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Danida
Synthesis Study on
SEA Lessons Learned
Final version
Contract Title:
Contract Number:
DC 2013/0018/KC
Assignment Period:
Contractor:
Disclaimer
This report was prepared by Martin Smutny, Jiri Dusik and Michal Musil (Integra Consulting Limited) in
cooperation with Indonesian experts Adi Wiyana and Dwi Nurcahyadi.
The report does not constitute any formal legal advice. The report is without warranty of any kind,
either expressed or implied.
Unless indicated otherwise, the authors have drafted the report. The findings, interpretations and
conclusions expressed in the report are those of the authors and do not necessarily represent the views
of Danida or governmental agencies in Indonesia.
This material has been prepared as a working document which has not been language edited.
Acknowledgement
The authors would like to thank to Mr. Tim Hansen and Ms. Trine Bargsteen from Royal Danish Embassy
in Jakarta as well as to Ms. Ida Lestari (ESP3 Secretariat) for overall coordination and support to the
assignment, to the representatives of the key governmental agencies Ms. Tri Dewi Virgiyanti
(Bappenas), Ms. Wahyu Indraningsih, Ms. Qurie Purnamasari, and Ms. Inge Retnowati (KLH), Ms. Reny
Windyawati (MOHA), Mr. Ir. Edison Siagian (MOHA) and the international consultants Mr. Kim Harboe,
Mr. Josh Van Berkel, and Mr. Nils Bull for their kind inputs to the SEA synthesis study.
Table of Contents
Disclaimer ........................................................................................................................... 2
Acknowledgement ................................................................................................................ 2
Table of Contents .................................................................................................................... iii
List of abbreviations ................................................................................................................ v
1.
Introduction .................................................................................................................. 6
1.1
1.2
1.3
2.
2.2
2.3
Scope of SEA........................................................................................................... 11
2.4
2.5
2.6
2.7
2.8
3.
3.2
3.3
4.
Annex I: Overview of comments from the workshop on SEA lessons learned ....................... 22
5.
Annex II: The list of participants at the workshop on SEA lessons learned ........................... 28
6.
6.2
SEA of Kota Serang Regional Spatial (Spatial Plan) and Long-Term Regional Development Plan
(RPJPD) ............................................................................................................................ 36
6.3
iii
6.4
SEA of National Mid-Term Development Plan for Palm Oil Sector .................................... 44
6.5
6.6
6.7
6.8
6.9
SEA for Padang New City (Post Earthquake Development Plan) ...................................... 59
6.10
6.11
6.12
6.13
6.14
6.15
6.16
SEA for Medium-Term Development Plan of the Central Java Province ............................ 84
6.17
6.18
6.19
6.20
SEA for Spatial Plan of National Strategic Area (KSN) Sunda Strait................................. 98
6.21
Rapid Environmental Assessment (REA) for Proposed Diversion of the Citanduy River ..... 102
6.22
SEA for Regional Medium-Term Development Plan of Bangka Belitung Province .............. 105
6.23
SEA for Regional Medium-Term Development Plan of Hulu Sungai Utara District ............. 109
6.24
6.25
6.26
6.27
iv
List of abbreviations
Bappenas
ESPII
Indonesia-Denmark Environmental
Phase 2, Component 1
FDG
KLH
KSN
LEPM
MoHA
MoPW
PPP
QA
Quality assurance
RPJMD
RPJPD
RTRW
Spatial Plan
SEA
ToR
Terms of Reference
Support
Programme,
1. Introduction
1.1 Objective of SEA synthesis study
Indonesia and Denmark have cooperated in the field of environment through an Environment
Support Programme since 2005. The second phase was running from 2008 to 2012 and consisted
of 3 components including a component on improving institutional capacity of public sector
institutions. This component (known as component 1) has 3 outputs:
1) Environmental Impact Assessment (EIA) reform and decentralized process strengthened
(implemented by Ministry of Environment / KLH)
2) Strategic Environmental Assessment (SEA) in development planning and policy analysis
(implemented by Ministry of Environment (KLH), National Development Planning Agency
(Bappenas), Ministry of Home Affairs/MOHA), Ministry of Public Works (MoPW)
3) Role of Economic Instruments/EI (implemented by KLH).
The major activity under Component 1 was a support to the Strategic Environmental Assessment
(SEA), both for preparation of guidelines and input for regulations, training at different levels and
preparation of following pilot SEAs:
SEA of Medium Term Development Plan of Kubu Raya (RPJMD)
SEA of Kota Serang Regional Spatial (Spatial Plan) and Long-Term Regional Development
Plan (RPJPD)
SEA of Padang Bay City Development Plan
SEA of National Mid-Term Development Plan for Palm Oil Sector
SEA of Spatial Plan of West Sumatera Province
SEA for Lake Maninjau Management Plan
SEA for Kapuas Watershed Management
SEA for Kota Banjarbaru Spatial Plan
SEA for Padang New City (Post Earthquake Development Plan)
SEA of Water Resources Management and Conservation on Bali
SEA for Amandit River Basin Management
SEA of Aquaculture Sector
SEA of Coal Mining Sector
SEA for Provincial Spatial Plan of the North Sulawesi
SEA for Spatial Plan of Central Sulawesi Province
SEA for Medium-Term Development Plan of the Central Java Province
SEA for Border Road Development Plan in West Kalimantan
SEA for Spatial Plan of Jambi Province
SEA for Mataram Metropolitan City Plan
SEA for Spatial Plan of National Strategic Area (KSN) Sunda Strait
Rapid Environmental Assessment (REA) for Proposed Diversion of the Citanduy River
SEA for Regional Medium-Term Development Plan of Bangka Belitung Province
SEA for Regional Medium-Term Development Plan of Hulu Sungai Utara District
SEA Pre-Scoping for National Strategic Area Sorowako
Environmental Assessment for Sei Mangkei Development Area
Preliminary Environmental Analysis for KSN Prambanan
It has to be noted that above listed SEAs represent only part of SEA application in Indonesia,
since a number of SEA cases (more than 100) was supported from the national budget in 2011
and 2012. The SEA for Spatial Plan (RTRW) of Tasikmalaya District was included in the SEA
lessons learned study as the representative of such SEAs.
Preparation of the synthesis study on SEA lessons learned has been assigned by the Royal Danish
Embassy in Jakarta in order to summarize experience from practical application of SEA within
the ESP2. The respective ToR for the assignment stipulates the overall objective of the review as
to assess the procedures, relevance and quality according to national and international SEA
standards, actual and potential impacts and capturing good practice. The synthesis study is
supposed to address suitability of the
The procedures, what are the procedures and are they suitable to address the problem
and improve the situation in Indonesia
The SEA lessons learned study shall analyse pilot SEAs prepared under the ESP2 in order to
provide recommendations for further SEA development in Indonesia as well as give specific
suggestions towards the ESP3.
The views of the key agencies involved in the SEA activities within ESP2 (i.e. KLH, Bappenas,
MOHA and MOPW) as well as national and international consultants have been integrated in the
draft study. Its preparation also involved survey among several provinces where SEA pilots had
been conducted in order to find out if and how the results and recommendations provided by
SEAs were considered in the final version of the plans and/or its approval.
The list of participants can be found in Annex II, the agenda of the workshop is provided in a
table below:
Time
Agenda
Note
08.30 09.00
Registration
09.00 09.15
Opening
09.15 10.15
Representatives of KLH
and Bappenas
10.15 10.45
Coffee break
10.45 11.45
Representatives of MoHA
and MoPW
11.45 12.45
International consultants
involved in ESP2 SEA
activities
12.45 13.00
Discussion
13.00 14.00
Lunch
14.00 14.45
14.45 15.15
Concluding discussion
15.15 15.30
Closing remarks
Integra Consulting
However, it needs to be noted that in many cases the SEA reports were finalized (due to the assignments
deadline) before the plan was finalized and thus the SEA reports could not reflect the decision-making.
As it can be concluded from discussions regarding the existing SEA practice in Indonesia at the
provincial and local levels, presentation of SEA results and recommendations by the SEA team
to the head of relevant agency, who has the responsibility and authority to accept (or reject) SEA
recommendation in the draft planning document, can be seen as an important moment when it
can be decided about (non)acceptance of SEA results. This single event can actually influence
further formal process, since the head of the planning agency then presents the plan (including
SEA results) to the governor or bupati/mayor, which has a mandate to adopt the final decision.
As found regarding the MOHA SEA pilots, the recommendations formulated by SEA for RTRW of
Jambi Province (2011) were presented at the final High Level Meeting with the Governor, and
the Governor accepted almost all the recommendations (however this was not the case for other
SEA pilots conducted by MOHA).
Whereas the ESP1 and ESP2 focused on methodologies and procedures, the ESP3 should pay
much more attention to the actual outcomes of the SEAs to further support first indications of
SEA influence on decision.
Recommendations for the ESP3:
We recommend that each and every pilot SEA supported by ESP3 should be thoroughly
evaluated by gathering information from the stakeholders concerned on the following matters:
1. How actively was the planning authority involved in SEA process?
2. What changes in the proposed PPP occurred as a result of SEA? How are these changes
being implemented in practice?
3. Why did the SEA influence decision-making or failed to do so?
4. What do the key decision-making actors and affected stakeholders think of the undertaken
SEA? What have they learnt through the SEA? What elements of the SEA do they regard
as the most and least useful? How would they improve the SEA in the future?
It is advisable that such evaluations are done by independent reviewers and internally
discussed with the teams that undertook SEAs and ESP3 advisors only. The primary objective
for these reports is to be frank and therefore it may not be advisable to debate them in open
forums. Their objective is to provide informal feedback to teams that undertook SEA and agree
on improvements in future processes.
10
In some observed cases, it seems that the SEA proceeded as an ex-ante more thanks to delays
experienced by the planning process, rather than thanks to thought-out process design (see for
example SEA KSN Prambanan). In such context then SEA often did not wait for further progress
of the planning and concluded with preliminary analyses and recommendations, leaving the
opportunity to comment on and influence more advanced versions of the plan to some little
specified future SEA follow-up. On the other hand, in several cases, the SEA had been planned
well in advance (e.g. SEA for RPJMD of Bangka Belitung Province), however even this could not
guarantee that SEA process will cover entire planning and decision-making cycle.
However, progress can be seen considering the overall design and methodological approach to
SEA. SEA pilots conducted in later stages of ESP2 (2011 and 2012) usually followed logical steps
and analyses to be conducted in SEA starting from definition of the scope of assessment (i.e.
a list of strategic issues), through description of existing conditions, impacts evaluation,
formulation of mitigation measures and conclusions and recommendations, while in earlier cases
often such a logical sequence of tasks and analyses cannot be found or these SEAs addressed
only selected analyses (e.g. there is no clear impacts evaluation, baseline analysis is missing
etc.). On the other hand it can be noted that despite applying above mentioned logical steps and
analyses in later ESP2 SEAs, the SEA processes did not fully utilize opportunities for providing
inputs to the plans preparation.
The issue of linking the SEA with planning was even more complicated in SEA pilots where SEA
was not carried out directly by planning agency. It was mainly obvious in SEA pilots supported
by Bappenas besides getting insufficient information on the planning process, the problems
also related to data gathering and involving right persons from the planning agency (ministry).
Especially in early years (2008 2010) SEAs were largely carried out as a series of meetings and
focus group discussions (FDG), where SEA experts were mainly facilitating the discussions and
the entire process. Later SEA pilots include more substantial analytical inputs from the SEA
experts or we carried out almost solely by the consultants. It neither case, it is nevertheless
often not clear who is responsible for specific analyses and recommendations made.
Recommendations for the ESP3:
SEA reports supported through ESP3 should clearly identify authors of the specific analyses
and recommendations put forward. The authors of the relevant analyses and conclusions
should be made accountable for their accuracy and technical soundness.
It is also important to ensure that the SEA pilots will have an opportunity to follow the planning
process until (or even after) the final decision is made. Since very often planning processes do
not run as originally planned (due to various technical as well as political reasons), it is
important to keep future SEA pilots administratively flexible and allow extensions of the
processes.
11
issues while others can be excluded. Notable exception is the Report on REA for Proposed
Diversion of the Citanduy River, where the limited scope of assessment is clearly explained
(including territorial dimension), well justified and presented.
It seems that the list of issues to be addressed in SEA stipulated by the Law on Environmental
Protection and Management (i.e. carrying capacity and environmental absorption capacity for
development, estimation of the impact and risk on environment, performance of ecosystem
services, utilization efficiency of natural resources, levels of vulnerability and adaptive capacity
to climate change, levels of resilience and the potential for biodiversity) does not provide
sufficient guidance for the scope of SEA. The above listed issues are often missing, or just
formally mentioned in the SEA report, while the analyses are focused on differently defined topics
and issues. Several SEAs discuss the issue of carrying capacity, however without any concrete
conclusions. However, this fact alone should not be seen as a failure of the involved consultants.
