With a report full of contradictions and unprofessionalism, you would be forgiven if you thought this is a PMR English writing exercise instead of a full-fledged Environmental Impact Assessment report. The thing that gives it away is that it came in three hefty volumes, dragging from one flaw to the next. A miserable read, I can assure you.

Yes, we are talking about the Environmental Impact Assessment (EIA) report for the proposed Kelau and Telemong dams in Pahang and why it must be rejected by the EIA review panel.

The fauna study for the impact on animals was done only over a two-week period. They acknowledge the limited study period as they say, "it should be noted that wildlife studies normally take a few years, with trail studies carried out at various times of the year," and, "due to limitations of the EIA study, there is a need for additional surveys and studies."

For the wildlife study they suggest a further two years at the minimum!

For the fishery study, it was done over a two-week period in January, and another one in April "by netting at a few locations." Again, "it is proposed that more detailed field studies be carried out prior to the dam construction."

They propose a further "one year study period."

Similarly with the flora study. The study was done on a one Hectare plot. According to Dr Appanah, former head of the Natural Division, Forest Research Institute Malaysia, an area of study covering 5 per cent of an inundated area must be taken, i.e., 77.5 Ha (he was commenting on the inadequacies of the Selangor Dam EIA study, but it applies here too).

Build first, studies later

The inadequacy of study is, again, admitted. In the conclusion on flora, they say "more long term botanical exploration will be most beneficial to provide a larger stock-taking of forest species which will be inundated," and they again stress, "in view of the loss of 1,549 Ha of the Lakum Forest Reserve, there is a need to pay particular emphasis on the potential conservation losses.

However, due to the limitations of the EIA study, there is a need for additional surveys and studies within the affected areas of the forests."

They propose another year of study.

What they are in fact saying is, we should have done a two-year minimum study on wildlife, another one year study on fishery, and yet another one year study on the flora before submitting this EIA.

We have not done that, but please pass this EIA first. The studies can be done later.

Now, this is one (of the many) bit that I'm wary about. The Department of Environment (DOE) should have checked the contents of the EIA first before okaying it for public comment and for the EIA review panel (that passes or rejects the EIA).

With such glaringly inadequate studies, admitted by the consultants themselves - and on the two most important aspects of the study, the fauna and flora - how could the DOE have allowed this EIA?

Another thing that makes my hair stand. The tone of the EIA is as though the construction of the dams is a foregone conclusion. The EIA is supposed to present the case, objectively, warts and all, and let the parties concerned make a judgement.

Exercise in futility

But no. It is as though the consultants are the proponents themselves. For example, as above, it is typical for them to write, "It is proposed that more detailed field studies be carried out prior to the dam construction."

Studies prior to the dam construction? If more negative impacts, like unacceptable losses to fauna and flora, are discovered, what then? I bet the construction will go on. No, the EIA is supposed to give the complete picture. It would be unacceptable to table the EIA as it is now, pass it, and do more studies later. For what? Just so it sounds good - more studies?

The Selangor dam EIA is worse. It proposes more studies on the impact of the dam on the firefly community after the dam is built! The dam is being built now.

If studies - and better yet, just watch what's happening to the fireflies - show that the fireflies are dying, what then? Study for the sake of studying. The ultimate academic exercise in futility.

The DOE produces EIA Guidelines to help in writing up an EIA. Now, the most important indication of the likely impacts from the Kelau and Telemong dams would be past experiences of other dams - Kenyir, Temenggor, Klang Gates, Semenyih, etc.

The Guidelines requires "inspecting similar projects elsewhere in Malaysia" for study. (Only one particular experience in Kenyir, of animals trapped on islands formed by impoundment, is cited.)

Heavy losses of animals

You would think this is the most natural thing to suggest and the immediate thing a consultant would do when they suggest this or that might happen. Nothing doing. They happily suggest that fish will easily move to other areas without checking whether this is indeed the case before.

It does sound reasonable but is that reality? Past experiences have indicated the opposite, of losses to fish species.

For animals, on the one hand the EIA suggests that on inundation, wildlife will move to the adjacent area. On the other, it states, "The best line of action is recommended but heavy losses of animals especially the small mammals will certainly take place it is known that survival rate [in general, not just small mammals] is very low."

However, later, one of the conclusions to the section merely states, "development of the area should allow migration of animals into the undisturbed forests." This leaves the impression that the above mentioned problems do not exist.

And "the proposed mitigation, if fully implemented, should leave no animals trapped in the reservoir area, and hence there is no issue of affecting overall diversity or conservation status".

By now you would be fuming mad. What has the rescue of (relatively) few animals (if any) trapped on islands got to do with the overall biodiversity when the consultants themselves have already stated that survival rate of animals moving into the remaining forest is low?

Reading this EIA and other EIAs in general, one gets the impression that conclusions are at odds with the detailed analyses if the detailed ones point to negative impacts. For me, this oddity can only be understood if one looks at the fundamental flaw of this whole EIA business: the inherent conflict of interest.

Conflict of interest

The conflict is at two levels. Firstly, a developer of a project appoints a consultant to write an EIA report, on its behalf, justifying the project. A report with too many negative impacts will be rejected and thus the project.

Full stop, no project. Thus the developer wants a positive report and the consultant knows it. This is in the interest of the consultant too, even though they will be paid for the consultancy, project or no project.

The thing is, if the consultant writes a negative EIA, or one too many, and this is known in the industry, they will not be appointed the next time around. They have to play ball. Thus, an inherent tendency to write a glowing report, highlighting the positives and toning down the negatives, sets in.

Secondly, the EIA consultancy industry is one of interlocking interests. The same firm, or its parent or subsidiaries, could be involved in the whole process of the project: assessing the viability of a project, designing dams, doing the EIA report, EIA monitoring, and project consultancy - all nicely within the family.

Even if a consultant is not involved in more than one aspect of a project, the fact is, it is in its own interest that the industry as a whole is growing. Thus they can come in at one point or another of the project process.

Take the case of our Pahang dams consultant, MAB Environmental Services Sdn Bhd. In their list of past achievements they state that they did the assessment on the EIA study for the proposed water supply scheme across Pahang and Selangor, as well as studies on its hydrology, geotechnical and project engineering.

Chummy arrangement

They also did a study on the development of waterworks projects and the potential of privatisation of water supply schemes for the Pahang State Government.

After doing the initial studies they conveniently went on to do the EIA for this present project, which is the outcome of those studies! The study and the project being done by the same consultant is in conflict.

Similarly, another consultant SMHB Sdn Bhd (the EIA consultant for the Selangor dam) assesses water needs for water transfer from Pahang to Selangor, then went on to design the Kelau and Telemong dams, and has been appointed by MAB as a project consultant for this EIA. This is very chummy indeed.

These interlocking interests might be legal (but something has to be done!), and there might not have been false reporting but the conflicts of interest are very much there.

There are many other flaws in the EIA. But, at the risk of boring the dear reader I will stop here and suggest that those still interested to refer to our detailed technical comments presented to the DOE in the SOS website (http://www.savesungaiselangor.org/). Comments from the Center for Orang Asli Concerns and Consumers Association of Penang are also available.

DR ROSLI OMAR is an academic interested in the impact of science and technology on society and environment (being bred on the white-heat of technology creed himself), be they dams, biotechnology/genetic engineering, or polluting machines. He believes that science and technology, as used at present, is sustaining an unsustainable development - the worst of all possible paradoxes.