My feedback to HDB on Environmental Impact Studies (EIS) report regarding Keppel Club Site


Before Singapore fell into the hands of colonial powers in the early 1800s, it was mostly forested. (Photo of NParks signboard by Jimmy Tan for illustration)

In 1819, Singapore was almost fully covered by primary rainforests: 82% are lowland evergreen rainforests, 13% mangroves and 5% freshwater swamp forests (according to NParks).

These natural vegetation types are best suited to the hot, humid and wet tropical climate in Singapore, which ensure optimal functioning of a healthy natural ecosystem.

After two centuries of deforestation for agriculture and urbanisation, Singapore has lost about 99% of the original primary rainforests and up to 73% of its flora and fauna species, thus compromising the livability of the environment and affecting both ecological connectivity and people’s physical health and mental well-being.

Due to rapid deforestation and urbanisation, Singapore is heating up twice as fast as the rest of the world, and the urban heat island effect in built-up areas has been affecting people’s physical health and mental well-being. (Screenshot from an NParks webinar)

Today, about half of Singapore is urbanised, and the other half is occupied by “green spaces”, comprising unmanaged secondary forest fragments (around 20% or less), managed parks, gardens and roadside trees.

The four nature reserves (Central catchment, Bukit Timah nature reserve, Sungei Buloh wetland reserves and Labrador nature reserve) make up less than 5% of Singapore’s land area.

Lawns, vacant grassy plots and scrublands with scattered trees have limited capacity to provide ecosystem services and support the kind of rich biodiversity of a dense tropical rainforest.

Hence, instead of replacing our remaining secondary forests with small fragmented urban parks, we should devote more attention to forest conservation and restoration, not only around the central catchment nature reserve, but also in the secondary forests around the island so as to enhance ecological connectivity and boost ecosystem services, in order to alleviate urban heat island effect and promote our health and well-being.

Feedback on EIS report regarding Keppel Club site

Based on my recce in Labrador nature reserve and Berlayer Creek, I realise the importance of rewilding the vacant land, which was formerly occupied by BP oil refinery, to protect biodiversity and improve ecosystem services of the mangroves and lowland forests, so as to better mitigate the negative impacts of climate change. (Photos by Jimmy Tan)

In my previous feedback to Housing & Development Board (HDB) on the environmental impact assessment reports regarding Bukit Batok Hillside Park area, Dover-Ulu Pandan forest, Tengah forest and Pang Sua woodland, I have proposed alternative brownfield sites for housing development.

In the case of Keppel Club site, it is heartening to know that the development will be done on previously developed lands, while sparing the green spaces in the vicinity, such as Bukit Chermin and Berlayer Creek mangroves.

Even so, I have some concerns, which I hope HDB (and/or other relevant agencies such as National Environment Agency (NEA), Public Utilities Board (PUB) and NParks) will look into.

1. Close proximity to the coast means greater vulnerability to the impact of climate change, specifically, rising sea levels.

It would be good to have buildings located further inland and on higher ground, in order to prevent them from being flooded during high tides as the sea level continues to rise in future.

We do not want Singapore city to suffer the same fate as other coastal cities, such as Bangkok, Jakarta and Manila, which are sinking faster than expected due to factors such as rapid urbanisation, land subsidence and rising sea levels caused by climate change exacerbated by human activities.

2. Berlayer Creek is currently narrow and a little too cramped for visitors, and there is only one walkway on one side of the river.

While it is good for the proposed Berlayer Creek corridor to be added as a green buffer on the opposite side of the existing walkway, could we utilise the former BP oil refinery site as an additional buffer by rewilding it?

Otherwise, it would not be realistic to expect wildlife to move in a straight line along the narrow creek all the time, and the small space not only exposes the smaller prey animals to predators more easily but also creates negative edge effects.

Human visitors would also appreciate more space to move around and minimise human-wildlife conflicts, while at the same time, being able to get closer to the muddy shores at certain points to observe creatures such as mudskippers, which would otherwise be difficult to spot from the boardwalk.

3. Refrain from using chemical insecticides and pesticides in the vicinity of Keppel club site and surrounding green spaces, and instead rely on natural predators to control pest insect populations.

This proposal has been mentioned in my earlier feedback on the Environmental Baseline Study (EBS) report regarding Pang Sua woodland – please have a read here for more details.

4. Minimise or avoid using petrol-powered leaf blowers and lawn mowers in the vicinity to reduce noise and air pollution, and instead rely on brooms and rakes, as well as focus on rewilding the landscape for better ecological health.

This proposal has also been mentioned in my earlier feedback on the above-mentioned EBS report regarding Pang Sua woodland.


While I commend the environmental studies on development project sites for making improvements to address various concerns from Nature groups and members of the public more comprehensively over the past year, I also hope that we can wean ourselves off the habit of sacrificing greenfield sites (especially secondary forests) for development well before the target of halting deforestation by the year 2030 (as pledged during last year’s COP26 conference).

We can choose to prioritise redeveloping brownfield sites and educating the public on making better and more sustainable decisions when it comes to public housing demand (whether it is for rental, resale or new flats, or whether it is for home ownership, upgrading, property investment, etc.).

This is because for every hectare of forest we destroy in Singapore, even if we replant young trees to replace them, it is like taking one step forward and two steps backward because it takes decades for the new trees to grow and mature in order to provide the same amount of ecosystem services and support the same level of biodiversity as the mature trees.

May we keep in mind that time is of essence, in the context of climate emergency, biodiversity loss and mental health challenges facing us.

“To have any chance of keeping below 1.5 degrees Celsius of global warming, we must halt deforestation and restore forests within the decade. Support solutions that harness the resilience of Nature. Empower indigenous peoples to be forest guardians. All countries, businesses and communities have the chance to change history by preventing further deforestation and restoring the natural world.”

David Attenborough, English broadcaster, biologist, natural historian and author (UN Climate Change Conference, UK 2021)

[Last updated on 30 May 2022]


2 thoughts on “My feedback to HDB on Environmental Impact Studies (EIS) report regarding Keppel Club Site

  1. Pingback: My feedback on the EIS report regarding the proposed development at Tengah Forest North – Nature and Us

  2. Pingback: My feedback to Urban Redevelopment Authority (URA) on Springleaf Consultancy Study Environmental Impact Assessment (EIA) – Nature and Us

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