The Protect Karpal Singh Drive action committee (ProtectKarpal) welcomes the proposal in the draft Penang State Structure Plan 2040 under review to designate Middle Bank as a marine sanctuary and to recognise it as the plan’s second high-impact project.
However, this important conservation commitment is fundamentally contradicted by the plan’s section 6.1, which continues to retain a proposed reclamation area at Middle Bank.
ProtectKarpal therefore calls on the Penang state government to take two clear and immediate actions.
First, remove the reclamation proposal affecting Middle Bank from the Structure Plan 2040.
And second, begin the process of gazetting Middle Bank as a marine sanctuary now rather than leaving its protection as an aspiration towards 2040.
Remove reclamation from Middle Bank
Clause 6.1 expressly identifies “Middle Bank Marine Sanctuary” as “High Impact Project No. 2”.
At the same time, the map retains areas categorised in its legend as “Kawasan Cadangan Tebus Guna Tanah Yang Telah Dipersetujui oleh Kerajaan Negeri” – proposed reclamation areas agreed to by the state government.
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The same plan also identifies Middle Bank within its environmental planning framework.
This contradiction must be corrected before the structure plan is finalised.
A marine sanctuary cannot be meaningfully protected while a reclamation proposal remains within the same ecological space and planning framework. Keeping both designations creates uncertainty over the state government’s actual policy direction and leaves open the possibility that future development decisions could undermine the very ecosystem the new structure plan proposes to conserve.
The principle should be straightforward: once Middle Bank has been identified for marine conservation, reclamation should no longer form part of its planning future.
The draft structure plan itself recognises Middle Bank as an ecologically significant area of about 10 sq km in the South Channel between Penang Island and the mainland. The plan describes its seagrass meadow as the only one of its kind in the Strait of Malacca and recognises its role as an effective natural carbon sink.
Protecting such an ecosystem requires more than placing a conservation label on a map. Reclamation, dredging and related coastal activities may alter sediment movement, water quality, tidal circulation and other environmental conditions upon which seagrass and associated marine life depend.
The reclamation designation must therefore be deleted from clause 6.1 and any corresponding provisions in the final structure plan.
Gazette Middle Bank now
ProtectKarpal further urges the state government not to treat 2040 as the deadline for protecting Middle Bank.
The structure plan may have a planning horizon to 2040, but an ecosystem already recognised today as environmentally important should not have to wait 14 years for meaningful protection.
The need to gazette this area is particularly urgent because Middle Bank is not an ecosystem existing in isolation. It is already facing mounting cumulative pressure from extensive coastal development taking place around Penang’s eastern shoreline and surrounding waters.
Reclamation, dredging, construction, increased sedimentation, declining water quality and changes to coastal hydrodynamics can progressively weaken the ecological conditions on which its seagrass meadow and associated marine life depend.
Waiting until further degradation becomes visible or irreversible would defeat the very purpose of declaring Middle Bank a marine sanctuary.
Legal protection must therefore come now – before continuing development pressures further compromise the ecosystem the state has already recognised as worthy of conservation.
The gazetting of this area should establish clear, scientifically determined boundaries and an appropriate ecological buffer, supported by marine ecological and hydrodynamic assessments.
It should also provide effective safeguards against reclamation, dredging, dumping and other activities capable of degrading the sanctuary.
The present public feedback and objection period, which ends on 9 September 2026, provides an important opportunity for the state government to resolve this contradiction.
ProtectKarpal welcomes the recognition of Middle Bank. But recognition must now be translated into decisive policy and legal action.
Our call is clear:
- Remove reclamation from Middle Bank in the Penang Structure Plan 2040.
- Gazette Middle Bank as a marine sanctuary now.
Penang should not wait until environmental damage has occurred before giving one of its most valuable marine ecosystems the protection it already acknowledges that it deserves.
ProtectKarpal also urges all Penangites to submit their feedback and objections on the draft Penang State Structure Plan 2040 before 10 September, and to call for the removal of reclamation from Middle Bank and its immediate protection as a marine sanctuary. – ProtectKarpal
The Protect Karpal Singh Drive action committee (ProtectKarpal) operates under the auspices of the Bandar Sri Pinang Pulau Pinang Residents’ Association.
The views expressed in Aliran's media statements and the NGO statements we have endorsed reflect Aliran's official stand. Views and opinions expressed in other pieces published here do not necessarily reflect Aliran's official position.
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