This review of the detailed EIA of one of the largest land reclamation projects in the country was prepared by the Penang Forum Steering Committee and concerned individuals.
1. Introduction to proposed land reclamation project at Tanjung Tokong – Its size, consequences and implications for all of Penang
Size of project – The coastal land reclamation of Sri Tanjung Pinang at Tanjung Tokong is of vital and critical significance to the people of Penang. The projected environmental and social impact of this colossal project is unprecedented in size and consequences. It necessitates the most critical and closest assessment and review to avoid or mitigate possible and probable negative and disastrous effects for all of Penang, both the island and the mainland. The total area to be reclaimed in STP1 and STP2 is more than 1000 acres plus an adjoining 131 acres at Gurney Drive.
The STP2 reclamation project will create an island(s) which is more than 85% of the size of Pulau Jerjak, the second largest island in Penang after Penang Island. It will permanently change the whole of the North Coast of Penang Island.
Only 25 per cent or 240 acres have been reclaimed so far in STP Phase 1, completed in 2006. The environmental impact of STP Phase 1 is self-evident to all Penangites. The sedimentation of Gurney Drive and the often foul smell at low tide, are the most visible adverse impacts. When a project of 240 acres along the coast of can have such an impact, what will a 891-acre project in the sea do to Penang. It is this environmental, social and economic impact that is the real concern about STP2
This review is in relation to Phase 2, the remaining 891 acres to be reclaimed. A project of such monumental proportion that would “forever alter the map of Penang’s coast” (Vol.1 ES-39 of DEIA Report) should have very clear and strong rationale as to why it is needed, what benefits (and costs) it will bring to the people of Penang.
STP2 when completed proposes to house 200,000 residents which, if achieved, would be about 13 per cent of Penang’s total population or close to 25 per cent of the Island’s population.
2. Some issues of concern in STP1 – What went wrong:
It should be noted that Phase 1 of the land reclamation for the entire 980 acres only had a Preliminary EIA, with NO public participation or input and was approved internally by the DOE. Given that the first phase has been completed and the developer wishes to start work on the next phase, it is timely for a review of the first phase to be conducted to establish if there are lessons to be learnt for the larger and potentially more problematical second phase. The review should be done by the Penang state DOE under the supervision of the State Environmental Committee with participation by relevant government departments and NGOs.
- Siltation and sedimentation along Gurney Drive
- Siltation effects at City Marina and possibility of Penang Port
- Wave pattern studies and modelling conducted have been dubious re: sedimentation and siltation
- Loss of fisheries resources and earnings to fishermen
- Siltation at the STP1 site itself causing run-off from drains to be trapped and stagnated
- Lack of monitoring by any independent body – only in-house monitoring and in-house data
As such, a review of STP1 by an independent review panel is both crucial and obligatory before an approval of STP2. The purpose of the review would be to establish:
a. Were the conditions set out in the preliminary EIA adequate?
b. Were there serious consequences of the reclamation work in Phase1 that were not anticipated or not mitigated?
c. Was the Environmental Management Plan (EMP) effective? Was the EMP implemented diligently?
e. Who/which agency, if any, conducted continuous monitoring ?
f. Are there lessons to be learnt that can be incorporated into the DEIA and an EMP for the coming phase?
3. The process of law
The Penang Island Structure 2020, gazetted in 2007, indicated approval in principle for a number of islands to be reclaimed. However, the number and shapes of these proposed islands have been changed continually in 2008, 2009a, 2009b, 2011 and 2012. Each of these revisions of land reclamation carries implications for the marine environment, our coastline and varying sedimentation and siltation problems.
Review Panel for the TOR for the DEIA – This panel was established by the Federal DOE for Detailed EIAs. The panel consisted of the relevant government departments and agencies of Penang as well as some representatives from universities. The panel was convened on 30 October 2012 by the DOE to look into the terms of reference for the Detailed EIA studies. One of the major concerns is based on what has happened on STP Phase 1: there is a greater need to ensure that all mitigation measures be taken to ensure that the adverse impact will not recur in Phase 2.
One item that was highlighted by the federal DOE is that the scale and size of the project meant that it falls under six prescribed activities such as coastal township, infrastructures besides coastal land reclamation. As such, this DEIA is for land reclamation only. Therefore there should be several more EIAs to be submitted. This should be strictly adhered to before approval to start work.
4. Non-independence of the DEIA
In the name of transparency and accountability, the DEIA should have been conducted by independent consultants rather than ones appointed by the project proponent. Even the peer review was by a foreign consultant employed by the proponent. He might not be fully cognisant of local fisheries resources and the livelihoods of the people affected.
For e.g. Volume 3 of the DEIA report, which carries a report of the public forum 2013, leaves out the fact that during the forum, the lead consultant for the hydraulic studies blamed the 2004 tsunami for the mud flats at Gurney Drive, while DID studies on Integrated Shoreline Management Plan of 2010 clearly attributed the sedimentation to STP1. The tsunami “explanation” was widely covered by the press but omitted in their report of the forum. The main Report Vol 2 is also dismissive of the destruction of fisheries resources and the livelihood of 470 fishermen saying this will be settled by the state(?) During the public forum, the same consultant asked fishermen whose livelihoods were threatened to “go and open seafood restaurants”.
5. Ad hoc expert panel for the review of the DEIA and public response
Given the size and scale of the total project and the fact that we have seen aspects of the DEIA that appear to both minimise and dismiss the adverse social, environmental, traffic and economic impacts, it would be necessary to have independent assessment by civil society and impartial experts to examine the DEIA.
In a DEIA, the customary practice is the formation of an ad hoc expert panel to review the EIA reports. It is not clear if an ad hoc expert panel will be invited to review the DEIA. We assume that the original TOR panel will be part of the ad hoc panel. They will be in the best position to judge whether the agreed TOR has been carried out in the DEIA (e.g. the TOR Panel requested an increase in the number of stations for marine biology sampling – this was not done). There is also a need to add some experts from the National Hydraulic Research Institute (Nahrim) who have experts in hydraulic modelling to evaluate the modelling studies. Additionally independent experts from civil society should be included in the review panel.
The Penang Forum would like to urge the organising of a public forum by the authorities, as with Penang Hill and the Porr, for a full and transparent review of these colossal threats to the integrity of our coastlines, our marine life, our traditional fishing villages and our entire environment as we know it.
Penang Forum Steering Committee and concerned citizens of Penang
27 March 2014