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
Jabatan
Perancang Bandar dan Desa Negeri Pulau Pinang,
Tingkat
57, Komtar,
10000,
Pulau Pinang.
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.
- 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.
- 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.
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.
- Further, in reference to L5.1.3.1 (at page C5-4), more clarity is needed on what is meant by “Garispanduan Digunapakai oleh Pihak Berkuasa Negeri”. Do these guidelines refer to the ‘Garispanduan kawasan berisiko’? There is need to clarify and explain what the guidelines are.
- We are concerned about whether these guidelines also include the existing Guidelines for ‘Special Projects’ (Projek Istimewa), which have become highly controversial as exemplified by the case of Sunway City project in Sungei Ara which is being challenged by residents who are affected by the Sunway project. (This case is currently being heard by the Court of Appeal). The ‘Special Projects’ guidelines as interpreted by the authorities currently are a loop hole to allow for developments on lands above 76 m or 25 degree gradient, based on the 1996 Master Plan or Pelan Dasar.
- In this regard, the ‘Special Project’ guidelines should no longer be applicable under the 2030 RSPP, as all efforts must be made to prevent any more loopholes that allow for developments on lands exceeding 76 m or slopes with 25 degree gradient and lands protected under the Land Conservation Act 1960 (Akta Pemeliharaan Tanah, 1960). This must be made clear and explicit in the DRSNPP 2030.
- In addition, we would like to see the gazetting of all hill-lands above 76 m as well as those will 25 degree gradient and which are sensitive areas from the perspective of the ecology and the environment as hill land or environmentally sensitive areas. Such a policy existed in the 2020 RSNPP (see DK 3) but is missing from the proposed DRSNPP 2030. The policy in the RSNPP 2020 reads as follows: “Mewartakan semua kawasan bukit yang sensitive dari segi ekologi dan alam sekitar sebagai bukit/kawasan alam semulajadi.” This policy has to be reinstated, with further improvements to cover lands above 76 m and slopes with 25 degree gradient.
- Furthermore, we propose that there be an explicit policy to prohibit the excision of lands which have been gazetted as hill-lands under the Land Conservation Act 1960. Otherwise, as was the case in the Sunway City project, the hill-land status of the land was removed by the State Authority in 2011, although the land was under the Land Conservation Act for a private housing project, which was more than 76 m involving 25 degree slope gradient.
- TAKE INTO ACCOUNT VULNERABILITY OF PENANG ISLAND TO CLIMATE CHANGE RISKS
Under
the DSP 5.1.4, we welcome the policy to ensure that all land use
planning and development take into account ‘risiko bencana’ or
disaster risks.
However,
the implementation measures (‘langkah-langkah pelaksanaan’) to be
taken are inadequate, as all that is proposed is to plan and develop
a land-use plan towards a resilient city and to prepare a disaster
risk study (‘kajian risiko bencana’) (L.5.1.4.1)
and
to encourage design, building methods and use of materials which are
durable to withstand disaster risks (L.5.1.4.2).
While
these measures are important, they are insufficient.
Moreover,
while L.5.1.4.1
proposes
the development of a land use plan towards a resilient city, some of
the mega projects being proposed on the DRSNPP 2030 under the PTMP
have been proposed for implementation (such as the reclamation of the
3 islands in the South of the Island and the proposed paired roads
under the PTMP etc.) without any assessment of whether they
contribute to or undermine the State from being climate resilient.
Clearly, this approach puts
the cart before the horse
as such mega developments compromise the resilience of the State to
disasters and climate change impacts.
- There is therefore a need to urgently review and assess all the proposed mega projects under the PTMP as to whether and how they take into account disaster risks and contribute to climate resilience and not gazette them under the proposed DRSNPP 2030.
In
addition, the Penang 2030’s fourth theme, “Invest
in the Built Environment to improve societal resilience”
is also not forthcoming in the DRSNPP 2030 as it does not include any
climate change adaptation plan for the State.
