PA3_BusinessClimate_FinalReport by Decentralization Support Facility

Sub‐National Business Climate Reform Program – Phase 2 January 2012

Sub‐National Business Climate Reform Program – Phase 2: Program Final Report January 2012

DECENTRALIZATION SUPPORT FACILITY Indonesia Stock Exchange Building, Tower I, 9th Floor Jalan Jenderal Sudirman Kav. 52-53 Jakarta 12190 Phone: (+6221) 5299 3199 Fax: (+6221) 5299 3299 Website: www.dsfindonesia.org The Decentralization Support Facility (DSF) is a government-led multi-donor trust fund whose principal purpose is to support the decentralization agenda of the Government of Indonesia. The DSF attempts to fulfill three principal roles, which are designed to help the Government of Indonesia to: (i) improve the harmonization, alignment, and effectiveness of development assistance; (ii) inform and thereby improve policy development and implementation; and (iii) build governance capacity, particularly at sub-national levels. The institutional membership of DSF comprises the National Development Planning Agency (BAPPENAS), the Ministry of Finance, the Ministry of Home Affairs, and nine donors (ADB, AusAID, CIDA, DfID, Government of Germany, Government of the Netherlands, UNDP, USAID, and the World Bank). The principal financial donor to DSF is DFID, with AusAID and CIDA also having made financial contributions. Cover photos copyright World Bank Photo Library and stock.xchng (www.sxc.hu). All rights reserved. Sub‐National Business Climate Reform Program – Phase 2: Program Final Report is a product of consultants of the Decentralization Support Facility. The findings, interpretation, and conclusions expressed herein do not necessarily represent the views of the Decentralization Support Facility or its donors. Cover design by Harityas Wiyoga

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

CONTENTS Contents ................................................................................................................................... i List of Acronyms and Abbreviations ........................................................................................ iii A. Introduction ........................................................................................................................ 1 1. Background.................................................................................................................... 1 2. Program Objective ......................................................................................................... 1 3. Results Framework ........................................................................................................ 2 4. Geographical Coverage and Timeframe .......................................................................... 3 5. Institutional Arrangement.............................................................................................. 3 B. Outcome‐level Achievements .............................................................................................. 4 C. Output‐level Achievements.................................................................................................. 7 1. Increase in National Government Capacity to Monitor Performance of OSS Services...... 7 a. Achievement of Output 1 Target ..................................................................................... 7 b. Implementation and Dissemination of OSS Monitoring Survey ...................................... 7 c. Formulation of OSS Service Standards............................................................................. 8 d. National OSS Training and Workshops ............................................................................ 8 e. Replication of Program Approach by MOHA ................................................................... 9 2. Targeted PGs Demonstrate Capacity to Facilitate and Monitor Implementation of OSS by LGs .......................................................................................................................... 10 a. Achievement of Output 2 Target ................................................................................... 10 b. Training of Trainers (ToT) on OSS establishment and development ............................. 10 c. Strengthening role of PGs in OSS development ............................................................ 11 d. Strengthening Capacity of PGs and LGs ......................................................................... 12 3. Improved National Policy on Sub‐National Business Regulations................................... 16 a. Achievement of Output 3 Target ................................................................................... 16 b. National‐level activities to support RIA development ................................................... 16 c. Increasing PG awareness on utilization of Regulatory Impact Assessment (RIA).......... 17 d. Supporting PGs and LGs in utilizing RIA method ........................................................... 18 D. Supporting Activities ......................................................................................................... 22 1. Capacity Building for Local Partners ............................................................................. 22 a. Programmatic Training................................................................................................... 22 b. Finance and Grant Training............................................................................................ 22 2. Program Coordination Workshops ............................................................................... 22 a. Program Partners Coordination Meeting ...................................................................... 22 b. National End‐of‐Program Workshop............................................................................... 23 c. Provincial End‐of‐Program Workshop ............................................................................. 23 3. Media Advocacy........................................................................................................... 23

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

E. Challenges, Lessons Learned and Recommendations.......................................................... 26 1. Challenges..................................................................................................................... 26 2. Lessons Learned and Recommendations ....................................................................... 27 Appendix 1. Political Economy of OSS Establishment ............................................................. 28 Appendix 2. List of Regulations Reviewed .............................................................................. 31

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

LIST OF ACRONYMS AND ABBREVIATIONS AKADEMIKA

Center for Public Policy Analysis, a Bekasi (West Java)‐based NGO

BAPPENAS

National Development Planning Agency (Badan Perencanaan Pembangunan Nasional)

BKPM

Indonesian Investment Coordinating Board (Badan Koordinasi Penanaman Modal)

DPR

National parliament (Dewan Perwakilan Rakyat)

DSF

Decentralization Support Facility

Nuisance permit (Hinder Ordonantie)

IFC

International Finance Corporation

IMB

Construction permit (Izin Mendirikan Bangunan)

KPPOD

Regional Autonomy Watch (Komite Pemantauan Pelaksanaan Otonomi Daerah), a Jakarta‐based NGO

LED

Local Economic Development

Local government

LPTP

Institute for Agricultural Technology Development (Lembaga Pengembangan Teknologi Pertanian), a Manado (North Sulawesi)‐based NGO

M&E

Monitoring and evaluation

MENPAN

State Ministry for Administration of State Apparatus and Bureaucracy Reform (Kementerian Pendayagunaan Aparatur Negara dan Reformasi Birokrasi)

MOHA

Ministry of Home Affairs

NGO

Non‐governmental organization

OSC

OSS Support Center

OSS

One stop shop for business licensing

PAD

Locally generated revenue (Pendapatan Asli Daerah)

Perda

Local regulation (peraturan daerah)

Provincial government

PINUS

Perkumpulan Pilar Nusantara, an NGO network with its headquarters in Bandung, West Java

POPI

Provincial OSS Performance Index

RIA

Regulatory impact assessment

SKPD

Local government department/unit (Satuan Kerja Pemerintah Daerah)

SITU

Business location permit (Surat Izin Tempat Usaha)

SIUP

Trading permit (Surat Izin Usaha Perdagangan)

SME

Small and medium enterprise

SOP

Standard Operating Procedure iii

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

STPDN

Institute for Public Administration (Sekolah Tinggi Pemerintahan Dalam Negeri)

Technical assistance

TDI

Industry registration certificate (Tanda Daftar Industri)

TDP

Company registration certificate (Tanda Daftar Perusahaan)

ToT

Training of trainers

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

A. INTRODUCTION 1. Background Decentralization has significantly increased the authority of local governments (LGs) to issue business licenses and permits, and to enact local regulations. Various international organizations have been supporting a limited number of LGs to reform their business licensing procedures through the establishment of One Stop Shops (OSS) for business licensing, and through improved regulatory processes, using various methods including Regulatory Impact Assessments (RIAs). To build on these efforts, the Decentralization Support Facility (DSF) together with the International Finance Corporation (IFC) supported implementation of a Sub‐National Business Climate Reform program by The Asia Foundation (the Foundation) in 2008‐2010. The program successfully supported the Ministry of Home Affairs (MOHA) and the National Development Planning Agency (BAPPENAS) in issuing various national‐level guidelines on OSS and RIA, including: (i) revised national OSS guidelines; (ii) a national OSS curriculum; (iii) a national OSS monitoring and evaluation (M&E) framework; and (iv) a revised RIA manual. At the provincial level, the program supported two provincial governments (PGs) – North Sulawesi and Bali – to establish OSS Support Centers (OSCs) and RIA Teams. Both OSCs developed and implemented Provincial OSS Performance Indices (POPIs) to evaluate the performance of the district‐level OSS, and established district‐level OSS forums to share knowledge and build up each other’s capacity. The second phase of the Sub‐National Business Climate Reform program (the Program) consolidated, scaled up and sustained the reforms introduced in the first phase of this program. This final report covers the achievements of the second phase and highlights detailed activities undertaken during the last three months of implementation that have not previously been reported. 2. Program Objective The goal of the Program was an improved sub‐national business climate that is conducive to increased investment. The purpose of the Program was to institutionalize capacity within LGs to support business licensing regulations and processes that are effective, efficient, and accountable, with an emphasis on small and medium enterprises (SMEs).

