My feedback to Housing & Development Board (HDB) for Bayshore environmental study

Here is my feedback to HDB for the Environmental Impact Assessment (EIA) report on Bayshore forest.

I appreciate that the EIA and Environmental Management and Monitoring Plan (EMMP) have been arranged for the regenerating scrubland and secondary forest in Bayshore area, which I noted has been fully reclaimed from the sea by the 1980s and zoned for development in 2003.

Firstly, according to the executive summary page 1, the “baseline ecological surveys were conducted between 25 April and 21 July 2022”. Given the considerable size (31.4 ha) of the study area, which is about the same size as Dover forest (33 ha), and the fact that the survey was conducted outside the bird migratory season (September to March), I think that the 54 avifauna species recorded in the EIA may not be fully representative of the bird demographics that use Bayshore forest as a core habitat and/or ecological corridor or stopover between the forested areas around Sungei Serangoon water catchment area in the north and the linear forests south of East Coast Parkway (ECP).

Bayshore forest may serve as a core habitat and stopover for resident and migratory birds. For instance, the vulnerable Buffy fish owls have been spotted in the eastern side of Singapore, and it is not inconceivable that they may use Bayshore forest as a feeding ground and/or ecological corridor too. (Map adapted from URA/NParks for illustration only)

During my short recce at Bayshore area on 21 November 2022, I saw some birds resembling parakeets flying around Upper East Coast Road (though I couldn’t make out their exact species from a distance). Together with other vulnerable species such as Rusty-breasted cuckoos and Red-legged crakes as well as endangered Blue-crowned hanging parrots, Changeable hawk-eagles, Oriental magpie robins and Red junglefowl, these birds may have nesting or roosting sites within Bayshore area.

The scrubland may double up as a freshwater marsh during rainy seasons, acting as a carbon sink and a refugium for waterbirds such as the vulnerable red-legged crakes. (Photo by Jimmy Tan)

If the entire forest were to be decimated for housing and road development, many of these birds would become homeless and would be forced to relocate to other forests where they have to compete with other forest-dependent birds for food and shelter.

Some of these birds may also be forced to nest or roost in roadside trees close to houses and apartments in urbanised or residential areas, such as Bedok, Siglap and so on, where they may face fierce competitions from urban-adaptive birds such as Javan mynahs, or they may be considered a nuisance by human residents, due to noise (like in the case of parakeets, as many of them were recently captured and/or culled in Choa Chu Kang, unfortunately due to their being displaced from Tengah forest as a result of deforestation and habitat loss in the vicinity).

Secondly, I noted from page 1 of the executive summary that “the Developments are located primarily on reclaimed land with an exotic-dominated secondary forest”. To me, land reclamation does not necessarily give humans the right to own the land, as it ultimately belongs to Mother Nature, to whom we owe our existence. We also owe our ability to reclaim the land partly to other countries where sand mining was carried out. As noted in an article, “instances of land erosion, community displacement, floods, or droughts in obscure parts of our Southeast Asia neighbours — all of which can be linked to Singapore’s land reclamation pursuits.”

Therefore, could we rethink our relationship with the reclaimed land of Bayshore, just like we have chosen to conserve most of the forest in Coney island which was mostly reclaimed too, and enhance the biodiversity of Gardens by the Bay which was also created on reclaimed land?

My fauna sightings include dragonflies, spiders, a snail shell and a palm civet’s poop. (Photos by Jimmy Tan)

Thirdly, during my recce at Bayshore forest on 21 November afternoon, I encountered many mosquitoes in the stretch of the forest between Bayshore MRT station construction site and ECP, and I had to swat at the mosquitoes that were biting my arms every few minutes.

Despite the presence of dragonflies, which are natural predators of the mosquitoes and other insects, the mosquitoes appear to proliferate in the area, most probably due to the forest ecosystem having been disturbed by the ongoing construction works in the vicinity.

A dragonfly seen in Bayshore forest. Since the profusion of mosquitoes is a sign of a disturbed ecosystem in this forest, restoring ecological health through habitat enhancement, such as improving water quality for frogs and incorporating dragonfly ponds (like the one in HDB’s Punggol Northshore), is vital to control the disease-carrying mosquito populations. (Photo by Jimmy Tan)

We need healthy ecosystems, such as the relatively undisturbed mature secondary forests in Windsor nature park and Bukit Batok nature park, where frogs and dragonflies thrive, in order to curb mosquito populations and prevent dengue outbreaks effectively. You need not have to take my word for it, as you could visit the aforementioned forests and check for yourself, for we cannot care for what we do not know experientially. I believe that your forest experiences will tally with the observations below:

“Urbanization, habitat destruction and fragmentation, climate change, as well as chemically-intensive landscape management and agriculture have all led to disruptions in ecosystems. While mosquitoes can readily breed in poor-quality sites created by human disturbance, other organisms, including many of the predators that naturally control mosquitoes, require higher quality habitat. Pesticides that are used to try to control mosquitoes may actually be making matters worse as mosquitoes become resistant to the pesticides, while natural predators and other invertebrates are killed or harmed, which throws aquatic food webs out of balance.” (“Ecological mosquito management” by City of Boulder Natural Climate Solutions)

Therefore, could we apply similar ecological mosquito management, such as the one recommended in section 1.2.10 “Biodiversity-sensitive insect pest control practices” in Springleaf forest EIS report commissioned by Urban Redevelopment Authority (URA), and also conserve and restore at least 20-40 percent of the forest to improve ecological health and support natural predators and other invertebrates such as spiders, so as to control disease-carrying mosquito populations and prevent dengue outbreaks effectively?

Poop of a palm civet, who plays an important role in the ecosystem as biological pest control and seed disperser for maintaining and improving the health of Singapore forests, as seen in Bayshore forest. (Photo by Jimmy Tan)

Fourthly, since palm civets live in Bayshore forest, as noted in the EIA report and evidenced by the presence of their poop on the forest floor, it would be good to not only ensure they have sizeable habitats to live in, but also to build drain culverts or tunnels to enable the civets and other ground-dwelling creatures, such as monitor lizards, otters and snakes, to move or escape to the wooded area across ECP for their long-term survival.

Otherwise, the civets will be forced to move to residential areas nearby where they have been sighted more often in recent years, as noted by Ms Xu Weiting, an instructor (ecology, evolution and biodiversity) at the National University of Singapore’s (NUS) Department of Biological Sciences: “The seemingly high encounter rates could be a combination of factors, which include increased awareness of local wildlife over the years, ease of reporting sightings on social media and also clearing of forest patches, which has led to civets dispersing out into nearby areas.”

Culverts act as underpasses for animals that prefer more privacy, like the common palm civet. (Photo of NParks poster by Jimmy Tan)

Although certified wildlife handling contractors or animal management specialists will be at hand to help relocate the animals to safer grounds during the construction phase, extra care should be taken to prevent or minimise incidences of roadkill and human-wildlife conflicts as a result of the forest-dependent animals being displaced from their habitats.

This is because the animals may end up injured or dead if they are not shepherded or captured for release under safe conditions, as illustrated in a recent case of a palm civet having to be euthanised after getting burnt on a hot stove in a coffee shop during an apparently botched attempt by the contractor to capture it.

My flora sightings at Bayshore forest include fish-tail palms, bird’s nest ferns and angsana trees. (Photos by Jimmy Tan)

Last but not least, while certain native flora species, such as fish-tail palms and bird’s nest ferns, may be common species, they are essential for supporting native fauna, including endangered species, thus ensuring functional biodiversity and optimal ecological health in Bayshore forest. As also noted in Tengah North Environmental Impact Studies (EIS) report (page 185), “it is important to recognize that both common and rare species contribute ecological functions in an ecosystem.”

Fruits of a fish-tail palm provide food for a wide variety of common and uncommon wildlife species. (Photo by Jimmy Tan)

For example, the fruits of fish-tail palms, which are found growing in Bayshore forest, provide food for squirrels, palm civets and a variety of birds, including the critically endangered Oriental pied hornbills (who may use Bayshore forest as a stepping stone in the East Coast vicinity even if they are not recorded in the EIA report), who are also seed dispersers.

