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Air pollution

1. The air quality in this part of South Sumatra is generally good at present. Recorded levels of pollutants such as sulphur dioxide, hydrogen sulphide and nitrogen oxides were well below 1.0 microgrammes per cubic metre of air (1m/m3), even though the 1994 data was collected only two weeks after forest fires had smothered the area in thick smoke.

2. Waste gases will be discharged into the air through 50-100m chimneys from the lime kiln and recovery and power boilers. Although these are fitted with electrostatic precipitators to reduce particulate pollution, considerable amounts of nitrogen oxides, sulphur dioxide and hydrogen sulphide will be produced by PT TEL. At best the waste gas treatment efficiency is only 65-99%. The EIA states that that 15kg of sulphur compounds will be released for every tonne of throughput (pII.26). Presuming this refers to tonnes of pulp produced, this is equivalent to 6,750 tonnes of sulphur for an annual production of 450,000 tonnes of pulp. In other words, over 18 tonnes of sulphurous gases released daily into the atmosphere. Similar calculations show an expected annual output of over 3,000 tonnes of nitrogen oxides which are harmful to human health in concentrations above 1ppm (1.8mg/m3).

3. These emissions are close to or exceed the legal limits, even with pollution control measures operating optimally. The most serious air pollution problems are expected to be within 3 km of the plant due to emissions of NOx and sulphurous gases. This area includes about six villages, each with 2-3,000 inhabitants. Much depends on the weather, but the health, homes and crops of people living as far as 10km from the PT TEL factory could be severely affected by acid rain and noxious gases (see pollution distribution maps in the EIA). It is odd that the EIA (p V.34) states that no hydrogen sulphide will be detectable under normal conditions. This gas, which smells of rotten eggs and is dangerous to human health, is detectable at concentrations of only 5m/m3. Emissions from the plant will be 2,000 fold above this (10 mg/m3). People in the villages nearest to the plant will probably be living with this stench for months at a time.

4. Environmental groups – especially those in ‘the North’ – pay much attention to the risks from dioxins associated with industries which use chlorine compounds (see above). In areas affected by Indonesia’s paper pulp plants other aspects of air pollution deserve more immediate attention – such as dust and sulphur emissions. Respiratory problems are already more common in this area than some others. Air pollution from the similar Indorayon pulp plant in North Sumatra has been a serious problem over the past decade.

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Water pollution

1. The water quality of the River Lematang is good at present, although the river is usually muddy in the rainy season. Both the 1994 and 1996 data sets were collected in the rainy season (October-April) so there is no baseline data about the state of the river in the dry season before the pulp mill operations began. The 1996 water quality data may have been influenced by land clearance on the PT TEL site. The use of heavy equipment to clear vegetation and level the ground affected local drainage patterns and increased soil erosion.

2. The EIA states that the PT TEL plant will have a potentially serious negative effect on the quality of water in the R. Lematang, especially in the dry season and if the waste treatment plant is not operating at maximum efficiency. Although the EIA considers that the waste treatment system will normally prevent serious water pollution problems, it predicts a general decline in aquatic plants and animals and in species which feed on them.

3. The 70,000 m3 of effluent which will be discharged daily into the River Lematang will contain substantial amounts of suspended solids and chemicals including chloroform, phenols, sulphides and organo-chlorides (TSS = 64mg/l; AOX = 19.4mg/l). This waste contains 5.5 tonnes of solids, amounting to 2,000 tonnes per year. It will make the river water more turbid and reduce the amount of oxygen for aquatic life (BOD = 34 mg/l ; COD = 350mg/l). Some of the waste will eventually decompose; the rest will remain dissolved or sink to form a sediment.

4. The tens of thousands of people living downstream of PT TEL’s waste outlet are at risk from water pollution since they use the river water for drinking, cooking, washing, transport, fishing and agriculture. The study shows that 90% of the local population use the river as their source of drinking water during the dry season as the wells run dry. Even in the wet season, 60% of the community depends on the river for drinking water. It also provides a livelihood for hundreds of fisher families. Its only comments are that the ‘negative perceptions’ of villagers living near the intake and outlet pipes for the plant could be a problem.

