IMPLEMENTATION COMPLETION REPORT …documents.worldbank.org/curated/en/902961468752742034/...for pollution control within the Indonesian governmental structure have been changing nearly

Document ofThe World Bank

FOR OFFICLL USE ONLY

Report No. 19400

IMPLEMENTATION COMPLETION REPORT

INDONESIA

BAPEDAL DEVELOPMENT TECHNICAL ASSISTANCE PROJECT

(Loan 3454-IND)

June 30, 1999

Environment and Social Development Sector UnitIndonesia Country Management UnitEast Asia and Pacific Region

This document has a restricted distribution and maybe used by recipients only in theperformance of their official duties. It contents may not otherwise be disclosed withoutWorld Bank authorization

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CUPRRENCY EQUIVALENTS

Currency Unit = Indonesian Rupiah (Rp)1992 $1 = Rp 2,0001993 $1=Rp 2,0701994 $1=Rp 2,1201995 $1 = Rp 2,2001996 $1 =Rp 2,3501997 $1=Rp 2,4001998 (Jan) $1 = Rp 8,0001998 (Jun) $1 = Rp 13,0001999 (Jan) $1 = Rp 8,000

FISCAL YEAR

April 1 - March 31

WEIGHTS AND MEASURES

Metric Units

ABBREVIATIONS AND ACRONYMS

ADB - Asian Development BankAMDAL - Environmental Impact Assessment ProcedureAusAID - Australian Agency for International DevelopmentBAPEDAL - Environmental Impact Management Agency (Central)BAPEDAL Wilayah - Regional office of BAPEDALBAPEDALDA - Environmental Impact Management Agency (Province or District)CIDA - Canadian International Development AgencyGOI - Government of IndonesiaICR - Implementation Completion ReportIMF - International Monetary FundGTZ - German Agency for Technical CooperationJABOTABEK - Jakarta-Bogor-Tangerang-Bekasi Metropolitan AreaJICA - Japan International Cooperation AgencyMHA - Ministry of Home AffairsMLH - Ministry of State for the EnvironmentMOP - Memorandum and Recommendation of the PresidentOECF - The Overseas Economic Cooperation Fund, JapanPEMDA - Provincial or district government

Vice President Jean-Michel Severino, EAPVPSector Manager Kristalina Georgieva, EASESCountry Director Mark Baird, EACIFTask Manager Thomas E. Walton, EACIF

FOR OFFICLIL USE ONLY

TABLE OF CONTENTS

PREFACE ........................................................... i

EVALUATION SUMMARY ............................................................ ii

PART I: PROJECT IMPLEMENTATION ASSESSMENT ....................................... 1A. Project Objectives and Description ............................................................ 1B. Achievement of Project Objectives ........................................................... 2C. Implementation Record and Major Factors Affecting the Project ......................... 3D. Project Sustainability ........................................................... 5E. Bank Performance ........................................................... 6F. Borrower Performance ........................................................... 7G. Assessment of Outcome ........................................................... 8H. Future Operation ........................................................... 9I. Key Lessons Learned ........................................................... 10

PART II: STATISTICAL TABLES ........................................................... 11Table 1: Summary of Assessments .11Table 2: Related Bank Loans/Credits .11Table 3: Project Timetable .12Table 4: Loan Disbursements: Cumulative Estimate and Actual .12Table 5: Key Indicators for Project Implementation .12Table 6: Key Indicators for Project Operations .13Table 7: Results of Training .13Table 8A: Project Costs ..................................................... 14Table 8B: Project Financing ..................................................... 15Table 9: Economic Costs and Benefits (not applicable) ................................... 15Table 10: Status of Legal Covenants ..................................................... 15Table 11: Compliance with Operational Manual Statements ............. .................. 16Table 12: Bank Resources: Staff Inputs ..................................................... 16Table 13: Bank Resources: Missions ..................................................... 16

ANNEX A: BORROWER'S CONTRIBUTION TO THE ICR ............. .................... 17

ANNEX B: ICR MISSION AIDE MEMOIRE ...................................................... 18

ANNEX C: EVOLUTION OF BAPEDAL ORGANIZATIONAL STRUCTURE ........... 35

This document has a restricted distribution and may be used by recipients only in theperformance of their official duties. Its contents may not otherwise be disclosed withoutWorld Bank authorization.

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IMPLEMENTATION COMPLETION REPORT

INDONESIA

BAPEDAL DEVELOPMENT TECHNICAL ASSISTANCE PROJECT(LOAN 3454-IND)

PREFACE

This is the Implementation Completion Report for the BAPEDAL Development TechnicalAssistance Project (BDTAP) in the Republic of Indonesia, for which a loan in the amount of US$12.0million equivalent was approved on March 4, 1992 and made effective on December 29, 1992.

The loan was closed on December 31, 1998, compared with the original closing date of June 30,1997. Final disbursement took place on April 30, 1999. There was no undisbursed balance.

The ICR was prepared by Mr. Sean Foley, consultant and former Task Team Leader, and Mr.Thomas Walton, present Task Team Leader (EACIF. It was reviewed by Messrs. Richard Calkins(EAPCO) and Benjamin Fisher (EACIF), who were the project's first and second Task Team Leaders,respectively, Mr. Heinrich Unger (EASES) and Ms. Kristalina Georgieva, Manager, EASES.

Preparation of this ICR was begun during the Bank's final supervision/completion mission,September/October 1997, and a first draft was given to BAPEDAL for comments in December 1997.When the loan was reopened and extended to assist BAPEDAL in managing forest fire emergencies inNovember 1997, work on the ICR was suspended. The draft was revised in February and March 1999 toreflect developments during the period of the loan extensions, and the Task Team Leader discussed itwith BAPEDAL staff in a brief ICR meeting in May 1999.

The borrower contributed to preparation of the ICR by making staff presentations on the outcomeof each contract during the final supervision mission, providing comments on the December 1997 AideMemoire, reviewing the work accomplished during the loan extension period for the ICR mission, andreviewing and commenting on the draft ICR. BAPEDAL staff were preparing a paper to be incorporatedin the ICR as the Borrower's Contribution, but illness of the primary author delayed its completionindefinitely.

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INDONESIA


(LOAN 3454-IND)

Evaluation Summary

Introduction

1. In June 1990, the national Environmental Impact Management Agency (BAPEDAL) wasformally established by Presidential Decree. It became operational in January 1991. The Bank obtainedfunding from the Japan Grant Facility to assist with start-up of the new agency. The funds used inassisting BAPEDAL staff to formulate the Five-Year BAPEDAL Development Program and to preparethis project.

Project Objectives

2. The project's overall development objective was to assist GOI in (a) strengthening theinstitutional capacity and role of BAPEDAL and other agencies of the borrower responsible forenvironmental management and pollution control; and (b) designing and implementing adequate pollutioncontrol measures at the central and regional levels. The overall objective was subdivided into five"subproject" objectives:

* clarify and strengthen the mandate of BAPEDAL and relevant agencies;* establish and strengthen systems and skills for pollution control;* establish and strengthen regional environmental agencies and laboratories;* design, development and implement a recruitment and training program; and* support BAPEDAL in mobilization and.administration of external finance.

Implementation Experience and Results

3. The project substantially achieved nearly all of its subproject objectives and exceeded some ofthem. In terms of its overall objective, BDTAP strengthened BAPEDAL's capacity in a variety of areas.It also succeeded in helping BAPEDAL to design adequate pollution control measures at central andregional levels, but BAPEDAL has not yet progressed very far towards their effective implementation.

4. The total project costs were estimated as US$ 15 million, US$ 12 million of which was providedby a loan from the Bank. The actual project costs were US$ 14.38 million. There were no changes in thefinancial arrangements during implementation. The project was appraised in January 1992. Boardapproval came in March of the same year, and the project became effective in December 1992. Threeseparate extensions of the loan closing date were granted. The loan closed on December 31, 1998.

5. The main factors not subject to Government control were all associated with the newness ofBAPEDAL: confusion about mandate and role, an initial shortage of trained and experienced staff, andthe unpredictability of the pace of change i1i a new institution. Factors within the Government's controlwere BAPEDAL's lack of clear authority and status within the Government, a legal system that wasdysfunctional in prosecuting pollution cases, and repeated postponements of decisions on the nature ofthe organizational structure for environmental management at regional, provincial and district levels.Among the factors BAPEDAL itself could have controlled, the single most detrimental one was theconsistently poor lateral communication and collaboration within the agency. Much more could have

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been achieved under BDTAP if all senior managers had seen its potential to benefit the agency as a wholeand had participated in it accordingly.

6. The Bank accurately identified BAPEDAL's institutional strengthening needs. All requiredpreparation procedures were completed rapidly; the project moved from the conceptual stage (IEPS) toappraisal within four months, in part because the concept of BAPEDAL itself had been under discussionby GOI and the Bank for more than two years. Identification is rated satisfactory, with the retrospectiveobservation that the Bank was unduly optimistic in the expectation that BAPEDAL would implementpollution control measures in the course of the project. Preparation performance is rated highlysatisfactory. Appraisal is rated as satisfactory; the one area that can with hindsight be questioned is theBank's implicit optimism about an inexperienced agency's capacity to accommodate the mobilization offive separate teams of consultants. The annual supervision missions were thorough and identified andfollowed up on issues of implementation, operation and sustainability. Because BDTAP was taskmanaged in the field office, the Task Team Leader was available to BAPEDAL in person at any time, andthis addressed the need for close and extended supervision identified in the FEPS. Supervision is rated ashighly satisfactory.

7. The borrower's performance in implementation is rated as satisfactory. For the most part,BAPEDAL had a clear view of its needs, and the project reflects that view overall. Throughout theproject, BAPEDAL followed Bank procedures. With respect to legal covenants, there were chronicdelays in timely submission of audit reports and Five-Year Plan updates, but compliance was eventuallyachieved each year with these two covenants and was not a problem with the others.

8. It was not appropriate to rate the operation of the project, given that it was an institutionalstrengthening project, that it has recently closed, and that the assignments of authority and responsibilityfor pollution control within the Indonesian governmental structure have been changing nearlycontinuously and sometimes dramatically since 1996.

9. The project outcome is rated as satisfactory.

Summary of Findings, Future Operations, and Key Lessons Learned

10. Findings and Key Lessons Learned. The Project Management Office proved vital to the level ofsuccess achieved. The central reason for its value lay in the fact that it was clearly managed byBAPEDAL rather than the Bank, and came to be seen as an "honest broker" among BAPEDAL, theBank, BDTAP consultants and a wide range of actual and potential donors. Besides its routine projectmanagement assistance functions, the PMO provided continuing informal and confidential advice toBAPEDAL management.

11. A balance of "advisory" versus "deliverables" roles for the TA consultants is useful. Inretrospect, BAPEDAL would have received additional benefits if more consultant time had beenavailable for experts to provide day-to-day advice to their counterparts, especially in the latter half of theproject.

12. BAPEDAL would also have received greater benefits from BDTAP if each of the consultantteams had been assigned to a member of the technical staff of the unit that would be responsible forimplementing the TA outputs. Ideally this would mean designating the technical counterpart as projectmanager, but this would require a change in the Indonesian regulations governing project managers.

13. Wider ownership by senior staff "stakeholders" would have improved the outcome. Assigningproject managers as suggested above would been one way to avoid the "that's Deputy I's project" attitudethat inhibited participation by the other deputies in BDTAP. More generally, the damaging internal

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communication barriers could perhaps have been overcome if more of the mid-level managers had beeninvolved in decisions about the content of the various BDTAP components, hence seeing themselves asgenuine stakeholders in the project's outcome.

14. In the future, project designs for assistance to technical agencies should explicitly include plansand funding for establishing, staffing and operating a repository of study outputs, and for reproducing,advertising and distributing materials to potential users.

15. Future Operations. The new Environmental Management Act drafted as part of BDTAP has thepotential to greatly strengthen BAPEDAL's ability to address pollution, once the necessary regulationshave been finalized. Likewise, the basic elements required for a regional presence have been createdwith the establishment of regional, provincial and district offices. On the technical side, BAPEDAL nowhas available to it probably more technical guidelines on laboratory practices and management than itcan use in the short-term, and a nearly similar situation prevails with regard to toxic and hazardousmaterials. It also has a set of training curricula that will be directly applied in building the humanresource capacity of provincial and district environmental agencies.

16. Sustainability. The question of sustainability is difficult, and the answers depend on whichaspects of the project are under discussion. The new Environmental Management Act and theestablishment of regional environmental management agencies (BAPEDALDA) will form the basis ofenvironmental management operations well into the future. The draft protocols for many enforcementactivities and the comprehensive range of laboratory reference material, staff guidelines and numeroustraining curricula are considered valuable and, with minor exceptions, usable by BAPEDAL and otherdonors. In these areas the project clearly has sustainable results, provided BAPEDAL addresses theurgent need to advertise and disseminate the many BDTAP products. On the other hand, there remainedat the project's closing doubts about BAPEDAL's ability to apply the full range of complianceinstruments to reduce pollution and to minimize or mitigate adverse environmental impacts. The shift ofpollution control and impact management responsibilities to the lower levels of government that began in1996 and intensified in 1999 leaves this aspect of project outcome still uncertain, particularly becausesuccess will depend so heavily on rapid development of capacity and resolve in the district or municipalBAPEDALDA.