Bayshore forest is one of the few remaining relatively biodiverse forests in the eastern part of Singapore that are dense and sizeable enough to cool the urban heat island effect considerably in the surrounding area. According to NParks, “denser tree canopies reflect radiant heat and cool our surface and ambient temperatures through shade and evapo-transpiration, and help to mitigate the Urban Heat Island (UHI) effect and climate change.” (Maps by and NParks)

In summary, given the urgency of climate emergency, threat of biodiversity loss and public health risks, may we implement or adapt the following measures?

1. Conserve at least 20-40 percent of Bayshore forest so that the densely growing trees can cool the rising urban heat island effect, mitigate floods and rising sea level along the East Coast, support forest-dependent birds and other wildlife, promote ecological health and prevent dengue outbreaks, as well as protect residents’ physical health and mental well-being.

The forest and marsh in Bayshore can function as a nature-based solution to help mitigate floods to some extent by absorbing excess water. (Map from the Straits Times, 19 August 2019)

2. Build in advance drain culverts across ECP to connect Bayshore forest and East Coast park woodland to ensure safe movements of palm civets and other animals.

3. Restore some degraded parts of the forest and create dragonfly ponds to support natural predators of mosquitoes and other pest insects, so as to prevent dengue and other disease outbreaks effectively, without resorting to harmful chemical pesticides (which inadvertently make mosquitoes more resistant).

4. Build taller buildings and redevelop brownfield sites elsewhere if need be, in order to optimise land use and ensure sustainable development, besides adopting a more sustainable economic model such as degrowth or Doughnut.

5. Implement measures to discourage short-term property investment/speculation that artificially boosts housing demand and makes it more difficult for genuine long-term home buyers (such as young couples getting married and starting a family) to buy a new Build To Order (BTO) flat, such as extending the Minimum Occupation Period (MOP) from 5 years to 10 years or longer.

Over-emphasising subsidised public housing as asset investment has its drawbacks, such as inflating housing demands (mostly by property investors eager to make quick profits who sell their flats upon fulfilling the 5-year MOP), which result in oversubscribed new BTO flats in popular housing estates, and habitat loss and fragmentation for the flora and fauna wherever the forests are cleared for housing development, thus reducing our climate resilience and compromising our well-being and long-term survival. (Article by the Sunday Times, 20 November 2022)

Thank you for reading.

(Last updated on 12 December 2022)


My Cross Island Line Phase 2 (CRL2) Environmental Impact Study (EIS) Feedback to Land Transport Authority (LTA)

Dear Sir/Madam,

It is heartening to know that “extensive engagements were made with stakeholders (including Nature Groups) to discuss measures to reduce environmental impacts during the EIS process, including the design optimisation of worksites as a method of Impact Avoidance / Elimination”, as mentioned on page 2 of the “Non-technical summary for the EIS of CRL2”.

I learnt that these measures include relocating the upcoming Maju station to protect the flora and fauna in Maju forest, and realigning the tunnels between King Albert Park station and Maju station to reduce the ecological impact on wildlife.

Even so, I am concerned to learn that “the nearly 2,000-page study found that the CRL could still have a major environmental impact on several forested areas near Eng Neo Avenue Forest, Clementi Forest and Windsor due to irreversible habitat loss.”

Several questions came to mind, which I hope LTA and other relevant agencies could address, and which I hope are not too late or inconvenient to ask, considering the fact that we are facing climate emergency, biodiversity loss and public health challenges in the Anthropocene:

Firstly, when the Cross Island Line was first announced in 2013, were the plans based on any public survey to ascertain if there was sufficient demand from residents in the affected areas for MRT connectivity, in view of the controversy over the alignment of the line’s Bukit Timah stretch crossing the Central Catchment Nature Reserve (CCNR) and MacRitchie Reservoir?

Part of the controversy centres on whether the protection conferred on nature reserves under the Parks and Tree Act extends for the entire infinite depth of the State-owned land below the surface of the reserve.

If there was no public survey or consultation done prior to the environmental groups voicing their concerns about the encroachment of the planned MRT line in the central nature reserve, other than the initial reason given that “the line was planned to relieve congestion on the existing East West Line”, I wonder what would be the economic imperative(s) that drove the CRL plans?

For example, would the planned CRL construction be driven by the “growth-at-all costs” capitalistic economic model that Singapore has been subscribing to, which would lead to a constant need to clear existing carbon-sequestering regenerating secondary forests for more housing, transport network, and other aspects of high consumption lifestyles (such as house flipping with no intention for long-term stay or little regard for habitat loss resulting from building new flats, condos, roads, MRT stations, etc), even if there is a low population growth rate?