5. The EIA shows that huge variations in the levels of acidity of PT TEL’s waste water will be tolerated. The ‘acceptable’ range of pH 6-9 is a thousand fold difference. This is of concern since even slight changes in the pH levels of river water can be very damaging to aquatic insect larvae and hence affect fish populations.

6. The ‘permitted’ temperature change of 2 degrees Celsius caused by the waste waster may also contribute to deoxygenation of the river and fish kills. As Indonesia lies on the Equator, the air temperature only varies a few degrees between day and night and between seasons; water temperatures are generally very stable.

7. The PT TEL plant could be a significant source of highly toxic, persistent organo-chlorines, including dioxins and furans. These chemicals are not present in the R. Lematang now. Widely differing figures for the outputs of organo-chlorines are presented at various points in the EIA report: from 19.4mg/l (pII.27) to 0.08 m/l (pV43). The EIA states that the amounts released will be within Indonesian legal limits (except if the waste treatment unit does not operate at 100% efficiency), but elsewhere outlines the potential damage to fish populations (pV.48) and human health (pV.60).

8. There is no mention of whether or how the chloroform, phenolics and sulphur compounds mentioned as effluent components are to be treated or what concentrations are expected (EIA II.28). These substances make the water taste bad if present at concentrations of only microgrammes per litre and phenols and their derivatives are dangerous to human health.

9. The EIA and the Management Plan do not refer to any academic studies of the impacts of pulp industry effluents on fresh-water systems. There have been serious water pollution incidents at other paper pulp plants in Indonesia e.g. Indah Kiat, Indorayon and Riau Andalan plants.

10. When the EIA report was presented, the company assured the Commission that pollution from the plant would be minimal due to the waste treatment unit. However PT TEL could not explain why, in that case, its water intake would be still be upstream of the waste outlet pipe for the site.

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Community impacts

1. The introduction to the EIA report clearly shows that the purpose of this and other paper pulp plants is to increase Indonesia’s export revenues, rather than to benefit the local community.

2. The EIA lists land use change as one of the most important impacts of the PT TEL development (see introduction), but makes little reference to the substantial numbers of local people who will be affected by the PT TEL development. It does not even include population figures for the six villages closest to the site location: Banuayu, Muara Niru, Gerinam, Tebat Agung, Kasih Dewa and Dalam. The EIA acknowledges that 900 families (4,500 people) from these villages will lose some or all of their rubber plantations. However, it does not address the issue that thirty villages with a total population around 45,000 lie alongside the river downstream of the waste outlet.

3. Almost all the land taken for the PT TEL site was rubber plantations bought or inherited by local people. It was not ‘state land’ or communally held customary land as is common in the area. The landowners had official letters signed by the village head as proof of ownership. The EIA contains no details on patterns of land ownership.

4. The local people live by farming, rubber tapping, fishing and trading. The EIA presents no data on occupations or incomes in the local community comparable with the pages of environmental data. The one brief mention of incomes from rubber tapping shows that people were making Rp40,000-80,000 per week. This is lower than the farmers’ own estimates but, even so, represents a reasonable income given that the daily minimum wage for factory workers at that time was around Rp3,000.

5. Once their farmland and rubber plantations have been taken for the PT TEL site (and if fishing is affected by water pollution and water deficits), they have no other source of income. The only suggestions in the Management Plan to prevent these people from becoming destitute - that they are involved in managing the site’s buffer zone and encouraged to sell agricultural produce in the PT TEL complex - are inappropriate and inadequate. Indeed, the buffer zone was created by displacing local farmers.

6. Although at least 450 families will lose all their plantations and another 450 will have less land, EIA does not include this as a negative impact of PT TEL. This makes a nonsense of company and government reassurances that the paper pulp will bring prosperity to the area.

