Prolintas SUKE Elevated Expressway

Project Description

The proposed Project is the construction, operation and maintenance of the Sungai Besi – Ulu Kelang Elevated Expressway (SUKE) in the Klang Valley (within which Kuala Lumpur is situated), Malaysia. SUKE is a 31.8 km, 3-lane, dual carriageway with 14 interchanges, three toll plazas, and two rest and service areas. SUKE will begin at Sri Petaling and terminate at Ulu Kelang with a mainly north-south orientation along the eastern boundary of Kuala Lumpur transversing Wilayah Persekutuan (i.e. the Federal Territory) and the state of Selangor Darul Ehsan; linking a number of other existing major expressways and roads, including the Shah Alam Expressway (KESAS), the Kuala Lumpur-Seremban Expressway, Besraya Expressway, Cheras-Kajang Highway, Middle Ring Road II (MRR2), the Ampang-Kuala Lumpur Elevated Highway (AKLEH), Jalan Ampang, and the Duta-Ulu Klang Expressway (DUKE).

The alignment follows the existing road network to the extent possible in a highly urbanized environment, with 90% of the route elevated. Approximately 4 km will be elevated directly on top of the existing MRR2, and the remainder following mostly other existing roads, as well as a few kilometers along a forest reserve. It is anticipated that the Project will be divided into 12 work packages, with construction contractors appointed to each package. Contractors will be responsible for individually determining workforce recruitment, worker housing and laydown areas.

The Project will be constructed, operated and maintained by PLSUKE, a wholly owned subsidiary of Projek Lintasan Kota Holdings Sdn Bhd (PROLINTAS) under a Build-Operate-Transfer concept with the Government of Malaysia (GoM). On the 25th of September 2013, PLSUKE was awarded the expressway concession for a period of 55 years. All Conditions Precedent to the concession agreement were fulfilled on the 25th December 2014. Construction is expected to begin in 2016 and last approximately 48 months.

Environmental and Social Categorization

The Project is Category A under MIGA’s Policy on Environmental and Social Sustainability (2013). Key environmental and social risks and impacts include waste, air quality, surface and ground water quality, noise and vibrations, biodiversity, physical and economic displacement resulting from land acquisition, worker and community health and safety, and security. These risks and impacts are expected to be avoided, reduced or managed in compliance with local legal and regulatory requirements, applicable Performance Standards and World Bank Group (WBG) General Environmental, Health and Safety (EHS) Guidelines and Industry Sector EHS Guidelines for Toll Roads.

The benefits of the Project are anticipated to include an increase in road capacity to cater for future traffic growth, reduction in travel time, fuel cost saving (thus reducing vehicle carbon emissions) and improved road safety.

While all Performance Standards are applicable to this investment, based on our current information, the investment will have impacts which must be managed in a manner consistent with the following Performance Standards:

• PS1:  Assessment and Management of Environmental and Social Risks and Impacts
• PS2:  Labor and Working Conditions
• PS3:  Resource Efficiency and Pollution Prevention
• PS4:  Community Health, Safety and Security
• PS5:  Land Acquisition and Involuntary Resettlement
• PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resource

PS7: Indigenous Peoples is not applicable as no indigenous people, as defined in PS7, have been identified within the Project’s area of influence. PS8: Cultural Heritage is not applicable as consultation with local regulatory organizations and the review of available records undertaken as part of the EIA process did not identify any known sites of archaeological or cultural heritage significance within the Project site boundary. However, a Chance Finds Procedure has been developed for the construction phase of the project consistent with the requirements of PS8.

The following World Bank Group (WBG) Environmental, Health, and Safety (EHS) guidelines are also applicable to the project:

• General EHS Guidelines
• EHS Guidelines for Toll Roads

MIGA conducted a due diligence site visit in December 2014. During the site visit, meetings were held with the PROLINTAS Group Chief Executive Officer, PLSUKE General Manager, PLSUKE Project Manager, traffic impact study consultant, environmental and social consultant, Guthrie Corridor Expressway (GCE) & Kemuning-Shah Alam Highway (LKSA) General Manager, AKLEH General Manager, PROLINTAS community relations representatives, GoM Department of Environment (DOE) representatives, GoM Department of Director General for Land and Mines representatives, and the Selangor State Forestry Department representatives. Meetings were also held with project-affected communities and stakeholders, including those potentially subject to physical and economic displacement, as well as those adjacent to the Project Right-of-Way (RoW) and potentially impacted by noise, vibration, dust and exhaust emissions. The site visit also included a field appraisal of the RoW focusing on environmental issues (e.g. affected surface waters and urban rivers, forest reserves and biodiversity).

In addition to the site visit, MIGA reviewed the following documents:

• Environmental Impact Assessment (EIA) Report for the Proposed Sg Besi – Ulu Klang (SUKE) Elevated Expressway, February 2013, prepared on behalf of PROLINTAS by UKM Pakarunding Sdn Bhd.
• The Proposed Sungai Besi – Ulu Klang Elevated Expressway (SUKE): International Finance Corporation (IFC) Gap Analysis, November 2014, prepared on behalf of PROLINTAS by ERM Asia Pacific (M) Sdn Bhd.
• Safety, Health & Environmental Management Plan Manual, September 2014, prepared on behalf of PROLINTAS by Turnpike Synergy Sdn Bhd.
• Environmental Management Plan for AKLEH Phase 2, October 2014, prepared on behalf of PROLINTAS by Jalin Timur Sdn Bhd.
• Public Consultation and Engagement Report, October 2014, prepared on behalf of PROLINTAS by Turnpike Synergy Sdn Bhd.
• The Proposed Sungai Besi – Ulu Klang Elevated Expressway (SUKE): Stakeholder Engagement Plan, January 2015, prepared on behalf of PROLINTAS by ERM Asia Pacific (M) Sdn Bhd.
• Malaysia Environmental Quality Report 2012, July 2013, prepared by Department of Environment, Ministry of Environment and Natural Resources, Malaysia.
• Malaysia Clean Air Action Plan, December 2010, prepared by Department of Environment, Ministry of Environment and Natural Resources, Malaysia.
• Land Acquisition Act 1960, Laws of Malaysia, Act 486, incorporating all amendments up to 1 January 2006.

PS1:  Assessment and Management of Environmental and Social Risks and Impacts

Environmental and Social Assessment: An Environmental Impact Assessment (EIA) was prepared in line with national regulatory requirements. The EIA describes the project activities, provides physical and environmental baseline information and socio-economic baseline information, identifies and assesses environmental and social risks and impacts during preparation, construction and operations phases, and proposes measures to mitigate adverse environmental and social risks and impacts. Significant adverse impacts identified in the EIA were related to noise, air quality, water quality, hydrology, traffic and socio-economics.

An analysis of alternatives was conducted assessing five alternative routes based on criteria including social and environmental impacts. The selected RoW was chosen to minimize impacts on nature reserves, surface water and urban rivers, and land acquisition issues by elevating the expressway and avoiding natural habitats as much as possible. A traffic impact study was also carried out, assessing the same 5 options as well as a no project option.

A gap analysis of the project’s compliance with the Performance Standards and WBG EHS Guidelines was conducted by an international environmental consultancy on behalf of PROLINTAS. The results of the gap analysis identified areas for additional studies to be carried out, including assessment of biodiversity, ecosystem services and critical habitat, air emissions and other impacts during the operations phase (i.e. noise, resources efficiency, waste, and wastewater). 

Management Program: The EIA includes a summary Environmental Management Plan (EMP) outlining strategies for management and monitoring during the construction and operations phases. The EMP includes a description of the legislative requirements, and outlines monitoring separate monitoring programs for the construction and operations stages.

Prior to undertaking construction works, a detailed EMP will be prepared and approved by the DOE based on the EIA, conditions set forth by the DOE, Performance Standards requirements set forth in the gap analysis, and requirements of other relevant government agencies such as Water Authority, River Management Authority and local government agencies. The EMP will be included as part of the Environmental, Health and Safety Management Plan (EHSMP) prepared by PLSUKE as an overall environmental and social management system for both construction and operations, consistent with the requirements of the Performance Standards and EHS Guidelines, as well as GoM laws and regulations on environment, health and safety. The EHSMP includes a Safety, Health and Environmental (SHE) Manual (which includes the EMP), as well as an Occupational Health and Safety (OHS) Manual that includes a policy, defines roles and responsibilities, and establishes guidelines for PLSUKE workers and contractors in developing and implementing procedures for managing environmental and social risks and impacts. Implementation of the EHSMP will be a requirement set forth in all construction contracts. Operational aspects of the EHSMP are based on Malaysian Highway Authority (MHA) guidelines and includes training and reporting. 

Organizational Capacity: PROLINTAS has 20 years of experience in constructing, operating and maintaining expressways in the Klang Valley, with 5 special project purpose subsidiaries for construction, operation and maintenance of major expressways in the Klang Valley. These include the currently operating AKLEH, GCE, and LKSA, as well as the planned Damansara-Shah Alam Elevated Expressway (DASH) and SUKE projects.

Emergency Preparedness and Response: As a condition of the approval of the EIA, GoM required PROLINTAS to prepare an on-site and off-site Emergency Response Plan (ERP) to ensure proper management of any accidents. The ERP is to be prepared in consultation with the Fire and Rescue Department, the police, the Department of Occupational Safety and Health and local authorities.

Monitoring and Review: During construction, ProLintas is required to submit an E&S monitoring report to DoE every three months from the commencement of construction. The report will include construction status, progress of implementation of EIA measures, and monitoring and evaluation of water quality, ambient air quality and noise and vibration levels.  The DoE also requires the Project to undertake an environmental audit annually during the operations phase.

Associated facilities, including quarries, borrow pits, laydown areas, concrete batching plants and worker accommodation will be the responsibility of contractors. PROLINTAS anticipates that the majority of the construction materials utilized by the contractors will be extracted from existing quarries. Contractors will be required to identify risks and impacts and mitigate impacts related to these associated facilities through procedures to be developed and implemented as part of the EHSMP. Should it be necessary to exploit greenfield quarries and/or borrow pits, PROLINTAS will require contractors to conduct a process of environmental and social risk and impact identification and development and implement mitigation measures consistent with the Performance Standards and WBG Industry Sector EHS Guidelines for Construction Materials Extraction.

PS2:  Labor and Working Conditions

PLSUKE currently employs 24 direct-hire workers performing the following roles and functions:

Designation

Role/function

No of employees

General Manager

Formulate, develop, design and recommend strategies and programs on the planning and execution of the SUKE project

1

Senior Project Manager

Manage and monitor the construction activities

1

Project Manager

Lead and manage the assigned project teams

4

Health & Safety Manager

Ensuring safety, health and environment systems are in accordance with government regulations

1

Project Engineer/Engineer

Plan and coordinate project and construction activities of the SUKE project

3

Manager (Concession Monitoring)

Monitor and ensure the compliance of the concession agreement

1

Land Executive

Coordinate with the GoM on the land acquisition process

1

PR Executive

Oversee all public relations activities regarding the SUKE project

1

Planning Executive

Assist in planning, identifying design requirements and coordinating the operational requirements of the SUKE project

1

Assistant Land Executive

Assist the Land Executive

3

Clerk

Provide administrative support to the company

4

Administrative personnel

General administrative work

3

TOTAL

24

At the peak of the construction stage, PLSUKE contractors will employ approximately 3,360 workers.

During operations and maintenance, PLSUKE expects to employ approximately 130 direct-hire workers, performing the following roles and functions:

Department

Role/function

No of employees

General Manager

Oversee the management and operations of SUKE

1

Support Services

Human capital, corporate communications, administration and information systems management

10

Operations

Operate the toll plazas of SUKE

84

Data Management

Management of data pertaining to SUKE

10

Engineering

Traffic & safety, mechanical & electrical and civil & structural elements of SUKE

25

TOTAL

130

PROLINTAS applies human resource (HR) processes and practices governed by the local labor law applicable to direct-hire staff. HR policies are however not comprehensively documented and currently are not communicated or applied to third-party workers and contractors. PROLINTAS is committed to developing HR policies and requirements consistent with the requirements of PS2 and local labor law, reflecting transparent worker relations, terms and duration of employment, non-discrimination and a workers grievance mechanism. These policies will also be applicable to third-party workers and contractors consistent with PS2 requirements. Worker accommodation, if provided by contractors, will be required to be consistent with the IFC guidance note on workers accommodation.

