Five reasons why DoE approval for Penang’s three-island reclamation is unjustified

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The Consumers’ Association of Penang and Sahabat Alam Malaysia (SAM) are most dismayed to learn that the environmental impact assessment for the Penang South Reclamation project has been approved by the Department of Environment (DoE).

We understand that 72 conditions have been imposed by the DoE for the approval. We call on the state to make public these conditions without delay.

We are alarmed that our comments and that of other civil society groups including members of the public have been pushed aside by the DoE – for we had called for the environmental impact assessment approval not to be given, due to the fundamental concerns that we had raised.

Among them were the following:

1) Population projection of the project area is questionable

The population projection for the project is 446,300 – which translates to a density of 24,522 persons per sq km. Penang’s natural birth rate at 1.4 is below the natural reproductive rate, and its net migration averaged 9,000 per year over the last two decades. This population projection is thus unrealistic. Hence, the population projection does not have a sound basis and justification.

2) Clear statement of purpose, need for project is paramount

However, the environmental impact assessment of the project has not provided such justification. The original justification by the project proponent is to sell the reclaimed land to fund the “Penang Transport Master Plan” (PTMP).

However, this “statement of need” is not articulated at all in the environmental impact assessment. Instead a vague statement of other “needs” is used to justify the reclamation, such as “delivering high impact results over the long term to resolve land supply, economic, social and related issues to the benefit of the Rakyat.”

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We had pointed out that if the concern was to address land supply, the proposed future growth of Penang can and should be planned on existing land already owned by the state government for instance in Batu Kawan and other vacant areas in Seberang Perai.

3) Serious impacts on fishery resources, livelihoods of fishermen

Fishermen from this area and also others depending on the fisheries stock derived from the southern part of Penang Island will be worse off if the proposed project is approved and implemented. There are about 1,500 small scale fishers, besides their families, whose livelihood are going to be affected by this project.

As it is, the inshore fisherfolk had already felt the impact of dwindling fish catches due to the construction of the second Penang bridge, arising from the deterioration of water quality and the shrinking of available fishing ground. We had pointed out that the fisher community is being wiped out – as well as the fishing industry itself – south of Penang Island.

All the alternatives proposed for the fishermen in the environmental impact assessment are unreasonable and unrealistic, devoid of empathy for the fishing community.

4) Landing, nesting grounds of Oliver Ridley turtles will be wiped out

The environmental impact assessment states that there are records of Olive Ridley turtle landings, including the green turtle (chelonia mydas) at Teluk Kumbar, Gertak Sanggul, Pantai Medan, Teluk Tempoyak and Pantai Belanda.

These turtles are natural assets which should be protected by the state and Malaysia. Sea turtles play vital roles in maintaining the health of the oceans by:

  • maintaining healthy seagrass beds and coral reefs;
  • providing key habitat for other marine life;
  • helping to balance marine food webs; and
  • facilitating nutrient cycling from water to land.
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While the environmental impact assessment recognises the negative impacts on the sea turtles, it is regrettable that it also dismissed the importance of these existing landing areas by merely stating that there is a “possibility of the turtles finding an alternative nesting site if the original site had been disturbed by human activities”.

Such a statement assumes that there would be a suitable alternative site available for the turtles to land, passing on the responsibility and downplaying the fact of the existing and thriving turtle landing site.

Essentially, this environmentally sensitive area would be completely wiped out by the project – but it was justified as merely a “trade-off”.

5) Incomplete assessment of sand mining impacts

The assessment falls short of making available the environmental impact assessment of off-site sea-sand mining (which will be in the waters of Perak) and the quarrying of rocks in all the areas identified as sources of supplies to the reclamation project.

The impact of sand-mining and the transportation of this sand supply to the project site is part and parcel of the reclamation project and must not be evaluated separately. The combined impacts on the waters south of Penang Island and the fishing activities (and navigation) are compounded by these two main components of the project.

These are among the fundamental issues that we had raised as to the shortcomings in the environmental impact assessment. How the environmental impact assessment has been approved despite these flaws is inexplicable and unjustified.

Mohideen Abdul Kader is acting president of the Consumers Association while Meenakshi Raman is president of Sahabat Alam Malaysia.

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