BATANG TORU HYDROPOWER

PROJECTFactcheck and References

on Key Issues

IUCN Section on Great Apes, April 2020

CONTENTS3

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INTRODUCTION

SUMMARY

APPROACH

NSHE DOCUMENT REFERENCES

BACKGROUND ON THE TAPANULIORANGUTAN

FACTCHECKS

Orangutan Distribution and EcologyOverview: Tapanuli Orangutan Distribution and Population Dynamics

Geographic Range

Population Density

Metapopulation Connectivity

Behavioural Response of Orangutans to Project Activities

Discrediting Previous Survey Results

Area Affected By Project ActivitiesExtent of Area Affected

Primary Forest in Project Area

Land Designations in Project Area

Provincial Power RequirementsOverview: Future Power Demand /Supply in North Sumatra

Power Demand / Supply

“Floating Diesel Generator”

CO2 ImpactsOverview: Greenhouse Gas EmissionBenefits

CO2 Emissions Reduction Calculations

River Flow and EcologyEnvironmental Impact of Run of RiverHydropower Systems

Earthquake RiskAssessment of Risk Level

Standards and ComplianceInternational Finance CorporationStandards

General ApproachEfforts to Minimise Impact

CONCLUSIONS

SGA STATEMENT ON THETAPANULI ORANGUTAN

Photos © Andrew Walmsley & Maxime AliagaDesign: www.designsolutions.me.ukCitation: Batang Toru Hydropower Project: Factcheck and Key References, IUCN SGA April 2020

3BATANG TORU HYDROPOWER PROJECT | FACTCHECK AND REFERENCES ON KEY ISSUES

INTRODUCTION

The project is being developed by PTNorth Sumatera Hydro Energy (NSHE)with main construction activities to beundertaken by the Chinese state-ownedcompany Sinohydro. The project site is inthe Batang Toru ecosystem whichcontains the only remaining habitat ofthe critically endangered Tapanuliorangutan (the recently describedspecies Pongo tapanuliensis). Plans forthe project have been controversial dueto the anticipated impact on local people,the local environment in general, and theTapanuli orangutan in particular. TheIUCN (the global authority on the status

of the natural world) has called for amoratorium on project activities toenable a careful assessment of the likelyimpacts, before deciding how (orwhether) to continue. With manycontradictory claims being made aboutthe project’s potential impacts, thisdocument identifies specific assertionsmade by NSHE and assesses themagainst the best scientific knowledgeavailable.

The Batang ToruHydropower Project is aplanned hydro-electricpower station that isunder construction onthe Batang Toru Riverin North Sumatra,Indonesia.

4

SUMMARY

Several significant claims found in NSHE publications or press releases are identified as being inaccurate ormisleading. In at least ten cases,assertions made in public-facing NSHEliterature or on the NSHE website arefound to be inconsistent with findingspresented in earlier impact assessments

conducted on behalf of NSHE. Numerous other claims in NSHEpublications, or directly attributed toNSHE staff in media articles, are found toconflict with findings in peer-reviewedliterature and technical reports, or withthe observations of established experts inrelevant fields. Some of these relate to

the most controversial aspects of theproject such as its impact on the Tapanuli orangutan and the ecology ofthe Batang Toru river, the demand for the power that the plant would produce,and the project’s compliance withinternational investment standards.

Contested claims from NSHE areaddressed in turn. For each, the nature ofthe concern is explained, the specificclaim made by NSHE is quoted, andcontradictory evidence is then detailedand referenced. In some cases theevidence comes directly from documents

commissioned by NSHE itself. In others,references are made to peer-reviewedscientific literature or other reputablestudies. Occasionally there is additionalinsight in the form of personal commentsfrom highly qualified experts acting in aprofessional capacity. Whilst various

documents have been circulated whichargue for or against the project onparticular issues, this review attempts tocover a broad range of subject areas butrestricts itself to investigating the validityof specific claims made by NSHE.

NSHE DOCUMENT REFERENCES

Several source documents produced byNSHE are referred to throughout thisreport. For those not familiar with themhere is a quick overview of the mostsignificant ones.

l The first is the original environmentalimpact assessment report or ANDAL(Analisis Dampak Lingkungan) for theproject which was produced in 2014,which is only available in Indonesian andconsists of 532 pages.1 (A previousANDAL exists for an earlier version of theproject2, but is not cited in this report.)

l This report was followed up in 2017 bya further document which covered someof the same topics in more detail andbrought in some additional topics, whichwas published in English (1,266 pages)and called the “AddendumEnvironmental, Social and Health ImpactAssessment (ESHIA)”.3

l In 2018 a report was produced by NSHEtogether with the NGO Pusaka Kalam(Pusat Kajian, Advokasi dan KonservasiAlam / Center for Nature Study,Advocacy and Conservation) based in

Bogor, entitled “Impact of Batang ToruHydropower Construction on PrimaryForest, Orangutan Population andHabitat, Drought and Flood, GreenhouseGases Emission and Socio-EconomicSurroundings” (English version 166pages). This states that its purpose is to“provide scientific clarification/justifications on data/information thathas been received by several researchersand nongovernmental organizations,who have raised objections/negativeaccusations toward the Batang Toruhydroelectric power plant development”.4

l Following this a shorter, moreaccessible report (English version 78pages) was produced entitled “PLTABatangtoru "A Socially andEnvironmentally ResponsibleDevelopment"”, with a foreword signedby Sarimudin Siregar, Director of DharmaHydro / NSHE and dated 5th October2018. This document draws on previousreports in order to, as it says, “… expressour research, fact-based findings andviews on the reports those have beendeveloping, which have causedmisconception on the project …”5

l An alternative and condensed versionof this report was also produced (nodate, English version 16 pages) with thetitle “Batang Toru Hydropower Plant –PLTA Batangtoru A Socially andEnvironmentally ResponsibleDevelopment”.6

l An additional 2-page document hasalso been circulated on NSHE headedpaper entitled “Common Misconceptionsabout Our Projects”, presenting alleged(but not attributed) criticisms of theproject and responses to them.7

APPROACH

5BATANG TORU HYDROPOWER PROJECT | FACTCHECK AND REFERENCES ON KEY ISSUES

BACKGROUND ON THE TAPANULI ORANGUTAN

Later in 2017 the species was assessed asCritically Endangered for the IUCN RedList, which noted a decreasing populationtrend and severely fragmentedpopulation.9 The Tapanuli orangutan isfound in three main populations, the twolargest of which are probably notconnected by forest cover (although it ispossible that individual orangutans couldstill move between them). The BatangToru hydropower project is situated at akey location for connectivity betweenthese sub-populations (see “Overview:Tapanuli Orangutan Distribution andPopulation Dynamics”).

In April 2019 a scientific letter waspublished in Conservation Science andPractice entitled “The Tapanuli orangutan:Status, threats, and steps for improvedconservation” which warned that “theTapanuli orangutan was the latest extantgreat ape to be discovered, but … it mightwell be the first one to go extinct.”10

The paper recommended (among othermeasures) that the Government ofIndonesia “halt the hydroelectric damdevelopment” and “establish a forestcorridor between the west and east block”.

In April 2019 the IUCN (InternationalUnion for the Conservation of Nature11)called for “a moratorium on projectsimpacting the Critically EndangeredTapanuli orangutan”.12 In October of thesame year the Section on Great Apes(SGA) of the IUCN Primate SpecialistGroup issued a statement proposing “a moratorium on development in theTapanuli orangutan’s range” saying that itwas “particularly concerned by the threatof a hydroelectric project development incore orangutan habitat”.13 This statement“calls for a complete halt to allencroachment and development” and“further proposes that its [the SGA’s]Executive Committee leads anindependent study to determine theimplications for the Tapanuli orangutan ofthe various threats to orangutans … andwhether or not those threats can bemitigated.” It explains that “The widebreadth of expertise in the IUCN SGA,which includes scientists from both range (e.g., Indonesia) and non-rangestate great ape countries, makes thisgroup particularly well suited to lead such a study.”

The Tapanuliorangutan was firstdescribed as a separatespecies in 2017 aftergenetic analysisrevealed that its lineage diverged from the rest of theorangutans on Sumatra over 3 millionyears ago, and gene-flow between themceased completely atleast 10 thousand years ago.8

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OVERVIEW: Tapanuli Orangutan Distribution and Population Dynamics

FACTCHECKS

Evaluating the impact of the project onthe Tapanuli orangutan requires anunderstanding of the species’ currentstatus. The map below, published in 2019in Conservation Science and Practice14,shows all the known populations ofPongo tapanuliensis. Several points areparticularly worth noting:

l The Hydro AoI (Area of Influence forthe hydropower project) and Corridor arepart of the West Block which extends tothe South East over the Batang Toru river.The AoI contains some of the last tractsof primary lowland forest in the BatangToru ecosystem.15 The hydropowerproject would establish an access roadand power lines following the river alongmost of this section, involving clearedground and hazards to orangutans.

l The most feasible connection pointbetween the West Block and the EastBlock is at the North end of the AoI.Historical maps (see MetapopulationConnectivity section) suggest that therewas forest connectivity here at leastwithin the last hundred years andpossibly much more recently. Geneticresearch would need to be conducted to

establish when or if movement ofindividuals between these populationsstopped taking place. This is the locationof the inundation area of the project,from which power transmission lines runNorth up the valley.

