The deadline for Environmental Impact Assessment (EIA) comments is the 31st of July. While the term EIA sounds daunting everyone has the right to comment on this document.
To help regular folks like ourselves out, we have summarised the "problems" with the EIA out with 14 points of concern. Click here to view whole document or scroll down.
We have also composed a sample letter you can use to write your concerns to the Department of Environment (DOE). Click here or scroll down.
However, these letters MUST REACH THE DOE BY SATURDAY THE 31ST OF JULY. To make sure that these letters reach DOE by Friday, you can fax it directly to us at 088-244502. We will make sure it gets to the DOE by Friday.
These letters are extremely important but they need to be signed hence the faxing. They also need to have your name and IC number. If you need to send them via email please do so to nocoal.sabah@gmail.com but you will need to scan the letter as the letter needs your signature.
Whether you are Malaysian or not, please do take the time to write.
NOW IS THE TIME OF ACTION, OF MAKING A DIFFERENCE. LET'S DO IT.
Points of concern
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Comments on Detailed Environmental Impact Assessment (DEIA) for
the 300MW Coal-Fired Power Plant in Sinakut, Lahad Datu, Sabah.
Key points for public comments:
1. One of the objectives for the DEIA is to improve on the environmental design of the project. However, the public or technical people are unable to assess the environmental design as it is not outlined/described and it is therefore difficult to know the efficiency of the plant. For instance, the DEIA does not specify the type of plant parts used. To assess the plant, we need to know types of parts used for the coal plant as the type used will determine efficiency of the plant in the waste generated.
2. The potential mitigation measures mentioned in the DEIA are shallow and general. One of the objectives of the DEIA is to facilitate informed decision making. However, the DEIA report does not allow for this as there is a lack of basic design details, poor data on the marine environment, and assumptions of sufficiency based on no data are unacceptable at this level of review and assessment.
3. Compensatory mitigation for impact on marine environment, loss of income, health impact, greenhouse gases and others are completely overlooked.
4. Earthquake risk: It is inaccurate to say that the site is safe from earthquake tremors. The whole Dent peninsula is within the 40-100 kilometre range of earthquake tremors generated onshore and offshore. In April 2008, an earthquake at the Celebes Sea caused tremors in the Tungku area, near the proposed site. This resulted in cracks on several buildings including SMK Tungku and Hospital Tungku. A New Sunday Times article on 20th May 2007 quoted Sabah Mineral and Geoscience Department director Alexander Yan as saying Sabah has experienced 78 quakes in the last century.
5. Sampling done for the DEIA do not cover a wide enough range of sites to give a full understanding of the site and its surroundings. In short, sampling site chosen are not good enough to represent the area. In assessing the marine area, only two days were taken for sampling and why certain sites were chosen were not indicated. A habitat map showing sand, mud/silt, seagrass, rocks, corals and areas of high benthic diversity should have been done. Comparisons are made with far away locations and coral ecosystems instead of similar habitats. This is misleading.
6. There is no mention that Darvel Bay is home to resident and migratory marine animals like turtles, whale sharks, dolphins, dugongs and others.
7. Fish species used in the report as indicators are not representative of species found at the site. The species list should have been modified to cover locally common, unique or commercially important species.
8. There will be a large impact on larvae fish according to the study, but that there will be no impact on adult fish. It is misleading for the DEIA to state that there is no impact on adult fish as larvae wont have a chance to grow. Marine zones like seagrass, mudflats and mangroves are spawning areas for fish and crustaceans. Impact on fish larvae will effect fish populations over a wider area.
9. In its list of mammal species, the report stated two mammals that are not present in Sabah. The two are wild pig (Sus scrofa) and Dusky langur (Semnopithecus obscurus). In its list of bird species, the White rumped shama is not present in Sabah.
10. There is a lack of assessment and interpretation of results on phytoplankton. The report calculates Boyd’s Biodiversity index for phytoplankton and shows it to have a value approaching that of pristine waters, but this is not indicated.
11. The socio-economic study is doubtful. It states that the community in Kampung Sinakut are squatters, which cannot be the case for a traditional village with a village headman. The DEIA also states that “Orang Sungai” are of Indonesian descent. This clearly shows ignorance on the part of those doing the study.
12. A baseline study shows that acid rain is already present at the site with a pH of 4.66. There is a need to further study why acid rain is happening in the area. It is also wrong to compare agriculture and forested Dent peninsula with Petaling Jaya which is industrialised and urbanized.
13. Climate change as a major impact is not mentioned. The scope of the DEIA should include measures to minimise/mitigate greenhouse gas emissions from the proposed project.
14. Despite repeated newspaper articles that mention clean coal technology will be used, there is no mention of it in the DEIA. This is a cause of grave concern. Also there is no such thing as “clean coal technology” today hence it is extremely misleading to use this term.
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Sample letter
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xxst July 2010
To:
The Department of Environment, Malaysia.
Comments on the Detailed Environmental Impact Assessment for the 300 MW coal-fired power plant in Lahad Datu, Sabah.
Having read the DEIA report that was put up at some public places, I have a number of concerns on the overall project. There are glaring technical issues:-
• the existing physical environment has been wrongly represented by the consultants, thereby misleading the public;
• the full adverse impacts from the plant has not been discussed analytically,
• identification of species that do not exist in Sabah have been listed, and
• that potential mitigation measures are shallow and too general.
This does not allow me to assess the real situation. In short, the whole study is faulty and should be dismissed.
I would like to single out some points which I feel are important to Sabah’s tourism industry and our potential as a seafood basket for the nation and region. The following are my comments:
1. There is no mention that Darvel Bay is home to resident and migratory marine
animals like turtles, whale sharks, dolphins, dugongs and others.
2. Fish species used in the report as indicators are not representative of species found at the site. The species list should have been modified to cover locally common, unique or commercially important species.
3. There will be a large impact on larvae fish according to the study, but that there will be no impact on adult fish. It is misleading for the DEIA to state that there is no impact on adult fish as larvae wont have a chance to grow. Marine zones like seagrass, mudflats and mangroves are spawning areas for fish and crustaceans. Impact on fish larvae will effect fish populations over a wider area.
I am unimpressed with the way this study has been carried out, and I will continue to closely monitor the next step that the government takes on this plant.
Thank you.
Yours sincerely,
Name
IC number
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