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INDONESIA


(LOAN 3454-IND)

PART I: PROJECT IMPLEMENTATION ASSESSMENT

A. PROJECT OBJECTIVES AND DEscRnPTIoN

Background

1, The Bank's 1989 report on Indonesia's environment identified two fundamental institutionalconstraints on Indonesia's capacity to manage environmental impacts. First, the Minister of State forPopulation and the Environrent had no line responsibilities, no official authority over other ministries orinfluence in the budgeting process, and limited staff and budget. Second, the existing environmentalagencies at the provincial level were set up to monitor and report, not to manage or regulate. The reportrecommended that a new pollution monitoring and control agency be established at the national level andthat the environmental bureau in each province be upgraded in the organizational structure andempowered to coordinate environmental matters.1

2. In June 1990, the national Environmental Impact Management Agency (BAPEDAL) wasestablished by Presidential Decree. It became operational in January 1991. The Bank had in 1989obtained funding from the Japan Grant Facility to assist with start-up, and the funds were first put to usein assisting BAPEDAL to formulate a Five-Year Development Program. GOI subsequently applied$300,000 of the grant to the preparation of a technical assistance loan. The resulting BAPEDALDevelopment Technical Assistance Project, or BDTAP, was approved by the Board in March 1992 andbecame effective in December of the same year.

Project Objectives And Components

3. Objectives. The project's overall objective was to assist GOI in implementing the Five-YearBAPEDAL Development Program through: (a) strengthening the institutional capacity and role ofBAPEDAL and other agencies responsible for environmental management and pollution control and (b)designing and implementing adequate pollution control measures at the central and regional levels. Theoverall objective was subdivided into five "subproject objectives":

1. clarify and strengthen the mandate of BAPEDAL and relevant agencies;

2. establish and strengthen systems and skills for pollution control;

3. establish and strengthen regional environmental agencies and laboratories;

4. design, develop and implement a recruitment and training program; and

5. support BAPEDAL in mobilization and administration of external finance.

4. Components. BDTAP was implemented through six consultant contracts: (a) Legal Mandate,Enforcement and Compliance ("Legal"); (b) Regional BAPEDAL Development ("Regional"); (c)Regional Laboratories Development ("Labs"); (d) BAPEDAL Training ("Training"); (e) StaffAcquisition and Human Resources Development ("Staff'); and, (f) Project Management Office ("PMO").The six contracts quickly became known as "components".

Indonesia Forest, Land and Water: Issues in Sustainable Development. Report 7822-IND, The World Bank, 1989.

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5. The Legal component was composed of two, semi-independent teams, one working onamendments to the Basic Environmental Law (Law No. 4 of 1982) and the other on compliance andenforcement systems (Objectives 1 and 2). The Training and Staff components both addressed portionsof Objective 4 and could have been implemented in a single contract, but because human resourcesmanagement and training were initially not located in the same branch of BAPEDAL, there was aseparate contract for each. In contrast, it was logical to separate Objective 3 into two components -Regional and Labs - because both the counterparts and the skills required were different.

6. Evaluation. The development objectives were clear and appropriate at the time of appraisal andcontinued to be so throughout implementation. They adequately addressed the identified needs of a newand growing environmental management agency, with two possible exceptions (see Bank performance,below). However, they proved rather general as a basis for supervision. Consequently, a set of indicatorsof development outcome was prepared for each objective, based on the MOP and reflected in the Form590 for the supervision of March 1997 (see Part II, Table 5).

7. The development objectives presented a significant challenge for an agency as young asBAPEDAL. The burden of administering six technical assistance contracts was demanding in itself. Atinception, the large number of consultants overwhelmed the small number of available staff.Conversely, the consultants complained that they had no BAPEDAL counterparts. When the componentsbegan to produce deliverables, the complexity and volume of material and the resulting demands forinformal feedback and formal review required time commitments from staff who were by then morenumerous, but who also had heavy operational obligations.

8. Purposes and results of loan extension. BAPEDAL requested a one-month extension of theclosing date to July 1997 to allow sufficient time for review of final reports from the consultants, most ofwhose contracts were ending on the original closing date because of initial procurement delays. Fourmonths later, the Minister asked the Bank to make available the unused loan balance (approximately$300,000) to support BAPEDAL in responding to the serious forest fires of 1997. The loan was reopenedand extended to close on June 30, 1998. Three small consulting contracts were issued, to assist in: (i)formulating forest fire control legislation, (ii) developing a BAPEDAL information system for forest firemanagement; and (iii) designing a national forest fire research and training center. A third closing dateextension to December 31, 1998 was granted because of delays caused by the political events in the firsthalf of 1998. In the meantime, issuance of implementing regulations for the Environmental ManagementAct of 1997 had been made a condition of IMF funding to Indonesia, and BAPEDAL used some of theremaining balance to draft four of them.

B. ACHIEVEMENT OF PROJECT OBJECTIVES

9. Quantitative criteria for judging the progress and performance of the project were onlyestablished in late 1996, and only for those parts of the project amenable to measurement. Consequently,this assessment is based on a mixture of qualitative and quantitative assessment and informedprofessional judgments. A round of structured interviews were conducted by the original ICR mission(1997) with all senior staff involved in BDTAP, and with the managers of the most significant donor-funded support - AusAID, CIDA, JICA, GTZ and ADB.

10. The project's single most notable achievement was the preparation of the legal draft of the newEnvironmental Management Act (Act No. 23 of 1997). BDTAP also supported BAPEDAL in promotingits passage. Nearly as important was support to MHA in developing the legal and administrativeframework for provincial and district environmental agencies (BAPEDALDA). In these twoaccomplishments alone, BDTAP substantially exceeded Subproject Objective 1.

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11. BDTAP exceeded Subproject Objective 3 in supporting the establishment of three regionaloffices of BAPEDAL (BAPEDAL Wilayah) and the authorization of 25 provincial BAPEDALDA;preparing the initial blueprint of working relationships among central, provincial and districtenvironmental agencies; identifying a network of regional laboratories; developing lab quality assurance,certification and procedures manuals; and training EMC laboratory staff.

12. BDTAP combined with an increase in BAPEDAL's managerial capacities resulted in substantialachievement of Subproject Objective 4. Among the significant outputs were: a comprehensive set oftraining curricula (31 modules); a five-year training program; detailed procedures for analysis of needs,preparation of job descriptions, recruitment, and performance appraisal; career patterns and anorganizational management information system. During the life of the project, BAPEDAL staff increasedin number from 53 in a single office to 590 in the central office, three regional offices and the centrallaboratory.

13. The PMO component supported BAPEDAL in managing BDTAP and other donor-fundedprojects, provided "on-the-job" training in project management, and coordinated the BDTAPcomponents. It assisted BAPEDAL in obtaining more than US$ 300 million in additional donor loan andgrant funding. In accomplishing this, the PMO exceeded Subproject Objective 5.

14. Evaluating the extent to which Subproject Objective 2 was achieved is more difficult, because itcalled for not only design of systems and strengthening of skills in pollution control but alsoimplementation of the results. The project substantially achieved its design and strengthening objectives,but implementation has been limited. For instance, the Legal component prepared model wastewaterdischarge permits for 22 industries; wrote standard operating procedures for permit writers andinspectors; and conducted training, overseas for investigators and "on-the-job" for inspectors. However,the permit system has not been implemented, the inspectors and investigators are underutilized, and noenforcement actions have been taken.

15. On balance, the project substantially achieved its five subproject objectives, all of which fall intothe Bank categories of sector policies or institutional development, or both. In terms of its two overalldevelopment objectives, BDTAP succeeded in assisting BAPEDAL with the first one, to become astronger, more capable environmental management institution. It was partially successful with thesecond; the design of adequate pollution control measures was accomplished, but BAPEDAL has not yetprogressed very far with making these measures operational.

C. IMPLEMENTATION RECORD AND MAJOR FACTORS AFFECTING THE PROJECT

16. Factors not generally subject to Government control. The risks noted in the MOP werecorrectly identified, and one of them was the unpredictability of the pace of change in a new institution.This risk was overcome sufficiently to allow the project to reach a satisfactory outcome, but the youth ofBAPEDAL was nevertheless the single most important factor affecting project implementation. Theagency was formally established in June 1990. Confusion about mandate and role and lack of trained andexperienced staff were obvious constraints during the first years, and there was a major reorganization inlate 1994. BAPEDAL had to find its place within the Indonesian bureaucracy at the same time as it hadto start up its pollution control and impact management functions and manage this complex technicalassistance project.

17. Factors generally subject to Government control. BAPEDAL was immediately faced with long-neglected pollution problems, and it was handicapped in its ability to respond. Its authority forundertaking inspections, collecting evidence and prosecuting serious polluters was not clear (henceSubproject Objective 1), and it was consequently reluctant to exert much force in the sectors overseen bythe more powerful and well-established line ministries. On the few occasions in which it attempted to

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prosecute environmental offenses, the cases were not handled by the courts in a manner that was eitherknowledgeable about or sympathetic to environmental management objectives. GOI could have donemore, and sooner, to elevate BAPEDAL's status in the Govemment.

18. Also constraining was indecision on the organizational structure for pollution control at theregional level. GOI had been considering options since 1988, at times assisted by the Bank (Tree CropsProcessing Project; Jabotabek Urban Development Project III) and other donors (AusAID's PollutionControl Implementation Project, GTZ's project on Water Quality Management for the Musi-MahakamRiver). However, the Presidential Decree to create the three BAPEDAL Wilayah was not issued until1994. Establishing provincial and district-level BAPEDALDA required negotiations with MHA thatcontinued until 1996. Furthermore, the new Environmental Management Act has ultimately failed toprovide the long-awaited answer to two critical questions. It left the relationship between BAPEDAL andMLH still ambiguous and did not select any of the altematives that were under consideration duringdrafting to strengthen BAPEDAL's authority. (In January 1999, in his own effort to increase theeffectiveness of the two agencies, the Minister of Environment combined the positions of the threeAssistant Ministers and three BAPEDAL Deputies, as shown in Appendix C.)

19. Because of the delays in reaching closure on these issues, the BDTAP consultants had to contendwith uncertainty regarding the fundamental nature of the organizational structure they were supposed tobe supporting throughout most of the project. This had a moderate but manageable adverse impact on theachievement of the overall development objective, because BDTAP could achieve only limited success instrengthening regional pollution control agencies that were not formally established until the project wasnearing completion. The uncertainty also contributed to BAPEDAL's inability to take effective legal oradministrative action against polluters or AMDAL regulation violators even as the project delivered newinstruments for doing so, and, when the decision to decentralize was confirmed in the RegionalGovernment Act (Act No. 22 of 1999) concerning regional government, it became apparent thatBAPEDAL would no longer be the principal operating agency for those functions.

20. Factors generally subject to implementing agency control. With a few exceptions, lateralcommunication and collaboration within BAPEDAL have been poor since the agency was created. Thischaracteristic the management culture is best described in comments and quotes from BAPEDAL seniormanagers, BAPPENAS, and various donor agencies and consultants interviewed during preparation ofthis ICR. One senior manager said, "What we have been doing is not a combined effort." The Ministerhimself observed during a supervision mission that "some managers in BAPEDAL have raised non-communication to a fine art." Comments from the donors echo this: working with BAPEDAL is "likeworking with two different organizations;" in BAPEDAL "nobody talks to anybody;" and "the protocolof who gets copies of what... is bizarre." Despite the appointment of a former senior Police Officer asVice-Chairman of BAPEDAL and the sincere efforts of a management expert who served as Deputy Iduring part of the project, this situation never improved during BDTAP. The covenant requiring yearlyupdating of the Five-Year Plan might have been expected to bring management together in developing aunified annual work plan, but it did not do so. Most of the burden for updating the plan fell on PMO;there was no meeting of deputies for work planning. Wisely, BAPEDAL has now established a Bureaufor Planning within the Secretary's Office (see Annex C), but it did not exist prior to 1999.

21. The negative effects of poor intemal communications and cooperation prevented BAPEDALfrom gaining full benefit from BDTAP. TWo examples suffice to show the impact. First, until about oneyear before the project finished, the head of the Environmental Management Center (BAPEDAL'senvironmental reference laboratory and training center at Serpong) did not know that an expert (the Labscomponent team leader) was available to assist him in preparing an action plan for gaining internationalaccreditation for his laboratories. Had he been made aware of this earlier by BAPEDAL management,much more progress toward certification might have been achieved. Second, little use was made byDeputy II of the expert advice, day-to-day support and other resources intended for him under the Legal

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component. Most of his energy was devoted to PROPER PROKASIH, his newly-developed businessperformance rating system. Even during the loan extension period, when informed that some of theremaining loan balance could be used to prepare implementing regulations for the EnvironmentalManagement Act, Deputy II replied, "But that's [Deputy I's] money."

