Optimalization of the Utilization of DBH DR for the Acceleration of Social Forestry

This PMK is a government breakthrough to answer the problem of absorption of DBH DR at the regency/city level, which often becomes unused funds (SiLPA) for years in local treasury. Up to 2016, SiLPA of DBH DR in 236 regencies and 24 cities reached Rp 6.9 trillion. This number is expected to increase, given that in 2017 DBH DR distributed directly to 27 provinces reached Rp 699.5 billion. Although since 2017 DBH DR has been transferred from the Regency/City Government to the Provincial Government as a consequence of the enactment of the new Regional Government Law (Law No. 23 of 2014), the regions do not make use of the fund or choose not to absorb it. This is due to strict regulation in Government Regulation No. 35 of 2002 regarding Reforestation Fund, where DBH DR is to be utilized only for Forest and Land Rehabilitation (RHL).

The PMK, signed on 29 December 2017, regulates the use of DBH DR by the Regional Governments, not only for forest and land rehabilitation. The use of DBH DR at the Province level, in addition to RHL, which includes planning, implementation, monitoring, and evaluation, can also finance other supporting activities. For regencies/cities that still have remaining DBH DR up to the 2016 budget, DBH DR can be used to fund the management of Taman Hutan Raya (forest parks), prevention and mitigation of forest and land fires, and planting trees on critical river basins, planting bamboo on the riverbanks, and procurement of structures for soil and water conservation.

The PMK stipulates that before proposing DBH DR activity plans and budgets (RKA), regional governments have to submit the realization report of the remaining DBH DR to the Ministry of Finance, to be discussed with the Ministry of Environment and Forestry (KemenLHK) and MoHA. For regions that still have remaining DBH DR but do not submit the proposal and report the utilization of DBH DR, the MoF will delay the distribution until the termination of other forestry DBH. The assertiveness of the government in this case should be appreciated to spur the optimization of DBH DR absorption in the regions. DBH DR monitoring is carried out by the MoF, Ministry of Environment and Forestry and MoHA to ensure compliance of reporting, conformity with RKA and measure absorption and output. The Government will evaluate the amount of residual DBH DR for each region and the conformity of DBH DR activities with applicable regulations.

As a technical guideline for PMK, the MoF has issued a Regulation of the Director General of Fiscal Balance No. 1 of 2018 on procedures for discussion, format, and standard of details on the design of activities and budgeting for the use of DBH DR.

Use of DBH DR for Social Forestry Acceleration

The major agenda of forest management is to create community welfare in forest areas and realize a sustainable forest model. To achieve these objectives, the government proclaimed Social Forestry, namely community empowerment by opening access to the community to propose forest management rights. The government itself has targeted an allocation of Social Forestry of 12.7 million ha. Unfortunately, entering the fourth year, only 744 ha or 6% of the target has been realized. This is due to lack of budget availability.

In 2017, DBH DR disbursed to the Province amounted to Rp 699.5 billion. Of this amount, Central Kalimantan Province received the largest amount, with Rp 211.3 billion or 30% of the total, followed by East Kalimantan with Rp 157 billion and North Kalimantan with Rp 126.5 billion. The imbalance of the Social Forestry target and budget availability happened in East Kalimantan, with the social forestry target being as many as 600 thousand Ha requiring a budget of Rp 107,300 per Ha or about Rp 11-12 billion per year. In fact, the annual budget allocation is less than that amount. As a result, the realization of Social Forestry by 2017 only reached 102 thousand Ha.

Table 1. 2017-2018 DBH DR Budgets in 13 Provinces in Indonesia (millions)

Source: Presidential Regulation No. 97 of 2016 on the Details of FY2017 State Budget, Presidential Regulation No. 107 of 2017 on the Details of FY2018 State Budget

Through PMK No. 230 of 2017, local governments can use DBH DR to support social forestry (Article 2 letter b). Social forestry programs and activities explicitly contained in the Regulation of Director General of Fiscal Balance No. 1 of 2018 are programs for provincial DBH DR in the form of empowerment of local communities in forest and land rehabilitation activities including: (1). Social forestry preparation activities in the forms of community forests, village forests, community plantations, customary forests and partnerships; (2). Development of social forestry enterprises; (3). Handling of Conflict, Tenure Issues and Indigenous Forests; and (4). Coaching. Referring to these programs and activities, the province may propose draft activities and budgets/RKA DBH DR to support social forestry.

