How Should Provincial Water Resource Councils Be Established Under PERMENPU 3/2024?

1.0 Introduction and Regulatory Context

The Ministry of Public Works has introduced comprehensive guidelines for the establishment and operation of water resource governance bodies at sub-national levels through Peraturan Menteri Pekerjaan Umum Nomor 3 Tahun 2024 tentang Pedoman Pembentukan Dewan Sumber Daya Air Provinsi dan Kabupaten/Kota (Ministerial Regulation of Public Works No. 3/2024 on Guidelines for Establishing Provincial and District/City Water Resource Councils). This regulation represents a critical implementation mechanism for decentralized water governance in Indonesia, establishing institutional frameworks for coordinated water resource management at provincial and district/city levels. The regulation directly implements Article 65(10) of Law No. 17/2019 on Water Resources, as subsequently amended by Law No. 6/2023 on the Enactment of Government Regulation in Lieu of Law No. 2/2022 on Job Creation. The regulation enters into force effective from the date of promulgation and establishes detailed procedural requirements for council formation, member selection, organizational structure, and operational protocols.

The regulatory framework established by PERMENPU 3/2024 addresses persistent coordination challenges in Indonesia's water resource management system. Indonesia's water resources cross multiple administrative jurisdictions, involve competing sectoral interests ranging from agriculture and industry to municipal water supply and environmental conservation, and require integration of technical expertise with community stakeholder representation. Prior to this regulation, many provinces and districts lacked formalized coordination mechanisms, resulting in fragmented policy implementation, conflicting resource allocation decisions, and inadequate stakeholder participation in water governance. The regulation establishes Provincial Water Resource Councils (Dewan Sumber Daya Air Provinsi) and District/City Water Resource Councils (Dewan Sumber Daya Air Kabupaten/Kota) as non-structural coordinating institutions directly accountable to governors and district heads respectively. These councils are explicitly designed to integrate multi-sectoral interests, facilitate cross-jurisdictional coordination, and ensure stakeholder participation in water policy formulation and implementation oversight.

The regulation's legal foundation rests on a comprehensive hierarchy of Indonesian water governance law. The primary constitutional authority derives from Article 17(3) of the 1945 Constitution establishing ministerial authority, supplemented by Law No. 39/2008 on State Ministries (as amended by Law No. 61/2024) defining ministerial regulatory powers, and Law No. 17/2019 on Water Resources establishing substantive water management principles. The regulatory framework is further elaborated through Government Regulation No. 30/2024 on Water Resource Management and Presidential Regulation No. 37/2023 on National Water Resource Policy, which establish overarching policy frameworks that provincial and district councils must implement. Presidential Regulation No. 170/2024 on the Ministry of Public Works and Ministerial Regulation No. 1/2024 on the Ministry's organizational structure complete the institutional framework authorizing this regulatory instrument. This multi-tiered legal foundation ensures that council establishment procedures align with constitutional principles of ministerial authority, statutory water management requirements, and national policy priorities while enabling appropriate adaptation to local circumstances and stakeholder configurations.

Understanding PERMENPU 3/2024 requires recognizing its position within Indonesia's evolving water governance paradigm. The regulation operationalizes participatory governance principles by mandating balanced representation between government and non-government stakeholders, establishes accountability mechanisms through mandatory reporting requirements and performance monitoring protocols, and creates coordination pathways connecting national, provincial, district, and river basin level water management institutions. For provincial and district governments, this regulation establishes mandatory institutional development requirements that must be implemented regardless of local resource constraints or competing administrative priorities. For water resource stakeholders including farmers, industry representatives, environmental organizations, and indigenous communities, the regulation creates formal participation mechanisms with defined selection criteria and protected representation rights. For legal practitioners and policy analysts, the regulation presents complex interpretive questions regarding implementation timelines, member selection processes, decision-making protocols, and coordination with existing administrative structures that will require careful regulatory analysis and practical guidance.

