Report 2 Implementation Check Renewable Energy Development in Indonesia 2024
Report 2 Implementation Check Renewable Energy Development in Indonesia 2024
Report 2 Implementation Check Renewable Energy Development in Indonesia 2024
POLICY ASSESSMENT:
RENEWABLE ENERGY
DEVELOPMENT IN
INDONESIA’S POWER
SECTOR
2
Climate Transparency is a global partnership with a shared mission to stimulate a “race to the top” in climate
action in G20 members through enhanced transparency.
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We would like to express our gratitude for inputs, reviews, and helpful hints to Fabby Tumiwa.
CLIMATE POLICY IMPLEMENTATION CHECK 2023 | POLICY ASSESSMENT: RENEWABLE ENERGY DEVELOPMENT IN INDONESIA’S POWER SECTOR
3
CONTENTS
EXECUTIVE SUMMARY 4
REFERENCES 16
CLIMATE POLICY IMPLEMENTATION CHECK 2023 | POLICY ASSESSMENT: RENEWABLE ENERGY DEVELOPMENT IN INDONESIA’S POWER SECTOR
4
EXECUTIVE SUMMARY
The development of renewable energy as an indigenous This renewable energy share target is enforced through
energy resource is part of the energy resources the National Electricity Plan (RUKN 2019-2038) and must
diversification strategy stipulated in the 2014 National be implemented by PT PLN (State Electricity Company)
Energy Policy. Energy diversification and conservation and private business area holders. Since RUKN only
are two main strategies to reduce reliance on fossil fuels serves as the main reference document for power sector
and to ensure energy security of the country. development planning in Indonesia, it lacks credible and
comprehensive rules to accelerate renewable energy
Indonesia’s electricity consumption is projected to
development. This shortcoming must be addressed
increase by 5% to 6% annually in the coming years. In
in the New and Renewable Energy Bill; however,
the last five years, electricity demand growth is below
the ratification process is still halted. This uncertain
5%, with annual electricity consumption of 1360 kWh
regulatory framework for commercial actors, which
per capita. The cause of this situation can be attributed
revolves around incentives, electricity pricing, and the
to the discrepancy between the top-down economic
negotiation process, has discouraged private investment
growth projection aimed at 5% to 6% annually and the
in renewable energy projects.
economic downturn prompted by the Covid-19 pandemic
in Indonesia. Due to a decline in economic activity, On the other hand, PLN is facing resource constraints
Indonesia was unable to expand its power consumption that delay renewable energy deployment, such as lack of
due to limited industrial activity. capital, lack of bankable project, and lack of experienced
personnel to handle RE projects. The government will
Indonesia has immense renewable energy resources,
need to impose stronger supervision and more precise
particularly solar with the highest potential, which has
direction on its implementing institutions while providing
been proven as economically viable1, yet the current
sufficient technical, financial, and regulatory supports that
energy plan shows continuous reliance on coal power.
favour renewable energy development. Indonesia should
Decarbonising power sector is essential in ensuring
also improve its monitoring mechanism to ensure greater
Indonesia to meet its fair contribution towards Paris
accountability of non-PLN business area holders and
target, where Indonesia’s power sector would need to at
further effectively track progress and address obstacles
least double its renewable share target to 45% by 20302,
to RE development projects.
currently set at 23% by 2025, and phase-out coal by
2040.
CLIMATE POLICY IMPLEMENTATION CHECK 2023 | POLICY ASSESSMENT: RENEWABLE ENERGY DEVELOPMENT IN INDONESIA’S POWER SECTOR
5
OVERVIEW:
RENEWABLE ENERGY DEVELOPMENTS IN
INDONESIA’S POWER SECTOR
The energy sector is the second largest greenhouse USD 4 billion in 2022, yet the realised investment only
gases (GHGs) emissions contributor, accounting for 35% accounts for USD 1.6 billion.8 This number is much smaller
of total emissions, as stated in Indonesia’s Third Biennial compared to the Ministry of Energy and Mineral Resource
Update Report (BUR). 3 The power sector accounts (MEMR) projection that USD 28.5 billion of investment is
for 43% of the total energy sector’s CO2 emission.4 needed annually to reach net zero emission by 2060.9
Indonesia’s electricity generation mainly relies on fossil In addition, the Ministry has also identified a number of
fuels, accounting for 81% of the total, with coal alone obstacles to renewable energy investment, including
constituting 62% in 2021.5 Despite the inclusion of but not limited to complicated bureaucracies, limited
decarbonisation in the LTS-LCCR 2050, the ambition technical capacities, lack of planning, and limited access
remains lacking, and the implementation planning must to financing for Independent Power Producers (IPP).10
be improved.
