Initial Environmental Examination - Asian Development Bank

 
Initial Environmental Examination - Asian Development Bank
Advanced Knowledge and Skills for Sustainable Growth Project (RRP INO 50395)

 Initial Environmental Examination

October 2018

INDONESIA: Advanced Knowledge and Skills for
Sustainable Growth Project

Prepared by the Ministry of Research, Technology and Higher Education for the Asian
Development Bank. This is an updated version of the draft originally posted in August 2018
available on http://www.adb.org/projects/50395-006/documents
Initial Environmental Examination - Asian Development Bank
Initial Environmental Examination - Asian Development Bank
CURRENCY EQUIVALENTS
                              (as of 23 June 2018)

                   Currency unit    –      Rupiah (Rp)
                        Rp1.00      =      $0.000070911
                          $1.00     =      Rp 14,102

                                  ABBREVIATIONS
ADB       -   Asian Development Bank
AIDS      -   Acquired Immune Deficiency Syndrome
AKSI      -   Advanced Knowledge and Skills for Sustainable Growth
AMDAL     -   Analisis Mengenai Dampak Lingkungan (Analysis of Environmental Impact)
ANDAL     -   Analisa Dampak Lingkungan (Environmental Impact Assessment)
ASEAN     -   Association of South-East Asian Nations
              Badan Perencanaan Pembangunan Daerah (Regional Development
BAPPEDA   -
              Planning Board)
              Badan Perencanaan Pembangunan Nasional (National Development
BAPPENAS -
              Planning Board)
BOD       -   Biological Oxygen Demand
BOQ       -   Bill of Quantity
CEMP      -   Contractor’s Environmental Management (and Monitoring) Plan
COD       -   Chemical Oxygen Demand
CSS       -   Country Safeguards System
DDC       -   Detailed Design Consultant
DELH      -   Dokumen Evaluasi Lingkungan Hidup (Environmental Evaluation Document)
              Dinas Lingkungan Hidup (dan Kehutanan) [Environmental and (Forestry)
DLH(K)    -
              Agency]
DO        -   Dissolved Oxygen
EA        -   Executing Agency
EIA       -   Environmental Impact Assessment
EMC       -   Environmental Monitoring Checklist (of ADB)
EMP       -   Environmental Management Plan
EMMP      -   Environmental Management and Monitoring Plan
EPA       -   Environmental Protection Agency
EPM       -   Environmental Protection Measures
GOI       -   Government of Indonesia
GRM       -   Grievance Redress Mechanism
GRC       -   Grievance Redress Committee
HIV       -   Human Immunodeficiency Virus
HM        -   Hazardous Material(s)
HW        -   Hazardous Waste(s)
IA        -   Implementing Agency
IEE       -   Initial Environmental Examination
IFC EHS   -   International Finance Corporation Environmental Health and Safety
JFPR      -   Japan Fund for Poverty Reduction
Initial Environmental Examination - Asian Development Bank
KEPMEN      -   Keputusan Menteri (Ministerial Decree)
KEPRES      -   Keputusan President (Presidential Decree)
MEA         -   Masyarakat Ekonomi ASEAN (ASEAN Economic Community)
MENLH(K)/   -   Menteri Lingkungan Hidup dan Kehutanan [ Minister of
MOEF        -   Environment and Forestry
MORTHE      -   Ministry of Research, Technology and Higher Education (or Kemristekdikti)
NTU         -   Nephelometric Turbidity Unit
OHS         -   Occupational Health and Safety
PISC        -   Project Implementation Supervision Consultant
PMSC        -   Project Management Supervision Consultant
PIU         -   Project Implementation Unit
PMU         -   Project Management Unit
PERPRES     -   Peraturan Presiden (Presidential Regulation)
PP          -   Peraturan Pemerintah (Government Regulation)
PPEs        -   Personal Protective Equipment/s
PPTA        -   Project Preparation Technical Assistance
UKL         -   Upaya Pengelolaan Lingkungan (Environmental Management Effort)
UPL         -   Upaya Pemantauan Lingkungan (Environmental Monitoring Effort)
REA         -   Rapid Environmental Assessment
RKL         -   Rencana Pengelolaan Lingkungan (Environmental Management Plan)
                Rencana Pembangunan Jangka Menengah (Medium-term Development
RPJM        -
                Plan)
UPL         -   Upaya Pemantauan Lingkungan (Environmental Monitoring Plan)
UU          -   Undang-Undang (Law/Act)
SEMR        -   Semi-annual Environmental Monitoring Report
SEMS        -   Social and Environmental Management Systems
SPS         -   Safeguards Policy Statement (ADB)
                Surat Pernyataan Kesanggupan Pengelolaan Lingkungan (Promise Letter
SPPL        -
                for Environmental Management)
STDs        -   Sexually Transmitted Disease(s)
SWM         -   Solid Waste Management
TA          -   Technical Assistance
UNIMAL      -   University of Malikussaleh
UNJA        -   University of Jambi
UPI         -   Universitas Pendidikan Indonesia
UNRI        -   University of Riau
WHO         -   World Health Organization
WWTP        -   Waste Water Treatment Plan
NOTES
       (i)    The fiscal year (FY) of the Government of Indonesia and its agencies ends on 31
              December. “FY” before a calendar year denotes the year in which the fiscal year
              ends, e.g., FY2011 ends on 31 December 2011.

       (ii)   In this report, "$" refers to US dollars unless otherwise stated. This initial
              environmental examination is a document of the borrower. The views expressed
              herein do not necessarily represent those of ADB's Board of Directors,
              Management, or staff, and may be preliminary in nature. Your attention is directed
              to the “terms of use” section on ADB’s website.