Table 2. Programs and Activities Utilizing Provincial DBH DR in Support of Social Forestry

Programs Activity Details
Empowerment of local communities in forest and land rehabilitation activities 1. Social forestry preparation activities in the forms of community forests, village forests, community plantations, customary forests and partnerships, through:

a. Operationalization of the Social Forestry Acceleration Working Group (Pokja PPS);

b. Site level socialization;

c. Facilitation of Proposals; and

d. Administrative and Technical Verification.

2. Development of social forestry enterprises, including:

a. Site level socialization;

b. Business development training;

c. Institutional building;

d. Forest and Land Rehabilitation (protection restoration and intercropping); and

e. Productive economic tools.

3. Handling of Conflict, Tenure Issues and Indigenous Forests, including:

a. Recording potential conflicts of tenure and customary forests;

b. Submitting and registering conflicts;

c. Mapping/assessment of tenurial conflict;

d. Facilitation/mediation of tenurial conflict;

e. Facilitating the acceleration of recognition of customary forests; and

f. Identification, inventory, verification and validation for customary forests.

4. Coaching, including:

a. Preparation of guidelines; and

b. Guidance on procedures.

Source: Annex of Perdirjen PK/1/2018

For regencies/cities, the use of residual DBH DR to support social forestry is not as explicit as with the province. The optimization of DBH DR can be done by following the guidance in Perdirjen PK/1/2018, which is to fund the management of Taman Hutan Raya (Tahura), control of forest and land fires, and tree planting. What needs to be considered by regencies/cities is the conformity of the programs and activities proposed in RKA DBH DR with applicable regulations.

Article 3 of PMK No. 230 of 2017 mentions that the residual DBH DR is conducted by the Regional Device Organization (OPD) appointed by the regent/mayor and may be proposed by the regional secretary. The use of DBH DR for social forestry can be carried out through the mechanism of assignment by the Governor, as set forth in Article 4 Paragraph (3): The Governor may assign the regent/mayor to implement DBH DR utilization activities through the co-administration mechanism in accordance with the provisions of law.

The Activities in Regency/City RKA DBH DR are as follows:

Table 3. Programs and Activities Utilizing Regency/City DBH DR

Programs Activity Details
Management of Forest Parks (Tahura) 1. Preparation of Long Term Management Plan

2. Document preparation

3. Preparation of Short Term Management Plan

4. Rehabilitation of Forest Parks (reforestation, tree maintenance, biodiversity enrichment, and implementation of soil and water conservation)

Prevention and mitigation of forest and land fires 1. Planning

2. Preventive activities

3. Mitigation activities

4. Post-fire handling activities

Planting trees on critical areas 1. Seedling

2. Planting

3. Maintenance

4. Construction of soil and water conservation facilities

Planting of bamboo on riverbanks, lake shores and water catchment areas, areas surrounding springs and ground water reservoirs 1. Planting bamboo on riverbanks;

2. Planting on lake shores and water catchment areas

3. Planting around springs and ground water reservoirs

Source: Annex of Annex of Perdirjen PK/1/2018

In an effort to accelerate the process of discussing RKA DBH DR, on 15 February 2018, the Ministry of Finance has submitted a letter to the Provincial/Regency/City Governments to convey the confirmation of the residual DBH DR with a statement no later than 8 March 2018. MoF, KLHK and MoHA would determine the amount of the remaining DBH DR on 13 March 2018, and the discussion of regional RKAs will be done on 21-23 March 2018. If the RKA has been approved by the discussion, then the region revises the operationalization of the regional budget. The implementation of activities can be done after the issuance of of SKPD Implementation Document A.

*Ramlan Nugraha, PATTIRO Project Officer

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PATTIRO maintains its position in the Global Top Think Tank Index

The Lauder Institute of the University of Pennsylvania has released the Global Top Think Tank Index Report 2017 on influential organizations on a global scale. PATTIRO, as a research and advocacy institution, has been able to maintain its position (34) for the category of Top Transparency and Good Governance Think Tanks out of 7,815 think tanks from all over the world.
“We are very grateful for this achievement, because it is not easy to maintain the position. The competition between think tanks is very strict. Comparing the 2016 and 2017 reports, there are some institutions having declining rankings, while others have significantly increased rankings,” said Maya Rostanty, PATTIRO Director.

The indicators for the rankings of the Global Top Think Tank Index are, among others, the reputation of research results, independent research products, ability to involve experts and reputable academics, as well as the ability to access and convince key decision makers and key figures in government to build cooperation. Others are the use of research products for the benefit of advocacy, impacts of research or programs undertaken for decision-makers and other policy-making actors, public involvement in research, reputation in the mass media, and the impact of programs being undertaken to the wider community. PATTIRO’s achievements in the Global Think Tank Index show the success of PATTIRO in terms of those indicators.

