Examining policy settings in Asia-Pacific

The development of waste-to-energy (WtE) and other waste projects is usually dependent on a combination of environmental and public health policies and (sometimes) energy policies. Without the right policies being in place it is challenging to develop long-term waste projects. Local circumstances can greatly affect policy development – but increasingly a policy in one jurisdiction can affect other jurisdictions and wider markets.

In this article,¹ we outline some frequently used policy levers in specific jurisdictions within the Asia-Pacific region.² For each jurisdiction, we consider the key policy levers used, landfill regulation and diversion, the environment for developing waste projects and, in some cases, the use of WtE projects to achieve environmental and public health outcomes.

Policy is important but it can and will change

Policy is ever-present: In 2017, the People’s Republic of China (PRC) changed its policy on the importation of recyclables.³ This policy change has affected waste projects which relied on exporting recyclables to the PRC, with the recycling industries in many jurisdictions now needing to consider how to respond to the structural change resulting from this policy change. In Australia, for example, container deposit schemes have been (and continue to be) introduced in some states for the first time, with the policy objective of increasing levels of recycling, thereby diverting recyclables from landfill.⁴ Globally, there is renewed focus on how best to combat the presence of plastics in our oceans and rivers.⁵ There is increasing recognition of the need for countries to work together to address the issue of plastics in our oceans.⁶ Thus, local and international policy underpins the waste sector in many ways.

Policy does not stand still: These “headline” policy developments illustrate that policies can and do change, and that a policy in one jurisdiction can have a significant impact on commercial interests in other jurisdictions. In the first articles of this publication we noted the importance of change in law provisions in waste projects. The recent policy change in the PRC has resulted in owners and operators of waste projects (and MBTs and MRFs in particular) looking closely at the change in law provisions in their contracts. Why? The economics of many projects rely heavily upon the ability to sell recyclables into the PRC. Given the nature of the PRC policy change, structural change has arisen in some jurisdictions, forcing policy makers to consider again the importance of markets for recyclables.

As noted in our previous articles, the Waste Management Hierarchy (see Diagram 1) is the touchstone for environmental and public health policy initiatives around the world.⁷

In the first article of this publication, we noted that legislative initiatives have sometimes underpinned the development of waste projects to achieve outcomes reflective of the Waste Management Hierarchy. The most significant of these is EC Council Directive 26 April 1999 (Directive 1999/31/EC). This was the catalyst in the European Union for government sponsored initiatives and regulatory policy settings aimed at diverting waste from landfill and facilitating investment in waste sorting, processing and treatment alternatives. In some form or another, the principles represented in the Waste Management Hierarchy have influenced the policy levers in each of the specific jurisdictions covered below.

In this article we consider the policies of the larger and more populous and still urbanising jurisdictions in Asia (the PRC, India, Indonesia, and the Philippines) and, as a point of different emphasis, Malaysia, which has high urbanisation levels, but still needs to respond to environmental and public health issues arising from waste.

Diagram 1: The Waste Management Hierarchy 

Revisiting policy levers in projects

As the third most populous country in the Asia-Pacific region, with increasing urbanisation (much of it on Java, the most populous island in the world) the way in which Indonesia responds to the environmental and health consequences of increasing levels of MSW may provide a blueprint for other jurisdictions around the world.

As noted in article 1 of this publication, it is estimated that Indonesia produces between 64 and 66 million tonnes of MSW a year. If all this MSW were collected it would provide the feedstock for 115 50MW WtE facilities, equivalent to one sixth of Indonesia’s planned 35GW expansion of installed capacity by 2019. In response to this opportunity, the Ministry of Energy and Mineral Resources (MEMR) developed a Waste-to-energy Guidebook (MEMR Guidebook). The MEMR Guidebook provides an overview of both the waste industry in Indonesia and the prospective range of projects, as well as providing a lot of useful information for any municipality wishing to develop a WtE project. In addition, the MEMR Guidebook is realistic in that it recognises that landfill remains an important part of Indonesia’s waste management industry.

In the context of the PRC, India and Indonesia, the challenge is to manage the calorific value of the MSW (or other feedstock) which is delivered to WtE projects: as referred to above in relation to India, the calorific value of the feedstock is a key consideration in the design of all WtE technologies. In each of the PRC, India and Indonesia the level of moisture in the MSW is critical: because of the nature of the organic fraction in the waste stream and because reusables and recyclables may have been removed (as is the case in India), the moisture level of the MSW is likely to be higher (i.e. it is wetter) and the MSW will have a lower calorific value.

