Evaluation of the PEIA December 2014

8/10/2019 Evaluation of the PEIA December 2014

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Evaluation of the

Preliminary Environmental Impact Assessment (PEIA) for theProposed Kinrara-Damansara Expressway (KIDEX)

Prepared by:

Mark Chernaik, Ph.D. Environmental Law Alliance Worldwide U.S.

December 2014



At the request of Sahabat Alam Malaysia/Friends of the Earth Malaysia, I evaluated the PEIA forthe proposed Kinrara-Damansara Expressway (KIDEX). My evaluation of the PEIA for the proposed Kinrara-Damansara Expressway (KIDEX) focusses on two serious deficiencies: 1) theair quality impact analysis in the PEIA for the KIDEX is woefully incomplete; and2) no analysisis presented as justification for the KIDEX as opposed to other transportation alternatives.

What follows is elaboration on these two defects of the EIA.

The air quality impact analysis in the PEIA for the KIDEX is woefully incomplete

Highways adversely impact air quality primarily because of tailpipe emissions of ultrafine particulate matter (that is, particulate matter with an aerodynamic radius of 1 micron or less),also known as elemental carbon (EC) or diesel emissions.

It is well established that proximity to a major highway can cause adverse health effects tochildren because of exposure to elevated levels of air pollutants. In 2007, scientists with the

University of Southern California published a study about the health of 3677 children from 12southern California communities. These researchers found that “children who lived within 500m of a freeway (motorway) had substantial deficits in 8-year growth of forced expiratory volume… and maximum midexpiratory flow … compared with children who lived at least 1500 m from

a freeway.” These researchers concluded:

“The concentrations of several pollutants are raised near major freeways. Daytimeconcentrations of black carbon, ultrafine particulate, and other exhaust pollutants have been reported to be high, but decline exponentially, within 500 m of a freeway, althoughnight-time concentrations of ultrafine particulate remain above backgroundconcentrations for distances greater than 500 m from a freeway. Some studies havereported increased traffic pollution, particularly nitrogen dioxide, at distances over 1000m from a freeway. Elemental carbon, an indicator of pollution from diesel exhaust, varieswith nearby high traffic roads but can also be transported across large distances. Dieselexhaust is one of the primary contributors to particulate-matter concentrations in thosecommunities most affected by traffic. A pollutant such as elemental carbon could explainour reported health effects both locally and regionally.”

“We have shown that residential distance from a freeway is associated with significant

deficits in 8-year respiratory growth, which result in important deficits in lung function atage 18 years. This study adds to evidence that the present regulatory emphasis onregional air quality might need to be modified to include consideration of local variationin air pollution. ... In view of the magnitude of the reported effects and the importance oflung function as a determinant of adult morbidity and mortality, reduction of exposure totraffic-related air pollutants could lead to substantial public-health benefits.”

1

1 Guaderman, W.J.. et al (February 2007) “Effect of exposure to traffic on lung development from 10 to 18 years of age: a cohort study,” The Lancet , 369:571-577



According to recent study published earlier this, other pollutants generated by highway vehiclesimpose a substantial cost in term of childhood asthma.2

“Background Emerging evidence suggests that near-roadway air pollution (NRP)exposure causes childhood asthma. The associated costs are not well documented.

“Objective We estimated the cost of childhood asthma attributable to residential NRPexposure and regional ozone (O3) and nitrogen dioxide (NO2) levels in Los AngelesCounty. We developed a novel approach to apportion the costs between these exposuresunder different pollution scenarios.

“Methods We integrated results from a study of willingness to pay to reduce the burdenof asthma with results from studies of health care use and charges to estimate the costs ofan asthma case and exacerbation. We applied those costs to the number of asthma casesand exacerbations caused by regional pollution in 2007 and to hypothetical scenarios of a20% reduction in regional pollution in combination with a 20% reduction or increase in

the proportion of the total population living within 75 m of a major roadway.

“Results Cost of air pollution – related asthma in Los Angeles County in 2007 was $441million for O3 and $202 million for NO2 in 2010 dollars. Cost of routine care (care inabsence of exacerbation) accounted for 18% of the combined NRP and O3 cost and 39%of the combined NRP and NO2 cost; these costs were not recognized in previousanalyses. NRP-attributable asthma accounted for 43% (O3) to 51% (NO2) of the totalannual cost of exacerbations and routine care associated with pollution. Hypotheticalscenarios showed that costs from increased NRP exposure might offset savings fromreduced regional pollution.

“Conclusions Our model disaggregates the costs of regional pollution and NRP exposureand illustrates how they might vary under alternative exposure scenarios. The cost of air pollution is a substantial burden on families and an economic loss for society.”

