85% or 100%: The SPARING Data Completeness Rule Operators Miss

If you run a wastewater plant in one of Indonesia’s 12 mandatory SPARING industries, you have probably hunted for the exact SPARING data completeness percentage your system must hit. You might have read PermenLHK P.93/2018 and its P.80/2019 amendment cover to cover looking for that number. You didn’t find it. It isn’t there.

The minimum uptime percentage that determines whether your daily SPARING data actually counts does not come from the SPARING regulation at all. It comes from a completely different rulebook: PROPER 2025 (PermenLH/BPLH No. 7/2025). This distinction matters. Confuse the two, and you will chase the wrong compliance target while completely misunderstanding what happens when your data logger goes dark.

Where the Data Completeness Numbers Actually Come From

PermenLHK P.93/2018 governs how continuous wastewater monitoring systems operate in Indonesia. It tells you to report to KLHK’s data center once every hour. It explains what happens if the system breaks down beyond a certain threshold. It outlines the notification procedure for extended outages. But nowhere does it say: “your system must achieve X% uptime per day.”

PP 22/2021 takes the exact same approach. It mandates continuous automated wastewater monitoring but kicks the technical specifics down to ministerial regulations. You won’t find a percentage target there either.

The 85% number that compliance officers constantly stress over lives inside the PROPER 2025 criteria. PermenLH/BPLH No. 7/2025 states that a daily SPARING reading is valid only if the system captured at least 85% of the expected hourly measurements for that day. In real life, that means you need 20 or more hours of data out of 24. Fall below that line, and the entire day is thrown out.

This is a massive difference. The SPARING regulations tell you how to report. PROPER tells you how much data qualifies as a valid report. Stop looking for the 85% threshold in P.93 or P.80. They never wrote it there.

PROPER 2025 Rules for Daily Validity and Full Reporting

PROPER forces you to clear two separate thresholds for SPARING data. You have to meet both simultaneously.

First threshold: 85% daily validity. Each day needs at least 85% of its hourly readings captured for that day’s average to count. If a sensor drops offline for five hours on a Tuesday, you only have 19 out of 24 readings. That is 79%. The entire day gets flagged as invalid.

Second threshold: 100% reporting compliance. PROPER calculates reporting compliance by dividing your valid daily data submitted to KLHK by the total number of days you were supposed to submit data. If you want a BLUE rating, that ratio must be 100%. Not 99%. Not just most days. Every single day you were obligated to report must have a valid submission.

There is a third dimension here. Even if your data arrives on time every day, at least 95% of those valid daily averages per parameter must meet the actual effluent standard. This quality threshold stacks on top of the completeness check.

Fail the reporting completeness requirement, and you automatically get a RED rating. In September 2025, Indonesia’s Deputy Minister of Environment made it clear: companies that stay RED after guidance will face administrative, civil, and potentially criminal sanctions. Out of 5,476 companies assessed between 2023 and 2024, 1,313 got slapped with a RED rating.

Framework	Jurisdiction	Medium	Minimum Data Capture	Notes
PROPER 2025 (PermenLH 7/2025)	Indonesia	Wastewater (SPARING)	85% per day, 100% reporting	85% = daily validity; 100% = BLUE rating threshold
EU AAQD 2024/2881	European Union	Ambient air	90%	Fixed measurement stations; EEA accepts 75% for assessment
US EPA 40 CFR Part 58	United States	Ambient air (PM2.5)	75%	Completeness goal for 3-year design value

The EU and EPA benchmarks apply to ambient air, not wastewater. I included them just for context. Indonesia’s SPARING requirement under PROPER is vastly stricter in one critical way: even if your daily data clears the 85% bar, your reporting obligation to KLHK remains absolute.

What Happens During a Three-Day Outage

PermenLHK P.93/2018 Article 8(5) draws a hard line at 72 consecutive hours. If a SPARING system stays offline for more than three days in a row, you have to report the outage to the local regent or mayor, the provincial environmental agency, and KLHK within 48 hours.

Separately, Article 8(1) sets a different trap. If your system’s downtime exceeds 5% of your average monitoring over the previous month, you have to switch to manual sampling. This is not a data completeness target. It is a fallback mechanism. Hitting that 5% triggers your duty to do manual monitoring. It is not a compliance grade.

