Thursday, September 07, 2017

STATE GOVERNMENT MUST MEET RESIDENTS AFFECTED BY NORTH COASTAL PAIRED ROAD PROJECT

Press Release                                                                            7 September 2017

STATE GOVERNMENT MUST MEET RESIDENTS AFFECTED BY
NORTH COASTAL PAIRED ROAD PROJECT

The Tanjung Bungah Residents Association (TBRA) calls on the Penang State Government to have a dialogue session with all residents along the alignment of the North Coastal Paired Road (NCPR) from Teluk Bahang to Tanjung Bungah, project to explain full details of the road and seek their feedback.

In addition, the State must also explain all the alternatives that have been explored for the road, and the cost-benefit analysis for the NCPR, so that the affected people in the area are fully aware about the State Government’s reasoning for the road project.

Such a dialogue session will be in the spirit of the State Government being transparent and accountable to the people of Penang.

Our call is in view of recent comments by State Works Committee Chairman, Lim Hock Seng in response to the appeal by TBRA for the NCPR to be scrapped.

According to recent press reports, Lim said that the State had considered all the alternatives to the road access to Teluk Bahang and Batu Ferringhi before arriving at the decision to proceed with the NCPR.

Lim was also reported to have said that the first phase of the NCPR is from Batu Ferringhi to Tanjung Bungah, which, according to him, is most urgent to be constructed.

He was also reported to have said that there is a plan to build a viaduct from Lembah Permai (in Tanjung Bungah) to Seri Tanjung Pinang.

Our response is that this plan for the viaduct was nowhere mentioned in the Environmental Impact Assessment for the NCPR.  

Such a viaduct is bound to have serious implications both socially and environmentally, which should also have been considered in the EIA.

What is its alignment and which communities and residential areas are going to be affected?

These are matters that must be clarified urgently.

Obviously, the State Government is not making matters clear and causing a lot of anxieties among the residents of Tanjung Bungah.

Furthermore, the EIA for the NCPR did not reveal all the alternatives that were considered by the State Government, which in our view, is a major flaw.

According to the guidelines for EIAs, a proper EIA for the project should have considered the alternatives or project options properly, including providing the basis for the elimination of options which are considered as unreasonable. 

Since this has not been done, the Department of Environment (DOE) should not approve the EIA as it is currently.

The first phase of the NCPR (from Batu Ferringhi to Tanjung Bungah) will involve thousands of residents being affected who live along the corridor of the road alignment which include Taman Leader Condominium, Jalan Chee Seng 8, Taman Tanjung Bungah, Jalan Chee Seng, Surin Condominimum, Coastal Tower, Desa Mar Vista Apartment, Beverly Hills, Shamrock Beach, Sri Sayang Service Apartment, Ferringhi Delima Condominium, and Kg. Batu Ferringhi.

Many of the residents are unaware as to the implications of the road project on their quality of life.

The ‘saving’ of 14 minutes of time travelled between Tanjung Bungah and Teluk Bahang at a cost of RM 1 billion for the NCPR will soon vanish once more traffic demand is generated by the new road in the coming years.

We are also puzzled why the NCPR has to be a four-lane dual carriage way?
Building more roads is never a sustainable solution, as more roads bring more cars. Finding truly sustainable transport options that move people instead of private cars is the only way forward for a truly greener Penang.

It therefore incumbent on and imperative for the State Government to be fully transparent on the need for the NCPR, the implications of this to the residents affected by the road and what alternatives were considered and deemed not feasible.




Chairperson,
Tanjung Bungah Residents Association
Phone: 012-4300042








  

Monday, September 04, 2017

Queries are coming in from residents in Tanjung Bungah who want to join TBRA. Life membership is RM 100 and you can get the form from this blogspot. See right hand column.

You can fill up the form and pass your cheque to Annalies Alain who can be contacted during off hours from 9 am to 5 pm at 11, Jalan Oldham, near Indian Temple along Tanjung Bungah road - opposite kintergarten.

