The Selangor Dam EIA

More Questions Than Answers

The Department of the Environment EIA Review
Date: 15th April 1999 by

Concerned For Sungai Selangor (CFSS)
c/o No. 10, Jalan 7/2 46050 Petaling Jaya Selangor

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

we cannot make an informed judgement on the Dam’s viability. reference 76 is not even listed.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 1. Without answers to the questions we pose in the following sections. therefore. Concern For Sungai Selangor: Our Stand The Environmental Impact Assessment Report The Environmental Impact Assessment Report [1] on the proposed Selangor Dam is unprofessional in its study. Please refer to our technical questions in section 2. As an example of shoddy work. The answers to the questions are important to determine how the EIA reached its conclusions and recommendations. . It. It is a shoddy piece of work. We have listed the questions posed according to the sections involved. If anything. has not changed our present judgement that the dam is unviable. It is hard to imagine how the EIA can help convince its commissioner. the EIA only strengthens our conviction that the dam is not only unviable. that the dam is a sound proposal. It raises more questions rather than provides answers. it is unnecessary. or even the authors of the EIA itself. And it is the most important reference of all: the technical feasibility report for the Dam.

If we were to follow this demand. is sacrificed in the name of development. and the unaccounted for ecological chains of fauna and flora affected by the inundation and the altered flow of the Selangor river once the dam is in place. after the Selangor Dam satisfies the present shortfall.water or birds. Some proponents of the dam even simplify the issue to the question of “fireflies or water for humans?”.Without the answers. the same argument would be given . And the last. this time? Where would it end? The inability to “draw the line” inevitably leads to the point where we no longer need to draw-the-line anywhere: when everything close to our hearts. the proposed dam must be deemed unviable and must not be built. Without them. there is no drawing-the-line. tapir and the panther [1]. the ancestral lands of the Orang Asli which would be innundated by the dam. . we retreat and resign ourselves again to the fact that a few more precious things would have to go. What Are We Losing? WATER DEMAND GROWTH Every year. some endangered species like the serow (kambing gurun). whitewater rafting in Sungai Selangor. then every time there is a shortfall in water supply. new sources must be found. when everything that conservationists have been struggling for. BASIC ARGUMENT: DRAWING THE LINE Where do we draw the line in protecting things dear to our hearts? In fact. there has been an increase in demand for potable water of 9% for Selangor (including Kuala Lumpur) [1]. the EIA study is an incomplete and an inconclusive piece of work. in the last decade. The trouble is that some of the things we hold dear to our hearts might have to go too! The fireflies in Kg Kuantan (and probably the community that supports the eco-tourism based on the fireflies). nature reserve of goes the exhortation. Every time there is a water shortage. The real questions are these: What are the limits to growth? Where do we draw the line? What are the things that give meaning to life? Five years down the road. In the name of development we need to sacrifice . pristine.

A growth of 9% in water demand each year means that water consumption/supply doubles nearly every 8 years. we need an alternative development path. in those two hours we would already be in Kg Kuantan marveling at the fireflies. 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. 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 everything dear to us is gone. Thus. or just quietly being in harmony with nature somewhere in the wilderness. things that give meaning to the quality of our lives. If we were to follow the present trend in water consumption. If there are things we hold dear to our hearts. in two hours. or whitewater rafting at Sg Selangor.000 mld. we must question the conventional wisdom of growth and more growth caused by population and development. in 2006 it will be 5000 mld. and so on. we will only end up with concrete jungles and their sterile gardens . the two growths that hunger for more water each year. Consumption in 1998 is 2500 million litres per day (mld). in 2014 10. Otherwise. i. if these mean that Selangor or Kuala Lumpur can only support a certain size of population and of development. in the present KL (which is already bad enough with its pollution and congestion). why not draw the line here and now. The difference between normal flow and after damming would lead to salt water intrusion . in 2022 20. or in Kuala Selangor enjoying the bird sanctuary. when no more water anywhere is available.if there are sterile gardens at all! And a Kuala Lumpur the size of Jakarta or Bangkok where.To prevent the inevitability of losing everything. It is these little pleasures that make for a good and meaningful quality of life. This is much lower than even during the dry season. we would still be in a traffic jam trying to escape the crowded and polluted city. by 2003 all the available water sources of Selangor and Kuala Lumpur would dry up [1].. At least.000 mld. then this is where we draw the line. We must pose the “drawing-theline” wisdom.e.

