PLEASE FIND BELOW THE TBRA COMMENTS SUBMITTED
TO THE DEPARTMENT OF ENVIRONMENT ON 31 JULY 2017 ON THE ENVIRONMENTAL IMPACT
ASSESSMENT OF THE NORTH COAST PAIRED ROAD (NCPR) FROM TELUK BAHANG TO TANJUNG
BUNGAH
Date:
31 July 2017
KETUA PENGARAH
Jabatan Alam Sekitar,
Kementerian Sumber Asli & Alam
Sekitar,
Aras1-4, Podium 2 &3 ,Wisma Sumber
Asli,
No 25 , Persiaran Perdana , Presint 4
62574 PUTRAJAYA.
(u.p:
Unit EIA- Urusetia EIA)
COMMENTS
RE: ENVIRONMENTAL IMPACT ASSESSMENT FOR PROPOSED CONSTRUCTION OF PACKAGE 1 (WHICH
IS THE NORTH COASTAL PAIRED ROAD) FROM TANJUNG BUNGAH TO TELOK BAHANG
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.
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
Chairperson,
Tanjung
Bungah Residents Association
