[On 18 November 2022, the following feedback has been sent to the representatives of Urban Redevelopment Authority (URA), Housing & Development Board (HDB) and National Parks Board (NParks) as part of our ongoing dialogue.]
Thank you for your reply dated 8 Sep 2022 regarding our email to Dr Amy Khor, in which she advised us to approach Ministry of National Development (MND) for a dialogue. We appreciate the time that you have taken to respond to our email.
As our email to Dr Khor didn’t convey our full feedback on Bukit Batok Hillside Park (BBHP) area, since we were requesting a Meet-the-People session to discuss the details, may we take this opportunity to respond to your email to briefly introduce ourselves and provide some details of our feedback, as part of the dialogue to promote environmental sustainability in the community?
Jimmy Tan’s background
As a resident of Bukit Batok East who is also a nature enthusiast and who works in the vicinity as a part-time food delivery cyclist and freelance writer and editor, Jimmy feels compelled to share his lived experience and observations after moving from his original hometown, Toa Payoh, several years ago, partly to seek refuge in a cooler and quieter environment next to Bukit Batok nature park (which makes him a “microclimate refugee”).
Also, as the creator of the petition to save BBHP area from housing development and one of the co-creators of the petition (with Roxane and Saniroz) to conserve at least 30-50% of Tengah forest, he hopes to be a voice representing almost 15,000 BBHP petition supporters and close to 10,000 Tengah forest petition supporters of nature conservation in some ways, who are concerned about the health, social and environmental impacts of development.
Denise Liu’s background
Denise is a senior researcher working in a social service agency and an associate lecturer with the Singapore University of Social Sciences. She is also an active member of the Bukit Batok community. She chose to purchase a BTO flat in Bukit Batok because she enjoys the greenery in the area. During COVID-19, in particular, taking her dog for long walks around BBHP Hill 2 is essential to her well-being and mental health.
As a member of her neighbourhood’s Resident Network, she has spoken to many residents who also value the greenery and nature of the estate. Many have expressed their concerns about losing these spaces, which provide a much-needed respite from the crowded BTOs they live in. The loss of BBHP Hill 2 will be particularly devastating for the hundreds of residents who cycle, jog or walk around the hill as part of their fitness routines. She spoke to a resident recently who is thinking about selling her flat if/once BBHP Hill 2 is redeveloped, as she cannot imagine living in a neighbourhood surrounded by BTOs, without greenery and the space to bring her dog for walks.

Our response to HDB’s reply to Jimmy’s feedback on EIS report on BBHP area
Firstly, we noted that HDB’s reply dated 9 September 2020 says:
“The land use zoning of this area is gazetted as ‘Residential’ and ‘Park’ in Urban Redevelopment Authority (URA)’s Master Plan since 2003. As reflected in the current Master Plan 2019, the area is safeguarded for housing and park development, which will offer more housing choices and recreational spaces in Bukit Batok town.”
Although URA’s Master Plan 2003 was approved and gazetted after public consultation, we have seen that many things have changed over the past 19 years.
Back then, the urgency of the existential crisis associated with the climate emergency facing us had not received as much attention and concern as it has today.
Early this month, United Nations Secretary-General Antonio Guterres reminded everyone at COP27 that the world was losing the battle against climate change, and it would soon be too late to undo the damage being inflicted on the planet.
Notably, eight of the ten warmest years on record in Singapore have occurred in the 21st century.
Since Singapore is heating up twice as fast as the rest of the world, mainly due to rapid deforestation and urbanisation, especially over the past few decades (as shown in the graphs below), it may be suicidal for us to keep on replacing the naturally cooling dense forests with heat-absorbing concrete and asphalt surfaces.
As the Centre for Climate Research Singapore has projected that Singapore could experience an increase in daily mean temperature of 1.4 to 4.6 degrees Celsius towards the end of this century, more intense and frequent heavy rainfall events, and mean sea level rise of up to 1 metre by 2100, the need to conserve and restore our forests is critical for our survival, as also noted in NParks’ One Million Trees Webinar | Beneath the Canopy: Uncovering the Science of our Forests in December 2020.



