As a Malaysian citizen who is concerned about the environment and health of the rakyat, I would like to comment on the Appendum EIA that was released for public feedback recently. There appears to be some improvements with regards to decrease in soil erosion and sedimentation in the new site (shifted 200 metre south-east from the original site), however, what is worrying is that the problems highlighted in the Detailed EIA for Broga/Semenyih 2003 have not been resolved.

For instance:

1) The incinerator site is too close to residential areas and the University of Nottingham. According to the Planning Guidelines for Incinerator Site 1999, published by the Town and Rural Planning Department Peninsular Malaysia, large-scale incinerators where toxic waste and solids are combined and processed, should be sited far away from public places. The distance should be at least 50km radius from sites of major development.

However, according to the Detailed EIA 2003, there are 400,000 people living within a 10km radius from the planned incinerator site. The closest housing area is Taman Tasik Semenyih and Kampung Broga which are merely 2km away from the site. The planned project is definitely in conflict with the planning guidelines from the Ministry of Housing and Local Government which published the 1999 guidelines, evidently for the safety of the public.

2) The new site is still within a water catchment area, i.e, between Sg Saringgit and Sg Rinching, and both these small rivers feed into Sg Semenyoh which provides drinking water to more than 1.5 million people in the Klang Valley and Selangor including Bangsar, Petaling Jaya, Puchong and parts of Shah Alam.

Clean water is our right and the Department of Environment (DOE) should understand the importance of clean rivers as a source of drinking water for the people. The incinerator must not be built in a water catchment area, as have been promised to us by the director of DOE and the Menteri Besar of Selangor.

3) No matter where the incinerator is located, it is well documented throughout the world that incinerators release toxic gases during operation. According to the Detailed EIA 2003, the main emissions from incinerators are dioxins, a group of chemicals that is known to be carcinogenic.

The report also acknowledges that the most poisonous is 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) that is known to affect the nervous system, reproductive and immune system. The International Agency for Research on Cancer classifies TCDD as a class 1 cancer causing agent, for instance, testicular, prostate and breast cancers.

4) Although it is moved to a new site, a portion of the site is still on slopes of more than 25 degrees, a reduction from 9 ha to 3 ha. This is clearly in conflict with the cabinet's announcement since the Highland Tower's tragedy, that development at slopes of more than 25 degrees should not be allowed. To built an incinerator on hill slopes and in a water catchment area is asking for trouble.

5) As there is no site for landfill nearby the planned incinerator to contain the toxic fly ash, tonnes of ash would have to be transported to another location. This toxic ash that contains various heavy metals and inorganic traces including dioxins will endanger the health of people living along the routes of trucks carrying the ash. In the event of accidents, the result would be catastrophic.

6) The incinerator is built on agricultural land. The local people depend on the land for their livelihoods. Most people in the area tap rubber, grow vegetables, tend orchards, farm fish and rear chickens. If this project goes ahead, they will loose their source of income and their work and lives will be disrupted. Food production, most of which is sent to Kuala Lumpur for sale, will stand the risk of contamination with an incinerator that is built so close by.

For the above reasons, the director of the DOE, cannot approve the site that is planned for the incinerator.

We want development, but we do not want a project that brings such high hazards and risks for such little benefits. We urge the government to find alternative means that are safer and more environmental friendly, for instance, recycling and sanitary landfill to manage Klang Valley's mounting trash. Malaysia is only recycling less than 3 percent of our waste, and we are already opting for the biggest incinerator of its type in Asia, compared to Japan that is recycling 20 percent.