The Just Energy Transition Partnership (JETP), which
The Government of Indonesia (GoI) aims to use the deals with a total financial commitment of USD 21.5
power sector, particularly through the National Electricity billion, is expected to reduce the gap in renewable
Plan (Rencana Umum Ketenagalistrikan Nasional/RUKN), energy financing in Indonesia. As of November 2022,
to drive its emission reduction to meet its NDC targets. the JETP investment plan also set the target of 44%
In the electricity sector, the NDC targets an additional (previously 34%) renewable energy shares by 2030 and
20 GW of installed RE, which will contribute 358 Mt net zero in power sector by 2050.11 Indonesia needs
CO2-eq unconditionally and 446 Mt CO2-eq conditionally to align the JETP target with future electricity plans.
by 2030. Given the importance of reducing carbon Although the JETP target is more ambitious than the
emissions in this sector, RUKN is critical in Indonesia’s RUKN, it is still not compatible with the Paris Agreement
decarbonisation efforts. The Indonesian government has pathway.12 This shows that the synchronisation of
also announced that the RUKN will be aligned with its Indonesia’s renewable energy targets is not yet available
Nationally Determined Contributions (NDCs) at different to guide a more ambitious decarbonisation path for the
intervals due to their different issuance years. country.
Indonesia’s current new and renewable energy (NRE) To provide a more comprehensive review of the
target is 23% by 2025, with 10.6 GW of additional implementation of key policies and regulations related
renewable power generation will be added by 2025 to RE development in Indonesia, this report assesses
according to the National Electricity Supply Business the current National Electricity Plan (RUKN 2019-2038).
Plan (Rencana Usaha Penyediaan Tenaga Listrik/ The assessment will also review its derivative, such as
RUPTL) 2021-2030.6 However, by 2022, the installed the RUPTL 2021-2030 with PT PLN (Persero) as the main
capacity of renewables was only at 12.3%.7 This situation implementing agency, and other applicable instruments
is in line with the limited investments made. Indonesia in the power sector.
targeted that investment in renewable will reach around
CLIMATE POLICY IMPLEMENTATION CHECK 2023 | POLICY ASSESSMENT: RENEWABLE ENERGY DEVELOPMENT IN INDONESIA’S POWER SECTOR
POLICY ASSESSMENT SCORECARD 6
IMPLEMENTATION CHECK OF
RUKN 2019-2038
LEGAL STATUS
STRONG
The National Electricity Plan (RUKN 2019-2038) is annually and is heavily dominated by the demand from
enacted through the Minister of Energy and Mineral the industry sector, followed by household, businesses,
Resources Decree No.143/2019. The RUKN provides a public, and transport sectors. In addition, the RUKN
framework for energy-related plans such as the Electricity 2019-2038 provides a blueprint for national electricity
Power Supply Business Plan (RUPTL) and Regional planning that integrates the emission reduction target as
Energy Plan (RUED). The RUKN 2019-2038 comes with an outlined in the First NDC.
assumption that electricity needs will grow around 6.9%
Electricity Law
Law 30/2009
GR 5/2021
The Implementation of Risk-Based
Business Licensing
KEN
National Energy Policy
GR 25/2021
The Implementation of the Energy and
Mineral Resources Sector
RUEN RUKN
National Energy National Electricity
General Plan General Plan
CLIMATE POLICY IMPLEMENTATION CHECK 2023 | POLICY ASSESSMENT: RENEWABLE ENERGY DEVELOPMENT IN INDONESIA’S POWER SECTOR
POLICY ASSESSMENT SCORECARD 8
MEMR is the regulator of Indonesia’s energy sector, The Directorate General of Electricity (DGE), under
which has the responsibility to formulate and supervise MEMR, is responsible to formulate and implement
the implementation of national energy strategy stipulated policies related to the development and supervision of
in the National Energy Policy (KEN). The KEN 2014 laid electricity system in Indonesia, as well as regulate the
the foundation for renewable energy target in the primary utility business through the RUKN 2019-2038. According
energy mix to reach 23% by 2025 and 31% by 2050. to RUKN 2019-2038 decree, PT. PLN as the state-
KEN also outlined the target for increased power plant owned electricity company and other utility business
capacity to reach 115 GW and 430 GW by 2025 and area holders are the main implementers of RUKN. They
2050, respectively. This target includes the utilisation of must integrate the national renewables target into their
renewable energy, such as solar, hydro, biomass, and business plans. PT. PLN and these utility business area
wind, in the power sector. To implement these targets, holders are obliged to submit their business plan to
the government has formulated the National Energy MEMR. However, the business plan from business area
Planning (RUEN) 2017-2050 and National Electricity holders outside of PT. PLN are not publicly accessible as
Planning (RUKN) 2019-2038. they do not have legal obligation to do so. In this case,
it is difficult to ensure whether the total target share
pledged by all business area holders is aligned with the
national renewable energy target prescribed in KEN.
