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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

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

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. If we were to follow this demand. the ancestral lands of the Orang Asli which would be innundated by the dam. Some proponents of the dam even simplify the issue to the question of “fireflies or water for humans?”.water or birds. the proposed dam must be deemed unviable and must not be built. BASIC ARGUMENT: DRAWING THE LINE Where do we draw the line in protecting things dear to our hearts? In fact. Every time there is a water shortage. What Are We Losing? WATER DEMAND GROWTH Every year. the EIA study is an incomplete and an inconclusive piece of work. there is no drawing-the-line. we retreat and resign ourselves again to the fact that a few more precious things would have to go. the same argument would be given . some endangered species like the serow (kambing gurun).so goes the exhortation. when everything that conservationists have been struggling for. In the name of development we need to sacrifice . pristine. there has been an increase in demand for potable water of 9% for Selangor (including Kuala Lumpur) [1]. after the Selangor Dam satisfies the present shortfall. 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. 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). is sacrificed in the name of development.Without the answers. 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. then every time there is a shortfall in water supply. nature reserve of Selangor. Without them. . in the last decade. new sources must be found. whitewater rafting in Sungai Selangor. tapir and the panther [1].

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

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

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

total national water supply was 10. water cross-reference with Table 2. In addition. WATER CRISIS JUSTIFICATION PLEASE NOTE: In 1998.622 million litres per day. Why was there a water shortage when supply is greater than demand? (source: http://corp.the area served by Sg Selangor is limited to the northern sector of the Klang Valley (not clearly shown in Figure 2. pollution. so why the focus here? From exec. and so on.water management.jkr. .my/air/STAT/DEMAND. The sections in the text below refer to the sections in the EIA.1) in the State of Selangor! Is major re-piping taking place?! We enclose detailed comments.221 million litres per day and total national demand was 8. filling to take two wet seasons (2 years?)" Thus the dam will only be ready and functioning in 2005.misinformation on the situation .HTM) Please provide data on the shortfall in water supply for the State during the last drought. (ES-2:) "Dam construction is due to take three years (2000 – 2003). A.3. 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. leaks. This will affect intake water-quality downstream . pipe leaks? The area served by the Sg Selangor apparently did not experience a water shortage.deliberately?) but the analysis for water demand shows the Selangor dam providing water to a much larger area (Figure 2. pollution. dam construction. That cannot meet the anticipated water crisis projected for 2003.2 . summary. clearing and building works will potentially result in siltation and increased turbidity downstream.

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. The justification given is for a project to meet “medium term water needs of Selangor”.during the critical anticipated 2003 water crisis year. 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. 2.2 is unclear. Water Supply and Demand Projection On what basis is Table 2.2. the dam will be empty or only filling. water transfer and others. If the issue is to solve the potential water crisis in 2003. it would not meet the requirements as it would still be filling up. Even if it was on schedule. changing public attitudes to water wastage. reducing leaks through old pipes.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. rainfall harvesting. This dam. only alternative dam sites. . groundwater. For example. whilst at that time. therefore. cannot fulfill the projected requirements for 2003. 2.1.3 Water Demand Projection for 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? Fig. then all other options should be considered too.

for a feasibility study. . . it is incredible that it failed to be noted in the reference list. The question otherwise then arises: Does such a report exist? Although 2. more analysis of flow before and after present dams construction and impacts. reference no. Section 2. Water . HYDROLOGY. No analysis is analysis shown for compensation flow requirements. Considering the importance of this report as the basis for the whole project justification.76 does not exist. TECHNICAL FEASIBILITY STUDY REPORT On Page 2 – 7. .no analysis shown for drought possibility... C. we hope the hydrological information is not at a “conceptual level”.why no measurements at dam site? . HYDRAULICS.6.why only tables given? .no consideration of impact on estuary ecosystem although this is recognised as an important impact in Section 4.5 Project Description a recently completed technical feasibility study report is mentioned as reference no.4. Hydrology is the most important factor in building a dam. 76.B. It should be included as an appendix to the EIA report and a summary of the findings described in the main report. It needs to be based on a solid study and research. In the reference list. .5 is purportedly engineering information based on the report. GEOHYDROLOGY In Section "Hydrology and Hydraulics Regime". however.