“This achievement will be our encouragement to continue to contribute actively in influencing the process of public policy formulation in Indonesia by conducting evidence-based advocacy, specifically in the three focus areas of PATTIRO, namely transparency, public financial management reform and public service accountability,” added Maya.
To find out more about the Global Top Think Tank Index Report 2017, download it below.

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Urgent, Establishment of Functional Position of Public Service Complaints Manager

The establishment of the functional position of public service complaints managers is felt to be urgent. This is because in general the management of public service complaints on government institutions, both at the central and regional levels, is still not conducted professionally. So far, activities related to complaints management are done only as an additional task, so that they are not optimal. The establishment of a functional position is expected to encourage complaints management officers to work full time, and be assured about their career path. Such was the opinion raised in the FGD held by PATTIRO on Tuesday, 6 February 2018 in Jakarta.

RI Ombudsman Commissioner Dadan S. Suharmawijaya stated that many parties think that the job of complaints management is only to receive complaints. This caused many parties to disagree with the establishment of the functional position of complaints managers, because it is considered to be simple work. “Whereas the complaints management officers can also do more advanced jobs, up to settling disputes,” said Dadan. A similar statement was also conveyed by M. Imanuddin, Deputy for Policy Innovation of KemenPAN-RB, namely that complaints managers not only receive complaints, but also could analyze problems, provide solutions and recommendations on the complaints.

“The complexity of the public service complaints management job can open the opportunity for the establishment of functional positions,” said Bejo Untung, PATTIRO Program Manager.

The Head of Facilitation of Complaints and Information Services of the Ministry of Home Affairs Handayani Ningrum remarked that currently complaints managers are being ‘exiled’, whereas according to her, complaints managers should be able to receive and process complaints or aspirations properly. “The person holding the position of complaints manager must be smart, quick thinking, and competent. The complaints manager should be able to become the agency’s mouthpiece, so they must have the necessary personal qualifications,” she said. Handayani further stated that she also strongly agrees with the formation of the functional position of the complaints manager.

The representative from Semarang City Office of Communication and Information Istiqomah said that complaints management in Semarang City was currently handled by a unit called the Center for Complaints Management (P3M). In 2017 there were about 6,000 complaints handled. She agreed about the necessity of a functional position for the management of complaints. “In our experience, every year, the position of administrator managing complaints is always changing. The administrator will be more focused if the position is set as functional position,” added Istiqomah.

University of Indonesia public administration expert Dr. Lina M. Jannah reminded, when proposing the functional position, it should not refer to just the activity, but also the ability of the position to resolve issues. “For the record, a complaint cannot be resolved alone, but must include a team. The functional position should be able to handle all twelve types of services. We also need to find out about possible overlapping of responsibilities with others,” she said.

The establishment of a complaints management unit at a service provider institution is an obligation as mandated by Law on Public Services Number 25 of 2009. The existence of the complaint management unit is inseparable from the public service. Through the means of complaints, the government knows what is desired by the community. “Complaints should dominate in the planning process. The content of the complaint is a good material for development planning,” said Imanuddin.

Field Findings of the Conditions of Complaints Management

On the same occasion, PATTIRO research results related to the condition of the management of complaints in several ministries and institutions were also presented. This research also explored data about experience of functional position formation done by the Directorate General of Fiscal Balance of the Ministry of Finance and Institution of State Administration.

PATTIRO researcher Wawanudin delivered some of his findings. First, most ministries and agencies already have special units for complaint management. In the Ministry of Health, for example, there is a complaints management unit located in the sub-section of public complaints. The number of complaints officers is generally sufficient with a division of tasks to handle call center, public services, and complaint application units. The complaints officer is recruited from an outsourcer called an agent. The contracted agent has experience in complaints management and is under the supervision of ASN. The recruitment of agents through third parties is repeated every year. The complaints management application in ministries and institutions are running independently, and most of them are not yet integrated with LAPOR! The trend or number of complaints coming into the ministry is about 90-100 complaints per day through various channels. Any incoming complaints are not directly answered because of cross-checking to the field. In some cases, complainants receive answers to their complaints after a one-month period.

Second, most of the informants mentioned that functional positions are necessary because the task of the complaints manager is not only to receive complaints, but also to analyze the complaint to become materials for policy. Through functional positions, there will be professionals who will strengthen the complaints management system. The establishment of functional positions is expected to have an impact on the level of satisfaction of public services, and will not have a significant impact on the increase in government budget.