7. An attitude survey carried out for the EIA showed that two-thirds of the villagers nearest the development thought the PT TEL development would bring little or no benefits to their household or community. The main opportunities were seen in terms of increased employment potential, but these expectations are unlikely to be realised..

8. The pulp plant will need a workforce of 730 people once it is operational and 1,929 during the construction phase. PT TEL says it will give priority to ‘suitable local employees’, but the locals do not have the educational background and skills required at the pulp mill and are unlikely to benefit directly from PT TEL’s long-term employment prospects. All the project management for the construction phase are foreigners (33). Workers from other areas will also be brought in for construction work. Once the construction phase is finished, unskilled labourers will be competing with the local community for jobs.

9. The EIA promotes the development paradigm which dominated during Suharto’s ‘New Order’. The introduction of urbanised industrial society into rural communities considered to have a positive, modernising influence (see pV.53), even when this entails the destruction of existing, sustainable livelihoods and their replacement by a service economy (including prostitution) – as has occurred in the vicinity of PT TEL.

10. The EIA and Management Plan state that a ‘town site’ covering 125 ha is to be constructed with its own power plant, electricity and water supply, schools, places of worship and sports facilities. The environmental and social impacts of this new settlement which will contain around 300 housing units are not discussed. Domestic rubbish will be dumped near the landfill site for the factory’s solid waste until the local council removes it. There is no mention of any sewage treatment plant. Piped water for the townsite and factory will be drawn from the R. Lematang and treated at two villages outside the PT TEL site.

11. The plant requires the construction of 7km of surfaced road and 5km of railway to supply raw materials and transport the product. The EIA briefly mentions an access road from the plantation to the plant (some 20-30km) plus a flyover to cross the main road and railway (pV.31). These will create more noise and dust for local inhabitants, during the construction phase and once the plant is operational. The plant will operate 24 hours a day, with 25 trucks per hour delivering logs.

12. The Management Plan only refers to the problems of land-use change from the company’s perspective: compensation disputes and local landowners who refuse to give up their property. It does however, acknowledge that the process of land procurement has led to conflicts and antagonism towards the company and local government.

13. Most of the measures for dealing with social problems are ‘discussion and direction’. The company makes it clear that it is relying on the authorities to settle any disputes. There appear to be no other mechanisms to deal seriously with complaints from the community. The prospects of justice for the community are slim. Even in the post-Suharto era, Indonesian land law allows the state to control land ‘in the national interest’ and the military play a prominent role in all aspects of everyday life.

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Water demands

1. The amount of water in the River Lematang varies considerably. Flow rates and water levels show marked seasonal variation. In the dry season the river may only be 1 metre deep, but in rainy season it may reach 10 metres or more.

2. The PT TEL plant, like most paper pulp plants, has a substantial water demand. The plant will take in 86,850m3/day from the River Lematang, but only return 70,130m3/day. The rest will be lost to the atmosphere as steam or contained in sludge to be dumped. The total demand from the plant and town site is estimated at 1m3/s.

3. The EIA states that water consumption by the factory and ‘town site’ will reduce the quantity and quality of water available to villages like Banuayu and Muara Niru (pop. 3,000 each). The water deficit should only be noticeable in the dry season (6% flow reduction), but will be more serious in drought years when the river almost runs dry. It will also compound the effects of water pollution. These communities rely on river water for all their domestic needs, including washing and toilets.

4. The Management Plan states that only these two villages will be provided with clean water. Whether this will be free and supply sufficient quantities to meet all domestic needs is not mentioned.

5. The EIA’s prediction that dumping 70,000 m3 of waste into the river daily will not affect flow rates is optimistic. The effluent will add 5.5 tonnes of insoluble solids daily, much of which will sink to the riverbed. Some scouring will occur, especially in the wet season, but the long-term effects of adding 2,000 tonnes of sediment annually to the river should not be ignored.

