Professional Documents
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Contents
Concern For Sungai Selangor: Our Stand The Environmental Impact Assessment Report What Are We Losing Technical questions on the EIA Summary Water Crisis Justification Technical Feasibility Study Report Hydrology, Hydraulics, Geohydrology
Water Quality Vegetation Terrestrial Fauna Human Development Dam Risk Assessment More Information on Dams From The New Internationalist Problems with Dams Heavy Metals: Effects of Cadmium in Water Supply REFERENCES
Without the answers, the EIA study is an incomplete and an inconclusive piece of work. Without them, the proposed dam must be deemed unviable and must not be built.
To prevent the inevitability of losing everything, we must question the conventional wisdom of growth and more growth caused by population and development, the two growths that hunger for more water each year. We must pose the drawing-theline wisdom, i.e., we need an alternative development path. If there are things we hold dear to our hearts, things that give meaning to the quality of our lives, if these mean that Selangor or Kuala Lumpur can only support a certain size of population and of development, then this is where we draw the line. Otherwise, we will only end up with concrete jungles and their sterile gardens - if there are sterile gardens at all! And a Kuala Lumpur the size of Jakarta or Bangkok where, in two hours, we would still be in a traffic jam trying to escape the crowded and polluted city. At least, in the present KL (which is already bad enough with its pollution and congestion), in those two hours we would already be in Kg Kuantan marveling at the fireflies, or in Kuala Selangor enjoying the bird sanctuary, or whitewater rafting at Sg Selangor, or just quietly being in harmony with nature somewhere in the wilderness. It is these little pleasures that make for a good and meaningful quality of life. If we were to follow the present trend in water consumption, by 2003 all the available water sources of Selangor and Kuala Lumpur would dry up [1]. A growth of 9% in water demand each year means that water consumption/supply doubles nearly every 8 years. Consumption in 1998 is 2500 million litres per day (mld). Thus, in 2006 it will be 5000 mld, in 2014 10,000 mld, in 2022 20,000 mld, and so on. Are we seriously going to follow this kind of development which incidentally pollutes available water resources and further limits fresh water supply? Before we allow the last line of retreat to be drawn, when no more water anywhere is available, when everything dear to us is gone, why not draw the line here and now, before the damage is beyond repair? Before everything that gives meaning to life has disappeared?
WATER FLOW
The regulated water after extraction leaves only a flow of 300 million litres per day [1] in Sg Selangor. This is much lower than even during the dry season. The difference between normal flow and after damming would lead to salt water intrusion
inland. This would kill the berembang trees the trees fireflies feed on. Without these trees, the unique synchronous flashing display of fireflies in Kg Kuantan will be lost forever. There are only two such colonies in the world, the other being in Brazil. What a loss for posterity! Salt water intrusion, too, will destroy land and agriculture around Kuala Selangor. This follows from examples everywhere where salt water intrusion has occurred.
OPTIONS
Building the dam has been made the first option. Other alternatives should have been looked into. Firstly, preventing leaks, either as stolen water or just plain leaky pipes. Some 37% of the supplied water is lost this way. We should emulate Singapore: it achieves only a 10% loss. As McCully says [2], fix the pipes, spare the river. Fixing leaky pipes together with conservation measures by the public, as well as supplementing with underground water extraction could be enough to offset the shortfall. (Of course in tackling water shortages, dam building has more impact than fixing pipes in terms of doing something!) Then if there is a shortfall, only a small, ecologically-sound dam is required. Underground extraction, however, must be sustainable. Extraction must not exceed replenishment, else the problem of subsidence results. This is a major problem for Mexico City (certain barios are sinking at 30 cm per year), Beijing, Houston (which sunk two meters in 10 years) and many others [2]. Uneven subsidence causes pipes to burst and cables to break and other problems. Costs due to subsidence run into billions of dollars. By making the dam a first option, the need to institute conservation measures and fixing leaks is lost. The pressure on the public and the authorities to be prudent is lost. Wasteful habits will never be curtailed - till the next crisis, maybe.. Rather than the dam, we need a sound, integrated, water-resource management system, and water conservation measures, and even decentralization of population centers. All are needed. Because once a resource is in plentiful supply, the need to conserve and the pressure to save, are lost.
resources, as well as an uneven distribution of income and wealth from the rest of the country. By putting a limit to population growth and development, other areas can now receive better development. We can ensure a more balanced development for the whole country by pushing development away from the Klang Valley. More capital intensive industries could still come here, but the more labour intensive ones could move out. Putting these limits in place will ensure the management of water demand growth, which is at the heart of the water crisis.
water management, pollution, leaks, theft, and so on. - misinformation on the situation - the area served by Sg Selangor is limited to the northern sector of the Klang Valley (not clearly shown in Figure 2.2 - deliberately?) but the analysis for water demand shows the Selangor dam providing water to a much larger area (Figure 2.3, cross-reference with Table 2.1) in the State of Selangor! Is major re-piping taking place?! We enclose detailed comments. The sections in the text below refer to the sections in the EIA.
during the critical anticipated 2003 water crisis year, whilst at that time, the dam will be empty or only filling. This dam, therefore, cannot fulfill the projected requirements for 2003. Even if it was on schedule, it would not meet the requirements as it would still be filling up. The justification given is for a project to meet medium term water needs of Selangor.
Project Description
What is the basis for minimum compensation release? Will this ensure that the aquatic system and river hydraulics will not be affected?
Options
The analysis on options is too brief and does not consider alternative means of sourcing water, only alternative dam sites. If the issue is to solve the potential water crisis in 2003, then all other options should be considered too. For example, groundwater, rainfall harvesting, reducing leaks through old pipes, changing public attitudes to water wastage, water transfer and others.
volume units should all be consistent in S.I. units. Different units MS-1, Mld, MCM etc are used and are awkward to compare; or at least the equivalent in S.I. units should be given.
- The impact to the water table due to elevation of water levels in the dam, seepage flow and potential affects downstream should be assessed quantitatively by modelling groundwater flows. - Siltation and erosion effects during construction and impacts on the river beds downstream should be extended from merely a qualitative discussion as at present in section 4.3.8. There should be a hydraulic model analysis. - The Catchment Management Plan as mentioned in the TOR (2) is not explained. Only the EMP is given. There is discussion of Catchment and
Reservoir Management (5.3) and an Erosion and Sediment Control Plan (ESCP) but the Plan itself is not given. - The residual impacts on the hydrology, hydraulics, geohydrology of the area is not discussed.
D. WATER QUALITY
The Model
The data collected in the study is for four stations only Fig. 3.6 (S1, S2, S3, S4). Other water quality is from DOE stations. For model calibration discharge at the time of sampling water quality must be known. Otherwise, it is not certain for what conditions one is calibrating. However, no discharge measurement at time of sampling is given. In the appendix it is stated that average flow conditions were used for calibration. In Figure C43, a value of 9.72m/l is given for the headwater. How was this obtained? Was water quality sampling carried out at this flow quantity during the study period? If not, what formulation was used to transfer the data to this flow quantity? What about turbidity model analysis? The cadmium (Cd) levels at all four stations S1-S4 of the study exceed the DOE Interim Standards by 3 to 6 times. Therefore, it cannot be considered suitable as a public water supply source. How did the EIA team miss this fact? Drinking water standards for Thailand and the USA give Cd levels of 0.01mg/l as maximum acceptable concentration, and 0.01 mg/l in ambient water respectively. Considering that the hardness of the water samples are less than 25 mg/l the existing Cd levels in the source waters are unhealthy. Cd is a toxic metal and can cause kidney damage when at elevated concentration. There must be detailed investigation to determine the suitability of the proposed reservoir water as a raw water supply and this can have great implications for health. The catchment may have naturally high Cd levels. Attached is downloaded information on Cd concentration standards.
