Implementation of TMDL approach to industrial wastewater managementin Indonesia
Dr. Budi Kurniawan, National Research and Innovation Agency (BRIN)
Prof. Tjandra Setiadi, PhD, Institut Teknologi Bandung,Siem Reap, Friday, 10th Feb 2023

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OutlineIndonesia - Introduction

TMDL Regulations inIndonesia

The Draft of MoEF ofEnhancing TMDL
Application in Indonesia

2Indonesia - Introduction
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INDONESIA & NEIGHBOURING COUNTRIES

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Some facts & statistics:

INDONESIA• 17,508 islands• The biggest moslem country• About 273 million inhabitants (85% moslem)• 336 different ethnics• 500 languages & dialects• lies between two oceans(Indian & Pacific) and two continents (Asia &Australia)• West-east 5150 km, North-south 2000 km• 81% of Indonesia is sea area

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TMDL Regulations in Indonesia
TMDL Guideline Contents

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DEFINITION• The capacity of water pollution load or TMDL (total maximum dailyload) is the ability of water at a water source to receive pollution load
without causing the water to become polluted.
• Total Maximum Daily Load (TMDL) is a term that describes thecalculation of the maximum amount of a pollutant allowed to enter awaterbody• Allocation of pollution load is• the amount of pollution load that is still allowed to be disposed or• the amount of pollutant load to be lowered in the administration
and / or watershed area from ​each pollutant source

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PURPOSE OF TMDL• The purpose of a TMDL is to establish allowable loadings ofpollutants for a waterbody to meet Water Quality Standards(WQS).
• TMDLs provide a basis for determining the pollutant reductions
necessary from point and nonpoint sources to restore andmaintain the quality of water resources.
• Determination of capacity of water pollution load/TMDL and waterpollution load allocation is part of the implementation of waterpollution control using water quality approach.
• The water quality approach aims to control pollutants originatingfrom various sources of pollutants entering the water source byconsidering the intrinsic conditions of water sources and water
quality standards established.
8Government Regulation No. 82 Year 2001 regarding with Water Quality
Management and Water Pollution Control*) this Gov Reg has been replaced by Gov Reg No 22 Year 2021

Article 20Government and Provincial Government, District / City Government accordingly with
their respective authorities in the context of water pollution control at the authorizedwater source:
a. determine the pollution load capacity (TMDL);b. conduct inventory and identification of pollutant sources;c. establishing wastewater requirements for applications on land;d. stipulate the requirements for disposal of wastewater into water or water sources;
e. monitoring water quality at water sources; andf. monitor other factors leading to changes in water quality.

99Government Regulation No. 82 Year 2001 regarding with Water Quality
Management and Water Pollution Control
Article 23(1) In the framework of efforts to control water pollution is determined pollution loadcapacity (TMDL) at water source.
(2) Determination of pollution load capacity (TMDL) as intendedin paragraph (1) shall be made periodically at least 5 (five)year.
(3) The capacity of pollution load (TMDL) as referred to in paragraph(1) is used for:a. granting location permits;b. water and water resources management;c. stipulation of spatial plan;d. granting permits for effluent discharge;e. determination of target water quality andwater pollution control policy.
(4) Guidelines for determining the carrying capacity of pollution loads (TMDL) referred toin paragraph (2) shall be stipulated by a Ministerial Decree.
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Ministerial Level Regulation
1.Minister of Environment Decree No. 110 Year 2003 About THE GUIDELINES OF TMDLDEVELOPMENT. The scope governed by this Ministerial Decree includes the method ofcalculating TMDL/DTBP
2.Regulation of the Minister of Environment 28/2009 concerning TMDL OF LAKE AND
RESERVOIR. The scope of arrangement is the method of determining the status ofwater quality, tropical status and calculation of the pollution load capacity of lakes
and reservoirs
3.Ministerial Regulation no. 01 of 2010 on the Implementation Procedures of WaterPollution Control
4.MenLHK Decree No.SK 298 Year 2017 About TMDL and Pollution Load Allocation ofCiliwung River
5.MenLHK Decree No.SK 299 Year 2017 Concerning TMDL and Pollution Load Allocationof Cisadane River
6.MenLHK Decree No.SK 300 Year 2017 About TMDL and Pollution Load Allocation of11Citarum River11

