Date: 3rd Feb 2012
Dear Puan Halimah bt Hassan, Ketua Pengarah, Jabatan Alam Sekitar,
I hope this email finds you well. Below you will find some general comments on the Detailed EIA (DEIA) for the Kuala Lumpur Outer Ring Road (KLORR) followed by more specific comments and criticisms. I hope that these will help facilitate a constructive decision by the DOE and its review panel.
In general, the DEIA was found to be lacking in a number of areas.
- In terms of overall approach, the DEIA broke from standard practice by failing to consider alternative project options to the KLORR, it only focuses on alignment options. An example of an alternative project option would be a public transportation system as well as alternative routes.
- It also appears that the Terms of Reference for the DEIA were not followed in a number of areas, including
i) assessing the compatibility of the highway with existing and future land-uses of the area;
ii) conducting consultation with the those both directly and indirectly affected by the project;
iii) assessing sediment yield to the Klang Gates Reservoir.
- Given the project’s focus is on a major infrastructural development, it is unacceptable that the DEIA made no reference to the National Physical Plan (NPP) which is the de facto ‘master plan’ for national infrastructural development. The lack of acknowledgement of the NPP and, in particular, its proposals for the Central Forest Spine habitat and the classification of much of the project area as an Environmentally Sensitive Area (ESA) Class I, is a major omission on the part of the DEIA consultants.
- The quality of maps provided in the DEIA were poor and were of very little help in assessing land-use.
- Far too much of the impact assessments offered are qualitative rather than quantitative, which suggests a lack of effort in foreseeing and projecting impacts. This does not bode well for the ability of the Project Proponent to control for risks, particularly in light of the presence of steep slopes and other geological risks.
- The KLORR route contravenes the National Physical Plan (NPP) by transgressing the Selangor State Park (an Environmentally Sensitive Area Class I). Incursion into the forest areas necessitates logging which contravenes the State Government’s policy of a moratorium on logging.
- The DEIA notes (7.2.10; 7.3.7) that there will be an impact on wildlife movement and roaming habitat of larger and medium mammal species. This contravenes the Selangor Menteri Besar’s stipulation that there be no such interference (DEIA Annex 1.1). The proposal for wildlife via-ducts has been presented in the DEIA absent of any consideration of their actual or potential effectiveness for the ecosystem in question. In general, conservation measures have not been proposed and evaluated according to effectiveness.
- The DEIA also appears to place undue reliance on the capacity of PERHILITAN and Forestry to control for poachers along the forested stretch of the highway. No indication has been given whether either of the two agencies have been consulted on this, nor where the funds and manpower will come from to address this.
- The NPP also upholds the formation of contiguous wildlife corridors in the Central Forest Spine (CFS) which includes this area.
- The Selangor State Planning Council has approved the national plan for a Central Forest Spine. JPBD has existing plans to implement the wildlife corridor linkages and the DEIA does not take this into account.
- As the DEIA notes, a number of the affected areas are habitats for plant species that are Critically Endangered, Endangered, and Vulnerable on the IUCN Red List.
The DEIA has also established the project area as a habitat for endangered fauna such as tigers and tapir. The National Tiger Action Plan 2008-2020 aims to double Malaysia’s tiger population to 1,000 by 2020. In line with this every effort should be taken to conserve both the tiger and the tapir (one of the former’s main prey species) and to avoid any disruption to their habitats.
- KLORR disrupts integrity of Klang Gates Quartz Ridge which the Selangor State Government plans to gazette as a national and international natural heritage site. The gazettement process has already been initiated and it is felt that a tunnel beneath the Quartz Ridge would present an unacceptable compromise of the Quart Ridge’s ecological and aesthetic values as well as geological integrity.
It is apparent that neither the Project Proponent nor the DEIA has attempted to assess what long-term effect vibrations caused by vehicles (including heavy vehicles) will have on the Quartz Ridge. The mitigation measures proposed for tunnelling appear far too vague and ad hoc (p. 7-4) since, as the DEIA suggests, the Project Proponent has no idea about the geological make-up of the ridge to the point where they intend to figure out the “actual depth of excavation, selection of support system as well as dosage of blasting” only after conducting pilot drilling.