Meena Raman
TBRA Chair
Visit http://www.thestar.com.my/news/nation/2017/09/04/residents-we-don't-want-that-road-fears-arise-about-impact-of-route-on-forest-reserves-and-slope-stab/

for coverage of TBRA press conference on NCPR road held on 3 Sept 2017







THIS IS THE PRESS STATEMENT RELEASED ON THE NORTH COASTAL PAIRED ROAD AT THE PRESS CONFERENCE ON 3 SEPT AT THE TANJUNG BUNGAH MARKET.


  
Date:     3 September 2017


PRESS STATEMENT

SAVING 14 MINUTES OF TIME AT COST OF RM 1 BILLION IS NO JUSTIFICATION FOR TANJUNG BUNGAH-TELOK BAHANG COASTAL ROAD – SAYS TBRA

The Tanjung Bungah Residents’ Association (TBRA),which represents residents in the Tanjung Bungah area, appeals to the Penang Chief Minister to scrap the proposed construction of the North Coastal Paired Road (NCPR) from Tanjung Bungah to Telok Bahang.

The TBRA makes this call after studying the Environmental Impact Assessment (EIA) for the road. In our comments on the EIA which were submitted to the Department of Environment (DOE) on the 31 July 17, we called on the DOE not to approve the EIA.   The comments were also forwarded to the Chief Minister on the 21st of August 17.

Among the reasons for the call to scrap the project include the following:

1.    ‘Saving’ 14 minutes of time travel is no justification for the proposed road; no proper cost-benefit analysis done

The NCPR will be 10.53 km long, (with 8.255 km at grade and 2.275 km which is elevated), with a dual two lane carriageway involving 4 lanes.

According to a speech by the Chief Minister of Penang in 2011, the NCPR is estimated to cost RM 518 million. (https://www.penang.gov.my/dmedia/879-penang-investment-seminar). 

This was the estimate in 2011 and is the cost of construction only. If the cost of land acquisition is taken into account, according to reliable sources, the NCPR is expected to cost RM 1 billion.  This cost does not include the money spent on conducting feasibility studies for the road which is many more million ringgit.

The EIA claims that “the travel time from Tanjung Bungah to Teluk Bahang using the existing road ranges from 20-23 minutes” and that the “proposed highway will reduce journey time to 9 minutes with vehicles able to travel at an average speed of 70 km/hr.”

This means there will be a ‘saving’ at best of 14 minutes of the time travelled between Tanjung Bungah to Teluk Bahang. 

Spending such a huge amount of public resources to ‘save’ 14 minutes of time travelled is a colossal waste of public resources and cannot be justified economically, environmentally and socially.

The EIA ought to have done a proper cost-benefit analysis to justify the need for the road, but it has neglected to do so.

Options such as improving public transport and alternative modes of transport as well as upgrading existing roads should have been properly considered, as part of the ‘no-build’ option, instead of just claiming that the ‘no-build’ option is not an option.

2.    Proposed road will not solve traffic congestion in Tanjung Bungah

In fact, the NCPR will not solve the traffic congestion in Tanjung Bungah and is likely to aggravate it, which is contrary to the purported claim of easing traffic congestion.

This is the case as the road ends abruptly in Lembah Permai. Where the traffic will be diverted to, is not discussed at all, which means all the vehicles will end in a bottleneck in Tanjung Bungah.

Hence, the claim in the EIA that this proposed road “will address the traffic congestion in Penang” is not true at all. In this regard, the EIA fails to demonstrate how the project will fulfil an existing need. 

Further, the EIA reveals that there will be 10 interchanges between Batu Ferringhi and Tanjong Bungah. That is far too many for the supposed intention of the road to “address the traffic congestion”.