2.0 Key Definitions and Scope

PERMENPU 3/2024 establishes precise technical definitions that govern interpretation and implementation of council establishment requirements. Article 1 provides comprehensive definitional framework covering fundamental water resource concepts, institutional structures, and governance mechanisms:

Pasal 1 (Key Definitions):
"Dalam Peraturan Menteri ini yang dimaksud dengan:
1. Sumber Daya Air adalah air, sumber air, dan daya air yang terkandung di dalamnya.
2. Air adalah semua air yang terdapat pada, di atas, ataupun di bawah permukaan tanah, termasuk dalam pengertian ini air permukaan, air tanah, air hujan, dan air laut yang berada di darat.
3. Wilayah Sungai adalah kesatuan wilayah pengelolaan Sumber Daya Air dalam satu atau lebih daerah aliran sungai dan/atau pulau-pulau kecil yang luasnya kurang dari atau sama dengan 2.000 (dua ribu) kilometer persegi."

[Translation: "In this Ministerial Regulation, what is meant by:
1. Water Resources means water, water sources, and the water power contained therein.
2. Water means all water found on, above, or below the ground surface, including in this definition surface water, groundwater, rainwater, and seawater located on land.
3. River Basin means a water resource management unit within one or more watershed areas and/or small islands with an area less than or equal to 2,000 (two thousand) square kilometers."]

The definition of "Wadah Koordinasi Pengelolaan Sumber Daya Air" (Water Resource Management Coordination Body) in Article 1(4) establishes the institutional nature of councils: "institusi tempat segenap pemilik kepentingan dalam bidang Sumber Daya Air melakukan koordinasi dalam rangka mengintegrasikan kepentingan berbagai sektor, wilayah, dan para pemilik kepentingan dalam bidang Sumber Daya Air" [an institution where all stakeholders in the field of Water Resources coordinate to integrate the interests of various sectors, regions, and stakeholders in Water Resources]. This definition emphasizes three critical characteristics: comprehensive stakeholder inclusion covering all water resource interest holders, coordination functionality focused on integration rather than hierarchical command, and multi-dimensional scope addressing sectoral, territorial, and stakeholder coordination simultaneously. The definitional framework establishes councils as coordination platforms rather than line management agencies, with authority derived from stakeholder consensus and policy influence rather than direct administrative control over water resources.

Article 1 continues with definitions establishing the policy framework governing council operations. "Kebijakan Nasional Sumber Daya Air" (National Water Resource Policy) is defined as "arah/tindakan yang diambil oleh Pemerintah untuk mencapai tujuan pengelolaan Sumber Daya Air dalam jangka waktu tertentu pada tingkat nasional" [direction/action taken by the Government to achieve water resource management objectives within a certain period at the national level]. This definition establishes mandatory alignment between council activities and national policy frameworks, ensuring that provincial and district coordination decisions support rather than contradict national water security priorities. The definition of "Pengelolaan Sumber Daya Air" (Water Resource Management) encompasses "upaya merencanakan, melaksanakan, memantau, dan mengevaluasi penyelenggaraan konservasi Sumber Daya Air, pendayagunaan Sumber Daya Air, dan pengendalian daya rusak air" [efforts to plan, implement, monitor, and evaluate the implementation of water resource conservation, water resource utilization, and control of destructive water forces], establishing the substantive scope of council coordination responsibilities across the full water management cycle from conservation through utilization to flood and erosion control.

The organizational definitions in Article 1 establish the specific institutions created by the regulation. "Dewan Sumber Daya Air Provinsi" (Provincial Water Resource Council) and "Dewan Sumber Daya Air Kabupaten/Kota" (District/City Water Resource Council) are defined as "wadah koordinasi pengelolaan Sumber Daya Air pada tingkat provinsi" and "tingkat kabupaten/kota" respectively [water resource management coordination bodies at the provincial level and district/city level]. These definitions establish parallel institutional structures at both governance levels, with functionally equivalent coordination mandates adapted to the respective territorial and administrative scope of provinces versus districts/cities. The definitions of "Unsur Pemerintah" (Government Elements) and "Unsur Nonpemerintah" (Non-Government Elements) establish the fundamental membership categories, with government elements defined as "perwakilan instansi pemerintah yang terkait dengan pengelolaan Sumber Daya Air" [representatives of government agencies related to water resource management] and non-government elements defined as "perwakilan organisasi/asosiasi masyarakat yang terkait dengan Sumber Daya Air" [representatives of community organizations/associations related to water resources]. This definitional distinction establishes the mandatory multi-stakeholder composition requirement that prevents councils from becoming exclusively governmental administrative organs.

