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Comments
by Sahabat Alam Malaysia and the Consumers Association of Penang
on the detailed EIA of: JKR proposed proposed raw water transfer
project from Pahang to Selangor by MAB, August 2000 I. INTRODUCTION The EIA for the proposed project has been undertaken in view of the requirements under Section 34A of the Environmental Quality Act 1974 and the EIA Order of 1987 for water supply projects. The project is initiated by the Government of Malaysia. Following the display of the Detailed EIA [ DE ] for public viewing and comments, we are pleased to submit our comments and feedback, as presented below. The justification given for this project is that demand for treated and piped water in Selangor and Kuala Lumpur will exceed current supply capacity of 3250 million litres per day (MLD) by 2003. Phase lll of the Sg. Selangor project will add a further 1,100 MLD allowing capacity to support projected demand until about 2007. The consequences of failure to meet demand after that time are compared with the economic loss and social unrest that came with the 1998 water crisis. This project is supposed to ensure that supply meets projected demand until 2017. The project proposes to: 1. Build two
earthfill dams in Pahang:
2. A water intake on the Sg. Kelau with 11 km of pipeline. 3. A weir on the Sg. Bentong with 7 km of pipeline. 4. A 37.5 or
45 km water transfer tunnel with inlet 1.5 km south of Karak that
goes beneath the Main Range and has It is pertinent
to note that the EIA legal requirements cover only the construction
of dams or impounding reservoirs and not the transfer tunnel, pipelines
or filtration plants and sludge ponds. This EIA study discusses
the tunnel and pipelines, but not the filtration plants or sludge
ponds.
The DE addresses impacts that will arise as a result of the project as set out above - viz. that involving the construction of both the Kelau and Telemong dams, the Kelau intake, the Bentong Weir, the transfer tunnel and the pipelines. Since the submission of the DE, we understand that there have been various changes to the project design such as the shelving of the Telemong Dam, changes to the Kelau intake and the Bentong Weir. According to press reports, the Pahang State Government has recommended that the Telemong dam be shelved due to 'sensitivities'. We welcome the decision of the Pahang State Government in this regard, and call for a review of the entire project including the Kelau Dam, the tunnels and the pipelines, since the environmental and social costs of the project are still grave and significant. Moreover, we are not convinced that the project can be justified given the huge costs involved and the social and environmental trade-offs that have to be made when other better alternatives to supply water have not been adequately dealt with. The proposed changes to the project design are not minor but are indeed substantial and major. A redesign of the project concept must necessarily involve the conduct and submission of a new EIA. A substantial change in the project design such as the shelving of the Telemong Dam would mean that the impacts as originally envisaged would be different, depending on the scale, location and changes to the original project design. In the circumstances, we submit that a completely new Detailed EIA ought to be submitted, taking into account the new changes to the project design. Of particular importance is the impact of the revised project on the existing river systems and water flows. Further, given that there are changes to the project design, it is imperative that public feedback is sought on the new EIA to be done, instead of soliciting comments on the present DE which is misleading. Hence, we reiterate
the need for a new Detailed EIA to be commissioned, based on the
revised project design so as to ensure that the public is given