Worker health and safety risks and impacts during construction, operations and maintenance will be managed through the EHSMP, which includes objectives and strategies to achieve safe working environments. The residual risks that cannot be avoided will be managed through appropriate protective measures, including controlling the hazard at the source and providing appropriate personal protective equipment (e.g. hats, gloves, boots, vests). During construction, contractors will be obliged to implement the SHE and OHS Manuals as a requirement of construction contracts, including the development of Safety Operating Procedures (SOPs) based on the specific method of construction, equipment, hazards and risks. Before construction work can commence, it will be mandatory for each contractor to produce an SOP that will describe in detail all matters related to method of works and the safety procedures that will be vetted by the design and site supervising consultants, as well as the independent engineer, before it is accepted.

Contractors will be required to follow all rules and regulations set out in an accident prevention program as part of the OHS manual, nominating a safety officer with responsibility for OHS matters, as well as providing training to all workers on OHS aspects relevant to their daily work and emergencies. Monitoring will be conducted by the contractors with oversight by PLSUKE, as well as relevant government agencies including the Department of Occupational Safety and Health (DOSH) and the Construction Industry Development Board (CIDB).

PS3:  Resource Efficiency and Pollution Prevention

Risks and impacts related to construction activities are expected to include air emissions, noise, soil erosion and runoff, surface and ground water quality, waste, hazardous materials, and spills. These risks and impacts will be managed through project design and mitigation measures provided in the ESHMP, implemented by contractors. Construction environmental management will be overseen by PLSUKE through the management and monitoring procedures set out in the EHSMP.

During operations, risks and impacts are expected to include air emissions, noise, wastewater, storm water runoff and waste. These areas were identified as deficiencies in the EIA by the gap analysis, resulting in additional studies to be carried out to assess the significance of impacts and identification of mitigation measures, where needed. The EMP will be updated to reflect the mitigation measures proposed as part of the additional studies.

Air quality and noise levels: Noise, vibration and air quality baselines conditions have been measured, and basic impact modeling has been carried out. Additional measurements at sensitive receptors will be taken, as modeling will be extended to include cumulative impacts, long-term scenarios and additional receptors. 

Baseline noise levels have been measured at 17 monitoring stations along the proposed RoW. Daytime noise levels were within the national guideline for daytime noise at 14 stations, but exceeded the guideline at 3 stations. Nighttime levels exceeded the national guideline for nighttime noise at all but one station.. During construction, heavy machinery, piling, transportation etc. will cause noise impacts. Such activities will be scheduled during the daytime in order to minimize disturbance. During operations and maintenance, noise modeling shows that the Project will likely have minor impacts to the nearest residential areas. PLSUKE will conduct additional noise modeling to identify proper placement of noise minimization barriers along the RoW to reduce impacts to nearest sensitive receptors during operations.

Air quality baseline levels were tested at 10 sampling points, where all parameters were below national air quality guidelines. Air emissions during construction are expected from fugitive dust generated from construction works, and gaseous emissions from construction vehicles, equipment and machinery. Good practice construction techniques will be employed to minimize dust generation, including covering loads, immediate re-vegetation of exposed areas, water spraying, and drive through wash stations for construction vehicles. PLSUKE will conduct additional air quality modeling to identify potential impacts to ambient air quality as a result of vehicle emissions during operations.

Water quality: Water quality baseline have been established at six sampling stations, with all sites having overall good water quality. Low levels of oil, grease and ammoniacal nitrogen indicate that the rivers do not receive oil-polluted effluents or sewage discharges. During construction, soil erosion will be intensified, especially at the at grade (non-elevated) section of approximately 3 kilometers. The Project is required to prepare an Earthworks Plan and an Erosion and Sediment Control Plan and submit it to the Department of Environment for approval prior to beginning any construction work. Temporary drainages, silt fences and silt traps will be installed before clearing activities at any area begin. Wastewater, solid waste and sewage from base camp and project offices will have a negative impact on surface water if released untreated to the drainage system. During operations and maintenance, oil spills and accidents may cause surface water through stormwater runoff from the road. SUKE is designed with a drainage system to collect stormwater runoff in silt traps and oil-water separators prior to discharge to surface waters. Rest & service facilities will be equipped with onsite treatment systems for sewage and water effluent.

Waste: A waste management plan will be prepared for construction, operations and maintenance, including solid, liquid, and hazardous waste streams.

PS4:  Community Health, Safety and Security

During construction, traffic safety hazards in the form of increased risk of vehicle and pedestrian accidents are expected related to increased congestion as a result of heavy equipment and construction machinery obstructing surface roads. Community safety risks may also be related to unauthorized access to construction area due to construction undertaken in densely populated areas. Contractors will be required to prepare a detailed Traffic Diversion and Management Plan prior to the start of construction as part of the EMP. The transportation of heavy equipment and construction machinery will be conducted during off-peak hours and maximum load capacity for trucks will be strictly enforced to prevent spillage onto roadways.

During operations, the primary community safety risk is vehicle accidents. Other safety risks include the potential for road collapse (particularly along the elevated sections) and risks associated with earth quakes and other natural hazards. SUKE is designed to meet MHA road safety requirements through implementation of MHA Guidelines for Traffic Control and Surveillance System (TCSS) and Guidelines on Expressway Road Marking. During operations, PLSUKE will maintain a control room to monitor real time traffic conditions and all traffic accidents and incidents will be recorded and reported monthly to PLSUKE management and the MHA.

The gap analysis identified that the EIA did not assess pedestrian safety. However, during construction pedestrian safety measures will be required to be included as part of the contractor’s Traffic Diversion and Management Plan. The Project’s elevated design will minimize pedestrian risks during operation. PLSUKE will also conduct a Road Safety Audit of the detailed design, pre and post construction, to ensure the Project will conform to GoM regulations and good international industry practice.

PS5:  Land Acquisition and Involuntary Resettlement

Land acquisition necessary for the Project RoW includes 32 ha of government owned land, 72 ha of private lots, 30.2 ha of forest reserves, and utilization of airspace above existing road and river reserves. Surveys identified 50 residential buildings and 52 commercial buildings, but exclude non-permitted structures and/or structures located on land without official title. Land acquisition is expected to commence early-2015 and conclude by the end of 2015.

The process for land acquisition follows the Malaysia Land Acquisition Act 1960 (LAA) establishing a cutoff date that freezes land prices to allow the Project to conduct an analysis of alternatives regarding RoW options and prepare a detailed design. The process of finalizing the detailed design includes consultation with affected communities and is conducted with the input of the government, who mandated PLSUKE to establish a RoW with the goal to avoid and minimize social and environmental impacts to the extent possible. Upon submission of the detailed design, land acquisition plans are prepared by a licensed surveyor. A land valuation report is then prepared and the properties to be acquired are publicly disclosed through publication in the state gazette followed by serving of notice to land owners who are invited to attend a hearing to establish the compensation award. Once the award is established, an offer of compensation is made which can be appealed in court. Otherwise, payment of compensation is provided based on the guidelines established in the LAA and title is transferred.

The LAA requires payment of compensation for land and assets at market value, consistent with PS5 requirements. However, MIGA’s due diligence and the gap analysis identified several areas where the LAA is inconsistent with PS5 requirements, particularly regarding no provisions for renters, structures without formal title to the land, livelihood restoration and monitoring. While the LAA does not explicitly establish compensation for renters, it can be mandated by the local governments in the form of moving assistance and rental allowance up to 3 months, which is consistent with PS5 requirements. Additionally, where mandated by local governments, cash compensation offers are made to affected-people who have established structures on land without formal title to facilitate their moving off the land. If these cash compensation offers are equal to or exceed replacement costs of the affected structures, then this approach could also be consistent with PS5 requirements.

PLSUKE will prepare a Resettlement Action Plan (RAP) that complies with PS5, including in particular a baseline of affected households, a compensation framework consistent with PS5 criteria, a monitoring plan and establishment of a process for consulting affected-people regarding livelihood restoration programs, where needed. MIGA will disclose the RAP once it is available.

PS6:  Biodiversity Conservation and Sustainable Management of Living Natural Resource

While the majority of the proposed route follows existing road networks, three stretches will impact approximately 30.2 ha of designated forest reserves, including the Bukit Sungei Puteh Forest Reserve (4.2 ha), the South Bukit Sungei Putih Forest Reserve (21.3 ha) and the North Bukit Sungei Puteh Forest Reserve (4.7 ha). While the Bukit Sungei Puteh Forest Reserve and North Bukit Sungei Putih Forest Reserve are designated forest reserves, the EIA concluded and MIGA’s due diligence confirms that both sites are degraded habitat and surrounded by urban environment.