3.    No proper public consultations: Public perception survey flawed

The perception survey done by the EIA consultants is very seriously flawed. Only 322 persons were involved in the survey in relation to the NCPR. Consequently, based on such a small sample size and the lack of more comprehensive consultations, we are unable to accept the EIA conclusion that 69% of the persons surveyed agree with the proposed road.

This figure is misleading due to the small sample size as well as the lack of consultation of people who will be most affected by the road alignment.

The survey is indeed seriously flawed and many who live along the NCPR alignment and its corridors are not agreeable to the project. This is evidenced by the 400 plus signatures collected in a very short timeframe among residents living in the vicinity of NCPR who have objected to the road.

4.   Failure to assess impacts of noise mitigation measures 

The EIA recognises that many communities along the NCPR will be affected by noise and vibration.

The locations requiring noise barriers (listed in Table 8.7) include Taman Leader Condominium, Jalan Chee Seng 8, Taman Tanjung Bungah, Jalan Chee Seng, Surin Condominimum, Coastal Tower, Desa Mar Vista Apartment, Berverly Hills, Shamrock Beach, Sri Sayang Service Apartment, Ferringhi Delima Condominium, and Kg. Batu Ferringhi.

Given the nature of the noise barriers described in the EIA, what is needed are semi-closed and fully-closed structures. The EIA fails to assess the impacts of these noise barriers on the quality of life of especially of those residents living in the high-rise condos and apartments described above.

There is also no proper assessment of how residents will be impacted by unhealthy noise levels from the elevated sections of the proposed road and negative impacts from the appearance of concrete walls and structures impairing their vistas.

In fact, in the EIA states that “residents in the high rise building will no longer see clear sky but in place, an elevated road passing near their homes and change (to the) visual aesthetics of the area.”

This relates to the impairment from the elevated highway itself but there is no consideration of the impact on the visual aesthetics by the noise barriers themselves. Such mitigation measures will definitely be unacceptable to the people residing along these concrete noise barrier structures.

5.    Impacts of air pollution not adequately considered

In relation to air pollution, the EIA (in Table 7.14) refers to the maximum incremental concentration of carbon monoxide, nitrogen oxide and particulate matters.

It also states that “the predicted 1 hour maximum concentration …is less than 133.1 µg/m3   for particulate matters.” What this means is unclear as this could be 100 µg/m3 or 10 µg/m3.

We are advised by experts that an incremental concentration increase of even 1 µg/m3 would be associated with significant health impacts, including increased risk of premature mortality. The EIA does not provide the information needed to properly assess the impact on public health of the project’s impact on air quality.

6.   Development on sensitive hill-land not justified

The EIA reveals that about 46% of the proposed road will be on terrain with a higher than 25 degree slope. Slopes above 25 degrees are well known to be ‘sensitive hill lands’ and should not be used for the proposed road.

In fact, the Penang Structure Plan 2020 generally prohibits hill land development except for very limited and justifiable exceptions, which in the case of this road, does not appear to be justifiable.

It is clear from the EIA that the risks are high from the proposed road which can lead to landscape disturbances and instability of slopes.

Mitigation measures are suggested but whether they will indeed prevent the occurrence of slope failures, landslides and landslips cannot be guaranteed. Previous studies in Malaysia have shown that most landslides are in man-made slopes and are mainly due to design deficiencies and poor maintenance.

The effect and impact of slope failures, landslides and landslips on the communities living along the road corridors has not been considered and is also a serious omission.
   
7.    Impact of immense cuttings of waste not properly assessed

The EIA states that extensive cuttings will be involved where there will be about 10.6 million cubic metres of cuts.  The EIA has failed to address the disposal of this vast amount of cut material which also presents a major problem to the residents in the vicinity of such earthworks.

8.   Destruction of forests in water catchment areas and highlands

The EIA also shows that about 3.34 ha (about 8.3 acres) of forests will be affected by the proposed road as it passes through the Teluk Bahang Forest Reserve and the Bukit Kerajaan Forest Reserve, which include water catchment areas and highland forests.