we need a sound. Houston (which sunk two meters in 10 years) and many others [2]. DECENTRALIZATION OF POPULATION AND DEVELOPMENT Development and population are heavily concentrated in the Klang Valley. Without these trees. We should emulate Singapore: it achieves only a 10% loss. Rather than the dam. will destroy land and agriculture around Kuala Selangor. and even decentralization of population centers. “fix the pipes. the need to conserve and the pressure to save. Some 37% of the supplied water is lost this way. OPTIONS Building the dam has been made the first option. the other being in Brazil. and water conservation measures. Extraction must not exceed replenishment. else the problem of subsidence results. (Of course in tackling water shortages. integrated. as well as supplementing with underground water extraction could be enough to offset the shortfall. maybe. Beijing. By making the dam a first option. Other alternatives should have been looked into. are lost.. As McCully says [2].inland. Because once a resource is in plentiful supply. spare the river. This would kill the berembang trees the trees fireflies feed on. Underground extraction. either as stolen water or just plain leaky pipes. the need to institute conservation measures and fixing leaks is lost. This draws a disproportionate consumption of natural . ecologically-sound dam is required. All are needed. too. This follows from examples everywhere where salt water intrusion has occurred. the unique synchronous flashing display of fireflies in Kg Kuantan will be lost forever. Wasteful habits will never be curtailed . preventing leaks. What a loss for posterity! Salt water intrusion. only a small. dam building has more impact than fixing pipes in terms of “doing something”!) Then if there is a shortfall. There are only two such colonies in the world. however. water-resource management system. must be sustainable.” Fixing leaky pipes together with conservation measures by the public. Uneven subsidence causes pipes to burst and cables to break and other problems.till the next crisis. Firstly. Costs due to subsidence run into billions of dollars. This is a major problem for Mexico City (certain barios are sinking at 30 cm per year). The pressure on the public and the authorities to be prudent is lost.

what was the analysis based on?) . and whether the dam or interstate transfer should come first wrong conclusions . By putting a limit to population growth and development. other areas can now receive better development. as well as an uneven distribution of income and wealth from the rest of the country. Technical questions on the EIA Summary We have severe reservations on the completeness of the EIA and have reservations about whether the project consultants and proponents exercised impartiality in looking at options to the dam due to: . but the more labour intensive ones could move out.the objective and conclusion do not conform . Putting these limits in place will ensure the management of water demand growth.incompleteness of information in the report(in particular on hydrology and water demands) . which is at the heart of the water crisis. thus all options should be considered and compared (cost-benefit analysis). The water crisis was also precipitated by poor . More capital intensive industries could still come here.there was no water shortage in areas served by the Sg Selangor during the drought. only the option of where to place a dam is considered. However.the objective is to ensure adequate water supply. We can ensure a more balanced development for the whole country by pushing development away from the Klang Valley.inadequate analysis of data (as no data was given.resources. the shortage was in other areas served by dams.

gov. summary.HTM) Please provide data on the shortfall in water supply for the State during the last drought. . water theft. What is the drought potential of last year’s drought? Was the problem of water crisis due to supply or mismanagement of water course. and so on. That cannot meet the anticipated water crisis projected for 2003. cross-reference with Table 2. Why was there a water shortage when supply is greater than demand? (source: http://corp.jkr. (ES-2:) "Dam construction is due to take three years (2000 – 2003). pipe leaks? The area served by the Sg Selangor apparently did not experience a water shortage. so why the focus here? From exec. In addition. clearing and building works will potentially result in siltation and increased turbidity downstream.water management.622 million litres per day.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.deliberately?) but the analysis for water demand shows the Selangor dam providing water to a much larger area (Figure 2. theft. pollution.misinformation on the situation .3. leaks. filling to take two wet seasons (2 years?)" Thus the dam will only be ready and functioning in 2005. total national water supply was 10. This will affect intake water-quality downstream . WATER CRISIS JUSTIFICATION PLEASE NOTE: In 1998.2 .221 million litres per day and total national demand was 8. dam construction.the area served by Sg Selangor is limited to the northern sector of the Klang Valley (not clearly shown in Figure 2. A.