In preparing any country program or strategy, financing any project, or by making any designation
of or reference to a particular territory or geographic area in this document, the Asian
Development Bank does not intend to make any judgments as to the legal or other status of any
territory or area
TABLE OF CONTENTS

EXECUTIVE SUMMARY.………………………………………………………………………...… i
EXECUTIVE SUMMARY ....................................................................................................... i
I. INTRODUCTION ........................................................................................................... 1
   Project Background ............................................................................................................... 1
       Purposes of IEE .................................................................................................................... 2
       Methodology and Approach of IEE ........................................................................................ 2
II.     POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK ............................................ 3
       Environmental Laws and Regulations in Indonesia ............................................................... 3
       ADB Environmental Safeguard Guidelines in the Context of Indonesia ................................. 4
       Environmental Studies Required for AKSI under ADB and Indonesian Regulations .............. 6
III.      DESCRIPTION OF the PROJECT ............................................................................. 8
       Project Overview ................................................................................................................... 8
       Need for Project .................................................................................................................... 9
       Category of Project ............................................................................................................... 9
       Location of Project .............................................................................................................. 10
       Project Elements ................................................................................................................ 12
IV.      DESCRIPTION OF THE ENVIRONMENT ............................................................... 19
       Physical Condition ............................................................................................................... 19
        1.    University of Malikussaleh...........................................................................................19
        2.    University of Jambi ....................................................................................................20
        3.    University of Riau ......................................................................................................21
        4.    Indonesia University of Education ............................................................................22
       Biological Conditions ......................................................................................................... 23
        1.    University of Malikussaleh.........................................................................................23
        2.    University of Riau .......................................................................................................23
        3.    University of Jambi ....................................................................................................24
        4.    Universitas Pendidikan Indonesia .............................................................................24
       Socio Economic Condition ................................................................................................ 24
        1.    University of Malikussaleh...........................................................................................24
        2.    University of Riau ......................................................................................................25
        3.    University of Jambi ....................................................................................................26
        4.    Universitas Pendidikan Indonesia ...............................................................................26
V. Anticipated Environmental Impacts and Mitigation Measures ...................................... 27
   Introduction ......................................................................................................................... 27
       Design/Pre-Construction Phase Impacts ............................................................................. 27
       Construction Phase Environmental Impacts ........................................................................ 28
Operation Phase Environmental Impacts ............................................................................ 31
VI.      Information Disclosure, consultation and participation ............................................. 33
      Information Disclosure ....................................................................................................... 33
      Consultations ..................................................................................................................... 33
      Participation80 ................................................................................................................... 34
VII. Grievance Redress Mechanism ............................................................................... 35
VIII. ENVIRONMENTAL MANAGEMENT PLAN.............................................................. 36
    Overview ............................................................................................................................. 36
      Institutional Arrangements ................................................................................................... 36
IX.       CONCLUSION AND RECOMMENDATIONS ........................................................... 51

Annexes
Annex 1: Details on campus plans, buildings, and proposed sites

Annex 2: The consultation process

Annex 3 Outline of the monitoring reports

Annex 4 project performance on environmental safeguards (sample)

Annex 5 comparison of IFC and GOI standards for EHS

Annex 6: Next steps for updating the IEE

                                                        LIST OF TABLES
Table 1. Summary of Gaps a between SPS and GOI Environmental Protection
Systems and Bridging Plans………………………………………………………………………. 4
Table 2: ADB and Indonesia Project Categorization Systems……………………………                                                  6
Table 3: Environmental Studies Required at each University in accordance with the
prevailing Government Laws and Regulations………………………………………………….. 7
Table 4 Building proposed by UNIMAL………………………………………………………….. 13
Table 5. Size and Number of Buildings to be constructed in UNJA, Jambi ……………… 15
Table 6: Size and Number of Buildings to be constructed in UNRI, Pekanbaru ……… …16
Table 7: Size and Number of Buildings to be Constructed in UPI, Bandung ..………….. 18
Table 8: GRM Processing of Complaints .........................................................................366
Table 9: Institutional Arrangements for EMP .........................................................................39
Table 10: Environmental Management Plan .........................................................................43

                                                        LIST OF FIGURES

Figure 1: Flowchart of Indonesian Environmental Clearance .............................................. 4
Figure 2. UNIMAL Location ...................................................................................................10
Figure 3: UNRI Location ......................................................................................................11
Figure 4. UNJA Location .......................................................................................................11
Figure 5: UPI Location .........................................................................................................12
LIST OF INDONESIAN LAWS AND REGULATIONS CITED IN THIS IEE

•   Keputusan Menteri Negara Lingkungan Hidup Nomor : KEP-48/MENLH/11/1996 -
    Environmental Ministry Regulation 48 /1996 On Noise Level Ranges

•   Undang-undang Nomor 23 Tahun 1997 tentang Pengelolaan. Lingkungan Hidup- Law
    23/1997 on Environmental Management

•   Peraturan Pemerintah Republik Indonesia Nomor 41 Tahun 1999 Tentang Pengendalian
    Pencemaran Udara – Government Regulation 41/1999 on Air Pollution Control

•   Peraturan Pemerintah Republik Indonesia Nomor 82 Tahun 2001 Tentang Pengelolaan
    Kualitas Air Dan Pengendalian Pencemaran Air- Government Regulation 82/2001 about
    Water Quality Management and Water Pollution Control

•   Peraturan Kepala Kepolisian Negara Republik Indonesia Nomor 23 Tahun 2007 Tentang
    Sistem Keamanan Lingkungan – National Police Chief Regulation 23/2007 on
    Environmental Protection System

•   Undang-undang No. 18 Tahun 2008 tentang Pengelolaan Sampah – Law 18/2008 on
    Waste Management

•   Peraturan Kementrian Tenaga Kerja Dan Transmigrasi PER.07/MEN/IV/2008 Tentang
    Penempatan Tenaga Kerja. - Ministry of Manpower and Transmigration Regulation No.
    Per.07/Men./IV/2008 on placement of manpower;

•   Peraturan Menteri Pekerjaan Umum Nomor: 10/Prt/M/2008 Tentang Penetapan Jenis
    Rencana Usaha Dan/Atau Kegiatan Bidang Pekerjaan Umum Yang Wajib Dilengkapi
    Dengan Upaya Pengelolaan Lingkungan Hidup Dan Upaya Pemantauan Lingkungan
    Hidup – Ministerial Regulation Department of Public Works No. 10/PRT/M/2008 on
    Establishing mandatory environmental management measures (ULK) environmental
    monitoring measures and criteria (UPL).