a true and fair account of what is at stake. There are some very major discrepancies in the DE in relation to the water demand projections. In chapter 1 pg. 6, the DE states that Phase III of the Sungei Selangor scheme which is now under construction and will be completed by 2002 will boost supply capacity to 4,350 MLD from the current reliable yield of 3,250 MLD. It further states that "This is only sufficient to meet demands up to the end of 2004 after which other sources need to be in place to avoid the water shortage in the Klang Valley." However, in the Executive Summary of the DE, it is stated that the Phase III of Sungei Selangor will be sufficient to meet demands "… up to the end of 2007." When we refer to Figure 1.6 on the 'Water Demand and Supply Balance', the conclusion in the Executive Summary appears to be more accurate. Such a glaring error right in the beginning of the DE reveals shoddy work and a lack of professionalism. Other areas of discrepancy further undermine the credibility of the DE. The DE is rather confusing as to what exactly the water yields will be from the proposed project. In chapter 2 at pg 14, the DE states that at the initial stage of operation, the average yield is 1043 MLD, derived from the Kelau dam and the Kelau intake. At the final stage, the DE says that an average yield of 886 MLD will be obtained from these sources. Firstly, there is no explanation provided as to why the yield will drop between the initial stage of operation and the final stage. Secondly, exactly how these figures have been obtained remains a mystery. The figures in Table 1.8 which show the increment of reliable yields by the project do not tally with the figures stated in chapter 2. If we adopt the figures in that table, the water yield from the Kelau dam and the intake should be 968 MLD [ 432 + 536 ] and not 1043 MLD. The same is the case for the figures in relation to the Telemong Dam and the Bentong Weir. In chapter 2 at pg 14, the DE states that the yield from these sources would be 1455 MLD. This conclusion cannot be derived from the figures in Table 1.8. If we adopt the figures in Table 1.8, then the total yield from the Telemong Dam and the Bentong Weir should be 1132 MLD [ 665 + 467 ]. The total reliable
yield from the entire project in Table 1.8 is 2,100 MLD. If we follow
the text in chapter 2 pg 14, the total average yield from the entire
project would be 2,321 Why the discrepancy
in the figures? This has to be explained. IV. NO JUSTIFICATION FOR THE PROJECT The present project is justified on the basis that the demand for water supply in Selangor/Kl will exceed the current supply capacity of 3,250 MLD by 2003. The supply from the ongoing Sungei Selangor Dam is expected to be an additional 1,100 MLD [making it total of 4,350 MLD], which is estimated to meet the water demand up till about the end of 2007. According to the figures in Table 1.8, the total increment in reliable yield derived from the entire project would be 2100 MLD. With the shelving of the Telemong dam, based on the figures in Table 1.8, the total increment in reliable yield would be 1,435 MLD, without any alteration to the Bentong Weir. With this additional supply, the total amount of water supply available for Selangor/KL will be 5,785 MLD. According to the water demand projections set out in Table 1.1 of the DE, in the year 2005, the demand is 4270 MLD and in 2010, it is 5,850 MLD. Therefore, assuming that these figures are correct, the revised project [ without the Telemong dam ] will not be able to meet water demands beyond 2010. According to
Table 1.9, the timing of the commissioning of the Kelau intake for
the planned demand would be 2006 and for the Kelau dam and the intake
would be 2008. Given the water demand projections, within a matter
of two years since 2008, the water demand needs would have outstripped
the supply potential of the revised project. The DE estimates the overall project cost to be more than RM 3 billion and this figure has not taken into account the financing costs of the investment. [ see chapter 15 pg.3 ]. With the shelving of the Telemong dam, we are not certain what the project cost will be. In any case, it is safe to presume that the construction of the 45 km tunnel to transfer the water would constitute a significant part of the project cost. In the light of the above, given the huge financial costs involved, there appears no sufficient justification whatsoever to carry on with either the original project or the revised one which will have only a very short-term 'benefit' before alternative sources of water supply have to be sourced. Why sink in such a huge sum of money for so short a duration? A more prudent approach would be to look for better alternatives which will meet the water demand needs in the long-run. The Statement of Need in chapter 1 is grossly inadequate, as it has failed to deal with the issues stated in the preceding paragraphs. The need for the project has not been sufficiently justified from an economic standpoint. Investing so much money on a project with no long-term benefit defies economic sense and prudence. What ought to