In Indonesia (as well as in the PRC and India) there is a need to balance the use of MSW that is wetter with the interests of existing stakeholders who remove some of the higher calorific materials from the waste stream. Although this may result in the use of less thermally efficient WtE technologies it is not helpful to be dogmatic. It needs to be recognised that projects are just a part of the broader waste management solution in Indonesia: as the MEMR Guidebook states, the most appropriate technology should be preferred, which is not necessarily the most thermally efficient. As a general statement and as a starting point, moving grate thermal technology is generally considered to be the most appropriate option, providing as it does a reasonably high level of flexibility to deal with variations in the composition of the MSW, a reasonably high level of efficiency, a proven track record, lower levels of emissions to air (flue gases) compared to some other thermal technologies, as well as reasonable capital and operating costs.

The key elements for any WtE project in Indonesia are the off-take agreement for power which is entered into with the Indonesian State-owned power utility PLN (the Power Purchase Agreement or PPA) and the supply of waste from the applicable municipality’s sanitation agency or department. It is likely that the PPA will provide all (or most of) the revenue stream for the project company to develop the WtE project. It is less likely that the municipality’s sanitation agency or department will pay the project company a Gate Fee for taking waste delivered by it, but the municipality may take an interest in the WtE facility.

Under Presidential Decree 35 of 2018 (PD 35/2018), the price for electricity purchased by PT PLN (Persero) is prescribed. This price depends on the generating capacity of the PLTSa,¹⁶ as follows:

• capacity of up to 20 MW: an amount of USD 13.35 cents/KWh;
• capacity of more than 20 MW: an amount of USD 14.54 cents/KWh - (0.076 x capacity of the PLTSa sold to PT PLN (Persero) under a power purchase agreement).

These prices apply to power purchase agreements without a need for the PLTSa Developer to negotiate with PT PLN (Persero). The prices are not escalated and are intended to cover the cost of connection from the PLTSa to the PT PLN (Persero) electricity network. The form of the power purchase agreement has to be agreed, and the expectation for the PLTSa Developer should be that the standard PT PLN (Persero) power purchase agreement will be used by PT PLN (Persero) with little scope of negotiation.

These prices do not apply if the PLTSa is undertaken by a State-owned Enterprise (SOE), rather than an Business Entity or Regional-Owned Enterprise (ROE). An SOE may undertake a PLTSa if no Business Entity is selected as a PLTSa Developer or if no ROE is able to act as a PLTSa Developer. This is discussed further below.¹⁷

These WtE projects enjoy certain benefits, including:

• expedited/simplified processes for the licences required
• for projects, namely a Location Permit, an Environmental Licence;
• a Forestry Land Use Licence (if the location of the project is located in a forestry area) and a building construction permit, in addition to other fiscal and non-fiscal incentives (e.g. exemption from import duty);
• government support for any spatial layout adjustments required for project development;
• the land acquisition law for public interest development may be used, providing timing and cost certainty for the acquisition of land;
• possible government guarantees; and
• support from government for WtE development.

Under Presidential Decree 35 of 2018 (PD 35/2018), the provisions stipulated in both: (i) PD 35/2018 and (ii) Presidential Decree No. 58 of 2017 (through an Amendment to Presidential Decree No. 3 of 2016) for the Acceleration of National Strategic Projects (PD 58/2017) are now also applicable to WtE projects in the following Regional Governments and Cities: (i) Special Region of Jakarta Province, (ii) Tangerang City, (iii) South Tangerang City, (iv) Bekasi City, (v) Bandung City, (vi) Semarang City, (vii) Surakarta City, (viii) Surabaya City, (ix) Makassar City, (x) Denpasar City, (xi) Palembang City and (xii) Manado City.

In 2018 (soon after the original version of this article was published), the President enacted PD 35/2018 (entitled “the Accelerated Construction of Waste-Processing Electrical-Energy Installations Based on Environmentally Friendly Technologies”) to replace Presidential Decree No. 18 of 2016 (entitled “the Acceleration of Waste to Energy Installation Development in 7 Cities”) which had been annulled by the Supreme Court of Indonesia in 2017 due to environmental related concerns.