If so, what if we were to adapt and adopt viable alternative economic models that respect planetary boundaries and de-prioritise limitless economic growth, like that of New Zealand and doughnut economics, as recommended by Singapore youths’ Green Policy Paper 2022?

Would we still need to proceed with the development of the CRL2 line as planned, and could we also revise or postpone the development of the CRL3 and the remaining phase of Jurong Region Line (JRL), if any, indefinitely until there is a definite demand from stakeholders, including residents in the affected areas, since CRL3 and JRL lines may adversely impact more forests and wildlife, such as in the highly biodiverse Western water catchment area, in the future?

Similarly, could I request that LTA work with other agencies such as Urban Redevelopment Authority (URA) and Housing & Development Board (HDB) to restrict any future housing developments around the new MRT stations, such as Turf City and Maju stations, to only previously developed lands because we do not want to end up with another undesirable scenario where more forests have to be sacrificed (resulting in ever-increasing habitat fragmentation and dwindling biodiversity, as well as rising urban heat island effect) like in the case of Dover forest, which is located next to Dover MRT station, whereby Dover Forest East is planned to be mostly cleared for public housing?

Global Forest Watch Singapore deforestation stats

Annual tree cover loss through deforestation in Singapore from 2001 to 2021 (Source: Global Forest Watch)

Secondly, while it is good that Singapore has revised our climate targets on achieving net-zero greenhouse gas emissions by 2050, it is worrying that Singapore has been experiencing an increase in tree loss through deforestation in the past decade. In 2021 alone, Singapore has lost 201 ha of tree cover, equivalent to 97,200,000 tonnes of carbon dioxide emissions.

Could LTA account for the carbon emissions that will be caused by the resultant forest habitat loss from the construction of CRL2 line, such as getting the polluting companies to bear the environmental costs proportionately, whether in the form of carbon tax or equivalent for channelling the funds to help the less privileged or protect nature areas, as a necessary part of upholding climate justice?

Thirdly, page 5 of the “Non-technical summary for the EIS of CRL2 – Windsor and Eng Neo Avenue Forest” notes that species of conservation significance, such as globally and nationally critically endangered Sunda pangolin and nationally threatened near threatened Sunda colugo, inhabit the forests in the study areas.

Although there are no stations located within the section of the alignment under this EIS, I noticed that the worksites are intended for the Tunnel Boring Machine launching activities near Eng Neo Avenue Forest and for the CRL facility building at Windsor nature park.

Incidentally, in 2015, I came across a dead pangolin along Dunearn Road near Kampong Chantek (about 200-300 m from Turf City), which is likely a roadkill. Earlier this year, a pangolin was spotted at an MRT station in Bukit Timah area. These sightings suggest that pangolins are vulnerable to becoming roadkills when they happen to venture onto roads in the vicinity.

Thus, I wonder how the pangolins would be affected by the upcoming construction of Cross Island Line (CRL2) MRT station in Turf City and underground tunnels in the vicinity.

Being nocturnal animals that burrow underground, the pangolins can be hard to track and monitor for their safety, and workers who are not trained in recognising such endangered wildlife might not realise how the digging activities in the ground may result in accidental injury or even death if a pangolin (or pangolin mother and child) happens to be moving within the construction sites.

Since Eng Neo Avenue forest used to be part of the Central nature reserve before becoming severed from the main nature reserve by the construction of Pan Island Expressway (PIE) years ago, and since the pangolin population in Singapore was estimated to be only around 100 in 2021, any further encroachment on their natural habitats, including Eng Neo Avenue forest, Windsor nature park, Tengah forest, etc, must be given serious attention to ensure that the pangolins do not eventually become extinct, just like the other native wildlife that Singapore used to have, including the cream-coloured giant squirrel and forest gecko (which might have become extinct as a result of the construction of Bukit Timah Expressway that separated Bukit Timah nature reserve from Central catchment nature reserve since the 1990s).

As noted in Private Lives: An Expose of Singapore’s Rainforests, isolated populations of plants and animals could experience an erosion of their genetic diversity and experience inbreeding depression, which could lead to decreased survivorship.