have been seriously and comprehensively dealt with are possible
alternatives to meeting the water demand for Selangor/KL. At pg 3, the DE states that there are other alternatives to this project that should also be considered. The Consultants recommend that " The costs of undertaking these alternatives must then be weighed against the total costs of the Project." It further states that " Without a more detailed information, the benefits and costs of the project cannot be squarely quantified. It is therefore proposed that a more detailed study at a later stage be carried out …The high investment cost alone justifies that alternatives must be looked at before a decision is finally made"
Under chapter 2, in relation to the 'No Build Option' and the 'Non-Dam Alternatives', the DE states that the "Alternatives to the proposed project have been identified and thoroughly evaluated for environmental impact". [ see chapter 2, pg 19 ]. This statement is grossly misleading, as there has been no thorough evaluation of the alternatives to the proposed project. Moreover, the conclusions in chapter 15 itself as alluded to above, contradict this claim as it recommends more detailed studies on the alternatives before a final decision is made. The Benefit Cost Analysis does not support the conclusion that the proposed project is the only option. From the foregoing analysis, it is clear that the DE itself in relation to the justification for the project is contradictory - the conclusions in chapter 1 under Statement of Need and in chapter 2 on the No Build Option are not supported by the recommendations in chapter 15 on the Benefit Cost Analysis. One of the options that was alluded to in the DE was the direct water intake of raw water from several large rivers in other states, requiring the construction of long distance pipelines. The DE refers to the need for feasibility and detailed studies. Without the conduct of one, the DE itself states that no conclusion on this can be derived. [ see chapter 2 pg. 15 ]. Since this option has not been properly studied, the DE cannot dismiss this option as one that is not viable. The DE states in a very cursory fashion that the cost of such a venture could be close to RM 2 billion. How this conclusion was arrived at is yet another mystery. This only proves the point that the DE is not objective and biased in favour of the proposed project as the only viable option. Alternatives such as using ground water reserves in Selangor, water from outside the Klang Valley from the Sg. Bernam or the Sg. Sepang or effective water conservation and recycling are dismissed as requiring further investigation or EIA work that would cause excessive delay. The only options discussed as being viable are the building dams with full supply levels (FSL) of 87.5m or 90m. The DE is indeed highly biased.
It is pertinent to note that in the consideration of viable options for water supply, the DE should have been more comprehensive in its approach. The proposal by a non-governmental group called the 'Concerned for Sg. Selangor' which was submitted to the DOE in relation to the Selangor Dam project ought to have been seriously and rigorously considered. A copy of the
proposal is attached herewith. In summary, the proposal is for the
intake of raw water from the Perak River, with pipelines that can
follow the existing railway track at a very low cost of only RM
741 million or from Lake Kenyir. These proposals should not be dismissed
as being without merit, when no opportunity has been provided to
consider them seriously. The most viable and practical option is to use existing lakes or dams to supply water to Klang Valley by using water pipelines following existing corridors such as roads, railway lines or the gas pipelines. Two sources of water supply are considered viable: water from Sungai Perak or water from Kenyir Lake in Terengganu. Water Transfer from Sungai Perak Perak has considerable
water storage capabilities in the 15,000ha Temenggor Dam and other
existing dams on the Perak River. A study in the early 1990s indicated
that a minimum of 500million litres per day (mld) supply from the
Perak River can be used for interstate water transfer or for export.