The definitional framework establishes crucial operational concepts governing council functioning. "Indeks Ketahanan Air" (Water Security Index) is defined as "angka yang menunjukkan tingkat ketahanan air pada suatu wilayah administrasi pada waktu tertentu" [a number indicating the level of water security in an administrative region at a certain time], establishing councils' responsibility for evidence-based water security assessment and monitoring. "Sidang Pleno" (Plenary Session) is defined as the principal decision-making forum where councils conduct their coordination functions, with mandatory frequency requirements established in subsequent articles. The definition of "Sekretariat" (Secretariat) as the administrative support structure establishes the institutional infrastructure requirements for council operations, including staffing, budgeting, and administrative management functions essential for sustained coordination activities. Together, these definitions create a comprehensive conceptual framework enabling precise interpretation of the regulation's establishment procedures, organizational requirements, operational protocols, and coordination functions while ensuring consistent implementation across Indonesia's diverse provincial and district contexts.

3.0 Core Requirements and Provisions

The organizational framework established by PERMENPU 3/2024 creates parallel institutional structures at provincial and district/city levels with functionally equivalent coordination mandates. Articles 5-8 establish Provincial Water Resource Council requirements while Articles 9-12 establish District/City Council requirements using nearly identical structural specifications. This parallel construction enables consistent multi-level coordination while allowing appropriate adaptation to the differing territorial scope, administrative capacity, and stakeholder configurations at each governance level. The regulation mandates that councils be non-structural institutions, meaning they operate outside the formal administrative hierarchy while maintaining direct accountability to the highest regional executive authority. Provincial councils are accountable to governors while district/city councils are accountable to district heads/mayors, ensuring political legitimacy and administrative authority while preserving the coordinating rather than line-management character of council functions.

Article 6 establishes that Provincial Water Resource Councils have the task of "mengoordinasikan Pengelolaan Sumber Daya Air pada tingkat provinsi" [coordinating Water Resource Management at the provincial level]. This coordination task is operationalized through seven specific functions detailed in Article 8:

Pasal 8 (Provincial Council Functions):
"Dalam melaksanakan tugas sebagaimana dimaksud dalam Pasal 6, Dewan SDA Provinsi menyelenggarakan fungsi:
a. koordinasi dalam perumusan kebijakan Pengelolaan Sumber Daya Air provinsi;
b. koordinasi dalam penyusunan rancangan penetapan Wilayah Sungai serta perubahan penetapan Wilayah Sungai kewenangan provinsi;
c. koordinasi dalam perumusan rancangan pola Pengelolaan Sumber Daya Air pada Wilayah Sungai kewenangan provinsi;
d. koordinasi dalam perumusan rancangan rencana Pengelolaan Sumber Daya Air pada Wilayah Sungai kewenangan provinsi;
e. koordinasi dalam perumusan kebijakan pengelolaan sistem informasi hidrologi, hidrometeorologi, dan hidrogeologi pada tingkat provinsi;
f. koordinasi dan sinkronisasi dalam pemberian pertimbangan dan rekomendasi penanganan isu strategis bidang Sumber Daya Air; dan
g. koordinasi dengan Dewan SDA Nasional, Dewan SDA Kabupaten/Kota, dan Wadah Koordinasi Pengelolaan Sumber Daya Air pada tingkat Wilayah Sungai dalam Pengelolaan Sumber Daya Air."

[Translation: Functions include: (a) coordination in formulating provincial water resource management policy; (b) coordination in drafting river basin designation and changes to provincial-authority river basins; (c) coordination in formulating water resource management patterns for provincial-authority river basins; (d) coordination in formulating water resource management plans for provincial-authority river basins; (e) coordination in formulating hydrology, hydrometeorology, and hydrogeology information system management policy at provincial level; (f) coordination and synchronization in providing consideration and recommendations for handling strategic water resource issues; and (g) coordination with National, District/City Councils and River Basin-level coordination bodies.]

These seven functions establish a comprehensive coordination mandate covering policy formulation, river basin planning, technical information systems, strategic issue response, and multi-level institutional coordination. The functional framework emphasizes coordination and synchronization rather than direct decision-making authority, consistent with the non-structural character of councils. District/City Councils have functionally equivalent coordination mandates adapted to their territorial scope, with Article 12 establishing five parallel functions focused on district/city level policy coordination, river basin designation, information system management, strategic issue response, and multi-level coordination.

