COMMENTS ON THE DETAILED ENVIRONMENTAL IMPACT ASSESSMENT STUDY FOR
THE PROPOSED DEVELOPMENT OF THE SUNGAI SELANGOR DAM IN HULU SELANGOR
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INTRODUCTION

The Sungai Selangor Dam construction in Hulu Selangor has been proposed to meet the projected water demand in the State of Selangor and Wilayah Persekutuan.

The Consumers' Association of Penang has studied the detailed Environmental Impact Assessment study [EIA] for the proposed development that was prepared by SMHB Sdn. Bhd for the project proponent, Konsortium TSWA-Gamuda-KDEB.

The main objective of the dam is to increase the yield of Sungai Selangor up to the water
abstraction point at Batang Berjuntai by regulating the flow of Sungai Selangor via releases from the impounding reservoir during low river flow periods.

The proposed Sungai Selangor dam will be a rockfill dam constructed across the Sungai Selangor.

 The height of the proposed dam will be 110m.  The impoundment has a surface area of 600 ha with a total catchment  area of 19,700ha.

The proposed dam and impoundment area are, as stated in the Detailed EIA, presently covered with belukar forest, rubber plantations, orchards and logged over forest fringing the impoundment area.  Most importantly the dam will inundate lowland forest, two Orang Asli settlements, some private land, recreational and picnic spots along the Sungai Selangor, a section of the Kuala Kubu Baru-Fraser's Hill road, among other tracts of land.

In line with Section 34A of the Environmental Quality Act 1974 and the guidelines made
thereunder for public feedback and comments on the EIA, our views on the study are presented below.
 
 

1.  Statement of Need  [Chap 2]
 

1.1 Water Demand Projections Questionable

The need for the Sungai Selangor dam in the EIA is premised on the assertion that given the water demand projections for the years ahead and the existing water supply for the state, the dam is imperative in order to avert an impending water crisis.

There are serious questions that need be addressed before one can accept the validity of the water demand projections. They are as follows -

i) The water demand projections as set out in Table 2.1 do not make clear the source of the data. Presumably, they come from a study done by the present consultants of this project in 1986 on the " Development of Sg. Selangor For Water Supplies to the Klang Valley and Southern Kuala Selangor".

ii) The assumptions and methodology adopted in arriving at these figures have not been clearly spelled out. In particular, the following information has not been made available-

 
 * what is the population growth rate assumed for each district and what is the basis?
 * what is the breakdown of domestic, commercial and industrial demand?
 * what is the respective growth rate for each category and what is the per capita/per
    unit consumption figure used?
 * what are the implications of introducing water demand management measures (e.g.
    reuse / recycling / conservation / pricing / reduction of NRW) on the demand growth?
 
This failure to disclose the fundamental assumptions and methodology in making water demand projections is, we submit, a major flaw and omission in the EIA.
 
iii) Further, if the data relied on were obtained from the 1986 study, then to what extent is it valid or relevant today?

In the Statement of Need (2.1.1), the EIA emphasizes rapid growth in    population and
industrialisation in the Klang Valley as the basis for the rising demand for water. This
statement is not supported by any facts and figures.

The basis for such an assertion needs to be clear and justifiable. This is so, as there have
been significant changes in the country's economic situation since last year to warrant a review of projections for water demand made in 1986.

Considering the growth of the Malaysian economy as a whole, the most recent government
projection for GDP growth is between 1% - 2 % this year. [NST, April 7, 1999]. The country recorded a GDP contraction of 6.7% after experiencing 13 years of uninterrupted growth averaging 7.5% annually. [Ibid]. The economic growth projections for the forthcoming years would have to be seriously reviewed given the current recession being faced.

There are certainly implications for water demand especially in the industrial sector and if
there has been a contraction in this sector, there must surely also be a corresponding
contraction in the demand for water.

According to the Bank Negara Report 1998, as a whole, the manufacturing sector contracted 10.2% and export-oriented industries recorded a decline in production by 7.3%. Owing to severe contractions in domestic demand, output of the domestic-oriented industries also declined by 13.4% last year. The construction sector's output contracted by 24.5% last year from a growth of 9.5% in 1997.

