The Tanjung Bungah Residents Association has released the following statement: 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’ 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 department not to approve the EIA. The comments were also forwarded to the chief minister on the 21 August 2017. Among the reasons for the call to scrap the project include the following:

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

The road will be 10.53km long, (with 8.255km at grade and 2.275km elevated) with a dual two-lane carriageway involving four lanes. According to a speech by the chief minister of Penang in 2011, the road is estimated to cost RM518m. 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 road is expected to cost RM1bn. 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 done 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.

Proposed road will not solve traffic congestion in Tanjung Bungah

In fact, the road 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”.

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 road. 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 per cent 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 road 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 the road who have objected.

Failure to assess impacts of noise mitigation measures

The EIA recognises that many communities along the road 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.

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.

Development on sensitive hill-land not justified

The EIA reveals that about 46 per cent 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 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.

Impact of immense cuttings of waste not properly assessed

The EIA states that extensive cuttings will be involved where there will be about 10.6m 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.

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

Loss of valuable recreation space and green lung

Objections have been raised by residents living along the proposed road 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 and its surroundings. At least a hundred 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 nowhere 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 wellbeing and our environment. In this regard, we have appealed to the DoE to not approve the EIA for the proposed road for the reasons mentioned above and also reiterate out call to the Chief Minister to scrap the road. Meenakshi Raman is chairperson of the Tanjung Bungah Residents Association.