By way of background, in early 2017, the Supreme Court of Indonesia decided that Presidential Decree No. 18/2016 contradicted the Indonesian Environmental Law by allowing developers to commence construction of WtE facilities prior to obtaining the relevant environmental license and building construction permit (IMB). PD 35/2018 has rectified this contradiction and provides a more comprehensive legal framework for the development of WtE projects.

Under PD 35/2018, household waste (and waste similar to household waste) is to be made available for waste processing at Waste Processors (a PLTSa being a Waste Processor) to be processed into Electrical Power based on Eco-friendly Technologies, amongst other things, to reduce significantly the volume of waste going to landfill.

Under PD 35/2018, Indonesia recognised the need to prescribe a structure to promote waste reduction and the management of waste through waste handling. Critically, PD 35/2018 provides for a contribution to a service fee for waste processing of up to IDR 500,000 per ton¹⁹ (approximately USD 35 per ton). In contemplating a service fee for waste processing, PD 35/2018 provides a further revenue source to underpin investment to develop PLTSa.

While Regional Governments and specified Cities²⁰ have duties and responsibilities to implement PD 35/2018, PD 35/2018 recognises that the market may not, or a ROE may not, be able to implement PD 35/2018. In these circumstances, a SOE may develop a PLTSa, based on a proposal from a governor or mayor of the applicable Regional Government or City. As such, PD 35/2018 contemplates that any of a Business Entity (following a competitive process), a ROE or a SOE may undertake the role of PLTSa Developer. It recognises that the funding to implement PD 35/2018 is to be sourced from Regional Budgets and may be supported by the State Budget.

PD 35/2018 recognises that each City-level Government (as detailed in footnote 19 below) may cooperate at Regional Government and City level to develop a PLTSa. Furthermore, cooperation may extend to a provincial government if an asset of a provincial government is used. 

This cooperation may include Regional and City Governments working together with a Waste Management Agency (WMA) or either of them alone with a WMA. Further, PD 35/2018 provides that the minister or the head of the applicable agency for each Regional Government²¹ is to conduct the development and supervision of approvals for each PLTSa. In addition, PD 35/2018, sets out the process for forming a Coordinating Team to support the acceleration of PLTSa developments. In order to speed up the development of WtE projects (in the Provinces and Cities which are the subject of Presidential Decree No. 35 of 2018), it provides that land required for the development of WtE projects can be acquired by way of land acquisition for developments in the public interest (also known as compulsory land acquisition) which is likely to be faster than a business-to-business land acquisition. This compulsory land acquisition is governed by Law No. 2 of 2012.

In addition, the Coordinating Team (consisting of various ministries and related institutions) will coordinate, supervise and support the development of WtE projects. The setting up of the Coordinating Team is to be governed by the Regulation of Coordinating Minister for the Maritime Sector (as the head of the Coordinating Team), although, this Regulation has not yet been issued. Given the important role of the Coordinating Team, it may be considered essential to the implementation of the policy to accelerate the development of WtE projects in Indonesia that the Regulation is issued.

By way of update to earlier Ashurst publications, on on-going WtE projects in Indonesia, the cities of South Tangerang and Tangerang are still seeking to accelerate the development of their WtE projects with a view to completion by 2020. However, the amount of the service fee for waste processing remains a key on-going issue to be agreed.
Indonesian law recognises that projects may be delivered in a variety of ways, including traditional BOO²²  and BOOT²³  delivery models. Critically important to the development of WtE projects as a sustainable industry across Indonesia is the ability of the government at every level to be assured that each WtE project is economically sustainable. The MEMR Guidebook emphasises this.

Based on a study undertaken by the MEMR’s Directorate of Bioenergy, and before Decree 35/2018 was enacted, the challenges for WtE in Indonesia were identified as follows:²⁴

• no uniformity in the payment of, or the amount of, any Gate Fee;
• a need for increased awareness by regional governments of the use of MSW as a feedstock for WtE projects;
• a perception by Regional Governments that the sale of electricity to PLN meant that the regional government did
  not need to manage waste through Gate Fees: a deeper understanding of the basis on which PLN purchases electricity was required;
• limited funding allocated for managing waste; and
• Regional Governments did not have the necessary “know how” to prepare procurement documents and there was no uniform mechanism for procurements.