Inappropriately, the air quality impact analysis in the PEIA for the KIDEX focusses on a single pollutant – carbon monoxide – and not on the other pollutants, ultrafine particulate matter, O2and NO2, that impact the health of children. Page 6-36 of the PEI concludes:

“In reference to the worst case scenario, where we assume all vehicles using the highwaywill be heavy vehicle (trucks and lorries), the highest predicted 1-hour averageconcentration at a closest sensitive receptor is 7.6 ppm (Class 7) at Kompleks SuriaKinrara. From the modeling results, the worst case CO levels were still well below theMalaysian Air Quality Guidelines for CO concentrations at 30 ppm (1-hour averagingtime). The CO concentrations for Scenario 1 (light vehicles) and Scenario 2 (medium

2 Brandt, S., Perez, L., Künzli, N., Lurmann, F., Wilson, J., Pastor, M., & McConnell, R. (2014). Cost of near-

roadway and regional air pollution – attributable childhood asthma in Los Angeles County. Journal of Allergy and

Clinical Immunology, 134(5), 1028-1035. http://www.jacionline.org/article/S0091-6749%2814%2901364-5/abstract

http://www.jacionline.org/article/S0091-6749%2814%2901364-5/abstract







heavy vehicles) give lower readings as expected in line with the lower CO emission rates.Hence, it can be expected that there will be a slight increase in the CO concentrations atthe receptors during the peak hours due to increase in traffic volume, which is theacceptable. The increase is not significant and the levels will still remain well below theMalaysia Air Quality Guidelines.”

Whether, worst case CO levels were still well below the Malaysian Air Quality Guidelines forCO is NOT the most important question that an assessment of the air quality impacts of the proposed KIDEX needs to answer. It is more important to answer whether the KIDEX wouldcause ultrafine particulate matter levels and levels of other pollutants, such as O3 and NO2, toimpact the health of children.

In this respect, the PEIA for the KIDEX should have followed the most recent guidance of theU.S. Federal Highway Administration for assessing air quality impacts of proposed highway projects in NEPA (EIA) documents.3

This guidance states:

“PURPOSE: The purpose of this memorandum is to update the September 2009 interimguidance that advised Federal Highway (FHWA) Division offices on when and how toanalyze Mobile Source Air Toxics (MSAT) under the National Environmental Policy Act(NEPA) review process for highway projects. ....

“3) Projects with Higher Potential MSAT Effects

“This category includes projects that have the potential for meaningful differences inMSAT emissions among project alternatives. We expect a limited number of projects tomeet this two-pronged test. To fall into this category, a project should:

“Create or significantly alter a major intermodal freight facility that has the potential to concentrate high levels of diesel particulate matter in a singlelocation, involving a significant number of diesel vehicles for new projects oraccommodating with a significant increase in the number of diesel vehicles forexpansion projects; or

“Create new capacity or add significant capacity to urban highways such asinterstates, urban arterials, or urban collector-distributor routes with trafficvolumes where the AADT is projected to be in the range of 140,000 to 150,000 orgreater by the design year;

“And also Proposed to be located in proximity to populated areas.

Projects falling within this category should be more rigorously assessed for impacts .If a project falls within this category, you should contact the Office of Natural

3 U.S. FHA (December 2012) "Interim Guidance Update on Mobile Source Air Toxic Analysis in NEPADocuments" https://www.fhwa.dot.gov/environment/air_quality/air_toxics/policy_and_guidance/aqintguidmem.cfm



Environment (HEPN) and the Office of Project Development and Environmental Review(HEPE) in FHWA Headquarters for assistance in developing a specific approach forassessing impacts. This approach would include a quantitative analysis to forecast local-specific emission trends of the priority MSAT for each alternative, to use as a basis ofcomparison. This analysis also may address the potential for cumulative impacts, where

appropriate, based on local conditions. How and when cumulative impacts should beconsidered would be addressed as part of the assistance outlined above.”

As shown in Table 6.17 from the PEIA, the KIDEX would “create new capacity or addsignificant capacity to urban highways … with traffic volumes where the AADT is projected to be in the range of 140,000 to 150,000 or greater by the design year. In fact, daily vehicle countson the KIDEX would exceed 220,000 by the year 2020:

As shown in Table 6.17 on pages 5-14 to 5-15 of the PEIA, the KIDEX would be in

extraordinary close proximity (in most instances, only 20-50 meters) to dozens of locationswhere children live and go to school and within 20 meters of a hospital.