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

3. Results Framework The results framework of the Program is summarized in Table 1. Table 1. Results Framework for Phase Two of Sub‐National Business Climate Reform Program Outcome/Output Outcomes: LGs adopt effective, efficient and accountable regulations and processes for business licensing

Indicator

Baseline

Milestone

Target

LG performance in implementing OSS for business licensing

143 OSS operating under non‐revised guidelines in 2009 Average time to process main business licenses was 65 days in 2009

157 OSS (10% increase) operating under revised guidelines by January 2011

LG performance in utilizing RIA method

No PGs have utilized RIA to evaluate provincial/local regulations MOHA collected unstructured data and information from PGs and LGs in 2009

178 OSS (25% increase) operating under revised guidelines by September 2011 Average 25% reduction in time required for acquiring business licenses in 24 districts by September 2011 8 local regulations modified as per RIA statements by September 2011

Output 1: National government capacity increased to monitor the performance of OSS services

National OSS monitoring survey implemented based on the national OSS M&E framework

Output 2: Targeted provincial governments (PGs) demonstrate capacity to facilitate and monitor the implementation of OSS

Target PGs have capacity to facilitate the establishment of effective OSS

Provincial OSS Support Centers (OSCs) established in six provinces

MOHA and PG Education and Training Units (Badan Diklat), OSCs and representatives of Organizational Bureaus in target provinces are trained to provide technical assistance (TA) to districts by March 2011

Output 3: Improved national policy on sub‐ national business regulations

RIA is utilized to review local regulations

National RIA manual published

Officials of 3 PGs are trained on RIA by March 2011 Target PGs utilize RIA to evaluate local regulations in April‐ June 2011

OSS monitoring survey implemented, documented in a structured database, and disseminated to all levels of government by April 2011 Provincial OSCs support at least 24 districts in establishing or improving OSS performance by September 2011

Target PGs implement RIA method by September 2011

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

4. Geographical Coverage and Timeframe At the outset, the Foundation selected three provinces to participate in the Program based on six criteria: (i) participants in the first phase; (ii) performance contract with the Minister of Home Affairs; (iii) regional champions of BKPM; (iv) commitment and readiness of PGs; (v) availability of potential local partners; and (vi) co‐location with other similar programs. Based on the six criteria, the three provinces selected (see Program Implementation Plan for details) were Riau, South Sumatra, and North Sulawesi. In addition, the Program also provided support to the national government, particularly MOHA and BAPPENAS. The Program ran for 10 months. A Grant Agreement between the World Bank and The Asia Foundation was countersigned by the Country Representative of the Foundation on November 24, 2010, and the program was closed on September 30, 2011. 5. Institutional Arrangement The Foundation engaged with two main local partners (sub‐grantees) in implementing the Program – the Institute for Agricultural Technology Development (LPTP) and the Center for Public Policy Analysis (AKADEMIKA). AKADEMIKA is partnering with Perkumpulan Pilar Nusantara (PINUS). The Foundation and AKADEMIKA coordinated program implementation with MOHA and BAPPENAS. LPTP coordinated with North Sulawesi PG while PINUS, under the oversight of AKADEMIKA, coordinated with the Riau and North Sulawesi PGs. Figure 1. Institutional Arrangement for Phase Two of Sub‐National Business Climate Reform Program National Government

The Asia Foundation

AKADEMIKA

PGs of Riau & South Sumatra

LPTP

PG of North Sulawesi

PINUS

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

B. OUTCOME‐LEVEL ACHIEVEMENTS As indicated in the results framework, there were two main outcome‐level indicators of the Program: local government (LG) performance in (i) implementing OSS for business licensing and (ii) utilizing the RIA method. With regard to the establishment of the OSS, based on the results of the OSS monitoring conducted by MOHA with support from the Program, by the end of September 2011 there were 207 LGs that had established OSS in accordance with the new guidelines, which authorize the unit to process and issue business licenses (“one door” OSS or PTSP).1 These findings were based on responses provided by 252 LGs in 20 provinces (i.e., 51% of the 497 districts in Indonesia). Since only 105 of these 252 LGs had established “one door” OSS at the baseline,2 there had been a 97% increase in the number of OSS established. In terms of numbers and percentage, the Program exceeded its outcome‐level target of 178 OSS, or a 25% increase in the number of OSS established.3 In addition, 32 other LGs have established OSS, but without the authority to issue the licenses (“one roof” OSS). In terms of the time required to process licenses, at the end of the program in the 168 districts where valid license processing data were available, it took OSS an average of 19.3 days to issue the main business license.4 This is a significant improvement on the 32.6 days required prior to OSS establishment in these districts, representing a 41% reduction in processing time. This achievement was significantly better than the 25% reduction targeted in this program. The main contributor to this reduction in processing time is attributable to the introduction of parallel processing, which can only be done in “one door” OSS. Of the 207 “one door” OSS, 144 have established parallel processing procedures, and 69 of these are able to process more than four licenses in parallel. Notwithstanding such a significant improvement, it is important to note several issues with regard to the OSS development. First, based on the results of the 2011 Local Economic Governance Study conducted by the Regional Autonomy Watch (KPPOD) and The Asia 1

The initial form of the OSS was called “one‐roof” services (Pelayanan Terpadu Satu Atap or PTSA). The PTSA are not authorized to issue licenses and only act as “front offices” to accept license applications. Since it is the various technical departments that process and issue the licenses, the PTSA‐type OSS does not have full control of the timing of license processing, and cannot implement reforms such as parallel license processing. Since 2006, MOHA has been promoting a “one‐door” OSS (Pelayanan Terpadu Satu Pintu or PTSP) that has full authority to issue business licenses and is able to process various business licenses in parallel. 2 The baseline is the result of assessment of the OSS monitoring and evaluation initiatives conducted by the Foundation in 2009, under the first phase of the Program. 3 Based on the baseline, which covers all 497 districts in Indonesia, 143 districts were identified to establish “one‐door” OSS in 2009. In addition, 131 districts had OSS that lacked the authority to issue licenses, merely being an integrated front office for submission of business license applications (“one roof” OSS), as identified in the baseline. 4 Main business licenses include construction permit (IMB), nuisance permit (HO/SITU), company registration certificate (TDP), trading permit (SIUP) and industry registration certificate (TDI). 4

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

Foundation in 245 districts in 19 provinces in Indonesia,5 the general perception of business licensing within the private sector is that it is quite good – over 75% of businesspeople think that business licensing is free from illegal charges, free from collusion, and effective. Nonetheless, the study also found that the overall quality of the services is still poor. The average time and cost spent in obtaining a company registration certificate (TDP, required for all firms) is still higher than the national standards. The level of business legalization is also low, with only 49% of firms holding a TDP and 58% having trading licenses (SIUP, required for all firms doing trading). Second, the 2011 OSS monitoring conducted by MOHA also has other important findings: • Of the 207 “one door” OSS, 106 (51%) have the authority to issue between five and 20 different licenses, while the other 101 have the authority to issue more than 20 licenses. Considering around 100 different business licenses fall under the authority of the LG, there are clearly still a substantial number of licenses that remain under the authority of LG technical departments. • The average official time required to issue TDP and SIUP is four days each, which is one day more than the three days stipulated in the relevant Ministry of Trade Decree. About 39% of OSS have standard processing times for TDP and SIUP that are higher than the national standards. • In terms of the number of licensing requirements, on average, nine documents are required to obtain each construction permit (IMB) and nuisance permit (HO/SITU), and seven documents are required for the TDP, SIUP and industry registration license (TDI). • Of the 239 OSS (both “one door” and “one roof”), 83% engage in public dissemination of license requirements, procedures, and costs, showing a high level of transparency. • It was also identified that 53 OSS arrange for payment of license charges to be made through a bank, and 135 have a separate payment counter, both indicating increased safeguards against bribes. With regard to the second indicator – use of the RIA method in reviewing local regulations – the Program supported the participating PGs and LGs in reviewing 46 local‐level regulations. However, only one of these regulations was eventually passed by the local legislative council (DPRD) – a local regulation (perda) of South Sumatra Province on user charges for specific permits. The other 45 regulations were still being discussed at the DPRD, or else were planned to be discussed after the issuance of the 2012 local budgets.6 As a result, the Program did not achieve its targeted outcome of eight local regulations being passed by the end of the Program using the RIA method. 5

The study was conducted with funding from AusAID. Data was collected mainly from in‐depth interviews with around 50 firms in each district. A total of 12,391 private firms were interviewed for this study. 6 Issuing local budget on time, i.e., by the end of December, was the priority of most DPRD following the introduction of an incentive by the Ministry of Finance. 5

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

As discussed in the Challenges and Lessons Learned section of this report, the limited timeframe to implement the Program – ten months overall, and only seven months at the sub‐national level – made it very difficult to advocate for enactment of revised perda based on the results of the regulation review before the Program ended. Based on the Foundation’s experience in other programs, LGs typically require one year to review local regulations. Furthermore, given that most of the regulations reviewed were perda that required DPRD approval prior to their enactment, the Program’s counterparts (provincial and local executives) at the sub‐national level did not have sufficient control to accelerate the approval process.

