TRANSIT woke up this morning and decided to confuse as many people as possible by using as many acronyms as possible in one post heading.
We have already done this in the past (for fun), but once the GTP and ETP were introduced, we felt that they really raised the bar on acronym use so we had to improve ourselves.
In this case, the post heading actually means: Mass-Rapid Transit Update: (the) Association for Water & Energy Research tells (the) Department of (the) Environment to reject (the) Environmental Impact Assessment (Report) from ERE Consulting Group for the Klang Valley Mass Rapid Transit Sg. Buloh – Kajang (Line).
Whew, that is certainly a mouthful – so now you know why our title was made this way:
MRT Update: AWER tells DoE to reject EIA from ERE for KVMRT (SBK)
But you, the reader, must be wondering why this organization has recommended that the EIA Report be rejected – and for that, we have this article from the Malaysian Insider:
Group tells DOE to reject MRT key report (Malaysian Insider)
By Clara Chooi
February 26, 2011
KUALA LUMPUR, Feb 26 — A local research group has told the Department of Environment (DOE) to reject the Environmental Impact Assessment (EIA) prepared for the multi-billion ringgit Klang Valley MRT project, accusing its project consultants of conducting a shoddy job on the key report.
Without an EIA approval, the government’s proposed multi-billion rail project cannot proceed as planned on July 16.
Association for Water and Energy Research Malaysia (AWER), a research-based non-governmental organisation, said in a press statement today that based on its studies of the EIA, the project cannot be approved as consultants had conducted an incomplete study of the rail system and its likely impact on the people and the environment.
AWER president S. Piarapakaran said that the group had submitted its seven-point comments on the EIA to the DOE director-general yesterday, urging the authority to pay close attention to the missing details in the report.
Firstly, he pointed out, consultants had made reference to a study on Integrated Urban Transportation Strategies for Environmental Improvement (JICA, 1997) as part of its reason to push for the MRT project.
“The validity of the study during 2016 (upon completion of the MRT) is questionable. Are there any latest studies done to support the MRT construction?” he asked.
Next, Piarapakaran argued that the estimation of commuters on the MRT as seen in the EIA report had only been based on areas where stations are proposed.
“But the EIA, and whichever date the EIA consultants have referred to, did not specify how many surveys were done to find people who are willing to use the MRT,” he said.
He claimed that project regulator Syarikat Prasarana Nasional Bhd had only carried out surveys at Rapid KL stations, which are filled with people already using the LRT rail services.
“Therefore, they will definitely agree to have the MRT, as it promises faster travelling mode,” he said.
Piarapakaran also observed that the consultants had not studied the number of likely commuters who are not within the station’s catchment areas that would be streaming into the area to use the MRT.
He also pointed out that the consultants had failed to detail the capacity of the 13 proposed park-and-ride stations, citing failures in the present Star and Putra line stations where capacity levels are too low to accommodate the traffic.
Furthermore, said Piarapakaran, many commuters using the KTM, Star or Putra lines presently park their cars in the housing estates surrounding the stations which often leads to complaints from residents.
On the consultants’ study of project options, Piarapakaran said it should be deemed “wrong”, as a qualitative comparison had been used to prove that the MRT was a viable solution.
“This is not how an EIA should be done. There was no proper numerical analysis or modelling done. It is ridiculous to compare the MRT directly with trams or buses,” he said.
The consultants, he said, of ERE Consultancy Group should have compared the relevant options together with supporting services like feeder buses and taxis with the MRT.
Next, Piarapakaran argued that the EIA had failed to include an air quality modelling for the project although one of the main criterion for the massive rail system was to improve air quality by reducing congestion.
“The consultants did not prove that air quality will improve except based on their own assumptions of everything going on well as imagined (not proven by any modelling or actual study),” he said.
He reiterated that the consultants had also failed to conduct a basic traffic modelling study to estimate the flow of commuters to and from station spots and make a comparison with the present traffic flow.
This, he said, was related the air quality modelling as any increase in traffic in the area would thereon cause a negative impactto the air quality.