The EIA states at page 2.2 that in Selangor, "...over the last decade, water demand in the state and Wilayah has increased to about 9% annually, as a result of rapid growth and development and the demand for water is expected to continue in the coming years although tapering to a lower rate of consumption."

The EIA has not taken into account these most recent changes in the economy and the consequent implications for water demand in the years ahead.

Viewed in this light, the water demand projections that were probably based on growth rates expected during a boom time can be said to be outdated.

Hence, a review of the water demand figures in Table 2.1 is imperative and the assumptions and methodology used to predict water demand in the forthcoming years must be made explicit before the data can be accepted and validated.
 
iv) Further, the EIA also states that in 1995 to 1998, "there was a sudden increase in water demand, exceeding earlier projections." The reasons for such an increase have not at all been explained. This is another major omission. This statement alone goes to show that the earlier water projection figures are not reliable.
 

1.2 Project Options Not Adequately Addressed

The Statement of Need does not address at all the fundamental issue of long-term, integrated, sustainable water resources planning and management on a regional/national basis which has been identified as an urgent priority for the country as far back as the early 1980s. The government is well aware of this situation but unfortunately has not been able to put together thenecessary legal and institutional framework due to political foot dragging.

The justification for the Sungai Selangor dam is still based on the assumption that water
resources are only available within the state boundaries, a premise that has been proven to be outmoded and inefficient in other parts of the world.

What the EIA is effectively saying is that the Sungai Selangor system is the last major water source for Selangor and therefore we have to forego all the environmental benefits in order to meet water demand. This argument is not only flawed but is also remarkably shortsighted; the conclusion in 2.4 that this dam project should take priority because it is faster and cheaper to build as well as an in-state scheme simply does not hold water.

This dam will not solve the water problems of Selangor and is only engineering a quick fix to what is actually a more serious resource planning problem.

This is evident from the cursory and almost offhanded manner in which the other project options have been dismissed (2.3) in the study. The primary criteria in identifying the Sungai Selangor Dam as the most feasible option is evidently land availability (and cost of acquisition).

Where are the detailed cost-benefit analyses that could show, for example, that other dam projects that involve re-alignment of sections of the North-South Highway and inundation of private land might not be more feasible options?

The other project options and the no project option have not been dealt with exhaustively and the conclusions are therefore unconvincing.

According to the DOE EIA Guidelines for dams, an EIA should provide the basis for the
elimination of options determined to be not reasonable. [Pg. 11-2]

For example, the option of developing groundwater resources is not mentioned at all any where in the report!

The EIA should therefore address the following issues;

* the need for the Sungai Selangor Dam from the perspective of long-term, integrated, sustainable water resources planning and management on a regional/national basis.

* the development of ground water resources as part of an integrated water supply system

* a more rigorous and thorough analysis of the other/no project options and approaches

* the feasibility and implications of water demand management measures such as water    recycling, reuse, conservation, pricing, reduction of non-revenue water etc. In this context, the benefits of plugging leaks in the system (refurbishment of reservoirs, treatment plants, pumping systems, replacement of old mains, improving metering efficiency, reducing water theft, improving maintenance efficiency) should be clearly identified and spelled out.
 

1.3     Alternatives Approaches to dam construction not considered

The EIA in particular has not at all addressed the issue of alternatives to dam construction. This is another major flaw as it is contrary to the DOE's own guidelines.

According to the DOE's Handbook on 'Environmental Impact Assessment Guidelines for Dams and/or Reservoir Projects', in considering project options, it is stated that "in the event of serious losses of natural environmental resources that are expected to result from the proposed project, the EIA report should include consideration of alternative projects or approaches which could achieve the same or equivalent results and the advantages/disadvantages of the alternatives from the point of view of environmental protection." [pg. 11-3 of the Handbook]

It further states that "in the discussion of options, alternative management systems should be described. This discussion would include upgrading existing systems. Before major new key sector projects are proposed, it must be demonstrated that upgrading existing systems will not solve the problems identified in the chapter setting out the need for the project."

Alternative approaches would necessarily involve the promotion of water-use efficiency and conservation in water resources management. This is an area that should be given prime consideration in the EIA instead of merely focussing on dam construction options and the inter-basin water project.