When considering land clearanceimpacts, it should be understood thatorangutans are not restricted to primaryforest areas but can inhabit many kinds ofsecondary forest, as well as travellingthrough a wide range of land cover typesincluding commercial plantations (seeGeographic Range section). Lack of treecover, rather than lack of primary forest,is a significant limiting factor on theirmovement.16 However, they are veryvulnerable to disturbance from humanpresence and often avoid forest areasthat are close to human activities (seeBehavioural Response section). It cannotbe assumed that they would use or travelthrough patches of forest which areexposed to significant human presence.

Although the map shows five populationsof Tapanuli orangutan these are usuallyconsidered as only three (East, West andSibualbuali), whilst the latest Orangutan

Population and Habitat ViabilityAssessment (PHVA) conducted in 2016divided these simply into an East and aWest block, with the prospects for eachpopulation in isolation very concerning.The assessment rated the viability of theEast Block as ‘poor’, with estimated timeto extinction of 124 years, and the WestBlock as ‘moderate to poor’ withestimated time to extinction 310 years.17The 2019 status review notes that, usingcriteria from the 2004 PHVA18, the EastBlock and any smaller blocks would beconsidered non-viable in isolation.19Hence, if connectivity were permanentlylost the only viable sub-population wouldbe the West Block. However the authorsexplain that “given the current andprojected threats of habitat degradationand loss, hunting, human-orangutanconflict, an expanding goldmine, and aneutralized logging concession in thearea … this is an extremely risky scenario… because these threats could drive thispopulation to nonviable status within asfew as 1–2 generations.” It is clear thatconnectivity between the two mainblocks in particular, as well as smallerpopulations, will be a major factor in thelong-term survival of the species.

ORANGUTAN DISTRIBUTION AND ECOLOGY

7BATANG TORU HYDROPOWER PROJECT | FACTCHECK AND REFERENCES ON KEY ISSUES

GEOGRAPHIC RANGE

“The Tapanuli Orangutan is endemic tothe Batang Toru forest, with anestimated population of around 800individuals. Their habitat is spread inthe 163,000 Ha of the Batang Toruforest ecosystem”20

l The total range of the Tapanuliorangutan is now estimated at only 1,023 km2 (102,300 ha).21

Concern: The total range of the Tapanuli orangutan has been misrepresented.

Concern: Elevation limits of Tapanuli orangutan range have been misrepresented.

Claim: Evidence:

“The flooded areas [by the reservoir]are the steep cliffs that were notinhabited and the area is not thehabitat of Orangutans.”31

l The original ANDAL document from2014 shows at least two orangutan neststhat were observed on steep slopes veryclose to the existing river and possiblywithin the inundation area.32

l The presence of nests indicates theareas where orangutans have recentlyslept but not all the areas that they utilise or travel through. In other areas in Sumatra (eg Ketambe) orangutans are known to use forest areas on steep slopes.33

Concern: The possibility of orangutans using steep slope areas, such as those around the proposed inundation area, is misrepresented.

Claim: Evidence:

“Tapanuli orangutan have adaptedwith the environment and live onhighland (>600masl22) with lowtemperatures. Therefore, it has verythick fur and longer than otherorangutans. The highest point ofBatang Toru Hydropower Plant projectis at 430masl,”23

l The 2017 paper describing the Tapanuliorangutan states that it is found atelevations from at least ~300masl.24

l Surveys conducted in 2000/1 identifiedorangutan presence in low altitudecoastal swamp areas near the BatangToru ecosystem around Lumut.25

l Historic records show that the speciesoccurred in the second half of the 19thCentury in the Batang Gadis lowlands

south of Batang Toru, approximately25masl26, and early in the 20th Centuryaround the Tapanuli Bay which is at sea level.27

l It has been documented that Sumatranorangutans28 prefer lowland forest29;where orangutans are found primarily athigher elevations this may indicateprevalence of hunting or loss of habitatat lower altitudes.30

Claim: Evidence:

Concern: The importance of primary forest is overemphasised compared to other habitat types.

“the forested area inside the projectsite … has been disturbed (not primaryforest)”34 / “… all of the project areaare not primary forest …”35 / “…vegetation inside the project area hasbeen disturbed (not a primary forestanymore) …”36 / “… the land isdominated by vegetation of pioneerspecies … indicating that no primaryforest exist but most likely secondaryforest …”37

l Primary forest is not the only habitat of orangutans, as acknowledged in theAddendum ESHIA - “The outcomes ofthe critical habitat determination indicatethat the primary forest and secondaryforest habitats within the Project area arecritical habitat for the species [Sumatranorangutan38] along with these habitattypes across the Project area of influenceand the wider landscape.”39

l Extensive orangutan use of habitatsother than primary forest is welldocumented in scientific literature.40 41 42

l See also the section on Area Affectedby Project Activities for further points onthis topic.

Claim: Evidence:

8

POPULATION DENSITY

“Survey of Kuswanda and Fitri (2017,2018) indicates the density of nestsaround the project area is 0.41 perkm2”43 / “possible number oforangutan population density of 0.48individuals/km2 across 7,200 hectaresin the Batang Toru HydropowerPlant”44 / “The analysis of orangutans’nest density data by Santosa et al.(2018), obtained the estimated value oforangutan population density of 0.22individuals/km2 (95% CI: 0.17-0.27individuals/km2) or equivalent to 1individual/500 ha. Similar to thisanalysis Kuswanda and Noor (2018),reported that the population density inthe project area is about 0,3individuals/km2. This proves that theproject location is not the main habitatof Tapanuli Orangutans (Pongotapanuliensis).”45

l Surveys in 2015 for the AddendumESHIA found substantially higherdensities of orangutans than latersurveys:

- “A total of 213 Sumatran orangutan46

nests were encountered within theProject Area of Influence with averagedensity calculated as 0.7 individuals/km2

for the west side of the Batang Toru River.The densities were recorded highest inthe southern survey area at 0.95individuals/km2. These results arebetween 26%-57% times higher thanother areas previously surveyed in theBatang Toru Forest.”47

- “The baseline survey of the Project areaof influence (West side of the river only)recorded orangutan average density tobe 0.7 individuals/km2. The analysis ofbaseline results identifies Sumatranorangutan48 density estimates on thewest side of the Batang Toru River, withinthe Project area of influence, to be higherthan those average estimates for thelarger Batang Toru Forest area.”49

l The existence of high densities ofTapanuli orangutan in this area is citedwithin the IUCN Red List assessment forthe species. “… a hydro-electricdevelopment has been proposed in thearea of highest orangutan density, whichcould impact roughly 100 km² of P.tapanuliensis habitat, or nearly 10% ofthe entire species population.”50

l Recent NSHE documents conspicuouslyomit the findings of these earlier surveys:“As indicated in the ESHIA study of thepresence of orangutan in the projectareas and its surrounding, the projectcarried out in depth studies to collectmore detailed information aboutorangutan and other wildlife necessarilyto arrange proper mitigation plan. The first study on orangutan and other wildlife population was conductedduring the wet season in January toMarch 2017.”51

Concern: Early studies reporting high orangutan densities are neglected in favour of recent NSHE-sponsored studies reporting low densities.

Concern: Attempts to present new data as a ‘baseline’ neglect the significance of original baseline data.

Claim: Evidence:

“to obtain up to date baseline data onendangered species, such as theorangutans, a detailed study wasrecently undertaken”52

l As expressed by a group of leadingorangutan conservation professionals:“Conducting research on orangutanswhile disturbances are taking placecannot generate baseline insights into the population dynamics of thethree subpopulations of Pongotapanuliensis, and therefore cannot bebases for determining mitigation oravoidance measures.”53

Claim: Evidence:

9BATANG TORU HYDROPOWER PROJECT | FACTCHECK AND REFERENCES ON KEY ISSUES

“These two facts [i.e. the constructionarea and elevation of the hydropowerproject] provide confirmation that theproject is not located on the mainhabitat or population source oforangutans.”54 / “This fact [nestobservations in Pusaka Kalam / NSHE2018] also proves that the area for theBatang Toru Hydropower Plant is leastused by orangutans, therefore cannotbe categorized as main habitat.”55

l The Addendum ESHIA repeatedly notes the significance of this area asorangutan habitat:

- “Field surveys reported densityestimates within the Project area ofinfluence to be 26-57% higher thanestimates from the Batang Toru Forest.As such it is considered likely that theProject area of influence may beassociated with critical habitat for this species.”56

- “The outcomes of the critical habitatdetermination indicate that the primaryforest and secondary forest habitatswithin the Project area are critical habitatfor the species [Sumatran orangutan57]along with these habitat types across the Project area of influence and thewider landscape.”58

- “Although the percentages of available habitat within the Batang Toru Forest area that will be lost appear small, baseline surveys identifiedthat the Project Area of Influencesupports a relatively higher density ofindividuals than other Batang Toru Forestareas assessed.”59

l In the assessment of Impact on IFC PS6 Biodiversity Values given in theAddendum ESHIA, the impact on theSumatran orangutan60 is assessed ashaving ‘high’ sensitivity and ‘medium’magnitude, resulting in a designation of‘major’ significance.61

l The significance of this area for thesurvival of the species is highlighted by the IUCN SGA which says: “We are particularly concerned by the threatof a hydroelectric project development in core orangutan habitat that is currently unprotected.62

Concern: It is inaccurately stated that the project area is not core habitat for orangutans.