According to research studies, sizeable forests (10 ha or above) with dense trees can cool the environment up to 300+ metres, whereas plants on facades of buildings can only cool within 4 metres effectively. (Graphs from Global Forest Watch and weather.gov.sg, map from NParks webinar, photos by Jimmy Tan)
Secondly, much as we appreciate the efforts and dedication of our urban planners, we note that they have not undergone any mandatory course on basic ecology and the EIA process until the plans were announced in 2020 regarding this requirement.
Hence, it is possible that the Master Plan 2013, as well as the Master Plan 2019, has not taken into consideration the full impacts of continual forest habitat loss and fragmentation on our climate, biodiversity, ecological connectivity and human health and well-being, partly because we did not have the benefit of hindsight.
In the past decade alone, Singapore has witnessed floods, landslides, animal roadkill, human-wildlife conflicts and disease outbreaks – many of which are unprecedented, as mentioned in Jimmy’s blog.
EIS report on BBHP area is likely to have been compromised by certain factors
As regards BBHP area (aka “Zone A” according to your email), while it is commendable that the agencies conducted an EIA in 2018 to better understand the site condition and recommend measures to mitigate environmental impacts of development, we note that the EIA was likely to have been compromised by the ongoing construction of Bukit Batok West Ave 5 in 2018, which divided the two hills (aka BBHP Hill 1 and Hill 2).
(The premature clearing of trees in Kranji woodland by JTC in 2020 before NParks could complete their biodiversity studies serves as a lesson here, since the exact impact on the environment could not be calculated because the offences took place before any studies were undertaken.)

Shouldn’t both BBHP Hill 1 and Hill 2 be studied together before any construction was done in the vicinity, as they were originally part of the same ecological corridor, which was also recognised by a National University of Singapore (NUS)’s paper on vascular plant flora of Bukit Batok in 2013 as having “the highest percentage of native species”?
Moreover, the various feedback from other members of the public, which was compiled by Singapore Youth Voices for Biodiversity (SYVB), also noted that the biodiversity survey was conducted in April over 8 days, which is outside the bird migratory season.
Another feedback noted that there was a lack of reporting being done with regard to the Chiropteran assemblage (bats), who provide an invaluable service as insect predators and seed dispersers.
Over the past couple of years, during recces in/around BBHP area, some native fauna not recorded in the EIS report have also been spotted, such as:
- Hill mynah (Gracula religiosa) at a junction next to BBHP Hill 2, 18 Nov 2021 (an indicator species identified in NParks’ Ecological Profiling Exercise)
- Laced woodpecker (Picus vittatus) in BBHP Hill 2, 8 March 2022
- Baya weavers’ (Ploceus philippinus) nests in BBHP Hill 2, 19 March 2022
- Blue-throated bee-eater (Merops viridis) in BBHP Hill 1, 12 Aug 2022
- White-throated kingfisher (Halcyon smyrnensis) in BBHP Hill 1, 12 Aug 2022
- Rare native cranefly (Hexatoma plecioides) in BBHP Hill 1, 17 Aug 2022

All these suggest that the EIA done on BBHP area could have been better and more comprehensive in its assessment of the environmental impacts if more time and attention had been given, as it is relatively limited compared to the other EIAs which were done for other ecologically sensitive areas, such as Tengah forest north and south, and Springleaf forest.
This is regrettable because a deeper appreciation and understanding of its relatively rich biodiversity should compel us to focus more on preserving natural features to facilitate ecological connectivity with minimal disruption and harm caused to the well-being of the wildlife and human residents living along and around Bukit Batok nature corridor.
Environmental impacts observed along Bukit Batok Nature Corridor in 2018-2022
As it turns out, we have seen some environmental impacts along Bukit Batok Nature Corridor after the EIA was conducted in BBHP area in 2018, and after about 30% of Tengah forest was cleared since 2018 (as well as 4 ha of the forest in BBHP area was cleared for housing development in early 2021), despite mitigation measures being taken, such as:
- A road accident involving a wild boar near Brickland Road and Bukit Batok West Ave 5 in 2019, who might have been displaced from Tengah forest or BBHP area due to habitat disturbances
- More mosquitoes were encountered in BBHP area this year compared to 2020-2021, possibly due to loss of forest cover resulting in warmer microclimate favouring mosquito breeding, and also a decline in the populations of their natural predators such as spiders, frogs and dragonflies (which testifies to the correlation between deforestation, urbanisation and dengue outbreaks)
- Soil erosion and tree falls in Zone B (aka BBHP Hill 2) during heavy rain, possibly due to edge effects and loss of tree cover on the steep slopes, 13 Aug 2022
- Many tree falls along the forest trails, especially near the BTO construction site, possibly due to edge effects in BBHP area, 19 Aug 2022
- A disoriented Sunda colugo (Galeopterus variegatus) was found stranded at a carpark next to Block 271, Bukit Batok East 4 and had to be rescued by ACRES, around 27 Sep 2022
Although the colugo, who most likely glided from BBNP and/or Toh Tuck forest (TTF), was not directly impacted by the ongoing deforestation in BBHP area, the fact that it got disoriented illustrates how the loss of ecological connectivity due to the removal of trees during the road widening process between BBNP and TTF has affected safe movements of the wildlife such as the colugos.

