulted _____________________________________________________________ 39

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Policy

ADB Tranche Lender JBIC

Equator Principles & associated policies

Environment, health and safety

Environment Policy of the Asian Development Bank (ADB document no. R154-02, November 2002)

JBIC Guidelines for Confirmation of Environmental and Social Considerations of April 2002 (but excluding any portion thereof relating solely to (i) the disclosure of information regarding confirmation of environmental and social considerations to concerned organizations, stakeholders and other third parties, and (ii) the submission to JBIC by concerned organizations and stakeholders of objections relating to the non-compliance of the Tangguh Project with JBIC’S stated policies) (the JBIC Guidelines)

The World Bank Pollution Prevention and Abatement Handbook 1998 incorporating Industry Sector Guidelines for Oil & Gas Development (Onshore)

International Finance Corporation (IFC) Operational Policy for Environmental Assessment (OP 4.01), October 1998

IFC Environmental, Health and Safety Guidelines for Oil and Gas Development (Offshore)

IFC Operational Policy for Natural Habitats (OP 4.04), November 1998

IFC Operational Policy Note for Management of Cultural Property (OPN 11.03) of September 1986

The Equator Principles, June 2003.

IFC Operational Policy 4.01 Environmental Assessment (October 1998)

IFC Operational Policy 4.04 Natural Habitats (November 1998)

IFC Operational Policy 4.09 Pest Management (November 1998)

IFC Operational Policy 4.36 Forestry (November 1998)

IFC Operational Policy 7.50 International Waterways (November 1998)

IFC Operational Policy Note 11.03 Management of Cultural Property (September 1986)

The World Bank Pollution Prevention and Abatement Handbook 1998 incorporating Industry Sector Guidelines for Oil & Gas Development (Onshore)

IFC Environmental, Health and Safety Guidelines for Oil and Gas Development (Offshore)

Involuntary resettlement

Involuntary Resettlement (ADB document no. R179-95, August 1995)

The JBIC Guidelines

IFC Operational Policy for Environmental Assessment (OP 4.01), October 1998

IFC Operational Policy for Involuntary Resettlement (OP 4.30) of June 1990




IFC Operational Policy for Involuntary Resettlement (OP 4.30) of June 1990


Indigenous peoples

Policy on Indigenous Peoples (ADB document no. R55-98, April 1998)

The JBIC Guidelines


IFC Operational Directive for Indigenous Peoples (OD 4.20), September 1991




IFC Operational Directive for Indigenous Peoples (OD 4.20), September 1991


Others Public Communications Policy (March 2005)

Child and Forced Labour Policy Statement (March 1998)

Appendix A. ADB, JBIC Policies & Equator Principles Relevant to the Original AMDAL

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The first EPII monitoring report (January 2012) listed all of the key contextual documents reviewed

including the PSC Parties Agreements, the AMDAL documentation, the Land Acquisition and Resettlement

Action Plan (LARAP), the Indigenous People’s Development Framework (IPDF), the Integrated Social

Program (ISP) I and the Community Investment Programme (CIP), amongst others. Those documents

have been returned to as key compliance reference points for this audit. Table B.1 lists the new documents

reviewed.

Table B.1: Documents reviewed

Type of Document Document Title Author

PPT. Update Presentations to EPII in April 2015

Joint Lenders EP and Consultant Visit, March 2015 – Tangguh Environmental Programs

BP

HSE overview (dated 31 March 2015) BP

Environmental and social sensitivity map of Bintuni – Berau Bay, west Papua (March 2015)

BP

Tangguh Sustainable Program BP

Tangguh Update (30 March 2015) BP

Community Relation (CAT) Program and Yayasan Dimaga BP

TangguhSocial Program Update BP

Amdal 2002 vs Amdal 2014 (September 2014) BP

Education Program Update - Growth and develop together in West Papua, 3 April 2015

BP

Governance Program Update -Growth and develop together in West Papua

BP

Papuan Capability BP

Papuan Development, External Panel – 31 March 2015 BP

Lenders External Panel Visit - Health Overview, 1st 2015, March31st,2015

BP

Integrated Community-Based Security BP

AMDAL / Environmental Monitoring documentation

AMDAL Report April – Dec 2014 BP

CEMs Emissions Report (Jan - March 2014) BP

CEMs Emissions Report (April – June 2014) BP

CEMs Emissions Report (July – September 2014) BP

Flaring Implementation Report at Tangguh LNG (Jan – June 2014) BP

Hazardous and toxic waste management implementation report (Jan – March 2014)

BP

Hazardous and toxic waste management implementation report (July - Sept 2014)

BP

011-ISP-WP-7003 (J714019) Fugitive Emissions ORF Overall BP

Surface Water Monitoring Points (old and new AMDAL) BP

Environmental Management Plans (2014) (set of 13) BP

Environmental Management Plans (2015) (set of 15) BP

Environmental Aspects Impact dentification (EAI 2014) BP

Appendix B. Key Documents Reviewed

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Environmental Aspects Impact dentification (EAI 2015) BP

