Members of TRANSIT recently attended the presentation by MRT Corp on the MRT 3 project on the 13th of April 2021. While we appreciate the opportunity for discussion and the media briefing, there are a few important questions we would like to raise regarding the proposed MRT 3 project. These questions revolve around the project alignment, the planning process, and how MRT 3 integrates with existing public transport services and affordable housing.
Policy
- Greater KL public transportation mode share is still way below the 2020 target of 30%. We estimate it to be about 10% only. What were the other public transportation options that were considered before the decision to invest on MRT 3? And what is the expected MRT 3 contribution to the mode share in 2030?
Planning
- The proposed alignment currently runs only within DBKL territory. Is this the best option to address commuters’ needs? During the presentation, there was an emphasis on keeping the lines within Kuala Lumpur boundaries. The idea here is to keep population growth within Kuala Lumpur and to encourage people outside KL to take the MRT when travelling within Kuala Lumpur. However, this is assuming that commuters outside Kuala Lumpur are always keen to travel to the closest train station and then travel into Kuala Lumpur. This approach ignores the fact that the public transport network has to compete with car infrastructure given the scale of Klang Valley’s highway network. If commuters have to drive to stations, why not just drive straight to their destination? This is not a convincing point without further concrete measures to ensure this strategy works.
- If MRT would like to go with the idealistic plans they have mentioned, how will MRT work with DBKL on creating policies and guidelines for building housing and neighbourhoods around the stations? If we can be more specific, would the KL Structure Plan 2040 be updated to include MRT’s proposed “station as a town center” to be implemented? Affordable housing, integrated neighbourhood plans, and more connectivity to the stations isn’t under MRT’s jurisdiction. That would be under the power of the PBTs, from sidewalks, landscaping & bus stops to land use & activities with its buffer zones and parking requirements allowed.
- We are keen to know how MRT 3 integrates not just with existing transit lines but also current and future bus networks, as the success of public transport is dependent on seamless first-last mile connectivity. We understand that bus operations are not within MRT Corp’s jurisdiction but we hope that APAD and Prasarana have been engaged sufficiently and can provide further information on the overall Klang Valley and Putrajaya transit masterplan.
- MRT 3 claims that it aims to catalyse urban regeneration by developing or integrating with existing properties along the proposed alignment. What is the feasibility and potential of establishing major town centres or urban hubs via this proposal? For example, in the case of MRT 1 and Kwasa Land, the (proposed) township has been slow to develop despite the two MRT stations (Kwasa Damansara and Kwasa Sentral) having been operating in the location since 2017.
- MRT 3 claims to have plans to develop affordable housing at major stations along the alignment. What is MRT Corp’s definition of affordable housing? We would like to know more about the proposals, given that land is very scarce along the MRT 3 alignment. It would not be cheap to procure the land required for affordable housing. Will the budget include the land acquisition cost? Is affordable housing tied to the feasibility study or simply a goal to work towards?
- Following the point above, MRT Corp stated that they are looking to develop Transit-Oriented Development (TOD) along the alignment as part of the urban regeneration and development objective. How would the TOD work to centre employment, social services, cultural and living opportunities for those living in those areas? Would Klang Valley citizens be priced out of these residential developments, as what a iProperty study has shown? The 2020 study finds that a majority of TOD residential properties along the MRT Sungai Buloh – Kajang line is unaffordable for the M40 market. Ideally, this should not happen for MRT 3 if the objective of affordable housing is to be achieved.
Communications to the Public
- Public inspections of proposed public transport alignments are mandated as per Section 84 of Land Public Transport Act 2010. For MRT 2, there was a 3-month public engagement period whereby details such as land acquisition plans, railway technical data and station design were displayed for feedback. We would like to know in greater detail when MRT Corp will prepare for public inspections. Displaying land acquisition plans are especially important due to the direct impact to the people residing in the affected areas. Hence, the public display should be conducted before the tender. This must form part of a wider public engagement strategy designed to allow residents, businesses and local government to provide continuous, valuable feedback on the project.
- The construction works will pose a significant impact to residents, businesses, and those working in KL, and add to the current congestion. What is the proposed timeline for the project and phasing? How will residents and businesses be kept informed about the project, and what help will be available for businesses that might be impacted by the disruption that construction activities bring?
Financing
- We require more details on the Public-Private Partnership (PPP) funding model. What is the criteria for private companies to participate? Which aspects of the project are targeted for private company participation? How would tenders be selected and contracts enforced to ensure compliance and good project outcomes?
- The total costs of the MRT 3 project has not been disclosed yet but figures between RM30 billion to RM50 billion have been floating around. We know that the government is fully backing the project financially if needed but such high costs have to be tabled and passed in parliament. Tabling a project like this in Parliament allows for due diligence between different state representatives on all aspects of the project. It also allows for issues to be highlighted and rectified before the project commences.
We hope MRT Corp will seriously consider these questions in the implementation of the MRT 3 development project. TRANSIT is more than happy to be part of the public consultation process to convey the Malaysian public’s concern to MRT Corp and bridge the knowledge gap between the grassroots and the project.
Transit Malaysia 