REASONS TO DO REVISION AFTER 20 YEARS OF TMDL INTRODUCTION• The need to accelerate the recovery of water quality• The change of pollution sources (type, number, distribution and characteristic)
and hydrology & morphology of water sources• the number of provinces and districts / cities that have performed TMDL
calculations is still low• Provinces and districts / municipalities that have calculated TMDL have not beenable to apply the calculation results for wastewater discharge permits• It may be caused by a less obvious concept or the unavailability of a simpler
method• It is necessary to clarify the concept and to use simpler and more implemented
methods

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BackgroundIndonesia suffered
Water Pollution
We need morefrom water
Control (WPC)
detail regulation toresource quality
needs to besupport action
degradation while regulated by Total
plan andplanning to
Maximum Daily implementation ofincrease theLoad (TMDL) to
TMDL for WPC
manufacturing
maintain the waterand also theactivities.
quality for eachguidelines forwatershed.
implementation.
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Strategic Action:
Guideline of TMDL
Development Assistance
IGES Team has preparedtechnical supports for
National and Local
Governments to achieve thegoals and relevant actions ofTMDL implementation.

Goals of the guideline• Construction of more specific policies and regulations by the governments forthe implementation and law enforcement of TMDL in Indonesia.
• Giving the national standard procedure on how to calculate the TMDL fornational and local governments to achieve the standardized implementationand monitoring data for future WPC (Water Pollution Control) actions inIndonesia.
• Fairly distributed common perspectives and knowledge of the TMDL approachfor every related stakeholder to reach an unchallenging consensus of actionplans for WPC actions.
Therefore, this guideline will be able to assist the local governments for any
further improvement in the action plans of TMDL implementation15

Outline of the guideline

Note: this guideline is not yet stipulated
In Indonesia• Section 1: Introduction• Background, Regulations, and Goals and Objective and Scope of TMDL
Guideline• Section 2: Review of TMDL Development• Review of TMDL Development: USA, Japan & Korea, and Lesson Learned forIndonesia• Section 3: Procedure to Develop TMDL
• A to Z of TMDL calculation and development method• Section 4: Development of Institutions and Framework for a SuccessfulImplementation• Suggestions on how institutions should collaborate to implement TMDL16

Lesson Learned for TMDL Implementation inIndonesia
Key Aspects to be considered

TMDL Structure in Indonesia• Watershed Strategy• TMDL development method.
• Funding• Stakeholder Engagement• Targeted and Staged/Phased Implementation

Challenge in Implementing TMDL
(Benham, et al., 2008)•

Lack of sufficient data to characterize the watershed andpollutant sources through modeling and/or monitoring
activities;•Lack of communication and coordination between local
governments and responsible agencies; and•Lack of funding, particularly cuts that occurred during theimplementation effort.

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The Draft of MoEF of Enhancing
TMDL Application in Indonesia
18The concept of TMDL in the draft Ministerial Regulation(1) The minister, governor or regent / mayor in accordance with
their authority to determine the priority of the water source tobe determined the capacity of water pollution load/TMDL andthe allocation of water pollution load.
(2) The determination of the priority of the water source to bedetermined by the capacity of the water pollution load /TMDL
and the allocation of water pollution load shall be based on:a. status of water quality and / or trophic status of water;b. pollutant source from the pollution source inventory andidentification result; and / orc. utilization of raw water for drinking water.
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The amount of actual pollutant load coming into the water source
The magnitude of the contribution of polluted water loadfrom each source of water pollution to the water source
the amount of pollutant load that can be received by the water source withoutcausing the water source to become polluted (TMDL)
the amount of pollutant load that is still allowed to be disposed in theadministrative and / or catchment areas of each pollutant source, in the eventthat the pollution load capacity/TMDL is still available; and / orthe amount of pollutant load to be lowered in the administration and / orwatershed area of each pollutant source, in the event that the pollution load
capacity/TMDL has been exceeded.
Priority programs or activities in order to reduce polluted loads to achieve water quality targets that havebeen set in the future.
The amount of effluent discharge used as a condition ofeffluent discharge permit.