22. Cramped working conditions and inadequate space for meetings and materials storage wereidentified as a constraint during project preparation. This practical problem was addressed by renting anadditional floor in the building to accommodate the increasing number of BAPEDAL staff and consultantteams. The rental was funded through the PMO contract. As the project closed, BAPEDAL was movingto altogether new quarters adjacent to MLH.

23. BAPEDAL's capacity to administer and supervise consulting contracts was virtually nonexistentat the inception of BDTAP. Training and staff size were inadequate. PMO filled this gap during itsexistence and transferred the necessary skills to the growing staff. However, serious delays in processingeven the simple "emergency" contracts for which the loan was twice extended indicate that contractmanagement capacity is uneven even now within BAPEDAL.

24. Implementation delays. The loan became effective in late December 1992, about four monthslater than planned, after the appointment of the PMO donor coordination advisor (a condition of loaneffectiveness). Finalizing the TOR for the five other bidding packages, completing the short-listing andconducting the bidding processes dragged on until late 1993. Contracts were signed in mid-1994,inception reports submitted in November 1994, and the project came under full implementation inJanuary 1995, compared to the scheduled date of April 1994. Much of this delay can be attributed to lackof staff and experience in BAPEDAL, exacerbated by the internal reorganization that occurred in late1994.

25. In retrospect, this slippage may have been a blessing in disguise. The bulk of the consultants'work was delayed until after the internal reorganization was almost complete and, despite some delayscaused by staff reassignments, this resulted in a more stable and capable institutional setting for theproject to proceed. Three other beneficial effects also resulted: (i) BAPEDAL's staff complementincreased sufficiently to allow assignment of counterparts to each contract (not possible in 1993-94); (ii)MHA was ready to make some use of the assistance with BAPEDALDA offered by the Regionalcomponent (on-schedule implementation would have prevented this); and, (iii) the PMO component wasin operation longer than expected and could provide more assistance to BAPEDAL in preparing for andobtaining new funding support from OECF, ADB and AusAID.

D. PROJECT SUSTAINABILITY

26. The question of sustainability is difficult, and the answers depend on which aspects of the projectare under discussion. First, it is clear that the new Environmental Management Act, draft protocols formany enforcement activities, the formal establishment of BAPEDALDA, a comprehensive range oflaboratory reference material, staff guidelines and numerous training curricula are valuable and, withminor exceptions, usable by BAPEDAL and other donors. In particular, the head of PUSARPEDAL andDirector of HRD both enthusiastically endorsed the usefulness of the laboratory training material, and theADB-funded Regional BAPEDAL Network Project has evaluated the training curricula and plans to usenearly all of them. These are strong indicators of sustainability.

27. The Environmental Management Act and the BAPEDALDA will form the basis of environmentalmanagement operations well into the future, with their influenced sharply enhanced by the economiccrisis that beset Indonesia in late 1997. At the Bank's urging, GOI included preparation of implementingregulations for the Environmental Management Act among the reforms of the IMF assistance packageand two crisis-related adjustment operations, Policy Reform Support Loans I and II. BAPEDAL

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responded with a will (and some of the remaining BDTAP funds), completing four draft regulations byDecember 1998 (the last of which was issued in May 1999), with more in preparation. And, largelybecause of BDTAP, the BAPEDALDA had already begun coming into existence before the RegionalGovernment decentralized environmental management to provincial and district govermment in 1999.This gave environment a head start as the line ministries grapple with the realities of decentralization.Clearly the project had sustainable and influential results in these important areas.

28. Without BDTAP, the newly established BAPEDAL would have been in a poor position toadminister support from other donors or to attract the level of funding that is currently available to it.With BDTAP, especially the day-to-day assistance provided by the PMO, required systems have been putin place and a number of staff have accumulated substantial project management experience. However,the opportunity requested by the Minister himself to use the undisbursed balance of the loan in assistingBAPEDAL with the forest fires have been lost twice as deadlines for simple administrative actionspassed, had not the Task Team Leader intervened extensively. For this new capacity to be sustainable,BAPEDAL needs to assign the trained people to project management tasks and clearly make their work apriority - two things it does not do consistently.

29. At the project's close, there remained doubts about BAPEDAL's capacity to use the range ofinstruments now at its disposal to effect compliance with pollution control standards, or to mitigateenvironmental impacts. Two central issues during the project were the agency's continuing lack of self-confidence and clear commitment to tackle difficult environmental issues, and its inability to establishand project unified principles and operational objectives and procedures - to speak with one voice,whether to polluters, donors, or sister agencies. These issues are linked, and solutions depended onchanging BAPEDAL's corporate culture, a task well beyond the scope of BDTAP. In 1999, the Ministerestablished a Bureau of Planning under the Secretary which may help with internal communications andplan development. To be fair, dramatic improvements in the functioning of the Indonesian judicialsystem and in the strength of the national leadership's commitment to sound environmental managementare also necessary conditions, and BAPEDAL does not control either of these. Moreover, with the shiftof enforcement authority to BAPEDALDA that began in 1996 and intensified in 1999, it has becomeclear that BAPEDAL will not be playing the lead role in directly enforcing environmental standardshenceforth. Now, success depends on rapid development of capacity and political will at the provincialand especially the district or municipal levels.

30. The outlook for regional development of environmental management capacity is also uncertain.When the three regional offices (BAPEDAL Wilayah) were established, it was unclear what form androle BAPEDALDA might take, and there was potential for overlap. The functions of BAPEDALDAhave been more thoroughly defined since the Regional component was completed, in a project at MHAsupported by an ADB grant (Master Plan for Capacity Building in BAPEDALDA, ADB TA No. 2598-INO). It is now obvious that the BAPEDALDA are the operational bodies and that the Wilayah have asupporting role. This leaves many important functions for the Wilayah to perform; however, withinBAPEDAL there has been evident reluctance to delegate responsibility to the Wilayah offices andprovide the necessary authority and resources. Signs of frustration and demoralization are consequentlyemerging among the Wilayah staff. However, it is important to point out that, in May 1999, BAPEDALmanagement was beginning to take on the task of developing an effective strategy related to the new roleand functions of BAPEDAL in dealing with.a decentralized environmental management structure.

E. BANK PERFORMANCE

31. The needs of BAPEDAL were accurately identified, and the definitions remained appropriatethroughout the project. Given the uncertainty surrounding the evolution of the growing organizationduring implementation - correctly identified from the outset as the main risk - the Bank's expectation

7

that BAPEDAL would not only design but implement pollution control measures should probably havebeen seen as unduly optimistic at the time. Project identification is rated as satisfactory.

32. Assistance for project preparation is rated as highly satisfactory. All required procedures werecompleted rapidly and the project moved from the conceptual stage (IEPS) to appraisal in four months.Project preparation began not long after BAPEDAL was formally established and became operational, inJune 1990 and January 1991, respectively . (The IEPS was issued in September 1991.) At that timework was still continuing on preparation of a five-year development program for BAPEDAL, withfunding from a Japan Grant signed in April 1990, and additional technical support from the Canadian-funded Environmental Management Development in Indonesia (EMDI) project. Funds from the Japangrant were extended to cover preparation of BDTAP and to establish the PMO.

33. Appraisal was conducted in January 1992. Negotiations were held in Jakarta in February, threemonths ahead of schedule, and the project was approved by the Board on March 4, 1992. Appraisal israted as satisfactory: risks were recognized, the financial package was appropriate in type and amount,the instrument was suitable and the agency's experience (minimal) was for the most part correctly takeninto account. The one area of appraisal that can be questioned, admittedly with the benefit of hindsight, isby what means the Bank envisioned this fledgling agency was going to be able to accommodate thesimultaneous mobilization of five separate teams of consultants. While unquestionably badly needed, theconsultants imposed an enormous burden on the small number of staff in the early years of the project.

34. The project was supervised formally each year during implementation, and a mid-term reviewwas conducted in March 1996. Supervision missions were thorough and identified issues ofimplementation, operation and sustainability. Supervision reports reflect continuity and consistency inBank-Borrower dialogue from one mission to the next. The project benefited from being managed in thefield, for the Task Team Leader was available to BAPEDAL as needed and was able to providecontinuity between missions in following up key issues and actions. Supervision is rated as highlysatisfactory.

F. BORROWER PERFORMANCE

35. BAPEDAL was an infant agency with a small and inexperienced staff. It is not surprising thatsome difficulties were experienced during preparation, but the borrower's performance is rated assatisfactory. For the most part, BAPEDAL had a clear view of its needs, and the project design reflectsthat view.

36. Some of the difficulties that arose during implementation were consequences of implementingsuch a project in a new, rapidly-growing organization, and some result from the internal managementproblems that BAPEDAL continues to experience. It is possible to see the parallel evolution of thisproject and BAPEDAL in three stages. In the first stage, BAPEDAL's capacity was low, the consultantswere desperately needed, but the burden of managing and responding to the multiple consulting teamshad a serious impact on the workload of agency staff. In the second stage, BAPEDAL and theconsultants were generally in equilibrium in terms of the demands made and responses given. Nearer theend, many BAPEDAL staff opined that it would have been better if a small number of specializedadvisors had been assigned to support the various Directorates. However, such a format would not haveworked in the young BAPEDAL of 1992-1994, when many key positions were still vacant.

37. Throughout the project, BAPEDAL followed Bank procedures. With respect to legal covenants,there were chronic delays in timely submission of audit reports and Five-Year Plan updates, butcompliance was eventually achieved each year with these two covenants and was not a problem with theothers. Particularly noteworthy was the quick and effective remedial action BAPEDAL took to get thefaltering Training component back on track; the BAPEDAL counterpart manager negotiated a change in

8

leadership in which the Indonesian expert serving as the consultant's deputy team leader replaced theinternational team leader and brought the contract to a successfully and timely conclusion. BAPEDAL'sperformance in implementation is rated as satisfactory.

38. Because the project focused on institutional strengthening and has recently closed, and becausethe decentralization of pollution control responsibilities that began in 1996 shifted most of the directenforcement and compliance functions from BAPEDAL to BAPEDALDA, the project has not been ratedfor operation.

G. ASSESSMENT OF OUTCOME

39. BDTAP achieved nearly all of its stated objectives, and BAPEDAL's capacity in a number of keyareas was indeed substantially strengthened. Examples are training, hazardous waste management,laboratory operation and quality assurance, and some aspects of contract administration. However, it isfrankly difficult to see much improvement in the agency's overall ability to control pollution and manageadverse environmental impacts effectively. The project provided BAPEDAL with many of theorganizational, legal, regulatory and technical tools needed for it to carry out its mandate. but theinitiative and responsibility to make use of those tools passed to BAPEDAL management. In manyrespects, management did not live up that responsibility.

40. To be sure, there are bright spots in this picture. BAPEDAL stepped up the to the challenge ofcoordinating forest fire information during the disastrous fires of 1997-98, establishing and manning a24-hour coordination post in which satellite imagery was interpreted, converted to map coordinates, andpassed to fire response teams in the field. BAPEDAL has also for several years tried to lead Indonesia toproper management of vehicle-related air pollution. It has also shown leadership in formulating ahazardous waste management program (yet to be implemented on any large scale) and in the evolution ofenvironmental impact assessment procedures. PROPER PROKASIH may have preoccupied Deputy II atthe expense of his participation in the Legal component of BDTAP, but it is achieving internationalrecognition as a model for "reputation-based" industrial compliance instruments. These are causes foroptimism.

41. But, a clear example of capacity developed and then not utilized is BAPEDAL's failure to makeactive use of approximately 20 staff who received extensive training (in-country and overseas) inconducting pollution control investigations or inspections. A second example is the unwillingness ofsenior management to draw on the support provided by the project to prepare and conduct prosecutionsagainst even one violator of pollution control regulations. Another is the inability or unwillingness ofmanagement to collect the personal information (education, training and experience) that is necessary tooperationalize the human resources development database designed by the Staff component, and, hence,map out training and career paths for all of its staff. These sorts of activities are fundamental to theoperation of an effective environmental agency, hence the conclusion of this ICR that across-the-boardimprovement in effectiveness has not occurred at BAPEDAL to the extent that would be hoped at thisstage in its evolution and after relatively large amounts of donor assistance.

42. This shortcoming needs to be viewed in the light of the bureaucratic culture that pervades somany aspects of government in Indonesia, because it may be unrealistic to expect the management of anewly established, junior agency such a BAPEDAL, working with critical and sensitive issues, to beeither willing or capable of "bucking" a deeply entrenched system. In Indonesia until very recently, thefrequent public expressions of commitment to respecting the environment have not been matched at thelevel of practice by willingness or care in planning, executing and operating most private or public sectorprojects. The pervasive culture of corruption and use of political power to evade legal responsibilities -for example, to circumvent the AMDAL process in obtaining permits and licenses, or to manipulate

9

outcomes of judicial proceedings - further impedes BAPEDAL's ability to fulfill its mandate.Moreover, obstacles encountered in attempting to implement "command and control" reinforceBAPEDAL's tendency to rely on the voluntary and incentive-based elements of overall compliancestrategy that are already much more compatible with the Indonesian national temperament, which avoidsconfrontation and seeks results through consensus.