•   Peraturan Menteri Pekerjaan Umum Nomor : 26/Prt/M/2008 Tanggal 30 Desember 2008
    Tentang Persyaratan Teknis Sistem Proteksi Kebakaran Pada Bangunan Gedung Dan
    Lingkungan – Ministry of Public Works Regulation 26/Prt/M/2008 onTechnical
    Requirements of Fire Protection Systems for Buildings and the Environment

•   Undang-undang No. 22 Tahun 2009 tentang Lalu Lintas dan Angkutan Jalan Law No.
    22/2009 on traffic and road transport

•   Undang-Undand Nomor 32 Tahun 2009 Tentang Perlindungan Dan Pengelolaan
    Lingkungan Hidup – Law 32/2009 about Environmental Management and Protection

•   Peraturan Menteri Negara Lingkungan Hidup Nomor 07 Tahun 2010 Tentang Sertifikasi
    Kompetensi Penyusun Dokumen Analisis Mengenai Dampak Lingkungan Hidup Dan
    Persyaratan Lembaga Pelatihan Kompetensi Penyusun Dokumen Analisis Mengenai
    Dampak Lingkungan Hidup - Regulation of Ministry of Environment (Permen LH) No.
    07/2010 on Competence Certification of AMDAL Preparation and Training Requirements
    for AMDAL Preparation
•   Undang-Undang Nomor 11 Tahun 2010 Tentang Cagar Budaya - Law 11/2010 – Law
    11/2010 on Concerning Cultural Heritage

•   Rencana Usaha Dan/Atau Kegiatan Yang Wajib Memilikianalisis Mengenai Dampak
    Lingkungan Hidup Peraturan Menteri Negara Lingkungan Hidup Nomor 05 Tahun
    2012 Tentang Jenis - Decree of the Minister of Environment No. 05/2012 on Screening
    Criteria (type/scale/magnitude) for activities requiring AMDAL/EIA;

•   Peraturan Pemerintah Nomor 81 Tahun 2012 tentang Pengelolaan Sampah Rumah
    Tangga Dan Sampah Sejenis Sampah Rumah Tanggapp- Government Regulation No.
    81/2012 on Managing Household and Neighborhood Waste

•   Peraturan Pemerintah Nomor 27 Tahun 2012 Tentang Izin Lingkungan - PP 27/2012 on
    Environmental Permits

•   Peraturan Pemerintah Republik Indonesia Nomor 81 Tahun 2012 Tentang Pengelolaan
    Sampah Rumah Tangga Dan Sampah Sejenis Sampah Rumah Tangga – Government
    Regulation 81/2012 on household and neighborhood waste management

•   Peraturan Pemerintah nomor 50 Tahun Peneratpan Sistem Manajemen Kelslematan dan
    Kesehatan Kerja. – Government Regulation 50/2012 on Occupational Health and Saftey

•   Peraturan Menteri Perkerjaan Umum Nomor 03/PRT/M/2013 tentang Penyelenggaraan
    Prasarana Dan Sarana Persampahan Dalam Penanga-nan Sampah Rumah Tangga Dan
    Sampah Sejenis Sampah Rumah Tangga – Ministry of Public Works Regulation
    03//PRT/M/2013 on Implementation of Solid Waste Facility infrastructure and equipment
    for household and neighborhood garbage collection

•   Peraturan Pemerintah nomor 66 Tahun 2014 tentang kesehatan lingkungan –
    Government Regulation No. 66/2014 on Environmental Health

•   Peraturan Menteri Lingkungan Hidup Nomor 5 Tahun 2014 Tentang Baku Mutu Air
    Limbah - Ministry of Environment Regulation 5/2014 concerning Wastewater Quality
    Standard
i

                                       EXECUTIVE SUMMARY
1.     The Government of Indonesia with loan funding from the Asian Development Bank (ADB)
has proposed to implement the Advanced Knowledge and Skills for Sustainable Growth in
Indonesia (AKSI) Project. The Executing Agency for the project is the Ministry of Research,
Technology, and Higher Education (MORTHE) and the Implementing Agencies are four
universities: the University of Malikussaleh (UNIMAL), the University of Jambi (UNJA), and the
University of Riau (UNRI) in Sumatra and the Indonesia University of Education (UPI) in Bandung,
West Java (a teacher education university).

2.      The AKSI project’s scope of work entails three categories of activities: (i) Development of
teaching and research facilities and procurement of equipment; (ii) Development of human
resources for lecturers and university staff; and (iii) Development of academic curriculum, applied
research, and services, with an aligned management system in a specific focus area, which is
referred to as a center of excellence. Under the physical component, AKSI will construct 39 new
buildings, complete 1 unfinished building, and demolish 3 buildings; activities will take place on 7
campuses within the 4 universities. The construction will all take place on university campuses
that are already developed. All buildings will have environmental clearance as required by
Indonesian laws. These clearances will be issued after environmental impact assessments have
been completed and plans to mitigate negative environmental impacts have been accepted by
the government’s environmental protection authorities ADB. Similarly, the ADB’s environmental
safeguards policy stipulates that MORTHE and the universities must prepare an Initial
Environmental Examination (IEE), including an Environmental Management Plan (EMP), which
is to be approved by ADB. The draft report will be made public for public consultation on the ADB
website and by MORTHE and the universities locally. At the detailed engineering design stage,
each university will develop its own IEE and seek MORTHE and ADB approval. During project
implementation the IEE of each university will be updated as and when required, and progress on
implementing the IEE needs to be reported twice a year. The progress report will be published on
the ADB website and by MORTHE and the universities.

3.      The objectives of this IEE are to: (i) provide information about the general environmental
setting of the project area; (ii) identify impact of the project activities (physical infrastructure
development of the buildings) on the bio-physical, socio-economic, and cultural environment of
the project, recommend site specific environmental mitigation measures; and (iii) prepare an
environmental management plan for the project area to ensure that the IEE addresses the
requirements of the following: (a). Relevant Indonesian laws, regulations, and standard practices
and (b) ADB’s Safeguard Policy Statement, July 2009, applicable treaties and agreements.

4.      The assessment of the project has been carried out for both positive and negative impacts.
It is expected that the project activities will not have any significant adverse impact on the
environment. Impacts are most likely to occur during the construction phase; these are expected
to be temporary in nature and can be mitigated with proper management and good practices.
During the operational phase, the most likely risk is disposal of small amounts of waste from
teaching laboratories and teaching workshops that will be mitigated with standard procedures and
good practices used by universities for managing educational laboratories and school workshop
waste.

5.     The IEE remains a “living document”, and will be updated as and when required.
1

                                     I.    INTRODUCTION

       Project Background

1.      The Advanced Knowledge and Skills for Sustainable Growth (AKSI) project is part of
Indonesia’s long-term development plan for higher education with the stated objectives of: (i)
Increasing access to higher education, thus increasing enrollment rate; (ii) Improving quality,
relevance, competitiveness, and accreditation of higher education through the enhancement of
academic quality, facilities, human resources development, and research; (iii) Increasing quality
and competitiveness of higher education graduates. Project activities will be carried out in four
universities: the University of Malikussaleh (UNIMAL), the University of Jambi (UNJA), and the
University of Riau (UNRI) in Sumatra and the Indonesia University of Education (UPI) in Bandung,
West Java (a teacher education university), to provide high quality and demand-based programs
as part of the first phase of support to the longer-term higher education reform strategy.

