Tuesday, August 01, 2017


Date:     31    July 2017

Jabatan Alam Sekitar,
Kementerian Sumber Asli & Alam Sekitar,
Aras1-4, Podium 2 &3 ,Wisma Sumber Asli,
No 25 , Persiaran Perdana , Presint 4

(u.p: Unit EIA- Urusetia EIA)


The Tanjung Bungah Residents’ Association (TBRA) represents residents in the Tanjung Bungah area.  

We are aware that over 400 residents living around Package 1 (also known as NCPR) and its vicinity, have also submitted their comments on the EIA and we too support them and incorporate the views herein. We also make additional observations which we hope will be considered and regarded very seriously.

We hereby provide our comments to the EIA in respect of the NCPR from Tanjung Bungah to Telok Bahang.

1.    No proper public consultations: Public perception survey flawed
The perception survey done by the EIA consultants is very seriously flawed.

Only 322 persons were involved in the survey in relation to Package 1, and this population sample used to study the acceptance of the project is extremely small and does not represent the majority of the residents who will be impacted by the road.

Those who live along the corridors of the road were not properly consulted at all. A more comprehensive survey ought to have been done, which should have comprised of mainly people living along the corridors of the road alignment.

Many persons we spoke to were not aware about the details of the proposed alignment of the road and the EIA that we viewed is also not clear on the exact details in this regard.

This clearly shows that proper public consultations should have been carried out, with details provided, especially to those will be adversely affected particularly from noise and air pollution in addition the loss of vista.

Consequently, based on such a small sample size and the lack of more comprehensive consultations, we are unable to accept the EIA conclusion that 69% of the persons surveyed agree with the proposed road.

This figure is misleading due to the small sample size as well as the lack of consultation of people who will be most affected by the road alignment.

The survey is indeed seriously flawed and many who live along the NCPR alignment and its corridors are not agreeable to the project. This is evidenced by the 400 plus signatures collected in a very short timeframe among residents living in the vicinity of Package 1 who have objected to the road.

Hence, the EIA conclusion that 69% of the persons consulted in Package 1 are agreeable to the project is grossly misleading and should not be basis for approving the EIA.
2.    ‘Saving’ 14 minutes of time travel is no justification for the proposed road; no proper cost-benefit analysis done

The NCPR will be 10.53 km, (with 8.255 km at grade and 2.275 km which is elevated), with a dual two lane carriageway involving 4 lanes.

According to a speech by the Chief Minister of Penang in 2011, the NCPR is estimated to cost RM 518 million. (https://www.penang.gov.my/dmedia/879-penang-investment-seminar). 

This was the estimate in 2011 and is the cost of construction only. If the cost of land acquisition is taken into account, according to reliable sources, the NCPR is expected to cost RM 1 billion.  This cost does not include the money spent on conducting feasibility studies for the road which is many more million ringgit.

At page 4.10, table 4.12, the EIA claims that “the travel time from Tanjung Bungah to Teluk Bahang using the existing road ranges from 20-23 minutes” and that the “proposed highway will reduce journey time to 9 minutes with vehicles able to travel at an average speed of 70 km/hr.”

This means there will be a ‘saving’ at best of 14 minutes of the time travelled between Tanjung Bungah to Teluk Bahang. 

Spending such a huge amount of public resources to ‘save’ 14 minutes of time travelled is a colossal waste of public resources and cannot be justified economically, environmentally and socially.

On the other hand, the costs involved especially to the thousands of people living along the road alignment, as well as to the environment, and the cost borne by the State for the project (which will be borne by the people of Penang), is much more immense and significant. Surely there can be alternative solutions at much less the cost which have not at all be considered in the case of Package 1.

The EIA ought to have done a proper cost-benefit analysis done to justify the need for the road, but it has neglected to do so. What has been provided is only an economic valuation in relation to the environmental services involved. This is grossly insufficient.