43. Taking into account all of the above, the project's development outcome is rated as satisfactory.

H. FUTURE OPERATION

44. The new Environmental Management Act has the potential to greatly strengthen BAPEDAL'sability to tackle pollution prevention and control once the necessary regulations have been finalized.Likewise, the basic elements required for a regional presence have been created with the establishment ofRegional BAPEDAL offices (BAPEDAL Wilayah), and BAPEDALDA as units of provincial and districtgovernments. On the technical side, BAPEDAL now has available to it probably more usable technicalguidelines on laboratory practices and management than it can use in the short-term, and a nearly similarsituation prevails with regard to toxic and hazardous materials.

45. In two vital areas -- laboratory and inspections -- BAPEDAL now has detailed "roadmaps" forprogress. EMC, with continuing financial and technical support from JICA and CIDA, should be ableduring the next two or three years to move fairly smoothly through the process of internationalaccreditation. This can be followed with accreditation of national laboratories by EMC. TheEnvironmental Management Act explicitly provides for civilian inspectors and invests them with right ofentry and power to collect many kinds of essential evidence. This provides the legal and practical basisto make much more active use of the inspectors who have been trained under BDTAP.

46. Finalizing the MOU for Regional Laboratories between BAPEDAL and the Departments ofHealth, Industry and Public Works is one of two critical outstanding issues yet to be resolved, despiterepeated reminders by supervision missions and informal exchanges with BAPEDAL management.Failure to act on this issue has potentially serious negative consequences with regard to theimplementation and success of the OECF and AusAID laboratory equipment projects, and the issue isfurther complicated by need for agreements between BAPEDALDA and their sister agencies in theprovinces. The second critical issue is authorizing and effecting distribution of the material outputs ofBDTAP. Currently, BAPEDAL has no library facilities, and outputs from a number of projects areuncatalogued and scattered carelessly throughout the office spaces. Some of the most important outputsfrom BDTAP (and a number of other donor-funded projects) are at risk of being ignored or, worse, lost.

47. An important next step is the forging of an effective regional environmental managementpresence, in which BAPEDAL and BAPEDAL Wilayah should play important advisory and technicalsupport roles. Development of provincial and local capacity will depend on effective and cleardevolution of functions, provision of standards and guidelines, administration of training, acquisition ofstaff through new hires and transfers from BAPEDAL, procurement of equipment, and funding.BAPEDAL should take advantage of the tools developed under BDTAP, supplemented by the ongoingADB-supported Regional BAPEDAL Network Project and the OECF and AusAID funding available forregional laboratories, to exert leadership in -building regional capacity.

I. KEY LESSONS LEARNED

48. Importance of a Project Management Office. The establishment of the PMO during projectpreparation and its continuation as a condition of the loan proved vital to the level of success achieved. Itis difficult to envision how the many difficult issues that arose during implementation would have been

10

resolved in a new organization like BAPEDAL without the PMO. The central reason for its value lay inthe fact that it was clearly managed by BAPEDAL rather than the Bank, and came to be seen as an"honest broker" between BAPEDAL, the Bank, BDTAP consultants and a wide range of actual andpotential donors. In large part this was also due to the professional and personal qualities of the personwho headed the PMO; careful personnel selection is extremely important.

49. Balance "advisory" versus "deliverables" roles for the TA consultants. A number ofBAPEDAL senior staff said that they could have made good use of experienced consultants acting in aday-to-day role as "advisors." It is apparent, in retrospect, that flexibility to shift more consultant time tothis service, especially in the latter half of the project, would have been beneficial. The project designprogrammed most of the TA team time for preparation of the "deliverables" that were handed over to theclient in draft or when complete.

50. Require assignment of counterpart managers for technical components. The complement ofthe above is that the client agency needs to appoint "counterpart managers" for each team of TAconsultants. BAPEDAL would have received greater benefits from BDTAP if each of the consultantteams had been able to work with one BAPEDAL staff member as contact point and coordinator. Thecounterpart manager should have sufficient seniority and experience to fully understand the consultant'srequired tasks, to be familiar with the procedures of his or her the agency, to be able to mobilizesufficient staff so that preparation and follow-up work can be completed efficiently by the agency itselfrather than by the consultants, and to carry out review and quality control functions. Ideally this wouldmean selecting as PIMPRO (project manager) a technical person representing the unit(s) that would beimplementing the TA component outputs. For BDTAP, this would have meant having more than onePIMPRO, requiring a change in Indonesian regulations that presently allow one PIMPRO per project.Another way to achieve nearly as good a result would be to assign a "program manager" to eachcomponent, appointed by the Deputy for whom the consultants were producing the majority of thedeliverables.

51. Emphasize wider ownership by senior BAPEDAL staff "stakeholders". Such counterpartassignments could also have helped to break down the "that's Deputy I's project" attitude that inhibitedparticipation by the other deputies in BDTAP. The responsibility for Legal would then have fallen underDeputy 1I and that for Labs under Deputy III. Regional, Training, and Staff would have remained withDeputy I. 52. The damaging internal communication barriers could perhaps have been overcome ifmore of the mid-level managers had been involved in decisions about the content of BDTAP components,hence feeling ownership of the outcome. A number of the managers complained during ICR interviewsthat they were not asked for their comments on terms of reference and draft deliverables, or that noaction was taken in response to the inputs they gave. But, to be fair to the consultants and theirBAPEDAL technical counterparts, probably an equal number of managers made no effort at suchparticipation.

53. Provide for access to project outputs. Difficulty obtaining materials produced by BDTAP hasbeen a complaint from BAPEDAL staff and from consultants from other projects. TA project designshould explicitly include plans and funding for a repository of study outputs and a mechanism fordistributing the materials to potential users.

11

PART II: STATISTICAL TABLES

TABLE 1: SUMMARY OF ASSESSMENTS

A. Achievement of Objectives Substantial Partial Negligible Not applicableMacro Policies D 0 0 QSector Policies 0 0 0 z

Financial Objectives a Q 0 [EInstitutional Development 0 0l 0] 0Physical Objectives Q 0 0 0Poverty Reduction a El 0 a0

Gender Issues 0 al El 0Other Social Objectives Q Q 0 0Environmental Objectives 5 5 El EEPublic Sector Management a 5 0l Private Sector Development a D D 0Other (specify) 5 5 a 03

B. Project Sustainability Likely Unlikely Uncertain

C. Bank Performance ghlySatisfactory Satisfactory Deficient

Identification 0 0 ElPreparation Assistance 0 0l 0lAppraisal Cl 0E 0Supervision 0 E E

D. Borrower Performance HighlySatisfactory Satisfactory Deficient

Preparation D E 0.Inplementation l 0 ElCovenant Compliance a 3 ElOperation (if applicable) El El El

E. Assessment of Outcome Highly HighlySatisfactory Satisfactory Unsatisfactory unsatisfactory

Ol [ El D

TABLE 2: RELATED BANK LOANS/CREDITS

Year ofLoan/credit title Purpose approval Status

Loan 3246-IND, Third Urban development, but included study of institutional 1991 Ongoing,JABOTABEK Urban arrangements for environmental management in area. SatisfactoryLoan 3000-IND, Agric. Dev., but included study of env. mgt. institutional 1989 ClosedTree Crop Processing arrangements for N. Sumatra and W. Kalimantan

12

TABLE 3: PROJECT TIMETABLE

Steps in Project Cycle Date Planned r Actual Date

Identification (Executive Project Summary) September 1991 September 1991

Preparation (start/complete) May 91/Jan 92 May 91/Jan 92

Appraisal January 1992 January 1992

Negotiations May 1992 February 1992

Board Presentation June 1992 March 1992

Signing May 1992

Effectiveness August 1992 December 1992

Midterm review (if applicable) September 1995 November 1995

Project Completion February 1997 June 1997

Loan Closing June 1997 December 1998

TABLE 4: LoAN DISBURSEMENTS: CUMULATIVE ESTIMATED AND ACTUAL

Date I Cumulative ] Estimated ] Actual I Act./Est.

30-Jun-92 977,822.17 977,822.17 --

01-Jul-93 1,249,883.78 1,000,000 272,061.61 27%

01-Jul-94 4,380,548.26 3,000,000 3,130,664.48 104%

01-Jul-95 7,582,446.32 3,500,000 3,201,898.06 91%

01-Jul-96 11,428,323.61 2,500,000 3,845,877.29 153%

01-Jul-97 11,695,761.19 2,000,000 267,890.32 13%

01-Jul-98 11,695,761.19 0 0 --

30-Apr-99 12,000,000.00 0 304,238.91

TABLE 5: KEY INDICATORS FOR PROJECT IMPLEMENTATION2

l______T Key Indicators Outcome

1 Specific elements of new legislation identified Complete

2 Interagency agreements or informal arrangements formulated Partial

3 Pollutant discharge permit system designed and implemented Partial

4 Number of test enforcement and compliance cases None

5 3 to 5 regional/provincial enviromnental agencies established Complete

6 Plan for laboratory training and certification developed and tested Partial

7 Annual growth in BAPEDAL staff complement Complete

8 Annual growth in BAPEDAL operating budget Complete

9 Amount of external funding obtained by BAPEDAL Complete

2 Indicators for preject implementation were not identified in the MOP but were derived from the MOP in 1996.

13

TABLE 6: KEY INDICATORS FOR PROJECT OPERATION3

F- Key Indicators

1 Regulations supporting new legislation drafted and signed

2 Interagency agreements or informal arrangements finalized

3 Pollutant discharge pernit system implemented

4 Number of test enforcement and compliance cases

5 Plan for laboratory training and certification implemented

6 Annual growth in BAPEDAL staff complement

7 Annual growth in BAPEDAL operating budget

TABLE 7: RESULTS OF TRAINING AND TECHNICAL ASSISTANCE

Component Topic & Training Method Date(T = formal training course, W = workshop)

Legal Environmental Law Enforcement for State Police (T) 8/95Refining the Academic Draft for Environmental Management Law (W) 8/95Discussion on Academic Draft for Air Quality Regulation (W) 8/95

Discussion on Draft of Environmental Management Law (W) 10/95Development of Licensing and Environmental Law Compliance System 5/97

Regional Joint Technical Working Team (BAPEDAL, PPLH) (W) 1/95Establishment of BAPEDALDA I AND II (W) 2/95Joint Technical Working Team (BAPEDAL, PPLH ) (W) - x 9 1/95-6/95BAPEDAL Wilayah Organizational Structure (W) 5/95Roles of BAPEDAL Wilayah/BAPPEDALDA (W) 6/95

BAPEDAL Ministerial Decree for Regional Organization (W) 6/95-9/95Central and Regional ITraining Needs Assessment (W) - x 5 8/95-10/95Working Relationships for Environmental Management (W) 4/96-8/96Forest Fire Management (W) 5/96

BAPEDAL Wilayah and Pemda Introductions (W) - x 3 5/96-8/96

Comparative Study Tours to NZ, USA & Canada 7/96-11/96Development Plans for BAPEDAL Wilayah (W) - x3 8/96-10/96

.____________ Finalizing BAPEDAL Wilayah Development Plans (W) x 2 3/96-4/96Laboratories QA/QC Practices for PROKASIH Analysts (T) 1/96

Analytical Criteria for Indonesian Laboratories (T) 1/96-2/96Wastewater Discharge Permits (with Legal) - x 2 (W) 3/96

Basic QA/QC Practices for Laboratories (T) 4/96

Technical Workshop on Laboratories (W) 6/96Overseas Training (Canada) - QA/QC (T) 7/96-8/96Application of QA/QC Methods (Regional) - x 27 provinces (T) 1996/97

Staff & HRD Workshops for Functional Positions (W) 1997Training Computer Skills (T) . 12/94

English Language (T) 4/95-6/95

3 Operation indicators were not identified in the MOP. These indicators have been chosen to reflect: (i) completion of activitiesthat remained outstanding at the end of BDTAP implementation and (ii) continuing growth in capacity and expansion ofoperations.