Claim: Evidence:

Concern: Ranging behaviour of orangutans is over-simplified with misleading effects.

“The Batang Toru Hydropower Plantoccupied land of 122 hectares, smallerthan the minimum area needed for asingle orangutan.”63

l Orangutans often have abutting oroverlapping ranges, needing access tothe full extent of these areas, hence122ha could potentially be essentialhabitat for a number of individualorangutans. One study in Borneo foundthat an average point in the survey area“is included in 3.36 home ranges ofknown adult females”64 whilst a study on Sumatran orangutans found that asingle 4 ha area was used by at least 40 individual orangutans.65

Claim: Evidence:

10

METAPOPULATION CONNECTIVITY

“The Western and Eastern habitatshave been naturally separated by theBatang Toru river for centuries ago.”66 /“The river Batang Toru has been themain barrier for movement ofOrangutan from eastern part towestern part of the river.”67

l In fact the separation of these blockshappened much more recently:

- US Army maps from 1943 (based onmaps from 1908) and from 1954 showcontinuous forest cover on both sides ofthe river over the entire length of thecurrent project site, strongly suggestingthat there was extensive connectivityduring this period.68 69

- During surveys in 2003, researchersobserved touching canopies providingconnectivity over the river.70

- Distribution maps71 show the WestBlock of Tapanuli orangutan habitatextending over a significant length of theBatang Toru river, indicating that the riverdoes not represent a barrier for thispopulation.

- Satellite images from 2013 in GoogleEarth (below) show many potential forestcanopy connectivity points over theBatang Toru River in close proximity toproject activities.

Concern: It is inaccurately claimed that the Batang Toru river has been a barrier to orangutan movement for some time.

Claim: Evidence:

11BATANG TORU HYDROPOWER PROJECT | FACTCHECK AND REFERENCES ON KEY ISSUES

Concern: Surveys conducted after project activities began are used as evidence for the situation prior to project presence.

“The river Batang Toru has been themain barrier for movement ofOrangutan from eastern part towestern part of the river. Project hadconducted on the ground survey (15km) along the river to find suspectedtree canopy that might link both sideof the river. The team found a singletree that most likely link both sides,however this tree won’t be affected bythe project.”72

l A 2015 report conducted for NSHErecorded extensive disturbance driven bythe project presence even at that earlystage, including human access to theWest bank of the river from NHSE-constructed cable crossings, and landspeculation within the project area in theform of vegetation clearance anddemarcation using paint cans andmachetes.73 The NSHE statement aboveappears to be based on a ground surveyconducted after this time and so cannotbe taken as representative of thecondition of canopy cover over the riverbefore project activities commenced.

Claim: Evidence:

“… the Orangutan population is 800individuals and living in the remaininghabitat 150.000 hectares, in averageeach individual occupies 187.5hectares. The size of permanentstructure of the hydropower facilitieswould be 122 hectares it is onlysuitable for single Orangutan.”74 /“"Tapanuli Orangutan Habitat isscattered in the Batangtoru ecosystemwith a total area of 165 thousandhectares. … While the area ofBatangtoru hydropower site is only 122Ha or 0.07 percent of the Batangtoruecosystem. Less than the roamingneeds of an orangutan," said BaritaManullang, Biodiversity Expert PT.North Sumatra Hydro Energy”.75

l The 2015 PanEco/YEL report for NSHEnotes that “The hydro electric target liesin a key biodiversity area, not only ingeneral due to its covering parts of thelast remaining habitat for the geneticallyunique Critically Endangered orangutanpopulation residing in the area, butbecause it is located in the key corridorareas providing the last hope forconnectivity between the West BatangToru forest block (84.000 ha) and thesmaller Strict Nature Reserves Sibual-buali to the South East, and also the East Batang Toru forest block and theStrict Nature Reserve Dolok Sipirok to the East.”76

l This observation is also reported in theNSHE Addendum ESHIA: “… the area ofinfluence is associated with a corridorthat provides connectivity between theWest Batang Toru forest block and DolokSipirok Strict Nature Reserve to the eastand Sibual-buali Strict Nature Reserve tothe south east (PanEco and YEL, 2015).PanEco and YEL (2015) note that the StrictNature Reserves contain smallerorangutan populations whose long-termsurvival depends on maintainingconnectivity with the larger, West BatangToru block population.”77

l The significance of the connectivityfunction of this area is highlighted by theIUCN SGA: “This threatened core area iscrucial for maintaining connectivitybetween the three forest blocks neededto ensure the species’ survival …”.78

l The importance of this area forconnectivity for the Tapanuli orangutan isalso recognised in the IUCN Red Listassessment for this species: “… a hydro-electric development has been proposedin the area of highest orangutan density,which could … jeopardize the chances ofmaintaining habitat corridors betweenthe western and eastern P. tapanuliensisranges, and with two smaller strict naturereserves, which could also maintain smallpopulations of P. tapanuliensis.”79

l As expressed by one experiencedorangutan field scientist, “The wall acrossBerlin didn't take up much space but ithad a huge impact”.80

Concern: Emphasis on the area of land directly impacted ignores the significance of the projectlocation for orangutan conservation.

Claim: Evidence:

12

Concern: The effectiveness of ‘arboreal bridges’ is overstated.

“Arboreal bridges for the animals willbe built in case the road constructionsfragment the orangutans from theriver.”81 / “Monitoring results on thefunction of the arboreal bridge,indicate that this facility is functioningproperly, and has been used by wildlifeto cross roads and rivers.”82

l The observation that cables have beenused by wildlife does not necessarilymean that they have been or will be usedby orangutans.

- The difficulty in ensuring thatorangutans use human-constructedcrossings is highlighted in an interviewwith experienced orangutan researcherSerge Wich: “In Ketambe, a research sitein Aceh, Sumatra, where Wich hasworked, a cable was placed over the river.It was very frequently used by macaques,Wich says. However, as far as he knows,in the thirty years that it was there, it wasnever used by orangutans. “Toexperiment with bridges for a speciesthat’s almost extinct seems completelyludicrous to me,” Wich said.”83

- In the same article Wich explains that“In Sabah, they’ve used fire hoses oververy narrow rivers and, after severalyears, orangutans sometimes use these.We know that there are differencesbetween the orangutans on Sumatra andBorneo so to assume that orangutans onSumatra would use similar bridges isdangerous.”84

Claim: Evidence:

BEHAVIOURAL RESPONSE OF ORANGUTANS TOPROJECT ACTIVITIES

“Other observations show that Tapanuliorangutans are not disturbed by thesound of heavy machinery working.Orangutans continue to conduct acalm behaviour around them while onthe move, eating and resting.”85

l The Addendum ESHIA notes that“Studies undertaken as part of aneighbouring project impact assessmentidentified a negative correlation betweendrilling intensity and Sumatranorangutan86 density, attributing‘temporary disappearance’ to noiserather than physical habitat loss(Agincourt 2008).”87

l The same document also states:“Sumatran orangutans88 are typicallyreluctant to move through highlyfragmented landscapes, even if existingcorridors of primary high value forestpersist.”89

Concern: Impacts of project activity on orangutan behaviour are misrepresented.

Claim: Evidence:

13BATANG TORU HYDROPOWER PROJECT | FACTCHECK AND REFERENCES ON KEY ISSUES

Concern: The PanEco/YEL 2015 study is discredited without adequate justification.