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Forest impacts

1. The EIA and Management Plan do not refer to the impact of the PT TEL development on local forests. The EIA describes PT TEL as a US$1 billion operation to produce ‘hardwood bleached kraft pulp’. The site covers 1,250ha, only 110 ha of which is for the factory building. Some 500ha are intended to be a buffer zone. This land is a mixture of small-scale rubber plantations, productive fields, secondary forest and scrubland.

2. The feeder plantations for PT TEL are controlled by PT Musi Hutan Persada (MHP), another Barito Pacific subsidiary. The total concession for this ‘industrial tree plantation’ (HTI) covers 300,000 ha in several locations at Benakat and Subanjeriji, 20-30 km from the pulp plant site. Between 1991 and 1997, 155,000 hectares had been planted – mainly with Acacia mangium. Some mature rainforest was destroyed to establish these plantations. PT MHP illegally cleared 1,000 ha of the Benakat community forest. The remaining 2,000ha was only saved after protests from the community and NGOs to the authorities.

3. Although the EIA states that the PT TEL plant will use plantation timber as feedstock, this pulp factory will still rely on natural forests for some of its raw materials. Initial levels of pulp production at the PT TEL plant (450,000 tonnes per year) require nearly 2 million m3 of wood per year: 4.3m3 of timber for every tonne of pulp produced. The EIA estimates plantation production at 180m3/ha, so each year 10,750ha of plantation will have to be cleared to feed the pulp mill. On this basis, only 96,750ha of plantation could supply the plant on a continuous 9 year cycle (8 years growth + 1 year replanting).

4. However, until the plantations are sufficiently mature, PT MHP will have to rely on timber felled from natural forests. Also, pulp production is intended to increase to 1 million tonnes early in the next decade. Furthermore, disease, drought and forest fires can seriously affect plantation productivity, raising questions about company assurances that plantations can meet all the pulp plant’s timber demands.

5. Pulp plantations differ from natural forests in many ways. As they contain a very limited number of species, they are susceptible to disease. Plantation owners commonly burn land to clear it after removing any valuable timber. This contributes to forest fires and the annual smoke ‘haze’ which affect Sumatra before the rainy season. The forest fires were bad in 1991 and 1994 when visibility was only 5 metres because of the smoke.

6. Indonesia’s worst forest fires for decades occurred in late 1997. The Minister of Forestry issued a list of 176 logging, plantation and transmigration sites implicated in starting fires according to satellite data. One of these was PT Musi Hutan Persada, the feeder plantation for the PT TEL development. The company was found guilty of illegally burning to clear land by a provincial court in a case brought against several companies by local NGOs in 1998.

7. The construction of the PT TEL pulp factory will cause the loss of an additional 725 hectares of natural and semi-natural habitat. The EIA acknowledges that this will result in losses of biodiversity and the amount of wildlife. The presence of the factory, town site and increased road and rail traffic will cause further disturbance. Birds and mammals are expected to move to other areas. However, the expansion of palm oil plantations, settlements and industrial developments like PT TEL are making high quality lowland riparian habitats increasingly scarce. This is expected to increase pressure on the following protected species: jungle fowl (Gallus gallus); kingfisher (Halcyon smyrensis); sunbird (Nectarinia calcosetha); fantail (Rhipidura albicolis); mousedeer (Tragulus javanicus); marbled cat (Felis marmorata); muntjak deer (Muntiacus muntjak); and sunbear (Helarctos malayanus) .

8. The ‘green belt’ which the company promotes as contribution to conservation and a haven for wildlife is not bare land, but secondary forest interspersed with rubber plantations and fruit trees. Local landowners and villagers are being displaced to create it.