. water transfer and others.3 Water Demand Projection for Selangor. changing public attitudes to water wastage. reducing leaks through old pipes. What is the potential demand for the area to be served by Sungai Selangor Dam Treatment Plant? The analysis given is for the whole of Selangor. Even if it was on schedule. Project Description What is the basis for minimum compensation release? Will this ensure that the aquatic system and river hydraulics will not be affected? Fig. Water Supply and Demand Projection On what basis is Table 2.1 calculated? What is the rate of population increase? What is the area of supply of the ten water supply areas and their water source? Figure 2. the dam will be empty or only filling. 2. cannot fulfill the projected requirements for 2003.during the critical anticipated 2003 water crisis year. whilst at that time. For example.2 is unclear. rainfall harvesting.1. then all other options should be considered too. it would not meet the requirements as it would still be filling up. only alternative dam sites. groundwater. This dam. 2. What is the projection for the area to be supplied by the dam project? Options The analysis on options is too brief and does not consider alternative means of sourcing water. The justification given is for a project to meet “medium term water needs of Selangor”. therefore.2. If the issue is to solve the potential water crisis in 2003.

.76 does not exist. In the reference analysis of flow before and after present dams construction and impacts. Section analysis shown for compensation flow consideration of impact on estuary ecosystem although this is recognised as an important impact in Section 4. . GEOHYDROLOGY In Section "Hydrology and Hydraulics Regime".. more importantly.5 Project Description a recently completed technical feasibility study report is mentioned as reference no.6.4. 76. reference analysis shown for drought possibility. it is incredible that it failed to be noted in the reference list. Water . HYDROLOGY. we hope the hydrological information is not at a “conceptual level”.why only tables given? . . TECHNICAL FEASIBILITY STUDY REPORT On Page 2 – 7. for a feasibility study. No analysis is shown. Considering the importance of this report as the basis for the whole project justification.5 is purportedly engineering information based on the report.why no measurements at dam site? . however. . The question otherwise then arises: Does such a report exist? Although 2. It needs to be based on a solid study and research. It should be included as an appendix to the EIA report and a summary of the findings described in the main report.. Hydrology is the most important factor in building a dam. C. HYDRAULICS.

seepage flow and potential affects downstream should be assessed quantitatively by modelling groundwater flows.Drought analysis for the particular catchment. .3. or at least the equivalent in S.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. The estuary only for the firefly ecosystem but also for fisheries culture around the river mouth area. Hydrology. Hydraulics and Geohydrology The report should include: . .8. Modelling is important not and shellfish .Measurement of discharge at the dam site.Hydrological analysis of the particular dam catchment and comparison to the whole Selangor catchment hydrology.volume units should all be consistent in S. MCM etc are used and are awkward to compare. Different units M³S-1. .The impact to the water table due to elevation of water levels in the dam. Mld.Hydraulic model analysis should be shown for river channels due to compensatory flow discharged from the should be shown for impact on the estuary. units. units should be given. Only the EMP is given. . There should be a hydraulic model analysis.I. There is discussion of Catchment and .I. impact on the dam.The Catchment Management Plan as mentioned in the TOR (2) is not explained. .

Therefore.6 (S1. hydraulics. S4). The catchment may have naturally high Cd levels. In the appendix it is stated that average flow conditions were used for calibration. it is not certain for what conditions one is calibrating. it cannot be considered suitable as a public water supply source.72m³/l is given for the headwater. Other water quality is from DOE stations. 3. no discharge measurement at time of sampling is given. Attached is downloaded information on Cd concentration standards. . . S2. geohydrology of the area is not discussed. 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. How was this obtained? Was water quality sampling carried out at this flow quantity during the study period? If not. In Figure C43. How did the EIA team miss this fact? Drinking water standards for Thailand and the USA give Cd levels of 0. D. 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. a value of 9. Cd is a toxic metal and can cause kidney damage when at elevated concentration.3) and an Erosion and Sediment Control Plan (ESCP) but the Plan itself is not given. For model calibration discharge at the time of sampling water quality must be known. Otherwise.01mg/l as maximum acceptable concentration. However.The residual impacts on the hydrology. and 0. WATER QUALITY The Model The data collected in the study is for four stations only Fig.01 mg/l in ambient water respectively. S3. Considering that the hardness of the water samples are less than 25 mg/l the existing Cd levels in the source waters are unhealthy.Reservoir Management (5.

