PERMENPUPR 20/2021: Regulation of Special Function Buildings in Indonesia

Peraturan Menteri Pekerjaan Umum dan Perumahan Rakyat Nomor 20 Tahun 2021 tentang Bangunan Gedung Fungsi Khusus ("PERMENPUPR 20/2021") establishes the regulatory framework for special function buildings—structures with unique design requirements, specialized uses, or critical public functions that demand heightened technical standards beyond conventional buildings. Published on April 1, 2021, in Berita Negara Nomor 312, this 102-page regulation addresses towers, stadiums, industrial facilities, transportation terminals, and other specialized structures.

Definition and Scope of Special Function Buildings

PERMENPUPR 20/2021 defines "Bangunan Gedung Fungsi Khusus" as buildings that:
1. Serve specific functions requiring specialized technical design
2. Exceed conventional height, span, or structural complexity thresholds
3. House critical public services or infrastructure
4. Involve unique operational risks or safety considerations

Categories of special function buildings include:
- Towers and High-Rise Structures: Communication towers, observation platforms, skyscrapers above 100 meters
- Large-Span Buildings: Stadiums, exhibition halls, aircraft hangars, convention centers
- Industrial Facilities: Factories with hazardous materials, power plants, refineries
- Transportation Infrastructure: Airport terminals, train stations, ports, intermodal hubs
- Critical Public Facilities: Hospitals, emergency operation centers, data centers

Enhanced Design and Safety Requirements

The regulation mandates stricter standards for special function buildings:

Structural Design:
- Performance-based seismic design for critical facilities
- Wind load analysis for high-rise and large-span structures
- Progressive collapse analysis for structures housing large assemblies
- Specialized foundation design for unusual loads or soil conditions

Fire Safety and Evacuation:
- Advanced fire suppression systems (sprinklers, gas suppression, foam systems)
- Multiple egress routes with protected stairwells
- Emergency elevator systems for high-rise buildings
- Smoke control and ventilation systems
- Fire command centers with real-time monitoring

Accessibility and Universal Design:
- Barrier-free access throughout the facility
- Accessible evacuation routes for persons with disabilities
- Assistive technologies (tactile paving, audible signals, accessible restrooms)

Environmental Performance:
- Energy efficiency targets specific to building function
- Waste management systems for specialized operations
- Water conservation measures
- Green building certification encouraged for new construction

Permitting and Approval Process

PERMENPUPR 20/2021 establishes a rigorous approval process for special function buildings:

1. Preliminary Consultation: Project proponents must consult with the Ministry of PUPR or designated provincial authorities to confirm special function classification
2. Design Review: Detailed technical review of architectural, structural, MEP (mechanical, electrical, plumbing), and fire safety drawings by certified reviewers
3. Expert Panel Assessment: For highly complex projects, an independent expert panel evaluates design adequacy
4. Construction Permit (IMB Khusus): Issuance of special building permits with conditions specific to the project
5. Staged Inspections: Mandatory inspections at foundation, structural frame, and final completion stages
6. Commissioning: Functional testing of all systems before occupancy
7. Certificate of Function (SLF Khusus): Issuance of special function certificates confirming compliance with regulatory standards

Operational and Maintenance Requirements

Post-construction, special function buildings face ongoing obligations:

Periodic Inspections: Mandatory structural and systems inspections every 1-5 years depending on building type and risk level

Maintenance Standards: Documented maintenance programs for critical systems (elevators, fire suppression, emergency power, HVAC)

Emergency Preparedness: Regular evacuation drills, emergency response plans, and coordination with local fire/emergency services

Modification Approvals: Any alterations to structure or systems require prior approval to ensure continued compliance

Implications for Indonesia's Infrastructure Development

Indonesia's infrastructure boom—including new airports (Kertajati, Yogyakarta International), stadiums (Jakarta International Stadium), and industrial estates—makes PERMENPUPR 20/2021 increasingly relevant. The regulation ensures that:

1. Public Safety: Rigorous standards protect occupants and surrounding communities from structural failure, fire, or industrial accidents
2. International Competitiveness: Alignment with international building codes (IBC, Eurocode) facilitates foreign investment and technology transfer
3. Disaster Resilience: Enhanced seismic and wind design requirements improve infrastructure survivability in Indonesia's earthquake-prone and cyclone-affected regions
4. Sustainable Development: Environmental performance requirements support Indonesia's climate commitments and green economy transition
5. Quality Assurance: Multi-stage review and inspection processes reduce construction defects and premature failures

Challenges and Recommendations

Implementation of PERMENPUPR 20/2021 faces several challenges:

Technical Capacity: Limited numbers of certified design reviewers and inspectors with specialized expertise in unique building types

Cost Implications: Enhanced standards increase construction costs, potentially deterring private sector projects

Regulatory Coordination: Special function buildings often require permits from multiple agencies (aviation authorities for airports, environmental agencies for industrial facilities), creating coordination complexity

Enforcement: Ensuring ongoing compliance with maintenance and inspection requirements demands sustained regulatory oversight

To address these challenges, the Ministry of PUPR should: (1) expand training programs for specialized building professionals; (2) provide financial incentives for compliance with advanced standards; (3) establish one-stop service centers for multi-agency permits; and (4) deploy digital monitoring systems for post-occupancy compliance tracking.

Conclusion

PERMENPUPR 20/2021 establishes a comprehensive regulatory framework for Indonesia's most complex and critical buildings. By applying heightened technical standards, rigorous approval processes, and ongoing oversight, the regulation aims to ensure that special function buildings serve their intended purposes safely, efficiently, and sustainably. As Indonesia continues to develop world-class infrastructure—from international airports to industrial zones—PERMENPUPR 20/2021 provides the legal foundation for excellence in design, construction, and operation of these vital assets.

Sumber Hukum: PERMENPUPR 20/2021 di BPK

Peraturan Terkait: UU 28/2002 (Bangunan Gedung), PP 16/2021 (Penyelenggaraan Bangunan Gedung)

Sektor: Building Regulation, Infrastructure, Construction

Status Regulasi: Aktif

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