2.      The Government of Indonesia (GOI) with loan financing from the ADB will upgrade these
four universities that were selected on a competitive basis based on proposals that indicated they
have the capacity to implement a relatively large project for constructing new buildings, upgrading
academic and non-academic human resources, and creating Centers of Excellence aligned with
their missions. AKSI’s envisioned scope of work entails three categories of activities: (i)
Development of teaching and research facilities, supporting infrastructures, and procurement of
equipment; (ii) Development and improvement of the quality of human resources, including
degree and non-degree programs for lecturers and university staff; (iii) Development of academic
curriculum, applied research, and services, with an aligned management system in a specific
focus area, which is referred to as a center of excellence. UNIMAL will focus at agriculture, UNJA
at sustainable natural resource management, UNRI on marine and aquatic science, UPI at
technical and vocational education and training (TVET) teacher education.

3.      The AKSI project includes financing the construction of 39 new buildings, completion of 1
unfinished building, and the demolition of 3 building on 7 locations within the boundaries of the 4
university campuses. The Executing Agency for the project is the Ministry of Research,
Technology, and Higher Education (MORTHE) and the Implementing Agencies are the four
universities. Within MORTHE, the key unit for the AKSI implementation will be the Project
Management Unit (PMU) established to manage and implement project/subprojects wholly at the
national level. Under the MORTHE PMU, Project Implementation Units (PIU) will be established in
each university to act as the Implementing Agencies (IA) that will manage and implement the
subprojects in their respective university on a day-to-day basis.

4.       All buildings constructed under this project will obtain all necessary permits and meet all
environmental protection, construction, and contracting requirements covered by ADB safeguards
as well as those required by Indonesian laws and regulations as they apply to this project.
Indonesian Environmental Permits can be issued for each building after environmental impact
assessments have been completed and plans to mitigate negative environmental impacts have
been accepted by the environmental protection authorities. Similarly, the ADB’s environmental
safeguards policy stipulates that MORTHE and the universities must prepare and publish a draft
Initial Environmental Examination (IEE), including an Environmental Management Plan (EMP) for
public consultation and that progress reporting on the EMP is required twice per year, and the
progress report will be made public at the ADB website as well as locally by the universities and
MORTHE.
2

5.      In addition to ensuring that the buildings comply with SPS requirements and GOI
regulations, the project will use good practices suitable for this project for environmental
sustainability, improving climate-change responsiveness (both in terms of adaptation and
mitigation), for increasing cost-efficiency including life cycle cost analysis to justify ‘green’
buildings, and for strengthening the overall academic and physical environment.1 All new
buildings will have engineering designs and checks to ensure specifications are included that
minimize risks to buildings and their occupants from earthquakes, flooding, temperature
increases, and hazardous air quality due to smoke haze. For overall campus design, the project
aims to use good practices appropriate for these campuses to minimize risks to campuses from
seasonal, flooding, temperature change, drought, and, for UNRI and UNJA, smoke haze.2

6.      Sumatra is on the front line of critical environmental issues such as rainforest reduction,
wetland depredation, and diminishing bio-diversity. Each of the three Sumatran universities is
already engaged in activities that address those issues. For example, UNJA has been undertaking
research on tropical rainforest management in collaboration with major universities in Germany
and Indonesia; UNRI has got accreditation from Institute for Coordination of Higher Education
(KOPERTIS) as Rank A for study program on marine science which is under Fishery Faculty with
focus on technology innovation in marine science for optimal and sustainable utilization of marine
resources;3 UNIMAL has been researching soil conservation to reduce soil depletion for small
holdings and plantations; they are also developing new seed varieties that eliminate the need for
pesticides and are best suited for local soil conditions.

          Purposes of IEE

7.       The purposes of conducting this IEE are: (i) to provide the government and ADB with
information about the general environmental setting of the 7 campuses where construction will
take place; (ii) to identify the impact of the proposed construction on the bio-physical environment;
and (iii) to recommend site specific environmental mitigation measures. Based on these initial
recommendations, the IEE includes an Environmental Management Plan (EMP) to ensure that
the IEE addresses the requirements of (a) relevant Indonesian laws, regulations and (b) ADB’s
Safeguard Policy Statement (SPS), July 2009. The initial assessment of the project’s
environmental impacts has been carried out, and the project activities are not likely to have any
significant adverse impacts on the environment that cannot be mitigated through proper
management and application of good practices.

          Methodology and Approach of IEE

8.        The works include the following activities:
      •   Desk review of information such as maps, and environmental analyses previously prepared
          for the universities;
      •   Preparation of checklists for collecting project related information;
      •   Review of national and local laws/regulations and procedures relating to environment,
          health and safety, resettlement and rehabilitation, etc.;
      •   Field visits to collect data relevant to the study area; and
      •   Discussions and interviews with the relevant stakeholders including: PIU teams,
          environmental study centers at each university, lecturers, students, relevant environmental

1   AKSI will follow SPS guidelines and will use IFC EHS good practice standards for the environment.
2   A best practice document to support using these principles is being prepared financed by a grant provided through
    the Project Readiness Improvement Trust Fund. It will be available in 2018.
3   UNRI has set aside more than 50% of its campus as protected conservation land;
3

       agencies, and project-influenced community members.

9.     At the detailed engineering design stage, the Project Management Unit together with the
Project Implementation Units at each university will develop a separate IEE for each university
and seek MORTHE and ADB approval.

10.    The IEEs remain “living documents” and will subsequently be updated as and when
required. The updated versions of the document are subject to ADB and MORTHE approval.

               II.   POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK

       Environmental Laws and Regulations in Indonesia

11.      In 2014, the Ministry of the Environment and the Ministry of Forestry were merged into the
Ministry of Environment and Forestry, which is the cabinet-level government ministry responsible
for managing and conserving the nation's environment and forests. In addition, each
district/province has its own Environment Agency that is responsible to the head of district or
province. Either level can issue Environmental Permits, depending upon the scope and nature of
the proposed activities.