index. Considering that only small areas of the catchment were surveyed. which resulted in a new species. The area is obviously unique if a new species was found. did not even bother to read unwanted facts others have found. For example: Vulnerability or ecological fragility defined as “likelihood of total alteration to the physical characteristics of the habitat…………. Considering this new tree species. It seems as if those who wrote the conclusion either glossed over specific findings of the other team members. Representativeness of Habitat defined such that “the more the habitat has in common with other similar habitats”. it is not correct to conclude (pg 4 – 18) that “no rare. Perhaps the wrong conclusion may have been reached. endemic or endangered plant species were identified”. VEGETATION In the flora survey.” and “ability to cope with changes…………” By that criterion. It is important to correct these. . the potential for other new species in the area is great. all areas to be inundated (IA) should be given a value of 10 as there will be total alteration. Yet it appears that even the rubber plantation is not representative (score = 2). it was mentioned that a new tree species was found in the dam site area. F.E. Only six stems of the species were found within the catchment area (pg 3 – 12). or worse. It must be rare indeed. TERRESTRIAL FAUNA The analysis of conservation status of the study area and habitats is given by the application of a number of indices. Only areas not to be altered will be given a value of 1. the evaluation of the sub-indices contradicts some of the descriptions given for each sub. However. because the evaluation is based on the summary index.

that they do not want to be moved this time around just to make way for a water project that does not benefit them. The valuation cannot be made in isolation of other information in the study considering the new tree species found in IA. DAM RISK ASSESSMENT Section 4. the scientific value for study of the ecological system must be rated greater than 6. H. 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. There should be comparisons to other Orang Asli reserve land in Selangor to indicate their plight and the socio-cultural impacts on them. some faraway people who waste water because they cannot value it. 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. but rather. The Orang Asli have been moved about in the name of development with promises of a better life. It is no wonder that they have decided.Scientific value defined as a reflection of its scientific importance for conservation and research. These promises have not materialised.5 on Dam Safety. for all the promises. What are the Seismic events expected due to the dam? How does this dam design and size compare to other Malaysian dams? What would the dam failure scenario be like? Who/What would be affected? . RISK ASSESSMENT should be given. Some data for Terengganu are given.

Is a contingency plan not necessary if a Dam Safety Review is in place? Considering the joints and shears at the dam site itself. reducing fertility downstream as well as the capacity and life-span of the dam. especially on safety.) 3. with reduced water and silt flow. is subject to much higher dangers of salination (saltpoisoning). Deforestation increases damaging erosion and destroys a river's watershed. 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.html Current follies The 'conquest of nature' approach to river-engineering creates as many problems as it solves. Dams always carry the danger of collapse due to earthquakes.B on Problems with Dams for a list of the problems. Downstream agriculture. flooding or Downstream silt must be replaced by expensive chemical fertilizers. More Information on Dams A. Silt is trapped behind dams.oneworld. The material that follows has been provided by New Internationalist: http://www. Reservoirs flood the often-fertile land at the bottom of valleys and displace thousands of people to less suitable land or . will this bring increased risk to the dam itself compared to other dam sites in Malaysia? (See section 3.

