The Protect Karpal Singh Drive Action Committee (ProtectKarpal), representing residents from multiple residential communities in the affected area, have submitted a comprehensive memorandum to the Department of Environment (DoE) Malaysia on 3 July.
The committee extends its appreciation to Penang DoE director Norazizi Adinan and his team for meeting directly with community representatives and receiving the memorandum in person.
At the meeting, DoE officials revealed that an overwhelming 98.6% of public feedback during the public display of the environmental impact assessment opposed the proposed reclamation project. This powerful statistic underscores the depth of community rejection and public discontent.
The memorandum details critical and systemic flaws in PLB Engineering Berhad’s environmental impact assessment for the Jelutong landfill rehabilitation, reclamation and open-air landfill waste recycling proposal. It includes a united call for the DoE to act immediately to safeguard public health and enforce robust environmental protections.
The formal objection, grounded in Malaysian environmental law and regulations, and peer-reviewed scientific evidence, exposes critical violations and scientific misrepresentations in the assessment report that threaten public health, marine ecosystems and community wellbeing.
Flawed assessment, community concerns
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Mandatory health impact assessment unlawfully omitted
Under Section 34A of the Environmental Quality Act 1974, the DoE guidance document on health impact assessment and a DoE directive of 10 January, the proposed waste treatment and open-air waste recycling operation – located immediately adjacent to residential areas, schools, and recreational areas – clearly meets critical criteria requiring comprehensive health impact assessment evaluation, as affirmed by Universiti Kebangsaan Malaysia’s health impact evaluation specialist Prof Mohd Hasni Jaafar.
“The developer’s failure to include an HIA is not an oversight – it’s a direct violation of Malaysian environmental law,” said Dr K Ganesh, a spokesperson for ProtectKarpal. “The DoE has clear legal authority and constitutional obligation to reject this incomplete and non-compliant proposal.”
Cumulative and synergistic health risks ignored
The environmental impact assessment fails to address the combined, long-term impact of landfill excavation, waste recycling, reclamation, construction noise, hazardous dust (PM2.5, PM10), toxic gases (methane, hydrogen sulphide) and potentially dangerous microorganisms from landfill waste.
Scientific evidence shows that combined exposure greatly amplifies risks to respiratory, cardiovascular and neurological health, particularly among children, seniors and vulnerable groups.
Open-air waste processing: public health catastrophe in waiting
The proposal calls for deploying up to 20 heavy-duty recycling machines operating over 10 hours daily in open-air conditions, processing 11.3 million cubic meters of landfill waste directly adjacent to dense residential communities for years.
Such operations are globally recognised sources of hazardous particulate matter (PM2.5, PM10), toxic gases, volatile organics and heavy metals.
“This is not modern waste management – this is industrial-scale pollution generation next to where our children sleep, study and play,” said Dr Ganesh. “International best practice demands enclosed facilities with advanced emission controls, not open-air processing that will shower surrounding communities with toxic gases and particulates.”
Misleading noise claims
The environmental impact assessment’s promises of “23-33 dBA reduction” via noise barriers are scientifically invalid for high-rise buildings and do not protect residents or workers at the project site.
The vast majority of affected residents live in multi-storey buildings (Maritime Suites, The Spring, Nautilus Bay, Summer Place, Pinang Court, etc) where barrier effectiveness dramatically decreases with height.
“Residents on higher floors will likely experience noise levels approaching 74.5-85.3 dB(A) – well above WHO [World Health Organization] and DoE health-based guidelines,” explained the ProtectKarpal research team.
“The EIA’s noise mitigation strategy is built on fundamental misunderstandings or misrepresenting of acoustic science, leaving thousands exposed to chronic health risks including cardiovascular disease, hypertension and impaired child development.”
Unsafe landfill closure plan
Despite being adjacent to schools and thousands of homes, the Jelutong landfill has no certified safe closure plan as required by national and international standards.
Open-air flaring and passive venting of landfill gas are fundamentally inadequate for safe rehabilitation for an urban 90-acre landfill of this scale and proximity.
Open-air waste recycling and using landfill waste for reclamation, without safe closure and long-term management, would compound pollution, gas and leachate risks.
Middle Bank – national marine treasure at immediate risk
The project’s physical footprint and associated hydrodynamic changes directly threaten Middle Bank, Penang’s last natural seagrass meadow and a habitat for over 400 marine species.
The environmental impact assessment mislabels Middle Bank geography, underplays irreversible ecosystem risks, and ignores scientific consensus on restoration limits.
Social impact assessment excludes affected residents
The social impact assessment surveyed only 5.5% (21 of 378 sample homes) in the primary impact zone and conducted zero public engagement sessions with affected high-rise communities. This systematic exclusion of stakeholder voices violates principles of environmental democracy and informed consent.
“How can a project of this magnitude proceed without meaningful consultation with those who will bear its health and environmental consequences?” asked Dr Ganesh. “We demand transparent, representative engagement before any approval consideration.”
Our united demands to the DoE:
- Immediately reject the current environmental impact assessment and require an independent, comprehensive health impact assessment that considers cumulative, synergistic and long-term community exposures.
- Mandate a safe closure plan for the Jelutong landfill in line with national standards before any new project approval.
- Enforce active landfill gas management, secure capping, and international-standard closure for the Jelutong landfill before considering any reclamation or new waste processing.
- Prohibit open-air waste recycling and reclamation work within urban residential zones.
- Protect Middle Bank as a critical national marine resource through a comprehensive ecological impact reassessment
- Mandate genuine, transparent consultation with all affected residents, not just token sampling.
- Disclose all technical findings and community input publicly before any project is considered.
Community statement
“The people of Penang are not willing to be made test subjects for flawed, dangerous projects that ignore science and public health,” said Dr Ganesh.
“We urge DoE Malaysia to enforce the law, defend the Constitution, and prioritise the rights of rakyat (the people) over developer interests. Nothing less than the health and future of Penang is at stake.”
Dr K Ganesh is a spokesperson and treasurer of the Protect Karpal Singh Drive Action Committee.
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