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

C. OUTPUT‐LEVEL ACHIEVEMENTS 1. Increase in National Government Capacity to Monitor Performance of OSS Services a. Achievement of Output 1 Target The Foundation and its local partners achieved the main target for this output, which is the implementation and dissemination of the OSS monitoring survey by MOHA. The survey aims to map the establishment of OSS in Indonesia and measure the institutional and operational capacity of each OSS. The survey is a part of the OSS monitoring and evaluation (M&E) framework developed by the Ministry with support from the Foundation and its local partner, AKADEMIKA, during the first phase of the Sub‐National Business Climate Reform program. The M&E framework provided for the implementation of annual monitoring of OSS performance, with a more thorough evaluation to be conducted every three years, starting in 2012. b. Implementation and Dissemination of OSS Monitoring Survey The Foundation and its local partner, AKADEMIKA, supported the Directorate of Local Economic Development (LED) at MOHA’s Directorate General of Regional Development through a review of the M&E framework and refinement of the questionnaire used for the monitoring survey. This review took place in February‐March 2011, and the questionnaire was then disseminated through a workshop held on April 12, 2011 in Jakarta. All provincial governments (PGs) that were expected to complete the questionnaire for the provincial‐ level OSS, and to monitor and assist the local governments (LGs) in completing the questionnaire in their respective provinces, participated in this workshop, which was led by the LED Director, W. Sigit Pudjianto. The PGs and LGs were requested to complete the questionnaire and report back to MOHA through the PGs. In Jakarta, AKADEMIKA assisted MOHA in data entry and analysis while in the three provinces supported by the program, the Foundation’s local partners – LPTP in North Sulawesi and PINUS in Riau and South Sumatra – assisted the respective PGs to disseminate and monitor the implementation of the survey. The results of the analysis were disseminated at a workshop hosted jointly by the Foundation and the LED Directorate on September 29, 2011 in Jakarta. The heads/staff of PG administrative bureaus and provincial‐level OSS in 28 provinces participated in the

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

workshop. Based on the completed questionnaires received by MOHA by August 1, 2011,7 there were 214 PGs and LGs (40% of the total) that submitted the questionnaires, 12 of which had not yet established OSS. The Director of AKADEMIKA, Edy Priyono, presented the results of the 2011 monitoring at the workshop. In addition, the Foundation’s Director for Local and Economic Governance, Erman Rahman, presented the results of the 2011 Local Economic Governance Study (LEGS) to complement the results of the OSS monitoring survey from the perspective of the private sector. The main findings of the OSS monitoring survey and the 2011 LEGS are presented in Section B (Outcome‐Level Achievements) of this report. The workshop participants discussed the main obstacles faced and action taken during the process of collecting OSS data from the LGs. The PG of Aceh, for example, had held a workshop with all LGs and regularly reminded them to submit the completed questionnaire, which led to this province achieving the highest response rate. In relation to OSS operations, most participants noted a lack of commitment and understanding among governors, regents and mayors as being the main obstacle to enhancing the authority and performance of the OSS. They hoped that MOHA would play a more significant role in convincing the heads of regions. They also noted that the issuance in September 2011 of a joint circular letter from MOHA, BKPM and the State Ministry for Administration of State Apparatus and Bureaucracy Reform (MENPAN) has helped them to reorganize their OSS. For more on this, please see Section C. c. Formulation of OSS Service Standards Although not included in the original plan, at the request of the LED Directorate of MOHA, the Program supported the formulation of OSS service standards that can be used as a reference by sub‐national OSS in providing services to the local private sector. The Foundation’s partner, AKADEMIKA, supported the LED Director through a series of meetings and a workshop on March 16, 2011 to finalize the service standards. The OSS standards include ten variables and service standards for indicators: the type of license/permit, OSS structure, licensing procedures, licensing requirements, processing time, cost of applications, complaint/grievance mechanism, human resources, infrastructure and facilities, and implementation of e‐government. d. National OSS Training and Workshops The MOHA’s LED Directorate and Training Agency (Badan Diklat) have been actively promoting OSS establishment, holding training and workshops using their own funds. These activities mainly targeted the PGs and LGs that had not established OSS. This positive initiative was supported by the Program through the participation of the Foundation’s

Additional questionnaires were received by MOHA in August‐September 2011, making a total of 11 PGs and 252 LGs that participated in the survey. The main findings are presented in Section B of this report. 8

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

Program Officer and AKADEMIKA’s Director as trainers/resource persons at these events, which were held in April and May 2011. In general, the PGs and LGs showed strong commitment to establishing the OSS. However, there was an interesting polemic on the two versions of OSS suggested by the national government. MOHA, through various decrees and letters, has been promoting the establishment of OSS for business licensing. At the same time, BKPM, through Government Regulation No. 27/2009, has asked the PGs and LGs to establish OSS to accelerate private investment. Many PGs and LGs are coping with these two different requests by establishing an OSS that serves both business licensing and private investment. However, some MOHA officials, particularly those at echelon 3 and 4 levels, are still reluctant to accept this solution and insist that the name of the OSS should refer to the MOHA request, and should not include the term “investment.” Although the Foundation and AKADEMIKA staff endeavored to mediate to convince MOHA officials to accept this practical solution, changing the mindset of these officials proved difficult. e. Replication of Program Approach by MOHA Back in 2008, The Asia Foundation changed its approach to supporting LGs in establishing and improving the performance of the OSS. In addition to working directly with the LGs, the Foundation’s assistance has been directed towards supporting an increasing role for the PGs in monitoring and providing technical assistance (TA) to the LGs.8 Partnerships and intensive communication with MOHA, particularly the LED Directorate, and examples taken from the Sub‐National Business Climate Reform Program, eventually led MOHA to adopt this approach. MOHA allocated Rp 8.5 billion (about USD 900,000) under its 2012 deconcentration budget plan to support 16 PGs to lead the monitoring of and TA and capacity building for the district‐level OSS. The 16 provinces were selected based on their progress in the establishment of the provincial‐level OSS, hence this can also be considered as an incentive for the PGs. The 2012 program was jointly developed by MOHA and the 16 PGs following the 2011 OSS Monitoring workshop discussed above. In general, the program supports establishment and implementation of a district‐level OSS Forum, implementation of OSS M&E, and TA and capacity building to support establishment of the district‐level OSS and improve the performance of the existing OSS.

The approach was piloted in two provinces, West Java and Central Java, under Reducing Barriers to Market Entry and Business Operation (PROMIS, funded by USAID) in 2008. The first phase of the Sub‐National Business Climate Reform Program supported the PGs of Bali and North Sulawesi in 2008‐2009. The PGs of Aceh and East Nusa Tenggara were also supported by Economic Governance in Aceh – Support for Poor and Disadvantaged Areas (EGA‐SPADA, funded by DFID and MDF through the Bank), and by Business Enabling Environment – Australia Nusa Tenggara Assistance for Regional Autonomy (BEE‐ANTARA, funded by AusAID through Cardno Acil), to play monitoring and TA roles in OSS development. 9

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

2. Targeted PGs Demonstrate Capacity to Facilitate and Monitor Implementation of OSS by LGs a. Achievement of Output 2 Target The Foundation and its provincial‐level partners, PINUS in Riau and South Sumatra, and LPTP in North Sulawesi, successfully supported the three PGs in meeting the target of providing support to at least 24 districts in establishing or improving OSS performance. As indicated in Table 2, the number of “one door” OSS in the three provinces increased from eight in 2009 to 36 in 2011), meaning than an additional 28 districts have either established “one door” OSS or upgraded their “one roof” OSS. In addition, four districts identified as not having OSS in 2009 had established “one roof” OSS in 2011. So the only district that still does not have an OSS in the three provinces is East Bolaang Mongondow (North Sulawesi). The Program supported the LG of East Bolaang Mongondow, and the local regulation on OSS establishment was passed by the local legislative council in July 2011, so all 40 districts in the three provinces supported by the Program now have OSS in various forms. Table 2. Progress of OSS Establishment in Riau, South Sumatra and North Sulawesi Province

Baseline (2009)

End of Program (2011)

Total Districts

"One Door" OSS (PTSP)

"One Roof" OSS (PTSA)

No OSS

"One Door" OSS (PTSP)

"One Roof" OSS (PTSA)

No OSS

Riau South Sumatra North Sulawesi

2 1 5

6 4 3

4 10 7

11 12 13

1 3 1

0 0 1

12 15 15

Total

Source: Assessment of OSS Monitoring Initiatives (The Asia Foundation: 2009) and results of OSS Monitoring (MOHA: 2011), processed by the Foundation.

b. Training of Trainers (ToT) on OSS establishment and development To increase the capacity of national and provincial governments and local non‐ governmental organizations (NGOs), the Foundation and AKADEMIKA, together with MOHA’s LED Directorate and Training Center (Badan Diklat), jointly conducted a three‐day Training‐of‐Trainers (ToT) course on OSS on April 19‐21, 2011 in Jakarta. Participants in this training included representatives from the three participating PGs, instructors from MOHA’s Badan Diklat at national and regional level, instructors from MOHA’s Institute for Public Administration (STPDN), staff from the LED Directorate at MOHA, and staff from several local NGOs. The main trainers were Foundation and AKADEMIKA staff, supported by several MOHA officials. In addition to imparting technical knowledge on OSS establishment and development, the training included several sessions on facilitation skills. This was particularly relevant to government officials from PGs, Badan Diklat and STPDN since they do not tend to have facilitation skills.

