THIS IS THE PRESS STATEMENT RELEASED ON THE NORTH COASTAL PAIRED ROAD AT THE PRESS CONFERENCE ON 3 SEPT AT THE TANJUNG BUNGAH MARKET.
Date: 3 September 2017
PRESS
STATEMENT
SAVING
14 MINUTES OF TIME AT COST OF RM 1 BILLION IS NO JUSTIFICATION FOR TANJUNG BUNGAH-TELOK
BAHANG COASTAL ROAD – SAYS TBRA
The Tanjung Bungah Residents’ Association
(TBRA),which represents residents in the Tanjung Bungah area, appeals to the
Penang Chief Minister to scrap the proposed construction of the North Coastal
Paired Road (NCPR) from Tanjung Bungah to Telok Bahang.
The TBRA makes this call after studying the
Environmental Impact Assessment (EIA) for the road. In our comments on the EIA which
were submitted to the Department of Environment (DOE) on the 31 July 17, we
called on the DOE not to approve the EIA.
The comments were also forwarded to the Chief Minister on the 21st
of August 17.
Among the reasons for the call to scrap the
project include the following:
1. ‘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 long, (with
8.255 km at grade and 2.275 km which is elevated), with a dual two lane
carriageway involving 4 lanes.
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.
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.
The
EIA ought to have done a proper cost-benefit analysis to justify the need for
the road, but it has neglected to do so.
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.
2. Proposed
road will not solve traffic congestion in Tanjung Bungah
In fact, the 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. 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, 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.
Further,
the EIA reveals that there will be 10
interchanges between Batu Ferringhi and Tanjong Bungah. That is far too
many for the supposed intention of the road to “address the traffic congestion”.
3. 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 the NCPR. 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 NCPR who have objected to the road.
4. Failure
to assess impacts of noise mitigation measures
The EIA recognises that many communities along
the NCPR will be affected by noise and vibration.
The locations requiring noise barriers (listed
in Table 8.7) 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 the EIA, what is needed are 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.
There
is also 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 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, the EIA
(in Table 7.14) refers to the maximum incremental concentration of carbon
monoxide, nitrogen oxide and particulate matters.
It also states that “the predicted 1
hour maximum concentration …is less than 133.1 µg/m3 for
particulate matters.” What this means is unclear as this could 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. The EIA does not
provide the information needed to properly assess the impact on public health
of the project’s impact on air quality.
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.
It
is clear from the EIA 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 studies in Malaysia have shown that
most landslides are in 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
The EIA states that extensive cuttings will
be involved where there will be about
10.6 million cubic metres of cuts. The
EIA has failed to address the disposal
of this vast amount of cut material which also presents a major problem to
the residents in the vicinity of such earthworks.
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
Objections have been raised by residents
living along the NCPR and its vicinity, where 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 tranquility, 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 ambiance.
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 have appealed to the DOE
to not approve the EIA for the NCPR for the reasons mentioned above and also
reiterate out call to the Chief Minister to scrap the NCPR.
Meenakshi Raman
Chairperson,
Tanjung
Bungah Residents Association
Phone:
012-4300042