RESOURCING
MEDIUM
The policy instrument outlines the necessary investment Due to the lack of PLN’s fiscal capacity, PLN prioritises
in electricity infrastructure from 2019-2038, with the private sector investment for renewable energy
majority (USD 217 billion) directed towards power development to overcome the high upfront cost.
generation. The financial implications of developing Even though PLN’s operations currently dominate the
electricity infrastructure will be handled through electricity supply chain, private sector can participate
multiple channels, including loans, bond issuance, in the generation side through IPPs. For IPPs wishing to
and government funds. For the fiscal year 2023, the participate in renewables development, the sales price
government has allocated around USD 57.6 million, of electricity generated from renewables is regulated
which is less than 1% of the total budget for infrastructure by Ministerial Decree 4/2020, which requires IPPs to
development 15, for rural electrification through solar negotiate with PT PLN before signing a power purchase
and micro-hydro power plants.15 This number is small, agreement. To access resources from the private sector,
compared to MEMR calculations where USD 28.5 incentives for renewable energy development are also
billion is needed annually until 2060 for power sector offered, such as tax holidays, allowances, and investment
transition.16 allowances, as outlined in Presidential Regulation (PR)
No. 112/2022.
As one of the implementers, PLN should have
the capability to access necessary capital for RE
development. However, the company’s internal budget
is currently limited, mainly because PLN’s income
is decreasing due to an increase in average cost of
generation without any increase in tariffs since May 2017.
CLIMATE POLICY IMPLEMENTATION CHECK 2023 | POLICY ASSESSMENT: RENEWABLE ENERGY DEVELOPMENT IN INDONESIA’S POWER SECTOR
POLICY ASSESSMENT SCORECARD 9
OVERSIGHT
MEDIUM
MEMR provides a publicly available annual performance Electricity’s website, which means that other business
report that contains the realisation status of RE shares.17 areas’ RUPTL is not publicly available, let alone their
At the implementation level, PLN provides finance monitoring reports. Since the RE target share should be
reports on the RUPTL target, which provides monitoring imposed on all electricity business areas, all businesses
reports for the status of renewable energy projects in areas’ monitoring reports are essential to track the
Indonesia.18 development progress.
The current monitoring system is already adequate According to the existing monitoring reports, RE
in terms of tracking the progress of RE development development has fallen short from MEMR’s target, only
and sharing in the PLN’s system. However, only PLN’s reached 12.3% by 2022 (out of 15.7%). Historically, the
RUPTL is available on the Directorate General of yearly RE share target has not met the target since 2018.
RE share
Year
Target (%) Realization (%)
2018 11.6 8.6
Several RE projects have been delayed and moved to There is a mandatory annual evaluation process
the new Commercial Operating Date (COD) year. The off- conducted by each ministry or agency to report its
track project has several implications, including unserved annual performance on the accountability and good
energy (except for the Jawa-Bali case) and high utilisation governance as mandated in Presidential Instruction No.
of expensive old fossil plants, e.g., diesel. 7 of 1999 and Minister of State for Administrative Reform
and Bureaucratic Reform Regulation No. 20 of 2010.
Several hydro and geothermal projects is reported to
At the project implementation level, RUPTL should be
experience delays; thus, the governments decide to
evaluated annually, as mandated in MEMR’s Ministerial
rely on bioenergy through a co-firing scheme to achieve
Regulation No. 11/2021. In that ministerial decree, the
the RE share target by 2025 (RUPTL PLN 2021-2030).
evaluation aims to update the electricity demand
However, this solution has its own challenges in the
projection. Consequently, RUPTL will be annually
feedstock availability. In terms of investment, it sets a bad
updating the power supply planning, which should
precedent for RE project development, which can hinder
include the projection of additional power plants for each
its attractiveness and increase the risk.
source, energy balance, energy share projection, fuel
needs, and greenhouse gas emissions projection.