The organizational structure mandated by the regulation establishes a three-tier leadership configuration comprising a chairman (simultaneously serving as member), daily chairman (simultaneously serving as member), and general members. Article 13 specifies that Provincial Council chairmanship must be held by the governor, who may delegate authority to the regional secretary through formal delegation established by gubernatorial decree. This structural requirement ensures councils have the political authority and administrative access necessary for effective cross-sectoral coordination, as only the governor possesses sufficient hierarchical authority to compel cooperation from provincial agencies representing different ministerial sectors. The daily chairman must be the head of the provincial agency responsible for water resources (typically the provincial public works agency), providing technical expertise and administrative continuity for council operations. The district/city council structure mirrors this configuration with the district head/mayor as chairman and the head of the district/city water resource agency as daily chairman, as specified in Article 19.

Council membership requirements establish mandatory multi-stakeholder composition with balanced representation between government and non-government elements. Article 13(7)-(9) establish that members shall come from both government and non-government elements "atas dasar prinsip keterwakilan" [on the basis of representation principles], with membership from each category "dalam jumlah yang seimbang" [in balanced numbers]. When perfect balance cannot be achieved, government membership may exceed non-government membership, but the regulation establishes a clear preference for balanced composition. Articles 14 and 20 specify detailed membership composition requirements:

This comprehensive membership specification ensures representation of all major water resource stakeholders, preventing capture of councils by dominant water users while ensuring that subsistence farmers, indigenous communities, environmental organizations, and other vulnerable stakeholders have formal participation rights. The membership structure operationalizes integrated water resource management principles by bringing competing water users into a shared coordination forum where allocation conflicts can be resolved through deliberation rather than unilateral administrative decree or market competition.

Member tenure and turnover regulations establish institutional stability while enabling periodic renewal. Articles 15 and 21 specify that members serve five-year terms, with replacement procedures for mid-term departures due to resignation, death, or replacement by the organization represented. Non-government members may be dismissed for failure to perform duties due to permanent incapacity for at least one year or conviction for criminal offenses by final court judgment. These provisions balance tenure protection ensuring members can develop expertise and institutional relationships with accountability mechanisms preventing members from indefinitely occupying positions without active participation. The regulation requires that non-government member selection processes be conducted at least six months before the expiration of existing member terms (Articles 14(4) and 20(4)), ensuring continuity and preventing gaps in council operations during leadership transitions.

The tasks and authorities assigned to council leadership establish clear operational responsibilities. Article 16 specifies that provincial council chairmen have eleven tasks and authorities including establishing work plans, establishing session procedures, establishing decisions based on session results, establishing water security index calculation guidelines and the index itself, optimizing agency roles in implementing session recommendations, issuing written warnings to agencies not following recommendations, reporting to the governor, coordinating results reporting to governor with copies to national council and relevant districts, and issuing warnings to inactive members. Daily chairmen have six tasks and authorities including establishing secretariat organizational structure and working procedures, implementing cross-sectoral coordination and consultation, performing chairman duties when the chairman is unavailable, coordinating discussion of policies and programs, supervising secretariat performance, and preparing reports. General members have seven specific tasks focused on policy formulation, index development, river basin designation, information system policy, strategic issue recommendations, and multi-level coordination. District/city council leadership has parallel responsibilities adapted to local governance scope as specified in Article 22.

4.0 Implementation Framework and Compliance

The establishment procedures mandated by PERMENPU 3/2024 create a detailed roadmap for council formation distinguishing between initial establishment and subsequent membership renewal cycles. Chapter V (Articles 33-40) establishes comprehensive formation procedures including member selection criteria, selection mechanisms, and organizational establishment protocols. The regulation recognizes that initial council establishment presents different challenges than ongoing membership renewal, as initial formation requires creating selection infrastructure that can subsequently be institutionalized for future cycles. This two-phase approach enables provinces and districts to build institutional capacity through the establishment process while ensuring future renewals follow more streamlined procedures.