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

c. Strengthening role of PGs in OSS development North Sulawesi

The program’s support to the PG of North Sulawesi was formally initiated with the signing of a Memorandum of Understanding (MoU) between Foundation partner LPTP and the PG of North Sulawesi on April 1, 2011. The PG’s Regional Secretary, Rahmad Mokodongan signed the MoU with the Director of LPTP, Adiloekito, witnessed by the Foundation’s Director for Local and Economic Governance, Erman Rahman. The MoU signing was followed by a dissemination workshop where the program implementation framework and plan were disseminated to and discussed with the representatives of relevant technical departments of the PG. The provincial OSS forums aim to monitor the progress of district‐level OSS establishment and development, and to facilitate knowledge sharing and learning among them. The provincial forum established during the first phase of the Program was revitalized and a workshop was held on May 5, 2011 in North Bolaang Mongondow (Bolmong). Forum participants included PG and LG officials, who are usually the heads of district‐level OSS. The forum identified two newly established districts without OSS – South Bolmong and East Bolmong – and agreed to support them in establishing OSS. The forum also agreed to improve the quality of the OSS already established in other districts. The improvement agenda includes SOP formulation, delegation of sectoral licensing authorities from technical departments to the OSS, database improvements, parallel processing of licenses, and a reduction in the number of requirements. The second OSS forum was held on August 5, 2011 in Manado. This second forum was attended by provincial and all district‐level OSS, with focus on sharing problems and challenges in the operations of the OSS. The forum was facilitated by the OSS Head for Kota Bitung, the provincial OSS, and LPTP staff. South Sumatra

The MoU signing and program dissemination workshop for the province were held on March 9, 2011 in Palembang. The MoU was signed by the Vice Governor of South Sumatra and the Country Representative of the Foundation, Dr. Robin Bush, witnessed by Mr. Delthy Simatupang of BAPPENAS. The signing was followed by presentations about the Program by Foundation Program Officer Hari Kusdaryanto, AKADEMIKA Director Edy Priyono, and Mr. Delthy Simatupang of BAPPENAS, and discussion. About 150 provincial and local government officials, business associations, academics from local universities, local NGOs and local media participated in the event. Following the signing of the MoUs, the PGs of Riau and South Sumatra were assisted by PINUS to establish the government counterpart teams to implement the Program. The Heads of the Legal Bureaus were appointed to lead RIA‐related activities in both provinces. 11

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

With regard to the OSS activities, the Head of the OSS (Badan Pelayanan Perizinan Terpadu or BP2T) for South Sumatra and the Head of the Provincial Investment Board (BPMD) of Riau were appointed to coordinate the PG officials in implementing the OSS component of the Program in the respective provinces. The Governor of South Sumatra issued a decree on the OSS and the establishment of the RIA teams on March 29, 2011, while in Riau a similar decree is still awaiting signing by the Governor. The OSS forum in the province was established in March 2011 and a workshop was held to identify the needs of each OSS and encourage them to share their experiences. The forum instructed the three districts that did not yet have operating OSS to establish them, namely, East Ogan Komering Ulu (OKU), Ogan Ilir and Kota Prabumulih. In addition, the forum agreed to support improvements in the quality of the existing OSS through steps similar to those agreed in North Sulawesi. The PG of South Sumatra included the newly established OSS forum in its annual plan and allocated a budget for the forum’s activities in the next fiscal year (2012). A governor’s decree to institutionalize the provincial OSS forum was issued in July 2011. Based on the results of the forum, the governor issued formal letters to three LGs that did not yet have operating OSS, instructing them to establish the OSS. Riau

The MoU signing with the PG of Riau was held in Pekanbaru on March 10, 2011. The Governor of Riau, Rusli Zainal, signed the MoU with the Director for Local and Economic Governance of the Foundation, Erman Rahman. The Director of PINUS Riau, Zainul Ikhwan, presented the Program implementation framework to 79 participants from the National Investment Coordinating Board (BKPM), provincial and local government officials, business associations, local universities, NGOs and local media. The presentation was followed by a lively discussion in which local government officials, particularly from district‐level OSS, expressed their interest in being supported by the Program. The OSS forum was established in April 2011 in Pekanbaru, with PG and LG officials participating. The forum noted that although all districts in the province had already established OSS, some of these OSS were not authorized to issue licenses, merely acting as “front offices” to accept license applications (“one roof” OSS). The forum agreed to prioritize the upgrading of these OSS, particularly in two districts –Indragiri Hilir and Kota Dumai. As in North Sulawesi province, the OSS forum in Riau agreed to support improvements in the OSS, with the same agenda as for North Sulawesi. d. Strengthening Capacity of PGs and LGs North Sulawesi

Based on the results of the OSS forum, five main activities were conducted to strengthen the capacity of the PG and LGs in North Sulawesi on OSS development: 12

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

(i) Improvement of Provincial‐level OSS. Prior to Program implementation, the provincial‐level OSS was a “one roof” OSS (PTSA), only authorized to accept license applications, while the process and issuance are beyond their control. The Program supported the upgrading of the OSS. The Governor of North Sulawesi issued a decree delegating his authority to sign 24 types of licenses and permits to the OSS on April 14, 2011. The decree was disseminated to more than 70 participants from all technical departments (SKPDs) on July 13, 2011. Representatives of the SKPDs signed a commitment letter to complete the process of transferring the authority for license/permit signing to the OSS and to cooperate with the OSS to establish a technical team under the OSS that would help the OSS to process and issue licenses/permits. (ii) Establishment of OSS in South Bolaang Mongondow (Bolmong). The PG and Foundation partner LPTP held a series of workshops to build the commitment and capacity of the LG of South Bolmong to establish an OSS, and the LG duly issued local regulation (perda) No. 7/2011 dated April 4, 2011 on establishing an OSS to process 14 types of business licenses and permits. In addition, a Regent (Bupati) Decree No. 122/2011 on parallel license processing was issued in the last week of June 2011. Under this decree, a private company can apply for four basic permits to be processed simultaneously – SIUP, Location Permit, TDP, and HO/SITU. The Program also supported the key officials of the OSS of South Bolmong to visit two OSS best practice sites in North Sulawesi Province – Kota Bitung and North Minahasa, on July 12, 2011. (iii) Establishment of OSS in East Bolmong. Similar to the activities in South Bolmong, the PG and LPTP held a series of workshops to build the commitment and capacity of the LG of East Bolmong to establish an OSS. In East Bolmong, the local regulation to establish the OSS was passed by the DPRD in July 2011. This was followed by the inauguration of the OSS head and officials in the same month. (iv) OSS customer service and team building. The Program arranged three training courses in Manado on customer service and team building for the provincial and local‐level OSS. The first one was held on July 22‐23, 2011 in Manado with participants from Bolmong, South Bolmong and Talaud Islands. The second one was held on July 29‐30, 2011, with participants from Southeast Minahasa and Sangihe Islands. The last training was held on August 12‐13, 2011 for the provincial OSS and the OSS for North Minahasa and Siau Tagulandang Biaro (Sitaro) Islands. (v) Study visits to OSS best practices in East Java. To encourage cross‐learning outside the participating provinces and enhance understanding of ideal OSS services, the Program supported visits by the PG of North Sulawesi and the LGs of Minahasa Selatan, East Bolmong, South Bolmong, Talaud, Sangihe, and Sitaro on June 27‐30, 2011 to OSS best practices in East Java. The team visited the East Java Provincial OSS (which had won the BKPM award for best provincial‐level OSS in 2010) and the district OSS in Kota Blitar, Lamongan, Sidoarjo, Gresik and Jombang. These OSS 13

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

provide many licenses free‐of‐charge, and have ISO certification, an integrated database and a good complaint mechanism. South Sumatra

The activities of the Program in South Sumatra were developed based on the results of the OSS forum held in March 2011 and discussed above. There were seven main activities conducted in the province: (i)

Improvement of provincial‐level OSS. Prior to Program implementation, business licensing services were provided by a working unit under the Provincial BPMD. The TA provided succeeded in influencing the PG to restructure the institution, and the BPMD was transformed into a “Promotion, Business Licensing and Investment Board.” This transformation is an example of how one sub‐national government resolved the issue of the two directives from the national government (MOHA and BKPM) discussed in Section C.1.d above.

(ii) Establishment of OSS in Ogan Ilir. Following the Governor’s letter to the LG, Foundation partner PINUS and the PG visited the district to obtain political commitment from the key officials to establish the OSS. This support resulted in the establishment of the OSS in Ogan Ilir through the issuance of perda No. 6/2011 in the first week of June. The PG and PINUS followed up by supporting the LG in preparing a regent (bupati) decree to delegate the authority to issue licenses from the technical departments to the newly established OSS. Bupati Decree No. 24/2011 was passed on September 8 and delegates ten licenses, including the five basic business licenses, to the OSS. (iii) Operationalization of OSS In East Ogan Komering Ulu (OKU). The perda on OSS establishment was issued in 2007. However, since this was not followed by a budget allocation, appointment of staff, or establishment of an office building and related infrastructure, the OSS could not operate. The PG and PINUS therefore assisted the LG to meet these needs. This led to the issuance of Bupati Decree No. 44/2011 in May 2011 appointing the head of the OSS. In addition, an office building was provided and nine staff were appointed to work at the OSS. As the Program ended, another decree on delegation of licensing authority to the OSS was being prepared in order to transfer authority to issue 13 licenses and permits to the OSS. (iv) Operationalization of OSS of Kota Prabumulih. Similar to East OKU, the OSS in Kota Prabumulih was formally established through Mayoral Decree No. 12/2008 as a unit under the Regional Secretariat. However, it did not have a separate office building and has not been operating as expected. The PG and PINUS assisted the municipal government in revising the mayoral decree to adopt an integrated working mechanism for the OSS. The revised decree (No. 11/2011) was issued in June 2011. At the same time, a draft perda was prepared to strengthen the legal

