From: "Friends of the Earth Melbourne" <foe@melbourne.foe.org.au>
To: <foe@foe.org.au>
Subject: alert on Malaysian pulp & paper project
Date: Tuesday, 24 October 2000
dear friends
attached is a fairly long action alert from Friends of the Earth Malaysia.
If you were able to write letters as requested, that would be greatly
appreciated by them (please cc them a copy so they know they are getting
support).
many thanks
Cam Walker
Friends of the Earth Australia
------------------------
FRIENDS OF THE EARTH MALAYSIA - SAHABAT ALAM MALAYSIA (SAM)
INTERNATIONAL ALERT TO SAVE SABAH RAINFORESTS FROM
PULP AND PAPER PROJECT IN KALABAKAN.
URGENT ACTION NEEDED
Dear Friends,
SAM is very disturbed over the destruction of vast amounts of natural
forests in Sabah, East Malaysia ( on the island of Borneo ) for a massive
pulp and paper project. The environmental impacts of the rainforest
destruction is extremely worrying as set out below. We urge you to read
this letter carefully and take the suggested measures. Should you have any
queries, do contact us at SAM ( Our address is given at the end of this
letter).
Thank-you for your response. Kindly circulate this letter to as many
concerned groups as possible.
Meenakshi Raman
Hon. Secretary
LOGGING AND FOREST CLEAREANCE OPERATION WITHOUT ENVIRONMENTAL IMPACT
ASSESSMENT
3% OF SABAH’S LAND FOR GIANT PULP AND PAPER PROJECT
In Kalabakan, Tawau, Sabah, East Malaysia, a business venture between a
State-owned company, Lions Group of Malaysia and the China Fuxing Pulp and
Paper Industries of China will be developing a US1.1 billion plantation and
pulp and paper mill project.
The project will necessitate the felling of 240,000 ha of natural forest to
be replaced by a huge pulp and paper mill and a massive monoculture
plantation of the Black Wattle trees (Acacia mangium) or also known as dry
acacia or the mangium tree, a fast growing plant which is native to
tropical Queensland, Australia. The size of this huge project, some 4 times
the size of Singapore, will take up approximately 3% of Sabah and 6% of its
remaining virgin forest. The mill is expected to process 750 tonnes of pulp
a year.
The project is expected to be fully operational by 2005. Mooted by the
Federal Government, it is said to be the single largest foreign investment
in forest plantation and paper mill by China, which incidentally, has
enforced a ban on logging in large swathes of its territory back home.
There are four important issues that the project raises.
· Is the project adhering to Malaysia and Sabah’s environmental law
requirements?
· Is the removal of a quarter of a million hectares of forest
acceptable, in terms of damage to water, soil, wildlife, human livelihoods
and the ecology system downstream?
· How much pollution will the huge monocrop plantation and mill cause?
· Is the proposed plantation scheme economically viable?
NO ENVIRONMENTAL IMPACT ASSESSMENT FOR LOGGING
Under the Sabah Conservation of Environment (Prescribed Activities) Order
1999, any forest which is cleared for the felling of timber covering an
area of 500ha or more or any development of forest plantation of 500ha or
more requires an Environmental Impact assessment (EIA) to be done.
According to our interpretation of the law, three EIA reports are required for:
· forest clearing for the establishment of the tree plantations
· development of the tree plantations
· construction of the pulp and paper mill.
Today, 12 000 ha of the land of the proposed project have already been
logged without a single EIA done. The state-owned company, Innoprise
Corporation Sdn Bhd is proceeding to log another 33 000 ha.
According to newspaper reports, the company claimed that it could not
afford to wait for the EIA to be submitted. The company is only now in the
midst of appointing a consultant to handle the EIA.