“Increase in traffic flow causes increase in air pollution and is worsened by traffic congestion. Air pollution due to traffic does increase the impact to health,” he said.
He noted that in this case, consultants had failed to justify the rationale behind the chosen station locations or conduct a study on the likely number of commuters that would flock to the stations both from within the catchment area and without.
“All these commuters will travel to the MRT stations via many modes of transport along with others who do not use the MRT stations.
“Therefore, sudden increase or concentrating traffic flow will give immediate increase in traffic congestion,” he said.
Piarapakaran then pointed to a 2007 health report by the Toronto Public Health in Canada, which stated that traffic had given rise to about 440 premature deaths and 1,700 hospitalisations per year in Toronto.
“While the majority of hospitalisations involve the elderly, traffic-related pollution also has significant adverse effects on children.
“Children experience more than 1,200 acute bronchitis episodes per year as a result of air pollution from traffic,” he said.
Without the traffic modelling or air quality modelling studies, said Piarapakaran, the EIA consultants’ estimate on carbon emission avoidance was also “misleading”.
“The estimation is not accurately representing what eventually will take place,” he said.
The report, he said, had made a net estimate that a total of 34,400 MT/Annum of carbon emissions could be avoided with the MRT system.
“But based on AWER’s modelling study, we have estimated two times traffic congestion with only 30 minutes peak traffic congestion, rate of passenger flow in an hour, 40 weeks of five working days for a year, fuel consumption and statistics of public transportation usage of 20 per cent.
“And we have estimated 50,145 MT/Annum will be released if the vehicles use petrol only,” he said.
AWER had earlier claimed that the MRT would only cost commuters an additional RM403.5 billion in fuel in the first five year’s of operations due to increased traffic congestion at station locations.
Later, project regulators Land Public Transport Commission and Prasarana had both admitted that the government had not conducted any basic traffic modelling study to justify the MRT project and the amount of traffic congestion the system would likely reduce.
“Without the necessary studies, the EIA should be rejected,” said Piarapakaran.
Piarapakaran also raised the question of the MRT’s interconnectivity with the present rail system, which he claimed that the EIA consultants had not studied.
“Connectivity from the major line can be increased by LRT type approaches for densely populated areas. This is how the Japan train line functions,” he said.
The MRT system is an entry point project identified for the Greater Kuala Lumpur/Klang Valley National Key Economic Area (NKEA) and aims to increase public transport modal share from 18 per cent to 40 per cent by 2020.
Initial estimates have put the MRT’s cost at a whopping RM36.6 billion, making it one of the most expensive construction projects ever undertaken by the Malaysian government.
With the 40 per cent public transport modal share, the government hopes that at least four million trips of the estimated total of 10 million are made via public transport.
The remaining six million trips will continue to be made via private vehicles.
In the EIA, it was also explained that the mode share for rail use in the Klang Valley was expected to increase five-fold by 2020 from 400,000 trips per day in 2009 to 2 million trips in 2020.
Well … there you go. And some people assume that TRANSIT is just skeptical and contrary because we have a problem with the government.
As always, our message has been the same – the development of public transport is a process that involves participation from all 4 stakeholder groups (government, operators, local authorities & the public) and this process takes time and cannot be rushed.
Public transport must be allowed to evolve in the right manner – you cannot rush the evolution of public transport and hope for it to be 100% successful (even for a place as special as Hong Kong).
So like AWER, we will also call upon the Director General of the Department of the Environment to reject the inadequate, incomplete Environmental Impact Assessment for the MRT Sg. Buloh Kajang Line, because of our reservations & concerns (similar to those expressed by AWER).
We do not categorically reject the MRT proposal. However, our concern is with the rush job triggered by the statement from the Prime Minister that the MRT project must start on 16 July 2011 – and the fact that all stakeholders are not getting the opportunity to participate in real, effective public consultation.
By the way, Piarapakaran also replied to comments on the article and made reference to this article placed in the DoE journal IMPAK magazine (See Page 6-7.)