In
Malaysia’s latest National Communications to the United Nations
Climate Change Convention (UNFCCC) Secretariat of October 2018, the
following issues are key that must be taken into account under the
DSP 5.1.3-
- The 2030 projected average temperature rise in Peninsular Malaysia is set to be between 0.6 to 0.9 degree C, while the average annual rainfall is set to rise between 1% to 6 % (from 1,998 mm to 2,663 mm) and the projected range of maximum sea level rise for Penang is projected at 1.16 meters to1.45 meters (see Figure 4.6, pg 95 of NC3).
- Given this scenario, a State Adaptation Plan is urgent and vital and must be included as a key recommendation. The implications of such climate vulnerabilities must be taken into account in all existing and future developments in Penang.
- Furthermore, DRSNPP 2030 does not even address the need to safeguard Penang’s food security that would be threatened by climate change. In short, the document fails to deliberate how to make Penang climate smart and climate proof and simply ignores the urgent need for climate adaptation.
Penang
is no stranger to extreme rainfall which causes a myriad of problems
such as flash floods and landslides, resulting in historical floods
in November 2017. However, the DRSNPP 2030 fails to provide a
comprehensive plan to reduce flood risks despite the extensive
damages and losses due these occasions.
- Even though disaster risk areas were mentioned in the document, the accompanying map (Rajah 4, page C1-12) omits key flooding hotspots and landslide risk areas which may give the false perception that Penang is not as climate vulnerable than it really is. This needs to be corrected.
- There is also a need to identify the areas prone and vulnerable to landslides. This has to be shown in the DRSNPP.
- THE PROJECTION ON FUTURE LAND AND RESOURCE USE DOES NOT CONSIDER FUTURE TRENDS
Commercial
floor space in Penang is already in oversupply from 2010 to 2014 and
the projection of additional new commercial floor space in DRSNPP
2030 continues to rise. Selangor, which is significantly more robust
economically with a larger land bank and a bigger population than
Penang, projects
5,000 m.p. (meter2)
commercial floor space per 1000 population by 2035. By comparison,
Penang aims to achieve 12,989 m.p. by 2030 in the DRSNPP 2030 –
more than twice that of Selangor’s – based on conventional
projection approaches.
The
DRSNPP 2030 has failed
to produce a landuse plan which is realistic, sustainable and
future-proof,
as it does not consider future and modern technology that would yield
greater efficiencies and inevitably affect the demands of commercial
building space, commuting trends and housing needs. As a result,
Penang will fail to tap into the current trends to attract the best
talents from the digital economy and knowledge industry.
- THE CURRENT PTMP IS STILL A PROPOSAL TO BE APPROVED AND SHOULD NOT BE GAZETTED AS THE MAIN GUIDELINE FOR TRANSPORTATION IN THE RSNPP 2030
According
to DSP
1.1.3
of the DRSNPP 2030, the PTMP (Pelan
Induk Pengangkutan Pulau Pinang)
would become the foundational reference for Penang’s transportation
development up to 2030. Penang
already has 2 to 3 times the road length per capita compared to
Singapore (a country with one of the most efficient mobility
network). Yet,
the DRSNPP 2030 is dominated by a network of highways and roads,
sprawling over hill slopes, boring through hills and tunneling
undersea.
This
PTMP allocates more for highways and roads (8 projects concentrated
on Penang island only) than for public transportation (3 to 4
projects). How is this consistent with the plan to increase the
public transport modal share to 40% by 2030 when the new roads and
highways would only encourage more private cars to be on the road, in
a country where there are no policies to deter people from buying
cars or disincentives for using private cars?
- THE DRSNPP 2030 AIMS TO REDUCE CARBON EMISSION THROUGH GREEN TECHNOLOGY BUT THEN EMPHASIZES ROAD AND HIGHWAY CONSTRUCTIONS
The
transportation sector in Malaysia contributes as high as 22.9% of
carbon emission and as it stands, and Malaysia has the third highest
car ownership in the world at 93% of households owning a car. As it
is, Penang charted a 1.13 million car ownership in 2017, the fourth
highest in Malaysia, only 27,000 cars less than Selangor’s figure
(Selangor
is 8 times the size of Penang),
and this number of car ownership in Penang is anticipated to
increase.