Thailand's 25 largest dams total of less than half filled in 1991.96 billion.5 million acre-feet vs 11. particularly in hot climates. Shouldn't there be more studies first to look at this phenomenon before the Selangor Dam is built? We could have another costly structure. Colorado Storage Project (projected flow of 17.7 maf). He did a comprehensive study of these problems. There could be more rainfall or less. Sardar Sarovar on the Narmada River. Problems With Dams The problems mentioned below are largely from Patrick McCully’s book [2]. a 1986 publication but not McCully's 1996 book. but worsened to only one-third in 1992. In 1994. have enormous losses of precious water through evaporation. but quite useless in its purpose. To name a few: Buendia-Entrepenas. Diking cuts off wetlands which are natural absorbers of flood and provide a wildlife habitat. Have the built up areas changed the pattern? Or is global warming already playing a role? We are now seeing the paradoxical situation where rain is falling almost every day in the city. There could be a shift in weather patterns which affect rainfall. Large reservoirs. in part. Irrigation channels spread disease. More would mean dam safety and breaching conditions need greater safety limits.overcrowded urban areas. which. blotting the environment.) We list a few of the problems McCully mentions without much elaboration: Global warming is a wildcard. RM1. particularly malaria (300 million sufferers) and bilharzia. Already we are seeing a shift in rainfall pattern from the dam catchment areas to the Kuala Lumpur built up areas. yet water levels in our dams are falling. 17% filled). India (27 maf vs 22. (The EIA put as reference Goldsmith and Hilyard's The Social and Environmental Impacts of Large Dams. Less would mean the dam is useless.7 million acre-feet actual). Spain (less than half filled. continues where they left off. or schistosomiasis (200 million affected). . McCully listed many dams not meeting its forecasted filling capacity.

200 megawatt storage became a 250 MW actuality. partners of New York consulting engineers TAMS. Is it true that the Kenyir Dam experienced an RIS of 2. China lost one-third of its storage capacity. completed in 1981 will be useless by 2000. and sedimentation makes them useless and dangerous. China. even before it was commissioned! Kulekhani Dam.0 sized earthquake on the Richter scale." Old dams then need to be decommissioned (defined as anything from stopping electricity generation to removing it completely and restoring the river to its pre-dam state)." Reservoir Induced Seismicity: This is earthquake induced by a huge body of stored water.6. In 1975 in Henan Province. 17 dams failed between 1990-95. they may well be big troubles. say. a 6.000 people.5 to 4.Sedimentation reduces storage capacity: Sanmenxia Dam. This problem has not been discussed much by dam proponents (probably pretending it is not there). "It is now obvious that the original project estimates of expected sedimentation rates were faulty. A 1990 World Bank working paper on India's dams concluded. even though it was predicted to last between 75-100 years. There have been RIS in more than 70 dams. India (103 m).3. a survey of US Federal dams concluded that one-fifth of the Bureau of Reclamation's 275 dams are unsafe. their structures become weak as time goes by. Hydropower Reform Coalition "believes that removing a hydrodam will cost more than building it. a 5. Hoover Dam. Binger. Koyna. Egypt (111m). Yangouxia Dam. "When a big project has troubles. as were one-third of the 554 dams operated by the Corps of Engineers. Aswan." Even dredging costs to remove sediments run into million of dollars from experience in the US. Nepal. USA (221m) experienced a 5. Most severe cases are reported for dams higher than 100 meters (Sg Selangor Dam will be crested at 110 meters) but even dams half this height are also believed to be vulnerable. a planned 1. a dam burst killing 250.6 on the Richter scale? What are the possibilities of the Selangor Dam experiencing RIS? Dangerous dams and Decommissioning: Dams become old. China. As John Lowe III and Wilson V. based on too few reliable data over too short a period. In 1987. .

actual $30-50bn. Itaipu. Silenced Rivers: The ecology and politics of large dams. estimated. water-borne diseases (malaria.P REPORT @ GUESTBOOK . etc) listed by McCully which we will not go into because of time considerations. Rs42bn. Narmada. There are other weighty problems . Japanese Encephalitis. Brazil.4bn.ecological. [2] Patrick McCully.Cost and time overruns: In Table 9.A. China. bilharzia. “Detailed Environmental Impact Assessment Study for the Proposed Development of Sungai Selangor Dam in Hulu Selangor. latest estimate Rs342bn. A sample: Three Gorges Dam. 1996 HOME @ INDEX @ BULLETIN @ ARCHIVE @ DAM ALERT @ DAM SPECS @ C. $10. actual $20 bn.” 1999.7bn. $3. Zed Books: London & New Jersey. REFERENCES [1] SMHB Sdn Bhd.3 McCully listed some 30 cases of cost and time overruns.

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