This impact is significant because as noted in the above blog:
“Wouldn’t the ongoing removal of vegetation at BBHP Hill 2, aka Zone B (as well as the planned deforestation for the November 2022 launch of BTO site in BBHP Hill 1, aka Zone A) further disrupt ecological connectivity, which might also further impact the wildlife (such as the uncommon native Sunga colugos, critically endangered pangolins, forest-dependent palm civets, endangered long-tailed macaques, etc) moving between western catchment forests (via Tengah nature way and Bukit Batok nature corridor) and the central nature reserves?”
Why Zone A and Zone B of BBHP area should be protected from further deforestation
While HDB has done well in retaining the natural stream (aka Stream A according to the EIS report) and its catchment area within the planned BBHNP and expanded the original ‘Park’ area from 7.5ha to about 9.2ha, it is regrettable that Stream B and its catchment area in Zone A of BBHP area have not been retained due to their being zoned as a BTO site to be launched in November 2022.
This is because Stream B catchment area has a large fig tree (Ficus vasculosa) with conservation status of Endangered and some seedlings are situated on higher ground immediately next to the stream B (where dragonflies can be found to control the mosquito population), and slender pitcher plants (Nepenthes gracilis), which the rare pitcher blue butterfly is dependent upon, have also been discovered growing on the steep slopes there.
Speaking of which, both the aforementioned areas in Zones A and B have steep slopes along parts of the perimeter of the forest – some of which have gradients of 30 to 40 degrees or more. As noted in an article, “Anything above 20% (incline) is deemed steep. Beyond about 15%, costs begin to increase significantly as the risks become greater and the work becomes more difficult.” (See below image for reference.)

Although we appreciate that the agencies seek to provide affordable public housing to Singaporeans, we wonder if it is feasible building BTO flats on such steep slopes, considering that it is more costly and also more risky, since the removal of vegetation that holds the soil together along the slopes may invariably result in soil erosion and even landslides, given the history of landslides occurring in the hilly regions of Bukit Batok and Bukit Gombak as well as the occurrences of more severe storms due to human-induced climate change over the past decades.
Why Tengah forest should also be protected from further deforestation
Speaking of climate change, residents living (and those who work outdoors such as food delivery cyclists and walkers) in Jurong, Bukit Batok West and Choa Chu Kang around Tengah forest risk experiencing heat injuries (such as dehydration, skin rashes, fatigue, irritability, heat strokes and inability to focus on work, affecting safety, creativity and productivity for those who work from home or outdoors) due to the warming microclimate as a result of the deforestation and urbanisation that have been going on since around 2018.
For example, while doing part-time food delivery in this region lately, I (Jimmy) could experience the warming effect on some of the apartment blocks, such as Block 435A, Bukit Batok West Ave 5 (see image below for reference).

