CAP and SAM Comments and Objections to the Penang Hill Draft Special Area Plan
We fear that the proposals in the Penang Hill Draft Special Area Plan (SAP) to promote tourism and develop tourist infrastructures will threaten the peace and tranquillity of this nature reserve and its ecology.
These include projects like hotels (about 100 rooms in total, 50 high-class and 50 budget class), the proposal of 2 or more cable cars (strangely not shown in the SAP), the legitimising of illegal farming by promoting organic methods, allowing more housing, retail outlets plus other so called eco-tourism projects.
Penang Hill was nearly lost to development in the 1990s when Berjaya proposed to develop the hill. Fortunately Penangites rallied to protest against the project and halted it when the Save Penang Hill campaign by Friends of Penang Hill (CAP, MNS, SAM, EPSM and civil society groups), brought awareness to Penangites of the importance of the natural heritage of Penang Hill and its many ecological functions like flood prevention and water resource management.
Several water catchments fall within the Penang Hill ridge and the new development project areas. These developments and new constructions will damage the water catchments and affect Penang Island’s water supply. The new developments will also need water supply which is limited on Penang Hill.
Today, the latest Penang Hill Draft Special Area Plan (SAP) is now bringing a tourist development plan to Penang Hill which had a lot of similar features found in the Berjaya proposal in 1990.
While the SAP mentions a great deal about ecological conservation, it is introducing avenues for commercial projects that can proliferate and expand in the future.
The vision of the SAP itself is flawed and contradictory. Its stated objective is to promote tourism and conservation. Tourism is inimical to conserving the ecological integrity of the hill and sustainable development.
Tourism activities cause high consumption of resources and generate excessive waste, leading to the destruction of the hill. This has been seen in Cameron Highlands.
Tourism produces bigger carbon footprints, thus aggravating the problem of climate change and earth warming.
There is a limit to the amount of development and the number of visitors that Penang Hill can sustain.
Large increase in the number of visitors will not only degrade the environment but also change the ambience. In a fragile hill environment, any attempt to upset the delicate ecological balance is a mistake and the consequences will be costly in the long run.
Thus the core principle in the SAP for Penang Hill should be conservation of the area. Conservation efforts should strive to keep the pristine as it is and to rehabilitate what has been altered.
The redevelopment of the Coolie Line and Crag Hotel would produce 100 rooms for tourist accommodation and if the private and government bungalows are to be used as tourist accommodation the number would be even higher.
They would require substantially increased supply of water, energy and transport. All these would have serious impacts on the hill’s ecology and water catchment areas.
The SAP mentions having “passive eco-tourism” such as aviary parks or bird watching centre, herbarium, mini zoos and butterfly farms.
These activities are very unnecessary and their artificial character is in contradiction to the open natural environment of Penang Hill. Having them may even lead to situation in the future where larger-scale zoos, aviaries and tourist sites will be built.
There is also repeated mention of allowing cafes, health services such as aromatherapy, reflexology and so on.
Such activities will only lead to commercialisation more intense and heavy than ever before- paving the way for the “Bukit-Bintangisation” of Penang Hill.
The carrying capacity for an ecologically sensitive area such as Penang Hill should consider the optimum number of persons in a said place that the hill environment can sustain without an unacceptable degree of deterioration of the character and quality of the environment, or the recreation experience that the visitors expect of the place.
In peak holiday seasons, the tourist load has already topped the maximum carrying capacity of 8,000 of the Bukit Bendera Local Plan. Visitors have topped to 10,000 during these periods.
The SAP had introduced new carrying capacity figures which are different from those in the gazetted Bukit Bendera Local Plan. The SAP must follow the same figure in the Local Plan and not introduce new ones.
Limits to Development
There must be limits to the development of a hill ecosystem such as Penang Hill as it is fragile. The limits of constraints are set by ecological features of the hill system and any development and use beyond the ecological limits would result in the degradation of the hill system, such as soil erosion, pollution of the streams, rivers, land slips and landslides, and loss of valuable plant and animal species.
New construction on steep slopes should not be permitted because of the potential negative impacts of such construction activity, in the light of use of heavy machinery, earth-works, or cut-and fill operations.
The Cable Car project is not in the SAP, but has been linked to it during the launch of the SAP without any explanation of the rationale behind it.
The current number of visitors to the hill has already exceeded its carrying capacity. Therefore what is the need for the cable car?
Also, the new high-speed funicular rail line has been installed to replace the old one, at a cost of RM73 million in 2011. This should render the cable car very unnecessary and redundant.
There is certainly no need for additional infrastructure to carry people to the hill. It should be noted that there is also a jeep track from the bottom to the top.
We object to any proposal of cable car to the Penang Hill as it would ferry more visitors and result in a drastic change in the hill’s natural atmosphere.
If the constraint of limited access helps to maintain the special characteristics of Penang Hill, then that constraint need not be seen in a negative light but as having a positive function.
We also have to look at the traffic congestion and parking facilities at the ground stations. The peace and tranquillity of Municipal Park (Youth Park) and/or the Rimba Rekreasi in Teluk Bahang will be affected. They cannot be called parks anymore if stations are built there.
Promoting organic farming is commendable but there must be certain restrictions.
Growing vegetables and flowers on the hill slopes for the market should be discouraged as they lead to serious soil erosion.
They can grow nutmeg and fruit trees.
Illegal farmers should over a period be resettled and the land be allowed to regenerate the forest cover.
There must be a single law enforcement authority for the SAP area.
The authorities must also enact stringent ecological protection law for the other hills in Penang.
The recent destruction of the Bukit Relau highlights the urgent need for such law. The greedy developers are eyeing the hills having destroyed the urban spaces and lowlands.
The SAP says: “Removing these local farmers may not be possible; however the impact of agricultural activities can be reduced through the adoption of Good Agricultural Practices (GAPs).”
Does this effectively serve as an amnesty for farmers who have been operating illegally, while cutting slopes and removing sections of forest? The SAP should include a plan to record and take action on these illegal farmers.
There should be provision to rehabilitate the forest areas that have been damaged due to illegal farming.
If indeed there are GAPs as proposed in the SAP, how will they be implemented and enforced with certainty? The problem with damaging farming practices has been a recurrent issue.
Adequate water supply is crucial to any development that will increase usage of the Hill by both transient visitors and residents. This would include public toilets and other facilities that needs constant water supply.
Presently Penang Hill is supplied by water from the Tiger Hill service reservoir.
The supply here is limited and if Penang Hill is to be developed, water will need to be pumped up from other catchments to meet the new demand which can be very high for tourism-related developments. This will be at the expense of the lowland population of the island.
Penang Hill is one of the last remaining natural forest sanctuaries for Penangites. The forests of Penang Hills are pristine and estimated to have existed in similar conditions for about 70 million years. The reason that the forests have remained as they are in the north central hills of Penang Island is that they have been gazetted as water catchment areas as well as forest reserves. Penang Hill is a treasure trove of plants and animals.
There are over 78 species of birds found here and some plants are known to be only found on Penang Hill. A number of small animals also live here. The Penang Hill area is the headwaters of several streams which form part of the two main river systems of Penang Island.
The natural heritage of Penang Hill is a treasure that we must protect. It must be saved from tourism development and commercialisation. Development on Penang Hill should be controlled, not expanded.
Press Release, 13 December 2013