On 30 March 2022, SAM submitted our comments to the Department of Environment on the Environmental Impact Assessment (EIA) for the proposed masterplan development called Maharani Energy Gateway in Muar, Johor.
Following are the project background and a summary of the comments we submitted. A copy of the full comments can be downloaded here.
The full EIA Report can be viewed here.
The Maharani Energy Gateway is the development of an energy hub and deep-sea port. The main project components are:
- 10 STS (ship-to-ship) slots at approximately the 24mCD contour;
- Plot A – 1,500 acres (607 ha) artificial island for oil and gas storage and deepsea port operation; including Jetty
- Plot B – 1,500 acres (607 ha) artificial island for future development of petrochemical plant;
- Plot C – 200 acres (80.9 ha) artificial island for future development of ship repair and facilities; and
- Floating liquefied natural gas terminal include trestle and regasification station for Boil-Off-Gas.
The main activities involved in the reclamation stage for the man-made islands are the transportation of sea sand from Malacca, sand filling work, compaction and bank revetment works.
Summary of Comments
Our assessment is that the quality of the EIA is far from adequate, and cannot be approved as it exists, for the following reasons:
- The legal and policy matters – The EIA cannot be approved if it contradicts the gazetted Muar District Local Plan and Johor State Structure Plan. Further, a reclamation project of this nature requires clearance from the National Physical Planning Council as required under section 20B of the Town and Country Planning Act 1976.
- The Statement of Need fails to take into account the urgency to address climate change and the global transition to renewable energy – thus exposing itself to serious financial risks due to stranded assets. The proposed project will also jeopardise Malaysia’s ability to meet its Nationally Determined Contribution under the Paris Agreement.
- The environmental impact assessment fails to take into account the sea level rise projections for Malaysia due to climate change.
- The EIA has failed to assess the potential impact of tidal intrusion due to sea level rise and climate change and also whether the proposed project will cause saline intrusion along Sg. Muar.
- The problem of flooding and stagnant water in the study area is a common phenomenon. One of the recreational sites, Pantai Mesra Sri Penanti, is already facing erosion due to impacts from waves during high tide. Meanwhile, Kampung Sri Menanti has been experiencing inland flooding/inundation whenever there is a high tide phenomenon. Given sea level rise and climate change, the proposed project may further aggravate the situation.
- The deduction that the impact of the reclamation activities on mangroves is insignificant because the hydraulic stimulation study found that the proposed works will have no impact on water level is again baseless due to the questionable conclusion from the water level impact assessment.
- Loss of fishing grounds and hindrance of access to the sea for fisher groups.
- Reclamation and sand mining will result in permanent loss of the seabed habitat.
- The proposed removal of the belt of mangroves is intolerable given that mangroves play an important role in mitigating and adapting to climate change and tsunami. Malaysia should aim to enhance the protection of mangrove areas and restore it instead of removing them.
- Incomplete Marine Risk Assessment study – Part B of the study is not available in the EIA.
- Lack of a comprehensive economic valuation assessment and cost and benefit analysis.