Allowing the NCPR to invade such environmentally sensitive areas is too much of a price to pay for its so-called ‘benefit’.

9.    Loss of valuable recreation space and green lung

Objections have been raised by residents living along the NCPR and its vicinity, where the tree lined existing road, hills and waterfall along the proposed alignment at Leader Garden, Surin Condominium and other condos nearby are the last remaining green lungs in the area for many in the Tanjung Bungah area in its surroundings.

At least a 100 people, if not more, use the place for daily walks & exercise, enjoying its tranquility, beauty and serenity.  The proposed road will irreparably change this space that has become a very popular public recreation area into a major highway that will completely transform and destroy our peace and ambiance.

This fact about the recreational use of this area is no-where mentioned in the EIA and is a major omission.

Clearly, the so-called ‘benefit’ of saving a few minutes is far outweighed by the massive 
negative impacts the proposed road will have on our lives, our communities, our well-being and our environment.

In this regard, we have appealed to the DOE to not approve the EIA for the NCPR for the reasons mentioned above and also reiterate out call to the Chief Minister to scrap the NCPR.

Meenakshi Raman
Chairperson,
Tanjung Bungah Residents Association
Phone: 012-4300042



Sunday, August 27, 2017

Summary of the Petition submitted by TBRA to DOE

Summary of the Petition submitted by TBRA to DOE against the proposed Paired Road from Tanjong Bungah to Telok Bahang
The residents of Tanjong Bungah and surrounding areas object to the
construction of the proposed road for the following reasons:
  1. Residents have not been properly informed about the project. The 322 population sample reportedly used to justify the acceptance of the project is not representative of the residents who will be impacted by these roads.
  2. Hill clearing and cutting forest reserves in this sensitive and steep slope area will cause soil erosion, flash floods and have a negative impact on water resources.
  3. Chee Seng Garden with its many condominiums is already densely populated. Additional traffic into this area will worsen congestion. Moreover, air pollution, dust, noise and vibration will affect residents’ quality of life and impact on their physical and mental health.
  4. The proposed alignment will destroy a vital green lung there. Part of the road has been reclaimed by residents who use it in their hundreds every day for exercise and recreation enjoying the hills and waterfall. Extending the road to Lemba Permai will destroy the beauty and serenity of this area for little benefit.
  5. The EIA shows the Paired Road stopping abruptly at Lemba Permai inevitably causing a new bottleneck in Tanjong Bungah. It claims to save 14 minutes of travel time from Batu Ferringhi but does not continue to improve the alternative exit via Mount Erskine.
  6. The Assessment reveals TEN interchanges between Batu Ferringhi and Tanjong Bungah. That is far to many for the supposed intention of the road (“address the traffic congestion”) and leads us to suspect that the real intent is to open up more hill land for the construction of high rises and high price bungalows.
We appeal to the Department of Environment to stop this project which will not ease traffic but bring more problems to Tanjung Bunga residents. Alternative plans such as improving public transport and upgrading existing roads should be looked into.

TBRA,  4 August 2017

Tuesday, August 01, 2017



PLEASE FIND BELOW THE TBRA COMMENTS SUBMITTED TO THE DEPARTMENT OF ENVIRONMENT ON 31 JULY 2017 ON THE ENVIRONMENTAL IMPACT ASSESSMENT OF THE NORTH COAST PAIRED ROAD (NCPR) FROM TELUK BAHANG TO TANJUNG BUNGAH





Date:     31    July 2017

KETUA PENGARAH
Jabatan Alam Sekitar,
Kementerian Sumber Asli & Alam Sekitar,
Aras1-4, Podium 2 &3 ,Wisma Sumber Asli,
No 25 , Persiaran Perdana , Presint 4
62574 PUTRAJAYA.