The above listed aspects of the environmental quality are highly complex issues and any attempt
to address them as defined within the respective legislation is likely to result either in formalistic
approach or in time- and resources- intensive endeavor fairly exceeding typical SEA scope.
This also poses a peculiar challenge to ESP3 program since it is the main donor instrument
supporting uptake of SEA in Indonesia. Projects funded by Danida should comply with the national
legal frameworks and this is valid for SEA as well. In this regard, it can be considered that (i)
all supported SEAs would be required to explain how their analyses relate to the legal
requirements of the Law on Environmental Protection and Management, or (ii) modifications of
the SEA section of the LEPM would be initiated in order to make the legal framework better
reflecting the practical application of SEA in the county.
Recommendations for the ESP3:
In case the modification of the LEPM are initiated, the amended law should ensure the flexibility
of the SEA focus and scope and rather provide provision on how to arrange the scoping stage
from the procedural point of view including consultations with relevant authorities and other
stakeholders (possibly also including general public). The amendments of the LEMP should also
introduce requirements for clear statement regarding consideration of the SEA
recommendations in decision-making to be issued by responsible decision-making
governmental authority.
If the first option mentioned above is chosen, it should be required for SEA processes that are
supported within the ESP3 to clearly define the key issues of concern that they focus on and
explain how they relate to carrying capacity and environmental absorption capacity for
development, estimation of the impact and risk on environment, performance of ecosystem
services, utilization efficiency of natural resources, levels of vulnerability and adaptive capacity
to climate change, levels of resilience and the potential for biodiversity.
This explanation can be brief and the SEA teams can later focus on the specific issues of
concern that they identified. However, it must be clear how the issues addressed by the SEA
relate to at least the most relevant concerns defined by the Law on Environmental Protection
and Management.
12
cases very descriptive. The trends in time are often not identified or poorly documented, and
main drivers of environmental change and their links to the interventions prospectively proposed
by the PPP are rarely explicitly acknowledged. Zero/do nothing scenario (e.g. likely further
developments without PPP implementation) is often not established or evident from the baseline
analysis. In some case the analysis of baseline trends is not always focused on key issues of
concern identified within the SEA. Hence it may be difficult to make a link between the baseline
studies and impact assessment.
Recommendation for the ESP3:
ESP3 should encourage those undertaking SEA to prepare proper analysis of baseline trends
and focus it on each of the issues of concern.
13
The brief description of the proposed measures and the language used in many cases indicates
that these recommendations were not discussed with the relevant decision-making actors and
stakeholders concerned and they are in fact not ready for implementation. They lack details on
who should implement them, and on how and when this should be done.
On the other hand, SEA for Sunda Strait KSN or RTRW of Jambi Provinces defined a number of
well described mitigation measures corresponding with likely impacts, and several measures go
beyond the plan oriented towards to other plans (RPJMD in case of SEA in Jambi Province)
or address administrative structures for management of likely impacts during the implementation
of the plan (establishing KSN Sunda Strait Social Welfare Panel was suggested by the SEA for
Sunda Strait KSN).
Most of SEAs didnt address monitoring there were neither indicators, nor monitoring system
described.
Recommendation for the ESP3
ESP3 should encourage all future supported SEAs to present the mitigation measures in a
simple manner (as proposed further) that helps the stakeholders review and appreciate
proposals put forward by SEA teams.
The required logic of mitigation measures presentation should be: identified impact ->
corresponding mitigation measure proposed -> recommendation for its implementation (who
should implement them and when) -> responses from the planning team. Such
recommendations should be prioritized especially if more than approx. 10 mitigation measures
or changes in the PPP are proposed.
ESP3 should also encourage further SEA pilots to propose relevant indicators (in accordance
with key issues addressed and main likely impacts identify) and optimally suggest
responsibility for monitoring during the PPP implementation.
14
15
Clearly link SEA to particular planning and decision-making process only such
arrangement allows that results and conclusions from SEA can be considered in the PPP and/or
its approval, and thus it can fulfill a primary role of SEA i.e. to provide inputs into planning
and decision-making process. Each specific SEA should at the beginning of the assessment
clearly define its position in relation to planning i.e. which planning process the assessment
follows, what type of the decision-making is at the end of the process, what will be the
procedure of the PPP implementation etc.
Communicate with planning agency SEA is supposed to provide inputs in the PPP and
its preparation. To achieve this, an intensive communication between SEA team and planning
agency teams is essential. If suggestions and conclusions from SEA are not properly
16
Present SEA results to the key decision-makers: As it can be concluded from discussions
regarding the existing SEA practice in Indonesia at the provincial and local levels, presentation
of SEA results and recommendations by the SEA team to the head of relevant agency, who
has the responsibility and authority to accept (or reject) SEA recommendations in the draft
planning document, can be seen as an important moment when it can be decided about
(non)acceptance of SEA results. This single event can actually influence further formal
process, since the head of the planning agency then presents the plan (including SEA results)
to the Governor or Bupati/Mayor, which has a mandate to adopt the final decision. Therefore
it can be recommended to organize high profile meeting when the SEA report is drafted and
present the key SEA recommendations and suggestions towards the plan to the head of
planning agency and/or to Governor or Bupati/Mayor to achieve his endorsement of SEA
results.
Find appropriate balance between analytical work and consultations SEA shouldnt
be perceived as only consultations process (as widely applied in Indonesia). Even if
stakeholders consultation and participation present an important and inseparable part of the
SEA process, SEA also has to include certain analytical work, which is supposed to be
performed by SEA team and thus providing a background for discussions with stakeholders.
Without knowledge of the baseline trends likely future trends cannot be estimated which in
turn does not allow proper impacts analysis such approach leads to only very formal and
normative conclusions and mitigation measures. As it was mentioned at the lessons learned
workshop, the quick appraisal approach widely applied at the local level from the national
budget can be seen as insufficient (as e.g. experience of West Sumatera Province from
supporting three districts/cities to undertaking SEA indicates).
Substantiate all findings and conclusions Impacts evaluation as well as all suggestions
made by SEA have to be substantiated by appropriate data and information, supported by
examples, references, illustrated by graphic aids (maps, graphs) etc. which need to be
described in the SEA report. Otherwise the planning agency and other stakeholders might be
reluctant to consider evaluation and suggestions provided by SEA, since they might not
understand on what base these have been made.
Open SEA process (in certain steps) for public scrutiny a number of SEAs conducted
so far in Indonesia invited for consultations mainly governmental agencies ministries,
departments within provincial government, municipal governments etc. This is a very
important target group and it needs to be involved indeed (as well as non-governmental
sector). However, there should be opportunities within the SEA process when all interested
stakeholders can express their view on the PPP and relevant likely impacts. Generally, it can
be recommended to open the SEA process for public, NGOs and all other interested
17
stakeholders in two stages: (i) in scoping, when defining issues to be addressed by SEA, main
environmental and health problems to be solved etc., and (ii) when draft SEA report is ready.
Pay attention to well defined ToR for SEA There is a broad variety of PPPs, which differs
in many aspects: level of planning, territory covered, stages and analysis usually performed
within preparation of the PPP, focus and substance of PPP, stakeholders involved etc. As
already previously mentioned, each SEA to be efficient should carefully take into account
a context which it is to be conducted in. Ensuring this requires planning of SEA process before
it starts. It can be done by the planning agency assigning the SEA; it can be done also by the
SEA team once established. The conclusions can be summarized in a form of the ToR, which
usually serves to define details of a specific SEA process to be conducted its time-schedule,
budget, expertise needed, stages and links to the planning process, analysis to be performed,
key stakeholders to be involved etc.
Informal consultations: Besides the workshops and focused group discussions it is highly
recommended to conduct additional meetings with selected stakeholders and partners (as it
was done with JATAM within SEA for RPJMD Bangka Belitung). These meetings can serve for
various purposes e.g. in the pre-scoping and scoping stage might help to receive data and
information to be used in baseline analysis (e.g. from KLH regarding biodiversity or water
quality, universities, Ministry of Forestry data on forestry etc.), later in the process usually it
is necessary to discuss in detail impacts evaluation and mitigation measures with relevant
institutions and NGOs etc.
Enhancing internal logic of the assessment: Work with results from scoping and baseline
analysis when evaluating the impacts this is actually the main task of the impacts evaluation
i.e. to estimate how the trends (and specific problems, concerns and drivers) can be affected
by the PPP implementation. Unfortunately none of SEAs provided this information.
Deal with monitoring: It can be recommended suggesting the key indicators (1 2) for
each strategic environmental issue, which would follow the main impacts identified these
could be used (i) directly during the PPP implementation, and/or (ii) as a basis for
determination of relevant indicators at the project level. Introducing at least simple monitoring
schemes would provide a basis for future SEAs and enabling better analysis of likely evolution
of the environment.
18
Clearly defined role of KLH: In order to avoid overlaps in SEA activities, it would be optimal
to clearly define responsibilities of each key ministry involved in SEA activities so far (i.e. KLH,
MOHA, Bappenas and MOPW). Considering the current operation of entire SEA system in
Indonesia as well as its possible further evolution, following role can be suggested for KLH:
o Managing and updating the legal framework
o Providing methodological support and advices (this should be demand-driven and focused
especially on sectoral ministries and non-governmental sector)
o Conducting quality assurance reviews for the most important SEAs (if requested by
planning agency, community or NGOs) and provide an expert opinion on quality of
particular SEA
o Operating SEA information system (see below) i.e. ensuring technical management of
necessary IT system as well as maintaining the database and coordinating inputs into it
o Becoming a national focal point for communication with international SEA community (e.g.
IAIA)
Focusing support only to SEA pilots: The overall SEA system can be considered as
established in Indonesia there is a legal framework, key ministries have developed the
methodological documents, and a number of local governments already have experience with
SEA. Therefore the main focus should generally be aimed at enhancing the SEA practice.
Indonesian SEA system can be seen in a transition period from initial stage with only SEA
cases conducted within various donors activities to functioning scheme where SEA is
considered as a standard tool. Considering this, it can be recommended that also ESP3 SEA
activities should solely support practical application of SEA, which shall be in line with
international good practice.
19
to only governmental officials, and wider public was not involved. Therefore before
providing the support from ESP3, the scope of consultations shall be agreed.
The above mentioned general points can be turned into more detailed evaluation questions,
which however still need to be focused on planning process and openness of planning agency
for integrating of SEA results and consultations. Should there be a need for more detailed
information on the key environmental and social problems in the respective area or sector
and the appropriate SEA approach, the ESP3 might consider supporting initial brief analysis
(pre-scoping) which then would provide a basis for selecting cases for full SEA application.
To our knowledge, the ESP3 support to SEA should be demand driven and thus the
governmental agencies should therefore be asked to address the points above in their
application (including also a description of the planning process). The selection can be done
in two steps:
o Step 1 would be pre-selection based only on applications,
o Step 2 would require a meeting with representatives of respective governmental
agency (optimally high profile officials) in order to discuss and agreed on the optimal
arrangement of the SEA process.
When selecting the SEA pilots for RPJPD/RPJMD at the provincials/districts/municipalities
level, the ESP3 should carry out consultations with the MOHAs Directorate General of
Regional Development to obtain the Regent/Mayor General Election Schedule. Since the
RPJMD has to be completed in three months and legalized in six months respectively after the
governor/regent/mayor is inaugurated. This information will help to identify which local
governments are in the position to conduct SEA in parallel with planning process. Similarly,
there should be communication with MOPW regarding the RTRWs.
Promoting basic principles of SEA good practice: Obviously, there is still a room for
further improvement of coordination among the national authorities involved in SEA i.e. KLH,
MOHA, Bappenas and MOPW as well as national and international consultants regarding
approaches to SEA. Although it can be understandable given a fact that SEA practice is still
evolving in Indonesia, on the other hand such situation might potentially lead to confusion
especially at the district and municipal levels what is role of SEA, which approach should be
followed etc. Therefore is can be recommended that SEA pilots supported within ESP3 would
be strongly encouraged to follow basic principles of SEA good practice as they are described
in section 3.2 above.
20
would mean same level of responsibility for the final result and should also be easier in terms
of management and coordination from Danidas side. In addition, duration of sub-contracts
should enable sufficient timeline for SEA process to follow the planning and decision-making
process until the approval of the PPP. Thus, the SEA teams and experts would be able to
provide assistance to planners and decision-makers to integrate SEA recommendations into
final drafts of PPPs as well as into the final decision. Such arrangement might require multiyear sub-contracts.
21
COMMENT/INPUT
a.
a.
b.
b.
c.
a.
b.
22
c.
MOHA
the
planning
process
is
23
META
Arie Djoekardi
(national SEA
consultant; planner)
a.
b.
24
c.
Pak Edison
(Bangda)
a.
b.
c.
d.