12.    All projects must comply with both the ADB’s SPS requirements and the review and
clearance procedures specified under Indonesia’s legal and regulatory framework for
environmental management, construction, public health and safety including those listed in this
document under Indonesian Laws and Regulations Cited in this Document (page 1): Figure 1
depicts the flow of activities needed to obtain environmental clearance in Indonesia.
4

                   Figure 1: Flowchart of Indonesian Environmental Clearance

Source: ADB 2015. Draft Environmental Assessment and Review Framework for Indonesia: Flood
Management in Selected River Basins Sector Project

        ADB Environmental Safeguard Guidelines in the Context of Indonesia

13.    The Indonesian AMDAL system is almost equivalent to ADB’s SPS. An equivalence
assessment between the Indonesian system and the SPS was conducted as part of the review
process to prepare for the decision to use country safeguard systems in the energy sector in
Indonesia. Table 1 shows the results and the mitigating measures of the gaps in the project.

    Table 1. Summary of Gaps a between SPS and GOI Environmental Protection Systems
                                   and Bridging Plans
           Policy Principals                    Gaps                              Bridging Plans
 1. Environmental Impact          Government of Indonesia (GOI)        In general, disclose environmental
 Assessment                       system does not include:             assessments for each campus to be
                                                                       disclosed and updated
                                  a. Gender considerations not
                                  included                             a. The Gender Action Plan
                                  b. Impact on vulnerable groups not   addresses specific gender issues
                                  included, except for indigenous      b. As there are no permanent
                                  people                               residents on campus, this is not
                                  c. Induced impact not included       applicable
                                  d. Cumulative Impact Assessment      c. The impact assessment includes
                                  for new Activities not included      impacts and mitigations at pre-
                                                                       construction, construction, and post-
                                                                       construction phases
5

           Policy Principals                       Gaps                                 Bridging Plans
                                                                           d(i). Cumulative impact assessment
                                                                           plan will be included in university’s
                                                                           future strategic – long-term
                                                                           planning.
                                                                           D(ii). If any new construction
                                                                           activities start, they will be
                                                                           monitored as mentioned in the
                                                                           Environmental Management Plan
                                                                           (EMP)
 2. Alternative assessment          GOI system does not include            a. Overall campus planning in each
                                    alternative assessment for the         university will be reviewed by an
                                    Environmental Management               independent engineering firm
                                    Measure (UKL) and the                  supported by international
                                    Environmental Monitoring Measure       consultant to advise on improving
                                    (UPL)                                  the current overall design.
 3. Environmental Management        GOI system does not include Cost       The environmental management
 Plan                               for implementation of mitigations      plan includes cost estimates
 4. Consultation and Grievance      GOI system does not continuing         a. Meaningful consultations with
 Redress Mechanism                  public consultation throughout the     affected people and facilitating their
                                    project cycle                          participation has been conducted
                                    As for UKL-UPL, it provides a          and will continue as part of Initial
                                    maximum of three days for public to    Environmental Examination (IEE)
                                    give input and for UKL-UPL it does     finalization
                                    not require public consultation        b. Continuing consultation with the
                                                                           stakeholders throughout the project
                                                                           cycle is planned
                                                                           c. Disclosing the draft
                                                                           environmental assessment
                                                                           d. Providing printed copies of the
                                                                           environmental assessment at
                                                                           campus and GOI offices, and
                                                                           suitable locations.
 5. Pollution Control               GOI standards for noise, air quality   a. Differences between GOI
                                    and water quality are lower than the   standards and IFC EHS standards
                                    International Financing Cooperation    have been assessed (Annex 5)
                                    Environmental, Health, and Safety      b. Where there is a difference in
                                    (IFC EHS) standards                    standards, the EMP includes the
                                                                           stricter standard
Source: Asian Development Bank: Draft equivalency assessment for using country safeguards systems.

14.    In case there are differences, the ADB’s SPS requirements will prevail. According to
Indonesian regulations, all projects should undergo environmental clearance before proceeding
to implementation. Essentially, an AMDAL study conforms to ADB’s Environmental Impact
Assessment (EIA), while an Environmental Management Measure (UKL) and Environmental
Monitoring Measure (UPL) corresponds to an IEE. The EIA and AMDAL are somewhat equivalent,
though the criteria used for ADB’s EIA requirements categorization and those under the
Government of Indonesia’s AMDAL procedure are slightly different. Indonesian regulations
provide quite rigid quantitative criteria, while ADB relies on quantitative criteria (e.g., significance).
For example, ADB’s SPS 2009 categorizes projects based on the “significance of impacts”
whereas Indonesia’s AMDAL procedure classifies projects based on specific magnitude (length,
depth, width, size, or other physical dimensions). Table 2 indicates the relationship between
ADB’s environmental categorizations and those under Indonesia’s regulations/policies.
6

                     Table 2: ADB and Indonesia Project Categorization Systems
                 ADB Project Categories                                  AMDAL Project Categories4
     Category A: Projects with potential for significant        AMDAL: Projects that according to law requires an
     adverse environmental impacts, requiring an                Environmental Impact Assessment (AMDAL)
     environmental impact assessment (EIA)
     Category B: Projects judged to have some                   UKL/UPL: Projects that according to law requires
     adverse environmental impacts, but of lower                Environmental Management Measure (UKL) and
     degree and/or less significant than those for              Environmental Monitoring Measure (UPL).
     category A projects. Category B projects require an
     initial environmental examination (IEE)                    However, special discretion and judgment of
                                                                environmental agencies at local and national level
                                                                (based on particular consideration) may override
                                                                the category, and UKL/UPL Category may be
                                                                “upgraded” to AMDAL Category.
     Category C: Projects unlikely to have adverse              SPPL: Projects that do not require AMDAL or UKL-
     environmental impacts. No special requirement, but         UPL are obliged to submit a ‘statement of
     the environmental aspects are reviewed as well.            management and environmental monitoring ability’
                                                                or SPPL.
     Category FI. Projects involve a credit line through        Not Applicable
     a financial intermediary or an equity investment in a
     financial intermediary. The financial intermediary
     must apply an environmental management system
     unless all projects will result in insignificant
     impacts.
    Source: ADB 2015. Draft Environmental Assessment and Review Framework for Indonesia: Flood
    Management in Selected River Basins Sector Project.

           Environmental Studies Required for AKSI under ADB and Indonesian Regulations

15.     Under Indonesia’s environmental protection legal and regulatory framework, the type of
environmental studies required depends upon the land area and building size; AMDAL is required
for areas >5 hectares or buildings larger than 10,000 square meters. The project preparation team
held discussions with the universities and local or regional environmental authorities to agree
upon which type of environmental study was required at each campus. When appropriate,
buildings were grouped into clusters. Table 2 provides a summary of those discussions and an
estimated date when the documentation needed for environmental clearances will be completed.
Once the documentation is completed, it is submitted to the relevant authority to receive the
approval to proceed with the next steps in the permit process. Construction of buildings under this
project will have limited adverse impact within campus area. Thus, they will be equivalently
characterized into category B of ADB’s SPS. All cost associated to the implementation of
UKL/UPL will be borne by the university, as part of the cost for construction permit.