The South Bukit Sungei Putih Forest Reserve borders the urban environment to the west. However, it is contiguous with larger forest blocks and protected forest areas to the east encompassing the central Malaysian peninsula, including the Ampang Forest Reserve which is part of the 914 km2 Selangor State Park. The EIA concludes that MIGA’s due diligence confirms that this site is in good condition, likely secondary forest, with many mature trees.

The survey of terrestrial fauna provided in the EIA identified 11 mammal, and 21 bird species in the forest reserve areas affected by the Project, including the IUCN Red List “Endangered” siamang monkey. In the contiguous Ampang Forest Reserve, the EIA identified the presence of 3 more IUCN Red List ”Endangered” species including the tiger, pangolin and lars gibbon. Flora surveys identified two species of IUCN Red List “Critically Endangered” diptocarp tree species (Shorea macroptera and Shorea foxworthyi) in the affected forest reserve areas. Seven individual critically endangered diptocarp tree species were identified representing the highest total amount of above ground biomass in the study area. While the diptocarp species are globally “Critically Endangered”, the Selangor State Forest Department confirmed that the species are locally abundant, cultivated in forest department nurserys, and can be readily transplanted for reforestation.

Potential impacts related to land conversion of the forest reserves will be limited due to the elevated design of the expressway, with the most significant impacts to habitat occurring only where support columns will be erected. Measures to avoid, reduce, or minimize biodiversity impacts including re-alignment of the RoW to the forest boundary to reduce fragmentation, minimization of forest clearance and earthwork, and monitoring and relocation of the lars gibbon in coordination with GoM. The DoE, in their conditional approval of the EIA, required PROLINTAS to prepare a Wildlife Management Plan, which will include a plan to relocate species, and submit it to DoE for approval prior to commencing construction works.

Consistent with the requirements of PS6, PLSUKE will purchase an equivalent area of private forest land (of equal or better habitat quality) to transfer to the GoM to offset the loss of forest reserve.

Because of the potential impacts to endangered and critically endangered flora and fauna, PLSUKE will conduct a biodiversity assessment, which will include a critical habitat assessment, identification of biodiversity values, assessment of ecosystem services and a Biodiversity Action Plan consistent with the requirements of PS6. The Biodiversity Action Plan will include measures to minimize impact on areas of conservation significance during construction and operation, as well as a management strategy to maximize conservation outcomes in the offset area and metrics for determining the effectiveness of the management strategy (e.g. ensuring net gain of biodiversity values for any identified critical habitats and no net loss for modified and natural habitats).

Public consultation and community engagement have been conducted on a regular basis since inception of the Project in 2011 with affected people and communities, as well as interested stakeholders and the public at large. These engagements include: the PLSUKE project team carrying out briefings and dialog sessions with Project-affected residents associations, business owners, and places of religious worship; the PLSUKE project team in cooperation with the MHA and the local governments conducting direct engagement with land owners; public hearings and displays, town hall meetings, and joint meetings with residents associations; and conducting a public opinion survey of a sample of residents within a 1 km corridor of the RoW. The public opinion survey found 81% support for the Project among respondents, 12% opposition and 7% neutral. A Stakeholder Engagement Plan (SEP) was prepared in January 2015 that includes a stakeholder analysis, summary of engagement activities carried out thus far, a plan for future activities, and a description of a grievance mechanism for both project affected persons and other stakeholders in line with the requirements of PS1.

• Environmental Impact Assessment (EIA) Report for the Proposed Sg Besi – Ulu Klang (SUKE) Elevated Expressway, February 2013, prepared on behalf of PROLINTAS by UKM Pakarunding Sdn Bhd.
• The Proposed Sungai Besi – Ulu Klang Elevated Expressway (SUKE): Stakeholder Engagement Plan, January 2015, prepared on behalf of PROLINTAS by ERM Asia Pacific (M) Sdn Bhd.

The above listed documentation is available electronically as PDF attachments to this ESRS at -0p.  It is also available for viewing at the following location:

• Level 3, Block G

          Excella Business Park, Jalan Ampang Hilir

         55100 Kuala Lumpur

         Tel: +603 4270 1540