25
26
27
NAMA
INSTITUSI
YIPD
Nizhar Marizi
Imelda Sinaga
Arie D. Djoekardi
Ex-KLH (Consultant)
Rudy P. Tambunan
Irhasy Ahmady
WALHI
Ilah Ladamay
10
Dani
Mitraplan Consultant
11
Riki Handriana
BAPPEDA Banten
28
12
13
Titin Masfetrin
14
15
16
17
Fahmi Djauhari
18
19
20
Bustami
21
M. Apriji
BLH Banjarbaru
22
Amruddin Ado
Bangda, MoHA
23
Peter Oksen
ESP 3
24
Devina F. Anasruron
Danish Embassy
29
25
Louise Grenier
ESP 3
26
Farida S
Sucofindo
27
Ratni
28
Mappatoba Andi
29
Bappenas
30
Danish Embassy
31
Hesti D. Nawangsidi
ITB
32
Adi Wiyana
Consultant to MoHA
33
Dwi Nurcahyadi
34
Trine Bargsteen
Danish Embassy
35
Bobbi Schijf
36
Inge Retnowati
MoE
37
DHI
30
38
Kim Harboe
Independent
39
Edison Siagian
MoHA
40
Reny Windyawati
MoPW
41
Anastasia Widya K
MoPW
42
Wahyu Indraningsih
MoE
43
Eva
44
Ina Susiana
BAPPEDA Banten
45
Irfan Kurniawan
BAPPEDA Banten
46
Sucofindo
47
Monica Kappiantari
ESP 3
48
Ida Lestari
ESP 3
49
Martin Smutny
50
Michal Musil
31
32
Name of pilot
Responsible authority
Year of implementation
National consultants involved
International
consultants
involved
Language
of
SEA
report
reviewed
Evaluation
M
33
Were the past trends for the key issues analyzed (optimally also including main
drivers)?
Was the likely future evolution of the key issues without the plans implementation
described
Did the analyses highlight main concerns regarding the key issues?
Verbal summary:
The SEA does not include any baseline analyses neither the current status nor the trends.
M
M
M
Evaluation
P
P
M
M
M
M
34
Verbal summary:
The SEA report summarizes the process but not the key recommendations. It is actually impossible to
see what recommendations were made if any and trace any linkages between the identified
impacts, recommendations and changes in the plan.
Quality issue 7: Decision-making
Detailed quality criteria
Evaluation
Have the conclusions and recommendations given by SEA been considered in the PPPs
approval?
Verbal summary:
The SEA concluded that the proposed final RPJMD Kubu Raya district is sufficient to be submitted to
Parliament Kubu Raya district
35
6.2
SEA of Kota Serang Regional Spatial (Spatial Plan) and LongTerm Regional Development Plan (RPJPD)
Name of pilot
Responsible authority
Year of implementation
National consultants involved
International
consultants
involved
Language
of
SEA
report
reviewed
Evaluation
F
F
P
P
P
P
P
P
F
N
36
(d) an increase in the conversion of agricultural land, and (e) the prevention of the urban sprawl
(e) protection of wetlands (wet land),
(f) protection of local cultural heritage and uniqueness of Serang
Interestingly, the issues mentioned in the official SEA report differ from those described by the
author of the SEA in his review of the case for the ESP2 who stated the following focus:
(a) water resource sustainability,
(b) sustainability of production and cultivation area ecosystems,
(c) ecosystem of conservation areas being converted for other uses,
(d) balance of development among sub-districts and between rural and urban areas,
Obviously, the focus of the SEA was not perfectly fine-tuned and agreed with everyone. But this can
be caused by some reporting problem.
Quality issue 3: Baseline analysis
Detailed quality criteria
Evaluation
Was the existing state in the key issues described?
P
Were the past trends for the key issues analyzed (optimally also including main
P
drivers)?
Was the likely future evolution of the key issues without the plans implementation
P
described
Did the analyses highlight main concerns regarding the key issues?
P
Verbal summary:
The baseline analyses was conducted through the following activities:
Identify the 2008 land-use and use it as baseline data for developing initial environmental profile.
Identify the appropriateness of the spatial planning policy, plan, and program initiatives with the
regional development funding strategy/approach.
Undertake SWOT analysis of Kota Serang in the field of regional spatial planning.
The approach chosen has capacity to provide useful data and makes sense.
Quality issue 4: Evaluation of impacts
Detailed quality criteria
Evaluation
Were conflicts between objectives for the key issues and PPPs objectives analysed?
P
Was the full range of impacts to all key issues evaluated? If not, what significant
P
impacts were overlooked?
Were the impacts characterized and described?
P
Were secondary/indirect and cumulative impacts considered?
P
Were impacts quantified where possible?
M
Was impacts evaluation sufficiently substantiated by calculations, examples,
P
references to international and national literature etc.?
Were all alternatives suggested by the PPP assessed?
P
Verbal summary:
The impact assessment was undertaken through the following steps:
Assess the potential implications of policy, plan, and program initiatives contained in the Spatial
Plan of the Province of Banten on environmental sustainability in Kota Serang.
Assess the potential implications of PPP initiatives contained in the Spatial Plan on environmental
sustainability - in particular in connection with the major environmental issues being faced (see
scoping).
Assess the implication of policy, plan, and program initiatives contained in the Spatial Plan of Kota
Serang, in connection with the institutional capacity in the fields of environmental management
and spatial planning, in order to ensure inplementation of compulsory government affairs in
37
meeting the minimal standard of services in the fields of spatial planning and environment
formulated in the Spatial Plan and SEA.
The SEA also proposed to consider scenario for construction and development of urban centers, and
scenario of implications of the development of the Capital City or Administrative Center of the Province
of Banten.
All in all, this entire approach can be considered as a honest though little incomplete attempt to
assess impact of the proposed land-use options and should be appreciated.
Quality issue 5: Mitigation measures and monitoring
Detailed quality criteria
Evaluation
Were measures to prevent, reduce and/or offset any significant adverse effects
F
suggested by SEA for all main impacts identified?
Can mitigation measures suggested by SEA efficiently manage likely adverse impacts?
P
If not, what residual impacts can be expected?
Is there any monitoring scheme proposed?
P
Is it based on the main impacts identified?
P
Verbal summary:
The SEA suggested a number of institutional initiatives to address cumulative impacts of ongoing
developments:
Regulate the patterns of environmental characteristics on the basis of various variables, including
density of buildings, coefficience of building base, coefficience of building floor, coefficience of
green areas, and coeffience of building height.
Enact technical stipulations on waste water treatment, including domestic waste, building waste,
and industrial waste.
Determine the uses of rivers and public canals and the standards of waste water that is allowed
to be disposed of to public canals or rivers.
Develop storm water management plan for the central part of the city, considering the problem of
drainage.
Provide land according to environmental planning standards, and develop and maintain green
open spaces in the central part of the city.
Formulate policies and strategy on the application of the 3-R concept (reduce-reuse-recycle) in
both settlement and trade services centers as implied in Law Number 18 Year 2008 concerning
the Management of Garbage.
While these proposals sound rather normative and would need more description and even if it is not
clear how there were integrated into the plan, they represent better-than-average attempt to address
the complex set of environmental-development-institutional issues than those presented in other
SEAs.
Quality issue 6: SEA report
Detailed quality criteria
Is the SEA report readers-friendly?
Does the SEA report describe the SEA process and all its stages and analyses as well as
the overall methodology/approach used?
Were the conclusions and recommendations towards the PPP given by SEA made
explicit?
Does the SEA report clearly state which recommendations and suggestions given by
SEA have been integrated in the plan (i.e. if there were any changes of the plan resulting
from SEA)?
Does the SEA report indentify sources of information, including expert judgement and
matters of opinion?
Does the SEA report contain a non-technical summary?
Verbal summary:
The SEA report is concise and well written.
Evaluation
F
F
F
F
F
F
38
Evaluation
?
39
6.3
Name of pilot
Responsible authority
Year of implementation
National consultants involved
International
consultants
involved
Language
of
SEA
report
reviewed
Evaluation
F
F
P
F
F
M
P
P
F
F
40
clearly language and visual aids not under terms required by the LEMP but rather as separate
issue that are easy to understand.
The SEA addresses not only the impacts in the study area but also in the wide area of the Padang
city and surroundings (e.g. mining of rock required for the proposed reclamation, impacts of flood
barrier on the upstream area, etc.).
Quality issue 3: Baseline analysis
Detailed quality criteria
Evaluation
Was the existing state in the key issues described?
F
Were the past trends for the key issues analyzed (optimally also including main
P
drivers)?
Was the likely future evolution of the key issues without the plans implementation
P
described
Did the analyses highlight main concerns regarding the key issues?
P
Verbal summary:
The SEA noted that There is a lot of information of the proposed development in coastal city in
Padang but was very scattered. It made an initial attempt to consolidate this information and gave
recommendations for further consolidation during detailed planning of the development.
In order to get a clear view of the evolving changes in coast line in Padang and the pattern of
coastal space use in the study area, the assessment team made efforts to obtain old maps available
within the Government of Padang City and from other sources. Maps and information received in
various formats were concerted, georeferenced and integrated into GIS base map. The results of the
map study were then compared with aerial photographs and costal hydrology and wave study. Also,
residents who have lived near the coast for a long time were interviewed to solicit their memory of
coastal abrasion. Other supporting data also included old photographs taken in Padang over the past
100 years.
The baseline studies also included overview of the proposed development policies for the study area
and ad hoc conclusions were made on key arising issues of concern (such as land ownerships,
socio-economic trends, etc.)
Quality issue 4: Evaluation of impacts
Detailed quality criteria
Evaluation
Were conflicts between objectives for the key issues and PPPs objectives analysed?
M
Was the full range of impacts to all key issues evaluated? If not, what significant
F
impacts were overlooked?
Were the impacts characterized and described?
F
Were secondary/indirect and cumulative impacts considered?
P
Were impacts quantified where possible?
M
Was impacts evaluation sufficiently substantiated by calculations, examples,
M
references to international and national literature etc.?
Were all alternatives suggested by the PPP assessed?
P
Verbal summary:
The SEA provides three types of information:
41
Evaluation
42
43
6.4
Name of pilot
Responsible authority
Year of implementation
National consultants involved
International
consultants
involved
Language
of
SEA
report
reviewed
Evaluation
P
M
P
P
P
P
P
P
P
F
44
development in the whole country. The SEA issues were however not very clearly and systematically
framed, nor was the territorial focus (key areas of concern) defined.
Overall, the analytical focus of the SEA was not well defined.
Quality issue 3: Baseline analysis
Detailed quality criteria
Was the existing state in the key issues described?
Were the past trends for the key issues analyzed (optimally also including main
drivers)?
Was the likely future evolution of the key issues without the plans implementation
described
Did the analyses highlight main concerns regarding the key issues?
Verbal summary:
The documentation provided in the SEA does not deal with baseline trends at all.
Evaluation
M
M
M
M
45
46
6.5
Name of pilot
Responsible authority
Year of implementation
National consultants involved
International
consultants
involved
Language
of
SEA
report
reviewed
47
Evaluation
P
M
P
48
Does the SEA report clearly state which recommendations and suggestions given by
M
SEA have been integrated in the plan (i.e. if there were any changes of the plan resulting
from SEA)?
Does the SEA report indentify sources of information, including expert judgement and
M
matters of opinion?
Does the SEA report contain a non-technical summary?
M
Verbal summary:
The SEA report includes chapters on impact evaluation, mitigation measures, and recommendations.
There are no sections describing background of SEA arrangement, SEA methodology, scoping, and
baseline data analysis. The report also does not provide a non-technical executive summary.
49
6.6
Name of pilot
Responsible authority
Year of implementation
National consultants involved
International
involved
Language
of
reviewed
consultants
SEA
report
Evaluation
50
Evaluation
P
P
P
M
51
Does the SEA report indentify sources of information, including expert judgement
M
and matters of opinion?
Does the SEA report contain a non-technical summary?
M
Verbal summary:
The report has a logical structure from the background to the recommendation, but there is unusual
structure to provide baseline data before the strategic issues. This makes the baseline data full of
information which could not have relationship with the key issues. The final chapter, which is
dedicated to the conclusions and recommendations, clearly states the recommendations which
linked with the mitigation measures.
Quality issue 7: Decision-making
Detailed quality criteria
Have the conclusions and recommendations given by SEA been considered in the
PPPs approval?
Verbal summary:
The report does not provide information regarding the decision making.
Evaluation
M
52
6.7
Name of pilot
Responsible authority
Year of implementation
National consultants involved
International
consultants
involved
Language
of
SEA
report
reviewed
Evaluation
P
53
Were the past trends for the key issues analyzed (optimally also including main
P
drivers)?
Was the likely future evolution of the key issues without the plans implementation
M
described
Did the analyses highlight main concerns regarding the key issues?
