Evaluation of the

Preliminary Environmental Impact Assessment (PEIA) for the

Proposed Kinrara-Damansara Expressway (KIDEX)

Prepared by:

Mark Chernaik, Ph.D.

Environmental Law Alliance Worldwide U.S.

December 2014

At the request of Sahabat Alam Malaysia/Friends of the Earth Malaysia, I evaluated the PEIA for
the proposed Kinrara-Damansara Expressway (KIDEX). My evaluation of the PEIA for the
proposed Kinrara-Damansara Expressway (KIDEX) focusses on two serious deficiencies: 1) the
air quality impact analysis in the PEIA for the KIDEX is woefully incomplete; and2) no analysis
is presented as justification for the KIDEX as opposed to other transportation alternatives.
What follows is elaboration on these two defects of the EIA.
The air quality impact analysis in the PEIA for the KIDEX is woefully incomplete
Highways adversely impact air quality primarily because of tailpipe emissions of ultrafine
particulate matter (that is, particulate matter with an aerodynamic radius of 1 micron or less),
also known as elemental carbon (EC) or diesel emissions.
It is well established that proximity to a major highway can cause adverse health effects to
children because of exposure to elevated levels of air pollutants. In 2007, scientists with the
University of Southern California published a study about the health of 3677 children from 12
southern California communities. These researchers found that children who lived within 500
m of a freeway (motorway) had substantial deficits in 8-year growth of forced expiratory volume
and maximum midexpiratory flow compared with children who lived at least 1500 m from
a freeway. These researchers concluded:
The concentrations of several pollutants are raised near major freeways. Daytime
concentrations of black carbon, ultrafine particulate, and other exhaust pollutants have
been reported to be high, but decline exponentially, within 500 m of a freeway, although
night-time concentrations of ultrafine particulate remain above background
concentrations for distances greater than 500 m from a freeway. Some studies have
reported increased traffic pollution, particularly nitrogen dioxide, at distances over 1000
m from a freeway. Elemental carbon, an indicator of pollution from diesel exhaust, varies
with nearby high traffic roads but can also be transported across large distances. Diesel
exhaust is one of the primary contributors to particulate-matter concentrations in those
communities most affected by traffic. A pollutant such as elemental carbon could explain
our reported health effects both locally and regionally.
We have shown that residential distance from a freeway is associated with significant
deficits in 8-year respiratory growth, which result in important deficits in lung function at
age 18 years. This study adds to evidence that the present regulatory emphasis on
regional air quality might need to be modified to include consideration of local variation
in air pollution. ... In view of the magnitude of the reported effects and the importance of
lung function as a determinant of adult morbidity and mortality, reduction of exposure to
traffic-related air pollutants could lead to substantial public-health benefits.1

Guaderman, W.J.. et al (February 2007) Effect of exposure to traffic on lung development from 10 to
18 years of age: a cohort study, The Lancet, 369:571-577

According to recent study published earlier this, other pollutants generated by highway vehicles
impose a substantial cost in term of childhood asthma.2
Background Emerging evidence suggests that near-roadway air pollution (NRP)
exposure causes childhood asthma. The associated costs are not well documented.
Objective We estimated the cost of childhood asthma attributable to residential NRP
exposure and regional ozone (O3) and nitrogen dioxide (NO2) levels in Los Angeles
County. We developed a novel approach to apportion the costs between these exposures
under different pollution scenarios.
Methods We integrated results from a study of willingness to pay to reduce the burden
of asthma with results from studies of health care use and charges to estimate the costs of
an asthma case and exacerbation. We applied those costs to the number of asthma cases
and exacerbations caused by regional pollution in 2007 and to hypothetical scenarios of a
20% reduction in regional pollution in combination with a 20% reduction or increase in
the proportion of the total population living within 75 m of a major roadway.
Results Cost of air pollutionrelated asthma in Los Angeles County in 2007 was $441
million for O3 and $202 million for NO2 in 2010 dollars. Cost of routine care (care in
absence of exacerbation) accounted for 18% of the combined NRP and O3 cost and 39%
of the combined NRP and NO2 cost; these costs were not recognized in previous
analyses. NRP-attributable asthma accounted for 43% (O3) to 51% (NO2) of the total
annual cost of exacerbations and routine care associated with pollution. Hypothetical
scenarios showed that costs from increased NRP exposure might offset savings from
reduced regional pollution.
Conclusions Our model disaggregates the costs of regional pollution and NRP exposure
and illustrates how they might vary under alternative exposure scenarios. The cost of air
pollution is a substantial burden on families and an economic loss for society.
Inappropriately, the air quality impact analysis in the PEIA for the KIDEX focusses on a single
pollutant carbon monoxide and not on the other pollutants, ultrafine particulate matter, O2
and NO2, that impact the health of children. Page 6-36 of the PEI concludes:
In reference to the worst case scenario, where we assume all vehicles using the highway
will be heavy vehicle (trucks and lorries), the highest predicted 1-hour average
concentration at a closest sensitive receptor is 7.6 ppm (Class 7) at Kompleks Suria
Kinrara. From the modeling results, the worst case CO levels were still well below the
Malaysian Air Quality Guidelines for CO concentrations at 30 ppm (1-hour averaging
time). The CO concentrations for Scenario 1 (light vehicles) and Scenario 2 (medium
2

Brandt, S., Perez, L., Knzli, N., Lurmann, F., Wilson, J., Pastor, M., & McConnell, R. (2014). Cost of nearroadway and regional air pollutionattributable childhood asthma in Los Angeles County. Journal of Allergy and
Clinical Immunology, 134(5), 1028-1035. http://www.jacionline.org/article/S0091-6749%2814%29013645/abstract

heavy vehicles) give lower readings as expected in line with the lower CO emission rates.
Hence, it can be expected that there will be a slight increase in the CO concentrations at
the receptors during the peak hours due to increase in traffic volume, which is the
acceptable. The increase is not significant and the levels will still remain well below the
Malaysia Air Quality Guidelines.
Whether, worst case CO levels were still well below the Malaysian Air Quality Guidelines for
CO is NOT the most important question that an assessment of the air quality impacts of the
proposed KIDEX needs to answer. It is more important to answer whether the KIDEX would
cause ultrafine particulate matter levels and levels of other pollutants, such as O3 and NO2, to
impact the health of children.
In this respect, the PEIA for the KIDEX should have followed the most recent guidance of the
U.S. Federal Highway Administration for assessing air quality impacts of proposed highway
projects in NEPA (EIA) documents.3
This guidance states:
PURPOSE: The purpose of this memorandum is to update the September 2009 interim
guidance that advised Federal Highway (FHWA) Division offices on when and how to
analyze Mobile Source Air Toxics (MSAT) under the National Environmental Policy Act
(NEPA) review process for highway projects. ....
3) Projects with Higher Potential MSAT Effects
This category includes projects that have the potential for meaningful differences in
MSAT emissions among project alternatives. We expect a limited number of projects to
meet this two-pronged test. To fall into this category, a project should:
Create or significantly alter a major intermodal freight facility that has the
potential to concentrate high levels of diesel particulate matter in a single
location, involving a significant number of diesel vehicles for new projects or
accommodating with a significant increase in the number of diesel vehicles for
expansion projects; or
Create new capacity or add significant capacity to urban highways such as
interstates, urban arterials, or urban collector-distributor routes with traffic
volumes where the AADT is projected to be in the range of 140,000 to 150,000 or
greater by the design year;
And also Proposed to be located in proximity to populated areas.
Projects falling within this category should be more rigorously assessed for impacts.
If a project falls within this category, you should contact the Office of Natural
3

U.S. FHA (December 2012) "Interim Guidance Update on Mobile Source Air Toxic Analysis in NEPA
Documents" https://www.fhwa.dot.gov/environment/air_quality/air_toxics/policy_and_guidance/aqintguidmem.cfm

Environment (HEPN) and the Office of Project Development and Environmental Review
(HEPE) in FHWA Headquarters for assistance in developing a specific approach for
assessing impacts. This approach would include a quantitative analysis to forecast localspecific emission trends of the priority MSAT for each alternative, to use as a basis of
comparison. This analysis also may address the potential for cumulative impacts, where
appropriate, based on local conditions. How and when cumulative impacts should be
considered would be addressed as part of the assistance outlined above.
As shown in Table 6.17 from the PEIA, the KIDEX would create new capacity or add
significant capacity to urban highways with traffic volumes where the AADT is projected to
be in the range of 140,000 to 150,000 or greater by the design year. In fact, daily vehicle counts
on the KIDEX would exceed 220,000 by the year 2020:

As shown in Table 6.17 on pages 5-14 to 5-15 of the PEIA, the KIDEX would be in
extraordinary close proximity (in most instances, only 20-50 meters) to dozens of locations
where children live and go to school and within 20 meters of a hospital.
Therefore, the impacts to air quality of the proposed KIDEX should have been rigorously
assessed. Specifically, impacts to air quality of the proposed KIDEX should have been assessed
according to the following internationally-accepted best practice.4
1.1 PURPOSE OF THIS GUIDANCE
This guidance describes how to complete quantitative hot-spot analyses for certain
highway and transit projects in PM2.5 and PM10 (PM) nonattainment and maintenance
areas. This guidance describes transportation conformity requirements for hot-spot
analyses, and provides technical guidance on estimating project emissions with the
Environmental Protection Agencys (EPAs) MOVES model, Californias EMFAC
model, and other methods. It also outlines how to apply air quality models for PM hotspot analyses and includes additional references and examples. However, the guidance
4

U.S. EPA (November 2013) "Transportation Conformity Guidance for Quantitative Hot-Spot Analyses in PM2.5
and PM10 Nonattainment and Maintenance Areas."
http://www.epa.gov/otaq/stateresources/transconf/policy/420b13053-sec.pdf

does not change the specific transportation conformity rule requirements for quantitative
PM hot-spot analyses, such as what projects require these analyses. EPA has coordinated
with the Department of Transportation (DOT) during the development of this guidance.
Finally, it should not have been reported in the PEIA for the KIDEX that Based on the air
quality results, it can be concluded that the ambient air quality at the areas along the alignment
was good with the four (4) parameters of TSP, NO2, CO and SO2 showing levels
below the Recommended Malaysian Environmental Air Quality Guidelines. The table below
copied from page 5-30 of the EIA, shows values of the Malaysian guidelines for only short-term
(24-hour exposures).

However, there are additional Malaysian Environmental Air Quality Guidelines for long-term
average (12 month) exposures, including a standard for PM10 of 50 g/m3. By way of
comparison, the World Health Organization guideline for PM10 is 50 g/m3 on a daily basis and
20 g/m3 on an annual average basis.5 Measurements reported in the PEIA for the KIDEX were
collected over a period of less than two months (September & October 2011). However, if these
measurements accurately reflect particulate matter levels that generally prevail at these locations,
the PEIA for the KIDEX should have reported that air quality at these locations is already
impaired.
No analysis is presented as justification for the KIDEX as opposed to other transportation
alternatives
According to the Public Works Department Malaysia:
In the discussion of options, alternative transportation management systems should be
described. This discussion would include upgrading existing transportation systems.
5

http://www.who.int/mediacentre/factsheets/fs313/en/

Before major new highway/road projects are proposed it must be demonstrated that
upgrading existing transportation systems will not solve the transportation problems
identified in the chapter setting out the need for the project.6 (Emphasis added).
This is consistent with internationally-accepted best practice that requires consideration of all
types of traffic congestion alleviation and transportation alternatives alongside with
consideration of a new road project.
Contrary to these guidelines, the PEIA for the KIDEX does not include a description of
alternative transportation management systems. Instead, as shown below, the PEIA for the
KIDEX merely states that there is traffic congestion in the area, and that a new road is the one
and only way to alleviate such traffic congestion:
1.4.1 Need of the Project
The thriving development of new townships within and around the Klang Valley has
made efficient and good road network a necessity. This good economic growth has seen
traffic within the Klang Valley and its surrounding areas increase significantly within
recent years, resulting in traffic congestion in many areas. The implementation of the
Kinrara Damansara Expressway (KIDEX) would be seen as timely since it would bring
a host of benefits with it. The proposed KIDEX would introduce an alternative route
between the areas of Puchong near Kinrara, west of Sunway through to Petaling Jaya
old and new town centres and Damansara. The proposed KIDEX will also provide a
vital link between the abutting residential areas, south of the KESAS Expressway
allowing direct access into Petaling Jaya, Damansara and NKVE.
The main aim for the construction of the proposed Kinrara - Damansara Expressway
(KIDEX) is to provide a short and direct access to both Puchong / Kinrara and Petaling
Jaya / Damansara ultimate catchments, giving guaranteed journey-time with dispersal
points planned strategically along its corridor for effective dispersal of traffic.
Carrying forward the untested idea that a new road is the only solution to traffic congestion,
Chapter 4 of the PEIA for the KIDEX considers only three kinds of alternatives: the no-action
alternative, alternative alignments of the KIDEX, and alternative ways to construct the KIDEX.
Considering the high capital cost of constructing a 14.9 kilometer elevated expressway and the
probably impacts of the highway on air quality, there is a necessity to consider other alternative
transportation management systems, such as upgrades to existing roads, traffic management
options, and improved public transportation infrastructure.

Public Works Department Malaysia (1995) Guidelines for the Environmental Impact Assessment of Highway or
Road Projects" at page 28.