AMICI CURIAE BRIEF (Pendapat Hukum Para Sahabat Pengadilan) State Administrative Lawsuit on Cancellation of Bali Governor's Decree No.660.3 / 3985 / IV-A / DISPMPT About Environmental Permit Development of Steam Power Plant (PLTU) given to PT. PLTU CELUKAN BAWANG ON THE VILLAGE ON THE SUPPORT OF GEROKGAK DISTRICT, REGENCY OF BULELENG

The brief contends that the environmental impact analysis (ANDAL) for the PLTU Celukan Bawang expansion in Bali is legally insufficient under Law no. 32/2009 because it omits a comprehensive climate change assessment. The authors argue that such assessments must include the project's direct and life-cycle greenhouse gas emissions, the project's vulnerability to climate-driven sea level rise and storm surges, and how climate change exacerbates the project's local environmental harms. Drawing on international legal precedents from South Africa, Australia, and the United States, as well as guidance from the European Union and Canada, the brief asserts that climate considerations are essential for meeting Indonesia's Nationally Determined Contribution (NDC) and Paris Agreement commitments. Specifically, the expansion is projected to release over 200 million tons of CO2 over 30 years and faces physical risks due to its low-lying coastal location and the degradation of protective coral reefs.

• The environmental impact analysis (ANDAL) for the PLTU Celukan Bawang expansion is deficient because it does not include a comprehensive climate change impact assessment, which is required to satisfy the principles of national environmental management under Law no. 32/2009.
• The expansion of the PLTU Celukan Bawang plant, which would increase total capacity to over 1,000 MW, is estimated to burn at least 75,241,207.8 tons of coal over 30 years, resulting in more than 200 million tons of CO2 emissions.
• The project site is physically vulnerable to climate change; sea level rise as high as 1.32 meters by 2100 could threaten the plant's operation and the integrity of coal ash containment structures, a risk compounded by the loss of protective coral reefs in north Bali.
• Indonesia's ability to meet its international climate commitments, including the Paris Agreement and its Nationally Determined Contribution (NDC) target of a 29% to 41% emissions reduction by 2030, depends on accurately accounting for the climate impacts of major fossil fuel projects.
• International legal precedents in South Africa, Australia, and the United States establish that climate change impacts must be incorporated into environmental impact assessments, even when domestic laws do not explicitly mandate such analysis.

APA

Centre for Environmental Rights (2018). AMICI CURIAE BRIEF (Pendapat Hukum Para Sahabat Pengadilan) State Administrative Lawsuit on Cancellation of Bali Governor's Decree No.660.3 / 3985 / IV-A / DISPMPT About Environmental Permit Development of Steam Power Plant (PLTU) given to PT. PLTU CELUKAN BAWANG ON THE VILLAGE ON THE SUPPORT OF GEROKGAK DISTRICT, REGENCY OF BULELENG. https://cer.org.za/wp-content/uploads/2018/06/CCIA-Amicus-FINAL-EN.pdf?x21779

Chicago

Centre for Environmental Rights. AMICI CURIAE BRIEF (Pendapat Hukum Para Sahabat Pengadilan) State Administrative Lawsuit on Cancellation of Bali Governor's Decree No.660.3 / 3985 / IV-A / DISPMPT About Environmental Permit Development of Steam Power Plant (PLTU) given to PT. PLTU CELUKAN BAWANG ON THE VILLAGE ON THE SUPPORT OF GEROKGAK DISTRICT, REGENCY OF BULELENG. 2018. https://cer.org.za/wp-content/uploads/2018/06/CCIA-Amicus-FINAL-EN.pdf?x21779.

Wikipedia

{{cite report |author=Centre for Environmental Rights |title=AMICI CURIAE BRIEF (Pendapat Hukum Para Sahabat Pengadilan) State Administrative Lawsuit on Cancellation of Bali Governor's Decree No.660.3 / 3985 / IV-A / DISPMPT About Environmental Permit Development of Steam Power Plant (PLTU) given to PT. PLTU CELUKAN BAWANG ON THE VILLAGE ON THE SUPPORT OF GEROKGAK DISTRICT, REGENCY OF BULELENG |date=June 2018 |url=https://cer.org.za/wp-content/uploads/2018/06/CCIA-Amicus-FINAL-EN.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{centreforenvironmentalrights2018amici, author = {{Centre for Environmental Rights}}, title = {{AMICI CURIAE BRIEF (Pendapat Hukum Para Sahabat Pengadilan) State Administrative Lawsuit on Cancellation of Bali Governor's Decree No.660.3 / 3985 / IV-A / DISPMPT About Environmental Permit Development of Steam Power Plant (PLTU) given to PT. PLTU CELUKAN BAWANG ON THE VILLAGE ON THE SUPPORT OF GEROKGAK DISTRICT, REGENCY OF BULELENG}}, institution = {Centre for Environmental Rights}, year = {2018}, month = jun, url = {https://cer.org.za/wp-content/uploads/2018/06/CCIA-Amicus-FINAL-EN.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }