proposed klorr detailed environmental impact...

Proposed KLORR Detailed Environmental Impact Assessment

A WWF-Malaysia (World Wide Fund for Nature) Public Briefing On:

based on the recent Public Briefing

IntroductionProposed alignment of the KLORR will traverse through the Selangor State Park (SSP). The SSP is a protected area, harbours rich biodiversity and provides crucial ecosystem services to people in the Klang Valley.

Proposed KLORR DEIAA public briefing by WWF-Malaysia

Should a dangerous precedent be set allowing a highway to pass through a Protected Area?


What can you do?

Voice concern about the project

Voice concern about the DEIA report


What can you do?•Keep these in mind during this briefing presentation.

For comments and concerns about the project itself, please write to:

Selangor State Government (Menteri Besar) and

Federal Government (Prime Minister).


Why write to the Selangor Menteri Besar?

According to the DEIA, the final decision on alignment was made by the highest approving authority in the state (EXCO) meeting chaired by theMenteri Besar after going through layers of decision making. Theagencies involved in the decision making process were :-•State EXCO

•Jawatankuasa Perancang Negeri (chaired by the Menteri Besar)

•Unit Perancangan Ekonomi Negeri (UPEN)

•Jawatankuasa Teknikal KLORR (Negeri) (chaired by Pengarah Jabatan PerancangBandar & Desa Selangor)

•Jawatankuasa Sasaran Penting Negeri Selangor

•Lembaga Lebuhraya Malaysia

•Pejabat Penasihat Ekonomi Negeri Selangor

•Majlis Perbandaran Ampang Jaya

•Majlis Perbandaran Kajang

•Majlis Perbandaran Selayang

•Jabatan Alam Sekitar Negeri Selangor

•Jabatan Kerjaraya Negeri SelangorSource : KLORR DEIA (Chapter 2, Pages 2-10 & 2-11)

Road projects are Federal government initiatives and as such, the ultimate decision making on the proposed KLORR can rest with the Prime Minister.

All stakeholders be it NGOs or members of the public ought to bring the negative impacts of the proposed KLORR on the Selangor state Park and water catchment forests to the attention of those at the highest level of decision making.


Why write to the Prime Minister


What are the potential impacts of the proposed KLORR ?

Source : The Star -January 2012

1. Highly sensitive area (Selangor State park) will be affected!2. Water catchment forests will be affected by the proposed KLORR!

According to news reports, Selangor is already facing pressure to meet rising demand in water supply. The water catchment affected is the main catchment for Klang Gates Dam, which supplies water to the not only areas in Selangor but also within Kuala Lumpur.Such impacts will only increase the threat to our water catchment forests and affect water security


Ways to get Involved

• Read up and get updates

You can read up and get updates about the Selangor State Park from:

selangorstatepark.blogspot.com

• Sign the petition to Protect Klang Gates Quartz Ridge and Selangor State Park from the proposed KL Outer Ring Road (KLORR)

http://www.petitiononline.com/KLORR/petition.html

• Review and comment on the DEIA of the proposed project

http://www.petitiononline.com/KLORR/petition.html

Commenting on the DEIA

Things to bear in mind -

The Dept. of Environment’s (DOE) Powers

•DOE does not have the powers to approve / reject a

proposed project.

•DOE only has powers to approve / reject a DEIA report. Therefore

comments to the Dept of Environment should be based on

the DEIA Report.



For comments about the DEIA - :

• Highlight areas which are not addressed in the report

• Questions/clarification regarding any area of concern

• Sensitivity of the Selangor State Park

• And any other suggestions that you have on the report(DOE’s contact details can be found at www.doe.gov.my)

Commenting on the DEIA (cont.)

Project Options

Project Options have not been presented in the Executive Summary

•Route Options are based on the Japan International

Cooperation Study (JICA) conducted in 1996

•Three options were considered and evaluated based on

engineering, economic and environmental criteria – Route B

was chosen as preferred general alignment

PROJECT OPTIONS


Route Options – JICA Study (1996)

Source :KLORR DEIA, 2011 (Chapter 2, Page 2-3)

Source : KLORR DEIA, 2011 (Chapter 2, Page 2-8)

This table is based on the evaluation criteria in the 1996 JICA Report

Route B was further refined where a total of 11 options were considered in the DEIA


Source : KLORR DEIA, 2011, (Chapter 2, Page 2-15)

Continuation….



