Aug 15, 2007

Possibilities of a truly integrated development?

After spending the morning low tide documenting the reclamation on Sentosa's shores, I went to view the Marine Environment Report for Resorts World on the reclamation project for the Sentosa IR (referred to as EIA or Environment Impact Assessment in this post.)

I'm not an expert, so here is a very layman take on the document.

Aspects covered
The report covered impact to currents and conditions for operations at Cruise Bay, quality of water at the intake to Underwater World, erosion and other impact on Sentosa Gateway Bridge and Pulau Brani, impact to nearby habitats including the reefs on Sentosa's Tanjung Rimau, at Labrador Nature Reserve and mangroves at Belayar Creek.

During the dredging and reclamation process, a limit will be set on the production of 'spill' (which is what makes the water murky).

The report concludes there won't be much serious impact on all these elements.

Surveys of the affected area conducted over two days at subtidal depth (highest depth was 2.8m) suggested low coral cover ranging from 20-8% and 2 species of seagrasses (Halophila minor and Enhalus acoroides). The survey found that most corals there were 10-50cm in diameter, with some specimens exceeding 50cm. Data was provided suggesting the live hard coral cover at the site was lower than average, and that the size of the site was a tiny proportion of all our reefs.

The impact to reefs and seagrasses are compensated by relocation of appropriate portions of the existing reef to another suitable location. Details of these are pretty much what has been reported in the media. The relocated portions will be monitored for a year, looking at state of health, mortality rates, water quality and siltation at the new site. There will be reports provided on this monitoring.

In addition, a portion of corals on the Sentosa shore will monitored during the dredging and reclamation for impact.

While there was a mention (in a tabulation) of the cultural heritage value of the reef, this was not touched upon in the conclusion.

Aspects not covered
I couldn't find mention of an intertidal survey.

Biodiversity list
There was a long list of hard corals and of a few other marine life found at the affected sites. Including some genera I didn't see on the intertidal.

What is the reclaimed land going to be used for?
From the Resorts World at Sentosa website
My thoughts

I am not an expert on EIAs and thus can't competently comment on the technical issues. I can't say whether proposals were adequate or have been properly implemented according to industry standards.

If an EIA is primarily intended to show proof that there was mindful development, my layman impression is that some key issues were addressed in the EIA.

It is certainly commendable to attempt to avoid mindlessly destructive development.

But further thoughts occurred to me after reading the EIA ...

Beyond Damage Control: Exploring all possibilities for our city

Instead of just mitigating the damage, why not plan to integrate existing natural heritage into the project?

This would benefit Resorts World, Sentosa, Singapore and the ordinary Singaporean.

How so?

Resorts World and Sentosa would have natural features that are uniquely Singapore. Living reefs just across from major shopping and commercial districts -- minutes from the city centre! Natural shores with natural seasonal changes provide continuous attraction year round.

Resorts World and Sentosa would save money. Upkeep of natural shores would be far less than keeping specimens alive in a tank. Not to mention the cost and damage in obtaining the tank specimens from the wild.

Singapore would gain know-how about integrating existing natural features into first-world facilities. This was an opportunity to prove Singapore's capability for sustainable city development with our own natural heritage. A capability that can be exported.

Ordinary Singaporeans would continue to enjoy our natural heritage. At lower cost than in a man-made facility. We will enjoy fresh air, real sand, and truly Singaporean marine life. Instead of exotic animals from elsewhere, and put behind glass. We can be proud that we can develop without losing what nature has granted in our care. Or taking from the reefs of other countries.

Instead of breaking up the reef and relocating small pieces elsewhere, why not adjust the design to integrate the natural shore? After all, there are plans for a marine theme to the development.

And Resorts World at Sentosa's tagline is "Where Imagination Lives". A little imagination might have gone some way to for a truly integrated development.

The EIA viewing process

Prior to this, I had a nearly 2-week email exchange with Sentosa about viewing the EIA. Full email exchange on wildsingapore.

I wanted to know if I could take notes on my laptop and post my views about the EIA online

I was told that Sentosa "regret to inform that any electronic devices capable of recording and editing such as digital cameras, handphones, laptops, personal digital assistants (PDAs)..etc, are not allowed in the viewing room. "

"We do not object to your posting of personal views on the internet. However, you will not be allowed to quote extracts from the report due to proprietary reasons."

I found this rather puzzling as the Government Gazette stated that the EIA was for "public viewing".

Regarding the issue of "proprietary reasons", I asked if the copyright vests in the government and not the consultants, and since the government isn't planning to publish and sell this, and wants the public to provide feedback what's the harm to the government if its contents are circulated for non-commercial purposes to facilitate public feedback?

I also asked, how would Sentosa proposed that I express personal views without stating the contents of the document? If I rephrase the contents to the point that they are no longer direct quotes, wouldn't then this be unfair representation of the document?

Sentosa's response was "We encourage interested parties to inspect the report personally, rather than obtain the information through 3rd party channels so as to avoid misrepresentation of its findings through 3rd party sources."

The most effective way to achieve this would surely be to post the EIA online! I suggested this.

This contrasts with their current arrangement of prohibiting recording devices which essentially means I was reduced to copying the EIA by hand.

In the final response, Sentosa said "On your suggestions to online viewing, we regret to inform that it will not be made available for this disclosure exercise."

When I arrived to read the EIA, I was told not to deface the documents and made to sign to agree to abide by the "proprietary" nature of the documents. Handphone and all other stuff was removed from the room; besides my notebook (the kind made from dead trees), ballpoint pen and my personal notes.

Nicole was nice and I gave her the Guidesheet to the Southern Shores to show her our reefs. The kind lady at the front desk of Sentosa Office shared that she grew up on Pulau Saking and remembers fondly her time at low tide exploring the reefs there with her father.

My comment on the EIA viewing process

The current process doesn't allow for thoughtful comment based on careful checks of independent data and reference to resources. It makes discussion difficult, among stakeholders and with independent experts.

The EIA was also released for public viewing AFTER reclamation was already well underway.

The entire situation makes it difficult to provide objective, useful feedback.

It is hard to avoid the conclusion that feedback is not genuinely sought.

I find this puzzling. Elsewhere, much effort is made to encourage active citizenry and to gather feedback from stakeholders through road shows and focus groups. In fact, a major initiative was recently announced to gather e-feedback on environmental issues as well as other issues.

Too late for Sentosa, but not too late for our other wild places?

It might be too late for the magnificently large and old corals on Sentosa that were buried in the reclamation.

But I believe it is never too late to learn so that we can do better the next time.

To be mindful when considering replacing genuine uniquely Singaporean features for artificial features that can be found in any other metropolis. To encourage a more creative approach and early consultation among stakeholders.

Surely this will contribute to a better home for all? Where together, we explore ALL the possibilities for our city.

Sentosa has just announced plans to develop the wooded foothills of Mount Faber:"Mount Faber was being tapped because the 500-ha Sentosa island was 'quickly running out of room'"

Here is another opportunity to explore all possibilities!

The url for this post has been forward to the following
Nicole Tan
and the contents is also is permanently online at wildsingapore

Your comments?
I have posted this on the blog so that you can add your comments to it. Sentosa has indicated that "the public disclosure period ends on 17 Aug 07" so do try to post your comments before this time.

More links
Doomed Sentosa shore with links to flickr photos, blog entries and more.
Coral relocation and announcement of EIA various media reports
Sentosa's treasure island of coral By Teh Jen Lee New Paper 25 May 07


haojie said...
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haojie said...

Thanks, Ria. Can I clarify whether you were allowed to take handwritten notes? And when you said the reports on monitoring would be provided. Did the EIA report indicate that these reports would actually be made available to the public?

I would like to share my experience with EIAs in Singapore for the benefit of those not familiar with how Singapore does their EIAs. There is no EIA legislation in Singapore. EIAs are entirely at the discretion of the authorities, and when carried out, the form of the Report and its transparency and openness are also entirely at the discretion of the authorities.

As a matter of practice, for the past few years, ever since Singapore and Malaysia had the international dispute about the environmental impacts of reclamation activities at Tekong and inter alia whether an EIA had been done properly, resulting in the matter being referred to an international tribunal (which inter alia ordered that a joint EIA be done) and subsequently settled out of court on confidential terms, the authorities have been making EIA Reports available for public viewing for reclamation projects only. Why only reclamation projects?

The transparency and accountability of EIA Reporting practices in Singapore are nowhere near international best practices (even though the Reports are typically prepared by internationally renowned consultants). Notably, there is very little publicity. The availability of a Report is 'publicly' announced once in the government gazete (how many of us ever read that?). The Report is typically made available for viewing only at a designated location during office hours (so one has to take time off work to read it) by prior appointment under the watchful eye of one of the staff of the authority making the report available. The voluminous report is not available for viewing or download online, and copying of the report in whole or part is prohibited. So this makes it difficult for anyone to seriously study or scrutinise the report or give substantial comments on it. Furthermore, I have observed that on a number of occasions, the preparatory work for the reclamation work (eg relocating the coral) takes place at the same time that the report is made available for public viewing. So what does this say about the sincerity of the authorities in welcoming feedback? Any feedback given is also not made public, so no one knows how many people wrote in, what feedback was given, and what the authorities' response was.

Coming to the substantial quality of the reports, I have noticed that the reports typically assume the need for the project and do not consider the reasonable alternatives to the proposed development, and the predicted impacts of these alternatives. After describing the project, they go straight into evaluating the impact and recommending mitigation and monitoring measures. Once again this is not in line with international practice. The correct way to do an EIA is to consider whether the project is necessary in terms of what will happen if the project is not carried out. Then consider the reasonable alternatives to the development as proposed, and their associated environmental impacts. Finally choose the one without serious or significant impacts as possible after weighing the benefits of each proposal, and propose mitigation and measures for the significant impacts that are unavoidable for the chosen alternative.

In conclusion, I believe it is within the capability and resources of the authorities to carry out a proper EIA and subject it to rigorous public scrutiny - one only need look at how the matters potentially affecting businesses are consulted on. What is lacking is the political will to do a proper EIA. This is probably due to a number of factors (my guess) - transparency and openness are characteristics the current political regime is not known for; the authorities are only too aware of the limitations of their EIA reports, and would rather as few people as possible read and critique it. As long as the report has been made available to the few locals able to read it during office hours on the authorities' premises, the authorities can proudly proclaim locally and internationally that they have made their EIA reports public. I don't think the authorities are sincere about substantial critiques of the EIA, particularly from independent international an local experts, particularly since they seem to have already decided, independently of the EIA and the public feedback, that the project is to go ahead and are only interested in looking into the mitigation measures that could be carried out.

beachbum said...
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ria said...

Thanks haojie for the very informative background!

Yes I took notes by hand and was allowed to take the notes back with me. Nicole didn't sit with me throughout and I was left alone to look through the documents.

I did send Nicole an email afterwards, asking whether the monitoring reports would be made public. Am awaiting her response.

ria said...

Nicole's response (received on 22 Aug) is below:

"On the viewing of the coral monitoring reports, as this is a private project, the reports will not be made available to the public. However, the information can be made available upon request, on a case-by-case basis."

haojie said...

Ha ha ha, reclaiming Sentosa is a private project? So citizens need not concern themselves about it? What does on request on case by case basis mean? More restrictions on accessibility of information? So now the state of the environment in Sentosa is a private affair? Then why bother making the EIA report public in the first place? It's just for show, right, Nicole? Hey, and while they're at it, they might as well declare all development projects on the other islands, and on the main island private projects as well. The political regime is simply shirking from its public responsibility and accountability by hiding information from the public domain. Is this how a regime that claims to be world class should behave? Looks like every time they put out an EIA report (assuming they put one out in the first place), they hide more information than they disclose. Utterly disappointing but so not out of character of this habitually secretive regime.

Monkey said...

hate to express a feeling of futility but these EIAs should be opened to the public way in advance before the works actually start! In the US, proper public consultation works in such a way that you should have the EIA, consultation or seeking feedback, going back to the drawing board then releasing the final plans and starting work ONLY after feedback for EIA and not before! :o sometimes they even have workshops where stakeholders can come together to jointly discuss alternatives and plans etc. but of course that is all a bonus when right now we have to go through so much red tape just to view the elusive EIA. how would this encourage people to feedback if people like myself feel its a futile effort?

Batfird Otakueh and Hatspam Fquirrel said...

It is clear that the authorities view tourism and development as seperate entities from conservation and the environment, even though given the extremely limited area we have in Singapore it should be a priority to pursue an integrated approach as Ria has mentioned. For all the hype about supporting the green movement (Did anyone read the recent news about our authorities making climate change and the environment a priority issue at the next APEC conference?), this is very disappointing indeed.

That said, power to the people. Even though i'm a tad late on the feedback, I still would like to thank you for making this issue accessible to the public. I will get my students to read and reflect on this!

- Huijia

ria said...

Reply from REACH received 18 Sep 07

Thank you for your patience while we ascertained which agency would be able to respond to your feedback.

The Ministry of National Development has provided the following reply, which we are forwarding to you on their behalf:

MND's reply

"We note your feedback on the public consultation process and will advise developing agencies to take this into consideration for future projects.

We would also like to highlight that the Resorts World had informed us that the activities being carried out during the EIA disclosure period were demolition works to the ferry terminal structures, not reclamation works.

To prevent and minimize water pollution, temporary sand bunds were built to contain any fallen debris from the demolition of the two ferry terminals.

Thank you."

Please feel free to contact us again should you have any further feedback on this or other issues.

ria said...

Thanks Huijia for sharing your thoughts.

And I'm glad you'll be raising awareness of the issues with your students as well.

Thank you!

YC said...

May I dare suggest to Sentosa that in future they blindfold viewers of their EIAs?