P
Verbal summary:
The SEA report mentions certain information on the baseline as a part of mitigation measures in
chapter 6. The report provides description of each issue and the main drivers influencing the
situation such as land clearing, which was identified as a driver for sedimentation and bush/forest
fires, while overlaps of land use permit was determined as a driver for social conflicts, and the land
conversions is driver for the loss of agriculture land. The report provides maps, which are related to
certain issues (e.g. land use change and land use conflicts), but there is no descriptive interpretation
of the maps. Past trend analysis was undertaken only for forest cover change.
Quality issue 4: Evaluation of impacts
Detailed quality criteria
Evaluation
Were conflicts between objectives for the key issues and PPPs objectives analysed?
M
Was the full range of impacts to all key issues evaluated? If not, what significant
M
impacts were overlooked?
Were the impacts characterized and described?
M
Were secondary/indirect and cumulative impacts considered?
M
Were impacts quantified where possible?
M
Was impacts evaluation sufficiently substantiated by calculations, examples,
M
references to international and national literature etc.?
Were all alternatives suggested by the PPP assessed?
M
Verbal summary:
The part on impacts evaluation (chapter 4) of the SEA report in its introduction claims that the SEA
shall address implication of several PPPs (National RPJP, RPJM and RTRW, RTRW of Kalimantan
Island, Provincial RPJP and RPJM, Provincial sectoral strategic plans); however the chapter mostly
describes the PPP themselves with no clear analysis of impacts. The maps provided in this chapter
illustrate mainly recent status of the issues, not the evaluation, and thus would be more relevant as
a part of the baseline.
Quality issue 5: Mitigation measures and monitoring
Detailed quality criteria
Evaluation
Were measures to prevent, reduce and/or offset any significant adverse effects
F
suggested by SEA for all main impacts identified?
Can mitigation measures suggested by SEA efficiently manage likely adverse impacts?
P
If not, what residual impacts can be expected?
Is there any monitoring scheme proposed?
M
Is it based on the main impacts identified?
M
Verbal summary:
Chapter 6 of the report provides mitigation measures. However, as described above, this chapter
also identifies driver force for each key issue e.g. land clearing is the main driver for
sedimentation key issue in the plantation sector; mining location close to river is the main driver
for sedimentation key issue in mining sector etc.. The mitigation measures are in fact suggested to
mitigate main drivers thus it can be concluded that SEA addressed mainly existing status and
problems and did not deal with the likely impacts of the plans (i.e. National RPJP, RPJM and RTRW,
RTRW of Kalimantan Island, Provincial RPJP and RPJM, Provincial sectoral strategic plans). Due to
this fact it is difficult to find a clear link between mitigation measures and relevant PPPs i.e. it is not
clear into which plans and how it is supposed the mitigation measures will be integrated and
implemented.
Quality issue 6: SEA report
Detailed quality criteria
Evaluation
54
Evaluation
M
55
6.8
Name of pilot
Responsible authority
Year of implementation
National consultants involved
International
consultants
involved
Language
of
SEA
report
reviewed
56
57
Evaluation
M
58
6.9
Name of pilot
Responsible authority
Year of implementation
National consultants involved
International
consultants
involved
Language
of
SEA
report
reviewed
Evaluation
P
59
Were the past trends for the key issues analyzed (optimally also including main
P
drivers)?
Was the likely future evolution of the key issues without the plans implementation
M
described
Did the analyses highlight main concerns regarding the key issues?
M
Verbal summary:
The SEA report contains specific chapter on baseline analysis. For some key issues defined in the
scoping the report provides description of current state such as disaster risk (flood, liquefaction,
tsunami) and population aspects , while for some other issues such information is missing (namely
key issues of public health, environment degradation and transportation system). Main drivers and
likely future evolution are provided on population issue only (high migration rate from hinterland),
while it was not elaborated for other issues.
Quality issue 4: Evaluation of impacts
Detailed quality criteria
Evaluation
Were conflicts between objectives for the key issues and PPPs objectives analysed?
M
Was the full range of impacts to all key issues evaluated? If not, what significant
M
impacts were overlooked?
Were the impacts characterized and described?
M
Were secondary/indirect and cumulative impacts considered?
M
Were impacts quantified where possible?
M
Was impacts evaluation sufficiently substantiated by calculations, examples,
M
references to international and national literature etc.?
Were all alternatives suggested by the PPP assessed?
P
Verbal summary:
The SEA did not evaluate the impacts. There is only description of the plans without any evaluation
measures. However there are altogether 16 alternatives provided actually it is only a list of
alternatives without further explanation such as references, calculation or examples Some of
suggested alternatives are (1) relocate the kindergarten and elementary schools from RED Zone of
tsunami; (2) Privatisation of waste management; (3) relocate the settlements from high risk zone of
earthquake (fault line). These alternatives are proposed in order to address the key issues such as
geological disaster and environmental degradation and public health. It can be concluded that the SEA
addressed existing status and proposed measures aimed at improving current problems rather than
mitigate likely impacts to be possibly caused by implementation of the plans. Obviously the SEA was
considered as a planning tool, which raised proposals on how to solve post-disaster development
rather than approach analysis plans and proposing their modifications.
Quality issue 5: Mitigation measures and monitoring
Detailed quality criteria
Evaluation
Were measures to prevent, reduce and/or offset any significant adverse effects
M
suggested by SEA for all main impacts identified?
Can mitigation measures suggested by SEA efficiently manage likely adverse impacts?
M
If not, what residual impacts can be expected?
Is there any monitoring scheme proposed?
M
Is it based on the main impacts identified?
M
Verbal summary:
The SEA report provides a list of 21 mitigation measures without clear information how these
measures were developed. Since the impacts evaluation is missing (see above) it is not clear how
the measures are linked to the likely impacts of a specific strategic document (i.e. RTRW, RPJPD,
RPJMD and the rehabilitation and reconstruction plan). Measures are mostly formulated in general
and normative terms e.g. to undertake monitoring on building construction plan in high risk zone.
Quality issue 6: SEA report
Detailed quality criteria
Evaluation
60
Evaluation
M
61
Evaluation
F
P
M
62
causes were identified and sub-objectives and development priorities defined. Considering the main
focus of SEA for Bali it can be concluded that also other issues effecting water resources should have
been included e.g. agriculture development. SEA report explains that a set of priority strategic
issues was developed through consultations with relevant stakeholders (in form of a series of
workshops), however it doesnt provide a clear indication if all originally suggested issues were
accepted and what was the mechanism for selection of the issues to the final list.
The SEA was focused on the entire territory of Bali island. However, this territorial scope was
naturally derived from the administrative and geographic borders (since SEA was conducted for the
Bali province, which covers entire island) and not based on preliminary evaluation of likely impacts
(since SEA was not focused on impacts evaluation).
Quality issue 3: Baseline analysis
Detailed quality criteria
Evaluation
Was the existing state in the key issues described?
F
Were the past trends for the key issues analyzed (optimally also including main
M
drivers)?
Was the likely future evolution of the key issues without the plans
M
implementation described
Did the analyses highlight main concerns regarding the key issues?
P
Verbal summary:
The SEA report provides a profile of Bali Province (Chapter III), which besides basic information
about the islands administration presents also facts on its topography, morphology, geological
structure, soil types, climate (including data on rainfalls and air temperature), hydrology and water
resources potential (with detailed overview of rivers, lakes, ponds, reservoirs and springs) and forest
areas. However, considering the main focus of SEA, more detailed information of water quality,
sources of water pollution, water consumption as well as regarding the health status and diversity of
forests should have been provided. The SEA did not describe the main aspects of the public health
(e.g. status of water-borne diseases etc.) and population growth, which can be considered as
important for Bali.
Even if the trends are not described, for each priority strategic issue the relevant causes are
described (e.g. salt water intrusion is caused by excessive exploitation of groundwater) in the SEA
report. However, causes described are not supported by data and information (e.g. destruction of
forests is mentioned as one of the causes of surface water discharge decline, but SEA report doesnt
provide any details on forest degradation, deforestation etc.) and thus a validity of statements
cannot be verified.
Quality issue 4: Evaluation of impacts
Detailed quality criteria
Evaluation
Were conflicts between objectives for the key issues and PPPs objectives
P
analysed?
Was the full range of impacts to all key issues evaluated? If not, what significant
M
impacts were overlooked?
Were the impacts characterized and described?
P
Were secondary/indirect and cumulative impacts considered?
P
Were impacts quantified where possible?
M
Was impacts evaluation sufficiently substantiated by calculations, examples,
M
references to international and national literature etc.?
Were all alternatives suggested by the PPP assessed?
NA
Verbal summary:
The SEA did not clearly evaluate the objectives (obviously due to absence of a single PPP to be
addressed by SEA). However, it seems that within discussion on the linkages between the priority
strategic issues and provincial PPPs also potential conflicts and synergies between PPPs objectives
were addressed, although the conclusions are not clearly described in the SEA report.
There are impacts briefly described for each priority strategic issue in the SEA report, however it
actually addresses how the priority strategic issue effects the situation i.e. it doesnt provide
63
information on how the strategic issue might be affected by proposed or expected development
(which is reflect in section causes).
SEA didnt cover a full range of likely impacts; due to its limitation to water resources related
implications, therefore e.g. likely impacts to public health, potential effects of climate change remain
unanswered.
It is also obvious that impacts described for each priority strategic issues could have been
broadened up, since development priorities (which logically should reflect impacts identified) cover
much wider range of issues and problems than presented in impacts description (e.g. neither
impacts nor causes defined for decline of the surface water quality. mention pollution from
agriculture, however several development priorities are focused on reducing the water pollution
from agriculture).
Even if not clearly stated in the SEA report, assessment obviously partially considered secondary
and indirect implications (e.g. regarding public awareness, law enforcement).
Quality issue 5: Mitigation measures and monitoring
Detailed quality criteria
Evaluation
Were measures to prevent, reduce and/or offset any significant adverse effects
P
suggested by SEA for all main impacts identified?
Can mitigation measures suggested by SEA efficiently manage likely adverse
NA
impacts? If not, what residual impacts can be expected?
Is there any monitoring scheme proposed?
P
Is it based on the main impacts identified?
NA
Verbal summary:
Since the SEA wasnt focused on impacts evaluation, there are no clearly defined mitigation
measures in the SEA report. However, development priorities proposed for each priority strategic
issue (and then clustered) can be understood as a certain form of mitigation, since development
priorities aimed at improving current situation. The nature of suggested mitigation measures is
rather general and is formulated as objectives (e.g. increase green open space or increasing use
of organic fertilizers and pesticides), which is in line with the overall approach to this SEA.
For each strategic priority issue there are indicators and their evaluation described in the SEA report
(Chapter IX). Their linkages to baseline trends cannot be evaluated, since baseline information was
not analyzed in the SEA. The SEA report doesnt clearly assign responsibility for monitoring and for
related activities (in response to monitoring results), however it is assumed that it should be a role
of the authorities listed in Table 25 (Chapter VIII) for each cluster of development priorities.
Quality issue 6: SEA report
Detailed quality criteria
Evaluation
Is the SEA report readers-friendly?
P
Does the SEA report describe the SEA process and all its stages and analyses as
P
well as the overall methodology/approach used?
Were the conclusions and recommendations towards the PPP given by SEA made
P
explicit?
Does the SEA report clearly state which recommendations and suggestions given
NA
by SEA have been integrated in the plan (i.e. if there were any changes of the
plan resulting from SEA)?
Does the SEA report indentify sources of information, including expert judgement
P
and matters of opinion?
Does the SEA report contain a non-technical summary?
M
Verbal summary:
The English version of the SEA report is easily readable in terms of the language; however the
structure and internal logic of the document could be enhanced (its e.g. not fully clear what methods
were used for final selection of priority strategic issues, why only three priority strategic issues are
analyzed in Table 24 etc.). Actually, the SEA report is structured along the workshops organized
within SEA process, however mixed with other parts (e.g. after Chapter III Brief profile of Bali
Province follows chapter IV dedicated to review of the workshop I Scoping) with no clear links
between chapters (e.g. how information from situation description (Chapter III) were used in further
64
steps, workshops and discussions) it is not always clear what is the main purpose of a certain step of
SEA (what are the main outputs from discussions on linkages between priority strategic issues and
provincial PPPs).
The SEA resulted in a list of recommendations (Chapter X of the SEA report), which are formulated
in a form of objectives or development priorities (which is in accordance with overall approach to
SEA for Bali). It is, however, not clear from the report, how proposed recommendations are
supposed to be used in further development, in PPPs, in relevant decision-making processes.
Chapter III Brief profile of Bali Province mentions sources of information, however further chapters
do not do so the most of the findings, conclusions is obviously based on the discussions among
stakeholders and it is not fully clear from the SEA report what were the experts inputs (e.g. from
the SEA team or from other experts involved).
Quality issue 7: Decision-making
Detailed quality criteria
Evaluation
Have the conclusions and recommendations given by SEA been considered in the
NA
PPPs approval?
Verbal summary:
As described earlier, the SEA was not attached to any planning process. There was a general
informal statement given by representatives of Bappeda, that results of SEA will be used in
preparation of future provincial plans as well as it will be promoted to be considered in planning
processes at the district level within the province. However, there is no information available how
exactly this statement has been followed.