CLIMATE POLICY IMPLEMENTATION CHECK 2023 | POLICY ASSESSMENT: RENEWABLE ENERGY DEVELOPMENT IN INDONESIA’S POWER SECTOR
POLICY ASSESSMENT OF RUKN 2019-2038 10
23%
19.5%
659.3
Coal 37.62% 17.9%
522.9
15.7%
14.5%
448.6
13.4%
12.2%
366.4
11.6% 12.3%
Geothermal 16.82% 9.2% 12.2%
8.6% 11.2%
212.7
175.8
163.2
143.2
126.0
Oil 32.4%
Renewable development in Indonesia has a strong legal Since electricity is a public good in Indonesia, there are
basis, but the implementation still falls short of the target. also implementation challenges. As a result, it is difficult
One reason is that the achievement of RE development in to increase the electricity tariff as the government must
Indonesia depends on economic feasibility as reflected also ensure its affordability to consumers, particularly
in the KEN and RUKN documents. Furthermore, many poor households and SMEs. Subsidy payments to PLN
relevant documents have varying RE targets for the from the government is made based on a revenue model
power sector, e.g. 45.2 GW in KEN and 31.72 in RUKN of of PLN’s accounting cost of electricity supply (BPP)
installed RE capacity by 2025. This makes the RE target plus a pre-determined margin set by the government
clauses in different corresponding documents not strong and parliament. The State Auditor of the Republic of
enough to serve as a reference. Indonesia (BPK) reviewed the entire authorised costs
booked by PLN for the previous year, which were divided
According to the RUKN document, there is an obligation
by PLN energy sales to arrive at BPP. The application
to reach the RE target, not only for PLN but also for other
of BPP plus margin as PLN’s revenue model has an
utility business areas. Consequently, PLN and these
issue. It considers PLN’s audited costs from the previous
utility business area holders must submit their business
year, while current and future costs are sure to differ.
plans to MEMR, which must contain renewable energy
Furthermore, as subsidies are correlated with the state
target shares within their business operation.
budget, GoI also aims to reduce subsidies to PLN.
Despite the fact that PLN’s business area covers 75% Consequently, PLN’s BPP should be minimised.
of Indonesia’s total demand by 2022 , business plans of
Another issue is that the MEMR overrides PLN’s BPP
other electricity business concession holders still play
through pricing regulation, which is regulated through
a crucial role. For example, PLN’s business plan targets
MEMR’s Ministerial Regulation (PERMEN ESDM) No.
a 23% RE share target by 2025, similar to RUKN’s RE
50/2017 on the Utilisation of Renewable Energy
target. Consequently, other business areas should have
Resources for Electricity Supply, and amended by
a similar target. However, only PLN’s business plan
PERMEN ESDM No. 53/2018. In the regulation, electricity
is publicly available, which is planned to be updated
purchases from IPPs are measured against BPP, which
annually. Hence, it is enormously challenging to track
is artificially lowered by the coal purchase subsidy limit.
Indonesia’s power sector’s ambitions and progress and
Unfortunately, the regulated price causes disagreement
to synchronise the target at the national level.
between PLN and its developers as the purchase
CLIMATE POLICY IMPLEMENTATION CHECK 2023 | POLICY ASSESSMENT: RENEWABLE ENERGY DEVELOPMENT IN INDONESIA’S POWER SECTOR
POLICY ASSESSMENT OF RUKN 2019-2038 11
price cap limits the potential revenue of the project. In study template for RE projects is essential to make the
addition, PLN is reluctant to agree to renewable prices process more seamless, but such documents are not
that could later be perceived as resulting in “state losses” available and cause project delays. As the number of RE
for renewable projects that are not subject to BPP price projects in Indonesia is limited, there is a lack of human
caps, especially in the 3T (Least Developed, Frontier resources with sufficient experiences to formulate such
and Outermost) regions. The Presidential Regulation documents. PLN can learn from other countries on how
No. 112/2022 already regulates a new pricing scheme to formulate RE’s feasibility and risk study template, such
for RE. Even though it can become a new fair signal, the as India and Brazil21, and adjust it to Indonesia’s context.
effectiveness of the regulation to attract investors and
The lack of simplified and clear administrative process for
shorten the negotiation period is yet to be seen, since
RE procurement, as well as low investment attractiveness
the regulation has just been implemented in 2023.
for IPPs, hinder the progress of renewable energy target
Additionally, the MEMR has identified several challenges achievement in Indonesia. The conclusion is that the
within PLN for the implementation of RUPTL, such as enabling environment of RE development in Indonesia
internal budget limitation, delays in preparing project is improving but is not enough to achieve the current RE
feasibility and risk studies, and lengthy price negotiation target.
process.20 The preparation of project feasibility and risk
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Indonesia’s electricity sector is mainly powered by coal. In the period of 2017 to 2022, the share of coal in
the electricity generation rose from 58.4% to 67.2%.22 The capacity addition of coal-fired power plants has
also sharply risen in the last decade, from 13 GW in 2010 to around 37 GW in 2020. 23 It makes sense that
current Indonesia’s power sector is not compatible with Paris target. The GoI estimated that it needs USD
247.2 billion to meet the Paris target.24 In the energy sector, investment of no less than GBP 124.5 billion
by 2025 is essential to reduce the prevalence of coal-fired power stations (CFPPs) in Sumatra, Borneo,
Java-Bali, and Sulawesi.25 This additional investment could support Indonesia towards a more reliable and
environmentally-friendly system and help the country to be in line with the Paris Agreement.