Therefore, the impacts to air quality of the proposed KIDEX should have been rigorouslyassessed. Specifically, impacts to air quality of the proposed KIDEX should have been assessedaccording to the following internationally-accepted best practice.4

“1.1 PURPOSE OF THIS GUIDANCE

This guidance describes how to complete quantitative hot-spot analyses for certainhighway and transit projects in PM2.5 and PM10 (PM) nonattainment and maintenance

areas. This guidance describes transportation conformity requirements for hot-spotanalyses, and provides technical guidance on estimating project emissions with theEnvironmental Protection Agency’s (EPA’s) MOVES model, California’s EMFAC

model, and other methods. It also outlines how to apply air quality models for PM hot-spot analyses and includes additional references and examples. However, the guidance

4 U.S. EPA (November 2013) "Transportation Conformity Guidance for Quantitative Hot-Spot Analyses in PM2.5and PM10 Nonattainment and Maintenance Areas."http://www.epa.gov/otaq/stateresources/transconf/policy/420b13053-sec.pdf

http://www.epa.gov/otaq/stateresources/transconf/policy/420b13053-sec.pdf





does not change the specific transportation conformity rule requirements for quantitativePM hot-spot analyses, such as what projects require these analyses. EPA has coordinatedwith the Department of Transportation (DOT) during the development of this guidance.

Finally, it should not have been reported in the PEIA for the KIDEX that “Based on the air

quality results, it can be concluded that the ambient air quality at the areas along the alignmentwas good with the four (4) parameters of TSP, NO2, CO and SO2 showing levels below the Recommended Malaysian Envir onmental Air Quality Guidelines.” The table below

copied from page 5-30 of the EIA, shows values of the Malaysian guidelines for only short-term(24-hour exposures).

However, there are additional Malaysian Environmental Air Quality Guidelines for long-termaverage (12 month) exposures, including a standard for PM10 of 50 µg/m3. By way ofcomparison, the World Health Organization guideline for PM10 is 50 µg/m3 on a daily basis and20 µg/m3 on an annual average basis.5 Measurements reported in the PEIA for the KIDEX werecollected over a period of less than two months (September & October 2011). However, if thesemeasurements accurately reflect particulate matter levels that generally prevail at these locations,the PEIA for the KIDEX should have reported that air quality at these locations is alreadyimpaired.

No analysis is presented as justification for the KIDEX as opposed to other transportation

alternatives

According to the Public Works Department Malaysia:

“In the discussion of options, alternative transportation management systems should bedescribed. This discussion would include upgrading existing transportation systems.

5 http://www.who.int/mediacentre/factsheets/fs313/en/

http://www.who.int/mediacentre/factsheets/fs313/en/






Before major new highway/road projects are proposed it must be demonstrated thatupgrading existing transportation systems will not solve the transportation problemsidentified in the chapter setting out the need for the project.”

6 (Emphasis added).

This is consistent with internationally-accepted best practice that requires consideration of all

types of traffic congestion alleviation and transportation alternatives alongside withconsideration of a new road project.

Contrary to these guidelines, the PEIA for the KIDEX does not include a description ofalternative transportation management systems. Instead, as shown below, the PEIA for theKIDEX merely states that there is traffic congestion in the area, and that a new road is the oneand only way to alleviate such traffic congestion:

“1.4.1 Need of the Project

“The thriving development of new townships within and around the Klang Valley has

made efficient and good road network a necessity. This good economic growth has seentraffic within the Klang Valley and its surrounding areas increase significantly withinrecent years, resulting in traffic congestion in many areas. The implementation of theKinrara – Damansara Expressway (KIDEX) would be seen as timely since it would bringa host of benefits with it. The proposed KIDEX would introduce an alternative route between the areas of Puchong near Kinrara, west of Sunway through to Petaling Jaya‘old’ and ‘new’ town centres and Damansara. The proposed KIDEX will also provide avital link between the abutting residential areas, south of the KESAS Expresswayallowing direct access into Petaling Jaya, Damansara and NKVE.

“The main aim for the construction of the proposed Kinrara - Damansara Expressway(KIDEX) is to provide a short and direct access to both Puchong / Kinrara and PetalingJaya / Damansara ultimate catchments, giving guaranteed journey-time with dispersal points planned strategically along its corridor for effective dispersal of traffic.”

Carrying forward the untested idea that a new road is the only solution to traffic congestion,Chapter 4 of the PEIA for the KIDEX considers only three kinds of alternatives: the no-actionalternative, alternative alignments of the KIDEX, and alternative ways to construct the KIDEX.Considering the high capital cost of constructing a 14.9 kilometer elevated expressway and the probably impacts of the highway on air quality, there is a necessity to consider other alternativetransportation management systems, such as upgrades to existing roads, traffic managementoptions, and improved public transportation infrastructure.

6 Public Works Department Malaysia (1995) “Guidelines for the Environmental Impact Assessment of Highway orRoad Projects" at page 28.