The Environmental Feasibility Decision Letter is often treated like a finish line. The documents are archived, consultants are released, and the project moves forward. However, the contents of the letter actually represent a list of obligations that begin on the day the letter is issued.
The contents are regulated by Government Regulation Number 22 of 2021 Article 49, which is still in effect according to JDIH BPK. Paragraph (3) emphasizes its position: the letter is a form of Environmental Approval and a prerequisite for the issuance of Business Licenses. Paragraph (6) specifies what must at least be written within it.
Nine obligations outlined in the SK
Paragraph (6) letter f details the obligations of the business responsible party, and the list is extensive:
- comply with the provisions according to the RKL-RPL documents
- adhere to regulations in the field of environmental protection and management
- fulfill obligations in the Technical Approval after verification of environmental quality standards, management of B3 hazardous and toxic waste, and traffic impact analysis
- prepare guarantee funds for the recovery of environmental functions
- manage non-B3 waste according to the details in the RKL-RPL documents
- submit reports on the implementation of requirements and obligations periodically every 6 months
- apply for changes to the Environmental Approval if the business is planned to change
- conduct environmental audits at the post-operation stage
- other obligations set by the minister, governor, or regent and mayor
The sixth item is the most frequently cited. The seventh and eighth items are often overlooked.
No expiration date, but not permanent
Letter g number 3 mentions its validity period: the letter is valid as long as the business is ongoing, as long as there are no changes to the business in question. Read together with letter f number 7, the consequences are clear. What ends the validity period is not the calendar, but changes to your business. Adding a production line, moving the disposal point, or increasing capacity triggers the application for changes, not something that can be postponed until an inspection occurs.
Technical Approval is not an attachment that is completed upon submission
Letter c mentions the scope of activities approved following the Technical Approval from the relevant authority that issues it. Letter d details the minimum contents of the Technical Approval: technical standards for environmental quality, management of B3 hazardous and toxic waste, and traffic impact analysis; competency standards for human resources for all three; and an environmental management system. Letter e concludes with a time requirement, stating that the commitments of the Technical Approval must be fulfilled before operations commence.
Two resources often overlooked in budgeting are personnel with the competencies mentioned in the Technical Approval and the environmental management system that is genuinely implemented.
Time running before the letter is issued
Two deadlines are worth noting. Article 48 paragraph (1) sets a maximum of 50 working days for the assessment of the substance of the Andal and RKL-RPL documents along with their feasibility tests, calculated from the time the documents are declared complete in the administrative assessment, and paragraph (2) clarifies that the time for document revisions is included in those 50 days. After receiving the recommendation of the feasibility test results, Article 49 paragraph (2) allows a maximum of 10 working days for the issuance of the decision letter.
Derivative regulations will move in 2026
The procedures for Technical Approval and Operational Feasibility Letters are regulated by the Minister of Environment and Forestry Regulation Number 5 of 2021. Its status is still in effect, but it has been partially revoked by the Minister of Environment/Bureau of Environmental Control Regulation Number 2 of 2026, established on February 23, 2026, and effective from February 26, 2026. The revoked provisions specifically apply to livestock feed and aquaculture feed businesses, namely the prohibition of wastewater disposal into drainage and irrigation channels, as well as the quality standards for wastewater utilization in certain formations. The nomenclature of the ministry has also changed, so you need to check the date of any guidance still referencing KLHK before using it.
One thing not addressed in Article 49: the channel for submitting the six-monthly reports is not mentioned there. Ensure the channel is directed to the agency that issued your approval, as its authority may lie at the central, provincial, or regency and city levels.
The levels of environmental documents themselves, from SPPL to AMDAL, are discussed separately in Understanding the Levels of Environmental Approval from SPPL to AMDAL.
Sources
- PP No. 22 Tahun 2021 tentang Penyelenggaraan Perlindungan dan Pengelolaan Lingkungan Hidup, JDIH BPK
- Text of Article 48 and Article 49 PP No. 22 Tahun 2021
- Permen LHK No. 5 Tahun 2021 tentang Tata Cara Penerbitan Persetujuan Teknis dan Surat Kelayakan Operasional, JDIH BPK
- Permen LH/BPLH No. 2 Tahun 2026, JDIH BPK