DEIA - WWF Malaysia

A WWF-Malaysia (World Wide Fund for Nature)
Public Briefing On:
Proposed KLORR
Detailed Environmental
Impact Assessment
based on the recent Public Briefing
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
Introduction
Proposed 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.
Should a dangerous precedent be set allowing a
highway to pass through a Protected Area?
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
What can you do?
Voice concern about the project
Voice concern about the DEIA report
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
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).
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
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 the
Menteri Besar after going through layers of decision making. The
agencies 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 Perancang
Bandar & 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 Selangor
Source : KLORR DEIA (Chapter 2, Pages 2-10 & 2-11)
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
Why write to the Prime Minister
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.
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
What are the potential impacts of the proposed KLORR ?
1.
2.
Highly sensitive area (Selangor State park) will be affected!
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
Source : The Star January 2012
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
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
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
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.
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
Commenting on the DEIA (cont.)
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)
Project Options Proposed KLORR DEIA
A public briefing by WWF-Malaysia
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
Route Options – JICA Study (1996)
Source :KLORR DEIA, 2011 (Chapter 2, Page 2-3)
This table is
based on the
evaluation
criteria in the
1996 JICA
Report
Source : KLORR
DEIA, 2011
(Chapter 2, Page 28)
This table is based on the evaluation criteria in
the 1996 JICA Report
Source : KLORR DEIA, 2011 (Chapter 2, Page 2-8)
Source : KLORR DEIA, 2011
(Chapter 2, Page 2-10)
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
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)
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
Continuation….
Source : KLORR DEIA, 2011 (Chapter 2, Page 2-15)
Proposed KLORR DEIA
A public briefing by
WWF-Malaysia
Source : WWFMalaysia, 2012
Note : Map
produced by
WWF-Malaysia
based on
information
provided in the
KLORR DEIA
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
Source : WWFMalaysia, 2012
Note : Map
produced by
WWF-Malaysia
based on
information
provided in the
KLORR DEIA
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
Source : WWFMalaysia, 2012
Note : Map
produced by
WWF-Malaysia
based on
information
provided in the
KLORR DEIA
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
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)
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
WWF-Malaysia’s comments on Project Options
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.
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
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.
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
Water Catchment Forests
• Ampang and Hulu Gombak forests reserves were
re-classified as water catchment forests in 1999
Selangor State Park
• Selangor State Park was gazetted in 2007
• Harbours rich biodiversity and provides valuable
eco system services such as watershed
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
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.
Proposed KLORR DEIA
A public briefing by WWF-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
selangorstatepark.blogspot.com
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
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
selangorstatepark.blogspot.com
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
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 – Ampang
area which has a history of landslide and slope failure.
d) Possibility of slope failure especially for high cut slopes in granite
areas exists.
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
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
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
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)
The area covered of Forest Reserve along the corridor of the proposed project
Forest Reserve Areas
Covered area (ha)
Hulu Langat Forest Reserve
10.6
Ampang Forest Reserve
110.4
Hulu Gombak Forest Reserve
93.7
Source : KLORR DEIA, 2012 (Table 4.4.1, Page 4-57)
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
LANDUSE SECTION (cont.)
Landuse for interchanges
are explained in the DEIA
based on the proposed
interchanges. E.g
Source : KLORR DEIA, 2011 (Page 4-60)
WWF-Malaysia’s Comments on the Landuse Section
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
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
Source : KLORR DEIA, 2011
(Page 4-68)
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
WWF-Malaysia’s Comments on the Landuse Section (cont.)
b) No mention of water catchment forests
It is not mentioned anywhere in the landuse section that
the proposed alignment will cut through water
catchment forests.
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
WWF-Malaysia’s Comments on the Landuse Section
c) Good landuse maps are missing.
- Satellite images are provided - Difficult to ascertain importance of
the landuse in the affected area.
E.g
Source : KLORR DEIA, 2011 (Page 4-65)
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
WWF-Malaysia’s Comments on the
Landuse Section
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.
Source : KLORR DEIA, 2011 (Page 4-59)
WWF-Malaysia’s Comments on the Landuse Section
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.
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
FLORA SECTION (Section 5.2)
• 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
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Results
•Species diversity was found to be high in four out of five sectors
• Endemic species were found in all sectors
Information descriptor
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the numbers
•Critically endangered species were found in two sectors
•Endangered species were found in two sectors
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
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?
Information descriptor
- size of the sampling plot / length of trail walked
at each
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the numbers
location
- size of quadrats and distribution for the biomass survey
- elevation at each sector
- survey locations not marked in a map
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Proposed KLORR DEIA
A public briefing by WWF-Malaysia
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
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• Ampang FR known to harbour very rare species (the endemic,
Information descriptor
Codonoboea leucantha and the rare Begonia rhoephila) – not
in
Canmentioned
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the numbers
the DEIA
• Endemic plants to Klang Quartz Ridge not mentioned
• There are glaring errors in identification – how reliable is the overall
assessment?