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

basis for establishing the OSS. This draft is being discussed with the local council (DPRD) and is expected to be passed in December 2011. (v) OSS customer service, team building and complaint handling training. Training was provided to the front‐office staff of provincial and all district‐level OSS in South Sumatra. The two‐day training was held on June 22‐23, 2011 in Palembang, and included a study visit to the OSS of Kota Palembang, which is considered one of the best in the province. In addition, two training courses were conducted for four newly established or underperforming OSS on customer service, team building and complaint handling. The first was conducted on July 14‐16, 2011 in Baturaja for the OSS staff of OKU and East OKU. The second was held on July 18‐20, 2011 in Palembang for the OSS staff of Ogan Ilir and Kota Prabumulih. (vi) SOP formulation workshop. The PG and PINUS held a workshop on June 24‐25, 2011 in Palembang to assist all LGs to formulate their SOP. The SOP includes detailed processes and procedures for the OSS staff to process license/permit applications. It was agreed at the workshop that each OSS would issue SOP for the four or five basic permits/licenses most frequently sought. (vii) Study visit to OSS best practices. The PG technical assistance team for South Sumatra was supported by the Program in visiting the OSS of East Java Province on May 4‐6, 2011. . Riau

As in the other two provinces, the activities of the Program to support the development of OSS were designed based on the results of the OSS forum, which can be grouped into the following five main activities: (i) Upgrading of OSS in Indragiri Hilir. The PG and Foundation partner PINUS supported the LG to revise Bupati Decree No. 11/2011 to allow the OSS to cover an additional 34 types of licenses and permits previously processed by the technical units, increasing the total number of licenses covered from 70 to 104. This was followed by technical assistance (TA) to assist the LG to simplify the requirements for issuing basic business licenses. A workshop was held on July 23‐24 to revise the bupati decree to delegate licensing authority to the OSS. (ii) Upgrading of OSS in Kota Dumai. The PG and PINUS also provided TA to Kota Dumai LG that resulted in the delegation of authority to process and issue investment‐ related permits from various technical departments to the OSS, meaning that the OSS now had the “one‐door” operations (PTSP) as intended by MOHA. In addition, the authority of the OSS was expanded to cover 70 licenses and permits, compared with 34 previously. A mayoral decree (No. 39/2011) was issued on June to ratify these transfers of authority. A series of workshops was held on July 13 and 27 and in the first week of August, 2011 to streamline 50 license/permit requirements and to draft a mayoral decree on SOP for the OSS. 15

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

(iii) SOP formulation workshop. Riau PG and PINUS held a workshop for the PG and all LGs on SOP formulation on June 21‐22, 2011 in Pekanbaru. With support from AKADEMIKA’s consultant, the LGs reviewed existing SOP for basic licenses or, in the case of the newly established OSS, developed new SOP. (iv) Customer service, complaint handing mechanism and team building training. There were two trainings conducted in Riau with support from the Program. The first training on customer service and complaint‐handling mechanism was conducted on July 4‐6, 2011 in Pekanbaru, for 30 staff from the OSS in Kepulauan Meranti, Dumai, Rokan Hulu, and Indragiri Hilir. Another training was held on July 8‐10, 2011 in Pekanbaru for the provincial OSS, covering customer service and team building. (v) Study visit to East Java Province. As a part of capacity building activity, 32 personnel from the provincial OSS and 12 district‐level OSS participated in a study visit to East Java Province and Sidoarjo on July 17‐19, 2011. Thirteen of these participants were funded by the PG and LGs. 3. Improved National Policy on Sub‐National Business Regulations a. Achievement of Output 3 Target The main target of the third output of the second phase of the Program was for the participating PGs to implement the RIA method by September 2011. In North Sulawesi Province, 27 provincial‐level local regulations (perda)9 and six district‐level perda (from South Bolaang Mongondow (Bolmong) and South Minahasa) were reviewed using the RIA method. In South Sumatra, the PG was assisted in reviewing two draft perda while the LGs of Kota Prabumulih and Muara Enim were supported in reviewing five draft perda. In Riau, five provincial‐level perda and a governor’s decree were reviewed using the RIA method. So a total of 46 provincial‐ and local‐level perda and decrees were reviewed using the RIA method with support from the Program. b. National‐level activities to support RIA development With support obtained during the first phase of the Program, BAPPENAS issued an RIA Manual in 2009 to introduce the RIA method for reviewing business‐related local regulations. During the second phase of the Program, various activities were conducted by the Foundation and its local partner, AKADEMIKA, to support the utilization of the RIA method: (i) Workshop to discuss regulatory review tool and technical assistance (TA) strategy. Based on a request from BAPPENAS, a workshop was held on February 22‐23, 2011 9

A local regulation (perda) is the highest level of regulation that an LG can issue. The perda must be discussed and approved by the local legislative council (DPRD). In addition to a perda, the local government can also issue a governor/mayor/regent decree or regulation covering operational guidelines. 16

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

in Jakarta to review the existing RIA tools and curriculum and to formulate (i) simplified regulatory review tools, particularly for the cost‐benefit analysis component, (ii) the strategy for dissemination of RIA through seminars and the media, and (iii) the Program implementation plan. The workshop was attended by BAPPENAS staff, University of Indonesia academics, and staff from the Foundation, AKADEMIKA, LPTP and PINUS. (ii) RIA Training for national level officials. To increase awareness and utilization of RIA by national government officials, RIA training was held on July 27‐29, 2011 in Jakarta. The training was attended by 20 officials from MOHA, BAPPENAS, the State Ministry of Cooperatives and Small and Medium Enterprises, and expert staff of the national parliament (DPR). The training used the RIA manual and was delivered by three trainers – Edy Priyono (Director of AKADEMIKA), Agus Ediawan and Hari Setianto (both RIA experts). (iii) Training of Trainers (ToT) for potential service providers. To increase the number of RIA trainers at sub‐national level to meet an increasing demand from the PGs and LGs, a ToT was held on August 22‐23, 2011 in Jakarta. There were 15 participants, mostly consisting of NGO activists and university lecturers with basic knowledge of RIA. In addition to refreshing their knowledge about RIA, particularly on conducting cost‐benefit analysis, the training also covered facilitation and presentation techniques. Two RIA experts, Hari Setianto and Agus Ediawan, accompanied by a facilitation expert, Juni Thamrin, delivered this two‐day training. c. Increasing PG awareness on utilization of Regulatory Impact Assessment (RIA) The capacity of the officials of the participating PGs and LGs to utilize the RIA method was built through a full RIA training program in two stages, each lasting three days. The first training stage focuses on introducing the RIA method and on its first three steps: identifying the problems that need to be addressed by a regulation, formulating the objectives of the regulation, and exploring alternative ways to address the problems. The second stage covers the last three steps of RIA: cost‐benefit analysis of the alternatives, selecting the best option, and formulating the implementation strategy for the regulation. The series of training was conducted in the three provinces in March‐June 2011, as summarized in Table 3. Table 3. Provincial‐level RIA Training Province

North Sulawesi South Sumatra Riau

First RIA Training

Second RIA Training

Event

Participants

Event

Participants

April 6‐8, 2011 in Manado March 24‐26, 2011 in Palembang

24 PG and LG officials 20 PG and LG officials

June 8‐10, 2011 in Manado May 27‐28, 2011 in Palembang

30 PG and LG officials 20 PG and LG officials

March 28‐31, 2011

26 PG and LG

June 23‐25, 2011 in

25 PG and LG 17

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation in Pekanbaru

officials

Pekanbaru

officials

In addition to the provincial training, the program also supported several RIA trainings and workshops based on specific requests from the LGs: • One‐day RIA workshops were held in South Minahasa, South Bolaang Mongondow and North Bolaang Mongondow (North Sulawesi Province) on April 27, July 21 and July 22, 2011, respectively, to disseminate the RIA method to LG officials, the DPRD, and business associations. These workshops, which were attended by the PG RIA team, were a follow‐up to the RIA training conducted by the LPTP and the PG, and became the starting point for the regulatory review processes in South Minahasa and South Bolaang Mongondow. • A two‐day training was held in Muara Enim on April 29‐30, 2011 attended by LG officials from Muara Enim and Kota Prabumulih (South Sumatra Province). A one‐day workshop on RIA was held for the Legislative Unit (Badan Legislasi) of the DPRD in Kota Palembang (South Sumatra Province) on August 1, 2011. PINUS facilitated the workshop in response to a request from DPRD members who had participated in the RIA training held by PINUS and the PG team. • A training was organized by the LG of Bengkalis (Riau Province) on September 21, 2011 using its own budget. PINUS Director Zainul Ikhwan and RIA expert Agus Ediawan delivered the training to all representatives of the LG’s technical departments (SKPDs) and sub‐district (kecamatan) offices. Another RIA training was held in October 25, 2011, again financed from the LG’s budget, for all heads of villages in the district so that they can issue appropriate village‐level regulations and better plan their village budgets. d. Supporting PGs and LGs in utilizing RIA method In addition to the RIA training series discussed above, the Program built the capacity of PG and LG officials by supporting their efforts to review existing local regulations using the newly introduced RIA method. The Foundation’s provincial‐level partners – LPTP in North Sulawesi, and PINUS in South Sumatra and Riau – held a series of discussions with the respective PGs and LGs in each province to identify local‐level regulations that were considered burdensome to private sector development. This effort also referred to the list of problematic perda issued by MOHA, and to Law No. 28/2009 on Local Tax and User Charges. Another criterion was that the regulations to be reviewed would become the priority of the PGs and LGs, and be included in their annual local legislative program (prolegda).