DISCREDITING PREVIOUS SURVEY RESULTS

“Based on the results of the groundcheck on the 2015 orangutan nestdistribution map, most locations thathave been reported as nest findingpoints, are no longer used for nestingactivities. Only 10.34% of the nests areclassified as new nest …”90 /“Groundcheck results (Professor YantoSantosa, 2018) on the map of the nestsspread by YEL (2015) in the permittedlocation (7,200 hectares) showing thatmost locations earlier reported asgathering nests are no longer used fornesting activities. Only 10.34% of nestsare classified as new nests (or A classnests) while largely are old nests (E class nests, 51.72%).”91

l This is not a valid interpretation ofthese results as orangutans build a newnest every night, hence this is a typicalnest age distribution for a healthypopulation:

- The Pusaka Kalam / NSHE report itselfexplains that “According to variousstudies (Rijksen, 1978; Sugardjito, 1986;van Schaik et al., 1995; Djojoasmoro et al., 2004), orangutans always build new nests, both for resting and sleepingat night.”92

- Accepted surveys that report nest stagedata show very similar patterns forhealthy populations, eg van Schaik et al.(1995) also reports 10% new nests.93

Concern: Criticisms of the PanEco/YEL 2015 orangutan survey are based on a misinterpretation of the original data.

Claim: Evidence:

“… most locations that have beenreported as nest finding points, are nolonger used for nesting activities …most of the orangutans’ nest findingsin 2015, lie on steep cliffs that arerelatively "very difficult" to reach …Any mistakes/errors in the applicationof this method in the field will result ininaccurate data and cannot be used asa scientific "reference".”94 / “most ofnests in “YEL version” are located onsteep cliffs very difficult to be reachedby orangutans, especially if they usednormal methods of orangutan nestsurvey … It needs to be reminded thatthe confusion/mistake of the methodon the field will result in inaccuratesurvey data and cannot be used asvalid reference for science.”95

l Orangutans have been observed inforest areas over steep ground at othersites, for example in Ketambe, Sumatra.96

l YEL are experienced professionals inorangutan survey methods (for instanceconducting much of the survey workreported in Wich et al (2016))97 and thisunsubstantiated accusation gives no cleargrounds to doubt their results.

Claim: Evidence:

14

EXTENT OF AREA AFFECTED

“Of the 669 hectares licensed for thisproject, 122 hectares will be used forpermanent building structures, 100hectares for support function, and theremaining 446 hectares will bereplanted and restored.”98

l The anticipated facilitation of humanaccess to, through and around theproject site is also likely to have seriousand wide ranging impacts on habitat,wildlife and the environment:

- The Addendum ESHIA observes that“With greater human activity in theregion and increased access points to theforest there is a risk of increased huntingand poaching activities leading to faunamortality. Hunting of wildlife, includingconservation significant species wasobserved commonly throughout baselinesurveys. Through the installation of newroads, i.e. increased ease of accesshunting and poaching may increase.”99

- In the Assessment of Impact to Habitatsin the Addendum ESHIA, the impact“Hunting and poaching” is assessed ashaving ‘high’ sensitivity and ‘medium’magnitude, resulting in a designation of‘major’ significance.100 The ‘residualimpact’ if all planned mitigation activitiesare implemented with complete successis still assessed as ‘moderate’.101

- The impact of hunting on orangutandistribution and density in Batang Toru isalready well documented in scientificliterature.102

Concern: Explanations of project impacts omit crucial indirect impacts.

Claim: Evidence:

FACTCHECKS

AREA AFFECTED BY PROJECT ACTIVITIES

PRIMARY FOREST IN PROJECT AREA

“… most of the lands that are allocatedfor the hydropower developmentactivities are not primary forest cover…”103 / “Field ground check has beenundertaken through three differentstudies, and all reports indicated thatthere is no primary forest in theproject area.”104

l The biodiversity monitoring reportsubmitted to NSHE in 2015 by PanEcoand Yayasan Ekosistem Lestari (YEL) aspart of the Addendum ESHIA (released in2017) says that “The last primary lowlandforest of the Batang Toru Ecosystem cannow only be found in the NHSE targetarea, reflected in the highest densities ofgreat apes found, and all other taxastudied” and notes that “people fromvarious villages on the east side of theBatang Toru river have now taken toclearing forest that was previouslyinaccessible and in primary condition.”105

l The Addendum ESHIA refers to afurther analysis conducted by HatfieldIndonesia in 2015106 in order “to assistwith compliance with the provisions ofIFC PS6” which uses a definition of‘primary forest’ taken from the FAO 2010Forest Resources Assessment107 andconcludes that “The majority of theProject area is mapped as primary forestwith approximately 268 ha followed by secondary forest with approximately101 ha.”108

Concern: Two studies reporting significant areas of primary forest in the project area are discounted based on a more recent NSHE report.

Claim: Evidence:

15BATANG TORU HYDROPOWER PROJECT | FACTCHECK AND REFERENCES ON KEY ISSUES

Concern: Pledges to reforest affected areas may be unrealistic.

LAND DESIGNATIONS IN PROJECT AREA

“The hydropower plant is located onthe Batang Toru region in Sipirok andMarancar, within the area designatedas ‘land allocated for other purposes’and not in the forest area.”109 / “… theproject area is located on non-forestArea (APL) …”110 / “The location of theBatangtoru hydropower developmentproject is located on a non-forest area(APL) …”111 / “… the project will requireonly 122 Ha that is located andclassified as Other Usage Area (APL) bythe Government of Indonesia, meaningthat it is non forest area.”112

l The land category APL stands for ArealPenggunaan Lain meaning ‘land for otheruses’, and is a legal designation that doesnot indicate whether the land is forestedor not.

l The Addendum ESHIA reports that “The majority of the Project area hasbeen mapped as the land class “primaryforest” … followed by secondary forest.”113

l The same document also notes that “An area of approximately 486 ha will bepermanently cleared of vegetation (directimpact) as part of the Project footprint.Approximately 76% of this areacomprises Natural Habitat which largelycorresponds with the primary andsecondary forest land class types.”114

l In a 2018 article in Mongabay theDirector General for Conservation at theMinistry of Environment and Forestry(Wiratno) is quoted as saying “Eventhough the area’s status has beenconverted for use for other purposes, theforest cover is still intact”; the article goeson to report that “Dana [Prima Tarigan ofWALHI] called on the government tochange the status of the area to protectit. “That area should have protectedstatus,” he said.”115

l In 2014 extensive areas of the BatangToru ecosystem were re-designated fromAPL (‘land for other uses’) to HutanLindung (‘protected forest’). However thearea around this project (which wasalready in development) was excluded,despite being included in earlierproposals for Hutan Lindung status.116The local government has been providedwith evidence that this land meets therequirements for Hutan Lindung withover 75% of the area scoring above thethreshold of 175 on the governmentscoring system.117

Concern: The project area is inaccurately described as a ‘non-forest area’.

Claim: Evidence:

“... the remaining 446 hectares will bereplanted and restored.”118

l The NSHE literature acknowledges that although spoil heap areas (totalling185ha) are intended for restoration this may not be realistic: “… spoil areaswill consist of large are [sic] ofunconsolidated material. The material isfrom underground and is potentiallysterile to rehabilitation efforts and/orvolatile to erosive processes.”119

Claim: Evidence:

In order to understand the importance ofbuilding a hydropower plant at BatangToru it is worth considering how thepower that it would generate fits into theoverall picture of supply and demand inNorth Sumatra over the next severalyears. Data from the 2019-2028 ‘PowerSupply Business Plan’ (Rencana UsahaPenyediaan Tenaga Listrik or RUPTL) ofthe Indonesian State Electricity CompanyPT Perusahaan Listrik Negara (PLN)120,together with reported figures for 2018(from an Okefinance news article121), canbe used to produce valuable forecasts.These have been considered in depth inother reports such as “A Roadmap ForIndonesia’s Power Sector” (IESR / Monash2019122) and “Analysis of ElectricityDemand in North Sumatra Province andthe Planned Batang Toru HydroelectricPower Plant’s Impacts” (B2E2 2020123).

The RUPTL predicts growth in powerdemand in Sumatra over the ten yearperiod of 9.8% a year (giving a total

increase of 141% over 2018 figures by2028, to a total of 4,420 MW). However,some experts consider this likely to be anoverestimate, with IESR suggesting 7.2%as a more realistic figure (giving a totalincrease of 100% to 3,674 MW). Bycomparison, actual annual growth overthe period 2012-2017 was 5.8%, while anarticle on CNN Indonesia in March 2020reported that “Minister of Energy andMineral Resources (ESDM) Arifin Tasrifsaid the current electricity supply followsthe assumption of high electricity growth."The assumption of electricity growth is6.5 percent per year, but in reality theelectricity consumption growth is only 4 percent …".”124

The RUPTL also details all the powerplants that are scheduled to beconstructed or expanded over the period2019-2028. If the plans for Batang Toruare removed, the remaining projects willproduce over 5,600 MW of additionalpower, increasing the total supply by

266% over the ten years to 7,805 MW.Given that in 2018 installed capacity inNorth Sumatra exceeded demand bysome 300 MW125 this means that by 2028total power supply is anticipated toexceed demand by 3,385 MW (43% ofthe total supply) even using the higherdemand growth estimate from PLN, orby 4,131 MW (53% of total supply) usingthe more modest IESR estimate.126

These calculations for power supply anddemand in North Sumatra over the nextdecade (which do not include anyhydropower production from BatangToru) indicate that this project cannot beconsidered essential in meeting theprovince’s future power needs. As theB2E2 report concludes: ”There may havebeen a rationale for the Batang Toruhydroelectric dam when it was proposedin 2012, before the identification of theTapanuli orangutan, and in a verydifferent energy situation. But there’s noneed for it in 2020.”127

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OVERVIEW: Future Power Demand / Supply in North Sumatra

FACTCHECKS

PROVINCIAL POWER REQUIREMENTS

POWER DEMAND / SUPPLY

“The 510 MW power plant will beoperated 24 hours … to overcome theelectricity crisis in North Sumatra …”128

l In fact the situation has changedsubstantially over recent years, so thatinstead of a shortfall there is now apower surplus in the province. This wasknown and covered in the media beforethe end of 2018: “Electric energyinfrastructure development in theProvince of North Sumatra (North

Sumatra) is growing rapidly. Theelectricity crisis that once happened nowhas a surplus. … Before the surplusoccurred, in North Sumatra there was a shortage of electricity, even NorthSumatra was said to have experienced an electricity crisis in 2014 to 2016.”129

Concern: The ‘energy crisis’ that the project was intended to address no longer exists.