Given the size of the Sungai Perak basin it is likely that more
than 1000mld can be supplied. The options are as follows: 1. Construction of a water intake station at or near Kampung Gajah, which is a small town next to the Sungai Perak and is above the salt water intrusion line. Pipelines would then have to be laid along road reserves to Tapah Road where it enters railway property and follow the railway line to Rasa in Selangor. Depending on the circumstances, it can either be discharged directly into the Sungai Selangor at the Rasa area or diverted into Sungai Tinggi, which already has an impounding dam under Phase 2 of the Selangor water supply plan. The approximate distance from Kampung Gajah to Sungai Selangor is about 130km and the piping diameter would be 213cm, which is considered sufficient to handle 1.1billion litres per day without any problems. The volume can be increased or decreased by regulating the turbines. The whole system includes an intake station at the riverbank with heavy particle settlement tanks, an outlet reservoir at the discharge point, a filter system to screen out particles above 5mm, a settlement reservoir with about 100,000 litres holding capacity along the way, pumping stations along the way, and pipes of mild steel with bitumen outer coating and concrete lining. The whole cost would amount to about RM740million. 2. Another option would be to place the water intake station further north at Parit and piped to the railway line at Batu Gajah. 3. A better way to move water is by gravity feed, where water is first pumped to higher ground and allowed to drain downwards for a long distance. This scenario entails that it would be possible to start intake at Chenderoh Dam. As Chenderoh Dam is shallow, water would have to be released from Temenggor Dam to keep feeding the lower dam. From here, the engineers can determine the method of flow, of which the smoother route would be to use the railway lines. Train routes are always gradual in gradient change. Water Transfer from Terengganu The water storage capacity of the Kenyir Dam is so large (37,000ha) that water extraction for a pipeline will not have a major impact on the dam itself. Based on a previous study, extraction of 1,000mld of water would drop about 1.5m of water level in the dam per year, insignificant considering he large area of catchment and the large amount of rainfall for inland Terengganu. Additionally, the availability of water from the Kenyir Dam is not a problem. The State Government in fact has no objection to supplying the water to other states provided that the developer pay for the annual premium/royalty to the state and bear the cost of pipeline construction. 1. A contractor has quoted Petronas a cost of RM 400million to deliver water to Dungun from Kenyir dam. With this in mind, we can assume that the pipeline corridor has been established and secured. 2. There is also an existing Petronas gas pipeline extending from Kertih to Gemas and north to the west coast. There will be a 30km stretch from Dungun to Kertih that requires a pipeline corridor, which can be constructed along road reserves. Evidently, there is now a clear water line route from Kenyir to Selangor. Waterpipes do not require wide spaces and they are able to utilize the narrow corridor route of the gas pipelines. 3. Otherwise, an alternative route would be to follow a newly constructed road from Kenyir Lake to Gua Musang and from there to connect to the railway track to Gemas and on to Selangor. Rain water harvesting The option and possibility of rainwater harvesting systems for the individual residence should be contemplated. The water collected would be filtered and automatically pumped to a gravity tank for cleaning purposes, which is a major source of household water consumption. Localized water sources Small, localized sources of ground and surface water should be identified and collected to serve the immediate vicinity and local communities. This would reduce the need for larger water resource and distribution facilities while utilizing the retention capacity of existing wetlands and natural underground aquifers. Polluted streams, rivers and lakes can be rehabilitated and revived as water supply sources for irrigation and industry. Appropriate water pricing policy A review of the existing water tariffs should be carried out and a fair pricing system based on an appropriate scale should be adopted to encourage water saving. This would reduce the demand for water. Reduce water losses The State Government in collaboration with the municipal council and JKR would have to begin extensive repair works of all the leaks in the system, tightening the theft problem and would have to eventually change all the asbestos piping in the city to long lasting pipes. Wise use of water in the agricultural sector In the agriculture
sector, wise water use can be promoted through the development of
more efficient irrigation practices, establishment of a cost-recovery
mechanism, development of conservation incentives, consolidation
of irregular and small landholdings, and through recycling water. VII. ENVIRONMENTAL ISSUES 1. Biodiversity Concerns 1.1 Both the floral and faunal investigations compiled partial name lists of species present. Most effort
was concentrated on timber species, and vertebrate animals, ignoring
the bulk of taxa that make up biological diversity. It was noted
that no rare or endemic species were found, thus implying that the
site haS little conservation value. No attempt was made to
interpret:
Name lists alone cannot adequately describe the biology of a site, interpret the role they play in local ecology and thus understand what impacts will arise from the loss of the habitats and the inundation of the sites. Because no attempt was made to qualify the interaction between the animal communities currently resident on the sites proposed for flooding and neighbouring areas, no model can be made to project impacts that could occur once the populations in the proposed reservoir sites have been eliminated. This is a failure of the DE to address a TOR - impacts on biological diversity. 1.2 The faunal study examined the single issue of impacts from the removal of existing wildlife, with emphasis on large mammals. The recommendation given was that animals should be driven into neighbouring forest areas or captured and transferred to ex-situ locations. What was not addressed include:
These are points where the DE has not adequately examined the feasibility of its recommendations. 1.3 The EIA warns of the potential negative publicity that could arise should large vertebrates be marooned on islands by the rising floodwaters. This happened on the much larger Kenyir dam site, requiring an expensive exercise to evacuate elephants from small islands. In this particular case there are no elephants recorded on the sites. (The EIA does not make clear what species were actually observed as resident or recorded from interviews and reports with local people.) And a crude evaluation of the species list given suggests that the marooned animal problems could be limited to primates, small felids and possibly bear. The DE recommended an animal rescue task force be mobilised on a large scale. Though maintaining this functional capability in government agencies may be important on a national scale, it may not be the best use of resources available for biological diversity for this project. We are concerned that concentrating discussion on high-cost animal rescue operations will ignore less news-making requirements to minimise biodiversity loss. The DE should emphasise that a Species Management Plan would be required for the clearance/construction phase to minimise impacts on biodiversity at the landscape, taxa and genetic level. 1.4 The DE recommended
the destruction of vegetation on islands in the reservoir area.
This would result in unnecessary loss of habitat space. The reason
given was to prevent large mammals becoming trapped. This recommendation
is concerned with animal welfare alone. This is a social issue and
does not contribute to the conservation of biological diversity.
1.5 Biomass removal has been included in the DE together with biodiversity issues. We submit that this item has been misplaced, regarding biomass removal as an issue of waste management and thus an engineering matter. We are concerned that by grouping biomass removal with 'soft' issues of biodiversity - issues that are usually undervalued by the EIA process through a lack of information, the EIA is attempting to endorse the avoidance of disposal costs. Biomass removal ought to be treated as a part of waste management. (See further discussion below in this regard). 1.6. Floral/forestry issues. The assessment
of flora and forestry aspects is limited to a 1ha plot and the information
from this plot has been the basis for biodiversity assessment.
2. Quarrying, waste material disposal and biomass removal Taking an engineer's
perspective, the DE has described what should be routine practices
for waste management from construction sites. It has not adequately
examined the wastes peculiar to this particular project. These would
include wastes from:
If the DE had adequately addressed these issues, it would have:
The DE study should have discussed the impacts and trade-offs that would arise if residual biomass were: It would have then examined options for waste management and made recommendations for the options that would have been most appropriate for the scale impacts and resources of the project.
The DE estimates in most parts that the length of the tunnel is 45 km with a diameter of 5.2 metres. Calculations show that the tunnel borrowing will generate spoil material to the tune of 1.2 million cubic metres! To dump such a large volume of spoil, we estimate that a landfill which is about 1km long, 100 m wide with a height of 10 m would be required to contain all that material. At a 10 m height, 24 acres of land would be required! The DE states that only 300,000 tonnes of aggregates will be generated from the tunnel construction. Exactly how this figure was arrived yet is not disclosed but given the tunnel specifications, it appears that this figure is a gross underestimate and must be challenged. One major omission
of the DE is its failure to address this issue adequately. All the
DE states is the areas to keep the spoil material have been identified
but exactly where they are and what size they will be have not been
dealt with. (b) Quarried Material In the case
of quarried material, that taken from sites within the reservoir
area that would later be flooded, requires mechanisms to minimise
siltation to local river systems. For other sites outside the flood
areas, the DE should describe the usual quarrying practices which
would apply as well as recommend methods that would ensure landscaping
and revegetation after quarry closure is actually implemented. The practice
of sand washing usually causes stream siltation. The DE should describe
the steps needed to minimise impacts of silt to local waterways. Under para 12.7.8,
the DE mentions preparation of a waste management plan, but this
does not make reference to biomass removal. The DE gives a biomass
of 2.238x 106 tonnes of biomass for removal from the Kelau site.