The annual rainfall over Malaysia amounts to 990 billion m3, of which 566 billion m3 appears as surface runoff and about 64 billion m3 recharges groundwater.  The balance returns to the atmosphere through evaporation and transpiration. With proper management of this precious resource we can alleviate the problem of water shortage.

In considering the aspect of water supply, water-use efficiency can be achieved and improved through a more efficient reticulation system and promoting wise use of water.

The following are some options that ought to have been addressed by the EIA but which have been neglected -

* Groundwater

   The Drainage and Irrigation Department (DID) states that we have groundwater recharge of 64 billion m3. They claim that tapping groundwater is a good way to deal with water shortage. In Terengganu, the DID has a 4 million gallon per day well that serves 100,000 people and has ust developed another one in Selangor that will produce 3.5 million gallons per day.
 
   97% of the water we use comes from rivers and only 3% from groundwater. In Denmark 99% of  of their water is obtained from groundwater sources.  In England and Wales, about 30% of the  total water supply is satisfied by groundwater and in the United States this figure rises to about  50%.

      Groundwater can complement the use of surface water and can be drawn on during dry periods when surface waters are inadequate.  With the increase in demand for water, groundwater can play an important role as an alternative water resource.

* Localized water resources

   Small, localized sources of ground or surface water, which can be collected and piped for use in the immediate vicinity, should have been identified. Larger water storage and distribution facilities can then be used only to supply areas where no local source can be found.

   Small ponds should be developed to serve local communities rather than having to centrally collect and store water and pipe it around the state.  We can utilise the retention capacity of existing wetlands and natural underground aquifers.

* Polluted streams, rivers, and lakes can be rehabilitated and revived as sources of water
supply for irrigation and industry.

 * Resolve Non-Revenue Water Problem

 A staggering 996 million litres per day or 37% of treated water is lost, what they call
 "non-revenue water."  Sixteen percent of this is lost through leakage (not consumed), 14% from water theft (consumed but not paid for), 5% non-revenue from faulty water meters (consumed and not paid for) and 2% for hydrants.

A systematic programme to repair or replace burst or leaking mains and pipes must begin at once.  Improving leakage and waste in urban water supply systems is very important. The public should be able to alert the relevant authorities to cases of water wastage, e.g., malfunctioning faucets in public washrooms, faulty hydrants, and so on.  At present bursts and leaks are often left unattended for weeks.

* Public Awareness

The lack of awareness among the public on wise use of water is a serious drawback.  The public has to be educated on the value of water and the urgent need to use it with utmost care and respect. A vigorous effort to convert unconscious water-wasters into conscious water-savers must be launched via the mass media over several years.

The government should embark on a water conservation campaign.  Among others, house
owners must be encouraged to improve the efficiency of roof gutters and get into the habit of collecting rainwater for washing cars, watering lawns and plants, clean the house, flush the toilet, etc. Simple tips such as don't clean teeth, shave or wash dishes with the tap running will also reduce water consumption.   Millions of gallons of precious water can thus be saved every day.

The fact that Orang Asli perceive their rivers as an eternal outflow of life-sustaining love
from the breast of Mother Earth illustrates their deep-rooted respect for Nature. We have a great deal to learn from these simple, modest folk.
 

* Appropriate Pricing Policy

 A significant approach to water demand management is the pricing of water. There is indeed a need to review existing water tariffs and an appropriate pricing policy needs to be considered. If a fair pricing system is adopted which is based on an appropriate scale that encourages water conservation instead of the misuse of water, there will certainly be a reduction in the demand for water. Such a policy is necessary, despite it being perceived as a 'political problem.'  Even the construction of a dam can have political implications!

* Urban environment

Urban areas are predominantly impervious areas due to the high level of development.One o the reasons that existing dams in Selangor have less water is due to heat rising from Kuala Lumpur, which affects local weather and rainfall patterns. Rather than falling in the catchment areas, a lot of rain is now falling on the city.

Housing developers only have to comply with 10% open space in their designs. Therefore a lot of rainwater falling over urban areas is lost as run off. This means none of it replenishes the groundwater supply - instead it contributes to flash flooding.
 
New by-laws must be introduced into urban planning rules to ensure that rainwater can return to the ground and replenish the water table. Every few blocks of built-up area must have runoff-friendly patches of greenery or miniature parks to break the monotony of concrete.
 