This ad hoc method presents far too great a risk to the integrity of a site of such valuable heritage interest.
- The DEIA proposals for mitigating the geological risks of slope failure are too vague and hypothetical since report acknowledges that slope stability has yet to be tested (p. 7-3). Furthermore, since 18.7% of the road is deemed to be Class III or Class IV hillslope (p. 4-21) there are no definite plans proposed for dealing with these risks. Specific remediation measures for specific stretches should be proposed to deal with these zones rather than vague “maybes” (p. 7-3). This is all crucial given the history of slope failures in this region.
- The DEIA does not present a comprehensive or realistic assessment of the potential of KLORR to alleviate congestion. The implicit assumption of the DEIA/Project Proponent is that there will be total transference of non-local commuters to the KLORR system. It does not appear to state the toll rates that commuters will incur on KLORR, nor does it make any attempt at estimating whether the planned pricing structure will encourage or discourage commuters from continuing to use existing routes. As an example, despite the existence of toll highways connecting Puchong to the Federal Highway, the preference of many Puchong commuters is to use the free roadways in Subang Jaya/USJ, which leads to severe congestion in the latter areas.
- KLORR is not based upon a recent and substantive transportation assessment. The 1996 JICA Study is 15-years out of date. Its projections on economic impact of the KLORR need to be double-checked in light of subsequent developments. Even the national Malaysia Plans deal with 5 year periods of national development. The conclusions of the JICA study are being assumed to hold true over three times the period of the Malaysia Plans. In particular, the impact of the proposed Mass-Rapid Transit system needs to be considered, as well as the contribution of the existing LRT system and the proposed SUKE Expressway.
- Building works and operation of the KLORR present a threat to water quality and the quantity of water catchment at the Klang Gates reservoir and rivers crossing the route. Given the high density of consumption serviced by the reservoir, and the need to plan against dry weather and climate change, reduction in water catchment capacity is unacceptable.
- Public consultation on KLORR has been too limited. Town hall meetings were restricted to merely the northernmost and southernmost nodes of the highway with the total number of individuals comprising a few dozen from two kampungs. The total population directly or indirectly affected by KLORR’s construction and operation is obviously far more than this.
We note that surveys were conducted in a limited set of areas around the same nodes as well as Ampang. Surveys are very limited means of generating feedback on concerns since they only sample the issues specified by the surveyor or their client. They do not solicit opinions or detail beyond the extent of their survey. Surveys are also very limited in temporal value. They only measure an opinion at a given point in time. A single survey does not capture change in opinions over time or through exposure to new information.
Broader consultation with affected communities downstream from construction and transport impacts should have been carried out. This includes town hall meetings with residents in the greater Gombak, Ampang and Hulu Langat areas in accordance with the stipulation in the DEIA Terms of Reference that call for consultation with those “directly or indirectly affected by the project”.
Therefore, it is my view that for these reasons the DEIA should be rejected. An alternative route and alternative project options should be studied. My suggestion is to:
- Re-design the route to avoid incursions into Forest Reserves and the State Park, to align closer to the edges and buffer zones of the State Park in order to avoid the complications of going deeper into the forest (and the need for wildlife via-ducts etc.).
- There must be an updated feasibility and traffic assessment. The 1996 JICA Study predates even the LRT system. Therefore, the new study must take into consideration the LRT, MRT and SUKE Expressway.
- Instead of an elevated highway, the option for an underground highway – that avoids impacts on the forest and water catchment – should be explored. This could be a landmark highway whereby a project funded by a government prioritises the environment to construct a minimum impact and forest-friendly highway, which could win Malaysia international recognition.
YB Elizabeth Wong
EXCO for Tourism, Consumer Affairs and the Environment
Article Source http://elizabethwong.org/comments-to-doe-on-klorr-deia/