This we feel is a gross overestimate. We urgently suggest that this
reference be consulted: Kato, R.,Y.Tadaki and H.Ogawa. 1978.
Plant biomass and growth increment studies in Pasoh Forest. Malayan
Nature Journal 30(2): 211-224. Composting and incineration are suggested as options but not discussed. The implication being that the DOE would grant permission to undertake open burning. Considering the disapproval Malaysia has made of the Indonesian practice of open burning for forest clearance in Indonesia - sometimes by Malaysia-owned companies, it will be embarrassing for the Malaysian Government to permit open burning at home for a Japanese funded project. Incineration may be difficult since 2.238 x 106 tonnes is a lot of matter to incinerate ; it would take the proposed Kg.Bohol MSW incinerator 5.1 years to process that amount. Since incineration would require chipping or shredding up-front to increase surface area, it may be possible to consider options such: as sale of wood chips (if a buyer can be identified), and/or composting wood chips with or without sewage sludge. These could be practical alternatives far cheaper than incineration and far more acceptable than open burning The DE study should have discussed the impacts and trade-offs that would arise if residual biomass were:
The study should have discussed the physical quality of the residual biomass, its conversion processes to an equilibrium state with the environment, the release of components into environmental media, transport routes, biological targets and the effects and impacts of these processes and on their targets. The DE may be
correct in implying that open burning is the only affordable solution,
but it should at least make an attempt to identify effects, identify
targets, qualify and quantify the costs that would be externalised
and assess health risks to affected communities. Safety risks
from construction and operations of the dam, water transfer tunnel,
etc. has been treated in a general discussion which makes no attempt
to qualify let alone quantify the risks that come from this project.
In our view the DE has failed to address the TOR on this issue.
We expect the DE to have:
Describing the circumstances leading up to failure locally - at Ampang Pechah, or from similar climatic areas would have been more informative than quoting examples of historical dam failure in the US and Europe. IX. SOCIAL IMPACTS The socio-economic impacts of the proposed project are indeed significant. Of particular concern is the displacement of local communities including the Orang Asli at Sungei Temir and the destruction of their livelihood. While resettlement plans and alternative income generation activities sound good on paper, actual implementation of such plans in other dam projects in the country are fraught with massive problems with serious grievances among the displaced communities. Examples include the Batang Ai Hydro-electric project in Sarawak, the Bakun Dam and the Selangor Dam project. SAM has compiled numerous complaints from the indigenous communites displaced by the Bakun Dam project, who now face food shortages, loss of jobs, increased crime, alcoholism, break up of community life, loss of their pride and dignity, with the threat of cultural extinction. Similar problems are also seen in studies of the Batang Ai project and other dam projects around the world. The DE has not taken into account these examples, which not only deal with issues related to compensation, but which involve the impact of such projects on the culture and lifestyle of these communities. These are very serious considerations, which are not dealt with in the DE and are neccesary to evaluate whether real benefits are realised by displaced communities from such projects. Superficial surveys which do not provide actual details of the trade-offs the communities have to put up with are grossly misleading and insufficient. If the communities are given the opportunity to visit other communities who have been displaced by other dam projects, we are convinced that no one will agree to be displaced in the first place. By and large, all the promises of a good life after the displacement have remained illusory. It is about
time that Consultants who undertake socio-ecomomic assesments and
make recommendations on paper visit actual resettlement schemes
to assess the actual impacts of such projects on local communities. In the light of the above, we submit that the DE is seriously flawed in many respects, inadequate, misleading in parts and suffers from fundamental defects. As it stands, the DE does not satisfy the requirements of Section 34A(2) of the EQA and should therefore be rejected as is provided in Section 34A(4).
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