Third, complaints management activities are encouraged to educate the public (creating demand). This effort is expected to increase public participation in delivering complaints. (RN)

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PATTIRO Holds Workshop on Program Planning to Kick Off New Program

In relation to corruption prevention efforts, the Government of Indonesia continues to promote bureaucratic reforms in the public sector, one of which is through the management of complaints. Currently the Government has developed a National Public Service Complaint Management System, known as LAPOR!SP4N, in order to improve the quality of public services such as health, education, road infrastructure, population administration, and social assistance. LAPOR!SP4N currently handles more than 10,000 complaints every month and seeks to respond and settle complaints from citizens within a five-day period.

Through complaints management, Ministries, Institutions and Local Governments are expected to develop better relationships and understand the needs of the community, and build public trust through inputs provided to improve transparency and accountability of public services. The complaints management system is also an effective means of increasing citizen participation in governance, and contributes significantly to the growth of responsible relations between the government and citizens.

In order to support the Government’s efforts in the management of complaints, PATTIRO, supported by CEGAH USAID, runs a 4-month program, developing an academic paper on the establishment of functional positions of public service complaints managers. The implementation of this program is carried out in support of the Ministry of Administrative and Bureaucracy Reform (KemenPAN-RB), the Ombudsman RI and the Presidential Staff Office (KSP) in implementing the LAPOR!SP4N development roadmap.

To initiate the implementation of the program and to prepare an activity plan, on December 15, 2017, PATTIRO held a Program Planning Workshop attended by USAID, KemenPAN-RB, Ombudsman RI and KSP. “The purpose of this activity is to equalize the understanding and perspective between PATTIRO, KemenPAN-RB, ORI and KSP, as well as other stakeholders, about the output to be generated, and share experiences of the creation of functional position of Central and Regional Financial Analysts conducted by Directorate General of Fiscal Balance, Ministry of Finance (DJPK Kemenkeu) as input in program planning,” said Bejo Untung, PATTIRO Program Manager.

“This academic paper will be the basis for the preparation of the Minister of Administrative and Bureaucratic Reform Regulation on functional positions of public service complaints managers,” added Bejo Untung.

In the discussion process, Ahsanul Minan from CEGAH USAID conveyed the need for the preparation of an Academic Paper on complaint management, based on the recommendations resulting from the evaluation of LAPOR!SP4N. “The review recommends that KemenPAN-RB creates a special unit that handles LAPOR!SP4N, including system management, coordination with Ministries and Agencies, monitoring the effectiveness of complaints management, training and technical support, sharing good practices of complaint management among government agencies, and reporting results regularly. The special unit should have sufficient authority for it,” said Minan.

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Citizen Voices, Community Solutions : Designing Better Transparency and Accountability Approaches to Improve Health

The Transparency for Development (T4D) study was designed to answer the question of whether a community-led transparency and accountability program can improve health outcomes and community empowerment, and, if so, how and in what contexts. To answer this question, researchers and civil society organization partners began by co-designing a program that would activate community participation to address myriad barriers to proper maternal and newborn care, with the ultimate goal of improving maternal and newborn health outcomes. This report presents the design of the program that was then implemented in 200 villages in Tanznia and Indonesia and studied using a mixed methods impact evaluation. In addition to detailing the program, the report outlines how we got there describing a number of principles that informed some distinguishing features of the program, as well as an iterative design process that defined other features through trial and error.

The program was designed to adhere to six principles: It was 1) co-designed with embedded and experienced in-country partners to be 2) health-focused rather than service delivery-focused, 3) locally relevant, 4) community-driven, 5) non-prescriptive, and 6) largely free of resources from outside the communities that received it. These design principles were defined by the researchers and partners seeking to use T4D to innovate in important ways that differed from the standard approaches commonly employed in transparency and accountability programs. First, the program was designed to mobilize citizens to solve health problems, rather than mobilizing them around a particular governance or service delivery problem. In doing so, the T4D program leaves open the possibility that communities might try to solve these problems by improving existing health services, self-help, or self-organizing or mobilizing other community members to increase the utilization of existing services.

Second, the T4D program leaves significant space for communities, rather than external experts or civil society organizations, to determine whom they will target with their actions (from frontline service providers to local politicians, to other community members, as well as regional or national politicians and health officials). It also allows communities to choose the nature of their actions, allowing them to educate, confront, or work with allies, or to take a different approach altogether. Finally, the program attempts to create space for communities to iterate and learn from their successful and less successful actions, in the hopes that iteration will improve their chances of achieving positive impact.