Following Decree 35/2018 it is good to see that these challenges have been recognised and, from a policy perspective, that the Government is seeking to address them. As well as an increasing interest in developing WtE projects in Indonesia, other initiatives already in place are helping the country to address environmental and public health issues, and are improving the urban environment. For example, Indonesia’s second largest city by population, Surabaya, has a population of approximately 3 million within the city itself, and a population of 6.5 million in its larger urban area. It is estimated that nearly 1,800 tonnes of waste is produced each day. The municipality itself collects nearly 1,550 tonnes of waste per day, and it is estimated that close to 250 tonnes is recovered by the private sector.

The system of waste management in Surabaya (including a long-standing arrangement in which the private sector plays an important part through waste banks to which recyclables are delivered) has made a material contribution to improving the environmental and public health outcomes in Surabaya over the past 15 years or so. For those visiting Surabaya over the years, the change has been clear to see.

Malaysia

Malaysia has a population of approximately 31 million people, producing approximately 9,125,000 to 10,950,000 tonnes of MSW a year (equivalent to 25,000 to 30,000 tonnes of waste per day). While the volume of MSW production is not at the levels of the PRC, India or Indonesia, the Malaysian government’s waste management policies encourage the collection of waste and it is estimated that more than 70 per cent of MSW generated in Malaysia is collected from kerbside or from collection centres. As such, Malaysia has the necessary systems in place to collect MSW as feedstock for WtE facilities. The issue for Malaysia is how to develop WtE projects in an economically efficient way as part of its ever-developing waste management system, while at the same time developing state of the art engineered/sanitary landfill facilities (some with annual capacity in excess of 1 million tonnes a year) and methane collection systems.

In the Malaysian context, neither the rate of population growth (historically fast, but slowing), nor the rate of urbanisation (close to 75 per cent) are going to drive the development of a large WtE energy industry. Rather the development of WtE projects will tend to be more strategic as part of the Malaysian federal government’s policy objective of reducing the quantity of waste landfill and greenhouse gas emissions from landfill, and generating energy from solid waste.

The policy settings in Malaysia have long responded to the fact that a high proportion of the landfill sites in Peninsula Malaysia have limited remaining air/void space. The majority of existing landfill sites are open landfills, as opposed to engineered/sanitary landfills, and as such there are environmental and health implications arising from existing landfill sites. Landfill will remain a requirement of Malaysia’s waste management industry, but the challenge is how best to extend the life of some landfill sites and manage the closure of others.

One of the distinguishing features of the Malaysian waste management industry (compared to the PRC, India and Indonesia) is the immediate opportunity for separation at source of reusable and recyclable materials. There is an opportunity in Malaysia to encourage higher rates of recycling, and this may be an area that will be considered in the medium term. We say the medium term because, at present, the issue with increased recovery of recyclables is finding a market for them (as has been shown by the response of exporting nations to the PRC’s prohibition on importing foreign recyclables). Notwithstanding the policy of reducing MSW sent to landfill and the reduction in greenhouse gas emissions from landfill, in the absence of a market for increased volumes of recyclables recovered, what is the best means of disposing of them? It may be that, in the medium term, one solution is the increased use of recyclables as feedstock for WtE facilities, even though in the longer term, there is a desire to move to an outcome higher up the Waste Management Hierarchy, including reuse.  

Philippines

The Philippines has a population of approximately 107 million people, producing approximately 12,775,000 to 14,600,000 tonnes of MSW a year (or 35,000 to 41,000 tonnes a day). The most recent estimates place production at a little under 41,000 tonnes a day, with over 70 per cent of this waste comprising household waste. (As with the estimates of MSW produced in India, it is likely that more MSW than this is actually produced.) Depending on the source of forward estimates, by 2025 the Philippines may be producing between 16,425,000 and 18,250,000 tonnes of MSW a year (or 45,000 to 50,000 tonnes of waste a day). There are estimates from 2012 which predict up to 28,100,500 tonnes a year, i.e. a doubling of some other forward estimates. What this illustrates is that, as the population of the Philippines continues to urbanise, the assumption is that more waste will be produced. As urbanisation increases, so too does the need for effective management of increased levels of MSW.