 

              * Agricultural sector

              In the agricultural sector, there have been proposals to promote wise water use through several mechanisms including the development of more efficient irrigation practices, establishment of a cost-recovery mechanism, development of conservation incentives, consolidation of irregular and small landholdings, and through recycling of water.  These proposals have to be carried out immediately and effectively.

              * Industrial sector

              The relevant authorities must take action against factories that have been stealing water and ensure that it does not persist.  Factories must be required to invest in rain collectors and storage tanks. Those that have been polluting streams and rivers must be dealt with swiftly and sternly.

              Industries that consume massive amounts of water must be required to incorporate rain-collecting and water-recycling facilities into their routine operations.

Viewed in this regard, the EIA is most inadequate, uncreative and lacks in-depth vision and
foresight.
 

 
1.4             No Project Option

As has been alluded to above, the 'no project option' has not been adequately and sufficiently considered, given that other options and approaches in meeting shortfalls in projected water demands have not been properly addressed or neglected completely.

The no project option in the EIA report states that "...if the Sungai Selangor dam is not
implemented there must be other alternative schemes to meet the expected shortfall of water supply in the near future... If the water resource of the Sungai Selangor is not tapped, there will be an immediate need to obtain water through inter-State transfers."  [Page 2-7]

 Having addressed the feasibility of supplying raw water from Pahang to Selangor, the EIA
concludes that it is technically feasible but will involve environmental problems and large
amounts of capital expenditure.

Given the problems associated with this inter-state transfer scheme, the EIA does not state that the Sungai Selangor Dam Phase 3 is a better option in place of the inter-state transfer. It in fact states that both the proposed dam and the inter-state transfer schemes are needed to meet the medium term water needs of the State.

The only reason why the dam is suggested as an immediate option is because it can be implemented faster and is cheaper as it is an in-state scheme.

Hence, it is clear that the dam is only a temporary quick fix to what is a long-term water
problem. This is indeed a very shortsighted approach which is environmentally, socially and
economically costly to adopt as an interim measure.

If both the proposed dam and the Pahang inter-state transfer scheme is to be adopted, then, there is then real need to address the cumulative impacts of both projects on the environment and the overall cost-benefit to the State.

In the final analysis, what is really needed for Selangor is a long-term, integrated and
sustainable water resources planning and management strategy that is considered both from a state and national perspective.

There simply cannot be costly short cuts!
 

1.5     No Cost-Benefit Analysis Provided

According to the DOE Handbook of Guidelines for EIAs, an evaluation of the environmental and development benefits and costs arising from a development project is an essential ingredient in a Detailed EIA. Such an evaluation is necessary as " ...an essential aid to decision-making by the project approving authority. The information that the assessor must provide in Detailed Assessment is an annotated list of economic costs and benefits to community." [Pg. 31]

The EIA has completely neglected to address this and hence, suffers from another very major omission and flaw.
 

2. Human Environment
 

2.1 The Position of the Orang Asli - Flawed Understanding of the Legal Issues

The EIA deals with the socio-economic aspects related to the Orang Asli who will be displaced by the proposed dam.

The Terms of    Reference as set out in Vol. 2 of the EIA in reference to the social and economic aspects, confines the scope of investigation in this regard to identifying "...key issues of concern in the development of an acceptable resettlement and compensation programme." [pg. A-1-7]

Consequently, the mitigation measure proposed concludes that "Fair compensation should ...be provided for the loss of economic activities." It also recommends that "The issue of
resettlement of the affected Orang Asli population should be professionally handled to seek the community's co-operation and also to avoid any discontentment and opposition on the project development." [ pg. 6-3]

There is a very major fundamental flaw in adopting this rather narrow approach of merely
focussing the issue on the question of "fair compensation."

There has been a total misunderstanding and misconception of the legal rights of the Orang Asli in Kg. Gerachi and Kg. Peretak.

At pg. 3-19 of the EIA, the issue of their status on the land is discussed. The EIA concludes that "...the Orang Asli do not have land rights ..." and suggests that they are tenants at will and that the State Government can take away their land without the need for compensation.

These conclusions reflect a complete ignorance of the law in relation to the rights of the Orang Asli in the two kampungs.