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

North Sulawesi

Foundation partner LPTP supported the PG of North Sulawesi and several LGs in reviewing provincial and local‐level perda. This support can be categorized into the following three types of activities: (i) Review of provincial‐level perda. At the provincial level, the PG established an evaluation team that was tasked with evaluating 374 perda related to economic development and issued between 1975 and 2010. Through a series of meetings in July and August 2011, 35 perda were identified for further detailed analysis. With support from LPTP and Agus Ediawan (RIA expert), the team was successful in reviewing 27 perda, while the remaining eight would be reviewed after this Program ended. With Law No. 28/2009 used as the basis for the review, six of the 27 perda were considered as being of good quality and able to be retained, while 17 others needed to be revised, and four would be revoked. This good practice was shared with other PG officials and representative of 13 LGs at a workshop on August 10‐12, 2011 in Manado. The workshop participants asked the PG to organize RIA training for provincial and district/municipality DPRD members and to convene another workshop with all LGs to apply the RIA method to a review of regulations relating to user charges. (ii) Review of perda in South Minahasa. The LG was supported by LPTP and the PG to review four perda, on nuisance permits (HO), user charges for general services, user charges for business services, and user charges for specific permits. The HO perda was fully reviewed using the RIA method and resulted in a draft revised perda containing lower fees for obtaining permits in order to attract more businesses to apply for the HO. The other three perda were not fully reviewed with RIA method. However, the PG team, LPTP and Agus Ediawan (RIA expert) reviewed these perda in small meetings with the LG RIA team, and a public consultation was held on August 5, 2011 to discuss the revisions with the private sector and DPRD. In addition, the RIA team recommended that a perda on tariffs and administrative costs for producing maps should also be revoked. (iii) Review of perda in South Bolaang Mongondow. There were two perda reviewed by the LG’s RIA team. The perda on user charges for general services reduced the number of user charges applicable, so reducing costs for the private sector and general public. Of 14 types of general service user charges permitted under Law No. 28/2009, the draft perda only adopted four types of user charges: health services, printing fees for ID cards and civic registration certificates, traditional market services, and vehicle inspections (KIR). The second perda reviewed related to specific permits, including building permits, nuisance permits, fishing enterprises, and route permits. A workshop was held on July 21, 2011 to discuss the drafts of the two perda with relevant stakeholders, the PG RIA team, and the national RIA expert. The workshop was followed by TA conducted by LPTP and the national RIA expert to

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

specify the time, mechanism and requirements to obtain permits as well as to design the formula for user charges. South Sumatra

The Foundation’s local partner in the province, PINUS, supported the PG and two LGs – Muara Enim and Kota Prabumulih – to utilize the RIA method to review their perda. (i) Review of provincial‐level draft perda. There were two draft provincial‐level perda reviewed by the PG’s RIA team – user charges for specific permits (route permits) and investment incentives. PINUS facilitated several discussions to review the existing draft of the route permit perda and organized a public consultation on May 12, 2011. Based on the results of the consultation, PINUS supported the PG to revise the draft to develop formula for the user‐charge tariff, compare the draft with other alternatives, and develop a specific mechanism for permit renewal. The PG was also supported in applying a simplified RIA method to review the draft perda on investment incentives. The draft was enhanced based on a cost‐benefit analysis of various alternatives, including mechanisms for both domestic and foreign investment, as well as to define the operational regulations. The two drafts were submitted to the Governor and the Provincial DPRD in June 2011. The former has been passed in October 2011, while the latter is now being discussed at BKPM and MOHA. (ii) Review of perda in Muara Enim. The LG’s RIA team, with assistance from the PG RIA team and national expert, conducted a full RIA process to review Perda No. 6/2005 on company registration licenses (TDP) and Perda No. 7/2005 on trading permits (SIUP), and provided input on a new draft perda on warehouse permits (TDG). The PG RIA Team and national expert conducted a series of TA visits in July 2011. In addition, two public consultations with private sectors were held on July 19 and 26. The team recommended reductions in user charges and the time required to process the licenses/permits, and streamlining of the procedures and number of requirements in the three perda. Final RIA statements were presented to the public on July 30, and the process continued with legal drafting by the legal bureau in August. The three draft perda were submitted to the DPRD in September, but further discussion was deferred to 2012 due to the DPRD’s prioritizing discussion of the 2012 budget with the executive. In addition to the three perda, the RIA team also recommended canceling the formulation of a draft perda on HO since this permit was already included in the draft perda on specific licenses/permits that was finalized by the DPRD. (iii) Review of perda in Kota Prabumulih. The LG’s RIA team successfully formulated a new regulation on construction permits (IMB). After receiving RIA training in April 2011, the LG of Prabumulih discussed the draft perda of IMB that had been submitted to the DPRD but been returned for revision due to several issues: a) the 20

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

absence of any reference to the zoning regulations (RTRW); b) inadequate justification of costs and benefits; c) the designated OSS lacking the necessary authority to process the permit; and d) lack of any explanation of the procedure and time required to process the permit. The LG team, assisted by PINUS, the PG RIA team and the national expert conducted a series of meetings and technical assistance from June to August to revise the draft accordingly. The draft perda was being discussed by the DPRD as the Program ended. Riau

In Riau, the Foundation’s local partner PINUS mainly supported the PG in reviewing five perda and a governor’s decree using the RIA method. These five perda all concerned the user charges imposed for route permits, local products, health services, fisheries permits, and use of provincial assets. Meanwhile, the governor’s decree reviewed concerned renting out the regency hall, which the Supreme Audit Agency (BPK) had recommended be revoked. The Program supported utilization of the RIA method to review these regulations, together with public consultations, during July and August 2011. All of the draft perda and the governor’s decree were finalized and submitted to the Legal Bureau of the PG in August 2011. In addition, the team prepared a governor’s decree on the use of provincial assets as an interim measure pending approval of the new perda by the provincial DPRD.

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

D. SUPPORTING ACTIVITIES 1. Capacity Building for Local Partners It is the Foundation’s approach to work with local partners to ensure transfer of knowledge from Foundation staff and more experienced local NGOs to those in the provinces. Furthermore, empowerment of provincial‐level partners allows for the continuation of advocacy and support to PGs and LGs to improve the sub‐national business climate beyond the life of the Program. a. Programmatic Training To refresh the knowledge of the local partners and to align the approach of the Sub‐ National Business Climate Reform 2 Program, two parallel OSS (ToT sessions were held in Palembang (South Sumatra) and Pekanbaru (Riau) on February 10‐11, 2011. The two training sessions covered business licensing reform principles, OSS technical assistance (TA) strategies and timeline, and basic facilitation methods. PINUS staff in both provinces participated in the training. Two weeks later, AKADEMIKA hosted an RIA ToT for LPTP and PINUS in Jakarta. In addition to discussing local regulation (perda) mapping (diagnostic study) tools, RIA principles and steps, strategies, and the Program timeline, the three‐day ToT was also used to share the experiences of LPTP and AKADEMIKA in implementing the first phase of the Program. b. Finance and Grant Training The Foundation’s Finance and Grants Management team and Program Officers held financial management training for the three local partners on February 23‐25, 2011 in Jakarta. The training covered a range of topics including principles of accounting, accounting software (QuickBooks), and procurement procedures. In addition to financial staff of the local partners, program staff also participated in the training to ensure aligned understanding of the financial management requirements of the Program. 2. Program Coordination Workshops a. Program Partners Coordination Meeting The Foundation convened a coordination meeting with all partners, both national and local. Program managers and officers of the partners attended a two‐day coordination meeting in Jakarta on June 20, 2011. The meeting discussed the progress of program implementation, 22

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

including achievements of outputs and outcomes; shared approaches used for advocacy and technical assistance; and formulated a strategy to ensure the Program was completed on schedule.