The EIA claims that the ‘no-build’ option is not an option (at page 4.10) as “…it will further aggravate the traffic congestion…”. This is in reference to the Penang Transport Master Plan (PTMP), 2013-2030 as a whole, and is not specific to the road projects. The PTMP has many components and is not confined to the road projects.

Hence, the need for Package 1 is not justified adequately or effectively and represents another flaw in the EIA.

Cheaper options such as improving public transport and alternative modes of transport as well as upgrading existing roads should have been properly considered, as part of the ‘no-build’ option, instead of just claiming that the ‘no-build’ option is not an option.
In fact, the proposed NCPR will not solve the traffic congestion in Tanjung Bungah and is likely to aggravate it, which is contrary to the purported claim of easing traffic congestion. This is the case as the road ends abruptly in Lembah Permai. (See point below.)

3.    Proposed road will not solve traffic congestion in Tanjung Bungah

To make matters worse, the proposed road ends abruptly in Lembah Permai. Where the traffic will be diverted to, is not discussed at all, which means all the vehicles will end in a bottleneck in Tanjung Bungah, hence not solving the daily congestion at peak hours already confronting commuters and people living along existing roads.

Hence, the claim in the EIA that this proposed road “will address the traffic congestion in Penang” is not true at all.

In this regard, the EIA fails to demonstrate how the project will fulfil an existing need. 

4.   Failure to assess impacts of noise mitigation measures  

The EIA recognises at page 7.7 (executive summary) that the following communities will be affected by noise and vibration such as Leader Garden, Surin Condo, Taman Tanjung Bungah, Waterfront Condo, Coastal Tower, Desa Mar Vista Apartment (in Tanjung Bungah) and others in Batu Ferringhi.

Further, in section 8.70 (page 8.32), the EIA states that “in the context of the proposed roads….moderate to high noise reduction performance would be required of the barriers…such that the recommended noise criteria could be met.” Section 8.71,  describes some options and says that “…it was noted that for typically high-rise building in close  proximity to the highways, it may require up to category 3 (semi closure structures) or 4 (full enclosures) in order to mitigate the traffic noise at these sensitive locations (especially at locations with quite ambient noise).”

The locations requiring noise barriers are listed in Table 8.7 which in Package 1 include Taman Leader Condominium, Jalan Chee Seng 8, Taman Tanjung Bungah, Jalan Chee Seng, Surin Condominimum, Coastal Tower, Desa Mar Vista Apartment, Berverly Hills, Shamrock Beach, Sri Sayang Service Apartment, Ferringhi Delima Condominium, and Kg. Batu Ferringhi.

Given the nature of the noise barriers described in section 8.71 which requires semi-closed and fully-closed structures, the EIA fails to assess the impacts of these noise barriers on the quality of life of especially of those residents living in the high-rise condos and apartments described above.

This in our view, is a major omission, as there is no proper assessment of how residents will be impacted by unhealthy noise levels from the elevated sections of the proposed road and negative impacts from the appearance of concrete walls and structures impairing their vistas.

In fact, in section 7.44 (page 7.7), the EIA states that “residents in the high rise building will no longer see clear sky but in place, an elevated road passing near their homes and change (to the) visual aesthetics of the area.” This relates to the impairment from the elevated highway itself but there is no consideration of the impact on the visual aesthetics by the noise barriers themselves.

Such mitigation measures will definitely be unacceptable to the people residing along these concrete noise barrier structures.

5.    Impacts of air pollution not adequately considered

In relation to air pollution, Table 7.14 refers to the maximum incremental concentration of carbon monoxide, nitrogen oxide and particulate matters.

It also states in section 7.200 that “the predicted 1 hour maximum concentration for Package 1 is less than 133.1 µg/m3   for particulate matters. What this means is unclear as would this be 100 µg/m3 or 10 µg/m3?  We are advised by experts that an incremental concentration increase of even 1 µg/m3 would be associated with significant health impacts, including increased risk of premature mortality.

