This report critically examines Minister of Energy and Mineral Resources Regulation No. 10 of 2025 on the Energy Transition Roadmap for the Electricity Sector, particularly its provisions on ending the operation of coal-fired power plants (PLTUs). It identifies a number of normative, methodological, and institutional weaknesses that instead hinder the acceleration of the energy transition. The roadmap was drafted with minimal public participation and low transparency, while positioning PLN as the dominant actor in studies on the early retirement of PLTUs—a situation that is vulnerable to conflicts of interest.
In addition, the policy framework makes early retirement a last-resort option and relies on natural retirement without a clear deadline, while opening the door to false solutions such as co-firing and PLTU retrofits. The analytical instrument used also prioritizes financing factors (27.1%) over environmental impacts (9.3%), while Article 12 makes early retirement voluntary and contingent on the availability of funding. Overall, the policy is deemed to have failed to drive a just and sustainable energy transition and remains misaligned with climate targets for achieving net zero emissions.
This report provides a critical review of Minister of Energy and Mineral Resources Regulation No. 10/2025 on the Energy Transition Roadmap for the Power Sector , particularly regarding the phase-out of coal-fired power plants (CFPPs). The analysis identifies normative, methodological, and institutional weaknesses that undermine efforts to accelerate the energy transition. The roadmap was drafted with minimal public participation, low transparency, and by assigning PLN as the dominant actor in planning early retirement; raising concerns of conflicts of interest.
The policy framework places early retirement as a last-resort option, relying heavily on natural retirement without clear timelines, while leaving space for false solutions such as co-firing and CFPP retrofits. The assessment method further prioritizes financing availability (27.1%) over environmental impacts (9.3%), and Article 12 makes early retirement a voluntary option contingent on funding rather than a binding state obligation. Overall, the regulation fails to serve as a driver of a just and sustainable energy transition and falls short of aligning with Indonesia’s climate commitments toward net zero emissions.
CELIOS_Kritik Peta Jalan Transisi Energi 2025 Download
CELIOS Indonesia Energy Transition Roadmap Challenges 2025 Download