Indonesia: Regional Infrastructure Development Fund Project (AIIB-000012)

  • East Asia and Pacific
Geographic location where the impacts of the investment may be experienced.
  • Indonesia
Geographic location where the impacts of the investment may be experienced.
Specific Location
Indonesia, nationwide
Whenever identified, the area within countries where the impacts of the investment may be experienced. Exact locations of projects may not be identified fully or at all in project documents. Please review updated project documents and community-led assessments.
Financial Institutions
  • Asian Infrastructure Investment Bank (AIIB)
  • World Bank (WB)
International, regional and national development finance institutions. Many of these banks have a public interest mission, such as poverty reduction.
Project Status
Stage of the project cycle. Stages vary by development bank and can include: pending, approval, implementation, and closed or completed.
Bank Risk Rating
Environmental and social categorization assessed by the development bank as a measure of the planned project’s environmental and social impacts. A higher risk rating may require more due diligence to limit or avoid harm to people and the environment. For example, "A" or "B" are risk categories where "A" represents the highest amount of risk. Results will include projects that specifically recorded a rating, all other projects are marked ‘U’ for "Undisclosed."
Voting Date
Mar 22, 2017
Date when project documentation and funding is reviewed by the Board for consideration and approval. Some development banks will state a "board date" or "decision date." When funding approval is obtained, the legal documents are accepted and signed, the implementation phase begins.
Government of Indonesia
A public entity (government or state-owned) provided with funds or financial support to manage and/or implement a project.
  • Infrastructure
The service or industry focus of the investment. A project can have several sectors.
Potential Rights Impacts
  • Cultural Rights
  • Housing & Property
  • Indigenous Peoples
  • Labor & Livelihood
  • Right to Health
Only for projects receiving a detailed analysis, a broad category of human and environmental rights and frequently at-risk populations.
Investment Type(s)
The categories of the bank investment: loan, grant, guarantee, technical assistance, advisory services, equity and fund.
Investment Amount (USD)
$ 100.00 million
Value listed on project documents at time of disclosure. If necessary, this amount is converted to USD ($) on the date of disclosure. Please review updated project documents for more information.
Project Cost (USD)
$ 406.00 million
Value listed on project documents at time of disclosure. If necessary, this amount is converted to USD ($) on the date of disclosure. Please review updated project documents for more information.
Primary Source

Original disclosure @ AIIB website

Updated in EWS Jun 29, 2020

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Project Description
If provided by the financial institution, the Early Warning System Team writes a short summary describing the purported development objective of the project and project components. Review the complete project documentation for a detailed description.

The following Early Warning System Analysis has been prepared in partnership with the NGO Forum on ADB (NGO Forum). The NGO Forum on ADB is an Asian-led network of civil society organizations, based in Asia and the Pacific region who monitor the Asian Infrastructure Investment Bank and the Asian Development Bank. This alert is based on a review of available project documents at the time of writing. In addition, this alert references the work of Indonesian NGOs, who have been monitoring this project and other Indonesian financial intermediaries.


Early Warning System Project Analysis
For a project with severe or irreversible impacts to local community and natural resources, the Early Warning System Team may conduct a thorough analysis regarding its potential impacts to human and environmental rights.

Risk Category: Category FI. The project is co-financed by the World Bank (WB) and Asian Infrastructure Investment Bank (AIIB). According to AIIB’s Environmental and Social Framework, the project will apply the World Bank’s policies. The World Bank classifies projects according to the project’s component presenting the highest environmental or social risks including direct, indirect, cumulative and induced impacts as relevant in the Project area. The World Bank classifies a project as “FI” if the financing structure involves the provision of funds to or through a financial intermediary (FI) for the Project. Under that categorization, the Bank delegates to the FI the decision- making on the use of Bank funds. This includes the selection, appraisal, approval and monitoring of Bank-financed subprojects.

The AIIB will apply the World Bank’s environmental and social safeguard policies. According to World Bank documents, the following environmental and social safeguards are triggered by this project:

Environment Assessment OP/BP 4.01 – This safeguard is triggered because the RIDF will accordingly finance environmental infrastructure investments e.g. water and sewerage plants, sanitary landfill, hazardous waste management facilities, hospital revitalization and urban slums improvement. As the project is categorized as FI, the subprojects to be supported could either be Category A or B.