(u.p: Unit EIA- Urusetia EIA)


COMMENTS RE: ENVIRONMENTAL IMPACT ASSESSMENT FOR PROPOSED CONSTRUCTION OF PACKAGE 1 (WHICH IS THE NORTH COASTAL PAIRED ROAD) FROM TANJUNG BUNGAH TO TELOK BAHANG

The Tanjung Bungah Residents’ Association (TBRA) represents residents in the Tanjung Bungah area.  

We are aware that over 400 residents living around Package 1 (also known as NCPR) and its vicinity, have also submitted their comments on the EIA and we too support them and incorporate the views herein. We also make additional observations which we hope will be considered and regarded very seriously.

We hereby provide our comments to the EIA in respect of the NCPR from Tanjung Bungah to Telok Bahang.

1.    No proper public consultations: Public perception survey flawed
The perception survey done by the EIA consultants is very seriously flawed.

Only 322 persons were involved in the survey in relation to Package 1, and this population sample used to study the acceptance of the project is extremely small and does not represent the majority of the residents who will be impacted by the road.

Those who live along the corridors of the road were not properly consulted at all. A more comprehensive survey ought to have been done, which should have comprised of mainly people living along the corridors of the road alignment.

Many persons we spoke to were not aware about the details of the proposed alignment of the road and the EIA that we viewed is also not clear on the exact details in this regard.

This clearly shows that proper public consultations should have been carried out, with details provided, especially to those will be adversely affected particularly from noise and air pollution in addition the loss of vista.

Consequently, based on such a small sample size and the lack of more comprehensive consultations, we are unable to accept the EIA conclusion that 69% of the persons surveyed agree with the proposed road.

This figure is misleading due to the small sample size as well as the lack of consultation of people who will be most affected by the road alignment.

The survey is indeed seriously flawed and many who live along the NCPR alignment and its corridors are not agreeable to the project. This is evidenced by the 400 plus signatures collected in a very short timeframe among residents living in the vicinity of Package 1 who have objected to the road.

Hence, the EIA conclusion that 69% of the persons consulted in Package 1 are agreeable to the project is grossly misleading and should not be basis for approving the EIA.
   
2.    ‘Saving’ 14 minutes of time travel is no justification for the proposed road; no proper cost-benefit analysis done

The NCPR will be 10.53 km, (with 8.255 km at grade and 2.275 km which is elevated), with a dual two lane carriageway involving 4 lanes.

According to a speech by the Chief Minister of Penang in 2011, the NCPR is estimated to cost RM 518 million. (https://www.penang.gov.my/dmedia/879-penang-investment-seminar). 

This was the estimate in 2011 and is the cost of construction only. If the cost of land acquisition is taken into account, according to reliable sources, the NCPR is expected to cost RM 1 billion.  This cost does not include the money spent on conducting feasibility studies for the road which is many more million ringgit.

At page 4.10, table 4.12, the EIA claims that “the travel time from Tanjung Bungah to Teluk Bahang using the existing road ranges from 20-23 minutes” and that the “proposed highway will reduce journey time to 9 minutes with vehicles able to travel at an average speed of 70 km/hr.”

This means there will be a ‘saving’ at best of 14 minutes of the time travelled between Tanjung Bungah to Teluk Bahang. 

Spending such a huge amount of public resources to ‘save’ 14 minutes of time travelled is a colossal waste of public resources and cannot be justified economically, environmentally and socially.

On the other hand, the costs involved especially to the thousands of people living along the road alignment, as well as to the environment, and the cost borne by the State for the project (which will be borne by the people of Penang), is much more immense and significant. Surely there can be alternative solutions at much less the cost which have not at all be considered in the case of Package 1.

The EIA ought to have done a proper cost-benefit analysis done to justify the need for the road, but it has neglected to do so. What has been provided is only an economic valuation in relation to the environmental services involved. This is grossly insufficient.