According to records of the JHEOA itself [see Data Tanah JHEOA 1990], the two kampungs were approved by the State Government for gazetting as Orang Asli reserves as far back as in 7 March 1965. This is in part admitted in the EIA.

Case law states that once the State Government approves the land for gazetting, though actual gazetting is not done, the approval of the State Government has without the necessity of gazetting, created the reserves. Consequently, only Orang Asli have exclusive rights over the land. [see case of Koperasi Kijang Mas and 3 others v Kerajaan Negeri Perak & 2 others [1991] 1CLJ 486]

Moreover, in a landmark judgment in the case of Adong bin Kuwau v Kerajaan Negeri Johor & Anor [1997] 1 MLJ 418, the High Court held that the Orang Asli who were affected by the Sg. Linggui dam had proprietary rights over their ancestral lands which were guaranteed by Article 13 of the Federal Constitution. This decision was subsequently upheld by the Court of Appeal in 1998. The Court of Appeal went further to affirm as follows -

              "It is now settled beyond argument in our jurisdiction that deprivation of livelihood may amount to deprivation of life itself and that state action which produces such a consequence may be  impugned on well established grounds." (see [1998] 2 CLJ 665 at pg. 671).

These court decisions have very serious implications with regard to the decision by the State Government to consider the construction of the dam without the prior consultation of the Orang Asli and in ignoring their rights to the land.

We are legally advised that it is not just a question of what is "fair compensation" but rather, whether the proposed displacement of the Orang Asli is constitutional in the first place.
 
We are informed that the Orang Asli have engaged lawyers to pursue their claims.
 

2.2 EIA Review Process Should Be Put On Hold

Given this backdrop, it would be prudent for the DOE and the project proponent to put on hold the review of the present EIA until these fundamental legal issues in relation to the land rights of the Orang Asli are thoroughly analysed, studied and determined.

If the legal challenge mounted by the Orang Asli against the Selangor State Government succeeds in favour of the natives, then the decision of State Government in proceeding with the dam may be invalid.

In such an eventuality, the current EIA review process may amount to an exercise in futility and a considerable waste of public funds and time. On the other hand, if the Orang Asli fail in their legal claim, then, the EIA review process can proceed as set out by law.
 

3.      Biodiversity

The negative impact of inundating nearly a thousand hectares of low montane forest cannot be adequately assessed or quantified.  For a start, we may stand to lose rare species of flora and fauna unique to the area. The WorldWide Fund for Nature (WWF) has acknowledged the rich biodiversity of the nearby Semangkok forest reserve. On Fraser's Hill alone, 256 bird species - nearly half the total number of avian species found in Europe - have been identified. If the Pertak forest reserve were further depleted, the forced migration of species would cause havoc to the overall balance in the ecosystem.

3.1     Biodiversity Sampling

According to the Head of FRIM's (Forest Research Institute of Malaysia) Natural Forest Unit, Dr S. Appanah, the methodology employed in assessing the biological diversity in the EIA is flawed. The size sampling used in the EIA is too small to provide an accurate picture of the habitat within the catchment area.

Out of the total catchment forest only three plots totaling 0.6 hectare were surveyed.  Ideally it should be at least 5% of the total area.

Dr S. Appanah suggests that there should be multiple plots spread across the area to take into account the shrubs, herbs and other non-timber species.  Dr Appanah's suggestion is supported by WWF and the Malaysian Nature Society.
 

4.      Impacts of Flow Manipulation

Reservoir operations produce artificial discharge variations.  These often involve extreme
fluctuations of water depth and flow velocity, having unnatural rates of change, unnatural
duration and unnatural frequencies.  Within natural rivers experiencing flows of high
variability, a high level of production can be attained if the community present is adapted to the frequency and magnitude of flow fluctuation.  However such adaptations require a long time period and the combination of severe water-level fluctuations and high content of suspended solids can devastate invertebrate populations.

The generation of high turbidities during dam releases can be an important factor causing the devastation of invertebrate communities.  Artificially high or low flows, especially at
unseasonal times, can have a major effect upon the composition of the benthos - by eliminating or favouring flow specific species.

The modification of downstream river-flow characteristics by an impoundment can have a variety of effects upon fish species; food production, stimuli for migration, the success of migration and spawning, the survival of eggs and juveniles, spatial requirements and species composition can all be adversely affected.