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Indonesia’s Village Law: enabler or constraint for more accountable governance?

Village underdevelopment is considered a major contributor to Indonesia’s high levels of inequality. Law No.6 / 2014 (‘Village Law’) on villages’ governance and finance is regarded as the most progressive policy in the history of local governance in Indonesia, and has great potential for rural development.

This study investigates the implementation of the Village Law, asking whether it is functioning as an enabler or a constraint for more accountable governance. Indonesian non-governmental organisation PATTIRO carried out the study and visited six villages, which were selected as examples of good practice in governance.

The study finds that, overall, the law both enables and constrains positive changes towards more accountable governance. It is an enabler in that its stipulations have generally encouraged some village reforms, compared with the previous law, and has helped to increase national and district funds going to villages.

But the law also constrains village governments from optimising their development programmes in various ways, including by imposing a complex reporting burden. It fails to define roles and responsibilities clearly and accurately, perpetuating ambiguities that impede better functioning and accountability.

Citizen participation within the framework of the law is also not optimum: first the law does not enable all village citizens to monitor village elections; second, there are restrictions on who can participate in village forums (Musdes); third, implementation of the law limits the authority of ‘the village’, subordinating it to district government for governance and finance.

Based on these findings, PATTIRO offered recommendations for different government authorities for strengthening the Village Law’s implementation and has created research uptake spaces to share knowledge and practical experience of implementing the Village Law.

To continue read our publication, please see below :

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Policy Paper | Considering the Revision of UU ASN and Its Impact on Merit System in Indonesia

Law No. 5 of 2014 on State Civil Apparatus (hereinafter UU ASN) has been in force since its enactment as law on 15 January 2014. The passing of this Law is part of the strategy of national bureaucratic reform, specifically in creating a system of State Civil Apparatus that is professional, free from political intervention, clean from corrupt, collusive and nepotistic practices, capable of implementing public service for the society, and capable of acting the role as the cement for national unity based on Pancasila and the 1945 Constitution.

While having been enacted three years ago, UU ASN has yet to be implemented effectively, though. One of the reasons is that the implementing regulations necessary for the law’s implementation have not been finished. Only two implementing regulations have been enacted, namely Government Regulation No. 70 of 2015 on the Insurance for Work Accidents and Death of ASN Employees, dated 16 September 2015, and Government Regulation No. 11 of 2017 on the Management of the Civil Service, dated 7 April 2017. Yet, the House of Representatives (DPR), through the invocation of its initiative right, has proposed to revise UU ASN.

In response to this, PATTIRO has formulated a Policy Paper focusing on two main points of the proposal to revise UU ASN as proposed by the DPR, namely the existence of the State Civil Apparatus Commission (KASN), and clarity of definition, fairness and legal certainty for Work Agreement Based Government Employees (PPPK), and the impact to the implementation of the merit system in Indonesia. The entire document can be read and downloaded below.

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Revision of UU ASN Considered to Benefit Few

jpnn.comJAKARTA – The State Civil Apparatus Law (UU ASN) is considered not appropriate to revise.

Other than being new, the government regulations that derive from this Law have not been published. From the 11 drafts of government regulations on state civil apparatus, only two have been enacted.

“We believe it’s too early to revise UU ASN. Especially as the Law has not been implemented. It’s funny that the Law has never been implemented, but it is to be revised,” said the Executive Director of PATTIRO, Maya Rostanty, in a discussion on the Revision of UU ASN in Hotel Ibis Tamarin, 2 August 2017.

Based on discussion with several parties, Maya continued, two groups have an interest in the revision of UU ASN.

The first group is the non-permanent (‘honorary’) employees and non-tenured (PTT) employees who demand to be given Civil Servant status. The second is the regional leaders, who are obstructed from the practice of trading of positions, due to the transparent system for the JPT (high leadership position).

“What is worse, the State Civil Apparatus Commission (KASN) is to be eliminated in the revised Law. This of course is a major obstacle to the merit system,” she said.

PATTIRO Program Manager Wawanudin added that to guard the implementation, an independent institution, namely the KASN, which is independent from the decision maker and the implementing organization, is required.