The 2022 moratorium on new coal plants does not signify an immediate stop to the development of coal
plants, as it exempts captive power for downstream industries. Indonesia aimed to phase-out unabated
coal power generation by 2050. However, to limit warming to 1.5°C, Indonesia must reduce 9 GW of
its coal-fired generation capacity by 2030 and phase-out coal by 2045. Based on IESR study, Paris’
compatible coal phase out requires 18 plants (9.2 GW, 8 PLN, and 10 IPP plants) to be put out of operation
by 2030, 39 plants (21.7 GW, 18 PLN, and 21 IPP plants) to retire in 2031–2040, and the remaining 15 plants
(12.5 GW, 5 PLN & 10 IPP plants) to continue operating beyond 2040 at a low utilisation level and retire
before 2045.26 Retirement costs are estimated to be USD 4.6 billion until 2030 and USD 27.5 billion until
2050.
Currently, Indonesia targets its renewable energy share to reach 23% by 2025. However, the government
has fallen short its renewable target by 12.3% in 2022. To limit warming to 1.5°C, Indonesia needs to at
least increase its RE target to 45% by 2030. It requires substantial deployment of renewable sources
including solar, wind, geothermal, and hydropower, not to mention a significant international support.
Climate Action
IEA Climate Analytics IESR
Tracker
RE share by 2030 (%) 57 70-75 45 55-82
[Source: IEA, 2022; Climate Analytics, 2022; IESR, 2022b; Climate Action Tracker, 2023]
The RE development comes with financial implications. Indonesia will need at least around USD 10
billion of annual investment until 2030 to meet the Paris target. The RE development investment needs
listed in Table 2 exclude the amount required for transmission and storage system development. These
large financial requirements signify the importance of global cooperation to support Indonesia towards
achieving a 1.5°C compatible target in the power sector.
CLIMATE POLICY IMPLEMENTATION CHECK 2023 | POLICY ASSESSMENT: RENEWABLE ENERGY DEVELOPMENT IN INDONESIA’S POWER SECTOR
POLICY ASSESSMENT OF RUKN 2019-2038 14
METHODOLOGY:
POLICY IMPLEMENTATION CHECK
The Climate Policy Implementation Check provides a assessments already exist to evaluate ambition, but only
concise framework to check from an early stage whether few assess the implementation. These independent
a policy is being implemented from the policy-maker assessments are especially valuable in the run-up to the
side. Therefore, it can serve as an evaluation tool for Global Stocktake, given that formal processes under the
civil society. This early check is important, as policy UNFCCC are not set up to fulfil this remit.
outcomes and impacts on greenhouse gas emissions
The framework checks different characteristics of
are typically only measurable several years after the
policy implementation, which can be grouped into four
implementation, leaving little time for course correction if
categories: legal status, institutions and governance,
the implementation of the policy is weak.
resourcing, and oversight. For each of these categories,
This implementation check is a tool that enables the framework includes specific questions that are
stakeholders to evaluate the implementation status of designed to make the results comparable across different
policies, engage in the exchange of good practices, countries.
and hold governments accountable. Multiple tools and
Depending on the answer to each specific question, the implementation of the relevant policy instrument in each
category is rated as Weak, Medium, Strong, or Frontrunner.
CLIMATE POLICY IMPLEMENTATION CHECK 2023 | POLICY ASSESSMENT: RENEWABLE ENERGY DEVELOPMENT IN INDONESIA’S POWER SECTOR
POLICY ASSESSMENT OF RUKN 2019-2038 15
TABLE 4. Rules for combining ratings per question to an overall rating at category level
These ratings are combined to produce an overall rating for the policy implementation in the format below.
NR = Not rated
Legal status Frontrunner yet or NA = Not
Institutions/ applicable
Oversight governance
Strong Weak
Resourcing
CLIMATE POLICY IMPLEMENTATION CHECK 2023 | POLICY ASSESSMENT: RENEWABLE ENERGY DEVELOPMENT IN INDONESIA’S POWER SECTOR
REFERENCES 16
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