Claim: Evidence:

“FLOATING DIESEL GENERATOR”

“The Batang Toru hydro power plantwill replace a floating diesel-basedgenerator that supplies 500 megawattsof electricity to North Sumatra.”130

l The floating power station is actuallypowered by natural gas.131

Concern: Claims that the project will replace a floating diesel generator are misleading.

Claim: Evidence:

17BATANG TORU HYDROPOWER PROJECT | FACTCHECK AND REFERENCES ON KEY ISSUES

The savings in Greenhouse Gas (GHG)emissions allegedly achieved by thehydropower project have been widelycirculated132 133 but a closer examinationreveals some flaws in the calculations andthe logic behind these arguments.

The key calculation of 1.6 Mt CO2e134 peryear, taken from the 2017 AddendumESHIA, is based on the assumption thatthe power used will directly replacealternative electricity generationproducing GHG emissions at the nationalaverage rate. However, it is very unlikelythat energy from alternative sourcessupplied in North Sumatra wouldgenerate emissions at such a high level(see CO2 Emissions section). A largeproportion of the power generation inthe province is from natural gas, whichproduces significantly lower emissions,with hydropower and geothermalreducing the average further still. If thishydropower project were to replace theequivalent power produced by atraditional gas turbine (such as theexisting offshore power plant) it would besaving more like 1.1 Mt CO2e. If it werereplacing power from the plannedSumbagut 1/3/4 ‘combined cycle’ gaspower plant the figure would drop toaround 0.9 Mt CO2e.135

Following on from the predictions offuture power demand and supply inNorth Sumatra (see “Overview: Future

Power Demand / Supply in NorthSumatra”) it is useful to consider the2019-2028 plans for renewable energyproduction based on the RUPTL.136

These plans would see an additional2,177 MW produced from hydropower(excluding Batang Toru) and 670 MWfrom geothermal (including expansion ofthe existing plant at Sarulla by 300 MWand a new plant at Sorik Marapi set togenerate 240 MW by 2023). Using the(higher) PLN figure of 9.2% annualgrowth, power demand in 2028 will besome 2,587 MW greater than in 2018,whilst at 7.2% growth it would increaseby 1,841 MW. Under current plans, a totalof 2,847 MW is set to be produced bythat time from new hydro andgeothermal plants alone. It thereforeseems that even a generously estimatedadditional power demand over thisperiod can be met by low emissionssources already planned or underconstruction, without any contributionfrom Batang Toru.137

Another important concern over carbonaccounting for hydropower projects isthat whilst emissions are calculated overa notional timespan for the wholeproject, most of the emissions take placeearly in the process as a result ofvegetation decay and other projectconstruction effects.138 This contrasts withfossil fuel generation, where emissionslargely take place as the power is

produced, spread evenly over the lifetimeof the project. In the context of a globalclimate crisis which needs to beaddressed in a matter of years ratherthan decades, a project that releases adisproportionate amount of GHGs in theshort term represents a greater threat toglobal efforts to urgently reduce GHGsthan the calculated figures suggest. Toput it another way: “A hydroelectric damemits large amounts of greenhousegases in the first few years after it is built,which creates a global warming “debt”that is slowly paid off as electricitygenerated by the dam displaces fossilfuels in the succeeding years”.139

If emissions reductions are to beprioritised, there are also many otheroptions for increasing renewable powerproduction in Indonesia, in particularfrom solar and wind generators. The IESR report explains: “[The Indonesiangovernment] stipulates that by 2025,renewable energy shall make up 23% ofprimary energy mix, up from 8% today.Policy focus is on hydro and geothermalresources, while solar and wind powerplay only a negligible role. Globally, thetrend is very different … Solar and wind –driven by significant technology costreduction – have been at the forefront ofpower sector investment for years andwill continue to play the decisive role inmodernizing and decarbonizing powersystems globally.”140

OVERVIEW: Greenhouse Gas Emission Benefits

FACTCHECKS

CO2 IMPACTS

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19BATANG TORU HYDROPOWER PROJECT | FACTCHECK AND REFERENCES ON KEY ISSUES

CO2 EMISSIONS REDUCTIONS CALCULATIONS

“Batang Toru Hydropower Plant is partof Indonesia’s plan to implement thecommitment to reduce greenhouse gas(GHG) emissions. When in operation,the reduction can reach 1.6-2.2 millionmetric tons CO2 …”141 / “The project will contribute to carbon emissionreduction at 1.6-2.2 MTon per year.”142

l The only clear calculations found inNSHE literature are for savings of 1.6 Mt(in fact 1,595,482 t CO2e) per year143:

- This is also the figure reached bycalculations laid out in a detailed pressarticle in Investor Daily.144

- There is no identified source for anestimate of 2.2 Mt CO2e per year.

l The 1.6 Mt per annum calculation in the Addendum ESHIA is based on theunlikely assumption that power from theproject will directly displace powerproduced elsewhere which wouldgenerate emissions at the nationalaverage level145:

- The national average emission rate(0.7568 tCO2/MWh) is significantly higherthan that for the existing offshore gaspower plant which is seen as the mainpower supply alternative at present(0.5094 tCO2/MWh), and hence is not arealistic basis for calculating emissionsreductions. The planned gas power plantSymbagut 1/3/4, which will have acapacity of 800MW and is anticipated tobe the primary future power supplyalternative, will use a combined cyclesystem which has even lower emissions(0.3369 tCO2/MWh)146

- An alternative calculation suggestsrealistic figures, if replacing existing orplanned gas-powered generators, of 1.1 Mt or 0.9 Mt CO2 saving annually.147

Concern: Quoted CO2 emissions figures are questionable.

Claim: Evidence:

Concern: Expressions of CO2 emissions savings in terms of trees are problematic.

“The presence of a clean energy plantwith a capacity of 510 MW willcontribute to reducing carbonemissions by around 1.6 million tons of CO2 per year, or the equivalent of 12.3 million trees. "This project is partof a national effort to reduce carbonemissions. If a hydropower plant isterminated it's the same as cutting 12 million trees" Firman said.”148

(quote attributed to Firman Taufick,Communications and External Directorof NSHE) / “The presence of a cleanenergy plant with a capacity of 510 MWwill contribute to reducing carbonemissions by 1.6 million tons / year or equivalent to the ability of 12.3 million Saga trees to absorbcarbon emissions”149

l The Saga tree (Adenanthera pavoniana)is estimated to absorb up to 221.18 kgCO2 per year.150 If the project were tosave 2.2 million tonnes of CO2 per year(an amount for which no justification hasbeen identified) this would be equivalentto only 9.9 million saga trees per year.The saving given in the NSHE AddendumESHIA of 1.6 million tonnes per yearwould be equivalent to 7.2 million trees.The proposed higher end alternativecalculation given by B2E2 of saving 1.1million tonnes would be equivalent toonly 5 million trees.

l One media article claims that the CO2savings are “the equivalent of 123 milliontrees” but this is presumed to be atypographical error.151

l It is not accurate to say that if theproject leads to carbon savingsequivalent to the sequestrationperformed by a certain number of trees,then not approving the project isequivalent to chopping down thatnumber of trees. It could perhaps becompared to not planting that number oftrees. However, chopping down trees canhave GHG impacts far beyond the lack ofsequestration, such as the release ofcarbon stores within the timber, soil orwider ecosystem, as well as broaderecological impacts.