“KASN is an independent body, directly responsible to the president. Thus, the suggestion to eliminate KASN through the revision of UU ASN, and returning its authority to the Ministry of State Apparatus Empowerment and Bureaucratic Reform (KemenPAN-RB) is not appropriate. (esy/jpnn)


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PATTIRO Director: Revision of UU ASN is Premature

Metrotvnews.com, Jakarta:  Director of PATTIRO Maya Rostanty (Tanty) rejected the proposal to revise the State Civil Apparatus Law (UU ASN). Tanty considered the plan as premature, as the Law itself was only enacted in 2014.

“We believe that this proposal for revision is premature,” she asserted when visiting the MetroTV complex in Kedoya, West Jakarta, 22 August 2017.

Tanty explained that the DPR, as the initiator of the discourse should give some opportunity to the government to implement the Law, rather than revising it. Further, not all supporting government regulations have been finished.

“It is better if the supporting regulations (GRs) are published and the Law is implemented first. Otherwise, the revision should only be done after the implementation of the Law. It has not been implemented,” Tanty said.

The revision is also considered to be an obstacle to bureaucratic reform, which is one of the main programs of President Joko Widodo-Vice President Jusuf Kalla’s administration. Eradication of corruption, collusion, and nepotism in the bureaucracy will be negatively affected if the reform is derailed by regulations.

One significant point is the abolition of the KASN. In fact, the institution was formed to oversee the merit system. The merit system oversees ASN management policies based on qualifications, competencies and performance.

In addition, Tanty explained, that the DPR also focuses on the automatic appointment of honorary employees as civil servants. Such a concern from the DPR for the fate of these employees raises the suspicion that this issue has been politicized, with the political year coming soon.

Automatic appointment of honorary employees can also create a new burden for the government. “If the revision is accepted, it will increase the burden of state finances. It also hurts the merit system, (where) everyone has to participate in the selection,” said Tanty.

PATTIRO Program Manager Wawanudin also mentioned that in the revision, the abolition of the KASN would return the authority and function to KemenPAN-RB. At least, there are 19 articles to be deleted.

Wawan thinks it would be very bizarre if KemenPAN-RB oversees itself.

The supervisor, Wawan explained, should be independent and neutral to ensure the merit system is running well. Wawan is worried about the fate of the merit system when executed by elements who are also within the scope of ASN.




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The Map of Subsidized Fertilizer Problems in Indonesia

Indonesia has implemented a policy of subsidized fertilizers since the 1970s. This policy aims to ease the burden of farmers so that when they need fertilizer to crops, fertilizers are available at affordable prices.

There is the argument that, in the first use of fertilizer technology until recently recognized as the intensification of agricultural technology to increase food yield. Second, Indonesia’s farmers generally can not use technology because less fertilizer is able to buy fertilizer market rates. So the Indonesian government with an interest in food yield productivity gains for national food security, then choose the option to subsidize fertilizer prices for farmers.

In current practice, the procurement and distribution of subsidized fertilizer to use terms ditataniagakan highest retail price (HET). Determination HET done at authorized dealer (retailer) designated distributor. Subsidized fertilizer earmarked for agriculture related to food crop cultivation, horticulture, plantation, livestock forage, and fish and / or shrimp.

Target users are farmers subsidized fertilizer, planters, farmers who seek the most widespread land 2 (two) hectares each planting season per family farmers. As for fish farmers and / or shrimp widest one (1) hectare.

Although the provision of subsidized fertilizer program implementation mechanism has been set up, but there are still many problems. Research PATTIRO in 10 (ten) regional states there are problems in aspects of data collection, budgeting, delivery / distribution, and monitoring of the implementation of the subsidized fertilizer program period from 2009 to 2011.

In the aspect of data collection, evaluation Definitive Plan Needs Group (RDKK) is invalid, where there are bubbles (mark-up) land area and number of farmers. In the aspect of budgeting, audit findings were obtained by correcting the calculation of the amount of subsidy for fertilizer volume counted Delivery Oder (DO) which have not been distributed.

In addition, because there are costs that are not included in the calculation of the production component of Cost of Goods Sold (COGS) as basis of calculation of subsidy pupuk.Pada aspects of distribution / distribution, found sales of fertilizer at a price above the HET, selling fertilizer to farmers who do not RDKK listed, no installation of banners price announcements, distribution of fertilizer that does not comply with the DO, delay distribution, rarity, replacement packaging, hoarding, sales outside the distribution area, and there are retailers who are not authorized.

While related aspects of monitoring, Fertilizer and Pesticide Supervisory Commission (kppp) at the provincial and district oversight is not optimal. They are considered not fully understand their duties and functions, do not make a report monitoring, and lack of funds to conduct surveillance. []

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