Member selection criteria establish minimum qualifications ensuring representatives possess appropriate expertise and organizational legitimacy. Article 33 specifies that government member nominees from provincial agencies must be officials at echelon II or III levels related to water resource management, while government nominees from district/city agencies within the province must be echelon II or III officials who manage water resources or are directly related to water resource management. This requirement ensures government representatives possess sufficient seniority and technical competence to participate meaningfully in policy coordination while maintaining connection to operational water management responsibilities. For non-government members, Article 33(2) establishes three mandatory criteria: nominees must be representatives proposed by organizations/associations of the types specified in Article 14(2); organizations/associations must be legally incorporated and registered with the provincial government and have been actively engaged in water resources for at least two years; and organizations/associations must be headquartered in the province concerned. These criteria balance organizational legitimacy requirements with accessibility, ensuring that emerging organizations can participate while preventing ad hoc groups lacking institutional capacity from occupying membership positions.

The initial council formation process utilizes a selection committee mechanism. Article 34 specifies that for the first period, selection of nominee members is conducted by a selection committee (tim pemilihan anggota) established by the governor. The selection committee must consist of representatives from agencies responsible for water resources, forestry, agriculture, environment, and provincial regional planning. This composition ensures the selection process itself involves multi-sectoral input rather than unilateral designation by the water resource agency alone, promoting legitimacy and stakeholder buy-in. The selection committee determines the number of members from government and non-government elements based on the balanced representation requirements in Article 13, ensuring the resulting council composition complies with regulatory requirements. Article 38 establishes parallel district/city council selection committee procedures with the committee established by the district head/mayor and comprising equivalent sectoral agency representatives at the local governance level.

Subsequent membership renewal cycles follow streamlined procedures. Article 35 specifies that when Provincial Council terms expire, subsequent selection of nominee members is conducted by the council secretariat rather than a special selection committee. The secretariat determines member numbers from government and non-government elements based on Article 13 requirements, effectively institutionalizing the selection infrastructure created during initial establishment. This transition from selection committee to secretariat-managed selection reflects the regulation's expectation that councils develop internal administrative capacity sufficient to manage their own renewal processes without requiring external facilitation. Article 39 establishes equivalent secretariat-managed renewal procedures for district/city councils, creating parallel processes at both governance levels. The regulation's specification that selection must occur at least six months before term expiration (Articles 14(4) and 20(4)) ensures adequate time for candidate identification, evaluation, and formalization without disrupting council operations.

The detailed member selection mechanisms are specified in regulatory annexes. Articles 36 and 40 note that "Mekanisme pemilihan anggota Dewan SDA Provinsi" and "Mekanisme pemilihan anggota Dewan SDA Kabupaten/Kota" [member selection mechanisms for Provincial and District/City Water Resource Councils] are contained in attachments that form an inseparable part of the ministerial regulation. These annexes presumably establish detailed procedures for nomination processes, evaluation criteria, decision-making protocols, and formalization procedures, though the specific content is not reproduced in the main regulatory text. This approach enables the regulation to establish mandatory selection requirements in the binding articles while providing detailed procedural guidance in technical annexes that can potentially be updated without amending the core regulation.

Operational procedures establish council working methods ensuring systematic coordination activity. Article 25 mandates that Provincial Councils conduct plenary sessions at least twice per year, chaired by the council chairman and attended by members. When the chairman is unavailable, the daily chairman presides. Plenary sessions may involve expert resources from government agencies, universities, non-governmental organizations, or relevant communities, enabling councils to access specialized technical expertise as needed for specific coordination challenges. Article 26 establishes that Provincial Councils must align their provincial water resource management policy development with National Water Resource Policy, ensuring multi-level policy coherence. Article 27 requires annual written reports on council task and function implementation to the governor with copies to the director general responsible for water resources at the national ministry, creating accountability mechanisms and enabling national oversight of decentralized coordination implementation. Articles 29-31 establish parallel operational procedures for district/city councils, including biannual plenary sessions, national policy alignment, and annual reporting requirements.