The prevention of floodplain inundation by flow regulation from an impoundment, will deprive many fish species of spawning grounds and valuable food supplies.   The Kuala Selangor mangroves at the river mouth of Sungai Selangor will be adversely affected by the dam construction. This was experienced in the dam construction for industrial use within the Rio Mogi Guassu, Brazil where it had resulted in the progressive loss of floodplain wetlands.
 

4.1     Flow of the Sungai Selangor

With the proposed dam, the flow is expected to be maintained at 300 million litres per day for longer periods than currently.  This means there will be longer period of reduced flow which will result in lesser dilution capacity, making the river prone to pollution impact.

Dr Loh Chi Leong of Malaysian Nature Society says previous studies recommend that the river's present flow of 5,500 million litres per day be regulated at 3,300 million litres instead.  Of this 3,000 million litres will be drawn for drinking water each day.  This leaves a residual flow of only 300 million litres.

In contrast a 1982 Japanese study estimates that the river needs a flow of at least 1,700
million litres.  This leaves the river with only 10% of its original flow.  It will cause
massive environmental and economic damage to Sungai Selangor.
 

4.2     Erosion and Siltation

The dam catchment is categorised as a High Erosion Risk area in the map of high-risk areas for Peninsular Malaysia.  The EIA report states that the removal of vegetation cover at steeper slope during the construction of the dam may result in soil loss of about 1,300 ton/ha/year. Exposed areas due to land clearing will result in surface runoff which can cause flashfloods an landslides during rainy season.

The engineering design of the Sungai Selangor dam has assumed a conservative erosion rate of 250 tonnes per km2 and a sediment density of 1.5 ton/m3 in the reservoir.

Provided these figures remain unchanged, the reservoir is said to be more than adequate to catch a sediment build up for 100 years. The EIA further states that future development in the area has to be checked as opening of new land can cause soil erosion and siltation.

Even if all mitigation measures were carried out to prevent siltation loading in the reservoir
during construction period, the storage life and viability of the dam still depend on future
activities.  As such the EIA recommends the protection of the Sungai Selangor catchment by gazetting it as a watershed where development has to be either prohibited or strictly controlled.

The EIA should recognise that the streams and tributaries feeding the Sungai Selangor are
already polluted with sediments and run-offs due to recent logging on the hill slopes.   The
construction of the new stretch of the road and logging of the inundated area will bring more debris into the reservoir that it will need to be desilted every two or three years, adding to the enormous cost of maintaining the dam.

What has to be taken into account is the most recent spate of mud and landslides in the upper reaches of the Sungai Luit, a main tributary to the Sungai Selangor. This was following a massive torrential downpour on 31 March this year. The landslides have been attributed to logging activities in Sungai Luit. The level of the river was reported to have arisen by over 10 feet and destroyed some unoccupied Orang Asli huts. People living in Ampang Pecah had thick muddy water entering their homes whilst those living in Bukit Beruntung had water supply problems since they pump water directly from the Sungai Selangor.

4.3     Reservoir Sedimentation

As soon as a dam is operational it will begin to trap sediment within its storage volume and
reservoir sedimentation will progressively alter the character of discharges downstream.
Reservoirs will permanently store almost the entire sediment load supplied by the drainage
basin.  Thus, many reservoirs in areas of high sediment yield have experienced reduced life
expectancy.  Consumption losses will decrease and flood peaks will increase as the reservoir becomes filled with sediments.

The catchment characteristics influence sediment yield. In general terms, resistant geology and well-vegetated slopes produce low rates of reservoir storage loss, whilst high rates of sedimentation are associated with erodible soils and semi-arid climates, where slope lack a protective vegetation cover.

In this case, the catchment area has already been logged over and as mentioned earlier erosion and landslides are quite rampant.  Hence the life expectancy of the Sungai Selangor dam is highly questionable.
 

4.4     Sediment transport
 
Changes in sediment transport have often been identified as the most important impacts in any assessment of environmental problems within impounded rivers.  These impacts arise because more than 90% of the sediment load, and effectively all of the coarser material, will be trapped behind the dam, at least during the early years of operation.

