Penang Forum assembled a team of 31 professionals that included 20 contributors with PhD and Master’s degrees to review the environmental impact assessment (EIA) on phase one of the Pan Island Link highway (PIL1).
We have submitted the review to the Department of the Environment, and given copies to the minister of energy, science, technology, environment and climate change and the Penang chief minister.
Our conclusion is that the EIA is fundamentally flawed and should be rejected or completely redone for the following reasons:
1. It does not fulfil a stipulation of the Environment Quality Act 1974 that requires alternative solutions to be studied or described to justify that the project will result in the least environmental impact. In other words, viable alternative proposals for cheaper, faster, more environmentally sustainable and less destructive solutions to tackle transport mobility and traffic congestion have not been considered or evaluated.
2. A proper cost-benefit analysis has not been conducted taking into account present and future costs and externalities including economic, environmental, social, health and other costs.
3. The EIA study has failed to justify the need to for the PIL1 because its own findings reveal that by 2030 (between five and seven years after project completion) the highway will reach congestion level. In other words, the PIL1 is not a medium-term, let alone a long-term, solution to the problem it sets out to resolve.
4. The report’s pledge of originality is discredited by incidences of plagiarism where data and information lifted verbatim from Penang Monthly has not been acknowledged.
5. The EIA has not adequately addressed significant costs and externalities of the project.
a. Health costs – the impact of air and noise pollution to thousands of school children close to the highway has not been investigated. The background and predicted values of air pollutants are underestimated and unrealistic.
b. Social costs – disruption to communities in sensitive receptor areas particularly in two of the most used and important parks in Penang island (the Youth Park and the Sungai Ara Linear Park) has not been adequately addressed. Members of affected communities from schools, residential areas, religious institutions and heritage sites have complained that they were not informed or their concerns seriously considered. A proper social impact assessment covering representative samples of affected groups is missing.
c. Ecological costs – soil erosion, loss of mature trees, landslides and flooding that will result from hill-cutting have been underplayed. The EIA recommends standard mitigation measures. But the track record of monitoring and enforcement by government authorities is extremely poor, as shown by the serious environmental degradation from road and residential construction projects in Paya Terubong and Tanjong Bungah.
d. Safety costs – The EIA highlights geological and geotechnical risks of tunnelling through fractured rocks and fault zones, rating the impact as medium to high risk. Of particular concern is the tunnel and viaduct construction about 350 metres from the Air Itam Dam (capacity 2.5 million litres) on one side and the historic Kek Lok Si Temple on the other, near fault lines. Yet there are no detailed geological and hydrogeological investigations to quantify the risk and safety factors.
e. Information on the amount of explosives to be used, location of storage, transport and operational risks through densely populated areas, workers’ safety, disposal of debris, etc is seriously lacking.
In light of the above concerns, we submit that the EIA report falls short of professional standards and should not be approved.
We urge the Department of Environment to:
- Give due consideration to our submissions and evaluate them purely on professional and scientific grounds, and without political considerations. This is in line with the prime minister’s directive that civil servants carry out their duties “menurut amanah dan bukan menurut arahan”.
- Appoint an independent and professional technical review committee, without participation from project proponents to assess the EIA as well as the feedback on the EIA.
- Make public all the above findings of the review committee and the DoE.