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STIPULATION OF ENVIRONMENTAL - TECHNICAL AGREEMENT FOR
BUSINESS AND / OR ACTIVITIES (Industrial Wastewater)

The minister, governor, regent / mayor shall reject theapplication for environmental technical agreement(Persetujuan Teknis) proposed by the party responsible for thebusiness and/or activity, in the case of the analysis of TMDL
indicate the proposed business location and / or activity plan
is a contributing factor to the violation of TMDL and theallocation of water pollution load.

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WATER QUALITY-BASED EFFLUENT STANDARD• Article 11• (1) In the case of effluent discharge based on the calculation of TMDL
is more stringent than the effluent standard of the national and regional,
then this will be used in the effluent discharge permit.
• (2) In the case of effluent discharge based on the calculation of islooser than the national and regional effluent standard, hence thenational effluent standard or regional effluent standard is used as acondition of effluent discharge permit.

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WATER QUALITY-BASED EFFLUENT DISCHARGE PERMIT FOR INDUSTRIES OR BUSINESSES
Inventory of Pollution Source s and DominantParameter an

Non-Point Source

Identification of Hydrology and Morfologyof Water Source

Point Source

Development of TMDL andPollution Load Allocation

Water Quality Standard and Tropic status

Allowable Load from Industry

Effluent DischargeStandard from TMDL
calculated is used for
Permit/License

LooserStricter

Better application of waste
minimization and / or wastewater
treatment technology

National/Provinc
ial Effluent
Standard

Technology-based
effluent discharge
permitThis standard can beused for Effluent
Discharge Permit

Decrease inproduction capacity
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The Next Steps and Challenges• The draft of Ministry Decree on Total Maximum Daily Load (TMDL) should bestipulated.
• The prepared Guideline will support TMDL application• Challenges:• Improve the capacity of government officers (national and locals),
consultants to understand and master the Guidelines.
• Allocation load (based on TMDL calculation) is for all sectors, however
currently in Indonesia only industries bear the burden of allocationloads (it is not fair). Notes: Action plans for other sectors (Citarum Riveras an example has been formulated, however it is still difficult inimplementation).

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Take Home Message• Successful implementation of TMDL and water quality
improvement is a function of the focus and detail of the TMDL
implementation plan and the plan development process,particularly to stakeholder engagement (Benham, et al.,2008)• Be cautious to use TMDL in the regulatory framework:• It could become a ‘trap’• Use the TMDL as a management tool at the beginning, before
becoming a regulation.
• Do the ‘basic’ things first.
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THANK YOU
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Action Plan of TMDL Implementation inCitarum RiverStatus quo and next action plan28

CITARUM RIVER
WATERSHED

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https://www.researchgate.net/publication/279514929_Influences_of_land_cover_distribution_on_dengue_and_waterborne_diarrhoeal_diseases_-_Case_study_in_the_Upper_Citarum_Catchment_Indonesia/figures?lo=1

The Status of Citarum River
TMDL for Citarum has been calculated and regulated in Minister of Environment and Forestry(MoEF) decree number 300 of 2017. But unfortunately, there is no further detail explanation on how
to achieve the target.
Table 1. TMDL of Citarum River on MoEF Decree number 300 of 2017

SegmentCity/Regency

Saguling CianjReservoir –urCirata
Reservoir

Districts

BOD
Existing(kg/day)

TMDL BOD(kg/day)

BOD LoadReduction(kg/day)

BOD per
BOD
Segment Reduction(kg/day) Precentage

1. Pacet
2. Cipanas
3. Sukaresmi
4. Cikalong
Kulon

32,219.81

16,109.91

16,109.91

26,612.87

8.77%

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The Status of Citarum River
Table 2. Allocation load of Citarum River on MoEF Decree number 300 of 2017

Segment

City/Re
gency

Districts

Domestic
BOD(kg/day)

Poultry
BOD(kg/day)

Industry(kg/day)

Fishery(kg/day)

Non-pointsource(kg/day)

Saguling
Reservoir –Cirata
ReservoirCianjur

1. Pacet
2. Cipanas
3. Sukaresmi
4. Cikalong
Kulon

7,944.39

2,515.75

171.66

3,884.4

1,593.71

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Action Plan
MoEF has also
documented an action
plan report of Citarum
called “Action Plan on
Water Pollution Control in
Citarum Watershed” or
RENAKSI Pengendalian
Pencemaran Air di DAS
Citarum. But up until now,there are lacking
Guidelines How toImplement it.
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