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

This amicus curiae brief, submitted by a coalition of environmental law organizations, urges the court to vacate the Bali Governor's Decree granting an environmental permit for the expansion of the PLTU Celukan Bawang coal-fired power plant. The brief argues that the project's environmental impact analysis (ANDAL) is legally insufficient because it fails to comprehensively assess climate change impacts, including greenhouse gas emissions and the project's vulnerability to sea-level rise.

• The environmental impact analysis (ANDAL) for the PLTU Celukan Bawang expansion is claimed to be deficient because it does not include a comprehensive climate change impact assessment, which the authors argue is required under Indonesia's Law on Environmental Protection and Management (Law no. 32/ 2009).
• The expansion of the PLTU Celukan Bawang power plant, which aims to add two 330 MW units to reach a total capacity exceeding 1,000 MW, is projected to burn at least 75,241,207.8 tons of coal over 30 years, releasing more than 200 million tons of CO2.
• The project site is highly vulnerable to climate-driven sea level rise; with elevations between 0 and 12.5 meters, projections of sea level rise up to 1.32 meters by 2100 could threaten the plant's operation and the integrity of coal ash containment structures.
• Climate change threatens the coral reefs in north Bali through acidification and rising temperatures, which may lead to beach erosion and expose the project's revetment wall to wave impacts beyond its design capacity, potentially endangering the coal stock and ash yards.
• The brief asserts that Indonesia's international commitments under the Paris Agreement and its Nationally Determined Contribution (NDC)—which targets a unilateral emission reduction of 29% below 'business as usual' by 2030—necessitate the accounting of climate impacts for major fossil fuel projects.
• The authors cite international legal precedents from South Africa, Australia, and the United States to argue that climate change considerations must be integrated into environmental impact assessments, even when domestic statutes do not explicitly mandate them.

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} }