Claim: Evidence:

20

ENVIRONMENTAL IMPACT OF RUN OF RIVERHYDROPOWER SYSTEMS

“This hydropower plant will implementenvironmentally friendly technologyknown as "Run off RiverHydroelectricity"”152 / “… the"environmentally friendly" technologyof "Run off River Hydropower"”153

l As identified in the Addendum ESHIA, the project will create a barrier to biotic movement up and down theriver which will have significantenvironmental impacts:

- “There will be a decrease in longitudinaland latitudinal connectivity within thebypass reach of the Project area whichwill negatively impact most fish species,in particular migrators.”154

- “The dams will result in restriction of fish migration in the aquaticenvironment, as well as alteration andfragmentation of habitats. The outcomeis an impact to species distribution. … A number of species encountered duringbaseline surveys are known to swimupstream to spawn with juvenile fishmoving downstream for maturing beforemigrating upstream again as adults forspawning. This restriction has potential to impact species distribution in thecatchment, availability of access tospawning grounds, reduced habitat areaand isolation of populations. The barrierwill be a permanent impact.”155

- In the Assessment of Impact to Habitatsin the Addendum ESHIA, the impact“Barrier to aquatic fauna movement andhabitat fragmentation” is assessed ashaving ‘medium’ sensitivity and‘medium/high’ magnitude, resulting in a designation of ‘major’ significance.156

The residual impact even if all plannedmitigation activities are implementedsuccessfully is still ‘moderate’.157

- In the Assessment of Positive andNegative Impacts of Changes in Flows toCH [Critical Habitat] Fish Species/Groups,in the Addendum ESHIA, the impacts onboth “Endemic and restricted range fishspecies” and “Migratory fish species” areassessed as having ‘high’ sensitivity and‘medium’ magnitude, resulting in adesignation of ‘major’ significance.158

l The ‘bypass reach’ of the river, wherethe water flow is diverted from the riverinto the tunnel that serves the powerhouse, will experience substantialenvironmental disturbance. TheAddendum ESHIA notes:

- “Decreases in longitudinal connectivityin [sic] one of the most significantimpacts of the project in the bypassreach, and will negatively affect most fishspecies in the bypass reach.”159

- “Most of the sensitive species, including indicator species and endemicspecies as identified will experience netneutral or net negative effects in thebypass reach.”160

l A 2015 paper on the impacts of run-of-river systems lists significant impacts of arange of projects and notes that “Thediversion of flow … can alter the physicalhabitat, with consequences for organismsand ecosystem functions … and habitatconnectivity” and that “Most high-headschemes require the construction of anew in-channel barrier ... [which] has two major impacts on a river ecosystem:(1) it disrupts longitudinal connectivity,fragmenting the river; (2) it alters the in-channel environment and thusphysical habitat.”161

Concern: Calling the run-of-river hydropower system ‘environmentally friendly’ overlooks many negative impacts.

Claim: Evidence:

FACTCHECKS

RIVER FLOW AND ECOLOGY

21BATANG TORU HYDROPOWER PROJECT | FACTCHECK AND REFERENCES ON KEY ISSUES

Concern: Claims of minimal impact on river flow are misleading.

“The hydropower plant employs therun-of-river hydro model that does not require dams and hence the impacton river flow is in the vein of thenormal conditions.”162

l The Addendum ESHIA acknowledgesthat changes to flow are expected tooccur and may have significant impact:“The Project would also affect flowsdownstream of the powerhouse. In thisreach, flows will fluctuate when the PowerHouse ramps flows up and down from asingle turbine to four turbines. Inparticular, the change from minimum tomaximum flows can occur in a very shorttime period, and a flow change will occurtwice a day. The anticipated effect ofthese rapidly changing flow regimes is anincrease or decrease in water depth andlateral extent of the Batang Toru River,which manifests as a flood or recessionwave. … Habitat changes in the reachdownstream of Power House arepredominantly related to down-rampingand include potential fish stranding …”163

l The same report also notes that the‘bypass reach’ of the river will experiencesubstantial change in flow rates: “The Project will create a “bypass reach”of the Batang Toru River between thedam and the powerhouse of around14km in length. This bypass reach will bedewatered because the water will bediverted from upstream of the damdirectly to the Powerhouse. The Projectwill alter flow patterns in the bypassreach as it will provide a minimum flow of 2.5m3/s to the bypass reach, which will be much lower than natural flows.The flow will also be constant withoutnatural fluctuation.”164

Claim: Evidence:

ASSESSMENT OF RISK LEVEL

“… site investigation reveals that theclosest active fault was Toru 1B whichhave a distance 4,02 km, and themaximum potential magnitude ofearthquake was Mw 6,7.”165

l The Sumatran fault has a history ofearthquakes above magnitude 6.7:

- There have been 15 large earthquakes(magnitude >7) on or near to Sumatrasince 2000.166

- The nearby Tapanuli Earthquake of 1892is estimated to have been magnitude 7.5or greater.167 168

l There is potentially a high risk of a largeearthquake occurring in this area due toa ‘seismic gap’ – a stretch of the faultlinethat has not slipped for a considerabletime and is therefore at greater risk ofdoing so. “Possible seismic gaps for

M≥7.0 earthquakes along the Sumatranfault are the northern half of the Sundasegment, and the Semangko, Dikit,Sianok, Barumun, Toru, Renun, Aceh, and Seulimeum segments.”169

l It should be noted that the earthquakemagnitude value is a logarithmic scaleand hence small differences in magnituderepresent much larger differences inactual size and energy released. Forinstance, an earthquake of magnitude 7is nearly twice the size of a magnitude6.7 event and releases 2.8 times theenergy, whilst one of magnitude 7.5 ismore than six times larger releasing over15 times as much energy.170

Concern: The risk of high magnitude earthquakes may have been underestimated.

Claim: Evidence:

FACTCHECKS

EARTHQUAKE RISK

INTERNATIONAL FINANCE CORPORATIONSTANDARDS

“… Batang Toru Hydropower Plantadopts the IFC standards, includingstandard number 6 on BiodiversityConservation and Management ofLiving Natural Resources.”171

l The ICF Guidance Note 6 (relating toPerformance Standard 6) says “Wheregreat apes may potentially occur, theIUCN/Species Survival Commission (SSC)Primate Specialist Group (PSG) Sectionon Great Apes (SGA) must be consultedas early as possible.”172 However as ofOctober 2019 – more than five years afterthe production of the original ANDAL173 –the SGA had no record of beingcontacted by or on behalf of thisproject.174 (According to SGA sources thisis still the case as of March 2020.175)

l The IFC standards also require that noproject activities take place until it hasbeen demonstrated that it will not lead toany reduction in the population of aCritically Endangered species. However,project activities have been undertakenwithout a satisfactory demonstration thatthis is the case, and significant impactson the Tapanuli orangutan populationhave already been reported:

- IFC PS6 states “In areas of criticalhabitat, the client will not implement any project activities unless all of thefollowing are demonstrated: … Theproject does not lead to a net reductionin the global and/or national/regionalpopulation of any Critically Endangeredor Endangered species over a reasonableperiod of time …”176

- The Addendum ESHIA confirms that theproject area includes critical habitat forthe species:

“In addition to density estimates, IFC PS6notes specialist consideration for greatapes given their anthropological andevolutionary significance. The outcomes ofthe critical habitat determination indicatethat the primary forest and secondaryforest habitats within the Project area arecritical habitat for the species.”177

“The baseline biodiversity studydocumented in this report identifies: …Project area contribution to corridor andconnectivity values between the WestBatang Toru forest block and DolokSipirok Srtict Nature Reserve to the eastand Sibual-buali Strict Nature Reserve tothe south east – which would beconsidered critical habitat for Criterion 5[of IFC Performance Standard 6, namely‘Key Evolutionary Processes’].”178

- However, the impact of the project onthe orangutan population has beenacknowledged by local authorities:

“"They [orangutans] escaped to locals’plantations," Wiratno, the ministry’sdirector general for conservation, toldMongabay in Jakarta. "So it’s alreadyproven that the project has already dealtan impact. While there’s no casualty yet,it’s an indication that the project musthave had an impact."”179

Concern: The project has not met the requirements of the International Finance Corporation Performance Standard 6.

Claim: Evidence:

FACTCHECKS

STANDARDS AND COMPLIANCE

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23BATANG TORU HYDROPOWER PROJECT | FACTCHECK AND REFERENCES ON KEY ISSUES

EFFORTS TO MINIMISE IMPACT

“As part of the Batang Toru ecosystem,Batang Toru Hydropower Plantmanages the project with highcommitment on conservation andecosystem biodiversity.”180

l Several issues concerning the planningand execution of the project to date callinto question the level of commitment toenvironmental protection. These includepoints relating to:

- The project development process:

The initial impact assessment process wasundertaken without any collaborationwith biodiversity conservationorganisations that had already beenactive in the area for several years, or with the IUCN SGA.

The risk of primates and other wildlifebeing electrocuted on power lines, which has been documented in otherlocations181 182, does not seem to have beenconsidered in the Addendum ESHIA, andno mitigation measures are proposed.