Natural Habitats OP/ BP 4.04 – Several subprojects may have an impact on natural habitats located in eastern part of Indonesia i.e. Papua, Kalimantan, Sulawesi, NTB.

Forests OP/ BP 4.36 – This safeguard policy is triggered as some of the investment proposals may take place in close proximity to or within forest areas. However, at the time of writing, there is no available detailed information on the said investment proposals.

Pest Management OP 4.09 – There is one proposal, which pertains to irrigation improvement from West Sumatra.

Physical Cultural Resources OP/BP 4.11 – Triggered as some of the subprojects may affect cultural property.

Indigenous Peoples OP/ BP 4.12 - Due to the scope of the RIDF it is also anticipated that it might have an impact on indigenous peoples communities including the Masyarakat Adat or Masyarakat Hukum Adat.

Involuntary Resettlement OP/BP 4.12 – This safeguard policy is triggered, as some of the proposed projects will likely involve land acquisition and/or resettlement. The scope and scale of the social impacts will be determined in the process of reviewing the subproject proposals submitted by subnational governments.

Safety of Dams OP/BP 4.37 – One of the subprojects might also finance the construction of a dam as part of water supply system and water resource management infrastructure.

People Affected By This Project
People Affected By This Project refers to the communities of people likely to be affected positively or negatively by a project.


A coalition of Indonesian NGOs and international allies have tracked financial intermediary funds and raised concerns over the risks to communities and the environment posted by RIDF and the other Indonesian infrastructure financial intermediaries. Their analysis can be found in the links below (see sources). As noted above, until specific subprojects are disclosed and approved, there are limitations to understanding the risks posed by this project. Based on available Bank documents and the analysis of NGO partners, we believe that the following human rights may be impacted:

The sectors eligible for subproject financing under this project include water supply and sanitation; solid waste and drainage, low income housing upgrading, transportation and logistics infrastructure and social infrastructure like educational and health facilities. The potential impacts from the proposed 32 subprojects are identified to be from medium to high, significant, diverse and irreversible. Due to this array of possible investments, these subprojects may likely have an impact on the right to housing and property of potentially affected households. According to project documents, PT Sarana Multi Infrastruktur developed an Environment Social and Management Framework which includes a Land Acquisition and Resettlement Policy Framework (LARPF) and a Process Framework to screen and evaluate the subprojects and its corresponding potential land acquisition and resettlement and social impacts. The scope of LARPF includes situation wherein impacts caused by a subproject resulted in involuntary land acquisition, relocation, loss of assets or loss of access to assets, loss of income sources or means of livelihood. Furthermore displacement can also be full or partial, permanent or temporary and includes both physical and economic displacement.

The following categories of impact or loss have also been identified in the LARPF: loss of agricultural land for food security, loss of forest land, loss of crops and trees, loss of structure including shops, and loss of income, venture and job. The corresponding qualified entitled person and entitlements for each loss are also indicated in the Entitlement Matrix for the potential project-affected persons. As mentioned in the previous section, the estimated number of affected households in each province should be duly accounted for and meaningful consultations should also undertake in all the phases of the project implementation.

According to Bank documents, “it is also anticipated that it might have an impact on indigenous peoples communities including the Masyarakat Adat or Masyarakat Hukum Adat.” In the Indigenous Peoples Planning Framework, the term “Indigenous Peoples” is often associated with “Masyarakat Hukum Adat” (or MHA--Customary Law Communities), which is a common terminology, used in Indonesian Laws and Regulations to describe groups of people with similar characteristics. These include self – identification as members of a distinct indigenous cultural group, collective attachment to geographically distinct habitats, customary cultural, economic or political institutions and have an indigenous language. As mentioned earlier, the scope of subprojects are mostly scattered throughout the country. Hence indigenous peoples might be present and adversely affected in these sites particularly if the large subprojects are located in rural or remote areas such as regional roads. The presence and impacts of IPs can only be evaluated during the review of subproject proposals.

The Environment and Social Impact Assessment identified environmental issues and risks on physical, chemical and biological hazards related to occupational health and safety. There is also an anticipation of possible exposure to infections and diseases and exposure to radiation and fire safety relevant to the social infrastructure investments i.e. construction of healthcare facilities which might pose some risks.

Some of the subprojects might affect archaeological, historical or unique natural values that cannot be ascertained yet as of this writing. However an anticipation of this potential impact might impede on the cultural rights of the potentially project affected persons.