4   To manage legacies, the government of Indonesia has put a provision in place for companies and entities who got a
     business permit before environmental audits were mandatory and who had not yet done such an audit. These
     companies and entities need to do an environmental audit process and obtain an Environmental Evaluation
     Document (DELH) which contains environmental management and monitoring specifications. (Prior to Law No.
     32/2009, DELH was not mandatory. To implement Law No. 32/2009, the Minister of Environment issued Regulation
     No. 14/2010 explaining how Environmental Evaluation Documents should be prepared by the business company or
     Government entity in order to meet the requirements of DELH. In the Regulation No. 14/2010, it specifies that
     environmental documents can be prepared in the form of DPLH (Dokumen Pengelolahan Lingkungan Hidup or
     Environmental Management Document) or DELH (Dokumen Evaluasi Lingkungan Hidup or Environmental
     Evaluation Document). Further, UKL-UPL is considered equivalent to DPLH, while AMDAL is equivalent to DELH. In
     case a DELH is already prepared by an entity for the full campus, preparing an Addendum can be considered if
     additional buildings are added.
7

    Table 3: Environmental Studies Required at each University in accordance with the
                     prevailing Government Laws and Regulations
                                                Required GOI Environmental Study Document and Actual
    University/             Proposed
                                                or Tentatively planned dates of Completion / Submission
     Campus                 Buildings
                                                    AMDAL             UKL-UPL         DELH/Addendum
 University of Malikussaleh
 Bukit Indah         Cluster I                                               ✓   (Oct’18)
                     Cluster II                                              ✓   (Oct’18)
                     Cluster III                                             ✓   (Oct’18)
 Reuleut             Reuleut Campus                                                                   ✓    (Oct’18)
                     (4 Clusters)                                                                           DELH
 University of Riau
 Binawidya           Ten Buildings                                                                   ✓     (Aug’18)
                                                                                                            DELH
                                                                                                          Addendum
 University of Jambi
 Telanaipura        PC (8,733 m2)                                            ✓   (Oct’18)
 Buluran            FMHS (6,236 m2)                                          ✓   (Oct’18)
 Mendalo            Seven Buildings                                                                  ✓     (Nov’18)
 Universitas Pendidikan Indonesia
 Bumi Siliwangi     PICL (8,200 m2)                                         ✓ (Apr’18)
                    FEBE (8,800 m2)                                         ✓ (Apr’18)
                    FADE (9,800 m2)                                         ✓ (Apr’18)
                    FTVE (9,900 m2)                                         ✓ (May’18)
                    TVET CoE                                                ✓ (May’18)
                    (9,800 m2)
                    PPG Center                                              ✓    (May’18)
                    (6,750 m2)
Notes:
University of Malikussaleh (UNIMAL), Bukit Indah Campus:
(i) Cluster I, covering buildings of Faculty of Technic (3,000 m2), Faculty of Social and Politics (2,300 m2), and
      Integrated Laboratory for Renewable Energy over (2,700 m2), total 8,000 m2.
(ii) Cluster II, covering buildings of General Lecture (3,000 m2), and Faculty of Economics (2,200 m2).
(iii) Cluster III, covering building of Library and Student Activity Center (7,200 m2).

UNIMAL, Reuleut Campus:
(i) Cluster I, covering buildings of Rectorate, Administration Office and Language Training Center (8,000 m 2).
(ii) Cluster II, covering buildings of Center for University Education and Training, Exposition and Event Center (4,800
      m2), and General Lecture Room/Building (3,000m2).
(iii) Cluster III, covering buildings of Faculty of Agriculture (2,300 m 2), Agriculture Laboratory (2,700 m2), and Green
      House (800 m2).
(iv) Cluster IV, covering buildings of Faculty of Education (2,100 m2), and Faculty of Medicine (2,200 m2).
For the Reuleut Campus a full DELH will be prepared.

University of Riau (UNRI):
Covering proposed buildings of Integrated Classrooms (8,500 m2), Integrated Laboratories (7,500 m2), Information and
Technology Center (4,000 m2), Student Center (3,500 m2), University Main Library (2,000 m2), Boat House and Marine
Center (2,000 m2), Health Study Complex (5,500 m2), Postgraduate Building (7,500 m2), University Training Center
(4,000 m2), Food Science and Technology Center (4,000 m2), and its associated supporting facilities. UNRI prepared
a DELH in 2015 for its existing buildings in Campus Ninawidya.. To comply with Indonesian Law an Addendum to the
ongoing DELH is sufficient. The Addendum was submitted to the relevant environmental authority on the date included
in the table, and the authority is reviewing it.

University of Jambi (UNJA):
Proposed Mendalo campus buildings covering University and Faculty Administration Center (9,361 m2), Integrated
Classroom A [Hexagon building] (8,500 m2), Integrated Classroom B (8,250 m2), Integrated Classroom C (6,600 m2),
8

Engineering (Science) Laboratory (3,600 m2), Integrated Social Science Laboratory (3,600 m2), Student Activity
Center (4,800 m2), Road [inside the campus] (4,000 m2) and other associated facilities. Wholly total 48,711 m2.

Universitas Pendidikan Indonesia (UPI):
Postgraduate Integrated Classrooms and Laboratory (8,200 m2), Faculty of Arts and Design Education Integrated
Classrooms, Laboratories, Studios and Performing Arts Laboratories (9,800 m2), Faculty of Technology Vocational
Education (TVET) Integrated Classroom, Laboratories, Workshops and Studios (8,500 m 2), Professional Teacher
Education and Training Center (6,000 m2).. Given the limited area used by the 6 new buildings within the campus
preparing UKL/UPL is enough. The required documentation was submitted to the relevant environmental authority on
the dates mentioned, and the clearance for seeking building permit has been issued.

                              III.    DESCRIPTION OF THE PROJECT

        Project Overview

16.    AKSI’s envisioned scope of work entails three categories of activities: (i) Development of
teaching and research facilities, supporting infrastructures, and procurement of equipment; (ii)
Development and improvement of the quality of human resources, including degree and non-
degree programs for lecturers and university staff; (iii) Development of academic curriculum,
applied research, and services, with an aligned management system in a specific focus area,
which is referred to as development of center of excellence.