The Philippines recognised the need to address the management of MSW relatively early, and put in place a policy framework intended to address the environmental and public health issues arising from the ineffective management of MSW, including closure of landfill and a prohibition on incineration as the natural alternative. Under the laws of the Philippines, each municipality (in the Philippines, referred to as a local government unit (LGU)) is obliged to establish a waste management system to manage MSW within its geographical area. In addition, the law has placed an emphasis on the avoidance, reduction and recycling of MSW, including by requiring separation at source, so as to divert MSW from landfill: the law requires that not less than 25 per cent of MSW must be diverted or recovered.

While there have been and remain challenges (including, in particular, enforcement) many municipalities working with the private sector have achieved relatively high levels of separation at source and recycling (with close to 10,000 MRFs in operation across the Philippines) achieving diversion rates of up to 48 per cent in Metro Manila. A key challenge remains the relatively low collection rates for MSW in some areas. The contrast between areas can be stark: one of the real successes has been the level of collection of MSW in some urban areas – for example, it is estimated that the collection rate in Metro Manila is in the 85-87 per cent range – but in other areas 40 per cent rates are said to exist. The level of collection has a direct impact on the effectiveness of the management of MSW.

Notwithstanding the use of policy levers, some key policies remain to be implemented (and enforced). Open dumping remains the predominant practice: even though municipalities were obliged to close their then-existing open dumping landfill sites some years ago, many of these landfill sites remain in use. Furthermore, while engineered/sanitary landfills have been developed, these have not been developed at the rate projected by government policy, and the environmental and public health objectives sought to be achieved have therefore not been achieved at the projected rates.

This is an illustration of the practicalities of waste management “bumping up” against the cost of implementing policy, and the time taken to do so. To address the costs issue, the government is suggesting to municipalities that they work together to share the costs of the development of engineered/sanitary landfills. This is an approach which has been used successfully in other jurisdictions, although in each jurisdiction it is important to confirm that a municipality is permitted to work with other municipalities, and the extent to which it may do so.

As with other jurisdictions, the development of long-term solid waste management plans by municipalities to outline the way in which waste is to be managed within their geographical areas is key. In this context, there are clearly opportunities for municipalities to plan co-ordinated waste management with other municipalities. We understand that the level of submission of 10-year plans by municipalities for approval by the Department of Environment and Natural Resources’ (DENR) Environmental Management Bureau continues to increase. That said, many municipalities are still to establish solid waste management boards, submit plans, and move to engineered/sanitary landfills.

Since 2015, the private sector has proposed (on an unsolicited basis) the development of WtE projects in the Philippines, and from statements from the DENR there is a clear recognition that the prohibition on incineration does not apply to all WtE projects: the critical issue for the DENR is the following of appropriate guidelines in relation to emissions to air.

This acceptance of the possible development of WtE projects reflects a recognition that other policy levers need to be applied to satisfy the environmental objectives of the Philippines (including the management of greenhouse gas emissions from landfill) provided public health concerns (emissions to air) are appropriately managed. Given the collection rates of MSW in Metro Manila, the development of a WtE facility (announced in 2016) at Quezon City (within the area of greater Manila) may be regarded as a natural private sector response to assured levels of necessary feedstock to enable the development of WtE facilities. (Other WtE facilities are planned and will follow.) In the Philippines, as in all jurisdictions, the choice of technology will be key, particularly in response to the higher level of the organic fraction in the waste stream.

Conclusion

Policy levers are critical to the effective implementation of waste management systems. The variety of responses described above illustrates that the policies in place in individual jurisdictions must recognise the needs of, while at the same time recognising what is achievable in, that particular jurisdiction.

Previously published in Infraread, Issue 11: April 2018, and then updated later in 2019.