Quality issue 8: Stakeholders participation
Detailed quality criteria
Evaluation
Were the stakeholders to be involved in SEA clearly identified?
?
Did all relevant stakeholders have an opportunity to provide comments and inputs
?
during the SEA process? If not, which key stakeholders were not invited?
Were any SEA information / documents made publicly accessible during the SEA
M
process? If so, which means were used?
Verbal summary
The approach to SEA for Bali was solely based on consultations and conclusions from discussions
present the main inputs for the assessment (and in fact present the assessment itself). The SEA
report present in Chapter II methods and tools used in the SEA process, however it is not clearly
indicated how comments and opinions raised by stakeholders were used (if all of them or how the
selection / clustering was made etc.). The SEA report doesnt provide any information on
stakeholders involved which stakeholders participated, how they were identified etc.
65
Evaluation
F
F
P
66
67
Evaluation
M
68
Evaluation
P
P
P
Evaluation
P
M
M
P
69
Verbal summary:
The baseline analysis was developed for a number of issues; however the large part is dedicated to
the aquaculture production itself and related issues (e.g. fish consumption, investments in fishery
sector, expert etc.). Besides it only mentioned water quality, mangroves and spatial aspect, however
again it is mainly related to production rather than environmental problems and concerns (e.g.
regarding water quality it describes mainly importance of water quality for aquaculture and does not
elaborate details on water pollution from aquaculture production). The future trend is estimate only
for aquaculture production.
Although not as a part of baseline analysis (in chapter on impacts), the SEA report mentions overall
trend for water quality (p. 94) If the growth and waste disposal of the entire industrial sub sectors
is not to be controlled then the rate of water pollution will become higher and described also other
drivers of water pollution (agriculture), however it is not clear how this fact was considered when
evaluating impacts of aquaculture development.
Quality issue 4: Evaluation of impacts
Detailed quality criteria
Evaluation
Were conflicts between objectives for the key issues and PPPs objectives
M
analysed?
Was the full range of impacts to all key issues evaluated? If not, what significant
P
impacts were overlooked?
Were the impacts characterized and described?
M
Were secondary/indirect and cumulative impacts considered?
P
Were impacts quantified where possible?
P
Was impacts evaluation sufficiently substantiated by calculations, examples,
P
references to international and national literature etc.?
Were all alternatives suggested by the PPP assessed?
NA
Verbal summary:
The SEA analyzes links between the aquaculture production and several other sectors. It describes
also environmental consequences of aquaculture production mentioning ecosystem/ habitat
degradation (focusing on mangroves) and water pollution, and provides an overview of ecological
characteristics of areas for aquaculture production and their land supporting capability.
It quantifies likely waste production (1.747.500 tons) resulting from shrimp production improvement
programme (with target 201% increase), other likely impacts are described only qualitatively and in
a very general way.
Quality issue 5: Mitigation measures and monitoring
Detailed quality criteria
Evaluation
Were measures to prevent, reduce and/or offset any significant adverse effects
P
suggested by SEA for all main impacts identified?
Can mitigation measures suggested by SEA efficiently manage likely adverse
M
impacts? If not, what residual impacts can be expected?
Is there any monitoring scheme proposed?
M
Is it based on the main impacts identified?
M
Verbal summary:
The SEA proposed several very general mitigation measures, which are not linked to impacts
identified (which in fact would be very difficult considering general description of likely impacts) and
formulated rather as policy guidance or objectives (e.g. adequate water quality needs to be
ensured). Establishment of specific body (team or committee) to accelerate increase of shrimp
production is proposed by SEA this body should include representatives of the Directorate General
of Aquaculture CTF, Shrimp Club Indonesia, Kiara, WWF, feed companies etc.
Chapter on mitigation measures describes two alternatives how to achieve planned target for shrimp
production and mentions related consequences regarding water pollution.
There is neither monitoring scheme nor indicators proposed in the SEA report.
Quality issue 6: SEA report
Detailed quality criteria
Is the SEA report readers-friendly?
Does the SEA report describe the SEA process and all its stages and analyses as
well as the overall methodology/approach used?
Evaluation
P
F
70
Were the conclusions and recommendations towards the PPP given by SEA made
P
explicit?
Does the SEA report clearly state which recommendations and suggestions given
M
by SEA have been integrated in the plan (i.e. if there were any changes of the
plan resulting from SEA)?
Does the SEA report indentify sources of information, including expert judgement
P
and matters of opinion?
Does the SEA report contain a non-technical summary?
F
Verbal summary:
The SEA report provides full description of the SEA method and approach used including thorough
theoretical background. Although it defines a number of recommendations, it is not explicitly linked
to the document assessed. The SEA report does not indicate whether recommendations were
integrated in the plan.
Quality issue 7: Decision-making
Detailed quality criteria
Evaluation
Have the conclusions and recommendations given by SEA been considered in the
PPPs approval?
Verbal summary:
It is not clear from the SEA report if (and how) the conclusions have been integrated in the PPP.
Quality issue 8: Stakeholders participation
Detailed quality criteria
Evaluation
Were the stakeholders to be involved in SEA clearly identified?
P
Did all relevant stakeholders have an opportunity to provide comments and inputs
F
during the SEA process? If not, which key stakeholders were not invited?
Were any SEA information / documents made publicly accessible during the SEA
M
process? If so, which means were used?
Verbal summary:
The SEA report mentions that relevant stakeholders were identified at the initial stages of SEA
process and provides that stakeholders identified are mainly from the ministries/institutions other
than the one that is responsible for the planning, non-governmental parties like business
association, relevant commission and community, environmental expert, research
institution/university, as well as organizations/NGOs which are having competency in fishery sector
development (especially in Aquaculture) being assessed however their list is not attached.
As it follows from the SEA report, the stakeholders were involved throughout the entire SEA process
participating at the workshops and meetings participants were mainly from other ministries,
however representatives from NGOs were invited and participated in some of the SEA meetings.
71
Moreover, it is states in the SEA report (p. 39), that there is only one activity that potentially
damage the environment and sustainable development: policy making activity, policy implementation
program and evaluation in mineral and coal mining (activity no. 2).
The SEA report doesnt clearly provide information on process design and communication among
teams, however obviously there was communication between SEA team (Bappenas) and the planning
agency (MOEMR). The SEA report mentions that the SEA process had been planned with full
involvement of the MOEMR (p. 35).
The SEA report mentions several times cooperation and communication between Bappenas and
MOEMR, however it is not fully clear if (and how) the SEA process was linked to the planning process.
Quality issue 2: Scope of SEA
Detailed quality criteria
Were the key issues clearly defined?
Did SEA cover all relevant issues? If not, what are the most important missing issues?
Were following aspects addressed in SEA:
Evaluation
F
P
M
P
NA
72
Verbal summary:
The SEA was focused on several strategic issues (table 4.6, p. 48):
1.
Change of paradigm about mine, from foreign exchange to main resource
2.
High social conflicts
3.
Post mining supervision and enforcement
4.
Licensing process problems
5.
Area overlapping
6.
Limited human resources in mining sector, especially in the district
7.
Unsynchronized policy and coordination between central and district government and inter
ministry.
However, the executive summary provides slightly different set of issues (p. viii). Moreover, tables
4.1 4.4 (pp. 37 39) provide more detailed overview of potential impacts (environmental and
social), obstacles and challenges (as a result of FDG). It is not fully clear how these issues were
translated in the strategic issues listed above. Considering likely generic impacts of the coal mining,
it can be recommended including theme of public health and livelihood as a separate issue in order
to clearly illustrate likely impacts of the mining to the human population (including migration and
resettlement due to opening new mines).
Generally, the report claims relevant provisions of the LEPM as well as it provides that
implementation of SEA is important to be carried out in energy and mineral resources sector in
order to achieve responsible management (p. 2), however obviously SEA did not explicitly focus on
aspects defined by the LEPM.
The territorial dimension of the SEA is not clearly formulated in the SEA report. As provided by the
SEA report the SEA was carried out for mining sector and thus the most probably the assessment
covered the entire country. For strategic issue Area overlapping is addressed only Sumatera and
South Kalimantan as the areas with the largest coal reserves and mining activities.
Quality issue 3: Baseline analysis
Detailed quality criteria
Evaluation
Was the existing state in the key issues described?
M
Were the past trends for the key issues analyzed (optimally also including main
M
drivers)?
Was the likely future evolution of the key issues without the plans
M
implementation described
Did the analyses highlight main concerns regarding the key issues?
M
Verbal summary:
The SEA report includes chapter on baseline analysis, however it is solely focused on the coal mining
sector itself and does not address the strategic issues identified.
Evaluation
M
P
P
P
P
P
NA
73
Verbal summary:
The SEA describes likely impacts of the coal mining in four aspects impacts on economy, impacts
on community and social issues, impacts on environmental issues, and impacts on institutional issues.
The impacts on the strategic issues Limited human resources in mining sector, especially in the
district and Unsynchronized policy and coordination between central and district government and
inter ministry are not addressed.
The evaluation is described in a general way and doesnt specify which impacts might be arising from
which PPPs objectives i.e. it doesnt identify specific conflicts. It seems that impacts evaluation
didnt deal with PPPs objectives, but rather addressed general likely effects on coal mining.
As mentioned above, the impacts evaluation was done in a very general way and it seems that
certain likely impacts have not been addressed. E.g. regarding likely environmental impacts the SEA
report (p. 52) only mentions that there are potential effects on water, soil, air, landscape, flora and
fauna etc., however no further details are provided. Similarly, likely social effects are listed only briefly
its provided that .social conflict has many different forms, but the report doesnt specific which
social problems can be expected, in which areas etc. The report doesnt mention e.g. impacts related
to migration or resettlement due to coal mining activities.
The sub-chapter on likely economic impacts (4.2.1) is mainly focused on positive impacts but it
doesnt mention likely negative impacts on local economy if other sectors can influenced by mining
(e.g. the loss of agriculture land, loss of forests etc.). It also doesnt address other likely secondary
economic impacts e.g. related to costs for transport infrastructure to be repaired after damages
caused by the coal transport (it is briefly mentioned in the sub-chapter 4.2.4). The evaluation doesnt
answer the question how to replace financial resources coming from the coal export if as planned
the coal will be used mainly to secure domestic energy demand.
The most detailed evaluation was carried out for the issue of Land overlapping in Sumatera
(4.2.4.1), which is based on the GIS analysis. However, it seems that more specific conclusions on
the likely impacts could have been summarized (some models show that up to approx. 40% of the
conservation areas can be affected by coal mining, and 43% of the protected forests respectively).
The assessment was carried out mainly on a qualitative basis. The only quantification was done for
Area overlapping (quantification of protected forests and conservation areas to be potentially
affected by mining activities in Sumatra island).
Quality issue 5: Mitigation measures and monitoring
Detailed quality criteria
Evaluation
Were measures to prevent, reduce and/or offset any significant adverse effects
P
suggested by SEA for all main impacts identified?
Can mitigation measures suggested by SEA efficiently manage likely adverse
P
impacts? If not, what residual impacts can be expected?
Is there any monitoring scheme proposed?
M
Is it based on the main impacts identified?
M
Verbal summary:
The SEA report defines mitigation measures in sub-chapter 4.2.5, as well as recommendations
provided in chapter 5 can be considered as mitigation measures; suggested mitigation measures are
formulated in a general way and can be understood mainly as policy recommendations, rather than
specific measure reflecting specific likely impacts.
Thus it is difficult to find out which specific impacts can be mitigated by suggested measure subchapter 4.2.5 e.g. only mentions that by implementing good mining practice mining companies
will automatically minimize the impact to the environment.
There are neither indicators nor monitoring system suggested by the SEA. The SEA Report only
mentions (chapter 5, p. 70) that Activities to build and implementation of monitoring and evaluation
system of mining activities and after completion of mining activities in accordance with the applicable
provisions.
Quality issue 6: SEA report
Detailed quality criteria
Is the SEA report readers-friendly?
Does the SEA report describe the SEA process and all its stages and analyses as
well as the overall methodology/approach used?
Evaluation
F
F
74
Were the conclusions and recommendations towards the PPP given by SEA made
P
explicit?
Does the SEA report clearly state which recommendations and suggestions given
M
by SEA have been integrated in the plan (i.e. if there were any changes of the
plan resulting from SEA)?
Does the SEA report indentify sources of information, including expert judgement
P
and matters of opinion?
Does the SEA report contain a non-technical summary?
F
Verbal summary:
The SEA report has a logical structure i.e. starting from introduction and background information,
followed by SEA methodology, through baseline analysis on coal, impacts evaluation, mitigation and
recommendations. It uses figures, tables and maps especially in baseline analysis on coal and GIS
analysis on Sumatra island (for the strategic issue Areas overlapping). However it could have been
used more extensively for impact analysis and evaluation.