The clear water reservoir releases will be able to pick up available sediment particles from the stream's bed and banks, replenishing the sediment load that is trapped by the reservoir.  Thus, severe erosion has been observed within the downstream channel and delta in other dam constructions. The erosion may extend for many kilometres downstream.  In coastal areas, erosional processes may produce detrimental effects.

Rates of channel bed erosion below dams are typically greater than erosion rates within residual rivers, at least for several years after dam closure and the erosional processes tend to dominate from year to year, whereas in natural rivers alternating erosional and depositional processes maintain the channel in quasi-equilibrium.
 

4.5     Vulnerable to Flooding

Both Kuala Kubu Bharu and Ampang Pecah are still very vulnerable to flooding. Human activities like mining and logging of the Sungai Selangor catchment area have given rise to heavy runoff and soil erosion which raises the height of the river to dangerous levels. The worst floods were recorded in the 1920s when the whole town was flooded.

It is reported that in 1996 residents of Ampang Pecah had to leave their homes in the middle of the night after the Sungai Selangor and its tributaries burst their banks and waist-deep muddy water inundated their homes.  A huge section of the road between Ampang Pecah and Rasa was also swept away during these floods.

With the construction of the dam, the residents in this surrounding area are predicting a bleak future of impending floods and landslides that may endanger their lives especially where flash floods and landslides have increased dramatically in recent years, due to irresponsible logging upstream.

The impact of forest clearance on river runoff combined with heavy rainfall is in all likelihood the main cause of the flash floods in Ampang Pecah.  The reservoir area of the Sungai Selangor Dam is expected to be logged. Forest clearing, logging tracts and deep gully formation lead to an increase in runoffs.  Hence the possibility of another round of flash floods during the clearing of the reservoir site and during the clearing for the construction of the new road is real and imminent.
 
 

5.      Kuala Selangor Mangroves

The negative impact of river impoundment is far-reaching, unpredictable, and usually
irreversible. In the case of the proposed Selangor Dam, it is quite possible that the wetlands and famous firefly colony near Kuala Selangor will be adversely affected.

Changes in the water level of the river caused by the dam can be expected to affect the profile of the river downstream specifically in terms of increased salinity.  Increased pollution and salinity of the water will affect the mangrove ecosystem downstream and firefly larvae and its food source, the river snails.

The EIA however cannot ascertain the impacts caused by the dam project due to little information on the ecosystem.  The mangroves in Kuala Selangor are already under threat due to development, aquaculture and reclamation projects.  Hence the State has to do everything possible to protect this valuable resource and not bring to its downfall.

Tampering with the riverine ecosystem will be detrimental to mangroves at the river mouth.   It may well affect the ecology of the forest  reserve in Kuala Selangor as well as the habitat of the fireflies at Kg Kuantan (about 4 kms upstream from Kuala Selangor). These are both well-established eco-tourism sites.

Once the river's flow drops, salt water from the sea will move up-river.  The higher salinity
will strangle existing vegetation.   We are concerned about the Sonneratia trees which attract the Kuala Selangor famous fireflies.  We fear that if the trees die, the insects which are indeed a sight to behold and treasure will be destroyed forever. This is indeed a tremendous loss to the Malaysian community as a whole, which can never be compensated in any monetary form.

Even now, environmentalists have already seen the effects of salt-water intrusion because of tree cutting and activities which affect the mangroves.  The Sonneratia trees used to reach the river mouth but now are found only 10km upstream.  It will be worse with the high extraction rate of water.

Since the EIA is unable to ascertain the impact of the dam on this ecosystem, there can be no consideration of any mitigation efforts. In this regard, the EIA is inadequate and cannot be approved as it is.
 
 

6.      Dam Safety

6.1     Dam Settlement

One problem peculiar to rockfill dams is that they are prone to settlement, deflection and
lateral displacement both during their construction, as well as after.

According to K.V. Taylor: "Design of Rockfill Dams in A.R. Golze: Handbook of Dam Engineering", the settlement of a dumped rockfill under its own weight occurs mostly during the construction but continues on a decreasing rate, sometimes for many years, after completion of fill.  Consequently, damage to the face resulting from that settlement may also continue progressively for a long time.  Permanent repair of the facing might require the reservoir to be drained down and taken out of service while the repairs are being affected.

