PUBLICATIONS

The Minister of Environment and Forestry Regulation No. P.10/2019 is an instrument to protect and manage the peat ecosystem by maintaining its hydrological function through the determination and management of peat dome peaks based on Peat Hydrological Units (KHG). The determination of the peat dome peak is based on water balance calculations, which designate areas for peat ecosystem protection, mandatory protected areas, and areas prohibited from being recultivated after harvesting or the expiration of business permits. Nevertheless, this regulation also introduces new management rules, including the utilization of previously used peat dome peaks on the condition that the hydrological function is replaced by another peat dome peak, as well as the utilization of areas outside the peat dome peak, whether permitted or unpermitted.

Regulation P.10/2019 mandates business and/or activity proponents to revise their Business Work Plan (RKU), adjust their Restoration Plan Document, and apply for a change in Environmental Permit due to the change in peat ecosystem function. Companies with business permits can continue to utilize their areas, both inside and outside the peat dome peak, until the permit expires, with the obligation to maintain the peat's hydrological function through the construction of canal bulkheads and monitoring of the groundwater level. The presence of this regulation clarifies the areas for protection and management within the KHG, yet it also creates ambiguities in the interpretation of the phrase "utilized peat dome peak" and the phrase "having a permit" regarding the management of areas outside the peat dome peak.