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

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

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

but rather. 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. Some data for Terengganu are given.5 on Dam Safety. 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. G. H.Scientific value defined as a reflection of its scientific importance for conservation and research. RISK ASSESSMENT should be given. DAM RISK ASSESSMENT Section 4. There should be comparisons to other Orang Asli reserve land in Selangor to indicate their plight and the socio-cultural impacts on them. for all the promises. some faraway people who waste water because they cannot value it. 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. 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? . These promises have not materialised. 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. 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 material that follows has been provided by New Internationalist: http://www. Casualties from a dam collapse will be much higher than those from normal flooding.oneworld. Downstream silt must be replaced by expensive chemical on Problems with Dams for a list of the problems. especially on safety.) 3.html Current follies The 'conquest of nature' approach to river-engineering creates as many problems as it solves. Downstream agriculture. Reservoirs flood the often-fertile land at the bottom of valleys and displace thousands of people to less suitable land or . Riverine fisheries are destroyed as nutrients (fish food) become trapped behind dams and fish are unable to move up river to spawn. is subject to much higher dangers of salination (saltpoisoning).Is a contingency plan not necessary if a Dam Safety Review is in place? Considering the joints and shears at the dam site itself. with reduced water and silt flow. Dams always carry the danger of collapse due to earthquakes. More Information on Dams A. Deforestation increases damaging erosion and destroys a river's watershed. reducing fertility downstream as well as the capacity and life-span of the dam. flooding or sabotage. will this bring increased risk to the dam itself compared to other dam sites in Malaysia? (See section 3. Silt is trapped behind dams.

particularly in hot climates. There could be a shift in weather patterns which affect rainfall. in part. . India (27 maf vs 22. He did a comprehensive study of these problems. 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. continues where they left off. Large reservoirs. More would mean dam safety and breaching conditions need greater safety limits. blotting the environment. but quite useless in its purpose.) We list a few of the problems McCully mentions without much elaboration: Global warming is a wildcard. Shouldn't there be more studies first to look at this phenomenon before the Selangor Dam is built? We could have another costly structure. a 1986 publication but not McCully's 1996 book.overcrowded urban areas. To name a few: Buendia-Entrepenas. yet water levels in our dams are falling. which. McCully listed many dams not meeting its forecasted filling capacity. Spain (less than half filled. 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. 17% filled). Less would mean the dam is useless. Diking cuts off wetlands which are natural absorbers of flood and provide a wildlife habitat. There could be more rainfall or less. Thailand's 25 largest dams total of less than half filled in 1991. Sardar Sarovar on the Narmada River. but worsened to only one-third in 1992.7 million acre-feet actual). or schistosomiasis (200 million affected). Problems With Dams The problems mentioned below are largely from Patrick McCully’s book [2]. have enormous losses of precious water through evaporation. In 1994. RM1. Irrigation channels spread disease.96 billion. (The EIA put as reference Goldsmith and Hilyard's The Social and Environmental Impacts of Large Dams.7 maf). Colorado Storage Project (projected flow of 17.5 million acre-feet vs 11.

even though it was predicted to last between 75-100 years. In 1987. "It is now obvious that the original project estimates of expected sedimentation rates were faulty. Koyna. they may well be big troubles. 17 dams failed between 1990-95. a survey of US Federal dams concluded that one-fifth of the Bureau of Reclamation's 275 dams are unsafe. completed in 1981 will be useless by 2000.Sedimentation reduces storage capacity: Sanmenxia Dam." 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). 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. Is it true that the Kenyir Dam experienced an RIS of 2. their structures become weak as time goes by. a planned 1.0 sized earthquake on the Richter scale. Aswan. India (103 m). partners of New York consulting engineers TAMS.3. . China. Egypt (111m). A 1990 World Bank working paper on India's dams concluded. Nepal. a dam burst killing 250.5 to 4. This problem has not been discussed much by dam proponents (probably pretending it is not there)." Even dredging costs to remove sediments run into million of dollars from experience in the US. as were one-third of the 554 dams operated by the Corps of Engineers. a 6. and sedimentation makes them useless and dangerous. Binger. Hoover Dam.200 megawatt storage became a 250 MW actuality.6. say. "When a big project has troubles. China lost one-third of its storage capacity. based on too few reliable data over too short a period.6 on the Richter scale? What are the possibilities of the Selangor Dam experiencing RIS? Dangerous dams and Decommissioning: Dams become old. USA (221m) experienced a 5. China. Yangouxia Dam. There have been RIS in more than 70 dams. a 5.000 people. In 1975 in Henan Province." Reservoir Induced Seismicity: This is earthquake induced by a huge body of stored water. even before it was commissioned! Kulekhani Dam. Hydropower Reform Coalition "believes that removing a hydrodam will cost more than building it. As John Lowe III and Wilson V.

[2] Patrick McCully. There are other weighty problems . actual $30-50bn. Japanese Encephalitis.4bn. 1996 HOME @ INDEX @ BULLETIN @ ARCHIVE @ DAM ALERT @ DAM SPECS @ C. actual $20 bn.” 1999. Narmada.ecological. water-borne diseases (malaria.P REPORT @ GUESTBOOK . $10. Itaipu. A sample: Three Gorges Dam. Brazil. Zed Books: London & New Jersey. estimated. REFERENCES [1] SMHB Sdn Bhd.A.Cost and time overruns: In Table 9.3 McCully listed some 30 cases of cost and time overruns. Silenced Rivers: The ecology and politics of large dams. latest estimate Rs342bn.7bn. $3. etc) listed by McCully which we will not go into because of time considerations. bilharzia. Rs42bn. “Detailed Environmental Impact Assessment Study for the Proposed Development of Sungai Selangor Dam in Hulu Selangor. China.