14

Office Management for Support Staff (T) 4/95-6/95

Training of Trainers - Facilitation (T) 7/95Training of Trainers - AMDAL (T) 9/95Approaches to Environmental Management (T) 10/95Preparing a Matrix for Functional Positions (W) 5196Environmental Management Technical Training (T) - x 89 5/96-4/97Improving Environmental Law Compliance (W) 8196Strengthening Enviromnental Law Enforcement - (T) 8/96Preparation of SOP for Training Administration (W) 8/96Coastal Zone Management - (T) 11/96Secretarial Staff Skills (T) 11/96Training Curriculum Development (W) - x 3 1/97-4/97Improving Community Awareness and Education (W) 4/97Environmental Executive Management (T) 6/97

TABLE 8A: PROJECT COSTS (US$ MILLION)4

_ _ _ _ _ _ _ _ _ _ J Appraisal Estimate _ Actual

Item Local | Foreign [ Total Local Foreign l Total

Strengthening BAPEDAL's Mandate 0.6 1.0 1.6

Pollution Control Systems 1.6 2.5 4.1

Legal Mandate, Enforcement & Compliance 2.471 1.800 4.271

Regional Agency and Laboratory Support 1.7 3.0 4.7

Regional Institutions 1.744 0.516 2.260

Regional Laboratories 0.831 0.683 1.514

Recruitment and Training 1.3 0.7 2.0

Staff Acquisition & HRD 0.609 0.198 0.807

Training 0.673 0.618 1.291

External Resources Administration 1.1 0.8 1.9

Project Management Office 1.103 1.728 2.831

Contingencies 0.4 0.3 0.7

BAPEDAL Building Renovations 1.067 1.067

Forest Fire Emergency/Implementing Regulations 0.339 0.339

Total 6.7 8.3 15.0 8.837 5.543 14.380

4 Names of components were modified between appraisal and implementation, In the table the name of the original componentand proposed amount are given on one line, followed by the samne information for the actual implementation contract(s); theoriginal names and amounts are in italics.

15

TABLE 8B: PROJECT FINANCING (US$ MILLION)

l ~~~~~~~~~~~~~Appraisal Estimate Actuall

Source Local ApForeisa Total Local Foreign [Total

GOI 2.6 - 2.6 2.380 0.0 2.380

Japan Grant 0.1 0.3 0.4 0.0 0.0 0.0

IBRD 4.0 8.0 12.0 6.457 5.543 12.000

Total 6.7 8.3 15.0 8.837 5.543 14.380

TABLE 9: ECONOMIC COSTS AND BENEFITS

Not applicable.

TABLE 10: STATUS OF COVENANTS IN LOAN AGREEMENT

OriginaltSection Type Status Fulfillment Description of Covenant Comments

Date2.02 (b) 01 C 2/28/93 GOI to open and maintain a

l_____ _______ Special Account3.01 04 C 9/22/93 BAPEDAL provide manage- Some delays in counter-

ment and resources as needed part staff appointments3.02 05 C 12/92 BAPEDAL employ consultants Effectiveness condition

for donor coordination3.03 09 CP 12/15/94 BAPEDAL provide copies of Number of reports and

l____ ______ reports to Bank outputs still outstanding

3.04 05 CD 9/20/30 BAPEDAL prepare a detailed Plan prepared, updatedannual work programn, in annually, but not used aaccordance with 5-year guide to annual workdevelopment plan program or budget.

3.05 05 C 9/20/93 BAPEDAL maintain Project Operated welll____ _____ Management Office supporting BAPEDAL

4.01 (a) 01 C 9/20/93 BAPEDAL maintain financialrecords and accounts

4.01 (b)(i) 01 CD 9/21/93 BAPEDAL arrange for audit All audits unqualified,some late.

4.01 (b)(ii) 01 CD 12/31/94 BAPEDAL provide Bank with Some reports receivedaudit reports late.

4.01 (b)(iii) 09 CP 9/21/93 BAPEDAL to provide the Bank No systematic provisionwith other related reports of reports

4.01 (c) 01 C 9/21/93 BAPEDAL to maintain recordsfor statements of expenditures l

6.01 05 C 12/92 BAPEDAL to employ PMO Effective in assistingand donor coordination advisor with all donors

Covenant Class: Status:I= Accounts/audits 8 = Indigenous people C = covenant complied with2= Financial performance/revenue 9 = Monitoring, review, and reporting CD = complied with after delay

generation from beneficiaries 10 = Project implementation not CP = complied with partially3= Flow and utilization of project covered by categories 1-9 NC = not complied

funds I1 = Sectoral or cross-sectoral4= Counterpart funding budgetary or other resources5= Management aspects of the allocationproject or executing agency 12 = Sectoral or cross-sectoral policy/6= Environmental covenants regulatory/institutional action7= Involuntary resettlement 13 = Other

16

TABLE 1 1: COMPLIANCE WITH OPERATIONAL MANUAL STATEMENTS

The project is in compliance with all applicable operational manual statements.

TABLE 12: BANK RESOURCES: STAFF INPUTS

FY 1992 1993 [ 1994 | 1995 [ 1996 | 1997 | 1998 | 1999 [ Total l

Preappraisal 84.1 84.1

Appraisal 0.9 0.9

Negotiations 8.5 8.5

Supervision 5.9 24.1 35.9 38.7 40.0 44.8 5.9 195.3

Completion 15.6 5.2 20.8

Totals 99.4 24.1 35.9 38.7 40.0 44.8 21.5 5.2 309.6

TABLE 13: BANK RESOURCES: MISSIONS

Number PerformanceStage of Date of Days in Skills Ratings /b Type of problems

project cycle persons field represented /a IS DO

Identification 9/91 NA NA NA

Preappraisal 11/91 6 17 IS/TL,ENV l

Appraisal 1/92 2 10 IS/TL,ENV

Negotiations 2/92 3 NA IS/TL,LC l

Supervision 1 9/93 3 17 IS/TL,ENV,EE 2 1 Effectiveness delays; slow.1___ |____ assembly of bidding teams

Supervision 2 12/94 2 14 ENV/TL,ENV, S S Long time lag betweenLE effectiveness and engagement

of consultants; impending:-_______ |___ reorganization of BAPEDAL.

Supervision 3 11- 3 18 ENV/TL,ENV, S S Major slippage in Trainingand 12/95 IS curriculum development; lack

Mid-Term of participation by Deputies IIReview and III; inadequate staff-

consultant interaction

||Supervision 4 2-3/97 3 11 ENV/TL,ENV, S S Lack of participation byI IS Deputies II and III

Completion 8-12/97 3 20 ENV/TL,ENV S S Final supervision of maincomponents; lack ofparticipation by Deputies II andIII; loan closing extended toassist BAPEDAL with forestfire management, and ICRcompletion deferred

IICR 6/99 1 1 ENV/TL S S Brief mission to obtain

I Li l Borrower's Contribution to ICR

/a TL: Task Team Leader; IS: Institutional Specialist; ENV: Environmental Specialist; LC: Legal Counsel; LE: Legal Expert/b 1: No significant IL oblerns; 2: Moderate problems; HS: Highly satisfactory; S: Satisfactory; U: Unsatisfactory; HU: Highly Unsatisfactory

17 ANNEX A

ANNEX A: BORROWER'S CONTRIBUTION TO THE ICR

None was provided.

18 ANNEX B

ANNEX B: ICR MISSION AIDE MEMOIRE

INTRODUCTION

1. A World Bank mission consisting of Mr. Thomas Walton (RSI - Mission Leader) and Mr. SeanFoley (Consultant) conducted supervision of BDTAP beginning August 4 and ending December 12,1997; the mission also prepared a Draft ICR which was provided to BAPEDAL for comment but is nowon hold because the loan was reopened and extended to assist BAPEDAL with the forest fire emergency.This aide memoire presents the mission findings and recommendations, which are subject to confirmationby Bank management. The mission worked closely with BAPEDAL senior staff, and held discussionswith other involved government departments, other donors supporting BAPEDAL, and team leaders ofprojects currently being implemented in BAPEDAL. As the BDTAP contracts had been completed priorto this mission (June 30, 1997) it was not possible to hold discussions with BDTAP team leaders or theProject Management Office (PMO). The mission wishes to thank BAPEDAL for its courtesy andcooperation during the supervision, and in particular for the active involvement of Deputy I, the Directorsfor Program Development and Institutional Development, and the Directors of almost all otherBAPEDAL Divisions.

2. The mission's objectives were to: (i) review the final outputs and completion reports from theBDTAP consultants; (ii) assist BDTAP management in clarifying any outstanding issues relating toBDTAP completion; and, (iii) discuss possible follow-up activities with BAPEDAL senior management.

3. The five BDTAP consultants submitted their Final Reports to BAPEDAL in June 1997. Themission reviewed these reports and discussed overall project progress and issues with relevantBAPEDAL senior staff and others. The complete list of outputs from the BDTAP consultants is presentedin Annex 1.

4. A number of significant outputs that were finalized during the last months of the project (andsomewhat beyond) and a number of outstanding issues requiring decisions from BAPEDAL seniormanagement are considered important enough to deserve attention in their own right, separate from theDraft ICR. Thus this aide memoire for the supervision mission, which covers only the brief periodMarch-June 1997, is presented separately from the Draft ICR which covers the full duration of the projectfrom 1993-97.

5. In June 1997, the project closing date was extended by one month to July 31, 1997, so as toprovide support for the consultation processes associated with Parliament (DPR) debating amendments toUU 4/82 and allow time for completion of some important outputs.

6. The mission notes that all of the BDTAP consultants provided material and advisory support toBAPEDAL well beyond that formally required by their TOR. BAPEDAL senior management andnumerous other staff have voiced their appreciation to the mission of this unstinting support.

7. No wrap-up meeting could be scheduled because of the demands placed on BAPEDAL staff bythe forest fire emergency. However, an earlier draft of this aide memoire was forwarded to theBAPEDAL Vice-Chairman, all BAPEDAL Deputies, and the Director of Program Development onOctober 16, 1997. It has since been updated to reflect the change in mission designation and extension ofthe loan.

19 ANNEX B

MiSSION FINDINGS, RECOMMENDATIONS AND AGREEMENTS

8. BAPEDAL's overall institutional development has maintained its pace during the final period ofthe project, and a number of major initiatives supported by the project were bought to fruition. The mostsignificant achievements during the mid- 1997 period are listed below.

* The signing into law in late September of Act 23/1997 making fundamental amendments tothe Basic Environmental Law (UU 4/1982) - this is a major achievement for BAPEDAL, andone of the primary institutional objectives of BDTAP.

* The formal establishment by DG BANGDA, with critical support from BAPEDAL via theRegional consultant team, of BAPEDALDA Tk. I (Provincial BAPEDAL under theGovernor's authority) in 24 locations; and the inception of a process whereby at least 65BAPEDAL Tk. II will be established. Most of these so far exist only on paper but areexpected to be operational in the next fiscal year.

* The promulgation on October 13, 1997 of a new Ministerial decree (KepMenLH 45/97) of anindex for air quality standards (Indeks Standar Pencemar Udara). This conforms closely withthe air quality indices used by other ASEAN nations, but lacks a formula for calculating therelative contribution of the five parameters (PMIo, CO, S02, NO2 and 03) to the index.

- Substantial increases of the staff complement of the three BAPEDAL Wilayah: UjungPandang (South Sulawesi), Denpasar (Bali) and Pekanbaru (Riau), and implementation ofcontinuing staff training programs (most supported by other donors).

- BAPEDAL's budget for FY 1997/98 is Rp 39.84 billion, two thirds greater than FY 1996/97of Rp 29.2 billion. BAPEDAL.

* Since the end of 1996, BAPEDAL has grown by 121 staff (central 268, PUSARPEDAL 73,Regions 55/52/53), bringing the total staff complement to 590 as of August 1997. Since thelast mission BAPEDAL has confirmed advance authorizations to achieve a staff complementof about 1,000 (Central 530, PUSARPEDAL 150, Regions 120/100/100) by the year 1999.

- Since the last mission the following loan and grant funding has become effective (amountsare approximate): Environmental Biology and Regional Laboratories, AusAID A$ 34 millionfor upgrading 21 regional laboratories; the second Pollution Abatement Equipment (PAE II),OECF US$ 200 million; and BAPEDAL Regional Network Project, ADB US$ 45 million.

9. During the final part of the project, interaction between BAPEDAL staff and the BDTAPconsultant teams continued to improve. In this period most of the written material was finalized and, inmost cases, time was available for BAPEDAL staff to review and discuss this material with individualconsultant teams. In both verbal and written reports BAPEDAL senior staff and BDTAP consultantsexpressed their belated wishes that communication could have been more effective and closer muchearlier during implementation; both sets of parties, in large part, attribute the lacks in communication tothe youth of the organization when the project started.

10. Since the last mission, a new draft of the Regional Laboratories MOU between BAPEDAL andthe Departments of Public Works, Industry and Health has been prepared and circulated. The number ofgovernment agencies involved had been extended to include the environmental units in BAPPENAS andBANGDA, the latter as representatives of BAPEDALDA. However, a review of the draft MOU indicatesthat a number of issues remain to be clarified: e.g. (i) the scale and sources of funding required; (ii) theactivities and responsibilities for implementing the proposed environmental quality monitoring programand, related to this; and, (iii) the respective roles of BAPEDAL and provincial governments with regardto coordination of environmental monitoring and reporting. BAPEDAL is still awaiting responses from

20 ANNEX B

these departments and agencies and the MOU remains unsigned. Given the near-term start-up of OECFand AusAID funded laboratory projects, the mission urged BAPEDAL to complete the MOU withoutfurther delay.