- Project planning decisions:

Spoil heaps have been located inside theBatang Toru ecosystem, and in somecases in forested areas183 rather thanmoving spoil to a less sensitive location.

The current Northern route for thetransmission line (as proposed by PLN)has been adopted by NSHE despite beingmore environmentally damaging thanalternatives such as the previouslysuggested South Easterly route.184

The extensive tunnel length (14 km)presents a barrier to movement oforangutans over a very significantconnection zone – a shorter tunnel would have allowed more opportunities to retain connectivity between orangutansub-populations.

The positioning of the tunnel, access roadand power lines on the West bank of theriver compromises this large forest blockand poses a greater threat to the largestTapanuli orangutan sub-population andits connectivity with the Eastern blockthan siting the tunnel on the East bank.

Application of the ‘precautionary principle’would dictate that lack of gene flowbetween populations should be proven by genetic studies before conductingactivities that could prevent connectivitybetween populations.

Concern: Several project decisions are inconsistent with prioritising environmental and conservation concerns.

Claim: Evidence:

FACTCHECKS

GENERAL APPROACH

24

CONCLUSION

These include several assertions aboutthe use of the project area by theTapanuli orangutan as well as widerenvironmental impacts on orangutans,forest areas and aquatic habitats.Claims about demand for the energyproduced by the power plant and thegreenhouse gas emissions benefits arealso found to be questionable. Inaddition to this, the requirements ofthe International Finance Corporation’sPerformance Standard 6 have not been

met, and engagement with the IUCNSection on Great Apes and a robuststudy into the impacts of the projecton the Tapanuli orangutan are urgentlyrequired. This review thereforesupports the position of the IUCN SGAthat the project should announce animmediate halt to all project activitieson the ground while a fullinvestigation of the impacts on theorangutan population is carried out.

This review has foundmultiple cases ofstatements made inpublic-facing NSHEdocuments that conflictwith findings in NSHE’sown impact assessmentreports and withcurrent scientificknowledge.

25BATANG TORU HYDROPOWER PROJECT | FACTCHECK AND REFERENCES ON KEY ISSUES

SGA STATEMENT ON THE TAPANULI ORANGUTAN

The IUCN SSC Primate Specialist Group’sSection on Great Apes (SGA) is deeplyconcerned about existing and emergingthreats to the Critically EndangeredTapanuli orangutan (Pongo tapanuliensis)in Sumatra, Indonesia. We are particularlyconcerned by the threat of ahydroelectric project development incore orangutan habitat that is currentlyunprotected.

This threatened core area is crucial formaintaining connectivity between thethree forest blocks needed to ensure thespecies’ survival, but is designated as APL(Areal Penggunaan Lain: lit. land for otheruses). Our concern regarding the fate ofthis core area and the orangutans is inline with a statement from the DirectorGeneral of Nature Resources andEcosystem Conservation, Mr. Wiratno,who said recently that “…as theauthorized ministry, we guarantee thatSumatran, Tapanuli and Borneanorangutans will not go extinct. One of theelements underlying this guarantee isthat core parts of their habitats arecovered in the permanent primary forestand peatland moratorium map.”

In line with this statement, the IUCN SGAcalls for a complete halt to allencroachment and development in thisAPL area. International guidelinespublished by the International FinanceCorporation and for all the Equator Banksnow require the following underPerformance Standard 6 Guidance Note6: “Special consideration should be givento great apes (gorillas, orangutans,chimpanzees and bonobos) due to theiranthropological significance. Where greatapes may potentially occur, theIUCN/Species Survival Commission (SSC)Primate Specialist Group (PSG) Section onGreat Apes (SGA) must be consulted asearly as possible to assist in thedetermination of the occurrence of greatapes in the project’s area of influence. Anyarea where there are great apes is likely tobe treated as critical habitat. Projects insuch areas will be acceptable only inexceptional circumstances, and individualsfrom the IUCN/SSC PSG SGA must beinvolved in the development of anymitigation strategy.”

The IUCN SGA further proposes that itsExecutive Committee leads anindependent study into the variousthreats to orangutans occurring in theAPL area, and whether they can bemitigated. The wide breadth of expertise

in the IUCN SGA, which includesscientists from both range and non-range state countries, makes this groupparticularly well suited to lead such astudy. The IUCN SGA therefore urges theIndonesian Government to engage in adialogue to initiate such a study. Furtheractivities in the APL area should only beconsidered once the results of the studyhave been fully reviewed.

The IUCN SGA also appeals to the NorthSumatra Hydro Energy company (PTNSHE), which is developing the hydro-electric project in Batang Toru, toimmediately halt this development toenable the careful assessment of theimpacts of the project. It is necessary tosuspend this development because thestudy may recommend changes to theproject design that would reducenegative impacts on the orangutans, ormay even suggest a relocation of theenergy plant to another site or to adifferent energy source if the impactscannot be mitigated.

The Tapanuli orangutan is the first newgreat ape species to be described sincethe 1920s. Wholly confined to the BatangToru Ecosystem with an estimatedpopulation of fewer than 800 individuals,it is listed as Critically Endangered on theIUCN Red List of Threatened Species. Ithas the lowest number of individuals ofany great ape species, and consequentlyany further loss of habitat, disturbance orkilling of orangutans could drive thespecies to extinction.

The IUCN SGA stands ready to supportIndonesia’s government agencies, NGOsand financial institutions committed topreventing the extinction of the Tapanuliorangutan.

October 5, 2019 (abridged version 27th April, 2020)

Russell A. Mittermeier, Chair, IUCN SSC Primate Specialist Group

Dirck Byler, Vice Chair, Section on Great Apes; dirckbyler.sga@gmail.com

Serge Wich, Vice Chair, Section on Great Apes: serge.wich@gmail.com

Rebecca Kormos, Deputy Vice-Chair, Section on Great Apes;rebeccakormos@yahoo.com

IUCN SSC PrimateSpecialist Group’sSection on Great Apescalls for a moratoriumon development in theTapanuli orangutan’srange.

