My feedback to Urban Redevelopment Authority (URA) on Springleaf Consultancy Study Environmental Impact Assessment (EIA)

Dear Sir/Madam,

I understand that according to the Environmental Impact Assessment (EIA) report commissioned by Urban Redevelopment Authority (URA), Springleaf precinct occupies around 33 ha (about the same size as Dover forest), of which 25 hectares of the undeveloped nature areas were studied.

I note that Springleaf study area consists of regenerating secondary forest, freshwater swamp forest, scrubland and grassland, in which a total of 343 fauna species and 283 flora species have been recorded, including charismatic endangered species such as Sunda pangolins and smooth-coated otters.

Sungei Seletar in the freshwater swamp area of Springleaf forest (Photo by Jimmy Tan)

Firstly, page 10 of the EIA report says:

“Considering the ecological value of the site, development of a residential precinct absent of any mitigating measures would lead to a significant impact on the rich biodiversity within the site at present. This includes plant species such as the Critically Endangered Elaceocarpus obtusus ssp. Apiculatus that can be found within the forested area, and Critically Endangered animal species such as the Sunda Pangolin, Lesser Mousedeer, and Lesser Bamboo Bat. It will be particularly important for this site to achieve a balance between the residential and commercial developments and the preservation of the natural heritage.”

Since critically endangered species can be found in Springleaf forest and the absence of any mitigating measures would lead to a significant impact on the rich biodiversity, wouldn’t it be more important to conserve the forest (or more specifically, the 25-hectare green spaces) fully as a core wildlife habitat and ecological corridor that links Nee Soon freshwater swamp forest (NSSF) to Springleaf nature park?

For example, given that Sunda Pangolins are estimated to number about 100 in the wild (as of the year 2016), it is possible that any further habitat loss and fragmentation will cause population decline and inch them closer towards local extinction, such as through roadkills and lack of genetic diversity, even if there are mitigation measures since pangolins are nocturnal, burrow underground and hard to track.

I am wondering what is the criteria for granting approval to this development proposal because by deliberately carrying out urban or housing development in an ecologically sensitive nature area that is adjacent to the Central Catchment Nature Reserve (CCNR) where critically endangered species can be found, wouldn’t we be committing a form of ecocide, which Oxford Dictionary defines as “destruction of the natural environment by deliberate or negligent human action”?

As page 20 of the EIA report also noted, “disturbance to Springleaf forest and its surrounding areas will pose a threat to these specialised groups of species (including the endemic freshwater fish species), and in turn results in the loss of ecological functions that Springleaf forest provides to NSSF.”

Also, how is it that developers and the like can be exempted from the law that protects the habitats of our rare, native species (such as Springleaf forest and Tengah forest, where pangolins live), while the general public can be fined for entering their habitats for nature appreciation in a national park or nature reserve outside the opening hours, as mentioned in a news article dated 17 April 2019?

“Sensitive fauna includes the pangolin, mousedeer, slow loris and the cinnamon bushfrog whose populations we are currently monitoring, carrying out habitat enhancements for and have in place species recovery efforts to build resilience and sustainability in their populations.”

Dr Adrian Loo, NParks’ group director of conservation (17 April 2019)
Grass lynx spider preying on an insect in the southern section of Springleaf forest (Photo by Jimmy Tan)

Secondly, page 28 of the EIA report says:

“In total, 283 species of plants, 21 species of mammals, 134 species of birds, 29 species of reptiles, 18 species of amphibians, 32 species of fish (19 in the present study), 3 species of shrimps, 64 species of butterflies and 42 species of dragonflies were recorded from Springleaf forest, including conservation significant species.”

It is unfortunate that certain invertebrates such as spiders are not accounted for in the EIA report because spiders are important to the ecosystem too, as they prey on pest insects such as mosquitoes and may help to control dengue outbreaks.

As also noted by Oxford Biodiversity Network, “invertebrates have important roles in the functioning of ecosystems: nutrient cycling, pollination, and herbivory. We need to better understand these complex interactions to predict how they are likely to change in the face of a rapidly changing climate.”

“Invertebrates occupy many important trophic niches in natural communities. Decreasing or changing invertebrate diversity and abundance can have strong effects on many ecosystem functions and services ranging from primary productivity, to pollination, and pest control.”

“Recognizing the quiet extinction of invertebrates” (3 January 2019)
A dragonfly at a stream in Springleaf forest. According to National Environment Agency (NEA), “When we fog, we kill not just the mosquitoes, we also kill the predators such as dragonflies. And dragonflies are nature’s air force. The dragonflies can eat as much as 100 mosquitoes a day”. Though some dragonflies, such as common parasol, are common species, may we bear in mind that both common species and rare species (of flora and fauna) are needed in order to maintain functional biodiversity, since all the species are interconnected in complex food webs in the ecosystem. (Photo by Jimmy Tan)

Last but not least, I understand from page 10 of the EIA report that “Springleaf Precinct is intended as an urban village, with a total of approximately 2,000 dwelling units (DUs)”, and page 53 says “development parcels will be privately owned land”.

Notably, according to HDB, “due to continued household growth and evolving housing needs, there is a strong demand for public housing in both mature and non-mature estates.”

If there is a strong demand for public housing, why are we sacrificing Springleaf forest for private housing instead, as it is antithetical to URA’s plans to make affordable housing more inclusive and accessible to Singapore’s transforming demographic (especially Singaporeans who are less well-off) with ever-changing housing needs?