17.     The project has the following outputs:

18.     Output 1 is delivery of market responsive programs by UNIMAL, UNJA, and UNRI, by: (i)
upgrading UNIMAL, UNJA and UNRI through completing construction and equipping 33 new
buildings, and finishing and equipping 1 unfinished building (with gender responsive, inclusive,
and sustainable infrastructure); (ii) training at least 586 additional teaching, management,
research and support staff (of which 40% women) of UNIMAL, UNJA and UNRI, to increase their
understanding on market responsive programs and research; and (iii) Supporting development of
centers of excellence in UNIMAL, UNJA and UNRI in Sustainable Natural Resources, Agriculture,
Marine and Aquatic Science, respectively, in collaboration with industry, community and other
stakeholders (a) to upgrade or develop at least 40 curricula; (b) to launch at least 21 new research
programs connected to the center or excellence; (c) to provide at least 65 additional training or
service programs; and (d) to sign at least 21 additional MoUs with industry and other stakeholders.
In addition, a separate Technical Assistance (TA) is proposed to be financed on a grant basis by
the Japan Fund for Poverty Reduction to support MORTHE in developing a medium-term
investment plan for the Higher Education and Advanced Skills Development Sector.

19.     Output 2 is provision of improved teacher training by UPI by: (i) Upgrading UPI by
completing construction and equipping 6 new buildings (including gender responsive, inclusive,
and sustainable infrastructure) to become center of excellence in TVET teacher education and
training; (ii) Training at least 53 teaching, management, research and support staff (of which 40%
are women) to increase understanding on designing and delivering accredited TVET teacher
education programs; (iii) Supporting UPI as part of its center of excellence development to (a)
establish 6 new S1 TVET teacher education programs; (b) to train at least 240 SMK-teachers (at
least 40 % female) in-service training programs, in collaboration with MOEC, relevant
polytechnics, SMKs and industry (c), to certify at least 300 participants (at least 35% female) by
the established LSP and PUK, and (d) to disseminate at least 2 case studies of UPI model for
TVET teacher education and training model. In addition, the proposed separate TA mentioned in
the previous paragraph is also designed to support MORTHE to develop a medium-term technical
and vocational education and training (TVET) teacher education strategy in collaboration with all
relevant stakeholders.
9

20.    The Executing Agency for the project is the Ministry of Research, Technology, and Higher
Education (MORTHE) and the Implementing Agencies are the four universities. Within MORTHE,
the key unit for the AKSI implementation will be the Project Management Unit (PMU) established
to manage and implement project/subprojects wholly at the national level. Under the MORTHE
PMU, Project Implementation Units (PIU) will be established in each university to act as the
Implementing Agencies (IA) that will manage and implement subprojects on a day-to-day basis.

          Need for Project

21.     Indonesia’s public universities are in need of capital improvements. In 2018, the gross
enrollment rate (GER) for HE in Indonesia was 31.2%, up from 14.9% in 2000. The number of
general5 universities expanded from 46 to 63 between 2005 and 2017 an increase of 37%, while
enrollment expanded by 207% during the same period. The rapid expansion of the public
university system was not matched by capital improvements sufficient to keep up with rising
demand. Shortages of lecturers with appropriate qualifications made it difficult for universities to
improve their performance, and many public universities hired temporary lecturers. Nearly 60,000
lecturers--permanent civil-service (PNS) and temporary non-civil service (non-PNS) lecturers--
teach in public universities. Approximately 3% of PNS and 14% of non-PNS lecturers have
Bachelor degrees as their highest credential, 66% of PNS and 68% of non-PNS have Masters
degrees and 31% of PNS and 18% of non PNS have PhDs.

22.     The government seeks to expand enrollment, upgrade quality and improve the relevance
of public universities to provide highly skilled professionals needed to support regional growth. In
addition, the Government also seeks to develop ‘World-Class Universities’, meaning institutions with
research capacity in science and technology, which are seen as necessary to achieve current and
future national goals.

23.    Public investment in higher education infrastructure has not been able to keep pace with
the expansion and the increasing number and types of programs offered. Most public universities
need additional and modern facilities that offer the quality and types of study programs needed to
support the Government of Indonesia (GOI’s) plans for economic growth and diversification. The
GOI’s higher education strategy includes upgrading public universities in terms of expanding the
enrollments by building new classrooms, laboratories, data centers, libraries, and faculty and
administration buildings.

24.     The four universities in the AKSI project have prepared a detailed justification for each
building including usage and size of each building, floor by floor. Building design complies with
existing regulations and standards and makes conscious effort to use best practices for: (i)
improving climate-change responsiveness (both in terms of adaptation and mitigation), (ii)
increasing cost-efficiency over a building’s life cycle to justify costs associated with construction
costs for ‘green’ buildings, and (ii) strengthening the overall academic environment, including
safe, sustainable and gender responsive campuses.

          Category of Project

25.    The government understands that the ADB classifies AKSI as Environment Category B, a
category that requires an IEE study level document. This categorization means that the project is
expected to have some adverse impacts that can be mitigated locally, and mitigation measures

5   Indonesia’s higher education system has both a general stream under MORTHE and a religious stream under the
     Ministry of Religious Affairs.
10

can be designed more readily.6 The project/subprojects are located at four (4) sites: UNIMAL in
Aceh Province, UNRI in Riau Province, and UNJA in Jambi Province, three universities in
Sumatera Island; and UPI in the City of Bandung in West Java Province.

           Location of Project

26.    The project/subprojects are located at four (4) sites: UNIMAL in Aceh Province, UNRI
in Riau Province, and UNJA in Jambi Province, three universities in Sumatera Island; and
UPI in the City of Bandung in West Java Province. In annex 1 details of the buildings are
presented, including, among others, location, site plan, building function, and pictures of
proposed location.

27.   UNIMAL. Infrastructure and human resource improvement in UNIMAL is expected to
enable the university to establish a Center of Excellence (CoE) for Applied Innovation and
Technology in Agriculture. The project will be implemented in two campuses, Bukit Indah and
Reuleut Campuses, which are located in the City of Lhokseumawe and North Aceh District,
respectively, both are entirely located on land belonging to the university.

                                             Figure 2. UNIMAL Location

                                                   Source: Google Maps

28.    UNRI. The project will take place in the main campus area of the University of Riau,
Binawidya Campus, at Jalan H.R. Soebrantas Km 12.5, in Pekanbaru City. All the new
buildings proposed in the UNRI proposal located on university owned land.