b. National End‐of‐Program Workshop The Foundation convened the final workshop for the Program in Jakarta on September 30, 2011. Around 40 MOHA, PG and LG officials, Foundation and local partner staff participated in the workshop. The workshop discussed overall achievements and lessons learned from the Program. Government officials at all levels expressed their appreciation for the Program’s efforts to stimulate them to streamline business licensing and local regulations. The program had come at the right time – in conjunction with increasing demands from the national government both to establish OSS and to align all local regulations with Law No. 28/2009 – but was considered too short, and the government officials requested additional support beyond the life of this Program. Several strategic recommendations were formulated and shared on how too sustain the initial good practices in both the OSS and RIA components. In South Minahasa, the RIA method has been institutionalized and will be used for drafting regulations in the future. In South Sumatra, the OSS Forum has been legalized through a governor’s decree, and the PG has allocated a budget for it to perform its activities. c. Provincial End‐of‐Program Workshop At the provincial level, end‐of‐program workshops with similar agendas were held in Pekanbaru (Riau) on August 9, 2011 and in Manado (North Sulawesi) on September 22, 2011. In Riau, the workshop focused on RIA program implementation and evaluation. While in Manado the workshop discussed overall program achievements and lessons learned. The North Sulawesi workshop was attended by around 70 participants, including representatives from eight LGs, business associations and the PG, with Dr. Ferry Liando from a local university leading the discussion on the program exit strategy. 3. Media Advocacy The Foundation’s local partners invited local journalists to major Program events. For example, the MoU signing with the PG of South Sumatra was covered by at least 22 print and online media, including Sumatera Ekspres, Berita Pagi, Sriwijaya Post, Sumsel Post, seputarindonesia.com, republika.com, and antartv.com. A similar event in Riau was covered by seven print and online media, including Riau Pos, Tribun Pekanbaru, Pekanbaru Pos, and riaubisnis.com. In addition, PINUS Riau utilized a local radio station to discuss the Program’s activities to support improvements in the local business climate. Two interactive talk shows were 23

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

broadcast by a Pekanbaru‐based radio and TV station on March 31, 2011. The first talk show, airing on Aditya FM Radio, was used to disseminate Program information, with the Director of PINUS, Zainul Ikhwan, and an official from the Riau Province OSS as the resource persons. Later that day, the PINUS Director and the Chairman of the Riau Chamber of Commerce, Mr. Delisis Hasanto, discussed the issues faced by local entrepreneurs in dealing with business licensing regimes on local TV station Riau Televisi. Towards the end of the Program, a TV dialog was aired on Riau TV on August 14, followed by a radio talk show on August 15, 2011. The Director of PINUS, Zainul Ikhwan, and s PG representative presented an update on the Program and its implementation. In South Sumatra, a radio talkshow aired on Trijaya FM Palembang on August 3, 2011 to discuss Program implementation, with a PINUS staff as the resource person. A talkshow was broadcast on state television station TVRI. The Head of the Provincial Investment Agency, Permana, and the Program Manager of PINUS, Rabin Ibnu Zainal, were interviewed to discuss business climate issues in South Sumatra. In North Sulawesi, a live TV dialog on the RIA program was aired on July 27, 2011, with LPTP staff and the Head of the PG’s Legal Bureau. On August 4, similar talkshow was broadcast on Delta FM Manado. The provincial‐level RIA event on August 8, 2011 also featured on local TV. In addition, several RIA‐related events were covered in local newspapers, including Tribun Manado (August 7, 2011), Komentar (August 8, 2011) and Manado Pos (August 9 and 12, 2011). At the national level, the Minister of Home Affairs (Gamawan Fauzi), the Chair of the Indonesian Entrepreneurs Association (APINDO, Anton Supit) and the Director for Local and Economic Governance of the Foundation (Erman Rahman) participated in a national television dialog program called Economic Challenge, which aired on Metro TV on August 8, 2011. Discussion topics included various issues to do with local economic governance, particularly business licensing, local regulations, and transaction costs. During this television dialog, the Minister of Home Affairs repeatedly expressed his concerns and asked 24

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

that all PGs and LGs continue improving the performance of the OSS and comply with the requirements under Law No. 28/2008 on Local Taxes and User Charges. A media gathering was held on August 19, 2011 in Jakarta to discuss business licensing, local regulations and transaction costs. Edy Priyono and Erman Rahman gave a briefing on the issues to journalists from Antara (Indonesian news agency), The Jakarta Post, Media Indonesia and Metro TV. This was reported in The Jakarta Post on August 22, 2011.

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

E. CHALLENGES, LESSONS LEARNED AND RECOMMENDATIONS 1. Challenges Delays in the approval of the Grant. The first phase of the Sub‐National Business Climate Reform Program was completed in January 2010. The two main national‐level counterparts, BAPPENAS and MOHA, then sought continuation of the program, initiating discussions with the DSF Secretariat in mid‐2010. The lengthy process needed for the DSF to approve and prepare a Grant Agreement between the World Bank and the Foundation resulted in the start of the second phase being delayed until November 2010. This resulted in a ten‐month gap in support to the national and sub‐national governments, and reduced the duration of the second phase to ten months. Momentum built during the first phase of the Program decreased significantly as a result of this delay. Reorganization of BAPPENAS, MOHA and PG of North Sulawesi. Another major challenge facing the Program was reorganization within its three main government counterparts. The Director for Regional Autonomy and the Head of Legal Bureau at BAPPENAS were replaced prior to and during the second phase of the Program. Similarly, the LED Director at MOHA was also replaced prior to implementation of the second phase. A significant amount of time was therefore spent building relationships and trust with the new government officials. A change of priority at the Legal Bureau of BAPPENAS also meant that the planned RIA activities had to be adjusted. Lastly, the replacement of the Regional Secretary of the PG of North Sulawesi at the start of the second phase of the Program delayed initiation of the program in that province. Major events at sub‐national level. Although the Foundation and its partners were able to complete all planned activities, the impact of several major events was not anticipated during program planning. In south Sumatra, the impact of a national boy and girl scouts jamboree in July 2011, and the Southeast Asia Games in November 2011 resulted in many PG and LG officials, even those not directly involved in these events, being very busy, and implementation of the Program was a lower priority. Similarly, other major events, including local elections, in Riau and South Sumatra Provinces reduced the pace of Program implementation. Issuance of revised regulations. Law No. 28/2009 on Local Taxes and User Charges provides a strong incentive for PGs and LGs to review their existing local regulations to make sure they comply with this Law. However, the results of the regulatory review under Output 3 of the Program required revisions of perda, which require approval from the DPRD. Since such approval is outside the control of the executive branch, which was the government branch engaged with the Program, many of these revisions could not be completed before the Program ended. 26

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

2. Lessons Learned and Recommendations The model of working with the PG to support LGs worked, and is being adopted by MOHA. The expansion of the model of working with the PG in the two new provinces – Riau and South Sumatra –worked as well as it had in North Sulawesi during the first phase of the Program. The PGs were incentivized by having a specific role in monitoring and supporting the LGs. The OSS forums established in the three provinces were also effective in allowing “peer learning” among the LGs within each province and created positive competition among them to establish or upgrade their OSS. Indeed, this model is now being adopted by MOHA for its own budgets in 16 provinces in 2012. The priority is changing from establishing OSS to service quality improvements. The comprehensive M&E framework developed in the first phase of the Program to some extent helped change the orientation of MOHA from focusing on the number of OSS established to becoming concerned about the performance of the OSS that have been established. The 2011 LEGS findings that business licensing has a good image in terms of being effective, and free from collusion and illegal charges, but that the actual time and cost of licensing still exceeds the national standard, highlight the relevance and importance of advocating for the MOHA to focus more on the quality of OSS services. Based on various discussions with MOHA officials at the end of the Program, this will likely receive more attention in the future. There is dichotomy between MOHA’s and BKPM’s version of OSS is being resolved. As discussed in the section on Activity 2 under Output 1 of this report, there are two national government instructions to PGs and LGs on the establishment of OSS. This issue was resolved through the issuance of a joint circular letter signed by MOHA, BKPM and MENPAN on September 15, 2010. This letter focuses the importance of the investment and business licensing functions promoted by BKPM and MOHA, rather than the OSS structure– meaning that PGs and LGs do not need to establish separate OSS for such similar functions. The Foundation and its partners fully support this circular letter and used it as a basis for facilitation and technical assistance during the Program. The RIA method has been simplified, and linked with Law No. 28/2009. Although the complete RIA method was introduced to the participating PGs and LGs, the Program was flexible on its use during support for reviews of local regulations (perda). The main principles of the RIA method – a cost‐benefit analysis of various alternatives to the regulations, and public consultation in the regulation‐making process – were applied, while the detailed steps were less stringently followed. Furthermore, using Law No. 28/2009 as a reference for regulatory reviews was very successful in encouraging PG and LG officials to be more thorough in their reviews of local regulations. This approach should be adopted in a future program on regulatory review.

