Feedback on DRSNPP 2030 (Penang Structural Plan Draft 2030) from TBRA

Persatuan Penduduk Tanjong Bunga Pulau Pinang (1469-05-3)

(Tanjong Bunga Residents’ Association Penang)

c/o No. 11, Jalan Oldham, Tanjung Bunga, 11200 Pulau Pinang

Email: Tanjongbunga@yahoo.com

19 Nov 2018

TUAN TPR HJ IDRIS BIN ABDUL RAHIM

Pengarah PLANMalaysia @ Pulau Pinang (JPBD),

Jabatan Perancang Bandar dan Desa Negeri Pulau Pinang,

Tingkat 57, Komtar,

10000, Pulau Pinang.

                                                                                                                     

Dear Sir,

RE: FEEDBACK (MAKLUMBALAS) ON THE DRSNPP 2030

FROM TANJUNG BUNGAH RESIDENTS ASSOCIATION (TBRA)

I provide this feedback on the DRSNPP 2030 on behalf of the Tanjung Bungah Residents’ Association (TBRA).

While this letter does not comprehensively address the errors and flaws in the DRSNPP 2030, we list our main concerns which lead us to the conclusion that: THE DRSNPP 2030 MUST GO BACK TO THE DRAWING BOARD AND BE THOROUGHLY REVISED, FOR ALL THE FOLLOWING REASONS.

1. WRONG PROJECTION OF POPULATION IN PENANG

The DRSNPP 2030 has been planned and designed based on a highly questionable average annual population growth rate of 2.52% (page A-5) for 2014 to 2030, even higher than Selangor’s average. No concrete analysis or explanation is given as to how this figure is arrived at.

In fact, the previous RSNPP 2020 projection of 1.9%, as per Department of Statistics Malaysia’s (DOSM) data, has continued to fall short year after year. The trend has been confined within a small margin of 0.9% to 1.5% (2014 and 2017), as crude birth rate has been decreasing and the crude death rate has been increasing in Penang.

Data from DOSM (in Nov 2016) showed that the annual population growth rate for the country decreasing from 1.8 per cent (2010) to 0.8 per cent (2040).

Hence, the growth rate figure of 2.52% for Penang in the DRSNPP 2030 is seriously questionable and unacceptable and has to be justified further, if it is to be relied on.

Data from the DOSM shows that Penang is projected to have a population of 1.98 million people in 2030 and not 2.45 million as projected in the DRSNPP.

We are concerned that the over-projection of population growth mainly serves to provide a justification for the sheer scale of proposed projects like the Penang Transport Master Plan (PTMP). The unrealistic projected ridership for the Penang LRT at 42 million per year (116,000 per day) during its first year of operations and the unrealistic projection of 300,000 population on the 3 proposed reclaimed islands appear to be justified using this flawed population projection. 

 

2. OPPOSED TO TANJUNG BUNGAH AREA CLASSIFIED AS MAIN DEVELOPMENT AREA (PEMBAGUNAN UTAMA)

In the 2020 RSNPP, the Tanjung Bungah-Telok Bahang area was classified as being in the secondary corridor (‘koridor pembangunan sekunder’), with only low-medium density development allowed (see DSU 5 L1). A density of 15 units per acre for general housing/low density housing of 6 units per acre was specified in the 2020 RSNPP.

However, in practice many developments of high density have been allowed in the Tanjung Bungah area, despite the concerns of some residential communities and TBRA, over what we believe to be violations of the RSNPP density limits. This has resulted in too many high-rise developments, much of which are not occupied and a scarring of the landscape in this tourist belt.

We are extremely concerned that in the new DRSNPP 2030, the Tanjung Bungah, Batu Ferringhi and Teluk Bahang areas (except for the ‘hutan simpan kekal’) are marked in Rajah 14, as ‘kawasan pembangunan keutamaan 1,’ similar to other areas in Penang which were in the primary corridor with no restrictions under the 2020 RSNPP.

We are aware that no density limits are specified in the DRSNPP 2030, but we are nevertheless concerned that the limits placed in the Tanjung Bungah-Teluk Bahang belt under the RSNPP 2020 have been completely removed.

• We are firmly opposed to high-density developments in the Tanjung-Bungah-Teluk Bahang area and stress that there is need in the DRSNPP to place restrictions on development in this area and to not remove the primary and secondary corridor classification which is present in the RSNPP 2020.

• We call the reinstatement of such classification and for the Tanjung Bungah-Teluk Bahang area to be under the secondary corridor classification, with limits to density as set out in the RSNPP 2020. There is no justification for the removal of such restrictions.

3. NEED FOR MORE PROTECTION OF HILL LANDS

We welcome the DSP 5.1.3 to enforce the guidelines for the protection and control of hill land cutting.

However, the previous RSNPP 2020 restricted development on hill sites at/above 76 meters OR at/above 25 gradient but the current DRSNPP 2030 only restricts development on hill sites at/above 76 meters AND at/above 25 gradient.

The word ‘AND’ effectively means that BOTH criteria must exist concurrently for this restriction to apply. We cannot allow the loosening of restrictions following the lessons from the Granito Landslide Tragedy of 2017 and the Bukit Kukus Landslide Tragedy of 2018.

• The DRSNPP 2030 must be amended to ensure that the word ‘dan’ (and) in clause L 5.1.3.1 be amended and substituted with the word ‘atau’ (or), to ensure that the restrictions are not weakened from the previous 2020 RSNPP. In other words, so long as the lands are above 76 m or at a 25 degree gradient, no development should be allowed.