What is Penang Forum’s stand on the Seri Tanjung Pinang Phase 2 project? Penang Forum rejects the Detailed Environmental Impact Assessment of the project because of its flawed assumptions, methodologies, calculations, and inconsistencies. We find that the harm outweighs the benefits.
Thus this Detailed EIA is NOT acceptable and should NOT be approved.
This is part one and two of a five-part media statement issued by the Penang Forum Steering Committee on 3 April 2014:
1. Impact on marine biology and fisheries
a) The DEIA is deficient and misleading in investigating and reporting on the impact of the STP2 project on the marine biology and fisheries in the area. The marine biology study was conducted at five sampling stations despite the undertaking made to the TOR Panel Review for the DEIA to increase the sampling coverage along extended transects and at multiple depths in the water. There is also no mention of sampling dates and frequency of sampling, given that occurrence and densities of mobile aquatic organisms can vary within a day and with season.
b) A map of fishing grounds shown repeatedly in the DEIA report is grossly misleading as it provides only a partial coverage of the fishing locations of the Tanjung Tokong fishers and omits altogether other fisher communities along the north coast i.e. Gurney Drive, Paramount and Tanjung Bungah.
c) The DEIA also under-estimates and under-values the project’s impact on fisheries while overstating the ease of mitigating this impact.
First, not enough detail is provided in the calculations for valuation of the direct use value of the mudflats for a proper check on the reported figures.
Second, computing the value of fisheries catch per hectare of mudflats based on the total mudflat area in Peninsular Malaysia is a gross under-estimation because not all mudflat areas are accessible and actively fished.
Third, the estimate of loss is done only for the 328ha of mudflat directly affected by the creation of the island and the reclamation along Gurney Drive but omits areas that will be off-limits to fishers during the five years of project implementation and after project completion.
Fourth, there are gross underestimations of losses to fishermen e.g. valuing shrimp at US$200/tonne when prices have already hit US$20/kg (or US$20,000/tonne) in February 2014.
Fifth, the DEIA valued the mudflats based on its direct use (i.e. direct harvest of seashells and shrimp) and wrongly equated this estimate with the total ecosystem service value. It has not considered a larger indirect use value of the mudflats as breeding and feeding grounds for many other fish species that are caught further offshore.
d) The DEIA does not cover the environmental impact of excavating 33.1 million m3 of sand (enough to form an island that is 85 per cent the size of Pulau Jerejak) from off the Perak coast, a mere 40km west of Pulau Pangkor, which is also an important fishing ground for Perak fishers. Hence there is a hidden value associated with off-site impact on the fisheries around and beyond the project site within Penang and Perak waters that adds to the gross under-estimation of the project’s impact on fisheries.
2. Impact on livelihood of fisher folk
The DEIA report is callous and equally dismissive in its treatment of affected fisher folk and birds in supposing that they can go seek new grounds to sustain their living. It conveniently transfers the responsibility for helping the fisher folk to other government organisations like LKIM and USM to seek new fishing grounds and aquaculture sites.
It is naive to suppose there are new fishing grounds when the entire inshore fishing area within reach of the affected artisanal fishermen is already over-fished. It is also equally naive to suggest that fishermen can be relocated to operate pond aquaculture in Sungai Pinang West and cage culture in the southern channel between Penang Island and Seberang Perai.
No costs – financial and social – are evaluated for displacing people who have lived all their lives in the north coast to areas already occupied by others to engage in livelihood activities that are totally alien to them. The only compensation suggested for the fishermen is for additional fuel costs for their boats to go further afield on their fishing trips. It is not even clear for how long this compensation will be provided, nor is there recognition of lost time and opportunity costs, as well as the possibility of reduced catch per unit effort.