E. VEGETATION
In the flora survey, it was mentioned that a new tree species was found in the dam site area. Only six stems of the species were found within the catchment area (pg 3 12). Considering this new tree species, it is not correct to conclude (pg 4 18) that no rare, endemic or endangered plant species were identified. It seems as if those who wrote the conclusion either glossed over specific findings of the other team members, or worse, did not even bother to read unwanted facts others have found. The area is obviously unique if a new species was found. It must be rare indeed. Considering that only small areas of the catchment were surveyed, which resulted in a new species, the potential for other new species in the area is great.
F. TERRESTRIAL FAUNA
The analysis of conservation status of the study area and habitats is given by the application of a number of indices. However, the evaluation of the sub-indices contradicts some of the descriptions given for each sub- index. It is important to correct these, because the evaluation is based on the summary index. Perhaps the wrong conclusion may have been reached. For example: Vulnerability or ecological fragility defined as likelihood of total alteration to the physical characteristics of the habitat. and ability to cope with changes By that criterion, all areas to be inundated (IA) should be given a value of 10 as there will be total alteration. Only areas not to be altered will be given a value of 1. Representativeness of Habitat defined such that the more the habitat has in common with other similar habitats. Yet it appears that even the rubber plantation is not representative (score = 2).
Scientific value defined as a reflection of its scientific importance for conservation and research. The valuation cannot be made in isolation of other information in the study considering the new tree species found in IA, the scientific value for study of the ecological system must be rated greater than 6.
G. HUMAN ENVIRONMENT
The cultural importance of the Orang Asli spiritual site and ancestral grounds should be explained so that a proper perspective of the area to the Orang Asli can be appreciated. The fact that the Orang Asli have always expected the area to be gazetted for them gives the land a much higher value to them than if they knew the land was never theirs. There should be comparisons to other Orang Asli reserve land in Selangor to indicate their plight and the socio-cultural impacts on them. The Orang Asli have been moved about in the name of development with promises of a better life. These promises have not materialised. It is no wonder that they have decided, for all the promises, that they do not want to be moved this time around just to make way for a water project that does not benefit them, but rather, some faraway people who waste water because they cannot value it.
Is a contingency plan not necessary if a Dam Safety Review is in place? Considering the joints and shears at the dam site itself, will this bring increased risk to the dam itself compared to other dam sites in Malaysia? (See section 3.B on Problems with Dams for a list of the problems, especially on safety.)
Current follies
The 'conquest of nature' approach to river-engineering creates as many problems as it solves. Deforestation increases damaging erosion and destroys a river's watershed. Silt is trapped behind dams, reducing fertility downstream as well as the capacity and life-span of the dam. Downstream silt must be replaced by expensive chemical fertilizers. Dams always carry the danger of collapse due to earthquakes, flooding or sabotage. Casualties from a dam collapse will be much higher than those from normal flooding. Riverine fisheries are destroyed as nutrients (fish food) become trapped behind dams and fish are unable to move up river to spawn. Downstream agriculture, with reduced water and silt flow, is subject to much higher dangers of salination (saltpoisoning). Reservoirs flood the often-fertile land at the bottom of valleys and displace thousands of people to less suitable land or
overcrowded urban areas. Large reservoirs, particularly in hot climates, have enormous losses of precious water through evaporation. Irrigation channels spread disease, particularly malaria (300 million sufferers) and bilharzia, or schistosomiasis (200 million affected). Diking cuts off wetlands which are natural absorbers of flood and provide a wildlife habitat.
REFERENCES
[1] SMHB Sdn Bhd, Detailed Environmental Impact Assessment Study for the Proposed Development of Sungai Selangor Dam in Hulu Selangor, 1999. [2] Patrick McCully, Silenced Rivers: The ecology and politics of large dams, Zed Books: London & New Jersey, 1996
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