2. BEACH
2. So in this BREATH submission, I would like to mention on the 6 key items not omitting points already raised in the first submission.
2.1 2.2.2.1 Beach (based on SEIA reference)
The existing 1.4 metre Tg Aru beach (TAB) is unlikely to be improved with a new beach (not water front) with quality and wider one.
2.2 The reasons are as follows:-
2.2.1 Can you show me one that has been done without costly maintenance to maintain it as a sandy beach?
2.2.2 Given that the equilibrium of the new waves/currents and water level would be finding its new positioning, the area would be affected in unknown possibilities.
2.2.3 Nothing is for sure how the new scenario would develop as the Tg Aru Beach or its hinterland proper would be a new structure of dredged area and raised ground levels of Beach 2, and Beach 3 and beyond towards Petagas.
2.2.4 Again nothing is for sure how erosion would emerge with the areas of the new beach and instead of getting quality wider beach, more unexpected erosion could occur as it was in the 1980s and 1990s due to the massive sea filling around the Kota Kinabalu port area now and in the near future when it was in Sinsuran and Segama (1980s) and 1990s (Suria Sabah site) areas in Kota Kinabalu City.
2.2.5 The damage of the critical climate change especially in Sabah which had seen increase of 3 degrees centigrade for 40 years from 1960 to 2000 according to the official weather statistics. [Source : Book titled “Water” by Joshua Y. C. Kong.] So how can anyone be sure the new artificial beach of whatever artificial nature be assured of no damage in the immediate future and possibly irreparable as left to the ravages of the weather as exacerbated by the worsening climate rises globally affecting all the oceans.
2.2.6 So this SEIA is just superficial as far as the justification of a very expensive artificial new beach at Tg Aru for the replacement of a very beautiful natural sandy beach just needing some improvement with common sense after a due diligence exercise with the hind sight of improvement at minimium costs and effort. The sort of expected “quality and wider new” beach could be non functional at all.
2.2.7 Would TAB in its present much neglected conditions all known for more than two decades due to the relevant authorities fault be re-invigorated by the planting of adequate mangrove trees with appropriate conducive landscape and generally clean up of the prevailing mess?
3. RECLAMATION
3.1 2.2.25 Reclamation of TAED
3.1.1 This is definitely a non starter as where in the world is there such a massive reclamation of 444 acres including substantial part of sea to the depth of 3 - 9 ? meters? The parameters of this operation such as soil availablilty from the sea nearby or land further afield can very much disturb the environment temporary or permanently. The SEIA has not sanctioned the Standard Operation Procedure for such massive reclamation operation to be adhere to and that the parties concerned would strictly comply with such specific stipulated SOP.
3.1.2 This SEIA has not considered the status of the coastline of the west coast of Sabah with the reclamation in the context of erosion given the water/current pressure has to be diverted to elsewhere except some have said that the current is not strong in the area. Who would now know how would the direction of current after China had a massive reclaimed area in the nearby Spratley islands zone?
4. EROSION
4.1. 3.1.3.1 Erosion
4.2 This item is done in great style by DHI as illustrated with data of SPY 1966 for the next 48 years and quote “threatened within 5-10 years unless remedial action is taken”
4.3 So DHI suggests the sole solution is a beach front or sea front with massive reclamation as earlier commented in 3.
4.4 How would the edition of SPY 1966 be reliable and comparable now in the context of scale, technology then and now, and why anyone was interested in the TAB in 1966?
4.4.1 Why now more attention is drawn to the less prominient and more remote area in the third beach?
4.4.2 Why not DHI secure the recent satellite images of Spot Asia for more appropriate comparison in 1987 and 2014 to give more assertive data?.
4.4.3 TAEDSB CEO did not qualify in his statement of the specific areas with acute erosion hence misrepresentation.
4.4.4 Solving the erosion with massive reclamation is akin to curing “cancer” with “cancer”, both remotely possible and costs - initial outlay and annual maintenance - prohibitive with uncertain results and bordering on an ecological bigger disaster in the making.
5. AIRPORT
5.1 The Airport is such an important item in parallel to the TAB throughout the length and yet the SEIA Report only briefly mentioned it in some instances.
5.2 With the massive reclamation towards the sea at a higher level and the Kepayan hills at the other side of the airport, the airport can be a valley of sort and nobody knows how the water would flow and accumulated in an area especially a valley in scenario of flash floods coupled with high tide. Even KLIA2 was flooded at the apron and some part of the tarmac recently.
5.3 To end any dispute of that to happen or not, the choice is for the public to accept any argument and it is more appropriate that we give a value to the airport so that when it is destroyed by whatever reasons in whatever situations including disturbance to any plane in flight, the parties concerned would be held fully liable. TAEDSB is likely in a precarious position to take the full blame for the “demise” of the Airport or KKIA and KKIA2..
6. TREES
6.1 What will happen to the existing valuable endemic trees or flora is anyone to imagine. For an ecological project like Tanjung Aru Eco Development, it is likely that most of the existing exotic old trees would perish especially with the massive reclamation impacting the roots adversely in the present second and third beach.
6.2 To cut the argument short, we need to give each existing tree as marked a certain value and monthly audit be done once operation/development is started and the compensation be given to various assigned NGOs.
6.3 The trees are also resting/transit place for some priceless exotic birds without any value to be attached to that. TAEDSB would argue that any trees lost would be replaced and of course with the young also likely “alien” plants.
7. HABITAT
7.1 2.2.2.2 Public Park and Amenities
The inclusion of the many artificial facilities in this list is just an excuse to do what are not really needed even with TAED making it no longer an eco project but likely a semi-commercial undertaking and if all these facilities are utilised to the full the likely over-crowding in times to come would be counter productive for those who would be the residents in the area. Woes like parking, cleanilessness, pollution and noise level would be prohibitive for the sustenance of the prevailing transquility of the Tg Atu Beach now. We are not assured of the exact nature of such new amenities in the context of ecology.
The increased size of Prince Philip Park is irrelevant as it is not a proportionate increase of the overall area including an exclusive Golf Course.
All the lack of amenities under KKCH cannot be an excuse for the massive development of TAED. When KKCH failed, the State and Federal Governments had also failed. Don’t use this stupid excuse to destroy Tg Aru Beach in 3 beaches beyond recogition. With TAED, a massive ecological disaster is just waiting to happen.
7.2 SOLE NATURAL SANDY BEACH IN THE CITY
It has been indisputeable that TAB is Kota Kinabalu’s sole comfort zone left for decades for leisure and sun set watching plus the birds’ calling place. It would never be the same again with the proposed massive very costly physical and eco-adverse project. Many would miss it once it is gone especially with the recent awareness of the beach.
7.3 State Land to be maintained as socio-economic status.
7.3.1 The status of the state land including the foreshores, seashores, open sea area as reclaimed should be gazetteed as stateland to prevent them falling into possession of others in any malfunctions of economic or commercial development. Sabah had lost too much state assets - land and otherwise including the sole Sabah bank. None of the land of TAED as a prime heritage site should be charged to any bank/finance agency to avoid the onerous situation should abandonement of the TAED occurs.
7.3.2 Although TAED is claimed to be owned and managed by the State, there is doubt and lack of transparency when the status of the Chief Executive Officer is in doubt. Not all the land in TAED had been purchased at genuine market value.
7.3.3 So whatever land of the State must be declared in a Gazette as State assets prior to the start of the project. Lets do an accounting accordingly. Otherwise it is a “private” project on largely public domain and implication of abuse of power and criminal breach of trust. The titles of the TAED land should be exhibited.
8. CONCLUSION - 8 BREATH points
8.1 It is very important that there is a mechanism of monitoring and accounting as once TAED is started, it is beyond control of the public as many items are unspecified in the revised SEIA.
8.2 Nothing is best or better as a natural sandy beach than anything else like the unreachable and untouchable Sun.
8.3 The reclamation process would present a period of uncertainty for our breath as pollution would be too abundant to be tolerated be it from the source of materials from the sea to the hills to be cut.
8.4 We have tolerated the minimum erosion from the waves for decades and the associated mess from our severage system as mismanaged for some years, and so far has anybody took a serious look using economical and natural mangrove swamp plus some bunding to recover our beach to reduce the battling of the waves and high tide? Mangrove trees would be the favoured ecological approach.
8.4 The airport is a crucial public asset to be maintained at all cost and who would guarantee that after TAED?
8.5 The valuable endemic trees and any such trees lost in the process of developmment should be compensated based on a pre-determined value.
8.6 Nothing is best except with the natural habitat of TAB largely untouched since time immemorail to be re-structured with such a socalled eco project when it is not so “eco” as it is in its so far disclosed purpose and intention.
8.7 Where would TAEDSB secure its fund of RM45m annually to manage and maintain TAB after TAED to avoid another massive “eyesore”.
8.8 Why touch anything that has not been done before and don’t try to do it better than God in His sole domain on Earth for our own BREATH comes from God WITHOUT a doubt.
[ will submit a signed copy later ]
BREATH submission by Joshua Y. C. Kong, P. O. Box 11923, 88821 Kota Kinabalu.
Chartered Accountant, Author, Founder Member of Sabah Environmental Protection Association, Social/political activist, poet, servant of God, 22/12/2014
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