The secretariat structure provides essential administrative infrastructure supporting council operations. Article 17 mandates establishment of Provincial Council secretariats led by a secretariat head who must be a division head (kepala bidang) within the regional agency responsible for water resources. Secretariat responsibilities include supporting council task and function implementation (preparing meeting materials, draft work plans, draft session procedures, draft coordination results, draft decisions); conducting studies, surveys and inventories required by the council; involving experts needed by the council; managing secretariat administration; managing financial administration; assisting in report preparation; facilitating and organizing non-government member selection; and monitoring follow-up on council recommendations with results reported to the chairman. Article 18 specifies that secretariat organizational structure and working procedures are established by the daily chairman, enabling adaptation to local capacity and operational needs. Article 23 establishes parallel secretariat requirements for district/city councils with equivalent functional responsibilities and leadership specifications.

Coordination relationships establish councils' integration into Indonesia's multi-level water governance architecture. Article 41 specifies that working relationships among National Council, Provincial Councils, District/City Councils, and River Basin-level Coordination Bodies are coordinative and consultative in nature, covering cross-boundary, cross-interest, cross-sectoral, and/or national interest matters. Provincial and District/City Councils may request consideration from the National Council when implementing their coordination tasks, creating upward coordination pathways. This coordinative rather than hierarchical relationship structure reflects integrated water resource management principles emphasizing networked coordination across administrative and territorial boundaries rather than command-and-control hierarchies. The regulation implicitly establishes that councils must develop coordination protocols and communication mechanisms enabling systematic information exchange, joint problem-solving, and policy alignment across the national-provincial-district/city governance levels.

Funding provisions establish financial responsibility and authorized sources. Article 42 specifies that Provincial Council operational funding comes from the provincial regional budget allocated through either the regional planning agency or the water resource management agency, or other legitimate sources according to statutory provisions. District/City Council operational funding similarly comes from district/city regional budgets allocated through planning or water resource management agencies or other legitimate sources. These provisions establish mandatory funding obligations for provincial and district governments, preventing councils from becoming unfunded mandates without resources to conduct coordination activities. The specification of multiple potential budget sources (planning agency or water resource agency) provides implementation flexibility enabling provinces and districts to align council funding with their specific budgetary structures. The authorization of "other legitimate sources" potentially enables councils to access grants, technical assistance funding, or inter-governmental transfers, though such funding must comply with applicable financial regulations.

5.0 Practical Implications and Recommendations

PERMENPU 3/2024 creates comprehensive institutional development obligations for provincial and district governments throughout Indonesia. The regulation's mandatory language establishes that council formation is not optional but rather a binding requirement implementing Law No. 17/2019 on Water Resources. Provinces and districts must allocate administrative resources for council establishment including staff time for selection committee operations, financial resources for council and secretariat operations, and ongoing budgetary commitments for sustained coordination activities. The regulation provides no explicit implementation deadline, though the reference to implementing Law No. 17/2019 implies that councils should be established as expeditiously as feasible given resource constraints and administrative priorities. Article 43's transitional provision partially addresses implementation timeline ambiguity by specifying that until councils are formed, water resource coordination tasks at provincial or district levels are performed by the agencies responsible for water resource management, preventing governance gaps during the establishment period while implicitly establishing an expectation of eventual council formation.

For provinces and districts initiating council establishment, several practical implementation challenges require attention. First, determining appropriate member numbers and achieving balanced representation between government and non-government elements demands careful stakeholder mapping. The regulation's requirement that government and non-government elements be "dalam jumlah yang seimbang" [in balanced numbers] requires provinces and districts to identify the universe of potential non-government stakeholders, assess organizational capacity and legitimacy, and structure membership to achieve representation without creating councils so large that effective deliberation becomes impossible. Second, identifying qualified non-government organizations meeting the Article 33 criteria presents challenges in provinces or districts where water resource civil society organizations are underdeveloped. The requirement that organizations be legally incorporated, registered with provincial/district government, and actively engaged in water resources for at least two years may exclude emerging organizations or informal community groups, potentially limiting representation of marginalized stakeholders such as subsistence farmers or indigenous communities lacking formal organizational infrastructure.

Third, establishing secretariat infrastructure with adequate capacity presents resource challenges particularly for districts with limited administrative capacity. The requirement that secretariat heads be division heads (kepala bidang) from water resource agencies presumes districts have sufficiently developed water resource agencies with division-level positions and personnel available for secondment to secretariat duties. Districts with limited water resource administrative capacity may struggle to provide secretariat leadership with sufficient seniority, technical expertise, and available time to effectively support council operations. Fourth, ensuring meaningful participation from government members representing diverse sectoral agencies requires securing political commitment from agency heads to authorize staff participation and allocate time for council activities. Water resource coordination necessarily involves agencies whose primary missions emphasize sectoral objectives (agricultural productivity, industrial development, energy generation) that may conflict with integrated water management priorities, creating potential reluctance to engage in coordination processes that might constrain sectoral autonomy.