The EIA claims that the ‘no-build’ option is not an option (at page 4.10) as “…it will further aggravate the traffic congestion…”. This is in reference to the Penang Transport Master Plan (PTMP), 2013-2030 as a whole, and is not specific to the road projects. The PTMP has many components and is not confined to the road projects.

Hence, the need for Package 1 is not justified adequately or effectively and represents another flaw in the EIA.

Cheaper options such as improving public transport and alternative modes of transport as well as upgrading existing roads should have been properly considered, as part of the ‘no-build’ option, instead of just claiming that the ‘no-build’ option is not an option.
In fact, the proposed NCPR will not solve the traffic congestion in Tanjung Bungah and is likely to aggravate it, which is contrary to the purported claim of easing traffic congestion. This is the case as the road ends abruptly in Lembah Permai. (See point below.)

3.    Proposed road will not solve traffic congestion in Tanjung Bungah

To make matters worse, the proposed road ends abruptly in Lembah Permai. Where the traffic will be diverted to, is not discussed at all, which means all the vehicles will end in a bottleneck in Tanjung Bungah, hence not solving the daily congestion at peak hours already confronting commuters and people living along existing roads.

Hence, the claim in the EIA that this proposed road “will address the traffic congestion in Penang” is not true at all.

In this regard, the EIA fails to demonstrate how the project will fulfil an existing need. 

4.   Failure to assess impacts of noise mitigation measures  

The EIA recognises at page 7.7 (executive summary) that the following communities will be affected by noise and vibration such as Leader Garden, Surin Condo, Taman Tanjung Bungah, Waterfront Condo, Coastal Tower, Desa Mar Vista Apartment (in Tanjung Bungah) and others in Batu Ferringhi.

Further, in section 8.70 (page 8.32), the EIA states that “in the context of the proposed roads….moderate to high noise reduction performance would be required of the barriers…such that the recommended noise criteria could be met.” Section 8.71,  describes some options and says that “…it was noted that for typically high-rise building in close  proximity to the highways, it may require up to category 3 (semi closure structures) or 4 (full enclosures) in order to mitigate the traffic noise at these sensitive locations (especially at locations with quite ambient noise).”

The locations requiring noise barriers are listed in Table 8.7 which in Package 1 include Taman Leader Condominium, Jalan Chee Seng 8, Taman Tanjung Bungah, Jalan Chee Seng, Surin Condominimum, Coastal Tower, Desa Mar Vista Apartment, Berverly Hills, Shamrock Beach, Sri Sayang Service Apartment, Ferringhi Delima Condominium, and Kg. Batu Ferringhi.

Given the nature of the noise barriers described in section 8.71 which requires semi-closed and fully-closed structures, the EIA fails to assess the impacts of these noise barriers on the quality of life of especially of those residents living in the high-rise condos and apartments described above.

This in our view, is a major omission, as there is no proper assessment of how residents will be impacted by unhealthy noise levels from the elevated sections of the proposed road and negative impacts from the appearance of concrete walls and structures impairing their vistas.

In fact, in section 7.44 (page 7.7), the EIA states that “residents in the high rise building will no longer see clear sky but in place, an elevated road passing near their homes and change (to the) visual aesthetics of the area.” This relates to the impairment from the elevated highway itself but there is no consideration of the impact on the visual aesthetics by the noise barriers themselves.

Such mitigation measures will definitely be unacceptable to the people residing along these concrete noise barrier structures.

5.    Impacts of air pollution not adequately considered

In relation to air pollution, Table 7.14 refers to the maximum incremental concentration of carbon monoxide, nitrogen oxide and particulate matters.

It also states in section 7.200 that “the predicted 1 hour maximum concentration for Package 1 is less than 133.1 µg/m3   for particulate matters. What this means is unclear as would this be 100 µg/m3 or 10 µg/m3?  We are advised by experts that an incremental concentration increase of even 1 µg/m3 would be associated with significant health impacts, including increased risk of premature mortality.