The SEA provides a number of recommendations and conclusions (Chapter 5), which are not clearly
linked to impacts identified and are formulated in a form of general statements i.e. the report doesnt
conclude what are the main impacts, whether these impacts can be fully mitigated etc.
Recommendations are focused on strengthening of the institutional cooperation and stakeholders
involvement in planning. The SEA also suggested specific inputs to be integrated in the PPP as well
as recommendations for better SEA practice. It is not clear from the SEA report if (and how) the
conclusions have been integrated in the PPP.
Quality issue 7: Decision-making
Detailed quality criteria
Evaluation
Have the conclusions and recommendations given by SEA been considered in the
M
PPPs approval?
Verbal summary:
It is not clear from the SEA report if (and how) the conclusions have been integrated in the PPP.
75
English
Assessing the potential impacts of policies, plans and programmes contained in the Provincial
Spatial Plan design on the environmental conditions
Formulating the options for mitigating of impacts and / or alternative PPP, and
Integrating the sustainable development principles into the formulation of the RSP PPP of the
North Sulawesi Province
Border Area
Biodiversity
Evaluation
F
F
P
F
M
76
Energy Availability
Social, Cultural and Nature Issues
The SEA wasnt solely focused on the environmental issues and addressed also wider sustainability
themes e.g. social and culture, energy availability etc. It is also very good that the SEA report
provides short description for each strategic issue explaining its importance and relevance to the SEA.
As explained in the SEA report, a set of 10 strategic issues was developed through discussion and the
original list of 35 issues was generalized and grouped into above mentioned 10 strategic issues.
Further in the SEA process, likely impacts on these 10 strategic issues were evaluated. However, the
logical link should go from general issues to more specific ones (and not vice versa).
The SEA was focused on the area of the North Sulawesi Province, which is defined in the SEA report.
Quality issue 3: Baseline analysis
Detailed quality criteria
Evaluation
Was the existing state in the key issues described?
P
Were the past trends for the key issues analyzed (optimally also including main
P
drivers)?
Was the likely future evolution of the key issues without the plans implementation
P
described
Did the analyses highlight main concerns regarding the key issues?
P
Verbal summary:
The SEA report provides a brief overview of each strategic issue its scope and detail vary issue by
issue. However, it can be concluded that the description of current status could be more detailed
considering the nature of RSP (i.e. specifying concrete development proposal) it would enable more
detailed analysis of the likely impacts. E.g. for the issue Management of coastal, marine and small
islands areas it could have been described which territories are the most endangered by coastal
development, which small islands etc. Similarly, for the Land, sea and air transportation the
information on areas and territories with significant lack of transport infrastructure could have been
provided, a part dedicated to Social, cultural and nature issues could have mentioned whether
there have been any tensions between different ethnic groups etc.
For some strategic issues the SEA report provides description of past trends (e.g. fishery production,
water pollution, population growth), while for other strategic issues such information are missing
(issues of border areas, land, sea and air transportation, biodiversity, environmental damage
and pollution, energy availability etc.).
Main drivers are mentioned only for few strategic issues by the SEA report (e.g. high population growth
and rapid development activities in coastal areas, environmental problems regarding illegal logging,
irresponsible human activities etc.), while for majority of strategic issues it is not addressed.
However, even if drivers are described, this description is not supported by data and information
(e.g. rapid development activities and high population growth are mentioned as drivers of the
coastal degradation, but the SEA report doesnt provide any details on it e.g. which parts of the
coastline are degraded, damaged etc.) and thus a validity of statements cannot be verified.
Likely future trends are estimated only for the population growth and regarding renewable energy
sources.
Quality issue 4: Evaluation of impacts
Detailed quality criteria
Were conflicts between objectives for the key issues and PPPs objectives analysed?
Was the full range of impacts to all key issues evaluated? If not, what significant
impacts were overlooked?
Were the impacts characterized and described?
Were secondary/indirect and cumulative impacts considered?
Were impacts quantified where possible?
Was impacts evaluation sufficiently substantiated by calculations, examples,
references to international and national literature etc.?
Evaluation
M
P
P
P
P
P
77
78
There are neither indicators nor monitoring system suggested by the SEA RSP. The SEA Report only
mentions (chapter 6.2) that To evaluate and monitor the implementation of North Sulawesi Province
SEA, the activities of North Sulawesi Province SEA team should be sustainable and set up the work
plan for the running years.
Stakeholders mapping
Scoping
Data collection
Document review
Involvement of stakeholders
Decision-making
It can be noted that data collection should be placed before analysis of baseline data, since logically
first it is necessary to collect data which can be further analyzed.
The SEA provides a number of recommendations (Chapter 5) and conclusions (Chapter 6), which are
formulated in a form of general statements, which can be understood mainly as spatial
development policies. It is not clear from the report, which recommendations were integrated in
the plan. The SEA report only concludes that North Sulawesi spatial plan has considered
environmental and sustainable development aspects in its PPP (sub-chapter 6.1, p. 77). This
statement seems to be contradicting with a number of significant impacts identified in previous steps
of the assessment.
The SEA report provides the list of references; however the source of information is not always
indicated directly in the text.
Quality issue 7: Decision-making
Detailed quality criteria
Have the conclusions and recommendations given by SEA been considered in the PPPs
approval?
Evaluation
M
79
Verbal summary:
The explanation of the decision-making (sub-chapter 1.4.8) is not fully clear from the SEA report,
since it talks about decision-making on the SEA RSP results., while doesnt mention how SEA RSP
results were considered in decision-making related to the RSP itself (i.e. approval or adoption of the
spatial plan). Further, the SEA report lists the steps of the SEA RSP (parts Abstract p. iii, and
Summary p. viii) and places preparation of final report only after decision-making. It is not
fully clear if final report means final SEA report if so, it should be finalized before the decisionmaking (i.e. approval of the spatial plan), because the SEA report should be a background document
for the decision.
Quality issue 8: Stakeholders participation
Detailed quality criteria
Evaluation
Were the stakeholders to be involved in SEA clearly identified?
P
Did all relevant stakeholders have an opportunity to provide comments and inputs
P
during the SEA process? If not, which key stakeholders were not invited?
Were any SEA information / documents made publicly accessible during the SEA
M
process? If so, which means were used?
Verbal summary:
The SEA report doesnt provide details regarding stakeholders consultations; it only mentions that
scoping exercise was carried out through group interaction and describes that the stakeholder
mapping was carried out (sub-chapter 1.4.1). Obviously, the SEA report was not open for wide
public, the consultations were limited only to invited stakeholders.
80
Evaluation
F
P
P
81
82
Evaluation
M
83
English
Evaluation
F
F
P
84
3.
4.
5.
6.
Infrastructure (competitiveness)
7. Inter-regional disparity
8. Agricultural facilities and infrastructures availability
9. Insufficient road infrastructure
10. Investment
11. Production competitiveness
12. IKM and UKM
Social disparity
13. High number of population growth and unequal population distribution
14. Low quality of public basic need services
15. High number of PMKS
16. Unachieved gender equality and justice
Considering this scope, it can be concluded that the SEA covered the most of the aspects defined by
the Law on Environmnetal Protection and Management, and in fact went beyond it by addressing
e.g. the issues of gender equality, population distribution, road infrastructure etc.
The SEA was focused on the area of the entire province and did not considered likely transboundary
impacts.
Quality issue 3: Baseline analysis
Detailed quality criteria
Evaluation
Was the existing state in the key issues described?
F
Were the past trends for the key issues analyzed (optimally also including main
P
drivers)?
Was the likely future evolution of the key issues without the plans
M
implementation described
Did the analyses highlight main concerns regarding the key issues?
P
Verbal summary:
The SEA report provides first a brief overview for each strategic issue explaining its importance as
well as mentioning existing problems in the province. Further, in following part (3.5.1) the baseline
trends are described. For a majority of strategic issues the SEA report provides description of past
trends.
For some trends, the SEA identified drivers of trends (e.g. for natural disasters the SEA report
provides that flood disaster..is normally caused by forests and protected areas degradation on its
upper side as well as the conversion of storm water catchment area to developed land, or for land
conversion it is mentioned that land conversion may occur due to policy leading to the conversion
and it can also be caused by low farmer exchange rate), while for other issues drivers are missing
(e.g. it is not explained why areas of forests or mangroves are decreasing, or why investments into
province has been lowered). It also seems that further drivers might be relevant for certain issues
e.g. industrial pollution or pollution from transport could have been probably mentioned within the
environmental pollution issue.
Quality issue 4: Evaluation of impacts
Detailed quality criteria
Were conflicts between objectives for the key issues and PPPs objectives
analysed?
Was the full range of impacts to all key issues evaluated? If not, what significant
impacts were overlooked?
Were the impacts characterized and described?
Evaluation
M
P
P
85
Evaluation
F
F
P
M
86
Evaluation
M
87
Evaluation
F
F
P
88
89
Evaluation
M
90
Evaluation
P
P
91
insufficiently defined territorial scope, since impacts going beyond borders of the province can be
expected.
Quality issue 3: Baseline analysis
Detailed quality criteria
Evaluation
Was the existing state in the key issues described?
P
Were the past trends for the key issues analyzed (optimally also including main
P
drivers)?
Was the likely future evolution of the key issues without the plans
P
implementation described
Did the analyses highlight main concerns regarding the key issues?
P
Verbal summary:
The SEA report provides a brief overview of the strategic issues. The scope and depth of the
description vary significantly issue by issue, obviously depending on data availability thus it can be
concluded that the focus of the analytical work was driven by data availability rather than by actual
SEA needs. Description for some of the issues provides past and future trends while the other issues
are not supplemented with such trend and there is no reasoning provided. Several main drivers
influencing trends were identified (e.g. high coal mining activities and related transport as drivers for
the damage of road infrastructure and overlapping land use permits as the driver for the land and
forest degradation).
Quality issue 4: Evaluation of impacts
Detailed quality criteria
Evaluation
Were conflicts between objectives for the key issues and PPPs objectives
F
analysed?
Was the full range of impacts to all key issues evaluated? If not, what significant
P
impacts were overlooked?
Were the impacts characterized and described?
P
Were secondary/indirect and cumulative impacts considered?
P
Were impacts quantified where possible?
Was impacts evaluation sufficiently substantiated by calculations, examples,
P
references to international and national literature etc.?
Were all alternatives suggested by the PPP assessed?
P
Verbal summary:
The SEA evaluates five development programs included in the spatial plan on two strategic issues
defined in scoping stage. The five programmes were screened from altogether eight programmes
suggested by the spatial plan as programmes that have potential negative impact on the key issues.
However, the SEA report does not provide sufficient description of the screening process and
substantiation of this selection.
The evaluation mentions secondary and cumulative impacts. The SEA did use spatial analyses to
evaluate impacts of certain programs such as the proposed of Sumatera Toll Road (where impacts to
the conservation area can be predicted). The SEA report provides information about Road Map of
Sumatera Ecosystem that is considered as an alternative for inclusion into the spatial plan of Jambi
Province. The SEA carried out a thorough assessment of the Road Map of Sumatera Ecosystem
concluding that proposed programmes in provincial and national spatial plans such toll road,
plantation and mining will endanger the conservation area.
Quality issue 5: Mitigation measures and monitoring
Detailed quality criteria
Were measures to prevent, reduce and/or offset any significant adverse effects
suggested by SEA for all main impacts identified?
Can mitigation measures suggested by SEA efficiently manage likely adverse
impacts? If not, what residual impacts can be expected?
Is there any monitoring scheme proposed?
Evaluation
P
P
M
92
to integrate the Road Map of Sumatera Ecosystem into the provincial spatial plan
to optimize and strengthen the transportation infrastructure programmes with mitigation
measures
to integrate the mitigation measures suggested by SEA into the plantation and mining
development programmes
to delete the development of industrial forest programme in the conservation area from the
proposed RTRW
Although the SEA report how the decision above is (will be) integrated into the plan, it can be
considered as an important achievement.
The SEA report provides a list of references and stakeholders consensus on the recommendations as
well as the non technical summary is provided in the beginning of the report.
Quality issue 7: Decision-making
Detailed quality criteria
Evaluation
Have the conclusions and recommendations given by SEA been considered in the
M
PPPs approval?
Verbal summary:
The report does not provide information about SEA considerations in plans approval, however it can
be supposed that the decision by the Governor (see above) shall be integrated in the plan and
considered in its implementation.
Quality issue 8: Stakeholders participation
Detailed quality criteria
Were the stakeholders to be involved in SEA clearly identified?
Evaluation
F
93
Did all relevant stakeholders have an opportunity to provide comments and inputs
F
during the SEA process? If not, which key stakeholders were not invited?
Were any SEA information / documents made publicly accessible during the SEA
M
process? If so, which means were used?