SUMMARY OF ENVIRONMENTAL AND SOCIAL IMPACTS RECOGNISED IN THE OFFICIAL EIA AND MANAGEMENT PLAN

NOTE
The EIA Report and Management plan consider the impact of the pulp plant in 3 stages: pre-construction, construction and operational. Each category is further divided into effects on the factory site and on the surrounding area. After listing the possible impacts in each category, the EIA then evaluates each impact as positive or negative qualified by the descriptor ‘not important’, ‘fairly important’ or ‘important’
(shown in bold/brackets e.g. –ve NOT imp).

Pre-construction ( planned July 94 – July 96)

• Land use changes: problems due to disagreements over compensation; not all the land needed has been procured; at least 450 families will lose all their land and source of livelihood; land prices tripled to Rp6-7 million/ha ( -ve IMP).

• Potential social conflict: negative attitude of community towards PT TEL due to the above is unlikely to spread to the wider area (-ve NOT imp).

  
  

Construction phase (planned Oct 96 – Feb 98)

• Air quality: construction vehicles will generate much dust, especially in the dry season causing potential health problems for villagers up to 1km away (Desa Dalam) (-ve IMP). Threat to workers unless wear masks (NOT imp).

• Climate: microclimate in vicinity of factory will be hotter and drier due to change in land use ( -ve fairly IMP).

• Noise levels: heavy machinery will create a noise problem for site workers ( -ve IMP) and up to 1-2km away .

• Erosion and sedimentation: erosion rates could reach 150 tonnes/ha/yr causing increased turbidity and sedimentation in the River Lematang (-ve IMP), but will only last a year.

• Vegetation: loss of 725 ha of natural vegetation or rubber plantations (NOT imp).

• Land animals: drop in numbers and species diversity as animals (including some protected species) move from the site location to other areas (-ve IMP).

• Population migration/density: construction will attract migrant labour which will increase demands on facilities in the immediate vicinity of the site (-ve fairly IMP), but long-term effects on the wider area NOT imp. (pages missing in MP)

• Employment prospects: much of the construction work is unskilled and can use local labour (+ve IMP). Increased potential for local services e.g. food stalls, transport (+ve IMP). (ditto)

• Local economy: stimulated by increase in labour force and transportation of materials (+ve IMP). (ditto)

• Social conflict: potentially increased due to competition between locals and incomers for work, especially if locals are not given priority ( -ve IMP).

• Hydrology: construction of the new railway line will change local drainage patterns (NOT imp).

• Traffic: increased traffic flow during daytime on main road between Muara Enim and Prabumulih (not IMP).

• Local facilities: more markets, places of worship and clinics (+ve fairly IMP)

• Health: main problem is dust, especially in the dry season in an area where respiratory infections are a major problem ( -ve IMP).

NOTES:
1. Blockage of natural drainage by earthmoving during site clearance resulted in the flooding of local rubber plantations, loss of income and damage to homes in late 1997.
2. The EIA predictions of social conflict over employment were realised in 1998.

Operational phase (planned Jan/Feb 2000)

• Air quality: dust levels will be a problem for workers on parts of the site ( -ve fairly IMP), but within legal limits outside - except in the dry season ( -ve fairly IMP). Smoke output from production will be reduced by electrostatic precipitators. Hydrogen sulphide, sulphur dioxide, nitrogen oxides and chlorine compounds will be released into the air. Reduction in air quality mainly at night. Villages affected to North June-Sept; to South Dec-March ( -ve IMP).

• Noise: a problem on site, but within legal limits (-ve fairly IMP). 25 trucks/hour will increase noise along roads.

• Water quality: Liquid waste will be separated into water and sludge in settling basins. Around 5.5. tonnes of waste will be discharged into the river per day. Amount of suspended solids will only increase by 10% (NOT imp). If the waste treatment unit malfunctions, aquatic life of the R. Lematang will be seriously affected by pollution because of the biological and chemical oxygen demand of the waste ( -ve IMP). The risk of pollution by highly toxic, bioaccumulative organo-chlorines is -ve IMP and may seriously affect fish populations and animals higher in the food chain (pV.48; pV.61).