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

APPENDIX 1. POLITICAL ECONOMY OF OSS ESTABLISHMENT In the last few years, the one stop shop for business licensing (OSS) has become an icon of local governance reform that many institutions – both government and non‐government organizations, including the State Ministry for State Apparatus Administration and Bureaucracy Reform (MENPAN), Corruption Eradication Commission (KPK), and Transparency International Indonesia – expect to become a model public service embedded with good governance principles that can be replicated in other areas of public services. On the other hand, some have criticized the fact that many OSS do not help businesses that much. They point out that many licenses still have to be obtained from the technical department rather than the OSS; several requirements must be fulfilled prior to the licensing processes within the OSS; bribery still occurs; and the OSS adds another layer to the business licensing processes. Such criticism arose because many OSS were initially established merely to comply with a national government requirement. Based on Ministry of Home Affairs (MOHA) 2011 monitoring,10 of the 195 LGs that established OSS and participated in its survey, 4% had “unit” status. This indicates that the OSS do not have authority to issue licenses. The OSS only receives license applications that must be forwarded to various technical departments to be processed and approved. This kind of OSS is called a “one‐roof” OSS and can be considered more like a “post office” and does indeed simply add another layer of business licensing. The results of the 2011 monitoring also showed that 62% of the OSS are only authorized to issue fewer than 20 licenses, indicating that many other, mainly sectoral, licenses still have to be obtained outside the OSS. However, the monitoring also identified that 26% of the OSS are led by relatively high‐ranking officials (minimum echelon 3), were established through a local regulation (indicating a higher probability of their being sustained), are authorized to issue more than 20 licenses, have a standard operating procedure (SOP) for issuing licenses, have transparent information about licensing time, costs and requirements, have established a complaint handling mechanism, and are able to process various licenses in parallel. All of these features indicate that the institutional requirements for a well‐run OSS are in place. Based on the Foundation’s experience, there are several issues that must be dealt with in the process of OSS establishment to ensure that all of these good characteristics in place. First is a strong commitment from the district head. Although it is not necessary for the district head to be the one who has have the idea of establishing the OSS, his or her strong commitment to establishing the OSS is a necessary condition. In general, inter‐district competition and “instruction” from the national government are adequate incentives for the head of district to establish the OSS. In addition, the extra “locally‐generated revenue” (PAD) from more firms legalizing their businesses can also be the driver for the head of district to promote OSS. The relatively small amount of “illegal

Based on completed questionnaires as of August 1, 2011. 28

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

charges” from business licensing that goes to the head of district means that there is no substantial disincentive that might encourage blocking the process. Second is the establishment of a strong “OSS preparation team” within the LG. It is important to build a network among mid‐level civil servants who are committed to work hard to establish the OSS. In many places, young, reform‐minded and ambitious civil servants are the primary drivers of change in business licensing. Being seen by the head of district, which may lead to accelerated career promotion, can be considered as the main incentive for them. Interestingly, in some regions civil servants who are about to retire (mostly echelon 3 and below), who “have had enough” and want to leave behind “something good” from their career, can also be a main driver of OSS establishment. These two factors – strong leadership and a solid preparation team – are needed to take on the main opponents of OSS establishment, namely, the heads and staff of the technical departments (SKPD) that held the licensing authority prior to the OSS establishment. Although theoretically these SKPDs should follow the local‐level regulations on OSS establishment and transfer of licensing authority, in many cases the SKPDs do not follow the regulations and maintain such authority within their departments, causing the OSS to have limited authority and not be able to leverage better services. Hence, it is necessary for the head of district and the preparation team to discuss with and lobby the SKPD heads and staff to “release” their licensing authority. The disincentive for the SKPDs , which will lose both formal and informal income, means that the importance of this process can not be underestimated. The other two stakeholders – the local legislative council (DPRD) and the private sector –‐ are also important considerations in the process of OSS establishment. In general, the incentives and disincentives for the head of district described above also apply to the DPRD members. Formally, they are happy if the district is recognized nationally and their PAD increases, and informally they do not really lose anything. And although the private sector is not strong enough in most places to initiate or demand licensing reform, small businesses in particular can be employed to advocate for licensing reform. Third is development of a standard operating procedure (SOP) for licensing process. The main feature of the OSS that most local‐level public services lack is clear and transparent SOP on issuing licenses. Although it can be time consuming and costly, participatory development of SOP (as opposed to using SOP developed by the national government) by the OSS preparation team is very important to build their understanding of the OSS and to ensure that the SOP is based on the capacity of the staff and other local context. Parallel processing of licenses, transparency of licensing time, costs and requirements should all be incorporated in the SOP development at this stage. Fourth is selection of personnel and image building. It is critical that the OSS be staffed with highly‐ motivated and reform‐minded civil servants. Hence, the selection process of the head and staff of newly‐established OSS cannot follow the regular civil servant recruitment and appointment. An open and transparent selection process involving non‐government stakeholders must be conducted to ensure that only capable staff run the OSS. Most of the well‐run OSS have a different uniform from other SKPDs. Instead of the standard military‐style uniforms, OSS staff usually have a more “business‐friendly” attire. In places where the Foundation provided support, team building activities

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

were also commonplace, serving to strengthen working and team spirit. Finally, many well‐run OSS also provide an additional honorarium as an incentive for OSS staff who perform well. In conclusion, several political and technical aspects of OSS establishment need to be considered in efforts to ensure that the OSS that are established operate as expected and provide a good service that benefits the private sector, particularly small businesses. Most of these features are not currently in place, meaning that the OSS will not operate well by relying solely on the MOHA’s instruction for replicating OSS best practices. On the other hand, working intensively with almost 500 different LGs is not an effective or efficient way to promote reform. The approach used by the Program, of working with the provincial governments, which then facilitate cross‐learning and inter‐ district competition within the province, in conjunction with national government directives, appears to be the most effective way to move forward.

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

APPENDIX 2. LIST OF REGULATIONS REVIEWED

No.

Number/Year

6/1978

3/1981

8/1987

4 5

4/1996 5/1998

1/1999

7 8 9

3/2000 4/2000 6/2000

3/2000

11 12

4/2002 5/2002

6/2002

7/2002

8/2002

9/2002

3/2003

4/2003

38/2003

1/2004

2/2004

3/2004

Regulation Title North Sulawesi Province Merubah untuk Pertama Kali Perda Prop. Dati I Sulut tentang Penggunaan Rumah‐Rumah Daerah Prop. Dati I Sulut Perubahan untuk Pertama Kali Perda No. Prn.G/DPR‐Sul/1970 Tentang Pendirian PD. Pembangunan Sulut. Penyidik Pegawai Negeri Sipil di Lingkungan Pemerintah Prop. Dati Sulut I R I G A S I Iuran Pelayanan Irigasi Perubahan Bentuk Hukum BPD Menjadi Perseroan Terbatas (PT) Bank Pembangunan Sulut Retribusi Izin Trayek Retribusi Penjualan Produksi Usaha Daerah Retribusi Pelayanan Kesehatan Pajak Pengambilan dan Pemanfaatan Air Bawah Tanah dan Air Permukaan Bea Balik Nama Kendaraan di Atas Air Pajak Kendaraan di Atas Air Perubahan Pertama Perda Propinsi Sulawesi Utara No. 4 Tahun 1998 Tentang Pajak Kendaraan Bermotor Perubahan Pertama Perda Propinsi Sulawesi Utara No. 5 Tahun 1998 Tentang Bea Balik Nama Kendaraan Bermotor Perubahan Pertama Perda Propinsi Sulawesi Utara No. 6 Tahun 1998 Tentang Pajak Bahan Bakar Kendaraan Bermotor Perubahan Pertama Perda Propinsi Sulawesi Utara Nomor 14 Tahun 2000 Tentang Pungutan masuk pada Kawasan Taman Nasional Bunaken Perubahan Pertama Perda Propinsi Sulawesi Utara No. 1 Tahun 2000 Tentang Retribusi Penggantian Biaya Cetak Peta dan Jasa Ketatausahaan Perubahan Pertama Perda Propinsi Sulawesi Utara No. 2 Tahun 2000 Tentang Retribusi Pemakaian Kekayaan Daerah Pengelolaan Wilayah Pesisir dan Laut Pencegahan dan pemberantasan Perdagangan (TRAFIKING) Terutama Perempuan dan Anak Pengelolaan Pelabuhan Perikanan Retribusi Pemakaian Laboratorium Pada Balai Pembinaan dan Pengujian Mutu Hasil Perikanan. 31

Program Final Report Sub‐National Business Climate Reform Program – Phase 2 The Asia Foundation

No.

Number/Year

23 24

4/2004 9/2004

25 26 27 28 29 30 31 32

33 34 35 36 37 38 39 40 41 42

Retribusi Perpustakaan Pengelolaan Barang Daerah Perubahan Pertama Perda Propinsi Sulawesi Utara Nomor 6 6/2005 Tahun 2000 tentang Retribusi Pelayanan Kesehatan. 9/2006 Penyertaan Modal Daerah Pada Badan Usaha 11/2006 Sempadan Sumber Air 1 /2009 Pencegahan dan Penanggulangan HIV ‐ AIDS South Minahasa District – North Sulawesi Perda Retribusi Izin HO Ranperda Retribusi Perizinan Tertentu Ranperda Retribusi Jasa Usaha Ranperda Retribusi Jasa Umum South Bolaang Mongondow District – North Sulawesi Ranperda Retribusi Jasa Umum Ranperda Retribusi Perizinan Tertentu Riau Province Ranperda Retribusi Izin Trayek Ranperda Retribusi Produk Daerah Ranperda Retribusi Pelayanan Kesehatan Ranperda Retribusi Penangkapan Ikan Ranperda Retribusi Pemakaian Aset dan Kekayaan Daerah Ranpergub Plaza Ternak South Sumatera Provincial Regulations Ranperda Retribusi Jasa Tertentu Ranperda Insentif Investasi Muara Enim District – South Sumatera

43 44 45

No. 6/2005 No. 7/2005

Regulation Title

Perda tentang Wajib Daftar Perusahaan Perda tentang Surat Izin Usaha Perdagangan (SIUP) Ranperda Tanda Daftar Gudang (TDG)

Prabumulih City – South Sumatera Ranperda Izin Mendirikan Bangunan (IMB)