COMMENT MRT Corp has invited the public to give feedback on the detailed environmental impact assessment (DEIA) so that necessary mitigation measures can be taken.

The report is on a one-month display for public inspection from April 20 until May 19, 2015.

Since the report is voluminous and time available to comment is restrictive, I would like to assist the affected stakeholders on some points in the report.

Before going into the report proper I would like to highlight a couple of things that MRT Corp may have overlooked.   

The media release on the report was issued on April 29, 2015, a clear nine days after it was supposed to be on display.

This is also a couple of days before we go for a long weekend. It does not leave much time for a layman to give meaningful feedback on the voluminous report.

Cart before the horse

Section 34A (2) of the Environmental Quality (Amendment) Act 1985 requires any person intending to carry out any prescribed activity, before any approval of such activity is granted by the relevant approving authority, submit a report to the director general.

The report shall contain an assessment of the impact such activity will have or is likely to have on the environment and the proposed measures that shall be undertaken to mitigate the adverse impact.

The point here is the DEIA draft report was submitted to the DOE for their review only on April 25, 2015 but Line 2 was approved by the federal government way back in early 2014.

In a newspaper report on March 17, 2014, MRT Corp said the MRT second line has been approved by the federal government and its then CEO Azhar Abdul Hamid said the company was waiting for the official announcement to enable it to begin work.

Further, item 6 of the DEIA Executive Summary, Volume 1 shows the Terms of Reference for the DEIA was approved by the Department of Environment only on Feb 12.

Let us move to the report proper.

Item 16 -  Line 2 starts from Damansara Damai.

Does the 52.2 km line include the track from Sungai Buloh and how does this relate to the total construction cost? There should not be a case of double counting.

Item 32 - A secondary depot handling mainly minor maintenance work will be built at Bukit Serdang and occupies 44 ha of land and the main depot for the Klang Valle MRT (KVMRT) will be at Sungai. Buloh.

But the main depot at Sungai Buloh occupies only 41 ha and the other one near Kampung Sungai Balak (for Line 1) is only 25 ha.

Do we need such a big secondary depot doing minor maintenance where for Line 1 cost-savings was primary and there seems to be lots of savings in land acquisition and compensation costs?

There should not be a case where affected stakeholders are short-changed but possibility of excesses in total construction costs.

Item 34 - Each train will be made up of  four cars.

Each car is 22m long, 3.1m wide and 3.7m high and will have a maximum carrying capacity of about 250 passengers, comprising 45 seated and 204 standing

Line 1, each car is 21.5m long with the same width and height, but has a higher carrying capacity of about 300 passengers, comprising 48 seated and 252 standing.

Table 3-1 in Section 3 (Project Description) shows Total Daily Ridership for Line 2 (529,000) higher than for Line 1 (508,000).

How is it possible for Line 2 with a longer distance, lesser carrying capacity and with about the same operating speed to carry higher daily ridership?  Line 1 has a 20 percent higher carrying capacity.

Typically, MRT refers to trains comprising of six or seven cars (usually 22-24 meters in length) with total length of 135-140m.

Our MRT train with four cars is approximately 89.1 m in length and as a comparison, the Ampang Line LRT with three articulated carriages is approximately 84.0 m.

Should we not build LRTs instead and are we overpaying for MRT?

Item 35 - A feeder bus system is currently being planned.

This is an important element for the MRT system and should have been planned earlier and included in the DEIA.

Item 36 - Fifteen park-and-ride facilities will be provided.

One of the criteria for choosing the location for the park-and-ride facilities is for future expansion potential.

Table 3-4 in Section 3 (Project Description) proves otherwise. Stations with higher daily ridership in year 2052 do not have this facility.

Item 63 - 24-hour noise level monitoring

Annex B (Item 4.4) of The Planning Guidelines for Environmental Noise Limits and Control published by Department of Environment (DOE) requires that compliance verification and record keeping the measurements be undertaken by the Project Proponent, for every day for a minimum of two weeks.

The location for measurement should be at appropriate spots. A lesson learned from Line 1 -  there was a measurement done 60 metres away from the proposed track while the affected area is very close at about nine metre away.

I trust the noise study includes sound reflection that travel upwards from the highways/roads to the underside of the track and bounce back towards affected areas.

In addition, item 4.5 of Annex B of the Planning Guideline states the DOE may require permanent or semi-permanent long term monitoring for sound while the sound source is in operation.

This is in the interest of abating community annoyance, in anticipation that the sound will be nuisance.

Item 75 - A vast majority of respondents believe that the project will not affect them adversely.

How was the assessment made when the alignment, feeder bus service and detailed traffic management plan, all of which have not been finalised and shown to the respondents?

Item 80 - Thirty-three stakeholder engagement sessions.

How many people attended in each of the 33 sessions, breakdown of the stakeholders and does it include the resident associations in affected areas?

Item 112 - Pier are small.

Exact designs must be shown because I know that for Line 1, one stretch of the pier is huge and not as per planned.

Item 123 - Noise modeling shows that the increase in LAeq (a widely used noise parameter describing a sound level ) is generally not significant.

It notes that this is due to the short term nature of train pass-bys, except at several locations.

But the point is not the short term nature of train pass-bys but more on the ultimate peak hour frequency of 1 minute and 49 seconds per train.

This is equivalent to an exposure of about 33 times per hour.

Item 131 - MRT Corp has conducted detailed traffic impact assessment (DTIA) for all the stations

It states that this is with a view of understanding the potential traffic volumes, planning for traffic circulation, estimating parking spaces and designing traffic management measures.

This is an important element during construction and operation. However, item 161 says the Detailed Traffic Management Plans (DTMP) are being prepared.

One says 'has conducted' and another 'are being prepared'.

There need to be an explanation as to whether the DTIA and DTMP are two separate exercises and why the potential impact during construction stage has not been completed?

If it is a separate exercise, should it not be combined since the subject matter is the same thereby reducing costs and time? Either way, the DTMP should have be made known to DOE upfront?

Suggestions to adopt

Time does not permit me to go into detail the other areas in the report.

I will now go into suggestion, the first of which is to use the Leopold matrix.

The matrix is a tool used in the systematic examination of potential interactions and to indicate the magnitude (from -10 to +10) and the importance (from 1 to 10) of the impact of each activity on each environmental factor.

This will give a clearer picture of the impact of each activity.

I also suggest that all relevant procedures and guidelines are followed religiously since this is a huge project with many inherent risks as can be seen in Line 1 with a number of accidents.

By the way, we have not heard or seen the report from National Institute of Occupations Safety and Health (Niosh) on the tragedy that took three lives at a MRT construction site in Kota Damansara in August 2014.

If there are cases of oversight, the relevant authorities should be more vigilant and ensure strict adherence.

There must be direct and proper supervision and not wait for people to call to complain of shortcomings.

An audit should be done at the end of the project, to evaluate the accuracy of the DEIA by comparing actual to predicted impacts. The objective is to improve the quality of future DEIAs.

Should there be some truth in the points highlighted above, it is my fervent wish that the various authorities and agencies in Malaysia to be more diligent and increase its professionalism in their respective duties.

The rakyat should come first.

SALEH MOHAMMED is the Infrastructure and Public Amenities exco member of the Taman Tun Dr Ismail Residents Association. In 2013, TTDI residents filed a suit stop the project, part of which is at their doorstep. The suit was dismissed.