Proposed KLORR DEIAA public briefing by

WWF-Malaysia

Source : WWF-Malaysia, 2012

Note : Map produced by WWF-Malaysia based on information provided in the KLORR DEIA


Source : WWF-Malaysia, 2012

Note : Map produced by WWF-Malaysia based on information provided in the KLORR DEIA

Why the current alignment was chosen?


According to the DEIA (Chapter 2, Page 2-15 & 2-16), the current alignment was chosen because :-

• The alignment is away from the Klang Gates Dam structure

• In compliance with the conditions set by the State for the gazettement process of the Quartz Ridge as a World Heritage whereby the construction of the 200m length tunnel will not affect the aesthetic value of the Quartz Ridge

•Construction of bridge / viaduct and tunnel will reduce the environmental impacts due to minimum earthworks

• The geometric design standard conforms to design speed of 90kph in rolling terrain

• It conforms to the intended KLORR concept (Outer Ring Road) of which the alignment is away from MRR2 and caters for future extension of KLORR (Northern Link)

According to the statement of need for the proposed project in the DEIA, the proposed project is needed to address traffic congestion on the MRR2 (Section 2.1) A DEIA in this regard should also provide various other options other than this project to address the problems above. The current DEIA only analyses alignment options and not provided other project options

For example, one option is to consider increasing the efficiency of public transportation system. E.g new initiatives such as the MRT project.

This is a major gap in the DEIA.


WWF-Malaysia’s comments on Project Options

Best route option is based on 1996 JICA study. In our opinion route options need to be re-analysed because in 1996 :-

• The Ampang and Hulu Gombak forests reserves were not protected as water catchment forests.

•The Selangor State Park did not exist

•The National Physical Plan did not exist

•The Central Forest Spine Masterplan did not exist

These new policies and protection status of the forests don’t seem to have been considered when deciding on the best route option.


WWF-Malaysia’s Comments on Project Options


Selangor State Park

• Selangor State Park was gazetted in 2007

• Harbours rich biodiversity and provides valuable eco system services such as watershed

Water Catchment Forests

• Ampang and Hulu Gombak forests reserves were re-classified as water catchment forests in 1999


NATIONAL PHYSICAL PLAN

The National Physical Plan-2 ranks Protected Areas (State and National Parks) as Environmentally Sensitive Area (ESA) Rank 1.

No development is allowed in ESA Rank 1 areas.

Selangor State Park = Protected Area = ESA Rank 1 =No development.

DEIA does not make any reference to the NPP-2 nor the fact that parts of the affected area is within a Rank 1 ESA.

Note : The National Physical Plan is the over-arching landuse plan for Peninsular Malaysia. It sets the policy direction for landuse planning in Peninsular Malaysia. It is approved by the National Physical Planning Council, chaired by the Prime Minister. Members of this Council include all Menteri Besars and Chief Ministers of the states in Peninsular Malaysia.

The Central Forest Spine Masterplan

The objective of the Central Forest Spine Masterplan(CFS) is to re-establish, maintain and enhance the contiguity of forest cover within the Central Forest Spine of Peninsular Malaysia.

The affected forests in Selangor State Park are within the CFS

The DEIA makes no reference to the CFS masterplan nor the fact that the affected forests are within the CFS


Note : The Central Forest Spine Masterplan is an “offspring” of the National Physical Plan.

Source: National Physical Plan-2 (2010)

Project Description



According to the DEIA (Chapter 3):-

1) Total length of proposed project is 39.5km

2) Tunnel (200m) proposed under the Klang Quartz Ridge

3) A total of 26 bridges / elevated segments with total length 8375m is proposed to :-

•To minimise tree cutting and earthworks thus reduce the environmental impacts

•To avoid massive cutting of slopes

•To reduce forest and habitat fragmentation

WWF-Malaysia’s Comment :-

It is unclear how many of these proposed bridges / elevated segments (including the length) are situated within the Selangor State Park. This is crucial information in order to determine the efforts towards avoiding fragmentation of forests and therefore must be provided in the report.