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1 NSHE / GIS (2014) “ANDAL: Rencana Pembangunan Pembangkit Listrik Tenaga Air(Plta) Batangtoru Kapasitas 500 Mw Dan Jaringan Transmisi 275 Kv Dari PltaBatangtoru Sampai Desa Parsalakan Kec. Angkola Barat Kab. Tapanuli Selatan Prov.Sumatera Utara” PT. North Sumatera Hydro Energy / CV. Global Inter System,Medan, 20142 NSHE/GIS 20143 NSHE (2017) “Final Report: Addendum Environmental, Social and Health ImpactAssessment (ESHIA)” PT. North Sumatra Hydro Energy, February 20174 Pusaka Kalam / NSHE (2018) “FINAL RESEARCH REPORT - Impact of Batang ToruHydropower Construction on Primary Forest, Orangutan Population and Habitat,Drought and Flood, Greenhouse Gases Emission and Socio-EconomicSurroundings” The Center of Study, Advocacy and Nature Conservation (PusakaKalam) / PT North Sumatera Hydro Energy, Research Team: Prof. Dr. Ir. YantoSantosa, DEA; Dr. Ir. Iwan Hilwan, MS; Dr. Ir. Nana Arif Jaya, MS; Dr. Ir. ArzyanaSunkar, MS; Dede Aulia Rahman, PhD; Ir. Idung Risdiyanto, M.Sc, available fromhttp://docplayer.net/130436049-Final-research-report.html accessed 10/03/20205 NSHE (2018) “PLTA Batangtoru "A Socially and Environmentally ResponsibleDevelopment"”, Dharma Hydro – PT North Sumatera Hydro Energy October 20186 NSHE ‘Batang Toru Hydropower Plant’: “Batang Toru Hydropower Plant – PLTABatangtoru A Socially and Environmentally Responsible Development”, DharmaHydro – PT North Sumatera Hydro Energy, 16 pages7 NSHE ‘Common Misconceptions’: “Common Misconceptions about Our Projects”,Dharma Hydro – PT North Sumatera Hydro Energy, 2 pages8 Nater et al. (2017) “Morphometric, Behavioral, and Genomic Evidence for a NewOrangutan Species” Current Biology 27, 3487–34989 Nowak, M.G., Rianti, P., Wich , S.A., Meijaard, E. & Fredriksson, G. 2017. Pongotapanuliensis . The IUCN Red List of Threatened Species 2017:e.T120588639A12058866210 Wich SA, Fredriksson G, Usher G, Kühl HS, Nowak MG. The Tapanuli orangutan:Status, threats, and steps for improved conservation, Conservation Science andPractice, 2019; 1:e33. https://doi.org/10.1111/csp2.3311 The IUCN is “a membership Union composed of both government and civilsociety organisations [which] harnesses the experience, resources and reach of itsmore than 1,300 Member organisations and the input of more than 15,000 experts[to make it] the global authority on the status of the natural world and themeasures needed to safeguard it.” https://www.iucn.org/about accessed09/03/202012 https://www.iucn.org/news/secretariat/201904/iucn-calls-a-moratorium-projects-impacting-critically-endangered-tapanuli-orangutan accessed 09/03/202013 IUCN PSG SGA (2019) “IUCN SSC Primate Specialist Group’s Section on GreatApes calls for a moratorium on development in the Tapanuli orangutan’s range”Mittermeier R.A., Wich S., Byler D., Kormos R., October 2019; available fromhttp://www.primate-sg.org/great_apes/ accessed 09/03/202014 Wich et al 201915 PanEco/YEL 2015: PanEco / Yayasan Ekosistem Lestari, 31 of August 2015,Prepared by PanEco / Yayasan Ekosistem Lestari, requested by ERM / PT. NorthSumatra Hydro Energy “FINAL REPORT Biodiversity Monitoring: Batang Toru riverarea, PT. North Sumatra Hydro Energy Target Area, South Tapanuli, NorthSumatra”, p(ix)16 Andrew B. Davies, Marc Ancrenaz, Felicity Oram, Gregory P. Asner, Orangutanuse of disturbed Bornean forests, Proceedings of the National Academy ofSciences Aug 2017, 114 (31) 8307-831217 Utami-Atmoko, S. Traylor-Holzer, K. Rifqi, M.A., Siregar, P.G., Achmad, B.,Priadjati, A., Husson, S., Wich, S., Hadisiswoyo, P., Saputra, F., Campbell-Smith, G.,Kuncoro, P., Russon, A., Voigt, M., Santika, T., Nowak, M., Singleton, I., Sapari, I.,Meididit, A., Chandradewi, D.S., Ripoll Capilla, B., Ermayanti, Lees, C.M. (eds.) (2017)Orangutan Population and Habitat Viability Assessment: Final Report. IUCN/SSCConservation Breeding Specialist Group, Apple Valley, MN18 Singleton, I., Wich, S., Husson, S., Stephens, S., Utami Atmoko, S. S., Leighton, M.,… Byers, O. (2004). Orangutan population and habitat viability assessment: Finalreport. Apple Valley, MN: IUCN/SSC Conservation Breeding Specialist Group.19 Wich et al 201920 NSHE website, page title ‘Environment and Biodiversity Efforts’,https://www.nshe-hydro.com/page/-environment-and-biodiversity-efforts.htmlaccessed 01/04/202021 Wich et al 201922 masl: metres above sea level23 NSHE ‘Batang Toru Hydropower Plant’, p1124 Nater et al 201725 Wich S. A., Singleton I., Utami-Atmoko S. S., Geurts M. L., Rijksen H. D. and vanSchaik C. P. (2003) The status of the Sumatran orang-utan Pongo abelii: an update,Oryx, 37(1), 49–5426 Kramm, W. (1879). "Tochtjes in Tapanoeli." Sumatra-Courant 20(180 (Thursday30 October)): 1-227 Miller, G. S. (1903). "Mammals collected by Dr. W.L. Abbott on the coast andislands of northwest Sumatra." Proceedings US National Museum, Washington 26:437-48428 This paper pre-dates the description of Pongo tapanuliensis as a separate species29 Rijksen H.D. and Meijaard E. 1999, “Our vanishing relative The status of wildorang-utans at the close of the twentieth century”, © 1997 Stichting Tropenbos /H.D. Rijksen30 Wich et al 200331 NSHE 2018, p2532 NSHE/GIS 2014, pII-3533 S Wich, pers comm34 Pusaka Kalam / NSHE 2018, p(ii)

35 NSHE 2018, Executive Summary36 NSHE 2018, p637 NSHE 2018, p4038 This report pre-dates the description of Pongo tapanuliensis as a separate species39 NSHE 2017, Annex A p6640 Meijaard E, Albar G, Nardiyono, Rayadin Y, Ancrenaz M, et al. (2010)Unexpected Ecological Resilience in Bornean Orangutans and Implications for Pulpand Paper Plantation Management. PLoS ONE 5(9)41 Campbell-Smith G, Campbell-Smith M, Singleton I, Linkie M (2011) Apes inSpace: Saving an Imperilled Orangutan Population in Sumatra. PLoS ONE 6(2)42 S. A. Wich, I. Singleton, M. G. Nowak, S. S. Utami Atmoko, G. Nisam, S. M. Arif,R. H. Putra, R. Ardi, G. Fredriksson, G. Usher, D. L. A. Gaveau, H. S. Kühl, Land-coverchanges predict steep declines for the Sumatran orangutan (Pongo abelii). Sci. Adv.2, e1500789 (2016)43 NSHE ‘Batang Toru Hydropower Plant’, p1144 NSHE ‘Batang Toru Hydropower Plant’, p1145 NSHE 2018, Executive Summary46 This report pre-dates the description of Pongo tapanuliensis as a separate species47 NSHE 2017, p7648 This report pre-dates the description of Pongo tapanuliensis as a separate species49 NSHE 2017, Annex B p31-3250 Nowak et al 201751 NSHE 2018, p152 “Terms of Reference: Conservation Initiatives For The Tapanuli Orangutan”,Joint Program Committee Between NSHE-PanEco “Collaboration On TheConservation Of The Tapanuli Orangutan And Its Habitat In The Batang ToruEcosystem, Sumatra”, briefing for workshop held by NSHE on 19th February 2020in Medan53 Changing Times “Hydropower project ‘imperils world’s rarest great apespecies’” 28th February 2020 (Annette Gartland)54 NSHE ‘Batang Toru Hydropower Plant’, p1155 NSHE ‘Batang Toru Hydropower Plant’, p1156 NSHE 2017, p9157 This report pre-dates the description of Pongo tapanuliensis as a separate species58 NSHE 2017, Annex A p6659 NSHE 2017, Annex B p6460 This report pre-dates the description of Pongo tapanuliensis as a separate species61 NSHE 2017, p111 & Annex B, p6462 IUCN PSG SGA 201963 NSHE ‘Batang Toru Hydropower Plant’, p1164 van Schaik C. P., Wich S. A., Utami S. S., Odom K. (2005) A simple alternative toline transects of nests for estimating orangutan, Primates 46:249–25465 Singleton, I., van Schaik, C.P. Orangutan Home Range Size and Its Determinantsin a Sumatran Swamp Forest. International Journal of Primatology 22, 877–911 (2001)66 NSHE ‘Common Misconceptions’67 NSHE 2018, p2968 HIND 1058 Sheet LI First Edition, available from ubl.webattach.nl/cgi-bin/iipview?krtid=5683&marklat=1.431&marklon=98.7821&sid=3g36bh5081484&svid=455650&lang=1#focus, accessed 30/03/202069 Indonesia 1:250,000, Series T503, U.S. Army Map Service, 1954-, available fromhttp://legacy.lib.utexas.edu/maps/ams/indonesia/index.html /http://legacy.lib.utexas.edu/maps/ams/indonesia/txu-oclc-21752461-na47-11.jpg,accessed 09/03/202070 S Wich, pers comm71 Wich et al 201972 NSHE 2018, p2973 PanEco/YEL 2015, p1974 NSHE 2018, p3875 Sumutpos.co “Orangutan Hidup Harmoni Berdampingan Dengan PLTABatangtoru” / “Orangutans Live In Harmony Together With The BatangtoruHydroelectric Power Plant” 1st October 2019https://sumutpos.co/2019/10/01/orangutan-hidup-harmoni-berdampingan-dengan-plta-batangtoru-2/ accessed 11/03/202076 PanEco/Yel 2015, p(ix)77 NSHE 2017, Annex B p3578 IUCN PSG SGA 201979 Nowak et al 201780 E Meijaard, pers comm81 NSHE ‘Batang Toru Hydropower Plant’, p1182 NSHE 2018, p1483 Changing Times, February 202084 Changing Times, February 202085 NSHE website page ‘Environment and Biodiversity Efforts’, 30/01/202086 This report pre-dates the description of Pongo tapanuliensis as a separate species87 NSHE 2017, Annex B p4388 This report pre-dates the description of Pongo tapanuliensis as a separate species89 NSHE 2017, Annex B p6490 Pusaka Kalam / NSHE 2018, p(ii)91 NSHE ‘Batang Toru Hydropower Plant’, p1192 Pusaka Kalam / NSHE 2018, p2393 van Schaik CP, Azwar, Priatna D (1995) Population estimates and habitatpreferences of orangutans based on line transects of nests. In: Nadler RD, GaldikasBMF, Sheeran LK, Rosen N (eds) The neglected ape. Plenum Press, N.Y., pp129–14794 Pusaka Kalam / NSHE 2018, p(ii)95 NSHE ‘Batang Toru Hydropower Plant’, p1196 S Wich, pers comm

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27BATANG TORU HYDROPOWER PROJECT | FACTCHECK AND REFERENCES ON KEY ISSUES