1. This article continues the "Waste-to-Wealth" series: previous articles appear in issue 9 and issue 10 of InfraRead (go to Ashurst.com and search "Waste-to-Wealth").
2. In July 2017, the PRC notified the World Trade Organisation that it would change its rules governing the importation of 24 categories of recyclable and solid waste ("foreign garbage") by the end of 2017. This has affected the recycling industries around the globe.
3. Container deposit schemes (CDS) aim to achieve the avoidance, reuse and recycling of waste: the outcomes at the pinnacle of the Waste Management Hierarchy – see Diagram 1. South Australia’s Environment Protection Authority has reported that its CDS has promoted an overall return rate of 79.9 per cent.
4. The Norwegian container recycling scheme requires consumers to pay an additional charge per bottle, which is then refunded when the bottle is deposited in a recycling machine. If Norway’s recycling rates are any indication, the scheme is highly successful, with 97 per cent of plastic bottles being recycled. The UK government has introduced a deposit return scheme for single use drinks containers (whether plastic, glass or metal).
5. For example, the Commonwealth Heads of Government meeting in London in April 2018 included a discussion on how to protect our oceans, and this issue is firmly on the agenda of relevant inter-governmental organisations.
6. For example, the Solid Waste Management Rules, 2016, applicable in India, define waste hierarchy as the priority in which the solid waste is to be (or should be) managed by giving emphasis to prevention, reduction, reuse, recycling, recovery and disposal, with prevention (i.e. avoid) being the most preferred option and disposal to landfill being the least preferred.
7. C&IW or C&I waste is commercial and industrial waste from commercial and industrial premises.
8. C&DW or C&D waste is construction and demolition waste from construction and demolition sites.
9. A Gate Fee being an amount paid by a municipality for acceptance and processing of waste at a landfill or waste project.
10. MSW is municipal solid waste (as distinct from sewage or waste water).
11. It is now estimated that 60 per cent of the population of the PRC lives in urban areas (including a material percentage of the population travelling to the urban environment to work, and in that urban environment produce waste). This figure is expected to exceed 70 per cent by 2030. There are over 100 cities in the PRC with populations of more than 1 million people, and 15 municipal areas of more than 10 million people.
12. NOx is the generic term for the Nitrogen Oxides which are most relevant to air pollution; SOx is the equivalent term for Sulphur Oxides.
13. The Solid Waste Management Rules, 2016 define solid waste as including "solid or semi-solid domestic waste, sanitary waste, commercial waste, institutional waste, catering and market waste and other non-residential wastes, street sweepings, silt removed or collected from surface drains, horticultural waste, agriculture and dairy waste, treated bio-medical waste excluding industrial waste, bio-medical waste and e-waste, battery waste, radioactive waste…"
14. It is our understanding that waste pickers are able to recover a very high percentage of reusable and recyclable material from municipal solid waste. Again our understanding is that approximately 80,000 people are engaged as waste pickers for every 3 million tonnes of reusable and recyclable material recovered.
15. PLTSa stands for Pembangkit Listrik Tenaga Sampah, or waste-fueled power plant.
16. This is a facsimile of Figure 8.2 of the MEMR Guidebook, p129, which is reproduced with kind permission of the MEMR.
17. A Waste Management Agency (WMA) is a business entity that is an incorporated company active and domiciled in the Republic of Indonesia, which may be an Indonesian private company or an SOE or a ROE.
18. A ton for these purposes is 2000 pounds, a short ton. A tonne is 1000 kilograms, or 2,205 pounds, a metric ton.
19. Special Region of Jakarta Province, Tangerang City (Banten Province), South Tangerang City, Bekasi City, Bandung City (West Java Province), Semarang City (Central Java Province), Surakarta City (Central Java Province), Surabaya City (East Java Province), Makassar City (South Sulawesi Province), Denpasar City (Bali Province), Palembang City and Manado City. Presidential Decree No. 35/2018 expanded the applicability of the provisions of Presidential Decree 58/2017 (referred to in our original article) so that they are applicable for WtE Projects located in (i) South Tangerang City, (ii) Bekasi City, (iii) Palembang City, and (iv) Manado City.
20. Governor of Special Region of Jakarta, Governor of Banten, Governor of West Java, Governor of Central Java, Governor of East Java, Governor of South Sulawesi, Governor of Bali, Governor of South Sumatera and Governor of North Sulawesi.
21. Build Own Operate (BOO) means that the project sponsor builds, owns and operates the WtE project, and the municipality (or government agency, authority or corporation) contracts with the WtE project for the provision of services using the WtE project (i.e. the provision of waste acceptance, treatment and processing).
22. Build Own Operate Transfer (BOOT) means that the project sponsor builds, owns and operates the WtE project for the term of the BOOT contract, providing services to the municipality (or government agency, authority or corporation) and then transfers the WtE to the municipality (or government agency, authority or corporation) at the end of the term of the BOOT contract, usually at the option of the municipality, and typically for a nominal purchase price on the basis that the municipality has effectively paid for the WtE project through the payment of service charges.
23. Extracted from a Presentation entitled "Policy on Waste to Energy Development in Indonesia" dated 18 December 2017, prepared by the MEMR's Directorate of Bioenergy.