Abstract

This contribution will discuss a narrow approach of integration, which is the concept of internal integration, being one of the starting points for designing domestic environmental legislation. We will start from a theoretical point of view in order to provide some main insights about internal integration of environmental law. On this basis we will examine what options might be suggested to the Indonesian legislator in the process of improving its environmental legislation. The contribution is structured as follows: Section 2 will discuss theoretical considerations on the integration of environmental law. The focus will be on polluting activities. After integration, two other challenging topics of environmental policy will be discussed, which are (1) the choice and mix of instruments and (2) the design and functioning of the administrative organization. It will be argued that these two topics should be related to the concept of integration of environmental law, and therefore these three basic concepts must be approached in a balanced way in designing environmental legislation. Section 3 will discuss some instruments for internal integration in greater depth, with close attention to the integrated permit and the alternative approach by general rules. Section 4 will examine the command and control provisions of the Indonesian Environmental Management Act 1997, in order to investigate what suggestions may be made in respect of the theoretical considerations in the previous sections. Section 5 will provide a conclusion.

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