Understanding environmental impact reports submitted by project proponents       

The system that requires project proponents to produce environmental impact assessments by their own consultants is flawed

Golden area: Fisherfolk bringing back a large catch at Teluk Kumbar, Penang - ZAKARIA ISMAIL

There is a Malay saying “indah khabar daripada rupa” (too good to be true).

Could this be an appropriate description of environmental impact assessment reports prepared by consultants employed by project proponents (which is the practice in Malaysia)? 

The proponents of the ‘Penang South Reclamation’ project, to build three artificial islands spanning 4,500 acres in fishing waters, have resubmitted a fresh environmental impact assessment. The voluminous report has now been put up for public feedback.

The credibility of the assessment rests a great deal on whether there is any conflict of interest that could affect the scientific ethics of the study. 

If there is a conflict of interest, could it affect the results and recommendations made? On this rests the degree of credibility of the environmental impact assessment.

Who engages the consultants and pays their wages? What are the implications of this practice?

The paymaster, who is also the project proponent, certainly wants an environmental report that will ensure the project is approved.

So, what happens if the consultants carrying out the study find that certain facts they may have discovered are not conducive to getting approval?

I once chatted with an environmental impact consultant for a project proponent (not the Penang three-island project).

He related the dilemma that consultants face. On the one hand, they need their salaries, and on the other, they have their professional ethics.

Which to choose when their paymaster doesn’t want them to include certain facts in the report or wants to water them down so that the approving authority will not reject the report?

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The consultants invariably choose to keep their jobs, as holding fast to professional ethics could mean not knowing where next month’s salary will come from and when. Who will employ them in future [if they come up with an unfavourable report]? At the end of the day, they are humans working for a living.

So if environmental impact assessments are produced by consultants in such conflict-of-interest situations, how much credibility will their reports have? Remember, they are humans and work under ‘pressure’ to produce reports that will ensure the projects are approved.    

Do the authorities look beyond the pages of the environmental reports submitted to them or take them as the truth and nothing but the truth?

Though the public is given an opportunity to look at these reports and give their comments, the process is often not done in good faith.

Obstacles are placed for the public: limited hours to read volumes of hard-copy pages and a limited period to comment on them. The report is usually open for viewing only during office hours, when working people who would like to see the report or make comments are at work.

[Though the full 936-page Penang ‘three-island’ environmental report may be viewed online upon filling up an online form, it cannot be downloaded to the reader’s device from the link given.]

That said, a news report touts a “High approval rating for Penang South Reclamation“.

The first paragraph of this news report, however, makes this claim a mockery:

The Penang South Reclamation’s (PSR) latest Social Impact Assessment (SIA) study has recorded a close to 80% approval rate from more than 700 survey respondents living near the proposed project on the south of the island.

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How reliable is the finding that there is “high approval rate” (80%) based on the feedback from 700 people out of a Penang population of 1.7 million? So, a teeny-weeny 0.0004% of the population reflects the views of 1.7 million? Is this statistically reliable?

[While it might be argued that the immediate impact area is limited to a distance of about 5km, the actual impact area could be much larger: many Penang people would consider the affected fishing waters as a source of food security especially during these times of rising prices.]

The system that requires project proponents to produce environmental impact assessments by their own consultants is flawed, and such reports must be taken with spoonfuls of salt.

The public depends on the authorities to be aware of all this conflict of interest and therefore look beyond the pages of the environmental impact assessments submitted to them. Any flaws or shortcomings discovered should render the whole document unreliable, in which case, it should be rejected in the greater public interest.



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Chia Ping
3 Aug 2022 5.15pm

It seems that Penang government had launched a new website to specifically talk about the Penang South Reclamation https://penanginfra.com/ . I hope prompt action will be taken soon.