SELECTED COMPONENTS OF THE DEIA


GEOLOGY - SLOPE

The DEIA states :-

a) slopes steeper than 25o are considered as risky area with high geotechnical limitations.

b) About 18.7% of the total proposed alignment (or 10.27km) is within areas with slope gradient of 25o or more.

c) Of particular concern for slope failure is the Ulu Klang – Ampangarea which has a history of landslide and slope failure.

d) Possibility of slope failure especially for high cut slopes in granite areas exists.


GEOLOGY - TUNNELLING

The DEIA states that impacts from tunnelling will be :-

-Ground vibration due to blasting

-Dust generation

-Instability of the excavation

The nearest residential area is 300m away from the proposed tunnel – Taman Serenia

Mitigating measures have been prescribed : –

- control rock blasting to minimise ground vibration

- systematic rock bolting and shotcreting to stabilise excavation

-spraying of water and application of forced ventilation to control

dust


LANDUSE SECTION (Section 4.4 of the DEIA)

The DEIA states that the entire Forest Reserve area affected along the corridor of the proposed project is 214.7 ha (0.2% of the overall total of Forest Reserve in the study area).

(Page 4-57 of the DEIA)


Forest Reserve Areas Covered area (ha)

Hulu Langat Forest Reserve 10.6

Ampang Forest Reserve 110.4

Hulu Gombak Forest Reserve 93.7

The area covered of Forest Reserve along the corridor of the proposed project

Source : KLORR DEIA, 2012 (Table 4.4.1, Page 4-57)

Landuse for interchanges are explained in the DEIA based on the proposed interchanges. E.g

LANDUSE SECTION (cont.)


Source : KLORR DEIA, 2011 (Page 4-60)

WWF-Malaysia’s Comments on the Landuse Section

a) Environmentally Sensitive Area (ESA)

- No emphasis on the importance of the landuse especially ESAs.

- No reference to the NPP-2! The DEIA mentions that Forest Reserves & SSP are classified as ESA but makes no reference to the NPP-2 nor the ranking and management criteria.E.g



WWF-Malaysia’s Comments on the Landuse Section (cont.)

b) No mention of water catchment forestsIt is not mentioned anywhere in the landuse section thatthe proposed alignment will cut through water catchment forests.



c) Good landuse maps are missing.

- Satellite images are provided - Difficult to ascertain importance of the landuse in the affected area.

E.g





Good landuse maps are missing

(cont.)

- One unclear map provided to indicate proposed alignment affecting the Selangor State Park.

-Boundary of forest reserves are not marked / unclear

-Affected water catchment areas not identified in maps.



d) The DEIA does not conform to the Terms of Reference (TOR) for the DEIA

TOR states that the landuse assessment will include compatibility of the proposed highway with existing and future landuses within the study area.

However this has not been carried out.

FLORA SECTION (Section 5.2)

+15%Information descriptor

Can appear belowthe numbers

• Provides a better description of landuse than the landuse section of the DEIA. Explains that the area affected includes water catchment forests.

According to the DEIA :-The affected area was divided into 5 sectors and survey was

conducted

Results•Species diversity was found to be high in four out of five sectors

• Endemic species were found in all sectors•Critically endangered species were found in two sectors

•Endangered species were found in two sectors


WWF-Malaysia’s Comments on the Flora Section



• Results based only on rapid assessment surveys conducted during the preparation of the DEIA. Secondary data based on existing literature was not included.

• Methodology is lacking in details e.g- length of survey, - how were plants selected for specimen selection?- size of the sampling plot / length of trail walked at each

location- size of quadrats and distribution for the biomass survey- elevation at each sector- survey locations not marked in a map


Other Comments on the Flora Section



• No information on epiphytes, climbers, herbs or ferns – these live in specific habitats and therefore more vulnerable to disturbance

• Biodiversity is not considered – surveys don’t cover all plant forms or microhabitat

• Ampang FR known to harbour very rare species (the endemic, Codonoboea leucantha and the rare Begonia rhoephila) – not mentioned in the DEIA

• Endemic plants to Klang Quartz Ridge not mentioned

• There are glaring errors in identification – how reliable is the overall assessment?