• Ground water: risk of seepage from landfill site NOT imp, but long-term effects (-ve fairly IMP).

• Erosion and sedimentation: the plant will only increase sedimentation at the outlet pipe at 0.001-0.1 tonnes/day (NOT imp).

• Water demand: factory and town site will take 1m3/s from R. Lematang; only 80% will be returned. Impact on river flow NOT imp normally, but in severe dry seasons -ve IMP. Concern expressed about ‘negative perceptions of villagers’ living near the inlet and outlet pipes.

• Solid waste/landfill: solid wastes from wood processing and chemical waste will be disposed in specifically designed sites. Hazardous wastes will be disposed of separately in specialist units in line with Indonesian safety regulations. Seepage from sludge if disposal sites not properly constructed could contaminate ground water with metals and heavy metals (pV.28 -ve fairly IMP; pV.46 -ve IMP).

• Land animals: A 525ha ‘green belt’ reserved for conservation will attract back some wildlife driven away from the 1250ha site during construction phase, but long-term effects of water pollution on food webs will cause a drop in numbers ( -ve IMP).

• Employment: most of the unskilled labourers from the construction phase will be dismissed and some skilled labour taken on. Locals will benefit from informal sector. (+ve IMP)

• Population growth/density/migration: no significant effects (NOT imp).

• Local economy: likely to increase due to transport of raw materials, products and workers; trade; and services (+ve IMP) .

• Social conflict: possible due to cultural differences between newcomers and locals; competition for employment; pollution of air and water; compensation demands (pV.31 NOT imp; pV.52 -ve IMP).

• Community health: could improve due to provision of clean water supplies and health facilities (+ve IMP) or get worse due to air and water pollution and poor disposal of rubbish. Levels of nitrogen oxides will exceed permitted limits 3-10km from site; other gases will not, but may have cumulative effects (-ve IMP). Also see organo-chlorines above.

• Local facilities: site will offer a clinic, shops, school, sports facilities and places of worship which locals can also use (+ve IMP).

• Transport: transport of workers, raw materials and products will not have any serious impacts on existing system. Pulp will go out by rail and an access road with flyover will be built from the plantation to the plant (NOT imp).

NOTES
1. Conflicting figures for amounts of sedimentation are presented in the EIA. On pII.27 Total Suspended Solids (TSS) output is estimated at 5.5 tonnes/day or 64mg/l. On pV.27, TSS levels in the river are only expected to rise from 43.7-173 mg/ml to 44.1 – 175.4 mg/ml.
2. Despite acknowledging the serious negative impact which the pulp plant could have on the aquatic life of the R. Lematang, the Management Plan simply states that “if the quality control measures outlined are fully and are functioning properly implemented, the aquatic fauna will be alright.” There are no procedures for routine monitoring or emergencies.
3. The EIA and Management Plan contain estimates of the physical, chemical and biological parameters of the liquid waste (BOD, COD, temperature and pH) plus gaseous emissions (dust/TSP,TRS/H2S, NO2, SO2) which it claims will be within Indonesian permitted levels (see also EIA pII.24, II.26, II.27;V.24).
4. The names of the gases hydrogen sulphide, nitrogen dioxide and sulphur dioxide are mixed up on ppV.57-59 and the diagram showing the maximum concentrations of sulphur dioxide at varying distance from the PT TEL plant has not units (presumed to be m/m3).
5. Different, much lower legally permitted Indonesian limits for hydrogen sulphide, nitrogen dioxide and sulphur dioxide are cited in the Management Plan (pIII.17).

Off-site impacts during construction and operations (to be tackled with local government)

• Employment prospects: local authorities should be involved in recruiting local employees with suitable skills and qualifications.

• Potential social conflict: seen primarily as arising from those who do and do not gain employment through PT TEL; to be solved by discussion, prioritising local employment and setting up local businesses

• Community perceptions: PT TEL to keep within water quality and water usage limits outlined and explain these to the community; consumption of local fish on PT TEL site.