Verbal summary:
The report provides the stakeholders identified in the preparation stage and there is a statement in
each chapter regarding the involvement of stakeholders. The stakeholders were invited in three
stages i.e. scoping, assessment and mitigation/recommendation formulation stage. The stakeholders
involved were from national, provincial and district government, local and national NGOs, local
universities and indigenous people. In addtion, in its appendix 1 the report provides stakeholder
consensus in the mitigation and recommendation stage with signatures included.
94
Evaluation
F
F
P
95
Evaluation
F
M
P
96
Does the SEA report clearly state which recommendations and suggestions given
M
by SEA have been integrated in the plan (i.e. if there were any changes of the
plan resulting from SEA)?
Does the SEA report indentify sources of information, including expert judgement
M
and matters of opinion?
Does the SEA report contain a non-technical summary?
F
Verbal summary:
The SEA report has a logical structure and follows SEA analyses from the initial stages to the
recommendations. The report does not provide description of the SEA process as well as the
methodology/approach to SEA is missing.
Evaluation
M
97
6.20 SEA for Spatial Plan of National Strategic Area (KSN) Sunda
Strait
Name of pilot
Responsible authority
Year of implementation
National consultants involved
International consultants involved
Language of SEA report reviewed
Evaluation
F
F
F
F
F
98
Verbal summary:
The SEA report (chapter 6 and further sections in chapters 8, 9 and 10) provides full overview of the
strategic environmental issues, which are addressed in detail in the SEA analyses, as well as it
explains how the issues were defined and identified. The the scoping process used the spatial
analyses and maps were prepared illustraiting current polluting activities and environmenal issues
and their spatial relation to future land-use and infrastructure.
As provided by the SEA report, aspects stipulated by the LEPM were considered when defining the
strategic environmental issues as well as obviously these issues (among others) were taken into
account within impacts assessment.
Administratively, the scope of SEA is given by the KSN Sunda Strait Spatial Plan. However, in order
to define the territorial scope of likely impacts (and thus the real scope of SEA), the SEA report
provides (chapter 6.2) maps to illustrate the overlay of the current baseline status with the future
land used and infrastructure as proposed by the spatial plan.
Although not explicitly mentioned in the SEA report, likely impacts beyond the administrative
boundaries of Banten and Lumpung provinces were obviously also considered in scoping (e.g.
possible interruption of important global oceanic thermal exchange processes).
Quality issue 3: Baseline analysis
Detailed quality criteria
Evaluation
Was the existing state in the key issues described?
F
Were the past trends for the key issues analyzed (optimally also including main
P
drivers)?
Was the likely future evolution of the key issues without the plans
P
implementation described
Did the analyses highlight main concerns regarding the key issues?
F
Verbal summary:
The chapter 5 of the SEA report provides description of baseline conditions, which was a basis for
identification of the strategic environmental issues. The description of the baseline conditions
(chapter 5) is mainly focused on existing status, however for several issues past trends are provided
(e.g. for mangroves, industrial growth or tourism development). Further description of some trends
is provided in the assessment chapters (9 11) and in appendixes D, E and F.
The factors influencing the development have been identified for several issues (e.g. reasons for
mangrove degradation, changes of paddy fields, flooding) in the chapter 5; other drivers are
described within evaluation (chapters 9 11, and appendixes D, E and F).
For several issues the future likely development was described (e.g. for water systems see
appendix F, p. F-18 or wastewater treatment p. 90), however for a number of issues the future
trends without the KSN Sunda Strait Spatial Plan implementation are not provided.
Quality issue 4: Evaluation of impacts
Detailed quality criteria
Were conflicts between objectives for the key issues and PPPs objectives
analysed?
Was the full range of impacts to all key issues evaluated? If not, what significant
impacts were overlooked?
Were the impacts characterized and described?
Were secondary/indirect and cumulative impacts considered?
Were impacts quantified where possible?
Was impacts evaluation sufficiently substantiated by calculations, examples,
references to international and national literature etc.?
Were all alternatives suggested by the PPP assessed?
Evaluation
M
F
F
F
F
F
NA
99
Verbal summary:
The SEA addressed all likely impacts resulting from the KSN Sunda Strait implementation on the
strategic environmental issues defined in the scoping. The assessment considered also secondary or
indirect impacts (where relevant) likely impacts resulting from the KSN Sunda Strait Spatial Plan
implementation as well as the SEA report provides an overview of cumulative evaluation i.e. table
12.1 summarizes how each of the strategic environmental issues can be influenced by the KSN
Sunda Strait Spatial Plan.
For a number of strategic issues the likely impacts were quantified (e.g. regarding the industrial
pollution). The evaluation of impacts is based on thorough studies including a number of national
and international references, case studies, calculations etc.
The KSN Sunda Strait Spatial Plan was prepared as mono-alterative it means that no alternatives
were proposed by the spatial plan.
Quality issue 5: Mitigation measures and monitoring
Detailed quality criteria
Evaluation
Were measures to prevent, reduce and/or offset any significant adverse effects
F
suggested by SEA for all main impacts identified?
Can mitigation measures suggested by SEA efficiently manage likely adverse
F
impacts? If not, what residual impacts can be expected?
Is there any monitoring scheme proposed?
F
Is it based on the main impacts identified?
P
Verbal summary:
The SEA report provides (chapter 13) a number of recommendations linked to likely impacts
identified. Part of recommendations is focused directly on KSN Sunda Strait Spatial Plan, and a
number of recommendations go beyond the plan (e.g. conducting additional studies) as well as
beyond the MOPW administrative responsibility (e.g. establishing KSN Sunda Strait Social Welfare
Panel).
The SEA report describes(chapter 14) general monitoring scheme as well as monitoring indicators
which are formulated mainly as activities needs to ensure the monitoring scheme operates.
However, there are no indicators directly focused on the strategic environmental issues allowing
monitoring the real effect of the KSN Sunda Strait Spatial Plan during its implementation.
The SEA suggested establishing a governmental sub-committee within the implementation and
monitoring scheme proposed, which would be responsible for coordinating the monitoring scheme.
The SEA also proposes that the Indonesian Auditor General should be involved in monitoring of the
SEA indicators.
Quality issue 6: SEA report
Detailed quality criteria
Evaluation
Is the SEA report readers-friendly?
F
Does the SEA report describe the SEA process and all its stages and analyses as
F
well as the overall methodology/approach used?
Were the conclusions and recommendations towards the PPP given by SEA made
F
explicit?
Does the SEA report clearly state which recommendations and suggestions given
M
by SEA have been integrated in the plan (i.e. if there were any changes of the
plan resulting from SEA)?
Does the SEA report indentify sources of information, including expert judgement
F
and matters of opinion?
Does the SEA report contain a non-technical summary?
F
Verbal summary:
The internal logic of the SEA report is very good, it is structured along the steps and analyses
conducted within the SEA and results in recommendations and conclusions. There is a number of
appendices attached to the main body of the report, which provide detailed studies, overview of
consultations etc., as well as the non-technical summary is provided as a separate document.
100
All statements in the SEA report are quite well substantiated by the references to literature or expert
opinion.
There is no clear documentation on which SEA suggestions made throughout the process have been
integrated in the KSN draft (although generally, SEA report claims that integration of SEA input at
different stages of KSN development directly into the KSN process, p. 202). As resulted from the
discussion with the MOPWs Sub-Directorate of Regulations and SEA team representatives in 2012
it seems that no changes of the KSN have been made due to SEA. There was a chance that some
SEA recommendations will be considered in the Presidential Decree on KSN Sunda Strait, and
current situation needs to checked.
Quality issue 7: Decision-making
Detailed quality criteria
Evaluation
Have the conclusions and recommendations given by SEA been considered in the
M
PPPs approval?
Verbal summary:
The SEA report does not provide any information regarding the decision-making due to the fact that
the SEA process was terminated before the approval process.
101
Evaluation
F
F
P
102
Evaluation
F
103
Does the SEA report describe the SEA process and all its stages and analyses as
F
well as the overall methodology/approach used?
Were the conclusions and recommendations towards the PPP given by SEA made
F
explicit?
Does the SEA report clearly state which recommendations and suggestions given
NA
by SEA have been integrated in the plan (i.e. if there were any changes of the
plan resulting from SEA)?
Does the SEA report indentify sources of information, including expert judgement
F
and matters of opinion?
Does the SEA report contain a non-technical summary?
F
Verbal summary:
The report is well structured and intelligible. Conclusions and implications for the planning process
were explicitly stated; employed analytical methods are clearly explained. The report does not
contain information about the reflection of the assessment outputs by the planning process. The
sources of information are in most cases provided and uncertainties regularly acknowledged.
Quality issue 7: Decision-making
Detailed quality criteria
Have the conclusions and recommendations given by SEA been considered in the
PPPs approval?
Verbal summary:
The REA only provides partial input to the overall planning process that is still ongoing.
Evaluation
NA
104
Evaluation
F
F
M
F
NA
105
Verbal summary:
The SEA Babel has a well defined scope i.e. several sustainability themes elaborated in more specific
strategic issues the list covers all relevant aspects. Considering that the tin mining presents the
key economic activity in the province, the emphasis is correctly given to tin-mining related issues.
From initial list of the key issues, the SEA team selected those issues which should be considered
directly in the RPMD this step was done in order to provide early suggestions for the RPJMD
formulation. It can be however recommended to address issue no. 14 The low quality of public
health directly in SEA i.e. enhancing the health quality can be part of RPJMD, but likely impacts on
public health resulting from other RPJMDs priorities and measures were analysed within SEA itself.
Similarly, the issue no. 18 The low law enforcement on environment could have been included in
SEA under Good governance theme and thus SEA should have suggested ways how to better
enforce environmental legislation.
From territorial point of view, the SEA addressed the entire province since the province consists of
two islands, transboundary effects were correctly not considered as relevant.
Quality issue 3: Baseline analysis
Detailed quality criteria
Evaluation
Was the existing state in the key issues described?
F
Were the past trends for the key issues analyzed (optimally also including main
F
drivers)?
Was the likely future evolution of the key issues without the plans
F
implementation described
Did the analyses highlight main concerns regarding the key issues?
F
Verbal summary:
The SEA elaborated the baseline analysis for each strategic issues identified in the scoping stage to
be addressed in the assessment. The baseline analysis is very well developed and provides a
number of information and data on past trends and current situation. It also identifies drivers
influencing trends and based on the likely scenarios of future development are estimated.
106
Evaluation
M
107
Verbal summary:
Although the SEA was carried out during the RPJMD preparation, the final stage of the planning was
still in process after the SEA had been terminated. However, suggestions and recommendations
given by SEA were discussed with the provincial authority at the final workshop and there is an
informal agreement that these would be considered in further RPJMD finalization.
108
Evaluation
F
P
M
P
M
109
Verbal summary:
The strategic issues are clearly defined; however the selection of the issues should have been more
oriented towards environmental, social (and possibly economic) problems in the district. For instance,
the issue 6 incomplete implementation of the district strategic plan is not quite relevant to the RPJMD
the SEA is supposed to evaluate likely effects of the RPJMD and the question is how the RPJMD can
affect the situation regarding the spatial planning (since the spatial planning is a separate planning
system)? Some potentially important issues seem to be missing e.g. the description of the area
(chapter 2) mentions water pollution from mining activities, however it has not been included in the
strategic issues.
In line with previous comments given by the Consultant it can be recommended to broaden-up the
scope of SEA HSU (optimally, it should have addressed at least all issues identified in the pre-scoping)
to cover all aspects of the sustainable development. Considering that issues e.g.:
are highly relevant for Indonesia as such, it is improbable that HSU would not be facing problems and
challenges regarding these issues. At least it should be addressed in scoping and baseline analysis to
find out specific concerns for the district and RPJMD in order to have a solid basis for decision on which
are the key issues to be considered in the SEA (and optimally in the RPJMD).
The SEA was focused on the area of the district, impacts likely going beyond its administrative borders
were not addressed.
Quality issue 3: Baseline analysis
Detailed quality criteria
Evaluation
Was the existing state in the key issues described?
P
Were the past trends for the key issues analyzed (optimally also including main
P
drivers)?
Was the likely future evolution of the key issues without the plans
P
implementation described
Did the analyses highlight main concerns regarding the key issues?
P
Verbal summary:
The SEA elaborated its analytical part within the scoping stage the description of the environment
in the district as well as social and economic conditions is provided. The baseline analysis mentions
important information and data (e.g. scope of floods and vulnerability of the residential areas, health
facilities and agriculture regarding the flood occurrence) including maps and GIS generated
illustrations, for several issue also trends are described (e.g. for the land-use, see p. 9, or population,
see p. 16) with identification of certain drivers e.g. the dominant land cover is swamp forest or
regarding the fishery the probability of caught fish seems like trend that keeps decreasing from year
to year. It much possibly happens because of the ecosystem changing, illegal fishing (however the
frequency keeps decreasing), and the stipulation of reservation that has not been optimal yet.