Hence, the EIA does not provide the information needed to properly assess the impact on public health of the project’s impact on air quality.

The impact on public health is critical. However, the information is lacking in this regard in the EIA and is another major omission.

6.   Development on sensitive hill-land not justified

The EIA reveals that about 46% of the proposed road will be on terrain with a higher than 25 degree slope. Slopes above 25 degrees are well known to be ‘sensitive hill lands’ and should not be used for the proposed road.

In fact, the Penang Structure Plan 2020 generally prohibits hill land development except for very limited and justifiable exceptions, which in the case of this road, does not appear to be justifiable.

In section 7.10, the EIA states that it is “imperative… that huge cuttings of hill sides should be minimised which will introduce disturbance to the landscape…”. At section 7.16, it further states that “initial cuttings involve very steep slopes …” in the Tanjung Bungah area and that “this will require substantial slope treatment or mitigation measures against future instability or localised failures.”

It is clear from the above that the risks are high from the proposed road which can lead to landscape disturbances and instability of slopes.

Mitigation measures are suggested but whether they will indeed prevent the occurrence of slope failures, landslides and landslips cannot be guaranteed. 

Previous cases of slope failures and landslides are many in Malaysia on major highways such as the North-South Expressway, (one being near Guar Tempurung in 2004), the PLUS Expressway at Bukit-Lanjan (2003), the Gerik-Jeli East-West Highway and the Karak Highway to name just a few.   

Previous studies in Malaysia have shown that most landslides are man-made slopes and are mainly due to design deficiencies and poor maintenance.

The effect and impact of slope failures, landslides and landslips on the communities living along the road corridors has not been considered and is also a serious omission.    

7.    Impact of immense cuttings of waste not properly assessed

Given the nature of the terrain involved in Package 1, the EIA in section 7.9 states that extensive cuttings will be involved in Package 1, involving about 10.6 million cubic metres of cuts. 

In section 7.12 the EIA states that “the transportation of the cart away will itself present massive logistical problems.” Further, in relation to Teluk Bahang, it states that “the formation of the slope will require removal of earth and rocks/boulders that may require blasting”.
The issue of how and where to dispose 10 million cubic meters of cuttings is significant environmental problem. The EIA has failed to address the disposal of this vast amount of cut material also presents a social problem to the residents in the vicinity of such earthworks. This represents yet another serious flaw in the EIA.

8.   Destruction of forests in water catchment areas and highlands

The EIA also shows that about 3.34 ha (about 8.3 acres) of forests will be affected by the proposed road as it passes through the Teluk Bahang Forest Reserve and the Bukit Kerajaan Forest Reserve, which include water catchment areas and highland forests.

Allowing the NCPR to invade such environmentally sensitive areas is too much of a price to pay for its so-called ‘benefit’.  

9.    Loss of valuable recreation space and green lung

As pointed out by the objections raised by over 400 residents living along the NCPR and its vicinity, the tree lined existing road, hills and waterfall along the proposed alignment at Leader Garden, Surin Condominium and other condos nearby are the last remaining green lungs in the area for many in the Tanjung Bungah area in its surroundings.

At least a 100 people, if not more, use the place for daily walks & exercise, enjoying its tranquillity, beauty and serenity.  The proposed road will irreparably change this space that has become a very popular public recreation area into a major highway that will completely transform and destroy our peace and ambience.

This fact about the recreational use of this area is no-where mentioned in the EIA and is a major omission.

Clearly, the so-called ‘benefit’ of saving a few minutes is far outweighed by the massive negative impacts the proposed road will have on our lives, our communities, our well-being and our environment.

In this regard, we appeal to the DOE to not approve the EIA for the NCPR for the reasons mentioned above.

We sincerely hope that our comments will be seriously taken into account.
Thank you.

Meena Raman

Tanjung Bungah Residents Association

No comments: