REGIONAL ENVIRONMENTAL AWARENESS CAMERON HIGHLANDS

No.1, Jalan Besar, 39100 Brinchang, Cameron Highlands, Pahang Darul Makmur
Tel: 05-491 4950, 491 5950 Fax: 05-491 5832 E-mail: reach@reach.org.my
http://www.reach.org.my

20th June 2004

Comments on the Supplementary Report “DEIA FOR THE PROPOSED REHABILITATION

OF RINGLET RESERVOIR, CAMERON HIGHLANDS” submitted by Tenaga Nasional
Berhad June 2004.

“Malaysian rain forest is among the oldest in the world, and is more than 100 million years old. It
is a heritage that has been recognized for its rich biodiversity and genetic pool holding secrets for
the survival of the whole human race.”(People Before Profits – The Rights of Malaysian
Communities in Development, 2001, SIRD & SUARAM).

“Tropical rain forest ecosystems such as that of the study site are extremely complex ecosystems
with rich and varied lifeforms. These life forms have evolved over many years and have established
linkages with one another and the surrounding environment. Many of these linkages have still not
been well understood. Any interference to such an ecosystem will surely disrupt such an environemt
and the long-term impacts and the recovery is not always accurately predictable.

In the highland areas there are always additional concerns, because of the steeper terrain renders
the area more inclined to soil erosion and slower recovery rates. It is thus very crucial to be able to
estimate the impact of the intervention and ensure that the impacts do not exceed the threshold level
that will allow the overall natural systems to recover from the intervention.

The forests of the study site have additional value, as it is the last few remaining parcels of
forestland within Ringlet that are still undisturbed. The forests within the study area are a diverse
undisturbed montane forest that is very valuable simply because of the scarcity of such ecosystem
within the country.” (Additional Information – DEIA for the Proposed Rehabilitation of Ringlet
Reservoir, Cameron Highlands February 2004 prepared by TNB Research Sdn Bhd.)

1. Status of Permanent Forest Reserve

a. It is made to understand that Forestry Department has not till now degazetted the area
identified within the Forest Reserve within the Sg. Jasik/Jasin area for the proposed
dumping site. How is that the project can proceed if the necessary approval has not
been given? If this is true, then it is violating the National Forestry Act 1984, Section
10-13 and 15.
b. The said area is classified as Lower Montane Forest (Montane Oak Forest), which
according to TNB’s earlier report (Feb 2004) is scarce and limited in the country.
Therefore, the justification for using primary forest, which is rare in occurrence,
needs a detail scrutiny. Other more suitable areas need to be considered. Please see
attached pictures taken on 20th June 2004 of TNB reserve area presently occupied by
farmers as a suitable area for the dumping of silt. We do not agree to the justification
in pg 6-5.

Protect Mother Nature, Protect Our Future.

 c. The earlier report (April 2003) states that the silt dredged is too contaminated to allow
any further regrowth, except weeds. How is then the reforestation programme going
to proceed in such a poor landscape? There is mention of future dumping of silt in
the said area (pg 6-6, June 2004). If that is the case, what is the logic of reforesting
the said area?

2. Future plans
a. In the April (2003), Appendix 5 Ecological Study there is mention of dredging
activities being abandoned altogether because of the risk of Methyl-mercury
contamination in the environment (Schultz et. al. 1995). Methyl-mercury has
dramatic health impacts such as neurological damages, and devastating effects on the
developing human embryo if ingested by pregnant women (Rosenberg et al., 1997).
What is TNB doing about this to prevent further downstream contamination of the
river water?
b. It is doubtful that only desilting work shall be able to restore the reservoir’s full
storage capacity (live storage) and its flood mitigation function (pg 8-1). Other
integrated measures are needed to address upstream issues such as unsuitable farming
methods, indiscriminate land clearing, etc. which involves other agencies.
c. The current siltation rate of 300,000m3/year, we estimate with unplanned
development upstream, the dredged silt lake will be filled up within the next 5 years.
TNB should not hastily clear the prime forests to dump the silt, instead use disturbed
areas such as farms and secondary growth areas.
3. Adequate drinking water
a. There is already a drastic reduction of clean drinking water supply in Cameron
Highlands. Both the quantity and quality of drinking water from primary forests is
reducing by the day. What is the guarantee that by further reducing the forested area
in Cameron Highlands, that the current situation is not exacerbated.
b. Of 123 rivers in Cameron highlands, only about 10% are classified as Class I and
Class II. Two of the rivers having clean drinking water is Sg. Jasik and Sg. Jasin.

4. Geology
a. Jabatan Mineral and Geoscience have identified the area as a “sensitive area” in the
previous meeting. As the area lies within a fault line, this area should not be
disturbed and the use of heavy machinery will have irreversible damage. Has TNB
taken special note to this point?

5. Land transport
a. In the previous meeting, there was a suggestion for TNB to build a flyover at the
Road Crossing. TNB’s consultant estimated the cost of the flyover to be
approximately RM1million. This suggestion is not reflected in Section 5.2 (pg 5-2,
June 2004).
 6. Water Quality
a. It is stated in the April 2003 DEIA report, that dredging may mobilize agricultural
chemicals and heavy metals in sediments. It is expected that the water quality will
deteriorate further with the dumping of the dredged silt. The relocation activities of
the silt will reduce water quality at the site from Class I to Class III or potentially
even Class IV due to high levels of suspended solids. It will be almost impossible to
rehabilitate the area after it has been contaminated.
b. In the previous meeting, the Chairman together with the Review Panel had rejected
the “One fish report” produced by TNB on the methyl-mercury monitoring. In the
June 2004 Supplementary Report, there seem to be no substantial information on the
methyl-mercury monitoring. Data is not given to show the extend of contamination
in the fishes sampled.

Recommendation

1. REACH strongly recommends that according to the National Forestry Act 1984, an equal
area of land should replace any degazettement of Permanent Forest Reserve.
2. The 14th National Forestry Councils’ meeting on 28th December 1998 agreed that forests that
are above 1000m have been accorded protection forest status, for regulating water resources,
biodiversity protection and to ensure soil stability. This decision has far and wide reaching
implications on the study area. REACH urges that National Forestry Councils’ decision be
implemented to the fullest.
3. REACH recommends that instead of using only one large undisturbed forested area, we
suggest that TNB use several disturbed sites, such as Sg. Kilat, Sg. Khazanah and Sg. Sok
Moi (pg 6-5, June 2004) for the purpose of dumping the dredged silt. REACH believes that
the combined area of the above mentioned sites can accommodate the amount of dredged silt.

Conclusion

With the latest information provided by TNB through the Supplementary Report June 2004, and
after further reviewing the previous reports (April 2003 and February 2004), TNB is not able to fully
justify the selection of the proposed site, i.e. Sg. Jasin and Sg. Jasik for the dumping of the dredged
silt.

REACH rejects the DEIA and the supplementary information for the proposed rehabilitation of
Ringlet Reservoir, Cameron Highlands.

All Figures 1-6 are within TNB reserve in the Sg. Sok Moi area. Pictures taken on 20th June 2004.
Fig 1. Road leading to Robinson Falls intake showing farms
on either side of TNB reserve (Sg. Sok Moi)

Fig 2. View of valley with farms along the

road leading to Robinson Falls intake (Sg. Sok Moi)

Fig 3. Electricity Transmission Line along

the road to Robinson Falls with farms under it (Sg. Sok Moi)
 Fig. 4. Flattened farm land within the Sg. Sok Moi area
which is suitable for dumping of the dredged silt

Fig 5. Gentle slopes within the Sg. Sok Moi area,

which is less, forested compared to Sg. Jasik/Sg. Jasin

Fig 6. Another view of the farm lands within

Sg. Sok Moi area which is suitable for dumping of dredged silt.