The member selection criteria in Articles 33 and 37 establish challenging qualification requirements that require careful interpretation. The specification that government members must be echelon II or III officials ensures senior representation but limits the available personnel pool and may create challenges when agencies lack personnel at these levels with water resource expertise. Provinces and districts should interpret this requirement flexibly to include officials whose organizational position is equivalent to echelon II or III even if formal echelon designations have been modified through administrative reforms. For non-government members, the requirement that organizations be legally incorporated and registered with provincial/district government for at least two years requires advance planning, as organizations wishing to participate must formalize legal status well before member selection processes commence. Provinces and districts should proactively conduct outreach to water user groups, environmental organizations, indigenous communities, and other stakeholder constituencies to encourage organizational formalization and registration, ensuring an adequate pool of qualified organizations when selection processes are initiated.

Operational sustainability presents long-term implementation challenges. The regulation's requirement for biannual plenary sessions establishes only minimum coordination frequency; effective integrated water resource management typically requires more frequent interaction including working group meetings, technical consultations, and field assessments. Councils must develop realistic work plans balancing coordination ambitions with member availability and secretariat capacity. The Article 42 funding provisions establishing provincial/district budget responsibility create recurring fiscal obligations that must compete with numerous other demands on limited regional budgets. Provincial and district governments should establish dedicated budget lines for council operations within annual budgets, protecting council funding from ad hoc cuts during budget negotiations. The specification that funding may come from planning agencies or water resource agencies provides flexibility but requires advance coordination between these agencies to determine funding responsibility and prevent bureaucratic disputes that could undermine council operations.

Coordination with national and river basin-level water governance institutions presents integration challenges. Article 41's specification of coordinative and consultative relationships requires developing practical coordination protocols, information exchange mechanisms, and joint problem-solving procedures enabling councils to effectively interact with National Council and river basin coordination bodies. The regulation establishes no detailed coordination procedures, leaving provinces, districts, and national authorities to develop these protocols through practice. Early establishment of information-sharing agreements, joint meeting schedules, and communication protocols will facilitate effective multi-level coordination. Provincial and district councils should proactively engage with National Council and relevant river basin coordination bodies during establishment phases, ensuring that local coordination structures align with and complement broader governance architectures rather than creating redundant or conflicting institutional arrangements.

The regulation's implications extend beyond administrative procedures to fundamental questions of water governance legitimacy and effectiveness. By mandating balanced multi-stakeholder composition including indigenous communities, subsistence farmers, environmental organizations, and other historically marginalized groups, PERMENPU 3/2024 creates opportunities for participatory water governance that transcends technocratic administration dominated by engineering agencies and commercial water users. However, the regulation provides limited guidance on ensuring that participation is substantive rather than tokenistic. Councils must develop deliberative practices ensuring non-government members have genuine influence over coordination outcomes rather than serving as passive attendees validating pre-determined decisions. This requires capacity building for non-government members on technical water management concepts, transparent information sharing on water resource status and management alternatives, and decision-making protocols that give appropriate weight to diverse stakeholder perspectives rather than privileging government or commercial user preferences.

PERMENPU 3/2024 represents significant progress in operationalizing participatory integrated water resource management in Indonesia. The regulation's detailed institutional design requirements, comprehensive stakeholder inclusion mandates, and integration into multi-level governance architectures create frameworks for water coordination that transcends fragmented sectoral administration. However, regulatory provisions alone cannot guarantee effective water governance. Implementation success depends on political commitment from governors and district heads to prioritize council establishment and ensure adequate resourcing, administrative capacity within water resource agencies to establish and support secretariats, civil society organizational development enabling qualified non-government participation, and sustained engagement by government and non-government stakeholders in coordination processes. Provinces, districts, water resource agencies, civil society organizations, and development partners should treat council establishment as priority institutional development work essential for sustainable and equitable water resource management in Indonesia's increasingly water-stressed environments.

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