FAUNA SECTION (Section 5.3)



Summary of the DEIA findings :-

1) Totally Protected Species listed in this section –tiger, tapir, leopard, sun bear, pangolin, serow, slow loris, largibbon, Siamang, Giant squirrel, Prevost’s Squirrel, Black Giant Squirrel

2) Most affected species are Tigers and tapirs which still roam in the area




a) Methodology is lacking in details e.g- man-hours involved, - size of the sampling plot or length of trail walked at each location not specified – e.g Large mammal studies require a larger area to be covered compared to other species, but readers do now know how much area/distance was covered,

- study area not marked in a map, just in satellite image- elevation details at each site not provided

b) Saltlick and mud wallow are not documented.

c) Were local people / PERHILITAN officers interviewed to find out if saltlick exists in the area?

d) Densities of several species (e.g. high or low) were inferred withoutany proper justification

WWF-Malaysia’s Comments on the Fauna Section




e) The study does not conform to the TOR for this DEIA- the relative abundance for large mammals is not provided - the relative abundance and distribution for small mammals & birds are not provided

- Conservation status, relative abundance and distribution for herpetofauna is not provided

WWF-Malaysia’s Comments on the Fauna Section (cont)


f) There seems to be some inaccuracies in identificationE.g The Hylarana erythraea is mistakenly identified

as Hylarana labialis. (Appendix E of the DEIA)

POTENTIAL IMPACTS & MITIGATING MEASURES



Quantitative analysis on impacts to Klang Gates Dam has not been carried out.

Clarification needs to be provided for the following :-

a) TOR states that the impact assessment will include the sediment yield to Klang Gates Dam. This is not carried out.

b) What is the estimated sediment load that will flow into the KlangGates Dam in different scenarios?

c) How will this affect the lifespan of the reservoir?

d) Will there be a need to dredge the reservoir due to increase in sedimentation?

WWF-Malaysia’s Comments on Potential ImpactsSurface Hydrology during Construction Stage

Section 7.2.3 (Pages 7-13 to 7-16)

WWF-Malaysia’s Comments on Potential ImpactsWater Quality during Construction Stage



Section 7.2.7 (Pages 7-22 to 7-25)

The “Potential Impacts” section provides qualitative, not quantitative analysis. General statements are made in the impact assessment section. E.g The DEIA states :-

“The main effects to adjacent river water quality will be away from the run-off containing water of high turbidity and high suspended solids (especially on rainy days) due to the activities”(Page 7-22)

“Inflated turbidity and sedimentation of Klang Gates Reservoir and of Sg. Ampang due to the polluted water of upper Sg. Klang and Sg. Ampang will definitely cause public outcry”(Page 7-22)

WWF-Malaysia’s Comments on Potential ImpactsWater Quality during Construction Stage (cont.)



• The “Potential Impacts” section provides qualitative, not quantitative analysis. E.g The DEIA states :-

Source : KLORR DEIA, 2012






Mitigating measure have been proposed such as preparation of Erosion and Sediment Control Plan and construction of adequate erosion and sediment control structures (e.g. temporary drainage, check dams, silt fences and silt traps). However clarification is still needed for the following :-

a) TOR states projections in the increase in sediment load will be done through water quality modeling. The results of the modeling will be used to determine the impact on riverineecology, water intake point and recreational activities. This has not been carried out.

a) What is the increase in Total Suspended Solids (TSS) and turbidity in the rivers for various scenarios (e.g. worst case scenario, mitigating measures are 50% effective etc)?

(Note : According to the Water Quality monitoring results, all rivers were Class I or Class IIA rivers. This means that the rivers are pristine)




c) How many workers will occupy the workers’ base camp? What is the estimated sewage and sullage load? How will the water quality be affected with these loads?

d) How effective are the proposed mitigating measures? Examples on how the proposed mitigating measures have been able to reduce water pollution based on other case studies in Malaysia need to be provided.