The company asserted that it need not carry out an EIA for the logging as
the Sabah Conservation of Environment (Prescribed Activities) Order 1999,
came into effect only in September 1999 while the company had already begun
logging since 1998. Innoprise further asserted that it proceeded with the
logging operation based on the Coup Permit from the Sabah Forestry
Department in 1996. The company reportedly is planning to conduct two EIA
reports only, one for the plantation, the other for the mill.
The Chief Minister of Sabah seemed to defend the legality of its
state-owned company's operation. He too claimed that the logging operation
was legally licensed in 1996, well before the State EIA requirement was
enforced and in addition to that, the licence did not specify the need for
an EIA.
Further shock came our way when the Sabah Forestry Department in their
reply to our queries affirmed that they had indeed issued a Coup Permit for
the company to log. According to the Department, in 1996, Benta Wawasan
Sdn. Bhd [a wholly owned subsidiary of Innoprise Corporation ] entered into
a Tree Plantation Agreement with the State Government of Sabah to log
106,310 ha of the Reserve Forest of Gunung Bara/Kalabakan and develop it
into a plantation. According to the Department, this agreement binds Benta
Wawasan to observe a set of conditions pertaining to environmental
protection and conservation. These conditions are claimed to be
"functionally equivalent" with the EIA legal requirement.
Prior to the coming into force of the Sabah Conservation of Environment
(Prescribed Activities) Order 1999, the Federal Government's Environment
Quality Act 1974 and the subsidiary law made pursuant to this called the
Environmental Quality (Prescribed Activities) (Environmental Impact
Assessment) Order 1987 instructs that all proposed logging activities
intended to be carried out on land larger than 500 ha to require an EIA to
be performed and approved before the commencement of the activities. This
law is not being followed.
In a response to SAM's query, the Sabah Environmental Conservation
Department said that the Federal law did not apply to Sabah as the project
involved matters such as 'land' and 'forests' which are within the
jurisdiction of the States. Malaysia operates under a Federal-State system,
where there is a division of areas between the Federal legislature and the
States’. The Sabah Government is clearly using a strict legal argument to
maintain that no EIA is needed to log such a huge area of forests until
they enforced their own law in 1999!
Worsening things up, on September 26, The Star, a national Malaysian daily,
reported that the "conditions" stipulated in the Forestry Department
licence on environmental protection are also being disregarded by the company.
According to The Star, the company has violated the restrictions that
prohibit logging activities from taking place right to a river’s bank or on
slopes of more than 25 degrees and clearing of a slope of more than 15
degrees steep. The company also does not seem to maintain the required 20m
buffer zone between development activities and the boundaries of a river
catchment.
SAM is appalled at how the logging can proceed without the submission and
approval of an EIA Report by the Department of Environmental Conservation
of Sabah, when the logging is clearly for the pulp mill project. The Sabah
Government should not fragment the various activities involved in
establishing the pulp mill, viz. logging for the tree plantations,
establishing the tree plantations and construction of the pulp mill. We are
very troubled by the fragmented approach taken by the Sabah State
Government to justify the lack of an EIA for the logging activities.
The purpose of an EIA prior to the commencement of any project is to assess
the environmental impacts and ascertain if the mitigation measures proposed
by the project developers are sufficient to minimise environmental damage.
The cumulative impacts of the project as a whole should be taken into
account. If foreseen environmental impacts are severe and the mitigation
measures inadequate, the EIA must be rejected and the project should not be
allowed to commence. Innoprise’s actions seem to imply that they are
confident that their two other EIAs (for the plantation and the mill) will
be approved. This is legally questionable and environmentally risky.
The Sabah Government in allowing the logging to go on is making a mockery
of the law and is undermining the EIA process. By allowing the logging to
proceed without an EIA, the Sabah Government is completely disregarding the
environmental impacts of the logging activities and is 'manipulating' the law.
Logging before agreement is signed
The most perplexing question about the issue is that as late as September,
the commercial department of the Chinese Embassy in Kuala Lumpur reportedly
maintained that "the project is still under negotiation." Nothing is
finalised yet.
It is a great puzzle to us as to how this one joint venture project was
allowed to commence its operation even before its own internal agreements
are finalised; risking the area to be wasted, should the project fail to
take-off.
In addition to that, Innoprise's claim that it had begun logging the area
since 1998 raises another important question. The Memorandum of
Understanding for the project was only signed in 1997 and an early
agreement between the various joint-venture partners was signed in August
1999. How could have Innoprise begun the logging operation when even the
first agreement between their business partners had not taken place?
ECOLOGICAL DAMAGE
Wildlife
The proposed project is situated in Sabah’s biggest remaining block of
continuous forest, sandwiched between two major conservation sites, the
Danum Valley and the Maliau Basin. Both are classified as Class One
Protection Areas allowing only scientific research and restricted
activities such as sustainable ecotourism to take place in the area.
The entire area, a world-renowned biodiversity hotspot, contains
significant populations of rare animals and plants. Elephants, orang utans,
Sumatran rhinoceros, sunbears, gibbons, clouded leopards and the Bornean
Bay cat and wild cattle (tembadau or banteng), once thought to be extinct,
are all present. The forest probably contains somewhere in the region of
120 mammals, 280 birds, and more than 2500 tree species.
The proposed plantation scheme would assault this pristine environment,
turning the remaining forests as “islands”, restricting the movement of
wildlife. This could potentially decimate their population. Wild animals
are reported to have been sighted more often, probably fleeing from the
logged area.
Does it make sense to annihilate this forest, the very area that has the
best chance of being managed sustainably, when other forest areas in Sabah
have been ravaged by fire to the point where natural forest management is
impossible?
Erosion
The land of the proposed project is mostly steep, and felling for
plantations will expose the soil to direct erosion by rainfall. Even a low
rate of erosion, for example 25 tonnes per hectare per year, would result
in more than 6 million tonnes of eroded material a year from the entire
proposed plantation. A higher estimate of erosion at 100 tonnes per hectare
per year would give 25 million tonnes of soil entering rivers every year.
What will the effects be on the price of water treatment for the villages
downstream? Will excessive silt cause the catch of villagers who fish along
the rivers to dwindle? Will there be greater flooding? Will the sediment
deposited at the river estuaries eventually reach the coastal mangrove
vegetation in Cowie Bay, depleting marine resources?
With only 12 000 ha logged, disastrous reports have already emerged. The
lush Danum Valley has already been flooded in recent months.
Threats of fire, pests, wild animal and dry spells
· In the 1980s, an Indonesian plantation of Leucena leucocephala was
totally destroyed by insects. The Black Wattle trees that will be planted
in Sabah are in the menu of 19 kinds of insects. The Black Wattle leaves
also contain 43 percent protein, and have even been recommended as an
excellent fodder for cattle. Asian elephants (Elephas maximus) are said to
love the bark of this tree. Planting such a huge area of the tree slap in
the middle of the biggest remaining habitat for Sabah’s elephant population
may be simply asking for trouble.
· The plant is also said to be a thirsty crop that can absorb a lot
of underground water, drawing down the water table and making the land drier.
· Local microclimate will often dry and heat up once the rainforest
is replaced with a plantation scheme. The drier mono-crop plantations will
no longer be the cool, damp and heavily clouded woods.
· Plantations burn easily. This is made more likely by the
accumulation of dry, leathery leaf litter in such plantations.
POISONS FROM PULPING AND BLEACHING
The processes involved in pulp and paper industry are known to be highly
damaging to the environment.
· The use of chlorine in bleaching the pulp has caused the industry
to be the third largest source of dioxin and its related compound in the
world. This problem is further compounded by the fact that Malaysia still
has no policy on dioxin and the laws to regulate its presence in the
environment.
Furthermore about 300 chemical compounds have been identified in pulp and
paper mill effluents. They are:
· Organic pollutants and suspended solids.