P.93/2018 won’t throw you in jail just for having missing data. But unreported downtime and persistent data gaps feed directly into your PROPER evaluation. A pattern of incomplete submissions guarantees a RED rating. And that RED rating is exactly what triggers the legal consequences the Deputy Minister warned about.

How to Stop Losing Data

Data gaps in SPARING systems usually stem from four predictable failures.

Sensor fouling. Biofilm, sludge, and mineral scale physically block the sensor face. A pH electrode covered in slime responds slowly or just stops reading. You need scheduled cleaning cycles, anti-fouling mechanisms, and wiper-equipped sensor housings to mitigate this. The goal is keeping the sensor reading accurately without waiting for it to fail completely.

Cellular communication failures. SPARING data travels from your logger to KLHK’s server over standard GSM or LTE networks. Network congestion, dead SIM cards, bad signal, or carrier outages will kill your transmission. Dual-SIM configurations and high-gain external antennas help. You also need an offline sensor detection system that texts your operations team the minute a connection drops.

Power outages. Remote industrial sites and regions with unstable grids suffer constant blackouts. If you don’t have backup power, everything goes dark at once. Size a UPS or solar backup to run the entire monitoring chain through short outages.

Scheduled maintenance. Calibration, cleaning, and parts replacement force you to take instruments offline. Maintenance is necessary. But doing it blindly is reckless. Schedule maintenance during hours when it won’t impact your 85% daily threshold, notify the authorities if required, and meticulously log every minute of planned downtime.

Store-and-Forward Architecture Saves You

There is a massive difference between “data was not transmitted” and “data was never recorded.” A network failure doesn’t have to cause a data gap if your logger can store readings locally and push them when the cell signal recovers.

This is the store-and-forward pattern. The data logger continuously saves sensor measurements to its internal memory, ignoring the dead network. When the LTE link reconnects, the logger dumps the backlog to the server chronologically. The regulator gets the data late, but they get it intact. Complete data submitted with a delay is fundamentally different from missing data.

The GEOVOS 1000 data logger we use in Fortuna Argatech’s SPARING systems packs 8 GB of local storage and HSDPA/LTE connectivity. That local buffer swallows data through brutal communication outages without losing a single reading. How long it buffers depends on your parameter count and logging interval. You should verify this during commissioning based on your actual site setup.

Store-and-forward won’t fix everything. A total power failure that kills the logger still creates a real gap. A broken sensor generating null values cannot be fixed by buffering. But this architecture completely neutralizes the communication layer, which is where most data loss actually happens.

Documenting Gaps for the Auditors

When a gap inevitably happens, your documentation is the only thing standing between an explainable event and a failed PROPER assessment.

Every time data goes missing, your team must log the exact start and end times, the root cause, the corrective action, and the exact minute the system recovered. This log is your proof during an audit that you managed the failure instead of ignoring it.

Unlike the US EPA, Indonesia lacks a standard set of quality flag codes for SPARING data. You have to build your own. Mark readings as VALID, INVALID, MISSING, or MAINTENANCE in your local database. It makes audit preparation painless and gives you a defensible trail.

Never fill SPARING data gaps with fake interpolated numbers. Statistical imputation is fine for internal trend analysis. But submitting fabricated data to the KLHK portal as if you actually measured it creates a compliance and legal nightmare far worse than just reporting a gap honestly.

Fortuna Argatech designs SPARING systems that manage structured data across the entire monitoring chain. From sensor-level anti-fouling to GEOVOS 1000 local storage to dashboard-level gap flagging, the hardware is built to keep data complete. If your facility needs to evaluate its SPARING data completeness posture or plan a system upgrade, contact our engineering team.

Sources

• PermenLHK P.93/2018 on Continuous Online Wastewater Monitoring (SPARING). BPK JDIH
• PermenLHK P.80/2019, Amendment to P.93/2018. BPK JDIH
• PP 22/2021 on Environmental Protection and Management. BPK JDIH
• PermenLH/BPLH No. 7/2025 on PROPER. ecobiz.asia PDF
• EU Ambient Air Quality Directive 2024/2881. EUR-Lex
• US EPA 40 CFR Part 58, Appendix A. eCFR
• Katadata: KLH Akan Beri Sanksi ke Perusahaan yang Tetap Berperingkat PROPER Merah (Sept 2025). Katadata