6   The Project is classified as environmental category B with the following justification: (i) Scale and size of the Project:
     where the building footprint ranges from 0.7% to 4.7% of the campus area, (ii) Construction and the associated
     impacts: where construction size is relatively small, so that the impact generated by the construction activities will be
     relatively small and can be readily mitigated to acceptable levels using available methods; and (iii) sensitivity of the
     environment: where there are no sensitive environment components such as occurrence of sensitive habitat in the
     project area and its surrounding (forests, swamps, protected areas, national park, nature reserves, wildlife reserves)
     and sensitive species (protected species, endemic species, endangered species according to government
     classification as well as IUCN Red List).
11

                                  Figure 3: UNRI Location

                                      Source: Google Maps

29.    UNJA. The project is located in three campuses, namely Mendalo, Telanaipura and
Buluran. In the Mendalo, UNJA’s main campus, the project will support development of the
majority of the construction. The Mendalo campus is located in Mendalo Indah Village,
Kecamatan Jambi Luar Kota (Sub-district), Kabupaten Muaro Jambi (District). While the
Telanaipura and Buluran campuses are located in Telanaipura Sub-District, Kota Jambi
(Jambi City).

                                  Figure 4. UNJA Location

                                      Source: Google Maps

30.     UPI. UPI will undertake new construction only on its main campus on the outskirts of the
City of Bandung. The campus has an area of 36 hectares totally owned by the university.
12

                                   Figure 5: UPI Location

                                      Source: Google Maps

       Project Elements

31.     UNIMAL – Infrastructure. UNIMAL. has one campus in the city of Lhokseumawe and
one in Aceh Utara. The project will be implemented in both locations: the Bukit Indah campus
has an area of approximately 105 hectares, and the Reuleut Campus has 84 hectares. All
buildings will be on the UNIMAL campuses.

32.     On the Bukit Indah Campus, the AKSI Project will construct 6 new buildings and finish
1 unfinished building: School of Engineering; School of Economics; School of Social and Political
Science; School of Law; General Lecture Building, Integrated Laboratory, and finish and modify
the unfinished Administration building to become the Central library and Student Activity Center;

33.     On the Reuleut Campus, the AKSI Project will construct 8 buildings: School of
Agriculture; School of Education; School of Medicine; a General Lecture Building; An Integrated
Laboratory; Green House; Administrative Offices; and a University and Community Education
Center. Table 4 shows the proposed buildings to be constructed in UNIMAL by AKSI.
13

                                                    Table 4 Building proposed by UNIMAL
                                                                                                                        Building    Landscape &        Total
                                                                                                           Floor area
    Location   Building – UNIMAL                                                                 Fls                    Footprint   Construction   Construction
                                                                                                              (M2)
                                                                                                                          (M2)        Site (M2)    Footprint (M2)

               1) General Lectures Building (C)                                                   3            3.000        1.000           400            1.400
               2) Finish and modify the Unfinished Administration Building to become Central
                                                                                                  3            7.500        2.500          1.000           3.500
               Library Building and Student Activity Centrum
               3) Integrated Laboratory of Renewable Energy                                       2            2.700        1.350           540            1.890
               4) School of Engineering Building                                                  2            3.000        1.500           600            2.100

Bukit Indah    5) School of Economic Building                                                     2            2.800        1.400           560            1.960
Campus         6) School of Social Science and Politics Building                                  2            2.300        1.150           460            1.610
               7) School of Law Building                                                          2            2.200        1.100           440            1.540
               Total Builing footprint                                                                                    10.000
               Supporting Infrastructure: Roads and Parking, Drainage, Culverts, Energy Power Supply, IT
                                                                                                                                           4.000
               connections, Landscaping, Water supply
               Total area for construction footprint                                                                                                     14.000
               8) General Lectures Building (D)                                                   3            3.000        1.000           400            1.400
               9) Integrated Laboratory for Agriculture, Medicine and other general Sciences      2            2.700        1.350           540            1.890
               10) Green House                                                                    1              800          800           320            1.120
               11) Administration Office of Reuleut Campus, Integrated with Data center,
                                                                                                  3            8.000        2.667          1.067           3.733
               international office and language Training Center

               12) School of Agriculture Building                                                 3            2.300          767           307            1.073
Reuleut
Campus         13) School of Teaching and Education                                               3            2.700          900           360            1.260
               14) School of Medicine Building                                                    3            2.200          733           293            1.027
               15) University and Community Education, Exposition and Event Center integrated
                                                                                                  2            4.800        2.400           960            3.360
               with University Training Center
               Total Building footprint                                                                                   10.617
               Supporting Infrastructures: Roads and Parking, Drainage, Culverts, Energy Power Supply, IT
                                                                                                                                           4.247
               connections, Landscaping, Water supply

               Total area for construction footprint                                                                                                     14.863
Total          15 buildings; 14 new building, 1 unfinished building to be finished.                                       20.617           8.247         28.863

Total are required for construction footprint:
Campus-1 Bukit Indah 14.000 M2 ~ 1,4 Ha, or approximately 1,3% from 105 Ha total campus area
Campus-2 Reulet           14.863 M2 ~ 1,5 Ha, or approximately 1,8% from 84 Ha total campus area
Total (2 campuses)        28,863 M2 ~ 2,9 Ha, or approximately 1,5% from 189 Ha total campus area
Details on site-plans, buildings, and usage by people are in annex 1

34.    The unfinished building (the administration building) will undergo a structural assessment
conducted by the engineering firm recruited by ADB from July to September 2018,7 and the
confirmation issued by the local Public Works Office statement that there are no major issues
preventing the continuation of the construction to complete the unfinished building. The
procurement plan includes separate re-design consulting services (funded by PNBP) and
construction (funded by ADB-loan). Procurement can only start after clearance from MORTHE
and ADB.

35.     UNIMAL plans to complete construction of the unfinished General Lectures Buildings (A)
and (B) using its own funds to ensure that sufficient facilities are available for students. UNIMAL
will make every reasonable effort to complete the construction of lecture building (A) by 2022 and
commence completion of lecture building (B) by 2022. UNIMAL includes progress of completion
of these buildings as part of project progress reporting. Completion of these buildings is not part
of the project scope, however any potential impact will be monitored as part of the environmental
management plan and reported on through the environmental monitoring report.

7   Including an assessment if Asbestos was used.
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