Also, considering how ecologically sensitive the natural habitat of this greenfield site is and how close its proximity is to the rare Nee Soon freshwater swamp forest and Central Catchment nature reserve, shouldn’t we be focusing on repurposing brownfield sites with structures that are less relevant to the modern economy for residential use to increase the total capacity of the local housing market?

Already we have lost Lentor forest (which is connected to CCNR via Thomson nature park and Tagore forest) almost entirely, and it is not known if any survey has been done before its clearance to ascertain if there is sufficient demand from potential property buyers for new housing in that area to justify the deforestation of such an ecologically sensitive habitat, especially since property agencies are advertising the planned condominium development(s) only after the forest has been cleared.

Moreover, let’s not forget that a considerable number of rich property buyers from overseas countries such as China are buying private property in Singapore not to live there but rather “purely to invest or rent the units out to tenants”, hence these owners and/or their tenants may not have long-term vested interests in caring for the environment in our ecologically sensitive areas.

As page 220 of the EIA report says, “Residents who choose to live here will be part of a community committed to sustainable living. Various design elements incorporated within the development, such as the Sustainability Education Centre sited within the Red House, will help reinforce the message and facilitate active stewardship in the community”, how can we ensure there will indeed be active stewardship in Springleaf forest if it turns out that half of the residents are property investors who have no intention of staying there long-term (if at all)?

Tragically, while many home upgraders and property investors may stay there for a few years before selling or renting out their units for quick profits, the natural streams and the native flora and fauna, including endangered species, as well as the various ecosystem services they provide (such as pollination, seed dispersal, soil detoxification, nutrient recycling, flood prevention, air purification, biodiversity protection, dengue outbreak mitigation, immune boosting benefits, carbon capture and storage, cooling of urban heat island effect, etc, all of which are worth at least millions of dollars if translated into tangible economic value), are lost and/or displaced permanently, as is the case for Lentor forest.

The severe fragmentation of Lentor forest has affected safe movements of Sunda pangolins and Raffles’ banded langurs between Thomson nature park and Lentor-Tagore forest and also exposed native wild boars and globally endangered long-tailed macaques to roadkills and/or potential human-wildlife conflicts. For example, the loss of streams due to the clearance of Lentor forest might have resulted in a Raffles’ banded langur having to climb down a huge canal in the vicinity to drink water and becoming stranded in July 2022. At least 3 wild boars have ended up as roadkills while crossing Seletar Expressway and/or Lentor Avenue (with injuries caused to humans in the accidents as well) ever since deforestation began at Lentor in 2016. (Photo by Jimmy Tan; maps by Google and Apple)

Could we have more accountability and transparency with regard to the planned destruction and development of Springleaf forest as well, since we should be focusing on managing the insatiable housing demands (most of which seem to be wants for more comfort and convenience rather than survival needs), redeveloping brownfield sites as well as conserving and restoring our forests and mangroves, instead of destroying our precious few remaining greenfield sites, given that we are facing the existential threat of climate emergency, biodiversity loss and public health challenges (such as dengue outbreaks, heat injuries, mental health issues, suicide cases, etc) in the age of Anthropocene?

P.S. It would be good if the following proposals can be taken into consideration in your Environmental Monitoring and Management Plan for Springleaf precinct development (which I mentioned in my recent feedback to HDB regarding the EBS report on Choa Chu Kang N1 and EIS report on Keppel Club site)?

For ease of reference, I have copied and pasted the relevant portions as follows:

(1) Avoid using chemical pesticides, including fumigation, in the vicinity, and instead leverage the help of natural predators of pest insects by ensuring the environment is conducive for frogs, toads, spiders, geckos, dragonflies, damselflies, etc to thrive (instead of concretising the ground surface and using harmful chemical sprays). This corresponds to page 35 of the section on Biodiversity Conservation Strategies found in the annex of the EIA report, under “Biodiversity-sensitive insect pest control practices”.

On a similar note, may I refer you to a field observation about the correlation between the ecological health of the ecosystem and the proliferation of Aedes mosquitoes in my Facebook post here?

(2) Avoid or minimise the use of petrol-powered leaf blowers and lawn mowers, not only in (Springleaf precinct), but also in all housing estates, because they cause air and noise pollution (thus affecting people’s health and well-being), and harm microorganisms and invertebrates (which include pollinators, such as bees, wasps, moths, beetles and butterflies).

(3) Observe holistically the United Nations’ Sustainable Development Goals, such as SDG12 “Responsible consumption and production”, by changing the way we produce and consume goods and resources, in order to reduce our ecological footprint, and SDG15 “Life on land”, by conserving and restoring the use of terrestrial ecosystems such as forests and wetlands, halting deforestation to mitigate the impact of climate change, and reducing the loss of natural habitats and biodiversity which are part of our natural heritage.

Any new housing development should be confined to the grassy parkland, scrubland and existing developed land (indicated by areas F, G and H, where there are no native flora species), so as to maximise the chances of natural propagation of the native flora species, as well as ensure minimal disturbance to the ecosystem services and biodiversity of Springleaf forest, aka future Nee Soon nature park. (Map by URA)

Thank you for your kind attention.

Yours sincerely,

Jimmy Tan San Tek, founder of Singapore’s Forests and Farms: Nature Conservation and Education

(Last updated 14 September 2022)


One thought on “My feedback to Urban Redevelopment Authority (URA) on Springleaf Consultancy Study Environmental Impact Assessment (EIA)

  1. Pingback: Feedback: Environmental concerns over habitat fragmentation in Bukit Batok nature corridor and Tengah nature way – Nature and Us

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