Note : According to the Water Quality monitoring results (Page 4-102), all rivers were Class I or Class IIA rivers. This means that the rivers are pristine)

WWF-Malaysia’s Comments on Potential ImpactsOn Terrestrial Flora during Construction Stage



Section 7.2.9 (Pages 7-28 & 7-29)

a) This section does not state that there were endemic species found in the survey.

b) Mitigating measures does not address the necessary conservation measures that should be put in place to conserve rare and endemic species.E.gThe DEIA states “Based on the survey site clearance would indirectly impact upon a number of these endangered and other conservation concern species due to invasion of habitat”. (Page 7-29)No mitigating measures were proposed to mitigate this impact.

WWF-Malaysia’s Comments on Potential Impacts On Terrestrial Fauna during Construction / Operation Stages



Section 7.2.10 (Pages 7-30 to 7-34) and Section 7.3.7 (Pages 7-62 to 7-66)

The DEIA states “The existence of road within any of the forest areas will have an impact on wildlife movements, and roaming habitat on larger and medium mammal species”.

Source : KLORR DEIA, 2011 (Annex 1.1, Page 1-10)

This clearly does not comply with the condition stipulated in the Selangor MenteriBesar’s approval letter addressed to the Ketua Pengarah of Lembaga LebuhrayaMalaysia (for full letter, please refer to Annex 1.1 Pages 1-10 & 1-11 of the DEIA) This letter states :-



Other impacts listed in the DEIA include :-1) Forest fragmentation – The DEIA states that this will reduce habitat

for large mammals reduction in wildlife population. The DEIA states that the wildlife population needs to be maintained to prevent extinction.

2) Human wildlife conflict

3) PoachingMitigating measures proposed in the DEIA

WWF’s comments

Align road as close to or along to forest boundary

But the DEIA has not included this as an alignment option. Why?

Viaduct for wildlife crossing Why cause forest fragmentation in the first place? And then spend more money to mitigate by constructing viaducts?

Patrolling by Forestry & Wildlife Dept Who will absorb the cost associated with increase in patrolling efforts?

WWF-Malaysia’s Comments on Potential ImpactsOn Terrestrial Fauna during Construction / Operation Stages (cont.)

Impacts on fauna due to lighting and noise during operation stage is not identified in the DEIA.

Economic Evaluation of Environmental Impacts



Chapter 9According to the DEIA :The Economic Evaluation concludes that “The environmental benefits outweigh the environmental costs because of the significant environmental gain expected to be produced by the reduction of CO2 emission”. (Page 9-25)

Main argument is that with proposed project, carbon emission will be reduced due to higher speed of vehicles if the proposed KLORR is built.

WWF-Malaysia’s Comments

a) In general, the economic evaluation argument seems simplistic and has not taken into account various components

b) The DEIA does not seem to take into account cost due to reduction in water quality. Only the loss of recreational value of Hutan Lipur Ampang due to reduction in water quality is considered.

Assumption Mitigating measures implemented, so no reduction in water quality during operation stage This is an unacceptable assumption! What about the cost of reduction in water quality during construction stage?




WWF-Malaysia’s Comments

c) Assumptions used to model the CO2 emission rate with and without project are not stated





d) In WWF-Malaysia’s opinion, the Economic Evaluation has not :-i. Considered cost of loss of provisioning services such as provision

of waterii. Considered cost of loss of regulating services such as erosion

control, groundwater replenishment & flood mitigationiii. Considered cost of loss of supporting services such as

biodiversity conservation

Source : FAO website, 2012

Estimates of these costs are available and can be used e.g :

Other Comments



Indirect impacts of the proposed project is not assessed –

For example, when roads are constructed, areas along the road will be developed. The impacts of opening up of forested areas along theproposed KLORR is not assessed in the DEIA.

Conclusion



In WWF-Malaysia’s opinion the DEIA has major gaps and inadequacies.


Important to bear in mind

Remember that the project developer can submit a new DEIA if the current one is rejected.

Therefore if you have concerns about the project and the impacts, apart from submitting your comments on the DEIA it is also very important to voice your concerns on the project to the State and Federal governments.

Thank you

• wwf.org.my

proposed klorr detailed environmental impact...

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