Hence, the EIA does not provide the information needed to properly assess the impact on public health of the project’s impact on air quality.

The impact on public health is critical. However, the information is lacking in this regard in the EIA and is another major omission.

6.   Development on sensitive hill-land not justified

The EIA reveals that about 46% of the proposed road will be on terrain with a higher than 25 degree slope. Slopes above 25 degrees are well known to be ‘sensitive hill lands’ and should not be used for the proposed road.

In fact, the Penang Structure Plan 2020 generally prohibits hill land development except for very limited and justifiable exceptions, which in the case of this road, does not appear to be justifiable.

In section 7.10, the EIA states that it is “imperative… that huge cuttings of hill sides should be minimised which will introduce disturbance to the landscape…”. At section 7.16, it further states that “initial cuttings involve very steep slopes …” in the Tanjung Bungah area and that “this will require substantial slope treatment or mitigation measures against future instability or localised failures.”

It is clear from the above that the risks are high from the proposed road which can lead to landscape disturbances and instability of slopes.

Mitigation measures are suggested but whether they will indeed prevent the occurrence of slope failures, landslides and landslips cannot be guaranteed. 

Previous cases of slope failures and landslides are many in Malaysia on major highways such as the North-South Expressway, (one being near Guar Tempurung in 2004), the PLUS Expressway at Bukit-Lanjan (2003), the Gerik-Jeli East-West Highway and the Karak Highway to name just a few.   

Previous studies in Malaysia have shown that most landslides are man-made slopes and are mainly due to design deficiencies and poor maintenance.

The effect and impact of slope failures, landslides and landslips on the communities living along the road corridors has not been considered and is also a serious omission.    

7.    Impact of immense cuttings of waste not properly assessed

Given the nature of the terrain involved in Package 1, the EIA in section 7.9 states that extensive cuttings will be involved in Package 1, involving about 10.6 million cubic metres of cuts. 

In section 7.12 the EIA states that “the transportation of the cart away will itself present massive logistical problems.” Further, in relation to Teluk Bahang, it states that “the formation of the slope will require removal of earth and rocks/boulders that may require blasting”.
The issue of how and where to dispose 10 million cubic meters of cuttings is significant environmental problem. The EIA has failed to address the disposal of this vast amount of cut material also presents a social problem to the residents in the vicinity of such earthworks. This represents yet another serious flaw in the EIA.

8.   Destruction of forests in water catchment areas and highlands

The EIA also shows that about 3.34 ha (about 8.3 acres) of forests will be affected by the proposed road as it passes through the Teluk Bahang Forest Reserve and the Bukit Kerajaan Forest Reserve, which include water catchment areas and highland forests.

Allowing the NCPR to invade such environmentally sensitive areas is too much of a price to pay for its so-called ‘benefit’.  

9.    Loss of valuable recreation space and green lung

As pointed out by the objections raised by over 400 residents living along the NCPR and its vicinity, the tree lined existing road, hills and waterfall along the proposed alignment at Leader Garden, Surin Condominium and other condos nearby are the last remaining green lungs in the area for many in the Tanjung Bungah area in its surroundings.

At least a 100 people, if not more, use the place for daily walks & exercise, enjoying its tranquillity, beauty and serenity.  The proposed road will irreparably change this space that has become a very popular public recreation area into a major highway that will completely transform and destroy our peace and ambience.

This fact about the recreational use of this area is no-where mentioned in the EIA and is a major omission.

Clearly, the so-called ‘benefit’ of saving a few minutes is far outweighed by the massive negative impacts the proposed road will have on our lives, our communities, our well-being and our environment.

In this regard, we appeal to the DOE to not approve the EIA for the NCPR for the reasons mentioned above.

We sincerely hope that our comments will be seriously taken into account.
Thank you.



Meena Raman

Chairperson,
Tanjung Bungah Residents Association