Therefore, may I recommend that LTA and other relevant agencies compensate for the loss and/or disturbance of forest habitats, by building eco-link(s) across PIE to connect Eng Neo Avenue forest and Central catchment nature reserve, whether in the form of a wildlife bridge or culvert or both, so as to facilitate safe movements of pangolins, colugos, etc should they need to escape and seek refuge from future human disturbances and ground vibrations caused by the planned construction in the vicinity?

Eco-links can help facilitate safe movements of our fauna species, such as pangolins, colugos, deer and snakes, and ensure healthy genetic exchange and improved survivorship. In particular, colugos have been found impaled on a wire fence outside Swiss Club (about 200 m from Turf City) in recent years, which may testify to their perilous journeys between CCNR and Eng Neo Avenue forest. (Illustration by Jimmy Tan; not drawn to scale)

If cost is an issue, could we get corporate sponsorship from companies that wish to be part of environmental sustainability for building the eco-links?

Thank you for your attention, and I look forward to receiving responses from LTA to the feedback and plans when ready.

Yours sincerely,

Jimmy Tan San Tek

(Last updated on 17 November 2022)

Environmental Impact Study for Proposed Housing Development at Bukit Batok Hillside Park Area: EIS Report for Bukit Batok Hillside Park Area

The following is an excerpt about the terrestrial fauna survey from the EIS report for Bukit Batok Hillside Park area (HDB BB EIS Report Final_rev13), dated 1 June 2020, prepared for Housing and Development Board (HDB) of Singapore.

“Many of the species recorded during these surveys are considered to be widespread and common in secondary vegetation and parkland across Singapore. However, the presence of some forest-dependent species, such as the Malay Tailed Judy (Abisara savitri savitri), Copper-cheeked Frog (Chalcorana labialis), Common Treeshrew (Tupaia glis), and Slender Squirrel (Sundasciurus tenuis) shows that the survey area may serve as a refugium for some of these species.

Due to the ongoing construction work taking place at the edges of the survey area, patches of grassland and small pools have been created. All of the damselfly and dragonfly species are typical of open areas, as are quite a number of butterflies. Among the amphibians, the Field Frog (Fejervarya limnocharis) was only found at the periphery of the construction sites, and was absent at the pond at the forest edge.

The number of Wild Boar (Sus scrofa) present in Bukit Batok Hillside Park area is unknown. The two camera traps that documented the presence of Wild Boar were placed at different areas of the site; one was located along the stream, while the other was near the top of the ridge, in close proximity to an old wallow. Each camera captured a single individual, a lone adult male. Based on the general scarcity of signs of Wild Boar activity during the surveys, and the territorial behaviour of the adult male Wild Boar, it is likely that there is only one resident individual in this forest patch, although the possibility of more individuals wandering from other nearby forest patches cannot be ruled out.

Other species that have been recorded from similar secondary forest habitats such as Bukit Batok Nature Park, may be present within the survey area but were not documented during the surveys. These include the more uncommon animals such as the Sunda Colugo (Galeopterus variegatus), Sunda Pangolin (Manis javanica), Horsfield’s Flying Squirrel (Iomys horsfieldii), and Lowland Freshwater Crab (Parathelphusa maculata). These species are rarely observed outside of Singapore’s central nature reserves and Bukit Batok Nature Park, but are often difficult to detect, with some being nocturnal or arboreal. Therefore, while they were not observed during the surveys, we cannot discount the possibility that some of these species may still be present at Bukit Batok Hillside Park. The non-native East Asian Ornate Chorus Frog (Microhyla fissipes) was not previously recorded in Bukit Batok; this may represent a new locality record for this species in Singapore.

It is also important to note that these surveys took place outside of the migratory season for birds; surveys conducted when various passage migrants and winter visitors may be found in Singapore would likely yield very different results.

Although the survey area is a small, isolated patch of secondary forest with relatively few species of conservation importance, its potential role in maintaining connectivity for birds and other animal species cannot be discounted. With the ongoing development of the Tengah area as a new housing estate, it is likely that some animals may move to the Bukit Batok Hillside Park area, and then disperse to other forest patches in Bukit Batok, possibly reaching Bukit Timah Nature Reserve via Bukit Batok Nature Park.”