11. The issue of safeguarding, distributing and facilitating access to the large body of legal,organizational and technical material that has been prepared under BDTAP was raised in the previoustwo aide memoires. It is important that it be made accessible to the large number of new projects that arejust starting to prevent duplication of material and increase the new projects' effectiveness. This issuehas not yet been resolved, and the mission is concerned about the number of reports it received fromother consulting teams of difficulty experienced in obtaining BDTAP outputs. The need for clarifyingauthorization and distribution procedures for this material is now more urgent, but to-date remainsunresolved. The mission again stressed the urgency of this to BAPEDAL senior management.

TABLE 1.SUMMARY OF MAJOR AGREEMENTS WITH BORROWER

AND FURTHER ACTIONS TO BE TAKEN

ACTION RESPONSIBLE IBRD TIMEAGENCY OBLIGATION FRAME

Loan disbursement cut-off, all invoices must be BAPEDAL 11/30/97submitted so that payments from the SpecialAccount are completed by this timeReview and finalize Regional Laboratory MOUs BAPEDAL Technical advice 01/31/98with other agencies for rehabilitation, equipment,services and cost sharingClarification of responsibilities for obtaining BAPEDAL 01/31/98formal approval for distribution of outputsIdentification of practical arrangements (CD- BAPEDAL Technical advice 01/31/98ROM recommended) including funding, fordistributing outputs to usersEstablish central repository/library for all BAPEDAL Technical advice 01/31/98BDTAP outputs, and advise all BAPEDAL staffand consultants of materials availableDraft ICR - Bank contribution by 10/3 1, BAPEDAL Draft ICR (Bank) 10/31/97BAPEDAL review and contribution by 11/30 11/30*

*Note: with the extension of BDTAP that was approved 11/27/97, ICR submission has been deferred. Afinal draft will be prepared during a follow-on ICR mission beginning on or about 6/1/98. In theinterim, a new version of the Bank's present draft will be sent for BAPEDAL review. We hopethat draft can reflect progress on the issues identified above.

ASSESSMENT OF BDTAP PROGRESS

Summary of General Issues

12. The mission reviewed the Final Reports and conducted interviews with BAPEDAL seniormanagers and key personnel to assess the final status of the project. The results and general issues aresummarized below, and achievements and issues relating to each of the components are briefly discussedin subsequent sections. Actions and recommendations to address outstanding issues are summarized inTable l above.

21 ANNEX B

* BAPEDAL management needs to ensure that all invoices and any outstanding disagreementswith consultants concerning final payments are finalized so that all disbursements arecompleted by November 30, 1997. [Note: this was completed on time.]

* Draft implementing regulations (Ministerial Decrees - KepMen) need to be issued for UW23/97 (new Environmental Management Law) so the it can be bought into force. This is amatter of some urgency, given the rapid expansion of regional environmental capacity.

* Their is urgent need to fully integrate all aspects of staff recruitment, training and careerpaths within a unified database, especially given BAPEDAL's plans to almost double its staffcomplement during the next 2-3 years.

* BAPEDAL (and DG BANGDA) need to formalize without further delay the workingagreements clarifying roles and responsibilities for BAPEDAL Wilayah and BAPEDALDA;

* BAPEDAL needs to assess the pace of decentralization and deconcentration. The imminentincrease of the number of BAPEDALDA will place significant demands for support from theBAPEDAL regional offices.

* There is still confusion as to what formal management approval ("sign-off", if any) for thebroad range of training, guidance, and technical reference material produced under BDTAPis required, so as to allow distribution without delay. The start-up of the ADB RegionalNetwork Project, and the OECF and AusAID assistance to regional laboratories makes thiscritical. The mission suggests that a letter of instruction from the Minister may be thesimplest and quickest means of achieving this.

* It is essential that BAPEDAL implement practical arrangements for distributing the referenceand guidance material produced under BDTAP to users, including BAPEDAL Pusat andWilayah, BAPEDALDA, the 60 regional laboratories and industry has been stressed in atleast the last two supervision missions but has not yet been adequately addressed. Themission suggests that Deputy I be given responsibility and authority for organizingdistribution.

* There is an urgent need to clarify, strengthen and finalize the Regional Laboratory MOU forcooperation and operations, including training, between BAPEDAL and the Departments ofPublic Works, Industry and Health, including specification of implementation protocols, andfinancial and operational and maintenance responsibilities.

* There is an equally urgent need for BAPEDAL management to prepare a realistic, medium-term plan for funding regional laboratory operations, including a scale of user charges, giventhat it is unlikely that sufficient funding will be available from government sources. The scaleof costs anticipated has major implications for BAPEDAL's overall budget.

* To sustain the usefulness of BDTAP outputs, BAPEDAL management needs to prepare astrategic operational plan based on the elements of BDTAP and linked to continuingimprovements in BAPEDAL's own capacity and anticipated outputs from ongoing projects.

Legal Mandate, Enforcement and Compliance Program (Legal)

13. Outstanding issues requiring attention from BAPEDAL's senior management include:* preparation and issuance of a significant number of implementing regulations (KepMen)

before UU 23/97 can be brought into fully into force. This is a matter of some urgency, giventhe rapid expansion of regional environmental capacity;

22 ANNEX B

* completion and issuance of "Air Quality Regulations", "Marine Pollution ControlRegulations" and "Emergency Response System(s)" under the newly amended Act; and,

* discharge parameters and related discharge fee structures for water and air discharges, andguidelines for permit writing, on-site inspections, and targeting violators - need to befinalized and officially issued by the Minister or his Deputy, and then put into operation.

14. The work of this component culminated in the signing of Act 23/1997, the new EnvironmentalManagement Law, by the President on September 19, 1997. During July and August the amendmentswere discussed intensively by the Commission X (environment) of the DPR (parliament), and theMinister was supported in his presentations to the Commission and other discussions by BAPEDAL andTeam A staff. In addition, Legal Team A completed academic drafts of the "Air Quality Regulations","Marine Pollution Control Regulations" and "Emergency Response System(s)," and these were discussedin a series of workshops, leading to incorporation of a number of changes. However, delays in finalizingUU 23/97, upon which these regulations depend, means that their approval by SekKab and signature bythe President will be delayed. The delays were clearly beyond the control of the consultants orBAPEDAL. BAPEDAL senior management estimates that implementation of UW 23/97 will require thepreparation some 1 1 new Ministerial Decrees to effect implementation of BAPEDAL's new powers andresponsibilities. (An English language translation of the text of the amendments is currently beingfinalized by the AusAID-funded Pollution Control Implementation Project.) The main features of WU23/97 are outlined in Annex 3. [Annex 3 omitted from ICR version of this aide memoire because of itslength.]

15. Legal Team B completed work on the Enforcement and Compliance Protocols (English andIndonesian versions) for a range of issues; these are listed in Annex 1. This was followed-up by fieldworkand providing staff with practice in conducting inspections and writing permits, provided continuingsupport to BAPEDAL staff in a range of technical issues, e.g. B3, MIS and emergency response. Team Balso provided support and advice on a wide range of issues beyond the requirements of their formal TOR,this continued during the final period of the project.

Regional BAPEDAL Institutional Development Program (Regional)

16. Outstanding issues requiring attention from BAPEDAL's senior management include:

* agreements clarifying roles and responsibilities for BAPEDAL Wilayah and BAPEDALDA;

* the need for management to seriously consider whether or not BAPEDAL is decentralizingand deconcentrating effectively and rapidly enough; and

* at both the central and regional levels, additional guidance from management to clarify therespective roles of BAPEDAL, DG BANGDA and BAPEDALDA regarding theimplementation of the ADB Regional Network Project.

17. The consultants completed the academic and legal drafts on the working relationships betweenBAPEDAL Pusat and Wilayah; drafts were completed for guiding the relationship between BAPEDALPusat and Ministry of Environment. Draft Development Plans for BAPEDAL Wilayah, based in part oninputs from workshops were completed. Despite these consultations, the mission received commentsfrom a number of stakeholders that the material was too theoretical and legalistic, and insufficientlypractical. Almost all work on the ten Technical Operating Guidelines was completed and four workshopsto introduce, explain and discuss these guidelines were conducted using funds reallocated from the StudyTours budget. There have been complaints that some of this material is repetitive and overly theoretical.The remaining outstanding items were completed by the consultant during the mission.

23 ANNEX B

18. Detailed discussions by the mission with the heads of BAPEDAL Wilayah have shown that thework performed by the component in facilitating the clarification and structuring of the role andresponsibility of BAPEDALDA, and the likewise the working relationships between BAPEDAL Wilayahand other provincial-level agencies (including BAPEDALDA) was invaluable and greatly appreciated.However, they expressed disappointment that this effective, practical approach was not reflected in thewritten output. (This work is being continued under the ADB Regional Network Project by the sameconsultant.) They also noted that it is vital that the working agreements regarding roles andresponsibilities be formalized without delay, and at the latest before the end of 1997.

19. At both the central and regional levels, additional guidance from management is required toclarify the respective roles of BAPEDAL, DG BANGDA and BAPEDALDA regarding theimplementation of the ADB Regional Network Project. The mission wishes to draw this need toBAPEDAL management's attention, as this new project will build upon the work done by this BDTAPcomponent and is essential for reaping longer-term benefits from the component's outputs.

20. The mission is also concerned that decentralization and devolution of responsibilities andactivities, and funds to support these, may be not be occurring quickly enough. In a number of instanceswhen this issue was discussed, the response from senior/middle management was that the regional officeswere unprepared and/or insufficiently experienced to take over a program. This presents BAPEDAL withthe classic problem, assuming that decentralization is to be seriously pursued, of how to rapidly providethe on-the-job training that will prepare the regional staff to take over local operational responsibility fornational programs. In this respect it is worth noting that many of these programs are handled in Jakarta byyoung, relatively inexperienced staff who have only been working with BAPEDAL for a year or two.Hence, the argument for slow or no decentralization, due to lack of experience at the regional level, ringssomewhat hollow. Moreover, the mission is of the opinion that BAPEDAL may be in danger of losing ordemoralizing young, committed regional staff unless they have (what they consider to be) a substantialand active role to play in BAPEDAL's operations.

Regional Laboratories Development and Certification Program (Labs)

21. Major outstanding issues affecting the sustainability of the outputs from the Labs program arelisted below; they remain substantially the same as those identified during the last mission:

* The urgent need to clarify, strengthen andfinalize the Regional Laboratories MOU for laboratorycooperation and operations, including training, between BAPEDAL and the Departments ofPUBLIC WORKS, Industry and Health, including specification of implementation protocols, andfinancial and maintenance responsibilities.

* An equally urgent need for BAPEDAL management to prepare a realistic, medium-term plan forfunding regional laboratory operations, including a scale of user charges, given that it is unlikelythat sufficient funding will be available from government sources. The scale of costs anticipatedhas major implications for BAPEDAL's overall budget.

* The need tofinalize whether or not formal approval ("sign-off") for the technical referencematerial is required, so as to allow distribution without delay - the near term start-up of OECFand AusAID assistance to regional laboratories makes this critical.

* The need to identify and implement practical arrangements for distributing this material to users,including BAPEDAL Wilayah, BAPEDALDA Tk. I, the 60 regional laboratories and industry;the need to identify means for monitoring actual use by laboratories, providing up-dates anddelivering post-BDTAP follow-up support.

24 ANNEX B

22. The work of this component was fully completed and all materials and reports required by theTOR have been submitted to BAPEDAL. As noted in the previous aide memoire, the consultant hasprovided BAPEDAL, and through them other departments and agencies, with a comprehensive set offirst-class materials for laboratory standards, procedures and QA/QC. In many respects the consultant hasexceeded the requirements of the TOR, especially with regard to training where seven times the specifiednumber of staff (from BAPEDAL and other agencies) from 27 provinces were trained.

23. With regard to International Accreditation, the consultant provided the EnvironmentalManagement Center (PUSARPEDAL) with a plan for achieving accreditation based on ISO guidelines;systematic performance audits based on a questionnaire covering 15 criteria were recommended ascentral to the process of accreditation. Despite the formal requirement of the TOR to achieveinternational accreditation during the project, BAPEDAL senior management have accepted that this isnot be possible, given that overseas experience clearly indicates that a minimum of two years is required.

24. As noted above, the issue of the MOU remained outstanding at the time of the mission. In brief,the new draft - referring explicitly to the 39 laboratories to be funded by OECF and the 21 to be fundedby AusAID - is being circulated for comment/signature from the agencies involved. The details of what itproposes are summarized in Annex 2.

25. The estimated annual operating costs of these laboratories are substantial - somewhere betweenRp 10-20 billion per annum; details are given in Annex 2. The issue of how these costs will be funded(especially in the current economic climate) or a substantial proportion recovered by user charges has notbeen resolved by BAPEDAL. The need to address this issue is made more urgent by the near-termimplementation of the OECF and AusAID projects for laboratory upgrading and the consequent need forBAPEDAL to establish a firm basis for operational funding. The mission considers it unlikely thatbudgets will be able to support continuing outlays on the scale estimated by the BDTAP consultant.

