November 16, 2023

Comment on the Comprehensive Investment and Policy Plan (CIPP) for Indonesia’s Just Energy Transition Partnership (JETP)

Dear JETP Secretariat,

I write on behalf of Climate Rights International, a U.S.-based NGO that conducts research and advocacy on the human rights dimensions of the climate crisis. As part of our work, we investigate how the policies and practices of governments, companies, and financial institutions directly and indirectly contribute to large-scale greenhouse gas emissions and climate-related human rights violations. In light of this, we are writing to comment on the Comprehensive Investment and Policy Plan (CIPP) for Indonesia’s Just Energy Transition Partnership (JETP).

As one of the world’s largest emitters of greenhouse gases, it is imperative that Indonesia transitions away from fossil fuel use as quickly as possible. We believe that generous funding in the form of grants instead of loans from the International Partners Group (IPG) will be critical in supporting Indonesia’s energy transition.1According to the International Energy Agency, Indonesia was the world’s ninth largest emitter of CO2 in 2021. International Energy Agency, “An Energy Sector Roadmap to Net Zero Emissions in Indonesia,” September 2022, At the same time, plans to support the decarbonization of Indonesia’s power sector must take into account all sources of emissions in the energy sector, including captive coal plants, include realistic and evidence-based solutions, respect human rights, and not lock Indonesia into decades of debt.

In addition to the points below, we are concerned that an Indonesian version of the CIPP became publicly available less than one week before the deadline to submit comments. The lack of an Indonesian version for the full comment period is likely to inhibit the participation of the people and groups who will be most impacted by the proposal. We request the Secretariat to extend the deadline for comments to allow the full participation of people in Indonesia.

We hope you will take the following concerns regarding the draft CIPP into account.

1Include the emissions from captive coal plants

Indonesia’s current and projected use of captive coal is enormous. Yet it is not counted in the CIPP, creating a misleading estimate of Indonesia’s total emissions. As a result, it threatens the target of “achieving peaking power sector emissions by 2030 at an absolute value of no more than 290 MT CO2 (down from a 2030 baseline value of 357 MT CO2), and immediately declining thereafter on an ambitious trajectory, and achieving net zero emissions in the power sector by 2050, including with the accelerated retirement of coal plants, conditional on international support.” This is because the Secretariat, in Chapter 5 of the CIPP, notes that the currently projected baseline emissions under the draft National Electricity General Plan is 478 MT, based on the emissions from captive coal plants. This is a staggering difference of 188 MT, or 65%.

The JETP Secretariat claims that these emissions from captive coal plants were not included in its official projection because of the absence of complete and full data and transparency regarding existing and planned captive coal power. While concerning, this is an unacceptable reason to disregard all captive coal emissions from the CIPP. As demonstrated by Box 5.1, the JETP Secretariat has a growing body of knowledge regarding the emissions and capacity of captive coal in Indonesia, and it should incorporate that information into the JETP targets and objectives.

In addition, the Secretariat’s statement in Chapter 2 that, “such a complex issue requires additional time for study and modeling to develop a technologically feasible, lower carbon pathway for off-grid industrial facilities that will not impede Indonesia’s economic growth,” is undermined by its statement in Chapter 4 that, “Improved access to renewable energy by either connecting to the grid or incentivizing captive power operators by fully utilizing the potential of decentralized solar PV will enable more green local processing.” There are already solutions to transitioning industrial activities from fossil fuel to renewables, including existing efforts to power nickel smelting operations in Indonesia and elsewhere with renewable energy. The Secretariat and the Government of Indonesia should look to these existing examples for technologically feasible pathways to decarbonization, rather than spending precious time studying and modeling new technologies.2For example, see examples of renewables used to power industrial smelting activities in Sorowako, Indonesia and Western Australia: 6b0c2da3633bafc2f1db1563dcafd888; power-bhp-nickel-mines/#google_vignette.

According to Chapter 2 of the CIPP, the JETP Secretariat aims to conclude a study within six months regarding captive decarbonization strategies. Based on the findings of that study, the JETP Secretariat should reissue the CIPP with specific provisions and joint targets, not only recommendations, to decarbonize the off-grid energy sector.

2. The Need for Realistic and Evidence-Based Solutions

The CIPP proposes emissions reduction technologies that could pose additional threats to human rights and the climate. The CIPP also relies on untested and controversial fuels, including ammonia and hydrogen fuels, which are both currently produced using fossil fuels.

The reliance on bioenergy electricity, as proposed in the CIPP, is concerning. Burning biomass emits carbon dioxide and air pollutants, including particulate matter, that threaten human health. In fact, researchers have found that burning biomass and wood contributes to more air- pollution related deaths than exposure to conventional coal plant pollutants.3

The proposal proposes to use agricultural products, like palm oil, rice husks, and corn, as bioenergy sources, which may contribute to deforestation, a key driver of the climate crisis. The JETP Secretariat should not promote energy technologies that continue to emit greenhouse gases and threaten human health.

Importantly, under the current draft CIPP, only medium and large-scale renewable energy projects are prioritized. This leaves a significant gap in supporting small-scale renewable energy projects at the community level. Community-level renewable energy projects in Indonesia have been successful and are particularly important for rural communities’ access to electricity, but many communities face obstacles financing or maintaining infrastructure.4For an example of community-scale renewable energy projects in Indonesia, see: energy/ To build on the existing success of small-scale renewable energy projects and support an equitable energy transition, Indonesia’s JETP should provide support for small-scale renewable energy developments in rural communities.

3. Insufficient human rights safeguards

As described in Chapter 6, human rights are an essential foundation of achieving a just energy transition. It is critical that the energy transition respects the rights of local communities and, while we welcome the principles and standards described in Appendix 10.8, the CIPP should include more explicit safeguards to protect human rights.

For instance, Figure 5.3-3 describes selection and prioritization criteria for JETP compliant projects. Yet, these criteria lack key metrics that would establish human and environmental safeguards for renewable energy projects, including mandates for public participation, transparency, an accessible grievance mechanism, and independent auditing.

Specific metrics and provisions should be included to ensure that Indigenous Peoples’ rights are respected, including the right to provide free, prior, and informed consent (FPIC) prior to the development of new projects that may impact indigenous communities or cut through customary lands.

4. Heavy reliance on loans

Under the current finance plan, only US$153.8 million, or 7.69 percent, of the proposed $20 billion would be allocated as grant funding. Another $138.5 million would be provided as technical assistance. Most of the funding by the IPG would come as concessional or non- concessional loans, and $10 billion in private finance would include market interest loans, equity investments, and other capital market instruments.

Due to the global nature of the climate crisis and global consequence of Indonesia’s energy transition, the JETP Secretariat should encourage States to leverage additional grant funding to prevent an unreasonable and unsustainable debt burden from potentially derailing projects to aid the energy transition or more generally harming the economy over the medium or long- term in Indonesia.

Thank you for providing the opportunity to submit comments on the CIPP. We hope you will consider Climate Rights International’s feedback in future iterations of the CIPP and in Indonesia’s JETP.


Brad Adams
Executive Director

Photo Credit: Power station in Indonesia. Photo by: Dominik Vanyi via Unsplash (license).

Like this article?

Share on Facebook
Share on Twitter
Share by Email

Related Articles