Illustration of Fly Ash from Coal. Credit : Flickr
SR Asia

Delisting Coal Ash from B3: In Support of Indonesia’s Circular Economy

1573 views – Earlier this year (2/02/2021), the Ministry of Environment and Forestry (KLHK) under Joko Widodo Administration excluded coal waste, specifically the coal fly ash and bottom ash (FABA), from the hazardous and toxic waste list (known as B3 waste). The delisting is regulated in the Government Regulation (PP) No. 22/2021 concerning the implementation of environmental protection and management as one of the derivative regulations of the Job Creation Law (Omnibus Law) that was previously passed in October last year. Other countries, particularly the developed ones, including the United States, China, Australia, and Japan, have excluded FABA from B3 waste category.

Rosa Ratnawati, the Director-General of Waste Management under the KLHK, explained that not all coal waste is off the B3 list. The coal waste as indicated in the regulation is the solid waste from coal combustion at steam power plants (PLTU). The regulation narrowly refers to pulverized coal that uses high temperature (more than 800O C) in the burning process, resulting in a minimum and stable carbon that is safe to be utilized. Meanwhile, the high-carbon waste from stoker boiler coal is still categorized as B3, as written in the regulation attachment. As of now, there are 43 state and private-owned PLTU across Indonesia, only six of which use stoker boiler.

The decision has sparked environmental and public health concerns. FABA was said to highly contain heavy metals such as mercury, lead, arsenic, and others. As such, it was worried that the move will negatively impact biodiversity and cause respiratory and cardiovascular disease on people. However, the tests done by independent researchers said otherwise. Backed by the Research Center for Metallurgy and Materials of the Indonesian Institute of Sciences (LIPI), the characteristic testing of Toxicity Characteristic Leaching Procedure (TCLP) and Lethal Dose 50 (LD50) shows that FABA contains a lower concentration of toxins than B3 required.

On the other hand, the decision paves the way for Indonesia to utilize the industry waste to achieve a circular economy that benefits the triple bottom line; industry, ecology, and society. Whilst the standard approach to production and consumption is take-make-waste, the circular model aims to prolong the life cycle of all resources. In practice, it aims to create economic value from negative products or waste, and prevent them from going to landfills or polluting the environment.

According to the data published in 2018 by the Ministry of Energy and Mineral Resources (KESDM), Indonesia’s coal demands are projected to surge up to 162 million tons until 2027. With the estimated 10% of coal use, 16.2 million tons of potential FABA will be produced. However, to date, the utilization of FABA is still on a small scale, ranging from only 1% to 2%, although the FABA production from PLTU reaches tens of millions of metric tons per year. The percentage is far lower compared to other countries, such as China-one of the largest global coal producer-that accounts for more than 50%, and Japan for up to 97%. This means that the utilization of the industrial waste has big opportunities for Indonesia’s triple bottom line, showing the potential for economic and environmental sustainability that the circular model offers.

When FABA was classified as B3 waste, FABA management was limited to ash piling to which is a linear approach to production. The waste was stored for a year in a temporary management site before transported over long distances to landfills at high cost and producing high emissions in the process.  As rain seeps through the waste in the landfills, FABA will eventually leak and release its substance into the local environment, infiltrating the soil and groundwater. In effect, FABA disposal, especially without proper management and in a large amount, will only cause harm to the environment and community.

There was some amount that must be paid if a PLTU wanted to utilize FABA as B3 waste. For example, obtaining the environmental impact assessment (AMDAL) permit could cost PLTU up to 400 million IDR, while transporting FABA could cost up to 1.2 million IDR per ton. In return, the high cost had been hindering the utilization of FABA.

Seeing the high environmental and economic cost of the linear coal production, one solution is to utilize or recycle ash rather than diverting coal ash to landfills. In line with the circular approach, recycling FABA provides added economic value in products of various industries, turning it from a cost center into a profit center. In the construction and infrastructure industry, as an instance, FABA can be used as additive materials in construction, and even as a replacement of raw resources to produce cement, paving blocks, and concrete.

PT Pembangkitan Jawa Bali (PJB) has used 100% of fly ash produced from its Paiton 1 and 2 Unit as artificial pozzolan for the construction of Manado-Bitung toll road in North Sulawesi. Pozzolan is proven to be a sustainable solution as it substitutes the use of raw silica, the main material in cement production. It offers numerous environmental benefits, such as reducing the need for substance mining, and lowering CO2 emissions as the FABA is already decarbonized. Moreover, FABA also has potentials for the agriculture and mining industry. It can be utilized for silica fertilizer mixture, as done by PLTU Ombilin, and preventing the formation of acidic water in mine reclamation, as conducted by PT Kaltim Prima Coal.

Delisting FABA from B3 waste may stimulate further economic benefits. FABA producers can supply the third parties, including SMEs, to process FABA as construction materials at a lower price. Using FABA as both an additive and a substitute for natural resources in concrete potentially renders cost efficiency of 4.3 trillion IDR until 2028 for Indonesia’s infrastructure development. Other PLTU units that have processed FABA accordingly are PLTU Suralaya, Tanjung Jati B, and Asam Asam. The low price of FABA can as well benefit SMEs in concrete brick and paving block production. Within the next ten years, it could absorb up to 500,000 labors that generate approximately 25.3 trillion IDR, according to the Indonesian Chamber of Commerce and Industry.

However, the implementation of the delisting regulation still needs to be monitored strictly. Companies may see the regulation as a loophole to avoid the cost of waste management altogether. While the majority of PLTU units in Indonesia are located along the coast, haphazardly storing and transporting the massive amount of waste will undoubtedly still harm the environment and community. New stringent standards for storing, shipping, and utilizing FABA shall be in place and evaluated regularly. A circular economy model provides a new perspective for waste utilization to generate economic value while preventing social and environmental damages. But still, it should be grounded to ethical values and professionalism of all stakeholders, as well as regulatory compliance to make it well in practice.




Nabila Khoiru Nisa – Programs & Communications Officer for SR Asia Indonesia


Dr. Semerdanta Pusaka – Country Director for SR Asia Indonesia