26. The issue of obtaining formal approval ("sign-off') for materials prepared by this component(and others) still needs to be resolved. In the case of the laboratories - and with two new projects about tocommence - it is important that BAPEDAL senior management decide whether or not formal approval isnecessary before distributing the materials (e.g. laboratory manuals to other departments). If formalapproval is necessary, then this should be provided without further delay; if formal approval is notnecessary, then the relevant divisions in BAPEDAL need to be informed that they are free to proceedwith distribution without delay. This is also an issue that was raised by the last mission and remainsunresolved.

27. Linked to this is the issue of distribution of these materials. The previous mission suggested thatCD-ROM technology be used to distribute the mass of material prepared by the labs component, given itsadvantages of durability, integrity and low cost. This suggestion has been endorsed by the consultant butso far no action has been taken to implement it or to devise an alternative. Given the vulnerability (tofungus) of the diskettes on which the information is currently stored, it is important that the material betransferred to more robust storage media without further delay. This issue should be resolved early in theextended period of BDTAP.

28. The consultant's final report raises many issues relating to sustainability of the Regional Labsupgrading being funded by OECF and AusAID; many of these are practical operational, documentation,financial and training issues that require attention by BAPEDAL's senior management (final report pp.68-93). Even though the Bank-funded assistance to BAPEDAL has been completed, the missionconsiders it important that these issues be actively addressed by senior management, so as to ensure theconsolidation of the results achieved under BDTAP and their continued application.

25 ANNEX B

BAPEDAL Training Program (Training)

29. The consultant has completed and submitted all work and material requiTed by the TOR. Much ofthe work, especially training plans and material, will be directly useable by BAPEDAL and, as part of theADB-funded BAPEDAL Network project, made use of by BAPEDALDA staff. The achievements ofthis component have been significant in terms of preparing directly usable training materials, especiallygiven that BAPEDAL's Institutional Development and HRD divisions have only been established duringthe course of BDTAP. However, much remains to be completed with regard to HRD and personneltraining and career planning.

30. In the final months the consultant completed preparation of three curriculum clusters:Institutional and Capacity Building (5 courses); Hazardous Waste Control (9 courses); and, LaboratoryManagement (6 courses); these are in addition to material already submitted. Guidelines onadministrative and technical requirements for staff of BAPEDALDA were completed and signed by theMinister. An outline staff training program for BAPEDAL staff (including BAPEDAL Wilayah,BAPEDALDA and other agency staff) for the period 1997-2002 was prepared, drafts of training policies,SOP manuals and standardized documents were completed, and a draft, a modular training evaluationinstrument prepared. Cooperation with the AusAID funded PCI project resulted in progress ondeveloping an MIS for Training and HRD.

Staff Acquisition and Human Resources Development and Management Program (SAHRM)

31. This component was already completed at the time of the last supervision mission. The mainpoints noted by the last mission are repeated below. There appears to have been no action by BAPEDALmanagement on these issues.

32. Three main issues raised in the last aide memoire remain outstanding. There is still a lack of jobdescriptions, except for staff at or above Echelon III. As a consequence of this, and lack of personalinformation on staff, no usable HRD database has been established. It has therefore not been possible forBAPEDAL (or the consultant) to develop career paths for staff. Assembling this information is clearly amatter for BAPEDAL management to address. These issues have been partially addressed by continuingwork on the part of the PCI project; to-date, they have assembled full personal, professional and trainingdata for about 25 percent of BAPEDAL staff .Despite this effort, it is clear that much more remains to bedone before BAPEDAL has a usable HRD database.

Integrated Comments on Training and SAIIRM

33. Outstanding issues requiring the attention of BAPEDAL senior management include:

* The urgent need to fully integrate all aspects of staff recruitment, training and career paths withina unified HRD database, especially given BAPEDAL's plans to almost double its staffcomplement during the next 2-3 years;

* The need to provide job descriptions for all staff below Echelon III;

* The need to include essential personal and educational details in staff records for all staff belowEchelon III; and

* The need to develop career paths and incentive programs to assist in retaining skilled andcommitted staff.

34. The need for full operational integration between Training and HRD has been noted in previousaide memoires - this is being addressed, but much remains to be done. Given BAPEDAL's plans toalmost double staff size in the coming years, the mission considers it important for BAPEDAL senior

26 ANNEX B

management to address HRD issues raised by the consultant in the Final Report. In the coming years it ispossible that, without a functionally integrated Training and HRD system, BAPEDAL may fail to retainthe younger, more enthusiastic and committed staff that it has so far recruited, or fail to make best use oftheir energy and skills.

35. In addition, the two major points made by the Minister during the last mission are reemphasised,as discussion with the Training consultant indicates that to-date they remain largely unaddressed:

* The need to improve practices for selecting candidates for training, so as to ensure that they were"trainable," and that the training courses were effective in transmitting needed skills andcompetencies, not just "fun."

* The need for a performance evaluation system that "works," i.e. one that links existing staffskills, on-the-job performance, career paths and training achievements.

BAPEDAL Project Management Office (PMO)

36. During the closing stages of the project the PMO ensured that all BDTAP consultants completedtheir work, submitted material outputs to BAPEDAL, handed over equipment to BAPEDAL andsubmitted their Final Reports. The PMO completed work and closed its operations at the end of June1997.

37. During the project the PMO has been successful in facilitating and maintaining communicationsbetween BAPEDAL and BDTAP components, among the five BDTAP components, between BDTAPcomponents and other assistance projects in BAPEDAL, and between BAPEDAL and a wide range ofpresent and potential donors. Partially as a result of PMO's efforts, BAPEDAL now has available to itfunds and expertise from a significant number of donors, and partially through BAPEDAL there is alsosignificant support beginning to be implemented for strengthening regional environmental management atthe regional level, i.e. BAPEDAL Wilayah and BAPEDALDA.

LoAN CLOSURE.

38. There was at the time of the mission a range of substantive issues associated with closure of theloan, which occurred on July 31, 1997; matters associated with preparing the ICR are dealt with under aseparate heading. The major substantive actions required are:

* ensuring that any outstanding disagreements with consultants over final payments are resolvedand all invoices are processed to ensure payment within four calendar months of loan closure, i.e.no later than November 30, 1997, after which the Special Account will be closed and no furtherdisbursements will be permitted under Bank regulations;

* unambiguous confirmation by BAPEDAL of handover of all materials (reference, software,databases and equipment) to the BAPEDAL units responsible for ongoing operation andmaintenance (the procedure implemented by Director of Program Development for SAHRM wasjudged to be effective and was supposed to be the model for other contracts);

* identifying and collecting and (where appropriate) all reference materials prepared under theproject;

* ensuring that relevant materials are'promptly made available to projects that have recently or areabout to start, e.g. ADB, OECF and AusAID; and,

* preparing for a final financial audit of the loan.

The first of these has been accomplished, and all consultants report that they received payment in full.The last one, final audit, can be deferred until after the new loan closure date, June 30, 1998. However,

27 ANNEX B

the annual project and special account audit reports will be due on December 31, 1997. The other threematters still need attention.

IMPLEMENTATION COMPLETION REPORT (ICR)

39. The mission discussed the requirements for the ICR in early 1997 with Deputy I, the Directors ofInstitutional Development and Program Development, PMO and BAPPENAS and provided them withcopies of OP, BP and GP 13.55 (the Bank guidelines for ICR preparation). Agreement was reached onactions required, responsibility and schedule as described below (Table 2). The mission subsequentlymodified the dates to reflect the closing date extension to June 30, 1998. New dates are shown inbrackets.

40. The ICR will primarily assess: (i) the degree of achievement of project objectives; (ii) prospectsfor the project's sustainability; (iii) Bank and BAPEDAL performance; (iv) project outcomes; (v) the planfor the project's future operations; and, (vi) identify lessons leamt from implementation.

FUTURE ASSISTANCE TO BAPEDAL

41. Possible follow-on work was discussed during the mission, but the forest fire emergencyprecluded any decisions except to reopen the loan and expend the remaining balance (approximately$300,000) for three projects: development of standard operating procedures for forest fires, developmentof an information system for fires and similar environmental disasters, and establishment of a forest fireresearch and training center in Palangkaraya, Central Kalimantan. TORs should be finalized andsubmitted to RSI as soon as possible so that the work can be completed before the next dry season.

TABLE 2. ICR PROCESSING SCHEDULE

ACTION RESPONSIBILITY TARGET DATE

Advise borrower on ICR steps and data Bank (supervision mission) 02-03/97 (completed)requirements.

Prepare/update plan and performance BAPEDAL submit to Bank 06/97indicators for operational phase of [04/98]project.

Accumulate data for ICR. Bank (RSI)/BAPEDAL (PMO) submit at start of ICRmission

Conduct ICR Mission and review Bank (RSI)/BAPEDAL 08-10/97operational plan; provide preliminary [06/98]views in aide-memoire.

Prepare draft ICR and submit to Bank (RSI) 08/97BAPEDAL for comment [07/98]

ICR Workshop BAPPENAS/BAPEDAL/Bank 10/97 [07/98]

Prepare borrower's evaluation and BAPEDAL/BAPPENAS 10/97comments on Bank's draft. [09/98]

Prepare ICR for internal review and Bank (RSI) 11/97clearance. [10/98]

28 ANNEX B

Print and distribute ICR to Bank staff, Bank (RSI) 12/97borrower agencies [11/98]

Transmit ICR to Bank Board Bank 01/98 [12/98]

OED comments to management and Bank (Operations Evaluation 02/98Board Departnent) [01/99]

BAPEDAL DEVELOPMENT PLAN

42. The annual revision of the Five-Year BAPEDAL Development Plan, required by loan covenant,was submitted on April 22, 1997.

ANNUAL FINANCIAL AUDIT

43. RSI received unqualified financial reports of BPKP audits on February 19, 1997 for FY 1996/97for the Special Account and the project. The audit reports for FY 1997/98 are due December 31, 1997.

29 ANNEX B

ANNEX 1SUMMARY OF OUTPUTS (1993-97) FROM ALL BDTAP COMPONENTS

This Annex summarizes the outputs of each of the six BDTAP components.

BDTAP Legal Mandate Development

The Amendment to Undang Undang 4/1982 had its second reading in DPR during July to September1997, and was signed into law at the end of September. Regulations for the Draft Marine, Air and WaterPollution Control Regulations, the Draft KepPres for Emergency Response, and the existing WaterPollution Control and Environmental Impact Assessment Regulations will need to be revised to be inaccordance with the Amended Environmental Management Act. Many new and revised supportingGuidelines (Pedoman) and Directives (Keputusan) will be needed. The Legal Drafting Team assistedMLH and BAPEDAL during final debate of Amendments to WU 4/92 in the DPR during June -September, 1997.

BDTAP Enforcement & Compliance Systems

The Enforcement and Compliance Systems Development Team has completed technical advisoryand training services to BAPEDAL as per their Terms of Reference.

Enforcement & Compliance Protocols completed include:

SOP's for Discharge Permit Writers

SOP's for Environmental Inspectors

SOP for Environmental Investigations

Model Waste Water Discharge Permits for 22 Industries.

Enforcement & Compliance Systems Advisory team technical assistance included:

BAPEDAL Management Information Systems Design

Hazardous Wastes Management Support

Guidance for Calculating LD5O Values for B3 Wastes

Emergency Response System Recommendations

Emergency Response System software

Recommendations for an Environmental Fund.

Assistance to AMDAL Directorate

Review of PT Freeport Environmental Audit

Support to JAGA NUSA enforcement cases

Workshops with BAPEDAL Wilayah 1, III and 111.

Enforcement & Compliance Systems Training & Transfer of Knowledge

Environmental Inspectors Training - Indonesia

Environmental Inspectors Safety Training - Indonesia

Internship Program with Environmental Protection Agency - in USA

30 ANNEXB

Kantor Wilayah Office Administration Training - 1, 11 & III.

BDTAP Regional Institutional Development Program

The Regional Institutional Development team have completed the substantive deliverables oftheir Terms of Reference as agreed with BAPEDAL. Outputs included:

"Integrated Environmental Management." This Concept Paper presented concepts and options forthe decentralization of environmental management in Indonesia and served as the Team'sfoundation policy and strategy document for subsequent work.

The Team prepared 26 Discussion Papers and 6 Working Papers on policy and strategy issuesrelated to the development of regional environmental management institutions and associatedhuman resources development and decentralization issues.

Development Plans for BAPEDAL Kantor Wilayah I, II & III were prepared jointly with theKepala and Staff of each BAPEDAL Kantor Wilayah Office.

Technical Operational Guidelines (10 volumes) were produced for reference use by BAPEDALPusat and Wilayah personnel. These internal Guidelines should be updated annually byBAPEDAL in the future, and a version developed and distributed as Environmental ManagementGuidelines for use by BAPEDALDA and sectoral agencies.

A Legal Draft on Working Relationships between BAPEDAL Pusat & Wilayah, and a LegalDraft on Working Relationships between BAPEDAL Pusat & MLH were completed andsubmitted to BAPEDAL.

