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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.
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Document type: Legal commentary