Hazardous Waste Permit (Indonesian) BP

Wastewater Discharge Permit BP

PRC-EN-2325 Environmental Sampling and Anaysis Protocol for External lab

BP

900-PRC-EN-2337 Environmental Audit Procedure BP

900-PRC-EN – 2320 Environmental Monitoring BP

900-PRC-EN – 2331 Non hazardous solid waste procedure BP

900-PRC-EN – 2324 Wastewater Management procedure BP

900-PRC-EN – 2326 – Environmental Communication BP

900-PRC-EN - 2329 – Marine Mammals and sea reptiles protection BP

900-PRC-EN – 2330 – Flora and Fauna Protection Procedure BP

900-PRC-EN – 2333 – Environmental aspect and impact identification

BP

920-MAN-EN – 2301 – EMS manual BP

900-PRC-HE – 1001 – HSE Training procedure BP

900-PRC-HE – 2750 – HSE Document Record Control process BP

920-PRC-HS-2245 HSE Regulatory Compliance Management BP

920 – WIS – HS-2432-03 Temporary Secondary Containment. BP

PROPER Certificate 2013 BP

Wastewater discharge activity to sea (Jan – March 2014) BP

Wastewater discharge activity to sea (Apr – June 2014) BP

Wastewater discharge activity to sea (July – Sept 2014) BP

Operators EHS Report (Oct 2013 – March 2014) BP

ANDAL chapter 2 – Environmental Baseline (Feb 2015) BP

Project Executiion Plant – Transfer wooden logs from log pond to TMB village (June 2014)

BP

Weekly Monitoring (2014) BP

CEMS reporting data – January to December 2013 BP

Internal Production daily report (2014) BP

Notice of exceedence of Ammonia (8 July 2014) BP

Notice of exceedence of Ammonia (7 Sept 2014) BP

Notice of potential exceedence of Ammonia (15 November 2014) BP

GHG Workbook BP

Biodiesel presentation (March 2014) BP

900-PRC-CM-1001 Oil Spill Continency Plan BP

Personal Benzene Monitoring 2013 BP

Energy Efficiency Review BP

Operator’s Environmental, Health and Safety Report BP

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Tangguh LNG, April 2014 – December 2014 (issued to Lenders)

Tangguh Operation Monthly Report Dec 2014 BP

Tangguh Operation Monthly Report Jan 2015 BP

Tangguh Operation Monthly Report Feb 2015 BP

Tangguh LNG Produced Water Management Update. Notice of Exceedance Dated 08 July 2014

BP

Tangguh LNG Produced Water Management Update. Notice of Exceedance Dated 07 September 2014

BP

External surface water monitoring results (June 2014) BP

Tangguh LNG Produced Water Management Update. Dated 15 November 2014

BP

Environmental management plan (RKL) and Environmental Monitoring Plan (RPL) Integrated activities of the Tangguh LNG Expansion Project, Taluk Bintinu and Fakfak Regencies, Papua Barat Province (August 2014) including Appendix 1: Relevant Environmental Standards.

BP

Greenhouse Gas Workbook BP

Biosludge Report update (Indonesian). BP

Tangguh Waste Biodiesel 25 March 2014 BP

Grievance log BP.

BP Partner reports /evaluations in Bahassa

Introduction of Oil and Gas Industry socialization and DBH To the Legislative and Local Government Staff Teluk Bintuni

The Board of Research , Study and Development of Legal Aid, LP3BH Manokwari

UPAYA MELESTARIKAN BAHASA DAN KESENIAN LOKAL MASYARAKAT ADAT SUMURI, KEMBERAN DAN NDAMBAN

(EFFORTS TO PRESERVE LANGUAGE AND ARTS, LOCAL COMMUNITY, ADAT wells , Kember AND Ndamba

Tim Peneliti, STUDY CENTER Melanesian

UNIVERSITY CENDERAWASIH, JAYAPURA

2014

CAPs evaluation study Institute for Research and Community Services, Cendrawasih Uni.

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Table C.1 and Table C.2 below list the stakeholders interviewed by EPII, and some of this consultation is

depicted in Figure C.1 to Figure C.5 overleaf.

Table C.1: External Stakeholders Consulted

Stakeholder Location Date

King (traditional leader) Kepala Kampung (village head) of Arguni Arguni & Taver Villages (New Amdal villages)

Saturday 4th April

Head of Fisheries Cooperative

Deputy Kepala Kampung (village head)

Adat leaders

Male and Female SD (primary) school teachers

Onar Baru (new) Village

Monday 6th April

Kepala Kampung (village head)

Head of Onar Lama UBSP Savings and Loan Cooperative

YSA Health Programme Cadres

Onar Lama (old) village

Meeting with Bintuni Regency Government representatives including from the Bapeda (planning), Trade and Cooperatives, Fisheries, Infrastructure, Health and Education departments

Bintuni Town Tuesday 7th April

Meeting with Weriagar District Head and heads of the Kepala Kampungs of the six villages in the dirstrict

Head of Puskesmas

Weriagar Village Wednesday 8th April

Kepala Kampung (village head)

Head of Mayri (Agriculture) Coperative

Sampoerna FoundationsSchool Head and teachers

Head of Puskesmas

Tanah Merah Baru village

Thursday 9th April

Babo Stocking Point crab fattening Cooperative Heads (x 2)

Babo High School Head, teachers and students

Head of Puskesmas and Posyandu

Babo Iratutu III Village

Friday 10th April

Appendix C. Stakeholders Consulted

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Figure C.1: Meeting with the King of Arguni Figure C.2: Woman’s focus group discussion in Onar

Lama

source: Mott MacDonald source: Mott MacDonald

figure C.3: Meeting with the Kepala Kampung of Tanah

Merah Baru

Figure C.4: Meeting with the Sampoerna Foundation

model-) School in Tanah Mera Baru


Figure C.5: Meeting with the Weriagar District and the village heads