The Team supported training needs assessment certification, and curriculum designrecommendations related to the development of human resources for the BAPEDAL Wilayah andBAPEDAL Daerah. This information was utilized by the BAPEDAL Training Program.

The program sponsored BAPEDAL staff training in:

HRD Planning - USA

Comparative Study - New Zealand

Opacity Training - Canada

Comparative Study EPA - USA

The Team organized workshops and seminars in support of the institutional development ofBAPEDAL Wilayah, BAPEDALDA and sectoral agencies involved in environmentalmanagement.

BDTAP Regional Laboratory Development Planning, Certification and Training Program

The BDTAP Regional Laboratory Development team has completed field work, workshops andseminars, prepared and submitted recommendations, working and discussion papers, and completed alltraining programs as required in the Terms of Reference.

The Regional Laboratory Development Outputs included:

Final Report, June 1997

Summary of Pollution Sources in Indonesia and Classification

Regional Laboratory Survey

31 ANNEX B

Regional Laboratory Development Plan

Standard Operating Procedures for Laboratories (4 vols.)

Laboratory Development and Cost of Analysis (2 vols.)

Sampling Methods (3 vols.)

Quality Assurance and Quality Control Manual (5 vols.);

Good Laboratory Practice (3 vols.)

National and Intemational Accreditation Systems for Environmental Labs (4 vols.)

Training programs completed included:

Overseas Training 10 BAPEDAL Staff - Vancouver, Canada;

QA/QC Training for Regional Laboratory Managers at PUSARPEDAL

QA/QC Training for Regional Laboratory Managers in the Regions

Supply of Training Materials for Environmental Laboratories.

The Regional Laboratory Development team has supported BAPEDAL Workshops and Seminarsrelated to development of regional Environmental Laboratories, and provided technical advisory supportto BAPEDAL Deputy III Director 2.

BDTAP Training Program

The team completed research and field work, conducted workshops and seminars, and preparedand submitted working and discussion papers, recommendations, standard operating procedures, andtraining curricula as required by their Terms of Reference.

The Training team completed the following recommendations:

Training Information Management Systems

Pengembangan Jabatan Fungsional BAPEDAL

Training Needs and Existing Curriculum;

Training Management Recommendations and Standard Operating Procedures.

The team prepared a draft of Keputusan Kepala BAPEDAL 01/1997, Pedoman SyaratAdministratip dan Kualifikasi Teknis Para Pejabat BAPEDALDA Tingkat I dan Tingkat 11.

The Training team assisted in the formulation and delivery of Training of Trainers for AMDAL.

New or Revised BAPEDAL Training Curriculum Modules prepared by the Team withBAPEDAL include:

Technical Training (23 modules)

Environmental Management Training (I module)

Management Training (3 modules)

Administration Training (2 modules)

Training of Trainers (2 modules).

The team has provided recommendations for BAPEDAL Training Programs for the period 1.997-2002; and for a BAPEDAL Training Project Phase H.

32 ANNEX B

BDTAP Staff Acquisition & Human Resources Management Program

The Staff Acquisition & Human Resources Management Team has completed and distributed allreports and recommendations required by their TOR. Team assisted BAPEDAL develop managementand administrative system for the recruitment, development, promotion of personnel, and to recommendincentives for BAPEDAL to adopt to attract and retain qualified personnel in the future.

Recommendations and other outputs by the SAHRM team include:

SAHRM Final Report, November 1996

Recommendations for BAPEDAL ERM Policy and Organizational Structure

Public Information Brochure for Attracting Qualified Staff

Recommendations for the Design and Implementation of a Human ResourcesManagement Plan for BAPEDAL

Instruction Manual to Enable BAPEDAL Staff to Analyze Needs and Preparerecruitment Procedures and Job Descriptions on a Consistent Basis

Performance Appraisal Procedures and Format

Assignment Plan for Urgent Staffing Needs

Techniques and Incentives to Attract and Retain Highly Skilled Staff

Job Analysis Procedures

Career Patterns in Accordance with GOI Regulations for Civil Servants

Organizational Management Information System (Computer Database)

Exploration of Prospects for Use of Retired Persons and Students

Hipunan Perundangan & Peraturan Negara Dalam Bidang Sumber Daya Manusia 1970-1996

BDTAP Project Management Office

The Project Management Office assistance to BAPEDAL terminates with the closing of theWorld Bank BAPEDAL Development Technical Assistance Project. The Component Programs of theBDTAP have been completed on time and under budget.

PMO reports submitted to BAPEDAL are:

PMO Final Report, June 1997

BAPEDAL Donor Project Database, June 1997

BDTAP Financial Summary Report, June 1997.

BAPEDAL Five Year Development Plan, Updated Version to 1999, April 1997

BAPEDAL Development Technical Assistance Project documents and materials provided toBAPEDAL for all of the BDTAP Programs 4nclude complete sets of:

Original Consulting Services Contracts

TOR, Inception, Quarterly, Annual and Final Reports

Reports and Recommendations and other Program Outputs

33 ANNEX B

Other Donor Project Reports:

ADB TA - Establishment of BAPEDAL Regional Network

ADB TA - Hazardous Wastes Management: Aceh and East Kalimantan

WB IEPA - Industrial Efficiency Pollution Abatement Project Feasibility Studies

WB EMTAG - BAPEDAL Development Plan

WB1 JIDP III - Institutional Analysis and Strengthening Strategy WB JUDP III -Environmental Action Plan

WB JUDP III - Small Scale Industry Waste Reduction

WB JUDP III - Joint Wastewater Treatment for Industrial Estates

WB PMCA II - Implementation of Pollution Monitoring and Control Systems in NorthSumatra and West Kalimantan (partial set)

PMO materials provided to BAPEDAL for reference purposes include:

ADB, World Bank, OECF agency guidelines, manuals and documents for theprocurement and management of loan funded projects

Assorted AusAID, CIDA, GTZ, JICA and ODA agency documents.

The PMO library of Indonesian environmental laws, regulations and guidelines; andassorted environmental management reference reports, books and papers.

34 ANNEX B

ANNEX 2

COMMENTS ON DRAFT REGIONAL LABORATORIES MOU AND RELATEDOPERATIONAL ISSUES

The draft Regional Laboratories MOU currently under review proposes that: (i) BAPEDAL willpay for renovating the laboratories; (ii) individual laboratories will be responsible for paying for andinstalling waste water treatment systems; (iii) these laboratories will undertake environmental qualitymonitoring tasks, in addition to their normal (sectoral) duties; (iv) the laboratories will be responsible formaintaining the equipment needed for environmental quality monitoring; (v) BAPEDALDA Tk. I willcoordinate provincial environmental quality monitoring and disbursement of funds for O&M, andforward to BAPEDAL Pusat via BAPEDAL Wilayah; (vi) after review and discussion BAPEDAL Pusatwill submit the funding request (DUP-OM) to BAPPENAS and Department of Finance; (vii) approvedfunds (DIP-OM) will be disbursed by the project manager (Pimpro BAPEDAL) to individuallaboratories; (viii) BAPEDALDA Tk. I and BAPEDAL Wilayah will be jointly responsible for oversightof environmental quality monitoring work; (ix) and, BAPEDALDA Tk. I and individual laboratories willbe jointly responsible for reporting on environmental improvement efforts and laboratory results to theprovincial government, BAPEDAL Wilayah and their own departments.

This, Indonesian language, version of the Draft MOU conflicts, however, with the Englishlanguage version of a similar Draft MOU regarding the AusAID project. In this English language versionthe individual departments are responsible for funding laboratory renovations (not BAPEDAL),BAPEDAL is identified as responsible for providing the equipment and training (this is not specified inthe Indonesian language version), and there are various other minor differences between the two versions.The mission considers it important that Indonesian and English language versions are identical in intentand the topics covered, especially as the Indonesia language version will (as far as it is possible to tell)apply to both the OECF and AusAID funded projects. The mission reminded BAPEDAL that that thisissue has been flagged for attention by management for some four years and yet still remains unresolved.

The estimated annual operating costs of these laboratories are substantial. The consultantestimates direct annual costs as follows: Rp 1.25 billion for the 14 II-C class labs with 100 samples permonth for wet chemistry and metal analysis; and Rp 8.19 billion for the 24 II-A class labs with 100samples per month for wet chemistry, metals and pesticides - a total of nearly Rp 10 billion per annum;

an alternative, even higher, estimate of Rp 20 billion has also been made by the consultant.5 The scale ofthese costs raises several issues. First, how likely is it that BAPPENAS and Department of Finance willbe willing (or able) to provide this level of funding on a continuing basis, or even for the duration of thetwo projects? Second, if they are not willing (or able) to provide adequate funding, how does BAPEDALpropose to ensure that the labs (and the new equipment) can be used effectively? Third, how certain isBAPEDAL that the three Departments will provide sufficient and timely funding for renovations - if thisis the intent of the English language MOU? Fourth, what provisions might be made for continuing O&Mfunding beyond the life of the two projects? And, fifth, what consideration has been given to costrecovery options to supplement central funding and/or finance the labs after the projects have beencompleted? In this regard the consultant has raised the possibility of an "over supply" of analyticservices, if all 60 of the labs are up-graded to similar levels, with, consequently, a marked reduction in thepossibility of using payments for services to cover costs.

5 The recent devaluation of the Indonesian Rupiah will have a marked effect on these estimates, as many of the materials andequipment required for routine operation are imported. Roughly speaking, an increase of approximately 50% can beanticipated for all imported requirements.

35 ANNEX C

ANNEX C: EVOLUTION OF BAPEDAL ORGANIZATIONAL STRUCTURE

Figure 1. BAPEDAL Organization in 1992



FIGURE I - BAPEDAL ORGANIZATIONAL STRUCTURE IN 1992

Chairman

r Secretariat

Deputy for Deputy forEnvironmental Development

Pollution Control

Directorate for Directorate for Directorate for Directorate for Dev. Directorate for Directorate for Dev.Water and Land Marine and Air Hazardous Control and Technical of Reference Lab. &Pollution Control Pollution Control Waste Monitoring of EIA Guidance Data Processing

Water Pollution Marine Pollution I Hazardous Institutional & Cross Sectoral & |Dev. of Referencen Control iil -Lontrol ___ Waste _Infrastructure _ Provincial ILaboratory

Development CooperationLand Pollution & FAir Poilution Emergency rDevelopment of|

Env. Destruction Control Response Control of EIA Training EnvironmentControl System Mgmt. Quality Information

|Catal Pollutionl System & Env.zSmall-Sle l Control _Incentive System |Quality|Activities Impact | Development | Evaluation[Control

_Domestic Waste|iControl Mgmt.

FIGURE II - BAPEDAL ORGANIZATIONAL STRUCTURE IN 1994

I CHAIRMAN IVICE CHAIRMAN

DEPUTY DEPUTY DEPUTY EIA (AMDAL)INSTITUTIONAL AND I POLLUTION AND TECHNICAL

_CAPACITY EXtPANSION L CONTROL . _ ASSISTANCE

u Directorate for Program | I SECRETARIAT Directorate for Water & D fDevelopment l l l | Sea Pollution Control

Directorate for Center for Env. Information | Directorate for Air | F Directorate for Env. |Institutional Dev. and Compliance Systems | Pollution Control Laboratory Assistance

Directorate for Human Environmental Directoratefor Hazardous Directoratefor TechnicalResources Dev. ManagementCenter & Toxic Management Development

BAPEDAL REGIONAL Directorate for Env.OFFICES Degradation Control

I T 11 .I III

FIGURE III - BAPEDAL ORGANIZATIONAL STRUCTURE IN 1999

CHAIRMAN I

VICE CHAIRMAN

EXECUTIVE SECRETARY *

I Bureau for General Bureau for

Adm. & P. Relation Planning

Deputy for Environmental Deputy for Environmental Deputy for Institutional & Deputy for Law EnforcementDegradation Control * Pollution Control * Human Resourse and Environmental Impact

_ ~~~~~~~~~~~~~~~~Capacity Building * _Assessment_

Directorate for Forest Directorate for Water and Directorate for Institutional Directorate for EnvironmentalI Fire l Soil Pollutiont & Dispute SolutionD

Directorate for Land Directorate for Coastal Directorate for Human Directorate for EnvironmentalDegradation a Marne Pollution Resources Development Impact Assessment

| Directorate for Protected Directorate for Air Directorate for Private L 6Directorate for EnvironmentalArea Degradation Pollution Sector and Public Role Laboratory Development

l Directorate for Hazardous | | Directorate for Technicall and Toxic Waste 2 | Development

Inspectorate BAPEDAL REGIONAL Center for Environmental Center for Education & TrainingOFFICES Data & Information & Environmental Impact

I II Management Facilities

*Indicates positions with joint appointments in Ministry of State for Environment

IMPLEMENTATION COMPLETION REPORT …documents.worldbank.org/curated/en/902961468752742034/...for pollution control within the Indonesian governmental structure have been changing nearly

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