The
DRSNPP 2030 absurdly does not even mention any plan of transition
towards electric vehicles. Nor does it talk much about intensifying
the usage of public transportation and non-motorized transportation
modes, thus ignoring current world trends towards sustainable
transportation.
- THE LAND RECLAMATION FINANCING MODEL FOR THE PTMP MUST BE THOROUGHLY REVIEWED
The
three man-made islands to finance the PTMP must be scrutinized as it
assumes that the Penang state government will be able to sell the
reclaimed land to finance part of the PTMP components. Has this
financial model considered the market volatility which will impact
land sale and the subsequent funding required to support the high
cost of operation and maintenance expenditures to upkeep the
infrastructure? The state government must commission an independent
comparative financial analysis of the various modes of public
transport systems and the need for it before making such major
decisions that have huge and long-term financial implications.
- LAND RECLAMATION PROJECTS DIMINISH EXISTING VALUES THAT SHOULD BE CONSERVED
While
Penang is already currently undertaking 760 acres of land reclamation
at Sri Tanjung Pinang 2 and 131 acres at Gurney Wharf, the DRSNPP
2030 is proposing up to a further 3,178.5 acres of land reclamation –
excluding the three man-made islands at the south of Penang island,
which is at 4,500 acres (equivalent to the size of Johore’s Forest
City). These proposed reclamation projects will destroy Penang’s
marine ecosystem, which include the second largest seagrass meadow in
Peninsular Malaysia (Middle Bank), the livelihood of fishermen and
cause disruption to the natural hydrological flow of the coastal
areas (which causes coastal erosion and accretion).
Damage
to these natural resources and coastal environment is irreversible
and brings about long-term negative ramifications that are often very
expensive to address when problems eventually arise, such as
siltation of port facilities.
Reclaiming
land also diverts and diminishes the comparative value of the
existing land in Seberang Perai which could have otherwise receive
more investment prospects for proper infill redevelopment. Such
redevelopment would better benefit the surrounding existing
population who require an economic boost from an inclusive
regeneration.
The
Penang 2030 vision that “The Future of Penang is in Seberang Perai”
is not reflected at all in the DRSNPP2030, in terms of any major
infrastructure development in Seberang Perai, nor is there any
explanation on how to achieve that vision.
- THE INVITATION FOR PARTICIPATION BY NGOs AND CIVIL SOCIETY AT LARGE MUST BE INCLUDED AT EVERY STAGE OF THE RSNPP
The
call for continuous commitment by all relevant government agencies as
well as NGOs and civil society is lauded. This clarion call, clearly
being critical to ensure effective management and monitoring to
achieve the desired outcomes cannot be overly emphasized. However,
that invitation for participation by the NGOs and the civil society
at large is mainly limited to during the planning stage.
After
that, they are excluded in the subsequent review and monitoring
stages as can be seen from the proposed Implementation and Monitoring
Committee (IMC) set-up; which contradicts the spirit of Local Agenda
21 and the SDG Goal 16 for promoting inclusive societies. This is
most unfortunate as their exclusion runs contrary the clarion call
above.
- CONCLUSION
The
DRSNPP lacks substance, is based on fictitious population
projections, and ignores important global trends in moving toward
greater landuse efficiencies and environmental sustainability. It is
a highly flawed plan which will take Penang along a dangerous path to
an unsustainable future.
We
urge the authorities to go back to the drawing board and thoroughly
revise the DRSNPP 2030 in order to come up with a realistic plan for
the next 12 years in Penang.
Sincerely,
Name:
Ms. Meenakshi Raman
IC
No: 580707055018
Mobile
phone: 012-4300042
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