Whereas fish farming looks like increasing trend because of many swamp pool making, either from
the government support or their own effort.). (see p. 34). The baseline analysis also provides several
very strong statements e.g. Lack of coordination across sectors, particularly with the Environment
sector, which so far are still considered as "parasites" in the process of regional development, because
of the many provisions that should be applied in the implementation of a program of activities, is
considered impractical. (see p. 35), which the most probably well reflects the situation in the district.
However for several issues the trends are not provided if the data are not available to do so (which
might be the case), it should be mentioned in the SEA report. For example, the SEA report mentions
The understanding of this geo-hydrology situation will be helpful to know the risk potential of water
pollution in lake and rivers in the HSU district as the effect of charcoal mine activity around it this
can be considered as a very important issue and the overlay maps is provided. However, optimally
this statement (and based on the map) should be substantiated by more information (i.e. how large
are potential mines, which rivers exactly could be affected etc. and what can be concluded regarding
potential risks of water pollution in the district?).
110
Obviously there has been misunderstanding of purpose of and approach to baseline analysis, since in
many case the parts of the baseline tables which are supposed to described drivers doesnt provide
this information.
For only few issues the likely future trends are estimated (e.g. If planning is not carried out, what
will likely to happen in the future is that Amuntai City will no longer be able to serve any activities of
its population. When this happens, the Amuntai City will be abandoned by its citizens., see p. 37, is
well described possible scenario of future development).
Some important issues were not addressed in the analytical part at all e.g. the availability of water
and waste management are among the key strategic issue, however there are no information and
data regarding situation in the district for these issues in baseline analysis. Thus, it cannot be verified
if these issues are relevant and key for the district. It is not fully on what basis certain issues were
eliminated (i.e. how the short list of the issues was identified from the long list). The relevant
objectives for the key issues were not formulated (it could have been done in the pre-scoping stage).
Quality issue 4: Evaluation of impacts
Detailed quality criteria
Evaluation
Were conflicts between objectives for the key issues and PPPs objectives
P
analysed?
Was the full range of impacts to all key issues evaluated? If not, what significant
P
impacts were overlooked?
Were the impacts characterized and described?
P
Were secondary/indirect and cumulative impacts considered?
M
Were impacts quantified where possible?
M
Was impacts evaluation sufficiently substantiated by calculations, examples,
M
references to international and national literature etc.?
Were all alternatives suggested by the PPP assessed?
NA
Verbal summary:
The SEA evaluated likely impacts of the RPJMD programmes and components on the key strategy
issues using evaluation tables. The impacts evaluation only indicates if the impacts is positive or
negative (using symbol ++,+,-, --) and provides verbal description, however further specification of
the likely impacts is completely missing (i.e. it is not evaluated if likely impacts are direct or indirect,
long-term or short term etc.).
It also seems that the scope of evaluation is too narrow i.e. only a few RPJMD components were
addressed and the most probably there are other parts (programmes etc.) of the PRJM which can have
likely impacts. For example, programme Construction or development of new irrigation areas polders
can for sure have impacts on agriculture (issues no 2), but it is not considered there. Evaluation
doesnt address likely impacts going beyond the borders of the district.
There is missing link between scoping stage and evaluation. The evaluation should conclude how the
RPJMD can affect likely future evaluation (compare to the status without RPJMD implementation as
supposedly described in scoping).
No explanation is provided why HSU spatial plan is mentioned in the evaluation tables (following
personal communication the information from the spatial plan were used to get more precise idea on
likely development as only generally stipulated in the RPJMD however, this is not clear from the
SEA report).
There were no alternatives proposed by the RPJMD.
Quality issue 5: Mitigation measures and monitoring
Detailed quality criteria
Were measures to prevent, reduce and/or offset any significant adverse effects
suggested by SEA for all main impacts identified?
Can mitigation measures suggested by SEA efficiently manage likely adverse
impacts? If not, what residual impacts can be expected?
Is there any monitoring scheme proposed?
Is it based on the main impacts identified?
Evaluation
P
P
M
M
111
Verbal summary:
SEA proposed a number of mitigation measures, some of them directly focused on the RPJMD are well
formulated e.g. for the palm oil plantations development (see p. 47) Do not add new oil palm
plantation land, also summary provided is very good, however for some other impacts identified the
mitigation is missing or seems to be irrelevant.
It would be useful to formulate some suggestions more clear e.g. SEA suggests that the programme
XY should be formulated as follows .. or SEA suggests to add measure on .. and in more detail.
If formulated in this way, this way then it should be easier to discuss it with the RPJMD team / district
authorities what changes of the RPJMD are needed
There are neither indicators nor monitoring scheme suggested by SEA.
Quality issue 6: SEA report
Detailed quality criteria
Evaluation
Is the SEA report readers-friendly?
P
Does the SEA report describe the SEA process and all its stages and analyses as
F
well as the overall methodology/approach used?
Were the conclusions and recommendations towards the PPP given by SEA made
F
explicit?
Does the SEA report clearly state which recommendations and suggestions given
M
by SEA have been integrated in the plan (i.e. if there were any changes of the
plan resulting from SEA)?
Does the SEA report indentify sources of information, including expert judgement
P
and matters of opinion?
Does the SEA report contain a non-technical summary?
F
Verbal summary:
The SEA report is well structured along the SEA stages. It explains the SEA procedure and approach
and describes the linkages between SEA and the planning process highlighting the fact that the SEA
was done during very early stages of the RPJMD formulation. It also provides references and sources
of data and information used in the SEA. The SEA report very correctly mentions limitation (p. 3).
The recommendations and suggestions are clearly formulated, however no indication is provided if
and how these were integrated in the RPJMD.
It is very good that the SEA report includes both Summary as well as Executive summary it can
be however recommended to mention explicitly in the executive summary what the key
recommendations and suggestions towards the RPJMD are provided by SEA (since the executive
summary is supposed to be the main and in some cases only part of the document, which will be
read by the top decision-makers).
Quality issue 7: Decision-making
Detailed quality criteria
Evaluation
Have the conclusions and recommendations given by SEA been considered in the
NA
PPPs approval?
Verbal summary:
As already described above, the SEA was conducted in early stages of the RPJMD preparation.
However, suggestions and recommendations given by SEA were discussed with the district authority
and an informal agreement was made that these will be considered in further RPJMD preparation.
Actually, chapter IV of the SEA report is dedicated to information on how the SEA results should be
considered in further RPJMD preparation.
Quality issue 8: Stakeholders participation
Detailed quality criteria
Were the stakeholders to be involved in SEA clearly identified?
Did all relevant stakeholders have an opportunity to provide comments and inputs
during the SEA process? If not, which key stakeholders were not invited?
Were any SEA information / documents made publicly accessible during the SEA
process? If so, which means were used?
Evaluation
F
F
M
112
Verbal summary:
The identification of relevant stakeholders was done at the beginning of SEA process during the prescoping stage. Inviting not only governmental agencies, but also NGOs (Walhi and Yadis are mentioned
in the SEA report, see p. 25) can be evaluated as a very positive approach.
The workshops were organized at the scoping stage and when the draft SEA report was prepared,
however no documents (e.g. scoping report or the draft SEA report) were publicly disclosed and made
open for written comments. The SEA report doesnt provide details on conclusions from the
consultations. The complete SEA Report was published (after the SEA was completed) at the ESP2
web site.
113
Evaluation
F
P
P
114
ecosystem services) is not indicated The territorial focus of SEA reflects the concerned area of the
spatial plan.
Quality issue 3: Baseline analysis
Detailed quality criteria
Evaluation
Was the existing state in the key issues described?
P
Were the past trends for the key issues analyzed (optimally also including main
M
drivers)?
Was the likely future evolution of the key issues without the plans
M
implementation described
Did the analyses highlight main concerns regarding the key issues?
F
Verbal summary:
The relevant issues are described, however, trend analysis and driving forces identification is mostly
absent. Future likely evolution without the plans implementation is not directly addressed,
however, some indication of objectives and planned developments incorporated in relevant spatial
plans and other PPPs is provided, unfortunately without clear link to the baseline analysis.
Evaluation
M
115
Does the SEA report describe the SEA process and all its stages and analyses as
P
well as the overall methodology/approach used?
Were the conclusions and recommendations towards the PPP given by SEA made
NA
explicit?
Does the SEA report clearly state which recommendations and suggestions given
NA
by SEA have been integrated in the plan (i.e. if there were any changes of the
plan resulting from SEA)?
Does the SEA report indentify sources of information, including expert judgement
P
and matters of opinion?
Does the SEA report contain a non-technical summary?
F
Verbal summary:
The document is not a full SEA report (only a Pre-Scoping report) the full draft of the Spatial plan
was not available for evaluation. The structure of the text is sometimes difficult to follow, some
sections are repetitive. Sometimes it is difficult to comprehend the meaning of the text due to the
poor English. Applied approach is not clearly explained (e.g. biodiversity description refers to a
conservation value index without further clarification p. III-44, similarly use reference to LQ
values for crops production p. III-62, or unclear role of the Matrix 3.1.6). For some of the
descriptive sections it is not clear to what extent are they relevant for the scoping and further SEA
analyses (e.g. description of socio-economic details).
Quality issue 7: Decision-making
Detailed quality criteria
Evaluation
Have the conclusions and recommendations given by SEA been considered in the
NA
PPPs approval?
Verbal summary:
The document is not a full SEA report (only a Pre-Scoping report) the full draft of the Spatial plan
was not available for evaluation.
116
Evaluation
F
F
P
117
adopted within the scoping analysis (through evaluation matrix). The territorial focus of SEA reflects
the concerned area of the spatial plan.
118
119
PRELIMINARY ENVIRONMENTAL
PRAMBANAN
Ministry of Public Works
2012
SUCOFINDO
DHI
English
ANALYSIS
FOR
KSN
Evaluation
F
F
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of vulnerability and adaptive capacity to climate change does not need to be regarded as
insufficient.
The clear definition of the territorial scope was not possible with respect to the fact, that the decision
on the delineation of the subject area has not yet been made. The SEA-related report however
demonstrably analyses broader territory, beyond the area supposedly covered by the Plan.
Quality issue 3: Baseline analysis
Detailed quality criteria
Evaluation
Was the existing state in the key issues described?
F
Were the past trends for the key issues analyzed (optimally also including main
P
drivers)?
Was the likely future evolution of the key issues without the plans
M
implementation described
Did the analyses highlight main concerns regarding the key issues?
F
Verbal summary:
The document is not a full SEA report. It only provides record of the pre-scoping analysis.
The relevant issues are described, however, trend analysis and driving forces identification remains
anecdotal. Future likely evolution without the plans implementation is not addressed.
121
122
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Evaluation
124
Were measures to prevent, reduce and/or offset any significant adverse effects
P
suggested by SEA for all main impacts identified?
Can mitigation measures suggested by SEA efficiently manage likely adverse
P
impacts? If not, what residual impacts can be expected?
Is there any monitoring scheme proposed?
M
Is it based on the main impacts identified?
M
Verbal summary:
The SEA doesnt clearly define mitigation measures; however there are chapters Alternative policies,
plans and/or programmes and Recommendations in the SEA report, which include certain
suggestions which might be considered as mitigation measures. These measures are focused more
or less on emphasizing environmental protection and sustainable development in the RTRW e.g.
to support the development of the province by improving the livelihood of the society taking into
account the carrying capacity of the environment and thus contribute to sustainable development
or it is recommended to add in the matrix of indicators also programme to control the use of
agriculture land. Some other measures are mentioned already in chapter Scope of the study
e.g. what activities should be implemented in order to decrease the sedimentation (e.g. limit licensing
of the mining exploitation in the beach finish line).
Even if the SEA suggested several mitigation measures, these (i) are not directly related to the
impacts identified (i.e. it is not clear what impacts should be mitigated), and (ii) measure remain
only on a very general level (e.g. mining shouldnt not be implemented at the locations of protected
areas).
There are neither indicators nor monitoring system suggested by the SEA RTRW. The SEA Report
only mentions within chapter Alternative PPPs that Monitoring of environmental quality should be
included as activity.
Quality issue 6: SEA report
Detailed quality criteria
Evaluation
Is the SEA report readers-friendly?
P
Does the SEA report describe the SEA process and all its stages and analyses as well
P
as the overall methodology/approach used?
Were the conclusions and recommendations towards the PPP given by SEA made
P
explicit?
Does the SEA report clearly state which recommendations and suggestions given by
M
SEA have been integrated in the plan (i.e. if there were any changes of the plan
resulting from SEA)?
Does the SEA report indentify sources of information, including expert judgement and
M
matters of opinion?
Does the SEA report contain a non-technical summary?
M
Verbal summary:
The SEA report has a logical structure i.e. starting from background information and objectives of
the SEA RTRW followed by a list of stakeholders involved, scope of the study (which also includes
analysis for each of the sustainable development issues), impacts assessment and alternative PPPs
and recommendations. The SEA provides a list of recommendations (Chapter V of the SEA report),
which are formulated in a form of general statements to be included at the RTRWs objectives or
development priorities.
Evaluation
125
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