The project may also have social impacts, such as the influx of workers from outside the subproject site, temporary relocation for traders of markets and disturbance on the access roads and livelihoods. The specific details of these are not yet disclosed in available project documents but it was noted in the ESIA that consultations with affected communities relevant to the subproject activities like the need for labor force and requirements and its impacts will be undertaken.


Investment Description
Here you can find a list of individual development financial institutions that finance the project.

Bank financing: As previously indicated, the project is co–financed by the AIIB and the World Bank. AIIB and World Bank will finance $100 USD million each for the Capital Support component for the RIDF. The Government of Indonesia will also support $200 USD million for the same component. The RIDF Project Development Facility will be financed through a $3 USD million grant financing from Switzerland and another $3 USD million of Borrower contribution.

Borrower: Ministry of Finance. Implementing Agency: PT Sarana Multi Infrastrutuk (Persero)

Total project cost: $406 USD million

Financial Intermediary
A financial intermediary is a bank or financial institution that receives funds from a development bank. A financial intermediary then lends these funds to their clients (private actors) in the form of loans, bonds, guarantees and equity shares. Financial intermediaries include insurance, pension and equity funds. The direct financial relationship is between the development bank and the financial intermediary.

Contact Information
This section aims to support the local communities and local CSO to get to know which stakeholders are involved in a project with their roles and responsibilities. If available, there may be a complaint office for the respective bank which operates independently to receive and determine violations in policy and practice. Independent Accountability Mechanisms receive and respond to complaints. Most Independent Accountability Mechanisms offer two functions for addressing complaints: dispute resolution and compliance review.

Mr. Sylvester Hsu
Project Team Leader / Senior Investment Operations Specialist

World Bank:
Mr. Marcus Lee
Task Team Leader / Senior Urban Economist

Ms. Ayu Sukorini
Director of Loans and Grants, Directorate General of Budget Financing and Risk Management,
Ministry of Finance

Implementation Agency:
Ms. Emma Sri Martini
President Director, PT. SMI

According to World Bank documents, stakeholder consultations on the draft Environmental and Social Management Framework were conducted on 21 – 22 June 2016 in Jakarta only. In addition the relevant inputs are incorporated into the final draft of the ESMF. The final ESMF is disclosed on the PT SMI website and on the World Bank website. Bank documents state that specific subproject safeguards instruments, such as environmental impact assessments, “will be subject to consultations and disclosure by the SGs. The timing for consultations shall be carried out prior to subproject appraisal. The SGs will disclose the EIA [Environmental Impact Assessment], EMP [Environmental Management Plan], LARAP [Land and Acquisition and Resettlement Action Plan], IPP [Indigenous Peoples Plan], etc. at the planning stage of subproject preparation, in their websites, a public space accessible to affected groups, local NGOs and other stakeholders. In addition, PT SMI will also disclose such instruments in its website, upon endorsement of the SGs getting the loan from RIDF and support from PDF.”

Based on AIIB’s Public Information Interim Policy, the public has the right to access information. Such information on AIIB’s policies and decision-making determines the public’s participation and ultimately on environmental and social sustainability and safeguards. This Policy will be fundamental to understanding and monitoring the AIIB’s impact, as well as carrying our corrective measures when needed. Similar to other multilateral development banks, the AIIB should also provide the possibility of appeal in cases where a requester believes that the AIIB client or the AIIB have improperly restricted access to information. Information disclosure requests can be sent to:  Additionally, the World Bank’s Access to Information policy requires the World Bank to disclose any information in possession of the Bank, subject to a list of exceptions. Information disclosure requests can be sent online at:


The AIIB has established the Accountability Mechanism for Project-Affected People (PPM).  The PPM provides “an opportunity for an independent and impartial review of submissions from Project-affected people who believe they have been or are likely to be adversely affected by AIIB’s failure to implement the ESP in situations when their concerns cannot be addressed satisfactorily through Project level GRMs or AIIB Management processes.” Two or more project-affected people can file a complaint.  Under the current AIIB policy, when the bank co-finances a project with another development bank, it may apply the other bank's standards. You can refer to the Project Summary Information document to find out which standards apply.  You can learn more about the PPM and how to file a complaint at:

The complaint submission form can be accessed in Arabic, Bahasa Indonesia, Bengali, Chinese, English, Tagalog, Hindi, Nepali, Russian, Turkish, or Urdu. The submission form can be found at:

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