The air outside some units of Block 435A felt stuffy and smelled stale due to lack of ventilation, and since the small units along the narrow corridors seem to be for lower income residents, they may be affected by the urban heat island effect the most due to inadequate or lack of access to air-cooling/conditioning devices and healthcare services, and there is only so much we can do to adapt to the warming climate in our own capacity.
Last year’s SG Climate Rally features Marlina, who shared about the challenges of dealing with the rising heat with no air conditioning in a rental flat, which shows that Muslim women in particular tend to suffer more from heat injuries as they have to wear tudung and full length clothes in the households.
As a Bukit Batok resident working as a food delivery cyclist in the vicinity, Jimmy has also been dealing with symptoms of heat injuries, such as skin rashes, which persisted for months earlier this year and required medical treatment before the symptoms finally subsided. (The receipt of the medical bill is available upon request.)
Last but not least, we learnt that certain fauna in the remaining parts of Tengah forest have been affected by the noise and disturbances caused by the ongoing construction works as well as the habitat loss and fragmentation – they include the native wild boars (Sus scrofa) and the nationally near-threatened (and globally vulnerable) long-tailed parakeets (Psittacula longicauda).
As shown in the above video dated 5 Sep 2022, the wild boar at the forest fringe along (old) Jurong Road somehow got a fright when it saw human beings and ran away even though the hikers stood still. Compared to wild boars in the forests of Pulau Ubin, as well as the nature parks and reserves in mainland Singapore, the wild boars encountered in Tengah forest ever since forest clearance began around 2017 tend to be skittish or nervous, possibly because they have been stressed by construction noise and habitat loss (and it is highly unlikely that the wild boars have been fed by humans since the forest perimeter has been fenced up).
If we are to learn from the encounters with wild boars who have been displaced from their homes and wandered into residential areas in Punggol and Pasir Ris in 2018-2021, in which humans got hurt by the disoriented wild boars, utmost care and attention should be given to minimise habitat loss and improve ecological connectivity in and around Tengah forest, in order to prevent such human-wildlife conflicts in future, such as by conserving at least 30-50% of the original forest.

As for long-tailed parakeets, even though they might seem to be more commonly seen in residential areas such as Choa Chu Kang, over the past year or so, their conservation status remains vulnerable especially since they are being displaced from their habitats in Tengah forest. Already, some residents find these parakeets too noisy, and it is a sad reality that such beautiful forest-dependent birds are being seen as a nuisance or even pests just because they became homeless and were forced to adapt and co-exist with humans in residential areas as a result of rapid deforestation and urbanisation in Singapore.
Let’s also remember the fate of other native fauna in the diminishing Tengah forest, such as the globally and nationally critically endangered Sunda pangolins (Manis javanica) and the globally endangered long-tailed macaques (Macaca fascicularis).
The current 20 percent of Tengah forest set aside for greenery is unfortunately insufficient to ensure their safety and long-term survival, if we were to go by the artists’ impressions of the manicured, sparsely growing plants in 50-m wide wildlife corridors (which is considered by botanist Dr Shawn Lum as too narrow since at least 50-m buffers are needed on both sides for adequate protection from human disturbances, light pollution, etc) surrounded by buildings and other man-made features, and the absence of eco-links to facilitate their safe movements between Western water catchment and Central catchment nature reserve.
At the very least, the mitigation measures recommended by the Tengah forest EIA reports should incorporate the same considerations for wildlife-friendly environments as those in Springleaf forest EIA report commissioned by URA, which has recommended about 70 percent of the forest to be conserved and specially designed housing and pathways that minimise human-wildlife conflicts to be built.