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
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, lar
gibbon, Siamang, Giant squirrel, Prevost’s Squirrel, Black Giant
Information descriptor
Squirrel
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2) Most affected species are Tigers and tapirs which still roam in
the area
Proposed KLORR DEIA
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WWF-Malaysia’s Comments on the Fauna Section
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.
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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
any proper justification
Information descriptor
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below
inferred
without
the numbers
Proposed KLORR DEIA
A public briefing by WWF-Malaysia
WWF-Malaysia’s Comments on the Fauna Section
(cont)
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
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f) There seems to be some inaccuracies in identification
E.g
The Hylarana erythraea is mistakenly identified
as Hylarana labialis. (Appendix E of the DEIA)
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POTENTIAL IMPACTS & MITIGATING MEASURES
WWF-Malaysia’s Comments on Potential Impacts
Surface Hydrology during Construction Stage
Section 7.2.3 (Pages 7-13 to 7-16)
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 Klang
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Gates Dam in different scenarios?
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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?
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WWF-Malaysia’s Comments on Potential Impacts
Water 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 runoff containing water of high turbidity and high suspended solids (especially
on rainy days) due to the activities”
(Page 7-22)
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Information
“Inflated turbidity and sedimentation of Klang Gates Reservoir
anddescriptor
of Sg.
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belowwill
Ampang due to the polluted water of upper Sg. Klang and Sg. Ampang
the numbers
definitely cause public outcry”
(Page 7-22)
WWF-Malaysia’s Comments on Potential Impacts
Water Quality during Construction Stage (cont.)
• The
“Potential Impacts” section provides qualitative, not quantitative
analysis. E.g The DEIA states :-
Source : KLORR DEIA, 2011 (Page 7-24)
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Source : KLORR DEIA, 2012
Source : KLORR DEIA, 2011 (Page 7-24)
WWF-Malaysia’s Comments on Potential Impacts
Water Quality during Construction Stage (cont.)
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
riverine
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ecology, water intake point and recreational activities.
the numbers
This has not been carried out.
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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)
WWF-Malaysia’s Comments on Potential Impacts
Water Quality during Construction Stage (cont.)
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.
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Note : According to the Water Quality monitoring results (Page 4-102), all rivers were Class the
I or numbers
Class IIA rivers.
This means that the rivers are pristine)
WWF-Malaysia’s Comments on Potential Impacts
On 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.g
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The DEIA states “Based on the survey site clearance wouldCan
indirectly
the numbers
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.
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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”.
This clearly does not comply with the condition stipulated in the Selangor Menteri
Besar’s approval letter addressed to the Ketua Pengarah of Lembaga Lebuhraya
Malaysia (for full letter, please refer to Annex 1.1 Pages 1-10 & 1-11 of the DEIA) This
letter states :-
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Source : KLORR DEIA, 2011 (Annex 1.1, Page 1-10)
WWF-Malaysia’s Comments on Potential Impacts
On Terrestrial Fauna during Construction / Operation
Stages (cont.)
Other impacts listed in the DEIA include :1) Forest fragmentation – The DEIA states that this will reduce habitat
for large mammals Æ reduction in wildlife population. The DEIA
states that the wildlife population needs to be maintained to prevent
extinction.
2) Human wildlife conflict
3) Poaching
Mitigating measures proposed in
the DEIA
WWF’s comments
Align road as close to or along to
forest boundary
Viaduct for wildlife crossing
But the DEIA has not
included this as
Information descriptor
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an alignment option.Can
Why?
Patrolling by Forestry & Wildlife Dept
Who will absorb the cost associated
with increase in patrolling efforts?
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the numbers
Why cause forest fragmentation in the first
place? And then spend more money to
mitigate by constructing viaducts?
Impacts on fauna due to lighting and noise during operation stage is not
identified in the DEIA.
Economic Evaluation of Environmental Impacts
Chapter 9
According 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
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a) In general, the economic evaluation argument seems simplistic and has not taken into
account various components
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descriptor
b) The DEIA does not seem to take into account cost due to reduction in water
quality.
Only
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the loss of recreational value of Hutan Lipur Ampang due to reduction in water quality is
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considered.
Assumption Æ 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?
Economic Evaluation of Environmental Impacts
WWF-Malaysia’s Comments
c) Assumptions used to model the CO2 emission rate with and without
project are not stated
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Source : KLORR DEIA, 2011 (Page 9-18)
Economic Evaluation of Environmental Impacts
d) In WWF-Malaysia’s opinion, the Economic Evaluation has not :i.
Considered cost of loss of provisioning services such as provision
of water
ii.
Considered cost of loss of regulating services such as erosion
control, groundwater replenishment & flood mitigation
iii.
Considered cost of loss of supporting services such as
biodiversity conservation
Estimates of these costs are available and can be used e.g :
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the numbers
Source : FAO
website, 2012
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 the
proposed KLORR is not assessed in the DEIA.
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Conclusion
In WWF-Malaysia’s opinion the DEIA has major gaps and inadequacies.
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Proposed KLORR DEIA
A public briefing by WWF-Malaysia
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