· Chlorophenolics and their transformation products
· Acidic compounds
· Other organochlorine products
Air emissions of pulp and paper mills are known to emit:
· carbon dioxide (global warming)
· hydrogen sulphide (rotten egg smell)
· oxides of sulphur (acid rain), oxides of nitrogen
· chloroform (possible carcinogen)
· dioxins and furans
· organochlorines
· other volatile organics (toxic and precursors to ozone formation).
UNSUSTAINABLE ECONOMIC PLANNING
The area is proposed to be planted at about 20,000 hectares per year, with
32,000 hectares in the first year alone, according to Innoprise
Corporation. Clearing at this rate is possible but re-planting is surely
not. Even the biggest operator in Sabah is now re-planting up to 6,000 ha a
year (less than a third of that proposed), after 15 years of experience.
The proposed plan would require 38 million seedlings to be planted in year
one. In the coming years, 23 million seedlings would be planted annually.
The logging operation is certainly an irresponsible corporate decision when
we consider the fact that the nursery to produce the seedlings for the
plantation has not even been set up while 12 000 ha have been logged.
At the proposed rate, by the start of the project’s fourth year, workers
would embark on planting the routine load of 23 million seedlings, while
taking care of the previous 85 million seedlings already planted over an
area of 720 square kilometres, an area larger than Singapore. Can this
really be done? It is obvious that the State is dangerously risking the
creation of huge chunks of bare and uncovered land in what used to be a
verdant rainwater-sponge.
As it is right now, swathes of bare earth are beginning to disfigure the
once biodiversity hotspot and the rivers are already brown with silt.
We also must remember that if this estimated high replanting rate fails to
be achieved, the mill would also face a shortage of pulp supply. Faced with
this predicament, an expensive and huge mill would surely suffer huge
losses. The mill then perhaps would have to import timber or pulp.
CALL FOR ACTION
It is for these environmental concerns that SAM has called the State
Government of Sabah and the Federal Government to:
· halt all further logging activities
· take action against the parties that are responsible for logging
the 12 000 ha of forest without an EIA.
· undertake a comprehensive EIA for all three aforementioned
components of the project
· seek extensive and genuine public feedback from the public in
relation to the reviewing of the EIA.
· review as a whole the project for its overall justification, given
the magnitude and scale of its environmental impacts.
Support our call for action
SAM appeals to all concerned groups and individuals to send all letters of
concern to:
YAB Datuk Seri Dr. Mahathir bin Mohamad
Prime Minister of Malaysia
Pejabat Perdana Menteri Malaysia
Blok Utama, Kompleks Jabatan Perdana Menteri
Pusat Pentadbiran Kerajaan Persekutuan
62502 Putrajaya
Malaysia.
Fax : 603-8883444
Email : epu@jpm.my
YAB Datuk Seri Panglima Osu Haji Sukam
Chief Minister of Sabah
Tingkat 28 Bangunan Yayasan Sabah
Teluk Likas
88502 Kota Kinabalu
Sabah.
Malaysia.
Fax : 6088-435350
Email : ketuamenteri@sabah.gov.my
Mr. Eric Juin
Director
Department of Environmental Conservation
Tingkat 2 & 3
Jalan Tuanku Abdul Rahman
Beg Berkunci No. 2078
88999 Kota Kinabalu
Sabah
Fax : 6088-238120
Email : pgh.jkas@sabah.gov.my
Mr. Daniel K.S. Khiong
Director
Forestry Department of Sabah
Beg Berkunci 68
90009 Sandakan
Sabah
Malaysia
Fax : 6089-669170
Email : pengarah.htan@sabah.gov.my
Kindly request the State Government of Sabah and the Federal Government of
Malaysia to take the actions that we have demanded above. Please send
copies of your letters of concern to us at:
Sahabat Alam Malaysia
27 Lorong Maktab
10250 Penang
Malaysia.
Tel : 604-2276930
Fax: 604-2275705
Email: smidris@tm.net.my and meenaco@pd.jaring.my