Last but not least, we note that the Straits Times reported on 11 November 2022 that “while Singapore’s forests provide refuge for up to about a third of the world’s straw-headed bulbuls, the globally critically endangered species prized for its singing has increasingly been driven to the brink of extinction.”
If the critically endangered straw-headed bulbuls (Pycnonotus zeylanicus) are becoming more endangered, then their forest habitats should also be even more protected, instead of just having the international songbird trade regulations tightened.
While it is good to show concern and take necessary actions regarding the trade of the endangered songbirds on the international stage, we should also spare no effort to stop the decimation of their forest habitats in our own backyard, such as Bukit Batok hillside park area, Tengah forest and Dover forest, where these songbirds have been seen and heard.
Otherwise, it would be tragic to witness the extinction of the straw-headed bulbuls in the wild happening right under our nose when we already have the knowledge and the means to protect them and their natural habitats, especially since Singapore has only about 200+ individuals left (in mainland Singapore, as of 2021) and is their last stronghold in Southeast Asia, if not the world.
Why we should focus on redeveloping brownfield sites to meet demand for public housing
Finally, we believe that our dialogue to promote environmental sustainability in the community wouldn’t be complete without a brief discussion about HDB’s announcement of strong demand for public housing in Singapore, as it has been cited as a major reason for the need to clear our secondary forests for housing development.
We note that the strong demand for public housing (whether BTO, resale or rental) tends to occur mainly in housing estates close to downtown, such as Bendemeer, Kallang, Queenstown and Redhill, whereas news reports have shown that initial applications for new BTO flats in western parts of Singapore, such as Tengah and Bukit Batok West, tend to be lower than those in Toa Payoh and other central locations in Singapore.
As stated by HDB in June 2022, “There were about 19 BTO projects that had flats with first-timer application rates of 1.7 or lower. The locations for these BTO projects included areas in Bukit Batok, Jurong West and Tengah for non-mature estates, and in Tampines for mature estates.”
Hence, we feel that our focus should be more on redeveloping brownfield sites for SERS, VERS and BTOs (such as in the case of the recent Tanglin Halt and Ang Mo Kio SERS projects as well as redevelopment of Mount Pleasant and Keppel Club golf course for public housing), rather than sacrificing the forests in ecologically sensitive areas and along the nature corridors identified by NParks in their Ecological Profiling Exercise (EPE), which include Bukit Batok nature corridor and Clementi nature corridor.
As also noted in the above blog, the news reported last year that many people buy property just to sell them in 5-10 years upon meeting the Minimum Occupation Period (MOP) to make quick profits, instead of staying long-term.
Hence, if we keep on building new BTOs and condos in the vicinity to cater to such frivolous housing demands instead of redeveloping brownfield sites elsewhere for genuine buyers who want to stay long-term, we not only may make it more difficult for Singaporeans to find affordable public housing given the space constraints, but also unwittingly sacrifice our precious few forest habitats, such as along Bukit Batok nature corridor, to build housing and widen roads mainly to cater to the rich and privileged who could afford to buy housing for property investment/speculation and drive cars.
There is also a chance that Singapore may eventually experience an oversupply of HDB flats, as noted in a commentary by Stacked Homes dated 20 October 2022, in view of the ageing population (and the global warming fallout).
Our proposals
In view of the climate emergency, biodiversity loss and public health crisis facing us, as well as in the spirit of participating in Forward SG, may we ask URA, HDB, NParks and other relevant agencies to seriously consider the following proposals:
- Increase MOP from 5 years to 10 or more years for new BTO flats (especially those that will be built in greenfield sites), so as to discourage people from buying new property purely for short-term investments and profits at the expense of the forests and forest-dependent wildlife.
- Make resale/rental flats more affordable/accessible, optimise the allocation of Sale-Of-Balance flats, and make it compulsory for those who own private housing to give up and sell back their public housing flat to HDB because subsidised public housing should not be used for profiteering.
- Avoid any further deforestation along Bukit Batok nature corridor (including BBHP Hill 1 and 2 area) and in Tengah forest, so as to maintain ecological connectivity, climate resilience and a liveable environment for humans and wildlife between Western water catchment and Central catchment nature reserve, and focus on redeveloping brownfield sites (such as old industrial sites, underutilised or vacant lands, abandoned schools, golf courses whose leases are expiring soon, etc) elsewhere.
- Adopt the Degrowth or Doughnut economic model to ensure that we respect our social foundation and ecological ceiling, so that every Singaporean will lead their life with dignity, opportunity and community within the means of our environment.

Although Bukit Batok Hillside Park area is relatively small and seemingly insignificant compared to other bigger forests in Singapore, it may well be our weakest link because any further disruption along this part of Bukit Batok nature corridor may irreversibly affect the safe movements of fauna (including pollinators and seed dispersers vital for our food security) between Western water catchment and Central catchment nature reserve. The physical and mental well-being of our residents living in the vicinity is also at stake, as shared earlier.
We are only as strong as our weakest link, for we are all members of the same body and citizens of the cosmos, and if the most vulnerable among us suffer as a result of climate emergency, we all suffer together as one. As rightly noted in the vision that Dr Amy Khor has for Hong Kah North (which can be applied for the entire Singapore) - may we build “a place where no one is left behind, but everyone progresses together, each at his own pace”. This can be achieved by adopting the above-mentioned proposals, which include conserving and restoring the forests in Bukit Batok nature corridor and Tengah nature way, to prevent further habitat fragmentation, boost climate resilience, and protect our health, well-being, safety and long-term survival.
Thank you for your attention, and we look forward to continue working with you and Dr Amy Khor on promoting environmental sustainability in the community.
Yours sincerely,
Jimmy Tan San Tek, Bukit Batok East resident
Denise Liu, Bukit Batok West resident
cc
Dr Amy Khor, Adviser to Hong Kah North SMC Grassroots Organisation
Mr Desmond Lee, Minister for National Development of Singapore
[Main text edited slightly to ensure clarity and reflect the latest updates as of 1 January 2023]