Another problem common to rockfill dams is the uneven settlement or sinking of the dam.  If the settlement or sinking of the dam is not even or above a certain level, it will cause  big cracks and leakage - possibly even dam failure.

The problem of water leakage and cracks are not only critical from a costing point of view -  i.e.: the cost of repairs, including the partial draining of the reservoir in order to make the necessary repairs - but also from the safety aspect.

Unfortunately the EIA fails to address these issues. These are issues of serious concern in
relation to the safety of the dam and the possible impacts of people living downstream.
 

6.2     Seismology

The larger the project, the higher the risk factor.  In this instance, the Selangor Dam will
inevitably distort the geomagnetic field of the area, resulting in drastic long-term climatic
and seismological changes - including the possibility of earth tremors in previously stable
areas.

The EIA states that there is a risk of RIS (Reservoir Induced Seismicity) as the dam is 110m high and reservoir volume is about 230Mm³. There is a possibility that an isolated seismic event of moderate magnitude could occur within the region.  The EIA further mentions that a ground acceleration of 0.1g will be incorporated in the design of the dam to overcome the risk of dam failure due to seismic activity.

The EIA should have taken into consideration the worst Seismic event that can be expected, probably 6 on the Richter scale.  If the dam is not sufficiently designed to withstand the anticipated magnitude of the seismic events, such readjustment of surface crust may damage the dam structure if it occurs in the foundation.

Cases of RIS for instances at the Koyna Dam in India and the Hsingfenkiang Dam in China have shown that RIS can exceed the magnitude of natural seismicity normally experienced in those areas.  This is substantiated by the findings of the UNESCO Working Group on Seismic Phenomena Associated with Large Reservoirs.

       "During the past few years, the impounding of certain reservoirs has been found to be
       responsible for triggering seismic phenomena, irrespective of the seismicity of the
       region. Characteristic examples are associated not only with recent tectonics and
       high seismicity but with older and more stable masses of very early tectonics."
                (Report of Second Meeting, UNESCO 14-17 Dec, 1971).

We are of the view that the EIA has not dealt with this aspect adequately and thoroughly enough.
 
Scant attention has been paid to the fate of the people of Kuala Kubu Baru and downstream who are at the greatest risk if the dam should breach.  There is no mention of how much the flood flow would be if the dam fails.  Even if a monitoring and alarm system is installed to alert the population downstream of dam failure, it would be redundant.  The flood flow, volume and force of water will devastate and submerge the areas downstream.  Human lives, belongings, flora, wildlife, etc are at stake.
 

6.3 Failure to consider environmental and social costs of dam failure

Dam failure and the subsequent inundation and devastation to downstream areas is an inescapable risk of dams. However, the EIA for the proposed Sungai Selangor Dam fails to assess and disclose the environmental and social impacts of a dam failure. Moreover, a dam failure is not unlikely. An earlier dam on the Sungai Selangor failed in 1883, resulting in the destruction of the original Kuala Kubu Baru town. Other dam failures have occurred in Asia more recently.

Without knowing the environmental and social costs of a dam failure, the Review Panel is denied meaningful opportunity to weigh the potential benefits of the dam against the potential catastrophic environmental and social costs that the dam may incur.

Failure to assess and disclose the environmental and social impacts of a dam failure - a
reasonable foreseeable effect - violates internationally accepted principles of EIA law.
 

7. Conclusion

Given the above analysis, we are of the view that the EIA for the Sungai Selangor Dam is flawed in many respects, inadequate, non-comprehensive and suffers from several fundamental defects and omissions.

We submit that the EIA as it stands, does not satisfy the requirements of Section 34A(2) of the Environmental Quality Act 1974 and should therefore be rejected as is provided by Section 34A(4).
 

Submitted by the Consumers' Association of Penang
Dated:  14 April, 1999
 

COMMENTS ON THE
DETAILED ENVIRONMENTAL IMPACT ASSESSMENT
STUDY FOR THE PROPOSED DEVELOPMENT OF THE SUNGAI SELANGOR DAM IN
HULU SELANGOR

DATED THE 14TH DAY OF APRIL 1999
 

CONSUMERS ASSOCIATION OF PENANG
No. 228 MACALISTER ROAD
10400 PENANG